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Independence policy

The Ctrl Worx Watch List only works if no one can buy their way off it. These rules apply to Ctrl Worx and to Russell Tomoum personally. Effective October 14, 2026. Updated October 25, 2026.

  1. The list is mechanical. A company joins or leaves the Watch List or the Five-Year List only when its own SEC filings change. No company can pay to be removed, delayed or reworded.
  2. No paid work with companies on the list. Ctrl Worx does not approach companies that have reported a material weakness, or concluded internal control isn’t effective, to sell them help. Ctrl Worx takes no new paid advisory work from a company while it’s on the Watch List or for 12 months after. Ctrl Worx does not refer a company on the list to a partner for paid work. Work already under contract with companies not on the list continues. If a client ever appears on the list, its entry is set by the published rules alone.
  3. No paid placement. We do not accept sponsorship, advertising or payment of any kind from companies on the Watch List. Sponsors have no say over the list.
  4. Corrections follow filings. We review a correction request within two business days, and correct the row when a filing shows we got it wrong. Each correction is recorded on How the Watch List works.

Data licenses

A company on the Watch List pays us nothing, for anything. Companies on the Watch List can’t buy any paid product.

A company that has cleared may buy a paid license to our data, but only at our published price and terms, with no custom deals or discounts. We don’t approach it about a paid license for 12 months after it clears.

Every paid licensee is named on our licensees page and, if it has one, on its own company page. If any one customer passes 10% of our revenue in a year, we say so.

Rows follow the filings. No contract gives a licensee any say over its own row. A licensee that reports a new weakness goes on the list like anyone else. While it’s listed it pays nothing, and its license runs to its end date without renewal or expansion.

Russell Tomoum is responsible for the Watch List and this policy. Questions to russell@ctrlworx.com.