MANAGEMENT SYSTEM INCIDENTS

Qualitas de Certificate (QDC) is the legal entity responsible for certification activities. Its managers, employees, auditors, and subcontractors are fully aware of the importance of impartiality in the performance of its certification activities. Therefore, we ensure that all employees and other personnel are and will remain impartial in all contacts with clients or potential clients. To ensure that impartiality is both maintained and can be demonstrated, the following principles have been established:

• QDC certificates are issued only after a review by an authorized and competent member of the management team (who was not involved in the review) to ensure that no interest prevails.
• QDC does not provide (and has never provided) management systems consulting or any other form of consulting to companies or individuals.
• QDC does not provide (and has never provided) internal audit services to its certified clients.
• QDC does not own or have an interest (financial or otherwise) in any other company that provides certification or management system consulting services.
• QDC does not, and will not, have any relationships with companies that provide consulting or other services that could be construed to affect the certification services provided by QDC.
• Any proposed relationship between QDC and another company will be subject to risk assessment by the Impartiality Committee before the relationship is formalized.
• All existing relationships with companies, organizations and individuals are risk assessed on a regular basis to ensure that the relationship does not impact the impartiality of the certification process.

Individuals employed or otherwise contracted by QDC are required to document and record their current and past relationships with all companies. Any past or present situation that may present a potential conflict of interest must be disclosed according to QDC.

QDC will use this information to determine a threat to impartiality and will not use the individual in any capacity unless it can demonstrate that no conflict of interest exists. We will not engage an employee, auditor or subcontractor in a management system audit with whom there has been a past relationship.

In exceptional circumstances and at the discretion of the Managing Director, an individual or subcontractor may be assigned to a management system audit if a previous relationship existed but has not existed for at least 2 years.

QDC does not offer commissions ("referral fees" or other incentives) to individuals or companies for referrals unless:

• The terms of 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 was paid does not affect the outcome of an audit in any way.
• All such payments are documented, recorded, and tracked and accompanied by a purchase order and invoice.
• QDC does not provide specific consultancy services for organizations to implement a particular standard for that organization.

Any training provided by QDC is general in nature and is available to any company or individual who wishes to attend. QDC will ensure that it is not associated or marketed in any way with the activities of any management systems consultancy and will take appropriate action should any such association be identified.

Auditors and others involved in the certification process will not be pressured or influenced in any way to reach a particular conclusion regarding the outcome of an audit.