LiberoGroup ltd is the legal entity responsible for certification activities; reference to LiberoGroup in this Policy and Public Statement refers to these legal entities.
LiberoGroup its Directors, Staff and Sub-contractors fully understand the importance of impartiality in undertaking its Certification Activities. LiberoGroup will therefore ensure that in all its dealings with clients or potential clients all employees or other personnel are and will remain impartial. To ensure that impartiality is both maintained and can be demonstrated the following principals have been established.
- LiberoGroup Certificates are only issued following a review by an independent authorised and competent member of the management team (who has not been involved in the audit) to ensure that no interest shall predominate
- LiberoGroup does not offer (and has never offered) any form of Management System consultancy to companies or individuals.
- LiberoGroup does not offer (and has never offered) an internal audit service to its certified clients.
- LiberoGroup does not own or have any interest (financial or otherwise) in any other company that offers certification or management system consulting services.
- LiberoGroup does not have (and will not form) any relationships with companies who offer consultancy or other services that can be construed as having an impact on the certification services provided by LiberoGroup. Any proposed relationship between LiberoGroup and any other company will undergo a risk assessment by the Committee for Impartiality prior to that relationship being formalised. Any current relationships with companies, organisations and individuals will be risk assessed on a regular basis to ensure that the relationship does not impact upon the impartiality of the certification process.
- Individuals employed by or otherwise contracted to LiberoGroup are required to document and record their current and past relationships with all companies. Any situation past or present, which may present a potential conflict of interest is required by LiberoGroup to be declared. LiberoGroup will use the information to identify any threats to impartiality and will not use that individual in any capacity unless they can demonstrate that there is no conflict of interest.
- LiberoGroup will not allocate a member of staff or sub-contractor to a management system audit where any past relationship has existed. Exceptionally and at the discretion of the Technical Manager or Directors an individual or sub-contractor may be allocated to a management system audit where a past relationship has existed but there has been no relationship for a minimum of 2 years.
- LiberoGroup does not and will not offer any commission, (‘finders fees’ or other inducements) to any individual or company in respect of referrals of clients unless:
- The terms and conditions of any such referral are clearly established and can be demonstrated and it can also be demonstrated that the fee is for a referral and the fact that a commission has been paid will in no way affect the outcome of an audit.
- A risk assessment (to establish the potential for an unacceptable threat to impartiality) has been carried out on the process through which any such payment is made to an individual or organisation (normally a consultant) requesting the commission for referrals.
- All such payments are documented, recorded, and traceable and accompanied by a purchase order and invoice.
- LiberoGroup does not offer specific training to any company in respect of implementing a particular standard for that company. Any training offered by LiberoGroup is general in nature and available to all companies or individuals who wish to attend.
- LiberoGroup will ensure that it is not linked or marketed in any way which links it with the activities of a management system consultancy and will take appropriate action should any such link be identified.
- Auditors and others involved in the certification process are not and will not be put under any pressure and will not be influenced in any way to come to a particular conclusion regarding the result of an audit.
LiberoGroup Impartiality Norms:
- No outsourcing of Audits to Consultancy Organisation.
- No Referral Fees to be paid to Consultancy Organisation.
- Facts based communication to Clients/ Consultancy Organisation.
- Adherence to all Accreditation and other LiberoGroup Policies.
- LiberoGroup shall not carry out any other conflicting services other than its core business of Certification.
- LiberoGroup shall not employ any professional conflicting its ethical policies.
- LiberoGroup shall not allow any of its auditors to market the services and conduct the audits for the same client.
- LiberoGroup shall not allow any of its auditors to carry out financial transactions with clients / consultants.
- LiberoGroup shall not carry out business with any consultant inducing pressures to compromise impartiality.
- All employees of LiberoGroup shall disclose any situation impairing the business ethics.
- LiberoGroup shall not allow any of the auditors to carry out audits for the client at least for 2 years from the date of relinquishment from their services for the client.
- LiberoGroup shall not allow any auditor to compromise on the audit timing as required as per the accreditation/ LiberoGroup norms.
- LiberoGroup shall not allow any auditor to conduct the audit for the client for which it has not been approved for.
- LiberoGroup shall maintain transparency with regard to all information.
- No auditor shall divulge any confidential information of the client to any third party without written consent from the client and approval by the MD
- No auditor shall carry any client information with them after the usage period. All client information shall be returned after use.
- Utmost care / verification to be carried out for granting the right scope of certification.
- Any unethical practice observed should be notified to the management at the earliest.
- LiberoGroup shall not allow any of its auditors to accept any gifts from the client / consultant of value greater than 6 Euros.
- LiberoGroup shall not allow any auditor to conduct audit for the organization where any of its family members / close relatives are involved in a decision making position.
- Disciplinary actions for non-adhering to impartiality policies shall be taken by the Management in consultation with Impartiality Committee.
Public Statement (as it appears on LiberoGroup’s website)
LiberoGroup, its Directors, Managers, Staff and others involved in the Certification of Organisations fully understand the importance of impartiality in undertaking its Certification Activities.
LiberoGroup will therefore ensure that in its dealings with clients or potential clients, all employees or other personnel involved in Certification Activities are, and will remain, impartial.
To ensure that impartiality is both maintained and can be demonstrated, LiberoGroup has identified and risk assessed all relationships which may result in a conflict of interest or pose a threat to impartiality.