APSCA Code and Standards of Professional Conduct (Code)  
Guidance 2 – Use of Subcontractors and Partner organizations  
Issue:  
Clarification regarding the use of Subcontractors and Partner  
organizations  
4.1.3.1 reference to Member Firm  
Applicable APSCA  
Code Section:  
Date Issued:  
April 14, 2021  
Background  
In some instances, Member Firms utilize non-employee resources to perform Social  
Compliance Audits. This is most commonly the case in countries where the Member Firm  
does not have a presence through their own organization. These cases typically involve  
arrangements with either individual Member Auditors (Subcontractors); other Member  
Firms; or other entities (Partner Organizations) that employ or engage Member Auditors.  
APSCA Member Firm designation is limited to the organization (including any identified,  
related entities) which were considered during the APSCA membership application process  
and subject to the related due diligence; and to whom membership was granted. As  
outlined in Section 2.8 of the APSCA By Laws, a Member Firm cannot assign, transfer, or  
extend their APSCA membership.  
While it is acceptable for an APSCA Member Firm to have arrangements with  
Subcontractors; other Member Firms; or Partner Organizations for the completion of Social  
Compliance Audits on their behalf, such audits must be managed consistent with the key  
processes and protocols of the Member Firm that has the obligation to the client and in  
accordance with the Code.  
Section 4.1.3.1 of the Code outlines the requirement for the use of a Member Auditor’s  
APSCA number as follows:  
A CSCA shall include reference to CSCA status and/or their APSCA member number  
only where the scope of work is a Social Compliance Audit and where the work is  
performed on behalf of a Member Firm.  
For audits performed by either Subcontractors; other Member Firms; or Partner  
Organizations, the Member Auditor can only include their RA/CSCA status and/or their  
APSCA member number if the audit has been conducted consistent with the key processes  
and protocols of the identified Member Firm.  
Document Name:  
Version & Date:  
Replaces:  
Guidance 2 Use of Subcontractors and Partner Firms - T-023  
Version 1 – April 14, 2021  
Nil  
Author/Owner: APSCA President & CEO  
Authorized by: APSCA Executive Board  
Date Printed: 26 May 2021  
This document is no longer version controlled once printed.  
Page 1 of 6  
APSCA has, therefore developed this guidance to provide clarity on the acceptable use of  
Subcontractors; other Member Firms; and Partner Organizations.  
Guidance  
In all cases, the Member Firm takes responsibility for the overall process for the effective  
execution (completion) of a Social Compliance Audit.  
Regardless of the Member Firm’s association with an individual Member Auditor, e.g.  
employee; Subcontractor; employee of another Member Firm; or employee or  
Subcontractor to a Partner Organization, the critical elements of all Social Compliance Audits  
performed by and on behalf of a Member Firm must be consistent with the key  
management processes and procedures considered in the evaluation of the Member Firm’s  
APSCA application, which were subject to due diligence and the basis of which membership  
was granted.  
To allow for or support the promotion of the activities of either a Subcontractor and/ or  
Partner Organization that would suggest the Subcontractor or Partner Organization is an  
APSCA Member Firm is a violation of the Code and Standards of Professional Conduct.  
Case Examples  
While not exhaustive, the case examples presented below are intended to provide  
perspective on the application of Guidance 2.  
Case 1  
A Member Firm receives a request for an audit that the Member Firm cannot complete with  
an employee Member Auditor. The Member Firm has an arrangement with a non-employee  
Member Auditor, who is “in good standing” and an RA/CSCA. The Member Auditor, a  
Subcontractor, has been subject to competency evaluation by the Member Firm and has  
been provided training by the Member Firm on the related client and Member Firm  
protocols for the audit. The Member Auditor will complete the key steps in the audit  
consistent with the processes and protocols for the Member Firm. The Member Firm will  
engage with the client on all business elements related to the audit and manage the quality  
and integrity elements associated with the audit. The Member Auditor will be compensated  
directly by the Member Firm for the services related to the completion of the audit.  
In this instance, the audit report can identify the Member Firm and the Member Auditor can  
include their APSCA Member Number on the audit report as the audit was completed by the  
Member Auditor consistent with the processes and protocols of the Member Firm - and the  
Member Firm was responsible for the audit.  
Document Name:  
Version & Date:  
Replaces:  
Guidance 2 Use of Subcontractors and Partner Firms - T-023  
Version 1 – April 14, 2021  
Nil  
Author/Owner: APSCA President & CEO  
Authorized by: APSCA Executive Board  
Date Printed: 26 May 2021  
This document is no longer version controlled once printed.  
Page 2 of 6  
Case 2  
A Member Firm 1 receives a request for an audit that the Member Firm 1 cannot complete  
with an employee Member Auditor. The Member Firm 1 has an arrangement with another  
Member Firm 2. A Member Auditor employed by Member Firm 2 has been subject to  
competency evaluation by Member Firm 1 and has been provided training by Member Firm  
1 on the related client and Member Firm 1’s protocols for the audit. Member Firm 2 will  
assign the identified Member Auditor to complete the audit on behalf of Member Firm 1.  
The Member Auditor will complete the key steps in the audit consistent with the processes  
and protocols for Member Firm 1. Member Firm 1 will engage with the client on all business  
elements related to the audit and takes responsibility for the overall process. Member Firm  
1 will compensate Member Firm 2 for the services related to the completion of the audit.  
In this instance, the audit report can identify the Member Firm 1 – and the Member Auditor  
can include their APSCA Member Number on the audit report as the audit was completed by  
the Member Auditor consistent with the processes and protocols of the Member Firm 1-  
and the Member Firm 1 was responsible for the audit.  
Case 3  
A Member Firm receives a request for an audit that the Member Firm cannot complete with  
an employee Member Auditor. The Member Firm has an arrangement with a Partner  
Organization. A Member Auditor employed by the Partner Organization has been subject to  
competency evaluation by the Member Firm and has been provided training by the Member  
Firm on the related client and the Member Firm’s protocols for the audit. The Partner  
Organization will assign the identified Member Auditor to complete the audit on behalf of  
the Member Firm. The Member Auditor will complete the key steps in the audit consistent  
with the processes and protocols for the Member Firm. The Member Firm will engage with  
the client on all business elements related to the audit and manage the quality and integrity  
elements associated with the audit. The Member Firm will compensate the Partner  
Organization for the services related to the completion of the audit.  
In this instance, the audit report can identify the Member Firm and the Member Auditor can  
include their APSCA Member Number on the audit report as the audit was completed by the  
Member Auditor consistent with the processes and protocols of the Member Firm - and the  
Member Firm was responsible for the audit.  
Document Name:  
Version & Date:  
Replaces:  
Guidance 2 Use of Subcontractors and Partner Firms - T-023  
Version 1 – April 14, 2021  
Nil  
Author/Owner: APSCA President & CEO  
Authorized by: APSCA Executive Board  
Date Printed: 26 May 2021  
This document is no longer version controlled once printed.  
Page 3 of 6  
Case 4  
A Member Firm receives a request for an audit that the Member Firm cannot complete with  
an employee Member Auditor. The Member Firm has an arrangement with a Partner  
Organization that has multiple Member Auditors. The Member Auditors employed by the  
Partner Organization have been subject to competency evaluation by the Member Firm and  
have been provided training by the Member Firm on the related client and the Member  
Firm’s protocols for the audit. The Partner Organization will assign one of the  
evaluated/trained Member Auditors to complete the audit on behalf of the Member Firm.  
The assigned Member Auditor will complete the key steps in the audit consistent with the  
processes and protocols for the Member Firm. The Member Firm will engage with the client  
on all business elements related to the audit and manage the quality and integrity elements  
associated with the audit. The Member Firm will compensate the Partner Organization for  
the services of the assigned Member Auditor related to the completion of the audit.  
In this instance, the audit report can identify the Member Firm and the assigned Member  
Auditor can include their APSCA Member Number on the audit report as the audit was  
completed by the Member Auditor consistent with the processes and protocols of the  
Member Firm - and the Member Firm was responsible for the audit.  
Case 5  
A Member Firm receives a request for an audit that the Member Firm cannot complete with  
an employee Member Auditor. The Member Firm has an arrangement with a non-employee  
Member Auditor, who is “in good standing” and an RA/CSCA. The Member Auditor – a  
Subcontractor – is experienced with execution of audits including audits for the client. The  
Member Auditor will complete the key steps in the audit consistent with the standard  
industry practices and previous engagements for the client. The Member Firm will engage  
with the client on all business elements related to the audit. The Member Auditor will be  
compensated directly by the Member Firm for the services related to the completion of the  
audit.  
In this instance, there is no indication that the audit process was aligned with the key  
protocols and processes of the Member Firm. As a result, the audit report cannot identify  
the Member Firm and the Member Auditor cannot include their APSCA Member Number on  
the audit report as the audit was not completed by the Member Auditor consistent with the  
key processes and protocols of the Member Firm.  
Document Name:  
Version & Date:  
Replaces:  
Guidance 2 Use of Subcontractors and Partner Firms - T-023  
Version 1 – April 14, 2021  
Nil  
Author/Owner: APSCA President & CEO  
Authorized by: APSCA Executive Board  
Date Printed: 26 May 2021  
This document is no longer version controlled once printed.  
Page 4 of 6  
Case 6  
A Member Firm 1 receives a request for an audit that the Member Firm 1 cannot complete  
with an employee Member Auditor. The Member Firm 1 has an arrangement with another  
Member Firm 2. Member Firm 2 is familiar with the client program and has Member  
Auditors experienced with the program. Member Firm 2 assigns a Member Auditor to  
perform the audit consistent with Member Firm 2’s protocols and processes. Member Firm  
2 will take responsibility for all aspects of the audit and the assigned Member Auditor will  
complete the key steps in the audit consistent with the processes and protocols for Member  
Firm 2. Member Firm 1 will engage with the client on all business elements related to the  
audit. Member Firm 2 will manage the quality and integrity elements associated with the  
audit. Member Firm 1will compensate Member Firm 2 for the services related to the  
completion of the audit.  
In this instance, there is no indication that the audit process was aligned with the key  
protocols and processes of Member Firm 1 and Member Firm 2 has taken responsibility for  
the completion of all elements of the audit – including key processes related quality and  
integrity management. As a result, the audit report cannot identify the Member Firm 1 and  
Member Auditor cannot include their APSCA Member Number on the audit report as the  
audit was not completed by the Member Auditor consistent with the key processes and  
protocols of the Member Firm 1 - and the Member Firm 1 was not responsible for all key  
elements of the audit.  
In this case, to the extent there was an agreement with the client that the audit was not  
going to be completed by Member Firm 1 but was going to be completed by Member Firm2  
– the audit report would logically be presented by Member Firm 2. As the audit would then  
have been completed consistent with the key processes and protocols of the Member Firm  
2 – it would be the case that the Member Auditor can include their APSCA Member Number  
on the audit report as the audit was completed consistent with the key processes and  
protocols of the Member Firm 2 – and the Member Firm 2 was responsible for all key  
elements of the audit.  
Case 7  
A Member Firm receives a request for an audit that the Member Firm cannot complete with  
an employee Member Auditor. The Member Firm has an arrangement with a Partner  
Organization that has multiple Member Auditors. Some – but not all – of the Member  
Auditors employed by the Partner Organization have been subject to competency  
evaluation by the Member Firm and have been provided training by the Member Firm on  
the related client and the Member Firm’s protocols for the audit. The Partner Organization  
assigns a Member Auditor that has not been evaluated/trained by the Member Firm to  
complete the audit on behalf of the Member Firm. The assigned Member Auditor will  
complete the key steps in the audit based on standard practices but not necessarily  
consistent with the processes and protocols for the Member Firm. The Member Firm will  
engage with the client on all business elements related to the audit and manage the quality  
Document Name:  
Version & Date:  
Replaces:  
Guidance 2 Use of Subcontractors and Partner Firms - T-023  
Version 1 – April 14, 2021  
Nil  
Author/Owner: APSCA President & CEO  
Authorized by: APSCA Executive Board  
Date Printed: 26 May 2021  
This document is no longer version controlled once printed.  
Page 5 of 6  
and integrity elements associated with the audit. The Member Firm will compensate the  
Partner Organization for the services of the assigned Member Auditor related to the  
completion of the audit.  
In this instance, the Member Firm did not assess the competency of the Member Auditor or  
the process utilized by the Partner Organization to assign the audit and there is no  
indication that the audit process was aligned with the key protocols and processes of the  
Member Firm. As a result, the audit report cannot identify the Member Firm and assigned  
Member Auditor cannot include their APSCA Member Number on the audit report as the  
audit was not completed by the Member Auditor consistent with the key processes and  
protocols of the Member Firm - and the Member Firm was not responsible for all key  
elements of the audit.  
Case 8  
A Member Firm receives a request for an audit that the Member Firm cannot complete with  
an employee Member Auditor. The Member Firm has an arrangement with a Partner  
Organization. The Partner Organization has capacity to perform the audit and will take  
overall responsibility for all aspects of the audit process. The Member Firm has no  
interaction with the Member Auditor related to either the specific audit or broader  
considerations. Additionally, as a result of the arrangement with the Member Firm, the  
Partner Organization presents itself publicly as having the ability to conduct Social  
Compliance Audits that can be signed off by Member Auditors through the Member Firm.  
In this instance, the Member Firm did not assess the competency of the auditor. Given that  
the Partner Organization will take responsibility for all aspects of the audit process – it is  
logical that the audit process will not be aligned with the key protocols and processes of the  
Member Firm. As a result, the audit report cannot identify the Member Firm and the  
Member Auditor cannot include their APSCA Member Number on the audit report as the  
audit was not completed by the Member Auditor consistent with the key processes and  
protocols of the Member Firm - and the Member Firm was not responsible for all key  
elements of the audit.  
Additionally, in this instance, the fact that the Partner Organization – which has the  
arrangement with the Member Firm – is presenting themselves as having Member Firm  
capabilities is a violation of the Code by the Member Firm and the Member Firm could be  
subject to disciplinary action by APSCA.  
Document Name:  
Version & Date:  
Replaces:  
Guidance 2 Use of Subcontractors and Partner Firms - T-023  
Version 1 – April 14, 2021  
Nil  
Author/Owner: APSCA President & CEO  
Authorized by: APSCA Executive Board  
Date Printed: 26 May 2021  
This document is no longer version controlled once printed.  
Page 6 of 6