RSJ Compliance Programme

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.


1.1.1 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 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. Conflicts of interest can arise in many ways. If not clear, associates should seek guidance from
Integrity Manager.

1.2.3. 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

1.2.4. Family members of RSJ associates shall be recruited to work with RSJ, with the explicit approval of
top management.

1.2.5. RSJ associates shall not hold any position with client / competitor such as director, advisor,
consultant, etc.

1.2.6. 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

1.2.7. 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. Safeguarding impartiality at policy level. Safeguarding impartiality at organization level Safeguarding impartiality at operational level 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 (in any form e.g. Physical or digital etc.) 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/business partners/intermediaries/agents of the company while in employment/or during contract period as well as after severance of the employment/or contract. Similarly, the use directly or indirectly of confidential Company business information and its stakeholders, 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 or during contract period as well as after severance of the employment/contract. The use of such information generally to the possible detriment of the Company also is prohibited.

1.3.3. RSJ & it’s associates will take appropriate action:
a) to safeguard the company’s & its stakeholders (of intermediaries, agents, business partners) Confidential Information.
b) To store to such confidential information, trade secret, proprietary information in secured location.

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

Sl. 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
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

1.3.6. 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 even after the end of the business relationship.

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, Agents, contractors/suppliers, business partners 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 and/or Kickback on any portion of a contract payments 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 RSJ is committed to fully complying with national regulations (PCA 1988) 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 Risk analysis relating to bribery is conducted by compliance committee and/or senior executive, or his/her delegate 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 & control measure shall be performed in each country of operation. 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

RSJ Inspection Service Ltd. Compliance committee is responsible for employ good business practices and risk management strategies in accordance with countering bribery. Political contribution As per policy, RSJ or individuals shall not make any contribution in cash or in kind (or indirectly in any forms), to support a political / religious cause to obtain or retain a business or other advantage to RSJ. This includes gifts of property or services, advertising or promotional activities endorsing a political parties, organization or individuals engaged in politics, and the purchase of tickets to fundraising events. Charitable contributions and sponsorships 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. Facilitation Payments 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 associates shall not involve in any facilitation payments. RSJ considers this as a bribe and prohibit them. Gifts, Hospitality, and expenses 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. 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 to employees, agents & intermediaries to adhere principle governing fair business conduct 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.

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 intentionally 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 or tendering 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, safe and meeting all legal requirements (Statutory & regulatory).

1.6.2. Associate(s) health & 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 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 and re-fresher training to existing associates which includes specific modules on health and occupational hazards including safety risks during on site work.

1.6.9. RSJ encourages employees to report issues related to 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, bullying, 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 legislative 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 labor.
  • make the terms and conditions of employment available to all associates before their employment is started - no forced and compulsory labor or coerced labor shall be tolerated as part of disciplinary measures
  • 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, make reports, seek advice or ask questions.
  • Ensure equal opportunities in the workplace.


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

2.1.2. Compliance Principles and Rules RSJ Management is committed for implementing its compliance programme by publishing and adopting, addressing all the key elements of TIC Council Compliance Principles and Requirements for implementation throughout its organization. RSJ shall require submitting 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 TIC Council Code.

 2.1.3. Compliance officer Board of Directors has nominated a Compliance officer 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. 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 RSJ Board of Directors has appointed a Compliance Committee Members 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. The Compliance Committee consists of CEO, Compliance officer, HR Manger. The terms of reference of the compliance committee are as under a) Review of the 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 Prior to job offer, prospective employees shall be informed of the Compliance Programme. 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 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. 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. 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 form, inform them of their responsibilities and make sure they understand the behaviour of any breach of the Program will result in serious discipline. 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. 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. 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 All employees, including managers of the RSJ undergo a Compliance training course & records of each employee shall be maintained.

2.2.4. Employee “Helplines” 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. The help line shall be operated by Compliance officer. Compliance Officer -

Abhishek Kumar


B-58, 2nd Floor, Sector – 60, Noida (UP) 201307.

Tel: + 91 7973868851

Email: [email protected]

2.2.5 Encouraging Employees to report details of violation or suspected violations. If anyone reporting violation related to bribery & ethics shall be protected against any form of reprisal unless he/she acted maliciously or in bad faith. Reporter (employees, Intermediaries, & Joint Venture Partners) shall be rewarded for each substantiated violations & a commendation letter will be issued by compliance officer.

2.3. Safeguarding confidential business information

2.3.1. Security Measures RSJ has implemented adequate security measures in organization premises and containing confidential business information to ensure that access is restricted to authorised personnel. 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. All documents are controlled by respective department manager and disposed of in a secure manner.

2.4. Communication

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 RSJ has published its compliance program on website 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: If staff has any questions or concerns about the implementation or interpretation of the Compliance Program, they can always contact their direct manager or and "Compliance Officer" for advice through suggestion box. If necessary, the question must be reasonably within the scope of application to ensure confidentiality and anonymity.

2.4.3. Reporting of Violations 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. 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. 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

2.5. 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 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. 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, The maintenance of records of all violations that have been reported, and subsequent measures taken. The author of such alleged violation shall have the right to be heard. 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. Compliance officer will hold the control over progress of the investigation or on nominated investigating staff & responsible to prepare periodic summary reports for the investigation, violation established & the implementation of corrective action & disciplinary measures. 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. Procedure PM 19 has been established for conducting investigations and sanctions.

2.5.2. Business Partners 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 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) 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. 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. 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. Further RSJ shall provide the appropriate training and support to all intermediaries and other parties as appropriate. 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. Procedure PM 20 has been established for Procedure for contracting with business partners.

2.5.3.TIC Council Complaints Handling Procedure Complaints concerning alleged non-compliance with TIC-Council compliance Code by other TIC Council members shall be lodged with 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. RSJ shall comply with provision of TIC-Council complaint handling procedure (http://www.ifia in respect of any complaint received by TIC council against RSJ by another party who is not a Full approved 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 TIC Council. When complaint is made against the RSJ by a Full TIC council member, RSJ shall fully co-operate with the investigations carried out by TIC council and submit any information required in this regard. RSJ shall also comply with requirements of review committee held by TIC global board, or any appeal made in this regard. Breaches of TIC council compliance Code may lead to sanctions imposed by the 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.

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.

  • 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.

b) 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 RSJ’s due diligence procedures as required.

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

  • Political contributions
  • Charitable contributions and sponsorships
  • Expenditures relating to gifts, hospitality, and expenses.
  • Intermediaries’ remuneration

d) Health & Safety

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

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