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ESG Policy (Environmental, Social & Governance)

  1. Introduction
    1. This Environmental, Social and Governance policy (this “Policy”) sets out Cloverum’s principles, controls and disclosures framework for ESG matters in the context of our current and future crypto-asset services. It should be read together with our Terms & Conditions and other published policies (including Privacy and AML/CFT), as amended from time to time.
    2. Purpose of publication. This Policy explains how we address ESG topics proportionately to our business model, risk profile and regulatory obligations, and how we will produce crypto-asset sustainability disclosures once authorised and our data feed is activated. Cloverum has applied to the Cyprus Securities and Exchange Commission (CySEC) for authorisation as a Crypto-Asset Service Provider (“CASP”). Until authorisation is granted, we do not provide regulated services and any per-asset sustainability pages may contain placeholders and explanatory notes.
    3. No advice. Nothing in this Policy constitutes legal, tax, financial or investment advice or a solicitation to engage in any transaction. Users and stakeholders should obtain independent advice where appropriate.
  2. Purpose & Scope
    1. Purpose. This Policy defines our ESG governance approach, processes and minimum disclosure standards for crypto-asset sustainability reporting under Regulation (EU) 2023/1114 on Markets in Crypto-assets (“MiCA”). It also sets out the internal approval and publication controls applied to ESG-related information.
    2. Scope of application.
      1. Corporate scope. Cloverum’s own operations (e.g., premises, staff practices, vendor selection, information security) and the public disclosures we make on our website and platform.
      2. Service scope. Upon CASP authorisation and onboarding of data providers, our in-scope crypto-asset services and any asset-level sustainability disclosures we publish for those assets.
      3. Affiliates. Where an affiliated entity is authorised to provide CASP services, this Policy (or a substantively equivalent policy) will apply to that entity, with adaptations for local legal requirements.
    3. Relationship to other documents. This Policy complements, and does not override, our Terms & Conditions and internal policies (e.g., Privacy; AML/CFT; Information Security). In case of inconsistency, applicable law and regulatory requirements prevail.
    4. Change control. The Board approves material changes to this Policy. Compliance maintains and updates it and ensures updates are reflected on our website. Public ESG text follows a two-person check, with basic incident/correction logs. AML/CFT, ethics, conflicts, GDPR and information security are governed by our dedicated policies.
  3. Regulatory Context
    1. Primary framework.We align our sustainability disclosures with MiCA and the related EU delegated acts and regulatory technical standards (RTS) issued by the competent EU authorities (including ESMA). For each in-scope crypto-asset we will disclose the six climate and environmental indicators specified under MiCA/ESMA (energy consumption, renewable energy share, energy intensity; Scope 1 and Scope 2 greenhouse-gas emissions; and GHG intensity per validated transaction), as further detailed in Section 7 (MiCA Sustainability Indicators).
    2. Methodologies and sources.We will base per-asset indicators on transparent, independently developed methodologies provided by reputable third-party data providers and/or recognised public sources. Where estimates are used (e.g., due to missing background data), they will be labelled clearly and updated promptly when final data becomes available.
    3. Proportionality and consistency.Disclosures are prepared on a consistent basis (definitions, units, timeframes) and in a manner proportionate to Cloverum’s scale and services, with safeguards against selective reporting or greenwashing.
    4. Without prejudice.This Policy operates without prejudice to other applicable EU/Cyprus regimes relevant to our operations (e.g., GDPR, AML/CFT, transfer-of-funds obligations) and any future ESG-related frameworks that may apply to Cloverum. We will review and update our disclosures if and when such frameworks become applicable.
  4. ESG Principles
    1. Materiality & Compliance.We focus on ESG topics that are material to Cloverum’s business model and risk profile and required by applicable law and regulation, including MiCA.
    2. Transparency & Comparability.We use clear definitions, units and reference periods; provide prominent caveats for estimates and methodology limits; and maintain consistency across assets to facilitate comparison.
    3. Proportionality & Prudence.Commitments are calibrated to our size, operating model and maturity. We avoid statements that are not supported by robust evidence or that could mislead stakeholders.
    4. Continuous Improvement.We review and enhance our ESG controls and disclosures as regulation, methodologies and data quality evolve, and as Cloverum’s operations scale.
    5. Integrity & Anti-Greenwashing.We present balanced information and avoid absolute environmental claims (e.g., “carbon neutral”) unless substantiated by auditable evidence. Estimates are clearly labelled and replaced when final data becomes available.
  5. Environmental (E)
    1. Approach.As a lean, service-based organisation, Cloverum aims to minimise its operational footprint through prudent office energy practices, reasonable travel policies, and the use of efficient cloud and vendor solutions with sound environmental controls.
    2. Operational measures.We seek to: (a) reduce avoidable energy use in premises; (b) prefer virtual meetings and efficient travel where proportionate; (c) apply information-security and cloud-efficiency practices that indirectly reduce environmental impact; and (d) consider environmental performance when selecting material suppliers.
    3. Data-driven disclosures.For in-scope crypto-assets, we will publish the six MiCA indicators based on transparent, independent methodologies and reputable sources (see Sections 7–9). Where background data is missing, we may use labelled estimates and will update promptly when final data becomes available.
    4. Claims & marketing controls.Environmental statements in public materials (including website copy and marketing) follow the internal approval flow noted in Section 2.4 to ensure accuracy, proportionality and appropriate disclaimers.
  6. Social (S)
    1. People & inclusion.Cloverum supports fair employment practices, equal opportunity, non-discrimination and a safe, respectful workplace environment, consistent with applicable Cyprus and EU law.
    2. Learning & awareness.Staff receive role-appropriate training (e.g., compliance, data protection, information security and ESG disclosure awareness). Training completion and refresh cycles are recorded.
    3. Stakeholder engagement.We maintain accessible channels for ESG-related questions and complaints (see Section 9). Feedback relevant to our disclosures is assessed by Compliance with input from relevant internal reviewers and, where required, escalated to the Board.
  7. MiCA Sustainability Indicators (Per-Asset)
    1. What we publish. For each in-scope crypto-asset, we will present the six MiCA climate and environmental indicators with definitions, units, reference period, "last updated" date, and links to methodology.
    2. Energy
      1. Energy Consumption – total kWh/year used for transaction validation and ledger integrity.
      2. Renewable Energy Consumption – percentage of total energy from renewable sources.
      3. Energy Intensity – average kWh per validated transaction.
    3. GHG Emissions:
      1. Scope 1 – Controlled – tCO2e/year.
      2. Scope 2 – Purchased – tCO2e/year.
      3. GHG Intensity – kg CO2e per validated transaction.
    4. Where to find it. See our public page “MiCA Sustainability Requirements” for the per-asset factsheets area. Until CASP authorisation and data-feed activation, some pages may display placeholders and explanatory notes (see Section 1.2).
  8. Data Sources, Methodologies & Attribution
    1. Sources and methods.We plan to obtain indicators from independent third-party providers (e.g., Crypto Carbon Ratings Institute (CCRI)) that publish transparent methodologies, data-verification approaches and, where available, external validation or peer review.
    2. Estimates and updates.If background data is temporarily unavailable, we may publish clearly labelled estimates and replace them promptly when final data becomes available (see update approach in Section 5.3 and Section 9).
    3. Attribution.We display source attribution (provider name and, where applicable, logo) next to indicators and link to methodology papers. Attribution does not imply endorsement and is provided for transparency and reproducibility.
    4. External links.Before authorisation, we may link to publicly available third-party examples (e.g., CCRI) for illustration. We do not host or republish third-party PDFs; attribution does not imply endorsement.
  9. Publication Cadence & Updates
    1. Activation & cadence.Per-asset pages go live after CASP authorisation and data-feed activation. Where supported by our provider and underlying networks, indicators are refreshed daily; material changes (e.g., consensus switch) are posted promptly.
    2. Versioning.Each per-asset page shows a last updated timestamp and the reference period. Material changes include a brief change note.
    3. Approval & quality.Public ESG text follows the internal approval flow in Section 2.4 (two-person check). We apply consistent definitions, units and timeframes and clearly label estimates, limitations and methodology changes, with links to methods where available.
    4. Corrections & greenwashing safeguards.Confirmed errors are corrected without undue delay, with an errata note kept for a reasonable period. We avoid selective presentation and absolute environmental claims unless supported by auditable evidence.
    5. Feedback & complaints.ESG-related queries can be sent to Cloverum’s email – see Section 10 (Contact Details). We aim to acknowledge within 5 business days and respond within a reasonable timeframe.
    6. Training.Relevant staff receive role-appropriate training on MiCA disclosures and data handling; records are maintained.
    7. Suppliers & partners.We expect key suppliers – particularly data providers and critical infrastructure partners – to uphold lawful, ethical practices and to cooperate in providing information needed for accurate and timely disclosures. Material supplier or methodology limitations will be flagged on relevant per-asset pages.
    8. Record-keeping & retention.We retain MiCA-mandated disclosures and supporting records for as long as required by applicable law and regulation. Personal-data retention follows our Privacy Policy; other records follow our internal retention schedules.