Anti-Bribery and Corruption Policy

• The Open Carbon Protocol adheres to the U.S. Foreign Corrupt Practices Act (FCPA) and has robust anti-bribery and corruption policies to mitigate potential issues within our business structure.

• This is relevant as policy changes have the potential to impact the carbon markets in years to come.

Scope and Policy

• Our anti-bribery and corruption policy applies to all employees, contractors (including expert panelists, VVBs, and dMRV providers), and advisors to the Open Carbon Protocol.

• The Open Carbon Protocol prohibits bribery in any form, whether indirect or direct, in exchange for gifts to receive a business advantage in all business dealings worldwide. We are committed to transparency, integrity, and fair business practices.

• Common sense should be used when deciding whether or not gifts are appropriate. Gifts are defined as anything of value to the receiver, such as merchandise, cash, tickets to events, travel, etc. If there is a question as to whether a gift is acceptable, it should be reported to and vetted by the Open Carbon Protocol Administration ([e-mail]). All suspicious activity will be reported to the Board, who will discern necessary next steps.

Mitigation and Training

• If any suspicious activity is detected, the case will be investigated, and if found guilty, the person will be removed from the OCP permanently, and their account will be deactivated. If an expert panelist is found guilty of bribery, they will be removed from the panel altogether, and a thorough investigation will be conducted to ensure no other panelists are involved. The project developer's proposal will be suspended.

• In the event there is reason to suspect board members are guilty of corruption or bribery, advisors and board members will be removed from their positions if it is known their decisions were influenced by the use of a bribe.

• In order to ensure problematic practices are not taking place, the Open Carbon Protocol will implement measures to assess and reduce risk. The Open Carbon Protocol will conduct risk-based due diligence on business partners, projects, and transactions to identify and mitigate potential bribery. We commit to recording all financial transactions accurately in the OCP's records and books. All staff undergo anti-bribery and money laundering training to ensure everyone understands what to look out for and how to manage instances if they should come up. This will include case studies of bribery as they pertain to carbon credits and the OCP's procedures for reporting such instances.

• Any interactions with government officials must adhere to the U.S. FCPA and adhere to strict ethical standards. The Foreign Corrupt Practices Act (FCPA) makes it unlawful for a person or company to offer, pay, or promise to pay for something of value to a foreign official in exchange for obtaining or retaining business. "Foreign official" is anyone acting on behalf of a government. A person or company may refer to anyone with authority acting on behalf of a company.