Project Integrity, Safeguarding
and Speak-Up Policy

Carbon and environmental markets depend on trust. Registration, validation, verification or an active registry status are important controls, but they do not remove the need for independent commercial and ethical due diligence by Kyoto Network.

A 2024 Verra review of the Kasigau Corridor REDD projects recorded four findings and thirteen required actions following allegations concerning sexual offences, failures in reporting mechanisms, negative community impacts and improper employment practices. Verra kept the projects active subject to remedial actions and evidence of implementation. The case demonstrates a critical governance lesson: a project can remain within a standard while still presenting issues that a buyer, intermediary or project partner may decide exceed its own risk appetite.

This policy therefore creates a single framework for:

• screening projects, project developers, counterparties and environmental credits before Kyoto Network becomes involved;
• identifying and escalating integrity concerns during project development and delivery;
• protecting communities, workers and other stakeholders from harm;
• providing confidential and anonymous reporting routes; and
• documenting decisions so that commercial pressure never overrides integrity controls.

This policy applies to all Kyoto Network entities and to everyone acting for or on behalf of Kyoto Network, including employees, directors, contractors, consultants, agents, introducers, country representatives and project-development partners. Contractual partners should be required to comply with equivalent standards where relevant.

It applies across the full lifecycle: project origination, feasibility, land and stakeholder engagement, methodology selection, validation, implementation, monitoring, verification, issuance, credit acquisition, brokerage, marketing, retirement and post-sale claims.

Report any actual, suspected, attempted or concealed issue that could affect project integrity, people, the environment, Kyoto Network, a buyer or the credibility of a credit. Examples include:

• sexual exploitation, abuse, harassment, gender-based violence, safeguarding failures, abuse of children or vulnerable people;
• retaliation, intimidation, threats, coercion or interference with complainants, witnesses, communities, staff or auditors;
• fraud, bribery, kickbacks, conflicts of interest, embezzlement, false invoicing, undisclosed commissions, money laundering, sanctions concerns or suspicious financial flows;
• fabricated, altered, backdated or misleading project data, monitoring records, surveys, GPS records, photographs, stakeholder minutes, signatures, consent records or verification evidence;
• double counting, double issuance, double claiming, unclear ownership, competing rights to credits or uncertainty over the legal right to project reductions or removals;
• land disputes, involuntary displacement, resource-access restrictions, inadequate consent, defects in FPIC or benefit-sharing disputes;
• worker exploitation, unsafe conditions, forced labour, child labour, discriminatory employment practices or contractor abuse;
• material environmental harm, biodiversity damage, pollution, use of prohibited or harmful practices, or impacts inconsistent with project claims;
• credible adverse media, NGO allegations, registry reviews, sanctions, suspensions, holds, regulator inquiries, litigation or law-enforcement interest;
• pressure to ignore, minimise, hide, misclassify or delay disclosure of any of the above.

Kyoto Network operates a zero-tolerance position on bribery and corruption in every form, in both the public and private sector, whether committed directly or through a third party. This standard applies to everyone within scope in section 3 and to any associated person acting on our behalf.

5.1 The legal framework

Kyoto Network is a United Kingdom company and is bound by the Bribery Act 2010, alongside the anti-corruption laws of every country in which we operate. The Act creates four offences: bribing another person, being bribed, bribing a foreign public official, and the corporate offence of failing to prevent bribery by an associated person. A company can be held liable for a bribe paid by an employee, agent, introducer or partner unless it can show it had adequate procedures in place to prevent it. Penalties include unlimited fines and imprisonment. Where our activities reach other jurisdictions, laws with international reach, such as the United States Foreign Corrupt Practices Act, may also apply.

5.2 Facilitation payments

Facilitation payments, meaning small unofficial payments made to secure or speed up a routine action to which we are already entitled, are bribes under the Bribery Act and are prohibited. If such a payment is demanded, refuse and report it to the Integrity Officer. The only exception is a payment made under genuine duress where health or safety is at immediate risk: make the payment, remove yourself from danger, then record and report it at the earliest safe opportunity.

5.3 Gifts and hospitality

Modest, proportionate and transparent business courtesies are acceptable. A gift or item of hospitality is only permitted when it is:

• reasonable in value, infrequent and proportionate to the business relationship;
• given openly and properly recorded, never concealed;
• not cash or a cash equivalent such as vouchers;
• never intended to influence a decision, and never offered or accepted during a live tender, negotiation or approval process.

Anything above the approved threshold, and anything involving a public official, requires prior written approval and an entry in the gifts and hospitality register.

5.4 Political and charitable contributions

Kyoto Network makes no political donations on its behalf without Board approval. Charitable donations, community benefit payments and sponsorships must be genuine, documented, paid to a bona fide organisation rather than an individual, and never used as a disguised route to obtain or retain an advantage.

5.5 Third parties, introducers and agents

Intermediaries are the highest bribery risk in carbon and environmental markets, because the company can be held liable for their conduct. Before engaging any introducer, agent, broker or partner, complete risk-based due diligence, put anti-bribery terms, audit rights and termination rights into the contract, and ensure any commission or success fee is disclosed, proportionate and paid transparently. Treat the following as red flags that require escalation before payment: requests for cash, payment to a third-party or offshore account, unusually large or vaguely described fees, a refusal to accept anti-bribery terms, or a connection between the intermediary and a public official. This standard operates together with Gate 6 of the acceptance procedure.

5.6 Books, records and reporting

All payments must be supported by accurate books and records that fairly reflect the transaction. Off-book accounts, false or misleading invoices, inflated descriptions and payments to unverified recipients are prohibited. Any actual or suspected bribery must be reported without delay through the Speak-Up channels in section 10, and the non-retaliation protection applies in full. A breach of this standard may lead to disciplinary action up to dismissal, termination of a contract or relationship, and referral to the relevant authorities.

No project or credit may be marketed, acquired, represented or contracted by Kyoto Network until the following process has been completed to a level proportionate to the risk. Enhanced due diligence is mandatory for REDD+ and AFOLU, cookstove and household interventions, projects involving land or resource rights, projects in conflict-affected or high-corruption-risk jurisdictions, and any opportunity involving adverse allegations.

Before onboarding and annually thereafter, project developers and material counterparties should provide a signed declaration confirming, to the best of their knowledge after reasonable enquiry, whether any of the following has occurred or is pending:

• registry review, suspension, hold, cancellation or material corrective action;
• allegation or finding involving fraud, bribery, corruption, sexual misconduct, safeguarding, forced labour, child labour, retaliation or serious worker or community harm;
• material land, tenure, consent, FPIC, benefit-sharing or right-to-carbon dispute;
• criminal, civil, regulatory or governmental investigation relevant to the project or project entity;
• material data correction, methodology deviation, over-crediting allegation, reversal, invalidation or competing claim to issued units;
• any circumstance that a reasonable buyer or partner would consider important when deciding whether to work with, finance or market the project.

A false, incomplete or misleading declaration is itself an integrity issue and may be grounds for suspension or termination.

10.1 Who can report

Anyone may report: staff, contractors, project workers, community members, suppliers, buyers, landholders, NGOs, advisers, public officials, auditors, validators and verifiers or members of the public. A reporter does not need contractual privity with Kyoto Network.

10.2 Reporting channels

Kyoto Network should maintain multiple channels so that no single manager can suppress a concern:

• Named contacts: report directly to the Integrity Officer, Sonali, at sonali@kyoto.network, or the Designated Director, Sheraz, at sheraz@kyoto.network.
• Web: a public Report a Concern or Speak Up form at kyoto.network/speakup or equivalent.
• Internal: direct report to the Integrity Officer, Designated Director or Board delegate; line management is optional, not mandatory.
• Project-level: local-language contact number, named community liaison and secure physical reporting option where internet access is limited.
• Independent route: where the concern involves senior management, the Integrity Officer, or where independence is otherwise compromised, the report must be routed to the Board delegate, Lynne Holgate, at mhbc.lh1@gmail.com, or an external adviser.

10.3 What information to provide

• what happened or may happen;
• which project, organisation, location and people are involved;
• when it happened and whether it is ongoing;
• how the reporter became aware of it;
• any documents, photographs, messages, names of witnesses or other evidence;
• whether anyone is currently at risk;
• whether the concern has been raised elsewhere and, if so, what happened;
• preferred contact method and whether confidentiality is requested.

Lack of documentary evidence must not prevent a report. Reporters should not place themselves or others at risk to obtain evidence.

10.4 Triage and response timeframes

These are internal service targets, not limits on legal rights. Project-specific standards, local law or contractual requirements may impose different or shorter periods and must be followed where they provide greater protection.

10.5 Investigation procedure

1. Log the concern with a unique case reference and record the requested confidentiality level.
2. Conduct an immediate conflict check. If the proposed case owner is implicated or conflicted, reassign the matter.
3. Assess immediate safety, retaliation, evidence-preservation and transaction or project-hold needs.
4. Define allegations and issues to be tested; do not prejudge guilt or dismiss a concern because the reporter is anonymous.
5. Preserve relevant records and suspend routine deletion where necessary.
6. Use appropriately qualified independent specialists for serious safeguarding, harassment, legal, forensic, land-rights, financial-crime or technical carbon matters.
7. Interview fairly and separately; protect complainants and witnesses; provide the subject a fair opportunity to respond where appropriate.
8. Document evidence, findings, confidence level, remediation and any unresolved uncertainty.
9. Communicate an appropriate outcome to the reporter where contact is possible, while respecting privacy, legal privilege and the rights of others.
10. Track corrective actions to closure and test that they are working. Closure of an investigation is not closure of remediation.

10.6 Non-retaliation

Retaliation is prohibited. This includes dismissal, demotion, reduced work, threats, harassment, exclusion, withholding benefits, reputational attacks, pressure to withdraw a complaint, interference with witnesses, community reprisals or adverse treatment of someone who supports a reporter. Alleged retaliation is treated as a separate integrity breach and may trigger immediate protective measures.

10.7 External reporting and urgent protection

Nothing in this policy is intended to prevent a person from making a legally protected disclosure, contacting an appropriate regulator, seeking legal advice or reporting suspected criminal conduct to competent authorities. Kyoto Network will obtain jurisdiction-specific legal advice where necessary, particularly for cross-border investigations, safeguarding, data protection, mandatory reporting and employment matters.

Following review, the Integrity Officer will recommend one or more of the following, with Designated Director approval for material cases:

• Proceed or clear with no conditions;
• Proceed subject to documented conditions, enhanced monitoring or independent verification;
• Suspend transaction, project activity, marketing or payments pending remediation;
• Commission independent investigation or technical review;
• Require corrective action, restitution, compensation, retraining, governance change, worker or community protection or redesign of project controls;
• Reject the project or credits or terminate the relationship;
• Notify a registry, verifier, buyer, insurer, funder, regulator, law-enforcement body or other authority where required, contractually appropriate or necessary to protect people or market integrity;
• Review prior transactions and buyer claims if new information could affect credits already marketed or sold.

• All relevant staff and project-development personnel must receive induction training on this policy and annual refresher training.
• Project workers with safeguarding, community, data, finance or verification responsibilities require role-specific training.
• Relevant staff should complete an annual acknowledgement confirming that they understand the policy, will report concerns and have disclosed known conflicts or integrity issues.
• A central case and due-diligence register must record decisions, evidence reviewed, approvals, restrictions and remediation. Access must be restricted based on need-to-know.
• Integrity and investigation records should be retained for at least seven years, or longer where required by law, contract, registry rules, litigation hold or project-crediting requirements.

• Compliance should report at least quarterly on the number and type of concerns, ageing, recurring themes, open corrective actions and any retaliation allegations, without unnecessary disclosure of identities.
• Material integrity incidents, senior-management allegations and systemic control failures should be escalated promptly rather than waiting for routine reporting.
• At least annually, Kyoto Network should test whether project-level grievance channels are actually accessible and trusted, not merely documented.
• This policy should be reviewed after any material incident, significant registry or standard change or control failure.

Any Yes, Unknown or Not evidenced response to a material question requires explanation before approval.

This form can be used internally and as the basis of the public web form. All fields other than the description of the concern should be optional unless required for safe follow-up.

• Create a public page, /speakup or /report-a-concern, linked from the website footer and relevant project websites.
• Allow anonymous submission. Do not require account creation, company email, national ID or telephone number.
• Allow a reporter to choose confidentiality and preferred language or contact method.
• Provide a unique case reference and, where technically feasible, a secure two-way anonymous follow-up method.
• Route submissions to a restricted mailbox or case system accessible to the Integrity Officer and one independent alternate only.
• Do not route reports through the project manager or local partner by default.
• Publish a short non-retaliation statement and explain that a concern does not need to be proven before it is reported.
• Provide local-language and offline channels for community-facing projects, with posters or QR codes and details displayed at project sites or community meetings.
• Maintain a case register showing date received, risk rating, owner, status, actions, escalation, outcome and remediation due dates.
• Test the channel at least quarterly and after any personnel or IT change to ensure reports are received and the alternate route still works.

This policy is a Kyoto Network internal control and should be applied alongside the law, contractual obligations and the current rules of the applicable registry or standard. Key references used in drafting include:

• Verra Review Findings Report, Projects 562 and 612 (2024): verra.org
• Verra VCS Program Details, current program documents and effective dates: verra.org
• Verra VCS Standard, v5.0, stakeholder engagement and ESG safeguards: verra.org
• UK Government, Whistleblowing guidance for employers (2026): gov.uk
• UK Government, Whistleblowing for employees, who to tell and what to expect: gov.uk
• UK Bribery Act 2010, including the corporate offence of failing to prevent bribery: legislation.gov.uk

Legal note: this document is designed as an operational integrity framework, not jurisdiction-specific legal advice. Local legal review should be obtained where mandatory reporting, employment, safeguarding, criminal law, data protection, sanctions or regulatory duties may apply.