OP009

OP009

IMPARTIALITY, INTEGRITY &

CONFIDENTIALITY

Prepared By: Authorised By: Document ID: Date: Revision:

IQ Ltd K Mcgarry OP009 13.06.17 005
Page 1 of 6 Uncontrolled When Printed
 AMENDMENT HISTORY

Date Amendment New Issue Reason Auth. By

14.02.2017 001 First issue L Lavery
17.02.2017 002 Review by RC L Lavery

29.03.2017 003 Review by RC L Lavery

Amendments history added and changed Parr FM to UKAS Audit
15.05.2017 004 L Lavery
Parr Facilities Management Ltd Finding
13.06.2018 review 005 Annual review Kmcgarry

Prepared By: Authorised By: Document ID: Date: Revision:

IQ Ltd K Mcgarry OP009 13.06.17 005
Page 2 of 6 Uncontrolled When Printed
1.0 SCOPE

1.1 This procedure applies to all persons within Parr Facilities Management Ltd involved in the
delivery of Inspection activities under the scope of accreditation. Parr Facilities Management
Ltd is completely committed to delivering impartial inspection services to all of its customers.

2.0 PURPOSE

2.1 While the organisational structure of Parr Facilities Management Ltd assures independence of
inspection decision making, the procedures of Parr Facilities Management Ltd seek to confirm
how the primary requirements of impartiality are fulfilled.
2.2 To give confidence to all parties involved that impartiality can be achieved whilst carrying out
inspections & tests.
2.3 This procedure considers the possible threats and safeguards against those threats to
independence and impartiality of decision making within Parr Facilities Management Ltd.

3.0 RESPONSIBILITIES

3.1 Identification of impartiality risks is the responsibility of all employees.

3.2 Decision making on the level of risk presented by impartiality and the remedial actions required
is the responsibility of the management team including the Directors, Quality Manager,
Technical Manager and Technical Supervisors

4.0 THREATS TO IMPARTIALITY

4.1 Threats to impartiality are sources of potential bias that may compromise, or may reasonably
be expected to compromise the ability to make unbiased observations or draw impartial
conclusions associated with inspection outcomes. Parr Facilities Management Ltd has identified
the type of threats applicable to its inspection activities below. Although the list is not
exhaustive, it illustrates the wide variety of types of threat that Parr Facilities Management Ltd
will consider when analysing independence and impartiality issues:

 self-interest threats: threats that arise from Inspectors acting in their own interest;
 self-review threats; threats that arise from reviewing the work done by themselves or by their
colleagues;
 familiarity (or trust) threats: threats that arise from being influenced by a close relationship
with a person;
 intimidation threats: threats that arise from being, or believing that they are being, openly or
secretly coerced by other interested parties;
 advocacy threats; e.g. a body or its personnel acting in support of, or in opposition to, a given
organisation which is at the same time its customer, in the resolution of a dispute or litigation;
 competition threats; Parr Facilities Management Ltd and/or the Inspector may be concerned
about risking the Inspection & Testing contract.
 ownership, governance, management: e.g. directors or managers responsible for financially
conflicting areas of the business e.g maintenance work being generated by deliberate failure of
sound installations during inspection to feed maintenance work;
 shared resources; threats that arise from electricians conducting maintenance and repairs on
behalf of Parr Facilities Management Ltd but also required to act as inspectors on behalf of the
Inspection Body
 finances: e.g. remuneration of employees should not being linked to the volume or outcome of
inspections performed
 contracts: e.g. contracts which require Parr Facilities Management Ltd to carry out conflicting
activities such as maintenance and inspection for the same client

Prepared By: Authorised By: Document ID: Date: Revision:

IQ Ltd K Mcgarry OP009 13.06.17 005
Page 3 of 6 Uncontrolled When Printed
  marketing (including branding) e.g. conflicting representation of the IB and/or its accreditation
within other areas of the group;
 payment of a sales commission or inducement for the referral of new clients to the IB or other
areas of the business.

5.0 SAFE GUARDS TO IMPARTIALITY

5.1 Parr Facilities Management Ltd has in place safeguards that, where possible, eliminate threats
to impartiality. Where this is not possible, mitigation to limit the risk are put in place. These
include:

 company policies linked to employment terms and conditions;

 operational procedures defining how all inspection activities will be controlled to meet the
requirements of the QMS and technical Standards;
 contractual arrangements with key employees and customers defining, inter alia, roles and
responsibilities;
 training, monitoring and technical rigour during inspection activities;
 the value Parr Facilities Management Ltd and an individual employee place on their reputations;
 external assessment by UKAS for Accreditation purposes and external assessment by
Certification Bodies for ISO9001 Certification of the management system to assess organisation-
wide compliance with standards and regulatory requirements regarding impartiality;
 oversight by Parr Facilities Management Ltd governance structures (for example, boards of
directors) concerning compliance with impartiality criteria;
 other aspects of corporate governance, including the Parr Facilities Management Ltd culture
that supports the accreditation and certification processes and impartiality from the top down;
 rules, standards, and codes of professional conduct governing behaviour;
 the raising of sanctions, and the possibility of such actions, by UKAS; and
 the legal liability faced by Parr Facilities Management Ltd should it become evident that
impartiality has been compromised
 maintaining a culture that stresses the expectation that staff will act in the wider interest and
the importance of impartiality;
 other policies, procedures, and practices, such as those concerning the rotation of staff, internal
audit, and requirements for internal consultation on technical issues;
 personnel hiring, training, promotion, retention, and reward policies, procedures, and practices
that emphasise the importance of impartiality;
 prohibitions against certain employment relationships between family members and Parr
Facilities Management Ltd.

6.0 ASSESSING THE LEVEL OF IMPARTIALITY RISK (RISK ASSESSMENT)

6.1 Parr Group assesses the level of impartiality risk by considering the types and significance of
threats to the impartiality of inspection delivery and the types and effectiveness of safeguards.
The risk assessment process identifies and assesses the level of impartiality risk that arises from
various activities, relationships, or other circumstances.

6.2 The level of impartiality risk can be expressed as a point on a continuum that ranges from ‘no
risk’ to ‘maximum risk’ as follows:

No Risk Remote Risk Some Risk High Risk Maximum Risk

(1-5) (6-10) (11-15) (16-20) (21-25)

Prepared By: Authorised By: Document ID: Date: Revision:

IQ Ltd K Mcgarry OP009 13.06.17 005
Page 4 of 6 Uncontrolled When Printed
 Compromised Compromised Compromised Compromised Compromised
objectivity is objectivity is very objectivity is objectivity is objectivity is
virtually unlikely possible probable virtually certain
impossible

6.3 Impartiality risk can be given a nominal numerical risk value by use of a 5x5 risk matrix (similar
to health and safety risks), the level of risk for any specific activity can be placed on the
impartiality risk continuum by use of the above scoring system. E.g.. likelihood of bonus
payments for inspectors risk score of (1) against the high hazard of bonus payments to
inspectors for inspection volume score of (5) gives an overall impartiality risk score of (5) or ‘No
Risk’.

7.0 DETERMINING THE ACCEPTABILITY OF THE LEVEL OF IMPARTIALITY RISK

7.1 The manager who has been made aware of the risk and/or identified the risk, shall evaluate the
level of risk and identify its position on the impartiality continuum. Safeguards shall then be
tested against the impartiality risk. Evaluation requires the manager to judge whether
safeguards eliminate, or adequately mitigate, threats to inspection activities impartiality. If
they do not, the manager must decide which additional safeguards, (including prohibition) or
combination of safeguards would reduce the risk, and the corresponding likelihood of
compromised objectivity, to an acceptably low level. Those safeguards must then be
implemented and checked for effectiveness.

7.2 Parr Facilities Management Ltd considers ‘No Risk’ or ‘Remote Risk’ to be acceptable. Only such
a small likelihood of compromised objectivity is consistent with both the definition and the goal
of inspection impartiality.

7.3 During on-site witnessing of inspectors or technical supervisors, on-going threats to impartiality
will be dynamically risk assessed and recorded on the F008 – “Witness form”.

7.4 Operational risks shall be risk assessed and the outcomes of those risk assessments and
safeguards recorded in a risk matrix.

8.0 INDEPENDENCE

8.1 Independence (and impartiality) of inspection activities needs to be further protected by placing
it within an organisational structure, which will guarantee that the safeguards required are
implemented. The organisational structure is such that Parr Facilities Management Ltd can
demonstrate its impartiality and independence by separation of Inspection from potentially
conflicting maintenance and repair activities. This is further defined in the ISO17020 Quality
Manual.

9.0 CONFIDENTIALITY

9.1 "Confidential Information" means all records, reports, data and other information and know-how
belonging to a party which are disclosed to another party as a result of a contract other than that
which is already in its possession or the public domain.

9.2 "Intellectual Property Rights" means all copyright and related rights, patents, right to inventions,
utility models, design rights, registered design, database right, topography rights, moral rights,
rights in confidential information (including know-how and trade secrets) trade-marks, service
marks, trade, business and domain names, rights in trade dress or get-up, rights in goodwill or to
sue for passing off, or other proprietary rights of a similar or equivalent nature whether registered

Prepared By: Authorised By: Document ID: Date: Revision:

IQ Ltd K Mcgarry OP009 13.06.17 005
Page 5 of 6 Uncontrolled When Printed
 or unregistered and including all applications for and renewals or extensions of such rights, arising
in the United Kingdom or anywhere in the world.

9.3 Parr Facilities Management Ltd shall not use any confidential Information or intellectual property
for any purpose other than in connection with the performance of the contract or case, or
disclose any confidential information without the prior written consent of the customer to any
person other than to employees, agents or contractors to whom disclosure is necessary to enable
performance of the contract. This shall continue after termination or expiry of the contract.

9.4 All employees and contracted staff are subject to strict confidentiality clauses included within
their Contracts of Employment or terms of engagement.

9.5 The Company’s Policy on Confidentiality is included in the document GEN007- “Parr FM
Inspection Contract” available and attached to all orders for services.

END OF DOCUMENT

Prepared By: Authorised By: Document ID: Date: Revision:

IQ Ltd K Mcgarry OP009 13.06.17 005
Page 6 of 6 Uncontrolled When Printed