← Governance framework
Trust & Verification
ESG and Impact Measurement Governance
Methodology, data sourcing and assurance for the Impact Miles Index (IMI) and any ESG claims made by ImpactMiles or its Sponsors, designed to prevent greenwashing and impact washing.
- Version
- v1.0
- Effective
- 2026-07-19
- Last reviewed
- 2026-07-20
- Next review
- 2027-07-19
- Owner
- Chief Trust Officer
- Approver
- Technology and Trust Committee
Anchored by content hashissued 2026-07-29
Payload hash
c4769be029eccfeec3cabde330b9f2a2ef751587dc1fa96fbfc0a74acee03c0aSHA-256 digest of the receipt content
Issuer AID
EP1_FGkcwfHAuih6VUzv9kgAVBvvSoaswSUao61lkxhEParty that issued this receipt
ImpactMiles handle
audit:governance:c4769be029eccfeeThis receipt is anchored by content hash. A resolvable credential SAID is not available for this record.
Applies to
- IMI calculations and public displays
- Sponsor and Charity impact claims routed through the platform
- External reports and marketing collateral referencing impact metrics
Jurisdictions
- Hong Kong (PDPO, IRD s.88)
- United Kingdom (UK GDPR, DPA 2018)
- European Union (GDPR)
- Singapore (PDPA)
- Australia (Privacy Act 1988)
- Japan (APPI)
- Wider APAC per country taxonomy
How this is applied in-product
- Deterministic IMI computation from ACDC-anchored evidence
- Signal weights published on /trust and version-controlled here
- Independent annual review of the IMI methodology
- Rejection of unverifiable ESG claims in Sponsor onboarding
1. IMI Signals and Weights
- Volume - number and value of verified actions, drawn from acdc_credentials.
- Inclusion - diversity of participants and beneficiaries by taxonomy tags.
- Retention - repeat participation across periods.
- Reach - verified downstream engagement with capped weighting to discourage vanity metrics.
- Weights are published, version-controlled and changed only by Board-approved amendment.
2. Data Sources and Validation
- Primary source: KERI-anchored ACDC evidence with SAID chain integrity.
- Secondary source: platform records reconciled quarterly against the TAS ledger.
- Manual overrides require two-person approval and a rationale entered in the audit log.
3. Assurance
Annual independent review of the IMI methodology and a sample audit of published claims. Findings and management responses are summarised in the annual Transparency Report.
4. Greenwashing and Impact-Washing Controls
- Sponsors may only publish impact claims that reference an anchored SAID.
- Aggregate claims must disclose the underlying methodology and time period.
- Comparative language ("leading", "largest") requires evidence retained on file.
5. Change Control
Material changes to signals, weights or definitions require Board approval and are announced at least 30 days before taking effect.
Questions or concerns about this policy? Contact the DPO.