1. Purpose 
This policy outlines CUALIS’s commitment to maintaining impartiality in all management system certification activities, in compliance with ISO/IEC 17021-1:2015. Impartiality is the cornerstone of delivering credible and trustworthy certification services to our clients, stakeholders, and the public.

This Impartiality Policy is publicly available on the CUALIS website and is communicated to, and understood by, all levels of the organization and all personnel involved in certification activities.

2. Policy Statement 
CUALIS is committed to operating in an impartial, objective, and transparent manner, free from any conflict of interest, undue influence, or bias. All certification decisions made by CUALIS shall be based solely on objective evidence of conformity and shall not be influenced by any financial, commercial, or other interests.

CUALIS top management understands the importance of impartiality in carrying out its certification activities and manages any potential conflicts of interest to ensure the objectivity of its management system certification activities.

3. Guiding Principles 
To ensure impartiality, CUALIS operates based on the following principles:

Objectivity: All audit and certification activities are conducted based on factual evidence and documented procedures.

Independence: CUALIS remains independent of all parties involved in the certification process, including consultancy bodies and other related organizations.

Conflict of Interest Management: Any actual, potential, or perceived conflict of interest is identified, documented, evaluated, and effectively managed or eliminated.

Non-Discrimination: Certification services are available to all applicants whose operations fall within CUALIS’s defined scope. CUALIS does not use unfair or discriminatory conditions, such as undue financial conditions, nor is certification conditional upon the size of the client, membership of any group or association, or the number of certifications already held.

Prohibition of Consultancy:

• CUALIS does not offer or provide management system consultancy services (as defined in ISO 17021-1, 3.2).
• CUALIS does not offer or provide internal audits to its certified clients.
• Separation from Sales and Marketing: CUALIS’s marketing and sales activities are separate from certification decisions. CUALIS will not state or imply that certification would be simpler, easier, faster, or less expensive if a specific consultancy organization were used.
• The Two-Year Rule: Auditors or decision-makers who have provided consultancy services, including internal audits, to a client shall not be involved in certification activities for that client for at least two years following the end of the consultancy.

4. Responsibilities 
Top Management: The Top Management of CUALIS holds the legal and financial responsibility for ensuring impartiality is embedded in the organization’s culture, processes, and decision-making. Top management has signed an annual commitment to ensure no commercial pressures influence technical decisions.

Impartiality Committee: An Independent Impartiality Committee, representing key stakeholders, is established to review, monitor, and advise on impartiality risks. The Committee has the authority to:

Review the ongoing risk assessment.

Review any certification decision or commercial relationship.

Independent Action: Take independent action (e.g., informing the Accreditation Body, e.g., INACAL) if CUALIS Top Management does not follow their advice regarding impartiality risks.

Personnel: All employees, auditors, and external contractors must sign an impartiality declaration and reveal any potential conflicts of interest. Personnel will not be used in certification activities unless they can demonstrate that there is no conflict of interest.

5. Risk Assessment 
CUALIS conducts ongoing and structured risk assessments to identify, analyze, evaluate, treat, monitor, and document threats to impartiality. This includes risks arising from its activities, its relationships, or from the relationships of its personnel. Threats analyzed include:

Self-interest: Financial or commercial.

Self-review: Reviewing one’s own work (e.g., past consultancy).

Familiarity (or trust): Personal or family relationships.

Intimidation: Pressure to influence a decision.

Undue Commercial Pressure: Dependency on a single client for financial viability.

When risks are identified, they are documented, and appropriate safeguards or controls are implemented to eliminate or minimize the threat.

6. Corrective Actions 
CUALIS will take action to respond to any threats to its impartiality arising from the actions of other persons, bodies, or organizations. CUALIS will take corrective actions if any consultancy organization states or implies that CUALIS certification is linked to their services.

7. Reporting Concerns
Anyone, internal or external to CUALIS, may report concerns or complaints about impartiality, objectivity, or conflicts of interest. Such concerns will be treated confidentially and investigated promptly and thoroughly, in accordance with CUALIS’s documented complaints procedure.

📧 diego.bueno@cualis.net
Compliance Department

8. Policy Review
This policy is reviewed annually or in response to any significant changes in operations or external requirements to ensure it remains suitable, adequate, and effective.