Statement of Impartiality
A certification body that cannot say where its own safeguards stand has no business grading anyone else. Every mechanism below is marked with what it actually is today: running, committed, or not yet in place.
Where AIC stands today
AIC has certified no organisations and holds no accreditation. It is a small body, which means some of the separations a mature certification body relies on are commitments here rather than running mechanisms. Those are marked as such throughout, and the gaps that matter — an independent reviewer, a conflicts panel — are tied to the first certificate being issued, not to some later milestone. The full position is set out in our public disclosures.
Version 2.0 — 7 September 2026 · Next scheduled review: December 2026
1. Our Commitment
AI Integrity Certification (Pty) Ltd (“AIC”) is committed to impartiality in all its certification activities. Impartiality means that AIC's certification decisions are based solely on objective evidence, assessed by competent and independent personnel, and are not influenced by commercial, financial or personal interests.
AIC will not allow commercial pressure, applicant relationships or external influences to compromise the integrity of any assessment or certification decision. This commitment applies to all directors, employees, contractors and auditors acting on behalf of AIC.
The AIC Separation Rule
AIC will never advise and certify the same organisation. This is a permanent bar, not a cooling-off period. An organisation that has received consultancy or advisory services from AIC, or from any person acting on AIC's behalf, is not eligible for AIC certification.
Teaching is treated separately and deliberately. AIC's workshops explain the standard and the regulation; they never design, review or implement a participant's controls. An organisation AIC has taught may still seek certification — but the individual who taught them takes no part in assessing or deciding it, and any material that AIC itself shaped is out of scope for AIC to assess, permanently.
2. Safeguards, and Their Actual Status
A commitment we have made and a mechanism that is already running are different things. Each safeguard below is marked with which it is.
AIC never certifies an organisation it has a commercial or advisory relationship with. Not a cooling-off period — a permanent bar, and the rule the entire body is built on.
AIC's governance workshops teach only. They never design, review or implement an organisation's controls, because doing so would put AIC in the position of grading its own work.
A written independence declaration, naming the organisation, signed before assessment work begins. The form is drafted; it has not been used, because no assessment has been carried out.
No single client to exceed 15% of annual revenue. AIC has issued no certificates, so this commitment has not been tested in practice.
AIC is currently small enough that the person who would assess and the person who would decide are the same person. No wording fixes that. It will be resolved by appointing an independent reviewer before the first certificate is issued, not before accreditation.
AIC maintains a risk register covering the business as a whole, including the structural conflicts that threaten impartiality. A dedicated impartiality analysis against each recognised threat category is being added to it, with the first quarterly review scheduled for December 2026.
Conflict allegations are currently handled by AIC's founders, because AIC is a small body and there is no panel yet. Balanced representation of interested parties is not achievable at AIC's present size; it is a prerequisite for accreditation and will be in place before the first certificate is issued.
No impartiality report has been published. Once AIC is accredited, its accreditation body reviews these arrangements; until then there is no external auditor of them and we will not imply otherwise.
3. Conflict of Interest Prohibitions
These are binding rules on AIC personnel, in force now. They constrain what AIC may do from the first engagement onward, rather than describing a process that has already run. AIC personnel may not:
Provide consultancy or advisory services to any organisation that is applying for, or holds, AIC certification.
Design, write, review or implement the policies, controls or documentation that AIC will later assess.
Assess work they have personally produced, reviewed or approved — regardless of how much time has passed.
Assess any organisation by which they have been employed within the preceding 24 months.
Accept gifts, entertainment or other inducements from applicants or certificate holders, beyond token hospitality.
Participate in any certification decision — scoring, reviewing or approving — for a candidate they have trained, coached or mentored within the preceding 12 months.
Hold a financial interest in, or receive remuneration from, any organisation subject to AIC assessment.
Make a certification decision contingent on the applicant procuring any other AIC service.
4. Conflict Declaration Obligations
The declaration form is drafted and will be signed before the first assessment AIC carries out. No assessment has been carried out, so no declaration has yet been signed — which is why this section describes an obligation rather than a history.
Declare on appointment
Complete a Conflicts of Interest Declaration before commencing any role at AIC, disclosing relevant relationships, employment history and financial interests.
Declare per engagement
Before each assessment, certify in writing that no conflict exists with the applicant organisation, or disclose any potential conflict for review.
Declare ongoing changes
Notify AIC's directors within 5 business days of any new relationship, employment offer or financial interest that could affect impartiality.
Accept recusal
Where a declared conflict cannot be adequately managed, the individual recuses themselves from the engagement entirely, and the applicant is reassigned without prejudice.
5. Independent Decision-Making
A certification decision should not be made by the person who carried out the assessment. AIC cannot claim that separation today: it is a small body, and the assessor and the decision-maker would currently be the same person. We are stating that plainly rather than describing a three-stage process that does not yet have three people in it.
The model below is what AIC commits to operating. An independent reviewer will be appointed to fill the review and decision roles before the first certificate is issued — not deferred to accreditation, because a decision nobody independent has checked is the thing certification is supposed to prevent.
Assessment
Conducted by a qualified assessor with no conflict with the applicant. Produces a scored Evidence Record.
Review
An independent reviewer examines the Evidence Record and the assessor's findings before any decision is made.
Decision
The decision is made by someone who took no part in the assessment or the review.
Status: committed, not yet operating. AIC has issued no certificates.
6. Identifying Threats to Impartiality
AIC maintains a risk register covering the business as a whole. It already records the structural conflicts most likely to compromise a certification body: the incentive to pass a paying client, and the deeper conflict that arises when the body that certifies also disciplines the people it earns fees from.
What is being added is a dedicated impartiality analysis — each recognised threat category (self-interest, self-review, advocacy, over-familiarity, intimidation and competition) assessed against AIC's actual relationships, reviewed on a quarterly cycle with the outcome dated. The first such review is scheduled for December 2026. Until a review has happened, this page will not describe one as routine.
7. Raising an Impartiality Concern
Any applicant, certificate holder or third party who believes AIC's impartiality has been compromised may raise a concern at any time. AIC treats such concerns as seriously as a challenge to an assessment decision.
What we commit to
Write to zander@ztoaholdings.com, marked “Impartiality Concern”.
AIC acknowledges receipt within 5 business days.
The concern is investigated by someone not involved in the matter under review. Where AIC's size makes that impossible, we will say so, and refer the matter to an external reviewer rather than mark our own work.
A written response setting out findings and any remedial action, within 30 days.
Once AIC is accredited, an unsatisfactory response may be escalated to its accreditation body. AIC is not accredited today, so that route does not yet exist — and we would rather say so than imply an appeal path that leads nowhere.
8. How This Statement Is Reviewed
This statement is reviewed on a quarterly cycle alongside the impartiality risk analysis, and in full once a year. It is also reviewed out of cycle whenever something happens that could change the answer — a new engagement, a change in ownership or personnel, a complaint, or an organisation AIC has taught seeking certification. The version date above records the last review, and it is intended to be checked: a date that has gone stale is itself a finding.