A Board of Directors oversees EFR’s operations. It is supported by a Impartiality Committee, a Finance and Audit Committee and a Excellence Committee.
Board of Directors
The EFR BOARD OF DIRECTORS meets twice a year. Its role is to ensure that EFR’s strategy and its implementation are aligned with the mission of the organization, taking into account the views and expectations of all stakeholder groups. It also strives to maximise the added-value for clients and to secure EFr’s sustainable financial independence. The Board of Directors consists of the Managing Directors or senior executives of EFR members.
Impartiality and Excellence Committee
1.1 This document details the EFRC policy and top management commitment regarding the impartiality.
1.2 Its also describe relationship between certification and consultancy related or lead to certification .
1.2 This policy and procedure shall apply to impartiality committee review on application and annual review
2.1 ISO/IEC 17021
2.2 EFRC Manual
2.3 Rules for achieving IATF recognition
Consultancy is defined as:
Consulting is the provision of training, documentation development, or assistance with implementation of quality management systems to a specific organization.
Examples as follows;
i) preparing or producing manuals or procedures
ii) participating in the operation or management of the system
iii) giving specific advice or specific training towards the development and implementation of the management system and/or competence
iv) giving specific advice or specific training for the development and implementation of the operational procedure
In the context of Section 3.1 above, consultancy services are those related to or lead to obtaining or maintaining certification.
Training open to the public, not organization specific, and held at a public forum is not considered consulting.
Individuals defined in procedure is EFRC auditor or contracted auditor which include the technical expert.
4.1 To ensure that activities of EFRC do not affect the confidentiality, objectivity, or impartiality of its certifications / registrations and shall not offer or provide:
1) those services that it certifies / registers others to perform;
2) consulting services to obtain or maintain certification / registration;
3) services to design, implement or maintain quality or environmental management systems
4) supply or design products of the type it certifies;
5) give advice or provide consultancy services to the applicant as methods of dealing with matters which are barriers to the certification requested;
6) provide any other products or services which could compromise the confidentiality, objectivity or impartiality of its certification process and decisions.
4.2 The EFRC top management commitment to impartiality in management system certification activities. This procedure is accessible statement of EFRC understands the importance of impartiality in carrying out its management system certification activities, manages conflict of interest and ensures the objectivity of its management system certification activities. EFRC, shall not and will not involved in consultancy activities that are related to the certification activities.
4.3 EFR have the corporate structure that provide training arm and a certification body, which is EFR Management (EFRM) for training and EFRC for certification, both EFRM and EFRC are not allowed nothing should be said, or implied, in any marketing material, written or oral.
• to give the impression that the two activities are linked, or
• to imply that an advantage would be gained as a result of the organisation providing both services; or
• to suggest that certification would be simpler, easier or less expensive if any specific consultancy services were used.
4.4 EFRC not permit its name to be linked with any programme or activity in association with a EFRM, or in any marketing material or activity, written or oral:
• that gives the impression that the two activities of consultancy and
certification are linked; or
• that implies that an advantage would be gained in achieving certification
as a result of participating in the programme or activity; or
• to suggest that certification would be simpler, easier or less expensive if
the programme or activity was used.
4.5 EFRC considers that consultancy has been provided if a training course has been conducted, which was designed to go beyond general principles and concepts in order to provide a company through the students attending the course, with company specific solutions, other than of a casual nature, by way of advising in detail on, for example, company structure, quality system structure, product quality plans, policy and/or procedures or work instructions. Inquiries of a casual nature, which elicit quick, off-the-cuff responses, are not considered to be consulting for this purpose. However the risk is minimized if EFRM already provide the services more than 2 years, hence EFRC can provide the certification or auditing services if the consulting have been conducted after 2 years.
4.6 When a relationship poses an unacceptable threat to impartiality (such as a wholly owned subsidiary of the EFRC requesting certification from its parent), then EFRC shall refused to provide the service with clear reason stated in the application review.
4.7 A EFRC shall not certify another EFRC for its management system certification activities.
4.8 The EFRC and any part of the same legal entity shall not offer or provide management system consultancy. This also applies to that part of government identified as the EFRC.
4.9 The EFRC and any part of the same legal entity shall not offer or provide internal audits to its certified clients. The EFRC shall not certify a management system on which it provided internal audits within two years following the end of the internal audits. This also applies to that part of government identified as the EFRC.
4.10 The EFRC shall not outsource audits to a management system consultancy organization, as this poses an unacceptable threat to the impartiality of the EFRC (see 7.5). This does not apply to individuals contracted as auditors covered in 7.3.
4.11 The EFRC’s activities shall not be marketed or offered as linked with the activities of an organization that provides management system consultancy. The EFRC shall take action to correct inappropriate claims by any consultancy organization stating or implying that certification would be simpler, easier, faster or less expensive if the EFRC were used. A EFRC shall not state or imply that certification would be simpler, easier, faster or less expensive if a specified consultancy organization were used.
4.12 To ensure that there is no conflict of interests, individual who have provided management system consultancy, including those acting in a managerial capacity, shall not be used by the EFRC to take part in an audit or other certification activities if they have been involved in management system consultancy towards the client in question within two years following the end of the consultancy.
4.13 All EFRC individual, either internal or external, or committees, who could influence the
certification activities, shall act impartially and shall not allow commercial, financial or other pressures to compromise impartiality.
4.14 Individuals involved in the certification process, including those acting in an audit or review capacity, shall not have been involved in consultancy, with EFRC, or any company related to the body being subjected to the certification process, within the previous two (2) years.
4.15 Individuals involved in the certification process shall not have any existing commercial or other associations with the body being subjected to certification, which may influence, or be seen to influence their judgment during the certification process.
4.16 An individual involved in the certification process should not give consultancy as part of an audit.
4.17 EFRC shall require personnel, internal and external, to reveal any situation known to them that may present them or the EFRC with a conflict of interests. Certification bodies shall use this information as input to identifying threats to impartiality raised by the activities of such personnel or by the organizations that employ them, and shall not use such personnel, internal or external, unless they can demonstrate that there is no conflict of interests.
4.18 EFRC can carry out the following duties without them being considered as consultancy or having a potential conflict of interest:
a) certification including information meetings, planning meetings, examination of documents, auditing and follow up of non-compliances;
b) arrange and participate as a lecturer in training courses. They should confine themselves to the provision of generic information and advice which is freely available in the public domain, i.e. EFRC should not provide company specific advice which contravenes the requirements above
c) make available or publish on request information on the basis for the certification body’s interpretation of the requirements of the assessment standards.
d) activities prior to audit (i.e. pre-audit) aimed solely at determining readiness for assessment. The documented output of such activities should be capable of confirming compliance with this requirement and should be available for review. This activities only allowed once. Pre-audit more than once is consider as consultancy.
e) perform second and third party audits according to other standards or regulations than those being part of the scope of accreditation
f) an auditor may seek to add value during assessments and surveillance visits, e.g., by identifying opportunities for improvement as they become evident, during the audit without recommending specific solutions and but shall clearly state the compliance to requirements of audit criteria.
4.19 The above requirements mean that people who have provided consultancy, including those acting in a managerial capacity, shall not be employed to conduct an audit as part of the certification process if they have been involved in any consultancy activities towards the client in question, (or any client related to that supplier and having a similar system), within the last two years. Situations such as an employer’s involvement or previous involvement with the organisation being assessed may present individuals involved in any part of the certification process with a conflict of interest. The Chairman of Impartiality committee has a responsibility to identify and evaluate such situations and to assign responsibilities and tasks so as to ensure that impartiality is not compromised.
4.20 EFRC require all assessment sub-contractors or external assessors/auditors to give undertakings regarding the marketing of any consultancy services.
4.21 EFRC shall be responsible for ensuring that neither related bodies, nor sub-contractors, nor external assessors / auditors operate in breach of the undertakings that they have given. It shall also be responsible for implementing appropriate corrective action in the event such a breach is identified.
4.22 The certification body shall be independent from the body or bodies (including any individuals) which provide the internal audit of the organisation’s system subject to certification.
4.23 Chairman of impartiality Committee or his/ her designated shall analyse and document the relationship with EFRC or individual to determine the possibilities for conflict of interest with provision of certification and identify those bodies and activities that could, if not subject to appropriate controls, affect confidentiality, objectivity or impartiality through application review
4.24 The Committee shall take action to respond to any threats to its impartiality arising from the
actions of other persons, bodies or organizations, by issuing corrective action request.
4.25 An auditor should explain the audit findings and/or clarify the requirements of the assessment standard during the audit and / or at the closing meeting but shall not give prescriptive advice or consultancy as part of an assessment.
4.26 The committee shall meet at least once a year to review all the matter related to impartiality.