Earthmark Business Environmental Scores For Brands

Conflict of Interest Policy

Version 1.0

Last updated: 01 September 2026

1. Purpose

Earthmark is committed to producing independent, impartial, and trustworthy sustainability insights. This Conflict of Interest (CoI) Policy explains how we identify, disclose, and manage conflicts of interest to protect the integrity of our Earthmark scores and methodology.

As an aggregator of company‑level environmental and governance performance data, Earthmark’s credibility depends on the perceived and actual independence of our benchmarking and ratings. This policy safeguards that independence.

Earthmark is a UK‑based company with a current geographic focus on the UK market. In line with our size and operating context, we align to the UK Competition and Markets Authority (CMA) Green Claims Code and the UK Advertising Standards Authority (ASA) anti‑greenwashing regulations. With an eye on future geographic expansion and transparency best practices, we also align with requirements under the European Union (EU) Empowering Consumers for the Green Transition (EmpCo) Directive and the EU Green Claims Directive (ECGT) to support clients serving EU consumers, as well as the United States (US) Federal Trade Commission (FTC) Green Guides, and are adopting best practices aligned to the new EU ESG Ratings Regulation (ESGR) for ratings transparency and governance, proportionate to our current scale.

2. What Is a Conflict of Interest?

A conflict of interest arises when an individual’s outside personal, professional, or private interests could compromise, or be perceived to compromise, their judgment, decisions, or actions in their work for Earthmark.

We recognise three types of conflict:

Actual: A real conflict between an individual’s Earthmark responsibilities and their outside interests.
Perceived: An unbiased observer could reasonably conclude that outside interests might influence decisions or actions.
Potential: There is some probability that outside interests could conflict with or influence decisions now or in the future.

The existence of a conflict does not imply wrongdoing. Our aim is to ensure that any conflicts are proactively disclosed and managed to safeguard the integrity and impartiality of Earthmark’s decision‑making.

3. Organisational Safeguards

To protect rating integrity, Earthmark maintains the following safeguards:

Functional separation of decisions. Although Earthmark is currently a small team (2 FTE) and cannot fully separate commercial and methodology staff organisationally, rating and methodology decisions are made independently of commercial considerations. Commercial activities (e.g., partnerships, sales) do not determine individual company ratings, scores, benchmarking position, or methodology design. Earthmark’s Advisory Board provides independent oversight of methodology, governance, and conflict handling to support this separation.

Independent decision‑making: Ratings decisions are made by trained analysts following documented methodologies. No rating or methodology change is made in exchange for payment, commercial benefit, or at the request of a rated company or partner.

No paid influence: Earthmark does not accept payment from companies to influence their ratings, scores, benchmarking position, or methodology. Companies cannot pay to improve their Earthmark or related insights.

Examples of potential conflicts. To illustrate the types of situations we guard against:

A brand requesting preferential treatment, higher scores, or altered benchmarking in exchange for partnership, promotion, or payment.
A marketplace or retailer seeking to promote certain brands on Earthmark in return for commercial benefits.
Any attempt by a rated company to “claim” or control its Earthmark page in a way that influences the rating or methodology.

In all such cases, Earthmark will not alter ratings, benchmarking, or methodology in exchange for commercial benefit. Any such approaches are logged and managed under this policy.

Access controls and review: Access to rating models, data, and override functions is restricted to authorised personnel. All rating changes are logged and subject to internal review, with additional oversight as the team scales.

Roadmap for structural separation: As Earthmark grows, we will implement formal organisational separation between ratings/methodology and commercial functions, in line with ESGR expectations and best practice.

Independent oversight. Earthmark has established an Advisory Board of industry experts to provide independent oversight of methodology, governance, commercial engagements, and conflict handling (see Section 4.1).

4. Disclosure and Management

All individuals involved in Earthmark’s rating activities (employees, contractors, advisors, Advisory Board members, and board members) are required to:

Disclose any financial, professional, or personal interests that could reasonably be perceived as a conflict of interest.
Update their disclosures promptly if circumstances change.
Recuse themselves from relevant discussions or decisions where a conflict exists.

Disclosed conflicts are assessed by Earthmark’s compliance function and managed proportionately. Management measures may include recusal from specific decisions, role adjustments, enhanced monitoring, or, in significant cases, divestment of financial interests or termination of external roles.

A central register of disclosed conflicts and management actions is maintained and reviewed by senior leadership.

4.1 Advisory Board and Conflicts of Interest

Earthmark has established an Advisory Board of industry experts with cross‑industry experience in sustainability, data, and consumer protection. The Board provides independent oversight and guidance on:

Earthmark’s approach, governance, and methodology for data collection and scoring.
Operational processes and procedures, including quality assurance and complaints handling.
Commercial client engagements and conflict handling/resolution.
External communications and the output of insights.
Overall strategic direction to ensure alignment with industry best practices and emerging regulatory expectations (including ESGR, EmpCo, and ECGT).

Time commitment and independence. The Board meets quarterly (approximately one hour per quarter) and may provide additional async feedback on key materials. Board members serve in an unpaid, pro‑bono capacity and are expected to act independently of any single client, brand, or commercial interest.

Advisory Board members and conflicts. Advisory Board members are subject to this Conflict of Interest Policy. They must disclose any actual, perceived, or potential conflicts (e.g., significant relationships with rated companies, marketplaces, or competitors) and may be recused from relevant discussions or decisions where a conflict exists. Disclosed conflicts and any management actions are recorded in Earthmark’s conflict register. The Advisory Board receives high‑level summaries of conflict trends and significant cases as part of its oversight of governance and conflict handling.

5. External Relationships

Earthmark applies conflict of interest considerations to our external relationships, including funders and investors, data providers and third‑party certifiers, research partners and consultancies, and any parties that might seek to influence our ratings, benchmarking, or comparative insights.

Where an external relationship could reasonably be perceived to influence ratings, we will disclose the nature of the relationship and any safeguards in place.

6. Reporting a Concern

We encourage employees, rated companies, consumers, and partners to report any threat to the independence and impartiality of Earthmark ratings, including concerns about conflicts of interest.

How to report: Concerns can be raised by emailing hello@earthmark.io.
What to include: Please describe the concern, the individuals or decisions involved, and any supporting information.
What happens next: Reports are acknowledged within five (5) business days and investigated in accordance with our internal complaints and review process.

We treat all reports seriously and confidentially, to the extent permitted by law.

7. Record Retention

Conflict of interest declarations and related records are retained for a minimum of 5 years, supporting EmpCo and ECGT transparency standards and proactively aligning with ESGR record‑keeping requirements.

8. Review and Updates

This policy is reviewed at least annually, or sooner if: