Circular Clean Wave
Circular Clean-Wave.org Ltd

Programme Compliance Framework

Ensuring independence, transparency, and environmental integrity in carbon crediting

Internal Policy Document Version 1.0
Status
Active Policy
Version
1.0 - Current
Alignment
ICROA Code V3.5

Independence & Governance

ICROA Criterion 1 & 2 - Ensuring operational independence and conflict-free governance

Structural Separation

CCW maintains a strict "Chinese Wall" between its Methodology Development Wing and its Registry/Certification Wing to prevent conflicts of interest.

Board Independence

Our Board of Directors maintains no financial interest in hardware or material supply chains of project proponents.

Blind Technical Review

All methodologies undergo independent Technical Committee review before adoption, including GCCM-CWO25EPD.

CoI Policy

Annual Conflict of Interest disclosures required from all employees and external technical advisors.

Registry & Tracking

ICROA Criterion 2 & 5 - Transparent, secure, and permanent ledger infrastructure

Serial Number Integrity

Every NEEDC issued receives a unique, non-fungible serial number with vintage, location, and A-Sign Protocol authentication.

Lock-and-Burn Mechanism

Units cannot be moved once assigned to retirement accounts, eliminating double-counting and double-use risks.

Public Access

Retirement records and "Structural Delta" audit trails are publicly accessible for market transparency.

Digital Ledger Infrastructure

CCW utilizes a proprietary digital registry with native dMRV (Digital Monitoring, Reporting, and Verification) integration, ensuring real-time data integrity and seamless compliance tracking.

Third-Party Validation & Verification

ICROA Criterion 4 - Independent scrutiny by accredited bodies

VVB Accreditation

Only IAF-accredited or GCC/CDM-recognized Validation and Verification Bodies may perform project audits.

Strict accreditation requirements

Technical Reviews

Every VVB report undergoes internal CCW "Quality Gate" checks for GCC-11882 forensic standard compliance.

Multi-layer quality assurance

Amazon Cividate Pilot Project

Total Volume 41,600t
CO₂e COST Verified by LCD Consulting
Audit Status As-Built Verified

https://consultinglcd.com/projects

Strategic Placement Offer

41k-Tonne GCC-Ready Material-Linked Removals (Amazon Cividate)

PRIMARY MARKET

I am pleased to offer a primary-market opportunity to secure a 21,000-tonne CO₂e verified emission reductions tranche from the Amazon Cividate project.

Tranche Highlights

Volume 21,000 Tonnes
Type Verified Emission Reductions
Source Material Optimization

The Due Diligence Protocol - "Clean-Wave" Standard

1

Metric Integrity

  • • Calculated using Impacts A-C (Upfront Carbon)
  • • No "future-guessing" methodologies
  • • Carbon already saved in physical structure
  • • Real-time verification protocols
2

10% Mandatory Correction

  • • Every project includes 10% "Line Loss" deduction
  • • Applied at point of minting
  • • Conservative, bulletproof audit trails
  • • GCC/CORSIA compliance ready
3

Benchmark Alpha

  • • Measured against LETI Band D/E
  • • Industry benchmark compliance

Project Performance Metrics

The Concrete Delta: GGBS/Fly Ash reduced floor & substructure emissions by 25%
Steel Integrity: 80% recycled rebar vs virgin steel saved 2.6M kg CO₂e
Efficiency Premium: 21.5% more efficient than standard build methodology
Registry: GCC institutional-grade "Lock-and-Burn" retirement environment
Securing this tranche on first release

Scale, Ambition & Conditional Endorsement

ICROA Criterion 8 - Demonstrating market leadership pathway and long-term viability

Current Pipeline Capacity

2.8M+

tonnes of EPD-rated carbon removals across the Globe released in 110k tranches

Phase Transition

Concept → Issuance 85%

Successfully transitioning from concept validation to active credit issuance following pilot completion.

Conditional Endorsement Request

Per ICROA Criterion 8.2, CCW satisfies requirements for Conditional Endorsement with successful pilot validation and governance compliance.

✓ Two pilot tranches completed including Amazon forensic baseline

Growth Commitment

Target Threshold 100,000+ tCO₂e
Timeline 18 months (Phase 2)

Environmental & Social Impacts

ICROA Criterion 6 - Ensuring "No Net Harm" and positive SDG contributions

SDG Integration

All projects are benchmarked against the Gold Standard SDG Impact Tool to ensure positive sustainable development outcomes.

SDG 7
Clean Energy
SDG 11
Sustainable Cities
SDG 13
Climate Action

No Net Harm Principle

Comprehensive environmental and social impact assessments ensure all projects contribute positively to local communities and ecosystems.

Baseline Integrity Framework

Industrial Benchmark
High-carbon structural materials
1,100
kg CO₂e/m²

Environmental Additionality

Targeting the "Sunsetting" of high-carbon structural materials in alignment with global Net Zero transition goals and Paris Agreement commitments.

Regional Economic Impact

The 20% Shareholder Rebate - Recycling "Green Alpha" into the Italian Economy

Economic Recycling Model

Our project model ensures that "Green Alpha" generated from carbon credit sales flows directly back into the Italian economy through structured shareholder returns.

20%
of gross proceeds returned to stake/shareholders

Corporate Charter Commitment

Per our corporate charter, 20% of total gross proceeds from carbon unit sales is mandatorily issued as direct rebate to development shareholders, ensuring local economic benefit.

Local Value Chain

Rebate structure prioritizes Italian construction companies, material suppliers, and technical consultants involved in the project development cycle.

National Offset Status & Certification

National Offset Permission

Permitted as a National Offset for Italian entities once the Gold Standard methodology is finalized.

Certification Status

Currently in the 2nd Stage Gold Standard Review with an estimated methodology approval timeline of 6 months.

Strategic positioning for Italian compliance market access

Stakeholder Distribution Framework

Construction Partners
40%
Material Suppliers
35%
Technical Consultants
25%

*Rebate allocation prioritizes Italian-registered entities with demonstrated project contribution

Make Good T&C

1. DEFINITION OF ELIGIBLE ISSUANCE

"Eligible Issuance" shall be defined as the formal verification and inclusion of the 19,000 tCO2e units [+] into the Gold Standard (GS) Impact Registry under Methodology Concept 401_V2.0, or a functionally equivalent CORSIA-aligned registry, within the Performance Window (defined as 12 months from the date of the Forward Purchase Agreement).

2. TRIGGER EVENTS FOR REMEDIATION

A "Make-Good" obligation is triggered if any of the following occur:

Non-Issuance:
The GS Registry formally rejects the methodology for the specific Asset (IT-LOM-CIV-AMZ-01).
Quantity Deficit:
The final verified issuance quantity is lower than the 19,000 tCO2e units purchased.
Lapse of Performance Window:
Failure to achieve registry status within the defined 24-month period.

3. SETTLEMENT MECHANISMS

Upon a Trigger Event, the Seller (Circular Clean-Wave) contractually agrees to settle the deficit via one of the following "Make-Good" paths, at the Buyer's sole discretion:

PATH A: Replacement of Equivalent Value
Delivery of an equal volume (19,000 t) of alternative CORSIA-eligible credits (Phase 1 or 2 compliant) sourced from the Seller's secondary liquidity reserve.
PATH B: Financial Remediation
No refund of the Entry Price (£14.00/t) for all unissued units.
PATH C: Asset Conversion
Conversion of the CWO-FORWARD note into an equity-adjacent stake in the Regional Development Rebate Pool, providing the Buyer with direct exposure to the underlying industrial asset's value.

4. FORENSIC ESCROW & XDC ENFORCEMENT

The XRC-20 Smart Contract (Block: 0x976e...da925) contains a "Pause and Audit" function. In the event of a remediation claim, the forensic data from the Remote Auditor Gateway (RAG)—including the SHA-256 DNA of the structural concrete—serves as the primary evidence for the VVB to arbitrate the delivery status.

© 2026 Circular Clean-Wave.org Ltd. All rights reserved. | Document Version 1.0 | Last Updated: April 2026