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OP009
OP009 IMPARTIALITY, INTEGRITY & CONFIDENTIALITY
Prepared By: IQ Ltd
Authorised By: K Mcgarry Page 1 of 6
Document ID: OP009
Date: Revision: 13.06.17 005 Uncontrolled When Printed
AMENDMENT HISTORY
Date
Amendment
New Issue
Reason
Auth. By
14.02.2017
001
First issue
L Lavery
17.02.2017
002
Review by RC
L Lavery
29.03.2017
003
Review by RC
L Lavery
15.05.2017
Amendments history added and changed Parr FM to Parr Facilities Management Ltd
004
UKAS Audit Finding
L Lavery
13.06.2018
review
005
Annual review
Kmcgarry
Prepared By: IQ Ltd
Authorised By: K Mcgarry Page 2 of 6
Document ID: OP009
Date: Revision: 13.06.17 005 Uncontrolled When Printed
1.0
SCOPE 1.1
2.0
This procedure applies to all persons within Parr Facilities Management Ltd involved in the delivery of Inspection activities under the scope of accreditation. Parr Facilities Management Ltd is completely committed to delivering impartial inspection services to all of its customers.
PURPOSE 2.1
While the organisational structure of Parr Facilities Management Ltd assures independence of inspection decision making, the procedures of Parr Facilities Management Ltd seek to confirm how the primary requirements of impartiality are fulfilled. To give confidence to all parties involved that impartiality can be achieved whilst carrying out inspections & tests. This procedure considers the possible threats and safeguards against those threats to independence and impartiality of decision making within Parr Facilities Management Ltd.
2.2 2.3
3.0
RESPONSIBILITIES 3.1 3.2
4.0
Identification of impartiality risks is the responsibility of all employees. Decision making on the level of risk presented by impartiality and the remedial actions required is the responsibility of the management team including the Directors, Quality Manager, Technical Manager and Technical Supervisors
THREATS TO IMPARTIALITY 4.1
Threats to impartiality are sources of potential bias that may compromise, or may reasonably be expected to compromise the ability to make unbiased observations or draw impartial conclusions associated with inspection outcomes. Parr Facilities Management Ltd has identified the type of threats applicable to its inspection activities below. Although the list is not exhaustive, it illustrates the wide variety of types of threat that Parr Facilities Management Ltd will consider when analysing independence and impartiality issues:
self-interest threats: threats that arise from Inspectors acting in their own interest; self-review threats; threats that arise from reviewing the work done by themselves or by their colleagues; familiarity (or trust) threats: threats that arise from being influenced by a close relationship with a person; intimidation threats: threats that arise from being, or believing that they are being, openly or secretly coerced by other interested parties; advocacy threats; e.g. a body or its personnel acting in support of, or in opposition to, a given organisation which is at the same time its customer, in the resolution of a dispute or litigation; competition threats; Parr Facilities Management Ltd and/or the Inspector may be concerned about risking the Inspection & Testing contract. ownership, governance, management: e.g. directors or managers responsible for financially conflicting areas of the business e.g maintenance work being generated by deliberate failure of sound installations during inspection to feed maintenance work; shared resources; threats that arise from electricians conducting maintenance and repairs on behalf of Parr Facilities Management Ltd but also required to act as inspectors on behalf of the Inspection Body finances: e.g. remuneration of employees should not being linked to the volume or outcome of inspections performed contracts: e.g. contracts which require Parr Facilities Management Ltd to carry out conflicting activities such as maintenance and inspection for the same client
Prepared By: IQ Ltd
Authorised By: K Mcgarry Page 3 of 6
Document ID: OP009
Date: Revision: 13.06.17 005 Uncontrolled When Printed
5.0
SAFE GUARDS TO IMPARTIALITY 5.1
Parr Facilities Management Ltd has in place safeguards that, where possible, eliminate threats to impartiality. Where this is not possible, mitigation to limit the risk are put in place. These include:
6.0
marketing (including branding) e.g. conflicting representation of the IB and/or its accreditation within other areas of the group; payment of a sales commission or inducement for the referral of new clients to the IB or other areas of the business.
company policies linked to employment terms and conditions; operational procedures defining how all inspection activities will be controlled to meet the requirements of the QMS and technical Standards; contractual arrangements with key employees and customers defining, inter alia, roles and responsibilities; training, monitoring and technical rigour during inspection activities; the value Parr Facilities Management Ltd and an individual employee place on their reputations; external assessment by UKAS for Accreditation purposes and external assessment by Certification Bodies for ISO9001 Certification of the management system to assess organisationwide compliance with standards and regulatory requirements regarding impartiality; oversight by Parr Facilities Management Ltd governance structures (for example, boards of directors) concerning compliance with impartiality criteria; other aspects of corporate governance, including the Parr Facilities Management Ltd culture that supports the accreditation and certification processes and impartiality from the top down; rules, standards, and codes of professional conduct governing behaviour; the raising of sanctions, and the possibility of such actions, by UKAS; and the legal liability faced by Parr Facilities Management Ltd should it become evident that impartiality has been compromised maintaining a culture that stresses the expectation that staff will act in the wider interest and the importance of impartiality; other policies, procedures, and practices, such as those concerning the rotation of staff, internal audit, and requirements for internal consultation on technical issues; personnel hiring, training, promotion, retention, and reward policies, procedures, and practices that emphasise the importance of impartiality; prohibitions against certain employment relationships between family members and Parr Facilities Management Ltd.
ASSESSING THE LEVEL OF IMPARTIALITY RISK (RISK ASSESSMENT) 6.1
Parr Group assesses the level of impartiality risk by considering the types and significance of threats to the impartiality of inspection delivery and the types and effectiveness of safeguards. The risk assessment process identifies and assesses the level of impartiality risk that arises from various activities, relationships, or other circumstances.
6.2
The level of impartiality risk can be expressed as a point on a continuum that ranges from ‘no risk’ to ‘maximum risk’ as follows: No Risk (1-5)
Prepared By: IQ Ltd
Remote Risk (6-10)
Authorised By: K Mcgarry Page 4 of 6
Some Risk (11-15)
Document ID: OP009
High Risk (16-20)
Maximum Risk (21-25)
Date: Revision: 13.06.17 005 Uncontrolled When Printed
Compromised objectivity is virtually impossible 6.3
7.0
8.0
Compromised objectivity is possible
Compromised objectivity is probable
Compromised objectivity is virtually certain
Impartiality risk can be given a nominal numerical risk value by use of a 5x5 risk matrix (similar to health and safety risks), the level of risk for any specific activity can be placed on the impartiality risk continuum by use of the above scoring system. E.g.. likelihood of bonus payments for inspectors risk score of (1) against the high hazard of bonus payments to inspectors for inspection volume score of (5) gives an overall impartiality risk score of (5) or ‘No Risk’.
DETERMINING THE ACCEPTABILITY OF THE LEVEL OF IMPARTIALITY RISK 7.1
The manager who has been made aware of the risk and/or identified the risk, shall evaluate the level of risk and identify its position on the impartiality continuum. Safeguards shall then be tested against the impartiality risk. Evaluation requires the manager to judge whether safeguards eliminate, or adequately mitigate, threats to inspection activities impartiality. If they do not, the manager must decide which additional safeguards, (including prohibition) or combination of safeguards would reduce the risk, and the corresponding likelihood of compromised objectivity, to an acceptably low level. Those safeguards must then be implemented and checked for effectiveness.
7.2
Parr Facilities Management Ltd considers ‘No Risk’ or ‘Remote Risk’ to be acceptable. Only such a small likelihood of compromised objectivity is consistent with both the definition and the goal of inspection impartiality.
7.3
During on-site witnessing of inspectors or technical supervisors, on-going threats to impartiality will be dynamically risk assessed and recorded on the F008 – “Witness form”.
7.4
Operational risks shall be risk assessed and the outcomes of those risk assessments and safeguards recorded in a risk matrix.
INDEPENDENCE 8.1
9.0
Compromised objectivity is very unlikely
Independence (and impartiality) of inspection activities needs to be further protected by placing it within an organisational structure, which will guarantee that the safeguards required are implemented. The organisational structure is such that Parr Facilities Management Ltd can demonstrate its impartiality and independence by separation of Inspection from potentially conflicting maintenance and repair activities. This is further defined in the ISO17020 Quality Manual.
CONFIDENTIALITY 9.1
"Confidential Information" means all records, reports, data and other information and know-how belonging to a party which are disclosed to another party as a result of a contract other than that which is already in its possession or the public domain.
9.2
"Intellectual Property Rights" means all copyright and related rights, patents, right to inventions, utility models, design rights, registered design, database right, topography rights, moral rights, rights in confidential information (including know-how and trade secrets) trade-marks, service marks, trade, business and domain names, rights in trade dress or get-up, rights in goodwill or to sue for passing off, or other proprietary rights of a similar or equivalent nature whether registered
Prepared By: IQ Ltd
Authorised By: K Mcgarry Page 5 of 6
Document ID: OP009
Date: Revision: 13.06.17 005 Uncontrolled When Printed
or unregistered and including all applications for and renewals or extensions of such rights, arising in the United Kingdom or anywhere in the world. 9.3
Parr Facilities Management Ltd shall not use any confidential Information or intellectual property for any purpose other than in connection with the performance of the contract or case, or disclose any confidential information without the prior written consent of the customer to any person other than to employees, agents or contractors to whom disclosure is necessary to enable performance of the contract. This shall continue after termination or expiry of the contract.
9.4
All employees and contracted staff are subject to strict confidentiality clauses included within their Contracts of Employment or terms of engagement.
9.5
The Company’s Policy on Confidentiality is included in the document GEN007- “Parr FM Inspection Contract” available and attached to all orders for services. END OF DOCUMENT
Prepared By: IQ Ltd
Authorised By: K Mcgarry Page 6 of 6
Document ID: OP009
Date: Revision: 13.06.17 005 Uncontrolled When Printed
OP009 IMPARTIALITY, INTEGRITY & CONFIDENTIALITY
Prepared By: IQ Ltd
Authorised By: K Mcgarry Page 1 of 6
Document ID: OP009
Date: Revision: 13.06.17 005 Uncontrolled When Printed
AMENDMENT HISTORY
Date
Amendment
New Issue
Reason
Auth. By
14.02.2017
001
First issue
L Lavery
17.02.2017
002
Review by RC
L Lavery
29.03.2017
003
Review by RC
L Lavery
15.05.2017
Amendments history added and changed Parr FM to Parr Facilities Management Ltd
004
UKAS Audit Finding
L Lavery
13.06.2018
review
005
Annual review
Kmcgarry
Prepared By: IQ Ltd
Authorised By: K Mcgarry Page 2 of 6
Document ID: OP009
Date: Revision: 13.06.17 005 Uncontrolled When Printed
1.0
SCOPE 1.1
2.0
This procedure applies to all persons within Parr Facilities Management Ltd involved in the delivery of Inspection activities under the scope of accreditation. Parr Facilities Management Ltd is completely committed to delivering impartial inspection services to all of its customers.
PURPOSE 2.1
While the organisational structure of Parr Facilities Management Ltd assures independence of inspection decision making, the procedures of Parr Facilities Management Ltd seek to confirm how the primary requirements of impartiality are fulfilled. To give confidence to all parties involved that impartiality can be achieved whilst carrying out inspections & tests. This procedure considers the possible threats and safeguards against those threats to independence and impartiality of decision making within Parr Facilities Management Ltd.
2.2 2.3
3.0
RESPONSIBILITIES 3.1 3.2
4.0
Identification of impartiality risks is the responsibility of all employees. Decision making on the level of risk presented by impartiality and the remedial actions required is the responsibility of the management team including the Directors, Quality Manager, Technical Manager and Technical Supervisors
THREATS TO IMPARTIALITY 4.1
Threats to impartiality are sources of potential bias that may compromise, or may reasonably be expected to compromise the ability to make unbiased observations or draw impartial conclusions associated with inspection outcomes. Parr Facilities Management Ltd has identified the type of threats applicable to its inspection activities below. Although the list is not exhaustive, it illustrates the wide variety of types of threat that Parr Facilities Management Ltd will consider when analysing independence and impartiality issues:
self-interest threats: threats that arise from Inspectors acting in their own interest; self-review threats; threats that arise from reviewing the work done by themselves or by their colleagues; familiarity (or trust) threats: threats that arise from being influenced by a close relationship with a person; intimidation threats: threats that arise from being, or believing that they are being, openly or secretly coerced by other interested parties; advocacy threats; e.g. a body or its personnel acting in support of, or in opposition to, a given organisation which is at the same time its customer, in the resolution of a dispute or litigation; competition threats; Parr Facilities Management Ltd and/or the Inspector may be concerned about risking the Inspection & Testing contract. ownership, governance, management: e.g. directors or managers responsible for financially conflicting areas of the business e.g maintenance work being generated by deliberate failure of sound installations during inspection to feed maintenance work; shared resources; threats that arise from electricians conducting maintenance and repairs on behalf of Parr Facilities Management Ltd but also required to act as inspectors on behalf of the Inspection Body finances: e.g. remuneration of employees should not being linked to the volume or outcome of inspections performed contracts: e.g. contracts which require Parr Facilities Management Ltd to carry out conflicting activities such as maintenance and inspection for the same client
Prepared By: IQ Ltd
Authorised By: K Mcgarry Page 3 of 6
Document ID: OP009
Date: Revision: 13.06.17 005 Uncontrolled When Printed
5.0
SAFE GUARDS TO IMPARTIALITY 5.1
Parr Facilities Management Ltd has in place safeguards that, where possible, eliminate threats to impartiality. Where this is not possible, mitigation to limit the risk are put in place. These include:
6.0
marketing (including branding) e.g. conflicting representation of the IB and/or its accreditation within other areas of the group; payment of a sales commission or inducement for the referral of new clients to the IB or other areas of the business.
company policies linked to employment terms and conditions; operational procedures defining how all inspection activities will be controlled to meet the requirements of the QMS and technical Standards; contractual arrangements with key employees and customers defining, inter alia, roles and responsibilities; training, monitoring and technical rigour during inspection activities; the value Parr Facilities Management Ltd and an individual employee place on their reputations; external assessment by UKAS for Accreditation purposes and external assessment by Certification Bodies for ISO9001 Certification of the management system to assess organisationwide compliance with standards and regulatory requirements regarding impartiality; oversight by Parr Facilities Management Ltd governance structures (for example, boards of directors) concerning compliance with impartiality criteria; other aspects of corporate governance, including the Parr Facilities Management Ltd culture that supports the accreditation and certification processes and impartiality from the top down; rules, standards, and codes of professional conduct governing behaviour; the raising of sanctions, and the possibility of such actions, by UKAS; and the legal liability faced by Parr Facilities Management Ltd should it become evident that impartiality has been compromised maintaining a culture that stresses the expectation that staff will act in the wider interest and the importance of impartiality; other policies, procedures, and practices, such as those concerning the rotation of staff, internal audit, and requirements for internal consultation on technical issues; personnel hiring, training, promotion, retention, and reward policies, procedures, and practices that emphasise the importance of impartiality; prohibitions against certain employment relationships between family members and Parr Facilities Management Ltd.
ASSESSING THE LEVEL OF IMPARTIALITY RISK (RISK ASSESSMENT) 6.1
Parr Group assesses the level of impartiality risk by considering the types and significance of threats to the impartiality of inspection delivery and the types and effectiveness of safeguards. The risk assessment process identifies and assesses the level of impartiality risk that arises from various activities, relationships, or other circumstances.
6.2
The level of impartiality risk can be expressed as a point on a continuum that ranges from ‘no risk’ to ‘maximum risk’ as follows: No Risk (1-5)
Prepared By: IQ Ltd
Remote Risk (6-10)
Authorised By: K Mcgarry Page 4 of 6
Some Risk (11-15)
Document ID: OP009
High Risk (16-20)
Maximum Risk (21-25)
Date: Revision: 13.06.17 005 Uncontrolled When Printed
Compromised objectivity is virtually impossible 6.3
7.0
8.0
Compromised objectivity is possible
Compromised objectivity is probable
Compromised objectivity is virtually certain
Impartiality risk can be given a nominal numerical risk value by use of a 5x5 risk matrix (similar to health and safety risks), the level of risk for any specific activity can be placed on the impartiality risk continuum by use of the above scoring system. E.g.. likelihood of bonus payments for inspectors risk score of (1) against the high hazard of bonus payments to inspectors for inspection volume score of (5) gives an overall impartiality risk score of (5) or ‘No Risk’.
DETERMINING THE ACCEPTABILITY OF THE LEVEL OF IMPARTIALITY RISK 7.1
The manager who has been made aware of the risk and/or identified the risk, shall evaluate the level of risk and identify its position on the impartiality continuum. Safeguards shall then be tested against the impartiality risk. Evaluation requires the manager to judge whether safeguards eliminate, or adequately mitigate, threats to inspection activities impartiality. If they do not, the manager must decide which additional safeguards, (including prohibition) or combination of safeguards would reduce the risk, and the corresponding likelihood of compromised objectivity, to an acceptably low level. Those safeguards must then be implemented and checked for effectiveness.
7.2
Parr Facilities Management Ltd considers ‘No Risk’ or ‘Remote Risk’ to be acceptable. Only such a small likelihood of compromised objectivity is consistent with both the definition and the goal of inspection impartiality.
7.3
During on-site witnessing of inspectors or technical supervisors, on-going threats to impartiality will be dynamically risk assessed and recorded on the F008 – “Witness form”.
7.4
Operational risks shall be risk assessed and the outcomes of those risk assessments and safeguards recorded in a risk matrix.
INDEPENDENCE 8.1
9.0
Compromised objectivity is very unlikely
Independence (and impartiality) of inspection activities needs to be further protected by placing it within an organisational structure, which will guarantee that the safeguards required are implemented. The organisational structure is such that Parr Facilities Management Ltd can demonstrate its impartiality and independence by separation of Inspection from potentially conflicting maintenance and repair activities. This is further defined in the ISO17020 Quality Manual.
CONFIDENTIALITY 9.1
"Confidential Information" means all records, reports, data and other information and know-how belonging to a party which are disclosed to another party as a result of a contract other than that which is already in its possession or the public domain.
9.2
"Intellectual Property Rights" means all copyright and related rights, patents, right to inventions, utility models, design rights, registered design, database right, topography rights, moral rights, rights in confidential information (including know-how and trade secrets) trade-marks, service marks, trade, business and domain names, rights in trade dress or get-up, rights in goodwill or to sue for passing off, or other proprietary rights of a similar or equivalent nature whether registered
Prepared By: IQ Ltd
Authorised By: K Mcgarry Page 5 of 6
Document ID: OP009
Date: Revision: 13.06.17 005 Uncontrolled When Printed
or unregistered and including all applications for and renewals or extensions of such rights, arising in the United Kingdom or anywhere in the world. 9.3
Parr Facilities Management Ltd shall not use any confidential Information or intellectual property for any purpose other than in connection with the performance of the contract or case, or disclose any confidential information without the prior written consent of the customer to any person other than to employees, agents or contractors to whom disclosure is necessary to enable performance of the contract. This shall continue after termination or expiry of the contract.
9.4
All employees and contracted staff are subject to strict confidentiality clauses included within their Contracts of Employment or terms of engagement.
9.5
The Company’s Policy on Confidentiality is included in the document GEN007- “Parr FM Inspection Contract” available and attached to all orders for services. END OF DOCUMENT
Prepared By: IQ Ltd
Authorised By: K Mcgarry Page 6 of 6
Document ID: OP009
Date: Revision: 13.06.17 005 Uncontrolled When Printed
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