Petroleum Development Oman L.L.C.: Document Title: Corporate HSE Audits

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Petroleum Development Oman L.L.C.

Document Title: Corporate HSE Audits


Document ID PR-1969

Document Type Procedure

Security Unrestricted

Discipline HSE MS Audit

Document Owner Corporate Function Discipline Head- Audit

Month and Year of Issue April 2012

Version 1.1

Keywords Audit

Copyright: This document is the property of Petroleum Development Oman, LLC. Neither the
whole nor any part of this document may be disclosed to others or reproduced, stored in a retrieval
system, or transmitted in any form by any means (electronic, mechanical, reprographic recording or
otherwise) without prior written consent of the owner.
Revision: 1.1
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Document Authorisation

Document Owner Document Custodian Document Author


Name in full: Naaman Naamany Name in full: Saeed Maamary Name in full: Younis Hinai
Title: Corporate SE Manager Title: Head HSE Corporate Planning Corporate HSE Auditor
Date: 01/04/2012 Date: 31/3/2012 Date: 27/3/2012

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Revision History
The following is a brief summary of the four most recent revisions to this document. Details of all revisions prior
to these are held on file by the Document Custodian.

Version No. Month & Author’s Name and Title Scope / Remarks
Year
1.0 Jan 2012 Younis Hinai New Corporate Audit procedure Issued
Corporate HSE Auditor
1.1 March 2012 Younis Hinai • Minor text edits
Corporate HSE Auditor • Drop of use of Risk Assessment Matrix
• Inclusion of action close-out time-frame in
table 3

User Notes:
1. The requirements of this document are mandatory. Non-compliance shall only be authorised by a
designated authority through STEP-OUT approval as described in this document.
2. A controlled copy of the current version of this document is on PDO's live link. Before making
reference to this document, it is the user's responsibility to ensure that any hard copy, or electronic
copy, is current. For assistance, contact the Document Custodian.
3. Users are encouraged to participate in the ongoing improvement of this document by providing
constructive feedback.

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Related Business Processes & CMF Documents


Related Business Processes
Code Document Title
CP-122 HSE MS

Parent Document(s)
Doc. No. Document Title
PL-04 HSE Policy
PL-10 Security & Emergency Response Policy

Other Related CMF Document(s)


Doc. No. Document Title
CP-142 Internal Audit Code of Practice
PR-1712 Level 3 Audit

The related CMF Documents can be retrieved from the Corporate Business Control
Documentation Register CMF.

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TABLE OF CONTENTS

1 Introduction 7
1.1 Purpose and Objectives 7
1.2 Scope and Applicability 7
1.3 Review and Improvement 7
1.4 Distribution 7
2 Roles and Responsibilities 8
2.1 Roles and Responsibilities 8
2.2 Step-out Approval 9
3 Procedure 10
3.1 Overview 10
3.2 Develop Audit Program 10
3.2.1 Level 1 HSE Audits 10
3.2.2 Level 2 HSE Audits 11
3.2.3 Level 3 HSE Audits 11
3.3 Audit Execution 11
3.3.1 Initiate the audit 12
3.3.2 Conduct document review 13
3.3.3 Prepare for audit activities 13
3.3.4 Conduct audit activities 13
3.3.5 Prepare Audit Report 16
3.3.6 Conduct Audit Follow Up 17
4 Auditor selection criteria 18
5 Performance Standards, Monitoring, and Reporting 19
5.1 Performance Standards 19
5.2 Performance Monitoring Requirements 19
5.3 Reporting Requirements 19
6 Appendices 20
6.1 Definitions 20
6.2 Abbreviations 20
6.3 Key References 21
6.4 Formats and Templates 21
6.5 Additional Information 21

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Tables
Table 1: Level 1 HSE audits program 10
Table 2: Level 2 HSE Audits program 11
Table 3: Classification of audit findings 15
Table 4: Controls assessments color coding 16
Table 5: HSE audits program compliance 19
Table 6: HSE audits action close out status 19

Figures
Figure 1: HSE Audit Hierarchy 7
Figure 2: Overview of audit activities 12

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Introduction
1.1 Purpose and Objectives
This procedure is required to define the levels of HSE MS Audit and the methodology to
manage them.

1.2 Scope and Applicability


This procedure applies to all levels of HSE Management Audits in PDO.
PDO has a three-tiered Audit hierarchy as explained in the diagram below:

Figure 1: HSE Audit Hierarchy

1.3 Review and Improvement


This procedure needs to be reviewed every three years as a minimum but if there are major
changes affecting the auditing practices, it will be reviewed as frequently as required.

1.4 Distribution
This procedure will be hyperlinked to the HSE MS of PDO and made accessible to all PDO
personnel and any other parties tasked with carrying out work covered by this procedure on
behalf of PDO.

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Roles and Responsibilities


1.5 Roles and Responsibilities

Audit Manager
For Level 1 Audits: Head Corporate HSE Planning and Audits.
For Level 2 Audits: Respective Directorate HSE Team Leader.
For Level 3 Audits: Process/Activity Owner.

The Audit manager is responsible for


• Establishing a risk based annual audit program
• Obtaining approval for the audit program – Internal Assurance committee (IAC) and
Business Assurance Committee (BAC) for level 1 and Director/Asset manager for
levels 2 and 3.
• Implementing audit program.
• Appointing audit leader and team members.
• Appointing, if required, an independent reviewer.
• Evaluating and developing auditors
• Reviewing and improving audit program
• Approving the Terms of Reference (ToR) and the Audit Report.
• Performing supervisory oversight of Audit Teams.
• Providing periodic analyses/reports to the IAC/BAC for Level 1 Audit and Asset
Director for Level 2 Audits
• Monitoring the quality of audit delivery.

Lead Auditor
• Leading the Audit Team and managing the audit delivery process to achieve stated
deliverables, according to the scope and time estimate in the agreed ToR.
• Reviewing the audit work carried out by the Auditors and ensuring that Auditors
properly conclude on the work performed.
• Acting as the primary contact for the Auditee.
• Preparing the draft ToR, the Audit plan and the Audit Report.
• Ensuring full compliance with the ToR and this procedure in all steps of the audit
Process.
• Confirming audit dates, duration and resource requirements with Auditee.

Auditor
• Preparing and participating in the audit teams.
• Carrying out allocated audit work and taking responsibility for the work carried out.
• Fully complying with the Audit ToR and in all steps of the Audit Process.

Independent Reviewer (by invitation)


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• Reviewing the ToR, the Audit Programme and the Audit Report, ensuring that the
Audit Assessment and Audit Findings are sufficiently substantiated and is responsible
for issuing an Independent Review to the Audit Lead before Close out meeting.

Principal Auditee
• Reviewing and agreeing the ToR and the plan for the audit
• Nominating Audit facilitator and follow up coordinator
• Supporting the Audit Process, ensuring availability of people, access to facilities,
documents and records for the audit
• Attending Opening and Closing Meetings
• Considering audit recommendations, identifying actions to address the root causes of
the findings, action parties and target dates.
• Ensuring that the agreed actions are closed as per plan

Follow up coordinator

• Inputting agreed actions, action parties and target dates in data management system
(Fountain/equivalent) and reporting close out status to the Auditee.

Action party
• Confirming ownership to the given action and the target completion date.
• Ensuring timely close-out of actions with supporting evidences.

1.6 Step-out Approval


This procedure is mandatory and any deviation to this procedure must be authorised by the
Head corporate HSE planning and audit. The Terms of Reference for an audit duly approved
by the Audit Manager may, however, override the requirements of Sections 3.3 and 4.0.

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Procedure
1.7 Overview
Level 1, Level 2 and Level 3 Audits are carried out to:
− Determine whether or not the elements and activities of PDO’s HSE Management System
conform to the planned arrangements and are being implemented effectively.
− Determine whether or not PDO’s HSE Management System is fulfilling the Company’s
HSE policy, objectives and performance criteria.
− Determine whether or not PDO’s HSE Management System complies with the relevant
legislative and regulatory requirements.
− Identify areas for improvement in PDO’s HSE Management System, with the aim of
progressively improving the HSE Management System.
− Enable management to ensure that potential or actual flaws in the system are remedied
through effective follow-up action.

1.8 Develop Audit Program


All business processes should be periodically audited, with the frequency and depth of HSE
auditing being determined based on:
• The level of risk for the process/activity.
• How critical the process or activity is, in relation to PDO’s business objectives.
• The statutory, regulatory and contractual requirements.
• The contribution or potential contribution of the activity concerned to PDO’s overall HSE
performance.
• The results of previous audits.
• All business processes activities and assets should be audited within the audit cycle. The
audit cycle should not be longer than five years, as it is likely that major changes (such as
asset, staff, mode of operations, organization, etc) may have taken place during that time.

1.8.1 Level 1 HSE Audits


Includes HSE audits conducted on behalf of PDO’s IAC and BAC as part of the Integrated
Audit Program, and also includes independent audits carried out by external bodies such as
ISO 14001 certification audits.
ACTION RESPONSIBILITY
Identify HSE Audit Units (assets, services, projects and functions) Audit Manager
that have a risk potential to affect the Company’s HSE objectives)
Prepare yearly and five-yearly Level 1 HSE Audit program based Audit Manager
on the risk potentials
Review and approve Level 1 HSE Audit Program IAC & BAC
Direct and review the development and implementation of the Corporate Safety and
Corporate HSE Audit Program Environmental Manager
Incorporate the Level 1 HSE Audit Program into Corporate HSE Audit Manager
Business Plan
Provide resources to manage the audit and lead the plan Corporate Safety and
execution Environmental Manager
Implement level 1 HSE audit program Audit Manager
Report level 1 HSE audit and action status to IAC/BAC Audit Manager
Monitor level 1 audits and actions IAC & BAC
Table 1: Level 1 HSE audits program

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1.8.2 Level 2 HSE Audits


Includes HSE audits carried out on behalf of Asset Directors as part of their own Asset Level
assurance processes and included in the Asset HSE Plan.
ACTION RESPONSIBILITY
Coordinate development and implementation of the Asset Asset Director
HSE Audit Programme
Identify HSE Audit Units (areas, services and functions) that Asset HSE Team Leader
have a risk potential to affect the Asset’s HSE objectives
Prepare yearly Level 1 HSE Audit program based on the risk Asset HSE Team Leader
potentials.
Review and approve Level 2 HSE Audit Program Asset director
Incorporate the Level 2 HSE Audit Program into directorate Asset HSE Team Leader
HSE Business Plan
Implement level 2 HSE audit program Asset HSE Team Leader
Report level 2 HSE audit and action status to director Asset HSE Team Leader
Monitor level 2 audits and actions Asset director
Table 2: Level 2 HSE Audits program

1.8.3 Level 3 HSE Audits


Includes planned and documented task verification activities to supplement the formal
HSE audit process. This is planned and managed by the managers of areas, services and
functions to assure compliance to requirements and procedures in processes. PR-1712 -
Level 3 Audit details the methodology for Level 3 Audits.

1.9 Audit Execution

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3.3.1 Initiate the audit


• Appoint audit team leader
• Establish ToR
• Select audit team
• Establish initial contact with the auditee

3.3.2 Conduct document review


• Review relevant HSE documents including records to determine
adequacy with respect to ToR.

3.3.3 Prepare for audit activities


• Prepare the audit schedule
• Assign work to the audit team
• Prepare work documents

3.3.4 Conduct audit activities


• Conduct opening meeting
• Communication during the audit
• Roles and responsibilities of guides and observers
• Collect and verify information
• Generate audit findings
• Classify audit findings
• Assess control acceptability
• Conduct closing meeting

3.3.5 Prepare, approve & distribute the audit report


• Prepare the audit report
• Approve and distribute the audit report

3.3.6 Conduct audit follow up


Figure 2: Overview of audit activities

1.9.1 Initiate the audit


• appoint the audit team leader for the specific audit.
• establish and seek agreement from the principal auditee the ToR for each audit that
should specify, as a minimum:
Audit Objectives
Scope of the Audit
Timing and duration of Audit
Name and position of the Principal Auditee
Audit Team Leader
Audit Team Members
Audit Methodology
Audit follow up coordinator
Audit report Distribution
• Select audit team

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Majority of Personnel on the audit team must be independent of the facility or process
audited, and may be sourced from within PDO or externally. People conducting HSE
audits should be able to carry out the task objectively, impartially and effectively.
Audit Manager selects the audit team members so that their training, skills and
knowledge are appropriate to the audit type and scope.

• Establish initial contact with the auditee by either audit manager or audit team leader
to:
Establish communication channels with the auditee’s representative(s)
Confirm the authority to conduct the audit
Provide information on the proposed timing and audit team composition
Request access to relevant documents, including records
Determine applicable site safety rules
Make arrangements for the audit
Agree on the attendance of observers and the need for guides for the
audit team.

1.9.2 Conduct document review


• Auditee’s documentations should be reviewed to determine the conformity of the
system, as documented, with audit ToR. The documentation may include relevant
management system documents and records as well as previous audit reports.

1.9.3 Prepare for audit activities


• Audit team leader should prepare the audit schedule to provide the basis for the
agreement among the auditee and audit team regarding the conduct of the audit.
The schedule should cover the following:
Organisational and functional units and processes to be audited
Dates and places where audit activities are to be conducted
Expected time and duration of audit activities, including meetings with the
auditee’s management and audit team meetings
Roles and responsibilities of the audit team members and accompanying
persons
Allocation of appropriate resources to critical areas of the audit
Logistics arrangements (travel, accommodation, working areas, etc)
• Audit team leader, in consultation with the audit team, should assign to each team
member responsibility for the auditing specific processes, functions, sites, areas or
activities.
• Audit team members should review the information relevant to their audit
assignments and prepare work documents as necessary for reference and for
recording audit proceedings such as checklists, audit sampling plans, forms for
recording information, audit working papers, etc. Work documents should be
generally retained at least until audit completion, confidential documents should be
suitably safeguarded at all times by the audit team members, however, the audit
working papers should be filed and retained with the audit report.

1.9.4 Conduct audit activities


• The audit leader shall conduct an opening meeting with the auditee to:

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Confirm the audit plan and ToR


Provide short summary of how the audit activities will be undertaken
Confirm communication channels
Provide opportunity for the auditee to ask questions
• The audit leader should confer periodically to exchange information, assess audit
progress and to reassign work between the audit team members as needed. During
the audit, the audit team leader should periodically communicate the progress of the
audit and any major concerns to the auditee. Evidence collected during the audit
that suggests an immediate and significant risk should be reported without delay to
the auditee. Any need for changes to the audit scope should be reviewed with and
approved by the auditee.
• Guides and observers may accompany the audit team but are not a part of it. They
should not influence or interfere with the conduct of the audit. They should assist the
audit team and act on the request of the audit team leader. Their responsibilities may
include:
Establishing contact and timing for interviews
Arranging visits to specific parts of the site or organisation
Ensuring that rules concerning site safety and security procedures are
known and respected by the audit team
Witnessing the audit on behalf of the auditee
Providing clarification or assisting in collecting information.
• During the audit, information related to the audit ToR should be collected by
appropriate sampling and should be verified. Only information that is verifiable may
be audit evidence. Audit evidence is based on samples of the available information
and should be recorded to help reaching audit conclusions.

• Generate audit findings


Audit team shall develop Audit Findings and determine ratings, risk/objectives based
on the observations made during the interviews, field visits and examination of
documents and records. Every Audit Finding should be based on demonstrable facts or
evidence and rated in line with the Assurance ratings definitions.

The primary criterion for rating Audit Findings is the risk to the achievement of
Business Objectives for the entity under audit. Whilst Low-Medium-High findings
indicate a continuum of increasing risk to the entity under audit, a Serious Finding
indicates a step-change in risk, and/or reflects notable impact on the entity under audit
or the company.

Classification of the audit findings shall be in accordance with the Rating Level table in
line with the matrix below.

• Classify audit findings

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Rating Level table for Classification of the audit findings:


Rating level Definition Follow-up
The next level of management
The finding is likely to cause a high undesirable effect should take urgent (generally within
on the achievement of the entity’s objectives and / 1 month) action to confront the
or is likely to have a notable impact on other PDO situation and commit appropriate
Serious
entities, therefore warranting immediate reporting to resources to immediate resolution of
senior management. e.g. Operations Manager or Asset the weaknesses. Senior Management
Director should monitor the implementation
of agreed actions/improvements.
The next level of management
The finding is likely to cause a high undesirable effect
should monitor the implementation
High on the achievement of one of the entity’s objectives,
(generally within 3 months) of
warranting reporting to the Auditee’s management.
agreed actions/improvements.
The next level of management
The finding is likely to cause a measurable undesirable should be advised (generally
Medium effect on the achievement of one of the entity’s within 6 months) of and review the
objectives. actions being taken to enhance the
framework.
No follow-up is required by the next
The weakness is unlikely to have a measurable impact
level of management, but action
Low on the entity’s objectives, but its correction would
should be completed within 12
enhance the risk based control framework.
months.
A non-compliance to a specific external legal or other Immediate follow-up by the Auditee/
regulations applicable to the entity. Reference shall be Sponsor.
Compliance
made to the number of the specific law or regulation in
the finding and after confirmation with Legal.
Table 3: Classification of audit findings

• Assess control acceptability of major risk areas.


The prime criterion for reaching a Control Acceptability Assessment is the level of
concern, as concluded by the Audit Team. This level of concern should be based
upon three key considerations:
The ‘implications’ for management, i.e. the action intended to be
provoked and by whom; the degree to which the Audit Team determines
the result of the audit needs to be escalated (or not).
The ‘scope of concern’, i.e. whether the exposure is seen to be confined
and contained, or whether it is far-reaching, potentially exposing other
entities.
The evidence gathered during the audit regarding the suitability and
effectiveness of the risk-based control framework for the entity under
audit in terms of achieving its objectives, i.e. the Audit Findings.

A three-point scale for Controls Assessments: Controls Acceptable, Controls Need


Improvement or Controls Need Major Improvement. As with the rating of Audit
Findings, this scale represents a continuum of increasing risk and increasing concern.
A “Controls Need Major Improvement” assessment indicates a step-change in the level
of concern.

The following terminology and scale are to be used for the Controls Assessments:
Impact on
Colour Category Definition Guidance Business Follow-up
Objectives
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None, or a few Low


and/or Medium rated
findings are reported
which indicate that The
a “once-off” rather expectation No follow-
than process or is that the up is required
Controls Less than three
system structural entity will by the next
Acceptable Medium findings.
weaknesses is present meet its level of
or that general Business management.
enhancement of the Objectives.
controls, process or
system framework is
not needed.
The next
Some Medium and
level of
/ or one or more
management
High rated findings
should be
Controls are reported which 1-2 High findings
advised of
Need indicate a weakness or 3-or-more
and review
Improvement in key controls / Medium findings.
the actions
barriers or in a part of The
being taken to
the process or system expectation
enhance the
structural framework. is that the
framework.
entity will
Three or more The next
not meet all
High and/or one or level of
its Business
more Serious rated management
Objectives.
findings are reported Any Serious should
Controls
indicating failures in finding or 3- monitor the
Need Major
key controls / barriers or-more High implementat
Improvement
or across a significant findings. ion of agreed
part of the process actions/
or system structural improvements
framework. .
Table 4: Controls assessments color coding

• Conduct Closing Presentation to the Auditee that includes, as a minimum:


Terms of Reference
Summary of Audit findings and ratings
Risk area Control Acceptability
Actions expected from the Auditee

1.9.5 Prepare Audit Report


• The Audit Lead shall prepare the Audit report from the audit team inputs.
As a minimum the Audit report shall contain:
Terms of Reference
Audit findings
Significance of findings
Recommendations
Risk area Control Acceptability
• Distribute Audit Report
The Audit Lead shall distribute report as determined by the ToR.
As a minimum, the report Audits shall be distributed to
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Principal Auditee
Principal Auditee’s line Supervisor
Audit team Members
Audit manager
Corporate HSE manager

1.9.6 Conduct Audit Follow Up


Audit Follow up coordinator and auditee shall retain and archive HSE Audit reports.
The Follow up coordinator has to consider the recommendations, if any, from the audit
and generate action plan that includes action parties and target completion dates for
all findings resulting from the HSE Audits. The Quality of Close out actions has to be
reviewed and verified by the follow up coordinator and auditee. Evidences supporting
the effective closure shall be retained until the next audit.

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Auditor selection criteria


The audit team shall have:
• Knowledge of HSE matters.
• Adequate independence from the activities being audited, to enable objective and
impartial judgement.
• Operational experience in the area being audited.
• The necessary expertise and experience in auditing practices and disciplines.
• Access to specialist HSE or other technical expertise, if necessary.
• The support and authority from management to procure the necessary information.
• Satisfactory completion of training program in auditing methodology
In order to maintain independence and objectivity, the Audit Team Leader and the majority of
the audit team should not have a direct reporting line to the Principal Auditee.
The minimum training requirements in auditing for Audit Team members is a HSE Auditing
course of 2 days duration.
In addition, the minimum requirements of the Audit Team Leaders for Level 1 Audits are:
• Completion of a prescribed HSE Auditing course of 5 days duration
• Participation in three corporate HSE audit as a team member.
• Lead one corporate HSE audit under supervision of a Competent Lead Auditor
• Job group 3 level or above.
• Deemed to be competent to lead audits by the HSE Audit Manager.
The minimum competency requirements of the Audit Team Leaders for Level 2 Audits are:
• Completion of a prescribed HSE Auditing course of 5 days duration
• Participation in one corporate HSE audit as a team member.
• Job group 4 level or above.
• Deemed to be competent to lead audits by the HSE Audit Manager.
The minimum competency requirements of the Audit Team Leaders for Level 3 Audits are:
• Completion of a prescribed HSE Auditing course of 2 days duration
• Participation in two HSE audit as a team member.
• Lead one level 3 HSE audit under supervision of a Competent Lead Auditor
• Deemed to be competent to lead audits by the HSE Audit Manager.

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Performance Standards, Monitoring, and Reporting


1.10 Performance Standards
Audit Program Compliance
Action close out status
1.11 Performance Monitoring Requirements
Audit managers report on a monthly basis the audit status and open & overdue actions from
the audits

HSE Audits program compliance

Audit Title Current Status

E.g. Corporate HSE MS Audit Planned for Q1 2011

Table 5: HSE audits program compliance

HSE Audits action close out status

Directorate No. of Open Action Items No. of Overdue Action Items


/Asset Principal
Audit Title
Auditee
Serious High Medium Low Total Serious High Medium Low Total

Corporate
E.g. MD MSEM 0 0 0 0 0 0 0 0 0 0
HSE MS

All Total

Table 6: HSE audits action close out status

1.12 Reporting Requirements


Level 1 Audit
Audit manager shall report the compliance to the Audit Program and HSE Audits Action close
out status to the IAC/BAC.
Level 2 Audit
Audit manager shall report the compliance to the Audit Program and HSE Audits Action close
out status to the Director.
Level 3 Audits
Audit manager shall report the compliance to the Audit Program and HSE Audits Action close
out status to the asset manager.

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Appendices
1.13 Definitions
Audit program Set of risk-based audits planned for a specific time frame.

Audit An objective examination of evidence for the purpose of providing an independent


assessment on risk management, control, or governance process for the organisation.

Audit Finding An identified area for improvement in the risk-based control framework.

Audit Objective The goals that an Audit Team plan to achieve in an Audit.

Audit Process Three phases (Plan, Execute and Wrap-Up) to be followed to issue an Audit
Conclusion

Audit Report A signed, written document which presents the purpose, scope, and results of
the audit.

Audit Scope Refers to the activities covered by the Audit.

Audit Team A team consisting of a Lead Auditor and one or more Auditors.

Auditee The person who manages the business area being audited.

Entity That part of the Business being audited. The ‘entity’ is not necessarily an
organizational unit; it could be a corporate function, a process or a risk area.

Terms of Reference A letter to the Auditee confirming the understanding of the


arrangements for the audit.

Working Papers All documentation required to support the Audit Report (including
Audit Findings and Audit conclusion).

1.14 Abbreviations
BAC Board Assurance Committee

IAC Internal Assurance Committee

ToR Terms of Reference

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Revision: 1.1
Petroleum Development Oman LLC Effective: Apr-12

1.15 Key References


In addition to the PDO documents listed on Page 3, the following references provide useful
information related to this procedure.
S. No. Title, author’s name, year of publication
1 ISO 14001-2004 Environmental management systems - Requirements with guidance for use
2 GU 441- HSE Inspection Guideline

3 PR-1171-Contract HSE Management Procedure


4 ISO 19011:2002 Guidelines for quality and/or environmental management systems auditing
5 OHSAS 18001:2007 Occupational health and safety management systems - Requirements

1.16 Formats and Templates

Model formats of ToR and Audit reports are given below. These are given as guidance;
however the use of these formats is not mandatory.

ToR HSE Audit.docx

Audit Report.docx

1.17 Additional Information


Nil

Page 21 Corporate HSE Audits


The controlled version of this CMF Document resides online in Livelink®. Printed copies are UNCONTROLLED.

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