Ethics & Integrity

A STATEMENT FROM THE ETHICS TEAM

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.  These Disciplinary Procedures (“Disciplinary Procedures”) describe the processes for enforcing the Code with respect to Member Auditors, and the bodies authorized to do so.

THE IMPORTANCE OF REPORTING

APSCA’s Ethics Team offers services to our members and stakeholders to ensure that when unethical behavior is reported, investigative action is taken to review each allegation. APSCA relies on reporters, whistleblowers, and collaborative parties to report concerns to APSCA because we cannot be everywhere at once. Frontline parties involved in all aspects of the social compliance audit process may witness unethical behavior. Every APSCA member (individual or firm) has a distinct responsibility to report ethical issues when they occur. The Ethics Team at APSCA safeguards the anonymity of whistleblowers and 

maintains confidentiality of sensitive information to protect the identity of reporters. APSCA stands up against retaliation and has implemented a zero-tolerance policy for retaliation against any party who reports in good faithAPSCA’s mission to professionalize social compliance auditing can only be successful if all members speak up and report concerns so that accountability and systemic issues in our profession can be addressed and remediatedYou can place your trust in the APSCA Ethics Team and Disciplinary Board Members to manage reported concerns with integrity.  

ETHICS & INTEGRITY POLICIES, PROCEDURES, GUIDANCE DOCUMENTS

The below two procedures should be read in conjunction with one another as APSCA trials the Pilot Procedure.

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.
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COVID-19

The Importance of Paying Attention to Ethics and Integrity During the COVID-19 Pandemic
COVID-19 had an immeasurable impact on global business and the social compliance auditing profession certainly exhibited changes in standard business practices during the global pandemic. Now, companies are forging a new path forward with a mixture of old and new processes. Social compliance auditors may see a rise in unethical behaviors as companies emerge from operating in crisis mode. Added pressure may exist during this transitional period for individual Member Auditors, Member Firms and Audit Facilities. This added pressure may increase the temptation to take short cuts and to rationalize some unethical actions. It is more important than ever for companies, and for individual auditors, to understand and diligently follow APSCA's Code and Standards of Professional Conduct. Companies should monitor compliance, maintain strong oversight and internal controls to address the pressures felt by employees, and continue to hold employees accountable for any misconduct.
TRENDING ETHICS CONCERNS SEEN BY APSCA
BRIBERY
Never accept a gift or financial incentive related to an audit. You must refuse and report when these concerns arise. Do not risk your professional reputation.
CONFLICT OF INTEREST
Carefully check the APSCA Code and your company guidelines before taking on any consulting work. You must wait 2 years after auditing a facility to provide any consulting services to that party, according to the APSCA Code and Standards of Professional Conduct.
Harassment
Be aware of your interactions with others and the power dynamic that may exist between parties. Some comments, gifts, and interactions may be offensive to others even if they smile or stay silent. Remain respectful, appropriate and professional, even after hours when travelling with coworkers.
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Did You Know?

Members of the Disciplinary Board 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. 

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.

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. 

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

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

Members are given 30 days to respond in writing and submit relevant supporting documentation and evidence to be considered by the Disciplinary Board, and shall have the right to appear in person or remotely before the Board.

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.

  1. No Action
  2. Written Warning:  A written warning to the Member found to have violated the Code.
  3. Demotion:  A demotion in the Member Auditor’s level.
  4. Suspension:  A suspension of APSCA membership for a period of up to and including one year.
  5. Revocation of APSCA Membership.

REPORT AN ISSUE

If you need to report a potential APSCA Code Violation please email the APSCA Ethics Team. Please note, any email received by the APSCA Ethics Team is kept confidential and will not be shared with any third parties without your consent.

ethics@theapsca.org

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