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Our impartiality and consistency policy
Version 1.0 (P:P) | January 2025
Travelife Ltd owns, operates and manages the Travelife Accommodation Sustainability Certification (TASC) scheme, acting as both the owner of the scheme and the conformity assessment body that certifies tourist accommodation providers against the scheme.
The purpose, objectives and core goals of the TASC scheme
The purpose of Travelife is to help ensure the long-term viability and success of the tourism industry so that it can continue to provide economic, environmental and social benefits on a global scale. Sitting specifically within the accommodation sector of the tourism industry, the TASC scheme has two simple objectives:
The Travelife Certification requirements have been carefully developed to ensure they are useful, relevant and meaningful in terms of improving the impact the accommodation sector has on people and the planet. The current requirements are based on 20-years experience with developing accommodation sustainability standards, auditing and certifying against them. We also ensure that we consult with stakeholders and experts when reviewing the requirements, and that we have aligned them with the Tourism Sustainability Certifications (TSC) Alliance standard, the GSTC Industry Criteria for Hotels as well as the UN SDGs.
Our certification process has been designed to ensure it is consistent, impartial and robust so that regardless of the type of accommodation and the location, stakeholders know what to expect from a Travelife Certified property. This is why we insist on 100% compliance with all the certification requirements and why a full independent onsite inspection audit is required. This is also why a certification is only valid for two years and why our process must be repeated in full if a property wishes to recertify. It is also why we do not offer multi-site certification or any other type of sampling that would certify a hotel chain or group.
Ensuring we stay on track with our purpose and objectives involves us continually striving to meet four core goals. They drive the decisions we make, the policies and processes we implement and the general way that we operate and manage the TASC scheme.
- Improve the impact of the accommodation sector on people and the planet.
- Consistently maintain the highest levels of quality, impartiality, reliability, credibility and independence.
- Continually increase the number of accommodation providers that are Travelife Certified.
- Ensuring the ongoing financial viability of Travelife Ltd.
The importance of impartiality and consistency
The success of Travelife relies on the credibility of our certification scheme. This credibility is centered on independence, impartiality, fairness and consistency. Without this credibility, our certification will almost certainly lose respect with stakeholders feeling that they cannot rely on our certification mark as an indication that an accommodation provider meets our standards. Accommodation providers may feel that we offer no value to them because they cannot rely on us to treat them fairly.
Independence
This is about us ensuring that we do not allow third parties to influence our decisions for their own interests. This is a particular problem if their interests do not line up with the purpose, objectives, core goals and guiding principles of the TASC Scheme. “Their own interests” could relate to their finances, their reputation, mitigating their own risks or promoting their own sustainability agenda.
Impartiality
This relates to ensuring that we make decisions based on facts, evidence and reasoned judgement. It means that we continually do our best to put aside our personal biases and prior experiences when making decisions, especially compliance and certification decisions. Impartiality is perhaps the most important behaviour we must display yet, simply due to human nature and the way society works, it can be the hardest to consistently display and is very difficult to monitor.
Consistency
This is about the same rules, standards and processes being applied all the time to accommodation providers, auditors and staff. Being consistent is an important part of ensuring we are applying our standards and processes equally and fairly so that everyone can prepare to meet a similar level of expectations.
A lack of consistency can result in frustration and a loss of trust because people cannot learn how to meet our expectations between their different interactions with us or cannot make sense of how we make compliance and certification decisions, or any other decisions that may affect them.
Our ability to be consistent is largely dependent on our ability to always be independent, impartial and fair. However, it is also influenced by our ability to carry out our tasks effectively and is therefore also dependent on our competencies and other factors that can affect our ability to properly focus on our tasks, such as workplace distractions, stress and fatigue.
Fairness
Fairness is about everyone being treated equally without any favouritism or discrimination. It is also about ensuring that everyone is given the same opportunities for success. Being fair is largely the result of being independent, impartial and consistent. By embedding these qualities into everything we do, the people and organisations we work with should experience fair treatment. But there are other factors that can influence our ability to treat people fairly, or at least their perception of whether we have been fair with them. These primarily relate to our competency and to the logistical aspects of our operations.
Risks to our ability to be impartial and consistent
At Travelife we celebrate the fact that our staff, auditors and stakeholders are diverse and unique individuals. However, we also acknowledge that humans are not robots! We each have our own failings, biases and experience the regular stresses and strains of life, all of which can affect our ability to be impartial and consistent. As such, we have identified a series of risks to our ability to be impartial and consistent that are summarised below. The Embedding impartiality and consistency principles within our business section of this policy explains how we mitigate these risks.
Personal conflicts of interest: This is when a person’s judgment is affected because they have a personal stake in the outcome of that judgment. It can mean that the person cannot act impartially, and therefore does not make the best decisions. A personal stake could be financial, professional, reputational or emotional. The outcome they are concerned about could be positive or negative. All that matters is that their judgment may be clouded by these outside pressures.
Commercial conflicts of interest: This could involve Travelife feeling under pressure to predetermine a certification decision due to a business relationship. It could also involve a certification customer having an unfair advantage or disadvantage due to a commercial relationship that Travelife has. For example, if Travelife offered paid consulting services (we do not!), the properties that could afford to pay for this would be unfairly advantaged over those that could not.
Personal biases: Everyone has biases that we have developed through our collective life experiences and influences. Sometimes we are acutely aware of how they make us feel, but often they are so ingrained into our psyche that we are not aware that they are influencing our judgements and decisions.
Stress and fatigue: People are known to be less thorough and accurate when they are experiencing high levels of stress, pressure or are simply tired or unwell.
Repetition fatigue: This happens when we repeat a similar task multiple times. Our brain tries to help us by memorising the steps in the task, allowing us to think about something else at the same time, or to multitask. It can also happen when we simply get bored with doing the same task repeatedly, and rush to get it finished. In all cases, this can cause us to pay less attention to detail and, in the case of making Travelife compliance judgments and decisions, possibly overlook a non-compliance or vice versa.
Bribery and corruption: A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage. A Travelife example could involve a hotel offering a bribe to an auditor or staff member in return for a favourable certification outcome.
Embedding these principles within our business
One of our guiding principles is to be independent, impartial, consistent and fair. We have summarised what that means above, along with the risks that may prevent us from meeting this principle. Below are the ways we ensure this principle is embedded within our business and how we mitigate the risks.
Key performance indicators
As part of our QMS, an internal audit is carried out each year to check that we are meeting each of the KPIs listed below that relate to being independent, impartial, consistent and fair.
- A policy describing Travelife’s commitment to independence, impartiality, consistency and fairness has been developed and implemented.
- All new staff are trained about how to follow the above policy when they first join and all staff are given formal refresher training every two years.
- Auditors are given clear information about our expectations of them in terms of independence, impartiality, consistency and fairness.
- All new auditors are trained about how to interpret and follow their guidelines related to independence, impartiality, consistency and fairness. All existing auditors must complete refresher training at least once every two years.
- An anti-bribery and corruption policy has been developed and implemented. There is a version that deals with the unique risks posed to auditors.
- All new staff and auditors are given training about how to interpret and follow anti-bribery and corruption policies, with refresher training occurring at least once every 2-years.
- A process is in place to monitor and record gifts and hospitality that are offered to staff and auditors (in accordance with the rules around gifts and hospitality in the anti-bribery and corruption policy).
- A process is in place to monitor and record conflicts of interest.
Staff competency
Our internal staff competency policies include the following attributes and behaviours that are relevant to this topic. All staff are expected to hold and consistently demonstrate these, and this is monitored via an annual staff competency evaluation cycle.
All Travelife staff should:
- Have an ability to pay attention to detail.
- Have a good sense of justice (what is right and what is fair) and be committed to equality and fair treatment for everyone.
- Act ethically and with integrity, always striving to remain independent, objective, impartial and consistent when making decisions and judgements.
- Be committed to being aware of their personal biases and to doing their best to ensure their biases do not influence the way they make decisions, judgements or how they treat people.
- Care about always doing a thorough and professional job.
The attributes and behaviours listed above will be included in all job descriptions from January 2025. Internal policies ensure that they are assessed and verified when a staff member first join. They are reassessed quarterly as part of an internal staff competency evaluation programme. When each staff member joins they must complete a training programme that includes impartiality and consistency, with this training being repeated every 2-years. Finally, all staff must sign a Quality, Integrity and Impartiality Commitment.
Peer reviews
The Travelife certifications team carry out an internal peer review process each quarter. This involves them scoring a random selection of each other’s audit report quality checks and compliance decisions in terms of the consistency of their decisions, the quality of their supporting notes and response times. They are invited to provide additional feedback that may assist with their peer’s learning and development. The findings are discussed during a special team meeting and the certifications manager determines if any follow-up actions are required, such as training, coaching and so on. This helps to ensure consistency and aims to motivate staff to maintain high standards at all times.
Auditor competency
An internal auditor competency policy outlines the personal attributes, behaviours, values and principles that we expect auditors to consistently demonstrate and how we evaluate if they are achieving this. These include integrity, impartiality, independence and consistency. Information about how to display these competencies is described in the Auditor Code of Conduct that has been developed into an e-learning module that all auditors must complete when they first start, then every two years. Auditors sign an agreement with Travelife that contains clauses related to abiding by their code of conduct, completing required training and undergoing regular competency evaluations.
Avoiding conflicts of interest
Every effort is made to prevent conflicts of interest, which means ensuring that the person making either a compliance judgement or decision, or a certification decision, does not have any kind of personal stake in the outcome. This is enforced via internal policies, with the main themes being summarised below.
Consulting and internal audit services: Travelife does not offer any form of paid consulting service, nor is consulting otherwise built into our fees. We do not provide internal auditing services to any third party, including our certification customers. We do provide generic guidance about how to comply with our requirements and will answer specific questions from properties to help them understand them. We also give specific feedback about what a property should do to demonstrate compliance during the post-audit improvements process.
Auditor consulting services: Travelife auditors are permitted to provide sustainability consultancy services to general accommodation providers, but they must declare any such history (or existing relationship) with a property they have been asked to audit, in which case Travelife will assign the property to a different auditor.
Audit assignments: During the audit assignment process, auditors are explicitly asked to declare any potential conflicts of interest which would normally involve any professional or personal relationships they may have with a property, along with the nature of this relationship. These are assessed by Travelife to determine if a different auditor should be assigned.
Travelife certifications specialists: Travelife certifications specialists are required to declare any professional or personal relationships they may have with a property that has been assigned to them for quality checks, compliance decisions or certification decisions. They must declare the nature of this relationship. Regular training and reminders are provided for this rule. Travelife then assesses the response to determine if there is a conflict.
All Travelife staff: Travelife staff are not permitted to engage in any external management system consultancy work. If they provided management system consultancy services to accommodation providers prior to joining Travelife, they are they are not permitted to engage in any auditing or certification activity for that same accommodation provider for two years after the management system consultancy services concluded.
Promoting other products and services: Auditors and staff are not permitted to promote or otherwise solicit business during any stage of the auditing process from when a property is assigned to them until 6 months have passed since the audit result. This includes consulting services they may offer or any other product or service they offer.
Familiarity/affinity with hotel staff: Although not always possible for logistical reasons, Travelife makes all reasonable efforts to ensure that an auditor does not carry out two consecutive inspection audits of the same property. An important exception is repeat audits that are required when a property fails their first inspection audit due to having 41 or more non-compliances and therefore has to have another inspection audit as part of the same certification attempt.
Anti-bribery and corruption
Travelife, as required by UK law, has an anti-bribery and corruption policy. A version for auditors has additional sections highlighting specific risks auditors are likely to face and that clarifies what sort of hospitality is acceptable. For example, we specifically ask hotels to provide complimentary accommodation for auditors.
All auditors and Travelife staff must undergo anti-bribery and corruption training when they first begin working with us and refresher training must be completed at least every two years.
Auditors are contractually obliged to comply with the policy as part of their agreement with Travelife. Each time the auditor submits an audit report, they are prompted in Evergreen (our certifications and property management system) to report any attempt (or suspected attempt) to potentially influence their compliance judgements and any gifts or hospitality that was offered. A process is in place to investigate, resolve and record any such instances.
How to report a concern with impartiality or consistency
If you have a concern about impartiality or consistency at Travelife, there are several mechanisms you can use to report this.
Concerns with a compliance decision for one or more of the certification requirements
Step 1: Contact the certifications team
You can do this by sending a message via the Evergreen system in relation to the specific requirement/s you are concerned about. Alternatively, you can email certifications@travelife.org.
Step 2: Appeal the decision/s
You should follow the instructions given in the Appeals section of the Travelife Complaints and Appeals Policy to launch a formal appeal against the decision/s.
Concerns with a decision to suspend or withdraw your certification
Step 1: Contact the certifications team
You can do this by sending a message via the Evergreen system in relation to the specific requirement/s you are concerned about. Alternatively, you can email certifications@travelife.org.
Step 2: Appeal the decision/s
You should follow the instructions given in the Appeals section of the Travelife Complaints and Appeals Policy to launch a formal appeal against the decision/s.
General concerns about impartiality or consistency at Travelife
Use the post-audit feedback survey: After each inspection audit, a survey is sent to our main contact at the property. The survey includes an area where you can provide general comments and this can be used to give us general feedback and suggestions.
Use our feedback form: Click here to view the form which can be used to give us general feedback and suggestions.
Make a formal complaint: Please review the Travelife Complaints and Appeals Policy which explains how to make a formal complaint.
Contact the Managing Director: If you are not comfortable with general Travelife staff seeing your concerns, or you feel that your concern needs to be escalated, you can email the Travelife Managing Director, Carolyn Wincer, at carolyn@travelife.org.
Report your concern to our parent company*: You can send your impartiality concern about Travelife by post to:
The Directors
ABTA Ltd
30 Park Street
London SE1 9EQ
United Kingdom
*Travelife is in the process of obtaining accreditation. Once achieved, it is expected that stakeholders will be able to report impartiality concerns to the accreditation body.
How we investigate impartiality or consistency concerns
We have several internal policies that we must follow in relation to general feedback, complaints and appeals about all aspects of Travelife, including impartiality and consistency. You can click here to see how we deal with formal complaints and appeals. Please email info@travelife.org if you would like to view our internal policies on handling general and/or informal feedback.