Clause 4 makes it clear that the adjudicator can conduct an investigation
“if the Adjudicator has reasonable grounds to suspect that…the retailer has broken the Code”.
Obviously that could result from a specific complaint made by a supplier, but the adjudicator might become aware of the existence of reasonable grounds through, for instance, press articles or investigatory television programmes. Proactive investigations will indeed be possible as long as such grounds exist.