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ElitePetz
Certification Authority
ElitePetz
Certification Authority
Independent Certification Body
Governance · Impartiality Safeguard
Conflict of Interest Policy
Anyone participating in certification review or oversight must protect the process from interests that could compromise—or reasonably appear to compromise—independent judgment. Conflicts are disclosed early, assessed by an authorized party, and managed on the record.
Status
Current
DOCUMENT ID
EP-GOV-COI-001
VERSION
1.0
EFFECTIVE DATE
September 3, 2026
Purpose and scope
This policy applies to every person who can influence a certification recommendation, determination, enforcement action, appeal, or related administrative record.
Covered participants
Reviewers, decision-makers, staff, contractors, advisers, and committee members
The duty applies whether participation is formal or informal and whether the interest belongs to the participant, a close associate, or an organization with which the participant has a material relationship.
Continuing duty
Disclosure is not a one-time event
A participant must update the disclosure if circumstances change or new information creates a possible conflict during the matter.
What counts as a conflict
The policy addresses more than proven bias. A potential or perceived conflict can damage confidence in a decision even when no improper influence occurred.
Present
Actual conflict
A personal, financial, professional, or organizational interest directly competes with the participant’s duty to exercise independent judgment.
Possible
Potential conflict
Circumstances could develop into a conflict or could reasonably affect impartial participation as the matter proceeds.
Reasonable appearance
Perceived conflict
An informed observer could reasonably question the participant’s impartiality, even if the participant believes they can remain objective.
Interests that should be disclosed
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Financial ownership, compensation, debt, or expected benefit
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Prior involvement in the same application, complaint, or evidence
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Recent or current employment, consulting, or business ties
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Gifts, favors, referrals, or benefits from an interested party
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Family, household, close personal, or adversarial relationships
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Public commitments or advocacy specific to the matter
Disclosure and review process
Participants disclose facts, not conclusions. The Governance function, not the affected participant, decides whether a safeguard is required.
01
Identify
Consider personal, financial, professional, and organizational connections before accessing or discussing the matter.
02
Disclose
Promptly submit the relevant facts to the Governance function through the Authority's Official Inquiry channel, and pause substantive participation until the assessment is complete.
03
Assess
An authorized, unaffected decision-maker evaluates materiality, appearance, and available safeguards.
04
Record and act
The determination, rationale, and any restriction, recusal, reassignment, or monitoring measure are documented.
Default rule
When in doubt, disclose
Disclosure does not itself establish wrongdoing. It allows the Authority to protect both the participant and the integrity of the certification process.
Late discovery
Stop and escalate
If a conflict is discovered after work begins, pause participation and request review. Prior actions may be independently reassessed.
How conflicts are managed
The response must match the risk and preserve a defensible record. Disclosure alone is not always an adequate safeguard.
No conflict found
Participation may continue, with the assessment retained in the administrative record.
Limited participation
Access, discussion, recommendation, voting, or decision authority may be restricted and independently supervised.
Recusal and reassignment
The participant takes no further part, receives no nonpublic updates, and the matter is assigned to an unaffected reviewer.
Independent re-review
Work completed before disclosure may be reconsidered without relying on the conflicted participant’s judgment.
Additional administrative action
Failure to disclose or comply with a safeguard may be referred under applicable conduct, contract, or personnel procedures.
Required record
Each assessment should show
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the interest disclosed;
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who assessed it;
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the determination and rationale;
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the safeguard imposed;
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the dates of disclosure and action.
Confidential information is shared only as needed to administer the policy and preserve the record.
Policy ownership and questions
Policy owner: ElitePetz Certification Authority, Governance function
Approved by: ElitePetz Certification Authority, Governance committee
Review cycle: At least annually and following a material legal, standards, or operational change
Last reviewed: September 3, 2026
Next scheduled review: September 3, 2027
Related governance resources
Governance
The controls that support consistent and accountable certification administration.
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Reporting
Raise a concern about certification integrity through the official channel.
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