Independence safeguards
Identifies ownership, investment, family, employment, and other economic relationships that require disclosure, recusal, mitigation, or prohibition.
Controlling public principle
Ownership, investment, family, employment, fiduciary, and other economic interests must be disclosed and prevented from reaching certification activity or decisions.
Controlled register
Equity, options, convertible instruments, voting rights, board rights, side arrangements, and known client overlaps are maintained in a controlled Ownership Register and reviewed through governance oversight.
Personal interests
Direct or indirect investments, private instruments, family interests, prior or prospective employment, gifts, hospitality, and external fiduciary duties may require disclosure, recusal, reassignment, divestiture, or prohibition.
Broad diversified holdings may be treated differently from deliberately selected direct interests, but materiality and treatment remain subject to the governing policy and documented review.
Recusal
A person with a relevant conflict does not evaluate, review, decide, receive preliminary findings, or participate in governance action for the affected entity. Assignment controls do not rely only on self-identification.
Cooling-off
The source policy applies documented cooling-off periods after divestiture, prior employment, family interests, or employment discussions. The Board may extend these safeguards but may not shorten them under the source policy.
Oversight
The COO administers disclosures and routine review. Material interests, Board conflicts, significant ownership conflicts, and pervasive threats escalate for Board determination and documented mitigation or prohibition.
Authority boundary
Public transparency should show that the control exists without exposing private ownership records, personal finances, non-public investor terms, or confidential portfolio information.
Controlled information
Connected governance
