Audit Methodology and Recusal Policy
This page documents how the Komodo Guide Certified Operator (KGCO) program conducts its assessments, who sits on assessment panels, how conflicts of interest are managed through a formal recusal policy, how certifications are renewed, and how they can be revoked. Transparency about process is as important as transparency about criteria: readers and operators alike are entitled to know not only what is assessed but how.
Audit Process
KGCO assessments occur under three distinct circumstances: the initial document audit upon application, the biennial renewal audit, and a complaint-triggered supplementary audit. Each type follows the same evidentiary standard but differs in scope and timing.
Initial Document Audit
Triggered when an operator submits a complete application. The assessment panel reviews all documents submitted against the criteria published on the Criteria page. The panel may request clarification or supplementary documents within 10 business days of receipt; the operator has 20 business days to respond before the application is considered incomplete and must be resubmitted.
Timeline: 4–6 weeks from receipt of a complete submission to certification decision.
Biennial Site Audit
All certified operators are subject to a site-visit audit at least once every two years, timed to coincide with the renewal cycle. The site audit is conducted by at minimum one panel member who is independent of komodoguide.org (see Panel Composition below). Site visits may be conducted in conjunction with a vessel inspection at Labuan Bajo or at the operator's registered office. The scope of the site audit is verification of the documents already submitted: confirming that originals match copies, that vessels listed exist and are in service, and that crew qualifications can be physically verified.
Notice: Operators receive 30 days' advance notice of a scheduled site audit. Site visits are conducted by appointment to minimise operational disruption.
Complaint-Triggered Supplementary Audit
If a credible complaint is received from a passenger, crew member, BTNK, or any other party alleging non-compliance with a certified criterion, the KGCO program initiates a supplementary audit. A complaint is treated as credible if it specifies a particular criterion, identifies a specific vessel or incident, and is submitted with at least one piece of supporting evidence (for example, a photograph, a booking confirmation, or a correspondence record).
On receipt of a credible complaint, the operator is notified within 5 business days and given 20 business days to respond with evidence of compliance. If the response is unsatisfactory or absent, the panel proceeds to a full supplementary document audit, which may include a site visit. The outcome — whether a finding of compliance, a corrective action plan, or revocation — is published on the Disclosures page.
Complaint channel: [email protected] with subject line "KGCO Complaint". Anonymous complaints are accepted but reduce the investigable scope.
Reviewer Panel Composition
Every KGCO assessment is conducted by a panel of at least two reviewers. The panel must include at least one independent reviewer — an individual who has no commercial, employment, or equity relationship with komodoguide.org or with PT. Komodo Explorer Indonesia (the operating entity of komodoguide.org). The criteria for independence are:
- ◆No current or former employment or contractor relationship with komodoguide.org, PT. Komodo Explorer Indonesia, or any of the three sister-brand operators (komodoexplorer.com, tripkomodotour.com, boatkomodotrip.com) within the preceding 36 months.
- ◆No equity interest, directorship, or advisory role in any of the above entities.
- ◆No material financial relationship (for example, as a supplier or creditor) with the operator under assessment.
- ◆No immediate family member in any of the above categories.
In addition to the independent reviewer, the panel includes one editorial staff member of komodoguide.org who oversees document management and applies the published criteria. For assessments involving affiliated operators (see Recusal Policy), this editorial staff role is also filled by an independent reviewer, so that no komodoguide.org staff member participates in the scoring of any criterion.
The composition of the panel for each assessment — including the independent reviewer's name or institutional affiliation — is recorded on the Disclosures page at the time of publication of the certification outcome.
Renewal Cycle
KGCO certification has a two-year validity period. Operators receive a renewal notice 90 days before their certification expiry date. Renewal requires re-submission of all documents listed in the criteria for the tier held, updated to reflect the current date of renewal. Documents that have not changed (for example, a NIB that remains the same) may be re-submitted as-is with a declaration of unchanged status; documents with expiry dates (for example, insurance policies, STCW certificates) must be replaced with currently valid versions.
An operator that does not submit a renewal application within 30 days of the expiry date has their certification status changed to "Lapsed" on the public directory. A lapsed certification may be reinstated by submitting a full renewal application; the reinstated certification date is the date of the new assessment, not the original certification date.
| Event | Timing relative to expiry |
|---|---|
| Renewal notice issued to operator | 90 days before expiry |
| Renewal submission deadline | 30 days before expiry |
| Certification expiry | Day 0 (2 years from original certification date) |
| Status changed to "Lapsed" if no submission | 30 days after expiry |
| Biennial site audit (combined with renewal where possible) | Within the 2-year certification period |
Recusal Policy
The KGCO recusal policy governs who may participate in the assessment of any given operator's application. Recusal is triggered automatically when a material conflict of interest exists between a panel member candidate and the operator under assessment. The two categories of recusal are described below.
Category A — Full Commercial Recusal (Affiliated Operators)
A full commercial recusal applies when the operator under assessment shares a common operating entity, common ownership, or a controlling interest with the publisher of komodoguide.org. Under full commercial recusal, no member of komodoguide.org's editorial or commercial team may participate in any aspect of the assessment: not document intake, not criterion scoring, not the final certification decision, and not any written public commentary about the operator's compliance status.
The following operators are permanently subject to full commercial recusal:
- komodoexplorer.com — shares operating entity PT. Komodo Explorer Indonesia with komodoguide.org
- tripkomodotour.com — shares operating entity PT. Komodo Explorer Indonesia with komodoguide.org
- boatkomodotrip.com — operates under the komodoexplorer.com entity, which shares operating entity with komodoguide.org
Under full commercial recusal, the entire assessment panel must be composed of independent reviewers meeting the independence criteria set out in the Panel Composition section above. The assessment record, including the names or institutional affiliations of all panel members, is published on the Disclosures page at the time of the certification outcome.
Category B — Individual Panel-Member Recusal
A panel member must individually recuse from a specific assessment if they have a personal conflict of interest with the operator under assessment, even where the operator is not affiliated with komodoguide.org. Grounds for individual recusal include: a pre-existing commercial relationship between the panel member and the operator; a personal relationship that could reasonably be perceived to affect impartiality; or a prior formal dispute with the operator. Any panel member who identifies a potential conflict must notify the program coordinator before the assessment begins. The program coordinator logs the recusal and appoints a replacement panel member.
Revocation Process
Certification may be revoked in two circumstances: (1) the operator fails to maintain compliance with a certified criterion; or (2) a complaint-triggered audit finds that the operator misrepresented its compliance during the original assessment. Revocation is not imposed summarily. The process is as follows:
Notice of concern issued
The operator receives a written Notice of Concern specifying the criterion at issue, the evidence of potential non-compliance, and the operator's right to respond. The notice is issued within 10 business days of the panel reaching a preliminary finding of non-compliance.
Operator response period (20 business days)
The operator has 20 business days from receipt of the Notice of Concern to submit a written response, including any evidence of continued or restored compliance. This period may be extended once by 10 business days on written request.
Panel determination
The panel reviews the operator's response and makes one of three determinations: (a) Compliant — the concern is resolved and no action is taken; (b) Corrective Action Required — the operator is given a defined corrective action period of up to 60 days to remedy the deficiency, after which a follow-up assessment occurs; or (c) Revocation — the evidence of non-compliance is sufficient and the operator's response does not adequately rebut it.
Publication of revocation
If revocation is determined, the operator's status on the public directory is updated to "Revoked" and a brief summary of the grounds — citing the specific criterion and the nature of the non-compliance — is added to the Public Revocation Log on the Disclosures page. The operator's name is not published in a manner designed to cause reputational harm; only the factual criterion and compliance status are recorded.
Re-application following revocation
An operator whose certification is revoked may re-apply no earlier than 12 months after the revocation date, provided they can demonstrate that the condition giving rise to the revocation has been remedied. The re-application is treated as a new initial application and assessed by a fresh panel.
Public Revocation Log
The revocation log below records all KGCO certifications that have been suspended, revoked, or allowed to lapse. It is maintained permanently on this page and is not removed after re-certification.
Revocation Log
No revocations or lapses recorded. Program launched 2026-05-31.
Program Overview
Back to KGCO hub →
Criteria
Full criteria by tier →
Disclosures
Affiliation & audit panels →
Frequently Asked Questions
How is the KGCO audit conducted?
All KGCO assessments are document-based. The assessment panel reviews submitted documents against the published criteria, cross-referencing public registries (OSS.go.id, Ditjen Hubla, MMSI databases) where possible. Three types of audit exist: an initial document audit on application (4–6 weeks), a biennial site audit combined with renewal, and a complaint-triggered supplementary audit when a credible complaint is received alleging non-compliance with a certified criterion.
Who sits on the KGCO assessment panel?
Every assessment panel includes at least two reviewers: one independent reviewer (no commercial, employment, or equity relationship with komodoguide.org or PT. Komodo Explorer Indonesia within the preceding 36 months) and one editorial staff member responsible for document management. For assessments involving affiliated operators, the editorial staff role is also filled by an independent reviewer, so that no komodoguide.org staff member participates in scoring any criterion.
What is the recusal policy for affiliated operators?
A full commercial recusal applies to the three operators affiliated with komodoguide.org: komodoexplorer.com, tripkomodotour.com, and boatkomodotrip.com. Under full commercial recusal, no employee, contractor, or director of komodoguide.org or PT. Komodo Explorer Indonesia may participate in any aspect of the assessment — not document intake, criterion scoring, the certification decision, or any written commentary about the operator's compliance status. The entire panel must be independent reviewers.
How often is certification renewed?
KGCO certification has a two-year validity period. Operators receive a renewal notice 90 days before expiry and must submit a renewal application at least 30 days before expiry. Documents with expiry dates (insurance policies, STCW certificates) must be replaced with current versions. An operator that does not submit within 30 days of expiry has their status changed to "Lapsed" on the public directory. Lapsed certifications may be reinstated with a full new application.
Can an operator appeal or challenge a revocation?
Certification is not revoked without a due process. The operator receives a Notice of Concern and has 20 business days to submit a written response with evidence of compliance (extendable once by 10 days). The panel then determines: Compliant (no action), Corrective Action Required (up to 60 days to remedy), or Revocation. An operator whose certification is revoked may re-apply no earlier than 12 months after the revocation date, provided the non-compliance condition has been remedied.
How can I submit a complaint about a certified operator?
Send an email to [email protected] with subject line "KGCO Complaint — [Operator Name]". A complaint is treated as credible if it specifies a particular criterion, identifies a specific vessel or incident, and includes at least one piece of supporting evidence. Anonymous complaints are accepted but reduce the investigable scope. All complaints are acknowledged within 5 business days, and investigations are completed within 30 business days of receipt of a complete complaint.