Authorizing Official
Auditors are deemed as the authorizing officials of documents presented; they are personally and professionally responsible for the content of those documents.
We maintain this code as Independent Auditors for employers who desire and/or require audits related to the use of artificial intelligence in employment, pay equity, wage solicitation, pay transparency, and human capital analytics disclosure.
We aspire to maintain the highest standard globally.
Updated November 2023
Auditors are deemed as the authorizing officials of documents presented; they are personally and professionally responsible for the content of those documents.
Auditors are credentialed academically as Masters in one or more of the following: mathematics, data analysis, statistics, actuarial science, industrial organizational psychology, accounting, or finance.
Auditors have no less than five years’ experience in the application of the accredited academia as their primary profession.
Auditors have documented five years of working experience and / or secondary academic accredited experience in human resources, employment practices, and / or labor relations.
Auditors have neither direct nor indirect financial relationship(s) with the organization and / or the technologies being audited. This includes, but it is not limited to, being a current or former employee, having direct stock or business ownership, and / or currently or formerly being either a user or auditor of any technology software included in the audit.
Auditors have neither direct nor indirect financial relationship(s) with a primary integrator or software technology partnered with the technologies under audit.
Auditors are prohibited from providing any service related to the audit client’s information system unless it is reasonable to conclude that the results of these services will not be subject to audit procedures during an audit of the audit client’s compliance and risk to enacted and potentially relevant regulations. These rules will not preclude an auditing firm from working on hardware or software systems that are unrelated to the audit client’s employment systems or employment records if those services are pre-approved by the auditing client and are disclosed in the audit.
An auditor is not independent if, at any point during the audit and professional engagement period, any audit partner earns or receives compensation based on that partner procuring engagements with the audit client to provide any services other than audit, review, or attest services.
A one-year cooling-off period before a member of the audit engagement team may accept employment in certain, designated positions with an audit client. An auditing firm is not independent if a member of management involved in overseeing reporting matters was the lead partner, the concurring partner, or any other member of the audit engagement team who provided more than ten hours of audit, review, or attest services for the issuer within the one-year period preceding the commencement of the audit of the current year.
Some of these provisions may impose an undue burden on certain smaller accounting firms. Firms with fewer than five audit clients may be exempt from the partner rotation and compensation provisions, provided each of these engagements is subject to a special review or disclosure to relevant regulators that demand independent audits are submitted on a mandated concurrence.
Appraisal and evaluation services include any process of valuing tangible or intangible resources, procedures, technology, or liabilities. Fairness opinions and contribution-in-kind reports are opinions and reports in which the firm provides its opinion on the adequacy of consideration in a transaction. An auditor is prohibited from providing such services unless it is reasonable to conclude that the results of these services will not be subject to audit procedures during an audit of the audit client’s employment actions.
These rules will prohibit an auditor from providing to an audit client any actuarially oriented advisory service involving the civil action penalties that are not defined in a relevant and applicable pending or enacted regulation. The auditor, however, may assist a client in understanding the methods, models, assumptions, and inputs used in computing the amount of potential fines and or penalties as listed in relevant and applicable pending or enacted regulations.
Auditors are prohibited from acting, temporarily or permanently, as a director, officer, or employee of an audit client, or performing any decision-making, supervisory, or ongoing monitoring function for the audit client. An auditor’s independence is impaired with respect to an audit client when the accountant seeks out prospective candidates for managerial, executive or director positions; acts as negotiator on the audit client’s behalf; or undertakes reference checks of prospective candidates. Under the rule, an auditor’s independence also will be impaired when the accountant engages in psychological testing or other formal testing or evaluation programs or recommends or advises the audit client to hire a specific candidate for a specific job.
Acting as a broker-dealer (registered or unregistered), promoter or underwriter on behalf of an audit client and similar activities will make the auditor an advocate for the audit client and will impair the auditor’s independence.
Some of these provisions may impose an undue burden on certain smaller accounting firms. Firms with fewer than five audit clients may be exempt from the partner rotation and compensation provisions, provided each of these engagements is subject to a special review or disclosure to relevant regulators that demand independent audits are submitted on a mandated concurrence.
Historical reporting or analyses for time periods prior to the effective date of a master agreement greater than 12 months with the auditing client can be executed by an auditor and are declared only as non-auditing services.
The scope of work can be limited to types of specific legislation or regulation and will be declared in the submission of the Audit.
Documentation and presentation produced is standardized with all methods and statistical presentation the same for any organization audited.
Auditors are granted direct, unfiltered, and unfettered access to any data included in the audit.
Auditors are prohibited from using data that has been delivered to the auditor which may have been filtered or altered from the organization.
Auditors are granted access to software users being audited within the organization.
Auditors are granted access to documentation that details standard operating procedures for both the usage and features of the technologies and practices enabled at the organization.
The auditor has the right to obtain copies of all contracts related to technology use and features included in the software purchased that would be included in the audit with financials redacted.
The audit is accepted with signature by a member of senior staff of the organization being audited.
The auditor will use scoring, bias, or mathematical models that are indicated in legislation and / or regulation.
If codes or regulations do not indicate specific measures, then the auditor will use multiple mathematical and / or statistical models and standards to validate the data being presented including counts, confidence, and source of data.
The audit will indicate the specific regulation and code being audited with reference to its current language and the date of the latest revision or passing.
The audit will include biographies of all audit personnel involved with the audit.
The audit will offer a declaration of general liability and errors and omissions insurance within the audit. A copy of the firm’s business continuity plan is included in the submitted audit.
The audit will reference the date and name of all agreements and statements of work with the organization including a declaration of fees to date.
(1) The auditing firm will report, prior to the filing of its audit report, all critical policies and practices used by the issuer; (2) all material alternative employment transactions or practices that have been discussed with management, including the ramifications of the use of such alternative treatments and disclosures and the treatment preferred by the auditing firm; and (3) other material written communications between the auditor and management.
An audit partner will be defined as a partner who is a member of the audit engagement team who has responsibility for decision-making on significant auditing, regulatory compliance and reporting matters that affect the employment practices or who maintains regular contact with management and the human resources. The term audit partner will include the lead and concurring partners as well as partners who serve the client at the issuer level, other than a partner who consults with others on the audit engagement team regarding technical or industry-specific issues.
The lead and concurring partner must be subject to rotation requirements after five years. The rules will specify that the lead and concurring partner must rotate after five years and be subject to a five-year “time out” period after rotation. Additionally, certain other significant audit partners will be subject to a seven-year rotation requirement with a two-year time out period.
The Auditor will publish and assess fees that are standard for the determined scope of work to its auditing clients. Fee schedules are publicized and standardized at the discretion of the Auditor.
Non–auditing services are not subject to standard fees yet are declared in the audit and may impact the independent status of the auditor. An auditor’s independence is impaired with respect to any audit client when audit fees with all audit clients are without parity.
The audit will include biographies of all audit personnel involved with the audit.
The audit will offer a declaration of general liability and errors and omissions insurance within the audit. A copy of the firm’s business continuity plan is included in the submitted audit.
The audit will reference the date and name of all agreements and statements of work with the organization including a declaration of fees to date.
(1) The auditing firm will report, prior to the filing of its audit report, all critical policies and practices used by the issuer; (2) all material alternative employment transactions or practices that have been discussed with management, including the ramifications of the use of such alternative treatments and disclosures and the treatment preferred by the auditing firm; and (3) other material written communications between the auditor and management.