Public Information

CONFLICT OF INTEREST

Only conflicting issues directly related to the scope of audit shall be considered as conflict of interest and the following cases apply:
Examples of conflict of interest:
1. The same person / Auditing Organization develops the corporate SHMS (including IMS) and conducts SHMS audit for any projects or at corporate level
2. The same person / Auditing Organization develops corporate QMS/EMS and conducts SHMS for the project; or
3. An Auditing Organization provides a WSH officer for Project A of ABC organization and conducts a SHMS audit for Project B of ABC organization;
4. An Auditing Organization is part of a parent organization and the parent organization is audited by the Auditing Organization;
5. An Auditing Organization audits a subsidiary of the same parent organization as the Auditing Organization though the subsidiary has influence over the decision making process of the Auditing Organization;
6. The same person / Auditing Organization provides WSHO consultancy and conducts SHMS audit for the same project;
7. An Auditing Organization provides WSH officer(s) to the same organization;
8. The management of the Auditing Organization (including directors and shareholders) is part of or whole of a consultancy organization (including managerial capacity) which provides management systems consultancy and auditing to the same organization.

A recognized mitigation of this threat is:
1. Personnel / Auditing Organization shall not be used to conduct the audit for a minimum of two years following the end of the consultancy of the corporate QMS/EMS, or
2. Personnel / Auditing Organization shall not be used to conduct the audit for the duration of the project where consultancy was provided.
3. In order to ensure that there is no conflict of interest, personnel including individual external auditors who have provided management system consultancy to the organization and including those acting in managerial capacity, shall not be used by the Auditing Organization to take part in an audit if they have been involved in providing management system consultancy to the organization for the past 2 years. The Auditing Organization shall not provide auditing services to a organization if any of the Auditing Organizations external auditors:
4. is currently employed by the organization on contract of service or contract for service; or
5. Has been involved in providing management system consultancy of the organization for the past 2 years.
6. Client does not use or permit the use of an audit report or testimony or any part thereof in a misleading manner.

INFORMATION ON THE AUDITING ACTIVITY AND REQUIREMENTS

Upon agreeing with this agreement, AAS SINGAPORE SERVICES PTE LTD shall provide and update the following information to the client/auditee:
a) a detailed description of the audit activity, including the audit plan, audit schedule etc.
b) the normative requirements for the audit
c) information about the fees for auditing

IMPARTIALITY POLICY

AAS’s top management is committed to safeguard and protect impartiality in auditing services. AAS shall be impartial and be perceived to be impartial to deliver auditing that provides confidence.
AAS shall identified the importance and need for impartiality and shall have communicated to all internal and external personnel whoever involved in its auditing services. It is recognized by AAS that the source of revenue for its auditing services is its client paying for auditing, and that this is a potential threat to impartiality. In order to obtain and maintain confidence, AAS shall take decisions based on objective evidence obtained, and that its decisions are not influenced by other interests or interested parties.
AAS has identified the followings as a threat to impartiality:
a) Self-interest: threats that arise from a person or body acting in their own interest e.g. for financial self-interest.
b) Self-review: threats that arise from a person or body reviewing the work done by themselves e.g management system consultancy provided by AOs would be a self-review threat.
c) Familiarity (or Trust): threats that arise from a person or body being too familiar with or trusting of another person instead of seeking audit evidence.
d) Intimidation: threats that arise from a person or body having a perception of being coerced openly or secretively, such as a threat to be replaced or reported to a supervisor. AAS manages conflict of interest to ensure the objectivity of its auditing services.

PROCESS OF HANDLING COMPLAINTS AND APPEAL

REQUEST FOR ADDITIONAL INFORMATION & COMPLAINT/FEEDBACK
1. Any verbal complaints received will be requested to be confirmed in writing. Only written complaints relating to auditing services operated by AAS will be processed in accordance with this procedure
2. All complaints are referred to the Auditing Service Committee appointed by the Director of AAS which comprises Director, Auditing Manager, and external Auditors as its members.
3. The Auditing Service Committee will write to acknowledge receipt of the complaint and is responsible for establishing the relevance of the complaint.
4. The Auditing Service Committee is authorized to confirm the validity of the complaint for carrying out subsequent investigation, including tracking and deciding the appropriate action if any to be taken in response.
5. The Auditing Service Committee is responsible for advising the AAS management of all complaints received. Details of all such complaints and resolution shall be recorded in the minutes of MR meeting.
6. The Auditing Service Committee is responsible for negotiating resolution of complaints with the complainant. They will advise the complainant about the outcome of the investigation. They will also decide, together with the client and complainant, how much information if any, including the outcome is made public
7. The top management will be kept informed on the progress of the complaint and final outcome of the investigation and corrective action if any.
8. When AAS is the subject of the nature of the complaint, the Auditing Service Committee is responsible to establish the relevance of the complaint and report to MR/Top management of the progress and outcome of the investigation. The final outcome of the investigation and action(s) to be taken shall be agreed by MR and communicated to the complainant and top management for follow up action.
9. When complaint against AAS that warrant a special visit to the client(s), the auditing Manager will determine the duration of the audit and type of audit to be conducted (partial or full assessment) taking into consideration the impartiality, responsibility, competence and openness of delivering the audit that gain/maintain public/stakeholders confidence. The planning of the audit such as Audit Plan and Audit Notification Letter to be provided to the client and reviewing of the report for auditing after audit shall follow same process as other normal audit with the exception of lack of opportunity for the client to object any of the auditors. The outcome of the special visits will be reported to the top management by the Auditing Manager for review.
10. If the complaint against the company director or senior staff, it can be difficult to handle, as there may be a conflict of interest for the staff investigating the complaint. When serious complaints are raised against director/ senior staff, it is particularly important that the investigation is conducted by an individual who is independent of the situation. A serious complaint against director/ senior staff of AAS is a ‘notifiable event’, and as such the regulator/accreditation authority/governing authority shall be informed immediately. It has also drawn up ‘regulatory expectations’ for the handling of serious complaints against the Director. This specifies that AAS shall seek independent, professional advice to support in handling, and in some cases investigating, the complaint. These arrangements take account of the need to ensure that the final decision is fair, objective and impartial.
11. All relevant records are retained in the Complaints File for not less than six years from the date of the complaint.