C.2.1 Management of impartiality
C.2.1.1
The designated body should have top management commitment to impartiality.
C.2.1.2
The designated body should have, and make available on request, a statement that it understands the importance of impartiality in carrying out its certification activities, manages conflicts of interest, and ensures the objectivity of its certification activities.
C.2.1.3
The designated body should identify risks to its impartiality on an ongoing basis. This should include those risks that arise from its activities, or from its relationships, or from the relationships of its personnel. However, such relationships do not necessarily present a designated body with a risk to impartiality.
C.2.1.4
If a risk to impartiality is identified, the designated body should be able to demonstrate how it eliminates or minimizes such risk.
C.2.1.5
When a relationship poses an unacceptable threat to impartiality (such as a wholly owned subsidiary of the designated body requesting product certification from its parent, or when the designated body belongs to a corporation or holding company, or manufacturer, etc. which requests product certification from its related designated body), then certification should not be provided.
C.2.1.6
Designated bodies should document how they manage their certification business and any other activities so as to eliminate actual conflicts of interest and minimize any identified risk to impartiality. The documentation should cover all potential sources of conflicts of interest that are identified, whether they arise from within the designated body or from the activities of other persons, bodies or organizations.
C.2.1.7
The designated body and any group within its organizational control or personnel, employed or contracted in an organization within its organizational control, should not offer or provide consultancy on the product that it certifies. This also applies to that part of government identified as the designated body.
C.2.1.8
The designated body should not give prescriptive advice or consultancy as part of an evaluation.
C.2.1.9
The designated body (and any group within its organizational control or personnel, employed or contracted, in an organization within its organizational control) should not offer or provide internal management system audits to the packer (or other legal entities involved in the certification process), in those schemes that require the packer (or other legal entities involved in the certification process), to perform internal management system audits. This also applies to that part of government identified as the designated body.
C.2.1.10
The designated body should not certify a product on which a packer has received consultancy or internal evaluations, where the relationship between the consultancy organization and the designated body poses an unacceptable threat to the impartiality of the designated body.
C.2.1.11
The designated body’s activities should not be marketed or offered as being linked with the activities of an organization that provides product consultancy. The designated body should take action to correct inappropriate claims by any consultancy organization stating or implying that certification would be simpler, easier, faster or less expensive if the designated body were used. A designated body should not state or imply that certification would be simpler, easier, faster or less expensive if a specified consultancy organization were used.
C.2.1.12
To ensure that there are no conflicts of interest, personnel who have provided consultancy for, or been employed by a packer, including those acting in a managerial capacity, should not be used by the designated body to make a certification decision, nor to resolve a complaint or appeal for that packer within two years following the end of the consultancy or employment.
C.2.1.13
The designated body should take action to respond to any threats to its impartiality arising from the actions of other persons, bodies or organizations.
C.2.1.14
All designated body personnel, either internal or external, or committees, who could influence the certification activities, should act impartially and should not allow commercial, financial or other pressures to compromise impartiality.
C.2.1.15
The designated body should manage the risk to impartiality arising from over-familiarity between its personnel and the packer.