Citadel Engineering - Impartiality Policy

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CITADEL IMPARTIALITY

POLICY

CITADEL Engineering Company is the legal entity responsible for certification activities; reference to CITADEL in this Policy and Public Statement refers to these legal entities. CITADEL, its Directors, Staff, and Subcontractors fully understand the importance of impartiality in undertaking its Certification Activities CITADEL will ensure that in all its dealings with clients or potential clients, all employees or other personnel are and will remain impartial To maintain and demonstrate impartiality, the following principles have been established:

CERTIFICATION REVIEW PROCESS:

CITADEL certificates are only issued following a review by an independent, authorized, and competent member of the management team who has not been involved in the audit. This ensures that no interests shall predominate.

SEPARATION FROM CONSULTANCY:

CITADEL does not offer, and has never offered, management system consultancy or any other form of consultancy to companies or individuals Similarly, CITADEL does not provide internal audit services to its certified clients

INDEPENDENCE FROM CONSULTANCY FIRMS:

CITADEL does not own, nor does it have any financial or other interests in, any company that offers certification or management system consultancy services Any proposed relationship between CITADEL and other companies undergoes a risk assessment by the Impartiality Committee before formalization All existing relationships are regularly assessed for risks to impartiality

CONFLICT OF INTEREST DECLARATIONS:

Individuals employed by or contracted to CITADEL are required to document and disclose their current and past relationships with all companies. Any situation that may present a potential conflict of interest must be declared, and such individuals will not participate in the certification process unless it can be demonstrated that no conflict of interest exists

ALLOCATION OF AUDITORS:

CITADEL does not allocate staff or subcontractors to audit clients where any past relationship exists, unless the relationship ceased a minimum of two years prior. This decision is at the discretion of the Technical Manager or Directors.

NO COMMISSION-BASED REFERRALS:

CITADEL does not offer commissions, finder’s fees, or other inducements in respect of referrals of clients unless:

Terms and conditions of the referral are clearly established

A risk assessment is conducted to evaluate the potential threat to impartiality. All payments are documented, recorded, and traceable.

CITADEL IMPARTIALITY POLICY

GENERAL TRAINING SERVICES:

CITADEL does not offer training specific to implementing a particular standard for individual companies. Any training offered is general and available to all.

MARKETING & AUDIT SEPARATION:

CITADEL ensures that auditors involved in certification are not responsible for marketing services or conducting audits for the same client

REGULAR RISK ASSESSMENTS:

CITADEL’s Impartiality Committee will regularly assess relationships with companies, clients, and other stakeholders to ensure there is no impact on the impartiality of certification processes.

CITADEL IMPARTIALITY NORMS:

No outsourcing of audits to consultancy organizations

No referral fees paid to consultancy organizations

All communications with clients/consultants are fact-based

Adherence to all accreditation and CITADEL policies.

CITADEL will not carry out any services conflicting with its core business of certification.

No professional or auditor conflicting with CITADEL’s ethical policies shall be employed

Auditors shall not engage in any financial transactions with clients/consultants

All employees must disclose situations impairing business ethics

No auditor shall conduct an audit for a client within two years of leaving their employment with that client Auditors shall not conduct audits they are not approved for

No confidential client information shall be shared without written client consent and CEO approval.

Strict adherence to certification scope and ethical practices in every engagement.

CITADEL auditors shall not accept gifts greater than £50 from clients/consultants

Certification decisions are made by Head of Certification & Training who was not part of the audit team

CITADEL recognizes potential threats to impartiality, including self-interest, self-review, familiarity, and intimidation, and mitigates them through documented controls

IMPARTIALITY COMMITTEE:

The Impartiality Committee oversees the risk assessment of all relationships and ensures that CITADEL’s impartiality is maintained in all operations. The Committee reviews all existing and proposed relationships, conducts annual impartiality reviews, and has the authority to take corrective action if impartiality is compromised

TRAINING AND MONITORING:

All CITADEL employees and contractors will undergo regular training on impartiality and conflict of interest management. Conflict of interest disclosures will be reviewed annually, and any breaches of impartiality policies will be addressed through corrective actions by the Impartiality Committee.

PUBLIC STATEMENT :

CITADEL, its Directors, Managers, Staff, and others involved in the certification of organizations fully understand the importance of impartiality in undertaking its certification activities CITADEL will ensure that in its dealings with clients or potential clients, all employees or other personnel involved in certification activities are, and will remain, impartial.

To ensure that impartiality is both maintained and demonstrated, CITADEL has identified and risk-assessed all relationships that may result in a conflict of interest or pose a threat to impartiality

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