{"id":6918,"date":"2015-02-15T19:48:42","date_gmt":"2015-02-15T19:48:42","guid":{"rendered":"https:\/\/amtivo.com\/us\/resources\/conflict-of-interest-gift-policy\/"},"modified":"2025-11-12T11:18:18","modified_gmt":"2025-11-12T11:18:18","slug":"conflict-of-interest-gift-policy","status":"publish","type":"resources-filter","link":"https:\/\/amtivo.com\/us\/resources\/technical\/conflict-of-interest-gift-policy\/","title":{"rendered":"Conflict of Interest &amp; Gift Policy"},"content":{"rendered":"<p>The purpose of this publication is to provide our customers, auditors, and employees with an explanation of our policies around avoiding Conflicts of Interest (COI), and our Gift Policy. The topic of Conflict of Interest is often not well understood, and as a result, we have noted a great deal of confusion regarding why our Conflict of Interest guidelines and Gift Policy have been constructed in a manner which appears to some to be highly and\/or unnecessarily restrictive.<\/p>\r\n<p>From our standpoint, our policies on avoiding Conflicts of Interest and accepting Gifts is a natural outgrowth of a firm which strives to operate on the basis of three critical elements:<\/p>\r\n<ul>\r\n\t<li>Transparency: the customer will always be able to understand all of the parameters associated with every audit, and the data-based basis for the audit results<\/li>\r\n\t<li>Integrity: the auditors supplied by Amtivo will always be individuals of the highest integrity, and will operate in such a way so as to provide an audit result that is a function of the audited conditions, and only those observed and\/or documented conditions<\/li>\r\n\t<li>Ethical Standards: all audits conducted by Amtivo personnel are conducted with industry-leading standards and expectations of ethical behavior.<\/li>\r\n<\/ul>\r\n<p>Given these expectations, it should not be surprising that Amtivo has established policies that lead rather than follow or match those of our competitors. Rather than dilute our ethical standards, or apologize for our policies, the material in this publication has been prepared and disseminated in order to explain our view of the Conflict of Interest issue in general, and the rationale for our Gift Policy specifically, which is intended to scrupulously avoid any question of Conflict of Interest issues in any audit we support or conduct. We believe that these policies are absolutely critical for a firm which depends upon its reputation as an auditor of unparalleled integrity.<\/p>\r\n<h2>Integrity and Ethics<\/h2>\r\n<p><strong>What Does Amtivo Expect of Its Employees and Subcontractors?<\/strong><\/p>\r\n<ul>\r\n\t<li>Amtivo expects its employees and subcontractors to follow the policy established by Amtivo&#8217;s Committee to Safeguard Impartiality (CSI), especially during the conduct of an audit or audit-associated services;<\/li>\r\n\t<li>Amtivo expects its employees and subcontractors to follow the Amtivo &#8220;Conflict of Interest and Impartiality Procedure&#8221;, and not accept any gifts or favors; especially during the conduct of an audit or audit-associated services;<\/li>\r\n\t<li>Amtivo expects its employees or subcontractors to report any instance where gifts or favors are offered by a client or customer prior to or during the conduct of a contracted Amtivo service. This report should be made to the appropriate Amtivo manager, who will forward the report to the President of Amtivo and the Chairman of the CSI.<\/li>\r\n<\/ul>\r\n<p><strong>What Does Amtivo Request from Its Clients and Customers?<\/strong><\/p>\r\n<ul>\r\n\t<li>Amtivo would request that its clients and customers recognize the importance of Amtivo&#8217;s COI policies and Gift policies to the long-term health of Amtivo, as well as to the integrity of the results of every audit performed by Amtivo personnel or its subcontractors.<\/li>\r\n\t<li>Amtivo personnel or subcontractors may be uncomfortable refusing gifts as required by Amtivo policy, because they (understandably) do not wish to offend the client or customer. We believe the best way to avoid this situation is to have every client or customer understand our gift policy, appreciate the rationale and reasoning behind it, and to assist us in avoiding an actual or apparent COI by not offering any gifts to Amtivo employees or subcontractors (unless specifically permitted within the written agreement with Amtivo).<\/li>\r\n<\/ul>\r\n<p>&nbsp;<\/p>\r\n<h2>Questions and Clarifications<\/h2>\r\n<p>From time to time, questions may arise as related to a potential conflict of interest situations or the Amtivo gift policy, as related to what may and may not be permissible. These questions may be sent directly to Amtivo\u2019s Committee to Safeguard Impartiality at <a title=\"csi@orioncertification.com\" href=\"mailto:csi.us@amtivo.com\">csi.us@amtivo.com<\/a>. The Committee will respond to these queries as quickly as possible. The Committee contains one Amtivo staff member, one Amtivo international representative and 3 or more non-Amtivo volunteers representing a variety of stakeholders. The purpose of the Committee is to act independently of Amtivo, reviewing information, conducting investigations and submitting binding and non-binding advice to Amtivo, in order to ensure that Amtivo remains impartial and to help Amtivo properly address any potential conflict of interest situations.<br \/>\r\nThe CSI subsequently unanimously approved the following policy: No partners, employees\/subcontractors of Amtivo shall accept any kind of gifts including entertainment, regardless of monetary value, from any individual or organization external to Amtivo that: (1) has any type of financial working relationship with Amtivo; or (2) has the potential to have any financial or working relationship with Amtivo. The CSI further recommended that unsolicited gifts received should either be returned or donated to a charitable organization, but our desire is that through the distribution of this document, such a situation will be totally avoided in the future.<\/p>\r\n<p>It should be noted that this policy is essentially identical to the policy previously specified in Amtivo Technical Procedure 02, which reads (in part): \u201c9.3c) Amtivo personnel and subcontractors\u2026may not solicit any gift or other item, nor accept any gift or other item, of monetary value from any person or entity seeking audit services.\u201d Since all gifts, including \u2018tokens\u2019 have some monetary value, however small and possibly inconsequential as considered by the two parties (but not necessarily to an outside observer), the CSI did not see the change from \u2018any monetary value\u2019 to \u2018regardless of monetary value\u2019 as a fundamental change in this policy, except to make Amtivo&#8217;s position on gifts very clear. It is very true that many firms view gifts from customers or clients to its employees and subcontractors with a less strict perspective. The value of the gift, its purpose, the circumstances under which the gift is given, accepted business practice in the industry, and the relationship between the gift giver and recipient are all factors which are commonly considered. This explains some companies\u2019 policies which allow employees to accept gifts worth, for example, less than $25.00.<\/p>\r\n<p>The problem for Amtivo is that we are not a \u2018typical\u2019 company, providing products or services to customers where COI issues are of interest, but not a matter of life or death for the reputation of the firm. Amtivo provides its clients with audit services that are intended and expressed to be performed at the highest possible levels of impartiality and objectivity; which in turn requires transparency, integrity, and the highest levels of ethical standards. As a result, Amtivo cannot tolerate a \u2018relaxed\u2019 standard for gift-giving in the auditee-auditor relationship. It is important to note that this policy does not apply to those services provided by the client to the auditor during the conduct of the audit which are an integral part of the contract or written agreement that Amtivo has with the client. For example, meals and refreshments which are included in the written agreement do not constitute \u2018gifts\u2019 under this policy. Supplies provided by the client for the conduct of the audit such as temporary office space, internet access, writing tools and tablets are likewise included in the written agreement, and are not considered \u2018gifts\u2019 for the purpose of this policy.<\/p>\r\n<p>For R2 clients, additional external requirements apply. For R2 clients, neither Amtivo nor any Auditor shall accept any hospitality, entertainment or in cash of any kind from the R2 Facility subject to the audit or its vendors that could influence their professional judgments and create potential or actual conflicts of interest. Reasonable meals on-site during the audit may be accepted. In addition, Amtivo and Auditors shall ensure that they do not engage in a paid or reciprocal relationship with consultants, owners, or employees working for the R2 Facility before, during or after the audit in a way that could appear to influence the Auditor and\/or Amtivo&#8217;s judgement and impartiality. Amtivo shall document and manage any allegations of bias or conflicts of interest in accordance with our complaints process and\/or internal corrective action process.<\/p>\r\n<h2>The Amtivo Gift Policy<\/h2>\r\n<p>In those instances where common practice within a particular industry and\/ or nation employs the exchange of gifts as a necessary basis for conducting business, and where both Amtivo and its client in those conditions recognize that this is the case, then this exclusion will be written into the contract between Amtivo and the client on a case-by-case basis, and the employee\/subcontractor will be advised of the terms and parameters around which the gift may be accepted. However, under no circumstances does the Amtivo employee\/subcontractor have the authority to make this decision on their own, as this would open Amtivo up to (at the very least) an apparent COI; which is under no circumstances acceptable.<\/p>\r\n<h2>The Exception to the Rule<\/h2>\r\n<h3><strong>Conflict of Interest &#8211; An Overview &amp; the Risk to Amtivo<\/strong><\/h3>\r\n<p>Conflicts of Interest (COI) in the case of Amtivo business activity occurs in any instance when any Amtivo employee or auditor is:<\/p>\r\n<p>Engaged in carrying out any audit or audit-related task on behalf of Amtivo; and the employee or auditor has or appears to have a personal interest in the outcome of the audit or audit-related task; and The employee or auditor is operating under the assumption of complete independence in their judgment and in the way they are performing their tasks. In essence, a COI will exist in any audit when employees have some form of interest that either can, or can appear to, motivate them to conduct the audit or some audit-related activity that is not in the best interest of Amtivo; which fundamentally is to be recognized as a source of audit services that is unparalleled in transparency, integrity, and which are of the highest ethical standards. A COI may be objective (financially-related, such as associated with bribes) or subjective (conflicts based on personal relationships, favors, or emotional relationships). A COI may also be either actual or potential depending on the status of assignments to individuals; and an additional distinction relates to individual versus organizational conflicts. This last distinction is very revealing in the context of how Amtivo is structured and has chosen to operate. An organizational COI exists when a firm is performing work for two clients with competing interests, or when a firm is providing two sets of services to a single client, where those services represent competing interests. Arthur Anderson, which provided both auditing and management consulting services to their clients, was clearly engaged in unethical behavior based on this clear COI, which ultimately led to scandal and their downfall. Amtivo has historically taken a position that this is an unethical condition, would represent an organizational COI, and refuses to use the technique that others have employed of constructing an \u2018artificial wall\u2019 between the audit and consulting groups. What is unethical may still be legal, but Amtivo operates at a higher level of ethics than the minimum standard required by what is simply legal. Because of this, Amtivo does not offer any consulting services. Perhaps the most difficult aspect of managing COI issues is related to the situation where an apparent COI exists. This situation exists when no actual COI exists, and no wrongdoing may have actually occurred, but where an appearance of ethical wrongdoing may exist. In essence, apparent COI situations are based on whether some external observer, viewing the situation, might logically conclude that some inappropriate behavior has taken place. Apparent COI situations can undermine the reputation of a firm, because although no actual unethical behavior may have taken place, the impartiality and fairness of the firm\u2019s products\/services may come into question or doubt \u2013 a kiss of death for a firm that strives to provide impartial audits. A concern that we proactively avoid this particular COI is the primary rationale behind Amtivo&#8217;s gift policy.<\/p>\r\n<h2>Frequently Asked Questions<\/h2>\r\n<p><strong>I worked in industry in three different companies, and they all had policies that allowed employees to accept gifts as long as they were low in value (e.g. $25.00 or $50.00). Why won\u2019t Amtivo operate in this way?<\/strong><\/p>\r\n<p>First, the firms you worked in with this sort of policy probably weren\u2019t auditors. If they were, they also probably maintained a number of other policies that made their ethical standards questionable. It is simply Amtivo&#8217;s position that any gift of any monetary value has the potential to affect, or seem to affect, the outcome of an Amtivo audit. Second, the setting of the amount is completely arbitrary; why $25.00? Is $25.50 so different? Why? And, what is included in the value assigned to the gift? Shipping costs? Taxes? Finally, who sets the value of the gift? If a<br \/>\r\ncustomer can obtain a $300.00 (retail) Netbook for $24.95 by making a large-quantity purchase, put their firm\u2019s name on the cover, and hand them out, does it become a gift worth less than $25.00? These are not issues we want to try to deal with, in that there is no \u2018upside\u2019 to auditors accepting gifts of any monetary value. We simply avoid all this confusion when customers do not offer gifts of any kind, and we do not solicit or accept them if they are offered.<\/p>\r\n<p><strong>I accepted a number of small gifts and tokens from a customer I was auditing during the conduct of the audit. None of the individual items were worth a great deal of money, and after the audit, I presented the customer with 18 nonconformances. Doesn\u2019t that prove that the gifts had no effect on the outcome of the audit, and eliminate the COI problem?<\/strong><\/p>\r\n<p>No, it doesn\u2019t eliminate the issue. First, and remember that no wrongdoing need to have occurred to have a COI issue, how would an external observer know that there would not have been an even higher number of nonconformances had the gifts\/tokens not been given and accepted? What would the next customer think, if s\/he received an audit result of 45 nonconformances after giving you no gifts, were they to find out the result of the previously-referenced audit and the fact that you had accepted these gifts? We implore our customers not to put our auditors or employees in this position, and we direct our auditors to accept no gifts.<\/p>\r\n<p><strong>What if the customer gives gifts to all the auditors conducting audits in their firm\u2019s locations. Since everyone received the same gift, does that make it OK?<\/strong><\/p>\r\n<p>No. We cannot control what others do. At Amtivo, we do not accept that such behavior is supportive of our objectives of Transparency, Integrity, and Ethical Standards.<\/p>","protected":false},"excerpt":{"rendered":"Discover our policies around avoiding Conflicts of Interest, and our Gift Policy. Learn why transparency, integrity and ethical standards are key.","protected":false},"author":24,"featured_media":8379,"template":"","resource":[21],"resource-tag":[],"class_list":["post-6918","resources-filter","type-resources-filter","status-publish","has-post-thumbnail","hentry","resource-technical"],"acf":[],"yoast_head":"<!-- This site is optimized with the Yoast SEO Premium plugin v27.2 (Yoast SEO v27.2) - https:\/\/yoast.com\/product\/yoast-seo-premium-wordpress\/ -->\n<title>Conflict of Interest &amp; Gift Policy - Amtivo<\/title>\n<meta name=\"description\" content=\"Read an explanation of our policies around avoiding Conflicts of Interest (COI), and our Gift Policy. 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