Programme Policies & Procedures Manual
ASF Surveyor Training Programme — Governance, Conduct, Complaints & Ethics Framework
Aligned with ISQua EEA STP 4th Edition (2021) Criteria 1.4, 2.5, 2.6, 3.4
ISQua EEA STP Criteria Addressed
| Criterion | Exact ISQua Text (4th Ed., 2021) | Status |
|---|---|---|
| 1.4 | “The organisation has documented policies and procedures that govern the surveyor training programme.” | MET |
| 2.5 | “The organisation has a policy for managing conflicts of interest in the training programme.” | MET |
| 2.6 | “The organisation has a code of conduct for trainers and surveyors.” | MET |
| 3.4 | “The organisation has a formal complaints and appeals procedure available to trainees.” | MET |
1. Programme Governance Policy (Criterion 1.4)
The ASF Surveyor Training Programme is governed by a documented framework comprising this Policies & Procedures Manual, the Programme Handbook, the Assessment Framework, and the Risk Register. Together, these documents constitute the complete policy suite required by ISQua EEA STP criterion 1.4.
1.1 Policy Hierarchy
- Level 1 — Strategic: ASF Board-approved Mission, Vision & Accreditation Strategy; ISQua Compliance Statement
- Level 2 — Operational: This Policies & Procedures Manual; Programme Handbook; Assessment Framework & Performance Management Policy
- Level 3 — Supporting: Module-specific Learning Guides; Mentor Handbook; Trainer Delivery Notes
1.2 Document Control
- All Level 1–2 documents are version-controlled with issue date, version number, and named document owner
- Annual review is mandatory; ad hoc review required following any ISQua guidance update, incident, or audit finding
- Superseded versions are archived in the ASF Quality Management System (QMS) for a minimum of 7 years per French archiving law (Décret n°79-1037 du 3 décembre 1979)
- Trainees, trainers, and surveyors are notified of material policy changes within 10 working days of approval, via the LMS notification system
2. Conflict of Interest Policy (Criterion 2.5)
ASF is committed to ensuring that all training, assessment, and accreditation decisions are free from conflicts of interest. This policy applies to all trainers, assessors, mentors, Board members, and programme staff.
2.1 Definition
A conflict of interest exists when a person’s private interests (financial, professional, personal, or familial) could improperly influence or be perceived to influence their professional judgement or actions in relation to the Surveyor Training Programme.
2.2 Mandatory Disclosure Requirements
- All programme participants must complete a Conflict of Interest Declaration Form before each training cohort, assessment event, and accreditation survey assignment
- Declarations must be updated within 5 working days of any new actual or potential conflict arising
- Completed declarations are retained in the ASF QMS for a minimum of 5 years
2.3 Management of Disclosed Conflicts
- Minor conflict (perceived, low risk): disclosed and noted; individual may continue with heightened monitoring by the Ethics Officer
- Moderate conflict (actual, manageable): individual is recused from the specific decision/assessment; substitute arranged within 5 working days
- Major conflict (actual, unmanageable): individual is removed from the programme component; Board notified; decision reviewed by independent panel
3. Code of Conduct (Criterion 2.6)
All trainers, mentors, assessors, and surveyors associated with the ASF Surveyor Training Programme are bound by the ASF Code of Conduct. Acceptance of appointment constitutes acceptance of this Code. The Code is reviewed annually by the Ethics Officer and approved by the Board.
3.1 Core Principles
- Integrity: Act honestly, transparently, and in accordance with stated roles and responsibilities at all times
- Impartiality: Conduct all training, assessment, and survey activities without favour, bias, or conflict of interest
- Confidentiality: Protect the confidentiality of trainees, facilities being surveyed, and programme materials in accordance with GDPR and ASF data protection policy
- Professional competence: Maintain the qualifications and continuing professional development (CPD) required for their programme role
- Respect: Treat all colleagues, trainees, and facility staff with dignity and respect, in accordance with the French anti-discrimination framework (Loi n°2008-496 du 27 mai 2008)
- Accountability: Accept responsibility for decisions made in their professional capacity; cooperate fully with any investigation or complaints process
3.2 Prohibited Conduct
- Falsification or misrepresentation of assessment findings or trainee performance records
- Acceptance of gifts, hospitality, or other benefits from facilities being surveyed, beyond a de minimis threshold (€50 per occasion, €150 per year)
- Disclosure of confidential programme information to third parties without authorisation
- Any conduct constituting harassment, bullying, or discrimination under French law
- Engaging in any activity that creates or could create a conflict of interest without prior disclosure
3.3 Consequences of Breach
Breaches of this Code are investigated by the Ethics Officer and may result in: formal written warning; suspension from programme activities; removal from the ASF surveyor register; referral to the relevant professional regulatory body where applicable.
4. Complaints & Appeals Procedure (Criterion 3.4)
ASF is committed to providing a fair, transparent, and accessible complaints and appeals process for all trainees and programme participants. This procedure is published on the ASF website and communicated to all trainees at programme induction.
4.1 Scope
This procedure covers complaints and appeals relating to: assessment decisions; trainer or mentor conduct; programme administration; discrimination or unfair treatment; any other aspect of the Surveyor Training Programme.
4.2 Informal Resolution (Stage 1)
- Trainees are encouraged to raise concerns informally with their trainer or the Training Coordinator in the first instance
- Informal resolution should be attempted within 10 working days of the concern being raised
- Outcome documented in the trainee’s programme file
4.3 Formal Complaint (Stage 2)
- If informal resolution fails or is inappropriate, the trainee may submit a written formal complaint to the Quality Director within 20 working days of the event giving rise to the complaint
- The Quality Director acknowledges receipt within 5 working days
- Investigation completed and written outcome communicated within 30 working days
- Complainant has the right to be accompanied by a colleague or representative at any meeting
4.4 Independent Appeal (Stage 3)
- If unsatisfied with the Stage 2 outcome, the trainee may appeal to the ASF Board Appeals Panel (3 members, majority non-executive) within 10 working days of receipt of the Stage 2 outcome
- The Appeals Panel decision is final within ASF’s processes
- All appeal decisions are communicated in writing within 20 working days
4.5 External Recourse
Trainees retain the right to refer complaints to the Médiateur de la consommation (consumer mediator) or relevant professional body at any stage, as required by French law (Loi n°2015-990 du 6 août 2015, Art. L.616-1 Code de la consommation). ISQua is informed of systemic complaints trends as part of the annual accreditation self-assessment.
References & Regulatory Basis
ISQua Accreditation Standards 5th Edition — §3.2 Conflict of interest in accreditation organisations. isqua.org
Loi n°2008-496 du 27 mai 2008 — portant diverses dispositions d’adaptation au droit communautaire dans le domaine de la lutte contre les discriminations. JORF, 28 mai 2008.
Loi n°2015-990 du 6 août 2015 (Loi Macron) — Art. L.616-1 Code de la consommation: obligation de médiation de la consommation.
Décret n°79-1037 du 3 décembre 1979 — relatif à la compétence des services d’archives publiques et à la coopération entre les administrations pour la collecte des archives.
GDPR — Regulation (EU) 2016/679 — Art. 5(1)(f) (integrity and confidentiality), Art. 25 (data protection by design).