Grievance Resolution Policy

1. Purpose and Scope

Teravent Limited (“Teravent” or “the Company”) operates as a carbon credit registry and provides associated standard-setting and market infrastructure services. Teravent is committed to ensuring that all aspects of its operations, including eligibility assessments, lifecycle management of credits, and registry services are conducted with transparency, procedural fairness, and adherence to its published standards and contractual commitments. The purpose of this Grievance Resolution Policy (“Policy”) is to set out a clear, formal, and timely process for addressing grievances related to Teravent’s role as a carbon credit standard and registry.

This Policy applies to any expression of dissatisfaction or concern raised by external stakeholders in relation to Teravent’s procedures, decisions, service delivery, or governance of crediting and registry processes. For the purposes of this Policy, the term “grievance” includes complaints, disputes, challenges, or conflicts regarding Teravent’s actions or omissions as a standard setting body or registry operator.

Grievances addressed under this Policy fall into two broad categories. The first relates to eligibility and crediting. This includes matters concerning standard requirements, the application of protocols, internal evaluation methodologies (including those related to life cycle assessment or quantification of net removals), approval and oversight of validation and verification bodies (VVBs), and Teravent’s approach to transparency and data confidentiality. The second category concerns registry services, including the issuance, transfer, retirement, and other lifecycle transactions associated with carbon credits; the registration and deregistration of registry accounts; and matters relating to fees and payments associated with Teravent’s registry operations.

When Teravent reviews grievances or renders a decision, the reference points for consideration differ based on the category of the grievance. For eligibility and crediting matters, Teravent’s assessment will examine whether the Company acted in accordance with the Teravent Standard, applicable protocols, and relevant policies that were in force at the time. A grievance will be upheld if the Company is found not to have followed its published procedures. For grievances relating to registry services, the assessment will be based on whether Teravent acted in accordance with its contractual obligations toward the complainant. A grievance will be upheld if the Company is found not to have followed the terms contractually agreed.

This Policy does not apply to grievances relating to the performance, impact, or on-the-ground conditions of individual carbon removal projects. Such matters fall under the rules outlined in the Teravent Standard’s Stakeholder Input Process or the procedures administered by the relevant project proponent and associated VVBs.

Teravent may accept grievances submitted anonymously. In such cases, Teravent will review the matter where possible, but may be unable to provide a direct response due to the absence of contact details. Where anonymity is requested or implied, Teravent will protect the identity of the complainant unless legal or regulatory obligations require disclosure.

The Company also reserves the right to file grievances against VVBs, marketplaces, platform partners, or other associated entities where Teravent identifies misconduct, procedural noncompliance, or any behaviour that jeopardizes the integrity of the carbon credits or related services.

2. Procedure

Any complainant wishing to submit a grievance must do so in writing via the dedicated email address provided by Teravent for legal and dispute-handling matters. Submissions should include the complainant’s full contact details, a description of any real or perceived conflicts of interest that may affect the grievance, and a clear, structured narrative explaining the nature of the grievance, the timeframe involved, and the impact perceived. The complainant must reference the specific Teravent principle, requirement, policy, or contractual clause they believe has been violated, and include all supporting evidence available.

The complainant must also include written confirmation that the information provided is accurate, that no false or misleading statements have been made, and that all relevant conflicts of interest have been disclosed. They must further acknowledge that Teravent will review the grievance based on the submitted information, and that any request for supplemental information will be issued at Teravent’s discretion.

Upon receipt, Teravent will conduct an initial review within thirty days to determine whether the grievance falls within the scope of this Policy, is complete, and is eligible for further assessment. External experts may be consulted if the matter requires specialized technical, legal, or scientific input. Following this review, Teravent will inform the complainant whether the grievance is accepted as eligible. If the submission is incomplete or ineligible, Teravent will provide an explanation and guidance on how the grievance might be re-submitted correctly.

Where possible and appropriate, Teravent may attempt to resolve the grievance informally by contacting the complainant and any implicated parties to seek clarification and explore potential resolution paths. If informal resolution is not viable, Teravent will proceed to conduct a full investigation. This investigation will typically be completed within ninety days following the initial review, but Teravent retains the right to extend the timeline where necessary. Should an extension be required, Teravent will inform the complainant and provide an updated timeframe.

Once the investigation is completed, Teravent will issue a written decision to the complainant. If the complainant disagrees with the findings, they may file an appeal by submitting a written request within thirty calendar days after receiving the decision. Appeals must relate strictly to the issues raised in the original grievance; no new evidence or expanded matters may be introduced. Teravent may dismiss the appeal if these requirements are not met.

Appeals will be managed by an independent representative appointed by Teravent, such as a law firm or qualified barrister, who will review the matter objectively and issue a final decision. The costs associated with appointing the independent representative will normally be borne by the complainant, unless Teravent determines that doing so would impose an unreasonable financial burden, particularly for grievances involving Indigenous Peoples and Local Communities (IPLCs). Estimated handling costs will be communicated in advance of appointment.

If the complainant fails to respond to communications from Teravent for a period of more than fifteen days during either the initial review or investigation, Teravent may close the grievance.

The final written decision, whether issued by Teravent or by an independent representative in the case of an appeal, will describe the investigation conducted, the reasons for the decision, and any corrective actions or follow-up measures required. For transparency, Teravent will publish decisions on its website, unless publication would compromise legal, privacy, or regulatory obligations.

3. Confidentiality

Teravent will treat all grievance submissions with strict confidentiality. Information shared through the grievance process will be accessed only by those individuals directly involved in the assessment, investigation, or resolution of the grievance. Confidentiality will be maintained unless disclosure is legally required or necessary to comply with regulatory requests, protect safety, or safeguard the integrity of Teravent’s systems and crediting processes.

4. Record-Keeping and Review

Teravent will maintain a complete record of all grievances, supporting evidence, correspondence, investigative materials, decisions, and corrective actions for an appropriate retention period consistent with legal and regulatory standards.

This Policy will be reviewed annually to ensure alignment with evolving regulatory requirements, market developments, and best practices in grievance and dispute resolution. Updates will be published accordingly.