D1. Business Integrity and No Improper Advantage

Code 8.0

The highest standards of integrity shall be upheld in all business interactions. Participants shall have a zero-tolerance policy to prohibit any and all forms of bribery, corruption, extortion, and embezzlement. Bribes or other means of obtaining undue or improper advantage shall not be promised, offered, authorized, given, or accepted. This prohibition covers promising, offering, authorizing, giving, or accepting anything of value, either directly or indirectly through a third party, in order to obtain or retain business, direct business to any person, or otherwise gain an improper advantage. Monitoring, record keeping, and enforcement procedures shall be implemented to ensure compliance with anti-corruption laws.

Elements to Demonstrate Compliance to RBA Code

1. Policy

There is no identified risk or evidence of bribes or obtaining undue or improper advantage being promised, offered, authorized, given, or accepted.

2. Procedures & Practices

Indirect workers should know both the Auditee's and the labor agent's process on bribes or other means of obtaining undue or improper advantage.

3. Controls & Monitoring

Record review confirms that:

• a. Public information does not reveal any current cases or allegations of bribery, improper advantage, corruption, extortion, or embezzlement.
• b. Grievance records do not reveal any current cases or allegations of bribery, improper advantage, corruption, extortion, or embezzlement.
• c. Declarations of conflict of interest are recorded for:
  • i. Direct workers
  • ii. Indirect workers
• d. Personnel files, leave records, disciplinary records, and grievance records confirm no negative consequence for any worker/employee refusing to do anything in non-conformance with the "highest standard of integrity" policy.

4. Serious conditions to ensure do not occur include

• A confirmed case of bribery, improper advantage, corruption, extortion, or embezzlement without a corrective action plan.

NOTE: Remote verification is acceptable for this criterion.

1.1.0 (2022-06-01)

Changed

• Remote verification changed from not acceptable to acceptable: Remote verification, which was not acceptable for the former D1 Business Integrity criterion, became acceptable for the merged No Improper Advantage criterion — a loosening.

Removed

• Former D1 (Business Integrity) and D2 (No Improper Advantage) merged; conformance requirements reduced to four record-review items: The 7.0.0 D1 (Business Integrity) and D2 (No Improper Advantage) criteria were merged and renumbered into a single No Improper Advantage criterion. The conformance requirements were reduced to four record-review items (public information, grievance records, conflict- of-interest declarations for direct and indirect workers, and personnel/leave/disciplinary/grievance records confirming no negative consequence). The former monitoring-program, investigation/sanctions requirements, the gifts cost/frequency item, and the explicit anti- corruption-law conformance item were dropped from the audit requirements. The fail-determinant (a confirmed case of bribery, improper advantage, corruption, extortion, or embezzlement without a corrective action plan) is equivalent across the merge. Removing ways to fail is a loosening, so this is minor; no facility that passed 7.0.0 D1+D2 could fail 7.1.2 D1 from these changes.

• Explicit Major/Minor rating bands replaced by generic finding-severity definition: The 7.0.0 explicit bands ('No detailed and understandable policy and procedures implemented' / 'Partial policy or procedures or implementation') were replaced by a generic 'See finding severity definition'. The Priority fail-trigger is unchanged, so no prior pass becomes a fail.

1.0.0 (2021-01-01)

Changed

• Initial historical baseline — Business Integrity (D1) + No Improper Advantage (D2) (RBA Code of Conduct 7.0): Earliest imported version, published as two separate criteria: D1 Business Integrity and D2 No Improper Advantage. Required adequate and effective policy and procedures upholding the highest standards of integrity with zero tolerance to bribery, corruption, extortion, and embezzlement; a monitoring program; an investigation and sanctions process with a preventive action plan; a gifts cost/frequency standard; conflict-of-interest declarations; and conformance with anti-corruption laws. Explicit Major/Minor rating bands were used and remote verification was not acceptable for the Business Integrity provision. The Priority trigger was a confirmed Ethics breach without investigation or corrective action plan (D1) and a confirmed case of bribery/improper advantage without a corrective action plan (D2).