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Answer each questionnaire once, then reuse it

We build an evidenced answer library for customer questionnaires on bribery, sanctions, conflicts and carbon.

Start a conversationRead about customer carbon requests
Part of
Transparency Consulting
Runs as
4 stages, from collect the requests to answer and hand over
You receive
6 deliverables, listed below
Pricing
Quoted after a scoping call

Each customer asks it differently

A mid-size supplier can receive questionnaires from several large customers in a single quarter, each with its own portal and its own wording. One asks whether you have an anti-bribery policy and who approved it. Another asks for Scope 1 and 2 emissions and the method used. A third asks you to confirm that no owner, director or bank appears on a sanctions list. The answers usually come from whoever opened the email, drawing on memory and last year's spreadsheet.

The risk is inconsistency. Two customers receive different answers to the same question, or a confident yes that the records do not support. When a customer asks for evidence, or a contract ties your answers to a warranty, that gap becomes a commercial problem.

Engraving of a small tugboat towing a huge ocean liner on a magenta rope.
Small suppliers carry big reports.

The library covers six question families

  • Anti-bribery and corruption

    The policy, gifts and hospitality rules, use of agents and intermediaries, training records, and how payments to third parties are approved and reviewed.

  • Sanctions and ownership

    Screening of owners, directors, banks and counterparties, with the lists used and the screening date, plus a defensible statement of who owns and controls the business.

  • Conflicts and conduct

    Conflict-of-interest disclosures, related-party transactions, the code of conduct, and the speak-up channel available to employees and suppliers.

  • Carbon activity data

    Scope 1 and 2 activity data drawn from your payables ledger, such as fuel, electricity and gas invoices, organized for your emissions calculator or adviser and for customers' Scope 3 requests.

  • VSME-sized sustainability answers

    For EU customers, a response sized to the voluntary SME standard, the most a large reporter may require from a value-chain company with up to 1,000 employees.

  • Portal mapping

    A map from the library to the portals and formats your customers use, so each new questionnaire is filled from approved answers instead of drafted again.

An answer library you maintain

DeliverableWhat it isWhen
Request registerEvery open and recent questionnaire, with the customer, deadline, question families and who answered last timeWeek 1
Evidence gap listQuestions you cannot yet answer truthfully with evidence, ranked by commercial consequence, each with a proposed fixWeek 3
Answer libraryApproved answers by question family, each with an owner, supporting document, last-verified date and approved wordingWeek 6
Activity data workbookFuel, electricity and gas quantities and spend extracted from your ledger and invoices, reconciled to the general ledgerWeek 6
Priority questionnairesThe most urgent customer questionnaires completed from the library and checked by a second reviewer before submissionWeek 7
Maintenance runbookWho updates which answers, when to re-verify them, and how to handle a question the library does not coverWeek 8

Eight weeks to a working library

  1. Weeks 1 to 2

    Collect the requests

    We gather every questionnaire from the past year, group the questions into families, and note what each customer can require under its contract and, for EU customers, under the value-chain cap.

  2. Weeks 2 to 4

    Find the evidence

    We locate the record behind each answer, test the answers that touch money against the ledger, such as payments to agents, and list the gaps.

  3. Weeks 4 to 6

    Write and approve

    We draft answers in plain, consistent language, each owner approves theirs, and a second reviewer checks every answer against its evidence.

  4. Weeks 6 to 8

    Answer and hand over

    We complete the most urgent questionnaires from the library, train the people who will answer the next ones, and hand over the runbook.

Bring every questionnaire you have

  • Every customer questionnaire received in the last twelve months, with any answers already sent
  • Relevant contract clauses, customer supplier codes and any warranties tied to your answers
  • Current policies on anti-bribery, conflicts, gifts, sanctions and conduct, with approval dates
  • Read-only access to the accounting system, or exports of payables and the vendor master
  • Utility, fuel and travel invoices or account statements for the reporting period
  • A named owner for each question family, usually drawn from finance, operations and HR

Is this the right fit?

A good fit

  • Suppliers to large US or EU companies that receive integrity or sustainability questionnaires several times a year
  • Companies that have answered the same question differently for different customers and want one approved version
  • Suppliers whose customers report under California SB 253 and have started asking for emissions data
  • EU-facing suppliers with up to 1,000 employees that want to know where a request exceeds the voluntary standard

Not the right fit

  • Companies that need assured emissions figures or formal greenhouse gas verification; we organize the data and work with your verifier
  • Organizations that must produce a full CSRD report of their own; this service is sized for value-chain requests

One answer, one owner, one record

Each entry in the library has four parts: the approved wording, the owner who may change it, the record that supports it and the date it was last verified. When a new questionnaire arrives, the person answering matches each question to an entry and uses the approved wording. If no entry fits, the question goes to the relevant owner, and the new answer joins the library once it is approved. Over a year the library comes to match the questions your customers actually ask, and the same question gets the same answer whichever customer asks it.

Carbon data starts in payables

For a smaller company, Scope 1 and 2 data usually comes from a handful of vendors: the electricity and gas utilities, the fuel card provider, perhaps a propane supplier. All of them are already in your payables ledger. We extract their invoices, capture quantities as well as spend, reconcile the totals to the general ledger, and flag gaps such as a site whose utility bills stop in August. The result is a workbook that a customer, adviser or verifier can trace line by line. For more on what customers are asking for and why, see your customer wants your carbon data.

Integrity answers need evidence too

An anti-bribery policy is easy to cite. The customer's next question is harder: how do you know it is followed? We test the transactions behind the answer, including payments to agents, gifts and hospitality spend, and payments to new vendors in higher-risk countries, so the library can say what was checked and when. Sanctions and ownership answers rest on screening records and, where a counterparty's ownership is unclear, on counterparty and vendor due diligence.

The library never overstates

It will not claim a certification you do not hold, a policy that has not been approved or a figure that has not been reconciled. Where the honest answer is "not yet", the library says so and gives a date, which a customer can plan around. We do not give legal advice on contract terms; where a request raises a legal question, we flag it for your counsel. Answers you are comfortable making public can also appear on an Integrity Center, which spares customers the question altogether.

What people ask before hiring us

Can a large EU customer require more than the voluntary SME standard?

Under the CSRD as amended by Directive (EU) 2026/470, a large reporter may not require more than the voluntary standard from value-chain companies with up to 1,000 employees. The Commission adopted that standard on 3 July 2026, and the cap applies from financial years beginning on or after 1 January 2027. Customers may still send longer questionnaires, and contracts can carry their own terms, so we map each request against the cap and your contract, and you decide, with your counsel where needed, how to respond.

Does SB 253 apply to us as a supplier?

SB 253 applies to US entities with more than $1 billion in annual revenue that do business in California. Most suppliers fall below that line, but their customers may not. First Scope 1 and 2 reports are due 10 November 2026, without assurance, and the California Air Resources Board has proposed Scope 3 reporting from 2027. Scope 3 covers emissions across a company's value chain, including its suppliers, which is when data requests are likely to grow.

Do you calculate our emissions?

We extract and reconcile the activity data, such as fuel, electricity and gas, from your ledger and invoices, and organize it in the form your calculator, adviser or customer needs. We do not issue assured emissions figures. If a customer requires verification, the workbook is built so a verifier can trace each figure to its invoice.

What about anti-bribery questions when we use agents or distributors?

Those questions need evidence, not just a policy. We test payments to agents, distributors and consultants in your ledger for round amounts, unusual timing and payments routed to a country other than the one where the agent works, so your answer reflects what the records show.

Also in Transparency Consulting

Help deciding what to disclose about financial integrity, then building the reports, public pages and questionnaire answers that prove it.

  • Financial Integrity Report

    A voluntary annual report, in plain language and checked against your records, that tells boards, funders and partners how money is governed and what changed this year.

  • Integrity Center

    A public page on your own domain that shows how your organization governs money, with dated policies, management's control attestations and a change log, kept current by subscription.

Related work and reading

Services

  • Counterparty & Vendor Due Diligence

    Sourced research on who owns and controls a counterparty, whether it is sanctioned or in adverse media, and whether its finances support the relationship, written up as a red-flag report.

  • Financial Policies & Procedures

    A six-to-twelve-week project that writes or rewrites your financial policies and procedures around how your systems and people work, checks them against the ledger and gives every document an owner.

Articles and scenarios

  • Your customer wants your carbon data

    Large customers are collecting emissions data for California's SB 253 and the EU's CSRD. What they may ask, what they will ask next, and how a supplier can answer once and reuse it.

  • Beneficial ownership after the CTA rollback

    FinCEN's final rule ended beneficial ownership reporting for US companies and US persons. Foreign reporting companies still file, banks still ask, New York has its own law, and buyers still want the chart.

Sectors

Tell us what you are seeing

A first conversation is a scoping call: what worries you, what you need to show, and to whom. You leave it with a view on where to start, whether or not you hire us.

Start a conversation
Writehello@financeethics.com
Call(307) 365-5252
Office7124 Commons Dr, Cheyenne, WY 82009
HoursMonday to Friday, 9:00 to 17:00 Mountain Time