Green Claims Policy

1. Introduction

As signatories of The Anti-Greenwash Charter, Perega is committed to upholding good standards of responsible marketing and communications practice.

The purpose of this policy is to define the standards we adopt throughout our organisation to ensure green claims made about our services are accurate and substantiated.

This policy applies to all the forms of marketing and communications we share, including digital marketing (including social media), direct marketing, events (including speaker slots and panel discussions), PR, and other professional promotions and communications.

Perega participates in independent third-party campaign reviews conducted under The Anti-Greenwash Charter’s verification framework. These reviews assess our marketing and communications campaigns to ensure all environmental claims are accurate, substantiated, and responsibly communicated.

This policy is guided by the principles of the CMA Green Claims Code, Advertising Standards Authority (ASA) guidelines, ISO 14021 (Environmental Labels and Declarations), and the EU Green Claims Directive, ensuring alignment with leading regulatory standards.

In addition to this policy, all marketing and communications must at all times comply with the relevant local laws and regulations.

2. Our standards

We commit to the standards of practice set out in The Anti-Greenwash Charter, which are as follows:

Transparency: We commit to clear communication of what environmental benefit our product or service offers and won’t conceal or omit information.

Accountability: We substantiate our green claims with accurate and regularly evaluated empirical evidence. We commit to sharing facts, figures and statements that can be checked.

Fairness: We commit to using fair, clear and unambiguous language when providing comparisons with other products or organisations.

Honesty: We will ensure we make specific statements about our organisation’s environmental efforts and that our actions match those promises.

3. Where we could improve

At Perega, we are committed to continuous improvement in our sustainability practices.

We have made significant advances with our service provision, particularly in reuse-focused design and our in-house carbon calculation tool, and from an operational carbon perspective with low-carbon travel and renewal energy adoption. However, we know there is always more we can do to push our sustainability efforts further.

We will endeavour to improve how we assess the impact of carbon at the earliest stages of our projects in order to help inform and advise our clients accordingly and work more closely with them to align sustainability goals.

Each year, we conduct a thorough assessment of our operations to identify areas where we can further reduce our environmental impact.

Perega undertakes an annual sustainability review using relevant project data, operational audits, and stakeholder feedback to identify areas for improvement. Progress is reviewed annually and informs updates to our sustainability strategy and client engagement practices.

4. Our practices

We implement the following practices and procedures to ensure we uphold our standards:

• Clearly define the green terms we use
• Set standards for authentic and accurate visual representation
• Outline a clear editorial process
• Ensure responsible use of AI in content creation
• Commit to regular reviews and effective governance

5. Green terms glossary

This glossary is maintained in compliance with the CMA Green Claims Code, ASA guidance, ISO 14021, and the EU Green Claims Directive. It ensures our terminology remains transparent, precise, and consistent with current best practice. The glossary is reviewed and updated annually, or when new sustainability terms are introduced.

We define the key ‘green’ terms and acronyms we use to describe our services and the work that we do, to ensure our claims are clear and transparent:

Net Zero Carbon (NZC): A state where the amount of greenhouse gases created are balanced by the amount removed from the atmosphere.

Embodied carbon: The total greenhouse gas emissions released throughout a building’s lifecycle, from raw material extraction and manufacturing to construction and maintenance.

Operational carbon: The greenhouse gas emissions generated from the day-to-day energy used to operate a building, such as heating, cooling, lighting and powering equipment.

Carbon footprint: A measure of the amount of carbon dioxide released into the atmosphere as a result of the activities of an individual, organisation or community.

Sustainable building design: Environmentally conscious approach to building design to minimise the negative impact on the environment.

Low carbon structure: A building designed to minimise its overall carbon footprint by using materials, techniques and technologies that reduce greenhouse gas emissions throughout its lifecycle.

Retrofit: Upgrading or enhancing an existing structure to improve or change its performance, efficiency or functionality.

Modern Methods of Construction (MMC): Innovative, often offsite, building techniques for increased efficiency and sustainability.

Circular design: An approach that eliminates waste and pollution, keeps products and materials in use and regenerates nature by designing everything from products to systems to be as sustainable as possible.

Hierarchy of net zero design: Prioritises a structured approach to reducing and managing carbon emissions in construction projects.

Low-carbon materials: Materials that generate significantly fewer greenhouse gas emissions compared to alternatives throughout their lifecycle e.g. timber.

Biodiversity Net Gain (BNG): A legal requirement in England for most developments to leave the natural environment in a measurably better state than before the development began.

ISO: The International Organisation for Standardisation is an independent, non-governmental organisation that develops standards to support innovation and provide solutions to global challenges. ISO certification verifies adherence to best practices.

If you come across a term you don’t understand and can’t find it on this list, please email Emma Neal at eneal@perega.co.uk for clarification.

6. Use of imagery and colour

Our visual content is created and designed by our marketing department and reviewed and fact-checked for accuracy by a relevant team or individual within the business.

We recognise the powerful impact of visual representation in shaping perceptions and therefore uphold the following principles related to the use of imagery and colours in our marketing and communications materials, balanced with appropriate review mechanisms:

• Authentic Imagery: We use genuine and representative images of our services and initiatives and avoid the use of stock photos or unrelated imagery that may mislead or give a false impression of our environmental efforts.
• Avoidance of Greenwashing through Colours: The use of green or earth tones in materials can evoke feelings of environmental friendliness. We ensure that colours are used responsibly and are not misleading.
• Transparency in Photo Alteration: Any alterations or edits to photos that may change the reality or context of our green initiatives will be clearly disclosed. This includes photoshopped elements, exaggerated effects, or other changes that might give a misleading impression.
• Educative Infographics: Where possible, we will use visual aids such as infographics to simplify and convey complex sustainability data or concepts. These visuals will always be based on substantiated facts and will be designed in a manner that is easy to understand without misrepresenting the information.
• Creative Flexibility & Review Process: While we encourage creativity and innovation in our visual content, we have processes in place to ensure that all materials are reviewed for accuracy and alignment with our sustainability values.

All imagery used in Perega’s communications must respect cultural, environmental, and social contexts. We avoid visuals that could misrepresent local communities, ecosystems, or sustainability impacts. If any visual content is later found to be inaccurate or misleading, we will promptly review and amend it through our established content approval process.

7. Editorial process

Our editorial process for green claims content is the same for all our marketing and communications material.

All green claims content follows a structured editorial approval process involving:

• A subject matter expert (e.g. Net Zero Carbon Lead)
• Two members of the marketing department
• Final approval by the article owner (or senior management if applicable)

Concerns or disputes about content accuracy are logged, reviewed and acted upon accordingly.

8. Training

All members of our marketing and business development department who are responsible for content generation have received training on this policy and The Anti-Greenwash Charter to ensure they fully understand the issues and benefits.

A link to this policy is provided to all new starters during the induction process and they must confirm it has been read and understood. Perega provides annual refresher sessions to all staff involved in sustainability communications, project delivery, or data provision.

Training covers updates to the CMA, ASA, ISO, and EU frameworks, ensuring consistent awareness of regulatory expectations.

9. Use of AI

We utilise AI tools to assist in the creation of written marketing and communications content, particularly for data analysis and content personalisation. To maintain the integrity of our green claims, all AI-generated content is rigorously reviewed by humans, as per our editorial process.

10. Stakeholder education

We recognise that our stakeholders play a crucial role in our efforts to combat greenwashing. Therefore, we commit to responding to any emails regarding our green claims within three working days.

Our strategy for stakeholder education involves creating content that informs them about sustainability issues, including the environmental impact of the buildings we design. This content is designed to be engaging, helping to raise awareness and understanding of key environmental issues. Examples include project case studies on our website.

11. Governance of this policy

Our Head of Marketing is responsible for ensuring that our compliance with this Green Claims Policy is reviewed annually. Any non-compliance with this policy will be dealt with accordingly.

12. Independent reviews

As a committed signatory of The Anti-Greenwash Charter, we actively endorse independent reviews to validate our Green Claims Policy.

These periodic assessments ensure our commitment to responsible marketing practice. We understand that any non-compliance may result in the revocation of our certified signatory status.

13. Verified Claims

We calculate embodied carbon using our in-house embodied carbon calculator, developed by our NZC team.

Backed by a set of algorithms, the Revit add-in assesses emitted CO2 through sophisticated material data analysis. The calculator uses advanced scripting software to tap into the Inventory of Carbon & Energy (ICE) database of carbon factors in conjunction with the building model and the materials specified. It allows us to compare different schemes and identify high carbon elements within the analysed models. The tool enables scoping of design changes, along with further assessments and improvements.

Results are presented to clients in a user-friendly dashboard, giving a concise and informative carbon impact assessment, based on material type and volume specified with the model.

In addition to our in-house tool, we use the latest version of The Structural Carbon Tool (TSCT) to estimate embodied carbon in our designs. This tool is approved and supported by the Institution of Structural Engineers.

Rev 0 11.2025

Campaign Review Log