Impartiality policy
We sell certification, and we sell help preparing for it. A certificate is worth something only if the audit behind it could have gone the other way. This policy says how we keep the two apart, and what you can hold us to.
01Our position
Where we stand
This page sets out our own commitments. Some of them depend on AQC Group, the certification body, whose own published procedures are the authority on audits and decisions.
Certification bodies are assessed against ISO/IEC 17021-1, the international standard for bodies that audit and certify management systems. It does not allow a certification body to provide management system consultancy. Where an organization has taken consultancy from a body that has a relationship with the certification body, the standard treats that as a significant threat to impartiality, which the certification body has to deal with before it certifies.
That is our situation, and we would rather state it than leave it to be noticed. Northwind is the regional partner of AQC Group. We sell certification, in which AQC Group makes the decision and issues the certificate. We also sell implementation and documentation support, which is consultancy in the standard's sense, and training.
The standard names one recognized way of dealing with the threat: the certification body does not certify a management system until two years after the related body's consultancy on it has ended. Whether an organization we have supported can be audited sooner, under the safeguards in this policy, is for AQC Group to decide when that organization applies. It is not for us to decide, and we do not promise it.
AQC Group's published process asks every applicant what consultancy it has used on its management system: see AQC Group's certification process. If we supported you, say so on the application. If a certificate from AQC Group is what you want at the end, ask us about this before you buy support from us, not afterwards.
02Why it matters
Why this matters to you
The people who read your certificate were not at your audit. A buyer, a tender committee or a regulator relies on one thing: that the auditor was free to find against you, and that the body which decided was free to refuse. A certificate is only worth something if the audit could have gone the other way.
If the people who built a system also audited it, they would be marking their own work. If the people who decided gained from saying yes, a yes would mean less. A buyer who doubts a certification body's independence gives its certificates less weight, yours among them.
So the commitments below protect you as much as they bind us. They are also the reason an auditor will not tell you how to fix a nonconformity, and the reason nobody here can promise you a certificate.
03Commitments
What we commit to
These apply to everyone who works for Northwind, whatever they sell and whoever the client is.
The decision is AQC Group's
Every certification decision is made by AQC Group: to grant a certificate, to refuse one, to suspend, withdraw or restore it, or to change its scope. It is never made by anyone who audited the organization, and never by anyone who advised it. Northwind does not make certification decisions.
Under AQC Group's published process, the people who make each decision are appointed by AQC Group, and the client's file is reviewed independently before a certificate is granted.
Support and audit are done by different people
Nobody audits a management system that they helped to build, document or audit internally. The people who give implementation support to an organization and the people who audit it are different people. Under AQC Group's published process, AQC Group appoints the audit team.
Two years apart
A person who has given implementation support to an organization takes no part in auditing it, in reviewing its audit file or in its certification decision for at least two years after the support ended. Internal audits carried out as part of our support count as support. So does training that gave advice specific to that organization.
No advantage from buying support
Taking our support brings no advantage in the audit. The audit is not shorter, not cheaper and not easier, and certification is not guaranteed. Audit time is set by the same rules for every organization, and the audit is the same however you prepared. We never say or imply otherwise, in a quotation, in a meeting or on this site.
Any consultant, or none
You are free to prepare with any consultant, or with none. Nothing in the certification process requires our support or favours it. An organization that prepared alone or with someone else is audited in exactly the same way.
Interests are declared
Auditors declare any interest in an organization before they audit it: past employment there, advice or training given to it, a family tie, a financial stake. An auditor with a conflict is replaced. AQC Group's published process says that the auditor signs a conflict of interest declaration before every visit.
If you believe an auditor assigned to you has a conflict, tell us before the audit and say why.
No commission or gift changes a result
No commission, fee, gift or favour changes an audit finding or a certification decision. We do not accept gifts or hospitality beyond ordinary courtesy from an organization that is being audited, and we do not offer them to anyone who audits or decides.
Findings are reported as found
What an auditor finds is written down as it was found, with the evidence. A nonconformity is not softened, left out or exchanged for anything, and none is invented. The report reads the same whoever the client is and whatever else it buys from us.
Commercial pressure does not change a decision
A sale, a deadline, the size of an account or a threat to take the business elsewhere does not change a finding or a decision. Nobody who sells our services tells an auditor what to find. If a correct decision costs us a client, it costs us a client.
Threats are reviewed regularly
We review the threats to our impartiality regularly: who owns and manages us, whom we work with, what we sell and to whom, and any concern raised with us. What the review finds is recorded and acted on. We give AQC Group the information it asks for, so that it can assess the same risks itself.
Anyone can raise a concern
A client, an auditor, a competitor, a member of the public or one of our own staff can tell us that something looks wrong. Use the complaints and appeals page. Raising a concern never counts against the person or organization that raised it.
04Where the line is
What counts as support, as training and as audit
The three are different kinds of work, and the rules follow the work, not the name on the invoice.
Implementation support
Support is work on your own system: a gap analysis, writing your procedures, setting up your records, your internal audit, advice on how to meet a requirement. This is consultancy. Whoever does it for you stays out of your audit and your decision for at least two years.
Implementation supportTraining
Training is general teaching: what a standard asks for, how to audit, what top management has to do. It is the same for any organization. Once a trainer starts advising on your own system, the work has become support, and the same rule applies to that person.
TrainingAudit
An auditor can explain what a requirement means and why something is a nonconformity. An auditor does not tell you how to fix it, does not write your procedure and does not recommend our support. If you ask and the auditor declines, the rule is working.
How certification works05In practice
What this means when you deal with us
- If you take support from us and then apply for certification, AQC Group decides whether and when it can audit you. Ask before you buy support.
- Declare on your application any consultancy you have used, ours included.
- You are audited by people who took no part in your preparation, and decided on by people who took no part in your audit.
- Expect the auditor to decline to advise you, and expect findings to be written as they were found.
- If anyone at Northwind suggests that support will make your audit quicker, cheaper or more likely to succeed, they are breaking this policy. Tell us.
Tell us if we fall short.
If something we have said or done does not match this policy, say so. It is passed to a person who was not involved in the matter.