Programme Procedures

PROGRAMME & METHODOLOGY DEVELOPMENT

ERS, in collaboration with the Technical Advisory Board, is responsible for developing and revising Programme and Methodology documents. Refer to the Standard Setting and Methodology Development Procedure for more details.



ACTIVE STAKEHOLDER FEEDBACK

To continually improve its processes and applications, a feedback page is made available on the ERS website under the Consultation section. The page features a feedback survey on operational activities, made available annually for one month at the end of every calendar year. 

All submitted feedback will be publicly shared on the webpage and thoroughly reviewed by the ERS Secretariat to inform improvements to the documentation and tools.



ERS GRIEVANCE MECHANISM

  1. Principles

    1. ERS employs the World Bank's definition of grievance and follows the High Carbon Stock Approach Grievance Mechanism. 
    2. The Secretariat manages the Grievance Mechanism. As such, ERS must train Secretariat Agents to uphold its Grievance Mechanism and ensure its effective implementation and usage.
    3. Grievance Issuers. Any Stakeholder who directly or indirectly interacts with ERS can use this Grievance Mechanism. This includes but is not limited to ERS Agents, VVBs, Buyers, Developers, Technical Advisory and Fiduciary Boards members, local communities, and other Third Parties. 
      1. In line with the French law of March 2022 aimed at improving the protection of whistleblowers, grievance Issuers are not required to use internal grievance channels.
      2. ERS Agents can directly voice their concerns to their supervisors unless they suspect the latter of wrongdoing. 
    4. Scope. Stakeholders must use the Grievance Mechanism to report issues related to: 
      1. Non-compliance with any requirement of the Standard and its affiliated documents. Special attention must be paid to:
        • Mistreatment of Stakeholders;
        • Breach of community agreements, such as the benefit-sharing mechanism;
        • Non-observance to the FPIC process, when applicable;
        • Violation of Environmental and Social Safeguards;
        • Fraud;
        • Corruption;
        • Deviation from any information disclosed in the Project Design Document.
      2. Non-compliance with ERS's Anti-Fraud Policy and Code of Ethics and Business Conduct, especially to ERS's provisions regarding conflicts of interest, anticorruption and ​​Anti-Money Laundering, Countering the Financing of Terrorism (AML/CTF).
      3. Non-compliance with ERS's Rules of Procedure.
      4. Information that is missing from the ERS website and/or ERS Registry.
    5. Grievance Types. There are three (3) types of grievance:
      1. Standard Grievance. When a grievance is issued against ERS for not respecting Programme procedures.
      2. Project Grievance. When a grievance is issued against a Developer for not respecting its obligations.
      3. Suspicious-Activity Grievance. When a grievance reports suspects violations of the law or any regulation, regardless of its actor.
    6. Evidence. All grievance claims must be supported by evidence and include the date and time of their occurrence, a detailed description, and their consequences (if any).
    7. Data Protection.
      1. Any personal data collected will be anonymised and must respect GDPR requirements. 
      2. The Issuer’s identity must remain confidential and cannot, under any circumstances, be disclosed publicly unless explicitly authorised. 
    8. Reviewers. All grievance claims are reviewed by the ERS Secretariat. To ensure impartiality:
      1. If a grievance is claimed against an ERS Secretariat Agent, the implicated Agent is excluded from participating in its resolution. 
      2. In cases where the entire Secretariat team is suspected of wrongdoing or if the claim relates to fraudulent Registry operations, ERS must engage a third-party auditor to investigate the claim.
      3. In the event of suspicious-activity grievances, the Director of the Secretariat is responsible for addressing the claim. If the suspicious-activity is reported against ERS or any of its affiliated Agents, a third-party auditor must be engaged to investigate the claim.
    9. Third Party Mandate. In cases where a third party is mandated, the Director of the Secretariat has twenty (20) business days from the day they receive the claim to contract the service.
      1. After contracting, the third party must report directly and exclusively to the Fiduciary Board.

  2. Channels & Accessibility 

    1. Stakeholders may issue their grievances using the following channels, solely dedicated to the Grievance Mechanism: 
      1. grievance@ers.org, 
      2. Phone line +33768862989 (French, English, Spanish, Italian, and German-speaking),
      3. WhatsApp +33768862989.
    2. All communications with the Issuer should be done using an accessible language and channel. 
    3. The Developer must ensure that all Stakeholders:
      1. Are aware of the ERS Grievance Mechanism.
      2. Are informed of its role, scope and functioning.
      3. Can access the mechanism without obstacles due to language, technology, literacy, and geographic location. 
    4. When a grievance is received, ERS must acknowledge its reception.
    5. The Secretariat must respond to grievances within two (2) working days. 

  3. Investigations

    1. Methods. When a grievance is received, the Secretariat Agent must open a dedicated file, assess the situation and determine the required actions and inquiries. The Secretariat Agent determines the investigation method on a case-by-case basis, depending on the content, evidence and potential implications of the grievance.
      1. When a third-party auditor conducts the investigation, they determine the methods to be used. ERS cannot challenge this decision.
    2. Investigation. The Secretariat Agent must thoroughly investigate grievances, assessing all evidence submitted and requesting further evidence from parties when necessary. 
      1. Suspicious-Activity claims follow a specific procedure. Upon reception, the ERS Secretariat Agent must issue a Suspicious-Activity Report (SAR) outlining the nature, timing, parties involved, and potential impacts of said violation. 
        • The Director of the Secretariat must review and approve this document to ensure its completeness and accuracy. 
        • The approved SAR is transmitted by the Director of the Secretariat to the appropriate local, state, or national authorities via a secure channel, ensuring its confidentiality and integrity. 
        • ERS must fully cooperate with the investigation and provide any further evidence or documentation as required.
        • Any ERS Agent's failure to report suspected violations and adhere to this protocol may result in disciplinary action, which may extend to contract termination and legal action. Third parties involved in suspicious activities may also be subjected to legal proceedings and termination of engagement with ERS.
    3. Urgent issues. If a grievance raises an issue that calls for an immediate response, Secretariat Agents may take immediate action without waiting for the end of the investigation. Urgent matters refer to situations where:
      1. There is an immediate threat to the integrity of a person.
      2. The proper functioning of a Project is disrupted, or its success is compromised. If so, ERS may suspend the Project until the grievance is resolved. 
    4. Decision. The Secretariat Agent and the third-party auditor, when applicable, have sixty (60) calendar days to provide an official decision on the grievance via an official Grievance Report containing:
      1. Name of the investigator(s); 
      2. Identification number associated with the grievance;
      3. Content of the grievance;
      4. All relevant evidence considered essential for the final decision;
      5. A written justification of the decision on the grievance, which can lead to: 
        • Closing and archiving the grievance without follow-up. 
        • Disciplinary and/or legal proceedings against the suspected person(s). The grievance is then archived. 
    5. Delay. If ERS or the third-party auditor cannot provide an official decision within sixty (60) calendar days, ERS must notify the Issuer of the delay or necessary extension to resolve the grievance appropriately.
    6. Information. Concerned parties are notified of the decision within one (1) consecutive working day after the decision is taken. In all cases, the Issuer is informed when the grievance is closed and archived.
    7. Appeal. An Issuer has thirty (30) calendar days to appeal to ERS’s or the third-party auditor’s decision via an official email to grievance@ers.org. If the decision is appealed, it is brought to the Executive team's attention, who can decide whether to confirm it or not. 

  4. External Verification

    1. Third-Party Audit. ERS is audited annually by an external and independent auditing firm. ERS must submit to the auditor all grievances from the previous year. If the auditing body disagrees with the decision, another Secretariat Agent must re-evaluate the file, and the auditor must validate the new decision.
    2. Notification. In such a case, the Issuer is notified that the grievance has been reopened and given the expected timeline for its resolution. Once the Secretariat Agent reaches a resolution and validates it with the auditing body, the complainant is notified of the final decision. The auditor cannot reopen a claim twice.

FEE SCHEDULE

  1. Principles

    1. To maintain its independence, ERS:
      1. Cannot charge based on the volume or price of Restoration Units, as doing so would create perverse incentives. 
      2. Cannot directly sell or benefit from the amount of Restoration Units sold. 
      3. Charges a fixed price for its Project Feasibility Review and Project Design Review services, and a price per hectare for its MRV services. This compensation structure ensures that ERS’s revenues do not rely on the issuance of Restoration Units and hence has no incentive to overestimate its volume.

  2. Schedule 

    1. Refer to the ERS website for the detailed Fee Schedule. 

  3. Fee Adjustment Policy

    1. ERS product and service prices are determined based on various factors, including but not limited to costs (data providers, internal certification costs, VVBs) and the competitive landscape.
    2. ERS reserves the right to change the fee structure at its discretion, considering the overall cost structure and business needs.
      1. Any changes to the fee structure must adhere to ERS's Fee Schedule Principles.
    3. Periodic Inflation Adjustments
      1. Prices may be adjusted periodically to reflect inflation. Such adjustments are based on the relevant and globally recognised inflation indices.
      2. ERS will review the inflation rates annually and may apply adjustments accordingly.
    4. Cost-Based Adjustments
      1. Beyond inflation, prices may also be adjusted in response to significant changes in ERS’ input or operational costs. This includes but is not limited to data licenses, labour, regulatory compliance, and other overhead.
    5. Notice
      1. ERS will give Developers advance notice of any fee changes. Adjustments will be communicated through appropriate channels, including email notifications and updates to the Fee Schedule published on the ERS website.
    6. Discounts
      1. ERS reserves the right to issue discounts on its fees at its sole discretion.
      2. ERS has implemented an Independence of the Certification team policy to ensure that its Certification team is not involved in any fee-related discussion. Refer to ERS Governance for more details. 

TRANSPARENCY

  1. ERS must publicly disclose on its website: 
    1. Programme documents;
    2. Methodologies, with their associated guidelines and templates;
    3. Validation and Verification procedures, including:
      1. Validation and Verification documents and templates 
      2. VVBs status
      3. VVBs Performance Reports 
    4. Governance policies, including:
      1. Governance documents 
      2. The composition of the Executive Team 
      3. The composition of all ERS Team Members 
      4. TAB Members 
      5. Fiduciary Board Members
    5. Standard Revisions, including:
      1. Summary of Standard versions 
      2. Public Consultation Documentation
    6. Public Reports, including: 
      1. Grievance Resolution Reports 
      2. Annual ERS Audit Reports 
      3. ERS’s Annual Reports 
  2. Refer to the Registry Procedures for a complete list of documentation disclosed in the ERS Registry.
  3. Documentation requests. The general public can contact ERS to request additional documentation. If not subject to confidentiality, an ERS Secretariat Agent will disclose the requested information. If relevant, public documentation will be updated. 
  4. ERS cannot use a document, process, or report that has not been publicly disclosed unless clearly authorised. 

CONFIDENTIALITY 

Respecting the privacy of ERS’ Stakeholders and Agents is a fundamental value of ERS. As such:

  1. ERS considers “Confidential Information” all information disclosed by a party (“Disclosing Party”) to the other party (“Receiving Party”), whether orally or in writing, that is explicitly designated as confidential or that reasonably should be understood as such, given the nature of the information and the circumstances of disclosure. Confidential Information includes but is not limited to personal, company and financial data, terms and conditions of contracts and agreements, as well as business, technology and technical information.
  2. ERS Agents, Fiduciary Board members and TAB members who may be exposed to confidential, privileged, and/or proprietary information, are not permitted to disclose it unless explicitly authorised.
  3. Unauthorised disclosure of confidential or privileged information is considered a violation of this policy and is subject to disciplinary sanctions.
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