This procedure is to identify the methods for ensuring GSCS Board, management, staffs, inspector/auditor and contractors are impartial and remain so during all dealings with any clients, potential clients and at all times during the certification and evaluation process. All staff and inspectors working for and on behalf of the company have signed a code of conduct and confidentiality agreement as well as declared all interest within and outside of the company.
This procedure relates to all Board and Committee members, all management and staff, including contractors of GSCS. This procedure relates to these members whilst directly working for GSCS and during any dealings with actual or potential clients during and at all times outside business hours.
2. Process of Action
GSCS Managing Director, COO and staffs are fully committed to ensuring that all operations and activities are impartial.
Any relationships between individuals employed by or contracted to GSCS with other organisations or individuals will be declared, reviewed, documented and risk assessed.
GSCS does not allow commercial, financial or other pressures to compromise the impartiality of its personnel and its responsibility for the impartiality of its certification activities.
GSCS does conduct training courses, however, all are public based and no training is offered or delivered to any individual GSCS client or any potential clients.
GSCS shall identify risks to its impartiality on an ongoing basis. This includes those risks that arise from its activities, from its relationships, or from the relationships of its personnel. However, such relationships may not necessarily present a risk to impartiality.
All declaration records shall be maintained. Failure to disclose data as required above shall disqualify Members from the Impartiality Committee.
GSCS have a process to identify, analyse, evaluate, treat, monitor, and document the risks related conflict of interest arising from provision of certification including any conflict arising from its relationships on an ongoing basis. Where threats to impartiality are identified, GSCS documents and demonstrates how the threat can be eliminated or minimized, documenting any residual risk.
This demonstration shall cover all potential threats that are identified, whether they arise from within or from the activities of other persons, bodies or organisations.
GSCS and any part of the same legal entities under its organizational control and shall not compromise with the impartiality.
GSCS shall not:
GSCS shall not be the designer, manufacturer, installer, distributor or maintainer of the certified product, processes and services.
GSCS do not offer or conduct any consultancy services or internal auditing for any of the standards where accreditation verification and certification or offered or conducted.
GSCS shall not provide or offer consultancy or internal auditing to its clients where the certification scheme requires the evaluation of the client’s management system or services.
GSCS shall not use personnel to review or make a certification decision for a product for which they have provided consultancy. Also shall not provide top management commitment to break impartiality in the management of certification activities.
GSCS shall identify and analyse (risk assessed) all relationships (formal or informal) with other organisations or individuals which may result in a conflict of interest arising from its certification activities.
2.1 Auditor/Decision Maker/File Reviewer/Scheme Manager Impartiality
Any conflict of interest arising from existing or past relationships between employees or contractors and GSCS clients (including potential clients), is required to be declared. All staffs and contractors are made aware of the need to declare any such conflict of interest and sign to acknowledge the obligation PCWI09-Auditor Agreement. Periodically the IC will review the activities of the company to ensure that impartiality continues to be demonstrated.
Conflicts of interest could refer to past, present or future involvement and/ or relationships and include:
- Who are their relatives or personal friends
- Who are or have been their employees or employers, or for whom they have worked during the previous three years, or still work as external consultants
- Who are or have been during the previous three years their business partners or competitors in any field not directly related to audit / certification issues.
- With whom they have or have had during the previous three years any kind of personal or business conflict, not directly related to audit/certification issues.
- Against or in favour of whom they are or have been advocating or campaigning. This includes not only individual companies, but also entire industries, projects, etc.
- An auditor must not perform audit in the same operation for more than three consecutive years, without external supervision or an independent audit performed by another auditor to the same operator in the meantime.
- In case that GSCS representatives who neither participate in audit nor in certification decisions are involved in production, consultancy, or trade in the same branch for which certification services are offered, then:
- GSCS will communicate the potential conflict of interest openly to clients
- Any confidential information related to clients (e.g. management plans, audit reports, documents required for transaction certificates, etc.) will be handled directly between the auditor and the GSCS office, without involving the respective representative.
Where the conflict of interest is not clear it is still a requirement of the individual to declare that interest, however, the COO will establish the nature of that possible conflict of interest and decides based upon the individual circumstance and will refer the matter to the IC if required
2.2 Certification Decision Making Impartiality
Certification decisions are made and signed by competent personnel who were not responsible for the audit and were not a member of the audit team.
The IC, COO, and Scheme Managers/File reviewer of Certifications will ensure that all staff, contractors and committees act impartially and shall not allow commercial, financial or other pressures to compromise impartiality. Appropriate action will be taken by the IC or COO, where any such pressures are identified.
GSCS internal audits on the contract review procedure there will be a check on who conducted contract review, made the certification decision. All internal audit reports shall be reviewed at the management review and impartiality committee meetings. The report shall also be run at all impartiality committee meetings for the time span after the last meeting.
3. Prevent Corruption
GSCS auditor may not accept:
- Direct payment of inspection and certification services, in cash or to their private bank account
- Any gifts with a value
- Invitations to inappropriately luxurious hotels, restaurants, etc.
- Invitations to locations or events which might compromise the inspector’s and/or certification body’s reputation.
5. Avoiding “Company Blindness”
GSCS Auditor and stafs are encouraged to exchange information, criteria, and experiences regularly with colleagues from other certification bodies, both at a day-to-day basis, and at a formalized level. This will help to challenge company-specific points of view, and make criteria and decisions more objective.
Auditors and other staff are encouraged to inform the GSCS general management immediately of any cases of intimidation by clients. The client may be sanctioned in such cases to the point of revocation of certificates or reports.
In respect of any claim, loss, damage or expense however arising, GSCS ‘s liability to the client shall in no circumstances exceed the amount of GSCS ’s fees paid by the client. Under no circumstance shall GSCS be liable for any consequential loss.
7. Annual Renewal of Conflict of Interest Statement
Any person involved in application review, audit, certification or evaluation must submit to GSCS a signed “conflict of interest” statement where the companies with whom a conflict of interest might exist are listed.
8. Intellectual Property
Auditors, Inspectors or other staff, who have been proven to
- Accept corrupting gifts
- Suppress consciously significant non-complient or otherwise alter important data in their inspection reports
- Help operators to hide significant non-complient
- Consciously not inform GSCS about an excluding relationship with a client, will be dismissed immediately