Impartiality Management

Last reviewed 1 April 2025

Based on UGG-SOP(MSPO)-01 Confidentiality and Impartiality Management, Rev 02

How we identify, review and control threats to impartiality, and the committee that oversees it.

1Our commitment

UGG Certification Sdn Bhd is responsible for the impartiality of its conformity assessment activities. We do not allow commercial, financial or other pressures to compromise impartiality, and we manage conflicts of interest so that our management system certification stays objective.

Top management demonstrates this commitment through the measures below.

2Impartiality Management Committee

  1. An Impartiality Management Committee (IMC) advises the General Manager (GM) and Operation Manager (OM) on impartiality matters, under written terms of reference.
  2. The IMC meets at least once a year, and whenever the organisation or its processes change significantly. The GM or OM attends as the company representative.
  3. Minutes are documented, distributed to all attendees and kept by the GM or OM for the retention period set in the Master List of Records.
  4. The IMC makes sure that the people who resolve appeals and complaints are independent of the people who carried out the audit.

3Declarations

Everyone involved in the certification process, including auditors, subcontracted auditors, peer reviewers, technical reviewers and IMC members, reads and signs the Impartiality and Confidentiality Declaration Form (UGG-FM(MSPO)-01A and 01B). Audit and non-audit personnel sign it once in each term of service, so that no conflict of interest exists for UGG, its non-audit staff or its audit staff, whether directly employed or outsourced.

4Identifying and controlling threats

  1. The OM uses the Risk Management Plan (UGG-FM(MSPO)-02) to monitor threats to impartiality and to mitigate them.
  2. The OM reviews every threat with the GM. Together they put mitigation in place and review any residual risk to confirm it is acceptable.
  3. A threat that the GM and OM cannot resolve goes to the IMC. The GM makes the final decision after reviewing the IMC's recommendation, and the review is recorded in the IMC minutes.
  4. Threats are considered whether they arise inside UGG or from the activities of other persons, bodies or organisations. Sources include ownership, governance, management, personnel, shared resources, finances, contracts, training, marketing, and the payment of commissions or other inducements for referring new clients.
  5. Where a relationship poses an unacceptable threat, for example a wholly owned subsidiary of UGG asking its parent for certification, UGG does not provide certification.

5Interested parties

Our risk assessment includes consulting appropriate interested parties on matters that affect impartiality, including openness and public perception. Interested parties can include our personnel and clients, customers of certified organisations, industry trade associations, government regulators and other government services, and non-governmental organisations, including consumer organisations.

6Business and operational risk

  1. The GM and OM identify general business risks, operational risks and risks to impartiality.
  2. General business risk covers the context of the organisation, strategic management and planning, and our external and internal stakeholders. Categories include political, technological, socio-economic and financial risk.
  3. Operational risk covers quality, process, health and safety risks in our operational activities.
  4. Risks are recorded in a risk register grouped by category, analysed with suitable quantitative or qualitative methods, prioritised by their significance to UGG's operations, and assigned a person in charge for monitoring and control.

Forms

Related Procedures

  • UGG-SOP(MSPO)-01 Confidentiality and Impartiality Management, Rev 02PDF237 KB
  • UGG-SOP(MSPO)-04 Risk Management, Rev 01PDF268 KB

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