CONFLICT OF INTEREST

AND
IMPARTIALITY POLICY

© CREST 2016
 Conflict of Interest and
Impartiality Policy

Version History

Version Date Authors Status

1.0 08.10.2013 E.A. Luck ISSUED
1.1 09.2015 E.A.Luck Conflict of Interest
added. Membership
accreditation activities
added.
2.0 10.2015 ISSUED
2.1 10.2016 Registered logo
included
3.0 10.2016 ISSUED

Document Review

Reviewer Position
President CREST Executive

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 Conflict of Interest and
Impartiality Policy

CONTENTS
Page No.

1. Conflict of Interest Policy.............................................................................................4

1.1 Introduction .....................................................................................................................4

1.2 Examples of Conflicts of Interest ....................................................................................5
1.3 Responsibilities ...............................................................................................................5
1.4 Behaviour ........................................................................................................................5
1.5 The Process ....................................................................................................................6

2. Impartiality Policy .........................................................................................................8

2.1 Individual Certification .....................................................................................................8

2.1.1 The Policy ...........................................................................................................8

2.2 Corporate Membership Accreditation ...........................................................................10

2.2.1 The Policy .........................................................................................................10

Annex A
Impartiality Risk Assessment Process: Individual Certification................................................12

Annex B
Impartiality Risk Assessment Process: Corporate Membership Accreditation ........................14

Amendment List .........................................................................................................................15

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 Conflict of Interest and
Impartiality Policy

1. CONFLICT OF INTEREST POLICY

A conflict of interest is typically defined as “a set of circumstances that creates a risk that
professional judgement or actions regarding a primary interest will be unduly influenced by a
secondary interest”.

Policy Definitions
“CREST” means CREST (GB) Ltd. or any of its legal entities.

“Employee” means a person directly employed by CREST or appointed by CREST (including

Directors and Executive members) or contracted by CREST (including Assessors) to act on their
behalf.

1.1 Introduction

A conflict may arise whenever an outside interest might influence, or be perceived to be capable of
influencing, a person’s judgement.

Some outside interests will create a clear conflict. Others will not do so but may nonetheless
prompt the need to take some action on a prudential basis.

Potential conflicts may be identified at the outset of an activity, arbitration or investigation; others
may only become apparent as the work develops, and circumstances change (eg. because of the
involvement of a new party, or a change in personal circumstances). If any doubts arise as to the
propriety of an outside interest, or as to the compatibility of a relationship, CREST should be
informed of all relevant facts.

All employees and Directors of CREST will strive to avoid any conflict of interest between the
interests of CREST on the one hand and personal, professional and business interests on the other.
This includes avoiding actual conflicts of interest as well as the perception of conflicts of interest.

The objective of this Policy is to

i. protect the integrity of CREST’s services and decision-making process;

ii. to enable stakeholders to have confidence in the organisation’s integrity; and
iii. to protect the integrity and reputation of CREST and its employees by means of effective
measures.

CREST is committed to protecting itself from the harm that is caused by such situations.

This policy is meant to supplement good judgment, and staff and Directors should respect its spirit
as well as its wording.

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 Conflict of Interest and
Impartiality Policy

1.2 Examples of Conflicts of Interest

Examples of conflicts of interest include, but are not limited to:

i. An Employee who is related to a member of staff and there is a decision to be taken on staff
pay and/or conditions;
ii. An Employee who is also on the board of another organisation that is competing for the same
contract
iii. An Employee who has shares in a business that may be awarded a contract to do work or
provide services for CREST or is a director, partner or employee or related to someone who
is.

Note that a relative may be a child, parent, grandchild, grandparent, brother, sister, spouse or civil
partner of the Employee or any person living with the Employee as his or her partner.

1.3 Responsibilities

All persons employed, directly or indirectly, by CREST owe a duty of fidelity to CREST and must
never place themselves in a position where their self-interest may conflict with this duty.

Any employee who breaches this policy is subject to disciplinary action, up to and including
dismissal.

1.4 Behaviour

All employees of CREST are expected to comply with the following:

1.3.1 Duty of Fidelity

Employees owe a duty of loyalty and fidelity to CREST. Employees are expected to perform their
duties on behalf of CREST faithfully, diligently and to the best of their abilities.

1.3.2 Conflict of Interest

Employees must never allow themselves to be placed in a position where their personal interests
are in conflict (or could be in conflict) with the interests or business of CREST.

Employees must avoid any situation or activity that compromises, or may compromise, their
judgement or ability to act in the best interest of CREST.

1.3.3 Harm to Business or Reputation

Employees must refrain from engaging in conduct that could adversely affect CREST’s business or
reputation. Such conduct includes, but is not limited to:

i. publicly criticising CREST, its management or its employees; or

ii. engaging in criminal conduct or other behaviour that could harm CREST’s business
or reputation.

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 Conflict of Interest and
Impartiality Policy

1.3.4 Outside Employment or Business Activity

During working hours, employees are expected to devote their full time and attention to the business
and the affairs of CREST.

If an employee wishes to engage in employment or business activity outside his/her employment

with CREST, the employee must first disclose to CREST the nature and extent of the proposed
employment or business activity, and obtain CREST’s written approval. Approval will only be
withheld if CREST reasonably determines that the employee’s proposed outside employment or
business activity could conflict or compete with the interests of CREST, or could negatively affect
the employee's job performance or attendance.

1.5 The Process

1.5.1 Disclosure of Potential Conflicts

Upon appointment Employees will make a full and written disclosure of interests, such as
relationships, posts held, ownerships or business interests (other than non-controlling investments
in publicly-traded corporations), whether direct or indirect, that the Employee or a member of his/her
immediate family has with any person, or in any business or enterprise and that could potentially
result in a conflict of interest.

These written disclosures will be retained by the CREST Operations Manager who will ensure their
maintenance on an ongoing basis. The Register of Interests for the CREST Executive will be
updated quarterly at each meeting of the CREST Executive. Disclosures from the CREST
Assessors will be updated at the regular meetings of the CREST Assessors’ Panel.

The CREST Executive Register of Interests will be held at \CREST EXECUTIVE\Register of Interests
which will also include any disclosures from the CREST Assessors. Further detailed procedures for
Assessors is included in the CREST Certification Procedure.

In addition, during the course of meetings or activities, Employees will disclose any interests in a
transaction or decision where there may be a conflict between CREST’s best interests and the
Employee’s best interests or a conflict between the best interests of two organisations that the
Employee is involved with. If in doubt the potential conflict must be declared anyway and
clarification sought.

1.5.2 Protective Steps

Upon disclosure of the information described at 1.5.1 above, CREST will take appropriate steps to
protect against any actual or potential conflict of interest. Such steps may include:

i. requiring the employee to refrain from being involved in any decisions made by
CREST regarding its dealings with such person, business or enterprise; or
ii. requiring the employee to refrain from being involved in any dealings on behalf of
CREST with such person, business or enterprise; or
iii. requiring the employee to dispose of his/her interest in such business or enterprise if
he/she wishes to remain in CREST’s employ.

In the case of a conflict of interests arising for an Employee because of a duty of loyalty owed to
another organisation or person and the conflict is not authorised by virtue of any other provision, for
example in Articles of Association, the unconflicted Employees may authorise such a conflict of
interests where the following conditions apply:

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 Conflict of Interest and
Impartiality Policy

i. the Employee who has declared the conflict of interest withdraws from the part of the meeting
at which there is discussion of any arrangement or transaction affecting that other
organisation or person;
ii. the Employee who has declared the conflict of interest withdraws from the activity affecting
that other organisation or person;
iii. the Employee who has the conflict of interest does not vote on any such matter and is not to
be counted when considering whether a quorum of Directors is present at the meeting;
iv. the other Employees who have no conflict of interest in this matter consider it is in the
interests of CREST to authorise the conflict of interest in the circumstances applying.

Any such disclosure and the subsequent actions taken will be noted in any meeting Minutes as
appropriate.

IAN GLOVER
President of CREST GB Ltd

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 Conflict of Interest and
Impartiality Policy

2. IMPARTIALITY POLICY

Impartiality is typically defined as “not favouring one side over another”.

2.1 INDIVIDUAL CERTIFICATION

This policy should be read in conjunction with the CREST Conflict of Interest policy.

Policy Definitions
“CREST” means CREST (GB) Ltd. or any of its legal entities.

CREST Executive” means the body elected by the members companies to whom operational
responsibility has been delegated by the legal Directors

“Customers”, in the context of individual certification, means candidates sitting a CREST

examination

2.1.1 The Policy

On the basis of that definition, CREST hereby confirms implementation and adherence to the
following policies:

2.1.1.1 CREST will ensure that the value of certification is upheld, the services of CREST shall be
available to all users of Certification and such services shall be applied in a manner
necessary to preserve impartiality, objectivity, independence, freedom from conflict of
interest, freedom from bias, lack of prejudice, neutrality, fairness, open-mindedness, even-
handedness, detachment and balance.

2.1.1.2 CREST (including its licensees, subsidiaries and auditors) shall not participate in the
designing, implementation or maintenance (including Internal Audit) of the management
systems of its Certification customers and shall not have been engaged in such activities
in the two years prior to the customer’s receipt of CREST’s Certification services.

2.1.1.3 CREST undertakes to instil confidence in the delivery of its Certification services to
customers and parties that have an interest in Certification. This shall be achieved by
upholding the principles of impartiality (including taking action against threats, ie. from self-
interest, self-review, familiarity, intimidation), competence, responsibility, openness,
confidentiality and responsiveness to complaints.

2.1.1.4 In the management of impartiality, CREST recognises the possibilities for conflicts of
interests arising from relationships of those persons or organisations having an interface
with CREST. This includes staff, sub-contractors and licensees. Please also refer to the
CREST Conflict of Interest policy for further guidance.

2.1.1.5 CREST undertakes to complete a thorough assessment of the risks to impartiality and to
determine the action to be taken to eliminate or minimise those risks. The risk
assessment process will be on-going and will be maintained through CREST's Executive
and associated Management Review process. Please refer to Annex A of this Policy.

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 Conflict of Interest and
Impartiality Policy

2.1.1.6 CREST shall maintain up to date operating procedures including processes for individual
certifications and appeals and will ensure that these procedures support impartiality.
These procedures are contained in the Certification Procedure and the Certification
Appeals Handling Process.

2.1.1.7 CREST undertakes a full review of its various insurances with a specialised broker on an
annual basis regarding the insurance cover that CREST may require in the conduct of its
business as an accredited certification body operating domestic and overseas certification.
The Directors of CREST have accepted that the following Insurance provision is
necessary to maintain CREST with proper insurance cover; [General Insurance, £1m;
Professional and Legal Liability, £2m; Public Liability, £2m; Cyber Risk, £2m]. Such
insurance cover requirements will continue to be reviewed on an on-going basis by
CREST and adjusted accordingly.

2.1.1.8 From time to time CREST is required to evaluate its systems, procedures and practices to
ensure that impartiality in its certification is maintained. Parties with an interest in the
certification services of CREST are invited, by virtue of this policy, to submit any
proposals, comments or relevant observations on the services of CREST, such that these
may be considered by CREST as part of its evaluation process for continual improvement.

2.1.1.9 Parties with an interest in certification include:

- Applicants to the Scheme;
- CREST Member Companies;
- CREST Qualified Individuals;
- Clients of certified companies;
- Governmental Authorities;
- Non-Governmental organisations and trade bodies;
- Consumers and members of the public.

All comments may be addressed to the President.

2.1.1.10 Consultancy organisations are an established part of the certification implementation

process. CREST will co-operate with outside organisations for the benefit of its members
but will have no direct affiliation with management/product system consultancy
organisations. CREST will take action to correct inappropriate claims of affiliation (stated
or implied) by any consultancy or other organisation that suggests directly, or indirectly,
that certification would be simpler, easier, faster or less expensive by virtue of their co-
operation with CREST.

IAN GLOVER
President of CREST GB Ltd

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 Conflict of Interest and
Impartiality Policy

2.2 CORPORATE MEMBERSHIP ACCREDITATION

This policy should be read in conjunction with the CREST Conflict of Interest policy.

Policy Definitions
“CREST” means CREST (GB) Ltd. or any of its legal entities.

“CREST Executive” means the body elected by the members companies to whom operational
responsibility has been delegated by the legal Directors

“Customers”, in the context of corporate membership accreditation, means

organisations/companies/firms applying to become corporate members of CREST.

2.2.1 The Policy

On the basis of the definition on page 8, CREST hereby confirms implementation and adherence to
the following policies:

2.2.1.1 CREST will ensure that the value of corporate membership accreditation is upheld, that
the services of CREST shall be available to all organisations that wish to apply and that
such services shall be applied in a manner necessary to preserve impartiality, objectivity,
independence, freedom from conflict of interest, freedom from bias, lack of prejudice,
neutrality, fairness, open-mindedness, even-handedness, detachment and balance.

2.2.1.2 CREST (including its licensees, subsidiaries and auditors) shall not participate in the
designing, implementation or maintenance (including Internal Audit) of the management
systems of its corporate membership accreditation customers and shall not have been
engaged in such activities in the two years prior to the customer’s receipt of CREST’s
Certification services.

2.2.1.3 CREST undertakes to instil confidence in the delivery of its corporate membership
accreditation services to customers and parties that have an interest in such accreditation.
This shall be achieved by upholding the principles of impartiality (including taking action
against threats, ie. from self-interest, self-review, familiarity, intimidation), competence,
responsibility, openness, confidentiality and responsiveness to complaints.

2.2.1.4 In the management of impartiality, CREST recognises the possibilities for conflicts of
interests arising from relationships of those persons or organisations having an interface
with CREST. This includes staff, sub-contractors and licensees. Please also refer to the
CREST Conflict of Interest policy for further guidance.

2.2.1.5 CREST undertakes to complete a thorough assessment of the risks to impartiality and to
determine the action to be taken to eliminate or minimise those risks. The risk
assessment process will be on-going and will be maintained through CREST's Executive
and associated Management Review process. Please refer to Annex B of this Policy.

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 Conflict of Interest and
Impartiality Policy

2.2.1.6 CREST shall maintain up to date operating procedures including processes for corporate
membership accreditation and appeals and will ensure that these procedures support
impartiality. These procedures are contained in the Corporate Membership Application
and Renewals Process and the Membership Appeals Process.

2.2.1.7 CREST undertakes a full review of its various insurances with a specialised broker on an
annual basis regarding the insurance cover that CREST may require in the conduct of its
business as a corporate membership accreditation body operating domestic and overseas
accreditations. The Directors of CREST have accepted that the following Insurance
provision is necessary to maintain CREST with proper insurance cover: General
Insurance, £1m; Professional and Legal Liability, £2m; Public Liability, £2m; Cyber Risk,
£2m]. Such insurance cover requirements will continue to be reviewed on an on-going
basis by CREST and adjusted accordingly.

2.2.1.8 From time to time CREST is required to evaluate its systems, procedures and practices to
ensure that impartiality in its corporate membership accreditation is maintained. Parties
with an interest in the corporate membership accreditation services of CREST are invited,
by virtue of this policy, to submit any proposals, comments or relevant observations on the
services of CREST, such that these may be considered by CREST as part of its
evaluation process for continual improvement.

2.2.1.9 Parties with an interest in certification include:

- Applicants to the Scheme;
- CREST Member Companies;
- Clients of accredited companies;
- Governmental Authorities;
- Non-Governmental organisations and trade bodies;
- Consumers and members of the public.

All comments may be addressed to the President.

2.2.1.10 CREST will co-operate with outside organisations for the benefit of its members but will
have no direct affiliation with management/product system consultancy organisations.
CREST will take action to correct inappropriate claims of affiliation (stated or implied) by
any consultancy or other organisation that suggests directly, or indirectly, that corporate
membership accreditation would be simpler, easier, faster or less expensive by virtue of
their co-operation with CREST.

IAN GLOVER
President of CREST GB Ltd

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 Conflict of Interest and
Impartiality Policy

ANNEX A

IMPARTIALITY RISK ASSESSMENT PROCESS - INDIVIDUAL CERTIFICATION

This process should be read in conjunction with the CREST Conflict of Interest policy.

1. The CREST Assessors Panel will meet regularly to evaluate the content and currency of the
CREST examinations and receive any Conflict of Interest disclosures. They will implement
the requisite changes and submit their report to the CREST Executive as necessary.

2. The CREST Executive will oversee and regularly evaluate all aspects of business activity to
ensure operations are carried out responsibly, openly, independently and objectively and
that all individuals, as well as those with previous certification(s), are treated alike. This will
guarantee that CREST certification maintains its high standards and integrity.

3. At its quarterly Executive meetings the CREST Executive will, under the direction of the
Operations Representative and the Assessors’ Representative, identify and analyse the
possibilities of conflicts of interest arising from its relationships and the delivery of its
assessment, verification and certification schemes.

4. Threats to impartiality that will be considered include, but are not limited to:

4.1 Self-interest threats (those arising from a person or body acting in its own interest to
benefit itself), such as: Companies assessing employees, Assessors assessing co-
workers, crib sheets from examinations, repetition of examinations in order to
achieve full set.

4.2 Subjectivity threats (those arising when personal bias overrules objective evidence),
such as: Companies assessing competitors, Assessors assessing competitors or
friends.

4.3 Familiarity threats (those arising from a person being familiar with or trusting of
another person, eg. an examiner or certification body personnel developing a
relationship with a candidate that affects the ability to reach an objective judgement),
such as: Assessors coaching candidates or training potential candidates, Coaching
of co-workers.

4.4 Intimidation threats: such as those that prevent a certification body or its personnel
from acting objectively due to fear of a candidate or other interested party;

4.5 Financial threats: the source of revenue for a certification body can be a threat to
impartiality.

5. Where threats of impartiality are identified, the provisions defined by the CREST Assessors’
Panel to eliminate or minimise such threats will be documented along with data
demonstrating their on-going effectiveness.

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 Conflict of Interest and
Impartiality Policy

6. These will be made available to the Executive by the Assessors Panel for their consideration
as part of the ongoing review of impartiality of the audit, certification and decision making
process of CREST.

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 Conflict of Interest and
Impartiality Policy

ANNEX B

IMPARTIALITY RISK ASSESSMENT PROCESS – CORPORATE MEMERSHIP

ACCREDITATION

This process should be read in conjunction with the CREST Conflict of Interest policy.

1. The CREST Executive have responsibility for the content and currency of the CREST
corporate membership accreditation process. They will implement requisite changes and
minute their findings as necessary and ensure consistent, impartial provision of accreditation
activities where no single interest can predominate.

2. The CREST Executive will oversee and evaluate all aspects of business activity to ensure
operations are carried out responsibly, openly, independently and objectively and that all
applicant companies are treated alike. This will guarantee that CREST corporate
membership accreditation maintains its high standards and integrity.

3. At its quarterly meetings the CREST Executive will, under the direction of the Operations
Representative, identify and analyse the possibilities of any conflicts of interest arising from
its relationships and the delivery of its corporate membership accreditation.

4. Threats to impartiality that will be considered include, but are not limited to:

4.1 Self-interest threats (those arising from a person or body acting in its own interest to
benefit itself), such as: commercial or other considerations preventing impartial
accreditation activity.

4.2 Subjectivity threats (those arising when personal bias overrules objective evidence),
such as: personal business interest in applicant company.

4.3 Familiarity threats (those arising from a person being familiar with or trusting of
another person, eg. accreditation body personnel developing a relationship with a
company that affects the ability to reach an objective judgement), such as:
relationship, business or personal, with individuals in applicant company.

4.4 Intimidation threats: such as those that prevent an accreditation body or its
personnel from acting objectively due to fear from the applicant company or other
interested party;

4.5 Financial threats: the source of revenue for an accreditation body can be a threat to
impartiality.

5. Where threats of impartiality are identified, the provisions defined to eliminate or minimise
such threats will be documented along with data demonstrating their on-going effectiveness.

6. These will be made available from the Executive and form part of their deliberations during
the ongoing review of impartiality of the audit, accreditation and decision making process of
CREST to ensure no single interest predominates.

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 Conflict of Interest and
Impartiality Policy

Amendment List

This document has been amended in the areas described below:

a. Section reference Description of Changes Authorised by

b. Date Issued
c. Clause Reference

a. 1 Conflict of Interest policy added E.A. Luck

b. 15.09.2015

c. New section

a. 2.2 CREST Membership E.A. Luck

accreditation activities included
b. 15.09.2015

c. New section

a. 2 Update to CREST insurance E.A. Luck

cover
b. 04.09.2015

c. 2.1.1.7 / 2.2.1.7

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