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Category: 20_procedures | Version: v1.0.0
Owner: DOCUMENT_CUSTODIAN | Review cycle: 90 days
Approval authority: GOVERNANCE_ADMIN, COMPLIANCE_OFFICER
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Kvary platform is originally created in Georgian. Where a Georgian version exists, Georgian is authoritative for platform UI, documentation, and legal interpretation.
Translations into other languages are provided for convenience. Some records may originate in other languages and carry their own source or legal locale for a specific flow, but where a Georgian version is available, the Georgian version prevails for platform-level wording and interpretation.
Metadata incomplete: Document ID, Version, Status, Owner Role, Last Review Date, Next Review Date, Change Log
Document Purpose: This document defines the COMPLIANCE GUARDRAILS and CONTROL REQUIREMENTS that any inspection workflow (KES template) must apply.
Analysis Date: 2026-02-09 Source: EX-QM-01-20.1 Quality Management System Manual
| Constraint ID | Requirement | Control Point | Violation Action | |--------------|-------------|-------------------|------------------| | GC-IND-01 | Inspection body must be independent from interested parties | Pre-contract validation | Block contract initiation | | GC-IND-02 | No commercial/financial pressure allowed on inspection results | Throughout workflow | Flag & escalate | | GC-IND-03 | Inspector cannot inspect their own work/products | Inspector assignment | Block assignment | | GC-IND-04 | Conflict of interest must be declared immediately | On assignment | Immediate reassignment | | GC-IND-05 | No participation in design/production/supply of inspected object | Pre-contract validation | Block contract |
PROHIBITED RELATIONSHIPS:
ACTION: Risk assessment must be performed before ANY assignment. REFERENCE: Declaration form in Annex A (EX-QM/MP-01-20.1)
| Constraint ID | Requirement | Affected Data | Control | |--------------|-------------|---------------|-------------| | GC-CONF-01 | All inspection information is confidential by default | Reports, observations, client data | System-level access control | | GC-CONF-02 | Client must be informed before data disclosure | Any client data | Pre-disclosure notification | | GC-CONF-03 | Legal/contractual disclosure is exception only | Reports to authorities | Log disclosure event | | GC-CONF-04 | All personnel sign confidentiality obligations | All data | Employment contract requirement |
| Role | Minimum Requirements | Authorization Process | Monitoring Frequency | |------|---------------------|----------------------|---------------------| | Inspector | Technical knowledge, professional judgment, training | Multi-stage (orientation supervised independent) | Continuous | | Technical Manager | Inspection methods expertise, process control | Appointed by Director | Annual review | | Quality Manager | QMS expertise, ISO 17020 knowledge | Appointed by Director | Annual review |
REFERENCE: EX-QM/MP-03-20.1 Personnel Management Procedure
MANDATORY STAGES:
CONSTRAINT: No inspector can perform unsupervised inspection until all stages completed.
METHODS (must use combination):
| Constraint ID | Requirement | Validation Frequency | Record | |--------------|-------------|---------------------|--------| | GC-EQP-01 | All equipment must be suitable for inspection scope | Pre-use | Equipment log | | GC-EQP-02 | Equipment must be maintained in working condition | Continuous | Maintenance records | | GC-EQP-03 | Measuring instruments must be calibrated | According to schedule | Calibration certificates | | GC-EQP-04 | Equipment affecting results must be uniquely identified | At acquisition | Equipment registry |
REFERENCE: EX-QM/MP-04-20.1 Equipment and Devices Procedure
TRACEABILITY REQUIREMENT: Calibrated equipment must have traceability to national/international measurement standards.
| Constraint ID | Requirement | When | Evidence | |--------------|-------------|------|----------| | GC-SUB-01 | Subcontractor must be competent and ISO compliant | Before subcontract | Competence proof | | GC-SUB-02 | Client must be notified in advance | Before subcontract | Written notification | | GC-SUB-03 | Inspection body remains responsible for subcontracted work | Throughout | Contractual liability | | GC-SUB-04 | Preference for accredited subcontractors | Selection phase | Accreditation check |
| Constraint ID | Requirement | Control | |--------------|-------------|-------------| | GC-PROC-01 | Only documented procedures may be used | Pre-operations check | | GC-PROC-02 | Only standard methods allowed (no non-standard) | Method selection | | GC-PROC-03 | All documents must be current version | Version control | | GC-PROC-04 | Third-party information must be verified for completeness | Data acceptance |
INSPECTION TYPES PERFORMED:
MISSING: Specific operational procedures for each type (IP-layer documents).
MANDATORY ACTIONS:
MANDATORY RECORDS:
RETENTION: 4 years (electronic format acceptable)
| Constraint ID | Requirement | Validation | Evidence | |--------------|-------------|------------|----------| | GC-REP-01 | All inspection work must be documented in report | Post-inspection | Inspection report | | GC-REP-02 | Report format may vary by inspection type | Report generation | Format specification | | GC-REP-03 | No corrections allowed in report | Post-issuance | Version control | | GC-REP-04 | If changes needed, withdraw old & issue new report | Change request | Report registry | | GC-REP-05 | Only authorized persons can sign reports | Signature | Authorization list | | GC-REP-06 | Negative report issued if critical deficiencies found | Final review | Report with findings |
REFERENCE: EX-QM/MP-06-20.1 Inspection Reports Procedure
RE-INSPECTION RULE (Section 8.4.9):
| Constraint ID | Requirement | Process Owner | Resolution Time | |--------------|-------------|---------------|-----------------| | GC-COMP-01 | Documented complaint handling procedure required | Quality Manager | UNSPECIFIED | | GC-COMP-02 | Complaint registered in registry journal | Administrative | Immediate | | GC-COMP-03 | Complaint assigned to investigator | Director | UNSPECIFIED | | GC-COMP-04 | Decision makers must NOT be involved in original inspection | Director | N/A | | GC-COMP-05 | Formal closure notification to complainant | Responsible Officer | UNSPECIFIED | | GC-COMP-06 | Complaints process must be publicly available | Quality Manager | N/A |
REFERENCE: EX-QM/MP-07-20.1 Complaints and Appeals Procedure
NON-DISCRIMINATION CONSTRAINT: All decisions must be free from discriminatory character.
| Constraint ID | Requirement | Responsible | Frequency | |--------------|-------------|-------------|-----------| | GC-DOC-01 | All controlled documents must be adequate, reviewed, updated | Quality Manager | As needed | | GC-DOC-02 | Document changes must be identified | Quality Manager | Per change | | GC-DOC-03 | Correct version must be available at point of use | Quality Manager | Continuous | | GC-DOC-04 | Obsolete documents must be clearly identified if retained | Quality Manager | At obsolescence | | GC-DOC-05 | Confidentiality of documentation must be protected | All personnel | Continuous |
REFERENCE: EX-QM/MP-12-20.1 Document Management Procedure
LEVEL 1: Quality Policy LEVEL 2: Quality Manual (this document) LEVEL 3: Procedures, plans, standards LEVEL 4: Other normative documents (orders, reports, forms, questionnaires, contracts)
RETENTION: Obsolete documents retained for 4 years.
| Constraint ID | Requirement | Evidence Type | Retention | |--------------|-------------|---------------|-----------| | GC-REC-01 | Records system must be established | Inspection records, audit reports, analysis results | MANDATORY | | GC-REC-02 | Records must be clear, precise, unambiguous | All records | N/A | | GC-REC-03 | Records protected from unauthorized access/changes | All records | Continuous | | GC-REC-04 | Records stored securely (physical or electronic) | All records | 4 years | | GC-REC-05 | Inspection info confidential between body & client | Inspection records | 4 years | | GC-REC-06 | Reports issued as single original (scanned copy stored) | Inspection reports | 4 years | | GC-REC-07 | Negative report if critical deficiencies found | Inspection reports | 4 years | | GC-REC-08 | Registry system required (electronic acceptable) | Registration journals | 4 years | | GC-REC-09 | Disposal must protect client confidentiality (burn paper) | All confidential records | At disposal |
REFERENCE: EX-QM/MP-05-20.1 Records Management Procedure
| Constraint ID | Requirement | Frequency | Participants | |--------------|-------------|-----------|--------------| | GC-REV-01 | Management review required | 12 months | Top management | | GC-REV-02 | Review must assess conformity, adequacy, effectiveness | Annually | Top management | | GC-REV-03 | Previous management review results must be considered | Annually | Top management |
INPUT DATA:
OUTPUT DATA:
REFERENCE: EX-QM/MP-09-20.1 Management Review Procedure
| Constraint ID | Requirement | Frequency | Scope | |--------------|-------------|-----------|-------| | GC-AUD-01 | Internal audit procedure required | MANDATORY | ISO 17020 compliance | | GC-AUD-02 | Audit must be conducted periodically | At least annually | All ISO 17020 clauses | | GC-AUD-03 | Previous audit results must be considered | Per audit | Historical data | | GC-AUD-04 | Auditors must be qualified | Per audit | ISO 17020 trained | | GC-AUD-05 | Auditors cannot audit their own work | Per audit | Independence | | GC-AUD-06 | Personnel must be informed of results | Post-audit | All staff | | GC-AUD-07 | Actions must be timely and appropriate | Post-audit | Findings | | GC-AUD-08 | Audit results must be documented | Post-audit | Audit records |
REFERENCE: EX-QM/MP-10-20.1 Internal Audit Procedure
| Constraint ID | Requirement | Trigger | Process | |--------------|-------------|---------|---------| | GC-COR-01 | Corrective action procedure required | Nonconformity detected | Documented process | | GC-COR-02 | Measures to eliminate nonconformity recurrence | Nonconformity | Root cause elimination | | GC-COR-03 | Actions must be timely implemented | Action plan | Defined timeline | | GC-COR-04 | Results must be documented | Action completion | Records | | GC-COR-05 | Effectiveness must be reviewed | Post-implementation | Verification |
MANDATORY STEPS:
REFERENCE: EX-QM/MP-11-20.1 Corrective and Preventive Actions Procedure
| Constraint ID | Requirement | Trigger | Process | |--------------|-------------|---------|---------| | GC-PRE-01 | Preventive action procedure required | Potential nonconformity | Documented process | | GC-PRE-02 | Actions appropriate to potential problems | Risk assessment | Proportional response | | GC-PRE-03 | Results must be documented | Action completion | Records | | GC-PRE-04 | Effectiveness must be analyzed | Post-implementation | Verification |
MANDATORY STEPS:
REFERENCE: EX-QM/MP-11-20.1 Corrective and Preventive Actions Procedure
| Decision Point | Decision Maker | Context | Constraints | |---------------|---------------|---------|-------------| | Conflict of interest declaration | Any personnel | Assignment | Must declare immediately | | Subcontractor selection | Inspection Body Head | Need for subcontracting | Must verify competence | | Inspector assignment | Technical Manager | New inspection request | Check competence, independence | | Inspection readiness | Inspector | Pre-inspection | Object must be prepared | | Nonconformity significance | Inspector | During inspection | Professional judgment | | Report approval | Technical Manager | Report finalization | Technical review | | Report signature | Authorized persons only | Report issuance | Authorization list | | Complaint investigation | Appointed investigator | Complaint received | Independence from original work | | Corrective action approval | Inspection Body Head | After investigation | Effectiveness assessment |
| Action | Approver | Alternative Approver | Veto Authority | |--------|----------|---------------------|----------------| | Quality Manual approval | Director | N/A | N/A | | Procedure approval | Director | N/A | N/A | | Inspector authorization | Technical Manager + IB Head | N/A | Director | | Report signature | Technical Manager | Authorized Inspector | N/A | | Contract initiation | Inspection Body Head | N/A | Director | | Subcontract approval | Inspection Body Head | N/A | Director | | Complaint resolution | Director | N/A | N/A |
IB Head: Inspection Body Head
| Prohibition ID | Action | Context | Penalty | |---------------|--------|---------|---------| | PROH-01 | Inspector inspecting own work | Any inspection | Immediate disqualification | | PROH-02 | Non-authorized person signing report | Report issuance | Report invalid | | PROH-03 | Using non-standard methods | Inspection operations | Non-compliance | | PROH-04 | Correcting issued report | Post-issuance | Must withdraw & reissue | | PROH-05 | Disclosing confidential info without authorization | Any time | Legal liability | | PROH-06 | Commercial pressure on inspection results | Any time | Accreditation risk | | PROH-07 | Auditor auditing own work | Internal audit | Audit invalid | | PROH-08 | Using obsolete documents | Any time | Non-compliance |
The Quality Manual (QM) references but does NOT contain operational workflows. These must be authored as separate IP (Inspection Procedure) documents:
| Missing Document ID | Title | Purpose | Referenced In | |-------------------|-------|---------|---------------| | EX-IP-01 | Cost Estimate Inspection Procedure | Step-by-step workflow for cost estimate inspection | Section 7.1.1 | | EX-IP-02 | Completed Works Inspection Procedure (Form N2) | Step-by-step workflow for Form N2 inspection | Section 7.1.1 | | EX-IP-03 | Technical Supervision Procedure | Step-by-step workflow for construction supervision | Section 7.1.1 |
| Procedure Code | Title | Status | Purpose | |---------------|-------|--------|---------| | EX-QM/MP-01-20.1 | Impartiality and Independence | UNKNOWN | Declaration form, conflict checks | | EX-QM/MP-03-20.1 | Personnel Management | UNKNOWN | Competence, training, authorization | | EX-QM/MP-04-20.1 | Equipment and Devices | UNKNOWN | Equipment management, calibration | | EX-QM/MP-05-20.1 | Records Management | UNKNOWN | Record creation, storage, disposal | | EX-QM/MP-06-20.1 | Inspection Reports | UNKNOWN | Report structure, content, issuance | | EX-QM/MP-07-20.1 | Complaints and Appeals | UNKNOWN | Complaint handling workflow | | EX-QM/MP-08-20.1 | Risk Management | UNKNOWN | Risk identification, mitigation | | EX-QM/MP-09-20.1 | Management Review | UNKNOWN | Review process, inputs, outputs | | EX-QM/MP-10-20.1 | Internal Audit | UNKNOWN | Audit planning, conduct, reporting | | EX-QM/MP-11-20.1 | Corrective and Preventive Actions | UNKNOWN | Nonconformity handling | | EX-QM/MP-12-20.1 | Document Management | UNKNOWN | Document control, version management |
Any KES template for inspection workflows MUST:
| Event Type | Trigger | Required Fields | Retention | |-----------|---------|-----------------|-----------| | CONFLICT_DECLARED | Inspector assignment | Personnel ID, Reason, Date | 4 years | | INSPECTOR_AUTHORIZED | Training completion | Inspector ID, Authorization Level, Date | Permanent | | REPORT_ISSUED | Report finalization | Report ID, Inspector, Manager, Date | 4 years | | REPORT_WITHDRAWN | Report change request | Report ID, Reason, Date | 4 years | | COMPLAINT_RECEIVED | Client submission | Complaint ID, Client, Date | 4 years | | CORRECTIVE_ACTION | Nonconformity found | Action ID, Finding, Date | 4 years | | AUDIT_PERFORMED | Scheduled audit | Audit ID, Scope, Findings, Date | 4 years | | SUBCONTRACT_APPROVED | Subcontracting need | Subcontractor, Scope, Date | 4 years |
Before ANY inspection can start:
During inspection:
Before report issuance:
To complete the governance-to-operations integration:
A compliance guardrail system A constraint layer for KES templates A governance requirements map An audit checklist
An operational workflow A step-by-step inspection guide A state machine definition A KES template
The Quality Manual defines the "rules of the game." The missing IP documents define "how to play the game." KES templates encode both into executable workflows.
END OF GOVERNANCE CONSTRAINTS MAP