Complaints and Appeals for Product Certification

1.0 Objective

The objective of this procedure is to establish a consistent and impartial process for receiving, investigating, deciding, and resolving complaints and appeals related to certification activities.

2.0 Scope

This procedure applies to all complaints and appeals submitted by applicants, certified clients, regulators, consumers, market stakeholders, or any interested party regarding:

• Certification decisions, including rejection, suspension, withdrawal, or termination
• Conduct, competence, or impartiality of AQMA CERT personnel
• Conformity of certified products
• Misuse of certification marks or fraudulent use of certificates
• Concerns relating to outsourced activities involved in certification
• Matters affecting impartiality or integrity as referenced in AC-QP-01
• Complaints or appeals that serve as inputs to AC-QP-13 and AC-QP-12

This procedure does not apply to commercial or contractual disputes unrelated to certification integrity unless such disputes impact impartiality or certification credibility.

The procedure shall be publicly available and communicated through AQMA CERT's website and certification agreements and a copy shall be provided to any interested party upon request. Handling of complaints and appeals shall not result in any discriminatory actions.

3.0 Responsibilities

3.1 Head of Product Certification (HOD)

The HOD shall:

• Oversee the complaints and appeals process to ensure impartiality and conformity with ISO/IEC 17065.
• Confirm admissibility of appeals and ensure that committee members or investigators are independent and competent.
• Approve the formation and composition of the Appeal Committee.
• Approve final decisions on appeals and complaints based on objective evidence.
• Determine whether certification status requires grant, suspension, withdrawal, limitation, or continuation.
• Ensure decisions are not made by personnel involved in original evaluations or certification decisions.
• Ensure progress updates are provided to appellants/complainants at appropriate intervals.
• Provide direction where systemic issues, risks to impartiality, or repeated complaints are identified.
• Ensure case outcomes are used as inputs for internal audits and management reviews.

3.2 Quality Assurance Manager / Executive (QA)

The QA shall:

• Receive, acknowledge, register, and track all complaints and appeals.
• Verify completeness of the submitted information and confirm absence of conflicts of interest.
• Maintain the Complaints and Appeals Register and case files in accordance with Records Control (AC-QP-11).
• Coordinate the activities of the Appeal Committee without influencing decision-making.
• Shall keep complainants and appellants informed of case progress, especially when delays or additional investigation steps occur.
• Escalate delayed cases to the HOD and revise the expected completion timeframe, ensuring the appellant/complainant is informed.
• Communicate receipt, progress, requests for evidence, and final outcomes to complainants/appellants.
• Initiate corrective and preventive actions arising from complaints or appeals under AC-QP-14.
• Prepare documentation, minutes, and communication associated with investigations and committee meetings.

3.3 Appeal Reviewer

The Appeal Reviewer shall be responsible for conducting an independent and impartial review of appeals related to certification decisions. The Appeal Reviewer shall:

• Review appeals objectively and independently of the original evaluation, review, and certification decision.
• Examine certification records, evaluation reports, decision files, and applicable certification scheme requirements relevant to the appeal.
• Confirm and declare absence of conflicts of interest prior to commencement of the review.
• Base conclusions and recommendations solely on objective evidence.
• Document review findings, conclusions, and recommendations in a clear and consistent manner.
• Maintain confidentiality and impartiality throughout the appeal review process.
• Submit documented recommendations to the HOD.

3.4 Investigators

Investigators shall:

• Conduct impartial investigations of complaints or appeals assigned to them.
• Review certification files, evaluation evidence, communications, and applicable scheme requirements.
• Request additional information, when necessary, without compromising independence.
• Document investigation findings, causes, and recommendations.
• Ensure they did not participate in original certification decisions or related consultancy.

3.5 Certification Personnel

Certification personnel shall:

• Forward any received complaint or appeal to QA immediately without interpretation or delay.
• Provide relevant records or clarifications requested during investigations.
• Maintain confidentiality and impartiality.

3.6 Complainant / Appellant

The complainant or appellant shall:

• Provide complete and accurate information supporting the case.
• Respond promptly to clarification requests.
• Cooperate throughout the investigation and decision process.

4.1 Appeals Handling

4.1.1 Receiving and Admissibility Review

4.1.1.1 Any applicant or contracted organization may submit an appeal against an AQMA CERT certification decision, including refusal, suspension, or withdrawal of certification.

4.1.1.2 Appeals shall be submitted within fifteen (15) calendar days from receipt of the certification decision, unless justification for delay is provided. The appeal shall clearly identify the decision being contested and provide the basis for the appeal.

4.1.1.3 Upon receipt of an appeal, QA shall promptly register the appeal in the Complaints and Appeals Register (ACQF-06), verify completeness of the submission, and forward the case to the HOD for admissibility determination.

4.1.1.4 The QA shall acknowledge receipt of the appeal within three (3) working days of the date the appeal was received.

4.1.1.5 The HOD shall conduct an admissibility review to confirm that: the appeal relates to AQMA CERT certification activities; the appeal has been submitted within the required timeframe; the appellant is authorized to represent the organization; and the grounds for the appeal are supported by verifiable certification records.

4.1.1.6 If any of these criteria are not satisfied, the HOD may reject the appeal. In such cases, the appellant is formally notified in writing normally within 3-5 working days of receipt of the appeal.

4.1.1.7 The HOD may request additional information from the appellant. If required information is not provided within a maximum of ten (10) working days, the HOD may close the appeal as inadmissible due to insufficient evidence.

4.1.1.8 Where the appeal is determined to be admissible, the HOD shall confirm admissibility and initiate the appointment of an independent appeal reviewer.

4.1.1.9 QA shall assign a unique appeal case identification number and create the case file.

4.1.1.10 All appeal-related records, correspondence, and evidence shall be maintained in a dedicated appeal file and controlled in accordance with the procedure Records Control (AC-QP-11).

4.1.2 Appeal Review Arrangement

4.1.2.1 Upon confirmation of appeal admissibility, the HOD shall appoint a competent and impartial appeal reviewer to conduct the appeal review without undue delay.

4.1.2.2 Appeals shall be reviewed by one or more competent and impartial persons independent of the original certification decision.

4.1.2.3 The appointed appeal reviewer shall be independent of the original evaluation, review, and certification decision related to the appealed case and shall not have provided consultancy services or held employment with the appellant within the preceding two (2) years.

4.1.2.4 Where internal independence cannot be demonstrated, the HOD shall appoint an external independent reviewer. External reviewers shall be subject to documented competence evaluation and shall sign confidentiality and impartiality declarations prior to commencement of the review.

4.1.2.5 QA shall coordinate administrative aspects of the appeal review, including communication, provision of records, and scheduling, without influencing the reviewer's assessment or conclusions.

4.1.2.6 The appeal reviewer shall examine relevant certification records, evaluation evidence, decision documentation, and applicable certification scheme requirements, and shall document findings and recommendations based on objective evidence.

4.1.2.7 The appeal reviewer shall submit documented recommendations to the HOD. Final decisions on appeals shall be approved by the HOD and shall not be made by personnel involved in the original certification activities.

4.1.2.8 An appellant may withdraw the appeal at any stage prior to completion of the appeal review. An appeal withdrawn on the same grounds shall not be reinstated.

4.1.3 Appeal Review, Decision, and Communication

4.1.3.1 Upon appointment, the Appeal Reviewer shall review the appeal independently and objectively, based on the appeal submission, certification records, evaluation evidence, decision documentation, and applicable certification scheme requirements. Where outsourced activities are involved, the Appeal Reviewer verifies the competence, accreditation status, and contractual compliance of the outsourced body as required under AC-QP-04.

4.1.3.2 If additional clarification or documentation is necessary, the Appeal Reviewer may request information from the appellant or relevant internal personnel, ensuring that such requests do not compromise impartiality or influence the outcome of the appeal.

4.1.3.3 If the appellant fails to provide required additional information within ten (10) working days, the Appeal Reviewer may proceed based on available evidence.

4.1.3.4 The Appeal Reviewer shall complete its review within a reasonable timeframe. If delays occur, QA shall document justification and provide progress updates to the appellant.

4.1.3.5 The Appeal Reviewer shall document the review findings, conclusions, and recommendations, clearly indicating whether the original certification decision is to be upheld, modified, or reversed, with justification based on objective evidence.

4.1.3.6 Where more than one appeal reviewer is exceptionally appointed, decisions shall be made by consensus. Where consensus is not possible, decisions shall be made by majority vote, and the decision method shall be documented. In the event of a tie, the HOD may appoint an additional independent reviewer or act as an independent reviewer, as suitable, to achieve a majority decision.

4.1.3.7 The documented recommendations shall be submitted to the HOD for review and final decision.

4.1.3.8 The HOD shall evaluate the recommendations to confirm compliance with impartiality obligations and ISO/IEC 17065 requirements. Where clarification is required, the HOD may request additional justification; however, the HOD shall not alter the factual findings or conclusions documented by the Appeal Reviewer.

4.1.3.9 The final decision shall not be made by personnel involved in the original evaluation, review, or certification decision.

4.1.3.10 The HOD shall review the recommendations and approve the final appeal decision.

4.1.3.11 The HOD shall determine whether the appeal outcome affects the ongoing validity of certification and shall initiate appropriate actions, including re-evaluation, suspension, withdrawal, limitation, or continuation of certification, in accordance with applicable certification procedures.

4.1.3.12 QA shall formally communicate the appeal decision and its rationale to the appellant in writing, normally within the defined appeal resolution timeframe.

4.1.3.13 The appeal decision shall be final and shall not be subject to further internal appeal.

4.1.3.14 The QA shall keep appellants informed of the progress of handling their cases.

4.1.3.15 The time period between confirmation of appeal admissibility and issuance of the final written decision shall normally not exceed thirty (30) working days, unless additional investigation is required and documented. Where delays are anticipated, QA shall inform the appellant and provide a revised expected timeline.

4.1.3.16 Where the HOD does not accept the Appeal Reviewer's recommendation, the HOD shall document the justification for the decision within three (3) working days. QA shall retain this justification as part of the appeal file.

4.1.3.17 Where systemic issues, recurring concerns, or risks to impartiality are identified through the appeal, the matter shall be included as input to internal audit and management review.

4.1.3.18 All personnel involved in appeal handling shall maintain confidentiality, impartiality, and independence at all times and shall not disclose or use appeal-related information outside the intended purpose.

4.2 Complaints Handling

4.2.1 Receipt, Review, and Registration of Complaint

4.2.1.1 Complaints may be submitted by clients, applicants, certified organizations, regulators, market participants, or members of the public who have concerns related to AQMA CERT's certification activities or the behaviour of certified organizations.

4.2.1.2 Complaints shall be submitted in writing with sufficient detail to allow meaningful assessment of the matter raised. Complaints may relate to AQMA CERT personnel conduct, impartiality concerns, the technical validity of certification activities, misuse of certification marks, fraudulent certificates, or the conformity of certified products.

4.2.1.3 A complaint shall not be treated as an appeal unless it explicitly challenges a certification decision made by AQMA CERT.

4.2.1.4 Upon receipt, QA shall review the complaint for adequacy and relevance to AQMA CERT's certification activities to determine whether it is admissible for further handling.

4.2.1.5 Where the complaint is found to be adequate and within scope, QA shall admit the complaint, assign a unique case identification number, and record it in the Complaints and Appeals Register (AC-QF-06).

4.2.1.6 Where the complaint is found to be outside scope, unsupported by sufficient information, or otherwise inadmissible, QA shall reject the complaint and inform the complainant in writing, providing documented justification. Such cases shall be closed without proceeding to investigation.

4.2.1.7 The QA shall acknowledge the complaint within three (3) working days, unless justified, confirming that the matter will be examined according to AQMA CERT's impartiality and confidentiality requirements.

4.2.1.8 Where necessary to determine admissibility, QA may request additional information from the complainant. If the requested information is not provided within ten (10) working days, the complaint may be closed based on available information, with justification recorded.

4.2.1.9 All documents, communications, and evidence related to admitted complaints shall be compiled into a dedicated complaint file and maintained as an Internal Record in accordance with Records Control (AC-QP-11).

4.2.1.10 Valid complaints are forwarded for investigation, and the complainant is informed accordingly.

4.2.2 Investigation, Decision, and Communication

4.2.2.1 The QA appoints an investigator who possesses no conflict of interest and has not been involved in the activities or decisions associated with the subject of the complaint.

4.2.2.2 The investigator shall review all relevant records, communications, and certification documentation to determine the validity of the complaint. Where the complaint concerns outsourced activities, the investigator shall examine the competence, accreditation status, and contractual compliance of the outsourced body in accordance with AC-QP-04. Where the complaint relates to impartiality or potential conflicts of interest, the investigator shall adhere to the requirements of AC-QP-01 and AC-QP-02.

4.2.2.3 The investigator shall determine whether the complaint affects the validity of any issued certificates and shall recommend suspension, withdrawal, or additional evaluation, where relevant.

4.2.2.4 When necessary, the investigator may request additional information from internal personnel, the complainant, or certified organizations, ensuring that such interactions shall not compromise independence or transparency.

4.2.2.5 If required information is not provided by the complainant or relevant parties within ten (10) working days, the investigation may proceed based on available evidence, and the outcome shall be documented accordingly.

4.2.2.6 All findings, evidence, and conclusions generated during the investigation are documented in the complaint file.

4.2.2.7 The QA shall keep complainants informed of the progress of handling their cases.

4.2.2.8 Upon completion of the investigation, the investigator shall submit the detail of investigation, the possible cause(s), a corrective action proposed and decision of the complaint to the QA, within a reasonable timeframe following the investigation appointment.

4.2.2.9 QA shall review the adequacy and completeness of the investigation documentation and may request additional clarification or information from the investigator, where required.

4.2.2.10 QA shall review completeness and forward the case to the HOD for review and approval.

4.2.2.11 The HOD shall ensure that the decision is supported by objective evidence, complies with ISO/IEC 17065 requirements, and appropriately addresses the issues raised in the complaint.

4.2.2.12 QA shall communicate the final decision and its rationale to the complainant in writing.

4.2.2.13 AQMA CERT shall normally resolve and communicate complaint decisions within thirty (30) working days from admission of the complaint, unless additional investigation is required and justified. Where delays are anticipated, QA shall inform the complainant and provide progress updates and a revised timeline.

4.2.2.14 Where a complaint reveals systemic issues or risks to impartiality, QA shall initiate corrective or preventive actions in accordance with AC-QP-14. Such cases shall also be used as inputs to internal audits under AC-QP-13 and as mandatory inputs to Management Review under AC-QP-12.

4.3 Record Keeping and Retention

4.3.1.1 For both appeals and complaints, once the decision has been communicated, the QA shall finalize the case file and records the case closure date and final status in the Complaints and Appeals Register (AC-QF-06).

4.3.1.2 QA shall maintain all records related to appeals and complaints in designated case folders established and maintained as an Internal Record, including: Complaints and Appeals Register, Appeal Reviewer Appointment and Impartiality Declarations, Acknowledgement and communication records, Case files (evidence, investigation notes, minutes, recommendations, decisions), Corrective and preventive actions related to cases, Final decision communications.

4.3.1.3 All communications related to complaints and appeals, including acknowledgements, requests for information, progress updates, decisions, and closures, shall be conducted and retained via controlled email communication. Email records shall constitute valid and sufficient records for the purpose of evidence, traceability, and record retention, and no separate communication form is required.

4.3.1.4 All records are retained for a minimum of five (5) years and stored in AQMA CERT's designated cloud system in accordance with Records Control (AC-QP-11).

4.3.1.5 Access to complaint files shall be restricted to authorized personnel, and shall be made available to accreditation bodies during assessments in accordance with confidentiality requirements.

5.0 Relevant Documents

• ISO/IEC 17065:2012 Clause 7.13
• AC-QM-01 Quality Manual
• AC-QP-01 Independence, Impartiality, Integrity and Confidentiality
• AC-QP-02 Management of Impartiality
• AC-QP-04 Selection and Evaluation of Outsourced Services
• AC-QP-10 Documents Control
• AC-QP-11 Records Control
• AC-QP-12 Management Review
• AC-QP-13 Internal Audit
• AC-QP-14 Corrective and Preventive Actions

6.0 Relevant Records

• AC-QF-06 Complaints and Appeals Register