Impartiality Policy (CHSPS-GOV-002)

Field	Value
Document ID	CHSPS-GOV-002
Title	Impartiality & Conflict of Interest Policy
Edition	2026.1
Status	Published Policy — effective August 19, 2026
Owner	Impartiality & Ethics Committee
Supersedes	New document
Next review	No later than August 2028, or earlier upon material change
Publication authority	CHSPS controlled-document publication authority

Purpose

To ensure that every accreditation-relevant judgment of CHSPS — eligibility determinations, technical findings, validation outcomes and accreditation decisions — is made free of commercial, financial, personal or organizational influence, and is seen to be so.

1. Scope

1.1 This policy applies to every covered person: commissioners, council and committee members, panel members, employees, technical reviewers, validators, technical specialists, contractors, and any person acting for CHSPS in an accreditation-relevant matter.

1.2 It applies to actual, potential and perceived conflicts alike. Where a reasonable, informed observer could doubt impartiality, this policy treats the conflict as real.

2. Definitions

2.1 Conflict of interest: any interest, relationship or activity that could impair, or reasonably appear to impair, a covered person’s independent judgment in a CHSPS matter — including employment, consulting, board service, financial holdings, close personal relationships, and competitive relationships.

2.2 Accreditation-relevant matter: any eligibility determination, review, finding, validation, reconsideration, decision, appeal, complaint investigation, or standards interpretation affecting an identifiable organization.

2.3 Cooling-off period: the interval during which a prior relationship bars participation, as fixed in Section 6.

3. General principles

3.1 No fee, dues payment, education purchase, sponsorship or other consideration shall influence any accreditation-relevant judgment, and no covered person shall suggest otherwise.

3.2 Every accreditation decision shall rest on the documented record and the published standards, and on nothing else.

3.3 Education, membership and other revenue programs shall be operated separately from the accreditation function; persons with sales responsibilities shall have no role in, and no advance knowledge of, accreditation-relevant judgments.

3.4 No covered person’s compensation shall depend, in whole or in part, on the outcome of any accreditation-relevant matter or on accreditation-revenue targets.

4. Disclosure

4.1 Each covered person shall file a written interest disclosure on appointment or engagement, annually thereafter, and within 10 business days of any material change.

4.2 Before each assignment, reviewers, validators and decision-makers shall additionally attest in writing that they have no conflict with the specific organization and scope, or shall disclose the potential conflict for screening.

4.3 Disclosures shall identify, at minimum: employers and clients (past 36 months), board and volunteer roles, financial interests in organizations subject to or seeking CHSPS accreditation, close personal relationships with such organizations’ personnel, and competitive relationships.

4.4 Failure to disclose a known conflict is itself a violation of this policy, independent of whether the conflict would have required recusal.

5. Screening and recusal

5.1 Per-assignment attestations shall be screened before work begins: for reviewers and validators by the accreditation function’s management; for committee and panel members by the body’s chair; for a chair, by the Impartiality & Ethics Committee.

5.2 Where a conflict exists or reasonably appears to exist, the covered person shall be recused from the matter. Doubt shall be resolved in favor of recusal.

5.3 Every recusal — voluntary or directed — shall be recorded in the file, including the person, the matter, the nature of the conflict and the date.

5.4 If recusals defeat a quorum, the matter shall be deferred to the body’s next session with substitute members seated under the applicable charter; a matter shall never proceed without quorum.

6. Prohibited participation and cooling-off periods

6.1 A covered person shall not participate in any accreditation-relevant matter concerning an organization that employs them, employed them within the past 24 months, or with which they have a consulting, financial or close personal relationship.

6.2 A person who has provided applicant-specific consulting, training or advisory services to an organization shall not review, validate for, or decide upon that organization’s scope for 24 months after the engagement ends.

6.3 A reviewer or validator shall not provide consulting or advisory services to an organization whose scope they reviewed for 12 months after the review concludes.

6.4 A person shall not serve simultaneously in the review of a matter and in the decision on that same matter; decision-makers shall not have participated in the underlying review, applicant education, or applicant support.

7. Gifts and hospitality

7.1 Covered persons shall not accept gifts, hospitality or other benefits from applicants, accredited organizations, or their agents, other than items of nominal value (under USD 50) incidental to ordinary professional interaction — and none whatsoever from an organization with a matter actively before that person.

7.2 Offers exceeding these limits shall be declined and reported to the Impartiality & Ethics Committee within 5 business days.

8. Structural safeguards

8.1 Reviewers and decision-makers shall not receive information about an organization’s membership status, education purchases or sponsorships, except where administrative conflict screening itself requires it.

8.2 The Accreditation Decision Committee, the Appeals Panel and the Impartiality & Ethics Committee shall each be composed so that no single stakeholder category holds a controlling majority.

8.3 CHSPS shall not provide applicant-specific consulting, evidence pre-approval, or predictive assessments of accreditation outcomes.

9. Breach, sanctions and reporting

9.1 Suspected violations may be reported by anyone, confidentially, through the published complaints channel; good-faith reporters shall be protected from retaliation.

9.2 The Impartiality & Ethics Committee shall investigate credible reports and may direct remedies including removal from a matter, re-performance of tainted work, suspension or termination of authorization or appointment, and — where a decision was materially affected — referral of the decision for review.

9.3 Outcomes of breach investigations shall be recorded; material breaches affecting a decision shall be disclosed to the affected organization.

10. Records

10.1 Disclosures, attestations, screening determinations, recusal records and breach investigations shall be retained per the Confidentiality & Accreditation Records Policy (CHSPS-ACC-104), and recusal records shall be retained for no fewer than 7 years.