D2. Disclosure of Information

Code 7.0

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

Elements to Demonstrate Compliance to RBA Code

1. Policy

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

• a. Public information must not make false or misleading statements about the reviewee's products, services, opportunities, position, ....
• b. Formal program to ensure public reviewee statements are not false or misleading.

2. Procedures & Practices

Procedures & Practices are in place such that there are adequate and effective procedures to:

• a. Record: Ensure that all business dealings are transparently performed and accurately reflected on the reviewee's business books and records.
• b. Inspect: Inspect/assess/audit records verifying they are not falsified and accurate.
• c. Investigate: Investigate misrepresentation by workers, managers and their agents.

NOTE: Information regarding participant labor, health and safety, environmental practices, business activities, structure, financial situation and performance is to be disclosed in accordance with applicable regulations and prevailing industry practices. Falsification of records or misrepresentation of conditions or practices in the supply chain is unacceptable. Unintentional errors are out of scope for this question.

3. Controls & Monitoring

Controls & Monitoring should include:

• a. Good accounting policies, procedures, and record keeping, with internal controls to ensure the accuracy of information.
• b. Annual periodic third-party financial audit to confirm that accounts are in order.
• c. Auditors will cross-check a number of 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 and ready for review.
• b. Inspection and investigation records are available for review.

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'.