1. PURPOSE
To provide a framework for operation of Inspection / Audit Schemes in an Objective and Impartial manner.
2. SCOPE
This procedure covers Impartiality issues related to all Inspection / Audit activities operated by ISPL in accordance with ISO/IEC 17020:2012 and Hygiene Rating Audit Agency (HRAA).
3. RESPONSIBILITY
- Director / CEO is responsible for management of Impartiality in the Inspection / Audit operation.
- Technical Manager/ Subject Matter Expert (SME) is responsible to ensure implementing management of Impartiality in the Inspection / Audit operation.
4. PROCEDURE
4.1 ISPL has the status of Private limited organization.
4.2 ISPL undertakes Inspection / Audit activities in an impartial manner without any Discrimination. The top management’s commitment to impartiality shall be demonstrated by documenting the HRAA’s policy on safe guarding impartiality and ensuring that it is understood at all levels of the organization and making available its policy on impartiality, to the public through our website.
4.3 ISPL is responsible for the impartiality of its Inspection / Audit activities and do risk assesement for commercial, financial or other pressures which may compromise impartiality and independence. The ISPL shall not have any direct relationship with the Food Establishments (FEs) other than audit activities as a HRAA / Third-party conformity assessment body.
4.4 ISPL identifies risks to its impartiality on regular basis (Yearly once) (See ISPL/F/37- RISK ASSESSMENT OF IMPARTIALITY AND CONFLICT OF INTEREST) or any changes in the structure or any incident. This includes those risks that a arise from its activities, from its relationships, or from the relationships of its personnel. But such relationships do not necessarily present in ISPL with a risk to impartiality and mitigation measures provided thereof.
4.5 Risk assessment conducted has taken into an account; relationship that threatens the impartiality of ISPL based on ownership, governance, management, personnel, shared resources, finances, contracts, marketing (including branding), and payment of a sales commission or other inducement for the referral of new clients, etc.
4.6 It is a continuous process to identify risk to impartiality as and when it occurs on account of changes/ incidents taking place or annually basis and it is demonstrated how ISPL eliminates orminimizes such risks. This information is made available to the Technical Manager/ Subject Matter Expert (SME).
4.7 ISPL has been independent to the extent that is required with regard to the conditions under which it per forms services. Depending on these conditions, it has been met the minimum requirements as given below:
a. The ISPL and its personnel has not been engage in any activities that may conflict with their independence of judgment and integrity in relation to their Inspection / audit activities. In particular, they shall not been gaged in the design and establishment of a Food Establishment, Supply, Purchase, Installation, Maintenance of Equipment or Services used in a FE and prohibited from any kind of consultation or offering training.
b. The ISPL has not been related to an entity that is engaged in the design and establishment of a FE, supply, purchase, installation, maintenance of equipment or Services used in an FE including any kind of consultation or training.
4.8 ISPL has top management’s commitment to impartiality and has made a public statement to adhere to impartiality:
The Management of ISPL Inspection / Audit recognizes and understands the importance of being impartial, and of being seen to be impartial, in carrying out its Inspection / Audit activities through:
- Identification of potential conflict of interest
- Elimination / just resolution of any conflict
- Impartiality of Inspection / Audit personnel
- Ensuring objectivity of management system Inspection / Audit activity
4.7 ISPL under its organizational control shall not:
a) be the designer, manufacturer, installer, distributer or maintainer of the inspected product,
b) be the designer, implementer, provider or maintainer of the inspected service
c) be the designer, implementer, operator or maintainer of the inspected process,
d) offer or provide consultancy to its clients related to the inspected products, services or processes,
e) offer or provide management system consultancy or internal auditing to its clients where the Inspection / Audit scheme requires the evaluation of the client’s management system.
f) offer or provide training to its clients related to the inspected products, services or processes,
- the possibility of exchange of information (e.g. explanations of findings or clarifying requirements) between ISPL and its clients and
- the use, installing and maintaining of inspected products which are necessary for the operations of the ISPL.
4.9 ISPL ensures that activities of separate legal entities with which the ISPL forms a part, do not compromise the impartiality of its Inspection / Audit activities. This situation is not visualized in the ISPL’s set up and this has been ensured while constituting Impartiality Committee.
4.10 When the separate legal entity in future offer or produce the inspected product or offers or provides consultancy related to the inspected product, ISPL’s management personnel and personnel in the review and Inspection / Audit decision making process are not involved in the activities of the separate legal entity. The personnel of the separate legal entity are not involved in the management of ISPL, the review, nor Inspection / Audit decision.
4.11 ISPL’s activities are not marketed or offered as linked with the activities of an organization that provides consultancy. ISPL do not state or imply that Inspection / Audit activities would be simpler, easier, faster or less expensive if a specified consultancy organization were used.
4.12 ISPL does not allow personnel for two years to review or make an Inspection / Audit decision for a product for which they have provided consultancy. The period of two years has been specified in the Inspection / Audit scheme which has been considered long enough to allow personnel to review or to take decision and will not compromise impartiality.
4.13 ISPL takes action to respond to any risks to its impartiality arising from the actions of other persons, bodies or organizations associated with it, when it becomes aware.
4.14 All ISPL personnel, either internal or external, or committees, who could influence the Inspection / Audit activities, act impartially and impartiality statements are taken from them.</br/>
4.15 The personnel involved in ISPL Inspection / Audit activities shall not be remunerated in a way that influences the results of inspections.
- ISPL/PRO/IMT/01 : Procedure for Impartiality
- ISPL/F/37 : Risk Assessment of Conflict Of Interest.
- ISPL/F/34 : Confidentiality Declaration- Inspector
- Annexure A : Competence Requirements as Per FSSAI Regulation