IMPARTIALITY MANAGEMENT IMPLEMENTATION

Impartiality Management Implementation

  • UGG shall demonstrate their commitment to managing impartiality by means of the following:
  1. Establishment of IMC in order to provide advice to GM and OM regarding impartiality matters.
    Note: the IMC provides recommendations to UGG Top Management (GM/OM) on matter relating to impartiality. Refer to APP 4 Terms of Reference
  2. All personal involved in the certification process (Auditor, Sub-con Auditor, Peer Reviewer, Technical Reviewer and Impartiality Committee) shall read and sign the Impartiality and Confidentiality Declaration Form (UGG-FM(MSPO)-01A and UGG-FM(MSPO)-01B ) to ensure no conflict of interest by UGG, non-audit staff, as well as audit staff (directly-employed or outsourced). This form shall be signed once in the term of services by all audit personal and non-audit personal who are involving in the certification activities.
  3. The OM shall establish and utilize the Risk Management Plan (UGG-FM(MSPO)-02 as a mechanism to monitor and mitigate threats to impartiality.
 
  • Where there are any threats to impartiality, the OM shall review these threats with the GM. The GM/OM shall implement suitable risk mitigation actions to minimize the impartiality threats to an acceptable level. The GM/OM shall review any residual risk after the risk mitigation actions to ensure that the residual risks are within the level of acceptable risks. Any impartiality threats that are not able to be resolved by the GM and OM shall be brought up to the IMC meeting. The GM shall be responsible for the final decision after reviewing of the recommendations by the IMC.
  • The IMC review result shall be documented in the IMC Meeting Minutes.
  • The impartiality threats shall cover all potential threats that are identified, whether they arise from within UGG or from the activities of other persons, bodies or organizations. These are summarized in the Risk Management Plan (UGG-FM(MSPO)-02).
  • If a relationship poses an unacceptable threat to impartiality (such as a wholly owned subsidiary of the UGG requesting certification from its parent), certification shall not be provided by UGG.
  • Source of impartiality threats for UGG can be based on ownership, governance, management, personnel, shared resources, finances, contracts, training, marketing and payment of a sales commission or other inducement for the referral of new clients, etc.
  • Interested parties can include personnel and clients of UGG, customers of organizations whose management systems are certified, representatives of industry trade associations, representatives of governmental regulatory bodies or other governmental services, or representatives of non-governmental organizations, including consumer organizations.
  • Impartiality Management Committee meetings are conducted at least once a year or whenever there are significant changes to the organization processes.
  • Impartiality Management meetings shall be participated by GM/OM as company representative and IMC members.
  • The IMC shall be responsible to ensure that the UGG personnel involved in resolving the appeals and complaints shall be independent of the personnel involved in conducting the audit.
  • Minutes of the Impartiality Management meetings shall be documented and distributed to all attendees.
  • Minutes of the Impartiality Management meetings shall be maintained by the GM/OM for a retention period as specified in the Master List of Records.
  • General business risks include reviewing the context of the organization, performing strategic management and planning, identifying external and internal stakeholders/interested parties.
  • The risk categories for business risk can include political risk, technological risk, socio-economic risk, and financial risk, among others.
  • The operational risk can include reviewing the quality, process, health, and safety risks related to operational activities.
  1. The GM/OM of UGG shall be responsible to identify general business and operational risks as well as risks to impartiality management.
  • These risks shall be included in a risk register which shall be segregated by risk categories.
  • The risks identified shall be analyzed by using suitable risk analysis methods which can include quantitative and qualitative assessments. This is done to prioritize these risks according to the magnitude/significance of these risks towards UGG’s operations.
  • Risks identified shall have a PIC to ensure effective monitoring and control of identified risks.
  • The risk assessment process shall include identification and consultation with appropriate interested parties to advise on matters affecting impartiality including openness and public perception.