Annual Verification Audit Overview and Provisions For Auditors and Sellers Participating in Green-e® Climate Reporting Year 2014 Center for Resource Solutions 1012 Torney Ave, 2nd Floor San Francisco, CA 94129 415-561-2100 | www.resource-solutions.org Copyright © 2015 Center for Resource Solutions. All Rights Reserved. Table of Contents I. OVERVIEW .................................................................................................................... 3 A. II. Summary Requirements .................................................................................................................. 4 GENERAL VERIFICATION AUDIT PROVISIONS ................................................................. 4 A. B. C. D. E. F. G. H. I. J. Scope of Verification Audit .............................................................................................................. 4 Form of Engagement and Report..................................................................................................... 4 Scope of Testing ............................................................................................................................... 5 Period and Sales Covered by Reporting Requirements ................................................................... 6 Date the Annual Verification Submission Is Due to the Center for Resource Solutions.................. 6 Other Materials to be Submitted to the Center for Resource Solutions with the Annual Verification Submission ................................................................................................................... 7 Use of Sampling Techniques ............................................................................................................ 7 Tests of Attributes.......................................................................................................................... 11 Principal Testing to Be Performed ................................................................................................. 11 Applying General Procedures to Specific Cases ............................................................................. 12 III. GENERAL NOTES ON AUDIT REQUIREMENTS ............................................................... 12 V. AUDITOR’S QUALIFICATIONS ....................................................................................... 13 VI. HOW TO GET HELP ...................................................................................................... 14 APPENDIX A: APPENDIX B: APPENDIX C: APPENDIX D: GLOSSARY OF TERMS ................................................................................................................................... 15 DESCRIPTION OF DOCUMENT TITLES AND OTHER INFORMATION NEEDED BY THE AUDITOR ....................... 19 USING REGISTRIES IN GREEN-E CLIMATE ANNUAL VERIFICATION ................................................................. 21 AUDITOR’S ATTESTATION FOR AGREED-UPON PROCEDURES REPORT .......................................................... 24 The Green-e Climate Annual Verification Audit Overview and Provisions RY2014 Copyright © 2015 Center for Resource Solutions. All Rights Reserved. I. OVERVIEW This document, the Green-e Climate Annual Verification Audit Overview and Provisions (“Audit Overview and Provisions”), addresses the verification reporting requirements for the Green-e Climate Program and provides general background and instructions for completing the Green-e Climate Verification Audit Agreed-upon Procedures (“Audit Procedures”), which are included as a separate document. The term Seller1, as used in this document, refers to a seller of greenhouse gas (GHG) emissions reductions (“emissions reductions”) that has a contract to sell Green-e Climate Certified emissions reductions (“Certified Offsets”). This document describes how to conduct the independent verification audit that Green-e Climate requires as part of its annual verification of sales of Certified Offsets. The verification audit covers all sales of Certified Offsets in a particular calendar year, referred to as the Reporting Year (RY). The verification audit should be documented in an Agreed-Upon Procedures Report. This report and the entire Green-e Climate Annual Verification Submission (“Annual Verification Submission”) must be received at the Center for Resource Solutions (CRS) no later than June 1, 2015, and must be mailed to the address on the cover page of this document. The verification audit is as follows. Sellers must complete the Green-e Climate Verification Worksheets2 (“Worksheets”), described in the Green-e Climate Annual Verification Audit Instructions (“Instructions”), and provide these and supporting documentation described in the Green-e Climate Verification Checklist (“Checklist”) and Appendix B to an independent certified public accountant or certified internal auditor (“Auditor”). The Auditor then follows the Audit Procedures to verify the accuracy of the information provided by the Seller. The Auditor’s Agreed-Upon Procedures Report, the Seller’s completed Worksheets, and other supporting documents identified in the Checklist are returned to CRS for final review and acceptance. All of these documents are collectively called the Annual Verification Submission. There are two different certification types within Green-e Climate that correspond to two different ways of selling Certified Offsets: 1. Sales by Project (also called “Project-specific Sales”); and 2. Sales of Fixed and Customized Mix Products (at times abbreviated to “Mix Products”). As such, there are three different sets of Verification Worksheets for reporting supply and sales and three different corresponding sets of Audit Procedures: 1. Set 1 - Project-specific Sales (Sales by Project) Only; 1 Terms defined in Appendix A are indicated in bold type the first time they appear. Documents necessary for the Auditor defined in Appendix B are indicated in bold italic type the first time they appear. 2 The Green-e Climate Annual Verification Audit Overview and Provisions RY2014 Copyright © 2015 Center for Resource Solutions. All Rights Reserved. Page 3 of 25 2. Set 2 - Sales of Fixed and/or Customized Mixes Only; and 3. Set 3 - Sales of Fixed and/or Customized Mixes AND Project-specific Sales. Worksheets and Audit Procedures are clearly labeled as listed above. Sellers will use only one of these three sets and the Auditor will complete only one set of Audit Procedures that correspond to the Worksheets completed by the Seller. Sellers have been sent the set of Worksheets and Audit Procedures that apply to them, and each Seller’s certification type(s) is also clearly listed on the Checklist. If you are unsure which set of Worksheets and Audit Procedures to use, contact Green-e Climate Staff. A. Summary Requirements Under Green-e Climate, the Seller is required to reconcile emissions reduction sales with emissions reduction retirements and/or transfers of emissions reduction ownership in order to verify that they have retired/transferred enough emissions reductions in quantity and type to meet its customer demand for all sales of Certified Offsets. Green-e Climate requires that the Certified Offsets sold by Sellers meet a variety of criteria. These criteria address supply and sales, eligibility of emissions reductions, product marketing, and customer disclosure. Full Program eligibility criteria can be found in the Green-e Climate Code of Conduct. All sales made by the Seller must be audited. The specific information to be provided by the Seller and the tests to be performed by the Auditor are described in detail in the Audit Procedures. II. GENERAL VERIFICATION AUDIT PROVISIONS A. Scope of Verification Audit The verification audit addressed is for the annual verification reporting requirements of the Green-e Climate Program. This guidance is to be used by Sellers participating in Green-e Climate and their Auditors. CRS acknowledges that the procedures put forward in the Audit Procedures are sufficient when performed in their entirety. B. Form of Engagement and Report Seller must engage an independent certified public accountant to perform the verification audit engagement and report on agreed-upon procedures. Alternatively, the Sellers may elect to have their internal audit department (or the internal audit department of an affiliated company) perform these procedures, provided that the individual accountant signing the report for the internal audit department is a Certified Internal Auditor in good standing with the Institute of Internal Auditors (IIA). The term “Auditor” in this document refers to an independent public accountant or certified internal auditor. The verification audit engagement and report on agreed-upon procedures must be performed in accordance with the Green-e Climate Verification Audit Overview and Provisions (this document), and the American Institute of Certified Public Accountants (AICPA) Statements on Standards for Attestation Engagements, Section 600, “Agreed Upon Procedures Engagements,” or under Statements on Auditing The Green-e Climate Annual Verification Audit Overview and Provisions RY2014 Copyright © 2015 Center for Resource Solutions. All Rights Reserved. Page 4 of 25 Standards, Section 622, “Engagements to Apply Agreed-Upon Procedures to Specified Elements, Accounts, or Items of a Financial Statement.” The form of the report should follow the instructions in Section III of this Audit Overview and Provisions and as such specify the procedures performed and findings in a manner similar to reporting under Section AT600 or AU622 of the AICPA’s attestation or auditing standards, respectively. The Auditor should make reasonable efforts to ensure that the report is prepared in accordance with these minimum standards. In accordance with paragraph .41 of AICPA Section AU622 (in which “accountant” is equivalent to “Auditor”): “The accountant need not perform procedures beyond the agreed-upon procedures. However, if, in connection with the application of agreed-upon procedures, matters come to the accountant’s attention by other means that significantly contradict the basis of accounting for the specified elements, accounts, or items of a financial statement referred to in the accountant’s report, the accountant should include this matter in his or her report. For example, if, in connection with the application of agreed-upon procedures, the accountant becomes aware of a potentially material adjustment to that account by means other than performance of the agreed-upon procedures, the accountant should include this matter in his or her report.” The Seller may elect a higher level of assurance with regard to its reporting requirements conducted by an Auditor. CRS welcomes attestation or similar audit-level assurance with regard to the information, forms and assertions described in this Audit Overview and Provisions document and the Audit Procedures. Such alternative reporting should also be discussed with Green-e Climate staff prior to submission of the report. The Agreed-Upon Procedures Report must contain an original signature of the Auditor performing the audit on his or her company letterhead. Photocopies or facsimile copies are not accepted. In addition, each Auditor must complete a copy of the Auditor Attestation to accompany each Agreed-Upon Procedures Report written. The Auditor Attestation must also contain and original signature, and is included as Appendix D. C. Scope of Testing The management of the Seller will need to make certain decisions regarding the scope of testing. This is due to the guidance involving agreed-upon procedures conducted in accordance with the AICPA, at Section AT600 or Section AU622, which results in an Auditor’s report that is in the form of procedures and findings and not in the form of an opinion or negative assurance. Additionally, the specified users of the Agreed-Upon Procedures Report are responsible for the sufficiency (nature, timing and extent) of the agreed-upon procedures, and assume the risk that such procedures might be insufficient for their purpose or that they might misunderstand or inappropriately use findings properly reported by the Auditors. The Green-e Climate Annual Verification Audit Overview and Provisions RY2014 Copyright © 2015 Center for Resource Solutions. All Rights Reserved. Page 5 of 25 CRS has attempted to provide Audit Procedures that require limited decisions necessary from the management of the Seller or from the Auditor. However, in those situations where it is necessary, the Audit Procedures clearly indicates when scope decisions are necessary and who should make those decisions. If questions regarding the scope arise, please contact Green-e Climate staff for guidance, and for approval of any changes that may be necessary to address scope issues. D. Period and Sales Covered by Reporting Requirements The Agreed-Upon Procedures Report must be prepared for Green-e Climate on a calendar year basis. For those companies that began participating in Green-e Climate in the middle of a RY, the reports should be prepared for the period starting on the date the Seller signed their Greene Climate contract and ending on December 31 of the RY, or alternatively for the full RY if given permission of Green-e Climate staff. RY2014 verification should cover sales made between January 1, 2014 and December 31, 2014—that is, sales that originated in 2014 or deliveries to be made in 2014 under Multi-year Purchase Agreements or contracts entered into in previous years. The time of delivery for sales that originated in 2014 may not line up exactly with the time of sale, and deliveries for 2014 sales may occur up until verification of RY2014 (which occurs in 2015). As long as the delivery is made in accordance with a 2014 sale or 2014 scheduled delivery under a multi-year purchase agreement, then the sale falls under the verification audit for RY2014. The year of sale or scheduled delivery should be evident based on Internal Reporting Documents and Billing Statements, but if it is not, then Seller can simply confirm the time of sale with the Auditor. The time of sale and time of delivery are different from the vintage, which is when the reduction occurred. For Mix Sales, Sellers must report the vintage to customers on the Carbon Offset Content Label. For Project-specific Sales, Sellers must report the vintage to customers on the Project Information Disclosure. The reduction must have occurred, been verified and credited by an Endorsed Program, and been delivered (fully retired/transferred) by the Seller by the time of the verification audit. E. Date the Annual Verification Submission Is Due to the Center for Resource Solutions The Agreed-Upon Procedures Report must be submitted to CRS and received no later than the date provided in the Reporting Year 2014 Annual Verification Submission Timeline and Deadlines (“Verification Timeline”). For RY2014, this due date is June 1, 2014. Materials should be submitted electronically by emailing them to climate@green-e.org (Subject: RY2014 Green-e Climate Verification Submission). Completed Verification Worksheets must be submitted in Microsoft Excel™ compatible electronic format. The Annual Verification Submission must be received no later than the date provided in the Verification Timeline for RY2014. Hard copies of materials may also be mailed to the following address. Center for Resource Solutions 1012 Torney Avenue, 2nd Floor San Francisco, CA 94129 The Green-e Climate Annual Verification Audit Overview and Provisions RY2014 Copyright © 2015 Center for Resource Solutions. All Rights Reserved. Page 6 of 25 ATTN: Green-e Climate Verification F. Other Materials to be Submitted to the Center for Resource Solutions with the Annual Verification Submission The following reports and information should accompany the Auditor’s Agreed-Upon Procedures Report: Copies of the Carbon Offset Content Label(s) for each Fixed and Customized Mix Product sold during RY2014; Copy of the Project List used for Fixed and Customized Mix Products during RY2014; Copy of Project Information for each project used to supply Project-specific Sales during RY2014; Copies of offset card(s) active in RY2014 for each unique combination of organization type and Mix Product, where applicable; Copies of Green-e Climate Verification Worksheets in Microsoft Excel™ electronic format; Registry Reports detailing the retirement and/or transfer of emissions reductions on behalf of Green-e Climate sales; Written explanation from the Seller for any exceptions in the Worksheets in the form of a Completed Green-e Climate Explanation of Exceptions Form; A completed Green-e Climate Attestation from Program Seller for the Seller for whom this verification audit is being conducted; and An original copy of the Auditor Attestation completed by the Auditor that has signed the Agreed-Upon Procedures Report. G. Use of Sampling Techniques In certain procedures in the Audit Procedures, the Auditor may use sampling techniques to test the attributes of the Participant’s data. Sampling criteria have been established by CRS to be followed in the performance of the agreed-upon procedures. Additionally, the Participant and the Auditor will need to make certain decisions and judgments in the process of establishing the appropriate sample size, following the guidance set forth in the AICPA AU Section 350, Audit Sampling. CRS will allow alternative methods to determine sample size than what is given below, provided that the resultant sample size is greater than or equal to that which results from the method below. If the Auditor chooses not to use approved sampling techniques or an alternative method that results in greater or equal sampling size, then 100% of the population must be tested. CRS has determined that an attributes sampling methodology is most appropriate given the characteristics of the populations for which sampling is utilized in the agreed upon procedures. Attributes sampling is used to reach a conclusion about a population in terms of the rate of occurrence of a certain attribute. For the purposes of sampling, an attribute is defined as a The Green-e Climate Annual Verification Audit Overview and Provisions RY2014 Copyright © 2015 Center for Resource Solutions. All Rights Reserved. Page 7 of 25 characteristic that is either present or absent in a sampling unit. Each sampling event required in the agreed upon procedures will identify the applicable sampling unit, but in general the sampling unit is each individual sale transaction, donation, or other transaction that conveys or retires GHG emissions reductions to the benefit of another party. Each occurrence (the presence or absence of an attribute) is given equal weight in the sample evaluation, regardless of the size of the transaction. If the Auditor elects to utilize sampling techniques rather than test 100% of the population, they must first ascertain the population size. The population size is defined in terms of the number of sampling units. If the population is greater than or equal to 2,000 transactions, the Auditor will utilize Table A-1 in Appendix A of the AICPA Audit Guide on Audit Sampling. The Auditor will determine the sample size based on 5% risk of overreliance, tolerable deviation rate of 10% and expected deviation rate of 3%. If the population is less than 2,000 transactions, then the Auditor will utilize the table below to determine the appropriate sample size. Population 1-19 20-25 26-30 31-40 41-50 51-60 61-70 71-80 81-90 91-100 101-120 121-140 141-160 161-180 181-200 201-300 301-400 401-500 501-600 601-700 701-1000 1001-1999 Sample Size Same as population size 19 21 25 28 31 34 36 37 39 42 44 45 47 48 52 54 56 57 58 59 60 The table above was created by using statistical attribute sampling software using the above guidance. The Green-e Climate Annual Verification Audit Overview and Provisions RY2014 Copyright © 2015 Center for Resource Solutions. All Rights Reserved. Page 8 of 25 Once the appropriate sample size has been determined, the sample selection should be made on a random basis with a random number generator or similar process as the preferred approach. Other sample selection methods (e.g., systematic), are acceptable, provided the resultant selection is ultimately random in nature (e.g., each member of the population has an equal chance of being selected). In any event, no more than 50% of the selected transactions may relate to any one month unless more than 50% of the population relates to the same month (in which case this should be included in the notes section of the applicable area of the agreed upon procedures report). Once testing is complete, the Auditor must evaluate the results of the testing to ensure the objectives of the test were met. If a greater number of deviations are found than were planned for, then the test objective has not been met and there is a high risk that the deviation rate in the population exceeds the tolerable deviation rate. If the number of deviations noted in the initial sample selection exceeds 3%, then an additional sample must be selected. The additional sample should equal the lesser of the initial sample size or the remaining items in the population. Once the additional sample is tested, if the total number of deviations is less than 3% of the total expanded sample (sum of initial sample and additional sample), no further test procedures are necessary. If after expanding the sample, the total number of deviations exceeds 3% of the total expanded sample, please contact CRS for additional guidance. A note for verification of both project-specific sales and sales of fixed and customized mix products (Set 3 of Worksheets and Audit Procedures): The total number of samples taken for verification of sales of less than 25,000 metric tons CO2e (i.e. the sum of samples taken per Steps III.B.4 and III.C.4 in the Set 3 Audit Procedures) should be the sample size corresponding to the sum of project-specific sales of less than 25,000 metric tons CO2e and sales of fixed and customized mix products of less than 25,000 metric tons CO2e, according to the table above for population sizes less than 2,000. The sample size for each of the two sampling events should be based on the proportion of the population of either project-specific sales <25,000 metric tons or sales of fixed and customized mix products <25,000 metric tons to this sum. For example, where: Number of project-specific transactions of <25,000 metric tons = 345 Number of transactions of fixed or customized mix products of <25,000 metric tons = 641 Then: Sum of project-specific sales and sales of fixed and customized mix products < 25,000 metric tons = 345+641 = 986 The total number of samples taken for verification of sales < 25,000 metric tons (sum of samples taken for Steps III.B.4 and III.C.4) = 59 Sample size for verification of project-specific sales <25,000 metric tons (Step III.B.4) = 345/986*59 = 21 Sample for verification of sales of fixed and customized mix products <25,000 metric tons (Step III.C.4) = 641/986*59 = 38 The Green-e Climate Annual Verification Audit Overview and Provisions RY2014 Copyright © 2015 Center for Resource Solutions. All Rights Reserved. Page 9 of 25 Consider this in the context of the full example provided below, where: Total population of transactions (including both project-specific sales and sales of fixed and customized mix products) = 1,000 Number of project-specific transactions = 350 Number of transactions of fixed and customized mix products = 650 Then: Sample Size necessary for verification Sample Size of both Corresponding projectSample size Sample size if to Table in specific sales if only only sales of Section II.G and sales of projectfixed and for fixed and specific sales customized Populations < customized were mix products Description Population 2,000 mix products verified were verified Number of 345 54 21 54 NA projectspecific transactions of <25,000 metric tons Number of 641 58 38 NA 58 transactions of fixed or customized mix products of <25,000 metric tons Project25 19 19 19 NA specific multi-year purchase agreement deliveries Multi-year 75 36 36 NA 36 purchase agreement deliveries of mix products The Green-e Climate Annual Verification Audit Overview and Provisions RY2014 Copyright © 2015 Center for Resource Solutions. All Rights Reserved. Page 10 of 25 Description Projectspecific automatic recurring purchases Automatic recurring purchases of mix products Customized mix product transactions Total samples taken Population 15 Sample Size necessary for verification Sample Size of both Corresponding projectto Table in specific sales Section II.G and sales of for fixed and Populations < customized 2,000 mix products 15 15 Sample size if only projectspecific sales were verified 15 Sample size if only sales of fixed and customized mix products were verified NA 45 28 28 NA 28 100 39 39 NA 39 249 196 88 161 H. Tests of Attributes When performing the procedures described in the Audit Procedures, it is important that the Auditor understand the objectives and nature of the tests to be performed. Each of the procedures is designed to test specific attributes, and the objectives of the procedures are noted at the beginning of each testing section. Each transaction or sampling unit may need to be tested for multiple attributes and any exception will need to be evaluated in accordance with the guidance noted above in Use of Sampling Techniques. Auditors who do not understand the objectives and nature of the tests to be performed should contact Green-e Climate staff for clarification. I. Principal Testing to Be Performed The principal testing to be performed by the Auditor will be reading, vouching, comparing and recalculating information provided to the Auditor by the Participant. See Audit Procedures for specific tests to be performed. The Green-e Climate Annual Verification Audit Overview and Provisions RY2014 Copyright © 2015 Center for Resource Solutions. All Rights Reserved. Page 11 of 25 J. Applying General Procedures to Specific Cases This document provides guidance and specific examples of the procedures to be performed in order to provide CRS with assurances as to the accuracy and completeness of the Worksheets that are to be completed by the Seller. The nature and complexity of supply and sale transactions differ among Sellers participating in Green-e Climate. Additionally, accounting systems and transaction data structures of each Seller will vary along with the types of information and reports internally available. Accordingly, the following requirements enumerated in the following sections are not intended to be all-inclusive, but rather represent the minimum standards to be applied in performing tests of the documentation associated with the information submitted to CRS by the Seller. Judgment will need to be applied in order to execute the agreed-upon procedures engagement under each specific circumstance. III. GENERAL NOTES ON AUDIT REQUIREMENTS The Audit Procedures direct the Auditor to perform a number of procedures for the purposes stated preceding each section (corresponding to a Worksheet) in the Audit Procedures. The Auditor, including a Certified Internal Auditor, shall not complete the Worksheets. The Worksheets must be completed by an employee of the Seller that is not performing the audit or part of the Seller’s internal audit department. Preparing the Agreed-Upon Procedures Report The Agreed-Upon Procedures Report must be produced by specifically responding to each review step in the Audit Procedures document. Each review step for the Auditor is followed by a box as shown in the example below: Step EXAMPLE was performed: Yes. No. N/A. Exceptions, Notes, Reason for “No” or “N/A”: Each review step is numbered in accordance with the structure of this document. The first step for Worksheet 1 review is “III.A.1.” In the box that corresponds to each review step, the Auditor must check one of the three checkboxes indicating whether the step was completed as written or whether the step did not apply. Also, the Auditor must provide explanation of any exceptions, any notes resulting from completion of the procedure, any notes on how the Auditor’s review differed from the specified instructions, and any reasons that “N/A” was checked because the step did not apply. The Auditor should explicitly state if an exception has been found. Once the Auditor has responded to each review step, the Auditor must print the Audit Procedures document, with Section IV.B on company letterhead, and sign Section IV.B. This signed printout, along with the Auditor Attestation in Appendix D, constitutes the Agreed-Upon Procedures Report due to CRS. The Green-e Climate Annual Verification Audit Overview and Provisions RY2014 Copyright © 2015 Center for Resource Solutions. All Rights Reserved. Page 12 of 25 Certain Worksheets will not be applicable to all Sellers. Ensure that at a minimum, all Worksheets have been filled in with RY, Date Completed, Seller Company Name and Name of Person Completing the Form. In the case that the given Worksheet is not applicable, ensure that “Not Applicable” has been entered in the first row of the first table in the Worksheet. Note any exceptions. If the Worksheet is not applicable, note this in the first available space in that Worksheet’s section of the Agreed-Upon Procedures Report. If review of documents provided by Participant, review of this Overview and Provisions document, and review of the Audit Procedures lead the Auditor to believe that a certain Worksheet(s) is applicable to the Participant’s sales of Green-e Climate Certified Offsets despite being filled in as “Not Applicable,” note this in the first available space in that Worksheet’s section of the Agreed-Upon Procedures Report. A description of each Worksheet appears in Appendix B. The introductory language before Section III.A of the Audit Procedures is to be included in the Agreed-Upon Procedures Report. The Auditor must fill in the blank spaces in this introductory language. If Green-e Climate Staff find that the Agreed-Upon Procedures Report is incomplete or prepared incorrectly, the Annual Verification Submission will not be considered complete until the Agreed-Upon Procedures Report is satisfactorily revised to reflect that the full audit was conducted correctly in accordance with this document and the Audit Procedures. Auditors that do not provide a satisfactory Agreed-Upon Procedures Report will not be eligible to be listed on the list of auditors on the Green-e website (http://www.greene.org/auditors.html), may be removed from that list if the Auditor has appeared on it in the past, may be placed on probation, and may be barred from performing future Green-e Climate audits, at the sole discretion of Green-e Climate staff. For Auditors placed on probation, should the quality of the subsequent year’s Agreed-Upon Procedures Reporting not improve, the Auditor may be deemed unacceptable to perform the Green-e Climate Annual Verification Audit thereafter. The remainder of Section III and Section IV of this document is constituted by the Audit Procedures document. V. AUDITOR’S QUALIFICATIONS The Auditor shall be a member in good standing with the American Institute of Certified Public Accountants or a member in good standing and certified as an internal auditor with the Institute of Internal Auditors (IIA). For more information see Section II.B above. The Green-e Climate Annual Verification Audit Overview and Provisions RY2014 Copyright © 2015 Center for Resource Solutions. All Rights Reserved. Page 13 of 25 VI. HOW TO GET HELP Should assistance be required, Center for Resource Solutions staff are available to answer questions. Questions relating to the verification may be directed to: Todd Jones or Sarah Busch at 415-561-2100 or climate@green-e.org. Electronic copies of this document, along with attestations and Worksheets, are available on the Green-e Climate Web page at http://www.green-e.org/climateverification. The Green-e Climate Annual Verification Audit Overview and Provisions RY2014 Copyright © 2015 Center for Resource Solutions. All Rights Reserved. Page 14 of 25 APPENDIX A: GLOSSARY OF TERMS Agreed-Upon Procedures Report (Audit Procedures): The report supplied to CRS prepared by the Auditor detailing the results of the annual verification audit by performing the procedures stipulated within in accordance with the Green-e Climate Annual Verification Audit Overview and Provisions. American Carbon Registry (ACR): The American Carbon Registry, a nonprofit enterprise of Winrock International, was established in 1996 as the first voluntary GHG registry in the world. ACR develops offset methodologies for the voluntary market and provides oversight of offset project verification, registration, offset issuance and retirement reporting. ACR is an Endorsed Program under Green-e Climate. Approved Registry: A greenhouse gas emissions reduction registry deemed eligible by Green-e Climate as an acceptable software database to document ownership and the retirement of emissions reductions for purposes of Green-e Climate verification. A list of approved registries is included in the Checklist for each Seller. Auditor: An independent public accountant or certified internal auditor that performs the Green-e Climate Verification Audit and reports on agreed-upon procedures. See Section II.B and V of the Instructions for Auditor qualifications. Auditor Attestation: A short attestation to be completed by the Auditor signing the Agreed-Upon Procedures Report, which states that the Auditor has followed certain practices when reviewing Participant’s verification materials and preparing the Agreed-Upon Procedures Report. It is available as Appendix D of the Audit Overview and Provisions. Automatic Recurring Sales: Sales of Certified Offsets continuously over time through automatic renewals of a purchasing agreement or sustained enrollment in a purchasing plan. Carbon Dioxide Equivalent (CO2e): The universal unit of measurement used to indicate the global warming potential of GHGs and to trade ownership of GHG emissions reductions. Used to evaluate and compare the impacts of releasing (or avoiding the release of) different GHGs. Certified Carbon Offset (Certified Offset): A carbon offset sold as Green-e Climate Certified. Greene Climate will certify carbon offsets sold by project (“Project-specific Sales”) or in mixes (“Customized Mix” and “Fixed Mix”) of project type, location, and Endorsed Program. A Certified Offset is a GHG emission reduction that has been certified and issues by an eligible Endorsed Program under an eligible protocol or methodology, and the sale and marketing of which meets the requirements of the Green-e Climate Code of Conduct, and the exclusive and correct delivery of which has been verified in accordance with the Code of Conduct and the Green-e Climate Verification Audit. Climate Action Reserve (CAR): The Climate Action Reserve is a national offsets program working to ensure integrity, transparency and financial value in the U.S. carbon market. It does this by establishing regulatory-quality standards for the development, quantification and verification of greenhouse gas emissions reduction projects in North America; issuing carbon offset credits known as Climate Reserve Tonnes (CRT) generated from such projects; and tracking the transaction of credits over time in a transparent, publicly-accessible system. CAR is an Endorsed Program under Green-e Climate. The Green-e Climate Annual Verification Audit Overview and Provisions RY2014 Copyright © 2015 Center for Resource Solutions. All Rights Reserved. Page 15 of 25 Commercial Customer: A business purchaser of Certified Offsets. Customer: For the purposes of this Audit Procedures, the customer is identified as the party who has purchased a Certified Offset from the Seller. Customer types include commercial, individual, and wholesale. Customized Mix: A Certified Offset in which a customer can choose a unique combination of different emissions reductions from project type(s), location(s) and Endorsed Program(s). EcoLogo: Founded in 1988, EcoLogo a multi-attribute criteria certification program for North America based in Canada and managed by TerraChoice, an environmental consultancy. Eligible Emissions Reductions: Emissions reductions that are certified by an Endorsed Program, and therefore an eligible source of supply in a Certified Offset. This includes emissions reductions derived from offset projects according to certain protocols of the American Carbon Registry, the Climate Action Reserve, the Gold Standard, and the Verified Carbon Standard. Endorsed Program: A greenhouse gas project certification program identified by Green-e Climate Stakeholders and the Green-e Governance Board as meeting the requirements set forth by the Green-e Climate Standard. Certain project protocols of Endorsed Programs are eligible sources of supply for Certified Products. The Endorsed Programs include the American Carbon Registry, the Climate Action Reserve, the Gold Standard, and the Verified Carbon Standard. Fixed Mix Product: A Certified Offset with the same combination and proportion of emissions reductions from project type(s), location(s) and Endorsed Program(s) sold to all customers. Gold Standard (GS): The Gold Standard Foundation is a project certification program for Clean Development Mechanism and voluntary offset projects. The Gold Standard is a non-profit foundation under Swiss law and funded by public and private donors. The Gold Standard is an Endorsed Program under Green-e Climate. Greenhouse Gas (GHG): Gases that trap heat in the atmosphere and are emitted through natural processes and human activities. Green-e Climate addresses GHG emissions reductions that originate from any gas that has been determined by the Intergovernmental Panel on Climate Change (IPCC) to have a radiative forcing effect on the atmosphere, including but not necessarily limited to six principle GHGs included in the Kyoto Protocol: carbon dioxide, nitrous oxide, methane, hydrofluorocarbons, perfluorocarbons and sulfur hexafluoride (CO2, N2O, CH4, HFCs, PFCs and SF6). Greenhouse Gas Emissions Reductions (emissions reductions): Reductions, removals or the permanent storage of greenhouse gases produced by projects or project activities that have been validated, verified and certified according to the program requirements of an Endorsed Program. GHG emissions reductions must originate from projects or parts of projects that meet the principles and criteria contained in the Green-e Climate Standard. They must meet the requirement of being real, verifiable, permanent and enforceable. They may not be claimed or registered by more than one end-user (quantified in metric tons of carbon dioxide equivalent). Green-e Climate Annual Verification Audit Instructions (Instructions): Provides instructions for Sellers in Green-e Climate on how to fill in the Worksheets and what materials to assemble for the Auditor to complete the Agreed-Upon Procedures Report. There are three different sets of Verification Worksheets for reporting supply and sales and three different corresponding sets of Audit Procedures: Set 1 - Project-specific Sales (Sales by Project) Only; Set 2 - Sales of Fixed The Green-e Climate Annual Verification Audit Overview and Provisions RY2014 Copyright © 2015 Center for Resource Solutions. All Rights Reserved. Page 16 of 25 and/or Customized Mixes Only; and Set 3 - Sales of Fixed and/or Customized Mixes AND Projectspecific Sales. Green-e Climate Annual Verification Audit Overview and Provisions (Audit Overview and Provisions): Addresses the verification reporting requirements for the Green-e Climate Program and provides general background and instructions for completing the Green-e Climate Verification Audit Agreed-upon Procedures (“Audit Procedures”), which are included as a separate document. Green-e Climate Annual Verification Submission (Annual Verification Submission): The collected, completed and audited documents required to be submitted annually to the Center for Resource Solutions as part of the requirements of Green-e Climate certification. These documents include: The Agreed-Upon Procedures Report, all completed Worksheets and all documents required by the Checklist. Green-e Climate Code of Conduct: The Green-e Climate Code of Conduct contains the Ethical Guidelines, Certification Categories, and Disclosure & Verification Requirements that apply to sellers of Green-e Climate Certified Offsets. Green-e Climate Standard: The governing document for Green-e Climate, the Green-e Climate Standard details the principles for Green-e Climate, as well as the criteria the Endorsed Programs must meet. It is available on the Green-e Climate Web site at http://www.greene.org/getcert_ghg_standard.shtml. Individual Customer: A residential purchaser of Certified Carbon Offsets. LEED Certification (Leadership in Energy and Environmental Design Certification): A green building standard administered by the U.S. Green Building Council. Low Impact Hydropower Institute (LIHI): The Low Impact Hydropower Institute is a national nonprofit organization dedicated to reducing the impacts of hydropower generation through the certification of hydropower projects that have avoided or reduced their environmental impacts pursuant to the Low Impact Hydropower Institute’s criteria. Multi-year Purchase Agreement: A purchase agreement or contract for the purchase of Green-e Climate Certified Offsets for more than a single year. Offline Sales: One-time sales of Green-e Climate Certified offsets not transacted via a web-based sales channel. Online Sales: Sales of Green-e Climate Certified Offsets transacted via a web-based sales channel. Offset Card: A pre-printed, single-denomination (uniform quantity and type of product) card (need not be in actual card form) used for in-person, over-the-counter offset transactions. Project Type: The type of resource used to create emissions reductions (including but not limited to renewable energy, energy efficiency, landfill gas methane destruction, forestry, etc). A list of eligible project types is available on the Green-e Climate Web site at http://www.greene.org/getcert_ghg_endorsed.shtml. The project type for each Certified Offset is found on the Carbon Offset Content Label for fixed mix or customized mix offsets, or on the Project Information for offset sales by project. Registry: An electronic system for issuance, tracking, trading, and retirement of GHG emissions reductions and emissions reduction credits. The Green-e Climate Annual Verification Audit Overview and Provisions RY2014 Copyright © 2015 Center for Resource Solutions. All Rights Reserved. Page 17 of 25 Reporting Year (RY): The reporting year is the period beginning January 1 in the sales year being reported or the date the Seller began selling Certified Offsets and ending on December 31 of that year. Reporting Year 2014 Annual Verification Submission Timeline and Deadlines (Verification Timeline): A document provided to Sellers that details the timeline, due dates and late fees associated with preparing and submitting all verification materials in Reporting Year 2014. Retirement: The process for setting aside, designating or allocating specific emissions reductions in a registry to ensure that said emissions reductions can no longer be traded. Specific processes and terminology regarding retirement will vary by registry, and more specific instructions for what constitutes appropriate retirement in a given Approved Registry can be found in Appendix C. Sales by Fixed and Customized Mix Products (Mix Sales or Sales of Mix Products): Carbon offsets sold in a combination of project type, location, and Endorsed Program. See Fixed Mix and Customized Mix. Sales by Project (Project-Specific Sales): Greenhouse gas emissions reductions from specific eligible projects that are sold to customers based on their preference. Seller: An entity offering Green-e Climate Certified carbon offsets to customers. Third-party Distributor: A company that sells Certified Offsets without any direct relation to procurement of supply of GHG emissions reductions, but rather through an arrangement with a Seller of a Certified Offset. Transaction Type (Sales Channel): Certified Offsets can be sold online, offline, through multi-year purchase agreements, and through automatically recurring purchases. Transfer: The process by which an account holder in a registry delivers specific emissions reductions from its registry account to the separate registry account of another party. The specific processes for transfers, the terminology and the documentation required for Green-e Climate verification with respect to such transfers may vary by registry, and more registryspecific instructions on this topic can be found in Appendix C. Using Registries in Green-e Climate Annual Verification: This document details the requirements for using registries to substantiate ownership of emissions reductions. It is available on the Green-e Web site at http://www.green-e.org/climateverification and is included with the verification materials sent to Sellers each year. It is also included as Appendix C of this document. Verified Carbon Standard (VCS): The VCS is a standard for voluntary GHG emissions reduction and removal projects and their validation and verification. The VCS program is managed by the VCS Association which is an independent, non-profit organization. The VCS is an Endorsed Program under Green-e Climate. Vintage: The date or time period that the emissions reduction was generated or created. Wholesale Customer: A company that buys emissions reductions from a Seller with the intension of reselling them to another wholesale or retail customer. Wholesale Supplier: A company that sells emissions reductions to a Seller of emissions reductions that intends to resell them. The Green-e Climate Annual Verification Audit Overview and Provisions RY2014 Copyright © 2015 Center for Resource Solutions. All Rights Reserved. Page 18 of 25 APPENDIX B: DESCRIPTION OF DOCUMENT TITLES AND OTHER INFORMATION NEEDED BY THE AUDITOR The following is a list of information that Sellers need to provide to their Auditor and should be tailored to each particular engagement as reports and information will vary. a. Internal Reporting Documents that Indicate Sales (“internal reporting documents”), which is any report from the Seller that contains the detail of sales per customer for Certified Sales and that was used to complete the Worksheets. These documents will indicate sales made in RY2014, and could include amounts of Certified Offsets delivered in RY2014 under multi-year agreements that were entered into in previous RYs. The Auditor will need to have the data sorted by customer type, Sales by Project and Sales by Mix, and by customer location (state). See Section III of the Audit Instructions for direction on the Preparation of Internal Reporting Documents. b. Billing Statements and/or any other necessary records of individual sales (e.g. contracts, purchase agreements, invoices, receipts of purchase, etc.), and also records of delivery for offset donations; should contain the Certified Offset sales of emissions reductions by customer. These should be provided to the Auditor upon request to substantiate Internal Reporting Documents, where different. c. Registry Report: Reports generated from Sellers’ Approved Registry accounts to substantiate the retirement of eligible emissions reductions. All Sellers must follow the rules in Appendix C: Using Registries in Green-e Climate Annual Verification. d. Green-e Climate Verification Audit Agreed-upon Procedures (“Audit Procedures”): Provides instructions for the Auditor on the procedures to perform in order to verify a Seller’s annual sales and supply of eligible emissions reductions. e. Green-e Climate Annual Verification Audit Overview and Provisions (“Audit Overview and Provisions”): Addresses the verification reporting requirements for the Green-e Climate Program and provides general background and instructions for completing the Audit Procedures, which are included as a separate document. f. Green-e Climate Attestation from Program Seller signed by the Seller company for which the Audit Procedures is being conducted. It is included as Appendix D of the Instructions. g. Green-e Climate Verification Checklist (“Checklist”): This document is provided by CRS to the Seller. It contains information regarding the Certified Offsets that are subject to this verification audit, the projects that are used to supply Certified Project-specific Sales and Mix Sales, and any additional reporting requirements for the Seller. Seller should provide a copy to the Auditor. h. Green-e Climate Explanation of Exceptions Form: A written explanation of exceptions found in the Worksheets. i. Green-e Climate Verification Worksheets: A series of Worksheets to be filled in by the Seller with data from the supply for and sales of Certified Offsets that are verified by the Auditor. The Worksheets exist in three versions: For Sellers that made only project-specific sales of certified carbon offsets, use Worksheet Set 1: Project-specific The Green-e Climate Annual Verification Audit Overview and Provisions RY2014 Copyright © 2015 Center for Resource Solutions. All Rights Reserved. Page 19 of 25 Only. For Sellers that made only fixed mix and/or customized mix sales of certified carbon offsets, use Worksheet Set 2: Sales of Fixed and/or Customized Mix Only. For Sellers that made both project-specific sales and mix sales, use Worksheet Set 3: Sales of Fixed and/or Customized Mix AND Project-specific Sales. j. Carbon Offset Content Label (“COCL”): For sales of Fixed Mix and Customized Mix offsets, the disclosure to customers of the mix of resources used to supply a Certified Mix Product for RY2014. COCLs submitted to the auditor should be those used in RY2014, not necessarily the COCLs that are current at the time of the audit (if different). If the Certified Mix Product(s) was changed during the RY, all COCLs used in the RY should be submitted. k. Project Information Disclosure: For sales of Certified Offsets by project (“Project-specific Sales”), Seller must disclosure to customers specific information on the individual project(s) used to supply the specific quantity of Certified Offsets including, but not limited to, the project name, project type, project location, and vintage year of reductions purchased. l. Offset Card(s): A copy of each card active in RY2014, where applicable; one copy for each unique combination of organization type and Certified Mix Product. m. Project List: For sales of Fixed Mix and Customized Mix offsets, the list disclosed to customers of the emissions reductions projects used to supply a Certified Mix Product. The Project List should include the project name, project type, project location, project start date, vintage of GHG emissions reductions (year or range of years), Endorsed Program, and the Registry in which the project is registered. Include all projects that supplied Certified Mix Products in RY2014. The Green-e Climate Annual Verification Audit Overview and Provisions RY2014 Copyright © 2015 Center for Resource Solutions. All Rights Reserved. Page 20 of 25 APPENDIX C: USING REGISTRIES IN GREEN-E CLIMATE ANNUAL VERIFICATION In combination with Appendix C of the Audit Instructions, these requirements govern the use of Registries toward the annual verification requirements for participants in Green-e Climate. This Appendix describes the procedures to be followed by Auditors when reviewing Registry Reports. Appendix C of the Audit Instructions includes the procedures for Sellers using a Registry for sales made to a customer without a Registry account (Section I) and the procedures for Sellers using a Registry for sales made to a customer with a Registry account (Section II). I. Procedures to be Followed By Auditors When Reviewing Registry Reports A. Verification of Retirements in the American Carbon Registry This section applies to sellers making Certified Sales of eligible emissions reductions from projects certified by the American Carbon Registry. i. B. APX Gain access to Seller’s account in the APX ACR registry. Request that the Seller set-up a Login with Limited Access to View the Account. Compare information included in the Registry Report(s) provided by Seller with the actual registry account, checking both records of retirements as well as interregistry transfers. Note any discrepancies found. Ensure that all information recorded in Worksheet 1: Supply can be accurately substantiated in Seller’s registry account. For each row of Table 1 in which “ACR” is listed in column 1E and APX is listed in column 1F, ensure that the emissions reductions listed in that row have in fact been retired or transferred by Seller and that they have been entered accurately into Worksheet 1. Ensure that the following information in the Registry matches the information on the printed Registry Report: Project Name, Project Type, Vintage, Project ID, ERT Serial Numbers and Quantity of ERTs. While logged in to the Seller’s registry account, access the additional documentation associated with each ACR project in the APX registry. Ensure that that Project Location (country), and Project Start Date (year) have been listed accurately in Table 1. Verification of Retirements in a Verified Carbon Standard Registry This section applies to sellers making Certified Sales of eligible emissions reductions from projects certified by the Verified Carbon Standard. i. APX The Green-e Climate Annual Verification Audit Overview and Provisions RY2014 Copyright © 2015 Center for Resource Solutions. All Rights Reserved. Page 21 of 25 ii. C. Gain access to Seller’s account in the APX VCS registry. Request a Login with Limited Access to View the Account. Compare information included in the Registry Report(s) provided by Seller with the actual registry account, checking both records of retirements as well as interregistry transfers. Note any discrepancies found. Ensure that all information recorded in Worksheet 1: Supply can be accurately substantiated in Seller’s registry account. For each row of Table 1 in which “VCS” is listed in column 1F and APX is listed in column 1I, ensure that the emissions reductions listed in that row have in fact been retired or transferred by Seller and that they have been entered accurately into Worksheet 1. Ensure that the following information in the Registry matches the information on the printed Registry Report: Project Name, Project Type, Vintage, Project ID, VCU Serial Numbers and Quantity of VCUs. While logged in to the Seller’s registry account, access the additional documentation associated with each VCS project in the APX registry. Ensure that that Project Location (country), Project Start Date (year) and Project Verifier have been listed accurately in Table 1. Markit Environmental Registry Gain access to Seller’s account in the Markit VCS registry. Request a Login with Limited Access to View the Account. Compare information included in the Registry Report(s) provided by Seller with the actual registry account, checking both records of retirements as well as interregistry transfers. Note any discrepancies found. Ensure that all information recorded in Worksheet 1: Supply can be accurately substantiated in Seller’s registry account. For each row of Table 1 in which “VCS” is listed in column 1F and TZ1 or Markit is listed in column 1I, ensure that the emissions reductions listed in that row have in fact been retired or transferred by Seller and that they have been entered accurately into Worksheet 1. Ensure that the following information in the Registry matches the information on the printed Registry Report: Project Name, Project Type, Vintage, Project ID, VCU Serial Numbers and Quantity of VCUs. While logged in to the Seller’s registry account, access the additional documentation associated with each VCS project in the Markit registry. Ensure that that Project Location (country), Project Start Date (year) and Project Verifier have been listed accurately in Table 1. Verification of Retirements in a Climate Action Reserve Registry This section applies to sellers supplying making Certified Sales of eligible emissions reductions from projects certified by the Climate Action Reserve. i. APX The Green-e Climate Annual Verification Audit Overview and Provisions RY2014 Copyright © 2015 Center for Resource Solutions. All Rights Reserved. Page 22 of 25 D. Gain access to Seller’s account in the APX CAR registry. Request a Login with Limited Access to View the Account. Compare information included in the Registry Report(s) provided by Seller with the actual registry account, checking both records of retirements as well as interregistry transfers. Note any discrepancies found. Ensure that all information recorded in Worksheet 1: Supply can be accurately substantiated in Seller’s registry account. For each row of Table 1 in which “CAR” is listed in column 1F and APX is listed in column 1I, ensure that the emissions reductions listed in that row have in fact been retired or transferred by Seller and that they have been entered accurately into Worksheet 1. Ensure that the following information in the Registry matches the information on the printed Registry Report: Project Name, Project Type, Vintage, Project ID, CRT Serial Numbers and Quantity of CRTs. While logged in to the Seller’s registry account, access the additional documentation associated with each CAR project in the APX registry. Ensure that that Project Location (country), Project Start Date (year) and Project Verifier have been listed accurately in Table 1. Verification of Retirements in a Gold Standard Registry This section applies to sellers making Certified Sales of eligible emissions reductions from projects certified by the Gold Standard. i. Markit Environmental Registry Gain access to Seller’s account in the Markit GS registry. Request a Login with Limited Access to View the Account. Compare information included in the Registry Report(s) provided by Seller with the actual registry account, checking both records of retirements as well as interregistry transfers. Note any discrepancies found. Ensure that all information recorded in Worksheet 1: Supply can be accurately substantiated in Seller’s registry account. For each row of Table 1 in which “GS” is listed in column 1F and TZ1 or Markit is listed in column 1I, ensure that the emissions reductions listed in that row have in fact been retired or transferred by Seller and that they have been entered accurately into Worksheet 1. Ensure that the following information in the Registry matches the information on the printed Registry Report: Project Name, Project Type, Vintage, Project ID, VER Serial Numbers and Quantity of VERs. While logged in to the Seller’s registry account, access the additional documentation associated with each GS project in the Markit registry. Ensure that that Project Location (country), Project Start Date (year) and Project Verifier have been listed accurately in Table 1. The Green-e Climate Annual Verification Audit Overview and Provisions RY2014 Copyright © 2015 Center for Resource Solutions. All Rights Reserved. Page 23 of 25 APPENDIX D: AUDITOR’S ATTESTATION FOR AGREED-UPON PROCEDURES REPORT This attestation has been completed by the Auditor, in regards to the Green-e Climate Certified sales of [Seller for which Audit was Performed] (“Participant”) made in 2014. Auditor Company Name: Business Address: [Auditor Company Name] [Address of Auditor Company] AUDITOR DECLARATION I declare that I am qualified to perform the Green-e Climate audit, as I am (check one): An external auditor and CPA; or Working for the Green-e Climate Seller company whose sales are being verified and I am a Certified Internal Auditor (CIA). I did not fill in the Green-e Climate Verification Worksheets. The RY2014 version of the Green-e Climate Verification Agreed-upon Audit Procedures (“Audit Procedures”) was read and its procedures were followed with due diligence. The Green-e Climate Agreed-Upon Procedures Report was completed according to the instructions in the Green-e Climate Verification Audit Overview and Provisions (“Audit Overview and Provisions”) and the Audit Procedures, to assist the Participant (or specified parties) in complying with the annual reporting requirements of the Center for Resource Solutions’ Green-e Climate certification program for the Reporting Year ended December 31, 2014. The Agreed-Upon Procedures Report was performed in accordance with the standards established by the American Institute of Certified Public Accountants and all requirements in Section II of the Audit Overview and Procedures document. All information within the Agreed-Upon Procedures Report and in this attestation fairly represents the results of my assessment. AGREED UPON PROCEDURES REPORT SUMMARY The Green-e Climate Annual Verification Audit Overview and Provisions RY2014 Copyright © 2015 Center for Resource Solutions. All Rights Reserved. Page 24 of 25 Based on the Audit Overview and Provisions and the results of the Agreed-Upon Procedures, [Auditor Company Name] (“Auditor”) asserts that Seller has: NO EXCEPTIONS with regard to its compliance of the Green-e Climate verification reporting requirements put forth in the Green-e Climate Annual Verification Audit Instructions (“Instructions”) and Audit Procedures; -- Or -EXCEPTIONS with regard to its compliance of the Green-e Climate verification reporting requirements put forth in the Instructions and Audit Procedures, and these exceptions are listed in the Agreed-Upon Procedures Report. Signature [Date Attesation Signed] Date Signed [Name of Lead Auditor] Printed Name [Title of Lead Auditor] Title *If more than one Auditor conducted the Agreed-Upon Procedures Report (AUPR), the manager of the audit procedures should sign this Auditor Attestation. The names of those others who were involved in the AUPR may be listed below: [Names of Additional Auditors] The Green-e Climate Annual Verification Audit Overview and Provisions RY2014 Copyright © 2015 Center for Resource Solutions. All Rights Reserved. Page 25 of 25