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 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. Public information must not make false or misleading statements about the reviewee's products, services, opportunities, position, ....

2. Procedures & Practices

Procedures & Practices are in place such that:

• a. If publicly communicated, company information is accurate.
• b. Information regarding participant labor, health and safety, environmental practices, business activities, structure, financial situation, and performance communicated to suppliers and customers is accurate.
• c. Falsification of records or misrepresentation of conditions or practices is unacceptable.
• d. All publicly communicated company information (job posting, product details, company/facility promotion (booklet/flyer), commercial advertising, press releases, website, etc.) are accurate.

NOTE: Unintentional errors are out-of-scope for this question.

3. Controls & Monitoring

Controls & Monitoring should include:

• a. Auditors will cross-check several different business records to ensure records align and are accurate.

4. Records

Records are maintained including:

• a. Financial and annual reports about the reviewee's business operations are available.

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'.