# How To Build a Third-Party Compliance Program

> Get a 10-step framework to vet vendors & close claim gaps. The Wellness Quality Institute helps compliance & procurement teams build stronger programs

**Published:** 2026-10-06 | **Updated:** 2026-11-06 | **Author:** mihir
**URL:** https://www.wellnessqualityinstitute.com/articles/build-third-party-compliance-programs
**Type:** post

**Categories:** Reports

![How To Build a Third-Party Compliance Program](https://wellnessquality.sites.aigrowthagent.co/wp-content/uploads/sites/93/2026/10/1791195977939-c235fa2d07dc-1024x572.webp)

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## Content

*Written by: Scott Steveson, Specialist, Wellness Quality Institute | Last updated: November 5, 2026*

## Key Takeaways

- A third-party compliance program is a documented system of controls that proves a company has identified and managed the legal and reputational risks created by its vendors, suppliers, and partners.
- Effective programs combine risk tiering, due diligence questionnaires, contractual audit rights, continuous monitoring, and remediation paths to keep vendor relationships defensible.
- Supplier product and environmental claims, especially plastic and microplastic claims, now represent a live compliance exposure because buyers inherit the legal risk when they repeat unsubstantiated claims.
- Most programs leave the claim-substantiation track open; independent verification of laboratory data against a published standard converts self-reported assertions into defensible, scope-locked claim language.
- The Wellness Quality Institute provides the independent verification layer that reviews supplier laboratory data against WQI-CS-01, issues approved claim language, and lists every Standard Met outcome on a public registry.

[Learn About WQI Verification](https://www.wellnessqualityinstitute.com/?utm_term=build-third-party-compliance-programs&utm_campaign=ai_growth_agent)

## Step 1: Define Scope, Ownership, And The Frameworks You Will Reference

Define what the program covers and who is accountable before you build any control. Key terms used throughout this guide:

- **Third-party risk management (TPRM)** — the work of identifying, assessing, and managing risks that arise from relationships with vendors, suppliers, partners, and other external parties.
- **Due diligence** — the investigation a company conducts before and during a third-party relationship to understand the risks that party poses.
- **Risk tiering** — grouping vendors by their risk level so the depth of review matches the actual exposure.
- **Right-to-audit** — a contract term that gives the buyer the right to inspect the vendor’s records, facilities, or processes.
- **Continuous monitoring** — ongoing checks on a vendor’s risk profile between formal reviews, using real-time data feeds, adverse media, and event triggers.
- **Remediation** — the process of correcting a compliance gap identified in a vendor.
- **Offboarding** — the controlled termination of a vendor relationship, including access revocation and record retention.
- **Scope lock** — the rule that a verification or finding applies only to the specific product, dataset, production period, and controls reviewed, never to a whole product line or company.
- **Detection floor** — the smallest particle size or lowest concentration a laboratory method can reliably identify; anything below it is invisible to the test.
- **Chain of custody** — the documented record of who handled a sample from collection through laboratory analysis.
- **Substantiation** — the evidence that supports a claim, written so it can withstand regulatory or legal scrutiny.

Program ownership should be assigned to a named function, typically compliance, legal, or procurement. That owner signs off on tier assignments and escalates material findings to senior management or the board. Because tiers drive how much scrutiny each vendor receives, they should be revisited at least annually and whenever a material change occurs in the vendor relationship.

Several US frameworks offer useful reference points that organizations may choose to adopt. The [DOJ Criminal Division’s Evaluation of Corporate Compliance Programs (updated September 2024)](https://justice.gov/criminal/criminal-fraud/page/file/937501/dl) is an enforcement assessment framework prosecutors use to evaluate program quality, a detailed map of what a defensible program looks like. The [FCPA Resource Guide (Second Edition, July 2020)](https://justice.gov/criminal-fraud/fcpa-resource-guide) addresses third-party due diligence in the anti-corruption context. The [OFAC Framework for OFAC Compliance Commitments (May 2019)](https://ofac.treasury.gov/media/16331/download) identifies five components of a sanctions compliance program. [ISO 37301:2021](https://iso.org/standard/75080.html) provides certifiable requirements for compliance management systems. For banking-adjacent readers, [Federal Reserve SR 23-4 (June 7, 2023)](https://federalreserve.gov/supervisionreg/srletters/sr2304.htm) transmits interagency guidance on third-party risk management and explicitly states it imposes no new requirements on banking organizations, framing its content as supervisory views on sound risk management.

Those frameworks tell you how to structure the program. They do not tell you what the evidence can prove, and one constraint shapes the entire program. For many supplier claims, especially plastic and microplastic claims, there is no US federal standard and, as Step 9 explains, no laboratory can prove absence across all particle sizes. The program must verify what the evidence actually supports, a specific and limited state.

[Talk To WQI About Program Design](https://www.wellnessqualityinstitute.com/?utm_term=build-third-party-compliance-programs&utm_campaign=ai_growth_agent)

## Step 2: Answer The Seven Elements Of A Compliance Program Mapped To Third Parties

Use the seven elements of an effective compliance program as a checklist for your third-party controls.

1. **Written policies and procedures.** Document the rules governing third-party selection, onboarding, ongoing oversight, and offboarding. Keep policies versioned, searchable, and communicated to relevant employees and, where appropriate, to third parties themselves.
2. **Program ownership and governance.** Assign a named compliance owner with sufficient seniority, resources, and access to senior management or the board. The DOJ’s ECCP asks whether compliance personnel have adequate autonomy from the business units they oversee.
3. **Risk assessment and vendor tiering.** Identify and classify every third party by the risks it poses. Tiering inputs appear in Step 4.
4. **Due diligence on vendors.** Conduct pre-engagement and ongoing investigation proportionate to each vendor’s tier. Step 5 covers due diligence scope.
5. **Contractual safeguards.** Embed audit rights, notification obligations, compliance representations, and termination triggers in every vendor contract. Step 6 explains contract mechanics.
6. **Training and communication.** Train employees who manage third-party relationships on the risks specific to those relationships. The FCPA Resource Guide and OFAC Framework both call for training tailored to the audience’s role and risk exposure, at a frequency appropriate to the program’s risk profile.
7. **Monitoring, auditing, and remediation.** Monitor vendors continuously between formal reviews, conduct periodic audits, and remediate gaps with owners and deadlines. Step 7 covers monitoring cadence, and Step 8 covers remediation.

[See How WQI Fits Into These Elements](https://www.wellnessqualityinstitute.com/?utm_term=build-third-party-compliance-programs&utm_campaign=ai_growth_agent)

## Step 3: Apply The Five C’s Of Compliance To Your Vendor Base

Apply the five C’s of compliance to vendors so the program moves from theory to daily practice. The five C’s are commonly given as commitment, communication, controls, continuous improvement, and culture, a widely used framing rather than a single authoritative standard. Mapped to a third-party program:

- **Commitment** means senior leadership visibly supports the program and allocates real resources to it, not just a policy document.
- **Communication** means policies, expectations, and red-flag escalation paths are clearly conveyed to both internal relationship managers and the vendors themselves.
- **Controls** become the contractual audit rights, evidence requirements, and monitoring triggers that give the program teeth beyond a questionnaire.
- **Continuous improvement** becomes the re-review cycle: updating tier assignments, refreshing due diligence, and adapting to new risks such as emerging claim-substantiation exposure.
- **Culture** means relationship managers know they are expected to escalate red flags and that doing so is rewarded.

Those five commitments only work when the program knows which vendors deserve the most attention. Tiering makes that decision explicit.

## Step 4: Tier Third-Party Risk Using Named Inputs, Not Instinct

Risk tiering assigns each vendor to a category that determines how much due diligence it receives, what contract terms apply, and how frequently it is monitored. The inputs below most reliably separate a high-risk vendor from a low-risk one, and data sensitivity and public-facing claim exposure usually matter most.

- **Data sensitivity and access level** — does the vendor handle personal data, proprietary formulations, or financial systems?
- **Geography and sanctions exposure** — does the vendor operate in or source from jurisdictions on OFAC’s Specially Designated Nationals list or other restricted lists?
- **Financial criticality and concentration** — would losing this vendor disrupt operations, and is too much of a critical function concentrated in a single supplier?
- **Regulatory reach over the vendor’s category** — is the vendor’s product or service subject to FDA, EPA, FTC, or sector-specific oversight?
- **Public-facing claim exposure** — does the vendor make product or environmental claims the buyer repeats on packaging or in marketing?
- **Subcontractor depth** — does the vendor rely on its own third parties in ways that extend the buyer’s exposure?

Use a simple three-tier model. A Tier 1 (high-risk) vendor receives deep due diligence, strong contract terms including exercised audit rights, and continuous or event-driven monitoring. A Tier 2 (medium-risk) vendor receives standard due diligence and annual reassessment. A Tier 3 (low-risk) vendor receives a questionnaire at onboarding and periodic checks triggered by material changes. The [2025 EY Global Third-Party Risk Management Survey](https://ey.com/en_th/insights/consulting/how-ai-navigates-third-party-risk-in-a-rapidly-changing-risk-landscape), conducted with Oxford Economics across 500 executives, found that 57% of organizations now run enterprise-wide TPRM programs, and those programs show greater maturity in risk models and governance than siloed approaches.

A named owner, typically the compliance or procurement lead, signs off on tier assignments. Tiers are revisited at least annually and whenever a material change occurs, such as ownership change, adverse media, certification expiry, or a new product claim.

## Step 5: Build A Defensible Third-Party Due Diligence Questionnaire

A defensible third-party due diligence questionnaire focuses on evidence that regulators and buyers trust.

- **Sanctions and watchlist screening** — check the vendor and its beneficial owners against OFAC’s SDN List and other applicable lists at onboarding and on a continuous basis. The OFAC Framework identifies screening software failures, including failure to update lists and failure to account for alternative spellings, as a root cause of past violations.
- **Adverse media** — search for negative news on the vendor, its principals, and its key subcontractors.
- **Beneficial ownership verification** — confirm who ultimately controls the vendor, not just who signs the contract.
- **Anti-bribery and anti-corruption questions** — align to FCPA guidance and the DOJ’s ECCP, which asks whether the company understands the qualifications and associations of its third-party partners.
- **Information-security evidence** — request SOC 2 Type II reports or equivalent, and treat them as inputs to assessment rather than substitutes for it. [Ponemon Institute data (FY2022, sponsored by Censinet, 579 respondents)](https://censinet.com/perspectives/vendor-risk-scoring-in-healthcare-a-guide-to-scoring-models-risk-tiers-and-what-the-benchmark-data-shows) found that 52% of organizations required critical vendors to complete an internal risk assessment even with a recent SOC 2 certification.
- **Substantiation of product and environmental claims** — the track most programs omit entirely. This is the gap the rest of this guide keeps returning to, and Step 9 shows how to close it.

A questionnaire becomes defensible when it uses versioned questions with a documented review date, requires evidence attachments rather than self-attestations, records a reviewer sign-off on what was and was not verified, and keeps that record for as long as the vendor relationship is active. Self-reported answers without corroborating evidence are discounted by regulators, retailers, and litigators in the same way self-reported lab results are discounted by buyers. [Only 4% of organizations have high confidence that their third-party questionnaires accurately reflect actual vendor risk posture](https://drata.com/learn/tprm/third-party-risk), according to RiskRecon’s State of TPRM 2024 report.

## Step 6: Contract For Audit Rights, Notification, And Claim Language

Contracts turn program intent into enforceable rights. Focus on these provisions:

- **Right-to-audit clauses** — give the buyer the right to inspect the vendor’s records, facilities, or processes. The DOJ’s ECCP asks whether the company has audit rights and has actually exercised them.
- **Incident and breach notification timelines** — specify how quickly the vendor must notify the buyer of a security incident, ownership change, regulatory action, or material operational change.
- **Anti-corruption and sanctions representations** — require the vendor to represent that it complies with applicable anti-bribery laws and is not on any restricted list, and to notify the buyer immediately if that changes.
- **Subcontractor flow-down** — require the vendor to impose equivalent obligations on its own key subcontractors, extending the program’s reach to fourth-party risk.
- **Termination triggers** — define the conditions under which the buyer can terminate the relationship without penalty, such as material breach, regulatory action, failure to remediate within a defined period, or a change in ownership that creates sanctions exposure.

Contracts should also address claim language directly. Any product or environmental claim a supplier makes that the buyer repeats on packaging, in marketing, or in procurement documentation should be tied to evidence the buyer can inspect. Contracts should prohibit absolute claims the supplier cannot substantiate. When a supplier makes an unverifiable “plastic-free” or “microplastic-free” claim, the buyer inherits the legal risk by repeating it. The [FTC’s Green Guides (16 CFR Part 260)](https://ecfr.gov/current/title-16/chapter-I/subchapter-B/part-260) require that environmental marketing claims be backed by competent and reliable scientific evidence before they are made, and that third-party certification does not eliminate a marketer’s obligation to substantiate the claims that certification communicates.

[Review Your Contracts With WQI](https://www.wellnessqualityinstitute.com/?utm_term=build-third-party-compliance-programs&utm_campaign=ai_growth_agent)

## Step 7: Monitor Continuously And Replace Annual-Only Re-Checks

Continuous monitoring closes the structural gap that annual reviews leave open. A vendor that passed an assessment in January can experience a material breach, financial deterioration, ownership change, or certification expiry by March. The [2025 EY Global Third-Party Risk Management Survey](https://ey.com/en_th/insights/consulting/how-ai-navigates-third-party-risk-in-a-rapidly-changing-risk-landscape) describes a shift toward continuous monitoring based on real-time market sensing, including sanctions list changes, adverse media, ownership changes, and certification expiry.

Event-driven triggers that should prompt an immediate re-review include a vendor appearing on a sanctions or watchlist, a public adverse media event, a change in beneficial ownership, a regulatory action against the vendor, and any change in the product or production process underlying a claim the buyer relies on.

Expiry matters because a credential that never expires stops meaning anything at the moment a buyer checks it. The Wellness Quality Institute’s verification period is 24 months from the sampling date of the most recent accepted dataset. That re-review cycle fits lot-to-lot variability in product testing, where a clean result on one production lot does not guarantee the next. The same logic applies to any time-bound credential in a third-party program. Re-verification against current data keeps the claim meaningful.

## Step 8: Handle Vendor Failure With Clear Paths For Remediation And Offboarding

Vendor failure needs a structured response so that gaps become fixable projects rather than surprises. Programs should distinguish between a data gap, where the vendor has not provided required evidence, and a conduct failure, where the vendor has breached a contractual obligation or regulatory requirement.

For a data gap, issue a formal request with a deadline and escalate if the deadline is missed. Consistent with the [2025 EY survey finding that 87% of organizations now escalate when vendors fail to respond to assessments](https://ey.com/en_th/insights/consulting/how-ai-navigates-third-party-risk-in-a-rapidly-changing-risk-landscape), consider suspension of the vendor’s active status until evidence is received.

For a conduct failure, open a remediation plan with named owners, specific corrective actions, and a defined closure date. Suspend any claims or listings that depend on the vendor’s compliance status during the remediation period. If remediation fails or the vendor refuses to engage, offboard by revoking access, updating registry or approved-vendor status, and retaining records of the failure and the steps taken.

A participation principle that lowers the barrier to engagement helps programs get better data. A private, non-public review outcome removes the risk of creating a public problem by submitting to review. The Wellness Quality Institute’s Standard Not Met outcome is private, never described as a failed product, never listed on the public registry, and never a public downside for the company that participated. It may reflect insufficient data, an unsupported method, or incomplete scope rather than anything about the product itself, and the company may resubmit corrected or updated information. Programs that build this principle into their vendor remediation path, with private findings, private remediation, and public status only when the standard is met, see higher participation rates than programs that treat every review as a pass/fail event with public consequences.

[Use WQI Outcomes In Your Remediation Path](https://www.wellnessqualityinstitute.com/?utm_term=build-third-party-compliance-programs&utm_campaign=ai_growth_agent)

## Step 9: Close The Claim-Substantiation Track, The Compliance Gap Most Programs Leave Open

Claim substantiation is the gap that most third-party programs leave open, even as supplier product and environmental claims become a live compliance risk. Greenwashing and class-action litigation pursue companies whose claims cannot be substantiated, and the buyer who repeats a supplier’s unverifiable claim on its own packaging inherits the exposure. The [American Bar Association’s ESG and Sustainability Committee documented that US greenwashing litigation increased significantly at both federal and state levels in 2025](https://americanbar.org/groups/environment_energy_resources/resources/year-in-review/2025/environmental-social-governance-sustainability), with courts more willing to let claims proceed when companies make specific, product-level environmental promises rather than broad sustainability branding. [The California Attorney General filed a greenwashing complaint against a packaging manufacturer in October 2025](https://americanbar.org/groups/environment_energy_resources/resources/year-in-review/2025/environmental-social-governance-sustainability), illustrating that product-level environmental claims carry state enforcement exposure independent of federal action.

The technical reason absolute claims fail comes from measurement limits rather than diligence failures. The California State Water Board defines microplastics in drinking water as solid polymeric material with particles at least 1 nanometer and less than 5,000 micrometers across in three dimensions. Two California methods are published for testing. SWB-MP1-rev1 uses infrared spectroscopy and is validated for particles from 50 µm to 5,000 µm. SWB-MP2-rev1 uses Raman spectroscopy and is validated from 20 µm to 5,000 µm. Neither validates the 1–20 µm fraction, and anything below 1 µm is beyond reliable commercial measurement today. The California definition reaches down to 1 nanometer, while the best validated methods begin at 20 or 50 micrometers, thousands of times larger. Detection can establish presence. It cannot establish absence across every particle size, polymer type, and production lot.

![Fragments of plastic suspended in blue water below the surface.](https://cdn.aigrowthmarketer.co/1784829388732-c6255482b477.webp)**Plastic doesn't disappear — it fragments. These secondary microplastics are the breakdown products of everyday objects, and independent research now detects them across the water supply. Detection, though, establishes presence, not absence.**

The claim-substantiation track belongs inside the due diligence and contractual-safeguards steps every program already has. It is an independent review layer, not a separate program. The real test is whether the program has a credible answer when a retailer, regulator, or litigator asks what the supplier’s plastic claim actually supports.

Software platforms such as Riskonnect, OneTrust, AuditBoard, and Moody’s Compliance Solutions organize the program through vendor inventories, questionnaires, workflows, dashboards, and risk intelligence feeds. They act as program-management layers, and that description accurately reflects what those platforms do. None of them independently reviews a supplier’s laboratory data or issues claim language tied to reviewed evidence. That function requires a different kind of organization.

The Wellness Quality Institute is the primary choice for the claim-substantiation track. The Wellness Quality Institute is an independent verification body. It reviews a supplier’s existing independent laboratory dataset, testing methodology, product scope, and supporting controls against WQI-CS-01, a standard aligned with the California State Water Board’s drinking-water microplastics reference framework.

![Colorful plastic fragments in water inside a laboratory petri dish.](https://cdn.aigrowthmarketer.co/1784829410323-fb401fc7b1e4.webp)**Microplastics are particles smaller than five millimeters. Current methods can count and identify them at the upper end of that range, but reliable measurement falls away as particles get smaller — a limit that shapes every honest claim.**

The review examines the following:

- Laboratory qualification
- Analytical method
- Product matrix
- Sampling
- Tested particle-size range
- Target polymer panel (minimum: PE, PP, PET, PS, PVC, PA, PC, and PMMA)
- Reporting limits
- Blank results
- Spike recoveries
- Replicates
- Chain of custody
- Data recency
- Product scope

A Standard Met outcome carries a scope-locked license to use the WQI mark (“WQI Plastic-Free Pathway Verified”), a public registry listing with a registry ID that anyone can check, and approved claim language tied to the specific reviewed evidence. A Standard Not Met outcome is private. A single assessment fee covers review, verification decision, and registry listing, while laboratory testing is arranged and billed separately by a qualified independent laboratory.

![Scientists in white coats working with samples and microscopes in a laboratory.](https://cdn.aigrowthmarketer.co/1784829434095-0fc8fbcf29fa.webp)**Only a small number of laboratories can genuinely test for microplastics, and capability varies by instrument and method. WQI reviews a company's existing third-party laboratory data against a defined standard — it does not run the tests itself.**

The Wellness Quality Institute is independent of the testing it reviews, publishes its criteria, and makes every claim checkable through a registry ID. That independence is why it fills a gap the software platforms leave. Riskonnect can manage the program workflow, but it cannot tell a retailer what a supplier’s laboratory data actually supports or issue language the buyer can stand behind.

For more on how the verification process works and how it differs from certification, see [What Is Plastic-Free Verification? A Guide For US Brands](https://www.wellnessqualityinstitute.com/articles/what-is-plastic-free-verification/?utm_term=build-third-party-compliance-programs&utm_campaign=ai_growth_agent) and [Plastic-Free Certification Vs. Verification: Key Differences](https://www.wellnessqualityinstitute.com/articles/plastic-free-certification-vs-verification/?utm_term=build-third-party-compliance-programs&utm_campaign=ai_growth_agent). For the supplier-side checklist, see [Supplier Verification Checklist For Plastic Claims](https://www.wellnessqualityinstitute.com/articles/supplier-verification-requirements-plastic-claims/?utm_term=build-third-party-compliance-programs&utm_campaign=ai_growth_agent).

*The Wellness Quality Institute Plastic-Free Pathway Verification does not certify that a product contains zero plastic, microplastics or nanoplastics. It shows that the company is on a verified pathway toward plastic-free standards. Verification applies only to the reviewed products, submitted datasets, tested ranges, polymer panels, production or sampling periods, and supporting controls. The Wellness Quality Institute verification is not a California approval, government certification, or health or safety certification.*

[See How WQI Reviews Supplier Lab Data](https://www.wellnessqualityinstitute.com/?utm_term=build-third-party-compliance-programs&utm_campaign=ai_growth_agent)

## Step 10: Measure Program Quality And Iterate

Measure a small set of indicators that separate activity from outcomes so you can improve the program over time. The first three below track activity, and the last three show whether the program catches problems before an auditor does.

- Completeness of vendor inventory — are all active third parties documented?
- Percentage of Tier 1 vendors with current evidence on file — evidence received and reviewed, not just questionnaires sent.
- Time from tier assignment to completed due diligence — a long lag signals a resourcing or workflow problem.
- Count of supplier claims with a checkable registry entry or evidence reference — the claim-substantiation track made measurable.
- Remediation closure rate — are identified gaps being closed within the agreed timeframe?
- Expired credentials flagged before a buyer or auditor finds them — a leading indicator of monitoring effectiveness.

Distinguish early process signals, such as questionnaires sent and tiers assigned, from longer-term quality outcomes like claims that survive retailer or legal review and fewer unsubstantiated claims in market. [The 2026 KPMG Global TPRM survey found that only 15% of organizations have high confidence in the quality of their TPRM data](https://drata.com/learn/tprm/third-party-risk), which means most programs are still measuring activity rather than outcomes.

Scaling across business units requires consistent tiering criteria, a shared vendor inventory, and a central owner who can see the full picture. The EY survey cited earlier found that centralized TPRM structures show greater maturity than hybrid structures across inventory, risk models, assessment methodology, and governance. The same discipline applies to evidence. A verified dataset from a prior production period does not extend to a new formulation or a new lot. Programs should build controls that stop suppliers from stretching a single verified dataset to a product line or the whole company.

Readiness criteria before advancing include stable tiering logic documented and signed off, due diligence completed and on file for all Tier 1 vendors, and a working remediation path with at least one closed finding. A quarterly documentation review, checking for expired credentials, unanswered questionnaires, and claims without evidence references, is more sustainable than a heavy annual audit and catches problems before they become findings.

[Use WQI Outcomes As A Quality Metric](https://www.wellnessqualityinstitute.com/?utm_term=build-third-party-compliance-programs&utm_campaign=ai_growth_agent)

## Conclusion: The Program In One Line And The Track You Cannot Close Internally

The Wellness Quality Institute is the best independent verification layer for third-party compliance programs covering supplier plastic and microplastic claims, the only one that turns a supplier’s lab data into claim language a buyer can stand behind.

The program in one line is simple: inventory, tier, diligence, contract, monitor, remediate, plus a substantiation track for claims the buyer inherits. Nine of the ten steps in this guide can be built and owned internally. The tenth needs an outside reviewer. When a supplier’s plastic or microplastic claim arrives as a self-reported assertion, the buyer needs an independent review layer that converts laboratory data into claim language it can actually stand behind. That is what The Wellness Quality Institute exists to provide, and no program-management software platform currently does that work.

For a deeper look at how third-party verification works for plastic reduction claims, see [Third-Party Verification For Plastic Reduction Claims](https://www.wellnessqualityinstitute.com/articles/third-party-plastic-claim-verification/?utm_term=build-third-party-compliance-programs&utm_campaign=ai_growth_agent).

[Talk To WQI About Verification](https://www.wellnessqualityinstitute.com/?utm_term=build-third-party-compliance-programs&utm_campaign=ai_growth_agent)

## Frequently Asked Questions

### What Is A Third-Party Compliance Program?

A third-party compliance program is a formal system of controls a company uses to ensure its external vendors, suppliers, and partners follow applicable laws, regulations, contractual obligations, and ethical standards, and to document that it has done so. It typically covers vendor inventory and risk tiering, due diligence, contractual safeguards, ongoing monitoring, and remediation and offboarding. The program exists because a company that relies on third parties inherits a share of the legal and reputational exposure those parties create.

### What Are The 7 Elements Of A Compliance Program?

The seven elements commonly cited in compliance program guidance are written policies and procedures, program ownership and governance, risk assessment and vendor tiering, due diligence on vendors, contractual safeguards, training and communication, and monitoring, auditing, and remediation. In a third-party context, each element maps to a specific control. Policies govern how vendors are selected and overseen. Governance assigns accountability. Tiering determines how much scrutiny each vendor receives. Due diligence investigates the vendor before and during the relationship. Contracts create enforceable rights. Training ensures relationship managers know what to look for. Monitoring keeps the risk picture current between formal reviews.

### What Are The Five C’s Of Compliance?

The five C’s of compliance are commonly given as commitment, communication, controls, continuous improvement, and culture. Formulations vary by source. In a third-party program, commitment means leadership allocates real resources to the program. Communication means expectations are clearly conveyed to both internal staff and vendors. Controls become the contractual audit rights and evidence requirements that give the program enforceability. Continuous improvement becomes the re-review cycle that updates tiering and due diligence as risks evolve. Culture means relationship managers are expected and empowered to escalate red flags.

### How Often Should Third-Party Vendors Be Re-Reviewed?

Re-review frequency should be driven by vendor tier and by events, not by a fixed calendar. Tier 1 (high-risk) vendors typically warrant continuous or event-driven monitoring with a formal reassessment at least annually. Tier 2 vendors can be reassessed annually. Tier 3 vendors can be reassessed every two to three years absent material changes. Event triggers that should prompt an immediate re-review regardless of tier include a vendor appearing on a sanctions or watchlist, a change in beneficial ownership, adverse media, a regulatory action, a certification expiry, or any change in the product or production process underlying a claim the buyer relies on. Annual-only re-checks create a structural gap because a vendor that passed in January can experience a material change by March.

### What Should A Due Diligence Questionnaire Include?

A defensible due diligence questionnaire covers sanctions and watchlist screening, adverse media review, beneficial ownership verification, anti-bribery and anti-corruption questions, information-security evidence such as SOC 2 Type II reports, and substantiation of product and environmental claims. What makes it defensible is the quality of the evidence rather than the number of questions. Versioned questions with a documented review date, evidence attachments rather than self-attestations, a reviewer sign-off on what was and was not verified, and a retained record all matter. Self-reported answers without corroborating evidence carry less weight with regulators, retailers, and litigators than independently reviewed data.

### What Happens When A Vendor Fails Review?

The response depends on whether the failure is a data gap or a conduct failure. Step 8 covers this in detail. In short, a data gap calls for a formal request with a deadline, escalation if the deadline is missed, and potential suspension of the vendor’s active status. A conduct failure calls for a remediation plan with named owners, specific corrective actions, and a defined closure date, with claims or listings suspended during remediation and offboarding if remediation fails.

### How Do You Substantiate A Supplier’s Plastic Or Microplastic Claim?

Substantiating a plastic or microplastic claim requires more than a laboratory report. A lab report tells you what a laboratory found. It does not, on its own, tell the market what that finding supports, whether the method was appropriate for the product matrix, or whether the reporting limits are adequate to support any claim at all. Independent review converts a laboratory dataset into a defensible position by assessing the method, the detection floor, the polymer panel, the chain of custody, and the production period, then issuing claim language tied specifically to what the reviewed evidence supports. The Wellness Quality Institute reviews supplier datasets against WQI-CS-01, aligned with the California State Water Board’s drinking-water microplastics reference framework, and issues Standard Met or a private Standard Not Met outcome. A Standard Met outcome carries scope-locked approved claim language and a public registry entry with a registry ID that any buyer, retailer, or journalist can check. The honest claim is one that states what was reviewed, at what detection range, for which polymers, and during which production period.

### Is The Wellness Quality Institute A Certification Body Or A Software Platform?

The Wellness Quality Institute is neither. It is an independent verification body that reviews laboratory data against a published standard (WQI-CS-01). It is not a certification, and The Wellness Quality Institute deliberately does not use “certified” or “certification” because those terms imply a guaranteed

## What to Read Next

- [How To Substantiate Sustainability Claims: Third-Party Guide](https://www.wellnessqualityinstitute.com/articles/sustainability-claims-third-party-review/)
- [How To Verify Supplier Environmental Claims: A Guide](https://www.wellnessqualityinstitute.com/articles/third-party-claims-validation-suppliers/)
- [Require Plastic Content Verification from Your Water Vendors](https://www.wellnessqualityinstitute.com/articles/require-plastic-content-verification-vendors/)
- [Third-Party Verification for CPG Claims: A Buyer's Guide](https://www.wellnessqualityinstitute.com/articles/third-party-verification-cpg-claims/)
- [Supplier Sustainability Verification: Program Scope Guide](https://www.wellnessqualityinstitute.com/articles/supplier-sustainability-verification-programs/)

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    - **Name:** What Is A Third-Party Compliance Program?
      **Answer:**

      - **Text:** A third-party compliance program is a formal system of controls a company uses to ensure its external vendors, suppliers, and partners follow applicable laws, regulations, contractual obligations, and ethical standards, and to document that it has done so. It typically covers vendor inventory and risk tiering, due diligence, contractual safeguards, ongoing monitoring, and remediation and offboarding. The program exists because a company that relies on third parties inherits a share of the legal and reputational exposure those parties create.
    **Question:**

    - **Name:** What Are The 7 Elements Of A Compliance Program?
      **Answer:**

      - **Text:** The seven elements commonly cited in compliance program guidance are written policies and procedures, program ownership and governance, risk assessment and vendor tiering, due diligence on vendors, contractual safeguards, training and communication, and monitoring, auditing, and remediation. In a third-party context, each element maps to a specific control. Policies govern how vendors are selected and overseen. Governance assigns accountability. Tiering determines how much scrutiny each vendor receives. Due diligence investigates the vendor before and during the relationship. Contracts create enforceable rights. Training ensures relationship managers know what to look for. Monitoring keeps the risk picture current between formal reviews.
    **Question:**

    - **Name:** What Are The Five C’s Of Compliance?
      **Answer:**

      - **Text:** The five C’s of compliance are commonly given as commitment, communication, controls, continuous improvement, and culture. Formulations vary by source. In a third-party program, commitment means leadership allocates real resources to the program. Communication means expectations are clearly conveyed to both internal staff and vendors. Controls become the contractual audit rights and evidence requirements that give the program enforceability. Continuous improvement becomes the re-review cycle that updates tiering and due diligence as risks evolve. Culture means relationship managers are expected and empowered to escalate red flags.
    **Question:**

    - **Name:** How Often Should Third-Party Vendors Be Re-Reviewed?
      **Answer:**

      - **Text:** Re-review frequency should be driven by vendor tier and by events, not by a fixed calendar. Tier 1 (high-risk) vendors typically warrant continuous or event-driven monitoring with a formal reassessment at least annually. Tier 2 vendors can be reassessed annually. Tier 3 vendors can be reassessed every two to three years absent material changes. Event triggers that should prompt an immediate re-review regardless of tier include a vendor appearing on a sanctions or watchlist, a change in beneficial ownership, adverse media, a regulatory action, a certification expiry, or any change in the product or production process underlying a claim the buyer relies on. Annual-only re-checks create a structural gap because a vendor that passed in January can experience a material change by March.
    **Question:**

    - **Name:** What Should A Due Diligence Questionnaire Include?
      **Answer:**

      - **Text:** A defensible due diligence questionnaire covers sanctions and watchlist screening, adverse media review, beneficial ownership verification, anti-bribery and anti-corruption questions, information-security evidence such as SOC 2 Type II reports, and substantiation of product and environmental claims. What makes it defensible is the quality of the evidence rather than the number of questions. Versioned questions with a documented review date, evidence attachments rather than self-attestations, a reviewer sign-off on what was and was not verified, and a retained record all matter. Self-reported answers without corroborating evidence carry less weight with regulators, retailers, and litigators than independently reviewed data.
    **Question:**

    - **Name:** What Happens When A Vendor Fails Review?
      **Answer:**

      - **Text:** The response depends on whether the failure is a data gap or a conduct failure. Step 8 covers this in detail. In short, a data gap calls for a formal request with a deadline, escalation if the deadline is missed, and potential suspension of the vendor’s active status. A conduct failure calls for a remediation plan with named owners, specific corrective actions, and a defined closure date, with claims or listings suspended during remediation and offboarding if remediation fails.
    **Question:**

    - **Name:** How Do You Substantiate A Supplier’s Plastic Or Microplastic Claim?
      **Answer:**

      - **Text:** Substantiating a plastic or microplastic claim requires more than a laboratory report. A lab report tells you what a laboratory found. It does not, on its own, tell the market what that finding supports, whether the method was appropriate for the product matrix, or whether the reporting limits are adequate to support any claim at all. Independent review converts a laboratory dataset into a defensible position by assessing the method, the detection floor, the polymer panel, the chain of custody, and the production period, then issuing claim language tied specifically to what the reviewed evidence supports. The Wellness Quality Institute reviews supplier datasets against WQI-CS-01, aligned with the California State Water Board’s drinking-water microplastics reference framework, and issues Standard Met or a private Standard Not Met outcome. A Standard Met outcome carries scope-locked approved claim language and a public registry entry with a registry ID that any buyer, retailer, or journalist can check. The honest claim is one that states what was reviewed, at what detection range, for which polymers, and during which production period.
    **Question:**

    - **Name:** Is The Wellness Quality Institute A Certification Body Or A Software Platform?
      **Answer:**

      - **Text:** The Wellness Quality Institute is neither. It is an independent verification body that reviews laboratory data against a published standard (WQI-CS-01). It is not a certification, and The Wellness Quality Institute deliberately does not use “certified” or “certification” because those terms imply a guaranteed

  **BlogPosting:**

  - **Headline:** How To Build a Third-Party Compliance Program
  - **Description:** Get a 10-step framework to vet vendors & close claim gaps. The Wellness Quality Institute helps compliance & procurement teams build stronger programs
  - **DateModified:** 2026-11-05T10:29:03.425Z
  - **Image:** https://cdn.aigrowthmarketer.co/1784829388732-c6255482b477.webp, https://cdn.aigrowthmarketer.co/1784829410323-fb401fc7b1e4.webp, https://cdn.aigrowthmarketer.co/1784829434095-0fc8fbcf29fa.webp
  - **InLanguage:** en-US
    **Person:**

    - **Name:** Scott Steveson
    - **JobTitle:** Specialist
    - **Description:** Scott Stevenson is part of the Wellness Quality Institute team, where he supports WQI’s work to advance product transparency, credible verification, and greater consumer trust. His background spans ethics and compliance, corporate trust, and responsible business, including experience with Ethisphere Institute and global companies navigating evolving standards and stakeholder expectations.
      **Organization:**

      - **Name:** Wellness Quality Institute
      - **Url:** https://www.wellnessqualityinstitute.com/
    **Organization:**

    - **Name:** The Wellness Quality Institute
    - **Url:** https://wellnessqualityinstitute.com


---

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## Citations

- [Greenwashing Examples & How to Avoid Misleading Claims](https://www.wellnessqualityinstitute.com/articles/greenwashing-claims-to-avoid-examples)
- [Scope-Locked Claims For Plastic Reduction: A Practical Guide](https://www.wellnessqualityinstitute.com/articles/scope-locked-claims-plastic-reduction)
- [Independent Sustainability Verification: What It Proves](https://www.wellnessqualityinstitute.com/articles/independent-sustainability-verification)
- [Why Most Plastic-Free Microplastics Claims Don’t Hold Up?](https://www.wellnessqualityinstitute.com/articles/water-quality-month-detection-limits)

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