Market Integrity & Transparency Policy

Our position

Environmental certificates only have value if the market behind them is clean.
Integrity isn’t a slogan for us — it’s the operating system.

This policy explains how we trade, what we disclose, what we never conceal, and how we protect the credibility of every certificate that passes through our hands.


What “market integrity” means to us

It means:

  • following market rules and registry procedures exactly
  • no artificial price manipulation
  • no misrepresentation of certificate type, origin, or eligibility
  • no “special treatment” for counterparties
  • no hidden margins or side arrangements
  • no selective disclosure that tilts the market
  • no trading behaviour that would embarrass a regulator

It’s straightforward: honesty creates liquidity. Everything else destroys it.


Our trading principles

Whenever we execute a trade, we follow these five commitments:

1. Price clarity

We state upfront what the price is, what it covers, and what it doesn’t.
No fuzzy rounding. No surprise add-ons.

2. Accurate product representation

REGOs, RGGOs, GOs, I-RECs — whatever the instrument, we describe:

  • technology
  • country
  • period
  • volume
  • eligibility
  • sustainability tags (where applicable)

Exactly as recorded in the registry. No embellishments. No shortcuts.

3. Clean flow of certificates

We only trade:

  • certificates held in compliant registries
  • certificates we can legally transfer
  • certificates with provenance we can verify

Nothing speculative. Nothing “off ledger.” Nothing without a traceable chain.

4. Fair dealing

We treat all counterparties consistently.
We do not:

  • set different prices based on insider information
  • favour one buyer over another in a way that distorts the market
  • engineer scarcity
  • distort timing to extract advantage

5. Record-keeping that stands up to scrutiny

We maintain clear audit trails of:

  • offers
  • acceptances
  • transfers
  • settlements
  • supporting documentation

If a regulator ever knocked, we wouldn’t need to tidy the room first.


Transparency commitments

We believe clarity increases confidence, which increases liquidity.
So we maintain:

1. Transparent fee and margin structure

We show counterparties:

  • what they are paying
  • what we earn
  • what is included
  • what is optional

No hidden brokerage. No concealed spreads.

2. Trade confirmations that are painfully clear

Each confirmation includes:

  • product
  • period
  • volume
  • price
  • registry
  • delivery method
  • settlement terms

If anything is unclear, it’s rewritten.

3. Clear counterparty communication

We share material information that affects:

  • eligibility
  • availability
  • timelines
  • regulatory changes
  • market constraints

We do not hoard information to manipulate outcomes.


What we never do

Just to remove all doubt:

  • we never “front run” or trade on private order flow
  • we never promise allocations we can’t deliver
  • we never mislabel origin or technology type
  • we never buy for resale without telling you
  • we never engage in wash trades or artificial volume
  • we never set prices to send false market signals
  • we never structure trades to avoid registry oversight

If a behaviour feels like something you shouldn’t read aloud in front of a regulator, we don’t do it.


Handling of errors or discrepancies

Certificate data errors happen.
What matters is how they’re handled.

When issues arise, we:

  1. Acknowledge the problem immediately
  2. Investigate the source
  3. Correct it transparently
  4. Notify affected counterparties
  5. Fix the underlying process so it doesn’t repeat

We don’t bury mistakes; we disinfect them.


Monitoring and audits

We run internal checks on:

  • trade execution
  • settlement timelines
  • registry activity
  • counterparty records
  • approvals
  • staff activity

We also welcome periodic external audits.
A clean business doesn’t fear someone looking under the hood.


Reporting concerns

If you see anything that looks like manipulation, misrepresentation or misuse of certificates:

Email: compliance@energymarketingandtrading.com
Anonymous channel: [link]

Every concern is reviewed.
Retaliation is prohibited.


Why this matters for the sector

Environmental markets are fragile.
One sloppy actor can undermine confidence across the board.

We choose to be the counterparty you never have to second-guess — the one you hope takes the other side of your trade, because you know exactly how we operate.

Integrity is good ethics.
But more importantly: integrity is good business.

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