Carbon Claims and Transparency Policy

Draft: November 2025

1. Purpose of this Policy

The Carbon Foundation (“Carbon Foundation”, “we”, “us”, “our”) operates in a context where carbon claims are increasingly regulated, scrutinised and challenged. We issue and support the use of compliant-grade, high-integrity carbon credits, including AAA-certified units, which may be used by sovereigns, project owners and market participants in the context of climate targets, Article 6 mechanisms and carbon-linked financial products.

The purpose of this Carbon Claims & Transparency Policy (the Policy) is to:

Set out the principles and controls that govern how we make, support and permit carbon-related claims;
Ensure that all claims associated with our projects, credits, frameworks and products are accurate, evidence-based and not misleading;
Provide a clear framework for transparency, documentation and disclosure aligned with our Quality Manual, methodologies and MRV governance; and
Reduce the risk of greenwashing, misinterpretation and misrepresentation by us or by those using our credits and services.

This Policy complements and works alongside:

Our Quality Manual and project-level methodologies
Our Data & MRV Governance Policy
Our Investor / Partner Information Policy
Our Privacy Policy, Cookie Policy and any relevant Platform / Registry Terms
Applicable laws and regulations, including emerging rules on environmental and sustainability claims in the jurisdictions where we operate

2. Scope and who this Policy applies to

This Policy applies to:

All carbon claims made by or on behalf of the Carbon Foundation in any medium, including websites, reports, marketing materials, presentations, data rooms and public statements;
The way we describe and label our credits, projects, methodologies, AAA ratings and frameworks;
Guidance and requirements we provide to project owners, brokers, investors, sovereigns and other partners on how they may refer to credits and services associated with the Carbon Foundation; and
Internal processes used to develop, review and approve such claims.

This Policy binds:

All employees, officers and directors of the Carbon Foundation group;
Consultants, contractors and advisers who assist in drafting, reviewing or disseminating carbon-related statements;
Any third parties making claims about our credits or services under our brand or with our express approval.

We cannot control all claims made independently by third parties. However, where we become aware of materially misleading or non-compliant use of our name, methodologies or credits, we may take steps as described in Section 16 (Misuse and enforcement).

3. Definitions

For the purposes of this Policy:

Carbon claim means any communication that states, implies or could reasonably be understood to state or imply a climate-related attribute, benefit or impact associated with:
- A project or portfolio of projects;
- A carbon credit, unit or instrument;
- A product, service or financial instrument;
- An organisation or jurisdiction (e.g. “carbon neutral”, “net zero”); or
- The use, retirement or holding of credits.
Carbon credit / unit means a quantified unit representing one metric tonne of CO₂ equivalent (tCO₂e) reduced or removed, issued under a recognised methodology and registry framework operated or recognised by the Carbon Foundation.
AAA-certified credit refers to a carbon credit that has undergone assessment and issuance under the Carbon Foundation’s AAA Certification Framework, as set out in our Quality Manual and associated methodologies. The meaning of “AAA” is technical and does not equate to a credit rating or financial guarantee.
Compliant-grade credit means a credit issued under frameworks designed to be aligned with emerging compliance standards (e.g. Article 6, CORSIA, domestic schemes) and our Quality Manual, acknowledging that full legal compliance recognition may depend on regulatory decisions in each jurisdiction.
Project claim refers to claims concerning a specific project’s climate impact (e.g. “this project reduces 100,000 tCO₂e annually”).
Organisational claim refers to claims about an organisation’s climate performance or targets (e.g. “carbon neutral”, “net zero”, “aligned with 1.5°C”).
Use claim refers to claims about what the use of credits achieves (e.g. “offsetting emissions”, “compensating for emissions”, “contribution”, “supporting mitigation beyond value chain”).
Forward-looking claim means any statement about future impact, performance, issuance or alignment (e.g. “expected to generate”, “targeting”, “aims to deliver”).

4. Guiding principles for carbon claims

All carbon claims associated with the Carbon Foundation are governed by the following principles:

Accuracy – Claims must be factually correct, supported by evidence and consistent with our Quality Manual, methodologies and MRV data.
Clarity – Claims must be clear, concrete and understandable to an informed reader, avoiding ambiguous or vague language which could mislead.
Completeness – Claims must not omit key information that would materially change the interpretation of the claim (e.g. boundaries, timeframes, assumptions, limitations).
Non-exaggeration – Claims must not overstate climate benefits, compliance status, certainty of future performance or the scope of coverage (e.g. whole organisation vs. part of operations).
Consistency – Claims must be consistent across documents, channels and audiences; we avoid making contradictory statements in different contexts.
Traceability – For any claim about a credit or project, there must be a documented link to underlying data, methodologies and registry records that can be audited.
Legal and regulatory alignment – Claims must be made in light of relevant consumer protection, advertising and financial promotion rules in the jurisdictions targeted.

5. Types of claims we make and support

We distinguish between the following categories of claims:

Project-level claims
- Statements about emissions reductions or removals attributed to a specific project or programme.
- Must be based on approved methodologies, baselines, MRV and verification as defined in our Quality Manual.
Credit-level claims
- Statements about attributes of specific credits or categories (e.g. AAA-certified, compliant-grade, Article 6-ready).
- Must reflect actual issuance, registry status, and the applicable framework at the time of the claim.
Organisational and framework claims
- Statements about the Carbon Foundation (or our frameworks) being “science-first”, “compliance-aligned”, “high-integrity” etc.
- Must be grounded in documented processes, governance and recognised standards.
Use and impact claims by clients
- Statements by counterparties (e.g. “our emissions are offset by Carbon Foundation credits”).
- While such claims are primarily the responsibility of the claimant, we set conditions on how our credits can be described (see Section 13) where our brand or frameworks are referenced.
Forward-looking claims
- Projections of future emission reductions, credit issuance or alignment with emerging standards.
- Must be clearly labelled as forward-looking, based on reasonable assumptions, and not presented as guaranteed outcomes.

6. Evidence and documentation requirements

Any material carbon claim made by or on behalf of the Carbon Foundation must be supported by:

An applicable approved methodology as referenced in our Quality Manual;
Documented baseline and additionality assessments;
Relevant MRV data, calculations and verification reports, including any uncertainty assessments;
Registry records (where credits are issued, held, transferred or retired); and
For organisational claims, documented inventory boundaries, scopes and assumptions.

Internally, claims should not be published until the relevant sustainability, MRV or methodology lead has endorsed the underlying evidence as adequate for the intended use and audience.

7. Double counting, double issuance and attribution

We are committed to avoiding double counting and double issuance of emissions reductions or removals associated with our frameworks.

Accordingly:

We maintain and/or use registry blockchain systems designed to prevent duplicate issuance of credits for the same emission reduction or removal.
We require that projects are not concurrently registered in multiple systems in a way that could result in double issuance of credits for the same activity and period, unless there is a clearly defined, non-overlapping structure that prevents double counting.
Where our credits may be used towards nationally determined contributions (NDCs) or under Article 6 mechanisms, we will follow or require adherence to applicable rules on corresponding adjustments and accounting.
Claims about the use of our credits must be made in a manner that reflects these accounting principles and avoids suggesting that the same reduction is used twice for climatically distinct purposes.

8. Compliant-grade and AAA claims

When we describe credits as “compliant-grade” or “AAA-certified”, we mean that:

They have been developed and issued under frameworks set out in our AAA Certification Framework and Quality Manual;
They are designed to meet or exceed current best practice in additionality, permanence, leakage control, robust MRV and governance; and
They are intended to be compatible with emerging compliance frameworks (e.g. Article 6, CORSIA, domestic schemes), though final recognition is subject to regulatory decisions in each jurisdiction.

We do not mean that:

The credits are guaranteed to be recognised by all regulators at all times;
They carry a credit rating in the sense used for financial instruments; or
They are risk-free or immune from future policy or market changes.

All such claims must, where appropriate, be accompanied by language that clarifies:

The context and boundaries of “compliant-grade” and “AAA”;
Any known limitations or conditionality (e.g. pending regulatory decisions, evolving rules).

9. Organisational and net-zero claims

The Carbon Foundation will be cautious in making any claim about our own organisational climate performance (e.g. “carbon neutral”, “net zero”, “aligned with 1.5°C”).

Where such claims are made, they must:

Be based on a documented inventory of our own emissions, with clear scopes and boundaries;
Distinguish between gross emissions reductions, residual emissions and use of credits;
Avoid implying that the mere purchase or holding of credits is equivalent to having eliminated underlying emissions; and
Be periodically reviewed and updated as our operations evolve.

We encourage counterparties using our credits to take a similar disciplined approach, and we may decline to provide endorsements where organisational claims are inconsistent with good practice or materially misleading.

10. Co-benefits, social and environmental claims

Where we or our partners describe co-benefits (e.g. biodiversity, community benefits, jobs, health outcomes), we will:

Only highlight benefits that are supported by evidence (e.g. assessments, studies, monitoring reports) and aligned with project documentation;
Avoid overstating the non-carbon benefits or implying certification of co-benefits beyond the scope of our frameworks;
Make clear where co-benefit assessments are undertaken by third-party standards or internal processes; and
Correct or update such claims if new evidence materially changes the picture.

11. Forward-looking statements and uncertainty

Forward-looking claims (e.g. “expected to generate X credits by year Y”) must:

Be clearly labelled as forward-looking and subject to uncertainty;
Be based on reasonable, documented assumptions, consistent with underlying methodologies and project design;
Avoid the impression of a guaranteed outcome or entitlement; and
Where used in financial or investment-related materials, comply with any applicable securities or financial promotion rules.

Uncertainty in MRV (e.g. measurement error, model assumptions) must be accounted for in line with our methodologies and, where material, disclosed as part of the claim or supporting documentation.

12. Transparency and access to information

Subject to confidentiality, security and regulatory constraints, we commit to providing reasonably accessible information on:

The methodology under which a credit is issued;
The project’s location, type and technology (to the extent not commercially sensitive);
The vintage, issuance and retirement status of credits;
Key baseline, additionality and MRV approaches used;
The meaning of our AAA certification and relevant quality criteria.

This may be delivered through:

Registry entries;
Public project descriptions and methodology summaries;
Investor or partner data rooms under NDA; and
High-level explanations on our website and in corporate materials.

We are committed to improving transparency over time as market standards, regulations and stakeholder expectations evolve.

13. Use of Carbon Foundation name and labels in third-party claims

We may grant Partners limited rights to reference the Carbon Foundation, our frameworks or labels (e.g. “AAA-certified carbon credits issued by the Carbon Foundation”) where:

The credits used are authentically issued under our frameworks and registered as such;
The nature and extent of claims (e.g. “offsetting”, “supporting mitigation”) are consistent with this Policy and our guidance; and
There is no implication that we have validated or endorsed broader organisational claims (e.g. “net zero”) unless expressly agreed.

We reserve the right to:

Review proposed descriptions and marketing materials referencing our frameworks;
Require corrections or clarifications where wording is ambiguous, misleading or inconsistent with this Policy; and
Withdraw permission to use our name or labels if misuse persists.

14. Competition, market conduct and price-related claims

The Carbon Foundation does not set market prices for carbon credits in a way that would breach competition or market conduct rules.

Accordingly:

Any price or performance information we publish is indicative and should not be treated as a binding offer or guarantee;
We will not use confidential price-sensitive information from one Partner to influence negotiations with another, consistent with our Investor / Partner Information Policy; and
Claims about pricing or returns on carbon-linked financial products will be drafted in line with applicable financial regulation and marketing standards in relevant jurisdictions.

15. Governance, review and approvals

Responsibility for this Policy and its implementation lies with [insert title – e.g. Chief Sustainability Officer / General Counsel / Chief Operating Officer] on behalf of senior management.

We will:

Integrate this Policy into our Quality Manual and project/methodology governance processes;
Require internal review of significant public-facing claims by appropriate experts (e.g. sustainability, MRV, legal, compliance) before publication;
Provide guidance and training to relevant staff on good practice in carbon claims; and
Periodically review and update this Policy as standards, regulations and our operating model evolve.

16. Misuse, concerns and enforcement

If we become aware that:

Our name, labels, methodologies or credits are being used in connection with misleading or non-compliant carbon claims; or
A Partner has made public statements about our frameworks or credits that materially misrepresent their nature or impact,

we may take steps including:

Contacting the Partner to request correction, clarification or withdrawal of the claim;
Issuing our own public clarification where necessary;
Restricting or terminating that Partner’s access to certain frameworks, labels or services; and/or
Considering legal remedies where our rights or reputation are materially harmed.

Stakeholders who have concerns about any carbon claim made by or connected to the Carbon Foundation are encouraged to contact us using the details in Section 18.

17. Relationship with other policies and agreements

This Policy operates alongside and is consistent with:

Our Quality Manual and project methodologies
Our Data & MRV Governance Policy
Our Investor / Partner Information Policy
Our Privacy Policy, Cookie Policy and platform/registry terms
Any NDAs, project agreements or offtake contracts with specific Partners

In case of conflict:

For the substance of climate impact and integrity, the Quality Manual and underlying methodologies will generally be the technical reference;
For confidentiality and information handling, the Investor / Partner Information Policy, NDAs and applicable law will govern;
For data protection, the Privacy Policy and applicable data protection laws will prevail.

Where a contract or NDA provides higher standards of integrity, confidentiality or disclosure than this Policy, the higher standard will apply in relation to that Partner.

18. Non-contractual nature of this Policy

This Policy describes our standard approach to carbon-related claims and transparency. It does not, by itself, create contractual rights or obligations.

Any legally binding obligations relating to:

The nature of credits or services;
Warranties or representations;
Confidentiality or data protection; or
Use of our name, labels and frameworks will arise from applicable law and from the specific terms of agreements we enter into with Partners. In the event of inconsistency, such agreements will prevail to the extent they provide a higher level of protection or impose more specific obligations.

19. Contact and queries

If you have any questions about this Carbon Claims & Transparency Policy, or wish to raise a concern about a carbon-related claim associated with the Carbon Foundation, please contact:

Carbon Claims & Transparency Enquiries
The Carbon Foundation
Email: claims@carbonfoundation.com

We will respond as promptly as reasonably possible and, where appropriate, work with you to address and resolve any legitimate concerns.

Carbon Claims and Transparency Policy

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