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COMPLAINTS AND APPEALS

Contents

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SustainCERT is committed to providing a fair, transparent, and objective procedure for any stakeholder who wishes to make a complaint about its performance as a VVB. It also applies the same principles to allow a Project Representative to appeal a validation or verification decision.

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

Complaint

The SustainCERT complaints procedure process is for all complaints, grievances, and facts discovered after the issuance of the statements.

A complaint would be an expression of dissatisfaction by any person or organisation about SustainCERT as a validation and verification body (VVB), or any other Product/Service we offer (see services). SustainCERT will treat the complaint in the same way as described in this procedure and will investigate impartially. Examples of Complaints are as follows:

SustainCERT VVB performance (for example, inconsistent or inaccurate reviews that are not serious in nature)

Grievance

A Grievance is a special type of Complaint defined as “… a “complaint,” “dispute,” “challenge,” “conflict,” and any similar term that expresses dissatisfaction with the procedure and functioning of SustainCERT’s services.
Examples of Grievances are as follows:

A grievance example might be a lack of clear communication by SustainCERT's VVB team, inconsistencies in verification/validation findings, and inadequate consideration of provided evidence, among other issues.

Appeals

A request by the Project Representative, consultants or clients to SustainCERT for reconsideration of a decision made as part of the services provided, such as Validation, Verification, or any other decision SustainCERT makes in the course of its activities. An appeal can only be made after a final decision has been taken. The types of decisions that SustainCERT make are:

  • Validation/Verification Opinions
  • Corrective actions resulting by a complaint

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

  • negative validation/verification opinions
  • insufficient corrective action resulting from a complaint

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

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 an Appeal Panel consisting of staff members who were not involved in the validation or verification, including the technical review and final decision-making that led to the appeal.

Process for a Complaint

Contact Person: Head of Quality and Compliance - compliance@sustain-cert.com

Upon receiving a Complaint, SustainCERT will:

  • confirm receipt of the email and inform the complainant that their information, along with the subject of the complaint, will remain confidential.
  • within 10 days of confirming receipt, determine if it has sufficient information for evaluating the validity of the complaint to decide on appropriate action or request further information from the Complainant. The criteria for determining the validity of complaints involve assessing whether the complaint is specific, supported by evidence, and relevant to SustainCERT's scope of work.
  • within 20 days of receiving sufficient information:
  1. determine if the Complaint will be processed as a Grievance
  2. provide a contact person during the review of the Complaint
  3. provide details of the staff engaged in reviewing the Complaint, confirming that they are different to those who took the decision; and
  4. 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 the outcome of the investigation with the Complainant (investigation report,progress report etc.)
  • upon informing the complainant, SustainCERT ensures that all complaints, including any actions taken, are tracked and recorded in its Complaints & Appeals tracker.

If the Complainant is nonresponsive for more than 20 days during an investigation into a Complaint, SustainCert reserves the right to close the Complaint.

The Quality & Compliance Team will keep a record of all Complaints and resulting actions to be made available for internal audits and management reviews.

Process for an Appeal

Contact Person: Head of Quality and Compliance - compliance@sustain-cert.com

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 independent appeal panel.

  • Within 10 working days of receiving an Appeal, SustainCERT will form a suitable appeals panel of at least 2 persons, and provide an initial response to the Project Representative determining if the Appeal criteria have been met. This ensures that the submission, investigation, and decision on appeals do not result in any discriminatory action against the appellant. SustainCERT will safeguard the confidentiality of appellants and the subjects of the appeal.
  • 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:
  1. Provide a contact person during the Appeal
  2. Provide details of the staff engaged in reviewing the Appeal, confirming that they are different to those who took the decision
  3. 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. If the appeals panel is meeting, the client representative will receive an invite and may attend this meeting.
  • Upon investigating the appeal, if the findings indicate a non-conformity, appropriate corrections and corrective actions will be taken to address the gaps in the system, particularly if the investigation reveals any system deficiencies
  • Upon conclusion of the Appeal, SustainCERT will share the decision made by the independent appeal panel with the Project Representative (A report includes information or notice of the final decision, such as an Appeal Report, Investigation Report, etc.)
  • Appeals received and the actions taken will be recorded in the Appeal Tracker.

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 the program/ scheme in which SC is recognised under the ISO track (such as Verra, Gold Standard or the Global Carbon Council), or The Supervisory Body of the UNFCCC under the Article 6.4 track.