Governance and independent control of the Positive Company® label

An organization designed to ensure the integrity of the label

The Positive Company® label is based on a clear distribution of responsibilities between:

• the owner of the label;
• the individuals responsible for the evaluation;
• the bodies participating in its governance;
• the competent and independent third party;
• the body responsible for the award decision.

This organization aims to ensure the impartiality, reliability, and traceability of the labeling process.

The role of Positive Company

Positive Company is the owner of the Positive Company® label and its labeling system.

In this capacity, Positive Company is particularly responsible for:

• defining and updating the reference framework;
• the evaluation and rating methodology;
• organizing the labeling process;
• designing surveys for stakeholders;
• selecting, training, and supervising evaluators;
• collecting and analyzing responses and supporting documents;
• managing the brand and its usage guide;
• monitoring labeled organizations;
• handling complaints, reports, and controversies according to applicable procedures.

Positive Company cannot replace the competent and independent third party for the verifications related to its mission.

The role of the evaluators

The evaluators analyze the organization's responses and the supporting documents provided.

Their mission includes, in particular, the following:

• to check the consistency between the responses and the evidence;
• to assess the relevance, timeliness, and scope of the supporting documents;
• to request additional information when necessary;
• to apply the scoring rules;
• to document the points awarded or deducted;
• to report any anomalies or non-conformities;
• to ensure the traceability of their analysis.

The evaluators operate according to procedures, methodological guides, and common rules designed to ensure the consistency of evaluations.

A review conducted by a competent and independent third party

Before the award or renewal of the label, each complete evaluation is subject to a review by a competent and independent third party.

Cet organisme est une entité juridiquement distincte de Positive Company. Sa compétence et son indépendance — tant à l'égard de Positive Company qu'à l'égard des organisations évaluées — reposent sur des normes et procédures reconnues, internationales, européennes ou nationales, conformément à l'article 2, point (r), (iv) de la directive (UE) 2024/825.

Their mission is to verify that the file complies with the specifications and that the labeling process has been correctly applied. In the context of this review, the third party may notably request explanations or additional evidence, request the correction of information, formalize a non-conformity, request the implementation of a corrective action, or trigger an additional control. They may also recommend the imposition of a penalty, the temporary suspension of the right to use the label, or its withdrawal. These recommendations are taken into account by Positive Company in its decision on allocation, renewal, suspension, or withdrawal.

The review may particularly focus on:

• the scope and framework of the evaluation: workforce, sector of activity (NACE), covered entities, labeling cycle (first labeling or renewal), version of the applied reference framework, and the realization of the peer review within Positive Company;
• the compliance with the specifications and the correct application of the methodology;
• the traceability of the evaluation, as well as the presence and consistency of the supporting documents;
• the consultation of stakeholders: volumes of shipments and returns, achievement of expected return rates and, if applicable, application of the planned penalty or referral to the ethics committee;
• the handling of anomalies or non-conformities identified: qualification of each verified subject (compliant, non-compliant, compliant under condition, not applicable), nature of the deviation, response provided by Positive Company, resolution status, and potential impact on the rating;
• the correct application of the criteria for awarding the label: overall score thresholds, elimination scores by category, and prerequisites (fundamentals) associated with each level, including those adapted to the size of the organization.

Competent and independent third party : [Name to be completed]

A clear separation of responsibilities

The system distinguishes the different functions necessary for the operation of the label.

This separation prevents the label owner from being the only actor responsible for designing, evaluating, and controlling their own system.

The award decision

The allocation decision occurs only after :

• the completion of the applicable process ;
• the analysis of responses and supporting documents ;
• the calculation of the score ;
• the consultation of stakeholders when it is planned ;
• the verification of any prerequisites ;
• the review of the file by the competent and independent third party ;
• the handling of any blocking non-conformities.

Une conclusion défavorable de l’organisme tiers ou une non-conformité non résolue empêche l’attribution ou le renouvellement du label.

The funding of the evaluation does not guarantee the obtaining of the label nor the allocation of a determined level.

Prevention of conflicts of interest

Positive Company applies rules intended to identify, prevent, and address situations that may affect the independence or impartiality of the participants.

A conflict of interest may result in particular from :

• a personal or professional link with the evaluated organization ;
• a direct or indirect financial interest ;
• a recent consulting service regarding the evaluated practices ;
• a hierarchical or commercial link that may influence the evaluation ;
• any situation creating a reasonable doubt about the impartiality of the participant.

The concerned participants must declare potential conflict of interest situations.

Depending on the circumstances, the measures may include :

• the replacement of the evaluator ;
• the recusal of a member of a body ;
• the assignment of the file to another person ;
• a supplementary review ;
• the exclusion of the intervenor from the decision concerned.

Consult the conflict of interest management policy : [Link to be added]

Separation between support and evaluation

Support services and evaluation activities must be organized in a way that preserves the impartiality of the label.

A person who has directly supported an organization in preparing responses or producing evidence must not be solely responsible for evaluating the same file.

Any previous support situations are identified and addressed according to the rules for preventing conflicts of interest.

Purchasing a support service does not guarantee obtaining the label.

Competence of the intervenors

Evaluators and controllers must have skills appropriate to the subjects examined.

These skills may particularly include :

• the social responsibility of organizations ;
• environmental, social, and governance issues ;
• the analysis of documents and data ;
• evaluation and control techniques ;
• the applicable regulations ;
• sector-specific characteristics ;
• the identification of inconsistencies and risks of misleading statements.

Positive Company organizes the development and maintenance of skills through :

• initial training ;
• methodological guides ;
• calibration sessions ;
• quality controls ;
• of file reviews ;
• of regular updates related to the developments of the framework.

Governance of the framework

Le référentiel Positive Company® évolue pour tenir compte :

• regulatory developments ;
• sustainability standards ;
• available scientific knowledge ;
• feedback ;
• expectations of the evaluated organizations ;
• expectations of stakeholders ;
• expert recommendations.

Significant developments are subject to :

• an appropriate consultation ;
• a validation according to the defined governance ;
• a new dated version ;
• a synthetic history of changes ;
• information for the concerned organizations.

Consult the version history of the framework : [Link to be added]

Governance bodies

Positive Company can rely on different bodies to ensure the quality and integrity of the label.

Depending on their missions, they can particularly intervene on :

• the developments of the framework ;
• methodological issues ;
• situations presenting a risk of conflict of interest ;
• complex cases ;
• controversies ;
• complaints and appeals ;
• decisions of suspension or withdrawal.

The composition, responsibilities, and operating rules of each body are formalized.

Members called to examine a file must recuse themselves when they find themselves in a conflict of interest.

Consult the synthetic governance of the label: [Link to be added]

Traceability and auditability

Each labeling decision must be reconstructible from the information kept in the file.

Traceability can notably cover :

• the assessed scope ;
• les réponses de l’organisation ;
• requests for additional information ;
• the controls carried out ;
• the results of the surveys ;
• any non-conformities ;
• the conclusion of the competent and independent third party ;
• the level and duration of validity assigned.

Individual files and evidence from organizations remain confidential, but must be accessible to authorized persons as part of the planned controls.

Quality control of evaluations

Positive Company implements controls aimed at ensuring the consistency and quality of evaluations.

These controls may notably include :

• file reviews ;
• sampling controls ;
• comparisons between evaluators ;
• calibration sessions ;
• monitoring of scoring discrepancies ;
• analysis of errors or anomalies ;
• corrective actions ;
• updating of guides and procedures.

The objective is to limit unjustified differences in treatment between organizations presenting comparable situations.

Complaints and appeals

An evaluated organization may request a review of a result or decision according to the applicable procedure.

The system specifies in particular :

• the conditions for admissibility ;
• the information to be transmitted ;
• the processing steps ;
• the responsibilities of the stakeholders ;
• the review procedures ;
• the communication of the final decision.

Stakeholders and third parties may also report :

• an abusive use of the label ;
• information likely to affect its validity ;
• a controversy ;
• misleading communication ;
• a potential conflict of interest.

File a complaint or report

Publicly available information

Positive Company gradually publishes the necessary information to understand the governance and guarantees of the system.

Public documents may include :

• a summary presentation of the governance ;
• the distribution of responsibilities ;
• the conflict of interest management policy ;
• the presentation of the competent and independent third party ;
• the scope of its mission ;
• the complaint and appeal procedure ;
• the suspension and withdrawal procedure ;
• the principles of quality control of evaluations.

Detailed operational guides, control grids, evaluation files, and evidence from organizations remain internal and confidential.

Version of this page : v2026.1.1

Publication date : July 2026

Last updated : July 2026

Contact : scoring@positive-company.eu