Terms of service & quality commitment

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Date: 17 November 2022

Author: Catherine Long, CEO and Co founder

Trace Terms and Conditions

First thing’s First

These Terms & Conditions (“Terms”) are a Legally Binding contract between you (‘The Company’) and us (‘Trace).

These Terms govern access to and use of the Trace (“Trace”, “We”, “Us”) Websites, Portal, Assets and Services (collectively “Services”) by Site visitors, individuals or entities who purchase our Services or create an Account and their Authorised Users (collectively “Customers”).

As part of these Terms, you agree to comply with the most recent version of our Protocol for use of Trace branding as defined in these Terms. 

Limitation of Liability


Termination of Use

Trace may, in its sole discretion at any time discontinue providing, or limit access to its Services if it determines, in its sole discretion, that you have infringed any of the Terms in this document.

Payment of Services and Fees

You agree to pay all applicable, undisputed fees for the Services on the terms set forth on the invoice. You agree that we may take steps to verify whether your payment method is valid, charge your payment card or bill you for all amounts due for your use of the Services. You agree that your payment card information and related personal data may be provided to third parties for payment processing and fraud prevention purposes. We may suspend or terminate your Services if at any time we determine that your payment information is inaccurate or not current, and you are responsible for fees and overdraft charges incurred when we charge your cards for the Services. 

Membership renewal and payments

You agree that we will automatically charge you for recurring membership fees on the membership end date, unless instructed by you that you intend to terminate the use of Trace Services.


Our listed prices do not include any taxes, levies, duties or similar government assessment for any nature such as value-add, sales, use of withholding taxes, assessible by any jurisdiction (collectively “Taxes”) unless otherwise indicated. You are responsible for paying Taxes associated with your purchase.

Data Privacy and security

We gather and store customer data securely within our proprietary application and a secure third party tool. Access is strictly limited to our employees on a need to know basis and confidential customer data will never be shared with third parties. Read our Privacy Policy.

Modification of these Terms

We reserve the right to change these Terms on a going-forward basis at any time. Please check these Terms periodically for changes. Modifications will become effective upon the earlier of (a) your acceptance of the modified Terms, (b) your use of the Services with the actual knowledge of the modified Terms, or (c) 30 days following our publication of the modified Terms.

Overview of Trace’s Services

Trace is a Climate Technology business which helps companies measure, manage and offset their carbon emissions and achieve Trace certification (definitions below).


Trace has developed a proprietary carbon emissions calculator methodology and supporting digital tools to measure the carbon emissions of a company’s services and/or products based on data provided by the customer. Read more in the Carbon Assessment Methodology section.


Trace provides educational content and tools via its digital Portal to enable businesses to identify opportunities for reducing their carbon emissions and track progress over time.


Trace customers offset their emissions by contributing funds which are pooled with other customers’ funds to acquire a portfolio of carbon credits curated, purchased and retired by Trace. The amount of funds that each customer contributes is based upon the estimated costs of acquiring sufficient carbon credits (calculated by Trace using available market information) to offset at least 100% their CO2 emissions. Read more in the Offsetting section.


See definitions of our certification badges and public disclosure requirements.

Trace Protocol for Use of Environmental Claims

There is increasing pressure for businesses to consider the environmental impact of the goods and services they deliver and as a result standards are emerging to ensure the validity of any environmental claims made so as not to mislead consumers. According to the ACCC ‘a business must not represent that goods or services have sponsorship, approval, performance characteristics, accessories, uses or benefits they do not have’.

The goal of this protocol is to ensure our customers correctly use the carbon claims attained through Trace so as not to mislead the public. 

Trace defines carbon neutral to mean that a business has calculated the greenhouse gas emissions (carbon dioxide or carbon dioxide equivalent) generated by its core activities (as defined in the emissions boundary) and has 'cancelled out' emissions by purchasing carbon offsets. Carbon offset units are generated from activities that prevent, reduce or remove greenhouse gas emissions from being released into the atmosphere. 

When the offsets purchased by an organisation are equal to or greater than the emissions produced within the specified time period they are carbon neutral.

By claiming carbon neutral status through Trace, customers acknowledge and accept that their emissions have been estimated using Trace’s proprietary methodology based on the activity data provided by the customer and that Trace carbon neutral certification does not constitute Australian Government approval. 

Trace relies on customers to provide complete and accurate data for the CO2 assessment in accordance with its methodology and guidance and does not take responsibility for inaccurate or omitted data.

Badge certification definitions

Trace has developed strict definitions associated with use of its badges to ensure that customers feel confident making credible claims about their environmental action and that consumers can understand and trust the scope of the action taken by Trace business customers.

Carbon Neutral

This badge is awarded to companies that measure and offset at least 100% of their emissions with Trace.

Carbon emissions are calculated by Trace using its proprietary methodology and based on actual activity data supplied by the customer for a previous 12 month period of operation.

Example: Carbon neutral organisation badge

Carbon Positive

This badge is awarded to companies that measure and offset at least 150% of their emissions with Trace.

Carbon emissions are calculated by Trace using its proprietary methodology and based on data supplied by the customer for a previous 12 month period of operation

Example: Carbon Positive organisation badge

Carbon Neutral: Estimated CO2

This badge is awarded when a material (15% or more) proportion of annual emissions has been estimated where activity data is unavailable, enabling businesses to become carbon neutral in the absence of a complete data set.

Carbon emissions are estimated by Trace based on the emissions intensity (CO2/FTE or CO2/expenses) of either

  1. The prior measurement period of the company, or 
  2. Peer benchmarks from the latest measurement period and adjusted / extrapolated according to the FTE or expenses of the company during the same period.

The Estimate badge is not permitted for more than 1 consecutive year; Businesses must source real data to maintain their ‘Carbon Neutral’ beyond 1 year.

Estimated emissions have been at least 100% offset using Trace’s project portfolio.

Example: Estimated carbon neutral organisation badge

Carbon Neutral: Forecast CO2

This badge is only available to companies that have been operating for less than 12 months and therefore do not have a full year’s activity data.

Annual carbon emissions are estimated based on forecast activity data provided by the company.

Forecast emissions have been at least 100% offset using Trace’s project portfolio

Forecast renewals: In order to renew its Carbon Neutral status at the end of the forecast period, Trace requires the Customer to provide actual data for the previous 12 month period so that Trace can calculate the actual emissions for the period. These emissions must be at least 100%  offset to achieve ‘Carbon Neutral’ status for the next 12 months

Carbon offset

This badge is awarded when carbon emissions are offset using Trace’s project portfolio

Carbon emissions calculated by the customer and not verified by Trace; as such the offsets do not count for carbon neutral certification

Example: Carbon offset badge

Carbon measured

Carbon emissions calculated by Trace using its proprietary methodology and based on data supplied by the customer for a previous 12 month period of operation.

Carbon emissions have not been offset using the Trace portfolio.

Example: Carbon measured badge

Membership, Measurement and Impact Period

Trace defines the impact of its customers based on 3 different time periods:

  1. Membership period: This is the period that a customer has paid to access the Trace portal, starting the date the membership fee is charged. Membership is generally charged annually.
  2. Measurement period: Period of activity data submitted to Trace for CO2 assessment. The measurement period cannot be more than 9 months old at the time the carbon impact period begins (i.e. to achieve carbon status, the CO2 assessment must represent data which is less than 9 months old). See Activity Data Time Period.

  1. Carbon impact period: represents the period of validity of a customers’ carbon badge. Begins from the day a customer pays to offset its emissions. The expiry month shows on the badge.


Protocol for use of Trace Assets & Branding

Customers that become certified ‘Carbon Neutral’ or ‘Carbon Positive’ with Trace are granted use of our Badges and associated visual assets (collectively Trace Assets’) subject to the terms below.

On and from the Carbon Neutral start date (which is when the certification is given by Trace) and in consideration for payment of the applicable fees, we grant you (the Company) a non-transferable, revocable, non-exclusive licence to use the Trace Assets on digital and physical assets provided that:

  • If the Company ceases to be certified ‘Carbon Neutral or ‘Carbon Positive’’, it immediately ceases to use the Trace Assets, unless the badge clearly displays the relevant expiry date
  • The Company clearly explains its relationship to Trace and the process it has undergone to become certified 
  • The Company links any Trace Assets to its public impact page (like this one), which acts as a digital audit trail and proof of certification
  • The Company only uses the badge(s) Trace has issued to it (as defined in the table above)
  • The Company clearly states any exclusions from the emissions boundary in any Public communications

Trace reserves the right to review the use of Trace Assets in the public domain and request changes or removal if such use fails to meet these terms.

Companies using the ‘Carbon Neutral Brand’ designation are NOT permitted to display the ‘Brand’ assets or language on physical products or packaging. Trace’s assessment is not a product-specific Lifecycle Assessment (LCA), therefore any Carbon Neutral claims should relate to the Brand rather than any specific product.  

Carbon assessment methodology

Trace principles

  1. Transparency of the scope of the carbon neutral claim, including Emissions boundary, Offsets procured, Time period of emissions
  2. Simplicity of methodology in order to remove barriers to action while maintaining the credibility and accuracy of the process
  3. Completeness of the emissions calculated based on data made available to Trace by the customer
  4. Quality of carbon offsets procured by Trace on behalf of its customers


Measuring, reducing and offsetting your emissions doesn’t have to be complex, time consuming and expensive. Our mission is to remove the barriers to becoming carbon neutral

Our methodology adopts the 80:20 rule - 80% accuracy comes from 20% of the effort, which allows us to analyse your emissions in a matter of days not weeks. We include emissions from our client’s operations, employees and supply chain, using data readily available in your business.

Our model has been independently reviewed and verified by environmental consultancy, Energy Link Services and we continuously review and enhance the underlying data to ensure accuracy, transparency and recency.


The trace emissions engine leverages best practice carbon accounting methodologies and emission factors, including the UK Government, Australian Government’s Climate Active programme, NABERs and the global GHG Protocol. Emissions factors and benchmark data come from auditable sources.

The model covers:

  • Scope 1: Direct emissions (fuel used by facilities and vehicles)
  • Scope 2: Indirect emissions (electricity usage on premises and by staff working from home)
  • Scope 3: Supply chain emissions (materials, manufacturing, freight, waste from operations, employee commuting & travel, customer deliveries)

Electricity accounting

We use a hybrid of the market-based and location-based approach, unless specifically directed by the customer.

This means we consider ‘carbon neutral’ electricity as zero emissions and use the location-specific emissions factor for any non-carbon neutral grid electricity. 

We define carbon neutral electricity as ‘Green Power’, certified carbon neutral energy plans from retailers, PPAs, LGCs and ‘behind the meter’ renewable energy generated on site (e.g. solar panels).

Emissions boundary

The emissions boundary relates to the activities undertaken by the company that are included within the Trace carbon assessment and defines the certification awarded if the company offsets the emissions. The emissions boundary is defined using the ‘Operational control approach’ and must include all emissions under the direct control or ownership of an organisation (scope 1 & 2), as well as emissions they can strongly influence (scope 3), subject to relevance and materiality.

Trace offers two Boundaries of carbon neutral certification – Organisation and Brand (Organisation + Product/Service).  The Boundary selected depends on the type of products or services a company delivers.

Organisation Boundary 

All companies must at a minimum include activities within the Organisation boundary in their assessment. Companies that manufacture, prepare, distribute and/or sell products must also include activities in the Organisation+ boundary.

Brand Boundary

In addition to the areas included in an Organisation and Organisation+ Boundaries, companies that manufacture products may choose to include activities within the Brand boundary, which includes emissions associated with the manufacturing of products sold.

The Organisation boundary includes any activity that the company directly controls or pays for. The Brand boundary includes activities controlled or paid for by the Company’s suppliers (known as upstream).

Out of scope activities

Downstream use and end-of-life activities are excluded from all assessments undertaken by Trace due to the complexity and reliance on high level assumptions required to calculate the emissions associated with these activities. If a company would like to complete a lifecycle analysis of their products including these activities, Trace can recommend specialist consultants to support.

Mandatory Emissions Categories by industry: Organisations

We make it easy for our clients by pre-defining their minimum emissions boundary based on the industry type and the level of control they generally have over emissions sources. In simple terms, we’ve used recognised methodologies and benchmarks from our customer base to determine which activities (or categories of activity) must be included in the CO2 assessment.

Emissions from the categories Trace determines relevant to your industry type MUST be included in the emissions boundary. 

For supplier spend outside of mandatory categories, the materiality & relevance tests apply (see below).

Rules for applying the Emissions Boundary

  • If data is unavailable for a category or activity, we require a short explanatory statement as to why it has been excluded (e.g. “no flights taken during measurement period”), or apply an assumption that includes an uplift*. 
  • When a category isn’t applicable to the measurement period in question (it doesn’t occur), the Company will be required to provide an explanatory statement as to why it has been excluded (e.g. “no flights taken during measurement period”)
  • When an activity has occurred, but data is partial or unavailable, trace will work with the Company to apply an assumption that includes an uplift
  • If data is unavailable, a data management plan must be put in place to provide data for future calculations

Key suppliers: Materiality and Relevance test

For supplier spend outside of mandatory categories, the materiality & relevance tests apply. Emission sources are relevant if they meet either of the following spend thresholds:

  • Spend in the supplier category is greater than or equal to 5% of total operating expenses
  • Spend with a single supplier is greater than or equal to 1% of total operating expenses

Or at least two of the following criteria are met:

  • the emissions from the source are likely to be large relative to the organisation’s electricity, stationary energy and fuel emissions
  • the emissions from the source contribute to the organisation’s greenhouse gas risk exposure
  • the emissions from the source are deemed relevant by key Company stakeholders
  • the responsible organisation could influence emissions reduction from the source
  • the emissions are from outsourced activities previously undertaken within the organisation’s boundary, or from outsourced activities typically undertaken in-house by comparable Companies

Activity Data Time Period (‘Measurement Period’)

Trace does not define the exact 12 month period of data required for the CO2 assessment but recommends submitting data that is as recent as possible, so that the CO2 assessment represents a realistic picture of the businesses’ current emissions profile. 

The data must represent a 12 month period that has an end date no more than 6 months prior to the date of data submission. In order to achieve ‘Carbon Neutral / Positive’ Certification, offsetting must occur within 6 months of assessment, otherwise a reassessment will be required at additional cost to the customer.

The data must represent a 12 month period that has an end date no more than 6 months prior to the date of data submission. In order to achieve ‘Carbon Neutral / Positive’ Certification, offsetting must occur within 9 months of the end of the measurement period, otherwise a reassessment will be required at additional cost to the customer.

Public disclosure declaration

All customers are required to agree to our public disclosure agreement when they submit their data to Trace:

  • The data I have provided as part of this assessment is a true reflection of the organisation's activities during the measurement period selected above.
  • I have reviewed and accepted Trace's Terms of Service (herein)
  • I agree to review the carbon assessment provided by Trace and highlight any required changes prior to offsetting.


How the carbon portfolio works

Trace manages a live portfolio of carbon credits, which means we procure credits from multiple projects on a regular basis. As such, the number and types of credits in the portfolio will change over time as we purchase and retire credits across various projects.

Carbon credits are subject to market price volatility as a result of fluctuations in supply and demand (which are outside our control). This has an impact on how we select projects to purchase credits from. The projects we acquire credits from, and the proportion of the portfolio that each respective project represents, will therefore vary over time.   As such, past portfolio composition is not a guarantee of future portfolio composition.  

The current portfolio of projects can be viewed here. Projects marked ‘live portfolio’ represent the projects from which we have acquired credits in the last two procurement cycles (see Timing below). When you make contributions to offset your emissions through Trace, we provide details of the portfolio that is held at that time, updated on a rolling 6 monthly basis. We believe this most closely illustrates the projects that your contribution could fund. However, since we procure credits up to 3 months in arrears (i.e. after receiving payment from you), the credits bought using your contributed funds may not correspond precisely to those credits which have been purchased in the past. See below for our explanation of how we select credits and our commitment to quality and transparency.

We charge a management fee, embedded in the cost to offset, which is deducted from customer contributions.  This fee relates to the project sourcing and portfolio management services we provide and covers the associated costs of conducting due diligence, administrative record keeping and reporting on the portfolio.

Credit selection criteria

At Trace we are committed to sourcing high quality, externally verified carbon credits on behalf of our customers. You can read our selection criteria here.

All carbon credits are certified by Gold Standard, Verra, the Australian Clean Energy Regulator or the UNFCC’s Clean Development Mechanism (CDM). On top of verified carbon credits, we also sponsor tree planting from a variety of nature-based projects around the World, which deliver additional CO2 sequestration benefits.

Thanks to our growing community of Climate Positive customers, Trace benefits from the economies of scale of aggregating the demand across all our customers, which means we can access more competitive pricing for credits than customers who buy credits directly on their own behalf in smaller quantities.

You can rest assured that when we select, acquire and retire carbon credits, we only partner with the intermediaries whom we trust to help us source credits that meet our strict quality criteria.

Timing of retirement

Trace procures credits in arrears, which means we accumulate funds from our customers before we go to market to acquire credits on a quarterly basis. In the meantime, Trace holds customers’ contributions in escrow, separately from its own business operating funds, pending the quarterly procurement cycle.

You can see our live tracker of carbon credits and trees here. This shows the carbon and trees purchased by Trace using contributions from our customers.

As a general rule, it can take up to 90 days from a customer contribution transaction taking place on our platform for the contribution proceeds to be converted into credits in our portfolio (because of transaction times, accounting procedures, waiting for receipts or carbon retirement certificates from our partners, etc).