Conflict of Interest Policy

This Policy is binding on all TNV Global personnel — employees, contracted auditors, technical reviewers, certification decision makers, Impartiality Committee members, Board members, sub-contractors, and any other persons acting on behalf of TNV Global. Breach of this Policy may result in disciplinary action including termination of employment or contract.

1. Purpose and Scope

This Policy aims to ensure that the integrity, impartiality, and credibility of TNV Global's certification activities are not compromised by personal, financial, or other interests of TNV Global personnel. It applies to all certification-related activities including pre-engagement screening, audit planning, audit conduct, certification decision-making, surveillance, suspension, withdrawal, and restoration.

2. Definitions

• Conflict of Interest: A situation in which the personal, financial, family, or other interests of an individual, or those of TNV Global as a body, could compromise — or could reasonably be perceived to compromise — the impartiality, objectivity, or independence of certification activities.
• Actual conflict: A direct conflict that exists between an individual's interest and TNV Global's certification activity.
• Potential conflict: A foreseeable situation that may lead to a conflict if not actively managed.
• Perceived conflict: A situation that, while not actually compromising independence, could be reasonably perceived by an external observer to do so.
• Related Party: Spouse, partner, parent, child, sibling, in-law, or anyone with whom the individual has a close personal or financial relationship.

3. Types of Conflicts We Identify

Conflicts of interest may arise from any of the following sources:

4. Disclosure Obligations

Every TNV Global person must disclose any actual, potential, or perceived conflict of interest as soon as the person becomes aware of it, and no later than the time at which the conflict could begin to influence a certification activity.

4.1 Annual Declaration

All TNV Global personnel involved in certification activities — including auditors (employed or contracted), technical reviewers, certification decision makers, Impartiality Committee members, and senior management — must complete a written Conflict of Interest Declaration at least annually. The declaration covers:

• Current and former employers (last 5 years)
• Current and former consulting clients (last 5 years)
• Shareholdings or material financial interests in any organisation
• Directorships, advisory positions, or trustee roles
• Family or close personal connections to senior personnel of potential clients
• Any other interests that could reasonably be perceived as a conflict

4.2 Engagement-Specific Disclosure

Before being assigned to any audit, technical review, or certification decision, the assigned person must:

• Review the client's name, organisation, and scope
• Confirm in writing whether any actual, potential, or perceived conflict exists
• If a conflict exists, decline the engagement or submit it for review by the Impartiality Committee
• This is documented in the engagement file before audit work commences

4.3 During Engagement

If a previously undisclosed conflict comes to light during an audit or certification process, the person concerned must:

• Immediately notify the Lead Auditor (if a team member) or Operations Director (if the Lead Auditor)
• Cease the conflicting activity pending review
• Cooperate fully with any investigation

5. Pre-Engagement Screening

Before formally accepting any new client or new audit engagement, TNV Global performs documented screening for conflicts of interest:

• Cross-check the proposed client against the database of past and current consulting engagements of all TNV Global personnel
• Verify no auditor has provided consultancy to the client within 2 years
• Check for any past disputes, complaints, or impartiality concerns involving the client
• Where related-party transactions exist between TNV Global and the client, document and mitigate
• Where no mitigation is available, decline the engagement

6. Active Management of Disclosed Conflicts

When a disclosed conflict is judged manageable rather than disqualifying, the following mitigations may be applied:

• Recusal: The conflicted person is removed from the engagement entirely.
• Reassignment: An alternative auditor or decision-maker is assigned.
• Enhanced oversight: An additional independent reviewer is added to the engagement to ensure objectivity.
• Transparency: The conflict is disclosed to the client, who may consent to the engagement proceeding with safeguards, or may request reassignment.
• Documented justification: The reasoning for proceeding (rather than recusal) is recorded with sign-off by the Impartiality Committee Chair.

7. Cooling-Off Periods

Mandatory minimum cooling-off periods apply:

8. Gifts, Hospitality, and Entertainment

TNV Global personnel must not solicit or accept gifts, hospitality, or entertainment that could reasonably be perceived as influencing certification activities. The following thresholds apply:

• Token gifts (under GBP 25 / USD 30): Acceptable (e.g., branded pen, company calendar)
• Modest hospitality (under GBP 50 / USD 65 per occasion): Acceptable for working meals during audit, with disclosure
• Significant hospitality (over GBP 50 / USD 65): Must be declined or, if unavoidable for diplomatic reasons, reported and approved
• Cash, cash equivalents, vouchers: Never accepted, regardless of value
• Travel and accommodation paid by client: Only acceptable if part of the audit contract and at-cost; never gratuitously

Personal connections with clients (e.g., wedding attendance, sponsored events) are disclosed in writing to the Impartiality Committee.

9. Outside Employment and Engagements

TNV Global personnel may hold outside positions (employment, consulting, advisory) provided that:

• The outside position is disclosed in writing to TNV Global
• The outside position does not involve consulting on management systems we certify (this is incompatible)
• The outside position does not create a conflict with any current TNV Global client
• The outside position does not impair the person's availability or objectivity
• Use of TNV Global's name, branding, or accreditation in connection with outside work is strictly prohibited

10. Reporting Suspected Non-Disclosure

Any person — internal or external — who suspects that a TNV Global colleague has failed to disclose a conflict of interest may report this in confidence to:

• admin@tnvglobal.com (subject: "Conflict Disclosure Concern")
• Impartiality Committee Chair via the same email channel
• UAF directly at https://uafaccreditation.org for serious concerns

All reports are treated confidentially. Retaliation against a person making a good-faith report is itself a serious breach of policy.

11. Sanctions for Breach

Failure to disclose a known conflict of interest is a serious breach of this Policy and of TNV Global's obligations under ISO/IEC 17021-1. Sanctions may include:

• Written warning
• Removal from current engagement
• Suspension from certification activities pending investigation
• Termination of employment or contracting arrangement
• Notification to professional bodies (e.g., IRCA, IEMA) where applicable
• Notification to UAF where accreditation implications arise
• Civil or criminal action where fraud, bribery, or material harm is established

12. Records and Retention

TNV Global maintains:

• Annual Conflict of Interest Declarations for all relevant personnel — retained for 6 years after the person ceases involvement in certification activities
• Engagement-specific conflict screenings — retained with the audit file for 3 certification cycles (~9 years)
• Records of disclosed conflicts and mitigation applied — retained for 6 years
• Records of conflict-related investigations and sanctions — retained for 6 years

13. Annual Review

This Policy is reviewed annually by senior management and the Impartiality Committee. The Conflict of Interest Register is reviewed quarterly. Updates are communicated to all personnel and contractors.

14. Contact

Questions or disclosures relating to this Policy: