Purpose and scope
ICC Group’s work depends on reliable information, professional judgment and responsible conduct. This code establishes the standards expected when representing ICC or handling information connected with its services.
The code applies to personnel within its adopted scope. Expectations for external providers and partners must be communicated through the relevant engagement or contractual arrangements.
Publishing this code does not itself amend an existing contract or establish an employment procedure.
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Integrity and truthful communication
Personnel must communicate honestly about capabilities, findings, limitations and progress.
Do not fabricate credentials, evidence, source access, approvals, certifications or results. Do not conceal a material limitation to make a finding appear more conclusive.
Marketing statements and client communications must be supportable. Commercial pressure must not override accuracy.
Objective reporting
Findings must follow the evidence rather than a preferred client outcome.
Distinguish verified information from source accounts, allegations, analytical conclusions and unresolved issues. Record material qualifications and avoid selective reporting that creates a misleading impression.
An individual must not be presented as guilty of wrongdoing solely because of an allegation, an unverified match or an incomplete check.
Lawful and proportionate methods
Information gathering must have an authorised purpose and use lawful methods. The scope must be relevant to the assignment.
Do not obtain information through unlawful access, coercion, bribery or misuse of credentials. Do not ask a source or provider to do something ICC is not permitted to do itself.
Source restrictions, local requirements and individual rights must be considered before collecting, disclosing or using information.
Anti-bribery and improper influence
Offering, requesting, accepting or facilitating a bribe is prohibited.
Do not provide money, gifts, favours or other advantages to improperly obtain records, influence a decision or secure business. Do not route an improper payment through an intermediary.
An improper request must be declined and escalated through an appropriate reporting route. Commercial urgency is not a justification.
Gifts and hospitality
Gifts and hospitality must not compromise, or reasonably appear to compromise, independent judgment.
Cash, concealed benefits and exchanges intended to influence a finding or official action are unacceptable. Where a proposed benefit could create a conflict, seek an appropriate management decision before proceeding.
This code does not invent monetary approval thresholds; any detailed limits require separately adopted procedures.
Conflicts of interest
Disclose personal, financial or professional interests that could affect an assignment or create a reasonable perception of bias.
Do not assess your own interests, investigate a close associate without disclosure, or use an engagement to advance an undisclosed personal objective.
A conflict should be assessed before affected work continues. Any management measures must be appropriate to the circumstances.
Confidentiality and privacy
Access information only where required for authorised work. Use approved business channels and disclose information only to recipients entitled to receive it.
Do not use client, candidate or source information for personal benefit, unrelated research or informal discussion.
Respect retention restrictions and privacy obligations. Confidentiality duties can continue after an assignment or working relationship ends.
Respect and fair treatment
Treat colleagues, candidates, clients and sources with dignity.
Harassment, intimidation and unlawful discrimination are prohibited. Screening and investigations must not be used to support an unlawful discriminatory purpose.
Recognise that people may have different language needs or require an appropriate adjustment to a process. Respectful conduct must continue when information is disputed.
Relationships with clients, sources and providers
Agree a clear scope and communicate material limitations. Do not promise an outcome unsupported by the work.
Sources must not be pressured to alter an account. Providers must receive lawful, proportionate instructions and must not be encouraged to bypass restrictions.
Payment or commercial dependence must not be concealed where it materially affects the assessment of information.
Records and evidence
Keep records accurate and preserve relevant context.
Do not destroy, alter, backdate or selectively omit records to obstruct a review or conceal an error. Corrections should be transparent and preserve an appropriate explanation of material changes.
Evidence handling must respect source conditions, confidentiality and the requirements of the engagement.
Technology and artificial intelligence
Use only tools authorised for the information and purpose involved.
Do not place confidential records in an external AI service or other unauthorised platform without the required assessment and approval.
Technology outputs require appropriate scrutiny. Automated matches, summaries and generated text can contain errors and must not be presented as verified evidence without support.
Personnel remain accountable for the work they approve.
Raising a concern
Report suspected misconduct promptly through an appropriate ICC management contact. General external enquiries can be directed to gcc@iccverify.com to request the appropriate reporting route.
Provide relevant facts and distinguish direct knowledge from assumptions. Avoid unnecessary disclosure of sensitive records in an initial email.
Absolute anonymity or confidentiality cannot be promised. Information should be handled with appropriate discretion and shared only where needed for assessment, response or legal requirements.
Fair consideration and non-retaliation
Concerns must be considered fairly, with attention to evidence and the interests of affected people.
Retaliation against a person for raising a concern honestly or participating in an appropriate review is prohibited. A concern need not ultimately be substantiated to have been raised in good faith.
Knowingly false allegations and deliberate interference with a review are inconsistent with this code.
Accountability and review
Breaches should receive a proportionate response consistent with the person’s relationship with ICC, contractual arrangements and applicable law.
This code does not promise automatic termination, a particular sanction or a fixed investigation outcome.
Management should review the code as business activities, risks and legal requirements change. Personnel should receive guidance appropriate to their responsibilities.