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ACTCommodities 2022 ICROA Annual Audit Form
Overview
The Code of Best Practice (the Code) ensures ICROA Accredited Organisations, and their clients, undertake carbon management strategies that lead to ambitious and impactful climate action.
The Code is structured as follows:
- Section 1: Sourcing and Use of Carbon Credits for Offsetting
- Section 2: GHG Emissions and Removals Inventories (Footprinting)
- Section 3: GHG Emission Reductions Advisory Services
Together, the three sections of the Code outline the requirements that must be met for a VCM organisation to be accredited. An ICROA Accredited Organisation must provide offsetting services and prove that this service is compliant with the requirements outlined in Section 1. If the organisation offers footprinting or advisory services, it should also meet all requirements outlined in Sections 2 and 3, respectively.
Services not covered by the Code include, but are not limited to, services related to compliance and pre-compliance activities such as the provision of carbon credits and non-project-based carbon instruments (e.g., allowances) in connection with clients’ current or future regulatory obligations.
Furthermore, the Code of Best Practice does not cover environmental instruments or activities when they are not used to offset a client’s footprint (e.g., tree planting services, Energy Attribute Certificates (EACs)). EACs are proof of ownership of zero-emission electricity and shall therefore not be used for offsetting but as an accounting tool to lower Scope 2 emissions. Consequently, EACs are not in the scope of the Code of Best Practice.
The Code of Best Practice is written using terminology to enable VCM organisations and third-party auditors to assess their compliance. The following terms are defined in accordance with established terminology of the international standards community:
- The term “shall” indicates a ‘requirement’ strictly to be followed, without deviation, in order to be in compliance.
- The term “should” indicates a ‘recommendation’ for a course of action that is preferred but not strictly required.
- The term “may” indicates a ‘permissible’ course of action within the limits of the Code of Best Practice.
- The term “can” indicates a ‘possible or capable’ situation that is actual or potential.
Reminders
- The 2022 compliance period covers January 1, 2022 to December 31, 2022.
- Under each section that you are required to complete below, you must provide detailed information that demonstrates you have fulfilled the requirements of the Code. You can also provide attachments as necessary.
- When you’ve completed the Audit Form, please notify the Lead Auditor, Eric Gladu, via email (eric.gladu@tetratech.com)
Attestations
On behalf of the company, I/we commit to actively advancing the following principles:
- That corporates measure and publicly report their organisation’s GHG emissions, including Scope 1, 2, and 3, following a recognised standard that is relevant to the intended use (i.e., ISO, Greenhouse Gas Protocol).
- That corporates strive to abate their GHG emissions in line with climate science to deliver a net-zero carbon reduction pathway by 2050 or sooner. The roadmap should include interim short- and medium-term targets that ensure action now and along the way.
- That progress towards these targets is monitored and publicly reported on an annual basis.
On behalf of the company, I/we confirm that I/we have read and agree to abide by the ICROA Terms & Conditions and act consistently with the ICROA Code of Best Practice.
On behalf of the company, I/we agree to pay the fees associated with this application and subsequent audit, even if not successful in achieving the ICROA Accreditation.
On behalf of the company, I/we acknowledge the following definition of the ICROA Accreditation.
ICROA Accreditation:
a. is recognition by ICROA that a voluntary carbon management service organisation ("VCM organisation") competently adheres to the ICROA Code of Best Practice;
b. enables the use of the ICROA Accreditation Label (in accordance with the requirements of the ICROA Accreditation Terms and Conditions);
c. is achieved and maintained through satisfactory completion of:
i. the ICROA Application process (including confirmation that a VCM organisation meets the Eligibility Criteria, in Appendix 1); and
ii. an annual audit programme performed by third-party specialists;
d. is maintained through ongoing compliance with the ICROA Accreditation Terms and Conditions and satisfactory completion of an annual compliance audit;
e. is granted on a non-reliance basis and neither IETA nor ICROA accept any liability for decisions made by third parties that considers or attributes value to the existence of an ICROA Accreditation; and
f. does not amount to any form of endorsement other than to accredit that the VCM organisation has satisfactorily completed the annual audit programme against the ICROA Code of Best Practice, nor does it:
i. give rise to a representation or endorsement to any third party of the VCM organisation;
ii. equate to any endorsement, accreditation, or verification by or on behalf of IETA; or
iii. confirm, accredit or verify any particular business activity, project or service offering of a VCM organisation.
Attestation of Completeness and Accuracy
Please upload as an attachment the Attestation of Completeness and Accuracy of this 2022 Audit Form. A template is provided on the right under attachments.
Declaration
My company provides the following services and will provide evidence of compliance with the Code in the following sections:
Section 1: Sourcing and Use of Carbon Credits for Offsetting
Responses to all questions in this section must be provided.
1.1
Accredited Organisations shall only use/sell carbon credits that are approved by ICROA in relation to their offsetting services. For carbon credits to be approved by ICROA, the criteria in Sections 1.1.1 – 1.1.4 must be met.
1.1.1
When Accredited Organisations are offsetting or contracting to offset GHG emissions on a client’s behalf, they shall only use carbon credits sourced from projects that are validated, verified, and registered under the ICROA Endorsed Standards/Conditionally Endorsed Standards.
Non-carbon Accounting Standards: Accredited Organisations may use carbon credits that have another certification, such as for biodiversity or any other sustainable development component, as long as the underlying carbon credit is from one of the Endorsed Standards listed below. For example, a project under the VCS may also achieve certification under Climate, Community and Biodiversity Standard (CCB) to demonstrate additional benefits associated with the project. These carbon credits must be labelled as appropriate.
Question: During the 2022 Compliance Period, did your organisation use (sell, transfer, and/or retire) credits on behalf of a client for voluntary offsetting from the following Standards (please check all that apply):
Question: For each of the Standards checked above, please provide a comprehensive list of all transactions which includes, at a minimum, the sale date, transfer and/or retirement date, project name, volume sold, the purchasing client/organisation, and the carbon credit serial reference number.
Type your response here
Question: During the 2022 Compliance Period, did your organisation use (sell, transfer, and/or retire) carbon credits which have another certification such as CCB?
Question: If yes, please provide a list of the credits sold with another certification.
Type your response here
1.1.2
The following exceptions apply to the Endorsed Standards in section 1.1.1. Accredited Organisations shall comply with these exceptions, if applicable.
1.1.2.1 Government Schemes:
Carbon credits from Government schemes may be provided by Accredited Organisations to their clients on the strict condition that they are only used within the context of the Government scheme to offset a local footprint within this specific jurisdiction. They shall not be sold as voluntary carbon credits internationally unless the scheme has been separately endorsed by ICROA or falls under a UNFCCC mechanism (e.g., Article 6.2 or Article 6.4 of the Paris Agreement). A link to the local registry shall be provided as evidence for any retirements made.
Question: During the 2022 Compliance Period, did your organisation use (sell, transfer, and/or retire) voluntary carbon credits from government schemes?
Question: If yes, please provide details about these sales including who the credits were sold to and for what purposes.
Type your response here
1.1.2.2 Non-compliant carbon credits:
Forecasted Mitigation Units (FMUs) issued by the Climate Action Reserve, forward carbon credits issued under Gold Standard’s forestry projects (Planned Emission Reductions), ex-ante Plan Vivo Certificates and Temporary or Long-term CER (t/l-CER), and any other ex-ante credits are not considered valid because they do not meet ICROA requirements on verification and permanence.
Question: During the 2022 Compliance Period, did your organisation use (sell, transfer, and/or retire) any ex-ante credits? Please explain.
Type your response here
1.1.2.3 Bundling :
Where Accredited Organisations offer their clients carbon credits from regional, emerging, or innovative schemes to enhance VCM development and innovation, Accredited Organisations shall demonstrate that the credits were effectively “bundled” with carbon credit retirements from at least one ICROA Endorsed Standard on a one-to-one ratio. In such scenarios, Accredited Organisations should communicate to their clients that offsetting is achieved only through carbon credits from the ICROA Endorsed Standard. Any such bundling shall be transparently reported.
Question: During the 2022 Compliance Period, did your organisation use (sell, transfer, and/or retire) carbon credits from regional, emerging, or innovative schemes?
Question: If yes, please provide a list of these credits with evidence to demonstrate that these credits were bundled with carbon credits retired from one of the ICROA Endorsed Standards. Please also provide evidence that your organisation communicated to the client that offsetting was achieved only through the credits from the ICROA Endorsed Standard.
Type your response here
1.1.3
All projects registered under an ICROA Endorsed Standard shall have a net positive or at least neutral impact on social, economic, and environmental factors. Standards must uphold the following principles and ensure all issued carbon credits are unique, real, permanent, additional, independently verified, and measurable. Accredited Organisations should promote sustainable development in the projects that they develop and/or transact. Accredited Organisations should communicate whether and how they have assessed the sustainability impacts of their projects and promote the co-benefits or refer to the UN sustainable development goals when evaluating their impacts. Sustainability standards such as CCB should be communicated appropriately so as not to be confused with carbon standards.
Question: Optional comments can go here.
Type your response here
1.1.4
When Accredited Organisations contract to sell carbon credits to a client in advance of verification and issuance of those credits (herein referred to as “Carbon Credits Sold in Advance of Verification”), they shall provide clients with appropriate and transparent levels of delivery assurance.
1.1.4.1
At a minimum, such Accredited Organisations shall either:
- Provide a contractual guarantee of delivery or replacement by demonstrating the financial viability to underwrite such guarantee (i.e., contractual financial guarantee) or by having in place ’contractual appropriate safeguards’ to minimize the requirement for replacement and protect the guarantee; or
- When a delivery guarantee is not provided, have in place appropriate safeguards to minimize the risk of project under-performance. Appropriate safeguards mean the minimization of, and insurance against, risks by reserving a portion of the project portfolio as a “buffer” to the extent reasonably required to safeguard performance adequately. Accredited Organisations using such safeguards shall adjust their reservation practices based on experience and industry best practices where available.
Question: During the 2022 Compliance Period, did your organisation sell carbon credits in advance of verification and issuance?
Question: If yes, please provide evidence that the guarantees in 1.1.4.1(a) and 1.1.4.1(b) were met.
Type your response here
1.1.4.2
At the point of sale, Accredited Organisations shall transparently disclose if the delivery is guaranteed, the measures that are in place to minimize the risk of project under-performance, and what sources of reductions and/or removals are eligible replacements, as applicable.
Question : Please provide evidence that Section 1.1.4.2 of the Code was met.
Type your response here
1.1.4.3
At the point of sale, Accredited Organisations shall make reasonably available* the current development or operational status of the project and the expected date or dates of future verification and issuance.
* For the purposes of this document, “Reasonably available” will be taken to mean the following: in the instance of sales to the public (also known as “consumer sales”), information will be considered to be “reasonably available” when made publicly available on an Accredited Organisation’s website or other publicly available materials / collateral. In the instance of corporate, or business-to-business, sales information will be considered to be “reasonably available” when included in written communications or documents (e.g., contractual documents) pertaining to the appropriate sale, either at the behest of the Accredited Organisation or the Accredited Organisation’s client.
Question: Please provide evidence that Section 1.1.4.3 of the Code was met.
Type your response here
1.1.4.4
If requested by clients, Accredited Organisations shall make reasonably available, directly or on their website as applicable, the actual dates of verification and issuance; any deficiency in the verified volume relative to the volume sold to such clients; and the sources of any replacements.
Question: Please provide evidence that Section 1.1.4.4 of the Code was met.
Type your response here
1.1.4.5
Accredited Organisations shall provide clients that purchase carbon credits with clear and easy-to-understand communication materials and shall encourage them to communicate the nature of their carbon credit purchases accurately and transparently.
Question: Please provide evidence that Section 1.1.4.5 of the Code was met.
Type your response here
1.2
Accredited Organisations and/or their clients shall retire carbon credits used for voluntary offsetting in a recognised third-party registry. Furthermore, when making a carbon neutrality and/or offsetting claim, retirements should be made in advance of such claim according to recognised protocols (e.g., BSI PAS 2060), or it must be explained why this is not the case and provide substantiation including how risk is managed - both the contractual risks and reputational risks associated with marketing claims as stated in Section 2.4.*
*For the avoidance of doubt, this clause does not pertain to the forward procurement by a company of emissions reductions to support a future strategy such as a commitment to Net Zero. This is regarded as a strategy and not a market claim as referred to in 1.3.2.
Question: During the 2022 Compliance Period, did your organisation retire credits for the client in advance of them making their carbon neutrality or offsetting claim?
Please provide evidence to substantiate your claim.
Type your response here
Please explain which protocols were followed, and how the retirements were done in accordance with said protocol.
Type your response here
Please explain why and provide substantiation on how risk (both contractual and reputational) is managed.
Type your response here
Question: If more than one box was checked, please explain your answer and provide supporting documentation.
Type your response here
1.3
Accredited Organisations shall encourage clients to communicate their carbon inventory and reduction activities, including but not necessarily limited to, the following:
- the client’s total GHG emissions associated with the organisation, product, service, or event;
- actions being taken by the client to reduce GHG emissions;
- any GHG emissions that are being offset for the client, and details of the project(s) generating the carbon credits (for example, if a portfolio approach is used);
- a link to the registry where the carbon credits have been retired; and/or
- any uncertainties or risks associated with the carbon footprint or internal or external emission reductions.
Question: Please provide evidence showing how your organisation encouraged clients to communicate their carbon inventory and reduction activities, including but not necessarily limited to the scenarios identified above.
Type your response here
Section 2: GHG Emissions and Removals Inventories (Footprinting)
Responses to all questions in this section should be provided if your organisation performed, or sub-contracted, services related to GHG emissions and removals inventories (footprinting) in the 2022 Compliance Period.
2.1
The Accredited Organisation shall actively require clients to measure their GHG inventory.
Question: Please provide evidence that your organisation actively requires clients to measure their GHG inventory.
Type your response here
2.2
If an Accredited Organisation performs GHG inventory measurement activities for clients or sub-contracts these to a third-party, then they shall perform these activities in accordance with the WRI/WBCSD GHG Protocol Corporate Accounting and Reporting Standard (including the GHG Protocol’s Scope 2 Guidance and Corporate Value Chain (Scope 3) Standard) or ISO 14064-1:2018. Furthermore, they shall measure in accordance with accepted standards and shall use where possible publicly available and nationally relevant emissions factors from reputable and recognized sources, for example, the IPCC, published Government data, or peer-reviewed studies.
Additionally, supplier-specific emission factors or calculations are encouraged, provided the supplier has derived their calculations using standards or guidance that are applicable to their operation and the intended use of the organisation completing the measurement.
Question: Please explain which accounting framework(s) were used.
Type your response here
Question: Please explain which emission factors were used.
Type your response here
Question: Please provide a list of all GHG inventories completed during the 2022 Compliance Period.
Type your response here
2.3
If Accredited Organisations conduct product or service footprints or if they sub-contract these activities to a third-party, then; the Accredited Organisations shall determine these footprints on a life cycle basis*. As examples, the PAS 2050, WBCSD-WRI GHG Protocol Product Life Cycle Accounting and Reporting Standard (2011), Greenhouse Friendly Program, Bilan Carbone documents, ISO 14067/14040/14044, or any other relevant and credible guidelines developed and/or adopted by international or national organisations in the future can provide guidance on how to estimate product and service emissions on a life cycle basis.
* The WBCSD-WRI GHG Protocol Corporate Value Chain (Scope 3) Accounting and Reporting Standard (2011) and WBCSD-WRI GHG Protocol Product Life Cycle Accounting and Reporting Standard (2011) provide international requirements and guidance, however, these documents are being considered by ICROA and are not incorporated explicitly into the ICROA Code of Best Practice.
Question: Please provide a list of all product and/or service footprints completed during the 2022 Compliance Period.
Type your response here
2.4
If Accredited Organisations perform any footprinting measurement for air travel, then they shall publicly disclose and justify what Radiative Force Index (RFI) they apply when calculating air travel emissions.
Question: Please explain and justify which Radiative Force Index was applied to footprints during the 2022 Compliance Period.
Type your response here
2.5
If Accredited Organisations provide calculators for clients to quantify trips, events, energy usage, etc or sub-contract this to a third-party, they shall ensure calculators are always accurate to the latest published emission factors and recognised GHG accounting practices.
Question: Please explain and provide evidence that calculators are accurate and use the latest published emission factors and GHG accounting practices.
Type your response here
Section 3: GHG Emissions Reduction Advisory Services
Responses to all questions in this section should be provided if your organisation provided GHG emission reduction advisory services in the 2022 Compliance Period.
3.1
Accredited Organisations shall encourage clients to set science-aligned emissions abatement targets, aligned to the Paris Agreement goals. Clients shall be encouraged to perform a comprehensive assessment of opportunities to reduce direct and value chain emissions aligned with science.
Question: Please provide evidence that Section 3.1 of the Code was met.
Type your response here
3.2
For product or service offers (e.g., carbon neutral deliveries), Accredited Organisations shall encourage their clients to set carbon abatement targets and be transparent in reporting. Ideally, recognised protocols for applying the mitigation hierarchy/carbon neutrality, such as BSI PAS 2060, should be followed.
Question: Please provide evidence that Section 3.2 of the Code was met.
Type your response here
3.3
Accredited Organisations shall encourage clients to transparently communicate performance relative to their short-, medium-, and long-term abatement targets. Likewise, clients’ product and/or service activities (as defined in 1.3 should be transparently communicated and in the public domain (e.g., on the client’s website).
Question: Please provide evidence that Section 3.3 of the Code was met.
Type your response here
3.4
Accredited Organisations shall encourage clients to increase ambition and go beyond their abatement targets through the use of offsetting.
Question: Please provide evidence that Section 3.4 of the Code was met.
Type your response here
3.5
Accredited Organisations may outsource the assessment of internal emissions reduction opportunities to a subcontractor, and under such circumstances, the subcontractor shall be contractually obligated to satisfy the requirements of the Code of Best Practice.
Question: Did your organisation outsource internal emission reduction opportunities during the 2022 Compliance Period?
Question: If yes, please provide the subcontractor agreement.
Type your response here