The Hong Kong Council for Testing and Certification (HKCTC), Hong Kong Accreditation Service (HKAS) and ICAC co-organized a seminar entitled “Integrity Management in Testing and Certification Industry” on 27th June 2016. One of key strengths of the testing and certification industry in Hong Kong is its high level of credibility, which gives confidence to users and consumers. The seminar aimed to bring together experts from ICAC, the testing and certification (T&C) industry, as well as professional bodies to share experiences and information about integrity management in T&C industry from different perspectives. Before the seminar, I took a photo with Dr. John Ho (Left) and Dr. Tommy Lo (Centre) for memory.
In the beginning, Prof. Albert Cheung (Chairman, HKCTC) gave a welcome speech. He said “Integrity is the most important of the Testing and Certification Industry and need to train all staff in the industry”. Then he introduced the aims of HKCTC and the coming events such as ISO 27001 workshop, MedTest and Construction test seminars.
Then all guest speakers took a group photo.(Left: Dr. Tommy Lo (HKICA), Mr. Michael WK Lee (ACML), Ms. Anna Lam (ICAC), Prof. Albert Cheung (HKCTC), Mr. Felix Chan (HKTIC), Dr. Tony Lee (OUHK) and Dr. John Ho (HKAS))
The first speaker was Ms. Anna Lam (Deputy Executive Director of Hong Kong Business Ethics Development Centre, Independent Commission Against Corruption (ICAC)) and his topic entitled “Professional Integrity and Corruption Prevention”. She said the competitive edge of Hong Kong’s T&C industry were “High Professional Integrity” and “Good Corporate Governance”.
Then she shared some real cases of corruption in T&C industry included “Forging Certificates”, “Forging test reports”, “Inspectors accepting bribes”. There were some Points-to-note including:
- Undermine the testing and inspection system
- Breach of trust of the public and employer
- Affect interests of stakeholders (company, clients colleagues, other suppliers, customers)
- Public safetyThe following diagram showed some common integrity risks in T&C industry.
After that Ms. Anna Lam introduced three tests of professional integrity that was Legal Test, Compliance Test and Sunshine Test.
1) Legal Control over Corruption
- Prevention of Bribery Ordinance (Cap. 201)
- Section 9: Corrupt transactions in private sector (4A – Agent, Advantage, Act and Approval)
- Section 11 and 19: No defence to solicit / accept any advantage
- Section 8: Offering advantage to public servants during official dealings
- Section 9(3): Use of False documents
2) Compliance – Administrative Control over Malpractices
- HKAS Accreditation Criteria
- International Standards such as ISO 17025 / 17020 / 17021
- Professional Code of Ethics (e.g. HKTIC, HKICA, HKIE)
- Company Code of Conduct3) Sunshine Test – Disclose decisions openly without misgivings
At the end, Ms. Anna Lam introduced Corruption Prevention Plan named “Corporate Ethics Compass” which included “Leadership”, “Training”, “Control Systems” and “Code of Conduct”.
The second speaker was Mr. Felix Chan (Chairman, HKTIC) and his topic was “Integrity Management of Conformity Assessment Bodies”. Firstly, Felix explained the definition of Integrity that is “Adherence to moral principles and code of conduct”. For conformity assessment bodies (CAB), its code of conduct requirements were specified in HKAS Supplementary Criteria No. 6.
Then Mr. Felix Chan discussed different types of misconduct in T&C industry.
1) Unprofessionalism – e.g. not fair enough, confidentiality broke
2) Undue benefit – e.g. conflict of interest
4) In breach of law
Why it is difficulty of prevention of misconduct? Felix pointed out four factors below.
1) Quality Control is not possible
4) Influence of non-employees
After that Felix introduced Integrity Management with four key elements.
1. Integrity Culture – It needs Leadership. (Felix said沒有打敗仗的兵, 只有打敗仗的將軍.)
2. Education – Orientation and Mentoring
3. Governance and control – Covert inspection, independent audit, job rotation & LIMS4. Communication and support – avoid undue pressure, management site walk, whistle-blower policy
Mr. Michael KW Lee (Chairman, Association of Construction Material Laboratories) was the third speaker and his topic named “Effort in Maintaining and Enhancing Integrity in Construction Material Laboratory”.
Mr. Lee said there were three elements of Integrity and they were Impartiality, Honesty and Confidentiality. He discussed the integrity requirements between professional and law that professional requirements should be much higher than the law (which is foundation).
Then Mr. Lee briefed several potential threats to integrity including test result/report, inspection/audit, conflict of interest, confidential information and advantages/entertainment.
Finally, Mr. Lee explained 3 layers control measurements as follows:
Level 1 – Management Level
- Influenced by: Associated Organization / Clients with good business relationship
- Control Measure: Contract review, Treat the repeat or loyal customer work equally and handled by another management staff
Level 2 – Frontline inspection / testing
- Influenced by: Personal interest – Referral, Commission, Advantages
- Control Measure: Sign Declaration, Video-cam shooting (CCTV), Surprise site surveillance & Training
Level 3 – Outsourcing / Contracting
- Influenced by: Performance of outsourcing / Contracting Inspection Body, Difference in impartiality requirements
- Control Measure: Subcontract shall be approved by senior management & Subcontractor shall declare compliance with the ethical commitments / requirements.
Finally, Mr. Lee suggested the inspection and testing done by 3rd party and direct report to Architect rather than subcontractors.
Dr. Tony Lee (Assistant Professor, Testing & Certification, School of Science and Technology, OUHK) was the fourth speaker and his topic entitled “Development of Professional Integrity in the Testing and Certification Industry”. Firstly, he briefed some core element in T&C programmes which related to Integrity and Ethics.
Then Dr. Lee discussed different motivation ways to his students in T&C Industry. It was not able to experiment such as issue a fake report because of broken the law. He said provision of guide was not enough because “Analysis” was more important! Integrity should be come from people’s heart. Therefore, Dr. Lee discussed with his student using Professional Career and Affecting the World.
He mentioned Environmental Protection, Consumer Protection, Occupational Safety and Health, IP, and Quality Management. Dr. Lee concluded through “Balance” that you should explain to your boss if something wrong and also explain to your colleagues if any observation about ethics, as well as, explain to your customers.
Dr. Tommy Lo (President, Hong Kong Institution of Certified Auditors (HKICA)) was the fifth speaker and his presentation was “Professionalism of Auditor – Core Element of Testing and Certification Industry”. In the beginning, he briefed the QMS audit in Hong Kong based on ISO 9001, ISO 14001, etc. And he questioned what professionalism of auditor is.
He reviewed the ISO 9001 history and different requirement from 1998 procedures focus to 2015 risk based thinking. He thought about Professionalism and Competence of auditor in laboratory assessment, system certification assessment, product certification technical audit and the 2nd party audit. Dr. Lo also pointed out some current problem such as how to contribute to risk and opportunity; internal auditors tend to become bored, management interest tends to fade away because such process was not value adding process.
Then Dr. Lo briefed the risk based thinking in an effective QMS organization should codified into seven broad areas such as Responsibility, Policy, Objectives, Integration, Compliance, Operational Awareness, and Authorities. Then he briefed the risk in construction project and told us audit plan should be considered different factors.
After that Dr. Lo introduced HKICA became a Certification Body for Certification of Persons based on ISO 17024 and accredited by CNAS last month. They were discussing the MOU with CCAA in China Mainland. Moreover, Dr. Lo said IRCA courses were recognized by HKICA. Lastly, he concluded his talk using CCAA statement “Demonstrated Capability and Transmitted the Trust”(証實能力, 傳遞信任.)
Dr. John Ho (Senior Accreditation Officer, HKAS) was the last speaker and his presentation named “HKAS Requirements for Professional Integrity of Accredited Organizations”.
HKAS 002 Regulations for HKAS Accreditation
- Clause 5.7 – an accredited organization shall maintain complete integrity and impartiality in all circumstances
- Clause 5.12 – to have a clear policy in writing concerning the provision or receipt of advantages
- The policy document shall notify its staff the law under Section 9 (Corrupt transaction with agents) of the Prevention of Bribery Ordinance (Cap 201)
- It shall document and implement a code of conduct based on HKAS Supplementary Criteria No. 6
Then Dr. Ho briefed the HKAS Supplementary Criteria No. 6 which was issued in Nov 2011 and the latest edition was published on 1 April 2015. The code of conduct cover elements were stated in this document and showed in the following diagrams.
At the end, Dr. Ho told us the ISO/IEC 17025 would be update in next year and aligned with ISO 9001:2015.
During the Q&A, some points were summarized as follows:
i) Ms. Anna Lam said some case for public service staff depended on their intention and the severity.
ii) Felix said they provided staff handbook with CoC in Chinese and English during Orientation. They also provided refreshment training and coaching.
iii) Michael told us they provided CoC training every 3 months per department because of 400 staff in his company.
HKTIC - http://www.hktic.org/
Previous ICAC involved T&C Seminars:
20101025: Seminar on Support to Testing and Certification Industry - http://qualityalchemist.blogspot.hk/2010/10/seminar-on-support-to-testing-and.html
20111103: Ethical Management Seminar for Testing and Certification Industry - http://qualityalchemist.blogspot.hk/2011/11/ethical-management-seminar-for-testing.html
20131008: HKCTC Seminar on Integrity and Professional Development in Testing & Certification Industry - http://qualityalchemist.blogspot.hk/2013/10/hkctc-seminar-on-integrity-and.html
20140114: ICAC Training Workshop for HKAS Accredited Organizations - http://qualityalchemist.blogspot.hk/2014/01/icac-training-workshop-for-hkas.html
20150713: HKCTC Seminar on Professional Integrity in Testing and Certification - http://qualityalchemist.blogspot.hk/2015/07/hkctc-seminar-on-professional-integrity.html