Bringing up communication is an excellent point in all of this. Communication is two-way, and implies and understanding/ acceptance, etc.; some level of communication back. One-way speech is a lecture, (or as Randy stated, information).
If the problem is communication, is this a finger pointing exercise, where upper management expects the quality team to perform this communication, or is it the upper management's responsibility to communicate?
Which to me brings us back to the original topic. Is this a non-conforming item? I say if there is no evidence that communication has occurred, then "yes"; it's a finding (or an observation).
Are employees not proud of that policy? Rather, do they laugh and snicker as to how 'untrue' it is, yet no one makes an effort to improve it?
Communication is two way. If there is not an avenue for communication regarding the quality policy, how few avenues are there for communication regarding more critical items, like incorrect procedures, etc.? Is that a fair question?