PECB ISO 18788 Lead Implementer study materials
PECB ISO 18788 Lead Implementer study resources

Volta Risk & Response: Five Weeks to Stage 1

PECB ISO 18788 Lead Implementer ยท Put your knowledge to work in context.

All case studies

Volta Risk & Response: Five Weeks to Stage 1

Volta Risk & Response has applied for ISO 18788 certification with an accredited body. Stage 1 is scheduled in five weeks. The company has 340 staff across three countries and a head office in Accra. Its readiness file shows: a security policy signed 20 months ago by a director who has since left; 41 standard operating procedures, of which 12 are still marked 'draft v0.9' and 4 are undated; an internal audit completed in-house by two operations managers who audited their own departments, with no records of auditor competence; three open corrective actions from a firearm discharge incident seven months ago, one of which has no owner; no management review in the current cycle; a risk assessment dated four years ago that predates a new contract in a conflict-affected region; and training records in a spreadsheet only the HR manager can access. The certification body's stage 1 plan lists document review, interviews with top management, and verification that internal audit and management review have been performed. The COO proposes to 'push ahead and fix things during stage 2'.

1. Explain what stage 1 is for, what the auditor is likely to conclude on these facts, and why the COO's proposal is not a viable strategy.

Read the worked answer

What stage 1 actually does

Stage 1 is a readiness evaluation, not a warm-up. The auditor checks that the management system's documented information covers the requirements and the scope, that the organisation has understood its context and the standard's expectations, that internal audit and management review have been performed, and that stage 2 is feasible. It exists so that a certification decision is not based on a system that has never been run.

What the evidence suggests

  • Policy signed by a departed director and not re-approved: a leadership and document-control finding.
  • Twelve procedures still in draft and four undated: the process descriptions an auditor would audit against are not approved, so conformity cannot be demonstrated.
  • Internal audit performed by managers on their own departments, with no competence records: the audit is not independent and its competence is unproven. This is a substantive gap, because internal audit is a prerequisite rather than a nice-to-have.
  • No management review in the cycle: another prerequisite unmet.
  • A four-year-old risk assessment that predates a new conflict-affected contract: the risk basis for the scope is out of date, which puts the scope itself in question.
  • Three open corrective actions with one unowned, from a firearm discharge: a safety-critical follow-up failure.

Likely outcome

Not ready. The auditor may raise findings and recommend postponement of stage 2 until internal audit and management review are performed and the findings are addressed. The report typically states areas of concern and can recommend that stage 2 not proceed.

Why 'fix it during stage 2' fails

Stage 2 verifies implementation and effectiveness through evidence and sampling. It does not accept promises, and an auditor who finds that internal audit and management review still have not happened cannot recommend certification. Attempting it wastes the fee, damages credibility with the client base, and creates a documented history that the next auditor will read.

2. Build a five-week remediation sequence and justify the order, stating which dependencies force it and where the plan is genuinely at risk.

Read the worked answer

Sequenced plan

  1. Week 1 - leadership and document control. Re-approve the security policy with a current, authorised signatory; confirm the scope statement is accurate for all three countries; move all 41 procedures into a controlled repository, force a decision (approve or withdraw) on the 12 drafts, and date the undated four. Internal audit cannot audit against unapproved procedures, so this must come first.
  2. Week 1โ€“2 - the firearm discharge corrective actions. Assign the unowned action, verify whether the other two were effective, and close or re-plan with evidence. This is the highest-severity open item and an auditor will sample it.
  3. Week 2 - risk assessment refresh. Update the assessment to include the conflict-affected contract. If the risk controls for that contract are not implemented, either implement them or reconsider the scope; do not carry it in scope on paper only.
  4. Week 3 - internal audit. Use competent, independent auditors (trained internal staff from another function, or a contracted auditor under the organisation's control) covering all clauses and all three countries at a sampling level. Two weeks is tight for three countries; prioritise high-risk processes and sites.
  5. Week 4 - management review. It must take the audit results and refreshed risk assessment as inputs, so it cannot precede the audit. Record decisions with owners and dates.
  6. Week 4โ€“5 - evidence housekeeping. Make training records accessible to those who need them with access control, reconcile any gaps, and brief interviewees so top management can explain the system in their own words.

Where the plan is genuinely at risk

The internal audit and management review are the critical path; if auditor competence or country access slips, the whole sequence fails. A realistic option is to ask the certification body to move stage 1 by three to four weeks, or to narrow the certification scope to the countries that can be evidenced, and add the others at a later surveillance or extension audit.

3. Advise on whether the conflict-affected contract should be excluded from the certification scope to make the stage 1 date, and how the decision should be communicated internally and to the certification body.

Read the worked answer

Why exclusion looks attractive and why it is risky

Excluding the contract would remove the stale risk assessment problem and reduce the audit sampling burden. But scope must reflect what the organisation actually does, and exclusions must be justified and must not mislead clients or other interested parties. A security provider that excludes its most sensitive operation from certification while presenting the certificate commercially is exposed on two fronts: the certificate misrepresents capability, and the excluded activity becomes an uncontrolled risk that no part of the management system is watching.

The better question

Is the contract's control set implemented? If the risk assessment is refreshed and controls for that region are genuinely in place - vetting, use-of-force rules, supervision, incident reporting, grievance channel - the contract should be in scope, and the work is a two-week catch-up rather than an exclusion. If controls are not in place, that is a serious operational finding independent of certification: the answer is to fix the operation, not to shrink the scope around it. A temporary, time-bound exclusion is defensible only where the activity is genuinely separate, the client is informed, and a dated plan exists to bring it in.

Communication

  • To top management: present it as a decision with consequences - proceed and risk a failed or postponed stage 1, delay by three to four weeks, or narrow scope with a plan to extend. State the cost and client impact of each, and record the decision and its owner. The auditor should not be asked to make a management decision.
  • To the certification body: be explicit and early about the scope, the exclusions and their justification, and about the stage 1 readiness gaps. Transparency lets the body schedule realistically; concealment surfaces at stage 2 as a finding about the integrity of the system and the client relationship.
  • To staff: explain that the delay or scope change is about evidence, not blame, and set out what each function must produce - otherwise the readiness work is treated as an audit chore rather than an operating discipline.