Independence and Non-Consultancy Policy

• To establish FVR's independence and non-consultancy policy: what it is independent of, what it does not offer, and which entities and persons it reaches. The policy statement is set out in §3.

• Applies to FVR and to any legal entity within the same corporate structure. Covers all FVR personnel (internal employees, internal auditors, subcontracted external auditors, evaluators, committee members, shareholders, contractors) and all certification body activities: scheme design, evaluation, decision, surveillance (FSA/SA), recertification (RA), transfer (TA) and communication.

• FVR operates with functional, financial and operational independence from the clients it certifies. FVR does not offer management system consultancy. FVR does not certify a management system for at least two years after FVR, any part of the same legal entity or any entity under its organizational control has completed an internal audit of that system. When a client has received management system consultancy from an organization related to FVR, FVR does not certify that system for at least two years after the consultancy ends.

• FVR and its personnel SHALL NOT perform:
• 1. Consultancy on management systems. This includes participation in establishing, implementing or maintaining a client's system; preparing or producing manuals or procedures; giving specific advice, instructions or solutions for its development or implementation; and training aimed at passing an audit. For ISO 45001, it also includes acting as the client's OH&S coordinator, preparing its safety reports, performing risk assessments, communicating with regulatory authorities on the client's behalf, and investigating accidents and incidents (IAF MD 22 G 3.3).
• 2. Internal audit of the certified or to-be-certified client's system.
• 3. Design or implementation of the client's system.
• 4. Promises of faster, easier, or cheaper certification if a specific consultant is hired.
• 5. Joint marketing with consultants providing services to CB clients (see §7).
• 6. Acceptance of gifts, attentions or payments beyond the symbolic value defined in FVR_GD-POL-04.
• In addition, FVR applies the following marketing prohibition. FVR does not promote any particular education or training service as improving access to certification, reducing its difficulty or lowering its cost — its own included. The rule reaches every channel FVR controls: the public site, the platform, commercial proposals, advertising and what its personnel say. In particular: where the applicable scheme permits a route without a course, at levels 1 and 2 the FVR course is not a prerequisite and is not presented as one; no discount, shortcut, advantage in the assessment or priority in scheduling is offered to whoever takes it; and no message may suggest that studying with FVR raises the chance of passing. Where the applicable scheme permits it, the route without the course — mandatory module practices and the examination, at levels 1 and 2 — is published on the same footing as the route with a course. For ISO 22000 and FSSC 22000, the complete HACCP course covering RQ, AU and TL must have been approved, which is verified once, when the person starts the course of those schemes: without it, that course cannot be started; the route without the course does not apply. Breach by personnel or by a franchise is a matter for the impartiality mechanism and, where it reaches the public, for the accuracy of public information.

• The FVR Platform (ERP) blocks an auditor's team assignment, scheduling, client-portal selection and participation in the certification decision for a client when the auditor completed management system consultancy for that client within the preceding 24 months. Personnel who provided such consultancy are also excluded from technical review and any other certification activity for that client. Under FVR's additional safeguard, the same 24-month period applies to an auditor who provided training to the client. The declaration is captured in the personnel declarations module (FVR_IM-PR-01 §5) and the block is recorded as `AuditorClientConflict`, fed by two sources: `PersonnelDeclaredService` — what the person declares in their four-monthly cycle — and `ClientDeclaredConsultancy` — what the client declares in its annual cycle. The block is structural and mandatory and currently permits no exception. Technical Management shall determine whether the previously stated exception is withdrawn or implemented.

• A person certified by FVR under line 17024 may be associated with an organization whose management system FVR certifies under line 17021. This does not constitute consultancy because the two certifications are independent objective evaluation activities and neither entails designing, implementing or advising on the subject of the other. Standard impartiality safeguards apply: independent assessment teams for each line, financial concentration analysis and Safeguard Committee review.

• FVR does not market or offer its certification activities jointly with any organization that provides management system consultancy. This includes:
• - Shared logos
• - Co-branding
• - Joint presentations
• - Cross-references on social media
• FVR acts to correct any inappropriate link or statement by a consultancy organization suggesting that certification with FVR would be simpler, easier, faster or less expensive.

• - Generic public training on standards (not specific consultancy to the client's system)
• - Public information on FVR certification processes

• - Semi-annual analysis of client portfolio (financial concentration)
• - Annual internal audit reviews compliance with rule 5.2.5/5.2.6
• - Review by Safeguard Committee

• FVR commits to:
• 1. Not offering consultancy on the management systems or competences it evaluates — neither design, nor implementation, nor advice to close a nonconformity, nor training aimed at passing an audit.
• 2. Blocking the assignment of an auditor to a client they have given consultancy or training to in the previous 24 months, and doing so in the platform rather than by judgement.
• 3. Not taking part in joint promotion with consultants who advise organisations that are FVR clients or in the process of becoming one.
• 4. Keeping the permitted exceptions to what is public and generic — training on standards that is not specific advice on a client's system, and public information about FVR's own processes.
• 5. Verifying compliance: a semi-annual analysis of financial concentration in the client portfolio, the annual internal audit, and review by the Safeguard Committee.

• General Management — approves this policy, guarantees the resources to sustain it and reviews its effectiveness annually.
• Safeguard Committee — assesses the declared relationships, decides the safeguards and escalates to the accreditation body where applicable, in both service lines.
• Technical Director — runs the threat analysis, keeps the 24-month block operating in the platform and supervises operational compliance.
• Personnel — declares any consultancy or training given to a client, abstains from the prohibited practices and reports any pressure received.

• The threats this policy governs are among the 37 impartiality entries of the management system risk register — self-interest, self-review through previous consultancy, familiarity and intimidation — and they are assessed there, not in this document.
• The family this policy primarily addresses is self-review through previous consultancy: it is the one the 24-month block prevents, and the only one the platform can stop before it happens rather than detect afterwards.
• A materialised threat is handled through the corrective action process, and the Safeguard Committee decides the applicable safeguard. This policy states the rule; the register holds the assessment and the treatment.

Approvals / Aprobaciones