GIF Due Diligence programme for

Non-Financial Reporting and Ethical Label

Regulation

1   Scope

This document specifies the Regulation of the “Get It Fair”, voluntary third-party Due Diligence programme, promoted by ICMQ Certification India, supporting the issue of a Non Financial Declaration on the ESG risks and an Ethical Label based on the “Get If Fair Framework”.

The purpose of the GIF Due Diligence Programme (here in after “The Programme”) is to determine the exposure to risks related to the Social Responsibility aspects (human rights & work conditions, health & safety, environment and business ethics) of a Unit belonging to an Organization.

The Programme is applied to all kinds of Unit regardless of their size, sector, and location.

The GIF Programme is applicable to an operational Units that can:

  1. correspond with the Organization legal entity or
  2. be part of a larger Organization having multiple Units (subsidiaries, production plants, etc.)

Upon positive completion of the Programme ICMQ grants to the Customer the right of using the ethical Label “GIF Responsible organization” to the Assessed Unit/s within the Programme.

The scope of the Programme is to provide assurance by verifying and confirming the plausibility of the Ethical Label with regards to the intended future use (validation). 

This document is also applicable in the event of customers requesting a second party Due Diligence and, for different reason, do not require a public disclosure of the either the Non-Financial Report or the Ethical Label.

2   GIF Reference Framework

The Programme refers to the GIF Framework, a non-prescriptive model based on 7 (seven) Social Responsibility fundamentals taking into consideration the social responsibility principles according to ISO 26000 standard.

The Get It Fair Framework provides Organizations and their Units with a common language that enables to:

  1. share knowledge and experience, both inside and outside their own Organization
  2. establish, implement and improve a Social Responsibility management system
  3. assess and reduce the exposure to risks affecting every social responsibility aspect.

The GIF Framework is based on five criteria: one “Enabler” (Management System) and four “Risk related aspects” (Social, Health & Safety, Environment and Business Ethics).

Each Aspect is broken down into Areas to be considered.

 Aspect

Area

MANAGEMENT SYSTEM

Context of the Organization

Leadership

Planning

Support

Implementation

Performance evaluation

Improvement

SOCIAL

Human rights

Labour practice

HEALTH & SAFETY

Safety

Welfare

ENVIRONMENT

Pollution and emissions

Sustainable resource

Climate change

Protection of the environment

BUSINESS ETHICS

Fair operating practices

Consumer issues

3   Application for GIF Programme

3.1      Application

The Customer contacts ICMQ and, upon request, will receive from ICMQ the Application Package within 7 working days of receipt of the query.

The Customer shall fill and submit the Application Form to ICMQ along with the requested forms and document and send it along with the Confidentiality Agreement.

The Customer shall specify the Unit/s to be included in the Due Diligence Programme

On reception of the Application Package documents duly filled ICMQ prepares and sends an Offer Letter.

3.2      Commercial Offer

The commercial offer is prepared by ICMQ on the basis of the information disclosed by the Applicant and the Programme requirements for calculation of the assessment man-days.

The Commercial offer shall specify the following fees:

  • Application and pre-engagement fee
  • Assessment fee (based on the estimated number of mandays)
  • Non Financial Reporting issue, Publication fee and use of the Ethical Label

The Customer is aware and accepts that ICMQ retains the right to:

  1. confirm the commecial offer
  2. modify the commercial offer (the Customer retains the right of accepting or rejecting the modified offer)
  3. decline to perform the Assessment.

after reception of more detailed information requested in the Pre-engagement phase.

3.2.1      Assessment man-day determination

The number of Assessment man-days for each Assessment (initial assessment, surveillance and renewal assessment) depends on the number of employees of the Customer’s Unit and is determined according to the following table. The calculation takes into account the days needed to plan and collect sufficiently objective evidence on original data and information.

Number of effective employees

Minimum number of man-days per Assessment type

Initial Assessment

Surveillance

Renewal

Short notice

Planned

1-15

3

1 ½

1 ½

3

16-65

5

2

2

4

66-125

7

4

126-165

9

3

5

166-275

11

3 ½

4

5

276-625

13

4

5

6

626-1175

15

6

7

1176-2025

17

5

7

8

2026-3450

19

8

10

3451-5450

21

6

10

11

5451-10700

23

11

12

10701-20000

25

7

13

14

>20001

27

14

15

The number of Assessment man-days includes the assessment preparation, the on-site assessment and the reporting activity.

In determining the number of the Assessment man-days, the following aspects will be taken into consideration:

  1. total number of employees, including permanent, part time, contract, and temporary employees
  2. a translator used in case the Assessor is not fluent in the language(s) spoken at site
  3. the number of shifts and people per shift

The total number of Assessment mandays shall be determined and record kept.

3.2.2      Permitted augmentation

The number of mandays can be increased for the following reasons:

  1. Some documents or activities are located in different premises from the Unit
  2. Travelling time to reach the Unit in remote area
  3. Travelling time to reach different premises of the unit
  4. Existence of multiple facilities having completely different processes in the same site
  5. High complexity of production processes and operations and related risks

3.2.3      Permitted reductions

A reduction of the number of Assessment man-days may be applied in presence of:

  1. Management system or other certifications issued to the Customer (provided such certification cover the interested Unit)
  2. Limited complexity of production processes and operations risks in the interested Unit.

Exceptions to the Assessment man-days reductions are allowed upon prior approval of the AB.

If the Customer has one or more management systems certified by accredited Certification Bodies the following reductions in the calculation of Assessment man-days are permitted:

ISO 9001

15%

ISO 14001

15%

ISO 45001

15%

Any Social Certifications

15%

Maximum permitted reduction: the maximum permitted reduction in the calculated man-days per Unit, including all possible reductions shall not exceed 45%.

Due Diligence of multiple sites based on sampling is not allowed and every Unit the Customer wish to cover within the Programme must be assessed.

3.2.4      Work order and Application Fee

ICMQ sends to the Applicant the comercial offer.

In case of acceptance the Applicant shall return the Offer countersigned along with the GIF Work Order template and the documents required in the Application Package duly filled and signed by a legal representitive and the payment receipt of the Application Fee.

ICMQ shall reject or close an application under the following conditions:

  1. the Application Fee is not received by ICMQ
  2. voluntary withdrawal of Application.

The Application Fee is not refundable.

ICMQ will formalize the application, update the Application Register and acknowledge the Applicant so starting the Pre-engagement phase.

3.3      Pre-engagement

Upon reception of the Application Fee payment the Customer enters the Pre-engagement phase.

ICMQ shall send the Pre-engagement Package constituted of a set of information documents, and forms & documents to be prepared and sent back to ICMQ within and not over 45 days.

The Customer accepts to provide ICMQ with information sufficient to carry out a pre-engagement review including the following information:

  1. Customer name
  2. List of Customer’s Unit/Units to be included in the GIF Programme
  3. Formal acceptance of the GIF Programme ethical claim
  4. The information required to plan and the Due Diligence to validate the ethical claim
  5. The objective and scope of the Due Diligence
  6. The Materiality Assessment
  7. The Self assessment
  8. Any other information as required by the Due Diligence Programme

3.3.1      Materiality matrix

The scope of the Materiality matrix is to identify what are the significant aspects for the Customer (an its Unit/s)  and its stakeholder able to affect decisions and judgment of the interested parties.

The pre-engaged Unit is requested to submit the Materiality Matrix according to the form sent by ICMQ.

The Form must be filled by the Unit also in the event the Customer it belongs to has already its own materiality assessment.

3.3.2      Self Assessment

The self-assessment is a “preliminary assessment” based on a questionnaire referring to the Get If Fair Framework.

The scope of the Self assessment is to identify the strengths and weaknesses point of the Pre-engaged Unit against the Get If Fair Framework.

3.3.3      Pre-engagement package verification and decision

ICMQ verifies the Pre-engagement package documents within 10 working days from the reception taking in consideration, particularly the following aspects:

  • applicability of GIF Programme
  • GIF claim is understood (context, objective and complexity)
  • objective and scope of the Assessment are agreed with the Pre-Engaged Unit
  • GIF requirements against which the claim will be assessed are suitable
  • materiality and level of assurance have been agreed
  • the process for assessment can be achieved

At the end of the review, ICMQ shall be able to identify and have access to the resource and competences, to estimate the assessment duration and propose a time frame for the assessment.

Following the Pre-engagement review of the submitted information from the Unit ICMQ retains the right of deciding whether accepting or declining to perform the assessment.

The ICMQ decision is communicated to the Customer by sending an acceptance/declining letter.

In case of ICMQ declines to complete the Due Diligence the application fee is not refundable.

Upon Customer’s acknowledgment of the decision, ICMQ shall:

  1. create the customer account and folder (i-Audit)
  2. enters the Customer in the Registation Register with a unique identification number.
  3. sends the Gap report to guide the organization in understanding the identified issues

4   Engagement

With the Registration update and the creation of the i-Audit account and folder, the Engagement stage can start.

ICMQ reviews the commercial offer, if necessary, with the correct man-days calculation.

4.1      Contractual agreement

ICMQ confirms or revises the final offer, specifying if it is a third or second-party assessment and sends the contractual documents to the Customer

The Customer acceptance by signing the contractual documents determines the start of the planning stage.

ICMQ shall take responsibility for any inputs it accepts take into account as part of the Programme, including those that have been generated by the Customer or other external parties.

4.2      Validity

In the event the Programme is not completed within 3 months from the Registration date, the registration number will expire, and the Customer will need to make a new Application and pay a new Application Fee.

5   Planning

5.1      Assessment Team

ICMQ shall appoint an Assessment Team, having all necessary competences and skills required to conduct the Assessment according to the GIF Framework and selected from the GIF Assessor Register.

GIF qualified Assessors are experienced professionals from a range of industries and countries.

The size of team varies depending on the size and complexity of the engaged Unit.

The Team Assessor appointment procedure will be completed with the formalization and the signature, from each member of the team, of the Assessor Appointment Package documents.

The Lead Assessor is permitted to access the i-Audit folder and related Customer documentation.

5.2      Documentation Review

The Lead Assessor starts the Documentation Review to:

  • Determine the assessment activities based on the understanding of the claim
  • Assess the risk of a material misstatement regarding the claim
  • Identify the timing and access arrangements with the Customer

5.3      Assessment Plan

Along with the documentation review the Lead Assessor prepares the planning activities and formalizes:

  1. a) the Sampling Plan
  2. Assessment Plan

Sampling Plan

In preparing the Sampling Plan, the Lead Assessor shall take into consideration the risk of material misstatement and any measure that the Unit has in place to control sources of potential errors, omissions and misrepresentation.

Part of the Assessment will consist of employees and workers interviews and records verification to evaluate the SR related risks: approximately 15% (twenty per cent) of the Assessment time will be dedicate to such activity.

The number of persons to be interviewed (individually and in group) and the number of workers files is calculated according to the following table :

Number of employees

Assessment Mandays

Interviews

Worker records checked

Total hours (interviews + files)

Individual

Group

Total employees interviewed

1-15

3

2

1×3

5

7,5

3

16-65

5

4

2×3

10

15

6

66-125

7

6

2×3

12

18

7

126-175

9

6

3×3

15

22,5

9

176-275

11

8

3×3

17

25,5

10

276-625

13

10

4×4

26

39

14

626-1175

15

12

5×4

32

48

18

1176-2025

17

14

6×4

38

57

21

2026-3450

19

16

7×4

44

66

24

3451-5450

21

18

8×4

50

75

27

5451-10700

23

20

9×4

56

84

31

10701-20000

25

         

>20001

27

         

Assessment Plan

The Sampling Plan constitutes an input for the Assessment Plan preparation regarding the Customer’s Unit.

ICMQ shall ensure that the Assessment is conducted during working days in which the Unit is in operation. The Assessment shall not be planned or carried out in case the Unit is non-operational for any reason.

The Assessment Plan is prepared to ensure that all the GIF Framework criteria are adequately assessed. In preparing the Plan the Lead assessor shall take into account the following tentative breakdown of the total assessment time.

Variations are permitted within a limited range and decided by the Lead Assessor according to specific situations and the result of the materiality assessmef not all the relevant documents are available at the Unit because kept in different premises (e.g. Customer’s Headquarter), part of the Assessment shall be conducted in that premises also and shall be planned before the Assessment.

The Assessment plan shall specify activities and schedule and in particular:

  • Objective and scope of the assessment
  • Identification of the team members and their roles and responsibilities in the team
  • Time frame and duration of the assessment
  • Specific requirements

5.4      Assessors’ alignement

The Lead Assessors prepares and align all Assessment Team Members on:

  1. Understanding of the context of the Customer and interested Units (Materiality): The Assessor shall understand the Unit’s context.

This includes, but is not limited to:

  • The Country related risks
  • The location in order to plan the logistics and to understand workers reality: the way they commute to work, the distance to schools, to hospitals and or other regular administrative offices (e.g. banks)
  • Social specific context (gender, social hierarchy, migration, homeworkers, youth situation)
  • The rough determination of remuneration as accurate as possible to the region and sector
  1. Understand the sector of the Unit: The Assessor shall collect information to ensure to understands the Customer’s and Unit’s sector practices including, but not limited to:
    • Industry specific applicable rules and laws
    • Unit’s processes structure (including the supply chain)
    • Existence of specific trade unions
    • Existence of specific collective bargaining agreements
    • Specific health and safety and environmental risks related to the industry
  2. Make sure to have all relevant documents. This includes:
    • The Self-Assessment Report (Excel version, printed version)
    • Copy of the previous Assessment Reports (if existing)

5.5      Due Diligence Programme

The Programme shall include an Initial Assessment, a number of Surveillances and a Re-assessment the third year according to the following structure.

 

Planned Assessment

Short notice Assessments

Initial Assessment

X

 

Surveillance Assessment

X

X

Re-Assessment

X

 

Planned Assessment: The Unit is informed on the date of the Assessment

Short Notice Assessment: The Unit is informed on the “timeframe” when the Assessment will be conducted with short notice (Max. 3 working days).

The Programme validity is limited to 3 (three) years. Afterwards Re-Assessent is required

5.6      Communication to the Organisation

The Lead Assessor sends the Sampling plan and Assessment Plan to the engaged Unit along with the Assessment Package.

ICMQ shall communicate the names and roles of the Assessment Team Members to the Unit with sufficient notice for any objection to the appointment of a team member to be made.

6    Assessment execution

6.1      Initial Assessment Conduction

ICMQ performs the assessment activity in accordance with Assessement Plan.

The scope of the Assessment covers all the GIF Framework Aspects and Areas and the objective is to veriry and collect sufficient objective evidence to support the scoring evaluation and calculation against the GIF Framework.

ICMQ has to ensure the information/data traceability through the data /information management process, any further analysis and calculation.

The Unit will allow the Assessor Team access to all operations’ areas and documentation of the Unit.

The Assessment Team will visit the Unit in order to collect evidences, assign the score for each Area and prepare detailed Final Assessment Report.

6.1.1      Opening meeting

The opening meeting aims to explain the dynamic and purpose of the Assessment.

During the opening meeting the Lead Assessor shall:

  1. Introduce the Assessor Team and explain the role and responsibility of each Assessor
  2. Collect information on the situation regarding products, processes, facilities, work and employment conditions, plant, equipment, raw materials and, more specifically, an overview on the risk management approach established and implemented by the Unit (materiality)

The Opening Meeting aims to provide the parties with:

  • Confirmation that the Assessment is conducted on a voluntary basis according to the GIF Framework
  • Confirmation on the Assessment objective/s, scope and criteria of the Assessment
  • Confirmation on the Assessment Plan and relevant arrangements
  • Confirmation on the Audit Methods to be used, particularly for sampling and random checks
  • H&S procedures, emergency plans and specific health and safety precautions
  • Assurance on the confidentialiy of the Assessment activity.

The Lead Assessor and the Unit’s Management Representative will agree on the scheduling of the closing meeting.

The Assessment Team will be available for any question that may arise regarding the Assessment and other matter discussed in the Opening meeting.

6.1.2      Site Visit Conduction

The Assessors collect objective evidence by:

  • verifying documents and records
  • visiting and observing the facilities
  • conducting interviews with management, workers representative and employees/workers from different areas and departments.

The Unit is required to provide Assessors with evidences related to all GIF Framework Aspects.

Management System: this part of the Assessment aims to verify whether a SR Management System is established, implemented, monitored and improved by the Unit with respect to all SR aspects. It also intends to have a deeper insight on the organization stakeholder identification and engagement and evaluation process of the material aspects with respect with GIF claim. Specific activities shall be undetarken to verify how the materiality assessment has been conducted.

In the event the Unit is part of a larger organization part of this Assessment shall be conducted in the Customer’s Head Quarter.

Social: this part of the Assessment aims to identify and evaluate the exposure to risks that can result into adverse impacts on workers, employees and/or other Stakeholder with reference to each SR Aspect.

In the event the Unit is part of a larger organization part of this Assessment shall be conducted in the Customer’s Head Quarter.

Health and Safety: this part of the Assessment focuses on the facilities, equipments and operational processes of the Unit. It aims to identify and evaluate the exposure to health and safety risks that can result into adverse impacts on workers and employees. This part of the Assessment is conducted in the Unit premise.

Environment: this part of the Assessment focuses on the facilities and equipments and aims to identify and evaluate the exposure to environmental risks that can result into adverse impacts on the environment and local communities. This part of the assessemtn is conducted in the Unit premise.

Business Ethics: this part of the Assessment focuses on the relationship between the Organization, its Unit and its Customers. It aims to evaluate the exposure to risks that can result into adverse impacts on the Customer. In the event the Unit is part of a larger organization part of this Assessment shall be conducted in the Customer’s Head Quarter.

At the end of the Assessement the Lead Assessor consolidates both “Strength points” and “Areas of improvement”, verifies the score and whether all the i-Audit forms have been completed.

The Assessors will save the Final Report.

6.1.3      Closing Meeting

The Lead Assessor shall explain the findings and present to the Unit high-level results (strength points and areas for improvements).

Both the Customer’s Management Representative as well as the Workers’ Representative shall sign the Closing Meeting Report to acknowledge the conclusion of the Assessment, even if they do not agree with all the content.

Any disagreement between the Assessement Team, the Customer’s Management Representative or Workers’ Representative will be recorded by the Lead Auditor in the Closing Meeting Report.

7   Scoring System

The overall scoring reflects the exposure level to the SR related risks of the Unit.

Score per Area: assigned by the Assessor in a scale of 5 or its multiple within a range from 0 to 100. The meaning of each score’s range depends on the Aspect (Management System or Risk Area) as explained in the table below:

Score per Aspect: is calculated as an average of the score assigned to each Area of the Aspect.

The score for Management System aspect reflects how the Unit has established, implemented and improved an approach to achieve the intended SR results.

The score for the Social/Safety/Environment/Business Ethics aspects reflect the overall exposure level to risks related to each area within each aspect.

Score

Management System

Social /H&S/Environment/Ethics

85-100

Very good: the approach covers all the SR aspects.

Complete evidence that the approach is systematically implemented, monitored, reviewed and improved.

Very Low

Very low exposure to both «core risks» and «not core» risks

65-80

Good: The approach covers all the SR aspects.

Clear evidence that an approach is established, implemented and monitored. Some evidences of improvement.

Low

Low exposure to «core risks» and

some exposure to «not core» risks

40-60

Medium: the approach covers all the SR aspects.

Evidence of formal and systematic approach established and implemented. No evidences of review and improvement

Acceptable

Low esposure to core risks and moderate exposure to «not core» risks

20-35

Poor: the approach partially covers the SR aspects.

Some evidences that the approach is established.

Sporadic evidences of implementation.

High

exposure to severe risks

0-15

Very poor: the approach covers only one SR aspect.

Poor evidence that the approach is established.

No evidence of implementation

Very high

exposure to catastrophic risks

Total Score: calculated as an average of the scores per Aspect. The meaning is defined in the following table.

Risk exposure

Explanation

85-100

Very Low

The Unit is exposed to very low risks in every SR aspect and is capable to monitor and treat them without exposing the Stakeholders to unexpected costs and adverse impacts.

No specific corrective actions to be planned and implemented.

65-80

Low

The Unit is exposed to low risks in every social responsibility aspect and is capable to manage them without exposing the Stakeholders to relevant unexpected cost and adverse impacts.

40-60

Acceptable

The Unit is exposed to acceptable risks of adverse impacts in every or some social responsibility aspects but needs to be periodically monitored to prevent any escalation.

Few necessary corrections are required.

20-35

High

The Unit is exposed to high risk in different social responsibility aspects that can result into high costs and adverse impacts on the Stakeholders. Relevant improvement actions must be lanned and implemented.

0-15

Very High

The Assessment has identified critical risks.

The Unit is required to implement improvement measures in the short term.

8   Reports preparation and review

8.1      Final Assessent and Non-Financial Report preparation

8.1.1      Final Assessment Report

Upon conclusion of the Assessment and the closure of the i-Audit forms, the Lead Auditor prepares the conclusion of the outcome of the activities in the Final Assessment Report and makes recommendations for the Due Diligence approval and the Programme Recognition issuance.

8.1.2      Non Financial Report preparation

An ICMQ Reviewer prepares the Non-Financial reports according to the provisions of the Directive 2014/95/EU on the basis of the Final Assessment Report.

8.2      Review

Both Final Assessment Report and Non-Financial Report are reviewed by one or more reviewer. A Reviewer cannot be in the Assessment.

The person in charge of reporting review shall be competent person priorly qualified by ICMQ for this rôle.

The Reviewer shall have available all records of the Due Diligence activities. Specific care shall be dedicated to review the score and its cohérence with the Final Assessment Report

9   Recognition decision

Upon conclusion of the review activities ICMQ Secretariat prepares a Review Package to be submitted to the ICMQ Programme Committee review activity. The package shall contain:

  • The Application documentation
  • The Pre-Engagement documentation
  • The Assessment documentation, records and findings (i-Audit forms)
  • The Final Asssesment Report
  • The Non-Financial Report

The Programme Committee shall be indipendent from the Assessment Team and from the Reviewers but shall communicate with them in case of clarification required.

The scope of the Programme Committee is to review and confirm the following :

  • Completeness: the assessment activities have been conducted in accordance with the GIF programme and assessment plan
  • Appropriateness: sufficiency and appropriateness of the collected evidence to support the decision
  • Relevance: significant findings have been identified and documented

At the end of the revision activities the Programme Committee shall make the decision on whether or not to confirm the Recognition and the claim.

9.1      Recognition Criteria

The GIF Recognition shall be approved and granted according to the following criteria:

  • At least an overall score of 41 (fortyone)
  • At least a score of 40 (forty) achieved in each «core Area» of the Framework.

9.2      Recognition validity

The Programme Committee shall take the decision whether granting the GIF Recognition provided all the following conditions are met:

  1. the Assessment Report, the Non Finanacial Report and all supporting documentation have been provided
  2. the score has been duly calculated and meets the Recognition criteria
  3. the organization has paid all the invoices and/or any outstanding dues.

The recognition decision depends on the results of the initial Assessment as per following table:

Risk exposure

Criteria

Recognition

Validity

81-100

Very Low

Overall score > 61

Minimum score achieved in ALL 5 criteria

At least a score of 40 in each “core Area”

Issued

3 years

61-80

Low

Issued

2 years

41-60

Acceptable

Overall score within 41 and 60

At least a score of 40 in each “core Area”

Issued

1 Year

21-40

High

Overall score within 21 and 40

Minimum of 40 scores is not achieved in all the “Core Areas”

Additional Assessment after at least 3 months

Not Issued

0-20

Very High

Overall score <20

Minimum of 40 scores is not achieved in the “Core Areas”

Additional Assessment after at least 9 months

Not issued

9.3      Recognition issuance and validity

Upon successful conclusion of the Initial Assessment the GIF Recognition is granted.

The Recognition is issued on the date of the recognition decision from the Programme Committee and the validity shall be determined according to the the result of the initial assessment.

A Recognition remains valid until it expires or is superseded, cancelled or withdrawn.

The expiry date of Recognition will be publicly available in Get It Fair website (www.getit-fair.com).

9.4      Communication

Upon completion of the decision proess a communication shall be sent by ICMQ to the assessed Unit specifying:

  1. The achieved result confirmation
  2. The validity period of the recognition
  3. The number and frequency of surveillance
  4. The Programme outcomes shall be sent along with such communication.

10         Due Diligence Outcome

Upon positive completion of the Initial Assessment ICMQ assigns a serial number to be used in all the following outcomes.

10.1   Final Assessment Report (Confidential)

The Final Assessment Report includes all the findings and evidences gathered during the assessment along with the score.

This report includes confidential information and is delivered to the assessed Unit for internal purpose.

10.2   Recognition Certificate (Publicly Available)

The Recognition Certificate shall report the following information:

Recognition identification number (serial) of the statement

Get It Fair logo (reference to the validation programme)

Company name (should be a legal entity)

Unit Address – City – Zip code

The validation claim

ICMQ logo, name and address (mentioning it is a third party validation)

Objective and scope of the validation

Whether the data and information supporting the claim where hypothetical, projected and/or historical in nature

Issuance Date and date & period which the claim cover)

Expiry date

Decision made about the claim

Signature of ICMQ’s legal representative

10.3   Non Financial Report (Publicly Available)

The Non Financial Report aims to provide the assessed Customer’s Unit with a communication tool to be delivered to its Boards and Directors in order to support their Non Financial Statement in compliance with the Directive 2014/95/EU.The Customer is aware and accepts that the Non-Financial Report will be publicly available and published on the Get It Fair web site.

The Non Financial Report is strictly correleted and supported by the Final Assessment Report.

10.4   Ethical Label (Publicly Available)

ICMQ recognizes the right of using an Ethical Label in compliance with the requirements of the ISO 17033.

The Ethical Label attests that the Unit has completed the GIF Due Diligence and can be associated only to the products realized by the Unit by the mean of an appropriate media referring to the Final Assessmet Report.

11         Recognition  publication and promotion

11.1   Publication Recognition

Upon positive completion of the initial assessment ICMQ takes a resolution for the publication of Get It Fair Recognition on the official Due Diligence programme WEB site www.getit-fair.com.

The publication is voluntary. The assessed Unit has the right of deciding if publishing or not any kind of information on GIF WEB site. In the second case the Unit renounces to the right of using the Ethical Label since the publication is a condition strictly required for labelling transparency.

The GIF Recognition publication in the GIF WEB site aims to:

  1. promote the assessed Unit
  2. allow every interested party to search in the database and verify whether a Unit has achieved the GIF Recognition.

The publication period is limited to the validity of the Recognition. In the event the Customer does not renew the Due Diligence programme for the interested Unit/s the publication shall be deleted.

The publication Fee is not refundable.

11.2   Cancellation of the publication

The Unit may require the pubblication cancellation at any time.

In this case, the legal representative will send a written notice, signed thereby, to ICMQ. No fine applies in case of such cancellation. In any case, the fees for the year in progress must be settled. Such cancellation is effective from the date indicated by the Organization and may not be earlier than that of receipt of the aforesaid notice.

As from cancellation, the Customer can no longer use the Get It Fair logo or refer to Get It Fair data by using the registration number which has been withdrawn.

10   Surveillance programme

In order to provide Stakeholders with confidence that a Unit maintains and improves the overall score according to the GIF Framework the Due Diligence Scheme requires a number of surveillance assessments.

The number and frequency of surveillance depend on the results of the Initial Assessment:

Risk exposure

Surveillance

81-100

Very Low

once in a year + one short notice surveillance in three years

61-80

Low

once in a year + two short notice surveillance in three years

41-60

Acceptable

Twice in a year: one planned and one short notice

21-40

High

New Initial Assessment at least after three months

0-20

Very High

New Initial Assessment: at least after nine months.

The Surveillance Assessment will normally be conducted within a defined period and a delay of maximum 30 days beyond the due date allowed in exceptional circumstances.

Any failure in conducting surveillance shall result in suspension of the Recognition.

11         Fee

A fee is charged to the Customer for various activities of the Due Diligence Scheme, without any discrimination between units, geographical location and size.

The fee structure includes the following components:

Fee component

Terms of payment

Application and Registration fee

invoiced and paid before the initial Due Diligence assessment

Assessment fee

invoiced and paid according to the effective assessment manday after the Assessment completion and anyway before the communication of the certification decision

Publication fee

invoiced and paid after the Certification decision and before the publication for three years. The amount includes the right of using Get It Fair logo for three years

Surveillance fee

invoiced at the beginning of the solar year and includes the surveillances to be conducted during the year. To be paid within 31st January.

The fees are publicly available and shall be provided on request.

ICMQ shall notify and obtain consent to its fee structure from the organizations prior to grant of Recognition.

As and when the fee undergoes a change, the same shall be communicate to all including applicants and the Organization having one or more units Assessed under this scheme for acceptance.

12         Suspension or withdrawal of Recognition

12.1   Suspension

ICMQ shall take a decision and shall inform the assessed Customer’s Unit/s for suspension of Recognition if:

  1. the Customer delays in payment of the fees due for publication, after receiving a first reminder
  2. the Customer (and its assessed Unit) breaches the contractual obligations
  3. major changes have taken place in the legal status, ownership, name etc without prior information to ICMQ
  4. the Customer is protested or liquidated or involved in executive and/or insolvency proceedings
  5. the Customer wilfully misuses Get It Fair logo
  6. the Assessor Team provides ICMQ with negative information regarding the results of a Surveillance
  7. any wilful false declaration in the application form or otherwise is detected
  8. excessive or serious complaints against the Customer and its Units are received by Public Authorities
  9. new facts or information materially affecting the validation are discovered after the Recognition decision
  10. outcome of arbitration proceedings in case of disputes.

ICMQ shall issue due notice of at least one week for suspension of recognition to the Assessed Unit.

On receipt of instructions for suspension of Recognition, the Customer shall suspend claiming and publicizing GIF Recognition regariding the assessed unitwith immediate effect.

Suspension shall not exceed a period of six months. The Customer inability to resolve issues relating to suspension within this period shall lead to withdrawal of Recognition after due notice of 15 days is given.

12.2   Withdrawal

ICMQ may decide to withdraw the GIF Recognition if:

  1. the Customer breaches the terms and conditions of provisions of the Get It Fair programme
  2. the Customer, and its Unit, does not meet the Criteria established for issuing the recognition
  3. non payment of registration fees, after receipt of a specific notice
  4. outcome of arbitration proceedings in case of disputes
  5. continuation of the reasons that have caused the suspention of the publication
  6. the Customer is protested or liquidated or involved in executive proceedings
  7. change in the applicable technical standards without these being accepted by the Customer
  8. final verdict against the Customer (res judicata) in judicial proceedings (including arbitration proceedings) for facts concerning non-compliance with these Regulation;
  9. serious irregularities with respect of the Get It Fair logo use.

ICMQ shall withdraw the Recognition at the request of the Unit, if the operation(s) in the Unit can no longer be carried out cause of force major events (flood, fire, earthquake etc,) and lock out declared by the management, or closure of the Unit operations etc.

12.3   Facts discovered after the Recognition and Report publication

If new facts or information that could materially affect the claim are discovered after the issue date, ICMQ shall:

  1. Communicate the matter as soon as practicable to the Customer and its assessed Unit/s;
  2. Take appropriate action including:
  • Discuss the matter with the organization
  • Consider if the recognition requires revision or withdrawal

If the Recognition requires revision, ICMQ shall issue a new Recognition and the revision of the Reports and, if needed, repeating the assessmment.

ICMQ may also communicate to other interested parties the fact that reliance of the original Recognition and Report can now be compromised given the new facts or information.

13         Complaints

13.1   Complaints submitted by the Customer

ICMQ has a documented process to receive, evaluate and make decisions on the complaints.

This process shall be subject to requirements for confidentiality, as it relates to the complainant and to the subject of the complaint.

The process to handle complaints is outlined according to the following approach:

  1. an outlined process for receiving, validating, and investigating the complaint, and for deciding what actions are to be taken in response to it;
  2. tracking and recording complaints, including actions undertaken in response to them;
  3. assurance that any appropriate correction and corrective action are taken.

ICMQ shall make a description of the complaint-handling process publicly available.

Upon receipt of a complaint, ICMQ shall confirm whether the complaint relates to Due Diligence activities that it is responsible for and, if so, shall deal with it. If the complaint relates to the Customer (and its Unit), then examination of the complaint shall consider the effectiveness of the assessed Unit. Any complaint about the assessed Unit (belonging to the Customer) shall be managed by ICMQ and communicated to the assessed Unit (and the Customer it belongs to) in question within 7 days from the date of receipt of the complaint.

The decision to be communicate to the complainant shall be made by (or reviewed and approved by) individual(s) not previously involved in the subject of the complaint.

Whenever possible, ICMQ shall give formal notice of the end of the complaints handling process to the complainant.

ICMQ shall determine, together with the client and the complainant, whether and, if so to what extent, the subject of the complaint and its resolution shall be publicly available.

13.2   Complaints regarding the activity carried out by the assessed Unit

ICMQ may receive a complaint regarding the activity of an assessed Unit from any interested party.

The Organization shall keep a register for complaints received by the Customers or other interested parties with detailed information regarding the reasons of the complaint.

Complaints shall be evaluated by ICMQ in accordance with its own procedure.

A decision shall be taken according to evidences. If the decision is to conduct a supplementary assessment ICMQ shall plan it, even with short notice. The Customer shall accept a supplementary assessment on the interested Units.

In case of refusal in receiving the assessment, ICMQ may decide for suspending the Recognition.

Investigation and resolution of complaints shall not result in any discriminatory actions.

14         Appeals and Grievance

14.1   Appeals

Upon reception of the complaint ICMQ shall confirm whether the complaint relates to its assessment activities and, if so, shall resolve it.

The terms and conditions of these appeals are defined in the Due Diligence Contract with the Customer.

14.2   Grievance

Any complaints and grievances relating to the activities of ICMQ can be addressed by the Customer and by any party referring to the Due Diligence Contract with the Customer.

The description of the grievances process is given to those applying therefore.

14.3   Dispute resolution

ICMQ ensures that the Programme is handled in accordance with the provisions of these Regulation. This should ensure uniformity in the verification of Get It Fair Recognition as well as the comparability between different documents belonging to the same organization category.

However, in case of disputes or complaints concerning the validity and/or quality of the content of Get It Fair these Regulation provide for the commencement of mediation or arbitration proceedings.

Any dispute arising between ICMQ and the Organization/Unit will be resolve by a dispute resolution center (Mediation or Arbitration) agreed by the Parties.

15         Information requirements

15.1   Publicly available information

The Customer is aware and accepts that the following information is made publicly available by ICMQ:

  1. The Due Diligence process
  2. Commitment to impartiality
  3. List of Due Diligence activities
  4. Complaints and appeals processes
  5. The fees for the Due Diligence programme
  6. The policy governing any statement that the Customer is authorized to use when making reference to the Ethical Label in communication of any kind

15.2   Use of the Trademark

The Customer accepts to comply with all the provisions of the general terms and condition for the use of the “Get It Fair” trademark set forth by ICMQ.

These rules ensure, among other things, traceability back to ICMQ and the Ethical Label issued.

The trademark can be used only in relation with the Ethical claim issued to the Assessed unit and shall not be misleading with regards to the product certification.

16          Confidentiality

ICMQ requires a Customer to sign a Confidentiality Agreement for the management of the all information obtained or created during the performance of the Due Diligence.

The Customer is aware and accepts that ICMQ may make publicly available the Non-Financial report prepared in accordance with the provisions of the Directive 2014/95 of the EU.

Except for the information that the Customer makes publicly available or upon agreement with ICMQ all other information is considered proprietary information and shall be regarded as confidential.