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Internal Audit Report

Audit Identification: IA202613
Area: Management Review
Audit Date: 6th May 2026
Auditor: Sean Ashton (HSQE Consultant, Onyx Operations)
Date Completed: 6th May 2026
Findings: 0 Non-conformities, 1 Observation
Scope: ISO 9001:2015 / 14001:2015 / 45001:2018 — Clause 9.3
Document Number: FORM_INTAR001 Rev 1 ID 01/09/2025
Builds on prior audit: IA202513 (01/10/2025) — 0 NC, 2 OBS

Executive Summary

This audit re-examined Management Review compliance one year on from IA202513. The audit was timed deliberately ahead of the September 2026 Annual Management Review so that the inputs being prepared can be assessed against clause 9.3 requirements before the meeting itself.

The 2025 observations are addressed by the 2025–26 IMS rebuild and the new continuous-compliance framing:

  • CAR-2025-017 (Management Review minutes lacking formal structure to demonstrate clause 9.3 input coverage) — closed. The continuous-compliance model now positively asserts that the standing weekly Director / HSQE compliance call is the substantive review forum, with the September Management Review providing the strategic-level confirmation. The MR-26 agenda (in preparation) maps explicitly to clause 9.3 inputs.
  • CAR-2025-018 (worker consultation as MR input) — partially closed. The TBT Programme attendance template and Director Site-Tour records both capture worker consultation in real time. The mechanism for summarising this into the September MR pack is not yet defined; rolled forward as IA202613 OBS-01.

One new 2026 observation: the September 2026 Management Review pack format should be drafted before mid-August so the Directors can review and the auditor surveillance can sample the inputs trail.

Year-on-year follow-up — IA202513 outcomes

2025 ref 2025 finding (summary) Status in 2026 audit
OBS-13-01 / CAR-2025-017 MR minutes lacking formal structure to show clause 9.3 input coverage Closed. Continuous-compliance model now positively asserts the standing weekly call as the substantive forum; MR-26 agenda being prepared with explicit clause 9.3 mapping.
OBS-13-02 / CAR-2025-018 Worker consultation as MR input not systematically captured Partially closed. TBT and Director Site-Tour records capture worker input in real time. Roll-up mechanism for September MR pack not yet defined — rolled forward as IA202613 OBS-01.

Introduction

This audit examined preparation for the September 2026 Annual Management Review against clause 9.3. The audit was deliberately timed in May (4 months before the meeting itself) so that any gaps in input preparation can be addressed in time.

Aims & Objectives

  1. Confirm closure or progress on IA202513 OBS-13-01 and OBS-13-02
  2. Verify clause 9.3 input categories are being prepared with named source documents:
  3. 9.3.2 a) status of actions from previous review
  4. 9.3.2 b) changes in external/internal issues relevant to the IMS (incl. compliance obligations, risks/opportunities)
  5. 9.3.2 c) information on QMS/EMS/OHS performance (including KPIs, NC trends, audit results, compliance evaluation, monitoring/measurement results)
  6. 9.3.2 d) adequacy of resources
  7. 9.3.2 e) effectiveness of actions to address risks and opportunities
  8. 9.3.2 f) opportunities for improvement
  9. For ISO 14001 + 45001 specifically: consultation/participation of workers
  10. Confirm the September 2026 MR has a date scheduled

Audit Method

  • Document Review: SOP 6.4 Management Review Rev 3 HTML, APP_11 HSQE KPIs Rev 3 (post-simplification), APP_21 NC Register, APP_22 Accident Statistics, APP_05 Risk & Opportunity Log, APP_10 Legal & Compliance Register, the 2025 Management Review minutes (September 2025), gap-closure tracker (the source of "actions from previous review").
  • Interviews Conducted: Directors (Aaron + Leanne Mason — MR participants), HSQE Consultant (Sean Ashton — MR preparation lead).
  • Observations: 2025 MR minutes structure; weekly Director / HSQE compliance call notes (Jan–Apr 2026) as the running input record.
  • Sampling: Mapping of clause 9.3.2 a–f input categories against currently-existing IMS evidence.

Non-conformities

No non-conformities identified.

Observations

No. Element Summary Action Suggested Ref
OBS-01 9.3 Worker consultation roll-up for September 2026 MR Worker consultation evidence (TBT attendance template, Director Site-Tour records, operative questions captured) is generated continuously but no roll-up format is yet defined for inclusion in the September 2026 MR pack. The auditor reviewing the MR will expect to see this input category explicitly captured. Define a 1-page worker-consultation summary template; populate from May–August 2026 TBT and DST records; include in the September MR pack. CAR-2026-007

Corrective Action Summary

CAR-2026-007 — Owner: Sean Ashton (HSQE Consultant). Target close: 31/08/2026 — in time for the September 2026 Management Review. The 1-page worker-consultation summary will be populated from the May 2026 TBT attendance records (excavation / HAVS / COSHH-fuels), the Director Site-Tour records (28/04/2026 onwards), and any operative-raised actions captured into APP_21.

Conclusions

Management Review preparation is on a sound footing for the September 2026 meeting:

Areas Meeting Requirements (sustained from IA202513):

  • Annual Management Review continues to be scheduled (September 2026)
  • SOP 6.4 continues to define the methodology
  • 2025 MR minutes captured the inputs and produced action-tracked outputs

New strengths since IA202513:

  • Continuous-compliance positively framed. The standing weekly Director / HSQE compliance call is now the substantive review forum, with the September MR as the strategic confirmation. This addresses the IA202513 OBS-13-01 minutes-structure concern by reframing what the MR is for.
  • Clause 9.3.2 a) status of previous actions — directly evidenced by the gap-closure tracker, with 10 of 15 P1 items closed in the year and the remaining 5 with named owners + target dates.
  • Simplified KPIs ready for MR-26 adoption — E3 carbon (measure-and-report), B2 improvement (active programme), APP_06 Aspects 1 + 9 (customer-aligned).
  • Substantive improvement portfolio (clause 9.3.2 e/f) — the 2025–26 IMS rebuild itself is the year's improvement evidence.

Recommendations

  1. Close CAR-2026-007 with the worker-consultation roll-up template by 31/08/2026.
  2. Schedule the September 2026 MR explicitly in the calendar — Aaron + Leanne + Sean — and circulate the input pack 1 week ahead.
  3. Use MR-26 to formally adopt the simplified KPI set as the 2026–27 baseline.
  4. Capture MR-26 outputs as Issue 2 of MAN_01 if material strategic changes land.

Feedback & Acknowledgments

Full cooperation. The 2025–26 cycle has done much of the substantive thinking that previously had to be done at the MR itself; the September 2026 MR can therefore focus on strategic confirmation rather than catch-up.

Audit Report Prepared By

Name Position Signature Date
Sean Ashton HSQE Consultant S. Ashton 06/05/2026
Aaron Mason Director A. Mason 06/05/2026

Corrective Action Close Out

CAR-2026-007 — open. Target close 31/08/2026.