Tel: 314-889-1100
Fax: 314-889-1101
www.bdo.com

101 S Hanley Rd, #800
St. Louis, MO 63105

REPORT OF THE INDEPENDENT ACCOUNTANT
To the management of Amazon Trust Services, LLC (“ATS”),
We have examined ATS management’s assertion that for its Certification Authority (“CA”)
operations in various locations in the United States of America, throughout the period January
16, 2019 to January 15, 2020 for its CAs as enumerated in Attachment B, ATS has:•disclosed its extended validation code signing (“EV CS”) certificate lifecycle managementbusiness practices in the applicable versions of its Certificate Practice Statement andCertificate Policy enumerated in Attachment A, including its commitment to provide EV
CS certificates in conformity with the CA/Browser Forum Guidelines on the ATS repository,
and provided such services in accordance with its disclosed practices•

maintained effective controls to provide reasonable assurance that the integrity of keys
and EV CS certificates it manages is established and protected throughout their lifecycles

based on the WebTrust Principles and Criteria for Certification Authorities – Extended Validation
Code Signing v1.4.1. ATS’ management is responsible for its assertion. Our responsibility is toexpress an opinion on management’s assertion based on our examination.
The relative effectiveness and significance of specific controls at ATS and their effect on
assessments of control risk for subscribers and relying parties are dependent on their interaction
with the controls and other factors present at individual subscriber and relying party locations.
Our examination did not extend to controls at individual subscriber and relying party locations
and we have not evaluated the effectiveness of such controls.
Our examination was conducted in accordance with attestation standards established by theAmerican Institute of Certified Public Accountants. Those standards require that we plan andperform the examination to obtain reasonable assurance about whether management’s assertionis fairly stated, in all material respects. An examination involves performing procedures to obtainevidence about management’s assertion. The nature, timing, and extent of the procedures
selected depend on our judgment, including an assessment of the risks of material misstatementof management’s assertion, whether due to fraud or error. We believe that the evidence weobtained is sufficient and appropriate to provide a reasonable basis for our opinion.
Because of the nature and inherent limitations of controls, ATS’ ability to meet theaforementioned criteria may be affected. For example, controls may not prevent, or detect andcorrect, error, fraud, unauthorized access to systems and information, or failure to comply withinternal and external policies or requirements. Also, the projection of any conclusions based on
our findings to future periods is subject to the risk that changes may alter the validity of suchconclusions.

BDO USA, LLP, a Delaware limited liability partnership, is the U.S. member of BDO International Limited, a UK company limited by guarantee, and forms part of theinternational BDO network of independent member firms.
BDO is the brand name for the BDO network and for each of the BDO Member Firms.

In our opinion management’s assertion, as referred to above, is fairly stated, in all materialrespects.
During the examination period, ATS did not issue any EV CS subscriber certificates.
This report does not include any representation as to the quality of ATS’ services other than its
CA services in various locations in the United States of America, nor the suitability of any of ATS’services for any customer's intended purpose.
The World Health Organization classified the COVID-19 outbreak as a pandemic in March 2020.
Based on the rapid increase in exposure globally, the gravity or length of the impact of theCOVID-19 outbreak cannot be determined at this time.
ATS’ use of the WebTrust for Certification Authorities – Extended Validation Code Signing Seal
constitutes a symbolic representation of the contents of this report and it is not intended, norshould it be construed, to update this report or provide any additional assurance.

April 8, 2020

2ATTACHMENT A – CERTIFICATION PRACTICE STATEMENT AND CERTIFICATEPOLICY VERSIONS IN-SCOPE
Policy Name
Amazon Trust Services Certification Practice Statement

Version1.0.8

Effective Date
December 17, 2019

Amazon Trust Services Certification Practice Statement

1.0.7

April 13, 2018

Amazon Trust Services Certificate Policy

1.0.7

December 18, 2019

Amazon Trust Services Certificate Policy

1.0.6

April 13, 20183

ATTACHMENT B – IN-SCOPE CAs
Root CA Subject DN

SHA2 Thumbprint

SPKI SHA256

Valid To

8ECDE6884F3D87B1125BA31AC3FCB13D7016DE7F57CC904FE1CB97C6AE98196E

FBE3018031F9586BCBF417
27E417B7D1C45C2F47F93B
E372A17B96B50757D5A25/25/2015

1/16/2038

CN = Amazon Root CA 2
O = Amazon
C = US

1BA5B2AA8C65401A82960118F80BEC4F62304D83CEC4713A19C39C011EA46DB47F4296FC5B6A4E3B35D3C369623E364AB1AF381D8FA7121533C9D6C633EA2461

5/25/2015

5/25/2040

CN = Amazon Root CA 3
O = Amazon
C = US

18CE6CFE7BF14E60B2E347B8DFE868CB31D02EBB3ADA271569F50343B46DB3A436ABC32656ACFC645C61B71613C4BF21C787F5CABBEE
48348D58597803D7ABC95/25/2015

5/25/2040

CN = Amazon Root CA 4
O = Amazon
C = US

E35D28419ED02025CFA69038CD623962458DA5C695FBDEA3C22B0BFB25897092

F7ECDED5C66047D28ED64
66B543C40E0743ABE81D109254DCF845D4C2C7853C55/25/2015

5/25/2040

CN = Starfield Services
Root Certificate
Authority - G2 1
O = Starfield
Technologies, Inc.
L = Scottsdale
S = Arizona
C = US

568D6905A2C88708A4B3025190EDCFEDB1974A606A13C6E5290FCB2AE63EDAB52B071C59A0A0AE76B0EAD
B2BAD23BAD4580B69C3601B630C2EAF0613AFA83F92

8/31/200912/31/2037

Cross-Signed Root CA
Subject DN

CN = Amazon Root CA 1
O = Amazon
C = USSHA2 Thumbprint

SPKI SHA256

87DCD4DC74640A322CD205552506D1BE64F12596258096544986B4850BC72706

FBE3018031F9586BCBF417
27E417B7D1C45C2F47F93B
E372A17B96B50757D5A2391220705B75BCF3ED3CD4B3631213F569D2CF8226101E170799A5354AB12861

CN = Amazon Root CA 2
O = Amazon
C = US1

Valid From

CN = Amazon Root CA 1
O = Amazon
C = US

8B358466D66126312120645A5875A6A57E3C81D98476A967604244254EAC00F0

7F4296FC5B6A4E3B35D3C369623E364AB1AF381D8FA7121533C9D6C633EA2461

Valid From

Valid To

5/25/201512/31/2037

10/21/2015

12/31/2037

5/25/201512/31/2037

ATS assumed operation of this Root CA on June 10, 2015. Starfield Technologies operated this CA prior to June 10, 2015 and was responsible for its key generation.

4

Cross-Signed Root CA
Subject DN

SHA2 Thumbprint

SPKI SHA256

CN = Amazon Root CA 3
O = Amazon
C = US

40C826FDB22BA32A2F9DB4F94770F72B8B1DA9C8FFDA7B11E6F27AF245C89B5E

36ABC32656ACFC645C61B7
1613C4BF21C787F5CABBEE
48348D58597803D7ABC95/25/2015

12/31/2037

CN = Amazon Root CA 4
O = Amazon
C = US

543D9B7FC2A6471CD84FCA52C2CF6159DF83EBFCD88D8B08B5AF3F88737F52E6

F7ECDED5C66047D28ED6466B543C40E0743ABE81D109254DCF845D4C2C7853C55/25/2015

12/31/2037

5Valid FromValid To

AMAZON TRUST SERVICES, LLC MANAGEMENT’S ASSERTION
Amazon Trust Services, LLC (“ATS”) operates the Certification Authority (“CA”) services for theCAs enumerated in Attachment B, and provides Extended Validation Code Signing (“EV CS”)
Certification Authority (“CA”) services.
The management of ATS is responsible for establishing and maintaining effective controls over its
EV CS CA operations, including its EV CS CA business practices disclosure in its repository, and EV
CS certificate lifecycle management controls. These controls contain monitoring mechanisms, andactions are taken to correct deficiencies identified.
There are inherent limitations in any controls, including the possibility of human error, and thecircumvention or overriding of controls. Accordingly, even effective controls can only provide
reasonable assurance with respect to ATS’ CA operations. Furthermore, because of changes inconditions, the effectiveness of controls may vary of time.
ATS management has assessed its disclosures of its certificate practices and controls over its EV
CS CA services. Based on that assessment, in ATS management’s opinion, in providing its EV CS
CA services in the United States of America, throughout the period January 16, 2019 to January
15, 2020, ATS has:•disclosed its EV CS certificate lifecycle management business practices in the applicableversions of its Certificate Practice Statement and Certificate Policy enumerated inAttachment A including its commitment to provide EV CS certificates in conformity with
the CA/Browser Forum Requirements on the ATS repository, and provided such services inaccordance with its disclosed practices•

maintained effective controls to provide reasonable assurance that the integrity of keys
and EV CS certificates it manages is established and protected throughout their lifecycles

based on the WebTrust Principles and Criteria for Certification Authorities – Extended Validation
Code Signing, Version 1.4.1.
During the examination period, ATS did not issue any Extended Validation Code Signing subscriber
certificates.

Jonathan Kozolchyk_____________________________________________________
Jonathan Kozolchyk
Vice President
Amazon Trust Services, LLC
April 8, 2020

ATTACHMENT A – CERTIFICATION PRACTICE STATEMENT AND CERTIFICATEPOLICY VERSIONS IN-SCOPE
Policy Name
Amazon Trust Services Certification Practice Statement

Version
1.0.8

Effective Date
December 17, 2019

Amazon Trust Services Certification Practice Statement

1.0.7

April 13, 2018

Amazon Trust Services Certificate Policy

1.0.7

December 18, 2019

Amazon Trust Services Certificate Policy

1.0.6

April 13, 2018

ATTACHMENT B – IN-SCOPE CAsRoot CA Subject DN

SHA2 Thumbprint

SPKI SHA256

Valid To

8ECDE6884F3D87B1125BA31AC3FCB13D7016DE7F57CC904FE1CB97C6AE98196E

FBE3018031F9586BCBF417
27E417B7D1C45C2F47F93B
E372A17B96B50757D5A2

5/25/2015

1/16/2038

CN = Amazon Root CA 2
O = Amazon
C = US

1BA5B2AA8C65401A82960118F80BEC4F62304D83CEC4713A19C39C011EA46DB4

7F4296FC5B6A4E3B35D3C369623E364AB1AF381D8FA7121533C9D6C633EA2461

5/25/2015

5/25/2040

CN = Amazon Root CA 3
O = Amazon
C = US

18CE6CFE7BF14E60B2E347B8DFE868CB31D02EBB3ADA271569F50343B46DB3A436ABC32656ACFC645C61B71613C4BF21C787F5CABBEE
48348D58597803D7ABC95/25/2015

5/25/2040

CN = Amazon Root CA 4
O = Amazon
C = US

E35D28419ED02025CFA69038CD623962458DA5C695FBDEA3C22B0BFB25897092

F7ECDED5C66047D28ED64
66B543C40E0743ABE81D109254DCF845D4C2C7853C55/25/2015

5/25/2040

CN = Starfield Services
Root Certificate
Authority - G2 1
O = Starfield
Technologies, Inc.
L = Scottsdale
S = Arizona
C = US

568D6905A2C88708A4B3025190EDCFEDB1974A606A13C6E5290FCB2AE63EDAB5

2B071C59A0A0AE76B0EAD
B2BAD23BAD4580B69C360
1B630C2EAF0613AFA83F92

8/31/200912/31/2037

SHA2 Thumbprint

SPKI SHA256

Cross-Signed Root CA
Subject DN

CN = Amazon Root CA 1
O = Amazon
C = US

87DCD4DC74640A322CD205552506D1BE64F12596258096544986B4850BC72706

FBE3018031F9586BCBF417
27E417B7D1C45C2F47F93B
E372A17B96B50757D5A2391220705B75BCF3ED3CD4B3631213F569D2CF8226101E170799A5354AB128611Valid From

CN = Amazon Root CA 1
O = Amazon
C = US

Valid From

Valid To

5/25/201512/31/2037

10/21/2015

12/31/2037

CN = Amazon Root CA 2
O = Amazon
C = US

8B358466D66126312120645A5875A6A57E3C81D98476A967604244254EAC00F07F4296FC5B6A4E3B35D3C369623E364AB1AF381D8FA7121533C9D6C633EA2461

5/25/201512/31/2037

CN = Amazon Root CA 3
O = Amazon
C = US

40C826FDB22BA32A2F9DB4F94770F72B8B1DA9C8FFDA7B11E6F27AF245C89B5E

36ABC32656ACFC645C61B71613C4BF21C787F5CABBEE48348D58597803D7ABC95/25/2015

12/31/2037

ATS assumed operation of this Root CA on June 10, 2015. Starfield Technologies operated this CA prior to June 10, 2015 and was responsible for its key generation.

Cross-Signed Root CA
Subject DN

CN = Amazon Root CA 4
O = Amazon
C = USSHA2 Thumbprint

SPKI SHA256

543D9B7FC2A6471CD84FCA52C2CF6159DF83EBFCD88D8B08B5AF3F88737F52E6

F7ECDED5C66047D28ED6466B543C40E0743ABE81D109254DCF845D4C2C7853C5

Valid From
5/25/2015

Valid To
12/31/2037