"Did you bribe the auditor?"

I've talked in earlier posts about how formally analyzing the Context of the Organization can support you in assessing the business risks you face, or the scope of your management system. But sometimes your context can have a huge impact even in a far less formal way.

Years ago, I worked for a small company here in Santa Barbara, California, that was acquired by a Big Company with headquarters in Europe. A couple of years after the acquisition, Big Company informed us that we had to certify to ISO 14001, the environmental management system standard.

So we set to work, building on our ISO 9001 quality system to create an integrated management system addressing both standards. We worked with an expert from another of Big Company's American offices, trained everyone at our location about the new system, and scheduled an audit. We passed the audit, and got our certificate. So far, so good.

The management from Big Company's home office back in Europe congratulated us, of course, but at the same time they expressed considerable incredulity. Our office had had a lot of trouble getting our initial certification to ISO 9001 some years before, so our European colleagues tended to think of us as chronically a day late and a dollar short. At the same time, when it came to ISO 14001 the European home office hadn't achieved certification until their third external audit! How did we—of all people—manage to score on our first? One vice-president even asked me, "Did you bribe the auditor?" I think he was joking—he made it sound like a joke—but clearly he was also rattled.

Just to be clear, no of course we didn't bribe the auditor. (Long time readers will remember this post from two years ago, where I explain exactly why bribery is a bad thing, as if that weren't already obvious!) I don't remember what I told our VP—the question was so unexpected that I probably fumbled it. But months later, in a very prolonged case of l'esprit d'escalier, I figured out the true answer to explain the seeming incongruity that was troubling him.

In the first place, certification to ISO 14001 generally involves implementing two kinds of measures in your organization: environmental measures and system measures.

• Environmental measures are the programs you put in place in order to address your environmental impacts. These can be simple things like recycling your waste paper and your printer toner cartridges, or they can be large programs to reduce pollution or toxic waste resulting from your manufacturing activities. It all depends on what your current environmental impacts happen to be.
• System measures are (in essence) a series of paperwork exercises, that integrate these environmental activities into an overall management system. These measures include assessing your current environmental impacts, planning which ones to address, planning the programs to address them, measuring the results (i.e., the effectiveness) of those programs, and then using the output of those measurements to replan for next year.  

Certification to ISO 14001 requires that both kinds of measures are in place and working smoothly. And the reason our European home office had so much trouble getting their certificate was that they had to implement measures like a recycling program (and others, of course) from scratch. But it took a while for their employees to develop new habits. 

So an auditor would come to the site and hear that the company had implemented a recycling program. Then he would see that all the recycling bins were empty, and that people discarded copier paper into the regular trash. Naturally he would write a nonconformity that the recycling program was ineffective. Multiply this one example by enough other instances of the same basic problem, and you can see why it took them three tries to get their certificate.

But in our office the project was a lot easier. Remember that we were located in Santa Barbara, California. Santa Barbara was the site of a major 1969 oil spill; public outrage at the spill kickstarted local environmental activism, resulting in the 1970 Environmental Rights Day, and (a few months later) the very first Earth Day. Consequently, state and local ordinances governing the environmental behavior of businesses are already very strict, and have been for many years. Any company operating here has to comply to keep their doors open, and employees take environ­mental measures for granted.

So when we began our project to achieve ISO 14001 certification, half the job was already done. All we had to implement were the system measures. We did the assessments, determined that our current environmental measures were appropriate, and set up metrics to track their effectiveness.

We didn't have to bribe the auditor. We didn't have to be smarter than our European colleagues, and we didn't have to work harder. We just benefitted from our location, and from all the extra requirements which that location implied. In that sense, our context did half the work for us.  

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Quality in voting, or, What's in ISO/TS 54001?

Last month, when I was writing about the proposed changes in ISO 9000, I noted that a lot of vocabulary had been imported from the sector-specific standard ISO/TS 54001, Quality management systems — Particular requirements for the application of ISO 9001:2015 for electoral organizations at all levels of government. At the time I thought it was an interesting curiosity, but I let it go. After a while, though, I began to wonder: What's really in this standard? How do you define a standard for quality in voting? 

That's a good question. Let me turn it around just a little bit: Suppose you had to write a quality standard for electoral bodies—what would you put in it?  

Where do you start?

First, I wouldn't want to start with a blank sheet of paper. I'd prefer to build on top of proven concepts. Since the question is about building a quality management system for electoral bodies, I'd start by using ISO 9001 as a framework.

Second, I'd recognize that voting is already governed by a lot of laws: national, regional, and local. They aren't going anywhere, so a general management system standard has to recognize those laws. There are even international compacts and conventions which touch on the right to vote; since these compacts are recognized around the world, a standard should be aware of them too.

Third, there is a very specific risk related to voting. All modern democracies rely on the secret ballot. But when ballots are filled out in secret, there is an enormous incentive for vote-counters to cheat in favor of the candidate they prefer. That doesn't mean a lot of cheating actually goes on; at any rate, I did a quick Google search just now which suggests that "documented cases of election fraud are relatively rare worldwide, particularly in established democracies." But the only thing that prevents it is that the world's "established democracies" have all implemented procedures to maximize the transparency of the electoral process and to minimize the opportunity for cheating. Therefore any management system standard governing an electoral body has to take the commitment to transparency very seriously indeed.

It turns out that those three points define the content of the ISO/TS 54001 standard pretty exactly. 

A sector-specific standard

In line with the first point above, ISO/TS 54001 is a sector-specific standard. Like many other such standards,* it is built on ISO 9001 in a very literal sense. It includes every word from the text of ISO 9001 (marked off in boxes) and then adds specialized requirements as needed which pertain to electoral bodies in particular. 

One of the important additions is that ISO/TS 54001 defines the high-level processes which electoral bodies have to address. You remember that ISO 9001 lets each organization define its own processes, because the standard is meant to cover any possible organization or industry. The electoral standard does not offer similar flexibility. The committee behind the standard determined that at a high level all electoral activity looks broadly similar, and they wanted to make sure all the elements are covered. Therefore one of the two largest additions which the electoral standard makes to ISO 9001 is in Annex B, which defines the eight electoral processes that must be considered:

1. Voter registration
2. Registration of political organizations and candidates
3. Electoral logistics
4. Vote casting
5. Vote counting and declaration of results
6. Electoral education
7. Oversight of campaign financing
8. Resolution of electoral disputes

Another important addition is that ISO/TS 54001 requires the electoral body to create an electoral service development plan, which is a document identifying all the requirements the electoral body has to meet, and spelling out how the body will meet them.

And there are a few updates to the rules of ISO 9001 that derive specifically from the periodic and cyclical nature of elections, as distinct from many other kinds of product or service provision which are more or less continuous.** 

Laws and compacts

To be sure, ISO 9001 recognizes the existence of legal requirements, as one of the factors that constrain an organization's choices.*** But there are a few points where ISO/TS 54001 addresses legal requirements more pointedly.

For example, clause 4.3 (Determining the scope of the quality management system) specifically forbids exclusions from the scope of the electoral quality management system, except in two cases:

• Exclusions are permitted from clause 8 (Operation), if applicable.
• Exclusions are permitted if they "resolve conflicts with the applicable legal framework." But in that case it is mandatory that the exclusions "not contravene the Universal Declaration of Human Rights or the International Covenant on Civil and Political Rights."

International law shows up again in clause 9.2.3 (Internal audit), which specifically requires that "The electoral body shall conduct further internal audits to determine whether the electoral quality management system conforms to international legal obligations for democratic elections."

There are smaller references as well, including one in clause 7.5.6.3 (For the registration of political organizations and candidates) which requires "an explicit statement indicating whether there are legal requirements for gender-specific quotas for candidate registration." In general, the topic of legal and international requirements is never far away.

Transparency    

The commitment to transparency drives the other huge addition to the requirements of ISO 9001. Under clause 7.5 (Documented information), ISO/TS 54001 adds more than five pages of explicit documentation requirements. 

This might surprise you. After all, in general the broad trend in quality management systems over the last couple of decades has been to reduce mandatory documentation. The key thought has been, "If you need to write it down, write it down. Otherwise why bother?"

But not for electoral bodies.

Here the rule is very clear: 

• Write down every requirement that pertains to you.
• Write down exactly how you are going to meet each requirement.
• Then keep records showing that you did exactly what you planned.  

There are specific documentation and records requirements for each of the eight electoral processes, and the ISO/TS 54001 standard requires you to meet all of them. To be clear, these rules are a minimum: you can always document or record more if you like. Never less.

This way, if there is ever a dispute—and remember that Dispute resolution is one of the eight electoral processes—there will be a clear paper trail showing exactly what happened. And if the paper trail is clear enough, it should be possible to resolve the dispute by conducting an audit rather than by massing in the streets.

That's certainly the hope, at any rate.

Demonstrations in Mozambique after a disputed vote in October 2024.

It's not clear to me how widely the standard has been adopted, but at least now I know how it holds together.

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* Consider, for example, IATF 16949 for automotive companies or AS9100 for aerospace, to name only two.

** For example, there is an addition to clause 5.3 (Organizational roles, responsibilities and authorities) which requires that "responsibilities and authorities are communicated within the electoral body prior to the election process" [my emphasis]. Again, clause 9.3.1 (Management review) requires the organization "to conduct management reviews with sufficient frequency to ensure adequate oversight of the entire electoral quality management system and all of its electoral processes." Depending on how often elections are held, one review a year might not be the best frequency to keep the system running reliably. 

*** See, for example, clause 4.1, NOTE 2: "Understanding the external context can be facilitated by considering issues arising from legal, technological, competitive, market, cultural, social and economic environments, whether international, national, regional or local." [Emphasis mine.]