Safety Norms: International Trade and Sustainability Consulting

1Purpose, scope, and safety principles

This document sets norms for people who advise companies on cross-border trade, customs and tariff matters, export control, sanctions exposure, supply chain sourcing, and sustainability performance or reporting. It applies to employees, contractors, interns, and any person acting for the firm, including remote work, travel, and visits to client or supplier facilities.

Its purpose is harm prevention in four areas: physical safety during travel and site visits, protection of confidential and personal information, accuracy of advice so that clients do not face avoidable legal or reputational harm, and safe handling of samples, documents, and data. Safety in this field is not only about injuries. Unsafe advice and careless data handling can injure clients and workers just as surely.

• Mandatory: every person working under this document must follow the rules marked mandatory and any stricter firm policy.
• Recommended: practices marked recommended should be adopted where feasible and any decision not to adopt them should be recorded in the engagement file.
• Principle: no client deadline or fee overrides a stop-work decision made on safety or compliance grounds.
• Principle: when in doubt, pause and escalate to the Safety and Compliance Lead before proceeding.

2Roles, competence, and accountability

Accountability must be named, not assumed. The managing director or equivalent senior leader owns the safety and compliance program and provides resources. A designated Safety and Compliance Lead maintains this document, approves travel and site visit plans, reviews sensitive advice, and receives incident reports. Project leads scope each engagement, confirm authorizations before work starts, and make sure team members hold current training. Each individual consultant follows the rules, reports hazards, and declines tasks outside their competence.

Competence is specific to the task. A person who understands customs procedures is not automatically qualified to sign off on chemical hazard classifications, product safety declarations, or greenhouse gas calculations. Advice outside one's qualification must be referred to a qualified specialist, whether inside the firm or outside it.

• Mandatory: each engagement must have a named project lead and a written scope before fieldwork begins or advice is issued.
• Mandatory: consultants may not sign tariff classifications, origin statements, sustainability certifications, or legal opinions unless authorized in writing for that work type.
• Mandatory: site visits involving industrial machinery, chemicals, pressurized systems, or construction must be led or accompanied by a person with relevant technical competence, or limited to observation from approved areas.
• Mandatory: staff must not give legal advice on a jurisdiction's law without qualified local counsel and documented verification.
• Recommended: maintain a competence register that lists each person's authorizations, specialist training, and refresher requirements.
• Recommended: pair newer staff with an experienced reviewer for first assignments in a new country, sector, or regulatory area.

3Course-specific hazards and risk assessment

Most hazards in trade and sustainability consulting are indirect, but several can cause serious harm. Physical hazards arise on factory floors, warehouses, ports, farms, and construction sites, including moving vehicles, forklifts, conveyors, unguarded machinery, slippery surfaces, poor lighting, and heat. Travel hazards include road accidents, air travel disruption, and personal security risks in regions affected by unrest or crime. Chemical hazards arise when consultants tour plants or receive product samples that have not been characterized.

Other hazards are legal, financial, and informational. Sanctions or export control breaches can occur through an unscreened counterparty. Misclassified goods can cause duty underpayment or seizure. Unsupported environmental claims can create misrepresentation exposure. Leaked supplier audit data, phishing, and insecure file sharing can expose personal data and trade secrets. Each hazard should be rated by likelihood and severity on a simple five-point scale, recorded in the engagement file, and reviewed when scope changes.

• Example: a visit to a metal fabrication plant is rated high severity for crush, cut, and struck-by injuries. Control: host site induction, required PPE, and an escort who keeps the visitor on marked walkways.
• Example: a classification request for a product with unclear composition is rated high for legal exposure. Control: written request for technical data and qualified review before any advice is issued.
• Example: a carbon reduction claim based on supplier-provided figures is rated high for misstatement. Control: source verification and a documented limit on how the claim may be worded.
• Example: travel to a region with an active government travel advisory. Control: documented travel risk review and a decision by the Safety and Compliance Lead before booking. Consult current official advisories and verify them with the relevant authority.

4Preventive controls and safe work practices

Controls should be applied in this order: eliminate the hazard, substitute a safer method, apply engineering or administrative controls, and use personal protective equipment as the last layer. In consulting, elimination often means answering a question through remote document review rather than a site visit. Substitution means using licensed third-party laboratory testing instead of informal sampling by consultants. Administrative controls include limiting visitor numbers, requiring two-person review, and setting time limits on field days.

Safe work practice includes verifying each restricted party screen with a recorded result, confirming scope before issuing conclusions, and keeping a clear trail showing who reviewed each sensitive output. Advice should state its assumptions and limits. A confident conclusion built on unverified inputs is a hazard to the client.

• Mandatory: screen all counterparties, consignees, banks, and intermediaries against applicable sanctions and restricted party lists before proceeding. Record the result and the list used.
• Mandatory: do not handle, open, or transport client samples or chemicals without written instructions and an approved handling procedure. Hazardous materials move only through qualified carriers.
• Mandatory: on host site visits, follow the site rules, wear the PPE the site provides, remain on marked routes, and stop if instructed by site staff.
• Mandatory: do not offer, accept, or solicit gifts, payments, or hospitality that could be considered improper under applicable anti-bribery laws. Report any request for a facilitation payment to the Safety and Compliance Lead.
• Mandatory: do not use client information for personal gain, and do not trade on or share material non-public information about listed companies.
• Mandatory: do not stand under suspended loads, cross moving equipment lines, or climb on machinery during a facility visit.
• Recommended: use two-person review for any sustainability claim that will be published or submitted to a regulator or buyer.
• Recommended: keep a claims register that marks each statement as verified, estimated, or unsupported, with its source.
• Recommended: avoid working alone during late-night travel or fieldwork. Use scheduled check-ins with a named colleague.

5Equipment, environment, information, and protective safeguards

Equipment in this field includes laptops, phones, cameras, handheld measurement devices used for observation, sample containers, and vehicles. Environments include offices, client premises, ports, warehouses, factories, farms, and remote locations with limited medical access. Information includes trade and customs records, supplier audit files, personal data about workers, interview notes, and confidential commercial terms. Each category needs its own safeguard.

Protective safeguards include PPE that matches the host site's hazard assessment, such as safety footwear, high-visibility clothing, eye protection, and hearing protection. Information safeguards include multi-factor authentication, encrypted storage, firm-approved file sharing, clean desk habits, and secure disposal. Data protection laws vary by jurisdiction and may restrict collection, storage, or cross-border transfer of personal data, so the Safety and Compliance Lead must confirm requirements before worker interviews begin.

• Mandatory: use only firm-approved devices and file sharing for client data. Do not send confidential files through personal email or consumer messaging apps.
• Mandatory: store worker interview notes and supplier audit data with access limited to the named engagement team.
• Mandatory: remove or protect personal identifiers in interview records, and obtain consent where applicable law requires it.
• Mandatory: operate measurement devices only as described in the manufacturer instructions and only with current calibration records where required.
• Recommended: carry an emergency information card and keep copies of identification and insurance details in approved encrypted storage.
• Recommended: set up a desk with an ergonomic chair and screen height, and take a short break at least once every hour during long drafting sessions.

6Incident reporting, emergency response, and escalation

Incidents include injuries, near misses during site visits, security threats, data breaches, suspected sanctions or bribery concerns, discovery of a material error in a report already issued, and environmental spills or releases. The first priority is life safety. For any injury, fire, medical emergency, or violent threat, call local emergency services first, then notify the host site and the Safety and Compliance Lead. Do not attempt rescue or first aid beyond your training.

After the immediate response, preserve evidence and do not delete files, messages, or photographs. Whether a data breach or misstatement triggers notification to clients, regulators, or affected individuals depends on the jurisdiction and facts. Legal counsel must decide this with the Safety and Compliance Lead.

• Mandatory: report every injury, near miss, and unsafe condition observed during a visit to the Safety and Compliance Lead as soon as it is safe to do so, within the time set in firm policy.
• Mandatory: stop work and withdraw from any area where a hazard cannot be controlled. No one is penalized for stopping work in good faith.
• Mandatory: escalate suspected sanctions violations, bribery requests, forced labor indicators, or environmental releases before any further client communication on that matter.
• Mandatory: suspend the trip or site visit and notify the Safety and Compliance Lead if a host government or security adviser recommends departure.
• Recommended: keep a wallet card listing local emergency numbers, the firm crisis contact, insurer details, and the embassy or consulate contact where applicable.
• Recommended: run a tabletop exercise on a data breach and a site injury at least once a year, and record lessons learned.

7Records, training, and inspection

Records prove that controls were applied. Each engagement file should contain the signed scope, risk assessment, authorizations, screening results, data sources, reviewer sign-off, and any deviation from this document. Travel approvals, site visit reports listing PPE and induction received, incident logs, and training records should be kept together and be retrievable. Retention periods depend on firm policy and applicable legal requirements, which vary by jurisdiction, so verify them with qualified advisers.

Training is layered. All new staff complete an induction covering this document, data security, travel safety, and anti-corruption rules before live client work. Specialist training is required before advice in a new area, such as chemical hazard classification, sanctions procedures, or a sustainability reporting framework. Refresher training follows the firm's schedule and is recorded.

• Mandatory: every engagement file must contain a signed scope, a risk assessment, and the names of authorized reviewers.
• Mandatory: complete the required training before performing fieldwork or issuing specialist advice in a new area.
• Recommended: use a standard checklist for each travel plan and site visit so that induction, PPE, contacts, and check-in arrangements are recorded.

8Monitoring, continuous improvement, and limits of this guidance

Monitoring turns this document into a working system. The Safety and Compliance Lead should review incident logs and near-miss trends regularly, spot check travel and site visit records, and audit access to client data. Findings should lead to specific changes, with an owner and a completion check. This document itself must be reviewed after any serious incident, after material changes in trade, sanctions, or sustainability law, and at least once a year.

This document is educational guidance and a starting point for locally approved procedures. It does not state current legal requirements, technical limits, or manufacturer specifications for any jurisdiction. Competent authorities, trade counsel, data protection specialists, qualified engineers, and the host site's own procedures must be consulted and their current versions verified. Consultants must not perform tasks that require authorization they do not hold, and must call emergency services in any situation that threatens life.

• Mandatory: record every significant deviation from this document and its justification in the firm's management review file.
• Recommended: update local procedures to reflect the specific client sectors, countries, and tools the team uses most often.

Implementation checklist

• Confirm a named project lead and written scope before any fieldwork or advice.
• Screen all counterparties against applicable sanctions and restricted party lists and record results.
• Verify your competence and authorization before signing classifications, origin, or sustainability statements.
• Obtain the host site induction and required PPE before any facility visit, and stay on marked routes.
• Use only firm-approved devices and file sharing for client and worker data.
• Do not handle client samples or chemicals without written instructions and an approved procedure.
• Report injuries, near misses, bribery requests, and suspected violations to the Safety and Compliance Lead immediately.
• Call local emergency services first for any injury, fire, or threat, then notify the host and the firm.
• Keep the engagement file, travel approval, and training records complete and retrievable.
• Verify all applicable laws and advisories with competent authorities or qualified professionals before acting.