D2. Disclosure of Information

Code 8.0

All business dealings shall be transparently performed and accurately reflected on the Participant's business books and records. Information regarding participant's labor, health and safety, environmental practices, business activities, structure, financial situation, and performance shall be disclosed in accordance with applicable regulations and prevailing industry practices. Falsification of records or misrepresentation of conditions or practices in the supply chain are unacceptable.

Elements to Demonstrate Compliance to RBA Code

1. Policy

Ensure your ethics and/or and information disclosure policy includes the following elements:

• a. All business dealings are performed transparently and accurately reflected in the reviewee's business books and records.
• b. No misrepresentation by workers, managers, and their agents.
• c. Public information must not make false or misleading statements about the reviewee's products, services, opportunities, position, ....
• d. Formal program to ensure public reviewee statements are not false or misleading.

2. Procedures & Practices

Procedures & Practices are in place such that:

• a. All business dealings should be done transparently and accurately performed with stakeholders.
• b. Do not communicate any non-public company information except through approved company spokespersons.
• c. Reports provided to government agencies are accurate and complete.
• d. There are good accounting policies, procedures, and record keeping, and conduct periodic data and financial assessments to confirm that accounts are in order.
• e. Ensure job posting and recruitment information is accurate and not misleading.
• f. Information regarding participant labor, health and safety, environmental practices, business activities, structure, financial situation, and performance (e.g., production, quality, timelines) communicated to suppliers and customers is accurate.
• g. Falsification of records or misrepresentation of conditions or practices is unacceptable.
• h. All publicly communicated company information (job posting, product details, company/facility promotion (booklet/flyer), commercial advertising, press releases, website, etc.) are accurate.

3. Controls & Monitoring

Controls & Monitoring should include:

• a. Maintain a system of internal controls to ensure the accuracy of information created, maintained, shared, and reported including to suppliers, customers, community, and government.
• b. Information regarding business activities, financial situation and performance is appropriately audited and verified by external organizations.
• c. Inspect/assess/assessment records verifying they are not falsified and accurate.
• d. Investigate misrepresentation by workers, managers, and their agents.

4. Records

Records are maintained including:

• a. Financial and annual reports about the reviewee's business operations are available.
• b. Publicly communicated company information (job posting, product details, company/facility promotion (booklet/flyer), commercial advertising, press releases, website, etc.)

2.1.0 (2024-01-01)

Added

• Disclosure expectations re-expressed into the modern template with additive audit guidance: The four Record-Review conformance items were re-expressed into the Policy / Procedures & Practices / Controls & Monitoring / Records template, and several additive audit elements were introduced: an approved-spokesperson rule for non-public information, accurate and complete government-agency reporting, good accounting policies plus periodic data and financial assessments, a system of internal controls, external audit/verification, record inspection/assessment, and investigation of misrepresentation. These are additive guidance; the pass/fail determinant is unchanged (the only Priority trigger remains 'Records are deliberately misleading', with Major/Minor per finding severity definition), so the boundary is a minor (additive) increment.

2.0.0 (2022-06-01)

Changed

• New mandatory supplier/customer-communication and public-information accuracy conformance items: Two new MANDATORY Record-Review conformance items were added that were absent from the 7.0.0 form: (1) information regarding participant labor, health and safety, environmental practices, business activities, structure, financial situation, and performance communicated to suppliers and customers is accurate; and (2) all publicly communicated company information (job postings, product details, company/facility promotion, advertising, press releases, website, etc.) is accurate. PASS->FAIL flip: a facility that passed in 7.0.0 with an adequate disclosure policy and program could now fail if inaccurate information communicated to a supplier or customer is found, a condition not assessed under 7.0.0, hence major.

• Rating table genericised: The 7.0.0 Major ('No detailed and understandable policy and procedures implemented') and Minor ('Partial policy or procedures or implementation') bands were replaced by 'See finding severity definition', and the Priority band was reworded from 'Documents are deliberately misleading' to 'Records are deliberately misleading'. On its own editorial; the new mandatory conformance items above drive the major severity.

1.0.0 (2021-01-01)

Changed

• Initial historical baseline — Disclosure of Information (RBA Code of Conduct 7.0, published as D3): Earliest imported version (published as criterion D3 in VAP 7.0.0). All business dealings to be transparently performed and accurately reflected on the Participant's business books and records. Binding requirements covered a disclosure policy (no false or misleading public statements plus a formal program), Record/Inspect/Investigate procedures, and the availability of financial, inspection, and investigation records. The rating table used Priority 'Documents are deliberately misleading', Major 'No detailed and understandable policy and procedures implemented', and Minor 'Partial policy or procedures or implementation'.