Impartiality and Conflict of Interest Policy
Summary
ICR maintains an impartiality policy requiring all personnel and affiliates to identify, disclose, and manage actual, potential, or perceived conflicts of interest. This ensures that program decisions are made independently and protects the integrity and credibility of the ICR program
Version
3.1
Date of version
December 2024
Purpose
The purpose of this policy is to ensure that all employees, board members, panel members, and affiliates of the International Carbon Registry (ICR) effectively identify, disclose, and manage any actual, potential, or perceived conflicts of interest in order to protect the integrity, independence, and impartiality of the ICR program and registry.
Objective
ICR aims to ensure that all individuals involved in the governance, administration, and operation of the ICR program are aware of their obligations to disclose any conflicts of interest and comply with this policy. The objective is to ensure that all conflicts of interest are appropriately identified and managed, thereby maintaining trust in the ICR program and safeguarding the credibility of the greenhouse gas (GHG) emission mitigation outcomes recognized by the program.
Policy coverage
This policy applies to all individuals involved in the governance or operation of the ICR program, including:
Board members
Chief Executive Officer (CEO)
Management
Employees and other personnel
Members of advisory or review panels, including the Program Advisory Panel (PAP)
External advisors, contractors, and affiliates acting on behalf of ICR
This policy supplements any conflict of interest obligations arising under employment contracts, service agreements, or contractual arrangements with affiliates or panel members. All personnel are expected to participate fully in conflict of interest disclosure and management.
Policy statement
The International Carbon Registry (ICR) is committed to ensuring impartiality in all activities relating to the operation and administration of the ICR greenhouse gas program and registry. ICR recognizes the importance of maintaining independence from project developers, validation and verification bodies (VVBs), market participants, and other stakeholders whose interests may be affected by program decisions.
ICR therefore maintains a framework through which conflicts of interest are identified, disclosed, and managed in a transparent and effective manner. This framework supports the integrity of the program and ensures that decisions related to project registration, validation and verification oversight, and issuance of instruments are taken objectively and free from undue influence.
To demonstrate effective implementation of this policy, ICR shall not undertake or permit activities that may compromise its impartiality. In particular:
ICR does not provide consultancy services for the design, implementation, or operation of climate projects seeking registration under the ICR program.
ICR does not participate in price negotiation or trading of instruments issued under the program.
ICR personnel shall not perform services for other GHG crediting programs where such roles could compromise their independence in relation to the ICR program.
ICR does not allow consultancy organizations to market or offer project registration services on behalf of ICR.
ICR does not state or imply that project registration is easier, faster, or less expensive when using a specific project developer, consultant, or VVB.
ICR does not provide project-specific consultancy or detailed advice relating to the design, implementation, or operation of climate projects subject to registration.
Validation and verification activities under the ICR program are conducted by independent Validation and Verification Bodies (VVBs), which operate separately from the program administrator.
ICR further ensures that no financial, commercial, administrative, or other form of pressure is applied to ICR personnel or affiliates that could influence the execution of their responsibilities.
ICR is committed to fostering an environment free from fraud, corruption, or the perception of fraud or corruption. Conflicts of interest may arise in the course of program activities; however, such situations do not necessarily present a problem when they are openly disclosed and appropriately managed. All personnel share responsibility for identifying, disclosing, and managing conflicts of interest in accordance with this policy.
Having a conflict of interest does not automatically constitute a breach of this policy. However, failure to disclose a conflict of interest may constitute a breach.
Definition of conflict of interest
A conflict of interest arises when an individual’s duty to act in the best interest of ICR is affected, or could reasonably be perceived to be affected, by personal interests.
Personal interests may be financial or non-financial and may relate to:
family members
close friends
professional associates
organizations with which the individual has a professional or financial relationship.
Conflicts of interest may be actual, potential, or perceived.
An actual conflict of interest occurs when a personal interest directly influences professional responsibilities.
A potential conflict of interest exists where circumstances could reasonably lead to a conflict in the future.
A perceived conflict of interest arises when a reasonable third party could conclude that an individual’s judgment may be influenced by personal interests, regardless of whether such influence actually exists.
Conflicts of interest may arise even without intent to act improperly, and therefore must be identified and managed appropriately.
Identification and disclosure of conflict of interest
All personnel and affiliates have an ongoing responsibility to identify, declare, and manage any potential, perceived, or actual conflicts of interest that may apply to them.
Where personnel believe that a conflict of interest may exist, they must disclose the matter to ICR management and submit a conflict of interest declaration describing the circumstances. Personnel should provide sufficient information to enable management to assess whether a conflict exists and determine appropriate management measures.
In circumstances where the conflict involves senior management, the matter shall be reported to the ICR Board.
Managing conflict of interest
Where ICR determines that a potential, perceived, or actual conflict of interest exists, ICR will develop and implement a conflict of interest management plan.
Personnel are responsible for cooperating with the implementation of any conflict management plan. While ICR will consider any input from the affected individual, the final decision regarding management measures rests with ICR.
Where conflicts involve senior management, the ICR Board will oversee the development and implementation of the conflict management plan.
Conflict of interest management plans may include one or more of the following measures:
Record and disclose
Ensure all relevant information surrounding the conflict of interest is documented and appropriately disclosed.
Restrict
Restrict the individual’s involvement in the relevant matter, limit access to information, or adjust the scope of work.
Recruit and monitor
Appoint an independent third party or reviewer to oversee part or all of the process related to the matter.
Remove
Require the individual to withdraw from participation in the relevant decision or process.
Relinquish
Where feasible, require the individual to relinquish the private interest that is creating the conflict.
Consequences of breaching this policy
Conflicts of interest themselves are not necessarily unethical or contrary to this policy. However, failure to disclose or properly manage a conflict of interest may constitute a breach of this policy.
Depending on the seriousness of the circumstances, a breach may result in disciplinary action, suspension of duties, removal from panel membership, or termination of employment or contractual engagement.
Policy review
This policy may be reviewed and updated periodically to reflect changes in ICR governance arrangements, operational practices, regulatory developments, or recognized best practices.
All employees, board members, and affiliates of the International Carbon Registry (ICR) shall effectively identify, disclose and manage any actual, potential, or perceived conflicts of interest to protect the integrity and impartiality of the ICR and sign an impartiality statement available here.
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