Certification Impartiality Policy
WHC is the legal entity responsible for certification activities; reference to WHC in this Policy and Public Statement refers to this legal entity.
WHC its Directors, Management, Staff and Sub–contractors fully understand the importance of impartiality in undertaking its Certification Activities. WHC will therefore ensure that in all its dealings with clients or potential clients all employees and/or sub-contractors are and will remain impartial. To ensure that impartiality is both maintained and can be demonstrated the following principals have been established.
- WHC Certificates are only issued following a review by an independent authorized and competent member of the management team (who has not been involved in the audit) to ensure that no interest shall predominate
- WHC does not offer (and has never offered) management system consultancy or any other form of consultancy to companies or individuals.
- WHC does not offer (and has never offered) an internal audit service to its certified clients.
- WHC does not own or have any interest (financial or otherwise) in any other company that offers certification or management system consultancy services.
- WHC 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 WHC Any proposed relationship between WHC and any other company will undergo a risk assessment by the Impartiality Committee prior to that relationship being formalized. Any current relationships with companies, organizations 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 WHC 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 WHC to be declared. WHC 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.
- WHC will not allocate a member of staff or sub–contractor to a certification audit where any past relationship has existed. Exceptionally and at the discretion of the General Manager an individual or sub–contractor may be allocated to a certification audit where a past relationship has existed but there has been no relationship for a minimum of 2 years.
- WHC 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 organization (normally a consultant) requesting the commission for referrals.
- All such payments are documented, recorded, and traceable and accompanied by a purchase order and invoice.
- WHC does not offer specific training to any company in respect of implementing a particular standard for that company. Any training offered by WHC is general in nature and available to all companies or individuals that it certifies or who is interested in engaging its services.
- WHC 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.
- WHC’s Impartiality Principles include the following:
- No outsourcing of Certification Audits to Consultancy Organization.
- No Referral Fees to be paid to Consultancy Organization.
- Facts based communication to Clients/ Consultancy Organization.
- Adherence to all Accreditation and other WHC Policies.
- WHC shall not carry out any other conflicting services other than its core business of Certification.
- WHC shall not employ any professional with conflicting ethical policies.
- WHC shall not allow any of its certification auditors to market the services and conduct the audits for the same client.
- WHC shall not allow any of its certification auditors to carry out financial transactions with clients / consultants.
- WHC shall not carry out business with any consultant inducing pressures to compromise impartiality.
- All employees of WHC shall disclose any situation impairing the business ethics.
- WHC shall not allow any of the auditors to carry out audits for the client for a period of at least 2 years from the date of terminating their services for the client.
- WHC shall not allow any certification auditor to compromise on the audit timing as required by WHC’s policies and procedures.
- WHC shall not allow any certification auditor to conduct the audit for the client for which it has not been approved for.
- WHC shall maintain transparency with regard to all information.
- No certification auditor shall divulge any confidential information of the client to any third party without written consent from the client and approval by the General manager
- No certification auditor shall carry any client information with them after the usage period. All client information shall be returned after usage.
- Utmost care/ verification to be taken to ensure the correct scope of the certification audit.
- Any unethical practice observed should be notified to the General Manager or a member of the Executive Committee at the earliest possible time.
- WHC shall not allow any of its auditors to accept any gifts from client / consultant of a value greater than US 50.00.
- WHC shall not allow any certification auditor to conduct audit of an organization where any of the auditors family members/ close relatives are involved in an ownership or in a decision making capacity.
- Disciplinary actions for non–adherence to impartiality policies shall be taken by the Executive Committee in consultation with the Impartiality Committee.
- To supplement in–house resources WHC employs sub–contract auditors. At no stage does WHC outsource its certification audits, outsource its certification decisions, or link its marketing activities with consultancy. WHC retains full control of all decision making processes regarding granting, maintaining, renewing, extending, reducing, suspending or withdrawing certification.
- WHC continues to evaluate the risks associated with its operations in the domestic and overseas markets to ensure it can meet liabilities associated with its certification activities. A risk analysis is maintained and reviewed annually.
- Conflict of Interest and objectivity is further covered through annual training sessions and contractually binding agreements, to ensure all certification activities are conducted in an independent and impartial manner.
- Certification Audit staff are prohibited from participating in the Audit / certification of any organization to which they have given assistance, by consultancy or training (other than professionally registered auditor training), or where they have any financial or commercial interest for a minimum period of 2 years prior to the date of application of the organization for registration.
- When allocated to a particular contract, Audit / certification staff shall not disclose or discuss any detail; before or after the Audit / certification; to any member of staff other than their direct Management or other members of the WHC team, as required by the Non–Disclosure Agreement signed on commencement of employment.
- All subcontracted Audit / certification staff or sector specialists used to support permanent staff of WHC shall sign a Subcontractor Agreement and a Non-Disclosure Agreement and shall be included on the Office Potential Conflict Listing.
- All directly employed Management and Staff are required to declare all financial interests or business activities on commencement and during the period of employment.
- WHC staff or subcontractors shall not suggest or imply that certification would be simpler, easier or less expensive if consultancy or training services were used. In addition subcontract staff cannot offer consultancy or training services to WHC’s clients that they have been assigned to audit, during or after the assigned task has been completed.
- Overall the certification of companies who supply a service to WHC is not deemed to be an unacceptable threat to conflict of interest. However, certification of a company in partnership with whom WHC provides a direct service is deemed to be an unacceptable Impartiality Policy.
- WHC recognizes that the source of revenue for a certification body is the client paying for certification, and that this is a potential threat to impartiality. Therefore WHC is a self financed independent organization, with a number of controls to ensure that impartiality is retained. To obtain and maintain confidence, it is essential that WHC’s certification decisions are based on objective evidence of conformity or nonconformity, and that any decisions made are not influenced by other interests or by other parties. Certification decisions are made and signed for by a competent Certification Manager who was not responsible for the audit and was not a member of the audit team. WHC recognizes that threats to impartiality include the following.
- Self–interest threats arising from a person or body acting in their own interest.
- Self–review threats arising from a person reviewing the work that they have conducted themselves.
- Familiarity (or trust) threats arising from a person becoming too familiar with or too trusting of another, instead of seeking audit evidence.
- Intimidation threats arising from a person having a perception of being coerced openly or secretively, such as a threat to be replaced or reported to a supervisor.
- WHC, its Directors, Managers, Staff and others involved in the Halal Certification of Organizations fully understand the importance of impartiality in undertaking its Certification Activities.
WHC 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, WHC has identified and risk assessed all relationships which may result in a conflict of interest or pose a threat to impartiality.