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.10If the member concludes that the threat is not at an acceptable level, the member should apply safeguardsto eliminate the threat or reduce it to an acceptable level. Examples of safeguards include the following:a. Implementing mechanisms to prevent unauthorized disclosure of confidential information whenperforming professional services related to a particular matter for two or more clients whoseinterests with respect to that matter are in conflict. This could includei. using separate engagement teams who are provided with clear policies and procedures onmaintaining confidentiality;ii. creating separate areas of practice for specialty functions within the firm, which may act asa barrier to the passing of confidential client information from one practice area to anotherwithin a firmiii. establishing policies and procedures to limit access to client files, the use of confidentialityagreements signed by employees and partners of the firm and the physical and electronicseparation of confidential information.b. Regularly reviewing the application of safeguards by a senior individual not involved with the clientengagement or engagements.c. Having a member of the firm who is not involved in providing the service or otherwise affected bythe conflict, review the work performed to assess whether the key judgments and conclusions areappropriate.d. Consulting with third parties, such as a professional body, legal counsel, or another professionalaccountant.;.11In cases where an identified threat may be so significant that no safeguards will eliminate the threat reduce it to an acceptable level, or the member is unable to implement effective safeguards, the membershould (orPart 1 — Members in Public Practice
of interest; or (b) terminate the relevant relationships or dispose of the relevant interests to eliminate thethreat or reduce it to an acceptable level.Disclosure of a Conflict of Interest and Consent.12When a conflict of interest exists, the member should disclose the nature of the conflict of interest toclients and other appropriate parties affected by the conflict and obtain their consent to perform theprofessional services. The member should disclose the conflict of interest and obtain consent even if themember concludes that threats are at an acceptable level..13Disclosure and consent may take different forms. The following are examples:a. General disclosure to clients of circumstances in which the member, in keeping with commoncommercial practice, does not provide services exclusively for any one client (for example, in aparticular service in a particular market sector) in order for the client to provide general consentaccordingly. Such disclosure might be made in a member’s standard terms and conditions for theengagement.