Criterion 1.3: Corruption Prevention in ASC Farm Standard Operations

Corruption Prevention and Ethical Business Practice Under ASC Criterion 1.3

The ASC Farm Standard, through Criterion 1.3, establishes two key requirements for Unit of Certification (UoC) operations: that farms discourage all forms of corruption and encourage ethical behaviour and integrity in business operations (Indicator 1.3.1), and that information provided as evidence of conformance to ASC Requirements is not falsified or misrepresented (Indicator 1.3.2). These requirements form part of Principle 1 of the standard, which ensures that aquaculture operations function legally and apply effective business management.

Understanding Corruption in the Aquaculture Context

The Interpretation Manual for ASC-INT-001 defines corruption broadly, noting that it can happen anywhere, involve anyone, and take many forms. According to the manual, corruption encompasses extortion, embezzlement, and bribery. Understanding these distinctions is critical for farm management and auditors assessing compliance with Indicator 1.3.1.

Embezzlement involves the misappropriation of funds or resources by a person in a position of trust. The manual provides a concrete example: "A site manager getting cash from the first point of sale in exchange for under-declaring harvest volumes (i.e. the purchaser receiving more product that they are paying for)." Another embezzlement scenario involves a sourcing manager who purchases cheaper non-eligible feed but falsely registers them as eligible feed, providing fraudulent documentation declaring the feed as more costly eligible feed in order to increase sourcing performance and boost personal bonuses.

Bribery occurs when goods, services, or money are offered or given in exchange for preferential treatment or contract awards. The manual lists several examples. A supplier may purchase a new car for a site manager in exchange for awarding a sourcing contract to that supplier. A site may pay cash to customs officials to expedite the passage of feed through import and export systems. In the context of audit integrity, a sustainability manager might offer auditors excessive accommodation and lunches in an attempt to reduce audit effort or obtain leniency regarding non-conformities.

Extortion involves threats or coercion to obtain money, goods, or services. One example from the manual is when Employee A threatens to provide information to management that could result in Employee B being fired, unless Employee A receives a requested payment. Another scenario describes a site owner threatening to harm a neighbouring landowner unless that landowner surrenders some of their land to allow the site to construct an additional building.

Beyond these three primary forms, the manual also notes that corruption can take the form of a manager buying supplies from a friend and, in return, receiving 20% of profits—practices that may extend to excluding other appropriate suppliers from the approved supplier system. The manual also addresses situations where infrastructure has unsafe mechanisms and an owner pays a manager cash to conceal this information from the next audit.

What Auditors Look for Under Indicator 1.3.1

When verifying compliance with Indicator 1.3.1, auditors must confirm that management and employees are aware of what these corrupt practices involve and how to recognise them. Auditors also verify that policies are in place to prevent corruption, including extortion, embezzlement, and bribery. Additionally, auditors confirm that the UoC has established terms of dismissal should employees engage in these practices.

Evidence of implementation typically includes documented policies preventing corruption in all its forms, with clear statements of disciplinary consequences for violations. These policies should be communicated to all staff and integrated into employment contracts and grievance procedures.

Record Integrity and Prevention of Falsification

Indicator 1.3.2 addresses a related but distinct requirement: ensuring that information provided as evidence of conformance is not falsified or misrepresented. This is critical because the integrity of records underpins all other audit findings and compliance determinations.

According to the Interpretation Manual, records are documented information that provides permanent evidence about past events. The manual specifies that records should:

• Be completed and maintained in a way that ensures information is accurate and preserved
• Be genuine and completed at the time of checks or shortly after
• Capture and illustrate information when processes do not perform as expected (for example, recording temperatures outside acceptable ranges when a cooling system fails, not merely recording acceptable temperatures)
• Be legible and complete, potentially including authorisation through supervisor initials verifying completeness
• Be stored appropriately, with paper records protected from damage and electronic records backed up

The manual emphasises that genuine records must reflect actual operational conditions, including failures and anomalies. If recording only acceptable data while concealing out-of-range values, management cannot understand whether additional safeguards—such as backup temperature regulators—might be needed.

Corrective Actions for Record Falsification

When incidences of falsification or misrepresentation are identified, the UoC is required to take corrective action and implement actions to prevent recurrence. Auditors confirm the existence of records demonstrating their genuineness and the effectiveness of corrective actions taken in response to any identified falsification.

Evidence of implementation under Indicator 1.3.2 includes records that demonstrate genuineness, as well as documented corrective actions and preventive measures when falsification or misrepresentation has been identified.

Practical Integration into Management Systems

Both Indicators 1.3.1 and 1.3.2 are supported by the broader management system requirements outlined in Criterion 1.2. The management system should include policies, procedures, and records that collectively address corruption prevention and record integrity. These are most valuable for topics where employees may have inconsistent or incomplete understanding, making explicit policies and training essential in contexts where corruption risks are elevated.

Farms are expected to maintain detailed, accurate records across all operational areas covered by the ASC Farm Standard. This record-keeping discipline serves both compliance and operational improvement purposes, enabling management to identify system failures and implement preventive measures.

This article summarises ASC-INT-001-ASC-Farm-Standard-Interpretation-Manual-V1.0.1-September-2025.pdf. Refer to the original document for the authoritative text and full requirements.