Governance
Impartiality Policy
Carbon Verification Limited’s formal commitment to impartiality in accordance with ISO/IEC 17029:2019. This policy governs all verification activities conducted by the organisation.
Policy Statement
Carbon Verification Limited is an independent verification body providing third-party verification of organisational greenhouse gas inventories to ISO 14064‑3. Impartiality is the foundation upon which the credibility and value of our verification opinions rest.
This policy sets out our commitment to impartiality and the structural, operational and procedural safeguards through which that commitment is maintained. It applies to all personnel involved in verification activities, including directors, employees, contracted auditors, technical reviewers and committee members.
This policy is reviewed annually by the directors of Carbon Verification Limited as part of the management review process required by ISO/IEC 17029 Clause 11.2.
Our Commitment
Carbon Verification Limited commits to the following:
We understand that impartiality is essential to the integrity of verification and to the confidence of all parties who rely on our verification statements — including clients, regulators, investors, procurement bodies and the public.
We will identify, evaluate and manage all threats to impartiality, whether real or perceived, and will take action to eliminate or minimise their effect on our verification activities.
We will not allow commercial, financial or other pressures to compromise the impartiality of our verification opinions.
We will ensure that all verification decisions are based on objective evidence obtained through our verification process and are not influenced by other interests or parties.
Identification and Management of Threats
We continuously monitor our activities, relationships and personnel to identify threats to impartiality. We recognise four categories of threat as defined by ISO/IEC 17029:
Self-interest — We operate fixed-fee engagements. Our fees are not contingent on the outcome of verification. No financial incentive exists to deliver a favourable opinion.
Self-review — We do not provide consultancy, advisory services, or any form of assistance in preparing GHG inventories. We do not verify claims that we played any role in establishing.
Familiarity — We apply structured verification procedures and require independent technical review of all verification conclusions. Long-standing client relationships are monitored for familiarity risk.
Intimidation — Our personnel are supported in reporting findings honestly. Verification opinions are determined by evidence and the requirements of the standard. No client pressure, commercial consideration, or internal management direction may override a finding of fact.
Structural Safeguards
Separation of execution, review and decision. In accordance with ISO/IEC 17029 Clause 5.3.7, verification review and decision-making are performed by personnel who were not involved in the verification execution. This ensures that no individual who conducts the audit has sole authority over the verification opinion.
Prohibition on consultancy. In accordance with Clause 5.3.9, we do not offer or provide both consultancy and verification for the same claim from the same client. In accordance with Clause 5.3.10, where a relationship between a consultancy provider and our verification body could pose an unacceptable threat, we decline the engagement.
No linked marketing. In accordance with Clause 5.3.11, our verification activities are not marketed or offered as linked with the activities of any organisation that provides consultancy. We do not state or imply that verification would be simpler, easier, faster or less expensive if a specified consultancy were used, and we take action if any consultancy organisation makes such claims in relation to our services.
No undisclosed commercial interests. We do not receive commissions from, hold equity in, or maintain referral arrangements with carbon accounting software providers, emissions reduction consultancies, carbon offset suppliers, or any other organisation whose commercial interests could conflict with our verification independence.
Personnel declarations. All personnel involved in verification activities are required to declare any prior or present association — on their own part or on the part of related persons or organisations — with any client of Carbon Verification Limited, and to reveal any situation that could present a perceived or actual conflict of interest.
Governance and Oversight
Impartiality is a standing agenda item in the annual management review conducted by the directors of Carbon Verification Limited. The review considers the effectiveness of the safeguards described in this policy, any threats identified during the preceding period, the actions taken to manage those threats, and any changes in the operating environment that could give rise to new risks.
The directors accept personal responsibility for the impartiality of all verification activities conducted by the organisation.
Raising Concerns About Impartiality
Any party who has concerns about the impartiality of a verification engagement conducted by Carbon Verification Limited — whether a client, an interested party, a member of the public, or a regulatory authority — is encouraged to raise those concerns through our formal complaints procedure.
All complaints relating to impartiality are investigated by personnel who were not involved in the engagement in question and are reported to the directors as part of the management review process.
Document reference: CVL-POL-IMP-001
Version: 7.3
Effective date: 1st April 2026
Review date: 31st March 2027
Approved by: Glenn Wilkinson, Technical Director, Carbon Verification Limited