Independence
The claim that has to be true for any of the rest to matter
An assurance institution that cannot demonstrate its own independence is asking clients to accept on faith exactly what it refuses to accept from them.
Structural controls
How independence is enforced rather than asserted
- No build, no resell
- Deep Heuristics does not develop AI products, resell AI platforms, or take referral fees from vendors. There is no product line whose sales an unfavourable finding could damage.
- Advisory firewall
- We do not certify a system whose controls we designed. Where we have advised on remediation, certification of that system is performed by a different provider or not at all.
- Non-contingent fees
- Fees are fixed at scoping. No fee, bonus, or commission at Deep Heuristics varies with the conclusion of an assessment.
- Separation of duties
- The team that assesses does not decide. The team that decides does not sell. Certification decisions require review by someone outside the engagement.
- Client concentration limits
- We monitor revenue concentration, because an institution that cannot afford to lose a client has already lost its independence with respect to that client.
- Personal interest declarations
- Assessors declare holdings and prior relationships and are recused where a conflict exists, including where it is only apparent.
- Right to withdraw
- Contracts preserve our right to suspend or withdraw a mark, and our right to publish the fact of withdrawal. This is not negotiable in commercial terms.
- Appeal, not pressure
- Clients who disagree with a finding have a documented appeal route heard by uninvolved reviewers. There is no informal route.
Engagements we decline
Turning work down is part of the control
The controls above only mean something if they have consequences. We decline engagements where scope restrictions would make an opinion misleading, where a prior relationship compromises the assessment, or where the client requires approval rights over the conclusion.
- Scope that excludes the risk
- Approval rights over findings
- Contingent or success-based fees
- Certification of our own advice
- Undisclosed related-party interest
- Restrictions on stating limitations
Independence is the product
Everything else we sell — reports, ratings, marks, monitoring — is a delivery mechanism for an opinion. If the opinion is not independent, there is nothing being delivered.
Related
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