Document Reference : FICPL/IM/Policy
Issue Date : 8th of July 2025
Revision : 01
Executive Summary
This policy represents a fundamental commitment for all executives and personnel of First Wave International Certifications (FICPL). Our primary objective is to protect stakeholder interests, manage conflicts of interest, and safeguard against impartiality threats in certification and inspection activities, ensuring a highly professional and transparent operational environment.
Management Policy Statement
The leadership team and management of FICPL are committed to implementing transparent operational strategies across all business functions. We maintain unwavering dedication to impartiality throughout all certification levels and related activities. Our management system eliminates undue pressures and implements robust impartiality safeguards across certification programs, inspections, and related services to enhance client confidence.
Inspection Activities
Objective Reporting Standards
All onsite inspection activities conclude with comprehensive, unbiased reports. Inspection processes maintain complete objectivity, with decisions based solely on conformity or non-conformity evidence. This evidence must be:
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Completely objective and factual
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Free from any form of bias or partiality
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Independent of commercial or financial pressures
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Based on verifiable observations and documentation
Certification Decision-Making
FICPL management conducts thorough investigations based on conformity and non-conformity evidence. All decisions made during onsite audits must be:
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Completely unbiased and objective
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Free from undue pressures (commercial, financial, or otherwise)
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Based solely on technical evidence and applicable standards
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Independent of external influences that could compromise impartiality
Organizational Commitments
Conflict of Interest Prevention
Related Party Restrictions
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FICPL will not conduct certification or inspection services for any related party where FICPL directors have interests including:
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Director positions
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Shareholding arrangements
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Business relationships or partnerships
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Financial interests or dependencies
Subsidiary and Parent Entity Restrictions
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Parent entities or wholly-owned subsidiaries of FICPL are prohibited from receiving certification or Type-A inspection services
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This ensures complete independence in all assessment activities
Independence Requirements
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FICPL operates independently without influence from external activities
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All decisions are made without consideration of individual party interests
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Staff members must not engage in activities that could compromise impartiality
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FICPL does not participate in manufacturing, designing, maintenance, supply, purchase, or installation activities for items under assessment
Potential Conflict Scenarios
The following parties may present potential conflicts requiring careful management:
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Management Reporting Relationships
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Personnel reporting to FICPL higher management (except where such relationships could influence inspections)
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Contractual Commitments
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Any contractual or related arrangements that could influence inspection decisions
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Common Ownership
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Shared ownership structures (except where owners could influence investigation processes)
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Board Appointments
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Common ownership through board appointees (except where these individuals could influence inspection or investigation decisions)
Prohibited Activities
Consultancy Services
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FICPL does not provide management system consultancy services
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This prohibition ensures complete independence in certification activities
Pressure Resistance
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FICPL personnel resist all financial or commercial pressures that could compromise impartiality
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This applies to all certification personnel and internal/external committee members
Immediate Response Protocol
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When impartiality threats are identified from any source, FICPL takes immediate corrective action
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All threats are mitigated through appropriate and necessary measures
Investigation Authority
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FICPL has authority to request information from any personnel (internal or external) to verify innocence regarding impartiality compromises or conflicts of interest
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Team members analyze gathered information to identify potential threats
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Personnel demonstrating conflicts of interest are excluded from critical organizational activities until conflicts are resolved
Personnel Commitment Framework
Staff Obligations
All FICPL personnel, including auditors, inspectors, committee members, investigation officers, certification personnel, and other employees, must demonstrate commitment to maintaining impartiality by:
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Signing confidentiality agreements specifically addressing impartiality
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Actively discouraging any activities that could compromise impartiality
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Reporting potential conflicts of interest immediately
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Participating in regular training on impartiality requirements
Monitoring and Review System
Continuous Oversight
Review Mechanisms The following activities ensure continuous monitoring and review of impartiality policies:
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Impartial Committee reviews
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Internal audit processes
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Management review meetings
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Related review activities across all FICPL operations
Assessment Frequency
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Regular scheduled reviews of impartiality implementation
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Ad-hoc reviews when potential threats are identified
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Annual comprehensive policy reviews
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Continuous monitoring of operational activities
Risk Management Framework
Risk Identification and Analysis
Threat Assessment Protocol
FICPL conducts comprehensive risk analysis and potential risk identification relating to impartiality threats, following established company policy guidelines. This includes:
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Systematic threat analysis procedures
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Conflict of interest assessments
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Regular risk evaluation activities
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Proactive threat identification processes
Monitoring and Mitigation Program
The Internal Audit Committee and top management verify risk monitoring and mitigation programs through:
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Regular committee meetings focused on impartiality risks
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Comprehensive risk assessment reviews
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Implementation of suitable corrective actions
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Strengthening of organizational control mechanisms
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Continuous improvement of risk management processes
Risk Response
Mitigation Strategies
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Immediate response protocols for identified threats
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Systematic risk reduction measures
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Enhanced control mechanism implementation
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Regular effectiveness reviews of mitigation measures
Management Oversight
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Executive review of all significant impartiality risks
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Board-level oversight of policy implementation
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Regular reporting on impartiality performance metrics
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Continuous improvement initiatives
Implementation and Compliance
Policy Enforcement
Compliance Monitoring
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Regular audits of impartiality policy implementation
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Staff performance reviews including impartiality assessments
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Client feedback evaluation regarding perceived impartiality
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Corrective action protocols for policy violations
Training and Awareness
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Mandatory impartiality training for all personnel
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Regular refresher training programs
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New employee orientation including impartiality requirements
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Ongoing awareness campaigns and communications
Documentation and Records
Record Keeping
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Comprehensive documentation of all impartiality-related decisions
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Maintenance of conflict of interest registers
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Recording of threat assessments and mitigation actions
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Regular reporting to management and oversight committees
Approval and Authorization
This policy has been reviewed and approved by the Board of Directors of First Wave International Certifications Pvt. Ltd.
Effective Date : 08th of July 2025
Next Review Date : 07th of July 2026
Document Owner : Chief Executive Officer
Review Authority : Board of Directors
This document supersedes all previous versions. All personnel must ensure they are working with the most current version of this policy.
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