Complaints and Appeals

SustainCERT is committed to providing a fair, transparent, and objective procedure for any stakeholder who wishes to make a Complaint about its performance, a VVB’s performance, or register any suspected non-compliance of a project with Gold Standard rules. It also provides the same principles to allow a Project Representative to Appeal a certification decision.

The following definitions and guide is designed to help stakeholders direct their enquiry.

Complaint

A Complaint is defined as an expression of dissatisfaction by any person or organisation about SustainCERT and its performance as a certification body (acting on behalf of Gold Standard (GS)) or as a validation and verification body (VVB).

When  acting on behalf of GS, a complaint may also be made to SustainCERT about other VVB performance, which SustainCERT will investigate and report the outcome to Gold Standard. Gold Standard are solely responsible for the approval, suspension, or cancellation of a VVB’s approval status. 

Please note, any expression of dissatisfaction with Gold Standard procedures and functioning, should be directed to the Gold Standard. Please refer to this procedure for further details.

Examples of Complaints are as follows:

  • SustainCERT certification body performance (for example, inconsistent or inaccurate reviews that are not serious in nature)
  • SustainCERT VVB performance (for example, inconsistent or inaccurate reviews that are not serious in nature)
  • Any other GS Validation and Verification Body (VVB) performance (for example, inaccurate opinions, unethical behaviour)

Grievance

A Grievance is a special type of Complaint defined by GS as “… a “complaint,” “dispute,” “challenge,” “conflict,” and any similar term that expresses dissatisfaction with the Gold Standard procedure and functioning, including entities mentioned in 1.1.1…” of the GS Grievance Procedure.

Examples of Grievances are as follows:

a project reported it had conducted a Gold Standard stakeholder consultation, but is accused of failing to actually conduct one (which would be a non-compliance with Gold Standard rules)
Complaints can be made by sending an email to compliance@sustain-cert.com and will be managed by the Compliance Team.

If the Complaint is regarding non-compliance of a project with Gold Standard rules, then it must be clearly marked as a Grievance.

Appeals

SustainCERT is committed to providing a confidential, fair, and transparent opportunity for Project Representatives to Appeal their decisions.  To ensure objectivity, Appeals are handled by different staff than those who took the decision resulting in an Appeal.

An Appeal is defined as a request by the Project Representative to SustainCERT for a reconsideration of their decision.

An appeal can only be made after a final certification decision has been taken. The types of decisions that SustainCERT make are:

  • Validation/Verification Opinions
  • GS Eligibility at Preliminary Review[1]
  • GS Design Certification/Renewal
  • GS Performance Certification
  • GS Design Change Reviews

Appeals can only be made by a Project Representative against the following:

  • negative validation/verification opinions
  • decisions to reject or decertify OR
  • alleged mistakes in decisions made by SustainCERT that are material and/or serious in nature (defined as greater than 10% emission reductions, or an error that causes significant harm[2] to a project)

The above criteria must be met in order for an Appeal to be investigated by SustainCERT.

To ensure an efficient process, Appeals make use of a template form that provides:

  • a space for the Project Representative to show how they meet the criteria for an Appeal (to ensure that Appeals are reserved for final, material and/or serious decisions made by sustainCERT)
  • a background to the project and the decision or opinion which is being appealed
  • an opportunity to communicate any mitigating circumstances for consideration

Process for a Complaint

Upon receiving a Complaint, SustainCERT will

  • Confirm receipt of the email.
  • Within 10 days of confirming receipt, determine if it has sufficient information to decide on appropriate action or request further information from the Complainant.
  • Within 20 days of receiving sufficient information:determine if the Complaint will be processed as a Grievance and inform Gold Standard
  • provide a contact person during the review of the Complaint
  • provide details of the staff engaged in reviewing the Complaint, confirming that they are different to those who took the decision; and
  • determine the indicative timelines and steps involved in reviewing the Complaint
  • Review the Complaint according to the indicative timeline and, in case of delay, promptly inform the Complainant.
  • Upon conclusion of a Complaint, take any necessary corrective actions and share these with the Complainant

If the Complainant is non-responsive for more than 20 days during an investigation into a Complaint, SustainCERT reserves the right to close the Complaint.

SustainCERT will keep a record of all Complaints and resulting actions to be made available for internal audits and management reviews.

Process for an Appeal

To appeal a decision, the Project Representative must fill out an Appeals form and send to compliance@sustain-cert.com. Appeals will be handled by the Compliance Team.

  • Within 10 working days of receiving an Appeal, SustainCERT will provide an initial response to the Project Representative determining if the Appeal criteria have been met.
  • If the Appeal criteria are deemed to have not been met, an explanation will be provided to the Project Representative why the Appeal is not being progressed (SustainCERT may provide an additional opportunity to supply for further information if the criteria could be met). The decision on whether to progress an Appeal is final.
  • If/when criteria have been met, SustainCERT will start the Appeal and:Provide a contact person during the Appeal
  • Provide details of the staff engaged in reviewing the Appeal, confirming that they are different to those who took the decision
  • Provide an outline of the proposed actions and an indicative timeline of no more than 1 month from the date the Appeal starts. If delays are expected, these will be communicated in advance.

Upon conclusion of the Appeal, SustainCERT will share the decision with the Project Representative.

In cases where the Project Representative is not satisfied with the Appeal decision, SustainCERT will inform the Project Representative that it has the option of making a complaint to Gold Standard / Verra or any other GHG scheme in which SC is recognized.

[1] Preliminary Review is not considered a certification decision unless SustainCERT decide that a project is ineligible and do not List the project – a project has the right to appeal this decision.

[2] Any claim of financial non-viability/project endangerment as a result of a SustainCERT decision will need to show a before and after scenario and provide objectively verifiable evidence in support of the claim.