Engagement
How the work is done, and where it stops.
Every engagement opens with the diagnostic, so the first scope is small and the second is informed.
The sequence
One gate, then a choice.
The diagnostic is not a proposal in disguise. It ends with a written answer, and you are free to stop there.
Work opens with a diagnostic. Scoping anything larger before the exposure is known produces a proposal that neither side can price honestly, and the diagnostic is deliberately small enough that a client can stop after it. Fixed fee where the scope allows one, day rate where it does not, basis agreed before work starts. The same practice carries it end to end, and where a specialist is brought in the client is told who that is and what they are doing before the work starts.
Independence
Two companies, two contracts.
Carbon Mandate Ltd is a separate company under common ownership with VICTROQUEST LIMITED. It prepares recurring CBAM compliance files, which is work this practice neither performs nor invoices for. Where a diagnostic points a client towards that work, the referral is made in writing, Carbon Mandate contracts the client directly, and no fee passes between the two companies for the introduction. The ownership is stated here, on the about page, and in the footer of every page, because a disclosure a reader has to hunt for is not a disclosure.
What we do not do
The boundary is part of the advice.
That paragraph carries more weight than anything else on this site. Two of the three sentences describe activities that are regulated in the United Kingdom, and the third describes a role that would change this practice's own legal position inside a client company.
We do not arrange finance, place capital, or introduce investors. We do not represent clients before regulators or customs authorities. We do not hold board positions or exercise decision authority in client organisations.
Where the question falls outside what this practice does, you will be told that rather than sold something else.
Why each line is there
- Arranging deals in investments is a regulated activity under article 25 of the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001. Section 19 of the Financial Services and Markets Act 2000 is the general prohibition on carrying one on without authorisation, and section 23 makes contravening it an offence.
- A person in accordance with whose directions or instructions the directors of a company are accustomed to act is a shadow director under section 251 of the Companies Act 2006, and carries a director's duties without holding the office. The same section excludes advice given in a professional capacity, which is the line this practice stays on the right side of by never taking a seat or a decision.
Controls
Written down before you ask.
- Confidentiality
- Written confidentiality terms in every engagement letter, surviving the end of the engagement.
- Conflicts
- A conflicts check before an engagement is accepted, covering the client, its European counterparties and any competitor already advised.
- Anti-bribery
- An anti-bribery and anti-facilitation position consistent with the Bribery Act 2010. Section 7 makes a commercial organisation liable where an associated person bribes on its behalf, and the defence is adequate procedures, so the procedures exist in writing.
- Data
- Enquiry data handled under the UK General Data Protection Regulation. Nothing sent through the enquiry form is written to a database.
Contact
Send the request your European customer made and a description of what you manufacture.