Gifts, Hospitality & Anti-Bribery

A certificate that could be bought would be worth nothing — to the client who holds it, to the customers who rely on it, or to CAS. CAS Conformity Assessment Services (“CAS”) therefore prohibits, absolutely, the offering, giving, soliciting or accepting of gifts, bribes, commissions or inducements of any kind, in any amount, in connection with any certification activity. The prohibition applies in both directions: to anything offered to CAS personnel, and to anything asked for by anyone acting — or claiming to act — for CAS.

CAS certifies anti-bribery management systems (ISO 37001). We hold our own audits to the discipline we assess in others.

None of the following may be offered to, or accepted by, the audit team, technical experts, decision-makers, committee members or any other CAS personnel — before, during or after an audit, and including the period while a certification decision, appeal or complaint is pending:

• Money in any form — cash, vouchers, gift cards, transfers, “expenses” beyond documented actuals, or payment of a person’s private bills.
• Gifts of any kind or value — merchandise, products, samples beyond what the audit itself requires as evidence, souvenirs, or seasonal presents.
• Benefits directed at family or associates — anything whose recipient is a relative, friend or associate of a person involved in certification has the same effect as a personal benefit, and is treated identically.
• Employment offers or discussions with a member of the audit team or a decision-maker while any audit, decision or appeal concerning that client is live. Any such approach must be declared to CAS at once, and the person concerned stands down.
• Consultancy — asking the audit team to design the management system or fix the findings it raises. CAS does not provide management-system consultancy (§5.2.5), and personnel who provided consultancy to a client take no part in its audit or certification for at least two years after that consultancy ended (§5.2.10).
• Personal discounts, free services, upgrades or entertainment — client products or services at preferential terms, hospitality that has become entertainment (tourism, events, celebration meals), or travel upgrades for personal benefit.
• Payments outside the costed scheme of work — every legitimate fee is invoiced by CAS in writing. No fee, charge or “expediting payment” is ever payable to an individual, in cash, or for a particular result.
• Commercial pressure — threatening to withhold fees, terminate the relationship, or escalate against a person unless a finding is softened or a decision changed. CAS treats this as an intimidation threat to impartiality and responds to it as such.

Exactly three things may be provided by a client to an audit team, and only because the audit itself needs them: hospitality, transport and accommodation — each of them reasonable and necessary for conducting the audit, never a gift by another name. In the normal case CAS pays its own travel and accommodation as part of the costed scheme of work; a client provides these only where the scheme of work agrees it (for example transport to a remote site).

Apply this test — all four parts must hold:

• Needed — the audit could not reasonably proceed without it.
• Modest and customary — working-visit grade, standard class, what any visitor on business would receive.
• Open — offered to the whole team, arranged with CAS, never directed privately at one person.
• Bounded by the audit — audit days only, audit team only, at or between the audit locations.

On either side of the line:

• A working lunch in the site canteen during audit days — permitted. A celebration dinner at a restaurant after the closing meeting — not.
• A car from the airport or hotel to a plant that has no practical alternative — permitted. The same car for sightseeing on the free afternoon — not.
• A standard hotel room near a remote site for the audit nights — permitted. An upgraded suite, extra nights for the weekend, or a room for a spouse — not.
• Water, coffee and required PPE on loan in the audit room — permitted. A “conference bag” of company merchandise to take home — not.

If a situation is not clearly on the permitted side, it is prohibited until CAS has agreed it in writing — ask us, not the auditor.

Every person who takes part in CAS certification activities is personally bound, in writing, before any assignment:

• a code of conduct — the personal behaviour described in ISO/IEC 17021-1 Annex D, turned into binding undertakings: to accept no inducement, gift or commission that could influence their judgement, to report findings accurately and without fear or favour, and not to bring CAS or the certification system into disrepute;
• an impartiality and conflict-of-interest declaration (§5.2) — to reveal to CAS, before undertaking any activity, every situation that may present a conflict of interest, renewed annually and attested again for each assignment; and
• a confidentiality undertaking covering everything they learn in the course of the work.

The duty is not only to refuse. Any offer, hint or demand — however small, however phrased — must be reported to CAS management the same day, so that it is CAS, not the individual, that judges the threat.

When an offer, demand or acceptance comes to light, CAS acts on the person, on the audit, and on the record:

• The offer is declined and reported the same day, and recorded as a threat to impartiality, which CAS is required to identify, analyse, treat and document (§5.2.3) and to act on as a threat arising from another party’s actions (§5.2.11).
• The person stands down from the assignment wherever the offer — accepted or not — could compromise them; CAS does not use personnel with an unresolved conflict of interest (§5.2.13). The audit team is changed and the client is informed.
• The audit work is re-examined. The certification decision is made by people who took no part in the audit; where the objectivity of any audit evidence is in doubt, the affected activity is repeated before any decision relies on it.
• A person who accepted an inducement faces the consequences of their signed undertakings and engagement terms — up to termination of the engagement and removal from CAS’s pool of approved auditors — and CAS may refer criminal conduct, such as bribery, to the competent authorities.
• The impartiality committee sees every such record. It may act independently of CAS management, up to and including informing the accreditation body.

Offering, giving or promising anything prohibited above — by the client or by anyone acting on its behalf — is a failure to satisfy the conditions of certification, whatever the audit would otherwise have found. Depending on when it happens:

• During an audit — the audit team leader stops the affected activity and reports to CAS. CAS may terminate the audit; fees for the work performed remain payable, because fees pay for assessment, not for a result.
• Before a decision — certification is not granted while the objectivity of the evidence or of the decision cannot be assured. Where the attempt itself makes impartial certification impossible, certification is refused.
• After a certificate exists — the matter is handled under our published Certification Rules: suspension of the certification and, where warranted, withdrawal. Suspended and withdrawn status is publicly accessible.

Anyone — an auditor, a client’s employee, a competitor, a member of the public — can report an offer, demand or acceptance through our complaints process. Reports are acknowledged within 2 working days, investigated by people not involved in the matter, handled in line with our confidentiality policy, and no discriminatory action is ever taken against a complainant.

Gift and inducement incidents — including declined offers — feed CAS’s ongoing identification and analysis of threats to impartiality, are reviewed by the impartiality committee, and feed into management review. The absence of reports is itself examined: an audit programme that never records a declined offer is asked why.