Complaints Procedures, (not) for greater good?

It remains a mystery to me why ‘the sole National Accreditation Body that performs accreditation with authority derived from the [Italian] State’ (Accredia) can accredit ‘the locally licensed representative of AJA Registrars in Indonesia’ (AJA Sertifikasi Indonesia). The distance (over 11,000 kilometres) – and related cultural differences – as well as substantial language gaps (Italian – English – Indonesian) seriously challenge any supervision of a wayward certification body. Accreditation really should be the domain of the Indonesian government!

The falsified signatures can be recognized as separate scans added to the reports.
The falsified signatures can be recognized as separate scans added to the reports.

However, things being as they are this meant a complaint concerning AJA – such as altered findings and falsified signatures in audit documents – has to go through Accredia. But this procedure is not for the faint at heart, and one can expect some serious bureaucrazy along the way.

First of all, be advised that Accredia does not respond to complaint by email only! One needs to fill in a complaints template, after translating it as this is ‘only in Italian. Also, make sure to activate ‘Delivery Status Notification’ and ‘Return Receipt’ before sending any emails to Accredia. (It ignored all my emails without these options activated.) And, be ready to – repeatedly – request an acknowledgment of your complaint!

Two (2) weeks and four (4) emails later Accredia confirmed receipt of the complaint. It furthermore wrote:
Please note that our procedures provides in fact that ACCREDIA notifies the CAB of the complaint received, asking for explanations and for the proposal of the appropriate corrective actions to be sent to Complaint Office within 30 days.

Accredia’s consequent requests for additional information were answered without delay; often within hours. (Don’t forget to activate ‘Delivery Status Notification’ and ‘Return Receipt’ on replies too!) However, Accredia quickly turned aloof and shared neither evidence compiled, nor communicated progress made (if any).

Weeks turned to months, and at the three-month-mark (mid January 2016) yet another audit document with a false signature surfaced: ‘Public Report Sustainable Forest Management System; RAPP Meranti West. (See ‘WWF’s concerns over certification of pulp plantations in Indonesia under the IFCC/PEFC Standard’. ) Another 5 documents possibly also contained false signatures and Accredia clearly needed a update / reminder by email.

Lo and behold, two weeks later (February 2016) Accredia replied to the reminder, but in an unexpected way:
Concerning your first complaint, please note that we have asked to the CAB to give us clarifications for the facts described into your complaint and to inform us about the actions that they intend to adopt in order to address it and avoid that similar facts could happen again.
The actions that the CAB’s proposed us seems acceptable. Nevertheless, as their implementation should have been effectively completed within December 2015, because of your update of yesterday, I ask you to give me further details about it.
We will deeply analyze the effective implementation of the action proposed during our next assessment at their offices.

To recap the chronology so far: Accredia agreed something was dodgy with the 6 audit documents provided. It required AJA to provide corrective actions within 30 days (November 2015), and implement those corrective actions a month later (December 2015). Yet, in February 2016 – over a month after that deadline for implementation – Accredia had not verified implementation or effectiveness of these actions. Furthermore, Accredia neither communicated progress – for nearly 3 months – nor sought consent for the proposed actions from the complainant!

But the real devil is, as is well known, in the details! Accredia acknowledges the complaint (read altered findings and falsified signatures in 6 documents) as facts (sic). Yet, somehow that additional falsified signature (and/or the 5 suspect documents) triggered the need for an on-site visit (office audit)! Accredia provides no justification for this on-site visit, whilst all evidence is available in soft-copy. Hence, there is no real need for an on-site visit… other than the following educated guess.

Most accreditation bodies and overseeing panels/committees/bodies consider 6 months a reasonable period to resolve a complaint, but only if said complaint needs no on-site visit! (See EA’s ‘Procedure for the investigation and resolution of Complaints and Appeals’, IAF’s ‘Procedure for the Investigation and Resolution of Complaints’ and the PEFC Council’s ‘Procedures for the Investigation and Resolution of Complaints and Appeals’.) At that point in time – 4 months after the initial complaint, 1 month after a false finish, and 0 communication on progress – Accredia had all but painted itself into a corner. With only 2 months left to resolve the complaint, the only face-saver was to (unilaterally) declare the need for an on-site visit?

With this stroke of “ingenuity”, Accredia crushed any opportunity for an open dialogue until after its undetermined ‘on-site visit’. As of mid February 2016, Accredia turned aloof yet again, and did not respond to inquiries regarding progress made, the date of the on-site visit, the opportunity to meet during the on-site visit, and whether falsified signatures have been removed from all audit documents. Its final communication (late April 2016) merely notes:
I confirm you that so far we consider that the information that we have received from you and from the CAB are not enough for us for definitively deciding if is trustable your or their description and view of the facts.
This said, in order to get the due confidence and hence close out the complaint we consider necessary to carry out additional evaluations.
This said, until now we cannot give you any further detail as we don’t consider completed our evaluations.

To some extent, communications go awry due to the language gap. But clearly Accredia is backpedalling on its conclusions: from the ‘fact’ of altered findings and falsified signatures in 6 documents, through an ‘on-site visit’ due to another falsified signature, to the complainant may be not ‘trustable’. (The altered findings are covered in detail in the post ‘Confirmed: discrepancies in audit reports AJA’.) So, let’s look at some evidence and determine if signatures have been falsified:

Acrobat Reader highlights (in blue) the “signature” above separate from the other text in this Package Submission Checklist – IFCC. The “signature” is a separate file, added to the text without my explicit consent, and thus is falsified.
Acrobat Reader highlights (in blue) the “signature” above separate from the other text in this Package Submission Checklist – IFCC. The “signature” is a separate file, added to the text without my explicit consent, and thus is falsified.
Acrobat Reader highlights (in blue) the signature above together with the text of this ‘Proposal and Application’. The signature is an integral part of the document, which is indicative (but not conclusive) that the signature not falsified.
Acrobat Reader highlights (in blue) the signature above together with the text of this ‘Proposal and Application’. The signature is an integral part of the document, which is indicative (but not conclusive) that the signature not falsified.

What can be expected in the (near) future from Accredia? Most likely, half a dozen reminders will be needed to trigger another response. This response will be a vague apology in shoddy English, stating a few months earlier Accredia’s team found nothing wrong and encountered no evidence of falsified signatures. (With a year to sanitize all dodgy behaviour, this will come as no surprise.) Accredia will provide no information on the number of documents verified, nor raise sanctions against AJA.

It should thus not be surprising that I won’t advice anyone to attempt Accredia’s complaints procedure! Do not for a moment think that this procedure is in place for the greater good: improvement of services provided. It’s merely a wad of red tape to comply with a concept required by some council, to suggest stakeholder consent. At no point in time expect some swift action from an “Italian Stallion” to set things straight.

The evidence may include sensitive commercial data that should never have left the desk of AJA’s director.
The evidence may include sensitive commercial data that should never have left the desk of AJA’s director.

On the other hand, uploading a complaint – and the supporting evidence – has far more and faster impact. Even the early warning shots (through Whatsapp, an app popular locally) put AJA on edge, and later posts resulted in knee-jerk reactions through its lawyer. (Including one hilariously flawed argument: because it paid for training, a contract with AJA is compulsory. However, that story is worthy of a separate post.)

Consequently, one could expect a leak of documents relating to the case at hand – altered findings and falsified signatures in audit documents, in particular Arara Abadi – in the near future! Once a rough pre-selection is done (there are numerous duplicate files), a link to these documents can be made available here. Do come back on occasion to grab the link.

Of course, “early birds” can contact me by email for that link, at bwvanassen@gmail.com.

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