CERES' Policy
 

No	Subject	Text
1	Aims	This policy aims at assuring the independent performance of inspection and certification work.
2	Back­ground	Private certification involves several immanent conflicts of interest. The key point is a certain contradiction between the relationship "controller – controlled opera­tor", on one side, and the relationship "service provider – client" on the other. This conflict cannot be completely overcome, but awareness of the problem and clear rules for all staff must minimize the risk of unfair decisions.
3	Norma­tive frame­work	EN 45011 defines: •   4.1.1:The policies and procedures under which the certification body operates and their administration shall be non-discriminatory, and shall be adminis­tered in a non-discriminatory manner. Procedures shall not be used to impede or inhibit access by applicants, other than as provided for in this Stan­dard. •   4.2 The certification body shall a)    Be impartial e)    Have a documented structure which safeguards impartiality f)      Ensure that each decision on certification is taken by a person(s) different from those who carried out the evaluation e)    Together with its senior executive and staff, be free from any commercial, financial and other pressures which might influence the results of the certification process NOP says: 205.501 (a) A private or State entity accredited as a certifying agent under this subpart must: (11) Prevent conflicts of interest by: (i) Not certifying a production or handling operation if the certifying agent or a responsibly connected party of such certifying agent has or has held a commercial interest in the production or handling operation, including an immediate family interest or the provision of consulting services, within the 12-month period prior to the application for certification; (ii) Excluding any person, including contractors, with conflicts of interest from work, discussions, and decisions in all stages of the certification process and the monitoring of certified production or handling operations for all entities in which such person has or has held a commercial interest, including an immediate family interest or the provision of consulting services, within the 12-month period prior to the application for certification; (iii) Not permitting any employee, inspector, contractor, or other personnel to accept payment, gifts, or favors of any kind, other than prescribed fees, from any business inspected, except that a certifying agent that is a not-for-profit organization with an Internal Revenue Code tax exemption, or in the case of a foreign cer­tifying agent a comparable recognition of not-for-profit status from its government, may accept voluntary labor from certified operations; (iv) Not providing advice concerning organic practices or techniques to any certification applicant or certified operation for a fee, other than as part of the fees un­der the applicable certification program established under the Act; and (v) Requiring all persons identified in § 205.504(a)(2) to complete an annual con­flict of interest disclosure report.
4	Terms	None.
5	Policy
5.1	Exclusion: •    CERES inspectors and certification officers may not perform inspection, or make or influence in certification decisions in case of operators, Who are their relatives or personal friends Who are or have been their employees or employers, or for whom they have worked as external consultants o        With whom they have or have had any kind of personal conflict, not directly related to inspection/certification issues. •    An inspector must not control the same operation for more than three consecutive years, with­out external supervision or an independent inspection performed by another inspector to the same operator.
5.2	Prevent corruption: CERES inspectors may not accept: •    Direct payment of inspection certification services, in cash or to their private bank account •    Gifts with a value higher than 15 Euro (20 USD). •    Invitations to inappropriately luxurious hotels, restaurants, etc. •    Invitations to locations or events, which might compromise the inspector's and/or certification body's reputation.
5.3	Prices, payment, acquisition: •    Based on a clear pricing scheme (see Document 9.4), CERES will charge the same price for similar operators in the same country. •    CERES will never charge volume or turnover-based fees. We work only on a flat fee base, or with daily fees, depending on the situation. •    Wherever possible, acquisition of new clients and inspection should be separated. This means, that, wherever possible, at least two persons should work for CERES in a country or region, and that the person, who acquired the new client, should be different from the person who performs the first inspection. This rules only for active acquisitions, not fro cases, where the client himself approaches CERES.
5.4	Decisions by the certification officer: •    In case of doubts concerning certification decisions, the responsible certification officer is obliged to consult at least with one colleague. In case that the two cannot find a consensus, they must consult with external specialists and/or competent state authorities. In especially difficult or important cases, the CERES advisory committee has to be consulted.
5.5	Financial dependence on particular clients: •    Except for the starting period of maximum one year, no single client must contribute with more than 10% to CERES' annual turnover •    Except for the starting period of maximum one year in a new country or region, a freelance in­spector must not depend with more than 20% of his/her annual income on one client.
5.6	Avoiding "company blindness": •    CERES inspectors and certification officers are encouraged to exchange information, criteria, and experiences regularly with colleagues from other certification bodies, both at a day-to-day basis, and at a formalized level. This will help to challenge company-specific points of view, and make criteria and decisions more objective.
5.7	Sanctions: •    Inspectors or other staff, who have been proven to o      Accept corrupting gifts o      Suppress consciously significant non-conformities or otherwise alter important data in their inspection reports o      Help operators to hide significant non-conformities o      Consciously not inform CERES about an excluding relationship with a client (see 5.1)        will be dismissed immediately.
6	Access to this policy	•    This policy is available to all interested public •    It must be handed out to all CERES certification and inspection personnel