In response to the Architects Registration Board’s (ARB) recent consultation on the proposed changes to the Code of Conduct for registered architects in the UK, ACANs Professional Standards Group offered the following response.

ACAN believes that the natural environment should be a key stakeholder in decisions registered architects make in designing the built environment, to facilitate decarbonisation. We welcome the clarity of the layout, and the language used to update the Code in line with other industries. However, we have specific feedback on several parts as follows:

Accountability

We believe architects should be held to account for designs that are damaging to the climate, actively linear and not circular, or that result in work for clients or suppliers who actively seek to promote the use of fossil fuels or climate damaging materials and processes.

Any update to the Code should be made with consideration of events that have knocked public trust and respect of the construction industry.  It is imperative to ensure continued collaboration with built environment professionals, community groups, institutions and activists, so that effective decarbonisation and an equitable future can be achieved.

Climate and Biodiversity Emergency

The Code should make an acknowledgement of the Climate and Biodiversity Emergency we face.  This should be explicit within the code, to focus architects’ attention on their efforts in dealing with the primary challenge of our generation. To date, 1,364 Architectural Practices have declared a Climate and Biodiversity Emergency (Architects Declare), and over 300 Local Planning Authorities have done the same (Local Government Association). ARB should reflect this stance in the code.

Climate and other regulatory bodies

We believe the ARB should take the approach of other architectural and built environment regulating bodies, both nationally and internationally, and include specific reference to climate-responsive design.

• The AIA Code of Ethics Canon VI is to the Environment, and specifically references energy conservation; water use; building materials; ecosystems; and climate change (AIA, 2024)
• The Landscape Institute’s Code of Practice includes the requirement: “You must deliver … services in ways which promote sustainable development and the environmentally responsible use of resources.” (Landscape Institute, 2021)
• The Engineering Council’s Statement of Ethical Principles includes the requirement to “protect, and where possible improve, the quality of built and natural environments” and “take due account of the limited availability of natural resources “. (Engineering Council, 2014)
• RICS Rules for Conduct “encourage solutions that are sustainable in that they minimise harm and deliver balanced economic, social and environmental benefits.” (RICS, 2021)
• The Institute of Structural Engineers Code of Conduct states in Article 2: ”Members carry out their professional duties cognisant of the short term and long-term impacts of their actions, taking measures to protect those affected by their advice and the laws that are relevant to their work. The Institution of Structural Engineers supports a policy of sustainability and renewable resources.”
• The BIID Code of Conduct states members should consider the Whole Life Impacts of projects, as well as consider and reduce impacts from business activities (BIID; 2021)

ACAN believes that unless ARB includes a similar statement in their Code, architects will be unable to fulfil their public function and ARB’s own objective (as stated on their website), namely: “We want a world in which the built environment inspires those who live and work in it, reflects the needs of society so that people are safe and can live well, and helps to tackle the fundamental challenges our planet faces.”

ACAN is very concerned about the removal of the previous requirement for architects to consider the “wider impact” of their work and recommends that it is reinserted.

As well as this, the Guidance Notes for Sustainability should be drafted and published for public review, and to be in line with the overwhelming scientific evidence, and to give Registered Architects the framework to deliver climate resilient design.

Hierarchy of priorities

ACAN welcomes the provision of a hierarchy of priorities and the proposed focus on public interest under Standard 2. However, the Standard to demonstrate “respect for life, environment, law and the public good” in order to prioritise “public interest” is unclear and unhelpful. This is due to the fact that the terms used are too broad, overlapping and poorly defined. In particular:

• It is unclear what the difference is between public interest and public good
• The term ‘environment’ is too broad to be meaningful in a regulatory framework
• issues of the law are covered in other parts of the code and do not need repeating here

Similarly, Standard 2.2 is unclear. Protecting the health and safety of those who “use buildings and places” is too broad a term if interpreted to refer to any building or place user (which would include the entire human population) or too narrow if interpreted to refer to only the users of the building and place that the architect is designing. If the latter is the case, the Code must clearly require that architects protect the health and safety of any users impacted by their work, in line with the suggested requirement to consider “wider impact” (see above).

ARB and other professional bodies

We believe that the ARB should coordinate the hierarchy of priorities with RIBA, bearing in mind that 66% of architects in the UK are also RIBA chartered architects and are subject to both Codes. As a minimum the two Codes should not set out contradictory priorities.

The RIBA Code enshrines the following duties owed by Members:

• To the wider world
• Towards society and the end user
• Towards those commissioning services (i.e. clients – this may include professional clients, investors and funders)
• Towards those in the workplace  (i.e. colleagues, employees, employers)
• Towards the profession
• Towards oneself

The RIBA also stated in its Sustainability and Ethics Commission that:  ‘RIBA Council reasserted the Institute’s unequivocal commitment to placing public interest, social purpose, ethics and sustainable development at the heart of its activities.’

The Landscape Institute Code of Practice provides a strong example of a professional code of conduct. The LI requires consideration of the impact “on the environment, people, place, and nature in all aspects of landscape activities and in landscape projects before work takes place.”

In light of the NCARB and ARB Mutual Recognition Agreement, priorities should also be easily transferable with AIA’s Code of Conduct. Currently AIA’s Code does not state an explicit hierarchy of priorities, but it does set out clear obligations to the public, client, profession, colleagues and environment.

ACAN recommends that the ARB Code is more clearly aligned with the codes of other adjacent professional bodies, including repetition of phrases as appropriate.

Code and guidance equivalence

ACAN welcomes the intention of improved clarity and accessibility of the proposed Code. It is understood that the much simplified, Standards-based Code will be supplemented by detailed guidance documents.

ACAN requests a clearer definition of the status of each section within the code. For example Standard 1 – “Architects must be honest and act with integrity” is very clear. 

Within the same standard however this statement is more subjective, and generalised. “Public confidence in the profession will be maintained only when architects act with integrity, by applying a high set of ethical standards across their actions and decisions.”

Clauses contained within the code – currently we are confused as to which sentences are binding, which are examples, and which are somewhere in between.

ACAN commends ARB on the published guidelines on Environmental Sustainability, which are clear on issues of climate and carbon, and recommend that more of this wording is used in the main document.

However, the legal status of the guidance documents is not clear and must be made explicit.

Existing Buildings /Demolition

We believe that our existing assets should be protected and enhanced, and that demolition should be the very last resort. Therefore we should “protect, conserve and enhance our built environment”.  The previous Code of Conduct was explicit in conserving: “5.1 Where appropriate, you should advise your client how best to conserve and enhance the quality of the environment and its natural resources.” We recommend that this standard should be enhanced rather than remove requirements for protection of our existing built environment. Growing evidence demonstrates that we cannot “Build As Usual”, and consideration for the whole life carbon impacts, especially emissions arising from the creation of new buildings, should be mandatory.

We welcome an open and constructive debate with the ARB and other industry bodies to develop this Code further.