Ethics, Integrity & Professional Conduct

Implementing the Code & Standards of Professional Conduct

Consistent with its mission of increasing the value and effectiveness of independent social compliance audits by enhancing their professionalism and consistency and the credibility of individuals and organizations performing them, APSCA has the authority to enforce the Code. This includes disciplining Member Auditors or Firms who violate the provision of these documents.

The Professional Conduct Team

The Professional Conduct Team at APSCA is divided into two sectors: Ethics & Integrity and Compliance. The Ethics Team investigates reported concerns, and guides Members through remediation and resolution processes within APSCA’s Disciplinary Framework, ensuring the APSCA Code and Standards are being met. The Compliance Team identifies non-compliant audits through self-reporting by Member Firms and third-party reports, maintaining the highest standards of social compliance auditing.

Reporting Ethics & Compliance Issues

APSCA’s Ethics Team investigates reported unethical behavior in social compliance audits, relying on reporters, whistleblowers, and collaborative parties. Frontline parties in the audit process are crucial in witnessing and reporting unethical actions. Every APSCA Member, whether individual or Firm, is responsible for reporting ethical issues. We protect the anonymity of whistleblowers and maintain the confidentiality of sensitive information, enforcing a zero-tolerance policy against retaliation for good faith reports. Our mission to professionalize social compliance auditing thrives on active member participation. By speaking up, Members help address and remedy accountability and systemic issues. Trust the APSCA Ethics Team and Disciplinary Board Members to handle concerns with integrity.

Ethics & Integrity Policies, Procedures, Guidance Documents

The below two procedures are specific to APSCA’s Disciplinary Process.

APSCA Ethics Team Process - Disciplinary Board For Member Auditors

The following process illustrates the investigation of cases that are promoted to APSCA’s Disciplinary Board for review. The Ethics Team at APSCA reserves the right to dismiss any case which does not raise a credible claim under the APSCA Code or if insufficient information is provided to pursue an investigation. In such cases, a Letter of Expectation will be issued, if warranted, to the party who has allegedly exhibited unethical behavior. Questions about this process can be submitted to ethics@theapsca.org

STEP 1
Concern Reported to APSCA

APSCA Receives initial allegation/complaint and conducts high-level review to validate legitimacy

STEP 2
Validate Concern

APSCA will determine if unethical behaviour or a Code Violation may have occured, and assigns a Case Number.

STEP 3
Initiate Investigation

Contact Member Firms & Collaborative Parties for investigation support, when necessary.
APSCA will also advise the Subject of the investigation via Rights & Process Letter; response required within 14 days.

STEP 4
Conduct Investigation

Collect further evidence from third parties if necessary and conduct interviews with relevant parties.

STEP 4
Conduct Investigation

Collect further evidence from third parties if necessary and conduct interviews with relevant parties.

STEP 5
Review Evidence

Create case summary and gather supplemental evidence for DBMA, if needed.

STEP 6
Engage DBMA

Schedule DBMA Meeting and advise Auditors of the meeting format.
APSCA will also schedule translators to attend the DBMA meeting if requested by Auditors.

STEP 7
DBMA Meeting

Present cases to DBMA where the Auditor is given the opportunity to appear on the DBMA call.

STEP 8
DBMA Deliberation

DBMA determines case outcome and assigns sanction or disciplinary action if any

STEP 9
Notification of Outcome

Advise Auditor of DBMA Outcome and update the APSCA System(s) to reflect any sanctions. APSCA will also advise any affiliated parties of the DBMA outcome.

STEP 10 - Appeal Process

Auditor may dispute DBMA outcome (assigned sanctions) via APSCA Appeals Process.

Ethical Auditor FAQ

Frequently Asked Questions from the 2024 Ethics Auditor Clinic

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Ethical Firm FAQ

Frequently Asked Questions from the 2024 Ethics Firm Clinic

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TRENDING ETHICS & INTEGRITY CONCERNS and BEST PRACTICES

BRIBERY and INDUCEMENT

Never accept a gift or financial incentive related to an audit. Never compromise independence and integrity due to pressure or agreements with parties related to the audit. You must refuse and report when these concerns arise. Do not risk your professional reputation.

CONSULTANCY GUIDANCE

Consultancy restrictions help maintain impartiality and avoid conflicts of interest that can compromise audit outcomes and integrity. APSCA’s standard for all Members – Firms and Auditors – is 2 years between providing any consulting services and social compliance audit services. Even when Programs or Firms have lower standards, APSCA’s requirements prevail for all APSCA Members.

THIRD-PARTY OVERSIGHT

APSCA Member Firms are fully responsible for overseeing their third parties and subcontractors to ensure the integrity of social compliance auditing. Firms must take proactive steps to uphold consistent ethical standards and practices across all operations – make sure that your contracted parties understand and abide by APSCA’s Code. Effective oversight helps prevent conflicts of interest, fraud, and other unethical behaviors that could compromise the reliability and credibility of the audit results and your Firm’s reputation.

CSCA EXPECTATIONS

Certified Social Compliance Auditors (CSCAs) must adhere to APSCA's Code and Standards of Professional Conduct, ensuring audits are performed with the highest quality, competency, and integrity. Every social compliance audit should be fully attended by a CSCA in order to meet ASPCA's compliance standards. ASCAs can lead audits under the full supervision of a CSCA. Never share credentials, only sign audit reports for fully provided services where accurate and true audit findings are reported, and always ensure fully accurate attendance is reported to all parties.

Useful Links

OECD Anti-Corruption Handbook

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U.S. DOJ Evaluation of Corporate Compliance Programs

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United Nations Ethics Standards

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U.S Dept Nations Ethics Standards

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Did You Know?

Disciplinary Independence

Members of the Disciplinary Review Committees, Disciplinary Boards and the Appeals Board shall recuse themselves from participating in the consideration of any matter where such participation would result in, or give the appearance of, a conflict of interest.

Disciplinary Action Relating to Misconduct During APSCA Exams

Guidelines for investigations and sanctions of suspected misconduct in connection with APSCA certifications exams are set out in a separate document. Actions of the President & CEO under these guidelines are not subject to review by the Disciplinary Board or the Appeals Board unless either the President & CEO, or APSCA’s Senior Advisor, Ethics & Integrity, specifically refer the case to the Disciplinary Board for its review and action.

Confidentiality

Unless disclosure is required by a court order or other applicable legal requirements, decisions of the Disciplinary Board and Appeals Board shall be confidential, provided that APSCA may share actions by the Boards with the relevant Member Firm, and may publish on its website and elsewhere information on cases individually and collectively, provided that the name of the Member Auditor or Member Firm involved is not revealed.

Jurisdiction

The Disciplinary Boards oversees the disciplinary process for APSCA. It is authorized to:

Make rules for the handling of complaints against Members and the discipline of Member Firms and Auditors.
Hear and decide cases involving alleged acts or omissions that violate the Code.
Discipline Members when it determines there has been a violation of the Code.
Take other such actions as is reasonably necessary to ensure an efficient and effective disciplinary system for APSCA.

Members may respond to allegations by working with the Professional Conduct Team to advise their perspective and submit relevant supporting evidence to be considered by the Disciplinary Bodies, as well as maintaining the right to appear in person or remotely before the Board at the scheduled time of their hearing.

To the extent feasible, APSCA shall present all matters to the Disciplinary Board in an anonymous format, without disclosing the name of the Member(s) involved.

The standard of review for the Disciplinary Board shall be a preponderance of the evidence, which generally means “more probable than not.”
The Appeals Board may only reverse a decision of the Disciplinary Board if it finds a clear error in the decision.

When the Disciplinary Board has reviewed an allegation that a Member Auditor has violated the Code, it may take any of the following types of actions.

No Action (case closure)
Written Warning: A written warning to the Member found to have violated the Code.
Level Change: A CSCA may be required to re-sit exams to regain their CSCA Auditor Member level.
Suspension: A suspension of APSCA membership for a period of up to two years.
For any of the above sanctions, additional tasks can be assigned to the Member Auditor to allow for reflection and remediation in conjunction with their assigned disciplinary sanction.
Revocation of APSCA Membership. Revocation is permanent.

All Disciplinary Outcomes may be appealed and reviewed by the appropriate Appeals body. The decisions of the Appeals bodies are final. There is no further ability to appeal once the Appeals body decision has been rendered.

Reporting Requirements

All APSCA Members (Auditors and Firms alike) are required to report ethical misconduct when witnessed. First line of reporting should be to the provided ethics reporting channels at the Firm level. However, if you are unable to report to the Firm, you can report to APSCA’s Professional Conduct Team (ethics@theapsca.org). Failure to report ethical misconduct can result in disciplinary action.

What's New?

REPORT AN ISSUE!

If you need to report a potential APSCA Code Violation please email the APSCA Professional Conduct Team. Please note, whistleblower reports are anonymized to conceal the sender’s identification, which will not be shared by the APSCA Professional Conduct Team with any third parties without your consent.

ethics@theapsca.org