TM RSJ Inspection · 2019-10-04 · RSJ InspectionTM-Complete Conformity Solutions Quality Manual...

RSJ Inspection

TM

-Complete Conformity Solutions Quality Manual

IAAC Division IFIA/ TIC Council - Compliance Programme

Section No. - 12

Revision No. 05 w. e. f. 21-09-2019

of 30

Introduction RSJ’s core values are integrity, impartiality, confidentiality, honesty, trust, respect, commitment & responsibility. Company’s reputation and customer relations are built on these values. Business growth and improvement drives are in correlation with these values. Placing these values at core & high intensity level, Ethics & Conduct Code (RSJ_HR_FT_04A) are structured. Associate means all Employee(s) including Quality Engineer(s), Senior Quality Engineer(s), Auditor(s), witness auditor, external witness auditor or other personal providing technical / Audit service to the RSJ. Here after referred to as “Associate(s)”. Ethics & Conduct Code (RSJ_HR_FT_04A) principles facilitate all associates, stakeholders & business partners to fabricate alignment with the RSJ values, vision and mission. It is shared with stakeholders & business partners to create awareness about our work culture; hence the relation starts on sturdy foundation & last eternally. For associates it’s obligatory to follow Ethics & Conduct Code (RSJ_HR_FT_04A) supported by Code of Conduct which provides a framework of simple Do’s and Not permitted (Don’ts). RSJ expectation is that the ethics & values to reflect in all RSJ business activities and in our associate’s work & behaviours. RSJ is implementing IFIA/ TIC Council compliance programme as expansion and in accordance with its existing Ethics & Conduct Codes (RSJ_HR_FT_04A) and Code of Conducts(RSJ_HR_FT_04) principles/ programme. IFIA/ TIC Council -The International Federation of Inspection Agencies is a trade federation that represents over total of approximately 90-member companies and organizations active in more than 160 countries, spanning every continent. IFIA’s / TIC ‘s compliance program reflects the transparent international and social responsibility of international organizations on a global scale for areas of anti-corruption / bribery and other related issues. This programme is structured in 3 phases, 1. Compliance Principles and its application cover 7 principles in this section,

Integrity Conflict of Interest Confidentiality and Data Protection Anti-bribery Fair business conduct Health and Safety Fair labour

2. Implementation of Compliance programme

Approval of the code implementation by IFIA/ TIC Council Compliance Program throughout the Organization Policies and procedures in accordance with the Code Training of staff globally, and Regular monitoring of compliance with the Code.

3. Verification of compliance programme implementation effectiveness The nominated internal auditor(s) shall perform internal audit(s) to ensure the implementation throughout the organization and that the Management declarations have been completed. Effectiveness of the implementation shall be verified at least annually by the RSJ's appointed

RSJ Inspection

TM



Section No. - 12

Revision No. 05 w. e. f. 21-09-2019

of 30

independent external audit firm based on agreed procedures and results are reported to IFIA/ TIC Council.

The below table provides overview of the programme,

1. Compliance Principles and its application

1.1. Integrity 1.2. Conflicts of interest 1.3. Confidentiality and Data Protection 1.4. Anti-bribery

1.4.1. Compliance with laws 1.4.2. Analysis of risks 1.4.3. Business principles for countering bribery

1.5. Fair business conduct 1.6. Health and Safety 1.7 Fair labour

1.4.3. Business principles for countering bribery 1.4.3.1. Political contributions 1.4.3.2. Charitable contributions and sponsorships 1.4.3.3. Facilitation payments 1.4.3.4. Gifts, hospitality and expenses

2. Implementation of Compliance programme 2.1. Management Commitment 2.1.1. Implementation 2.1.2. Compliance principles and rules 2.1.3. Compliance officer 2.1.4. Compliance committee

2.2. People Experience 2.2.1. Recruitment 2.2.2. Employee commitment 2.2.3. Training 2.2.4.Employee “Helplines”

2.3. Safegaurding confidential business information

2.3.1. Security Measures

2.4. Communication2.4.1. External communications 2.4.2. Internal communication 2.4.3. Reporting of violations

2.5. Complaint handling 2.5.1. Investigation and sanctions 2.5.2. Business relationships 2.5.3. Complaints and disciplinary procedures

2.6. Accounting and bookkeeping

2.7. Health & Safety 2.8.Compliance Summary Report

3. Verification of compliance programme implementation effectiveness

3.1. Effectiveness monitoring – Internal 3.1.1. Management declaration 3.1.2. Internal audits

3.2. Effectiveness monitoring – External Verification

3.2.1. Frequency 3.2.2. Appointment of audit firm 3.3. Notification to IFIA/ TIC Council of RSJ’s appointed audit firm(s) 3.3.1. Scope of Verification 3.2.4.1. Submit documents for verification to IFIA/ TIC Council

3.2.4.2. Request audit firm to carry out verification based on agreed upon procedures 3.3.2. Independent external audit firm’s Report

RSJ Inspection

TM



Section No. - 12

Revision No. 05 w. e. f. 21-09-2019

of 30

1.0.Compliance Principles and its application

We have established Ethics and conduct code (RSJ_HR_FT_04A) and Code of Conduct for Associates (RSJ_HR_FT_04) which covers compliance principles. Refer these documents for detailed information. 1.1. Integrity

1.1.1 RSJ is committed to conduct its business and govern itself with integrity in a manner that is ethical, transparent and accountable. 1.1.2 RSJ and its associate(s) are committed to being honest & to ensure impartiality and independent in providing Third Party Inspection, Audit, Product Certification and Assessment services by,

a. Carrying out assigned work in a professional, objective and impartial manner. Inappropriate behavior is not allowed, and RSJ has zero tolerance for violation of Integrity, Impartiality, Confidentiality and Codes.

b. Work shall be carried out honestly, with no influence tolerated in respect to any deviation from either approved methods and procedures or the accurate reporting of results. Data, assessment results, test results and other material facts shall be reported by Associate(s) as factually observed and will not be altered.

c. Being neutral and financially/commercially independent and not to surrender under pressure and inducements to misrepresent findings or alter the results.

1.1.3. RSJ_HR_FT_04 Code of conduct for Associates and RSJ_HR_FT_06_Safety instruction provide guidance to all the associates for dealing with the clients in case where they expect that RSJ to abuse tolerances to obtain acceptable results. 1.1.4. Integrity is being monitored at RSJ as per procedure PM 02+ Supervisory checks - Service performance evaluation and monitoring procedure. Please refer PM 02+ Supervisory checks - Service performance evaluation and monitoring procedure for detailed integrity monitoring process. 1.1.5. RSJ is complying with the integrity rules published by IFIA/ TIC Council and committed to follow sector specific integrity rules whenever it enters new sectors. 1.2. Conflict of Interest

1.2.1. In order to avoid conflict of interest, or the appearance of conflict of interest, in the RSJ business transactions and services, RSJ has maintained the policy regarding the conflict of interest and same has been communicated to all associates through Ethics and conduct code (RSJ_HR_FT_04A) and Code of Conduct for Associates (RSJ_HR_FT_04). 1.2.2. RSJ associate(s) should declare to compliance officer through RSJ_INSP_FT_99_COI declaration form and withdraw from the service if they are affected by a potential conflict of interest situations which

RSJ Inspection

TM



Section No. - 12

Revision No. 05 w. e. f. 21-09-2019

of 30

arises from any personal relationships, external interests or activities that could interfere with their judgment, objectivity, independence or loyalty of the reporting. 1.2.3. Conflicts of interest can arise in many ways. If not clear, associates should seek guidance from Integrity Manager. 1.2.4. RSJ is a clean third-party conformity assessment body and does not have any other related organization, or activity that presents any conflict of interest with third party conformity assessment services. RSJ does not have any direct or indirect financial or commercial interest in any other organization. 1.2.5. Family members of RSJ associates shall be recruited to work with RSJ, with the explicit approval of top management.

1.2.6. Rsj associates shall not hold any position with client / competitor such as director, advisor, consultant, etc. 1.2.7. The policy regarding conflict of interest covered in Ethics & Conduct Code section 1 (Impartiality). RSJ conduct annual COI analysis and identify mitigating actions to all significant COI risks through RSJ_INSP_FT_100_RISK ANALYSIS. 1.2.8. RSJ’s Procedural Manual, PM 11+ Safeguarding Impartiality Procedure, covers at the following levels to protect impartiality, to avoid conflict of interest or the appearance of conflict of interest.

1.2.8.1 Safeguarding impartiality at policy level. 1.2.8.2 Safeguarding impartiality at organization level 1.2.8.3 Safeguarding impartiality at operational level 1.2.8.4 Reviewing effectiveness of the above measures 1.3. Confidentiality and Data Protection– Safeguarding confidential business information

1.3.1. RSJ and its associate(s) shall treat all information received in the course of the provision of its services as commercial-to-confidence to the extent that such information is not already published or made generally available to third parties or otherwise in the public domain. It is RSJ’s responsibility to protect our clients and their factory’s information including details of the factory and shipment.

1.3.2. RSJ is committed to maintain confidentiality and to ensure that all the information in our database remains accurate and complete and are protected from unauthorized access and use. The unauthorized disclosure, of any of the Company's confidential business information or intellectual property such as financial data, formulae, processes, advertising methods or prospective transactions, to any other person, firm or corporation is prohibited to all associates of the company while in employment as well as after severance of the employment. Similarly, the use directly or indirectly of confidential Company business information, for personal benefit or for the benefit of immediate family or for the benefit of any other person, firm or corporation is prohibited to all associates of the company while in employment as well as after severance of the employment. The use of such information generally to the possible detriment of the Company also is prohibited.

RSJ Inspection

TM



Section No. - 12

Revision No. 05 w. e. f. 21-09-2019

of 30

1.3.3. All RSJ associates acknowledge the non-disclosure agreement at several stages of their employment as follows,

Sr. No.

Document Period Stakeholder

1. RSJ_HR_FT_ 04_Code of Conduct for associates and RSJ_HR_FT_04A_ Ethics and Conduct Code

At the time of job offer / annually and whenever it is updated

All

2. Appointment / empanelment letter Before joining All

3. Confirmation letter At the time of confirmation Full time associate

4. Service condition form During each IAAC activity QE / Auditor / Assessor

1.3.4. RSJ ensures that all intermediaries, joint venture partners, agents, subcontractors, franchisees, contractors and suppliers are made aware of the confidential nature of business information that they may handle through their dealings with RSJ, and that they should not disclose confidential information to other parties.

References:

a. RSJ Quality Manual, QM 05+General Requirements - Impartiality, Independence and Confidentiality

Section 4.2 b. Procedural manual – PM 18+ Maintaining Confidentiality - Procedure

1.4. Anti-bribery

RSJ prohibits and has zero-tolerance policy for bribery in any form. As per contractually binding conditions, RSJ associates must never, directly or through intermediaries, offer or promise any personal or any financial or other advantage to obtain or retain a business or other advantage from the stakeholders of RSJ. An associate must not accept any such advantage in return or receive preferential treatment from the stakeholders of RSJ. We consider the offering, promising, giving, accepting or soliciting of an advantage (which could be financial or non-financial), directly or indirectly, as an inducement or reward for a person acting, or refraining from acting, in relation to the performance of that person’s duties.

1.4.1. Compliance with laws

1.4.1.1. RSJ is committed to fully complying with national regulations and laws, including such on anti-corruption and bribery. Relevant national and international anti-bribery law applies whenever arranging or performing services outside India.

1.4.2. Analysis of Risk 1.4.2.1. Risk analysis relating to bribery is conducted once in a year or whenever significant Code of Conduct / integrity breach is observed or reported. In same way, prior to commencement of new service, risk analysis shall be performed in each country of operation.

RSJ Inspection

TM



Section No. - 12

Revision No. 05 w. e. f. 21-09-2019

of 30

1.4.2.2. Identified Risk are evaluated and categorized as significant / non-significant. Mitigation actions are recorded / reviewed for all significant risks. If required, additional mitigation measures are determined for action.

1.4.3. Business principles for Countering Bribery

1.4.3.1. Political contribution

1.4.3.1.1. As per policy, RSJ shall not make any contribution in cash or in kind, to support a political / religious cause in general. This includes gifts of property or services, advertising or promotional activities endorsing a political party, and the purchase of tickets to fundraising events.

1.4.3.2. Charitable contributions and sponsorships

1.4.3.2.1. RSJ shall account all its charitable contributions or sponsorships in a separate ledger and consolidate all such payments made by any of the operations that form part of its organization. RSJ and it’s all associates will ensure that charitable contributions and sponsorships are not being used as a subterfuge for bribery. 1.4.3.3. Facilitation Payments

1.4.3.3.1. Facilitation payments are defined as small payments made to secure or expedite the performance of a routine or necessary action to which the payer of the facilitation payment has legal or other entitlement. 1.4.3.3.2.RSJ associates shall not involve in any facilitation payments. RSJ considers this as a bribe and prohibit them. 1.4.3.4. Gifts, Hospitality and expenses 1.4.3.4.1. RSJ and its associates are prohibited to offer or accept/receipt any tangible or intangible favours, gifts, accommodations, free transportation, hospitality or expense whenever such arrangements could affect the outcome of business transactions and are not reasonable and bona fide expenditures. which may impair or be presumed to impair its professional judgment.

1.4.3.4.2.RSJ will maintain the separate ledger account whenever any gifts or hospitality is offered, or expense made in this regard. 1.5. Fair Business conduct 1.5.1. RSJ is committed to build its professional reputation on the merit of services and to compete fairly with competitors / within Team and guidelines are provided through Ethics and conduct code (RSJ_HR_FT_04A) and Code of Conduct for Associates (RSJ_HR_FT_04). 1.5.2. RSJ conduct itself with the highest standard of business ethics and integrity. Respects the interest and committed to be responsive to all its stakeholders. 1.5.3. RSJ is committed to engage and provide value to its customers in responsible manners.

RSJ Inspection

TM



Section No. - 12

Revision No. 05 w. e. f. 21-09-2019

of 30

1.5.4. RSJ is committed to be responsible & transparent particularly when engaging in influencing public & regulatory policy. 1.5.5. At RSJ, we believe in free competition and strive to outdo our competitors through honest and fair business practices. The management, all employees and associated are committed to make only factual claims and not provide any misleading or incorrect information about our competitor, their operations and their services. 1.5.6. RSJ is committed to adhere to Fair competition & anti-trust provisions and their compliance in accordance with the “Compliance Manual for Enterprises under the competition act 2002” This applies to services provided in India as well as to overseas client. Additionally, specific Fair competition & anti-trust provisions of overseas market are studied for ensuring compliance. RSJ is committed not to indulge in any malpractice relating to obtaining unauthorized information about its competitors when participating in tenders. 1.5.7. The fair business policy includes a strict prohibition to all employees, especially those engage in contractual activities not to obtain any information that is confidentially held by client, competitors through any act of incitement or inducement. RSJ does not support obtaining any information through commercial espionage and/or data theft. 1.5.8. RSJ presents itself & conducts marketing in an ethical manner that is truthful & not deceptive or misleading, including any comparisons / references with its competitors and their services. 1.5.9. RSJ does not,

a. pays or offer improper incentives in any form for securing RSJ’s business. b. makes untrue statements about competitors, their operations, services or service offerings; C. Indulge in or support activities contrary to rules for fair competition, anti-trust or tendering; d. Incite, induce or encourage any person to breach its contractual obligations (including obligations of confidentiality); e. Indulge in or support commercial espionage and/or data theft.

1.6. Health and Safety 1.6.1. RSJ is committed to provide its services in a manner that is sustainable and safe. 1.6.2. Associate(s) safety is the first priority than anything else. RSJ holds paramount the safety, health, and welfare of the public in the performance of professional duties. 1.6.3. RSJ is firmly committed to a policy enabling all work activities to be carried out safely, and with all possible measures taken to remove (or at least reduce) risks to the health, safety and welfare of associates and anyone else who may be affected by our operations. 1.6.4. Associates have been advised to immediately terminate their work when there is threat to their own safety.

1.6.5. In case the intimidation at the work premises amounts to inflicting injury or threat to their personal safety, RSJ Associate has been advised to tactfully extricate themselves from the immediate

RSJ Inspection

TM



Section No. - 12

Revision No. 05 w. e. f. 21-09-2019

of 30

situation, make themselves safe and subsequently report the full details of the incident to the management.

1.6.6. The company provides facilities to enable reporting of such conditions through Onsite incident report (RSJ_ INSP_ FT_ 91) and normal channel.

1.6.7. RSJ associates shall ensure that all safety instructions given in RSJ_HR_FT_06 being followed on site to work in safe environment.

1.6.8. The induction training imparted to all fresh recruits includes specific modules on health and occupational hazards including safety risks during on site work.

1.6.9. Health and Safety related incidents reported are recorded and investigated further. In case required, corrective measures are taken. 1.6.10 Procedure PM-21+Health and safety incident reporting and investigations procedure has been established for reporting health & safety incidents and conducting investigations.

1.7. Fair labour 1.7.1. Each associate is required to respect the rights and cultural differences of individuals. RSJ is committed to following the applicable labour and employment laws including working time wherever it operates. These include laws pertaining to freedom of association, privacy, child labour and discrimination.

1.7.2. RSJ strongly believes it has the responsibility to engage in employment practices that meet the highest legal and ethical standards, ensuring that no associate will suffer undue harm because he or she raises an issue, reports a Code violation or cooperates with an investigation.

1.7.3. RSJ ensures equal employment opportunity (Examples are hiring, compensation, access to training, promotion, termination or retirement) without discrimination or harassment based on race, colour, religion, caste, sex, sexual orientation, gender identity or expression, age, disability, marital status, citizenship, national origin, genetic information, union membership, political affiliation or any other characteristic protected by law.

1.7.4. RSJ has zero tolerance on discrimination, harassment, forced / bonded / prisoned labour and human trafficking/modern slavery.

1.7.5. RSJ is committed to:

Ensure that remuneration to all associates including contractual associates meets applicable laws and prescribed limits of minimum wages at all times. Provide freedom to all associates to choose their employment Fair recruitment and prohibits forced or bonded labour make the terms and conditions of employment available to all associates before their

employment is started - no forced or coerced labour shall be tolerated as part of disciplinary measures

RSJ Inspection

TM



Section No. - 12

Revision No. 05 w. e. f. 21-09-2019

of 30

not to use any form of prison labour Provide an opportunity to associates to continue their professional / ethical development in their

careers. Protect associates who, in good faith, make reports, seek advice or ask questions.

2.Implementation of Compliance programme

Implementation of Compliance programme divided into 6 phases, 2.1. Management commitment 2.2. People Experience 2.3. Safegaurding confidential business information 2.4. Communication 2.5. Complaint handling 2.6. Accounting and bookkeeping

2.1. Management commitment:

This is divided into 4 phases, 2.1.1. Implementation 2.1.2. Compliance principles and rules 2.1.3. Compliance officer 2.1.4. Compliance committee

2.1.1. Implementation

2.1.1.1. RSJ has implemented this Compliance Program based on the Compliance Principles of IFIA/ TIC Council, throughout the organization.

2.1.2. Compliance Principles and Rules

2.1.2.1. RSJ Management is committed for implementing its compliance programme by publishing and adopting, addressing all the key elements of IFIA/ TIC Council Compliance Principles and Requirements for implementation throughout its organization. 2.1.2.2. RSJ shall require to submit a copy of its Compliance Programme, within one month of publication, and any subsequent updates, to the Director General for verification of compliance with the IFIA / TIC Council Code.

2.1.3. Compliance officer

2.1.3.1.RSJ Board of Directors has appointed a Compliance officer (Yuvraj Jambhale) which, regardless of his other responsibilities, also has full responsibility and authority for the co-ordination and implementation of RSJ Compliance Program throughout the RSJ.

RSJ Inspection

TM



Section No. - 12

Revision No. 05 w. e. f. 21-09-2019

of 30

2.1.3.2.The Compliance Officer may nominate delegates to perform some or all his/her functions within specified parts of the organization. Additionally, Senior managers throughout the organization shall have responsibility for implementation of the Program in their areas of responsibility.

2.1.4.Compliance committee

2.1.4.1. RSJ Board of Directors has appointed a Compliance committee for the whole group to carry out periodic reviews of the progress of the Compliance Program and provide policy guidance. The compliance committee will conduct the reviews at least once a year. 2.1.4.2. The Compliance Committee consists of CEO, Compliance officer, HR Manger. 2.1.4.3. The terms of reference of the compliance committee are as under a) Review of the IFIA / TIC council compliance principles, program requirements and responsible for overseeing the Compliance Programme. b) Review and approve background of intermediary’s investigation report, if any c) Verifying, reviewing, approving remuneration analysis of intermediaries for its appropriateness and justifiable for legitimate services rendered and does not facilitate improper payments by the intermediary 2.2.People Experience:

The following are covered in this section, 2.2.1. Recruitment 2.2.2. Employee commitment 2.2.3. Training 2.2.4.Employee “Helplines”

2.2.1. Recruitment

2.2.1.1. Prior to job offer, prospective employees shall be informed of the Compliance Programme. 2.2.1.2.IFIA / TIC council compliance programme (weblink) is provided along with offer letter to potential employees. After joining, new recruits shall undergo training on compliance program.

2.2.2. Employee commitment

2.2.2.1. Each Associate is provided with a copy of the Compliance program requested to sign a declaration that it has been received, read and understood. Also, same has been discussed during training programme. A record is kept in the employee’s training file by People experience department.

2.2.2.2. Each department manager is responsible for the departments under their jurisdiction and management of the implementation of the Compliance Program and is subject to the supervision of the Director - Admin.

2.2.2.3. In order to implement the Program, each Senior manager is responsible for the Compliance Program to provide a copy to the staff, and see that they are trained in a simple, practical and concrete

RSJ Inspection

TM



Section No. - 12

Revision No. 05 w. e. f. 21-09-2019

of 30

form, inform them of their responsibilities and make sure they understand the behaviour of any breach of the Program will result in serious discipline.

2.2.2.4. Each Senior Manager shall be required to sign an annual declaration (Annex: A) that the Compliance Program has been implemented in his/her area of responsibility.

2.2.2.5. The Compliance Program is included with provision that employees will not suffer demotion, penalty or any other adverse consequences arising from strict implementation of the Program even if it may result in a loss of business.

2.2.2.6. The implementation of the compliance program shall be made by the internal and external auditor’s regular check and results submitted to the Compliance Committee. Department managers within the company should act in accordance with procedures to prepare compliance reports.

2.2.3. Training

2.2.3.1. All employees, including managers of the RSJ undergo a Compliance training course & records of each employee shall be maintained.

2.2.4.Employee “Helplines”

2.2.4.1. RSJ is committed to implement the compliance programme & each policy should be understood by each employee. Hence RSJ has made a provision for “help line” where its employees obtain guidance on any question or matter of concern relating to the implementation or interpretation of the programme. At the employees request any such question should be dealt with confidentially and the anonymity of the employees should be protected to the extent reasonably practicable. This help lines may utilise by the RSJ employee or external third-party organization.

2.2.4.2. The help line shall be operated by Compliance officer (Yuvraj Jambhale) GB-25, Highstreet Corporate Centre, Kapurbawadi, Thane-400607 Ph-022-41310570 [email protected] www.rsjqa.com

2.3.Safeguarding confidential business information

2.3.1. Security Measures

2.3.1.1. RSJ has implemented adequate security measures in organization premises and containing confidential business information to ensure that access is restricted to authorised personnel. 2.3.1.2. RSJ has webQBMS portal for each employee with own user account and it is password protected. All data in software are protected from virus and secured by daily back up through IT team. 2.3.1.3. All documents are controlled by respective department manager and disposed of in a secure manner.

2.4. Communication

RSJ Inspection

TM



Section No. - 12

Revision No. 05 w. e. f. 21-09-2019

of 30

This is divided into 3 phases, 2.4.1. External communications 2.4.2. Internal communications 2.4.3. Reporting of violations

2.4.1. External communication

2.4.1.1. RSJ has published its compliance program on website www.rsjqa.com. Further RSJ is open to receive any enquiries, feedback, suggestion, complaint and appeal from any stakeholder through website or by e-mail [email protected].

2.4.2.Internal communication:

2.4.2.1. If staff has any questions or concerns about the implementation or interpretation of the Compliance Program, they can always contact their direct manager or "Compliance Officer" for advice.

2.4.2.2. If necessary, the question must be reasonably within the scope of application to ensure confidentiality and anonymity.

2.4.3. Reporting of Violations

2.4.3.1. Employees shall be encouraged to report details of violations or suspected violations / breaches of the program to either (a) the Compliance Officer or (b) the employee's Superior or RSJ’s Senior Management or internal auditor who shall, in turn, inform the Compliance Officer.

2.4.3.2. The reporting employee shall be fully protected against any form of reprisal unless s/he acted maliciously or in bad faith. If requested, the employee's anonymity shall be protected to the extent reasonably practicable.

2.4.3.3. Employee shall be required to report any solicitation for, or offer of, an improper payment or advantage coming to their knowledge to compliance officer contact mentioned in section 2.2.4.2. 2.5.Complaint handling This is divided into 3 phases, 2.5.1. Investigation and sanctions 2.5.2. Business relationships 2.5.3. Complaints and disciplinary procedures 2.5.1. Investigation and sanctions

RSJ Inspection

TM



Section No. - 12

Revision No. 05 w. e. f. 21-09-2019

of 30

2.5.1.1. Compliance officer shall start, whenever appropriate, an investigation into any violation of the Programme as reported to him or her, or of which he or she may become aware. 2.5.1.2. To deal with investigations and sanctions related to violations of the Programme, RSJ has established the procedure for conducting investigations that includes requirement as under, 2.5.1.2.1. The maintenance of records of all violations that have been reported, and subsequent measures taken; 2.5.1.2.2. The author of such alleged violation shall have the right to be heard; 2.5.1.2.3. The management of RSJ shall decide about the corrective and disciplinary measures as appropriate, to be implemented, should a violation be established. These measures could include a reprimand, demotion, suspension or dismissal; 2.5.1.3. Compliance officer shall receive reports on the progress of the appointed representative and prepare regular summary reports for the Compliance Committee, about investigations, violations as established and the implementation of corrective and disciplinary measures. 2.5.1.4. Procedure PM 19 has been established for conducting investigations and sanctions.

2.5.2. Business Partners 2.5.2.1. Business relations are external parties with whom RSJ does business such parties who are also referred as business partners including the following, •intermediaries, (entities or individuals external to the Member who are required to promote the services of the Member as part of their responsibilities, including consultants and advisers) •joint venture partners •agents (entities or individuals external to the Member who are required to provide operational services, within the Profession as defined in IFIA / TIC Council’s Articles of Association, on the Member’s behalf) •subcontractors (entities or individuals performing outsourced activities within the Profession under a contract with the Member) •franchisees (entities or individuals external to the Member who carry on business within the Profession using the Member's trading name and/or brand, the rights to which are purchased from the Member under a franchise contract) 2.5.2.2.RSJ ensures that Compliance programme is applied to the extent appropriate in its business relations with parties external to the organization and that improper payments are not channelled through them; also, RSJ ensure that such parties abide by the compliance Programme to the extent that is appropriate. 2.5.2.3. Before having contract with any business relationship (like intermediaries, joint ventures, agents, sub-contractor, franchisees, etc) RSJ carries following checks, - conducting due diligence before entering into or renewing any contract with the party - making known to its compliance principles to the party and seeking assurance that the party will comply with Principles in so far as these apply to activities performed on behalf of RSJ. - Obtaining the party’s (except for subcontractor) contractual commitment to comply with the compliance Principles and verify this periodically. - monitoring the party’s continual compliance with the principles. - not dealing with any parties known to be involved in bribery.

RSJ Inspection

TM



Section No. - 12

Revision No. 05 w. e. f. 21-09-2019

of 30

2.5.2.4. Due diligence includes, A risk analysis An interview with the party An investigation of the party’s background which, for intermediaries, should be reviewed and approved

by the RSJ compliance committee. Verification through remuneration analysis, which should be reviewed and approved by RSJ compliance committee, that the remuneration paid to each intermediary is appropriate and justifiable for legitimate service rendered and does not facilitate improper payments by the intermediary.

2.5.2.5. Further RSJ shall provide the appropriate training and support to all intermediaries and other parties as appropriate. 2.5.2.6. RSJ shall ensure to have all intermediary’s remuneration in a separate general ledger account in accounting records and consolidate all such payments made by any of its operations and prepare annually a consolidate management statement of all intermediary’s remuneration.

2.5.2.7. Procedure PM 20 has been established for Procedure for contracting with business partners. 2.5.3.TIC Council Complaints Handling Procedure

2.5.3.1. Complaints concerning alleged non-compliance with IFIA/ TIC-Council compliance Code by other IFIA/ TIC-Council members shall be lodged with IFIA/ TIC Council in accordance with the TIC Council Complaints Handling Procedures. RSJ shall refrain from submitting such complaints to other parties unless it is necessary to do so to protect RSJ reputation. 2.5.3.2. RSJ shall comply with provision of TIC-Council complaint handling procedure (http://www.ifia-federation.org) in respect of any complaint received by IFIA/TIC council against RSJ by another party who is not a Full approved IFIA/TIC member, and shall conduct complete investigation of the issues raised in the complaint as per RSJ complaint handling procedure and shall submit the findings to IFIA/ TIC Council.

2.5.3.3. When complaint is made against the RSJ by a Full IFIA/TIC council member, RSJ shall fully co-operate with the investigations carried out by IFIA/TIC council and submit any information required in this regard. RSJ shall also comply with requirements of review committee held by IFIA/TIC global board or any appeal made in this regard. 2.5.3.4. Breaches of IFIA/ TIC council compliance Code may lead to sanctions imposed by the IFIA/ TIC Council subject to the rules, including rights of appeal, set out in the TIC Council Complaints Handling Procedures.

2.6. Accounting and bookkeeping

2.6.1. RSJ is committed and maintains accurate books and records, documenting all the financial transactions in a correct and honest manner. 2.6.2. It is strictly forbidden to have accounts kept outside the books.

RSJ Inspection

TM



Section No. - 12

Revision No. 05 w. e. f. 21-09-2019

of 30

2.7. Health and safety 2.7.1. RSJ record all health and safety incidents reported and are further investigated.

2.7.2. In case required appropriate corrective measures are taken. 2.8. Compliance Summary Report 2.8.1. Compliance officer shall prepare a summary Report on an annual basis. This summary Report shall cover statistics or confirmations to show compliance with the RSJ’s procedures and policies for the following area: a) Violations

i. Number of violations/ suspected violations reported ii. Number of violations substantiated iii. Confirmation that remedial actions have been determined and action undertaken/ being undertaken for each substantiated violation / non-compliance.

b) New or renewed Intermediaries, joint venture partners and franchisees

i. Number of new or renewed Intermediaries, joint venture partners and franchisees in the financial year ii. Confirmation that each has gone through the RSJ’s due diligence procedures as required. iii. Confirmation that an appropriate contract/ terms of business have been put in place with each.

c) Expenses- Confirmation of the expenses are in line with the RSJ’s compliance programme

and related policies for i.Political contributions ii.Charitable contributions and sponsorships iii.Expenditures relating to gifts, hospitality and expenses iv.Intermediaries remuneration

d) Health & Safety

i.Number of health & safety incidents reported ii.Confirmation that remedial actions have been determined and action undertaken/ being undertaken for each incident

RSJ Inspection

TM



Section No. - 12

Revision No. 05 w. e. f. 21-09-2019

of 30

3.Verification of compliance programme implementation effectiveness

Verification of compliance programme implementation effectiveness is divided into 2 phases, 3.1. Effectiveness monitoring – Internal 3.2. Effectiveness monitoring – External verifications

3.1. Effectiveness monitoring – Internal

Effectiveness monitoring – Internal is divided into 2 phases, 3.1.1. Management declaration 3.1.2. Internal audits

3.1.1. Management declaration

3.1.1.1. RSJ shall require its senior managers throughout its organization to prepare and sign a compliance declaration, on an annual basis, based on the template contained in Annex A of this compliance programme guidelines.

3.1.1.2. These compliance declarations shall be received, in respect of all applicable locations and/or activities, by the compliance officer who shall submit an annual summary report to the compliance committee.

3.1.2. Internal audits

3.1.2.1. RSJ carries out internal (quality) and administrative audits at regular intervals according to the defined programme.

3.1.2.2. These are carried out by qualified auditor and the implementation of the compliance programme is verified within the whole organization and the Management declarations. In particular,

A) have been completed in conformance with annex a B) reflect compliance with the principles and rules and C) in respect of those locations selected for site audits, correctly reflect the actual situation.

3.1.2.3. Such site audits shall review the processes in place to ensure the effective application and implementation of the program.

3.1.2.4. “IFIA / TIC Council Guidance check list for members’ internal compliance audits” shall be used for RSJs Internal Compliance Audits.

3.1.2.4. The compliance findings result from such audits shall be reported to the compliance officer who shall submit a summary report to the compliance committee. The compliance officer and/or compliance committee shall take follow-up actions wherever appropriate. 3.2. Effectiveness monitoring – External verifications The implementation of the compliance Programme shall be verified through submission of documents and by agreed upon procedures carried out by the RSJ’s appointed recognised independent external audit firm.

RSJ Inspection

TM



Section No. - 12

Revision No. 05 w. e. f. 21-09-2019

of 30

This is divided into 5 phases, 3.2.1. Frequency 3.2.2. Appointment of independent external audit firm 3.2.3. Notification to IFIA/ TIC Council of RSJ’s appointed external audit firm(s) 3.2.4. Scope of verification 3.2.5. External audit firms report

3.2.1. Frequency

3.2.1.1. Every year, verification shall be conducted to see the efficiency and the effectiveness of the implementation of Compliance Programme by an external independent auditing company as appointed.

3.2.2. Appointment of independent external audit firm 3.2.2.1. The independent external audit firm to carry out the verification by agreed upon procedures could be the firm engaged for the statutory audit of the RSJ's consolidated financial statements. 3.2.2.2. The appointed audit firm shall be a reputable organisation that is a member of a recognised national professional accountancy organisation.

3.2.3. Notification to IFIA informing the Appointed External Audit Company 3.2.3.1. RSJ shall send details of external auditing company for the confirmation of compliance with IFIA/ TIC Council requirements, to the IFIA/ TIC Council before appointment. 3.2.3.2. In case of any subsequent changes as proposed, shall follow the same procedure prior to appointment. 3.2.4. Scope of the verification

3.2.4.1. Submit documents for verification to IFIA / TIC Council 3.2.4.1.1. To demonstrate that RSJ is following the IFIA/ TIC council Compliance programme. RSJ shall submit the following documents to IFIA/ TIC Council,

a)RSJ’s Compliance Programme, as well as policies in relation to each principle, if applicable b) The terms of reference for the Compliance Committee including the specification that the

Compliance Committee is responsible for overseeing the Compliance Programme. c) List of members of the Compliance Committee (including job title). d) Compliance Programme training course material. e)Material helping the awareness of the Employee Help Line including designated email. f)Material encouraging employees to report details of violations or suspected violations and to whom

they can report. g) Print screen of RSJ's website where:

- the Compliance Principles are explained. - an interested party can make inquiries, complaints or feedback.

h)Documented procedure for the handling of investigations and sanctions i)Policies related to confidential business information (information security policy, confidentiality

RSJ Inspection

TM



Section No. - 12

Revision No. 05 w. e. f. 21-09-2019

of 30

policy). j)Procedures for due diligence for initiating or renewing relationships with intermediaries, joint

ventures partners and franchisees. k)Procedure for contracting with intermediaries, joint venture partners and franchisees and related

template(s) of contract / terms & conditions with a new / renewed intermediary, joint venture partner or franchisee.

l)Template of the annual management declaration based on the template in Annex A. m)Scope of Internal Audit plan that includes the review of the implementation of the Compliance

Code. n)Annual summary reports prepared by the Compliance Officer covering statistics or confirmations to

show compliance with RSJ’s procedures and policies, as specified in Annex B. o)Annual report of the results of the agreed upon procedures. p) Health and safety incident reporting and investigations procedure. (PM_21 Refer Procedural

manual).

3.2.4.1.2. RSJ shall self-assess whether the evidence being submitted meets all the evidence requirements before submitting the documents, (The evidence requirements are detailed in Annex B). RSJ shall explain the reasons for any deviations to the evidence requirements, if any. 3.2.4.1.3. Unless otherwise stated, documents are required to be re-submitted only if they have been updated. All documents shall be reviewed and updated at least every three years or whenever there is an updated version of the Compliance Code and/or guidelines issued by IFIA / TIC Council. 3.2.4.2. Request audit firm to carry out agreed upon procedures 3.2.4.2.1. Independent audit firm shall carry out verification, agreed upon procedures for the following areas annually:

a)Understanding of compliance code by each new employee b) Attendance of Compliance Programme training course(s) by employees c) Employee Help Line including designated email to raise queries and / or issues relating to the

Compliance Programme d) Reviewing and taking actions on enquiries, complaints and feedback from interested parties e)Understanding of the confidentiality requirements by each new employee f)Schedules prepared for political contributions; charitable contributions and sponsorships;

expenditures relating to gifts, hospitality and expenses; and Intermediaries' remuneration g) Monitoring of annual compliance declaration submitted by Senior Managers

The specific agreed upon procedures is detailed in Annex C. 3.2.4.3. External audit firm report: 3.2.4.3.1. RSJ shall ask the external audit company to issue a report showing the results of the agreed upon procedures using the template contained in Annex C. 3.2.4.3.2. RSJ shall send a copy of its external audit firm’s Report to the IFIA/ TIC Council within 6 months (before 31st Sep) from the end of RSJ’s financial year.

RSJ Inspection

TM



Section No. - 12

Revision No. 05 w. e. f. 21-09-2019

of 30

Annex A (confidential)

Management Declaration

RSJ's Compliance Program

Management Declaration for the year ending: 20 To: …………………………………………. (RSJ's Compliance Officer)

Name of the Manager Job Title

Locations and/or activities covered by this Declaration

I ________ (name of manager) do hereby declare that in implementation of RSJ’s Compliance Program in each of the locations and/or activities, as listed above, falling under my area of responsibility and for the given year,

1. To the best of my knowledge I, and the RSJs of staff reporting to me, have complied in all respects

with the compliance programme; 2. I have verified that the compliance programme have been distributed to each employee who had not

previously received them; 3. I have fully and completely reported to the compliance officer any violation or suspected violation of

the programme, including any solicitation or offer of any improper payment or advantage, which has come to my knowledge;

4. I have fully and completely implemented all corrective and disciplinary actions required by the Compliance committee in respect of any violation of the principles and rules.

Signature Place Date

RSJ Inspection

TM



Section No. - 12

Revision No. 04 w. e. f. 10-06-2019

of 30

Annex B Detailed requirements for evidence to be submitted

Evidence to be submitted Evidence Requirements RSJ Evidences

1)RSJ’s Compliance Programme as well as policies in relation to each principle

The programme should cover the compliance code principles: - Integrity - Conflicts of interest - Confidentiality and Data Protection - Anti-bribery - Fair business conduct - Fair labour - Health & Safety The programme and policies require to be in line with the details provided in the 'Application of Compliance principles' in the Compliance Code guidelines. The programme should include: - Reference to the Help Line. - Provisions for protection of confidentiality for reporting violations. - a provision where employees can report known or suspected violations to the Compliance Officer, the employee's superior, a member of senior management, or an internal auditor. - Requirement for employees to report any solicitation of, or offer of, an improper payment or advantage coming to their attention. - provision that it be made clear that employees will not suffer demotion, penalty or any other adverse consequences arising from strict implementation of the Programme even if it may result in a loss of business.

RSJ compliance programme covers the following principles: - Integrity Section 1.1 - Conflicts of interest Section 1.2 - Confidentiality and Data Protection - Anti-bribery - Fair business conduct - Fair labour - Health & Safety The programme and policies as mentioned in compliance manual are aligned with the clause numbers as given in the Compliance Code guidelines. The programme includes: - Reference to the Help Line – Section. - Provisions for protection of confidentiality for reporting violations – Section - a provision where employees can report known or suspected violations to the Compliance Officer, the employee's superior, a member of senior management, or an internal auditor. - Requirement for employees to report any solicitation of, or offer of, an improper payment or advantage coming to their attention. - provision that it be made clear that employees will not suffer demotion, penalty or any other adverse consequences arising from strict implementation of the Programme even if it may result in a loss of business.

2) The Terms of Reference for the Compliance Committee (or equivalent) including the specification that the Compliance Committee (or equivalent) is responsible for overseeing the Compliance Programme

The Terms of Reference should specify that the Committee is responsible for overseeing the Compliance Programme. The Terms of Reference should specify the frequency of the Compliance Committee meetings. The Compliance Committee should meet regularly (at least on an annual basis).

Section 2.4.3 covers the Terms of Reference of the Compliance Committee. Section 2.4.1 specifies the frequency of the Compliance Committee meetings. It should be at least once a year.

3) Compliance Committee members list (including job title)

There should be at least 3 members in the Compliance Committee. The members of the Committee should include:

Section 2.1.4.2 cover composition of the Compliance Committee. The Compliance Committee consists of CEO, Compliance officer, HR manger.

RSJ Inspection

TM



Section No. - 12

Revision No. 04 w. e. f. 10-06-2019

of 30

- Compliance Officer (or reports into as attendee) - CEO (or equivalent) - Representative from Legal (if member has a legal function) - Representative from HR (if member has a HR function)

4) Compliance Programme training course material

The material should include sections on: - Integrity - Conflicts of interest - Confidentiality and data protection - Anti-bribery - Fair business conduct - Fair labour - Health & Safety Any training relevant to the financial year should be submitted.

Training material for orientation / refresher training is attached. Document Code of Conduct RSJ Associates RSJ_HR_FT_04 which is used as a reference material for training is attached.

5) Material helping the awareness of the Employee Help Line (or equivalent - e.g. designated email)

The material should explain: - That employee can obtain guidance on any question or matter of concern relating to the implementation or interpretation of the Compliance Programme. - at the employee's request, any such question should be dealt with confidentially and the anonymity of the employee should be protected to the extent reasonably practicable.

Clause 6.2.2.4 compliance manual refers.

6) Material encouraging employees to report details of violations or suspected violations and to whom they can report

The material should explain that the: - Employee is fully protected against any form of reprisal unless he/she acted maliciously or in bad faith. - Employee is required to report any solicitation for, or offer of, an improper payment or advantage coming to their knowledge. May be the same as submission 5.

Clause 2.4.3 compliance program refers. Clause 4.0 of Code of conduct – RSJ Associates RSJ_HR_FT_04 refers. Clause 14.0 of Ethics and Conduct Code RSJ_HR_FT_04A refers.

7) Screen print of RSJ’s website where: - The Compliance Principles are explained. - An interested party can make inquiries, complaints or feedback.

N/A Screen shot of website.

8) Documented procedure for the handling of investigations and sanctions

The procedures should include requirements for: (a) the maintenance of records of all reported violations and subsequent actions taken; (b) the alleged perpetrator of such violation to have the right to be heard; (c) The Member's management or

Clause 2.5.1 compliance program refers. 2.8.1.1.Procedure PM 19 has been established for conducting investigations and sanctions.

RSJ Inspection

TM



Section No. - 12

Revision No. 04 w. e. f. 10-06-2019

of 30

Compliance Committee to decide on the appropriate corrective and disciplinary measures to be implemented if a violation has been established. These measures may include a reprimand, demotion, suspension or dismissal; and (d) The Compliance Officer to receive progress reports from his/her nominated delegates and/or the management in the locations concerned and prepare periodic summary reports for the Compliance Committee on investigations, violations established and the implementation of corrective actions and disciplinary measures.

9) Policies relating to confidential business information (information security policy, confidentiality policy)

The policy should cover the need for the business to implement adequate security measures to ensure that access is restricted to authorised personnel only and that documents/data are stored in designated secure areas and disposed of in a secure manner.

Clause 1.3 of Compliance program refers. Section 4.2 of RSJ Quality manual attached. Procedure PM 18 – Maintaining confidentiality attached. Clauses 6.2.4.4 and 6.2.4.5 refer.

10) Procedures for health & safety incident reporting and investigations

The procedures should: - define what a health & safety incident is. - explain how the employee can report health & safety incidents. - encourage employees to report health & safety incidents. - explain how health & safety incidents will be investigated and remedial actions will be determined.

Clause 1.6 of Compliance program refers. Code of Conduct RSJ_HR_FT_04 Clause 12.0 refers. Safety Instruction RSJ_FT_06 attached which defines various types of Safety and health hazards during factory inspections.

10 Procedure PM 21 has been established for reporting health & safety incidents and conducting investigations

11) Procedures for due diligence for initiating or renewing the relationships with intermediaries, joint venture partners and franchisees

For intermediaries, joint venture partners and franchisees, the Member requires to have a written procedure in terms of what due diligence steps they require to carry out and what approval is required for initiating or renewing the intermediary, joint venture partner or franchisee.

Clause 2.5.2 of Compliance program refers. Procedure PM 20 has been established for Procedure for contracting with business partners. Currently RSJ does not have any joint venture partners and franchisees and we don’t have any plans enter in to any new relationships in near future.

12) Procedure for contracting with intermediaries, joint venture partners and

The contract / terms of business should include: - A requirement that the Business Partner complies with the Compliance

The contract / terms of business include:- A requirement that the Business Partner complies with the Compliance Programme

RSJ Inspection

TM



Section No. - 12

Revision No. 04 w. e. f. 10-06-2019

of 30

franchisees and related template(s) of contract / terms & conditions with a new / renewed intermediary, joint venture partner or franchisee

Programme - A provision allowing the Member to verify the Business Partner's compliance with the Compliance Programme. For intermediary, joint venture partner and franchisee, the Member requires to have written procedures in terms of what contracts / terms of business requires to be put in place covering the intermediary, joint venture partner or franchisee’s acknowledgement of compliance with Member’s compliance programme. Where the Member does not have a standard template, Member should submit examples of contracts which includes above.

- A provision allowing RSJ to verify the Business Partner's compliance with the Compliance Programme. For intermediary, joint venture partner and franchisee, RSJ has written procedures in terms of what contracts / terms of business requires to be put in place covering the intermediary, joint venture partner or franchisee’s acknowledgement of compliance with RSJ’s compliance programme. Where the Member does not have a standard template, Member should submit examples of contracts which includes above.

13) Template of the annual management declaration based on the template in Annex A

Compliance declaration should include the attributes in Annex A including locations and/or activities covered by the declaration as well as declaration of implementation of the Compliance Programme

Sample Declaration attached.

14) Scope of Internal Audit plan that includes the review of the implementation of the Compliance Code

The Scope of the Internal Audit plan should cover the Member's organisation.

The Scope of the Internal Audit plan cover RSJ's organisation. RSJ Internal Audit Checklist attached.

15) Annual summary reports prepared by the Compliance Officer covering statistics or confirmations to show compliance with RSJ’s procedures and policies and policies, as specified in Annex B

On an annual basis (in line with financial year-end), the Member should prepare an annual summary reports detailing: 1) Violations: - Number of violations / suspected violations reported - Number of violations substantiated - Confirmation that remedial actions have been determined and action undertaken / being undertaken for each substantiated violation / non-compliance.(The above statistics are required to cover those violations / suspected violations reported through Help Line as well as found during Internal Audits.) 2) For new or renewed intermediaries, joint venture partners and franchisees: - Number of new or renewed intermediaries, joint venture partners and franchisees in the financial year. - Confirmation that each has gone through the Member's due diligence procedures as required. - Confirmation that an appropriate contract / terms of business have been

RSJ Annual IFIA/TIC council Compliance Template attached.

RSJ Inspection

TM



Section No. - 12

Revision No. 04 w. e. f. 10-06-2019

of 30

put in place with each. 3) Confirmation the expenses are in line with the Member’s Compliance Programme and related policies for: - Political contributions. - Charitable contributions and sponsorships. - Expenditures relating to gifts, hospitality and expenses. - Intermediaries' remuneration. 4) Health & Safety: - Number of health & safety incidents reported - Confirmation that remedial actions have been determined and action undertaken / being undertaken for each incident.

16) Annual report of the results of the agreed upon procedures

N/A N/A

RSJ Inspection

TM



Section No. - 12

Revision No. 04 w. e. f. 10-06-2019

of 30

ANNEX C

Template Report for Agreed Upon Procedures results

“Report on……… (name of Member)’s Compliance Programme”

We have performed the agreed upon procedures enumerated below, which were agreed to by the Member and the IFIA / TIC Council, solely to assist you the Member in reviewing your Compliance Programme in connection with your membership in IFIA / TIC Council. The Member is responsible for implementing a Compliance Programme that conforms to IFIA / TIC Council guidance. The sufficiency of these procedures is solely the responsibility of those parties specified in this report. Consequently, we make no representation regarding the sufficiency of the procedures described below either for the purpose for which this report has been requested or for any other purpose.

Audit area Agreed upon procedures Results and Factual Findings (to

be completed by audit firm) I) Understanding of compliance code by each new employee

1. Obtain a list of new employees during the 12 months to financial year-end. For Members who operate in multiple offices/locations, the sample should be selected across the offices/locations. Alternative: Where the Member has more than 10 offices, the Member can provide a list of ALL offices. The auditor then selects 10 offices. For the office, the Member provides a list of new joiners in the audit period. If there is no new joiner another office is selected. 2. Select a sample of 10 new employees 3. For each selected sample, obtain the signed declaration that they have read and understood the Compliance Programme and signed within 30 days of joining.

1. Obtained from management a list of all new employees of the Member for the financial accounting period of [date] to [date]. (We make no comment with respect to the completeness or accuracy of the list.) Alternative: Obtained from management a list of ALL offices and selected 10 offices. Obtained a list of all new employees from the offices selected for the financial accounting period of [date] to [date]. 2. Non-statistically selected [xx] employees from the list. 3. Confirmed each employee selected in 2. had signed declaration that they have read and understood the Compliance Programme and signed within [days for longest period] days of joining.

RSJ Inspection

TM



Section No. - 12

Revision No. 04 w. e. f. 10-06-2019

of 30

Audit area Agreed upon procedures Results and Factual Findings (to be completed by audit firm)

II) Attendance of Compliance Programme training course(s) by employees

1. Obtain a list of all employees. Explanation: This is a list of ALL employees, and not just a list of those that attended the course. 2. Select a sample of 10 employees who have attended the course in the 12 month period to financial year-end. Alternative: For Members who operate in multiple offices/locations, the sample should be selected across the offices/locations. 3. For the sample selected, obtain training records showing their attendance of the Compliance Programme training course. Explanation: For any new employee (if sample selected), it is noted that they may yet to be trained depending on their date of joining and training schedule / timetable. All employees should have Compliance Programme training at least on a two yearly basis.

1. Obtained from management a list of all employees of the Member for the financial accounting period of [date] to [date]. (We make no comment with respect to the completeness or accuracy of the list.) 2. Non-statistically selected [xx] employees from the list covering different offices and locations. 3. Confirmed each employee selected in 2. had attended the following Compliance Programme training courses within the last 2 years from financial year-end: - [name of course] - [name of course] - [name of course]

III) Employee Help Line (or equivalent - e.g. designated email) to raise queries and / or issues relating to the Compliance Programme

1. Obtain the Employee Help Line number or email address. 2. Call / send email to confirm the Help Line is in operation. 3. Discuss with Management how queries and / or issues reported on Help Line are being investigated / looked into and resolved. 4. Obtain / inspect evidence showing that the queries and / or issues are being handled as explained in step 3. Explanation: Need to obtain / inspect actual evidence showing operation - not just template.

1. Confirmed with management the following Employee Help Line details: [Help Line number] or [Help Line email] 2. Contacted the Help Line on [date] to confirm the Help Line in operation. 3. Discussed with Management the queries and / or issues reported on Help Line are being investigated / looked into and resolved by [the team / person responsible] and tracked using [queries / issues tracking mechanise]. 4. Inspected the [queries / issues tracking mechanism] and confirmed that queries / issues status is being tracked and queries / issues are being resolved.

RSJ Inspection

TM



Section No. - 12

Revision No. 04 w. e. f. 10-06-2019

of 30


IV) Reviewing and taking actions on enquiries, complaints and feedback from interested parties

1. Obtain the Third Party Help Line number or email address. 2. Call / send email to confirm the Help Line is in operation. 3. Discuss with Management how queries and / or issues reported on Help Line are being investigated / looked into and resolved. 4. Obtain / inspect evidence showing that the queries and / or issues are being handled as explained in step 3. Explanation: Need to obtain / inspect actual evidence showing operation - not just template. Explanation: If the mechanism for third parties to raise queries and / or issues is the same as employees cover as part of III.

1. Confirmed with management the following Third Party Help Line details: [Help Line number] or [Help Line email] 2. Contacted the Third Party Help Line on [date] to confirm the Help Line in operation. 3. Discussed with Management the queries and / or issues reported on Help Line are being investigated / looked into and resolved by [the team / person responsible] and tracked using [queries / issues tracking mechanise]. 4. Inspected the [queries / issues tracking mechanism] and confirmed that queries / issues status is being tracked and queries / issues are being resolved.

V) Understanding of the confidentiality requirements by each new employee

1. Obtain a list of new employees during the 12 months to financial year-end. (same list as agreed upon procedures I) For Members who operate in multiple offices/locations, the sample should be selected across the offices/locations. Alternative: Where the Member has more than 10 offices, the Member can provide a list of ALL offices. The auditor then selects 10 offices. For the office, the Member provides a list of new joiners in the audit period. If no new joiner another office is selected. 2. Select a sample of 10 new employees (same sample as agreed upon procedures I) 3. For each selected sample, obtain the signed confidentiality agreement (or obtain the signed declaration that they have read and understood the confidential business information policy).

1. Obtained from management a list of all new employees of the Member for the financial accounting period of [date] to [date]. (We make no comment with respect to the completeness or accuracy of the list.) Alternative: Obtained from management a list of ALL offices and selected 10 offices. Obtained a list of all new employees from the offices selected for the financial accounting period of [date] to [date]. 2. Non-statistically selected [xx] employees from the list. 3. Confirmed each employee selected in 2. had signed confidentiality agreement within [days for longest period] days of joining.

RSJ Inspection

TM



Section No. - 12

Revision No. 04 w. e. f. 10-06-2019

of 30

Factual Findings: Our findings with respect to the above procedures are as follows: Please list any non-compliance / partial compliance findings from the agreed upon procedures performed or type ‘N/A’

The agreed upon procedures that we have performed do not constitute an audit or a review made in accordance with International Standards on Auditing or International Standards on Review Engagements and, consequently no assurance will be expressed on the adherence to IFIA / TIC Council's Compliance Code. Had we performed additional procedures, or had we performed an audit or review, other matters might have come to our attention that would have been reported to you.


VI) Schedules prepared for political contributions; charitable contributions and sponsorships; expenditures relating to gifts, hospitality and expenses; and Intermediaries' remuneration.

1. Obtain the year-end schedule prepared by Management for: - Political contributions - Charitable contributions and sponsorships - Expenditures relating to gifts, hospitality and expenses - Intermediaries' remuneration 2. Discuss with management how they are comfortable each schedule is complete and accurate. 3. Obtain the review and approval of the schedules by the Audit Committee and/or Compliance Officer. (This can be part of the annual summary report - submission document 15).

1. Obtain the year-end schedule prepared by [job title of person preparing] for: - Political contributions - Charitable contributions and sponsorships - Expenditures relating to gifts, hospitality and expenses - Intermediaries' remuneration 2. Discussed with [job title of person preparing] how they are comfortable each schedule is complete and accurate. 3. Obtained the review and approval of the schedule by [name of committee or job title of person reviewing] confirming that the transactions are in adherence with the Member’s policies.

VII) Monitoring of annual compliance declaration submissions by Senior Managers

1. Obtain evidence of monitoring of completeness of annual submissions by Senior Manager. Explanation: It is the responsibility of the Member to define and identify the Senior Managers across the organisation. 2. If the mechanism is not in place, raise a finding and obtain a list of Senior Managers. Explanation: It is the responsibility of the Member to define and identify the Senior Managers across the organisation. 3. Confirm the list of Senior Managers from 1. or 2. has at least one Senior Manager identified for each 'Group Member' specified by the Member within the Member’s Group Membership (if applicable). 4. Select a sample of 10 employees from list. 5. For the selected samples obtain the annual signed management declaration.

1. Obtained [mechanism of monitoring completeness of annual submission by Senior Manager] for the financial accounting period of [date] to [date]. 2. Was required / Was not required to obtain a list of Senior Managers. 3. Confirmed with [job title] the list of Senior Managers from [specify 1. or 2.] has at least one Senior Manager identified for each ‘Group Member’ specified by the Member within the Member’s Group Membership. 4. Non-statistically selected [xx] employees from the list. 5. Confirmed each Senior Manager selected in 4. had signed the annual management declaration for the financial accounting period [date] to [date].

RSJ Inspection

TM



Section No. - 12

Revision No. 04 w. e. f. 10-06-2019

of 30

This report is intended solely for the information and use of Member and the Director General of the IFIA / TIC Council and is not intended to be and should not be used by anyone other than these specified parties. This report relates only to the accounts and items specified above and does not extend to any consolidated financial statements of the Member, taken as a whole.

…………………………………….. …………………………………….. Name of External Audit Firm Date

RSJ Inspection

TM



Section No. - 12

Revision No. 04 w. e. f. 10-06-2019

of 30

Establishment and Revision History

Rev No.

Page Affected

Effective date

Revised content Prepared by

Reviewed by

Approved by

00 All Nov 15, 2018

Establishment of documents

Saravana kumar

Yuvraj Jambhale

Sarath Chandran

01 1,2,4,5,7, 8, 10,15

Nov 22, 2018

Grammatical and typo errors corrected (highlighted in yellow)

Saravana kumar

Yuvraj Jambhale

Sarath Chandran

02 All Jan 22, 2019

IFIA comments Saravana kumar

Yuvraj Jambhale

Sarath Chandran

03 All April 04, 2019

As per IFIA TIC Council Compliance Code 6th Edition December 2018

Saravana kumar

Yuvraj Jambhale

Sarath Chandran

04 06, 14 June ,10 2019

cl.1.4.3.1.1.-sentence “as a way of obtaining advantage in business transactions” are replaced with word “in general”. Cl 1.4.3.4- amended and added will maintain separate ledger account Cl2.5.3. name change to “TIC council complaints handling procedure” cl.3.1.2.4- name has amended

Yuvraj Jambhale

Sarath Chandran

Sarath Chandran

05 6,7,15 September 21, 2019

Amended highlighted in colour Blue 1.4.3.1.1, 1.4.3.4.1, 1.4.3.4.2-newly added 1.5.9.-Newly added 2.5.3.2-Newly added 2.5.3.3.-newly added 3.2.4.1.1P-newly added

Yuvraj Jambhale

Sarath Chandran

Sarath Chandran

TM RSJ Inspection · 2019-10-04 · RSJ InspectionTM-Complete Conformity Solutions Quality Manual...

Documents

Transcript of TM RSJ Inspection · 2019-10-04 · RSJ InspectionTM-Complete Conformity Solutions Quality Manual...