DISCIPLINARY FRAMEWORK AND PROCEDURES  
Section 1 – Introduction  
APSCA has adopted a Code and Standards of Professional Conduct (Code) which  
establishes the expected level of professional conduct by APSCA Members. Consistent  
with its mission of increasing the value and effectiveness of independent social compliance  
audits by enhancing their professionalism and consistency, and the credibility of individuals  
and organizations performing them, APSCA has the authority to enforce the Code. This  
includes disciplining Member Auditors and Member Firms who violate the provision of the  
Code. This Disciplinary Framework and Procedures (Disciplinary Procedures) describes the  
processes for enforcing the Code with respect to Member Auditors and Member Firms, and  
the bodies authorized to do so.  
This document should be read in conjunction with the Code, Competency Framework and  
Glossary of Terms.  
Section 2 – Definitions  
A. Director of Code and Compliance means the APSCA employee/s or  
representative responsible for administering the disciplinary process.  
B. Member means a Member Auditor or a Member Firm.  
C. Member Auditor means an auditor who is enrolled and in good standing with  
APSCA in either an ASCA, or CSCA capacity.  
D. Member Firm means an audit firm that is a member of APSCA and provides  
social compliance audit services.  
Section 3 – Disciplinary Boards  
These Disciplinary Procedures describe the jurisdiction of the bodies authorized to enforce  
the Code, and their membership, rules, and procedures. These bodies are:  
A. The Disciplinary Board for Member Auditors (DBMA) reviews alleged violations  
of the Code by Member Auditors, and where appropriate, imposes disciplinary  
sanctions on a Member Auditor.  
B. The Disciplinary Board for Member Firms (DBMF) reviews alleged violations of  
the Code by Member Firms, and where appropriate, imposes disciplinary  
sanctions on a Member Firm.  
C. The Appeals Board for Member Auditors hears and decides appeals of decisions  
by the DBMA.  
D. The Executive Board of APSCA operates as the appeals board for Member Firms  
and hears and decides appeals of decisions by the DBMF.  
Section 4 – Disciplinary Board for Member Auditors (DBMA)  
4.1 Jurisdiction  
The DBMA oversees the disciplinary process for Member Auditors. It is authorized to:  
A. Make rules for the handling of complaints against Member Auditors and the  
discipline of Member Auditors.  
B. Hear and decide cases involving alleged acts or omissions that violate the Code.  
Document Name:  
Version & Date:  
Replaces:  
APSCA Disciplinary Framework and Procedures-D-029  
Version 4 – September 2022  
Version 3 – September 2020  
Author/Owner: APSCA Code & Compliance Team  
Authorized by: Executive Board  
Date Printed: 8 September 2022  
This document is no longer version controlled once printed.  
Page 1 of 9.  
C. Discipline Member Auditors when it determines there has been a violation of the  
Code.  
D. Take other such actions as is reasonably necessary to ensure an efficient and  
effective disciplinary system for APSCA.  
4.2 Membership of DBMA  
A. Membership of the DBMA shall consist of five representatives, one of which shall  
be the Chair, as follows:  
i. Two independents member with a legal, ethics or other relevant  
background, one of who shall be the Chair.  
ii. One representative of the Stakeholder Board.  
iii. Two Member Firm representatives.  
B. The independent members of the DBMA and the Member Firm representatives  
shall be appointed by the Executive Board.  
C. The representative from the Stakeholder Board shall be nominated by the  
Stakeholder Board and ratified by the Executive Board.  
D. The Executive Board shall designate one of the two independent members to  
serve as Chair of the DBMA.  
E. DBMA members shall be appointed for a term of one-year. They may be re-  
appointed for additional terms of one-year each.  
F. In the event of a vacancy on the DBMA, the Executive Board shall appoint a new  
representative for the category, who shall serve for the remainder of the term.  
4.3 Forms of Action  
When the DBMA has reviewed an allegation that a Member Auditor has violated the  
Code, it may take any of the following types of actions.  
A. No Action.  
B. Written Warning: A written warning to the Member Auditor found to have  
violated the Code. Unless otherwise specified by the DBMA, a Written Warning  
will remain in a Member Auditor’s APSCA file for two years, and then be removed.  
C. Demotion: A demotion in the Member Auditor’s level and permitted authority.  
The Member Auditor demoted will be required to re-sit any or all exams  
specified by APSCA and will do so on Pathway 4.  
D. Suspension: A suspension of the Member Auditor’s APSCA membership and/ or  
certification, for a period of up to and including two years. A Member Auditor  
who has been suspended may apply for reinstatement of membership at the end  
of suspension period. The Member Auditor will be required to re-sign and  
upload the Code and may be assigned additional requirements for reinstatement  
of membership, as specified by APSCA. The DBMA reserves the right to require  
the suspended Member Auditor to re-sit specified APSCA Exams.  
E. Revocation of APSCA Certification and/ or Membership: An Auditor whose  
APSCA Membership has been revoked is not able to conduct any Social  
Compliance Audit associated with an APSCA Member Firm. There is no  
reapplication process for a Member Auditor whose Membership has been  
revoked.  
Document Name:  
Version & Date:  
Replaces:  
APSCA Disciplinary Framework and Procedures-D-029  
Version 4 – September 2022  
Version 3 – September 2020  
Author/Owner: APSCA Code & Compliance Team  
Authorized by: Executive Board  
Date Printed: 8 September 2022  
This document is no longer version controlled once printed.  
Page 2 of 9.  
4.4. Procedures for Handling Allegations Regarding Member Auditors That May be  
Referred to the DBMA  
4.4.1. Administrative Matters. The Director of Code and Compliance shall be  
responsible for receiving and preparing case(s) for consideration by the DBMA, for  
circulating an agenda and supporting materials prior to each DBMA meeting and  
recording and implementing decisions made at each meeting. The Director of Code  
and Compliance shall present all case reports to the DBMA in an anonymous format,  
without disclosing the name of the Member Auditor or Member Firm involved, or the  
identity of the person who made the allegation.  
4.4.2. Matters Referred to APSCA by a Member Firm Pursuant to 5.3.2 of APSCA’s Code  
In the event that a Member Firm informs APSCA that a Member Auditor has been  
disciplined for conduct that constitutes a violation of the Code, through the filing of a  
Disciplinary Action Form, or otherwise, the Director of Code & Compliance shall:  
A. Review the Member Firm’s investigation and the grounds for disciplinary action of  
the Member Auditor.  
B. Notify the Member Auditor that APSCA is considering disciplinary proceedings,  
which in some cases may include suspension or revocation of their certification  
and/ or membership.  
C. Provide the Member Auditor with at least 14-days to respond in writing and to  
submit relevant supporting documentation and evidence.  
D. Conduct an independent investigation, if necessary, to collect additional  
information relevant to the proceeding before the DBMA.  
4.4.3. Matters Received Directly by APSCA  
When APSCA receives an allegation that a Member Auditor has violated the Code,  
other than through the Member Firm referral process described above, the Director  
Code and Compliance shall:  
A. Review the allegation to assess if it raises a credible claim. A credible claim is one  
that appears to have been made in good faith, and, if proven, would constitute a  
violation of the Code. If appropriate, the Director Code and Compliance may  
request additional information from the person presenting the allegation before  
making this assessment.  
B. Dismiss a matter if the allegation does not raise a credible claim, or if insufficient  
information is given to pursue an investigation.  
C. If an investigation is warranted, refer the allegation to the relevant Member Firm  
to conduct the investigation and take appropriate action.  
D. If the Director Code and Compliance determines that it is not appropriate to refer  
an allegation to a Member Firm, the Director Code and Compliance may request  
authorization from the President and CEO to conduct an independent  
investigation. If the projected cost of the investigation is not covered by the  
budgets approved by the Executive Committee, the President and CEO shall  
consult with the Chair of the Executive Board, who may in turn consult with the  
Stakeholder Board representatives on the Executive Board.  
Document Name:  
Version & Date:  
Replaces:  
APSCA Disciplinary Framework and Procedures-D-029  
Version 4 – September 2022  
Version 3 – September 2020  
Author/Owner: APSCA Code & Compliance Team  
Authorized by: Executive Board  
Date Printed: 8 September 2022  
This document is no longer version controlled once printed.  
Page 3 of 9.  
4.4.4. Temporary Suspension  
The Director of Code and Compliance, with the concurrence of the Chair of the  
Disciplinary Board, has the authority to temporarily suspend a Membership before  
the completion of an investigation and consideration by the DBMA if the following  
conditions have been met:  
A. A Member Auditor has admitted to the allegation or based on evidence available  
to APSCA there is clear and convincing evidence to substantiate the violation,  
and  
B. The violation is one that is likely to lead to suspension or revocation of  
membership by the DBMA.  
The Member Auditor and any Member Firm/s employing the Member Auditor shall be  
notified in writing of the temporary suspension.  
4.5 DBMA Procedures and Meetings  
A. The DBMA shall meet at least quarterly at the call of the Chair. In the event there  
are no pending cases to be considered by the DBMA, the Chair may decide not to  
hold a quarterly meeting.  
B. The Director Code and Compliance shall keep a record of decisions reached at  
all meetings of the DBMA.  
C. Attendance at DBMA meetings may be in person, by video or by conference call.  
D. Three members of the DBMA shall constitute a quorum of the DBMA, provided  
that at least three of the members are not representatives of Member Firms.  
E. Any Member Auditor subject to a recommendation of discipline shall have the  
right to appear before the DBMA with or without a proxy, provided they confirm  
their participation at least 5 calendar days prior to the DBMA meeting.  
F. No Member Auditor shall be found to have violated the Code unless at least three  
voting members vote to establish the violation, one of which may not be a  
representative of a Member Firm.  
G. The Director Code and Compliance shall notify the relevant Member Auditor in  
writing of the decision of the DBMA. The notice shall inform the Member Auditor  
of the right to appeal the decision to the Appeals Board.  
H. The Director of Code and Compliance shall notify Member Firms currently  
associated with the sanctioned Member Auditor of the decision of the DBMA. The  
notification will include the description of the relevant Code violation and  
decision reached by the DBMA. Details of the investigation will not be disclosed.  
If the sanctioned Auditor Appeals the decision of the DBMA and the sanction is  
changed, applicable Member Firms will be notified.  
Section 5 - Disciplinary Board for Member Firms (DBMF)  
5.1 Jurisdiction  
The DBMF oversees the disciplinary process for Member Firms. It is authorized to:  
A. Make rules for the handling of complaints against Member Firms and the  
discipline of Member Firms.  
Document Name:  
Version & Date:  
Replaces:  
APSCA Disciplinary Framework and Procedures-D-029  
Version 4 – September 2022  
Version 3 – September 2020  
Author/Owner: APSCA Code & Compliance Team  
Authorized by: Executive Board  
Date Printed: 8 September 2022  
This document is no longer version controlled once printed.  
Page 4 of 9.  
B. Hear and decide cases involving alleged acts or omissions that violate the  
obligations of Members Firms under the Code, including Section 2.3 on Integrity  
Management, which requires a Member Firm to “have a system in place to  
identify risks and manage compliance relating to ethics and integrity.”  
C. Discipline Member Firms when it determines there has been a violation of the  
Code.  
D. Take other such actions as is reasonably necessary to ensure an efficient and  
effective disciplinary system for APSCA.  
5.2 Membership of DBMF  
A. Membership of the DBMF shall consist of five representatives, one of which shall  
be the Chair.  
B. None of the members may be officers or employees of any APSCA Member Firm.  
C. The members of the DBMF shall be appointed by the Executive Board which  
shall designate one of the members to serve as Chair.  
D. DBMF members shall be appointed for a term of one-year. They may be  
reappointed for additional terms of one-year each.  
E. In the event of a vacancy on the DBMF, the Executive Board shall appoint a new  
member, who shall serve for the remainder of the term.  
5.3 Forms of Action  
When the DBMF has reviewed an allegation that a Member Firm has violated the  
Code, it may take any of the following types of actions.  
A. No Action.  
B. Written Warning: A written warning to the Member Firm found to have violated  
the Code. Unless otherwise specified by the DBMF, a Written Warning will  
remain in a Member Firm’s APSCA file for two years, and then be removed.  
C. Suspension: A suspension of a portion of a Member Firm membership, such as  
operations in a specific country or region, for a period of up to and including one  
year. A Member Firm whose membership has been suspended for a portion of  
its operations may apply for reinstatement of membership for those operations at  
the end of suspension period. The Member Firm will be required to meet  
reinstatement criteria specified by APSCA.  
D. Revocation: A revocation of the Member Firm’s APSCA membership for a period  
of up to and including one year. A Member Firm whose membership has been  
revoked may apply for reinstatement of membership at the end of revocation  
period. The Member Firm will be required to meet reinstatement criteria  
specified by APSCA.  
5.4. Procedures for Handling Member Firm Allegations That May be Referred to the  
DBMF  
5.4.1. Administrative Matters  
The Director of Code and Compliance shall be responsible for receiving and  
preparing case(s) for consideration by the DBMF, and for circulating an agenda and  
supporting materials prior to each DBMF meeting, and for recording and  
implementing decisions made at each meeting.  
Document Name:  
Version & Date:  
Replaces:  
APSCA Disciplinary Framework and Procedures-D-029  
Version 4 – September 2022  
Version 3 – September 2020  
Author/Owner: APSCA Code & Compliance Team  
Authorized by: Executive Board  
Date Printed: 8 September 2022  
This document is no longer version controlled once printed.  
Page 5 of 9.  
5.4.2. Handling of Matters Received by APSCA  
When APSCA receives an allegation that a Member Firm has violated the Code, the  
Director of Code and Compliance shall:  
A. Review the allegation to assess if it raises a credible claim. A credible claim is one  
that appears to have been made in good faith, and, if proven, would constitute a  
violation of the Code. If appropriate, the Director of Code and Compliance may  
request additional information from the person making the allegation before  
making this assessment.  
B. Dismiss a matter if the allegation does not raise a credible claim, or if insufficient  
information is given to pursue an investigation.  
C. If the Director of Code and Compliance determines that a detailed investigation is  
warranted, the Director of Code and Compliance may request authorization from  
the President and CEO, who may consult the Chair of the Executive Board is  
applicable, to conduct an independent investigation. The Chair of the Executive  
Board shall consult on any such request with the Chair of the DBMF and the  
Stakeholder Board representatives on the Executive Board.  
5.4.3. DBMF Procedures and Meetings  
A. The DBMF shall meet at the call of the Chair. In the event that there are no  
pending cases to be considered by the DBMF, the Chair may decide not to hold a  
quarterly meeting.  
B. The Director Code and Compliance Manager shall keep a record of decisions  
reached at all meetings of the DBMF.  
C. Attendance at DBMF meetings may be in person, by video or by conference call.  
D. The Chair and two other voting members will constitute a quorum of the  
Disciplinary Board  
E. Any Member Firm subject to a recommendation of discipline shall have the right  
to designate a representative to appear with or without a proxy in person or  
remotely, e.g., by video or by conference call, before the DBMF, provided that  
such request is received by APSCA at least ten days prior to the date of the  
DBMF meeting.  
F. The Director of Code and Compliance shall notify the relevant Member Firm in  
writing of the decision of the DBMF. The notice shall inform the Member Firm of  
the right to appeal the decision to the Executive Board.  
If the DBMF revokes the Membership of a Member Firm, Member Auditors  
associated with that Member Firm will also be notified.  
Section 6 - Appeals Board – Member Auditor Cases  
6.1 Jurisdiction  
The Appeals Board is authorized to:  
A. Set the procedures for appeals of decisions by the DBMA.  
B. Hear and decide cases involving appeals of decisions by the DBMA.  
C. Take such other actions as are reasonably necessary to ensure an efficient and  
effective system of appeal.  
Document Name:  
Version & Date:  
Replaces:  
APSCA Disciplinary Framework and Procedures-D-029  
Version 4 – September 2022  
Version 3 – September 2020  
Author/Owner: APSCA Code & Compliance Team  
Authorized by: Executive Board  
Date Printed: 8 September 2022  
This document is no longer version controlled once printed.  
Page 6 of 9.  
6.2 Membership of the Appeals Board  
A. Membership of the Appeals Board shall consist of a Chair and two other  
members, as follows:  
i. The Chair of the Executive Board shall be the Chair.  
ii. The Executive Board shall appoint two Stakeholder Board representatives  
who serve on the Executive Board, provided that if there are not two  
representatives in this category available to become members of the  
Appeals Board, the Executive Board may appoint any representative of the  
Stakeholder Board.  
B. No member may serve as a voting member on both the DBMA and the Appeals  
Board.  
C. In the event of a vacancy in the Stakeholder Board representatives, the Executive  
Board, in consultation with the Stakeholder Board, shall appoint a new  
representative who shall serve for the remainder of the term.  
6.3 Procedures for Handling Member Auditor Requests for Appeal  
A. Any Member Auditor subject to discipline by the DBMA shall have the right to  
submit a written petition for appeal to the Appeals Board. This petition must be  
submitted within 30 days of the date the written notice of the DBMA decision is  
sent to the Member Auditor.  
B. Petitions for appeal shall specify the party filing the appeal, the DBMA decision,  
and shall state clearly the grounds on which review of the decision is being  
sought. The contents of the appeal shall be limited to the evidence submitted to  
the DBMA.  
C. The Director Code and Compliance shall prepare an agenda for Appeals Board  
meetings. The agenda should include the description of the case prepared for  
the DBMA review, the decision of the DBMA, and any materials provided by the  
Member Auditor to support the appeal.  
D. To the extent feasible, the Director Code and Compliance Manager shall present  
all matters to the Appeals Board in an anonymous format, without disclosing the  
name of the Member Auditor or the Member Firm involved.  
6.4 Appeals Board Procedures and Meetings  
A. The Appeals Board shall meet at the call of the Chair.  
B. The Director Code and Compliance and the Chair of the DBMF may attend the  
Appeals Board meeting but shall not have voting rights.  
C. The Director Code and Compliance shall keep records of decisions reached at all  
meetings of the Appeals Board.  
D. Attendance at Appeals Board meetings may be in person, by video, or by  
conference call.  
E. The Chair and one other voting member shall constitute a quorum of the Appeals  
Board.  
F. No decision of the DBMA shall be overturned without the votes of at least two  
voting members of the Appeals Board.  
G. The decision of the Appeals Board is final and cannot be appealed further.  
Document Name:  
Version & Date:  
Replaces:  
APSCA Disciplinary Framework and Procedures-D-029  
Version 4 – September 2022  
Version 3 – September 2020  
Author/Owner: APSCA Code & Compliance Team  
Authorized by: Executive Board  
Date Printed: 8 September 2022  
This document is no longer version controlled once printed.  
Page 7 of 9.  
Section 7 - Executive Board  
7.1 Jurisdiction  
The Executive Board is authorized to:  
A. Set the procedures for appeals of decisions by the DBMF.  
B. Hear and decide cases involving appeals of decisions by the DBMF.  
C. Take such other actions as are reasonably necessary to ensure an efficient and  
effective system of appeal.  
7.2 Procedures for Handling Member Firm Requests for Appeal  
A. Any Member Firm subject to discipline by the DBMF shall have the right to submit  
a written petition for appeal to the Executive Board. This petition must be  
submitted within 45 days of the date the written notice of the DBMF decision is  
sent to the Member Firm.  
B. Petitions for appeal shall specify the Member Firm filing the appeal and the DBMF  
decision and shall state clearly the grounds on which review of the decision is  
being sought. The contents of the appeal shall be limited to the evidence  
submitted to the DBMF.  
C. The Director Code and Compliance shall prepare for the Executive Board a  
description of the case prepared for the DBMF review, the decision of the DBMF,  
and any materials provided by the Member Firm to support the appeal.  
D. The decision of the Executive Board is final and cannot be appealed further.  
Section 8 – Referral of Matters by Disciplinary Bodies  
A. Either the DBMA or the Appeals Board may refer a matter to the DBMF for  
consideration. Situations where such a referral may be appropriate include  
where (i) the Member Firm may have played a significant role in allegations  
involving a Member Auditor or (ii) a violation of the Code by a Member Auditor may  
have involved a pattern of broader misconduct by a Member Firm.  
B. The DBMF or the Executive Board may refer a matter to the DBMA for  
consideration. A situation where such a referral may be appropriate is where a  
Member Auditor in a Member Firm subject to review by the DBMF or the Executive  
Board may have engaged in conduct that may violate the APSCA Code.  
Section 9 – Standard of Review  
A. The standard of review for the DMBA and the DBMF shall be a preponderance of  
the evidence, which generally means “more probable than not.”  
B. The standard of review for the Appeals Board and the Executive Board shall be:  
i.  
For findings of fact, “clear error.”  
ii.  
For findings that, based on the facts, a violation of the Code has been  
substantiated, de novo review.  
iii.  
For determination of the appropriate sanction, “abuse of discretion.”  
Document Name:  
Version & Date:  
Replaces:  
APSCA Disciplinary Framework and Procedures-D-029  
Version 4 – September 2022  
Version 3 – September 2020  
Author/Owner: APSCA Code & Compliance Team  
Authorized by: Executive Board  
Date Printed: 8 September 2022  
This document is no longer version controlled once printed.  
Page 8 of 9.  
Section 10 – Conflict of Interest  
Members of the DBMA, the DBMF and the Appeals Board shall recuse themselves from  
participating in the consideration of any matter where such participation would result in, or  
give the appearance of, a conflict of interest.  
Section 11 – Disciplinary Action Relating to Misconduct During APSCA Exams  
Guidelines for investigations and sanctions of suspected misconduct in connection with  
APSCA certifications exams are set out in a separate document. Actions of the Director  
Code and Compliance under these guidelines are not subject to review by the DBMA unless  
the Director Code and Compliance specifically refers the case to the DBMA for its review  
and action.  
Section 12 – Confidentiality  
Unless disclosure is required by a court order or other applicable legal requirements,  
disciplinary decisions by the APSCA boards shall be confidential to APSCA, provided that  
APSCA may share actions by the DBMA or the Appeals Board with the relevant Member  
Firm, and may publish on its website and elsewhere information on cases individually and  
collectively, provided that the name of the Member Auditor or Member Firm involved is not  
revealed.  
Document Name:  
Version & Date:  
Replaces:  
APSCA Disciplinary Framework and Procedures-D-029  
Version 4 – September 2022  
Version 3 – September 2020  
Author/Owner: APSCA Code & Compliance Team  
Authorized by: Executive Board  
Date Printed: 8 September 2022  
This document is no longer version controlled once printed.  
Page 9 of 9.