Impartiality & Conflicts of Interest Policy

MARRYMARK IMPARTIALITY & CONFLICTS OF INTEREST POLICY
Version: 1.1
Effective date: 21 January 2026
Owner: MarryMark Pty Ltd (ACN 689 159 064) (“MarryMark”, “we”, “us”, “our”)

  1. Purpose

MarryMark is a verified, tiered, earned trust standard. The credibility of our accreditation and credentials relies on impartial decision-making and robust management of conflicts of interest.

This Policy:

  • establishes impartiality principles and safeguards across verification, complaints, investigations, sanctions, appeals, and re-verification;
  • defines what constitutes an actual, potential, or perceived conflict; and
  • sets mandatory steps for disclosure, mitigation, and recusal.
  1. Scope

This Policy applies to all persons involved in MarryMark activities, including:

  • MarryMark directors, staff, and volunteers;
  • assessors, auditors, contractors, and consultants;
  • Ambassadors and any Standards & Integrity Panel members;
  • any external independent reviewers appointed by MarryMark; and
  • any person with access to confidential scheme materials or evidence.
  1. Principles (non-negotiables)

MarryMark commits to:

  1. Independence of outcomes – accreditation/credential outcomes are not influenced by sales targets, relationships, reputation, or commercial arrangements.
  2. Procedural fairness – decisions are evidence-based, consistent, and the subject has a fair opportunity to respond, subject to safety/privacy.
  3. Transparency of interests – conflicts are declared early, recorded, and managed.
  4. Confidentiality – scheme evidence and complaints materials are handled on a need-to-know basis.
  5. Integrity above convenience – where impartiality cannot be assured, we escalate to an external independent reviewer.
  6. Definitions

Conflict of interest means any situation where a person’s personal, professional, financial, or relational interests could reasonably influence (or be perceived to influence) impartial judgement.

Conflicts include:

  • Actual conflict: a real conflict exists now.
  • Potential conflict: a conflict could arise depending on circumstances.
  • Perceived conflict: a reasonable person could suspect bias, even if none exists.

Competitor conflict (MarryMark-specific):
A conflict is presumed where a panel member/assessor operates in a directly competing category and a materially overlapping market with the subject business (including perceived competition).

Improper influence:
Any pressure, inducement, gift, benefit, threat, or relationship used to sway an outcome.

  1. Impartiality safeguards (scheme-wide)

5.1 Separation of commercial activity from standards decisions

  • People in sales/partnership/marketing roles must not make or influence decisions on:
    accreditation tier outcomes, complaint determinations, sanctions, appeals, or re-verification approvals.
  • Where one person must perform multiple functions (small team reality), MarryMark will apply compensating controls (e.g., independent panel member + second internal reviewer).

5.2 Evidence-based decisions and written reasons

  • Decisions must be anchored to relevant Scheme Documents and recorded with a clear rationale.

5.3 No “pay-to-play” influence

  • Payment of fees does not guarantee accreditation/renewal/tier outcome.
  • Sponsorships, advertising, partnerships, or ambassador status do not provide preferential treatment.
  1. What must be declared (examples)

All personnel covered by this Policy must declare any actual/potential/perceived conflicts, including:

  • family, close personal, or romantic relationships with a party;
  • employment, contracting, coaching, mentoring, or advisory relationships;
  • financial interests, investments, commissions, or referral arrangements;
  • active disputes, litigation, or prior complaints involving a party;
  • competitor conflict (same category + same geography/market);
  • public statements that suggest a predetermined view of a party or outcome;
  • gifts, hospitality, or benefits connected to scheme matters.
  1. Disclosure requirements and timing

7.1 Mandatory disclosure

A disclosure must be made:

  • on appointment to any assessor/panel role;
  • annually (or per accreditation year); and
  • immediately when circumstances change or a new matter arises.

7.2 How to disclose

Disclosures must be made in writing using the MarryMark Conflict Declaration Form (or email to the Standards Lead), and recorded in the Conflict Register.

  1. Managing conflicts

MarryMark will apply one or more controls depending on risk:

  1. No action – only where conflict is clearly not present and not reasonably perceived.
  2. Disclosure + limited participation – e.g., administrative role only, no decision-making.
  3. Recusal – remove the person from any involvement in the matter.
  4. Role reassignment – appoint different assessor/panel member.
  5. External independent reviewer – where impartiality cannot be assured internally.
  6. Removal from role – where conflict is serious, repeated, concealed, or unmanaged.

Presumption: For complaints/investigations affecting tier/credential status, perceived competition conflicts require recusal unless MarryMark determines otherwise and records reasons.

  1. Gifts, hospitality, and benefits
  • No person covered by this Policy may accept gifts, hospitality, discounts, or benefits that could reasonably be perceived to influence scheme decisions.
  • Any gift/benefit connected to scheme participants must be declared and may be refused/returned.
  1. Confidentiality and information barriers
  • Complaint evidence, audit material, and assessment documentation are confidential and shared strictly on a need-to-know basis.
  • Panel/assessors must not use scheme access to gain competitive advantage or solicit clients.
  1. Breaches of this Policy

Breaches include: failure to disclose conflicts, participating while conflicted, leaking information, accepting improper influence, or attempting to sway an outcome.

MarryMark may respond by:

  • removing a person from the matter or role;
  • invalidating and re-running an affected decision;
  • escalating to an external reviewer; and/or
  • applying sanctions under relevant Terms/Policies (including revocation of Ambassador appointment if applicable).
  1. Complaints about impartiality

Any person may raise an impartiality concern via:

  • privacy@marrymark.com.au
    Impartiality complaints are escalated to a senior MarryMark representative not involved in the matter, and may be referred to an external independent reviewer.
  1. Records and review

MarryMark maintains:

  • a Conflict Register,
  • conflict declarations, recusals and decisions logs, and
  • records of external reviewer appointments.

This Policy is reviewed annually or when scheme governance changes.