Conflicts of Interest Policy
All assessors, decision makers, and staff must disclose conflicts of interest and follow recusal procedures. This policy implements the requirements of ISO/IEC 17011 § 4.4.5 and complements the Impartiality Policy.
Conflict categories
| Category | Examples | Disclosure trigger |
|---|---|---|
| Financial interest | Equity, debt, profit-sharing, or deferred compensation with an applicant. | Any amount above $0 |
| Employment / consultancy | Current or past (within 2 years) employment, consulting, or advisory role. | Any engagement within 24 months |
| Family / personal | Spouse, domestic partner, parent, child, or sibling employed by the applicant. | Any qualifying relationship |
| Competitive / commercial | Direct competitor relationship between assessor's employer and the applicant. | Market overlap in declared scope |
| Gifts / hospitality | Gifts, meals, travel, or entertainment valued above $50 from the applicant. | Cumulative value exceeds $50 in 12 months |
Required actions
- Disclosure: Report the conflict to the Compliance Office in writing before the assessment or meeting begins.
- Screening: The Compliance Office evaluates severity and records the conflict in the threat register.
- Recusal: If the threat cannot be adequately mitigated, the individual is recused from the case entirely.
- Mitigation: Where partial mitigation is possible (e.g., limiting scope of participation), the mitigation plan is documented and monitored.
- Audit trail: All disclosures, decisions, and mitigations are retained for a minimum of 6 years.
Annual declaration cycle
Every assessor, committee member, and board director must submit a signed Conflict of Interest Declaration at the beginning of each calendar year, even if no conflicts exist ("nil return"). Supplementary declarations are required whenever circumstances change.
Failure to submit the annual declaration by the deadline results in automatic suspension from assessment and decision activities until compliance is restored.
Governance controls
- The Compliance Office reviews all declarations and maintains the central threat register.
- The Impartiality Committee audits the threat register biannually and may request further disclosures.
- Undisclosed conflicts discovered after the fact trigger a formal investigation and may result in decision review, disciplinary action, or contract termination.
- Statistical summaries (anonymized) are included in the Annual Governance Report.
Questions or concerns about conflicts should be directed to Compliance at compliance@accreditationcenter.org or submitted via the formal complaints process.
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