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Team Briefing programme

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1 Team Briefing programme
Why do we audit? Link Model HSE-MS auditing Audit methodology Eight HSE-MS Elements (questionnaire) Site visits & interviews Report writing Audit rating Audit completion

2 In the Group we are all committed to:
Group commitment In the Group we are all committed to: pursue the goal of no harm to people protect the environment use material/energy efficiently to provide our products/services develop energy resources, products and services consistent with these aims publicly report on our performance play a leading role in promoting best practice in our industries manage HSE matters as any other critical business activity promote a culture in which all Shell employees share this commitment In this way we aim to have an HSE performance we can be proud of, to earn the confidence of customers, shareholders and society at large, to be a good neighbour and to contribute to sustainable development.

3 Group HSE Policy Every Shell company:
has a systematic approach to HSE management, designed to ensure compliance with the law and to achieve continuous performance improvement; sets targets for improvement and measures, appraises and reports on performance; requires contractors to manage HSE in line with this policy; requires joint ventures under its operational control to apply this policy, and uses its influence to promote it in its other ventures; includes HSE performance in the appraisal of all staff and rewards accordingly.

4 Phil Watts - Shell EP HSE Conference
HSE Performance “There must always be a gap between ... aspirations and performance.... But a gap between policy and performance is unacceptable” . Phil Watts - Shell EP HSE Conference 22 September 1997

5 HSE Performance “There should be absolutely no question of operational urgency or other pressures taking priority over safety. It has been repeatedly demonstrated that improved safety in operations goes hand in hand with greater efficiency, quality and cost effectiveness I would therefore request you to ensure that work does not start before it is confirmed that essential safety systems are in place and that staff are accountable for this requirement. Where we cannot ensure safety, operations should be suspended. M Moody-Stuart 24/4/92

6 Team Briefing programme
Why do we audit? Audit methodology Eight HSE-MS Elements (questionnaire) Site visits & interviews Report writing Audit rating Audit completion

7 SIEP-led Audit Focus verification that structured risk assessment has been applied to the key HSE risk elements of the facility or activity, sample whether these risks have been appropriately assessed and the correct controls have been identified, and sample whether these controls are adequately implemented and complied with.

8 SIEP HSE Audit method (1)
OU and Contractor Staff involved Based on National and OU/Contractor standards HSE - Management System Audits Fully cover H, S and E Focus on system Focus on risk instead of compliance Focus on controls Sampling Process Questionnaire based

9 SIEP HSE Audit method (2)
Strategy and Process Bottom up Approach Look for unknown problems Focus on gaps between areas of responsibility Overall impression usually negative Attempt to balance but focus on improvement Investigate identified deficiencies in depth - find underlying causes Record all areas investigated, noting any omissions Verification!

10 Weakness Classification Matrix
People Assets Environ- ment Repu- tation Severity 1 2 3 4 5 No injury or damage to health Slight injury or health effects Minor injury Major injury Single fatality or permanent total disability Multiple fatalities No damage Slight Minor Local Major Extensive effect impact Localised Consider- able National Inter- national Massive Never heard of in EP industry A Low Medium High Has occurred in B Has occurred in the audited OU C D Happens several times a year in the audited OU E Happens several times a year in the audited facility Serious High: Though not serious, essential to be brought to Management attention. Includes medium weaknesses as repeat from previous reports. Low: No major HSE impact at process level, correction will assure greater effectiveness/efficiency in process concerned. Serious: Exposes OU to a major extent in terms of achievement of corporate HSE objectives or results. Medium: Could result in perceptible and undesirable effect on achievement of HSE objectives.

11 Root Causes Cause Recommendation HSE Management System Problem
Business objectives? Cause Policy failing? Organisation failing? Review & App. failing? Recommendation HSE Management System Procedural failing? Supervisory failing? Problem Detailed findings/deficiencies/problems

12 Team Briefing programme
Why do we audit? Link Model HSE-MS auditing Audit methodology Eight HSE-MS Elements (questionnaire) Site visits & interviews Report writing Audit rating Audit completion

13 Audit process The HSE MS

14 Corrective Action & Improvement Corrective Action & Improvement
HSE Management System Leadership and Commitment Policy and Strategic Objectives CORPORATE Organisation, Responsibilities Resources, Standards & Doc. PROCESS TASK Hazard and Effects Management Corrective Action Planning & Procedures Implementation Monitoring Audit Corrective Action & Improvement Corrective Action & Improvement Management Review

15 Leadership & Commitment
HSE an integral part of business Do managers effectively balance any conflict in the competing requirements to safeguard technical integrity and to optimise cashflow? Do staff believe that management and supervisors are serious about the priority of HSE matters? Do managers and supervisors periodically visit worksites and attend departmental safety meetings? Do managers and supervisors lead by example - do they follow their own rules?

16 Policy & Strategic Objectives
Challenging policy and objectives understood by all Is there a Health, Safety and Environment policy? Are strategic objectives defined (also for HSE aspects)? Do the policy and objectives require continuous improvement, and set a leadership goal? Are objectives cascaded to tasks and targets for all staff? Does the policy contain an explicit statement that work should be stopped/not started if unsafe? Are the policy and objectives endorsed by the present chief executive? Are they readily available to employees and contractors? Do employees and contractors understand policy and objectives? Is Contractors' HSE management is consistent with Company's?

17 Organisation, Responsibilities, Resources, Contractor Management Communications, HSE-MS Documentation Standards and Change Control Is the organisation appropriate? Are boundaries and interfaces adequately described? Are responsibilities defined to fully cover all activities? Is there an appropriate balance between line staff and advisers? Do all staff have job descriptions (also defining HSE aspects)? Do staff understand and accept their responsibilities and authorities? Are resources adequate for effective HSE management?

18 Organisation, Responsibilities, Resources, Contractor Management Communications, HSE-MS Documentation Standards and Change Control Are job competence needs defined? Are individual competencies assessed against the job requirements? Are the mandatory competency requirements being complied with? Is there an structured HSE training system? Does the HSE training system meet line requirements? Are there documented procedures for the separate stages of the contracting process? Are relevant HSE clauses in contracts adequate? Are Contractors required to submit a description of how risks will be systematically managed to ALARP prior to being allowed to start work

19 Organisation, Responsibilities, Resources, Contractor Management Communications, HSE-MS Documentation Standards and Change Control Is there a structured system for HSE communication? Are HSE bulletin boards available carrying appropriate and current information? Are staff (at all levels) HSE motivated? Is the Corporate HSE-MS substantially complete Is there a project / departmental HSE - MS Manual? Are shortfalls in the HSE-MS identified and is an action plan for rectification in place? Are standards clearly defined and appropriate? Are hazards and effects documented in an HSE case? Is there an effective document control system? Is there effective change and variance control?

20 Contractor HSE What is contracted? equipment and personnel
specified product or service Contractor HSE management system Pre-qualification: can contractor meet all HSE req’s? Role of contractholder/ single point responsibility Contract HSE plan have all hazards been identified are controls in place to eliminate/control hazards are systems in place to verify: audits and inspections

21 WORKPLACE HAZARD MANAGEMENT
HSE Risk Management SAFETY / HSE CASE COMPANY CONTRACTOR Demonstration (regulator, shareholder Major hazards of installation Quantitative risk assessment Safety-critical activities Latent failures Execution (Minor) hazards at the workplace Qualitative risk assessment Hazardous activities Active failures Engineering Design Hardware WORKPLACE HAZARD MANAGEMENT Operations People

22 contractual requirements HSE Plan
Managing HSE Risk OU Contractor Policy Process Task HSE-MS HSE-MS interface documents Seismic specific HSE Case HSE Case contractual requirements HSE Plan Manage workplace hazards Manage workplace hazards

23 ? Documented systems e.g. for seismic operations Company Common
industry guidance Company Common Contractor Policy and vision ? HSE-MS HSE-MS processes (high level) Contract HSE Requirements Departmental MS HSE-Case for Equipment + Site Addendum HSE-Case for Company Operation processes (detailed) Interface Document Demonstration/assurance that all documents are in place and are operational at the right level etc. Workplace hazard management system Workplace hazard management system task level

24 SIEP-led Audit Focus HAZARD
CONSEQUENCES Harm to people and damage to assets or environment Events and Circumstances BARRIERS HAZARD Undesirable event with potential for harm or damage Hazards: Undesirable event moving equipment, vehicles trapped/crash wires / ropes under tension uncontrolled whiplash steep slopes fall poor hygiene contaminated food/water Line clearance in tropical erosion, deforestation rainforests Barriers: equipment standards,competent workforce, work plans & procedures, good supervision Equipment guards, seat belts, safety cut-out devices, PPE, first aid, Emergency Plans 1 verification that structured risk assessment has been applied to the key (HSE) risk elements of the facility or activity Engineering activities Maintenance activities Operations activities 2 sample whether these risks have been appropriately assessed and the correct controls have been identified 3 Sample whether these controls are adequately implemented and complied with 9

25 HEMP Have all hazards and effects been identified?
Have all risks and effects from from hazards been evaluated? Have appropriate measures been defined and implemented to reduce tolerable risks to ALARP level? Are the procedures and other measures and practices effective in containing hazards at ALARP level? Have hazard controls been assigned to responsible parties look in team activity and hazard sheets are the responsible parties aware are the controls being implemented

26 Planning and Procedures 1
Is there an effective integrated planning process, including short, medium and venture life plans? Do plans align with corporate objectives? Do plans cover all activities necessary to protect asset integrity? Is there an annual HSE plan? Emergency response (ER) Are adequate ER plans and procedures in place within a defined hierarchy? Are ER plans and procedures available where required? Are ER plans and procedures known and understood and used? Are ER plans and procedures and plans systematically reviewed/updated?

27 Planning and Procedures 2
Are adequate procedures in place within a defined hierarchy? Are procedures appropriate to the operation and do they define mandatory aspects? Are procedures available where required? Are procedures known and understood and used? Are procedures and plans systematically reviewed/updated?

28 Implementation & Monitoring
Is work implemented in line with plans and procedures? Do supervisors regularly check the work of their subordinates and provide remedial advice as needed? Are performance measurement and control systems established? Are improvement targets set and achieved, are there regular reviews at all levels? Is performance measured against SMART targets and are appropriate and timely reports generated? Are control breakdowns investigated and remedied? Is non-compliance adequately dealt with? Is there an adequate system for incident investigation reporting?

29 A structured programme in place
Audit A structured programme in place Is there an Internal Audit Committee? Is there an integrated audit programme? How is the audit programme managed? Are audits truly independent? Are the audit resources adequate and competent? Are audit recommendations comprehensively followed-up? Is the follow-up process adequately reported? Is there a system for lateral application of audit recommendations?

30 Management retain overview and stimulate improvement
Review Management retain overview and stimulate improvement Is there a comprehensive HSE review (at least annually)? Is there an effective management inspection visit programme? Is asset integrity periodically assessed by management? Are audit reports (singly and cumulatively) reviewed by management? Are incident investigations (singly and cumulatively) reviewed by management? Do managers of an appropriate level lead investigations of serious incidents? What improvements have resulted from the management review process? Do management have their eyes on (the right) ball?

31 Team Briefing programme
Why do we audit? Link Model HSE-MS auditing Audit methodology Eight HSE-MS Elements (questionnaire) Site visits & interviews Report writing Audit rating Audit completion

32 Interviewing - Preparation
Review collected documents & data Team members select areas Edit questionnaire for selected areas Discuss finalised questionnaires Identify site interviewees Adjust areas selected to give full coverage Ask Auditee to schedule interviews

33 Questionnaires Define areas to be covered, and divide between the team members Reduce gaps and oversights Reduce overlap and repetition Suggest subjects and detail for new auditors Help structure interviews and research Stimulate memory and imagination to add Must be edited, tailored, NOT a check list

34 Generic Questions Equipment Aspects
What is it? What does it do? Does it work? How do you know? How often tested / maintained? Test / maintenance covered by procedure? Procedure available? - correct? - followed? Is special equipment needed? - available? - used? Test / maintenance checked by supervisor? Results recorded? Reliability calculated? Procedure / frequency systemmatically reviewed / adjusted?

35 Generic Questions Competence Aspects
Are job needs defined? Are each individual’s skills recorded? Is there a gap analysis? Is supplementary training planned? Has competence been verified? By whom? - against what criteria? Who checks your work? What exactly is checked? - how often? Is feedback provided? What training has been received? (also on-the-job) What further training is required?

36 Generic Questions Procedural Aspects
Are all safety-critical aspects covered by procedures? Are mandatory aspects identified? Is each procedure: comprehensive, clear and concise? available where required? known and used? authorised by an appropriate person? a controlled document? systematically reviewed? Are staff encouraged to improve procedures? Do procedures satisfy underlying objectives?

37 Interviewing - Pairing
Each auditor paired: to witness deficiencies to confirm adequacy to question the other’s assumptions to minimise misunderstandings between interviewer and interviewee

38 Interviewing - Organisation
Make an appointment if possible on interviewee's territory Pick relevant areas, highlight key questions Also those of others! Decide on sequence and share of time Agree timing and stick to it Make notes Keep quiet during other's time Be on time and don’t overrun Cover all key points or make another appointment Compare overall impressions & key issues The better one is prepared for the interview , the more one gets from it !

39 Interviewing - Approach (1)
Minimise stress establish relationship / do not intimidate use interpreter if necessary / adapt language to level of interviewee interview outside presence of boss 2 interviewers only (max one hour) take notes all the time or not at all try to avoid visible checklist Introduce interviewers Outline aims of audit Normal OU routine supported by Dept. Audit of system - not individuals Aim to improve future - not witch hunt past Open report and presentation Report is view of audit team - not of sources

40 Interviewing - Approach (2)
Ask interviewee’s background Use open questions and listen to replies No prompting or interrupting by audit team Avoid judgments, but do not condone Do not accuse, argue or attack Keep calm yourself If interviewee hostile or unhelpful, interview somebody else Stick to key questions, diverge briefly if you detect (possible) deficiencies Cover all your key questions Thank interviewee

41 End of Team Briefing Session 1
Audit process End of Team Briefing Session 1

42 Team Briefing programme
Why do we audit? Link Model HSE-MS auditing Audit methodology Eight HSE-MS Elements (questionnaire) Site visits & interviews Report writing Audit rating Audit completion

43 Findings Require Verification eg:
Interview confirming written procedure Observation of activity confirming written procedure MoM confirming interview Observation of hardware confirming standard

44 Deficiencies Policy Deficiency? Control Deficiency? Control Lateral?
Detail Lateral? Detail Deficiency Detail Lateral? Detail Lateral?

45 Tabular Report Format

46 Format of Findings in Ch. 4
Present in a tabular (landscape) format: Part 1 Reference Finding A number of significant PPE short comings and other safety violations were observed Section ref. Order of findings in section Severity of finding (S,H, M, L) risk category HSE MS element linked to the finding b H P 4

47 Format of Findings in Ch. 4
Part 2 Significance Violation of Company PPE policy ref. xyz Site management’s commitment to HSE Recommendation Reinforce HSE responsibilities of site supervision

48 Team Briefing programme (3)
Report Writing Deadline individual contributions See hints in handout Focus on your area Verify facts with documentation Start with Operational findings, finish with management findings Use questionnaires as a guide

49 Report - Text Handling 2nd Draft Team Author Team Author Team Author
1st Draft Critic Team Critic 2nd Draft Auditee Team Discussion Auditee Report

50 Report - Style Standard index and format
Team editor solely responsible for English Minimise recommendations "to study" Factual rather than opinion IS/IS NOT rather than TEAM CONSIDER if necessary verify further No time for perfection not "agreed" by auditee not binding on auditee

51 Report - Text Drafting If you consider an aspect is particularly well managed: include it as a finding but omit the significance and recommendations. These aspects will be discussed and may be included in the principal positive findings in the executive summary Recommendation: “Improve....” Keep it short, punchy and to-the-point

52 Report - recommendations
Stand Alone, Clear & Concise Definitive when read in isolation Not longer than three lines SMAR(T) Specific - as specific as expertise allows and sufficiently specific to ensure that deficiency will indeed be remedied Measurable - must be able to define completion Achievable - must be possible Realistic - should be fit-for-purpose Time-based - timeframe not included in audit report - to be decided by Auditee Motivational Start with an active verb - verify, issue, revise, replace, remove, provide, install, define or appoint Avoid - consider, coordinate, ensure, initiate, monitor, supervise

53 Tabular Report Format

54 Classification of Findings
Each Finding is categorised as follows: 1. Category: People (P); Assets (A); Environment (E); or Reputation (R) 2. Severity level (from Weakness Classification Matrix): Serious (S); High (H); Medium (M); or Low (L) 3. Each Finding is assigned to one HSE MS element 4. A Finding is accompanied by the Significance and one or more recommendations to address the gap

55 Weakness Classification Matrix
B C D E Severity People Assets Environ- ment Repu- tation Never heard of in EP industry Has occurred in EP industry Has occurred in the audited OU Happens several times a year in the audited OU Happens several times a year in the audited facility No injury or damage to health No damage No effect No impact Low Slight injury or health effects Slight damage Slight effect Slight impact 1 Minor injury or health effects 2 Minor damage Minor effect Minor impact Medium Major injury or health effects Consider- able impact 3 Local damage Localised effect High Single fatality or permanent total disability 4 Major damage Major effect National impact Inter- national impact Serious 5 Multiple fatalities Extensive damage Massive effect High: Though not serious, essential to be brought to Management attention. Includes medium weaknesses as repeat from previous reports. Low: No major HSE impact at process level, correction will assure greater effectiveness/efficiency in process concerned. Serious: Exposes OU to a major extent in terms of achievement of corporate HSE objectives or results. Medium: Could result in perceptible and undesirable effect on achievement of HSE objectives.

56 Classification findings/recommendations
Weakness Definition Serious Exposes company to a major extent in terms of achievement of corporate HSE objectives or results High Though not serious, is essential to be brought to attention of senior management team. Includes any medium weakness which is repeat finding from previous report. Medium Could result in perceptible and undesirable effect on achievement of HSE objectives. Low No major HSE impact at process level, correction will assure greater effectiveness/efficiency.

57 Risk Assessment Matrix
Definitions Consequence consequence of scenarios that can develop from the release of a hazard given the available barriers and defences (in incidents or near misses the hazard has been released already whereas in all other cases the hazard has not yet been released) Probability probability is estimated on the basis of historical evidence that the assessed consequence has materialised (i.e. not the probability of the release of the hazard)

58 Risk to People Severity Description 0 No injury or damage to health
1 Slight injury or health effects (including first aid case and medical treatment case) - Not affecting work performance or causing disability. 2 Minor injury or health effects (Lost Time Injury) - Affecting work performance, such as restriction to activities (Restricted Work Case) or a need to take a few days to fully recover (Lost Work Case). Limited health effects which are reversible, eg skin irritation, food poisoning. 3 Major injury or health effects (including Permanent Disability) - Affecting work performance in the longer term, such as a prolonged absence from work. Irreversible health damage without loss of life, eg noise induced hearing loss, chronic back injuries. 4 Single fatality or permanent total disability. From an accident or occupational illness (poisoning, cancer). 5 Multiple fatalities - From an accident or occupational illness (poisoning, cancer).

59 Risk to Assets Severity Description 0 Zero damage.
1 Slight damage - No disruption to operation (costs less than US$10,000). 2 Minor damage - Brief disruption (costs less than US$100,000). 3 Local damage - Partial shutdown (can be restarted but costs up to US$500,000). 4 Major damage - Partial operation loss (2 weeks shutdown, costs up to US$10,000,000. 5 Extensive damage - Substantial or total loss of operation (costs in excess of US$10,000,000)

60 Risk to Environment Severity Description
0 Zero effect - No environmental damage. No change in the environment. No financial consequences. 1 Slight effect - Local environmental damage. Within the fence and within systems. Negligible financial consequences. 2 Minor effect - Contamination. Damage sufficiently large to attack the environment. Single exceedance of statutory or prescribed criterion. Single complaint. No permanent effect on the environment. 3 Localised effect - Limited loss of discharges known toxicity. Repeated exceedance of statutory or prescribed limit. Affecting neighbourhood. 4 Major effect - Severe environmental damage. The company is required to take extensive measures to restore contaminated environment to its original state. Extended exceedance of statutory or prescribed limits. 5 Massive effect - Persistent severe environmental damage or severe nuisance xtending over a large area. In terms of commercial or recreational use or nature conservancy, a major economic loss for the company. Constant, high exceedance of statutory or prescribed limits.

61 Risk to Reputation Severity Description
0 No impact - No public awareness. 1 Slight impact - Public awareness may exist, but there is no public concern. 2 Limited impact - Some local public concern. Some local media and/or political attention with potentially adverse aspects for company operations. 3 Considerable impact - Regional public concern. Extensive adverse attention in local media. Slight national media and/or local/regional political attention. Adverse stance of local government and/or action groups. 4 National impact - National public concern. Extensive adverse attention in the national media. Regional/national policies with potentially restrictive measures and/or impact on grant of licences. Mobilisation of action group. 5 International impact - International public attention. Extensive adverse attention in international media. National/international policies with potentially severe impact on access to new areas, grants of licences and/or tax legislation.

62 Bad Recommendation “If engineers and users require MC information, they should access the CAIRS system. However if a hard copy needs to be sighted, usually a copy is available at either the Plant or Warehouse. Only as a last resort should copies be requested from Information Services”. Identify potential users and train them in the use of CAIRS.

63 Report - Text Drafting Tips and hints:
Write your findings in style “tablebody” Don’t attempt to format your text i.e. do not put TABS and CRs in an attempt to “make it look nice”. Make a separate file for each section have to write. Omit the section heading line in the file. name the file as the section heading number, followed by your initials e.g sd.doc

64 Team Editing - Objectives
i Agree & confirm documentation of facts ii Build consensus and common view (total report supported by all team members) iii Obtain ownership by all team members iv Ensure clarity and conciseness v Eliminate irrelevant detail and repetition vi Unify style and correct grammar (also define audit-specific global checks)

65 Team Editing - Process One sub-section at a time:
i Is text understandable - can it be clarified? ii Does it demonstrate sampling of the subject area? iii Are findings factually correct? iv Are there any sensitivities? v Do all findings have related recommendations? vi Are all recommendations linked to a finding? vii Are recommendations SMAR(T)? viii Minimise additional sub-headings ix Ungroup recommendations x Unify style and correct grammar minute sessions Anyone may call for time-out

66 End of Team Briefing Session 2
Audit process End of Team Briefing Session 2

67 Team Briefing programme
Why do we audit? Link Model HSE-MS auditing Audit methodology Eight HSE-MS Elements (questionnaire) Site visits & interviews Report writing Audit rating Audit completion

68 Audit Assessment Good Fair Level of concern: Specific
No follow-up required by auditee’s function head (IAC member) Level of concern: Overall scope for enhancement In addition to following up correction of any High or Medium weaknesses the function head should encourage general improvement in controls awareness Good Fair

69 Audit Assessment Unsatisfactory Poor Unacceptable
Level of concern: Overall cause for concern In addition to following up correction of any Serious, High or Medium weaknesses the function head should take affirmative action to ensure that control standards in this area are raised Level of concern: Overall cause for grave concern In addition to following up correction of any Serious, High or Medium weaknesses the function head should satisfy the senior management team concerning affirmative action to raise control standards in this area Unsatisfactory Poor Unacceptable

70 Key: F = few <20 My = many >40
Revised Audit Opinion Key: F = few <20 My = many >40 Findings Most Favourable Opinion S H M H+M Unacc. Unsat. Fair Good / Poor /F  My  F F  F F/My My  My  > 

71 Audit opinion derivation
Based upon an assessment of severity and breadth of Findings Independent from Recommendations Findings rated ‘Low’ excluded Definition of Few and Many: ‘Few’ and ‘Many’ terms from IAG Based on review of past SIEP HSE audits: Few < 20 Many > 40 Provides differentiation Team decision required to deviate

72 HSE MS Self Assessment Questionnaire

73 HSE-MS Sub Element Assessment
System sustained and supported by an ongoing improvement process and essentially all elements satisfied. System functioning and being verified, results being measured, key system procedures documented. System is documented, approved, resourced and being implemented with priority objectives satisfied and the majority of objectives being met. System is under development and partially implemented. 4 3 2 1

74 Team Briefing programme
Why do we audit? Link Model HSE-MS auditing Audit methodology Eight HSE-MS Elements (questionnaire) Site visits & interviews Report writing Audit rating Audit completion

75 Finalisation of Report
Plug gaps Gather all outstanding data Check classified actions Collate appendices: Summary sheet Glossary of abbreviations Classified action list Correspondence on TOR Global checks spelling, references, etc.

76 Completion of Audit Give team-edited draft report to Auditee
Assessment and audit opinion Draft Main Findings Agree wording of Main Findings with Auditee Incorporate feedback agreed with Auditee Dry-run presentation within team Make final presentation to management Finalise report editing Present final draft report to Auditee (formal report to be issued within one month)

77 End of Team Briefing Session 3
Audit process End of Team Briefing Session 3


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