Revision 2

December 2013 Rev. 0

 GUIDELINES FOR THE SAFEGUARD OF IMPARTIALITY IN THE ACTIVITIES Rev.2
OF THE RINA GROUP COMPANIES

GUIDELINES FOR THE SAFEGUARD

OF IMPARTIALITY IN THE ACTIVITIES
OF THE RINA GROUP COMPANIES

Finding the right solution

in compliance with the Rules

from a Group point of view

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Index
1. FOREWORD
2. RINA GROUP COMPANY STRUCTURE
3. RINA GROUP COMPANY ORGANISATION
4. DEFINITIONS
5. REFERENCE RULES AND STANDARDS
6. IMPARTIALITY THREATS MANAGEMENT
6.1 Introduction
6.2 Risk Assessment Document (RAD)
6.3 Committee for Safeguarding Impartiality
6.4 Corporate Compliance Board
7. GUIDELINES
7.1 Foreword
7.2 Inspection (ISO/IEC 17020)
7.3 Public procurement regulations (Presidential Decree 207/2010)
7.4 Management system certification (ISO/IEC 17021)
7.5 Product certification (ISO/IEC 17065)
7.6 Clean Development Mechanism (CDM)
7.7 EU Commission Regulation No. 600/2012 (verification of greenhouse gas emission and
tonne-kilometre reports pursuant to directive 2003/87/EC)
7.8 ISO 14065:2012 (verification of greenhouse gas inventories in order to comply with ISO
14064-1:2012)
7.9 Energy Management System (EMS) certification (ISO 50001)
7.10 Railway sector certification
7.11 Regulation 391/2009
8. CONCLUSIONS

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1. FOREWORD
Companies belonging to the RINA Group carry out a wide range of activities in several
economic sectors. As described in more detail in paragraph 2, some of them mainly focus
on consulting and engineering services, while others mainly focus on conformity assess-
ment (testing, inspection, certification, attestation) in highly regulated sectors, that need
the possession and maintenance of specific requirements for impartiality and independ-
ence.
The main national and international regulations that discipline the role and the duties of a
Conformity Assessment Body (CAB) highlight the importance for the same to guarantee its
own impartiality and independence.
The main objective of a conformity assessment is to instill trust in the interested entities
(the so-called “stakeholders”, who include, depending on the type of assessment, clients,
authorities, market and users). In order to obtain and maintain such trust, it is necessary
for the CAB not only to be impartial, but also to be perceived as such by the stakeholders.
In 2013 the RINA Group has examined, through a dedicated Working Group, the relations
between the activities carried out by its companies, in the light of safeguarding impartiality
and preventing conflicts of interest, so as to allow the provision of engineering services
(Consulting Engineering - CE) and conformity assessment services (Testing, Inspection
and Certification .- TIC), while ensuring compliance with the applicable accreditation and
authorisation rules.
The scope of these Guidelines is to disseminate within the RINA Group (particularly refer-
ring to those compaies not directly involved in third-party activities) the knowledge of
impartiality and independence principles which represent essential requirements for con-
formity assessment activities. At the same time, while ensuring compliance with the inde-
pendence of individual Group Companies, these Guidelines define behavioural principles
that each of them must adopt when carrying out activities that, if associated with each
other, may cause a threat to Impartiality.
These Guidelines are mainly inspired and its contents are taken from the analysis carried
out by the above-mentioned Working Group, based on the contributions provided by the
main companies and units of the Group involved in activities which require compliance with
the principles of impartiality. This document is subject to continuous review and develop-
ment, to take changes in legislation and Group evolution (e.g. new acquisitions) into ac-
count. It is open to contributions from those working within the RINA Group who wish to
provide comments, suggestions or highlight possible errors or shortcomings.
These Guidelines are approved and constantly updated by the Corporate Compliance
Board, whose composition, duties and responsibilities are described in Organizational
Structure Document DO-CCB-01.

2. RINA GROUP COMPANY STRUCTURE

Today, the RINA Group consists of the Parent Company RINA S.p.A., founded in 1999, as
well as several operational companies situated in Italy and abroad.
RINA S.p.A. (in the following: “RSPA”) carries out control and coordination activities for
subsidiaries exclusively from an administrative and financial point of view, excluding any
technical control and coordination.
The subsidiaries may be grouped into two macro-categories, according to the services they
provide:
1. Companies that mainly carry out conformity assessments (“TIC” – Testing, In-
spection and Certification) within the maritime, industrial, civil, building, health
service, agricultural and food, energy, finance, transport, tertiary sectors and in

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the other production sectors, generally on the basis of accreditations, authorisa-

tion and notifications and relating to the RINA trademark, of which RINA Services
S.p.A. (in the following: “RSSE”), entirely owned by RINA S.p.A., is the parent
company These companies currently include, in addition to RSSE (whose share-
holding rate is indicated in brackets):
▪ RINA Check S.r.l. (100%);
▪ Agroqualità S.p.A. (50%, where RSSE carries out direction and technical
co-ordination);
▪ RINA Intermodal S.r.l. (90%);
▪ ITA S.r.l. (60%);
▪ SSM S.r.l. (100%);
▪ Foreign companies which report to and are entirely owned by RSSE, either
directly or through the subsidiary RINA International B.V.,(e.g. RINA Hel-
las, RINA Brasil, RINA UK, RINA India, etc.), including Hayes Stuart and
QIC.
TIC activities are also carried out by the following companies, which are currently
under the direct control of RSPA: SOA RINA, an attestation company, and SOGEA
S.c.r.l., which deliver training services for both the market and RINA personnel.
2. Companies that carry out activities mainly within the Consulting Engineering sec-
tor (“CE”), of which D’Appolonia (in the following: “DAPP”), entirely owned by
RSPA, is the parent company:
▪ Logmarin Advisors S.r.l. (100%);
▪ Sembenelli (100%);
▪ Seatech (100%);
▪ Foreign companies which report to and are entirely owned by D’Appolonia.
“CE” activities are also carried out by the following Companies, which are currently
under the direct control of RSPA:
▪ Centro Sviluppo Materiali S.p.A. (CSM), which carries out research, exper-
iments, tests and training on materials for mechanical and high-technology
industrial sectors;
▪ Polaris S.r.l., owned by RSPA (51%) e Ansaldo Energia S.p.A. (49%).

3. RINA GROUP COMPANY ORGANISATION

The content of Section 2 is described in the RINA Group Organisatal Chart, consisting of
the two operational parent companies RSSE and DAPP, to which the other companies refer
to, according to the type of activity carried out (see Figure 1):

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Figure 1

4. DEFINITIONS
In the following paragraphs, the main regulations of reference will be analysed relating to
the regulated activities of third-party certification, inspection and testing. In order to better
understand these regulations, it has been considered useful to state some of the most
significant and recurrent definitions of the accreditation regulations:
▪ Conformity assessment: this is a demonstration that specified requirements relating
to a product, process, system, person or body are fulfilled [ISO/IEC 17000].
▪ First-party conformity assessment activity: this is a conformity assessment activity
that is performed by the person or organisation that provides the object [ISO/IEC
17000]. Activities performed by an assessor who carries out his duties in the absence
of third-party control also come under this definition (e.g. accreditation bodies, public
authorities, etc.) and who has been requested by the client to carry out inspection ac-
tivities on his own systems or internal audit activities relating to the client’s organisa-
tion.
▪ Second-party conformity assessment activity: this is a conformity assessment ac-
tivity that is performed by a person or organisation that has a user interest in the object
[ISO/IEC 17000]. Activities performed by an assessor who carries out his duties in the
absence of third-party control (e.g. accreditation bodies, public authorities, etc.) and
who has been requested by the client to carry out verification/auditing activities on his
own suppliers/contractors or on goods supplied /produced by these to the client himself
also come under this definition.
▪ Third-party conformity assessment activity: this is a conformity assessment activ-
ity that is performed by a person or body that is independent of the person or organi-
sation that provides the object, and of user interests in that subject [ISO/IEC 17000].
From a practical point of view, third-party activities may consist in the same first and
second-party checks or verifications carried out by the first and second-party conformity

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assessor. What actually characterises third-party activities is the control of impartial-

ity on behalf of the evaluator who has been appointed by the interested party to
carry out such monitoring activities, but he is subject to verification of the accreditation
bodies or the public authorities that verify and monitor the compliance with technical
regulations and applicable procedures relating to accreditation, including those regard-
ing impartiality.
▪ Attestation: The issuing of a statement that declares that the fulfilment of the specified
requirements has been demonstrated [ISO/IEC 17000].
▪ Declaration: First-party attestation [ISO/IEC 17000].
▪ Certification: Third-party attestation related to products, processes, systems or per-
sons [ISO/IEC 17000].
 Validation: confirmation, through the provision of objective evidence, that the require-
ments for a specific intended use or application have been fulfilled [ISO 9000].
 Verification: confirmation, through the provision of objective evidence that specified
requirements have been fulfilled [ISO 9000].
▪ Accreditation: third-party attestation related to a conformity assessment body con-
veying formal demonstration of its competence to carry out specific conformity assess-
ment tasks [ISO/IEC 17000].
▪ Impartiality: presence of objectivity [ISO/IEC 17021]1.
Note 1 Objectivity means that conflicts of interest do not exist or are resolved so as not to adversely
influence subsequent activities of the certification body.
Note 2 Other terms that are useful in conveying the concept of impartiality are: independence, freedom from
conflict of interests, freedom from bias, lack of prejudice, neutrality, fairness, open-mindedness,
even-handedness, detachment, balance.

▪ Consultancy services (general): This refers to the professional services of a person

or company that advises, assists and supports its client as regards the preparation and
carrying out of documents, processes or projects. In order to assess any incompatibili-
ties with third-party certification/inspection services, all preparatory activities relating
to subsequent certification/inspection activities are to be considered consultancy ser-
vices, except customer support activities aimed at a preliminary verification of the com-
pliance to national and international regulations, including those issued by the Certifi-
cation Body.
▪ Consultancy relevant to products, processes and services: participation in the
designing, manufacturing, installing, maintaining or distributing of a certified product or
a product to be certified; or the designing, implementing, operating or maintaining of a
certified process or a process to be certified; or the designing, implementing, providing
or maintaining of a certified service or a service to be certified [ISO/IEC 17065, para
3.2].
▪ Consultancy relevant to inspection activities: : engagement in the design, manu-
facture, supply, installation, purchase, ownership, use or maintenance of the items in-
spected [ISO/IEC 17020 2]; specialized studies on specific issues not directly associated
with design activities (e.g. transport studies, analysis of monitoring and/or experimental
data, environmental characterization studies, etc.) are not considered “consultancy” ac-
tivities.
▪ Management system consultancy services: participation in the definition, imple-
mentation or maintenance of a management system [ISO/IEC 17021, para 3.3].

1 In the previous version of the ISO/IEC 17021 (2011) standard reference was made to “actual and perceived
presence of objectivity”. The new ISO/IEC 17021 (2015) standard only mentions the “presence of objectivity”.
2 In the absence of an explicit definition, the meaning of “consultancy” may be inferred from the requirements
for Type A Inspection Bodies in Annex A.

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Examples:
a) Preparing or producing manuals and procedures, and
b) Giving specific advice, instructions or solutions towards the development and implementation of a
management system.
Note 1 Arranging training and participating as a trainer is not considered consultancy, provided that, where
the course relates to management systems or auditing, it is confined to the provision of generic
information; i.e. the trainer should not provide client-specific solutions.
Note 2 The provision of generic information, but not client specific solutions for the improvement of pro-
cesses or systems, is not considered to be consultancy. Such information may include:
- explaining the meaning and intention of certification criteria;
- identifying improvement opportunities;
- explaining associated theories, methodologies, techniques or tools;
- sharing non-confidential information on related best practices;
- other management aspects that are not covered by the management system being audited.

5. REFERENCE RULES AND STANDARDS

The Guidelines take into account the Impartiality requirements contained in the accredita-
tion/authorisation regulations shown in Table 1 3. For each regulation the activities carried
out as well as the RINA Group company involved are specified:

Standard of reference Activity Accredita- Group company that

tion/authorisa- provides the service
tion Body

ISO/IEC 17020:2012 Third-party inspection ACCREDIA RINA Services (Railways,

TURKAK Environmental Technology
Verification)
RINA Check
RINA Turkey
ISO/IEC 17021:2015 Management system certifica- - ACCREDIA RINA Services
tion - ANAB Agroqualità
- INMETRO
- EGAC
- DAC
- RENAR
- (SAAS) 4
ISO/IEC 17065:2015 Product, process and service ACCREDIA RINA Services
certification
 Standard PEFC Italia Agroqualità
ITA 1003

 FSC INTERNA-
TIONAL STANDARD
General require-
ments for FSC ac-
credited certification
bodies - application
of ISO/IEC Guide
65:1996 (E)

 FSC-STD-20-001
(Version 3-0) EN

3 The list in the table takes into consideration the most important regulatory documents for the purposes of the
activities carried out within the RINA Group, according to what suggested by those who have taken part in
the Working Group on the Prevention of Conflicts. This is not a complete list, other documents or regulatory
requirements may be submitted to the Corporate Compliance Board by the interested Group company/func-
tions for the purposes of future inclusion in these Guidelines.
4 Some Group companies (RINA Simtex, RINA India, RINA Brasil) operate locally using local accreditations that
refer to the same ISO/IEC 17021 regulation.

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CDM Accreditation Validation and Verification UNFCCC RINA Services (Environ-

standard “Clean Development Mecha- ment)
nism” – CDM Projects
ISO/IEC 17020:2012 Inspection ACCREDIA RINA Services (Environ-
ETV-EU Environmental ment)
Technology verification
pilot programme– gen-
eral verification protocol
– 15-12-2011
ISO 14065:2013 Verification of greenhouse gas ACCREDIA RINA Services (Environ-
EU Commission Regula- emission reports and tonne-kil- ment)
tion No. 600/2012 (Art. ometre reports and the accred-
42) itation of verifiers pursuant to
 EA-6/03 2013 “EA Directive 2003/87/EC
Guidance For Recogni-
tion of Verification
Bodies Under EU ETS
Directive”
 IAF MD 6:2014 Appli-
cation of ISO
14065:2007
 RG-15 Rules for the
accreditation of verifi-
cation bodies for
greenhouse gas emis-
sions (03-12-2012)
ISO 14065:2013 Verification of greenhouse gas RINA Services (Environ-
UE Regulation N. inventories in order to comply ment)
600/2012 of the Com- with ISO 14064-1:2012
mission (art. 42)
 EA-6/03 _ 2013 “EA
Guidance For Recogni-
tion of Verification
Bodies Under EU ETS
Directive”
 IAF MD 6:2014 Appli-
cation of ISO
14065:2007
 RG-15 Regulation for
the accreditation of
greenhouse gas emis-
sion Verification Bod-
ies (03-12-2012)
Public procurement Third-party verification for the Anti-Corruption RINA Check
Code Legislative Decree. purposes of validation of pro- (Italian) Authority
163/2006 jects for public tender contracts (ANAC)

Public procurement Reg-

ulation (Presidential De-
cree 207/2010)
Legislative Decree. Railway Interoperability Certifi- Ministry of RINA Services (Railways)
191/2010 (implementa- cation of subsystems and com- Transport and In-
tion of EU Directive EC ponents frastructures
2008/57)
National Agency for Rail- Independent third-party safety ANSF RINA Services (Railways)
way Safety (ANSF) verification (VIS)
Guidelines for the quali-
fication of Independent
safety verifiers
EU Regulation N. Certification of personnel re- Ministry of RINA Services (Railways)
445/2011 sponsible for the maintenance Transport and In-
of railway wagons frastructure /
ANSF
ANSF Guidelines for the Risk Assessment in the Railway ANSF RINA Services (Railways)
recognition of Bodies for Sector
Risk Assessment in ac-
cordance with EU Regu-
lation N. 402/2013

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EU Regulation N. Ship classification and certifica- - EMSA RINA Services

391/2009 tion - EU Commission
ISO/IEC 17020:2012 - Ministry of In-
ISO 9001 frastructures
and Transport
- Flag admin-
istrations
- QACE (DEKRA)
IACS QSCS Ship classification and certifica- IACS RINA Services
tion
Italian regulations Periodical inspections (pressure - Ministry of Eco- RINA Services
DM 81/2008 vessels, lifting appliances, etc.) nomical Devel-
DM 11/04/2011 opment
DPR 462/2001 - Ministry of
ISO/IEC 17020:2012 Health
- Ministry of La-
bour
EU product directive EC marking and product con- - Ministry of Eco- RINA Services
Reg. (CE) n. 756/2008 formity certification (lifts, nomical Devel-
Decision 768/2008/CE pleasure vessels, building ma- opment
ISO/IEC 17065:2012 terials, machinery, ATEX, MED, - Ministry of In-
PED, PPE, etc.) frastructures
and Transport
- Ministry of La-
bour
- Ministry of In-
ternal Affairs
- ACCREDIA

Table 1

6. IMPARTIALITY THREAT MANAGEMENT

6.1 Introduction
The Impartiality threat risk control system, for the RINA Group companies, is mainly based
on the following:

▪ Risk Assessment Document (Group);

▪ Committee for Safeguarding Impartiality (RINA Services, Agroqualità and foreign
companies reporting to RINA Services);
▪ Resolutions of the Corporate Compliance Board (Group).
6.2 Impartiality threat Risk Assessment Document for RINA Group companies
(RAD)5
As from 24th October 2005, the RINA Group has adopted a RAD, the aim of which is to
identify the threats to Impartiality for the various companies of the Group and as regards
their mutual relations.
This is periodically updated in order to take into account any modifications made to the
organisational structure as well as any indications provided by the Accreditation Bodies and
the controlling authorities.
The most recent version (no. 22 dated 27th November 2015) considers the current Group
structure, defines the interrelations among the various companies, identifies, as for the
four macro-categories of threats (from own interests, self-assessment, familiarity and in-
timidation) “sensitive activities” that can hypothetically cause an Impartiality risk and
makes reference to Procedure GP-AUD-RIS-01 for the evaluation of intrinsic and residual
risk.

5 This can be consulted on the Lotus Notes database: RINA S.p.A. icon (M.S.D.)=>References=>RINA=>”
Impartiality threat Risk Assessment Document for RINA Group Companies”.

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Furthermore, it defines the revision process of the Group RAD, which includes the direct
involvement of the controlled companies as regards the detailed definition of possible risks
and their management.
For this purposes, controlled companies may establish ad-hoc functions.
The Group RAD consists of a main text and of several addenda, one for each controlled
company or group of companies with similar activities.
The RAD of each controlled company or group of companies with similar activities consists
of the same main text and of the relevant addendum.
A third compenent of the RAD is the digital archive, which allows the collection, as for each
Group company and for each sensitive activity, of the control points expressed in the com-
pany procedures and instructions (the so-called “protections”) as well as the controls in-
troduced in the managerial IT applications.
For each sensitive activity the impact and the probability of occurrence are defined and
that, once they have been appropriately evaluated, allow the calculation of the inherent
company risk.
The evaluation of the risk mitigation protections allows the definition of the residual risk
that is brought to the attention of the top company management in case this risk results
as being “medium” or “high”.
The evaluation of the protection is assigned to the RINA S.p.A Internal Audit department
which collects also the reports written by the Surveillance Body.

6.3 Committee for Safeguarding Impartiality (CSI)

The RINA Services and Agroqualità Committee for Safeguarding Impartiality (including all
foreign companies which operates in the certification market) has the aim of guaranteeing
the Impartiality of the activities carried out (certification of management systems, products
and personnel, validation/verification of CDM projects, etc.) from biased interests and,
therefore, to allow the participation of all the entities significantly involved in such activi-
ties.
In particular, the CSI carries out the functions foreseen by the regulations relating to the
certification bodies:
• To provide support for the development of impartiality policies relating to the com-
pany’s own certification activities;
• To contrast all tendencies that permit commercial aspects or those of any other na-
ture preventing a coherent and objective performance of certification activities;
• To provide support as regards aspects that may influence trust relating to certification
activities, including transparency and public perception;
• To conduct a re-assessment relating to the Impartiality of auditing procedures, cer-
tifications and decisional processes at least once a year.

6.4 Corporate Compliance Board

In consideration of the number, the complexity and the continuous diversification and evo-
lution of the regulations applicable to the activities carried out in the RINA Group it is not
possible to use a single model to manage all possible cases relating to the safeguard of
Impartiality and the prevention of any possible conflicts of interest,.

In the light of the above, a Corporate Compliance Board has been established, which has
the following duties and responsibilities:
To ensure that the activities carried out by the Companies belonging to the RINA Group
are performed in compliance with the requirements of:

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a) impartiality6 indicated in the applicable standards and regulations; and

b) integrity, confidentiality, fair marketing issues.
The above is achieved through:

1. Definition and continuous updating of methodologies, procedures and instru-

ments to safeguard impartiality within the RINA Group;

2. Identification on an on-going basis of risks to impartiality arising from activities

and relationships 7, also through the analysis of particular cases brought to the
attention of the Board by the Companies involved or by the Internal Audits Func-
tion;

3. Monitoring of regulatory developments and dissemination of information to the

interested companies of the Group;

4. Relationship with the Committee for Safeguarding of Impartiality and Internal

Audit function;

5. Dissemination within the Companies of the RINA Group of information on impar-

tiality and conflict of interest management, e.g. through the development of in-
structions and guidelines.

6. Supporting the CEO in monitoring the Internal Audit function independence, ef-
ficiency, adequacy of its resources for the assigned tasks, assessing the com-
pleteness and adequacy of workplan, and periodical reports in view of its presen-
tation to the CEO;

7. Monitoring and periodically reviewing the implementation within the RINA Group
of the IFIA 8 compliance principles 9 and relevant compliance programme adopted
by the RINA Group

8. Pronouncing on any other matter related to the above submitted to it by the CEO
of the RINA Group or a Company of the RINA Group.

7. GUIDELINES
7.1 Foreword
The concepts of impartiality and impartiality threat management are referred to in the
main regulations that govern the activities carried out by the bodies that perform third-
party conformity assessment activities and which, as such, must be unrelated to the person
or organisation that provides the subject of the evaluation and must also have no interests
as a user.
Impartiality is associated with the presence of objectivity.
Objectivity means, in turn, that no conflicts of interest exist or that these have been re-
solved in order not to negatively influence the consequent certification/inspection body
activities.

6 Impartiality means that conflicts of interest do not exist or are resolved so as not to adversely influence sub-
sequent activities.
7 A relationship that threatens the impartiality can be based e.g. on ownership, governance, management, per-
sonnel, shared resources, finances, contracts and marketing (including branding).
8 International Federation of Inspection Agencies
9 In particular relating to integrity, conflict of interest, confidentiality, anti-bribery and fair marketing

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One of the most common threats to impartiality is represented by self-assessment, that

comes from a person or a body which re-examines one’s own work or by the presence of
own interests, that means the interference/coincidence/similarity between the interests
of the controller and of the interested party involved in the certification/inspection.
Self-assessment is generally associated with consultancy services, intended as the partic-
ipation in the design, implementation or maintenance of a system or product subject to
certification/inspection.
Maintaining relationships within a Group of companies does not necessarily represent a
conflict of interests, but it requires the careful management of the same in order to avoid
that these cause threats to the impartiality of entities that carry out third-party activities.
A relationship that threatens Impartiality may derive from factors such as the following:
▪ Ownership;
▪ Governance;
▪ Management;
▪ Personnel;
▪ shared resources;
▪ Financial resources;
▪ Contracts;
▪ Marketing.
In the presence of such threats, the body must be capable of showing how they can be
eliminated or mitigated, by dealing with these factors appropriately, usually by carrying
out a risk analysis and the establishment of a Committee for Safeguarding Impartiality .
The fact that the relationships within a Group do not necessarily indicate a conflict of in-
terests can be confirmed also by the commercial strategy of the main RINA Group com-
petitors within the CE-TIC sector10.
The RINA Group competitors started out as bodies operating within the TIC sector and,
over the years, they have gradually expanded their activities to include the CE sector, by
means of the internal development of skills or the incorporation of specialised companies.
The internal development of skills has often brought about the creation of separate com-
panies (spin-offs), such as companies dedicated to Business Assurance, companies dedi-
cated to a specific market or companies that offer exclusively engineering services.
Also in the case of incorporations, in most cases the companies that operate in the two
sectors remain separate entities.
In order to reduce the level of risk, competitors deal with ownership and governance and
they tend to keep the TIC companies within the Group formally separate from those which
offer engineering or consultancy services.
The RINA Group has adopted a similar approach, at both a company and an organisational
level, as already indicated in Sections 2 and 3 of this document, conveying this system
outside in a clear and coherent way.
RINA S.p.A. is the holding company that does not carry out its own operational activities.
It provides other Group companies with staff services (HR, Administration, Marketing,
Communications, Legal departments);it carries out control and coordination activities for
subsidiaries exclusively from an administrative and financial point of view with the exclu-

10 In this study, the following companies have been taken into consideration: ABS, DNV, GL, LRS, Applus, In-
tertek, SGS and TUV Sud

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sion therefore of any technical and operational control and coordination activities. Moreo-
ver, by means of its own supervisory bodies (Surveillance Body, Corporate Compliance
Board, the Internal Audit) as well as its own procedures (Impartiality, RAD), it collects
information relating to the activities carried out by the Subsidiaries so as to facilitate veri-
fication on behalf of the respective administrative and supervisory bodies as regards the
compliance of regulations on the subject of Impartiality.
Despite the general principles mentioned above, as regards the management of relation-
ships that may cause a threat to Impartiality, it is necessary to take into account some
essential rules set by the regulations themselves (generally specified as “prohibitions”) as
regards the relationships between the activities of the certification/inspection and body
(TIC) and any consultancy, design and engineering activities (CE) carried out by the same
body or by other entities within the Group which the certification/inspection body is part
of.
With reference to the activities carried out by the RINA Group, the main rules are summa-
rised in the following paragraphs.

7.2 Third-party inspections (ISO/IEC 17020)

i. The Type A inspection body cannot carry out inspection activities if the same body has
been engaged in the design, manufacture, supply, installation, purchase, ownership,
use or maintenance of the items inspected or similar competitive items 11;
ii. The type A inspection body that carries out project verification activities for the pur-
poses of validation relating to public works is strictly forbidden to carry out design, its
co-ordination, construction supervision, safety co-ordination and testing, also in rela-
tion to projects that are not submitted to its assessment 12;
iii. The inspection body must not be connected in any way to a separate legal entity in-
volved in consultancy services relating to the items inspected or similar competitive
items. For this purpose, the relevant “connection” can be created through:
a. common ownership, except where the owners have no ability to influence the
outcome of an inspection (for example a holding company consisting of sev-
eral separate legal entities, sister companies, under a common mother com-
pany, where neither the sister companies nor the mother company can influ-
ence the outcome of an inspection);
b. Common ownership appointees on the boards of directors, except where these
have functions that have no influence on the outcome of an inspection (for
example a council member nominated by a financial backer with the sole aim
of controlling the company management and he will have no decision-mak-
ing/executive powers);
c. directly reporting to the same higher level of management, except where this
cannot influence the outcome of an inspection;
d. contractual commitments, or other means that may have an ability to influ-
ence the outcome of an inspection.

11 The expression “items inspected or similar competitive items” must be intended as “referring to macro-families
that can be distinguished by elements of similarity, not so much from a technical and technological point of
view, but in relation to the intended use of the inspected entities and to the related economic, commercial
and industrial problem (potential competitiveness)”. This requirement is not stated in the regulation of refer-
ence ISO/IEC 17020 but only in the complementary application regulations developed by the accreditation
bodies”.
12 This requirement is not included in the reference standard ISO/IEC 17020 but only in the complementary
applicative regulations developed by accreditation bodies (in this case Technical Regulation RT-07 developed
by ACCREDIA).

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iv. In order to comply even further with the principle of Impartiality and in the light of the
requirements of Italian public procurement regulations (see also paragraph 7.3), the
two RINA Group entities involved in ISO/IEC 17020 inspection activities (RINA Services
and RINA Check) refrain from carrying out inspection activities on elements that have
been subject to design, manufacture, supply, installation, purchase, ownership, use or
maintenance by another Group company. Therefore, the requirement as of the previ-
ous point is automatically complied with.
v. Furthermore, the RINA Group has developed internal procedures for the preventive
verification, through the consultation of databases, of the possible involvement of com-
panies in projects requiring inspection activities under acrreditation.

7.3 Public Procurement Regulation (Presidential Decree 207/2010)

7.3.1 General
i. The body in charge of project verification activities shall ensure the complete separa-
tion from the technical, procedural, administrative and financial points of view, of in-
spection actvities from other potentially conflictual activites;
ii. The body in charge of project verification activities of a given work shall demonstrate
that it is not having and did not have in the last three years any professional and
commercial relationship with the bodies involved in the design of the work to be veri-
fied;
iii. The Public Procurement Regulation identifies two reasons of incompatibility:
a. For a given work, between the assignment of external verification activities
for the purposes of validation and the execution, for the same work, of the
design, its co-ordination, construction supervision, safety co-ordination and
testing (art. 49.5 of Presidential Decree 207/2010);
b. The body who intends to participate to the verification tender shall not partic-
ipate or have participated directly or indirectly to the tender for the assign-
ment of design and its drafting at any stage (art. 50.4 of Presidential Decree
n. 207/2010). The violation of this limitation will cause the exclusion for five
years from verification activities and the violation shall be communicated by
the responsible for the administrative procedure to the Accreditation Bodies.
iv. Para 7.3.1.iii.a necessarily refers to the same legal entity and as such does not apply
to activities possibly carried out individually by D’Appolonia and RINA Services and
RINA Check 13;
v. The same principle applies to para 7.3.1.iii.b, where the prohibition to participate in
the tender for verification activities for the purposes of validation refers to the same
subject which had attended the tender for the design or its drafting and cannot be
extended to other entities. It is believed that the reference to an “indirect participation”
is not referred to the participation of another entity (e.g. D’Appolonia) but to other
circumstances (e.g. a situation where an entity did not participate directly but as a
subcontractor or through a third party). However, in the absence of a relevant unam-
biguous regulatory scenario and in the presence of different judgements, reference
shall be made to para 7.3.2.

7.3.2 Tender participation

i. As mentioned in 7.2.iv above, as of today RINA Services and RINA Check did not
voluntarily participate – even in the absence of an explicit prohibition - in tenders

13 The governance model adopted by the RINA Group provides for a separation of responsibilities and hyerar-
chical relationships between “CE” and “TIC” activities and strengthen the distinction between the two subjects
involved in the subject activities.

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where another company of the RINA Group (usually D’Appolonia) had carried out de-
sign activity which could be subject to verification;
ii. However, this caution does not appear justifiable in case of simple participation to the
tender, in those case where design activities had not been assigned to another com-
pany of the RINA Group. It may in fact happen that design activities are eventually
assigned to another body and in this case the abstention of RINA Services or RINA
Check from the tender for verification activities would cause the loss of a legitimate
opportunity and reduce the competition level, to the detriment of the contracting en-
tity.
iii. In order to manage in accordance with 7.2.iv (abstention) the case where design ac-
tivities are eventually assigned to D’Appolonia, RINA Check indicates in the tender
documentation for design verification activities its corporate connection with one of
the applicants in the already issued but not yet assigned tender for design activities;
iv. Similarly, in order to manage in accordance with 7.2.iv (abstention) the case where
verification activities are eventually assigned to RINA Check, D’Appolonia indicates in
the tender documentation for design activities its corporate connection with one of the
applicants in the already issued but not yet assigned tender for design verification
activities;

7.3.3 Construction supervision

i. According to 7.3.1.iii.a, the body in charge of verification activities is in a position of
conflict of interest as regards design, its coordination, construction supervision, safety
coordination and testing, relevant to the same project subject to verification; this sit-
uation happens when the activities are carried out by the same entity and the verifi-
cation body in involved in both activities;
ii. A reference to an “indirect” involvement of the verification body exists in Art. 50.4,
but it is relevant to the design activity only and not to construction supervision, safety
coordination or testing. The 5-year exclusion from verification activities is envisaged
only for direct or indirect participation of the verification body to design activities (and
not to other activities different from design, including construction supervision);
iii. In the light of the above, no incompatibility exists between the participation of D’Ap-
polonia in tenders for construction supervision of on-going works, whose design activ-
ities (not carried out by D’Appolonia) had been verified by RINA Services or RINA
Check.

7.4 Management system certification (ISO/IEC 17021)

i. The certification body and any part of the same legal entity and any entity under the
organizational control of the certification body shall not offer or provide management
system consultancy. This is strictly forbidden, and this also applies to clients/systems
that are not covered by certification activities carried out by the relative body;
ii. A certification body’s organizational control shall be one of the following:
 Whole or majority ownership of another entity by the certification body;
 Majority participation by the certification body on the board of directors of another
entity;
 A documented authority by the certification body over another entity in a network
of legal entities (in which the certification body resides), linked by ownership or
board of director control;

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ii. The certification body and any part of the same legal entity shall not offer or provide
internal audits to its certified clients. The certification body shall not certify a manage-
ment system on which it provided internal audits within two years following the end of
the internal audits; in the case in which the internal audit activities have been carried
out, for example, by a related legal entity, the certification body may continue with
the certification procedure after having carried out the relative analysis and any miti-
gation of Impartiality risks at tolerable levels. Where, despite the mitigation of risks,
the threat to Impartiality remains intolerable, the certification body cannot proceed
with the certification unless two years have passed since the conclusion of the audits.
iii. Accreditation regulations allow a separate legal entity related to the certification body,
on which the certification body has not an organizational control, to carry out consul-
tancy services and internal auditing, on the condition that the impartiality of the cer-
tification body is guaranteed;
iv. The accreditation regulation imposes the Certification Body to evaluate and manage
the risks of conflict deriving from the relationship with the entities that have provided
consultancy services and internal auditing on the system, whatever this relationship
may be (therefore, not only of a corporate nature). The accreditation bodies may ac-
cept that the Certification Body attests a system on which a related entity (belonging
to the same company group but on which the certification body does not have organ-
izational control) has carried out consultancy services;
v. RINA Services (and also Agroqualità) may carry out certification and internal auditing
activities on systems that are/have been subject to consultancy services from another
legal entity belonging to the RINA Group, on which RINA Services does not have or-
ganizational control. This is possible due to the present model of governance and or-
ganizational structure of the Group (which ensures the complete separation between
CE and TIC services) and provided that the threat to impartiality is managed through
ad-hoc mechanisms and procedures for the exchange of information within the Group
and with the Clients, defined and agreed with the Accreditation body. Similarly and
subject to the same conditions, D’Appolonia may carry out consultancy activities on
management systems certified or under certification by RINA Services (and also
Agroqualità) 14.

7.5 Product, process or service certification (ISO/IEC 17065)

i. The certification body and any part of the same legal entity and entities under its
organisational control shall not be involved in the design, manufacturing, installation
and distribution of the product, process or service that is the subject of the certification
activities and they cannot offer consultancy services to their own clients relating to the
product, process or service that is the subject of such certification activities;
ii. A distinct legal entity belonging to the Group may carry out design activities /consul-
tancy services also on the product that is the subject of certification procedure, on the
condition that the Impartiality of the certification body is not jeopardised. For example:
▪ The certification body’s management personnel and personnel in the review and
decision relevant to the certification shall not be involved in the activities of the
separate legal entity;
▪ The personnel of the separate legal entity shall not be involved in the management
of the certification body or in the certification process;
iii. RINA Services may use the personnel of another legal entity of the Group for the
verification of pressure equipment for PED certification purposes, provided that the

14 See instruction ITT-SYS01-ALL-01 Rev. 0 “Guidelines for the management of communications between RINA
Services and D’Appolonia on contracts.

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same personnel had not carried out consultancy activities for the manufacturer of the
product undert certification.
iv. The certification body’s activities shall not be marketed or offered as linked with the
activities of an organisation that provides consultancy. A certification body shall not
state or imply that certification would be simpler, easier, faster or less expensive if a
specified consultancy organization were used.
7.6 Clean Development Mechanism (CDM)
i. According to the regulations of the accreditation body (UNFCCC), the Designated Op-
erational Entity (DOE), including the locations where the DOE has delegated the oper-
ational activities (presently RINA Brasil, RINA China and RINA India) shall not under-
take validation and/or verification/certification of CDM project activity if the DOE or
another part of the same legal entity , a parent organization, an entity belonging to
the same group or a related body has been engaged in any function relating to the
CDM project activity. It is, therefore, strictly forbidden to carry out the two activities
(consultancy services and certification) within the Group on the same CDM project;
ii. Other entities related to the DOE may carry out consultancy services/design activities
on CDM projects that are not subject to validation/verification on behalf of the DOE;
iii. According to the interpretation currently adopted by RINA Services, the DOE refrains
from directly carrying out consultancy services/design activities also on projects that
are not subject to its validation/verification;
iv. The DOE shall not carry out both validation and verification/certification activities for
the same project, unless this is explicitly permitted by the applicable requirements.

7.7 EU Commission Regulation No. 600/2012 (verification of greenhouse gas

emission and tonne-kilometre reports pursuant to directive 2003/87/EC)

i. The verifier and any part of the same legal entity, must not offer consultancy services
or technical assistance to its own verified clients15;
ii. The verifier and other entities related to the body can carry out the abovementioned
activities for an organisation that is not subject to verification;
iii The regulation forbids the verifier from carrying out verification activities for an organ-
isation if other related entities have carried out consultancy services or technical as-
sistance for the same organisation. In facts, it identifies as situations in which the
impartiality of the verifier is jeopardised the case in which the relationship between
the verifier and the consultancy company, the technical assistance body or the other
organisation is based on common ownership and governance, common management
or personnel, shared resources, common funds, contracts or marketing, or rather com-
missions on sales or any other incentive earned for the signalling of new clients.
iv. Currently, RINA Services waives carrying out verification activities when other related
entities have carried out the abovementioned activities, consequently, the requirement
as of the point (iii) is automatically fulfilled;
v. The activities of the certification body must not be published or offered in connection
with the activities carried out by an organisation providing consultancy services (so-
called “co-marketing”).

15 In order to develop part of the monitoring and communication process described in the monitoring plan ap-
proved by the competent authority, including the elaboration of the monitoring method, the elaboration of
the provider or air operator communication as well as the drafting of the monitoring plan or to develop or
maintain the system updated so as to monitor and communicate the tonne-kilometre data and emissions.

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vi. Finally, the verifier must be independent from the bodies that carry out emission al-
lowance trading in compliance with the system for greenhouse gas emission allowance
trading established according to Art. 19 of the 2003/87/EC directive;

7.8 ISO 14065:2013 (verification of greenhouse gas inventories in order to com-

ply with ISO 14064-1:2013)
i. The verifier must not verify an inventory in the case where it has provided consultancy
services supporting the assertion of greenhouse gas emissions;
ii. According to ISO 14065, the verifier and other related entities may carry out consul-
tancy services for an organisation that is not a client as regards verification activities.
The ACCREDIA RG-15 regulation gives quite a restrictive interpretation of the require-
ments of the ISO 14065 regulation and it seems to introduce an absolute/structural
ban for the certification body and any other part of the same legal entity to offer a)
consultancy services which focus on the development or on the maintenance of mon-
itoring systems and methods relating to GHG emissions in voluntary schemes or in a
binding EU ETS context; b) other consultancy services or technical assistance where
the economic dependency on the specific verification activity could jeopardise the ver-
ifier’s independence.
iii. Currently, RINA Services waives carrying out consultancy services in this field; there-
fore, the requirement as of the previous paragraphs is automatically fulfilled;
iv. The regulation indirectly forbids the verifier from carrying out verification activities if
other related entities have carried out consultancy services; in facts, it considers as
situations in which there is a risk of Impartiality: a relationship based on ownership,
governance, management, personnel, shared resources, financial resources, con-
tracts, market strategies and the payment of a sales commission or other incentive in
order to encourage new clients.
v. Currently, RINA Services waives carrying out verification activities when other related
entities have carried out the abovementioned activities, consequently, the requirement
as of the previous point is fulfilled;
vi. RINA Services cannot offer internal audit services relating to GHG inventories belong-
ing to their own verified clients.
vii. The activities of the certification body must not be published or offered in connection
with the activities carried out by an organisation providing consultancy services (so-
called “co-marketing”).

7.9 Energy Management Systems (EMS) certification (ISO 50001)

i. The requirements of paragraph 7.3 relevqnt to management system certification
(ISO/IEC 17021) apply;
ii. With reference to the minutes of the meeting of ACCREDIA Environment Working
Group of 9 November 2015: “In case of EMS certification, the energy audit – which
coincides with the energy analysis mentioned in para 4.4.3 of UNI EN ISO 50001:2011
standard – is equivalent to the initial environmental verification mentioned in UNI EN
ISO 14001 standard and requires in-depth ad-hoc evaluations. ACCREDIA auditors will
therefore verify that these verifications are carried out with the same level of compe-
tence required for ISO 50001 auditors;
iii. In the light of the above, energy audit and certification carried out by the same entity
for the same Client represents an unacceptable threat to impartiality. Therefore, the
delivery of certification services for a given Client is not compatible with the delivery
of energy audit services;

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iv. The same principle applies to energy audits carried out in accordance with ISO 50002
standard.

7.10 Railway sector certification

7.10.1 Foreword
The RINA Services railway sector basically works within two completely different certifica-
tion fields even if they are (obviously) connected: on one hand, the railway interoperability
(both within the high-speed railway sector and in that relating to the so-called conventional
speed railway sector) and on the other hand the compliance to regulations on a national
level.
The first field regards, in particular, technical regulations issued at a European level (de-
fined as Technical Specifications for Interoperability, in short TSIs) that tend to guarantee
that the different railway transport components comply with homogeneous criteria (Legis-
lative Decree dated 8th October 2010, no. 191 implementing the 2008/57/EC and
2009/131/EC directives relating to the interoperability of the rail system within the com-
munity).
The second field refers to the national railway transport, also implementing the TSIs, as
well as the aspects that, in any case, are not subject to the discipline contained in such
TSIs (Legislative Decree dated 10th August 2007, no. 162 relating to the "Implementation
of the 2004/49/EC and 2004/51/EC directives regarding the safety and the development
of community railways ").
In the first field, RINA Services (QTL) works as a Notified Body (“NoBo”) i.e. “body in
charge of evaluating the conformity or the suitability to use interoperability components or
to establish EC subsystem verification procedures”.
Instead, it works in the second field as an Independent Safety Inspector (“VIS”) recognised
by the Italian National Agency for Railway Safety (ANSF), as a “body in charge of evaluating
the conformity of a component to the relative safety type approval certification require-
ments as well as the suitability to use this, and/or to establish the relative type approval
certification procedure”.

7.10.2 NoBo independence regulations (Legislative Decree 191/2010) 16

i. Impartiality and independence: The body, its director and personnel in charge of car-
rying out verification activities cannot intervene neither directly nor as agents as re-
gards the design, manufacturing, construction, marketing or maintenance of interop-
erability components or subsystems, nor in the operation of these. This does not ex-
clude the possibility of an exchange of technical information between the manufacturer
or the constructor and the body.
ii. Impartiality and professional integrity: The body and the personnel in charge of the
control activities must carry out the verification operation with the utmost profession-
alism and technical competence and they must not be under any pressure or stress,
in particular that of a financial nature, which could influence their judgement or the
results of their inspection, in particular those coming from people or associations of
people interested in the results of such verifications. In particular the body and the
personnel in charge of the verifications must be independent from a functional point
of view from the authorities appointed as regards the issuing of the authorisations
concerning commissioning within the context of the present decree, of licences within
the context of legislative decree no. 188 dated 8th July 2003, regarding railway com-
pany licences and safety certificates within the context of legislative decree no. 162

16 Attachment VIII of Legislative Decree 191/2010

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dated 10th August 2007, as well as the entities in charge of investigations in case of
accidents.
iii. Instead, as for the laboratories used by the body, the same attachment foresees that
“the independence of the personnel in charge of inspection must be guaranteed. The
retribution of each agent must not depend neither according to the number of inspec-
tions nor according to the results of the latter”.

7.10.3 Italian National Agency for Railway Safety Guidelines (ANSF)

i. In order to obtain and maintain the qualification as VIS, the verifier must comply with
the requirements foreseen for the type A inspection bodies as of the ISO/IEC 17020
regulation, achieve and maintain the relative accreditation;
ii. The VIS and its technical personnel must not be related to a party that is directly
involved in design, production, supply, installation, purchase, possession, use and
maintenance activities relating to the items inspected or similar competitive items (as
foreseen for the Type A Inspection Bodies by ISO/IEC 17020, according to which the
VIS must be accredited);
iii. A VIS cannot be classified as such, where another part of its same organisation is
directly involved in activities/situation relating to the design, production, supply, in-
stallation, incorporation, possession, use and maintenance on the items inspected or
similar competitive items, where the abovementioned other part does not have a dis-
tinct legal identity from that of the VIS, without prejudice however to the criteria of
separation mentioned above;
iv. The VIS inspectors (either internal or external employees) must not have carried out
during the previous two years any evaluation activities, nor can they carry out during
the following two years activities relating to the design, production, maintenance and
marketing of the product subject to verification.

7.10.4 Summary of observations

Essentially, the QTL structure is obliged to be submitted to a triple conformity verification
due to the i) criteria contained in Legislative Decree 191/2010; ii) VIS Guidelines defined
by ANSF; iii) accreditation according to the UNI CEI EN ISO 17020 regulation that is a
necessary requirement in order to be recognised as a VIS.
As for the requirements contained in the ISO 17020 regulation, please refer to what has
already been mentioned at point 7.2 relating to the Inspection Bodies. With reference to
the further binding disciplines, it can be observed that, while attachment VIII to Legislative
Decree 191/2010 states the incompatibility of only the body (NoBo), the ANSF Guidelines
extend the concept of threat also to the separate yet related entity (see no. 2 of the pre-
vious par. 7.9.3). Moreover, the same incompatibility regards not only the design, manu-
facturing, supply, installation activities, etc. relating to the item inspected, but also to
“similar competitive items”17.
In fact, the public bodies in charge of surveillance duties (ANSF and the Ministry of Infra-
structure) have identified a threat to the Impartiality of RINA Services as NoBo and as VIS
(and therefore precluding an operation) in the presence of D’Appolonia within the Group,
with specific reference to cases where this latter carries out design activities on an item
which was subsequently subject to QTL verification. RINA Services has therefore been
asked to implement countermeasures aimed at avoiding the intervention of the same in
cases where D’Appolonia had carried out design activities.

17 The expression “entities similar to those which have been inspected and which are in competition with these”
must be intended as “referring to macro-families that can be distinguished by elements of similarity, not so
much from a technical and technological point of view, but in relation to the intended use of the inspected
entities and to the related economic, commercial and industrial problem (potential competitiveness)”.

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In particular, such bodies have requested RINA Services to formalise the way it intended
to manage such threat with particular reference to the communication tools between the
two companies that allow the prevention of the abovementioned cases and therefore their
occurrence in the future. RINA Services has fulfilled the requests by adopting the procedure
IS-BRA-CER-01 in which the cases of possible interference between the activities carried
out by D’Appolonia and the verification duties performed by Rina Services S.p.A. as well
as the abovementioned communication methods are specified.

7.11 Regulation 391/2009 (ship inspection activity recognition)

i. European legislation that refers to the corresponding IMO regulations is, in turn, rele-
vant for national authorisations released by the Flag Administrations; it lays down that
the Recognised Body must be independent from the entities that are interested in its
inspections: shipowners, shipbuilders, or other entities engaged commercially in the
manufacture, equipping, repair or operations of ships;
ii. Moreover, it foresees an obligation of abstention for the Recognised Body if it is iden-
tical to or has business, personal or family links to the ship-owner or operator. This
incompatibility shall also apply to surveyors employed by the recognized organisation;
iii. The regulation does not specify what it intends by “control”, or by “business links” and
it leaves therefore wide scope for interpretation, by EMSA and the European Commis-
sion during the audit and verification phase of the requirements;
iv. RINA Services (and RINA S.p.A. beforehand) have always surpassed the close exami-
nation of the European and national authorities as regards general independence (the
absence of control) and compliance with the obligation of abstention, also thanks to
the governance structure that makes the operational structure accountable for control
“waterproofing” with respects to any interests of professional entities (ship owners,
shipyards) present in both the Board of the Registro Italiano Navale as well as RINA
S.p.A. In some cases, EMSA and the European Commission have requested interven-
tions in order to enhance the guarantees of impartiality and to avoid the possibility of
being biased, even if only occasionally, by such entities. These requests have been
satisfied promptly also by organizational and governance modifications.
v. Apart from the general and specific requirements foreseen here, the Regulation re-
quires that the Recognised Body must have an internal quality system in conformity
with ISO/IEC 17020:2004 and ISO 9001:2000 regulations. Therefore, the incompati-
bilities and the limits described in the section relating to inspection activities are also
valid for the purposes of such activity.

8. CONCLUSIONS
What is stated in the previous points from 1 to 7 defines the lines of conduct to follow
during the performance of “TIC” activities in the presence of concurrent “E” activities within
the Group.
It is extremely difficult to include all the activities and all the possible situations of conflict
in a general model, also in consideration of the complexity of the regulations of reference,
the correlated rules issued by the accreditation bodies and their continuous evolution.
Sometimes the regulations of reference contain precise indications. For example, the CDM
Accreditation Standard prohibits the Designated Operational Entity (DOE) to validate CDM
projects in which it has carried out consultancy services and it unmistakably extends such
prohibition also to other entities of the same Group. In a way that is just as unmistakable
as this, it allows other entities related to the DOE to carry out consultancy services on CDM
projects that are not subject to validation on behalf of the DOE.

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ISO 17021 standard does not allow a certification body, any other part of the same legal
entity and any other entity under its organizational control to provide consultancy services
relating to quality management systems, regardless of the fact that the system has been
accredited or not by the same body.
The relevant regulations developed by the Accreditation Bodies do not provide indications
that are just as clear and unmistakable as regards any consultancy services provided by
other Group companies.
The present model of governance and organizational structure of the RINA Group ensures
the separation between RINA Services and the other Companies of the Group which deliver
CE services as well as the management of threat to impartiality through specific proce-
dures.
In the light of the above, RINA has decided to:
i. to voluntarily abstain from the delivery of certain activities (like e.g. those indicated in
paragraphs 7.2.iv and 7.6.iii);
ii. RINA Services (and also Agroqualità) may carry out certification and internal auditing
activities on systems that are/have been subject to consultancy services from another
legal entity belonging to the RINA Group, on which RINA Services does not have or-
ganizational control, while ensuring that the threat to impartiality is managed through
ad-hoc mechanisms and procedures for the exchange of information within the Group
and with the Clients, defined and agreed with the Accreditation body.
However, it cannot be excluded beforehand that some of these limitations may be removed
in the future, following a careful evaluation of the associated risks to Impartiality and of
the consequent identification of suitable mitigation measures relating to the risk itself.
In the light of the above, as already mentioned, the Corporate Compliance Board has been
established that analyses specific situations that may possibly be brought to its attention
and it monitors regulatory development.
Then, the entities belonging to the various Companies of RINA Group shall contact this
Body to resolve issues that, presenting a risk of conflict of interest within the Group or
even coming from outside elements, cannot be easily and promptly resolved on the basis
of the reference standards or these Guidelines.

The Corporate Compliance Board

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