Anti-corruption policy

The value of certification is based on the degree of confidence and trust that is established by an impartial, consistent and competent demonstration of fulfilment of specified requirements by a certification body. Being impartial, and being perceived to be impartial, is therefore essential for Control Union Certifications B.V. to inspire this confidence and trust in our stakeholders and key to our success. To obtain and maintain confidence, it is essential that Control Union Certification's decisions be based on objective evidence of conformity (or nonconformity), and that our decisions are not influenced by other interests or by other parties.

Based on this principle and our Code of Conduct, we strive to ensure that the highest standards of integrity, objectivity and professional behaviour are applied to all our assessment activities. Control Union Certifications B.V. applies risk assessments regarding impartiality and potential conflicts of interest on our offices, employees and clients. We do not tolerate bribery or fraud.

We understand bribery to be an act of promising, offering, giving, receiving, or soliciting money, goods or other forms of recompense other than what is otherwise available to everyone on an equivalent basis not for dishonest purposes, with the aim to alter the judgment or conduct of the recipient, normally to the benefit or interest of the giver, that the recipient would otherwise not alter.

While bribery is the use of positive inducements for improper aims, extortion and blackmail also aim to alter the judgment or conduct of the recipient through the use of threats. This can be the threat of physical violence or exposure of an individual's secrets.

Abuse of discretion is the misuse of one's powers and decision-making facilities. This may include influence peddling, which is the practice of using one's influence or connections with persons in authority, for instance to alter somebody’s position or behaviour.

Examples may include:

• Soliciting, offering and/or accepting money, gifts, loans, fees, hospitality, discounts, services, promotions, sexual favours, benefits, company shares, privileges, entertainment, employment in return for a favourable assessment result of the own object of assessment;
• Soliciting, offering and or accepting money, gifts, loans, fees, hospitality, discounts, services, promotions, sexual favours, benefits, company shares, privileges, entertainment, employment in return for a less favourable assessment result of someone else’s object of assessment;
• Threatening to go to the media or another influential party if a defined element is not altered or provided to the benefit of the threatening party or a relation thereof;
• Threatening with loss of contract if a defined element is not altered or provided to the benefit of the threatening party or a relation thereof;
• Improperly dismissing a finding or nonconformity;
• Using CAB discretion to incorrectly allow a banned substance or practice.

Fraud is understood to be an act of giving a deliberate misleading presentation of the truth, or the concealment of a significant fact, in order to gain a benefit at the disadvantage of another party by use of a tort or unlawful act. Examples may include:

• Manipulation, falsification or alteration of audit records or documents;
• Deliberate omitting of audit evidence;
• Designation of conformities or closure of nonconformities through falsification;
• Paying or receiving bribes or other inappropriate payments / gifts / favours (see above);
• To misappropriate, for personal gain, an asset of the Company that has been received in deposit, commission, administration or other similar title that produces an obligation to deliver, return, or make a specific use.

CUC insists on honesty, integrity and fairness in all aspects of its activities and expects the same in their relationships with all those with whom they do business. The direct or indirect offer, payment, soliciting and acceptance of bribes in any form are unacceptable practices to which CUC applies a zero-tolerance policy. Employees are required to report any solicitation for, or offer of, an improper payment or advantage coming to their knowledge. Acceptance of or offering bribes will be justification for dismissal, subject to and following a proper and fair investigation into the matter.

There are no political contributions and facilitation payments. Charitable contributions and sponsorships need to be approved by the CUC Director.

CUC does apply zero tolerance towards bribery and fraud. Subject to a diligent and impartial inquiry and a decision by the managing director, the perpetrator will be sanctioned.

Where the perpetrator is a manager, officer or employees of CUC, the sanction may, depending on the seriousness of the infringement,  be a reprimand, fine, conditional non-qualification / authorisation or dismissal.

Where the perpetrator is a client of CUC, the sanction may, depending on the seriousness of the infringement,  be a reprimand, registration with the scheme owner and/or accreditation body, registration with an applicable authoritative organisation, suspension of the certificate or withdrawal of the certificate and contract.

Where the perpetrator is a scheme owner, accreditation body or other authoritative organisation, the sanction may, depending on the seriousness of the infringement, be a formal protest, registration with an applicable authoritative organisation, publication to other stakeholders or withdrawal of contract.

CUC strives to impose sanctions that are proportionate in both nature and scope to the sanctionable act for which they are imposed and the culpability or responsibility of the sanctioned party for such sanctionable act.

In lieu of sanctions proceedings, CUC may agree with a defendant or other party that controls the defendant on an appropriate sanction and related terms and conditions governing the resolution of the case, subject to appropriate checks and balances in decision-making and within such guidelines as management may establish from time to time in accordance with this policy.

CUC may agree with entities and individuals to lessen sanctions in exchange for voluntary disclosure of past sanctionable practices, on such terms and conditions as management may establish from time to time in accordance with this policy. In any case, individuals may never be unnecessarily harmed by such disclosure.

CUC strives to ensure transparency for defendants, other sanctioned parties and the general public, while protecting the integrity of the investigatory and adjudicatory processes, which are confidential and not open to the public. In furtherance of this principle, the names of sanctioned parties, the sanctions imposed and the grounds therefor are publicly disclosed.