Establishment file · Impartiality and governance

Impartiality and governance

Independence is a structure, not a statement of intent. These are the bodies, what each may decide, and where each is stopped.

Who may decide what

Body	Power	Limit
Board	Budget, appointments, strategy	Cannot touch case conclusions or working papers
Impartiality committee	Can veto any commercial decision	Chair must not come from a verified industry
Technical lead	Method interpretation, dispute rulings	Appointed by the committee; board cannot dismiss
Verification team	Independent conclusion, qualified opinion, refusal	Sales cannot intervene in findings

Seven controls

No equity in any party we verify, declared annually by every member of staff.
Fixed fees, never a share of the premium, the label revenue or a carbon price.
Sales staff cannot alter findings, scope or conclusions.
The technical reviewer holds a veto on issuance.
No advisory work for a client we verify, and a two-year cooling-off after any prior role.
Conflicts are recorded in a register that the committee reviews each quarter.
Refusal is a documented outcome, not an embarrassment: the file records what was missing.

Appeals

Step	Time limit	Who acts
Client challenges a finding	30 days from the statement	Technical lead
Review by someone who did not work the case	15 working days	Independent reviewer
Panel decision	30 working days	Impartiality committee
Published ruling	on conclusion	Anonymised summary in the register

Records

Working papers, sampling evidence and the technical review are retained for a minimum of seven years, longer where the label is still valid. A verification whose working papers no longer exist cannot be defended, and a body that cannot defend its old work is not a body.

The most common breach of independence is not corruption. It is convenience: helping a friendly client prepare the data, then verifying the help. We do not take those engagements.

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