Comply Direct Ltd.
PAS 2060: Specification for the
demonstration of carbon neutrality
Qualifying Explanatory Statement in
support of PAS 2060 selfcertification
May 2015
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Contents
Section
Page
Introduction
3
Illustration of Comply Direct’s PAS 2060
Baseline, Achievement and Commitment
periods
4
Declaration of achievement of carbon
neutrality
5
Emissions
6-7
Appendix A: Methodology
8
Appendix B: Carbon Management Plan
9
Appendix C: Carbon offset strategy
10-11
PAS 2060 Checklist
12-13
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Introduction
PAS 2060 Information Requirement
Information as it relates to Comply
Direct
Entity making the PAS 2060 declaration
Comply Direct Ltd.
Subject of PAS 2060 declaration
The offices, staff and business activities
of Comply Direct in the UK
Description of Organisation
Comply Direct is the UK’s fastest growing
packaging compliance scheme, who also
provide WEEE and Batteries compliance
in addition to waste management, energy
and carbon management services.
Rationale for selection of the subject
The scope and subject of this
PAS2060 includes all emissions based
on the operational control principle
defined in the WBCSD / WRI GHG
Protocol – Corporate Standard.
Type of certification undertaken
Self-certification
Baseline Period for PAS 2060
programme
1st December 2012 – 30th November
2013
Achievement Period (Current)
1st December 2013 – 30th November
2014
Commitment Period
1st December 2014 – 30th November
2015
This qualifying statement contains information providing evidence that Comply Direct Ltd
have demonstrated carbon neutrality. All information hereafter is believed to be correct
at the time of publishing. Should any change in circumstance occur that affects the
validity of a carbon neutrality claim by Comply Direct, this document will be updated
accordingly.
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Illustration of Comply Direct PAS 2060 Baseline, Achievement and Commitment Periods
Baseline Period
- 01/12/12 30/11/13
Acheivement
Period (AP1) 01/12/13 30/11/14
Commitment
Period (AP2) 01/12/14 30/11/15
This diagram illustrates the baseline, achievement and commitment periods for demonstrating carbon neutrality in line with the PAS 2060
method. Comply Direct will fully offset all carbon emissions and produce a carbon offset strategy and carbon management plan in order
to demonstrate carbon neutrality, and commit to carbon emissions reductions relative to the baseline period in subsequent commitment
periods.
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Declaration of achievement of carbon neutrality
PAS 2060 Information Requirement
Information as it relates to Comply
Direct
State the period during which the entity
is demonstrating achievement of carbon
neutrality of the subject
1st December 2013 – 30th November 2014
Carbon Footprint of the subject for the
period stated above
AP1: 23.961 tCO2e
AP2: 29.303 tCO2e
Which method, as defined by PAS 2060,
has been followed to achieve carbon
neutrality?
Method 1 – Demonstrating carbon
neutrality
How have the reductions in GHG
emissions during this period been
achieved?
Carbon Offsetting and implementing a
Carbon Management Plan. Achievement of
ISO 14001 accreditation
Location of GHG emissions report
supporting this claim
Page 2-7: Carbon Emissions
Location of the details describing
internal reductions during the period
Page 8 – Carbon Management Plan
Location of the details describing the
carbon offsets
Page 9 – Carbon Offset Strategy
UK economic growth rate over the
application period
Individuals responsible for provision of
data necessary for demonstrating
carbon neutrality of the entity
Senior representative responsible for
the declaration of carbon neutrality for
the entity
2.8%
James Dobing
Gareth Roberts
Signature
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Scope 1 CO2e Emissions
Scope 1 Emissions
Heating
Total Emissions
tCO2e
1.166
1.166
The table above states the total carbon emissions (CO2e) for Scope 1. Comply Direct
contribute only to Scope 1 emissions through heating oil using an onsite boiler. The
emissions are classified as Scope 1 because Comply Direct has direct control over the
import and burning of the fuel for the purposes of heating.
Scope 2 CO2 Emissions
Summary
Scope 2 Emissions
tCO2e
Electricity
5.407
Total Emissions
5.407
The graph and table above show total carbon emissions (CO2e) calculated for Scope
2 (indirect) emissions. The above are classified as Scope 2 emissions due to their
categorisation as imported consumption of purchased electricity, as opposed to
direct (Scope 1) emissions.
Scope 3 CO2 Emissions
Water Supply
Water Treatment
Business Travel
61%
Employee Commuting
Business Travel
Waste
Employee
Commuting
36%
Waste
0%
Water Supply
Water 1%
Treatment
2%
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Scope 3 Emissions
tCO2e
Water Supply
0.178
Water Treatment
0.35
Employee Commuting
8.184
Business Travel
13.94
Waste
0.078
Total Scope 3 Emissions
22.730
Summary
The graph and table above show all Scope 3 emissions calculated. The above are classified
as Scope 3 emissions due to their categorisation as all other indirect emissions that are not
imported heat or electricity, for example commuting, business travel, waste and water.
Total Emissions
Scope 1 Emissions
5%
Scope 2
Emissions
23%
Scope 3 Emissions
72%
Scope 1 Emissions
Scope 2 Emissions
Scope 3 Emissions
Total Carbon Emissions (tCO2e)
1.166
5.407
22.730
29.303
The total carbon emissions for Comply Direct Ltd. for the reporting period 1st December 2013
– 30th November 2014 is 29.303 tCO2e. This is the sum of all emissions as a result of the
business activities – direct and indirect – of Comply Direct Ltd. The quantified footprint
covers is as accurate as is reasonably possible, however some emissions may have not
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been captured. Comply Direct is not liable for the use of the above figures by any other
party. An evidence pack exists that provides a basis for any calculations in this report.
Business mileage has increased relative to AP1, this is likely due to increased mileage as a
result of carbon consultancy and a large number of onsite audits conducted during AP2.
Appendix A
Methodology
All calculations were made in accordance with the Greenhouse Gas (GHG) Protocol,
categorising emissions as Scope 1, 2 and 3. Emissions are calculated from the DEFRA 2014
Conversion Factors for Company Reporting, which convert all emissions to CO2e (Carbon
dioxide equivalent). These methods are widely recognised and recommended for the
reporting of GHG emissions for PAS 2060.
Key Assumptions
Imported Heating – Monthly energy bills were used. This unit data was converted into litres
of burning oil using a recognised and verified industry methodology provided by Tempest
Estates.
Imported Electricity – Electricity usage was assumed to be verified, and conversion factors
from DEFRA were applied to convert values from kWh to CO2e.
Water Supply and Treatment – Exact usage data via metering was not available therefore
bills (£) were converted to volume data (m3) using conversion factors provided by Yorkshire
Water; the supplier of water to Comply Direct.
Commuting – Travel data was assumed to be constant, whereby all employees take the
same route to work on a daily basis. Data was calculated using maps.google.co.uk and
scaled up to represent annual commuting distances.
Business Travel – All business travel claims were used, this data was assumed to be
correct. In addition flight and public transport data was calculated using
http://www.webflyer.com/travel/mileage_calculator/ and http://www.mileage.railmiles.org/
respectively.
Waste – Waste has been calculated pro rata based on ongoing waste collections and
recycling in the office.
Manchester Office – Electricity, water supply and waste data was not available, therefore per
capita emissions were calculated in order to ‘scale up’ total emissions, accounting as
accurately as possible the total emissions for Comply Direct Ltd.
Data Quality
The data collected is believed to be representative of the total carbon emissions of Comply
Direct Ltd. Imported electricity and business travel data is based on accurate measurements
(kWh and mileage data respectively). As the two most significant contributors to Scope 2
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and Scope 3 emissions, this suggests that the carbon emissions calculations are reasonably
accurate.
For data with a greater uncertainty, appropriate sampling methods and calculations have
been used in order to ‘scale up’ data in order to ensure it accurately reflects the carbon
emissions produced by a particular activity. Care was taken to quantify emissions in a
manner that limits underestimation. No emissions sources have been knowingly excluded.
Appendix B: Carbon Management Plan
Reduction Plan for Commitment Period
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Where possible, Comply Direct will complete an audit via desktop in an attempt to
reduce carbon emissions associated with business travel. The entity aims to
complete 60% of audits by desktop during the commitment period (AP2)
Four members of staff have agreed to car share on their commute from Leeds to
Skipton. All members of staff that are based in Leeds now car share, significantly
reducing employee commuting mileage that would otherwise occur. All staff are
encouraged to car share where possible.
Awareness of carbon emissions in the office has been heightened through the
development of posters designed to remind employees to actively reduce their
carbon emissions at work. Procedures are now in place to implement change to
reduce energy usage.
Recycling facilities to be further improved by working with Broughton Hall to improve
collections.
Inhibit business travel by air where feasible, during AP2 only 2 flights were made by
employees.
Ongoing commitment to ISO 14001 which promotes continual improvement of the
environmental aspects of Comply Direct.
Emissions Reduction Targets for Commitment Period AP1 (2013-2014)
Achieve reduction in emissions from electricity use by 5% relative to full time staff
equivalents by 1st December 2014
Result – An absolute reduction of 1.40% has been recorded. A relative reduction of
21% was identified
Achieve reduction in emissions from water use by 5% relative to full time staff equivalents by
1st December 2014
Result – Water use is not metered therefore this cannot be accurately measured.
Achieve reduction in emissions from heating use by 5% relative to full time staff equivalents
by 1st December 2014
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Result - An absolute reduction of 1.93% has been made. The relative reduction of
21.55% has been made during AP2.
Achieve Zero Waste to Landfill across operations of Comply Direct by 2020
Progress towards goal – 51% of all waste is currently recycled. Improvements
towards goal include further segregation of waste and the introduction of food waste
bins.
Emissions Reductions
Emissions reductions have been achieved through producing a carbon management plan
and employees adhering to its guidelines. Preparation for ISO 14001 accreditation has
further induced change which has allowed Comply Direct to reduce the majority of its
emissions.
Targets for AP2
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Continue accreditation of ISO 14001, benefitting both Comply Direct and its supply
chain.
Achieve a relative reduction of 30% in emissions from electricity use per FTE on the
base period by 1st December 2015.
Achieve a relative reduction of 30% in emissions from heating per FTE on the base
period by 1st December 2015.
Achieve a company recycling rate of 60% by December 2015.
Achieve zero waste to landfill by 2020
Demonstrating Commitment to Carbon Management Plan


The Carbon Management Supervisor will on an annual basis assess company
performance relative to commitments made in the Carbon Management Plan.
Comply Direct Ltd is committed to carbon neutrality through reducing carbon
emissions where possible in all activities conducted by the business.
Further to our quantifiable targets, we wish to encourage increased carbon awareness with
all of our employees, and to find a better way where possible in all aspects of our functioning
in business with respect to the environment.
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Appendix C: Carbon Offset Strategy
CO2e emissions to be offset – 29.303 tCO2e
Carbon Offsets purchased and validated through CO2balance

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Yorkshire Dales Millennium Trust to retire 30 WCC credits on behalf of Comply Direct
Ltd.
Self-verification assessment with third party carbon credit validation.
Project Details:
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Project name: Nethergill Woodland, Oughtershaw, Langstrothdale
Location: UK
Standard: Woodland Carbon Code
Reference number: 40033/3
Volume of credits purchased: 30
Retirement registry: Markit
Credits certified by Yorkshire Dales Millennium Trust
UK Carbon sequestration project
Credits are valid for use in PAS 2060 standard
Location of retired credits
In total 12 Gold Standard credits used for carbon offsets were retired and can be found on
an independent public register:
Markit Gold Standard Registry: http://mer.markit.com/br-reg/public/index.jsp?s=cr
12 WCC credits retired and can be found on the markit registry: www.markit.com
Commitment to carbon neutrality
The entity will commit to monitor, reduce and declare all of its carbon equivalent emissions
for the commitment period AP2. Comply Direct will subsequently offset the declared
emissions using a genuine source of carbon credits for AP2.
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Item
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PAS 2060
Define standard and methodology use to determine its GHG
emissions reductions
Confirm that the methodology used was applied in accordance with its
provisions and principles set out in PAS 2060 were met
Provide justification for the selection of the methodologies chosen to
quantify the reductions in the carbon footprint, including all
assumptions and calculations made and any assessments of
uncertainty. (The methodology employed to quantify reductions shall
be the same as that used to quantify the original carbon footprint.
Should an alternative methodology be available that would reduce
uncertainty and yield more accurate, consistent and reproducible
results, then this may be used provided the original carbon footprint is
re-quantified to the same methodology, for comparison purposes.
Recalculated carbon footprints shall use the most recently available
emissions factors, ensuring that for purposes of comparison with the
original calculation, any change in the factors used is taken into
account)
Describe the means by which reductions have been achieved and any
applicable assumptions or justifications
Ensure that there has been no change to the definition of the subject
(The entity shall ensure that the definition of the subject remains
unchanged through each and every stage of the methodology. In the
event that material change to the subject occurs, the sequence shall
be re-started on the basis of a newly defined subject.)
Describe the actual reductions achieved in absolute and intensity
terms and as a percentage of the original carbon footprint (Quantified
GHG emissions reductions shall be expressed in absolute terms and
shall relate to the application period selected and/or shall be
expressed in emission intensity terms (e.g. per specified unit of
product or instance of service))
State the baseline/qualification date
Record the percentage economic growth rate for the given application
period used as a threshold for recognising reductions in intensity
terms
Provide an explanation for circumstances where a GHG reduction in
intensity terms is accompanied by an increase in absolute terms for
the determined subject
Select and document the standard and methodology used to achieve
carbon offset
Confirm that:
Offsets purchased or allowance credits surrendered represent
genuine, additional GHG emission reductions elsewhere –a
Projects involved in delivering offsets meet the criteria of additionality,
permanence, leakage and double counting. (See the WRI
Greenhouse Gas Protocol for definitions of additionality, permanence,
leakage and double counting) -b
Carbon offsets are verified by an independent third party verifier -c
Credits from Carbon offset projects are only issued after emission
reduction has taken place -d
Credits from Carbon offset projects are retired within 12 months from
the date of the declaration of achievement -e
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Credits from Carbon offset projects are supported by publically
available project documentation on a registry which shall provide
information about the offset project, quantification methodology and
validation and verification procedures –f
Credits from Carbon offset projects are stored and retired in an
independent and credible registry –g
Document the quantity of GHG emissions offset and the type and
nature of offsets actually purchased including the number and type of
credits used and the time period over which credits were generated
including:
Which GHG emissions have been offset –a
The actual amount of carbon offset – b
The type of offset and projects involved – c
The number and type of carbon offset credits used and the time period
over which the credits have been generated -d
Information regarding the retirement/cancellation of carbon offset
credits to prevent their use by others including a link to the registry
where the offset has been retired –e
Specify the type of conformity assessment
a- Independent third party certification
b- Other party validation
c- Self-validation
Include statements of validation where declarations of achievement of
carbon neutrality are validated by a third party certifier or second party
organizations.
Date the WES and have it signed by a senior representative of the
entity concerned (e.g. CEO, Divisional Director, where the subject is a
division of a larger entity; the Chairman of a town council or the head
of the household for a family group)
Make QES publicly available and provide a reference to any freely
accessible information upon which the substantiation depends
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N/A
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Y
QES openness and clarity – Entities should satisfy themselves that the QES:
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2
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Does not suggest a reduction which does not exist, either directly or
by implication
Is not presented in a manner which implies that the declaration is
endorsed or certified by an independent third party organisation when
it is not
Is not likely to be misinterpreted or be misleading as a result of the
omission of relative facts
Is readily available to any interested party
Y
Y
Y
Y
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