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INDEPENDENCE

Independence

We audit. That is the whole business. We do not operate a consulting arm, we do not sell readiness services, and we do not accept referral fees in either direction.

THE RULE

The rule, stated affirmatively.

Usurity and its related entities do not and will not provide:

  1. Management system consultancy
  2. Readiness assessments or gap analyses prior to audit
  3. Control design or implementation services
  4. Internal audit services
  5. Virtual CISO (vCISO) services

Furthermore, we pay zero referral commissions to consulting platforms or advisory firms, and we accept zero commissions from them.

WHY THE RULES EXIST

Why the rules exist

An auditor cannot objectively evaluate a control they designed themselves. This is not a stylistic preference; it is a hard structural requirement for accredited certification and licensed attestation.

ISO

ISO/IEC 17021-1 Clause 5.2.5

The certification body and any part of the same legal entity and any entity under the organizational control of the certification body shall not offer or provide management system consultancy.

ISO

Clause 5.2.7

A minimum period of two years shall elapse following the end of management system consultancy before certification can be provided.

AICPA

AICPA Code of Professional Conduct

Independence rules restrict non-attest services to attest clients and prohibit advocating for an attest client to third parties.

Many firms in the market push the edges of these rules, running nominally separate advisory and audit arms. We do not. The structure of our firm is built entirely around these restrictions.

WHY THIS IS GOOD FOR YOU

Why this is good for you

ISO/IEC 17021-1 explicitly excludes from the definition of consultancy the transmission of generic publicly-available information. AICPA rules allow for the publication of generic educational material.

Because we cannot sell bespoke consulting to a specific client, we are giving the entire generic toolkit away. The templates, the calculators, and the questionnaire tooling are free.

IMPARTIALITY MANAGEMENT

Impartiality management

Threats to impartiality are continuously identified, logged, and reviewed by an independent impartiality committee. Before accepting any engagement, we require a declaration regarding prior consulting relationships. If you have received advisory services from any party related to us within the last two years, we will decline the audit engagement.

If you believe an impartiality threat exists in your engagement, you can raise it directly via our complaints and appeals process.

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