Impartiality Policy

CleanCarbon Assurance Private Limited · CIN U39000PN2026PTC257939 · Version 1.0

Impartiality is the foundation on which a verification body exists. A verification statement has value only if the body issuing it is independent of the party whose data is being verified. CleanCarbon Assurance Private Limited treats impartiality not as a compliance formality but as the core of its product, in accordance with EN ISO/IEC 17029:2019, EN ISO 14065:2021 and the EU CBAM legal framework.

Our commitment

CleanCarbon Assurance commits that it:

• Acts impartially in fact and in appearance, and structures its governance, staffing, remuneration and finances to keep it so.
• Identifies threats to its impartiality on an ongoing basis — including those arising from its relationships, ownership, group, personnel and finances — and eliminates or controls them.
• Declines or halts any engagement where a threat to impartiality cannot be reduced to an acceptable level.
• Permits no commercial, financial or other pressure to compromise a verification opinion.
• Issues the opinion the evidence supports — including an unsatisfactory opinion — without regard to commercial consequence.

The CleanCarbon group relationship

CleanCarbon Assurance is a member of a group whose other entities — principally CleanCarbon.ai — provide CBAM advisory services and carbon-accounting software to industrial clients. We disclose this openly, because we regard it as the most significant potential threat to our impartiality, and we address it structurally rather than by declaration.

The exclusion rule is enforced by mandatory pre-engagement screening of every prospective client against a group-wide client register. An engagement cannot proceed until that screening is recorded and cleared, and the screening record is retained as verification evidence.

Structural separation

• Legal: a separate legal person whose constitutional objects are confined to verification and assurance, and do not permit consultancy.
• Governance: an impartiality committee with a majority of members external to the body and the group, reporting to the Board rather than to management. Management cannot override the committee on impartiality matters.
• People: no person holds a role in both the body and a group advisory entity; personnel declare their client history and are excluded from verifying any client they have served.
• Systems: verification records are held in a tenancy separate from group systems, to which group entities have no access.
• Money: no verifier's remuneration is linked to verification outcomes or to group revenue, and no group service is cross-sold to a verification client.

Raising a concern

Any party who believes our impartiality has been compromised may contact us at nb@cbamassure.com. Concerns relating to impartiality are directed to the Chair of our impartiality committee and are handled independently of the persons involved. We do not take, and prohibit, any retaliatory action against a person raising a concern in good faith.