Communication on Progress

Participant
Published
  • 2012/02/06
Time period
  • January 2011  –  December 2011
Format
  • Stand alone document – Basic COP Template
Differentiation Level
  • This COP qualifies for the Global Compact Active level
Self-assessment
  • Includes a CEO statement of continued support for the UN Global Compact and its ten principles
  • Description of actions or relevant policies related to Human Rights
  • Description of actions or relevant policies related to Labour
  • Description of actions or relevant policies related to Environment
  • Description of actions or relevant policies related to Anti-Corruption
  • Includes a measurement of outcomes
 
  • Statement of continued support by the Chief Executive Officer
  • Statement of the company's chief executive (CEO or equivalent) expressing continued support for the Global Compact and renewing the company's ongoing commitment to the initiative and its principles.

  • 29 January 2012

    To our stakeholders:

    I am pleased to confirm that The CarbonNeutral Company reaffirms its support of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labour, Environment and Anti-Corruption.

    In this annual Communication on Progress, we describe our actions to continually improve the integration of the Global Compact and its principles into our business strategy, culture and daily operations. We also commit to share this information with our stakeholders using our primary channels of communication.

    Sincerely yours,

    Stephen J. Killeen
    Chief Executive Officer

Human Rights
  • Assessment, policy and goals
  • Description of the relevance of human rights for the company (i.e. human rights risk-assessment). Description of policies, public commitments and company goals on Human Rights.

  • The importance of human rights to The CarbonNeutral Company is particularly important when procuring carbon credits from projects around the world. We have developed a proprietary screening and grading process for all projects prior to procuring carbon to ensure we have a full understanding of the environmental, social and economic impacts of their activities. We only procure carbon credits verified under recognised standards that respect internationally proclaimed human rights including dignity, cultural property and uniqueness of indigenous people, and are not complicit in human rights abuses.

    The CarbonNeutral Company adheres to the human rights principles in our policies and practices within an overall corporate code and supply chain and subcontracting arrangements. These apply to employees, suppliers and other business partners. We support the Universal Declaration of Human Rights and recognise it as a common standard of achievement for all peoples and all nations. We have a stringent screening process that we adhere to in order that our partners and suppliers adhere to Global Company principles on Human Rights.
    All of the projects sourced by The CarbonNeutral Company are certified to an internationally recognised standard including:
    The Verified Carbon Standard (VCS)
    The Gold Standard
    Climate Action Reserve (CAR)
    The Kyoto Protocol’s Clean Development Mechanism (CDM)

  • Implementation
  • Description of concrete actions to implement Human Rights policies, address Human Rights risks and respond to Human Rights violations.

  • The primary role of The CarbonNeutral Company is to help our clients to measure their carbon emissions and help to achieve their carbon emission reduction goals. Our company handbook contains all relevant information regarding the key principles by which we operate.

  • Measurement of outcomes
  • Description of how the company monitors and evaluates performance.

  • The CarbonNeutral Company has a list of carbon offset project screening questions which must be completed before a project is contracted. These questions ensure that provisions are being made for the ongoing social well being of employees at the projects as well as healthcare and education.

    There have been no reported cases of human rights abuses for the recent reporting period. Should any incident involving the violation of Human Rights occur, The CarbonNeutral Company would act accordingly to ensure that the correct procedures and disciplines are put in place to both rectify and avoid future breaches of these rights.

Labour
  • Assessment, policy and goals
  • Description of the relevance of labour rights for the company (i.e. labour rights-related risks and opportunities). Description of written policies, public commitments and company goals on labour rights.

  • The CarbonNeutral Company has a detailed handbook that is provided to all 40 employees. The handbook lays out the guiding principles by which we run our business and provides the policies and procedures for all employees to operate from. Any instances that occur that may be seen to violate these principles would be managed accordingly.

    The CarbonNeutral Company respects the principles and rights of International Labour Conventions declaration covering: freedom of association and the effective recognition of the right to collective bargaining, the elimination of forced or compulsory labour, the abolition of child labour and the elimination of discrimination in respect of employment and occupation.
    The CarbonNeutral Company adheres to a strict screening process for its purchase of carbon credits from offset projects around the world. This process assesses labour related risks in the industry, sector and country of operation.

    In addition, for employees, The CarbonNeutral Company employee handbook has specific guidance and principles relating to health and safety and special risks:
    Health and Safety
    The Company will do all in its power to ensure your wellbeing and safety whilst at work. If you become aware of any potential hazard or unsafe working conditions, you should have no hesitation raising them with your manager.
    You are required to take all reasonable steps to safeguard your health and safety, and that of any other person who may be affected by your actions, and to observe at all times published safety and fire rules and procedures.
    Employees at Special Risk
    The Company recognises that some employees may from time to time be at increased risk of injury or ill health resulting from work activities. The Company therefore requires that all employees advise their Line Manager if they become aware of any change in their personal circumstances which could result in their being at increased risk. This could include medical conditions, permanent or temporary disability, taking medication and pregnancy.
    The CarbonNeutral Company is committed to providing a workplace that is free from violence, threats, intimidation, and harassment, in accordance with applicable federal, state and local law.

  • Implementation
  • Description of concrete actions taken by the company to implement labour policies, address labour risks and respond to labour violations.

  • The CarbonNeutral Company has created a list of screening questions which must be addressed before contracting with an offset project supplier. Some of these questions directly address the following:
    Type of labour employment in each category
    Measures in place to ensure fair and equitable pay and working conditions
    Local air quality
    Transport
    Water
    Ongoing maintenance and funding requirements
    Employees are trained to understand and complete valid documentation to support this screening process and escalate any concerns to senior management.
    The CarbonNeutral Company is committed to equal employment opportunity. Accordingly management will ensure that recruitment, selection, training, development and promotion procedures result in no job applicant or employee receiving less favourable treatment on the grounds of race, colour, nationality, ethnic or national origin, disability, trade union membership or non-membership, sex, sexual orientation or marital status, or being a full or part-time worker. The Company’s objective is to ensure that individuals are selected, promoted and otherwise treated solely on the basis of their relevant aptitudes, skills and abilities.
    Company Safety Rules
    • All employees should be aware of and adhere to the Company’s rules and procedures on health and safety
    • All employees must immediately report any unsafe working practices or conditions to their Line Manager, their health and safety representative or to the safety officer
    • Horseplay, practical joking, misuse of equipment or any other acts which might jeopardise the health and safety of any other person are forbidden
    • Employees must not adjust, move or otherwise tamper with any electrical equipment
    • All waste materials must be disposed of carefully in the receptacles provided and in such a way that they do not constitute a hazard to other workers
    • All injuries must be reported to the employee’s Line Manager or to the safety officer
    • Work stations must be kept clean and tidy
    • Walkways and passageways must be kept clear and free from obstructions at all times
    • Trailing cables should not be left in any passageway
    • When lifting an object off the ground, employees should assume a squatting position, keeping the back straight. The load should be lifted by straightening the knees, not the back
    • Employees should not attempt to obtain items from shelves which are beyond their reach. A ladder or stepping stool should be used. Employees should not use chairs or any makeshift device for climbing and should never climb up the shelves themselves

  • Measurement of outcomes
  • Description of how the company monitors and evaluates performance.

  • The CarbonNeutral Company does not have a specific measurement of outcomes but there have been no incidents or violations reported in the last reporting period. Should an incident occur, this would be managed accordingly against our standard day-to-day management practices.

Environment
  • Assessment, policy and goals
  • Description of the relevance of environmental protection for the company (i.e. environmental risks and opportunities). Description of policies, public commitments and company goals on environmental protection.

  • The primary role of our business is to help our clients measure their carbon emissions and build a robust carbon management strategy in order to achieve their carbon emissions goals. In unison with our clients we are actively engaged in addressing climate change. Our aim is to go beyond mere compliance, and to continuously improve our stewardship of the environment and people in our influence.

    In addition to the day to day execution of our business, we use our role and expertise to partner with other climate change experts and to support groups who are leading and developing climate change policy. We believe we are in a unique position to ensure that all businesses understand their environmental impact and to help them lead the way in reducing their carbon emissions.

    As a global company, we operate in compliance with all relevant national, regional and international regulatory requirements. Therefore, we lead by example, work to educate and inform our stakeholders and ensure we monitor and review our own progress towards our environmental goals.

    In 2002 we developed The CarbonNeutral Protocol; the market leading global standard developed by The CarbonNeutral Company, to guarantee the integrity and credibility of clients’ carbon neutral certification and enable them to be certified CarbonNeutral®. It is revised and updated annually to reflect the changing requirements of both science and business. Development of The CarbonNeutral Protocol is assisted by a continual process of review and advice from an Advisory Forum, appointed by The CarbonNeutral Company and representing international carbon management experts from a broad scope of backgrounds including science, economics, business, international policy and sustainable development.

    Corporate Social Responsibility Policy Plan
    This covers three key areas that are material to the way we run and conduct our business and will have the greatest positive impression on our environmental impact:
    1. Building awareness and leading action on climate change
    2. Resource usage and emissions from offices and operations
    3. Transparency and integrity of our business transactions

  • Implementation
  • Description of concrete actions to implement environmental policies, address environmental risks and respond to environmental incidents.

  • The CarbonNeutral Company conducts an annual greenhouse gas assessment that is verified by an independent third party and has a target to reduce these emissions year on year where possible. Any unavoidable emissions are offset using high quality carbon offsets that have been accepted by a third party Designated Operational Entity and validated to a third party standard such as the Verified Carbon Standard. In the execution of our business, we take responsibility for our own impact on the environment. The CarbonNeutral Company is itself a CarbonNeutral® company.

    We have a dedicated internal ‘Green Team’ that ensures the company is actively involved in achieving internal emission reductions. Any key decisions made by this team that mean a change in policy or behaviour is reported to and signed off by senior management. We have a number of initiatives that have been executed that address specific areas such as:
    Waste - audit carried out every quarter by waste management company
    Business travel - employees must calculate distances for each journey so that data for GHG assessment is accurate
    Employee commuting - cycle-to-work scheme offered and encouraged
    Energy consumption – reviewed quarterly

    The CarbonNeutral Company contracts with a wide range of high quality carbon offset project types in various geographical locations, all of which are validated and verified to recognised, market-leading standards, including the Verified Carbon Standard (VCS), The Gold Standard, the Clean Development Mechanism (CDM), the Climate Action Reserve (CAR) and Green-e Climate. These projects are regularly audited by accredited third parties to ensure that they meet all of the quality requirements of the standard; including additionality, accurate quantification, unique ownership, permanence, leakage, sustainability standards and retirement via a publicly accessible registry.

    We also procure carbon offset projects that are certified to additional standards such as the Climate Community and Biodiversity Alliance (CCBA) and Social Carbon. These standards monitor and verify additional benefits of the project, beyond emission reductions.

    In addition, The CarbonNeutral Company has developed a proprietary screening and grading process for all projects prior to procuring carbon from them to ensure we have a full understanding of the environmental, social and economic impacts of their activities.

    We also have an Advisory Forum which is chaired by The CarbonNeutral Company’s Chief Scientific Advisor, Professor John Murlis. Its membership consists of international carbon management experts from a broad scope of backgrounds including science, economics, business, international policy and sustainable development. Two places within the Advisory Forum are reserved for clients of The CarbonNeutral Company to ensure the company’s client base is actively involved in the development of its business activities.

    The objective of the Advisory Forum is to review, challenge and advise The CarbonNeutral Company on its work in climate change, and to provide guidance on the strategic, scientific and technical aspects of the Company’s activities. In addition to regularly reviewing The CarbonNeutral Protocol to ensure it is aligned with best practice in carbon emissions reductions, members of the Forum conduct site visits to some of our projects to personally verify the quality, and advise the company on ways in which it can continue to pioneer and innovate in the industry.

  • Measurement of outcomes
  • Description of how the company monitors and evaluates environmental performance.

  • The CarbonNeutral Company achieved a 27% reduction in its annual carbon footprint measurement from 2009 to 2010. We aim to achieve a further reduction when we calculate our 2011 footprint this month and promote further behaviour change initiatives throughout 2012.

    Since we began in 1997 we have contracted more than eight million tonnes of carbon from 246 projects on six continents. We only procure carbon credits certified under specific standards that have been determined to be real, measurable, permanent, additional, independently verified and unique, and are therefore guaranteed to offset a subject’s GHG emissions.

    The integrity of The CarbonNeutral Company’s carbon transactions are executed to the highest industry standards. Since 2009, all carbon we procure is managed through third party registries including the Voluntary Carbon Standard (VCS) and Gold Standard registries hosted by APX and the Climate Action Reserve. We use one of the world’s largest independent auditing and accounting firms to check our carbon procurement, registration and retirement processes and controls to ensure our compliance with the International Carbon Reduction and Offset Alliance (ICROA) quality code. The CarbonNeutral Company is a founding member of the International Carbon Reduction and Offset Alliance (ICROA), the self-regulatory body established to ensure rigorous standards for the carbon management industry and to help businesses achieve significant emission reductions.

Anti-Corruption
  • Assessment, policy and goals
  • Description of the relevance of anti-corruption for the company (i.e. anti-corruption risk-assessment). Description of policies, public commitments and company goals on anti-corruption.

  • The CarbonNeutral Company has a detailed handbook that is provided to all 40 employees. The handbook contains rules, policies and procedures that must be adhered to. Any breaches may result in disciplinary action.

  • Implementation
  • Description of concrete actions to implement anti-corruption policies, address anti-corruption risks and respond to incidents.

  • Anti-bribery policy

    APPLICABILITY
    This policy:
     applies to all personnel, namely, directors, officers and employees of The CarbonNeutral Company and
    its other companies, as well as affiliates doing business in the United Kingdom and/or third parties
    acting on behalf of any of those companies from time to time;
     relates to business activities with any individuals, private commercial organisations, national or foreign
    governmental or public sector bodies or other (quasi‐) international or supranational bodies;
     applies in addition to the Company’s other operations around the world.

    INTRODUCTION
    It is The CarbonNeutral Company’s worldwide policy to comply with all applicable anti‐corruption and other
    laws wherever The CarbonNeutral Company operates, and to reflect all transactions fully and accurately on
    the company’s books and records. Accordingly, The CarbonNeutral Company will not offer, give or receive
    any bribes, corrupt payments or other inducements of any kind whether directly or indirectly through any
    third party. The CarbonNeutral Company needs to be satisfied that its suppliers, sales channels, agents,
    representatives, consultants and other relevant business partners will achieve and maintain equivalent
    standards of legal compliance and integrity and themselves take adequate measures to prevent bribery and
    corruption whenever and wherever they operate on The CarbonNeutral Company’s behalf.

    THE NATURE OF BRIBERY
    Bribery take many forms, including the provision directly or indirectly of cash, anything of value or any
    monetary, financial or other advantage to someone in order to gain business advantage or induce them to
    do or not do something improperly or to reward them for improper performance after the event. It
    involves influencing officials in the exercise of their functions. There is no limit in value of a bribe. It is
    irrelevant that the recipient of a bribe is not the person whose performance is affected.

    HIGHER RISK AREAS
    Certain higher risk areas of activity require a greater level of management scrutiny and oversight. The
    following are higher risk areas determined by The CarbonNeutral Company to need prior management
    approval:
     any payments or benefits for national or foreign government or public sector officials;
     business involving the use of agents, consultants or intermediaries;
     business relationships involving payments or other advantages to third parties;
     payment for hospitality, promotional offers, travel, accommodation, expenses or gifts exceeding The
    CarbonNeutral Company’s published limits;
     making political or charitable donations or contributions of any kind;
     making small facilitating payments to obtain routine official actions (even though legally acceptable in
    some countries);
     any situation where there is a history of corruption;
     proposed off‐invoice or over‐invoicing transactions; and
     situations where a party is reluctant to take The CarbonNeutral Company’s requested action to prevent
    corruption.

    COMPLIANCE
    All Company personnel will:
     not by act or omission, authorise, offer, promise or give a bribe, or request, agree to, or accept a bribe
    or create the impression that any of those things will or may occur;
     follow the mandated Company procedures designed to prevent bribery in regard to risk assessment,
    due diligence, approval, reporting and documenting transactions;
     promptly report to the Company any known or suspected instances of bribery by the Company’s
    personnel or those doing business on the Company’s behalf and cooperate with any investigation into
    the matter. Reporting a possible impropriety must never serve as a basis for retaliation against the
    Company’s personnel reporting the matter; and
     take steps to require that any third party engaged on the Company’s behalf conducts The
    CarbonNeutral Company’s business under equivalent standards of bribery prevention and to the
    highest ethical and professional standards.

  • Measurement of outcomes
  • Description of how the company monitors and evaluates anti-corruption performance.

  • The CarbonNeutral Company adheres to an anti-bribery policy which is attached. We also have a number of stringent processes which are fulfilled when sourcing carbon offset projects. Countries where there may be the potential risk of corruption we endeavour to procure carbon offset projects that have additional standard certification that go beyond carbon emission reductions and bring additional benefits to the local community for example the Gold Standard, Climate Community and Biodiversity (CCB) and Social Carbon. These additional standards have robust screening and validation processes that we trust and support.