Code of Ethics for IAJ Investigators

1. Purpose and Scope

1.1 Purpose

This Code of Ethics establishes the standards of conduct, professional discipline, and institutional duty that govern every IAJ investigator. Its purpose is to ensure that IAJ investigations meet the methodological and ethical standards required of an independent human rights investigative body organized under the Paris Principles, and that the IAJ's findings can be evaluated on their methodological merits by complainants, treaty bodies, courts, and the public.

1.2 Who Is Bound

This Code applies to:

• Staff investigators of the IAJ;
• Volunteer investigators, including independent investigators accepted to assist with fact-finding;
• Clinical and forensic experts retained or accepted to conduct medical or psychological evaluations;
• Court observers acting under IAJ designation;
• Researchers and analysts contributing to IAJ findings, reports, and publications;
• Any other person who, with IAJ authorization, conducts investigative, evaluative, or documentary work referenced to the IAJ.

1.3 Relationship to Other Instruments

This Code operates alongside, and does not displace, the IAJ Terms of Service, Privacy Policy, applicable investigation standards, the Istanbul Protocol (2022), Paris Principles, and the human rights treaty obligations binding on the United States. Where any of these impose a stricter duty than this Code, the stricter duty applies.

1.4 Tiered Investigator Roles

The IAJ operates with tiered investigative roles, each governed by an operating protocol consistent with this Code:

• Level 1 (intake and documentation). Open assignment with no required formal credential; performs complainant intake, document inventory, contradiction preservation, contemporaneous observation, and routing to higher levels. Level 1 may produce intake-triage classifications — strength ratings, contradiction classifications, missing-evidence priorities, issue-map flags — to assist Level 2 routing. These classifications are preliminary and non-anchoring; they are not findings and they do not determine the merits of any case. Level 2 reviewers shall conduct an initial review of the primary preserved materials — the complete statement, the v0 raw record, the session recordings, the key documents, the timeline — before relying on any Level 1 intake-triage classification, and shall make their own determinations from those primary materials. Level 1 matrices may be used for navigation after that initial orientation, not as substitutes for primary review. The IAJ's Level 1 Investigator Operating Manual implements this section at the Level 1 tier.
• Level 2 and above (analysis, evaluation, findings). Qualified reviewers, clinical and forensic experts, and counsel conduct credibility assessment under Istanbul Protocol indicators, clinical evaluation, legal analysis, and findings. Authority to issue findings resides at Level 2 and above.

The duties of impartiality (§3), methodological rigor (§4), epistemic precision (§5), and truthfulness (§6) apply to all tiers. Where a duty refers specifically to making findings, assessing credibility, or determining admissibility, the duty attaches to the level at which that determination is actually made. Level 1 investigators do not make findings, do not perform formal credibility assessment, and do not determine admissibility; they preserve and organize the record so qualified reviewers can do so.

2. Independence

2.1 Freedom from External Direction

Investigators conduct their work entirely free of government control, judicial influence, and political direction. No accused official, court, agency, donor, advocacy organization, or third party shall be permitted to direct the scope, methodology, conclusions, or publication timing of an IAJ investigation.

2.2 Agenda-Setting

The investigative agenda is set on the basis of complaints received and evidence gathered. Investigators do not initiate, expand, or curtail inquiries on the basis of considerations extrinsic to the evidence and to the IAJ's mandate.

2.3 No Advance Notice to Subjects

Investigations are conducted without advance notice to accused officials except where notice is methodologically required (for example, to invite response prior to publication) and is authorized in writing by the IAJ.

2.4 Institutional Loyalty Without Captivity

Investigators owe institutional loyalty to the IAJ's mandate. They do not owe institutional loyalty to any conclusion that the evidence does not support. An investigator who is asked, formally or informally, to reach a particular finding must refuse and report the request to the IAJ Director.

3. Impartiality and Non-Prejudice

3.1 Impartial Stance

Investigators hold no prejudice against any person, including judges, court officials, law enforcement officers, attorneys, or other public officials whose conduct is under examination. Findings are based on evidence and methodology, not on the identity, office, ideology, or reputation of the subject.

The identification of a subject's official capacity (judge, agency staff, law enforcement officer, court-appointed evaluator, contractor with delegated authority) as a factual element of treaty analysis is not the prejudgment-by-identity that this section forbids. It is a fact about the conduct under examination and may be required to assess whether state involvement is implicated. Prejudgment of conclusions on the basis of a subject's office, ideology, or reputation remains prohibited.

3.2 Accountability Distinguished from Animus

The IAJ's institutional purpose includes the possibility of rehabilitation: persons who violate human rights can, when confronted with independent documentation and provided with education and standards, reform. Investigators conduct their work consistent with that purpose. Accountability is pursued; animus is not.

3.3 Equal Treatment of Complainants

Investigators do not credit or discredit a complainant's account on the basis of the complainant's status, demographic characteristics, prior litigation history, or institutional affiliation. Credibility, where it is formally assessed, is assessed against the Istanbul Protocol's evidentiary indicators and the complete evidentiary record, by investigators operating at the level at which credibility findings are made (see §1.4). Level 1 investigators do not perform formal credibility assessment; the intake-triage classifications they may produce under §1.4 are not credibility findings.

4. Methodological Rigor

4.1 Istanbul Protocol Standard

Every investigation is conducted to Istanbul Protocol (2022) standards. Trauma-informed interviewing, credibility and arguability assessment aligned with Istanbul Protocol indicators, medical and psychological evaluation where applicable, and documentation of harm meeting international standards recognized by treaty bodies are required, not optional.

4.2 Multi-Treaty Legal Analysis

Findings are assessed against all human rights treaty frameworks applicable to the conduct in question — including but not limited to UNCAT, ICCPR, CRPD, CERD, and customary international law. No treaty is privileged; no applicable framework is omitted for convenience.

4.3 Evidence-Based Conclusions

Findings are grounded in evidence, clinical methodology, and legal analysis. Advocacy, rhetorical assertion, and conclusory characterization are not substitutes for evidence and shall not appear in IAJ findings.

4.4 Documentation and Chain of Custody

Investigators document the source, date, and provenance of every evidentiary item considered. Original materials are preserved; alterations, redactions, or annotations are recorded and attributable to the investigator who made them.

4.5 Contemporaneous Recording

Investigators shall make and preserve contemporaneous audio or audio-video recordings of substantive investigative contacts with complainants, to the extent lawful in the relevant jurisdiction, technically feasible in the relevant setting, and consented to by every person whose voice will be captured. Refusal of recording by any person whose voice would be captured carries no negative inference and shall not affect case handling. Where recording is not made, contemporaneous handwritten or typed notes are taken under §4.4. Recordings are preserved unaltered; covert recording is prohibited.

Operating protocols issued for particular investigator tiers shall specify consent procedures (including the form of consent and the documentation of refusal), storage, integrity, access, retention, and the handling of withdrawal of consent. Operating protocols addressing withdrawal of consent must, at a minimum, specify which of the following applies to recordings already made before withdrawal: destruction, sequestration without further use, or preservation under restricted access. Open-ended deferral of the question is not permitted.

Materials preserved under this section and under §4.6 may become subject to discovery, subpoena, or other compulsion. The IAJ's intake process shall inform complainants of this exposure as part of the informed-consent disclosure for participation, in language the complainant can understand. The Level 1 Investigator Operating Manual implements this section at the Level 1 tier.

4.6 Preservation of Adverse Materials

Investigators preserve, document, and report materials that contradict or complicate the complainant's account on equal footing with materials that corroborate it. Concealment, omission, or minimization of adverse materials is a methodological failure and an ethical breach.

Where a complainant offers an explanation for an apparent contradiction, the explanation is recorded as offered, without embellishment or rephrasing by the investigator. Investigators may ask open-ended questions inviting the complainant to clarify or complete an account; investigators shall not propose specific explanations, sequences, or characterizations for the complainant to adopt or reject. Open-ended invitation is permitted; supplying the proposed content is not.

The duty under this section, in combination with the recording duty under §4.5, may create a body of preserved materials that becomes subject to discovery or subpoena. Disclosure of this exposure to the complainant under §4.5 applies equally to materials preserved under this section. The Level 1 Investigator Operating Manual implements this section at the Level 1 tier.

5. Epistemic Precision

5.1 Distinctions Required

Investigators expressly distinguish, in every report:

• preliminary findings from verified conclusions;
• argued legal positions from settled doctrine;
• independent expert evidence from case-record documentation;
• complainant account from third-party corroboration;
• intake routing classifications from merits findings (see §1.4).

5.2 Acknowledgment of Contested Questions

Where a legal or factual question remains contested, the investigator says so. Overstatement of certainty is a methodological failure and an ethical breach.

5.3 No Manufactured Consensus

Investigators do not present a single view as if it were a consensus, nor do they cite supportive authority while omitting contrary authority of comparable weight.

6. Truthfulness and Accuracy

6.1 Truthful Representation

Investigators provide truthful, accurate, and complete information in every submission, report, internal record, and external communication made on behalf of the IAJ.

6.2 Correction of Errors

Investigators who discover material errors in their own prior work, or in published IAJ work to which they contributed, shall promptly notify the IAJ Director in writing so that a correction may be considered.

6.3 No Misrepresentation of Authority

Investigators do not represent IAJ findings as adjudicative orders, do not claim enforcement authority the IAJ does not possess, and do not suggest to any complainant, court, or third party that engagement with the IAJ guarantees a legal remedy.

7. Confidentiality and Data Protection

7.1 Duty of Confidentiality

Investigators handle complainant information, medical and psychological records, evidentiary materials, and case communications with the highest level of confidentiality. Sensitive information is accessed only as necessary to perform assigned work and is never disclosed beyond the scope authorized by the complainant and by the IAJ.

7.2 Respect for Complainant Control

Complainants control the publication scope of their case materials through the features provided in their secure “My Account” page. Investigators shall not override, circumvent, or pressure complainants to alter those settings.

7.3 Secure Handling

Investigators access IAJ systems only through authorized credentials, do not share credentials, do not store sensitive case material on unsecured personal devices, and report any suspected breach or loss of materials to the IAJ Director without delay.

7.4 Post-Engagement Duties

The duty of confidentiality continues after the conclusion of any particular investigation and after the cessation of the investigator's role with the IAJ.

7.5 Retention

Operating protocols shall specify retention periods for each category of case material, distinguishing among active-matter retention, post-closure retention, research or pattern-analysis retention (with separate consent), and scheduled destruction. The IAJ informs complainants at intake of the retention scheme applicable to their materials.

8. Conflicts of Interest

8.1 Disclosure

Before accepting assignment to any case, an investigator shall disclose to the IAJ any relationship, financial interest, prior representation, personal acquaintance, public statement, or other circumstance that could reasonably be perceived as compromising independence or impartiality with respect to the complainant, the accused official, or the matter under investigation.

8.2 Recusal

Where a conflict exists, or where the appearance of conflict would reasonably impair public confidence in the investigation, the investigator shall recuse. Recusal is not a disciplinary event; failure to recuse may be.

8.3 Ongoing Duty

The disclosure duty is continuing. Investigators shall promptly report conflicts that arise during the course of an investigation.

9. Fidelity to the Legal Framework

9.1 Governing Sources

Investigators uphold the human rights treaty framework applicable to the conduct under investigation, the constitutional and statutory framework of the jurisdiction in which the conduct occurred, the jus cogens of customary international law, and the analytical frameworks adopted by the IAJ.

The IAJ's primary mandate addresses conduct within the United States. Investigations of conduct in other jurisdictions are conducted only on specific authorization by the IAJ Director and with appropriate jurisdictional expertise.

9.2 Lawful Methods

Fact-finding shall be conducted by lawful means. Investigators shall not impersonate officials, obtain materials by deception in violation of applicable law, gather facial images of subjects of investigation, or otherwise employ methods inconsistent with this Code or applicable law.

The contemporaneous recording of a consenting complainant under §4.5 is not the gathering of facial images of a subject of investigation prohibited by this section. The prohibition addresses non-consensual capture of images of accused officials and other subjects; it does not restrict consented documentation of the complainant's own statements.

9.3 Public Interest

Investigators act in the public interest. They do not frivolously or carelessly take action that could compromise complainants, the institution, or the public.

10. Prohibited Conduct

Investigators shall not:

• Pursue frivolous, vexatious, or bad-faith inquiries;
• Harass, intimidate, or retaliate against any complainant, witness, or subject of investigation;
• Solicit or accept any payment, gift, or benefit from a complainant, subject, or interested third party in connection with an investigation;
• Disclose confidential case material to unauthorized persons, including journalists, social media audiences, family members, or other litigants;
• Make public statements in their personal capacity that purport to represent IAJ findings without authorization;
• Use IAJ credentials, letterhead, or case access for any personal, commercial, or political purpose;
• Engage in conduct that, in the reasonable judgment of the IAJ Director, materially impairs public confidence in the integrity of an IAJ investigation.

11. Compassion and Dignity

11.1 Treatment of Complainants

Investigators treat every complainant as a bearer of inherent dignity and equal rights under the Universal Declaration of Human Rights. Interviews are conducted on a trauma-informed basis; complainants are informed of their rights and of the voluntary nature of their participation.

11.2 Treatment of Subjects

Investigators treat subjects of investigation with the same dignity. Rigorous documentation of alleged wrongdoing is consistent with — and does not authorize the abandonment of — respect for the personhood of the subject.

11.3 Minor Children

Where a minor child's experience is itself a subject of an investigation, or where the interests of a minor child may diverge from those of a parent complainant, investigators shall:

• Document any apparent divergence of interests between the parent complainant and the child;
• Refrain from characterizing the child's experience without competent input — obtained from a pediatric forensic clinician, the child's independent counsel or guardian ad litem where one is appointed, or the child directly where developmentally appropriate and lawful;
• Refer for pediatric forensic evaluation where the child's experience is itself a subject of the investigation and the question requires clinical competence the investigator does not possess;
• Respect the child's separate consent and information rights, to the extent consistent with applicable law and the child's developmental capacity;
• Apply the interpretive standards of the Convention on the Rights of the Child as relevant to the analysis of harm to children, notwithstanding that the United States has not ratified the CRC.

The Level 1 Investigator Operating Manual implements this section at the Level 1 tier.

12. Reporting Violations

12.1 Duty to Report

An investigator who becomes aware of a violation of this Code by another investigator, staff member, or affiliate shall report the matter in writing to the IAJ Director, or, where the Director is implicated, to such alternative reviewer as the IAJ may designate.

12.2 No Retaliation

Good-faith reports under §12.1 shall not subject the reporting investigator to retaliation. Retaliation against a reporting investigator is itself a violation of this Code.

13. Review, Discipline, and Consequences

13.1 Inquiry

The IAJ may inquire into any alleged violation of this Code. The investigator who is the subject of the inquiry shall be given notice of the substance of the allegation and a reasonable opportunity to respond in writing.

13.2 Consequences

Depending on the nature and severity of the violation, consequences may include written counseling, suspension from active assignment, recusal from a specific matter, and withdrawal of designation as an IAJ investigator. Where the investigator holds professional licensure (medical, psychological, legal, or other licensure under whose authority the investigator performed work for the IAJ), the IAJ may additionally notify the relevant licensing body. Withdrawal of designation applies to all investigators regardless of licensure; licensing-body notification is available only against investigators who hold the relevant licensure.

13.3 Record Preservation

Where a violation is found, the IAJ shall consider whether any investigative work product produced under conditions of violation must be reviewed, supplemented, or withdrawn from publication.

14. Disclaimer of Authority and Evidentiary Status

The IAJ is an independent NGO organized under Paris Principles standards. It possesses no state-conferred legal authority, enforcement power, or jurisdictional control over any court, agency, or public official. Its work is investigative, educational, and advisory in nature. Findings are non-binding. Investigators shall not represent otherwise to any complainant, court, or third party.

Intake organization and routing classifications produced by Level 1 investigators — including Issue Map flags, corroboration strength ratings, contradiction classifications, missing-evidence priorities, and witness-register notes — are not findings of the IAJ and are not evidence on the merits of any case. The underlying documents, verbatim statements, contemporaneous observations, and recordings preserved by Level 1 may have evidentiary value if reviewed and relied upon at Level 2 or above, subject to the rules applicable to the forum. Investigators at every level shall describe their work product accurately and shall not misrepresent intake materials as findings.

15. Acknowledgment

Every investigator, upon designation by the IAJ, shall acknowledge in writing that they have read, understood, and agree to be bound by this Code of Ethics. Continued designation is conditioned on continued adherence.

The acknowledgment under this section is a condition precedent to beginning any investigative, evaluative, or documentary work for the IAJ at any tier. The conflict-disclosure under §8.1 accompanies the acknowledgment and is repeated upon each new case assignment.

Assignment of an investigator to a case shall not proceed until the most recent version of this Code has been acknowledged of record and the assignment-time conflict disclosure under §8.1 has been recorded. The IAJ's case-management systems shall enforce this gate at the point of assignment; an assignment recorded without acknowledgment is irregular and shall be corrected before substantive work continues.

16. Amendment

The IAJ may amend this Code from time to time. Material amendments shall be communicated to designated investigators, who shall acknowledge the amended Code in the same manner as the original.

Pending acknowledgment of a material amendment, an investigator may continue work on existing assignments under the version of the Code then in effect at the time of original acknowledgment. Acknowledgment of the amended Code is required before accepting any new assignment.