Purpose and Validity

This declaration is signed by the top management of SRS Certification GmbH (hereinafter referred to as "this Certification Body") and constitutes the top-level public document of this Certification Body's impartiality management system. This declaration is publicly available to all clients, interested parties, and the general public, and serves as the baseline statement of this Certification Body's commitment to impartiality in its certification activities. This Certification Body understands that impartiality is not only the factual independence of certification decisions, but also the perceived independence from improper influence of commercial interests by the public; the value of certification depends on the trust of interested parties in this Certification Body's objective and independent status.

Scope of Application

This declaration applies to the management system certification activities carried out by this Certification Body, as well as all personnel, committees, subcontractors, and any party acting on behalf of this Certification Body related thereto. This Certification Body establishes and operates an impartiality management system in accordance with ISO/IEC 17065 to identify, analyze, and manage threats to impartiality arising from ownership, governance, management, personnel, shared resources, finances, contracts, and marketing.

Commitment to Impartiality

This Certification Body makes public commitments regarding the following matters:

• Commitment and Responsibility of Top Management. The top management of this Certification Body bears ultimate responsibility for the impartiality management system, ensuring that impartiality requirements are integrated into all levels and all decisions of certification activities, and that impartiality is not compromised by the number of certifications, financial indicators, or commercial growth targets.
• Non-profit-oriented Third-Party Stance. Operating as an independent third-party certification body, this Certification Body does not engage in activities that may compromise the impartiality, objectivity, or confidentiality of certification, and does not accept any commercial, financial, or other pressures that might cause certification decisions to deviate from objective evidence.
• Prohibition of Certification Consulting. This Certification Body does not provide any consulting related to certification, does not offer quotations for consulting, and does not provide internal audits to certified clients; it does not state or imply that certification would be simpler, easier, faster, or cheaper if a specified consultancy organization were used; it does not have direct or indirect economic interest relationships with consultancy organizations that may affect impartiality. Personnel who have provided management system consulting or internal audits to a client shall not participate in certification activities for that client within two years following the end of the consulting or internal audit activities.
• Identification and Management of Conflicts of Interest. This Certification Body identifies and manages the following categories of threats to impartiality: self-interest, self-

review, familiarity or trust, intimidation, and advocacy—namely, actions by this Certification Body or its personnel to promote, or appear to promote, the interests of a specific client. Any identified threats, whether originating from within this Certification Body or from external individuals, organizations, or relationships, must be eliminated, minimized, or managed in a documented manner prior to the commencement of certification activities.

• Impartial Behavior of Personnel. All personnel involved in certification activities— including auditors, technical experts, certification decision-makers, management personnel, and members of the impartiality committee—must sign an impartiality commitment, declaring their understanding of this declaration and disclosing any relationships that may constitute a risk to impartiality. The aforementioned declarations are updated regularly. Auditors shall not engage in certification consulting under any name, nor shall they provide internal management system audits at the invitation of clients.
• Impartiality Committee and Independent Oversight. This Certification Body establishes an impartiality committee, the composition of which ensures the balanced participation of key interested parties, with no single party predominating. The impartiality committee is responsible for reviewing this Certification Body's impartiality analysis, the results of conflict of interest identification, and significant changes that may affect impartiality, and advises top management on impartiality matters. Top management shall not serve as the chair of the impartiality committee.
• Information Disclosure and Regulatory Cooperation. This Certification Body provides its impartiality analysis and related records to accreditation bodies for review and cooperates when requested by the accreditation bodies. This Certification Body assumes confidentiality obligations for state secrets, commercial secrets, and technical secrets learned during certification activities.

Commitments Regarding Marketing, Public Information, and Client Narratives

Given that public communication and marketing activities themselves are recognized as sources of threats to impartiality under ISO/IEC 17065, this Certification Body makes the following commitments regarding the content of its website, promotional materials, case displays, and other public communications:

• No Presentation of Clients within a Commercial Success Narrative Framework. When disclosing the fact that a client has obtained certification in public communications, this Certification Body limits the information to neutral facts such as the scope of certification, standard applied, certificate status, and the certification activity itself. It does not use the client's "business development," "market expansion," or "achievement of commercial cooperation" as a narrative framework or main storyline. Factual statements regarding the obtainment of certification must not be embedded in an endorsing narrative of the client's commercial success.
• No Implication of Causal Link Between Certification and Commercial Success through Selective Presentation. The client information publicly presented by this Certification Body does not represent an evaluation or guarantee of the client's commercial results, market performance, or management effectiveness. This Certification Body does not create a simplified public impression that "certification equals commercial success" by solely presenting clients with "successful development" while omitting the neutral nature of certification activities.
• No Use of Endorsing or Consulting Wording in Public Communications. In public information involving clients, this Certification Body does not use wording such as "help," "support," "boost," or "promote development" that might lead the public to understand that the certification body is intervening in the client's commercial operations or management improvements. Statements regarding the value of certification activities are limited to the independent and objective evaluation of the conformity of the management system with agreed standards.
• Pre-release Impartiality Review. This Certification Body conducts pre-release impartiality reviews on website news, client stories, case studies, and other public communication content involving clients. The review focuses on: whether there is any implied connection with consulting services, whether it constitutes advocacy or promotion for a specific client, whether there is a selective success narrative, and whether wording that could reasonably be construed as a commercial endorsement is used. Review records are incorporated into the controlled documents of the impartiality management system.
• Accessible Comparison Between Impartiality Declaration and Public Information. This declaration is continuously and publicly accessible on this Certification Body's website and is situated in the same accessible information environment as public information involving clients, enabling interested parties to comparatively understand the boundaries between this Certification Body's certification activities and its public communications.

Handling of Violations of Commitments

Should any personnel violate the commitments contained in this declaration, this Certification Body will take appropriate measures in accordance with documented procedures, including but not limited to corrective actions, suspension or withdrawal of personnel qualifications, and, where applicable, reporting to accreditation bodies and relevant regulatory authorities.

Review and Update of the Declaration

This declaration is reviewed regularly by top management in conjunction with the review results of the impartiality committee, and shall be updated when significant changes occur in this Certification Body's organizational structure, ownership, business scope, or impartiality risk profile.