The ICROA Code of Best Practice is written using terminology to enable ICROA to assess the compliance of ICROA Affiliates. 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.
• The term “can” indicates a „possible or capable‟ situation that is actual or potential.

ICROA Compliance Form

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Contents of the Compliance Form:

Name of Organization: 

Name of Person Completing Compliance Audit Form: 

Contact Telephone:

Contact Email: 

I hereby confirm that to the best of my knowledge the Compliance Form below has been completed accurately and that each response can be corroborated with sufficient evidence. I hereby confirm that to the best of my knowledge [Affiliate name] continues to meet the membership criteria of ICROA. The Compliance Audit Form covers the following period: 2020.

[Insert electronic signature*]

1.0 Carbon Footprinting

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1.1 ICROA Member Actions to Encourage Client Carbon Footprint Measurements

ICROA members shall actively encourage clients to measure their carbon footprint.

Example Evidence:

• Affiliate website - include URLs
• Customer proposals and reports
• Promotional material

1.2 ICROA Member Use of Accepted Standards and Emission Factors

If the ICROA member performs carbon footprint measurement activities for clients or if the ICROA members sub-contract these to a 3rd party, then; ICROA members shall measure carbon footprints in accordance with accepted standards and shall use publicly available and nationally relevant emissions factors from reputable and recognised sources, for example, the IPCC, and published Government data. 

Example Evidence:

• List of all carbon footprinting assessments completed during the audit period
• Based on the list above, the Auditor will then request the report and calculations for 2 Corporate/Organizational Carbon Footprints

Auditor Tasks:

• Auditor should obtain a list of relevant customers. For a sample of two relevant customers, auditor should obtain the services contract and confirm whether contractually the Affiliate is required to perform carbon footprinting in line with the cited standard and emission factors. For the same customers, auditor should obtain the carbon footprint calculation relating to them and the auditor should
  • Re-perform the carbon footprint calculation;
  • Trace the emission factors used back to the cited source and document the sources of emission factor and the version/version date
  • Document the accepted standard cited.
  • Document whether any differences are identified and if so, the percentage difference noted.

Auditor Tests and Findings:

• Auditor should re-perform a footprint calculation for 2 customers to confirm the calculations are consistent with accepted standards, and use publicly available, relevant and reliable emission factors
• Auditor should confirm whether the Affiliate’s policies includes a section on carbon footprinting
• Auditor should test a sample of 2 assessments (one organisation assessment and one product assessment) and check whether it makes reference to the Affiliate policies or the protocols listed by ICROA.

1.3 ICROA members subcontract carbon footprinting activities, shall ensure the subcontractor satisfies all requirements of the ICROA

If ICROA members subcontract carbon footprinting activities then ICROA members shall ensure the subcontractor satisfies all requirements of the ICROA.

Example Evidence:

• Relevant contractual details
• Due diligence policy

1.4 Organisation Carbon Footprinting

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1.4.1 ICROA Member Organisation Carbon Footprint Activities in Accordance with GHG Protocol-Corporate and ISO 14064-1 for Clients

If ICROA members perform carbon footprint measurement activities for clients or if ICROA members sub-contract these to a 3rd party, then; ICROA members shall perform these activities in accordance with the WRI/WBCSD GHG Protocol Corporate Accounting and Reporting Standard (2015) and ISO 14064-1: 2018. The GHG Protocol Corporate Accounting and Reporting Standard includes the Scope 2 Guidance, which allows companies to credibly measure and report emissions from purchased or acquired electricity, steam, heat, and cooling. Consequently, carbon footprints performed by ICROA members shall be line with the Scope 2 Guidance.

 Example Evidence:

• Affiliate internal procedures guide
• Evidence of checks undertaken (as per procedures manual)
• Data capture sheets/system
• Calculation tool/formulae/calculator used to complete the carbon footprint measurement report, and if available the tool user guide
• Customer proposals and reports
• Organisational Carbon Footprint measurement reports

Auditor Tasks:

• Auditor should obtain a copy of the Affiliate’s procedures manual and confirm whether conformance with WRI/WBCSD GHG Protocol Corporate Accounting and Reporting Standard (2015) (the “GHG Protocol”) and ISO 14064-1:2018 (“ISO 14064”).
• Auditor should obtain a list of relevant customers. For a sample of two relevant customers, auditor should obtain the services contract and confirm whether contractually the Affiliate is required to perform carbon footprinting in line with the GHG Protocol and ISO 14064.
• For the same customers, auditor should obtain the carbon footprint calculation relating to them and confirm whether it:
  • defines organisational boundaries;
  • considers each of the operational boundaries separately;
  • actively excludes any known scope 1 or scope 2 emissions sources or activities;
  • detail any relevant assumptions and make appropriate references to the accounting and calculation methodologies and data sources used;
  • define and measure emissions for a base year; and
  • follows the same methodology for the current and base year.
  • For the same customers, auditor should obtain the carbon
• footprint report relating to them and confirm whether it:
  • states is has been prepared in accordance with the GHG Protocol and ISO 14064;
  • discloses and justifies any specifically excluded emission
  • Ensure that carbon footprints performed by ICROA Affiliates are in line with the GHG Protocol Scope 2 Guidance.

Auditor Tests and Findings:

• Auditor should review Affiliates standard GHG Inventory Report and two specific customer reports to confirm that the approach complies with the WRI/WBCSD GHG Protocol Corporate Accounting Standard, as detailed under "Auditor Tasks”

1.4.2 ICROA Member Advice for Clients to Disclose which Scope 3 Emissions are Included in Carbon Footprint

If ICROA members perform organizational carbon footprint activities or if ICROA members sub-contract these activities to a 3rd party, then; ICROA members shall advise clients to disclose which ‘Scope 3’ or ‘Other Indirect’ emissions sources have and have not been included in their carbon footprint.

Example Evidence:

• Affiliate website - include URLs
• Customer proposals and reports
• Promotional material
• Affiliate internal procedures guide

Auditor Tasks:

• Auditor should obtain evidence presented and document where this evidence is held (e.g. website, promotional material).
• Auditor should document extracts from the material cited by the Affiliate as demonstrating advice to disclose scope 3 emissions. Where this material is included on a website, the auditor should take a screenshot with the URL, content and date the website was accessed by the auditor. Where this material is only available to prospective or current customers, e.g. in a customer proposal or report, auditor should obtain two relevant proposals/reports and should confirm whether they contain the same or similar language.

Auditor Tests and Findings:

• Auditor should review GHG Inventory Reports / Summaries for 2 transactions involving a footprint calculation
• Auditor should review standard communications sent to clients

1.4.3 ICROA Member Ensure Clarity with Client which Emissions Being Offset with Carbon Credits

If ICROA members perform organizational carbon footprint activities for clients or if ICROA members sub-contract these activities to a 3rd party, then; ICROA members shall ensure clarity with their clients regarding which organisation footprint emissions are being offset with carbon credits supplied by the ICROA member.

Example Evidence:

• Customer reports
• Emails or other client communication
• Affiliate internal procedures guide
• Certificates for 2 offset transactions

Auditor Tasks:

• Auditor should obtain a list of relevant customers. For a sample of two relevant customers, auditor should obtain evidence presented.
• Auditor should document where this evidence is held (e.g. customer report, email to customer).
• Auditor should document extracts from the material cited by the Affiliate as demonstrating clarity over allocation of carbon credits. Note: Customer confidential information need not be shared, but the auditor’s documentation should make the method/nature of allocation clear.

Auditor Tests and Findings:

• Auditor should review Certificates for 2 offset transactions
• Auditor should review standard communications sent to clients
• Auditor should confirm whether the Affiliate policies includes a section on which organisation footprint emissions are being offset with carbon credits supplied.

1.5 ICROA Member Product and Service Footprint Activities on a Life Cycle Basis for Clients

If ICROA members perform product or service footprints or if ICROA members sub-contract these activities to a 3rd party, then; ICROA members shall determine these footprints on a life cycle basis**. The PAS 2050, WBCSD-WRI GHG Protocol Product Life Cycle Accounting and Reporting Standard (2011), Greenhouse Friendly Program, Bilan Carbone documents and ISO14067:2018 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.

Example Evidence:

• Affiliate internal procedures guide
• Customer contracts
• 2 LCA Reports & Calculation tool/formulae completed for clients during the Audit Period

Auditor Tasks:

• Auditor should obtain a copy of the Affiliate’s procedures manual and confirm whether it includes reference to product and service footprints being performed on a LCA basis. If conformance with a specific life cycle methodology is cited, auditor should document the name of the methodology.
• Auditor should obtain a list of relevant customers. For a sample of two relevant customers, auditor should obtain the services contract and confirm whether contractually the Affiliate is required to perform product and service footprints on a life cycle basis. For the same customers, auditor should obtain a product or service footprint calculation relating to them and confirm whether it:
  • defines the product or service;
  • defines the unit of analysis and/or functional unit;
  • defines the product/service boundary,
  • attributable processes and time boundary;
  • demonstrates inclusion of some primary data;
  • documents the life cycle stages included some primary data;
  • documents the life cycle stages included in the calculation, e.g. material acquisition and pre-processing, production, distribution and storage, use and end-of life
  • if any life cycle stages are intentionally excluded, documents the Affiliate’s justification for this. Note: This may be through discussion.

Auditor Tests and Findings:

• Auditor should discuss with the Affiliate and document how the Affiliate is satisfied that its footprinting service adheres to ICROA.

1.6 ICROA Member Use, Rationale and Disclosure of Radiative Forcing Index (RFI)

If ICROA members perform any footprinting measurement for air travel, then; ICROA members shall publicly disclose and justify (on their website) what Radiative Force Index (RFI) they apply when calculating air travel emissions.

Example Evidence:

• Affiliate website - include URLs
• Communications Materials
• Affiliate internal procedures guide

Auditor Tasks:

• Auditor should obtain evidence presented
• Auditor should document extracts from the material cited by the Affiliate as disclosing and justifying what Radiative Force Index the Affiliate applies when calculating air travel emissions.
• The auditor should take a screenshot with the URL, content and date the website was accessed by the auditor.

Auditor Tests and Findings:

• Auditors should confirm Affiliate’s website as at the date the procedure is performed, communicates Affiliate’s position on Radiative Forcing Index
• Auditor should validate that the information is publicly available on website.

1.7 Greenhouse Gas Reduction Advice

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1.7.1 ICROA Member Actions to Encourage Clients to Set Emission Reduction Targets Beyond BAU

ICROA members should encourage clients to set emission reduction targets that challenge clients to go beyond business-as-usual practices.

Example Evidence:

• Affiliate website - include URLs
• Communications/Marketing Materials
• Affiliate internal procedures guide
• Customer proposals and reports

1.7.2 ICROA Member Actions to Encourage Clients to Assess Emission Reduction Opportunities

ICROA members should encourage clients to perform a comprehensive assessment of opportunities to reduce emissions internally and externally. 

Example Evidence:

• Affiliate website - include URLs
• Communications/Marketing Materials
• Affiliate internal procedures guide
• Customer proposals and reports

1.7.3 ICROA Member Actions to Encourage Clients to Prioritise Cost Effective Reductions to Meet Targets

ICROA members should encourage clients to prioritise cost effective reductions to meet those targets through internal and external reductions, including renewable energy and offsetting using carbon credits. 

Example Evidence:

• Affiliate website - include URLs
• Communications/Marketing Materials
• Affiliate internal procedures guide
• Customer proposals and reports

1.7.4 ICROA Member Subcontracting of Assessment of Internal Emission Reduction Satisfies ICROA Code

If ICROA member subcontracts the assessment of internal emission reduction opportunities, ICROA members shall ensure that the subcontractor satisfies the requirements of the ICROA Code.

Example Evidence:

• Relevant contractual details

Auditor Tasks:

• Auditor should obtain a copy of relevant sub-contracts. If applicable, auditor should document the relevant clause extract(s) cited as evidencing that they meet the requirements of the ICROA code. Note: disclosure of the name of the subcontractor(s) is not required.• If no such clauses exist, auditor should document how the Affiliate ensures that the subcontractor satisfies all requirements of the ICROA Code. If the Affiliate can provide evidence to support this, auditor should document the nature of the evidence.

1.8 Offset Services

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1.8.1  ICROA Member Retirement of Carbon Credits Used for Offsetting

ICROA members shall retire carbon credits used for voluntary offsetting in a third-party registry or permanently remove the carbon credits from the market.

Example Evidence:

• A comprehensive list of offset customers where credits have been sold (whether they are retired or transfer if sold). The list should include sold date, retired date, project name, volume, standard, and the carbon credit serial reference number
• Retirement notice or equivalent issued documentation (no need to tag to client)

Auditor Tasks:

• Auditor should obtain a copy of the Affiliate’s procedures manual and confirm whether it includes reference to retiring carbon credits used for voluntary offsetting in a third-party registry or permanently removing the carbon credits from the market
• Auditor should document relevant extracts from the material
• Auditor should obtain a list of relevant customers and trace the sold offsets to one or both of the following:
  • an internal register, evidencing that they are updated to reflect the sale of the offsets; and/or
  • a retirement notice from an external register evidencing they have been retired.
• Auditor should review a list of all offsets transferred to a 3rd party, including the date, amount of tonnes transferred and the name of the 3rd party

Auditor Tests and Findings:

• Auditor should review Affiliate policies, procedures and documentation to confirm that all credits sold have been retired by Affiliate on the relevant registry

1.8.2 ICROA Member Use of Documented Terms and Conditions if Carbon Credits Not Retired

ICROA members should use documented Terms and Conditions with clients stating the purpose and nature of the instrument in cases where the carbon credits are not retired by the ICROA member.

Example Evidence:

• Customer proposals and reports
• ERPA

1.9 Communication

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1.9.1 ICROA Member Actions to Encourage Clients to Report Total Emissions

ICROA members should encourage clients to report total emissions associated with the organisation, product, service or event

Example Evidence:

• Affiliate website - include URLs
• Communications/Marketing Materials
• Affiliate internal procedures guide
• Customer proposals and reports

1.9.2 ICROA Member Actions to Encourage Clients to Report Actions to Reduce Emissions

ICROA members should encourage clients to report all other actions being taken by the client to reduce greenhouse gas emissions. 

Example Evidence:

• Affiliate website - include URLs
• Communications/Marketing Materials
• Affiliat einternal procedures guide
• Customer proposals and reports

1.9.3 ICROA Member Actions to Encourage Clients to Report Offsetting of Emissions

ICROA members should encourage clients to report any emissions that are being offset by the client, and details of the project(s) generating the offset (for example, if a portfolio approach is used) 

Example Evidence:

• Affiliate website - include URLs
• Communications/Marketing Materials
• Affiliate internal procedures guide
• Customer proposals and reports

1.9.4 ICROA Member Actions to Encourage Clients to Report Link to Offset Registry

ICROA members should encourage clients to report a link to the registry where the offset has been retired. 

Example Evidence:

• Affiliate website - include URLs
• Communications/Marketing Materials
• Affiliate internal procedures guide
• Customer proposals and reports

1.9.5 ICROA Member Actions to Encourage Clients to Report Uncertainties and Risks of Carbon Footprint or Reductions

ICROA members should encourage clients to report any uncertainties or risks associated with the carbon footprint or internal or external emission reductions. 

Example Evidence:

• Affiliate website - include URLs
• Communications/Marketing Materials
• Affiliate internal procedures guide
• Customer proposals and reports

2.0 Sourcing and Use of Carbon Credits for Offsetting

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2.1 ICROA Member Use of Credible Carbon Credits According to ICROA Code of Best Practice Principles

ICROA members shall use credible carbon credits that meet international standards when offsetting is used to meet voluntary reduction targets. When offsetting, or contracting to offset, GHG emissions on behalf of a client, ICROA members shall only use carbon credits sourced from offset projects that are or will be validated, verified and registered under the following offset standards approved by ICROA:

• Clean Development Mechanism
• Climate Action Reserve
• Gold Standard
• Joint Implementation
• Verra's Verified Carbon Standard
• American Carbon Registry
• Emissions Reduction Fund (ERF) of the Australian Government
• Global Standard Council
• UK Woodland Carbon Code (WCC),
• the Architecture for REDD+ Transactions (ACT) The REDD+ Environmental Excellence Standards (TREE)

If the carbon credits sourced from these offset standards are not in accordance with the principles of Real, Measurable, Permanent, Additional, Independently Verified and Unique., they shall not be used to offset GHGs emissions on behalf of a client**. For the avoidance of doubt, ex-ante carbon credits cannot be used to offset GHG emissions on behalf of an organization.

**As a consequence, units such as: i) Forecast Mitigation Units issued by the Climate Action Reserve and forward carbon credits issued under Gold Standard‟s forestry projects are not considered valid; ii) Temporary CER (t-CER) are not considered valid because they do not meet the requirements.

All carbon credits used for the purpose of carbon offsetting shall be in accordance with the following principles:  

1. Project-based emission reductions and removals shall be additional to what would have occurred if the project had not been carried out.
2. ICROA members shall demonstrate the project would not have occurred without the availability of carbon finance.

Example Evidence:

• A comprehensive list of all credits sold (whether they are retired or transfer if sold). The list should include sold date, retired date, project name, volume, standard, and the carbon credit serial reference number

Auditor Tasks:

• Auditor should obtain evidence presented. Document where this evidence is held (e.g. website, promotional material). Document extracts from the material cited by the Affiliate as demonstrating they use credible carbon credits that meet international standards.
• Auditor should document the name of the international standard(s) cited as being applicable for carbon credits sold and should confirm if they are all endorsed by ICROA (see approved standards above)
• Auditor should obtain list of projects (names, identification codes, dates) and should trace sample of 3 contracts to relevant registry. The auditor should then provide a screenshot that includes the URL and time the Auditor accessed the webpage, of the validation report, verification report and PDD. Auditor should identify, from the verification reports, the name of the independent third party verifier. Auditor should validate that they are accredited under the ICROA approved offset standard

Auditor Tests and Findings:

• Auditor should perform review of Affiliate policies, procedures and documentation to confirm that all credits sold are accredited under either the approved standards
• Auditor should validate that the cited offset standard is ICROA approved
• Auditor should discuss with the Affiliate and document the types of projects theAffiliate may source credits from
• For a sample, auditor should check project screening,  validation or verification reports/proof of engagement with DOE.
• Auditor should consider timeliness of validation by comparing the validation date with the date of the ERPA
• Auditor should consider whether accreditation provided by independent third party (DOE or verifier accredited by the standards) is permitted by the ICROA Code of Best Practice.

2.1.1 ICROA Member Use of Carbon Credits - Government-approved Schemes

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Government-Approved Schemes: Offsets from approved Government schemes may be provided by ICROA members to their clients, on the strict condition that Government scheme certified offsets shall only be used within the context of the Government scheme and shall not be sold as voluntary offsets outside the context of the Government scheme, unless these methodologies have been separately approved by ICROA.

Example Evidence:

• A comprehensive list of all credits sold to government-approved schemes. The list should include sold date, retired date, project name, volume, standard, and the carbon credit serial reference number

Auditor Tasks:

• Auditor should obtain a list of sold/used offsets Government Schemes provided to the Affiliate by ICROA. Auditor should validate that these offsets have only been used within the context of the government scheme

Auditor Tests and Findings:

• Auditor should discuss with the Affiliate and document whether any offsets from approved Government schemes have been used. If the answer is yes, auditor should select a sample of three offsets approved Government scheme and verify they have been separately approved by ICROA.

2.1.2 ICROA Member Use of Carbon Credits - Non-carbon Accounting Standards

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Non-carbon Accounting Standards: ICROA members may use units issued under the Clean Development Mechanism (CDM) and qualifying Verified Emission Reductions (VER) carbon accounting standards that have been combined or “tagged” with the CCB Standard and SOCIALCARBON Standard.

Example Evidence:

• A comprehensive list of all credits sold under the CDM or VER. The list should include sold date, retired date, project name, volume, standard, and the carbon credit serial reference number

Auditor Tasks:

• Auditor should obtain a list of sold/used offsets provided to the Affiliate by ICROA. Auditor should validate that these offsets have been tagged with the CCB Standard and SOCIALCARBON Standard.

2.1.3 ICROA Member Use of Carbon Credits - VER+

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VER+: Selected VER+ credits may be accepted under ICROA‟s grandfathering rules provided that certain criteria are met: to accept into the ICROA Code of Best Practice those projects that committed themselves to the VER+ standard prior to the launch of VCS Version1 [i.e. before March 2007]; generate less than 100,000 tons of emission reductions per annum; and are based on technology types other than large hydropower and industrial gases.

Example Evidence:

• A comprehensive list of all credits sold under VER+. The list should include sold date, retired date, project name, volume, standard, and the carbon credit serial reference number

Auditor Tasks:

• Auditor should obtain a list of sold/used offsets provided to the Affiliate by ICROA. Auditor should validate that these offsets predate March 2007, generate less than 10,000 tons of emission reduction per annum and are based on technology types other than large hydropower and industrial gases

2.1.4 ICROA Member Use of Carbon Credits - Australian Carbon Credit Units (ACCU)

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Australian Carbon Credit Units (ACCU): For the use ACCUs generated under the ERF to be permitted, ICROA members are required to provide the following documentation during the annual audit:

1. Project documentation including; project plan (document equivalent to the PDD), proof of project registration and/or ERF Project ID, relevant verification report(s), proof that verifier is accredited (or equivalent) under the CFI; and
2. Details of all ACCU transactions and retirements, such as screenshots from ANREU accounts and serial number/identification data of carbon credit(s)

Example Evidence:

• A comprehensive list of all credits sold under ACCU. The list should include sold date, retired date, project name, volume, standard, and the carbon credit serial reference number
• Project documentation and details of transactions as stated above

Auditor Tasks:

• Auditor should obtain a list of ACCU sold/used offsets provided and document relevant extracts from the material including the project plan, proof of project registration, ERF project ID, verification report, proof that the verifier is accredited.
• Auditor should review the screenshots provided by the Affiliate showing the transactions along with serial number and identification data.

2.2 ICROA Member Disclosure of Project/Offset Sustainability Assessments

ICROA members shall disclose the methods used to assess the sustainability impacts of their projects/offsets.

Example Evidence:

• Internal Company Procedures
• Affiliate website (including URL)

Auditor Tasks:

• Auditor should obtain evidence presented and should document where this evidence is held (e.g. website, promotional material)
• Auditor should document extracts from the material cited by the Affiliate as disclosing the methods they have used to assess the sustainability impacts of their projects/offsets
• Where this material is included on a website, the auditor should take a screenshot with the URL, content and date the website was accessed by the auditor.
• Where this material is only available to customers, e.g. in a customer proposal/report, auditor should obtain a list of relevant customers and for a sample of two relevant proposals/reports to confirm whether they contain the same or similar language.

Auditor Tests and Findings:

• From the sample selected in 2.1, auditor should verify that the PDDs and the validation reports include sustainability assessments and that the assessment’s basis is clearly disclosed.

2.3 ICROA Member Delivery Assurance, Guarantee and Disclosure to Client

When contracting to offset greenhouse gas emissions on behalf of a client occurs in advance of verification and issuance of the carbon credits (herein referred to as “Reductions Sold in Advance of Verification”), ICROA members shall provide clients with appropriate and transparent levels of delivery assurance.At a minimum, such ICROA members shall:

1. 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
2. When a delivery guarantee is not provided, have in place ‟Appropriate Safeguards‟ to minimize the risk of project under-performance. “Appropriate safeguards” means the minimization of, and insurance against, risks by reserving a portion of the project portfolio as a „buffer‟, to the extent and as long as reasonably required to safeguard performance adequately. ICROA members using such safeguards shall adjust their reservation practices based on experience and industry best practice where available.

At the point of sale, ICROA members shall:

1.  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. 
2. I make reasonably available the current development or operational status of the project and the expected date or dates of future verification and issuance.

Example Evidence:

• Contract with project developer/client
• Terms and Conditions of Sale
• ERPA
• Proof of engagement of a DOE

Auditor Tasks:

• Auditor should obtain a copy of the Affiliate’s procedures manual and confirm whether contractual delivery guarantees are provided.
• Auditor should discuss with the Affiliate and document relevant risk management policies regarding financial viability
• Using the projects selected for testing in 2.1, auditor should obtain the contracts with the project developer and:
  • identify whether a guarantee of delivery or replacement is include
  • if no guarantee is in place, trace the project’s offsets through to the buffer account and document the percentage of offsets contracted that are held in the buffer account.
  • Confirm that a delivery guarantee is included
  • the sources of reductions and/or removals are eligible replacements, as applicable;
  • the current development or operational status of the project and the expected date or dates of future verification and issuance.
• Auditor should obtain a list of customers where non-guaranteed offsets have been supplied pre-verification. Auditor should compare with the buffer account and determine and document, on a total basis, the relative size of the buffer account to the quantity of non-guaranteed offsets supplied

Auditor Tests and Findings:

• Auditor should review Terms and Conditions and check they clearly state the risk of under-delivery and consequences
• Auditor should obtain a sample of 3 contracts where undelivered carbon has been sold.
  • For each contract, auditor should check Terms and Conditions attached / sent to customer
  • For each contract, auditor should confirm nature of dialogue between the salesperson and the client through discussion with the salesperson.

2.4 ICROA Member Provision of Verification Information to Client

ICROA members shall make reasonably available to the client the actual dates of verification and issuance; any deficiency in the verified volume relative to the volume actually sold to such clients; and, the sources of any replacements.

Example Evidence:

• Email communications between the Affiliate and the client

Auditor Tasks:

• Auditor should obtain evidence presented
• Auditor should document extracts from the material cited by the Affiliate as disclosing the actual dates of verification and issuance; any deficiency in the verified volume relative to the volume actually sold to such clients; and, the sources of any replacements.

2.5 ICROA Member Communications or Any Deficiency in the Verified Volume

Where Appropriate Safeguards have been implemented, ICROA members shall include in the member‟s annual report to the Executive Committee, and shall make reasonably available to the public on the member‟s website at least annually, any deficiency in the verified volume relative to the volume then anticipated to have been verified from the portfolio, as sold across the entire portfolio, and the reservations practices applied to the portfolio.

Example Evidence:

• Affiliate website
• Affiliate Report to ICROA Executive Committee

2.6 ICROA Member Communications to Clients that Purchase Carbon Credits

ICROA members should provide clients that purchase carbon credits with clear and easy to understand communications materials and encourage them to communicate the nature of their carbon credit purchases accurately.

Example Evidence:

• Promotional material
• Affiliate Internal Procedures
• Example communications to clients