Case Alert - [2018] EWCA Civ 366

Court of Appeal defines "integrity" in a professional conduct context

All professions usually have codes of conduct which require the professional to act with "integrity" (for example, all FCA and PRA-authorised firms are required to conduct their business with integrity). This case concerned alleged breaches of the Solicitors Regulation Authority's Code of Conduct and a central issue was the meaning of "integrity".

Following a review of caselaw, the Court of Appeal held that integrity is a broader concept than dishonesty. In professional codes of conduct, it is a useful shorthand to express the higher standards which society expects from professional persons and which the professions expect from their own members. Although it is not possible to formulate an all-purpose definition, the Court of Appeal said that "Obviously, neither courts nor professional tribunals must set unrealistically high standards, as was observed during argument. The duty of integrity does not require professional people to be paragons of virtue. In every instance, professional integrity is linked to the manner in which that particular profession professes to serve the public".