Green Claims Policy

1. Our Green Claims Policy

Ltt Group Limited is applying to become a Certified Signatory of The Anti Greenwash Charter. We are committed to upholding the highest standards of responsible marketing and communications practice. The purpose of our Green Claims Policy (GCP) is to define the standards and practices we adopt throughout our organisation to ensure green claims made about our services, our operations, our impact, and our work with clients are accurate and substantiated.

This policy applies to all the forms of marketing and communications we use, including our website, proposals, tenders, pitch decks, brochures, email marketing, social media, events, press activity, thought leadership, case studies, sales materials, recruitment marketing, partner communications, and any other professional promotions and communications.

Where Ltt Group supports clients with sustainability communications, we will apply the standards in this policy to any green claims we draft, edit, recommend, approve, or publish on their behalf, and we will require appropriate evidence to substantiate those claims.

In addition to this policy, all marketing and communications must at all times comply with relevant laws and regulations. In the UK this includes, where applicable, the CMA Green Claims Code, consumer protection and business marketing rules, and the ASA CAP Code rules on environmental claims. We also consider international requirements where our communications reach audiences outside the UK.

As part of becoming, and remaining, a Certified Signatory of The Anti Greenwash Charter, we will participate in Campaign Reviews conducted by an independent third party. These reviews assess marketing and communications campaigns against our GCP, verifying that claims are evidence backed and responsibly communicated.

2. Definitions

Green claim

Any statement, suggestion, wording, imagery, badge, label, comparison, or overall impression that implies an environmental benefit, reduced environmental harm, or improved sustainability performance. This includes claims about carbon, net zero, climate positive, offsets, recycled content, responsible sourcing, ethical supply chains, biodiversity, waste, circularity, energy, water, transport, and environmental certifications.

Substantiation

Clear, accurate, up to date evidence that supports a claim, with boundaries, assumptions, methodology, dates, and scope stated where needed so the claim can be understood and checked.

Stakeholders

Anyone who reads, views, receives, or relies on our communications, including clients, prospective clients, candidates, partners, suppliers, employees, regulators, media, and the public.

3. Our Standards

We commit to the standards of practice set out in The Anti Greenwash Charter, which are as follows:

Transparency

We commit to clear communication of what environmental benefit our product or service offers and won't conceal or omit information.

Accountability

We substantiate our green claims with accurate, and regularly evaluated empirical evidence. We commit to sharing facts, figures and statements that can be checked.

Fairness

We commit to using fair, clear and unambiguous language when providing comparisons with other products or organisations.

Honesty

We will ensure we make specific statements about our organisation's environmental efforts and that our actions match those promises.

4. Where We Could Improve

We recognise that responsible sustainability communication requires continual improvement in both what we do and how we talk about it.

As a growing organisation, our improvement focus includes:

• Strengthening data governance so all sustainability data, calculations, and evidence are consistently recorded, version controlled, and easily auditable
• Increasing transparency on the boundaries and assumptions behind any carbon related statements, including what is included and excluded
• Improving our approach to measuring and reducing emissions associated with business travel, digital services, and supply chain purchasing
• Deepening due diligence on third parties we reference, recommend, or collaborate with, including verification of their sustainability claims where relevant
• Continuing to improve how we communicate uncertainty, limitations, and trade-offs so stakeholders are not misled by simplification

We review our progress regularly, and we update our practices and communications when we identify gaps, changes in best practice, or changes in regulation.

5. Our Practices

We implement the following practices and procedures to uphold the standards above:

• Clearly define the green terms we use
• Provide third party verified evidence for the claims we make where appropriate and proportionate
• Set standards for authentic and accurate visual representation
• Operate a clear editorial and approval process for green claims
• Train our employees so they understand greenwashing risk and how to prevent it
• Ensure responsible use of AI in content creation
• Maintain an escalation procedure for internal and external concerns
• Educate stakeholders using clear definitions and accessible evidence
• Support partners and collaborators to adopt similar standards
• Commit to regular reviews and effective governance
• Maintain strict legal compliance

6. Green Terms Glossary

We define the key green terms we use to describe our services and our sustainability work to ensure our claims are clear, consistent, transparent, and aligned with recognised best practice. If you come across a term you do not understand and cannot find in this glossary, please email info@lttgroup.uk.

7. Verified Claims Database and Evidence Access

We will only make green claims that can be substantiated. To support transparency, we maintain an internal evidence pack for all public green claims and we will provide reasonable access to supporting evidence on request, subject to confidentiality and client permissions.

On our website, we will maintain a public list of any key green claims we make about Ltt Group Limited that require formal substantiation, with links to supporting evidence where appropriate.

Where we cannot provide public evidence (for example due to client confidentiality), we will not present the claim in a way that implies independent public verification, and we will clearly explain any limitations.

8. Evidence and Substantiation Requirements

All green claims must be supported by evidence that is:

• Relevant to the claim
• Accurate, complete, and not misleading by omission
• Up to date, with dates stated where needed
• Clear about boundaries, scope, and assumptions
• Proportionate to the strength and visibility of the claim
• Stored in an evidence pack that can be audited

Evidence may include, where appropriate:

• Calculations and working papers including assumptions and emission factors
• Source documentation and supplier confirmations
• Independent certifications and audit reports
• Client approved case studies with documented outcomes and boundaries
• Policies, procedures, and governance records demonstrating implementation
• Independent third-party verification statements

We avoid absolute claims such as "zero impact", "100% sustainable", "guilt free", or "planet friendly" unless we can robustly substantiate them and explain boundaries clearly.

9. Claims Governance and Approval Rules

All external communications that include, or could reasonably be interpreted as including, a green claim must follow this approval approach:

• We define the claim and identify what the audience might infer
• We confirm the evidence exists and is current
• We check the claim is clear, specific, and not exaggerated
• We check comparisons are fair and like for like
• We add qualifiers where needed so the claim is not misleading
• We confirm the claim aligns with our glossary definitions
• We approve the claim through our editorial process before publication

Where a claim relates to carbon data or targets, we will state, where applicable:

• The organisational or service boundary covered
• The reporting period and base year if relevant
• Whether the claim covers Scope 1, Scope 2, and Scope 3
• The methodology used
• Any use of carbon credits, with clear explanation of what that means
• Any material limitations, exclusions, or uncertainties

10. Use of Imagery and Colour

In our commitment to transparent and honest communication regarding our sustainability efforts, we recognise the powerful impact of visual representation in shaping perceptions. Therefore, we uphold the following principles related to the use of imagery and colours in our marketing and communications materials:

• Authentic imagery: We commit to using genuine and representative images of our work, our initiatives, and our partners, avoiding imagery that may mislead or give an exaggerated impression of our green efforts.
• Avoidance of greenwashing through colours: The use of green or earth tones can evoke feelings of environmental friendliness. We ensure such colours are used responsibly and are not misleading. If a service, programme, or offer is represented with environmental cues, it must have substantiated credentials to back up that representation.
• Highlighting actual efforts: When showcasing sustainability projects or achievements visually, we use images from actual initiatives we have undertaken or supported, avoiding generic or unrelated imagery that may give a false sense of impact.
• Transparency in photo alteration: Any alterations that change the reality or context of our sustainability work will be disclosed where relevant.
• Educative visuals: Where possible, we use infographics and simple visuals to explain sustainability concepts, based on substantiated facts and designed to be clear without misrepresentation.
• Review process: Visual materials that relate to sustainability are reviewed as part of our editorial process for green claims.

For any concerns regarding imagery and colours used in our materials, please contact info@lttgroup.uk.

11. Editorial Processes

We operate a structured review process to reduce the risk of unsubstantiated or unclear green claims.

Minimum review standard

Every piece of external content that includes a green claim must be reviewed by two people, ideally from separate functions, before publication. At least one reviewer must be trained on this policy and the legal and reputational risks of greenwashing.

Editorial steps

1. Draft content and identify any green claims, including implied claims from visuals and overall impression
2. Link each claim to evidence in the evidence pack
3. Confirm definitions align to our glossary
4. Reviewer one checks clarity, specificity, and evidence
5. Reviewer two checks fairness, omissions, and what the audience might infer
6. If needed, escalate for leadership review or external advice
7. Approve, publish, and record in the Green Claims log with a link to evidence

We recognise and encourage staff and collaborators who challenge our green claims when they believe something is unclear, too broad, or insufficiently evidenced.

12. Training

All new employees and associates receive an induction briefing that includes:

• What greenwashing is and why it matters
• Our Green Claims Policy and approval process
• How to identify implied environmental claims in text and visuals
• How to raise concerns internally

Every year, we provide refresher training for relevant team members covering:

• Updates to regulations and best practice
• Lessons learned from reviews, queries, or escalations
• Any changes to our glossary, evidence requirements, or approval process

13. Use of AI

We may use AI tools to assist with drafting, summarising, editing, or analysing information for content creation. To maintain integrity:

• AI output is treated as a draft, not as evidence
• All AI assisted content is reviewed by human editors before publication
• Any green claim suggested by AI must be substantiated in the same way as any other claim
• We do not rely on AI generated citations or facts without checking original sources
• We disclose meaningful AI contribution where it is material to the creation of published content, where appropriate and practical
• We audit AI use periodically to confirm compliance with this policy

14. Escalation Procedure and Complaints

We recognise that our stakeholders play a crucial role in combating greenwashing. We commit to responding to emails regarding our green claims within three working days.

If a concern is raised, we will:

1. Acknowledge receipt within three working days
2. Assess the claim and review the evidence pack
3. If needed, pause or amend the content while we investigate
4. Provide a clear response, including any corrections or clarifications
5. Record the incident in our Green Claims log and implement corrective actions to prevent recurrence

15. Stakeholder Education

We aim to help stakeholders understand sustainability topics and the meaning behind the terms used in our communications. We do this by:

• Publishing our Green Claims Policy and glossary on our website
• Explaining boundaries and assumptions in case studies and reports
• Sharing clear guidance with clients and partners on responsible sustainability communications
• Using plain English to avoid unnecessary jargon and ambiguity

16. Partnerships and Collaborations

We promote responsible sustainability communications across our partners, collaborators, and supply chain. Where relevant, we:

• Share this policy with partners when entering joint communications
• Encourage partners to adopt similar standards
• Request evidence for any partner claim we reference or amplify
• Avoid endorsing claims we cannot substantiate

17. Reviews of Content

We conduct regular reviews to keep our communications accurate and up to date:

• Quarterly internal audits of key marketing and communications content that includes green claims, to confirm references and evidence remain current
• An annual review of static content such as website pages, brochures, and core documents, to ensure compliance with changes in best practice, regulation, and Charter standards

18. Legal Compliance

Our commitment to legal compliance is unwavering, particularly in relation to green claims. We maintain a compliance approach that includes:

• Training and awareness for team members involved in marketing and communications
• Pre-publication review of green claims via our editorial process
• Escalation to leadership and external support where needed for higher risk claims
• Monitoring updates to relevant guidance and regulation

19. Governance of This Policy

Accountability

The CEO of Ltt Group Limited is ultimately responsible for ensuring this policy is implemented and reviewed.

Operational responsibility

Day to day responsibility for applying the policy sits with:

• Marketing lead for publication controls and content reviews
• Service leads for ensuring evidence exists for service-related claims
• All employees and associates for raising concerns and following the process

Non-compliance

Any suspected non-compliance will be investigated promptly. Corrective actions may include content withdrawal, correction, retraining, process updates, and escalation for independent review where appropriate.

Before entering into new partnerships involving joint sustainability communications, we will share this policy with the third party to encourage adoption of similar standards.

20. Campaign Reviews

As part of our commitment to The Anti Greenwash Charter, we will engage in an ongoing audit process to demonstrate compliance with this Green Claims Policy. This involves providing evidence of effective implementation of our practices and procedures during periodic reviews conducted by an independent third party of a marketing or communications campaign.

We recognise and accept that audit reports may be appended to our Green Claims Policy for public review, ensuring an added layer of transparency and accountability. We understand that any instances of non-compliance may result in revocation of Certified Signatory status if granted.

21. Claim Verification

We recognise that independent verification of green claims is important for ensuring accuracy and credibility.

Where claims would reasonably be relied upon for commercial decisions, or where claims are high impact or high visibility, we will seek appropriate independent verification or assurance, proportionate to the claim, and we will clearly state what has been verified, by whom, and within what boundary.