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Objective of this quality control element:

To provide the firm with reasonable assurance that personnel maintain independence (in fact and in appearance) in all required circumstances, perform all professional responsibilities with integrity, and maintain objectivity in discharging professional responsibilities.

General Policies:

• Compliance with applicable rules, regulations and requirements.
• Familiarity with policies and procedures relating to independence, integrity, and objectivity.
• Confirmation of independence of another firm performing parts of an engagement, or when we act as principal auditor.

QC Document Sections:

Independence	Engagement Performance
Personnel Management	Monitoring
Acceptance and Continuance	Introduction to QC Document

Implementation: The firm implements this policy through the following procedures: 

1. Developing and maintaining a manual that contains the firm's policies and procedures relating to independence, objectivity and integrity. Such policies and procedures contain the firm's interpretations of professional and regulatory requirements, and guidance for identifying and resolving potential issues or situations.
2. Designating on of its partners to provides guidance, answer questions and resolve matters and determine the circumstances that might require consultation with sources outside the firm.
3. Identifying circumstances where documentation of the resolutions of matters is appropriate.
4. Obtaining written representations from personnel upon hire and on an annual basis, stating whether they are familiar with and are in compliance with professional standards and the firm's policies and procedures regarding independence, integrity, and objectivity.
5. Assigning responsibility for obtaining representation, reviewing compliance files for completeness, and resolving reported exceptions to the firm's quality control partner.
6. Requiring the managing partner in each office to  periodically review unpaid fees from clients to ascertain whether any outstanding amounts impair the firm's independence.
7. Additional implementation procedures, if desired by the firm:
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Top of Independence
Top of Quality Control Document

Implementation: The firm implements this policy through the following procedures: 

1. The firm provides it personnel with access to professional and regulatory literature (through its hard copy references or by computer and software with access to applicable databases) and advising them that they are to expected to be familiar with it.
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2. Emphasizing the concepts of independence, integrity, and objectivity in its professional development meetings, in the acceptance and continuance of clients and engagements, and in the performance of engagements, including discussing the implications regarding engagements for financial institutions, such as the prohibition of any member of the engagement team having a loan with the institution, and the types of nonattest services that could affect independence.
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3. Informing personnel on a timely basis of those entities to which independence policies apply, by:
• Preparing and maintaining lists of entities to which independence policies apply.
• Making the lists available to personnel who need them to determine their independence (including personnel new to the firm or to an office, and to certain former partners).
• Notifying personnel of changes in the lists on a timely basis via a memorandum or the firm's e-mail system.
4. Additional implementation procedures, if desired by the firm:
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Top of Independence
Top of Quality Control Document

Implementation: The firm implements this policy through the following procedures: 

1. Describing in its policies and procedures manual the form, content, and frequency of independence representations that are to be obtained.
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2. Requiring that such representations be documented.
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3. Additional implementation procedures, if desired by the firm:
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Top of Independence
Top of Quality Control Document

(Version dated XX XX, XXXX)