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30 March 2023

Overview of the program

ASI Witness Assessments form part of the ASI Oversight Mechanism and enable the direct in-person observation of auditor(s) undertaking certification, surveillance and re-certification audits across the ASI Membership’s certified Entities against the ASI Performance Standard.

Managed by the Director of Assurance, and supported by the ASI Secretariat, the program has been established to evaluate consistency with the requirements of the ASI Assurance Manual, evaluate competency and impartiality of the ASI Accredited Auditors, identify risks to the ASI assurance system and identify improvement opportunities for the ASI assurance system. This program forms an important component of the ASI Assurance framework as it assists in meeting ASI’s obligations as an ISEAL Code Compliant Member. It offers an ideal opportunity for ASI to observe auditors ‘in action’ and assess the comprehensiveness of the audits performed. It also provides a great opportunity for ASI to identify potential improvement opportunities with respect to the ASI Assurance Manual, Guidance documentation, training material and potentially provide feedback into regular Standards revision processes.

It is important to note that witness assessments are NOT shadow audits – they do not assess the performance of the Entity or make recommendations on conformance to the ASI Performance Standard; instead they assess the planning and execution of the audit by the responsible audit team.

Program planning

Witness assessors are selected with an appreciation of their prior experience with assurance, certification and/or accreditation systems, experience with witness assessments and oversight and independence from ASI Accredited Auditing Firms and ASI Members. Specifically, witness assessors are selected based on their knowledge of key topics relevant to the ASI Standards, such as those related to governance, environment and social issues, and where relevant language capability.

Due to the global covid-19 pandemic and the associated significant travel restrictions and risks to health, the program was put on hold from early 2020 to mid-2022. However in the second half of 2022, five assessments were successfully undertaken at Entities located in Australia, Brazil, China, Germany and Guinea. One assessment has already been completed in 2023 (Australia), with additional assessments currently planned for Entities in Guinea, Canada, China and Australia, and further options being proposed for Western Europe, the Gulf region, and South-east Asia.

Entities are selected for witness assessment based on a number of factors which include (but not necessarily limited to) the following:

  • Country and setting (including consideration of the Entity’s Area of Influence)
  • Previous audit findings (if currently certified)
  • Ensuring all supply chain activities are included, however with an emphasis on ‘upstream’ Entities (risk-based approach in selection)
  • Ensuring a variety of both audit firms and auditors are selected over time.

Following completion of the oversight process and the release of the Certificate and Report, the Auditor(s) receives a letter report that provides a summary of the findings, including a discussion on any opportunities for improvement identified in the witness assessment. Any major issues identified are typically followed up in person with the auditor during the witness assessment, and followed up later with the Accredited Auditing Firm’s Primary Contact.

The assessment methodology

Witness assessments consider the whole-of-audit approach and methodology used by the audit team, and does not assess the performance of the Entity with respect to the Performance Standard. Aspects of the audit that are reviewed include (but are not necessarily limited to) the following:

  • Audit plan, schedule and execution of the audit
  • Allowances for changes to employee availability and other Entity requests and requirements
  • Auditor(s) understanding of the criteria and the specific applicability of the criteria related to the audit scope
  • Appropriate time spent on each criteria commensurate with the level of risk and materiality
  • The method(s) of questioning by the auditor(s) and whether they stayed ‘on topic’
  • Areas inspected by the auditor(s) and whether these included all material risk types
  • Requests, review and interrogation of objective evidence
  • Auditor(s) acknowledgement and adherence to any specific site-specific requirements
  • Appreciation of the Entity’s setting and its area of influence with respect to material issues
  • Appropriateness of interviews, including number and type of interviewees, line of questioning
  • Overall level of professionalism and candour demonstrated by the auditor(s).

Findings so far

The assessments undertaken so far have demonstrated a high level of professional competency, and a thorough understanding of the requirements of the Performance Standard. A risk-based approach to auditing has been evident across all audits assessed, with more time and rigour applied to those issues and criterion that are of significance to the Entity. The demeanour and approach of auditors has been professional and sincere, and importantly the auditors have been flexible to accommodate sudden or unplanned changes to the audit schedule in the event of operational issues and/or unavailability of certain Entity staff due to illness or absence. There has been an appropriate level of engagement with external stakeholders applied in all audits observed to date, and the review of objective evidence has been appropriate to level of risk.

Some opportunities for improvement have been noted however, where witness assessors noted that improvements to pre-audit planning could be made (including pre-reading of key documentation), improvements to on-site time management, isolated incidents of auditors not fully complying with Entity-specific health and safety requirements (such as correct PPE) and at times, evidence of an overly literal interpretation of some criterion. This feedback has been provided to not only auditors, but also considered by the Secretariat as potential improvements to guidance, procedures and learning interventions.

Both Members and auditors have been accommodating and welcoming of the witness assessments, as they appreciate the importance of the program in improving the ASI assurance framework, the ability to receive improvement opportunities and the flow-on effect into improved guidance and training for all Members and auditors.

The program moving forward

The Secretariat is currently proposing the involvement of representatives from the Indigenous Peoples Advisory Forum (IPAF) in future witness assessments, particularly for audits of Entities where there are inherent potential impacts to Indigenous Peoples. Now as the world has opened up again following the global pandemic, ASI looks forward to an increased level of engagement in the on-site auditing component of its assurance framework to further add value by identifying opportunities for improvement for both auditors and the ASI process to continually improve the ASI certification program.


iseal code compliant