First line — Operational management.
The Marketing, Sales, and Client Affairs functions handle commercial relationships. They have no role in certification decisions.
Leadership & Governance
Guardian Middle East LLC’s governance is structured around a registered Senior Executive Function (SEF) accountable to the QFC Authority, an independent Impartiality Committee, and dedicated Quality, Information Security, and Compliance functions. This separation of duties ensures certification decisions remain independent of commercial relationships, in line with ISO/IEC 17021-1 §5.2.
Governance Philosophy
Why Governance Matters
For a third-party certification body, governance is not a corporate-affairs concern — it is a regulatory requirement. The credibility of every certificate Guardian issues depends on a clear, documented, and consistently applied separation between commercial activities (sales, account management, marketing) and certification-decision activities (auditor selection, audit conduct, certification decision-making, complaints handling). This separation is mandated by ISO/IEC 17021-1 §5.2 and applicable IAF Mandatory Documents (notably MD 1, MD 4, MD 11, MD 22, MD 23).
Guardian’s governance structure is designed around this requirement. Every named office-holder, every committee, and every reporting line in this page exists to give the SEF, the Impartiality Committee, the QFC Authority, and our clients confidence that certification decisions are made independently — on technical merit, by competent personnel, free from commercial pressure or conflicts of interest.
The Three Lines of Governance
Second line — Quality and Compliance.
The Quality Function, Information Security Function, and Compliance / MLRO operate the management system, monitor conformity, and report independently to the SEF.
Third line — Independent oversight.
The Impartiality Committee provides oversight of impartiality risks, free of operational management. The Committee reports to the SEF and the wider Guardian governance structure outside Qatar.
Senior Executive Function (SEF)
Pursuant to QFC Companies Regulations and the Conduct of Business Rules, Guardian Middle East LLC has a designated Senior Executive Function (SEF) registered with the QFC Authority. The SEF is the ultimate accountable office-holder for the firm’s regulated activity and the primary point of contact with the QFC Authority and the Companies Registration Office.
| Field | Detail |
|---|---|
| Role | Senior Executive Function (SEF) |
| Office-holder | Pragyesh Kumar Singh |
| Registration | Registered with the QFC Authority under Licence 03870 and reported to the QFC Companies Registration Office (CRO). |
| Effective From | 21 August 2025 date of QFC Licence effective. |
| Primary Accountabilities |
|
| Reporting | To the Board of Guardian Middle East LLC and to the wider Guardian governance structure outside Qatar. |
| Public contact | Via the Office of the SEF, sef@guardian.qa corporate channel only. |
Notification of Changes
Any change to the SEF must be notified to the QFC Authority via the Client Portal immediately upon such change, in accordance with the QFC LLC submission requirements (Reference: post-licensing Item 21 — Change in Registered Function). Updated SEF details will be reflected on this page within 14 days of QFC Authority confirmation.
Impartiality Committee
Guardian Middle East LLC operates an Impartiality Committee in alignment with ISO/IEC 17021-1 §5.2 and applicable IAF Mandatory Documents. The Committee is structurally independent of operational management and certification decision-making.
Mandate of the Committee
- Identify, assess, and treat threats to impartiality across all certification activities.
- Maintain and review the Impartiality Risk Register, with quarterly assessment cycles and ad-hoc review on triggering events.
- Oversee the management of conflicts of interest declared by auditors, decision-makers, and other personnel involved in certification activity.
- Review the financial and commercial relationships between Guardian Middle East LLC and any client, partner, or third party that could create or appear to create an impartiality threat.
- Provide an independent escalation channel for any personnel raising impartiality concerns.
- Approve the appointment and removal of decision-makers and designated personnel handling complaints and appeals.
- Report annually to the SEF and the wider Guardian governance structure on impartiality posture and remediation actions.
For detailed controls, review Our Impartiality Policy.
Composition
The Impartiality Committee comprises members drawn from the following categories, in line with IAF MD 1 and the impartiality balance principle of ISO/IEC 17021-1:
- A representative of certification body management — internal, with no direct line of authority over auditors or decision-makers.
- Independent members — external to Guardian Middle East LLC, with sectoral expertise across the standards Guardian certifies. Independent members hold the majority position in the Committee’s decisions on impartiality matters.
- A representative of the certificated organizations — invited from clients holding active Guardian-issued certificates, on rotation.
- A representative of broader interested parties — drawn from regulators, NGOs, academia, or industry bodies, where available.
Operating Rhythm
- Quarterly Impartiality Risk Register review.
- Ad-hoc reviews triggered by significant changes (new partnership, major commercial event, complaint about impartiality, regulatory change).
- Annual self-assessment of Committee effectiveness reported to the SEF.
- Records maintained under the Quality Management System and available for accreditation-body assessment.
Guardian’s formal commitment to independence and impartial decision-making is outlined in the full Impartiality Statement.
Quality Function
The Quality Function holds custody of Guardian’s Quality Management System and the conformity of operational activity with ISO/IEC 17021-1, ISO/IEC 17020 (where applicable), and applicable IAF Mandatory Documents.
Primary Responsibilities
- Quality Manual custody — maintenance, version control, distribution, and revision of the Quality Manual and supporting procedures.
- Internal audit programme — planning, conducting, and reporting internal audits of Guardian’s certification body activities, with corrective and preventive action follow-up.
- Management review — preparation of management review inputs (audit results, complaints, impartiality risks, accreditation findings, market changes) and tracking of management review actions to closure.
- Competency management — auditor competency framework, qualification matrices for the standards Guardian audits, training-needs analysis, and witnessed-audit programmes.
- Document and record control — ensuring confidentiality, integrity, retention, and secure disposal of audit information, certificate records, and client documentation.
- Calibration and method validation — for inspection activity, ensuring inspection methods, equipment, and personnel meet ISO/IEC 17020 requirements via the partnership with TNV Global Limited.
Reporting
The Quality Function reports to the SEF, with a direct line to the Impartiality Committee on matters affecting impartiality. The Quality Function is the primary internal interface with the accreditation bodies (UAF, IAS) and recognition body (QS) during accreditation and recognition assessments.
Information Security Function
The Information Security Function holds custody of Guardian’s Information Security Management System aligned with ISO/IEC 27001 controls. The function ensures confidentiality, integrity, and availability of audit information, client records, and personal data processed by Guardian Middle East LLC.
Primary Responsibilities
- Information Security Management System — maintenance, control, and continual improvement aligned with ISO/IEC 27001.
- Audit information confidentiality — controls, access management, and secure communication channels for audit team information, client management system documentation, and audit working papers.
- Personal data protection — alignment with QFC Data Protection Regulations and Qatar PDPPL Law 13/2016. Privacy notices, data subject rights handling, records of processing operations.
- Personal Data Breach response — notification to the QFC Data Protection Office within 72 hours of becoming aware of a breach, in line with QFC DPR requirements.
- IT security operations — endpoint security, identity and access management, audit logging, vulnerability management, and incident response.
- Cloud and platform governance — security review and risk assessment of cloud services and SaaS platforms used in operational activity.
- Cryptographic controls — protection of certificates, audit reports, and transmissions of sensitive data.
Reporting
The Quality Function reports to the SEF, with a direct line to the Impartiality Committee on matters affecting impartiality. The Quality Function is the primary internal interface with the accreditation bodies (UAF, IAS) and recognition body (QS) during accreditation and recognition assessments.
Information Security Function
The Information Security Function holds custody of Guardian’s Information Security Management System aligned with ISO/IEC 27001 controls. The function ensures confidentiality, integrity, and availability of audit information, client records, and personal data processed by Guardian Middle East LLC.
Primary Responsibilities
- Information Security Management System — maintenance, control, and continual improvement aligned with ISO/IEC 27001.
- Audit information confidentiality — controls, access management, and secure communication channels for audit team information, client management system documentation, and audit working papers.
- Personal data protection — alignment with QFC Data Protection Regulations and Qatar PDPPL Law 13/2016. Privacy notices, data subject rights handling, records of processing operations.
- Personal Data Breach response — notification to the QFC Data Protection Office within 72 hours of becoming aware of a breach, in line with QFC DPR requirements.
- IT security operations — endpoint security, identity and access management, audit logging, vulnerability management, and incident response.
- Cloud and platform governance — security review and risk assessment of cloud services and SaaS platforms used in operational activity.
- Cryptographic controls — protection of certificates, audit reports, and transmissions of sensitive data.
Reporting
The Information Security Function reports to the SEF and provides quarterly information-security posture reports to the SEF and the Impartiality Committee. Material incidents are reported to the SEF immediately upon detection.
Compliance / MLRO Function
The Compliance / MLRO function holds custody of Guardian Middle East LLC’s compliance posture under QFC AML/CFTR 2019, Qatar AML Law No. 20 of 2019, QFC General Rule 8A on Beneficial Ownership, and the broader regulatory environment applicable to QFC firms.
Primary Responsibilities
- Customer Due Diligence (CDD) — implementing the firm’s Risk-Based Approach for client onboarding, including identification, verification, beneficial ownership, source of funds for onboarding fees, and politically-exposed-person screening.
- Enhanced Due Diligence (EDD) — applied to higher-risk clients, jurisdictions, scopes, and beneficial-ownership structures, with ongoing monitoring and senior management approval where required.
- Beneficial Ownership Register — establishment, verification, maintenance, and reporting of beneficial ownership in line with QFC General Rule 8A.
- Suspicious Transaction Reporting — assessment, escalation, and reporting of suspicious activity in line with Qatar AML Law and QFC AML/CFTR.
- Sanctions screening — at onboarding and on an ongoing basis, against UN Security Council sanctions, Qatar national sanctions lists, and other applicable lists.
- Training and awareness — annual AML/CFT training for all client-facing personnel, with role-specific modules for personnel performing CDD.
- Regulatory liaison — primary contact with the QFC Authority, FIU Qatar, and other competent authorities on AML/CFT matters.
- Conflicts and inducements register — together with the Quality Function and Impartiality Committee, monitoring conflicts of interest, gifts, and inducements that could affect impartiality.
Reporting
The Compliance / MLRO function reports to the SEF with a direct escalation channel to the QFC Authority and the FIU Qatar where required. Compliance reports are tabled at quarterly Impartiality Committee meetings on matters with impartiality implications.
Operational Functions
Operational functions support the regulated activity but do NOT participate in certification decisions. They are part of the first line of governance and are structurally separated from the Quality, Compliance, and Impartiality functions.
| Function | Scope |
|---|---|
| Client Affairs | First point of contact for client enquiries, applications, contracting, scheduling, account management, and routine client communications. Excluded from audit team selection and certification decision-making. |
| Marketing & Communications | Brand, website, content, public relations, and event participation. Marketing materials are reviewed by the Quality and Compliance functions for consistency with impartiality and use-of-marks policies before publication. |
| Finance & Administration | Invoicing, receivables, payables, payroll, premises, IT support, and statutory filings with Compliance. Excluded from audit and certification decision activity. |
| Audit Coordination | Logistics for audit-team mobilisation, document collation, scheduling, travel, and accommodation. Coordination only, does NOT participate in audit findings or certification decisions. |
Audit Personnel & Decision-Makers
The personnel performing audits and making certification decisions are appointed under documented competency frameworks and are subject to ongoing performance monitoring, witnessed-audit assessments, and periodic recertification of competence.
Auditor Pool
- Lead Auditors qualified per ISO/IEC 17021-1 and applicable IAF Mandatory Documents (notably MD 5 on duration of audits and MD 11 on sector-specific application).
- Technical Experts drawn from sectoral specialisations (construction, oil & gas, healthcare, IT/AI, financial services, education, manufacturing, energy).
- Witnessed audits required at appointment and periodically thereafter, in line with the relevant accreditation requirements.
- Continuing professional development required annually, with documented training records.
- Confidentiality, impartiality, and conflicts-of-interest declarations signed at appointment and renewed annually.
Certification Decision-Makers
Decision-makers for issuance, suspension, withdrawal, and renewal of certificates are individuals appointed by the SEF on recommendation of the Quality Function and approval of the Impartiality Committee. Decision-makers operate independently of the audit team that conducted the underlying audit. The same individual cannot serve as the audit team leader and the decision-maker for the same certification.
Tier 4 Decision Authority
Certification decisions for Tier 4 (Guardian Approved Scheme) certifications and ISO 26000 attestations are made by Guardian Middle East LLC’s appointed decision-maker under the same documented procedures as accredited certifications, with oversight from the Quality Function and Impartiality Committee. The fact that the scheme is non-accredited does not relax the decision-making controls — it is the absence of external accreditation oversight that makes internal governance more, not less, important.
Use of External Advisors
Guardian Middle East LLC engages external advisors in narrowly-defined circumstances, always with documented controls to ensure independence of certification activity:
- Legal advisors — for QFC compliance, contract drafting, regulatory advice, and dispute resolution.
- Auditors of the firm itself — appointed under QFC Companies Regulations for the firm’s own statutory audit (separate from certification activity).
- Information security and IT advisors — for ISMS development, penetration testing, and incident response.
- Translation and interpretation — for Arabic / English translation of audit reports, marketing materials, and certificates.
- Witnessed-audit observers — appointed by the accreditation bodies (UAF, IAS) and recognition body (QS).
External advisors are NOT involved in certification decisions. They are engaged on documented terms of engagement that include confidentiality, conflicts-of-interest, and impartiality declarations where their work could touch a certification activity.
COMPLAINTS & APPEALS
Guardian operates an independent complaints and appeals process compliant with ISO/IEC 17021-1:2015.
Full process: → /complaints-appeals/
Frequently Asked Questions
Pragyesh Kumar Singh is the registered Senior Executive Function (SEF) of Guardian Middle East LLC, named in QFC Licence 03870 and reported to the QFC Companies Registration Office. The SEF is the ultimate accountable office-holder for the firm's regulated activity and the primary contact with the QFC Authority.
The Impartiality Committee is an independent governance body required under ISO/IEC 17021-1 §5.2. It is structurally separate from operational management and is responsible for identifying, assessing, and treating threats to impartiality across all of Guardian's certification activities. Independent members hold the majority position on impartiality decisions.
The Committee comprises a representative of certification-body management, independent members (external, with sectoral expertise — holding the majority position), a representative of certificated organisations (rotational), and where available, a representative of broader interested parties such as regulators, NGOs, academia, or industry bodies.
Guardian operates documented conflict-of-interest controls: declarations at appointment and annually for all personnel; structural separation between commercial functions (Marketing, Sales, Client Affairs) and certification-decision functions (Audit, Quality, Decision-Maker); auditor rotation policies; impartiality reviews before audit team appointment; and an Impartiality Committee escalation channel for personnel raising concerns.
Certification decisions are made by an appointed decision-maker who is structurally independent of the audit team that conducted the underlying audit. The same individual cannot serve as audit team leader and decision-maker for the same certification. Decision-makers are appointed by the SEF on recommendation of the Quality Function and approval of the Impartiality Committee.
Guardian uses both employed lead auditors and contracted technical experts, drawn from a documented pool. All auditors — employed or contracted — are subject to the same competency framework, witnessed-audit programmes, declarations of confidentiality and impartiality, and continuing professional development requirements. Selection for any specific audit is based on competence and absence of impartiality concerns, not employment status.
No. Certification decisions are made by appointed decision-makers operating under documented procedures. The SEF is the strategic accountable office-holder, not the operational decision-maker for individual certifications. The SEF retains escalation authority for material exceptions, unresolved impartiality concerns, and matters with regulatory implications.
Anyone may raise an impartiality concern through impartiality@guardian.qa or by formal correspondence addressed to the Impartiality Committee at Guardian Middle East LLC's registered office. Concerns are acknowledged within five working days and escalated to the Committee for review. Confidentiality is preserved. The Impartiality Committee escalation route is independent of the Complaints and Appeals process.
Yes. Changes in registered functions (SEF, MLRO, etc.), changes in directors and shareholders, changes in beneficial ownership, and changes in key personnel are reported to the QFC Authority and Companies Registration Office through the Client Portal in line with QFC LLC submission requirements. Material governance changes are recorded against Guardian's QFC Licence.
Photographs and biographical details of named office-holders are published only with explicit written consent from the individual concerned, in line with Qatar PDPPL Law 13/2016. Where consent has been provided, biographies are kept current and aligned with the individual's regulated function. Where consent has not been provided, the role and accountabilities are described without personal information.
Guardian Assessment Pvt Ltd (the certification body whose accreditation underpins Guardian's Tier 1 and Tier 2 activity) and Guardian Middle East LLC (the QFC-licensed Qatar entity) are separate legal entities with separate leadership. Where individuals serve roles in both entities, conflict-of-interest declarations are documented and managed through the Impartiality Committee. The accreditation chain is published on /about/accreditation/.
Guardian's full Impartiality Statement is published at /legal/impartiality-statement/. The Statement includes the impartiality commitment, the structural safeguards in place, the framework for managing impartiality threats, and the escalation channels available to clients, personnel, and the public.
Compliance Footnotes
Guardian Middle East LLC’s governance and impartiality framework is structured in alignment with ISO/IEC 17021-1 §5.2 and applicable IAF Mandatory Documents (MD 1, MD 4, MD 11, MD 22, MD 23). The Senior Executive Function is registered with the QFC Authority under QFC License 03870. Personal information of named office-holders is published only with consent under Qatar PDPPL Law 13/2016. Material changes in registered functions are notified to the QFC Authority within the timelines required by QFC LLC submission requirements.