Carbon Market Watch files a complaint about Verra’s “review” of the Southern Cardamom REDD project in Cambodia

The complaint has been submitted to the Integrity Council for Voluntary Carbon Market.

Carbon Market Watch has filed a complaint with the Integrity Council for the Voluntary Carbon Market about the way Verra carried out its “review” of the Southern Cardamom REDD project in Cambodia following Human Rights Watch’s reports of human rights abuses involving the project.

Carbon Market Watch argues that the “review” was not impartial, in breach of ICVCM’s requirements.

ICVCM’s Core Carbon Principle label is supposed to provide “a credible, rigorous, and readily accessible means of identifying high-quality carbon credits”.

The Assessment Framework details the criteria that must be met for carbon-crediting programmes and categories of carbon credits to use the Core Carbon Principle label.

Verra, the US-based carbon certification company, is approved by the ICVCM. Verra is therefore required to have a grievance mechanism that complies with ICVCM’s Core Carbon Principles.

Assessment Framework Criterion 1.2 is titled “Public engagement, consultation and grievances”. It includes the requirement that “carbon-crediting programmes shall have a process for”:

addressing grievances, for which the process shall be clear and transparent, ensure impartiality and where appropriate, confidentiality, in the filing and resolution of grievances. . . .

Human Rights Watch investigation

Human Rights Watch carried out a two-year investigation into the Southern Cardamom REDD project in Cambodia. In June 2023, following a letter from Human Rights Watch, Verra put the project on hold.

In February 2024, Human Rights Watch published its report on the project. The report documents human rights violations against Indigenous Chong communities living in and near the project area. Several Chong villagers were forcibly evicted from their customary farmland and harassed by rangers for collecting forest products.

One Chong man told Human Rights Watch that,

“When they first rushed into the camp they hit me in the back with their gun. . . . I told them, ‘Brother, I am not going to run away.’ They destroyed everything I had with me — even the clothes on my back. All I was left with was my underwear.”

He was detained for two days. He was handcuffed the whole time and given no food or water.

In September 2024, after carrying out its review, Verra reinstated the Southern Cardamom REDD project.

In its complaint to ICVCM, Carbon Market Watch writes that,

To conduct its review, Verra asked several Validation/Verification Bodies (VVBs) – SCS Global Services, Aster Global and Aenor — all of whom had previously provided validation and / or verification services for the project — to review their earlier work in light of HRW’s allegations. Verra subsequently examined their respective reports on the matter. Verra also asked Wildlife Alliance to provide information. Therefore, all parties in which Verra engaged to review HRW’s allegations were involved in the evaluation of the project at an earlier stage, and would have suffered (financially and/or reputationally) from a conclusion that would confirm HRW’s allegations. Verra staff did not travel to Cambodia to conduct fact-finding.

On paper, Verra appears to comply with ICVCM’s requirements on grievances. Its Grievance Redress Policy, which was updated in September 2024, states that,

Verra is committed to the timely, effective, and impartial resolution of grievances (i.e., complaints and appeals) in relation to all programs managed by Verra.

But the way Verra dealt with Human Rights Watch’s investigation reveals that in practice Verra’s grievance process is not impartial.

Verra’s review of Southern Cardamom REDD project “lacked impartiality”

Carbon Market Watch outlines two important ways that Verra’s review “lacked impartiality”:

• Verra did not employ an impartial third party. SCS Global Services, Aster Global, and Aenor are the auditors that the project developer Wildlife Alliance hired to produce validation and/or verification reports for the project. Yet Verra relied on these companies to respond to Human Rights Watch’s findings of human rights abuses. This is a blatant conflict of interest. It is clearly in the auditors’ reputational and financial interests not to uncover problems in a project that they have already approved.

  The only other organisation that Verra relied on was Wildlife Alliance.

• Verra itself is not an impartial party. Verra did not investigate Human Rights Watch’s allegations, by travelling to the project area, for example. However, as Carbon Market Watch notes, Verra “had complete discretion over the outcome of the investigations”. Verra issued recommendations and remedial actions after the auditors and Wildlife Alliance responded to Human Rights Watch’s report. The recommendations focus on improvements in future and internal changes for Wildlife Alliance.

  “Verra’s position is not impartial,” Carbon Market Watch writes in its complaint.

  “Verra approved the project in the past and has since issued millions of credits. It therefore faces a reputational risk if it was to confirm that the project infringed on human rights, in addition to a financial risk from (1) forgone revenues from future issuance of credits and (2) implications for its buffer pool if it had to tap into it to make up for wrongfully issued credits.”