Team & Governance

Purpose

This document (the Governance Document) describes how Trading Integrity Bureau (TIB, operated by Stratinova LTD) is structured, governed, and held accountable. It is published so that any party — Firm, participant, regulator, journalist, or counterparty — can examine the structures behind a TIB Determination.

Companion documents

The Governance Document is read together with the Methodology, the Standards, the Terms of Service, the Legal & Disclosures, and the Privacy Policy.

Operating entity

TIB is operated by Stratinova LTD, a private company limited by shares incorporated in the Republic of Cyprus.

Legal name	Stratinova LTD
Trading name	Trading Integrity Bureau (TIB)
Form	Private company limited by shares
Jurisdiction of incorporation	Republic of Cyprus
Registration number	HE475207
Registered office	Archiepiskopou Makariou III 228, Agios Pavlos Building, 3030 Limassol, Cyprus
Principal website	integritybureau.org
Public registry	registry.integritybureau.org
General contact	contact@integritybureau.org

Regulatory and licensing status

Not a regulator

Stratinova LTD, trading as TIB, is a private, independent verification body. It is not a regulator, supervisory authority, or self-regulatory organisation, and does not hold any financial-services licence in any jurisdiction.

Permitted activities

The activities undertaken under the TIB name are limited to: (a) conducting verification engagements; (b) maintaining the public registry; (c) publishing the Standards, Methodology, and related research; and (d) issuing the Verified Mark to verified Firms under written licence.

Excluded activities

TIB does not, and will not, undertake any of the following: investment advice, portfolio management, custody of client funds, payment services, broking, dealing, market-making, or any other activity that requires financial-services authorisation in any jurisdiction.

Governance structure

Decision bodies

TIB operates the following internal bodies:

• Board. The board of directors of Stratinova LTD has overall responsibility for the operating entity. The board does not participate in individual Determinations.
• Standards Committee. Custodian of the published Standards. Approves new versions and is responsible for the annual review.
• Engagement Lead Function. Owns end-to-end delivery of each Engagement, including assignment of Reviewers, evidence sufficiency, and timeline.
• Appeals Panel. Convened on a per-appeal basis from senior Reviewers who did not participate in the original Determination.

Separation of functions

Commercial activity (scoping, fees, engagement letters) is organisationally separated from review activity (evidence assessment and Determinations). Personnel performing one function are excluded from the other in respect of the same Engagement.

Independence controls

The following controls operate to maintain the independence of every Engagement and are detailed in the Methodology, § 11:

• Separation of functions between commercial and review.
• Two-reviewer rule — no single individual may issue, deny, or revoke a Determination.
• Fixed criteria — a Firm cannot negotiate which criteria apply to it.
• Right of factual reply, not editorial control — a Firm may correct factual errors before publication but cannot alter the Determination.
• Revocation authority — a Determination may be withdrawn at any time on Material Findings to the contrary.
• Independent appeals — heard by Reviewers who did not participate in the original Determination.

Conflicts of interest

Reviewer-level conflicts

Before assignment to an Engagement, every Reviewer signs a written declaration covering: prior employment with the Firm in the preceding 24 months, financial interests in the Firm or its affiliates, personal relationships with controlling persons, and any other circumstance that could reasonably impair independent judgement. Where a conflict is identified, the Reviewer is disqualified.

Engagement-level conflicts

TIB does not conduct verification engagements where TIB or its operating entity has a relationship with the Firm that extends beyond the engagement itself. Such disqualifying relationships include, without limitation:

• Common ownership, common shareholders of significance, or any other relationship whereby Stratinova LTD or any of its affiliates holds a material economic interest in the Firm;
• Common directors, officers, or controlling persons;
• A separate commercial relationship with the Firm — including consulting, advisory, remediation, training, or service-provision arrangements;
• Any other circumstance that, on a reasonable view, could be regarded as compromising independence.

Where such a relationship exists, exists in prospect, or arises during an engagement, the engagement is declined or terminated. TIB does not operate a "related-party" carve-out: independence is preserved by exclusion, not by disclosure.

Excluded services

TIB does not provide consulting, advisory, remediation, training, or implementation services to any Firm in respect of matters within the scope of the Standards. This exclusion applies before, during, and after any verification engagement.

Conflict register

A confidential register of declared conflicts and declined engagements is maintained and reviewed periodically by the Engagement Lead Function. Material exceptions are escalated to the board.

Gifts and hospitality

TIB personnel may not accept gifts, hospitality, or entertainment of more than nominal value from a Firm under review. Anything beyond nominal value is recorded in a register and may be required to be returned or declined.

Funding model

Source of revenue

TIB's revenue comes from engagement fees paid by Firms. This is the customary model for third-party assurance services and introduces a structural conflict that is managed through the controls described in § 5 and § 6.

Fee policy

Engagement fees are confirmed in the engagement letter prior to the commencement of work. TIB does not operate performance-based, success, or contingent fees. Fees do not vary with the Determination.

Concentration

Where the revenue from a single Firm or affiliated group would exceed a threshold set by the board, additional independence safeguards apply, including mandatory rotation of Reviewers and additional oversight by the Standards Committee.

External funding

Stratinova LTD is privately held. Its ownership is disclosed in the company register of the Republic of Cyprus. TIB does not accept government, regulatory, or industry-association funding.

Roles and responsibilities

Role	Responsibility
Head of Verification	Ownership of the Reviewer team, Methodology consistency across Engagements, escalation of complex or contested cases.
Head of Standards	Custodian of the published Standards, chair of the Standards Committee, lead on the annual review.
Head of Operations	Registry integrity, security, data protection, vendor management, business continuity.
Engagement Leads	End-to-end delivery of individual Engagements; phase progression; evidence sufficiency.
Reviewers	Evidence assessment against the Standards; co-signing of Determinations.
Commercial	Scoping, fees, engagement letters; organisationally separated from Reviewers.
Data Protection Lead	Day-to-day responsibility for compliance with the UK and EU GDPR and Cyprus data-protection law.
Legal	Service of process, IP enforcement, mark-misuse, Engagement Agreement drafting.

Reviewer eligibility

Reviewers are appointed on the basis of demonstrable expertise relevant to the pillars they assess. Eligibility requirements include:

• Documented professional experience in trading-industry operations, risk, compliance, audit, or a related discipline;
• No disqualifying regulatory or criminal history;
• Acceptance of TIB's code of conduct, confidentiality obligations, and conflict-of-interest policy;
• Periodic training on the current Methodology and Standards.

Appeals

Right of appeal

A Firm subject to an adverse Determination has a right of appeal as set out in the Methodology, § 15.

Composition of panel

Appeals are heard by a panel of two senior Reviewers who did not participate in the original Determination. Where appropriate, the panel may co-opt an external subject-matter expert under confidentiality.

Decisions

The appeal panel may uphold, vary, or substitute the Determination. The decision is final and is recorded alongside the Registry entry.

Whistleblowing

Channel

Concerns relating to a Firm under review or already verified, or to TIB's own conduct, may be reported in confidence to whistleblower@integritybureau.org.

Protection of identity

TIB protects the identity of reporters to the extent permitted by Applicable Law. Identity is disclosed only where strictly necessary, and where reasonably possible the reporter is informed in advance.

Treatment of reports

Every report is reviewed by personnel independent of the subject of the report. Substantiated reports may trigger reassessment, revocation, or other appropriate action.

Quality assurance

TIB operates the following quality controls:

• Working-paper review. Each Engagement working file is subject to a quality review by personnel not involved in the Engagement;
• Periodic file sampling. A sample of completed Engagements is re-examined for adherence to Methodology;
• Annual Methodology review. The Standards Committee reviews the Methodology and Standards annually and recommends changes;
• Post-revocation review. Every revocation is reviewed for lessons learned and incorporated into Methodology guidance.

Records and retention

Engagement files, evidence items, and Reviewer working papers are retained for the duration of the Firm's Registry listing plus seven (7) years, in accordance with the Privacy Policy, § 9. Records are stored under access controls on a need-to-know basis and are encrypted at rest.

Insurance

Stratinova LTD maintains professional indemnity insurance appropriate to its activities. Details are confirmed to counterparties under engagement-specific terms where required. Insurance does not constitute or imply an indemnity to any third party in respect of any Firm.

Public disclosures

The following items are published and maintained on the TIB website:

• Operating entity details (this document);
• Verification Methodology;
• Integrity Standards with versioned changelog;
• Legal & Disclosures, Terms of Service, and Privacy Policy;
• The public registry with current and historical Determinations.

Updates and changelog

The Governance Document is reviewed at least annually and may be updated more frequently. Each version is identified by a document code (TIB-GOV-x.y) and an Effective Date.

Contact

• General: contact@integritybureau.org
• Engagements: engagements@integritybureau.org
• Legal: legal@integritybureau.org
• Privacy / data protection: privacy@integritybureau.org
• Whistleblowing: whistleblower@integritybureau.org
• Media: media@integritybureau.org
• Post: Stratinova LTD, Archiepiskopou Makariou III 228, Agios Pavlos Building, 3030 Limassol, Cyprus