Procedures Management Policy

1. Introduction

This document (“Policy”) outlines the principles and operational standards governing procedure management at Origin Ledgers. It is designed in alignment with the ISO 9001:2015 quality management standard, which forms the basis for our internal quality system. By adopting ISO 9001:2015, we reaffirm our commitment to maintaining best-in-class governance, standardization, and process control across every aspect of the Trade Room's lifecycle—from emissions auditing and stakeholder engagement to the development and enforcement of methodologies.

2. Scope

For the purposes of this Policy, a Procedure is defined as a documented, approved, and maintained set of instructions that provides a standardized method for performing a task, operation, or process within the organization. Procedures are central to achieving consistency, reproducibility, and traceability across all areas of Carbon Trade AG’s Trade Room registry and organizational functions.

This Policy applies to all departments and personnel involved in the development, implementation, or oversight of procedures that relate to:

• The administration and operations of the Trade Room’s registry
• The development, maintenance, and application of the Trade Room’s registry, methodologies, and supporting technical documentation
• Project validation and verification workflows
• Supplier and customer onboarding and management
• Internal quality audits and risk management
• Technical system design, including MRV and registry infrastructure
• Communications and external stakeholder engagements

All procedures are to be developed, reviewed, and managed in accordance with the principles and requirements of ISO 9001:2015, ensuring that quality objectives, documentation control, and feedback mechanisms are embedded throughout the lifecycle of each process.

3. Development of Procedures

At Origin Ledgers, the development of internal Procedures follows a structured and methodical process designed to uphold quality, consistency, and compliance across all registry operations. Each procedure is developed in accordance with the principles and requirements of ISO 9001:2015, ensuring alignment with our organizational objectives, stakeholder expectations, and the evolving needs of the voluntary carbon market.

The process of procedure development incorporates the following core elements:

• Identification of External and Internal Context
  
  Origin Ledgers systematically identifies and evaluates internal and external factors that may influence our ability to achieve quality objectives. This includes legal, technological, regulatory, environmental, and organizational developments, as outlined in Section 4.1 of ISO 9001:2015. These insights inform the design of robust, adaptive processes.
• Consideration of Interested Parties
  
  We continuously monitor and assess the expectations and requirements of stakeholders, including Account Holders, validation and verification bodies, scientific advisors, corporate buyers, and regulatory authorities. Their input helps shape procedure design and scope, in accordance with ISO 9001:2015 Section 4.2.
• Determination of Scope and Applicability
  
  Each procedure is developed with a clearly defined scope that reflects its boundaries, responsibilities, and operational context. Scope determination is informed by stakeholder needs, risk assessments, and the strategic objectives of the Trade Room registry, as referenced in Section 4.3 of ISO 9001:2015.
• Process Identification, Implementation, and Improvement
  
  Origin Ledgers identifies all necessary quality-related processes and integrates them into the broader quality management system. We ensure each process is defined, documented, implemented, and periodically reviewed for effectiveness and compliance. Opportunities for improvement are identified and acted upon in line with Section 4.4 of ISO 9001:2015.

This framework ensures that procedures are developed not only to meet current operational needs, but also to anticipate future requirements, maintain stakeholder confidence, and uphold the scientific and regulatory credibility of the Trade Room registry.

4. Documentation and Accessibility

To ensure that internal procedures and related documentation are well-governed, consistently formatted, and readily accessible to authorized personnel, Origin Ledgers adheres to the following documentation management principles, in alignment with ISO 9001:2015 requirements:

• All procedures are documented using a standardized format, incorporating input from relevant stakeholders including internal subject matter experts, operational teams, external partners, and, where applicable, scientific or regulatory advisors. This inclusive approach ensures procedural relevance, clarity, and operational alignment.
• Each document is formally reviewed and approved by designated leadership within the responsible department or the Governance Team prior to finalization. Approval records and version histories are maintained to ensure traceability and control.
• Finalized procedures are stored in a centralized, secure, and accessible digital repository. COrigin Ledgers uses modern documentation management systems to ensure version control, auditability, and appropriate access restrictions based on user roles and responsibilities.
• Access to procedural documentation is granted based on employee role, function, and level of responsibility, while promoting a culture of transparency and knowledge sharing.

Unless a procedure is classified as confidential or sensitive, staff are encouraged to make documents visible across departments to enable cross-functional learning and consistency in implementation. This structured documentation framework supports the Origin Ledgers’ mission to maintain operational clarity, facilitate continuous improvement, and uphold procedural integrity across all facets of platform and organizational activity.

5. Training and Communication

To ensure that all personnel at Origin Ledgers are equipped to implement and uphold the organization’s documented procedures, a structured approach to training, communication, and procedural awareness is maintained across the organization. These measures are aligned with ISO 9001:2015 requirements on competence, awareness, and communication, and are integral to preserving the scientific and operational rigor of the Trade Room registry.

• All employees receive role-specific training to understand and adhere to approved procedures. New team members are provided with core documentation and onboarding resources upon joining, and are required to complete assigned learning modules within a defined period. Ongoing training and refresher sessions are delivered in accordance with the needs of each function.
• Origin Ledgers maintains clear and structured communication channels to disseminate procedures, updates, and related policy information. Internal communication tools and knowledge sharing platforms are used to ensure timely, accessible, and consistent distribution of procedural guidance to all relevant personnel.
• Regular feedback loops are established to promote open dialogue regarding the clarity, effectiveness, and implementation of procedures. Team leads conduct periodic internal reviews, workshops, or Q&A sessions to evaluate procedural compliance and address practical challenges experienced by staff.
• In support of continuous improvement, employees are encouraged to identify and report any deviation from best practice, outdated instructions, or operational inefficiencies related to procedural execution. In the first instance, such issues should be raised with the appropriate line manager. Where this is not feasible or appropriate, employees may escalate concerns directly to the Head of Compliance, the Head of Policy, or the Chief Executive Officer.

This culture of procedural ownership and feedback ensures that Origin Ledgers maintains not only compliance, but also a dynamic and collaborative environment where high standards are upheld and improved through shared responsibility.

6. Quality Control Mechanisms

To ensure effective implementation, enforcement, and continuous improvement of its operational procedures, Origin Ledgers has established a suite of quality control mechanisms aligned with the principles and requirements of ISO 9001:2015.

These mechanisms safeguard the integrity of processes across the organization, with particular emphasis on the delivery, governance, and security of the Trade Room registry, as well as related standards and services. Origin Ledgers maintains and enforces the following quality controls:

• Documented Information
  
  In accordance with Clause 8 of ISO 9001:2015, Origin Ledgers determines, maintains, and retains documented information necessary to demonstrate conformity to product, service, and regulatory requirements. This includes process records, audit trails, verification protocols, and approval documentation across all registry operations.
• Document Control
  
  All procedural documents, protocols, and registry specifications are managed in compliance with Clause 7.5 of ISO 9001:2015, ensuring appropriate versioning, authorship, accessibility, and format control. Change logs and approval histories are maintained to support transparency and internal auditability.
• Operational Planning and Control
  
  Origin Ledgers implements comprehensive process planning, risk management, and performance monitoring in alignment with Clauses 6.1 and 8.1 of ISO 9001:2015. Operational planning is based on risk based thinking and includes mitigation strategies for key areas such as regulatory compliance, cybersecurity, credit issuance integrity, and stakeholder service delivery. 

Internal design and development processes are applied to the Trade Room registry, including associated standards, methodologies, and supporting tools. These processes are governed by documented procedures that align with the Trade Room and its normative framework. 

Products and services are released through a planned and staged approval process, ensuring that all system functions, protocols, and methodologies meet internal quality benchmarks as well as any applicable external legal or regulatory requirements. Documented release notes and compliance checks are retained at each stage. 

In cases where Origin Ledgers integrates externally sourced systems, tools, or services into its operations, a technical and cybersecurity risk review is conducted. This includes vendor assessment, interface security testing, and assurance of functional compatibility with registry protocols. 

Customer communication processes are standardized to ensure transparency, responsiveness, and clarity. This includes defined channels for providing information about products and services, managing stakeholder inquiries or contractual matters, and securely handling any client data or digital assets entrusted to the Registry.

Through this integrated quality control system, Origin Ledgers ensures that all aspects of the Trade Room’s registry—technical, procedural, legal, and strategic—are managed under a framework of continuous improvement, operational integrity, and demonstrable compliance.

7. Continuous Improvement

Origin Ledgers is committed to the continuous improvement of its quality management system (QMS), procedures, and operational processes to ensure that the Trade Room registry remains credible, transparent, and responsive to stakeholder expectations and regulatory developments.

Improvement is embedded into our governance framework and supported by regular internal reviews, stakeholder engagement, and structured feedback mechanisms. All procedures, quality controls, and service delivery processes are evaluated periodically for their effectiveness, efficiency, and alignment with the organization’s strategic direction. Senior leadership maintains full accountability for the QMS and is responsible for promoting a culture of quality and continuous learning across all divisions. Leadership ensures that all policies and procedures are consistently applied, regularly reviewed, and aligned with both Origin Ledgers’s mission and external standards, including ISO 9001:2015.

Team leads conduct scheduled project and policy evaluations—referred to internally as “retrospectives”—to assess implementation quality, identify any nonconformities or inefficiencies, and recommend corrective or preventive measures. These recommendations are reviewed by the Governance Team and, where appropriate, approved for immediate implementation. In line with our commitment to transparency and accountability, Origin Ledgers actively welcomes feedback from internal and external stakeholders, including Account Holders, VVBs, project managers, partners, and regulators. Feedback may address the clarity, accessibility, or impact of any policy or procedure. All submissions are assessed by the Quality or Legal teams and responded to in a timely and appropriate manner. Stakeholders are encouraged to submit comments, concerns, or improvement suggestions to: legal@originledgers.com

Through these mechanisms, Origin Ledgers ensures that its systems not only meet current quality benchmarks but evolve to reflect emerging risks, stakeholder needs, and global best practices.