# Data Privacy Policy

V1.1 October 23, 2024

## 1. INTRODUCTION

Welcome to the privacy policy of MillPont's Environmental Trust Infrastructure (METI). This policy outlines how we collect, use, store, and protect data. MillPont is committed to maintaining the trust and confidence of our users, especially in the agricultural sector, where data sensitivity is paramount.

## 2. TYPES OF INFORMATION WE COLLECT

MillPont collects various types of data to provide and enhance our services:

1. **Personal Contact and Billing Information:** Upon registration, users provide name, address, telephone, and email address. This information may also include basic account information for billing or other purposes.&#x20;
2. **Identifiers and Classification Information:** Uniquely identifies entities, projects, and activities, consolidating decentralized data for cross-verification and referenceable assertion of uniqueness.&#x20;
3. **Geospatial and Temporal Data:** Details the location and timing of projects and activities, ensuring accurate representation and provenance of claims.
4. **Attributes and Quantities:** Describes specific attributes and quantities of environmental claims, ensuring accurate and reliable accounting and reporting.
5. **Verification and Certification Information:** Includes verification and certification details, maintaining credibility and trustworthiness of environmental claims through secure and confidential handling.

## 3. HOW WE COLLECT YOUR DATA

1. **Direct Collection**: We gather data you provide when applying to become a member of METI, using METI services, and communicating with us.
2. **Indirect Collection**: MillPont uses cookies and similar technologies to enhance user experience and service functionality. This includes the use web server logs and similar tools to help diagnose problems with the server, to administer the website, and to enhance security or authenticate users.
3. **Third-Party Sources**: We may receive data from partners and affiliates under strict privacy agreements.

## 4. OPTIONS CONCERNING INFORMATION WE COLLECT

MillPont will not collect or use information for purposes other than those described in this Privacy Policy without your consent. You can decline to submit personal information to any of our services, in which case MillPont may not be able to provide those services to you.&#x20;

## 5. USE OF YOUR INFORMATION

MillPont uses your data to:

* **Service Provision and Technical Function**: Provide, maintain, and improve the METI services tailored to environmental market needs.
* **Data Reporting:** Aggregate and anonymize data to report total number of Secure Source Identifiers (SSIDs), affiliated hectares, and outcomes tied to Environmental Attribute Certificates (EACs).&#x20;
* **Enhance User Experience:** Improve your experience of METI services ensuring relevant information and services are offered.
* **Communication**: Communicate with you about service updates, educational content, offers, and important notifications related to METI services.&#x20;
* **Data Security and Safety:** Detect, prevent, or otherwise address fraud, security or technical issues; or protect against harm the rights, property, safety of MillPont, our users and or the public as required or permitted by law.
* **Compliance and Legal:** Ensure compliance with Terms of Use, including investigation of potential violation thereof, legal requirements, and respond to enforceable law or governmental requests.&#x20;

In aggregating data, we strip away any personally identifiable information to ensure individual data privacy while still providing valuable collective insights to market stakeholders. &#x20;

## 6. DATA SHARING AND DISCLOSURE&#x20;

We do not sell personal data. Data sharing is limited to:

* Service providers under strict contractual obligations.
* Legal requirements and law enforcement requests.
* Business transfers, such as mergers or acquisitions.

## 7. DATA SECURITY AND INTEGRITY

MillPont employs robust security measures, including:

* One-way encryption and secure data storage.
* Regular security audits and updates.
* Compliance with industry standards and regulations.

Despite our efforts, no data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk.  In the even of a security incident, we will notify our clients or end-user customers in accordance with applicable law.

## 8. ENHANCED PRIVACY PROTECTION FOR GEOSPATIAL DATA

MillPont recognizes the sensitive nature of geospatial data related to agricultural activities. To ensure the utmost privacy and protection of this information, we implement the following specialized measures:

* **Advanced Encryption**: All geospatial data is encrypted using state-of-the-art encryption techniques, both in transit and at rest, to prevent unauthorized access.
* **Restricted Access:** Access to geospatial data is strictly controlled and limited to authorized personnel only. We employ rigorous access controls and monitoring systems to prevent unauthorized data access and breaches.
* **Anonymization Protocols**: Before any geospatial data is used for analysis or shared with partners, it is anonymized via one-way hash algorithms to remove any identifiers that could link it back to individual farmers or specific locations.
* **Geospatial Data Masking:** To further protect farmer privacy, we employ data masking techniques, obscuring sensitive geospatial details where necessary.
* **Transparency and Control**: Users have full control over their geospatial data. They can access, review, update, or request deletion of their data at any time. We also provide detailed logs of data access and usage upon request.
* **Terms of Use:** The METI Terms of Use recognizes farmer’s rights over their data. Users of METI are required to maintain, and upon request, provide detailed documentation that demonstrates their ability to manage geospatial farmer data. This is essential for maintaining trust, legal compliance, and the integrity of our platform.

By implementing these measures, MillPont ensures that market participant's geospatial data is handled with the highest level of security and confidentiality, reflecting our commitment to protecting the privacy and interests of our agricultural community.

## 9. YOUR RIGHTS AND CHOICES

You have the right to:

* Access, update, or delete your personal data.
* Opt out of non-essential data collection.
* Request data portability.

## 10. CHANGES TO THIS POLICY AND CHANGELOG

We may update this policy periodically. We maintain a [Changelog](https://millpont.gitbook.io/changelogs/) to keep track of updates to the document. Your continued use of METI services after any changes signifies your acceptance of these changes.&#x20;

## 11. CONTACT US

You may contact us regarding the METI Services or this Privacy Policy <info@millpont.com>.


# Terms of Use

V1.3 April 30, 2026

**Contents**

1. [DEFINITIONS](#id-1.-definitions)
2. [ACCEPTANCE OF TERMS](#id-2.-acceptance-of-terms)
3. [DESCRIPTION OF SERVICES](#id-3.-description-of-services)
4. [AUTHORIZED USER](#id-4.-authorized-user)
5. [DATA OWNERSHIP AND CONFIDENTIALITY ](#id-5.-data-ownership-and-confidentiality)
6. [LICENSE GRANT AND USE RIGHTS](#id-6.-license-grant-and-use-rights)
7. [DATA OWNERSHIP AND THIRD PARTIES](#id-6.-data-ownership-and-third-parties)
8. [FEES](#id-7.-fees)
9. [PAYMENTS AND TAXES](#id-8.-payments-and-taxes)
10. [LATE PAYMENTS](#id-9.-late-payments)
11. [TERM AND TERMINATION](#id-10.-term-and-termination)
12. [DEFAULT AND REMEDIES](#id-11.-default-and-remedies)
13. [INTELLECTUAL PROPERTY](#id-12.-intellectual-property)
14. [REPRESENTATIONS AND WARRANTIES](#id-13.-representations-and-warranties)
15. [DISCLAIMER AND WARRANTIES ](#id-14.-disclaimer-and-warranties)
16. [LIMITATION OF LIABILITIES](#id-15.-limitation-of-liabilities)
17. [LOGINS, PASSWORDS, and IDS](#id-16.-logins-passwords-and-ids)
18. [INDEMIFICATION](#id-17.-indemification)
19. [FORCE MAJEURE](#id-18.-force-majeure)
20. [NOTICES](#id-19.-notices)
21. [GOVERNING LAW AND DISPUTE RESOLUTION](#id-20.-governing-law-and-dispute-resolution)
22. [ENTIRE AGREEMENT ](#id-21.-entire-agreement)
23. [CONTACT INFORMATION](#id-22.-contact-information)

## FROM THE ADMINISTRATION

Welcome to MillPont Environmental Trust Infrastructure ("METI"), operated and administered by MillPont, Inc. ("Administrator"). MillPont is an independent organization that offers workable, global, and practical solutions to ensure the integrity of environmental claims ownership in agricultural supply chains.

METI was created to facilitate collaboration among environmental market operators, registries, marketplaces, and government programs seeking standardized infrastructure for climate and environmental markets. METI is designed to help address shared market-integrity challenges, including double-counting, greenwashing, and the credibility of climate impact reporting. It functions as a standardized electronic clearinghouse for the secure exchange of geospatial and environmental reference data. It serves as trusted reference-data infrastructure and a system of record for the uniqueness, provenance, and chain of custody of Sources and their associated environmental attributes, as well as the identifiers, ledger records, and reference data that rely on them.

The platform is web-based and cloud-hosted, with a globally accessible public interface and secure registered-user accounts requiring authentication.

METI users will be provided functions relevant to their specific role through their account/s in METI and will be subject to these Terms of Use ("Terms") and, if applicable, the specific METI Product Rulebook/s (“Rulebooks”) affiliated with the products and services (collectively, the "Services") subscribed to. Upon submission of the relevant Application Form, as described below, and **by accessing or using our Services, you agree to be bound by these Terms.**

These Terms form the general legal layer governing access to and use of METI, and are supplemented and, where applicable, superseded by the more specific Operative Documents in the order of precedence set out in Section 22.2.

## 1.      DEFINITIONS

* **Account Holder:** The person or entity that holds a METI Account and is responsible for that Account and its Authorized Users. An Account Holder may occupy more than one role (for example, Custodian/Issuer or Data Accessor) to the extent authorized under the applicable Services agreement or other Operative Document.
* **Authorized Data Vendor:** A party authorized under a separate Authorized Data Vendor Agreement to redistribute, display, host, syndicate, supply through a feed or API, or otherwise make METI Data available to downstream customers, only to the extent and only for the products and channels expressly authorized in that agreement.
* **Authorized User:** An individual or entity (including an Account Holder's owners, officers, employees, contractors, and Agents) permitted by an Account Holder to access METI through its Account, within the scope authorized.
* **Affiliate:** Any entity that controls, is controlled by, or is under common control with a party, where "control" means ownership of more than fifty percent (50%) of the voting interests or the power to direct management.
* **Beneficiary:** An individual, entity, or organization that receives the intangible property rights (referred to as 'Ecosystem Services Rights') and the quantified environmental benefits conveyed through Environmental Attribute Certificates. Beneficiaries can include, but are not limited to, stakeholders such as investors, public entities, private organizations, NGOs, or other parties entitled to the benefits generated by sustainable practices and interventions documented, registered, and transferred via METI.&#x20;
* **Custodian/Issuer:** An individual, entity, or organization responsible for the custody, management, and administrative oversight of one or more Secure Source Identifiers. In this capacity the Custodian is also the issuer and registrant of SSIDs and Sources in METI. Custodians ensure the proper issuance, distribution, and tracking of these identifiers, and may also underwrite Environmental Attribute Certificates associated with the Secure Source Identifiers. Custodians must have active commercial agreements with Source owners (i.e., Landowners or Operators) or Beneficiaries with agreements tied to the Source owners. They are required to adhere to all applicable Terms of Use and Rulebook standards.
* **Data Accessor**: A party that accesses, queries, consumes, or relies upon METI Data for its internal, enterprise, compliance, reporting, analysis, or other authorized business purposes.
* **Derived Outputs:** The outputs, scores, benchmarks, models, or datasets created by a user from or using METI Data.
* **Environmental Attribute Certificates (or Claim) ("EACs")**: Representing intangible property rights, EACs are tradeable market-based instruments used to quantify, verify, and track specific ecosystem service benefits resulting from climate mitigation activities or projects. EACs can operate within various chains of custody models, with traceability levels ranging from fully traceable models—where the benefits associated with the EAC remain connected throughout the value chain—to models where the EAC is traded independently of the original benefits and activities, thereby removing traceability of the initial benefits within the value chain. Trading these EACs may allow buyers to claim ownership or credit for the underlying Ecosystem Services Right(s) and/or associated benefits, while also providing financial incentives to interventions that reduce greenhouse gas emissions, promote renewable energy, or achieve other sustainability objectives. EACs offer a secure, traceable, and standardized mechanism for transferring the rights and information associated with various environmental assets—such as verified carbon credits, Scope 3 claims, low-carbon commodities, and biodiversity credits—and their affiliated benefits across platforms and between parties.
* **Ecosystem Services Rights:** The entitlements to benefits derived from natural ecosystems, which directly contribute to human survival, economic activity, and resilience. These rights are typically held by Landowners and Operators and may be transferred or assigned, as permitted within the governing frameworks established by EAC market standards, to Beneficiaries. These rights include the ability to participate in, reserve, or transfer entitlements to ecosystem services, encompassing:
  * **Provisioning Services**: Rights to tangible products provided by ecosystems, such as food, water, timber, and genetic resources.
  * **Regulating Services**: Rights related to services that support climate mitigation and environmental balance, including carbon sequestration, water flow regulation, soil health, and pest control.
  * **Supporting Services**: Rights tied to essential ecological functions that sustain ecosystem productivity, such as nutrient cycling, soil formation, pollination, and habitat provision.
  * **Cultural Services**: Rights to non-material benefits from ecosystems that support emotional well-being, cultural identity, and recreation, such as hunting, fishing, and hiking.
* **Landowners and Operators:** One or more related entities which owns and or operates the Source/s and Ecosystem Services Rights transferred or assigned via EACs. Landowners and Operators can be individuals, organizations, and or groups of individuals or organizations which operate under similar ownership or organizational structures, produce similar goods or services, and are located in close regional proximity to each other.
* **METI Data**: all data, records, identifiers, and outputs generated through METI -  including METI Identifiers, ledger and Source records, certification and lifecycle records, methodology metadata, and supplemental analytics -  together with the selection, arrangement, normalization, and compilation thereof.
* **METI Identifiers:** The SSIDs and any other identifiers, keys, or codes assigned, generated, or maintained by METI, together with the identifier system and its structure.
* **MRV Provider**: A party that operates or supports monitoring, reporting, and verification ("MRV") activities and that may submit, validate, or support data flows into METI. MRV Provider status does not, of itself, confer any right to redistribute or commercialize METI Data.
* **Principal; Agent:** a "Principal" authorizes an "Agent," through a Declaration of Agency, to access and act within METI on the Principal's behalf, solely within the authorized scope.
* **Public METI Data; Confidential METI Data:** "Public METI Data" is the subset of METI Data that the Administrator makes available through the public interface or designates as public; "Confidential METI Data" is all other METI Data, including Source-level data.
* **Operative Documents:** The documents MillPont publishes and maintains for METI and makes available at [docs.millpont.com](https://docs.millpont.com), as each may be may be updated from time to time, including these Terms, the Source Rulebook, the Data Privacy Policy, any published Schedules, Declaration of Agency Form, and the SSID Conflict Resolution Request Form.
* **Regulated Entity:** Any of the following: (i) Any Bank; (ii) Any broker or dealer that (a) is registered pursuant to Section 15 of the Securities Exchange Act of 1934, as amended; and (b) is a member of all requisite self-regulatory organizations; (iii) Any member of the National Futures Association that is registered under the Commodity Exchange Act, as amended, as a futures commission merchant, introducing broker, commodity pool operator, commodity trading advisor or floor broker; (iv) (a) Any investment company registered under the Investment Company Act of 1940, as amended; (b) Any investment adviser registered under the Investment Advisers Act of 1940, as amended; or (c) Any fund that has assets under management with an aggregate market value of no less than $100 million and that is advised or managed by an investment adviser registered under the Investment Advisers Act of 1940, as amended; (v) Any “business development company” as defined in (a) Section 2(a)(13) of the Investment Company Act of 1940, as amended, or (b) Section 202(a)(22) of the Investment Advisers Act of 1940, as amended; (vi) (a) Any plan established and maintained by a state, its political subdivisions, or any agency or instrumentality of a state or its political subdivisions, for the benefit of its employees; (b) Any employee benefit plan within the meaning of title I of the Employee Retirement Income Security Act of 1974, as amended; or (c) Any trust fund whose trustee is a Bank and whose participants are exclusively plans of the types identified in the above clause (a) or (b), except trust funds that include as participants individual retirement accounts or H.R. 10 plans.
* **Secure Source Identifiers ("SSIDs")**: A unique and addressable digital statement that represents exclusivity over a geographic extent (i.e. Source) for a period of time for a specific type of environmental attribute. SSIDs incorporate geospatial, temporal, and attribute ownership data to ensure secure and verifiable provenance for claims. They support robust data integrity, traceability, and facilitate seamless comparison across platforms and workflows. Represented by a unique 16-character identifier, they work in tandem with Environmental Attribute Certificates (EACs) to maintain a secure chain of custody. SSIDs and their associated metadata are securely stored using advanced encryption methods, generating unique yet comparable cryptographic fingerprints of claims. This facilitates easy machine reading and comparison across various user operations, interfaces, platforms, and workflows, thereby enhancing the efficiency and reliability of underwriting, verification, trading, settlement, and clearing of environmental assets.
* **Source**: A registered provenance, measurement, aggregation, or accounting reference unit in METI, assigned or associated with an SSID or other METI Identifier, that identifies the boundary, measurement point, operational unit, program envelope, jurisdictional area, or other approved reference point from which Environmental Attribute Certificates, environmental attributes, registry records, certification records, or related lifecycle data may be originated, measured, tracked, aggregated, verified, or referenced. Each Source has a single declared Source Type and is defined by its applicable boundary or measurement basis, temporal validity, attribute type, Custodian, submitted evidence, and any parent-child, constituent, or external-registry relationships recorded in METI.
* **Source Type:** The classification assigned to a Source under the Source Rulebook to identify the boundary level at which the Source is registered, governed, and administered. Each Source must have one Source Type. The Source Types are:
  * **Field Source:** Defined at the smallest continuous physical boundary, or the smallest group of continuous physical boundaries, that reflects common management, common cover or land-use characteristics, and common ownership or control. A Field Source is generally represented by polygon geometry and is intended to serve as the highest-resolution land-based provenance unit.
  * **Facility Source:** Reference to an identifiable industrial, processing, production, storage, terminal, interconnection, or other operational facility that is the origin of measurable environmental attributes. A Facility Source is defined by the facility’s operational boundary, fence-line, permit boundary, metering boundary, or other facility-level boundary recognized under the Source Rulebook.
  * **Device Source:** A registered production device, generation unit, meter, sensor, asset, equipment item, or other discrete physical or digital device that produces, measures, or is otherwise associated with environmental attributes. A Device Source is tied to identifiable measurement point or device-level evidence.
  * **Program Source:** An aggregated, grouped, programmatic, project, initiative, methodology, registry, protocol, procurement, cooperative, supply-shed, or other organized activity boundary that encompasses or administers multiple constituent Sources. A Program Source functions as a governance or aggregation boundary and derives its provenance from its declared constituent Sources unless the Source Rulebook provides otherwise.
  * **Jurisdictional Source:** Defined by a recognized administrative, political, regulatory, market, watershed, airshed, grid, or other jurisdictional boundary. A Jurisdictional Source is generally based on authoritative external boundary data and is used where environmental attribute accounting, reporting, or governance is organized at a jurisdictional level.

## 2.      ACCEPTANCE OF TERMS

**(a)** The use by you and your Users (as defined below) of the Services and the Services' website located online at [www.millpont.com](https://millpont.gitbook.io/docs/operative-documents/www.millpont.com) (or such other website as Administrator may notify you is the location of the Services) (the “Services Site”) is subject to these Terms, which constitute a binding contract between you (“User” or "Account Holder") and MillPont as the administrator and owner of the Services (User and MillPont are individually referred to herein as a “Party,” and collectively referred to herein as “the Parties”). BY USING OR ACCESSING THE SERVICES, YOU ACCEPT AND AGREE TO BE BOUND BY THESE TERMS OF USE AS MODIFIED FROM TIME TO TIME IN ACCORDANCE WITH THE TERMS HEREOF, AND YOU AGREE TO TAKE AFFIRMATIVE RESPONSIBILITY FOR THE COMPLIANCE OF YOUR USERS WITH THESE TERMS OF USE.

**(b)** You can review the current version of the Terms of Use at any time on the Services Site. CONTINUED USE AND ACCESS OF THE SERVICES BY YOU AND/OR YOUR USERS AFTER MODIFICATION OF THE TERMS OF USE SIGNIFIES YOUR AGREEMENT TO BE BOUND BY THE MODIFIED TERMS OF USE, AND YOUR AGREEMENT TO TAKE AFFIRMATIVE RESPONSIBILITY FOR THE COMPLIANCE OF YOUR USERS WITH THE MODIFIED TERMS OF USE.

**(c)** In addition, when using the Services, you shall be subject to any rules, guidelines, and/or operating procedures, including but not limited to the applicable fee schedule, rulebook(s), and/or operating procedures, each as modified or restated from time to time (collectively, the “Operative Documents”) applicable to such use which may be posted on the Services Site from time to time. All such Operative Documents are incorporated by reference into these Terms of Use. If you do not agree to these Terms of Use, you and your Users may not access or otherwise use the Services.

**(d)** Notwithstanding subsection (b), no modification of these Terms of Use will expand an Agent's authority, impose new agency obligations on a Principal, create new or additional liability for a Principal, or modify the scope of a previously executed Declaration of Agency, unless the Principal agrees in writing or the applicable Declaration of Agency permits the modification. Where a Declaration of Agency defines the governing "METI Agreements" as the versions of these Terms and the Data Privacy Policy in effect as of its effective date, those versions continue to govern the authorized agency activities until the Principal agrees otherwise in writing.

## 3.      DESCRIPTION OF SERVICES

### **3.1. Services Overview**

METI provides digital infrastructure for the administration of environmental claims ownership via products and services tied to Secure Source Identifiers (SSIDs) and Environmental Attribute Certificates (EACs). Upon acceptance of registration by the Administrator, the Account Holder will have an Account in METI where they can create, modify and administer records related to SSIDs and EACs. Account Holders can import data from, and export  to, other public or private registries not managed by the Administrator. The data comprising METI includes, but is not limited to:

* SSIDs related to sustainable projects, provided to the Administrator by qualified Custodians as detailed in the METI Source Rulebook.
* Meta data provided by Account Holders, their Users, or other participants in METI, such as project type, geographic location, time, and environmental benefits.

### **3.2. Data Assembly**

METI is an assembly of data regarding environmental project sources. Any issues or disputes arising between the Account Holder, other METI participants, and third parties from the use of METI or its data (including disputes about the validity of project data, the purchase and sale of EACs, or ownership rights to an EAC's affiliated benefits) must be resolved between the involved parties. The Administrator’s role in resolving these issues is covered in the METI Source Rulebook. The Administrator’s responsibility in resolving these issues is covered by the liability limitation and indemnification provisions of Sections 13, 14 and 15 of these Terms. The Administrator reserves the right, in accordance with procedures in the relevant Product Rulebook/s, to handle disputed SSIDs and EACS by interpleader or other suitable actions and may deposit disputed SSIDs or EACs with the relevant court or arbitral panel.

### **3.3. Import and Export of Data**

Account Holders can import and export data to and from other digital ecosystems. The Administrator may need to receive or transmit data on behalf of the Account Holder for such transfers. The Account Holder’s instruction to the Administrator to facilitate such imports or exports constitutes authorization for the Administrator to act accordingly. Import or export functionality does not grant any right to redistribute METI Data except as expressly authorized under Section 6.7.

### **3.4. Modification of Service**

The Administrator reserves the right to modify, augment, segment, reformat, reconfigure, or otherwise alter the content or methods of transmission of METI, the Operative Documents, or these Terms of Use at any time. The Administrator will report any non-compliance with Operative Documents that may have a material adverse effect on METI within thirty (30) days of occurrence. Account Holders will be given at least seven (7) days’ prior notice of significant changes to METI or these Terms, which will be effective as stated in the notice, communicated via posting on the Service Site or through electronic or conventional mail. Other changes will take effect upon posting on the Service Site. Continued use of METI by the Account Holder after changes take effect will constitute acceptance of those changes, subject to Sections 2(d) and 22.2.

### **3.5. Clearinghouse Integrity and Correction**

To preserve the integrity, provenance, and reliability of METI, the Administrator may: (i) reject submissions or request supporting evidence before accepting them; (ii) suspend, annotate, freeze, or restrict records, including disputed records and records as to which legal or agency authority is unclear; (iii) correct errors and reconcile or resolve SSID conflicts under the Source Rulebook, including by maintaining conflicting SSIDs in an encumbered status; (iv) reverse or update lifecycle events where necessary for accuracy or integrity; (v) require periodic verification and re-certification; and (vi) preserve historical records and maintain audit trails. The Source Rulebook governs operational clearinghouse matters; in the event of conflict, the Source Rulebook controls operational matters and these Terms control general legal and contractual matters, subject to Section 22.2.

## 4.      AUTHORIZED USER

**(a)** The rights and responsibilities outlined in these Terms apply to you, the Account Holder, and your successors and authorized assigns. You must ensure that your owners, trustees, partners, members, officers, directors, employees, and agents who access the Services (collectively, the “Representatives” or “Users”) comply with these Terms and any related guidelines.

**(b)** If you wish to hire or contract a third-party agent to access the Services on your behalf, you are required to complete and submit a signed Declaration of Agency form to the METI Administrator. This form will be made available on the Services Site or provided upon request. Please note that only one entity may access an Account at a time. If you grant access to an agent, you will not be able to access the Account yourself unless you revoke the agent's Declaration of Agency.

**(c)**   The rights and licenses provided under these Terms are for your benefit and are to be used only by you and your Representatives in connection with your use of the Services. You may not transfer or sublicense your rights, licenses, or Account, or any portion thereof, to any third party, except as specified in this section.

**(d)** Account Holder agrees to comply with all applicable laws, regulations or other legally enforceable requirements, including without limitation applicable provisions of the USA PATRIOT Act and the regulations of the Office of Foreign Assets Control of the U.S. Department of the Treasury.

**(e)** The Administrator may suspend or restrict an Agent's access, or decline to act on an instruction, where the relevant authority is disputed, expired, revoked, incomplete, or inconsistent with METI records, until the matter is resolved. No posted modification of these Terms expands an Agent's authority or a Principal's obligations except as permitted by Section 2(d).

**(f)** A participant may act as a Custodian/Issuer (registering, issuing, and managing SSIDs, Sources, and records), a Data Accessor or Licensee (consuming METI Data for internal, authorized purposes), an Authorized Data Vendor (redistributing METI Data only under a separate Authorized Data Vendor Agreement), an MRV Provider (submitting or supporting data flows, without redistribution rights), or an Agent (acting within an authorized scope), and may hold more than one role only to the extent authorized under the applicable Operative Document.

## 5.      DATA OWNERSHIP AND CONFIDENTIALITY

**(a)** Account Holder acknowledges that (i) Confidential Information (as defined in Section 5.5) is and shall remain the exclusive property of the party who submitted it or on whose behalf it was submitted, and (ii) Administrator owns or controls METI and the METI platform, including the clearinghouse structure, METI Identifiers, compilations, normalized records, metadata, schemas, taxonomies, and validation outputs, and all METI Data created by or through METI, in each case subject to the Account Holder's retained ownership of its Customer Data under Section 6.2, and including the METI operating system and any components, modifications, adaptations, and copies thereof. All software used in providing, accessing (other than commercially available third-party internet browsers), or using the Services (“Software”) is proprietary software of Administrator. Account Holder shall not obtain, have, or retain any right, title, or interest in or to the METI Services, the Software, or any part thereof. The rights granted to Account Holder are solely defined by these Terms of Use and the Operative Documents.

**(b)** The data transmitted by METI is derived from proprietary and public third-party sources, including data from other participants in the Services. Account Holder will not use METI for any unlawful purpose and will prevent unauthorized use or copying of the Services and related materials by Representatives.

**(c)** Administrator grants Account Holder non-exclusive permission to access, retrieve, and download data from METI subject to these Terms of Use and the Operative Documents. This access is effective only after the Account Holder has: (i) accepted these Terms of Use on the Services Site, (ii) paid all applicable fees, and (iii) completed and submitted the online application, which must be accepted by Administrator. Account Holder must take appropriate steps to protect access, use, and security of METI and user access information.

**(d)** METI, including the selection, arrangement, and compilation of data, may include confidential, market-sensitive, and trade secret information of the Account Holder and other participants. Administrator agrees to (i) use and maintain information provided by Account Holder in accordance with METI’s Data Privacy Policy, and (ii) not use or disclose Confidential Information except as authorized by Account Holder or these Terms of Use. Account Holder agrees not to use or disclose information contained in the METI, including other participants' Confidential Information, except as authorized by the Operative Documents and these Terms of Use. Confidentiality obligations survive the termination of these Terms for as long as the information remains Confidential Information.

**(e)** Confidential Information includes (i) Source data, including Account Holder data, related to SSIDs and EACs; (ii) Data that can be used to reveal identify of an Account Holder’s Account and sub-accounts; (iii) The amount, timing, and counterparty identities of transaction settlement activity facilitated by METI; (iv). Communications between Account Holder and Administrators regarding METI containing any of the aforementioned information.

**(f)** Confidential Information does not include information that: (i) was publicly known prior to disclosure, (ii) becomes publicly known without fault of the Receiving Party, (iii) is received from a third party with the right to disclose it, (iv) is independently developed without access to the Confidential Information, (v) is common technical information, (vi) must be disclosed by law, (vii) is already known to the Receiving Party, or (viii) is otherwise permitted to be disclosed under the Operating Procedures.

**(g)** Confidential Information may be aggregated with other information in METI and included in public reports, provided it is sufficiently aggregated to prevent identification and misuses of the Confidential Information of a particular Account Holder or group of Account Holders.

**(h)** If Account Holder accesses data in the Services that: (i) is not provided or owned by the Account Holder, (ii) is not part of a public Services report, and (iii) Account Holder is not authorized to use, then Account Holder shall: (a) immediately notify Administrator of the access, and (b) not disclose, disseminate, copy, or use such information.

**(i)** Personal data is processed in accordance with the Data Privacy Policy, which controls for personal-data processing; these Terms control for general contractual access and use. The Account Holder will not submit personal data beyond what is necessary for the relevant METI functions.

## 6.      LICENSE GRANT AND USE RIGHTS

### **6.1. License to Access and Use Services**

Subject to Account Holder’s compliance with these Terms and the applicable Operative Documents, Administrator hereby grants to the Account Holder a limited, non-exclusive, non-transferable, non-sublicensable right and license, during the Term, to access and use the Services solely for the Account Holder’s internal business purposes and strictly in accordance with these Terms.

Except for the limited rights expressly granted herein, no other rights in or to the Services or Administrator’s intellectual property are granted, whether by implication, estoppel, or otherwise.

### **6.2. License to Use Account Holder Data**

As between the parties, Account Holder retains ownership of Account Holder Data submitted to or processed through the Services.

Account Holder hereby grants Administrator a non-exclusive, worldwide, royalty-free, non-transferable, non-sublicensable (except to service providers acting on Administrator’s behalf) right and license to host, copy, store, process, transmit, analyze, display, and otherwise use Account Holder Data solely as necessary to:

* operate, provide, maintain, secure, and support the Services;
* administer, validate, reconcile, verify, and manage registry, ledger, custody, and reporting functions within METI;
* fulfill Account Holder’s requests, including data import, export, and reporting;
* comply with applicable law or regulatory obligations; and
* develop, enhance, maintain, and improve the Services and related features, functionality, analytics, and technical METI infrastructure.

Administrator shall use Account Holder Data in accordance with the confidentiality and data protection provisions of these Terms.

### **6.3. Usage Data and De-Identified Data**

Administrator may generate, collect, use, and analyze data derived from Account Holder’s access to and use of the Services, including usage patterns, operational metrics, system performance data, logs, metadata, statistical information, and other technical analytics (“Usage Data”).

Administrator may use Usage Data and other data derived from the operation of the Services to:

* operate, secure, maintain, and support the Services;
* develop, improve, enhance, and optimize the Services and related offerings;
* perform research, analytics, benchmarking, and statistical analysis; and
* improve platform performance, functionality, reliability, and security.

Administrator may publish, disclose, or otherwise utilize Usage Data only in aggregated or de-identified form that does not identify, and cannot reasonably be used to identify, Account Holder, its Confidential Information, or its Authorized Users.

All right, title, and interest in and to Usage Data and any aggregated or de-identified data derived from the Services shall be owned exclusively by Administrator.

### **6.4. Derivative Works and Platform Improvements**

To the extent Administrator develops enhancements, improvements, modifications, analytics, methodologies, models, or other derivative works arising from or relating to the Services (excluding identifiable Account Holder Data), all such materials shall be owned exclusively by Administrator.

Nothing in these Terms restricts Administrator from using generalized knowledge, experience, technical know-how, analytics, insights, or methodologies acquired in the course of providing the Services, provided that no Account Holder Confidential Information is disclosed.

### **6.5. No Redistribution by Default**

The license granted in Section 6.1 is for internal use only. It does not include any right to redistribute, resell, sublicense, syndicate, externally display, provide as a service, host for third parties, include in a data feed, or make available through an API any METI Data, except as expressly authorized under Section 6.6.

### **6.6. No Data Vendor or Redistribution Rights Unless Seperately Granted**&#x20;

**(a)** These Terms do not grant any right to redistribute, resell, sublicense, syndicate, externally display, provide as a service, host for third parties, include in a data feed, make available through an API, or otherwise distribute METI Data to any third party, except as expressly authorized in an Authorized Data Vendor Agreement or applicable Services agreement.

**(b)** A Customer is not an Authorized Data Vendor merely because it has an Account, receives METI Data, integrates with METI, uses an API, pays Fees, or holds any particular role. A party becomes an Authorized Data Vendor only by entering into an Authorized Data Vendor Agreement, and only for the products and channels expressly listed in that agreement.

**(c)** The detailed redistribution permissions, end-user and Affiliate pass-through requirements, reporting, audit, and fee mechanics are set out in the Authorized Data Vendor Agreement and applicable Schedules, and not in these Terms.

### **6.7. Restrictions on Use**&#x20;

Except as expressly permitted by these Terms, an applicable Service Agreement or Operative Document, the Account Holder will not, and will not permit any Authorized User or third party to: (i) scrape, crawl, harvest, or use automated means to extract METI Data; (ii) bulk download or systematically retrieve METI Data; (iii) share, transfer, or pool credentials, or circumvent or exceed any rate limit, technical limit, or field-level entitlement; (iv) reverse engineer, decompile, or disassemble METI, except to the extent prohibited by applicable law; (v) use METI Identifiers outside approved contexts, strip identifiers from METI records for independent reuse, or build identifier crosswalks, lookup services, or external feeds unless authorized; or (vi) use METI Data to create, maintain, enhance, or commercialize a database, clearinghouse, registry, identifier system, reference-data product, certification database, environmental-asset ledger, or similar service that substitutes for or competes with METI (a "Substitute Clearinghouse Product"). Public display of METI Identifiers is permitted only to the extent expressly permitted by these Terms, an applicable Service Agreement, or public-data terms.

### **6.8. API and Integration**

API access requires approved credentials; API keys and tokens are confidential and may not be shared. API use is subject to rate limits, technical limits, field-level entitlements, logging, monitoring, and suspension, and does not imply any redistribution, bulk-feed, or external-display right. Bulk feeds and managed-service or hosted integrations on behalf of third parties require a separate Service Agreement, where applicable, the Administrator's prior written approval. The Administrator may modify the APIs, schemas, endpoints, and entitlements with reasonable notice where commercially practicable.

### **6.9. Derived Outputs; Artificial Intelligence and Machine Learning**&#x20;

Derived Outputs may be created for internal analysis only, within the user's permitted scope; external commercialization or distribution of Derived Outputs requires authorization under an Service Agreement or Authorized Data Vendor Agreement. The Account Holder may not use METI Data to create any output that exposes, reconstructs, reverse engineers, or substitutes for METI Data, the clearinghouse, or the identifier system, or to train, fine-tune, benchmark, validate, or enrich any commercial artificial-intelligence or machine-learning model, unless expressly authorized.

### **7.0. No Other Rights**

Except for the rights expressly granted in this Section 6, no other rights, licenses, or permissions to intellectual property or other proprietary rights are granted or implied.

## 7.      DATA OWNERSHIP AND THIRD PARTIES

### **7.1. General Prohibition of Third-Party Ownership**

Except as otherwise permitted under Sections 6.2 and 6.3 below; (i) Account Holder will only manage data for which it is the sole holder of all legal title and all Ecosystem Services Rights, and (ii) Account Holder may not hold any Accounts, or hold, transfer or manage in its Accounts, any SSIDs on behalf of one or more third parties.

### **7.2.** **Aggregator Exception**

An Account Holder may administer METI Services on behalf of one or more third parties, provided that: (i) Each third party has authorized the Account Holder in writing to manage the legal title to all Ecosystem Services Rights on their behalf. The Account Holder may hold or share legal title to Ecosystem Services Rights only if explicitly authorized by the third party; And (ii) Account Holder maintains an identification program that contains reasonable procedures to verify the identity of any third-party individual or organization on whose behalf Account Holder is administering METI Services and maintains records of the information used to verify such identity, which records will be made available to Administrator upon request.

### **7.3. Optional Omnibus Account**&#x20;

An Account Holder may administer METI Services on behalf of one or more third parties, provided that: (i) Account Holder is a Regulated Person and has provided Administrator a signed Regulated Person Attestation, available at the Services Site; provided, however, that Administrator may, in its sole discretion, waive the requirements set forth in this paragraph with respect to Account Holder by providing Account Holder with written notice of such waiver; (ii) All legal title and Ecosystem Services Rights held by the Account Holder must be held by the third parties who authorize the Account Holder in writing to administer METI Services on their behalf and share any related data with the Administrator. The Account Holder may also hold or share some Ecosystem Services Rights with the one or more third parties if applicable; And (iii) Account Holder maintains an identification program that contains reasonable procedures to verify the identity of any third-party individual or organization on whose behalf Account Holder is administrating METI Services, and maintains records of the information used to verify such identity, which records will be made available to Administrator upon request.

## 8.      FEES

Administrator may, in its sole discretion and upon thirty (30) days’ notice to the Account Holder, establish, increase, decrease, or otherwise modify any or all Fees. All Fees are non-refundable unless otherwise stated. During certain periods, the Administrator may implement temporary pricing or fee adjustments as part of controlled product or service testing.

Fees are set by the applicable Service Agreement, invoice, Authorized Data Vendor Agreement, or enterprise agreement, and may be based on one or more of: SSIDs; Sources; Source Types; acres; projects; account type; custody/issuer role; data-access role; identifiers accessed; data classes accessed; business lines; geographies; API volume; external display; redistribution; certification or verification activity; MRV-provider activity; and data-vendor channel. These Terms do not contain fee tables. The Account Holder must provide accurate usage information on request; expanded use may trigger additional Fees, and underreported use may be invoiced retroactively.

## 9.      PAYMENTS AND TAXES

Invoices for Fees will be sent electronically via email. The Account Holder shall pay any Fees via ACH or wire transfer of immediately available funds in U.S. dollars to the account specified by the Administrator, no later than thirty (30) days from the invoice date (the “Due Date”). All Fees are non-refundable. The Account Holder is responsible for paying all wire transfer fees, sales, use, value-added taxes, and other consumption taxes, personal property taxes, and other charges imposed by any governmental entity (excluding taxes based on the Administrator’s net income) related to the use of METI, unless the Account Holder provides satisfactory proof of exemption. Taxes, if any, are not included in the Fees and will be added to the Account Holder’s invoices if the Administrator is required to pay them.

## 10.      LATE PAYMENTS

If the Account Holder fails to pay any Fees, Taxes, or other charges by the Due Date, the Account Holder will be responsible for paying interest at a rate of 1.5% per month, or the highest rate permitted by applicable law, whichever is lower. Additionally, the Account Holder will be responsible for any costs or expenses incurred by the Administrator in collecting overdue amounts. Acceptance of any interest, cost, or expense payments does not constitute a waiver of the Account Holder’s default or prevent the Administrator from exercising other rights or remedies.

## 11.      TERM AND TERMINATION

### **11.1.** **Term**

These Terms become effective when the Account Holder accepts them on the Service Site and remain in effect until either the Administrator or the Account Holder terminates access to METI.

### **11.2.** **Termination by Administrator**

The Administrator may: (i) Reject the Account Holder’s registration and terminate access immediately before accepting the registration; (ii) Terminate access with five (5) days’ notice if the Account Holder is in default, with immediate termination in the event of certain defaults; And (iii) Terminate access with at least sixty (60) days’ notice for any reason. The Account Holder must pay any Fees due at the time of termination.

### **11.3.** **Termination by Account Holder**

The Account Holder can terminate use of METI with at least sixty (60) days’ notice. The obligation to pay any Fees due at termination survives such termination.

### **11.4. Termination Required by Law**

If required by law or by an order of a court or governmental agency, either party must terminate access to METI. Sixty (60) days’ notice should be given unless a shorter notice period is required.

### **11.5.** **Effect of Termination**

Upon termination, (i) the Terms of Sections 5, 8, 10, 11, 12, 13, 14, 15, 16, 17, 18, 20, and other provisions meant to survive termination or expiration of these Terms, shall survive termination of these Terms of Use; And (ii) Certain sections of the Terms with relation to the data held in the Account Holder’s Account/s will be forfeited upon termination. Before termination, the Account Holder can transfer data to another participant, consistent with the Terms.

Notwithstanding the foregoing, the Administrator may retain Source records, SSID and ledger records, lifecycle and certification records, audit logs, and historical data needed for clearinghouse integrity, provenance, no-double-counting, chain-of-custody, certification, dispute, and compliance purposes.&#x20;

**Requests to delete or erase personal data are governed by the Data Privacy Policy and applicable data-protection law. Where applicable law grants a right of erasure, the Administrator will honor it to the extent required, relying on exemptions available for legal compliance, the defense of legal claims, and registry and archival integrity. Where a record must be retained for the purposes described above but contains personal data subject to a valid erasure right, the Administrator may satisfy that right by de-identifying or anonymizing the personal elements while retaining the de-identified record, and may retain a minimal non-personal record (for example, an SSID and its lifecycle status) where necessary to prevent double-counting or preserve chain-of-custody.**&#x20;

The Administrator makes no representation or warranty of immutability, permanent access, or permanent publication of any record. **Except to the extent of a right that cannot be waived under applicable law,** the Account Holder may not require deletion of records that must be preserved for these purposes.

### **11.6.** **Reinstatement**

The Administrator may reinstate access at its discretion if the Account Holder resolves the default and pays all due Fees. A reinstatement fee equal to the Fees due during the termination period must be paid. If directed by a dispute resolution outcome, the Administrator will reinstate access, with any reinstatement fee determined by the resolution.

## 12.      DEFAULT AND REMEDIES

### **12.1.** **Default**&#x20;

The occurrence of any of the following shall be considered a “Default”:

**(a)** The Account Holder fails to abide by the Terms or perform any duties or obligations under these Terms, not cured within five (5) days after notice specifying the default.

**(b)** The Account Holder fails to pay any Fees, Taxes, or other charges due within five (5) days of their Due Date.

**(c)** The Account Holder or its Representatives tamper with, damage, or destroy METI or any data of other participants.

**(d)** The Account Holder uses METI in a manner that violates any applicable law.

**(e)** The Account Holder's assets are attached or levied under execution, a petition in bankruptcy is filed, the Account Holder becomes insolvent, or similar financial distress occurs.

**(f)** The Account Holder falsifies or misrepresents any data or information provided to METI.

**(g)** The Account Holder makes false representations in these Terms.

**(h)** The Account Holder violates confidentiality obligations.

**(i)** The Account Holder receives notice of a violation of any material term or condition of the Terms three (3) or more times in any twelve (12) month period.

### **12.2.** **Remedies**

Upon the occurrence of any Default, the Administrator shall have the following rights and remedies, in addition to those stated elsewhere and those allowed by law or in equity, any one or more of which may be exercised without further notice:

**(a)** Injunctive relief to prevent further breaches.

**(b)** Obligation for the Account Holder to pay all monies due, including attorney's fees incurred to enforce rights.

**(c)** Notification to Beneficiaries of erroneous SCIDs and EACs, suspension of the Account, administrative fines, and or prohibition of participation in METI.

### **12.3.** **Non-waiver of Defaults**

Failure or delay of the Administrator in exercising any rights or remedies shall not constitute a waiver thereof or affect the right to enforce such right or remedy. No waiver of any Default shall be deemed a waiver of any other Default.

## 13.      INTELLECTUAL PROPERTY

The METI name, brand, and all content and software related to METI, including the clearinghouse structure, METI Identifiers and identifier system, compilations, taxonomies, and schemas, are protected by copyright and other intellectual property laws. Unauthorized use may violate these laws. Except as expressly provided, the Administrator and its affiliates do not grant any rights or licenses under any patents, copyrights, trademarks, or trade secrets. The Account Holder may not copy, distribute, modify, publish, sell, transfer, license, transmit, display, or create derivative works of any intellectual property or information related to METI without express permission.

## 14.      REPRESENTATIONS AND WARRANTIES

### **14.1.** **Legal Authority**

The Account Holder represents and warrants that it is duly organized, validly existing, and in good standing under the laws of its jurisdiction of formation or incorporation. The Account Holder further represents that it has the legal capacity to enter into and perform its obligations under these Terms and that such obligations do not violate or conflict with any laws, regulations, or contractual agreements to which the Account Holder is subject.

### **14.2. Compliance and Authority**

The Account Holder represents and warrants that it has obtained all necessary approvals, consents, licenses, and authorizations required to enter into these Terms and to perform its obligations hereunder. The Account Holder further warrants that its execution, delivery, and performance of these Terms have been duly authorized by all necessary corporate or organizational action and that it will comply with all applicable laws, regulations, and policies in connection with its use of METI.

### **14.3. Authorized Signatory**

The Account Holder represents and warrants that the individual executing these Terms on its behalf has been duly authorized to do so, and that the execution and delivery of these Terms will create legal, valid, and binding obligations enforceable against the Account Holder in accordance with their terms.

### **14.4. Use of METI**

The Account Holder represents and warrants that it will use METI solely for legitimate and lawful purposes as set forth in these Terms. The Account Holder agrees to use METI in a manner consistent with all applicable laws, regulations, and policies and not to engage in any activity that would harm or interfere with the functionality or security of METI.

### **14.5. Accurate Information**

The Account Holder represents and warrants that all data and information provided to the Administrator or entered into METI by the Account Holder or its Representatives are accurate, complete, and truthful. The Account Holder agrees to promptly update any such data or information to ensure its continued accuracy and completeness.

### **14.6.** **No Conflict**

The Account Holder represents and warrants that entering into and performing its obligations under these Terms do not and will not conflict with or result in a breach of any terms, conditions, or provisions of any other agreement to which the Account Holder is a party.

### **14.7. Ownership of Data**

The Account Holder represents and warrants that it has the right to provide all data and information submitted to METI and that such submission does not violate the rights of any third party.

### **14.8. No Infringement**

The Account Holder represents and warrants that its use of METI and the data and information provided therein do not infringe on any intellectual property rights, privacy rights, or other legal rights of any third party.

### **14.9. Financial Stability**

The Account Holder represents and warrants that it is financially solvent and capable of meeting its obligations under these Terms, including but not limited to the payment of any Fees and Taxes.

### **14.10. Compliance with Terms**

The Account Holder represents and warrants that it has read, understood, and agrees to be bound by these Terms and any Operative Documents referenced herein. The Account Holder agrees to comply with these Terms at all times during its use of METI. These representations and warranties are continuous throughout the duration of the Account Holder's use of METI and shall be deemed to be reaffirmed each time the Account Holder accesses or uses METI. The Account Holder agrees to notify the Administrator immediately if any representation or warranty is or becomes untrue or misleading.

## 15.      DISCLAIMER AND WARRANTIES

### **15.1.** **Data and Information**

The data contained in METI has been gathered by the Administrator from sources believed to be reliable, including but not limited to METI participants, Account Holders, and Account Holders’ Representatives. The Administrator does not warrant that the information in METI is correct, complete, current, or accurate, nor does the Administrator warrant that the software will be error-free or bug-free.

### **15.2.** **"As Is" Provision**

METI is provided “as is,” and the Administrator makes no representations or warranties, express or implied, with respect to these Terms, the Operative Documents, or the adequacy or performance of METI. The Administrator hereby disclaims, to the extent permitted by law, any such warranties, including but not limited to warranties of merchantability, non-infringement, title, or fitness for a particular purpose, or any implied warranties arising from any course of dealing, usage, or trade practice. The Administrator does not warrant that the services provided hereunder shall be uninterrupted, error-free, or completely secure, or that the provision of such services shall always be executed without errors or omissions.

### **15.3.** **Acts or Omissions of Participants**

The Administrator shall not be responsible for the acts or omissions of any METI participant or any other party who inputs data into METI or from whom data is obtained for inclusion in METI.

### **15.4.** **Responsibility for Network Security**

The Account Holder is solely responsible for the protection, security, and management of its computer network usage and security. The Administrator shall not compensate the Account Holder for damages incurred due to violations of the security of the Account Holder’s computer network, nor shall the Account Holder make deductions or set-offs of any kind for Fees resulting therefrom.

### **15.5.** **Service Levels and Availability**&#x20;

Any service-level or uptime commitment applies only if and to the extent expressly included in an applicable Service Agreement or enterprise contract. Absent such a commitment, METI is provided subject to reasonable operational availability and to the disclaimers in these Terms, and the Administrator retains the right to perform maintenance and to apply security controls, upgrades, suspension, and emergency interventions. Any ninety-nine percent (99%) or other uptime commitment in a Service Agreement applies only to that agreement and is not a general or universal warranty under these Terms.

### **15.6.** **No Outcome Guarantee; Environmental Claims**

METI is designed as authoritative environmental clearinghouse and reference-data infrastructure. Clearinghouse status does not, of itself, guarantee legal compliance, any environmental outcome, market value, buyer acceptance, eligibility under any third-party standard, regulatory recognition, or any tax or accounting treatment. The Account Holder is responsible for the claims it makes using METI Data, for its compliance with applicable environmental, consumer-protection, anti-greenwashing, certification, reporting, tax, accounting, securities, commodities, and other rules, and for verifying whether METI Data is sufficient for its specific claim, filing, disclosure, or certification.

## 16.      LIMITATION OF LIABILITIES

### **16.1.** **Responsibility and Risk**

The Account Holder assumes full responsibility and risk of loss resulting from its use of METI and the METI Site.

### **16.2.** **Limitation of Liability**&#x20;

The Administrator’s sole liability for METI, service disruption, performance or nonperformance by the Administrator, or in any way related to these Terms, regardless of whether the claim for damages is based in contract, tort, strict liability, or otherwise, is limited, to the extent permitted by law, to an aggregate amount equal to the greater of (i) the Fees paid by the Account Holder hereunder during the calendar year immediately preceding the date any such claim is made by the Account Holder and (ii) the Fees paid by the Account Holder hereunder during the calendar year in which any such claim is made by the Account Holder.

### **16.3.** **Exclusion of Damages**

The Administrator shall not be liable for consequential, incidental, special, exemplary, or other indirect damages regardless of cause, nor for economic loss, loss of use, loss of data, loss of business, personal injuries, or property damages sustained by the Account Holder or any third parties, even if the Administrator has been advised by the Account Holder or any third party of such damages.

### **16.4.** **Disclaimer of Liability**

The Administrator disclaims any liability for errors, omissions, or other inaccuracies in any part of METI, or the reports, certificates, or other information compiled or produced by and from or input into METI.

### **16.5.** **Release of Liability**

To the maximum extent permitted by law, the Account Holder hereby releases and protects the Administrator, any subsidiaries or other corporate affiliates thereof, their successors and assigns, agents, contractors, service providers, and vendors from any and all liability with respect to any damages or injuries incurred by the Account Holder as it relates to METI.

## 17.      LOGINS, PASSWORDS, AND IDS

The Account Holder is responsible for the security of its logins, passwords, IDs, and of any API keys and tokens, all of which are confidential and issued for accessing METI. Any unauthorized use must be reported to the Administrator immediately.

## 18.      INDEMIFICATION

### **18.1.** **Indemnification by Account Holder** &#x20;

Except to the extent finally determined by a court of competent jurisdiction to have resulted from the Administrator’s gross negligence, fraud, or willful misconduct, the Account Holder will indemnify, defend, and hold harmless the Administrator, its affiliates, and their respective officers, directors, employees, agents, licensors, service providers, successors, and assigns from and against all claims, demands, actions, proceedings, investigations, liabilities, losses, damages, judgments, settlements, penalties, fines, costs, and expenses, including reasonable attorneys’ fees, arising out of or relating to:

**(a)** the Account Holder’s or its Authorized Users’, Agents’, Service Providers’, MRV Providers’, downstream recipients’, or representatives’ access to, use of, reliance on, redistribution of, publication of, or other exploitation of METI, METI Data, METI Identifiers, or any METI-related services, systems, outputs, records, or materials;

**(b)** any breach or alleged breach of these Terms, any applicable law, regulation, rule, order, standard, contractual obligation, third-party right, or METI policy, technical requirement, data-use restriction, or attribution requirement;

**(c)** any unauthorized access to, use of, disclosure of, redistribution of, sublicensing of, commercialization of, modification of, or derivative use of METI Data or METI Identifiers;

**(d)** any false, misleading, incomplete, inaccurate, unauthorized, or unlawful submission, representation, certification, environmental claim, market claim, registry claim, disclosure, report, or other statement made by or on behalf of the Account Holder, including any claim using or referencing METI Data, METI Identifiers, or METI-derived outputs;

**(e)** Account Holder Data, including any claim that Account Holder Data, or the Administrator’s receipt, hosting, processing, display, use, or publication of Account Holder Data in accordance with these Terms, infringes, misappropriates, or violates any intellectual property, privacy, publicity, contractual, confidentiality, data-protection, or other third-party right; and

**(f)** any decision, act, omission, transaction, investment, certification, verification, disclosure, market activity, regulatory filing, environmental claim, or other reliance by the Account Holder or any third party based on METI, METI Data, METI Identifiers, Account Holder Data, METI-related outputs, or any alleged inaccuracies, errors, omissions, interruptions, delays, unavailability, or limitations in the foregoing.

### **18.2.** **Indemnification by Administrator**

Subject to these Terms, the Administrator will indemnify, defend, and hold harmless the Account Holder from and against any third-party claim alleging that the Administrator’s proprietary software platform, documentation, or other Administrator-owned materials made available through METI, when used by the Account Holder in accordance with these Terms, infringe or misappropriate that third party’s copyright, trademark, trade secret, or other intellectual property right.

The Administrator will have no obligation under this Section 18.2 to the extent a claim arises out of or relates to: (a) Account Holder Data or any data, materials, submissions, instructions, or content provided by or on behalf of the Account Holder or any third party; (b) METI Data, METI Identifiers, outputs, reports, analytics, or other materials to the extent derived from, based on, or incorporating Account Holder Data, third-party data, public-source data, registry data, MRV provider data, or other non-Administrator materials; (c) use of METI, METI Data, METI Identifiers, or related materials in breach of these Terms or outside the rights granted to the Account Holder; (d) modification of Administrator-provided materials by anyone other than the Administrator; (e) combination, integration, or use with software, systems, data, materials, processes, or services not provided by the Administrator, where the claim would have been avoided without such combination, integration, or use; (f) continued use after the Administrator provides notice of a potential or actual infringement claim or provides a non-infringing alternative; or (g) any environmental, market, registry, certification, verification, disclosure, investment, transaction, or regulatory claim made by or on behalf of the Account Holder or any downstream recipient.

If the Administrator reasonably determines that METI or any Administrator-provided material may be subject to an infringement or misappropriation claim, the Administrator may, at its option and expense: (i) procure the right for the Account Holder to continue using the affected item; (ii) replace or modify the affected item so that it is non-infringing while providing materially similar functionality; or (iii) suspend or terminate access to the affected item or to METI, in whole or in part.

## 19.      FORCE MAJEURE

No Party shall be deemed to have breached any provision of these Terms as a result of any delay, failure in performance, or interruption of service resulting from events beyond their reasonable control, including acts of God, network failures, civil disturbances, wars, terrorism, fires, floods, strikes, and other similar events.

## 20.      NOTICES

All notices must be in writing and delivered in person, by email, or by first-class, registered, or certified mail. Notices to the Administrator should be sent to the provided address. Notices to the Account Holder will be sent to the address provided at registration.

If to Administrator:

MillPont, Inc.

666 Grand Ave, Ste 2000

Des Moines, Iowa 50309

Attn: METI Administrator

<info@millpont.com>

## 21.      GOVERNING LAW AND DISPUTE RESOLUTION

### **21.1.** **Governing Law**

These Terms of Use shall be governed exclusively by the laws of the State of Iowa without regard to its rules on conflicts of laws to the extent they would require the application of the laws or procedures of a different jurisdiction.

### **21.2.** **Initial Dispute Resolution**

The Parties shall first attempt in good faith to settle any controversy or claim arising out of or relating to these Terms of Use, the breach thereof, or the use of METI (any such claim, a “Dispute”), by direct negotiation between the principals or a designee of the principals of each Party. Direct negotiation shall commence upon the delivery of notice by a Party of a Dispute. Direct negotiation shall conclude on or before the forty-fifth (45th) day following delivery of notice of the Dispute.

### **21.3. Arbitration**

Any Dispute that has not been resolved by direct negotiation shall be finally resolved by arbitration administered by the American Arbitration Association (“AAA”). Disputes of one hundred thousand dollars ($100,000.00) or less shall be heard under the AAA Expedited Commercial Rules and Procedures (“Expedited Rules”) then in effect. Disputes that exceed one hundred thousand dollars ($100,000.00) shall be heard under the Commercial Arbitration Rules and Supplementary Procedures for Online Arbitration (“Commercial Rules”) then in effect.&#x20;

SSID and clearinghouse-record conflicts are first addressed under the Source Rulebook's conflict-resolution process before arbitration of any underlying contractual Dispute.

### **21.4.** **Selection of Arbitrators**

(i) For Disputes pursuant to the Expedited Rules, the AAA shall appoint an arbitrator with commercial experience with contracts and/or commodities. (ii) For Disputes pursuant to the Commercial Rules, the AAA shall deliver to the Parties a list of arbitrators with commercial experience with contracts and/or commodities, including diverse persons from the AAA roster. The Parties will strike and rank the arbitrators contained on the list until they arrive at three (3) arbitrators to hear the Dispute. If the Parties cannot agree on at least one (1) or more arbitrators from the ranked list, each Party shall select one Party-appointed arbitrator from the list provided by the AAA. The Party-appointed arbitrators shall then select the third (3rd) arbitrator, who shall serve as chair of the tribunal, from a list provided by the AAA containing the names of arbitrators who meet the criteria set forth above.

### **21.5. Arbitration Procedures**&#x20;

(i) Limited disclosures shall be as agreed to by the Parties or, if there is no agreement, as ordered by the arbitrators after due consideration of each Party’s position at the initial preliminary hearing. (ii) The arbitrators shall have no authority to award punitive damages or any other damages not measured by a prevailing Party’s actual damages, and may not, in any event, make any ruling, finding, or award that does not conform to the terms and conditions of these Terms of Use. (iii) A standard award shall be prepared by the arbitrators unless the Parties agree otherwise in a written amendment. The award may be confirmed in a state or federal court within Polk County, Iowa (which proceeding shall be filed under seal). The arbitration and resulting award shall be deemed confidential by the Parties, their representatives, the arbitrators, and the AAA.

### **21.6.** **Costs and Fees**&#x20;

(i) The Party filing a demand for arbitration with the AAA regarding the Dispute shall be responsible for the AAA case administration fees. (ii) Each Party shall be responsible for one-half of the arbitrators’ fees. Other than the arbitrators’ fees, each Party is responsible for its own costs associated with the resolution of a Dispute, including but not limited to AAA or court filing fees, attorneys’ fees, and other costs incurred in prosecuting or defending a Dispute.

## 22.      ENTIRE AGREEMENT; ORDER OF PRECEDENCE&#x20;

### **22.1.** **Entire Agreement**

These Terms, along with any applicable Operative Documents and Service Agreement(s), constitute the entire agreement between the Parties regarding the subject matter and supersede any prior agreements.

### **22.2.** **Order of Precendence**

In the event of conflict among these Terms, the Operative Documents, and any applicable Service Agreement(s), the following order of precedence applies, from highest to lowest: (1) any signed Service Agreement, master services or negotiated enterprise agreement; (2) an Authorized Data Vendor Agreement, for authorized redistribution activities; (3) the applicable Order Form or account agreement; (4) product, data, API, and use-of-service Schedules and service descriptions; (5) the Source Rulebook, for operational clearinghouse matters; (6) the Data Privacy Policy, for personal-data processing; (7) these Terms of Use; and (8) documentation, website notices, FAQs, and support materials.&#x20;

Notwithstanding this order, the Source Rulebook controls operational clearinghouse matters and the Data Privacy Policy controls personal-data processing, and no document or later-posted version of these Terms expands an Agent's authority or a Principal's obligations except as permitted by Section 2(d).

## 23.      CONTACT INFORMATION

For any questions about these Terms, please contact us at:

Email: <info@millpont.com>

Website: [millpont.com](https://millpont.com/)

[<br>](https://millpont.gitbook.io/docs)


# Source Rulebook (V0.9)

**Content**

1. [OVERVIEW](#id-1.-overview)
2. [GOVERNANCE AND OVERSIGHT](#id-2.-governance-and-oversight)
3. [GUIDING PRINCIPLES](#id-3.-guiding-principles)
4. [CUSTODIAN RESPONSIBILITIES AND REQUIREMENTS](#id-4.-custodian-responsibilities-and-requirements)
5. [SOURCE LEDGER AND DATA SUBMISSION REQUIREMENTS](#id-5.-source-ledger-and-data-submission-requirements)
6. [CHAIN OF CUSTODY DOCUMENTATION REQUIREMENTS](#id-6.-chain-of-custody-documentation-requirements)
7. [ANNUAL COMPLIANCE VERIFICATION](#id-7.-annual-compliance-verification)
8. [DATA SECURITY AND OPERATIONAL INTEGRITY](#id-8.-data-security-and-operational-integrity)
9. [SSID CONFLICT RESOLUTION PROCESS](#id-9.-ssid-conflict-resolution-process)
10. [RULEBOOK GOVERNANCE ](#id-10.-rulebook-governance)
11. [RULEBOOK UPDATE PROCEDURES](#id-11.-rulebook-updates-procedures)

## 1.     OVERVIEW

### **1.1.**   **Purpose**

**(a)** A core document of the MillPont Environmental Trust Infrastructure ("METI") clearinghouse platform, the METI Source Rulebook (the “Rulebook”) outlines the guidelines and protocols that govern the operations of the METI Source Ledger (“MSL”). The MSL is designed to provide a verifiable and transparent means for managing Secure Source Identifiers (“SSIDs”) tied to Environmental Attribute Certificates (“EACs”) across independent attribute tracking systems and critical font- and back-office operations in various agricultural commodities and value chains.

**(b)** The Rulebook incorporates over two decades of best practices in environmental attribute tracking, aligned with both the [International Attribute Tracking Standard](https://www.trackingstandard.org/the-standard/) (“IATS”) and [the Commodity Futures Trading Commission's (“CFTC”) No Double-Counting Guidance](https://www.federalregister.gov/d/2024-23105/p-440) to prevent duplicative claims and double issuances of EACs. Through the MSL, METI enables Market Participants to securely submit, verify, and manage geospatial, temporal and attribute data, ensuring each source is uniquely registered, comparable and traceable through the EAC lifecycle in compliance with global standards for data accuracy, non-duplication, and operational transparency.

### **1.2.   Scope**

This Rulebook applies to all METI Members, partners, and stakeholders involved in data submission, verification, and claim management through the MSL. It covers the full data lifecycle from initial submission to claim verification, including data security measures, periodic audits, and procedures for SSID conflict resolution. The comprehensive approach ensures that MSL represents the highest industry standards for accuracy, non-duplication, and reliable reporting. This Rulebook supplements the METI Terms of Use (“Terms of Use”). In the event of any conflict, the Terms of Use provisions take precedence.

### &#x20;**1.3.** **General Definitions**

* **Account:** A data store within MillPont Environmental Trust Infrastructure (“METI”) attributed to an Account Holder and used to access, submit, administer, or receive records, data, identifiers, or other information through the METI Platform, subject to the Terms of Use, applicable Rulebook(s), approved role entitlements, and any applicable Operative Documents.
* **Account Holder:** A User or other approved party that has been accepted by the METI Administrator for an Account in METI and is responsible for its own use of the Services and the use of the Services by its Users, Representatives, agents, and authorized designees.
* **Beneficiary:** Has the meaning given in the Terms of Use. For purposes of this Source Rulebook, a Beneficiary is a party that receives, claims, holds, or is entitled to receive Ecosystem Services Rights or quantified environmental benefits conveyed, documented, registered, transferred, or otherwise supported through EACs, SSIDs, or related METI records.
* **Custodian:** Has the meaning given in the Terms of Use. For purposes of this Source Rulebook, a Custodian is a party responsible for the custody, management, and administrative oversight of one or more SSIDs, including issuance, distribution, tracking, and, where applicable, underwriting of EACs associated with those SSIDs. A Custodian must maintain an active commercial agreement with the relevant Source owner, Landowner or Operator, or Beneficiary whose agreement is tied to the relevant Source. A Custodian’s access to create, modify, or administer records in the METI Source Ledger is limited to the rights granted under its Account, applicable agreements, approved entitlements, the Terms of Use, this Source Rulebook, and other applicable Operative Documents.
* **Ecosystem Services Rights:** Has the meaning given in the Terms of Use.
* **Entity:** A legally recognized organization, institution, governmental body, partnership, corporation, association, trust, or individual. Status as an Entity does not itself create a right to access METI, hold an Account, administer SSIDs, or act in any METI role unless approved by the METI Administrator under the Terms of Use, this Source Rulebook, and applicable Operative Documents.
* **Environmental Attribute Certificate or Claim (“EAC”):** Has the meaning given in the Terms of Use. For purposes of this Source Rulebook, an EAC is a market-based instrument or claim record associated with Ecosystem Services Rights or quantified environmental benefits and may be linked to one or more SSIDs to support provenance, chain of custody, traceability, exclusivity, or double-counting controls.
* **Know Your Customer (“KYC”):** The know-your-customer, sanctions, counterparty, beneficial ownership, authority, eligibility, and other diligence or evaluation criteria implemented by the METI Administrator under applicable law, the Terms of Use, good industry practice, or applicable Operative Documents.
* **Labeling Authority:** An organization that establishes standards, methodologies, criteria, or labels for EACs or related environmental claims and determines, validates, certifies, or supports whether EACs or claims conform to those standards.
* **Landowners and Operators:** Has the meaning given in the Terms of Use. For purposes of this Source Rulebook, Landowners and Operators include one or more related individuals or entities that own, operate, control, manage, or hold relevant rights in the Source, the associated Ecosystem Services Rights, or the activities giving rise to an EAC.
* **Local Working Instructions (“LWIs”):** A document or set of documents maintained and adopted by a Custodian that defines operational procedures, data requirements, quality controls, issuance controls, administration standards, and distribution procedures for EACs, SSIDs, or related Source records. LWIs must be consistent with the Terms of Use, this Source Rulebook, applicable Operative Documents, and any relevant standards, methodologies, or scientific requirements.
* **Market Participant:** An Account Holder or other approved party that participates in METI in a role involving SSIDs, EACs, Source records, Ecosystem Services Rights, data submissions, data access, or related transactions. Market Participants may include Landowners and Operators, Custodians, Beneficiaries, MRV Providers, Registries, Labeling Authorities, and other approved participants, as applicable. A Market Participant may designate a third-party agent only in accordance with the Terms of Use and an accepted Declaration of Agency.
* **Member and Membership Status:** A party recognized by the METI Administrator as having satisfied the applicable onboarding, eligibility, agreement, role, and compliance requirements for one or more METI Services. Membership Status reflects the Administrator’s confirmation of a party’s standing for the relevant Services and may be limited, suspended, conditioned, or terminated in accordance with the Terms of Use, this Source Rulebook, and applicable Operative Documents.
* **METI Administrator:** MillPont, Inc., in its capacity as administrator of MillPont Environmental Trust Infrastructure, responsible for administering the METI Platform, implementing applicable Operative Documents, and overseeing the Services in accordance with the Terms of Use.
* **METI Platform:** The digital infrastructure, systems, ledgers, interfaces, services, accounts, tools, and related functionality administered by the METI Administrator for the administration, recording, comparison, exchange, verification, or management of SSIDs, EACs, Source records, and related environmental-claim data.
* **METI Source Ledger (“MSL”):** The electronic accounting ledger within the METI Platform used to record, store, track, compare, and administer data submissions, SSIDs, Source records, EAC linkages, and related claims or metadata. The MSL supports provenance, chain of custody, exclusivity, conflict detection, and double-counting controls for environmental claims and related records.
* **MRV Platform:** A monitoring, reporting, and verification platform, system, tool, or service that collects, validates, analyzes, stores, or reports data related to environmental activities, Sources, SSIDs, EACs, or associated environmental outcomes. An MRV Platform may integrate with the METI Source Ledger where approved by the METI Administrator.
* **MRV Provider:** An Entity that administers or operates an MRV Platform or otherwise provides monitoring, reporting, verification, data collection, validation, audit, or environmental-outcome measurement services related to SSIDs, EACs, Sources, or Source records. An MRV Provider may be part of a Custodian’s organization or may operate as an independent third-party provider, subject to applicable approval, agreements, and role entitlements.
* **Omnibus Custodian:** A Custodian, MRV Provider, or other approved Entity authorized to manage, administer, or oversee one or more SSIDs, EACs, Accounts, or Source records on behalf of another party pursuant to an accepted Declaration of Agency or other written authorization approved by the METI Administrator. An Omnibus Custodian is responsible for its use of METI clearing services on behalf of its principal and remains subject to the Terms of Use, this Source Rulebook, applicable Operative Documents, and any applicable financial, data-integrity, and compliance obligations.
* **Registry:** A database, ledger, platform, or system that records the issuance, ownership, transfer, retirement, redemption, cancellation, or other lifecycle status of EACs or related environmental claims. A Registry may also act as, integrate with, or support a Labeling Authority.
* **Resolution Period:** A timeframe designated by the METI Administrator during which an identified conflict, incompatibility, duplication, overlap, or other issue involving SSIDs, Sources, EACs, or related records may be investigated, corrected, resolved, suspended, escalated, or otherwise administered in accordance with the Terms of Use, this Source Rulebook, and applicable Operative Documents.
* **Secure Source Identifier (“SSID”):** Has the meaning given in the Terms of Use. For purposes of this Source Rulebook, an SSID is a unique, addressable, 16-character digital identifier representing exclusivity over a Source for a defined period of time and a specific type of environmental attribute. SSIDs support provenance, chain of custody, data integrity, traceability, conflict detection, and comparison across approved platforms, workflows, and records.
* **Source:** Has the meaning given in the Terms of Use. For agricultural-based projects, a Source is the point of origin of an EAC and may consist of a single parcel or a group of related boundary polygons treated as one operational field, production unit, or managed area, provided the boundary or boundaries have a) common or coordinated management, b) common land cover or operational use, c) common ownership or operating control, and d) a common project administrator or Custodian.
* **Source Type**: Has the meaning given in the Terms of Use.&#x20;

Capitalized terms used but not defined in this Source Rulebook have the meanings given to them in the METI Terms of Use. If a definition in this Source Rulebook conflicts with the METI Terms of Use, the Terms of Use control, except where this Source Rulebook expressly provides a more specific operational meaning for use within the METI Source Ledger.

### **1.4.   Organizational Structure**

The Rulebook serves as an overarching governance document for METI’s Source Ledger, ensuring consistent application of the platform’s principles and procedures. The governance structure is led by the METI Governance Committee composed of industry stakeholders, METI Originate Members, and independent experts who provide strategic oversight and guidance. This committee plays a crucial role in maintaining the integrity and alignment of the Rulebook with best practices and evolving industry standards. MillPont, Inc., designated as the METI Administrator, is responsible for the practical implementation of the Rulebook’s protocols. MillPont manages the day-to-day operations, ensuring that the Rulebook’s principles, processes, and procedures are applied effectively and are continuously refined to meet the Rulebook’s requirements. This structure supports a collaborative and transparent operational framework that fosters trust and engagement among all METI Members and market participants.

&#x20;

<figure><img src="https://935478215-files.gitbook.io/~/files/v0/b/gitbook-x-prod.appspot.com/o/spaces%2FsOHSoZVLzSuaTRyLHoDS%2Fuploads%2FjWUuv1wHAdirUJ9SR6X3%2FPicture1.png?alt=media&amp;token=582a0c9b-2db5-4ef1-a295-baadc3844863" alt=""><figcaption><p>METI Organizational Structure</p></figcaption></figure>

### **1.5.   Alignment with International Standards/Protocols**

These include Greenhouse Gas Protocol (“GHGP”), Science-Based Target Initiative (“SBTi”), Value Change Initiative (“VCI”) Guidance, International Attribute Tracking Standard (“IATS”), ISO 14064-1-4, and the Commodity Future Trading Commission’s (“CFTC”) Guidance on No-Double Counting.

## &#x20;2.     GOVERNANCE AND OVERSIGHT

### **2.1.   Role of METI Governance Committee:**&#x20;

The METI Governance Committee is comprised of METI Members, industry stakeholders, and independent experts. This governance structure ensures that METI remains aligned with the principles of transparency, integrity, and continuous improvement. This body is responsible for:

#### *<mark style="color:red;">**2.1.1. Approving and Amending Processes**</mark>*

Overseeing updates to the Rulebook and approving new or revised protocols to ensure they are seamlessly integrated into platform operations.

#### *<mark style="color:red;">**2.1.2. Advising METI Administrators**</mark>*

Providing strategic guidance to align METI processes and procedures with evolving standards and best practices.

#### *<mark style="color:red;">**2.1.3. Ensuring Fair and Transparent Governance**</mark>*

Upholding the fairness and integrity of METI operations.

### **2.2.   Role of METI Administrators**

METI Administrators, represented by MillPont, Inc., are tasked with maintaining the governance and oversight of METI Platform and the MSL. Their primary responsibilities include:

#### *<mark style="color:red;">**2.2.1. Administering Compliance**</mark>*

Monitoring member activities to ensure adherence to the METI Rulebook/s, Terms of Use, and operational protocols to maintain the platform's credibility.

*<mark style="color:red;">**2.2.2. Guiding Operational Integrity**</mark>*

Providing guidance to align operations with industry best practices and adapting to new environmental standards and legal frameworks.

*<mark style="color:red;">**2.2.3. Facilitating Member Engagement**</mark>*

Acting as a liaison between METI and its members to address questions, clarify procedures, and support continuous improvement in data submission and record management.

*<mark style="color:red;">**2.2.4. Dispute Resolution**</mark>*

Acting as an independent mediator in member disputes as specified by the Terms of Use, relevant Rulebook/s, and applicable contractual agreements.

### **2.3.   Oversight Mechanisms**

METI Administrators employ various oversight mechanisms to uphold platform standards, including:

#### *<mark style="color:red;">**2.3.1. Routine Audits and Monitoring**</mark>*

Conducting periodic audits and monitoring member activities to ensure adherence to the Rulebook.

#### *<mark style="color:red;">**2.3.2. Data Integrity Protocols**</mark>*

Protecting the accuracy and reliability of data within the Source Ledger.

#### *<mark style="color:red;">**2.3.3. Transparency and Accountability**</mark>*&#x20;

Members must support these administration activities by providing documentation and participating in reviews, with METI ensuring the protection of confidential information.

### **2.4.   Member Responsibilities**

METI Member responsibilities include:&#x20;

#### *<mark style="color:red;">**2.4.1. Statement of Compliance**</mark>*

All members of METI, including METI Originate Members, must comply fully with the Terms of Use and this Rulebook.&#x20;

#### *<mark style="color:red;">**2.4.2. Legal Obligations**</mark>*

Upholding confidentiality, intellectual property rights, and data privacy as outlined by Terms of Use and this Rulebook.&#x20;

#### *<mark style="color:red;">**2.4.3. Data Integrity**</mark>*

Submitting data that is accurate, complete, and aligned with METI’s rules and procedures to maintain a trusted clearinghouse.

#### *<mark style="color:red;">**2.4.4. Transparency**</mark>*

Ensuring environmental claims are verifiable and contribute to sustainability goals, reinforcing trust in the platform.

### **2.5.   Compliance Oversight**

**(a)** METI Administrators monitor member activities to ensure compliance, while respecting business-sensitive information. Members are expected to: (i) Provide necessary documentation upon request; And (ii) Facilitate reviews to confirm adherence to compliance standards.

**(b)** These responsibilities are integral to fostering confidence in transparent and high-integrity market operations, ensuring that all environmental claims are accurate and verifiable, and contributing to the platform’s overall mission of enhancing environmental market reliability and scale.

## &#x20;**3.     GUIDING PRINCIPLES**&#x20;

The METI Source Rulebook is guided by a set of principles that define its operations, governance, and member interactions. These guiding principles collectively support the MSL mission to operate as a transparent, secure, and adaptable clearinghouse for environmental assets, reinforcing MillPont's commitment to reliability and trust in the global marketplace.&#x20;

### **3.1.   Transparency**

Transparency is a cornerstone of MSL operations, ensuring that all participants have access to essential information:

#### *<mark style="color:red;">**3.1.1. Confidential Transparency**</mark>*

The MSL upholds participants’ right to comprehensive information about the origin, attributes, and handling of environmental assets while balancing the protection of data sovereignty, anonymity, and trade secrets. This approach supports traceability for producers and verification confidence for end-users.

#### *<mark style="color:red;">**3.1.2. Clear Communication**</mark>*

MillPont prioritizes clear, accurate, and timely communication to maintain trust and facilitate effective member participation.

### **3.2.   Data Integrity and Accuracy**

#### *<mark style="color:red;">**3.2.1. Accurate Data Submission**</mark>*

Members are required to submit complete, verified data that aligns with METI’s standards.

#### *<mark style="color:red;">**3.2.2.**</mark>* *<mark style="color:red;">**Continuous Verification**</mark>*

METI Administration conducts ongoing audits and checks to ensure data quality and prevent errors.

#### *<mark style="color:red;">**3.2.3.**</mark>* *<mark style="color:red;">**Evidence-Based Ownership**</mark>*

Ownership of SSIDs and associated claims must be verifiable through documented evidence to uphold trust in the MSL.

### **3.3.   Traceability and Chain of Custody**

#### *<mark style="color:red;">**3.3.1. Unique and Exclusive Identification**</mark>*

Every EAC source is assigned a Secure Source Identifier (SSID) to prevent duplication and ensure traceability. An SSID is a unique and addressable digital statement that represents exclusivity over a geographic extent for a period of time for a specific type of environmental attribute. In EAC markets, only one SSID statement has an effect at any one point in time. When an SSID overlaps with another, then a conflict exists on the MSL until it is resolved to a distinct and exclusive claim.

#### *<mark style="color:red;">**3.3.2. Continuous Chain of Custody**</mark>*

The platform maintains a clear chain of possession from the Land Owner/Operator to the end-user/Beneficiary, supporting verifiable ownership and claims. It is mandatory that the possession of an SSID to be always verifiable.

#### *<mark style="color:red;">**3.3.3. Compatibility with External Systems**</mark>*

METI’s framework integrates with member-managed systems to align data and avoid duplication, enhancing the overall traceability of environmental assets.

### **3.4.   Security and Data Protection**

#### &#x20;*<mark style="color:red;">**3.4.1. Secure Infrastructure**</mark>*

METI employs robust encryption and secure infrastructure to protect data at rest and during transfer.

#### *<mark style="color:red;">**3.4.2. Controlled Access**</mark>*

Access to data is restricted to authorized members, ensuring secure data handling.

#### *<mark style="color:red;">**3.4.3. Sustainable and Resilient Processes**</mark>*

Infrastructure is designed to provide reliable and continuous service that meets market needs.

### **3.5.   Adaptability**

METI adapts to changes in technology, regulatory frameworks, and market requirements:

#### *<mark style="color:red;">**3.5.1. Support for Innovation**</mark>*

METI fosters the implementation and exploration of new governance models and environmental accounting frameworks.

#### *<mark style="color:red;">**3.5.2. Flexibility**</mark>*

The platform applies a principle of proportionality to ensure that operations remain fair, effective, and equitable across different scenarios.

#### *<mark style="color:red;">**3.5.3. Continuous Evolution**</mark>*

Practices and technologies are regularly updated to remain in alignment with market needs and harmonized standards.

### **3.6.   Independence and Fair Access:**&#x20;

Ensuring fairness and impartiality in market operations is fundamental. To achieve this, METI Administration takes several measures to maintain the integrity of the MSL, aiming to remove conflicts of interests from operational decision making and incentive structures. These include, but are not limited to:

#### *<mark style="color:red;">**3.6.1. Non-Participation in Markets**</mark>*

METI Administration maintains independence by not participating in the markets it oversees and or interacts with, ensuring an unbiased approach and avoiding conflicts of interest.

#### *<mark style="color:red;">**3.6.2. Inclusive Participation**</mark>*

METI Administration is committed to preventing discrimination and reducing barriers to market access, ensuring broad and fair participation.

### 3.7.   Stakeholder Engagement

METI Administration actively involves stakeholders to align its processes with industry standards and best practices, including:&#x20;

#### *<mark style="color:red;">**3.7.1. Feedback Integration**</mark>*

Designing, maintaining, and updating regular processes and procedures for soliciting feedback from members and key stakeholders to refine procedures and enhance platform functionality.

#### *<mark style="color:red;">**3.7.2. Collaboration**</mark>*

Actively seeking engagement with industry leaders and complementary systems to strengthen the market’s overall reliability and cohesion.

### 3.8.   Compliance with Regulations

The Source Ledger ensures adherence to all relevant legal and regulatory requirements:

#### *<mark style="color:red;">**3.8.1. Regulatory Compliance**</mark>*

All operations are conducted in accordance with applicable laws and standards across jurisdictions to maintain legal integrity and market trust.

## 4.     CUSTODIAN RESPONSIBILITIES AND REQUIREMENTS

### 4.1.   General Responsibilities

The main responsibility of a Custodian is to facilitate the registration of SSIDs and underwrite and manage EACs for which the Custodian maintains contractual rights to administer. A Custodian may be any form of a legally recognizable entity, including a government authority, non-governmental organization, and or commercial enterprise.

#### *<mark style="color:red;">**4.1.1. Commercial Relationships**</mark>*&#x20;

The registration and management of SSIDs on the METI Source Ledger requires auditable commercial agreements between the Custodian and the underlying Landowner/s and Operator/s, and or, between the Custodian and Beneficiary/s who may hold the commercial relationship and agreements with the Land Owner/s and Operator/s. The commercial agreements should clearly define the services provided and ensure that the registration and management of SSIDs is aligned with those services. A Custodian may not request and manage any SSID they are not authorized to do so by a commercial agreement. Any deviations from commercial terms that would alter or remove the rights to administer SSIDs by the Custodian should be discussed with METI Administration to ensure adherence to the Principle of Data Integrity and Accuracy.

#### *<mark style="color:red;">**4.1.2. Minimum  Qualifications**</mark>*

Custodians are required to have appropriate training, staff, and a degree of professionalism consistent with good industry practice and shall demonstrate competence to operate in the capacity for which they are serving Market Participants. This includes complying with METI’s KYC requirements and proper registration, accreditation, and licensing in compliance with the legislation in the geographies and countries wherever Custodians provide services.

#### *<mark style="color:red;">**4.1.3. SSID Requests**</mark>*

Only a registered Custodian may request, manage and modify an SSID issued by METI. SSID requests can only be made when a Custodian has satisfied the commercial agreements required to evidence that an SSID issued on the METI Source Ledger is a unique and exclusive representation of the relevant Source for a given time period and environmental attribute. SSID requests may not be made in speculation, or prior to the effective date of administration as evidenced by the relevant commercial agreement/s. &#x20;

### 4.2.   Membership Requirements

Custodians shall demonstrate competence to operate in the capacity for which they are required by the METI Source Rulebook. The Administration has sole authority to assess the adequacy of adherence to the Rulebook’s requirements and grant or revoke any resulting Membership. The Administration may grant conditional or limited Membership where there are concerns related to competition, legislative implementation, or other requirements related to adherence to best practice. Unless explicitly stated, the following requirements shall apply to all Custodial Members and evidence of ongoing compliance with these requirements shall form part of the annual membership accreditation and verification process outlined in [Section 7](#id-7.-annual-compliance-verification).  &#x20;

#### *<mark style="color:red;">**4.2.1. Know Your Customer (KYC)**</mark>*

Consistent with good industry practice and to comply with applicable law relating to anti-money laundering and prevention of fraud, illicit proceeds from crimes or sanctioned activities, METI Administrators shall verify:

**(a)** Identity of any natural person with controlling ownership, and or, at least one officer of the Custodian;

**(b)** Legal Address of the Custodian;

**(c)** Appropriate legal and fiscal registration of the Custodian;

**(d)** Appropriate Local Working Instructions (LWIs).

#### *<mark style="color:red;">**4.2.2. Fraud Prevention**</mark>*

**(a)** Custodians have a responsibility to act legally and in accordance with any agreed contracts. Where the actions of Custodians raise concerns that the integrity of METI Source Ledger may be compromised, whether by malicious intent or through poor practice, METI Administration may take appropriate actions permitted under law to maintain the integrity of the METI Source Ledger and reputation and operations of its collective Members.

**(b)** Any Custodian that suspects fraudulent activity, money laundering, tax evasion, or other illegal activity should report such a suspicion confidentially to METI Administration and the relevant authorities for review. Custodians may at any time contact relevant authorities in relation to suspicious activity or concerns related to fraud.

#### *<mark style="color:red;">**4.2.3. Local Working Instructions**</mark>*

Custodians shall create, maintain, and operate Local Working Instructions (“LWIs”) that must comply with METI’s Terms of Use and Rulebook/s. METI Administration may review LWIs as part of the onboarding and Know Your Customer process. LWIs must clearly document how Custodians guarantee unique issuance of each EAC and exclusive chain of custody using SSIDs. The steps or checks made to ensure this unique issuance and exclusive chain of custody must be documented in a manner that is easily understood by external stakeholders. Defined aspects of LWIs include:

**(a)** **Geographical and Temporal Restrictions:** A Custodian shall request, manage, and administer the registration of Sources, and any affiliated temporal and attribute data, solely within the geographical and temporal scope for which it is authorized and engaged as a Custodian by the Market Participants.

**(b) Commercial Restrictions:** Custodians shall only request the registration of Sources, and manage and administer SSIDs, for which they have established commercial agreements. Custodians may act in this capacity only when formally engaged as a Custodian by Market Participants.

**(c) Records Management:** A Custodian must define how it maintains records to ensure:

&#x20;     **(i)** The Custodian satisfies KYC requirements of this Rulebook;

&#x20;     **(ii)** The Land Owners and Operators satisfy the KYC requirements of the Custodian;

&#x20;     **(iii)** The Custodian is legally able to contract on behalf of Land Owners and Operators, and or Beneficiaries, for the administration of SSIDs;

&#x20;     **(iv)** The Custodian is not or has not engaged in fraudulent activities;

&#x20;     **(v)** The Land Owners and Operators are not or have not engaged in fraudulent activities;

&#x20;     **(iv)** All supporting documents submitted in support of establishing the unique and exclusive characteristics of a SSID;

&#x20;     **(iiv)** These documents and records must be maintained throughout the lifecycle of a SSID and for at least three years after expiration.

**(d)** **Process Outlines:** The prospective Custodian must clearly define, in its LWIs, the process by which it will enroll Land Owners’ and Operators’ Sources and manage EACs produced. The Custodian must also outline how the specific steps related to registering the Sources/requesting SSIDs are completed on the METI Source Ledger.

**(e) Data Maintenance:** A Custodian must establish and document protocols to ensure that all registration data associated with Sources and affiliated SSIDs remains current and accurate. The registration of a Source may expire after a defined period from the date of its initial registration, as specified in the commercial agreement/s between a Custodian and Land Owner and Operator. Registration can be renewed or extended by the Custodian upon renewal or extension of the commercial agreements between the parties.

**(f) Change Management for Registered Sources:** After a Source has been registered and an SSID issued on the Source Ledger, the Custodians must implement procedures to identify, review, and validate any modifications to the Source that may impact the validity of the information the Source Ledger. These procedures should ensure that all changes are assessed to maintain the integrity and accuracy of METI’s services.

**(g) Supporting Evidence Requirements:** LWIs shall detail how SSIDs are issued based on verifiable evidence they represent a unique and exclusive Source. Evidence supporting the issuance of SSID must include for a specified time:

&#x20;     **(i)** A permanent, contiguous boundary;

&#x20;     **(ii)** Common land cover, management practice, or operational facility;

&#x20;     **(iii)** Common ownership or group of Landowners and Operators, and;

&#x20;     **(iv)** A common project administrator (i.e. Custodian).

#### *<mark style="color:red;">**4.2.4. Third-Party Verification**</mark>*

Custodians shall not conduct verification of SSIDs for which they are the Custodian unless recognized as a Unified Entity by METI Administration. Custodians may engage independent third-party auditors or verification bodies to confirm SSID-related data as per Rulebook requirements. Custodians shall submit verification documentation to Administration upon request and maintain these records for a minimum period of five years following SSID expiration. This documentation must be readily accessible for METI’s audit and compliance reviews.

#### *<mark style="color:red;">**4.2.5. Unified Entity Requirements**</mark>*

A Unified Entity is a Custodian organization that holds dual roles, acting both as the administrator and verifier of SSID data within the METI Source framework. This designation allows the organization to validate SSID-related data internally rather than through an independent third-party auditor. This status is typically reserved for Custodians with advanced verification infrastructure and proven adherence to METI’s transparency, traceability, and data integrity protocols. To qualify as a Unified Entity, the Custodian must receive formal recognition from METI Administration during Account onboarding and continue to meet the following conditions:

**(a)** **Approval and Oversight:** The designation as a Unified Entity is granted by METI Administration, contingent on the Custodian’s demonstrated capacity to maintain unbiased, rigorous data validation protocols and adhere to METI’s principles for data integrity, security and traceability.

**(b)** **Third-Party Audit Requirement:** Despite internal verification capabilities, Unified Entities are subject to periodic third-party audits by METI Administration to ensure ongoing compliance with Rulebook requirements. This additional oversight maintains data integrity and impartiality, preventing conflicts of interest within Unified Entity operations.

**(c)** **Conditions for Internal Verification:** As a Unified Entity, the Custodian must document robust internal processes for data validation, which must meet or exceed the requirements typically applied to independent verification bodies. These processes are outlined in the Custodian’s Local Working Instructions (LWI) and are reviewed periodically by METI.

### 4.3.   Annual Accreditation Process:

#### *<mark style="color:red;">**4.3.1. Certification Mailings**</mark>*

Each year, METI Administrators will distribute certification mailings electronically to all Custodians. This process allows Custodians to review and verify the accuracy of the data they have provided, ensuring it remains current and correct. Custodians must provide feedback and revisions if discrepancies or missing information are identified.

#### *<mark style="color:red;">**4.3.2. Certification Status**</mark>*

Once reviewed and updated data is approved, METI registers the Custodian’s data as “Certified by the Member,” signaling to market participants and third-party verifiers that the data has been actively verified and certified by the Custodian.

#### *<mark style="color:red;">**4.3.3. Continuous Updates**</mark>*

Custodians shall notify METI Administrators of any significant data changes or corporate actions throughout the year to maintain the accuracy and reliability of data between annual certification periods.

#### *<mark style="color:red;">**4.3.4. Accreditation Fee**</mark>*

The annual METI Originate membership fee covers the review, modification, maintenance, and certification process.

### 4.4.   Membership Suspension or Termination of Services

As outlined in [Section 10](https://docs.millpont.com/meti-operative-documents/pages/xPG0F2pSgiLptt5NN6Qe#id-10.-term-and-termination) and [Section 11](https://docs.millpont.com/meti-operative-documents/pages/xPG0F2pSgiLptt5NN6Qe#id-11.-default-and-remedies) of the Terms of Use, METI Administration may suspend or terminate the provision of service to any Custodian, if the Custodian is in default, or suspected of being in default, as defined under [Section 11](https://docs.millpont.com/meti-operative-documents/pages/xPG0F2pSgiLptt5NN6Qe#id-11.1.-default) Terms of Use.

#### *<mark style="color:red;">**4.4.1. Grounds for Suspension or Termination**</mark>*

Defaults that may result in suspension or termination include, but are not limited to, the following:

**(a) Non-compliance:** Failure to comply with the Rulebook standards, Terms of Use, or KYC requirements.

**(b) Fraudulent Activity or Tampering:** Fraudulent actions, intentional misrepresentation, or tampering with METI data or systems.

**(c) Falsification and Misrepresentation:** Intentional or grossly negligent misrepresentation.

**(d)** Any attempt to compromise the proper functioning of METI and the Source Ledger.

#### *<mark style="color:red;">**4.4.2. Notification of Suspension**</mark>*

**(a)** METI Administration will issue a written notification of suspension to any Custodian found non-compliant with the METI Source Rulebook’s standards, KYC requirements, or other obligations. This notification shall:

&#x20;     **(i)** Clearly specify the reason for suspension;

&#x20;     **(ii)** Outline the actions required for reinstatement of services;

&#x20;     **(iii)** Provide a five (5) business day period for the Custodian to respond and take corrective action, unless otherwise required under the Terms of Use or outlined in the notification.

**(b)** Certain Defaults, as defined in [Section 11](https://docs.millpont.com/meti-operative-documents/pages/xPG0F2pSgiLptt5NN6Qe#id-11.1.-default) of the Terms of Use, may result in immediate termination without prior notification. These include, but are not limited to:

&#x20;     **(i)** Fraudulent, illicit, or illegal activity;

&#x20;     **(ii)** Tampering with or damaging METI systems or participant data;

&#x20;     **(iii)** Violations of applicable laws.

In such cases, METI Administration reserves the right to terminate services immediately, consistent with [Section 10](https://docs.millpont.com/meti-operative-documents/pages/xPG0F2pSgiLptt5NN6Qe#id-10.-term-and-termination) and [Section 11](https://docs.millpont.com/meti-operative-documents/pages/xPG0F2pSgiLptt5NN6Qe#id-11.-default-and-remedies) of the Terms of Use.

#### *<mark style="color:red;">**4.4.3. Termination and Reapplication**</mark>*

If the Custodian fails to respond or address the issue within this period, METI reserves the right to terminate provision of services according to the Terms of Use and Rulebook. METI Administration shall act fairly and in a non-discriminatory manner, allowing any suspended or terminated Custodian to reapply for Membership. Reapplication will be permitted provided that the Custodian demonstrates it has remedied all issues that led to the suspension or termination.

## &#x20;5.     SOURCE LEDGER AND DATA SUBMISSION REQUIREMENTS

This section outlines procedures and requirements for using the Source Ledger and submitting data within the METI Platform. This section ensures that all data submissions meet METI’s standards for accuracy, traceability, and compliance, supporting the overall integrity and reliability of the platform.

### 5.1.   Entry and Exit Procedures

#### *<mark style="color:red;">**5.1.1. Entry Procedures**</mark>*

**(a) Application Review:** Prospective members must submit an application, which METI Administrators review to assess eligibility based on the Terms of Use and compliance standards.

**(b) Onboarding Process:** Approved members undergo an onboarding process that includes training on data submission protocols, the use of the MSL, and adherence to METI’s Rulebook.

**(c) Account Setup:** New members receive a METI Account, providing them with the ability to securely create, track and monitor SSIDs and associated EACs.

#### *<mark style="color:red;">**5.1.2. Exit Procedures:**</mark>*

**(a) Notice of Withdrawal:** Members who wish to withdraw must comply with the procedures outlined in [Section 10](https://docs.millpont.com/meti-operative-documents/pages/xPG0F2pSgiLptt5NN6Qe#id-10.-term-and-termination) of the Terms of Use, which specifies the requirements for providing formal notification of their intent to exit the METI platform.

**(b) Reconciliation of Data:** METI Administrators will conduct a review of all active SSIDs and associated data to reconcile and validate information before the member’s exit.

**(c) Data Archiving and Transfer:** Following the reconciliation process, members' data will be securely archived or, if appropriate, transferred according to the Terms of Use and member agreements to maintain the integrity of the platform.

**(d) Final Audit:** As part of the exit procedure, a final compliance audit may be conducted to ensure all member obligations have been met, as required by METI Administrators and in accordance with [Section 10](https://docs.millpont.com/meti-operative-documents/pages/xPG0F2pSgiLptt5NN6Qe#id-10.-term-and-termination) of the Terms of Use.

### 5.2.   Data Submission Protocols

#### *<mark style="color:red;">**5.2.1. Data Elements for SSID Issuance Requests**</mark>*

**(a) File Type:** GeoJSON format as per [IETF RFC 7946 standards](https://datatracker.ietf.org/doc/html/rfc7946)

**(b) Type:** Must be `"FeatureCollection"`&#x20;

**(c) Geometry:** Accepted values: `Polygon` **or** `MultiPolygon`. Submit a **Polygon** when the Source is a single, continuous parcel. Submit a **MultiPolygon** *only* when every component parcel shares **all** of the following:

&#x20;     **(i)** identical land cover and production/management system;

&#x20;     **(ii)** identical ownership or unified operating agreement;

&#x20;     **(iii)** a single Custodian (project administrator)<br>

If any component differs on these points, file separate Polygon requests. This safeguard preserves traceability, supports conflict checks, and maintains ledger integrity.

**(d) Internal Identifier:** Each feature must contain an `"id"` field that maps unambiguously to the Custodian’s internal Source identifier and chain-of-custody records.

**(e) Properties:**

&#x20;     **(i)** `"contract_start"` and `"contract_end"` - [ISO 8601 format](https://www.iso.org/iso-8601-date-and-time-format.html).

&#x20;     **(ii) Optional** `"attribute_type"` - e.g., `"carbon"`, `"CI"`, `"biodiversity"`.

**Note:** METI treats the entire Polygon or every component of a qualifying MultiPolygon as one [Source](/meti-resources/what-is-a-source) for SSID purposes. Submissions that do not meet the uniform-management criteria will be rejected or marked for future resubmission as discrete Polygon features.

*<mark style="color:red;">**5.2.2. Example JSON Structure**</mark>*

<pre class="language-json"><code class="lang-json">{
    "type": "FeatureCollection",
    "features": [
<strong>        {
</strong>        "type": "Feature",
        "id": "InternalSourceID", 
        "properties": {
            "start_at": "2024-11-01T16:25:00.000Z",
            "end_at": "2024-11-10T16:25:00.000Z"
<strong>        },
</strong>        "geometry": {
         "coordinates": [
            [
             [
                -95.99151831445964,
                32.776695443574994
            ],
            [
                -95.99151831445964,
                32.77064374883592
            ],
            [
                -95.98497521320726,
                32.77064374883592
            ],
            [
                -95.98497521320726,
                32.776695443574994
            ],
            [
                -95.99151831445964,
                32.776695443574994
            ]
<strong>           ]
</strong>          ],
       "type": "Polygon"
      }
     },
More polygons...
  ]
}
</code></pre>

### 5.3.   Data Quality and Reliability:

**(a) Detailed Reporting:** Must identify Source/s and establish chain of custody.

**(b) Auditable Records:** Data must be inherently reliable and traceable to field- or facility-level for projects in the process of generating and or issuing EACs.

### 5.4.   Data Security and Integration

#### *<mark style="color:red;">**5.4.1. Integration Methods**</mark>*&#x20;

Data can be submitted, managed and updated through the [METI Platform](https://app.meti.millpont.com/login/) using a Custodian’s login credentials and access through:

**(a)** APIs &#x20;

**(b)** Front-End&#x20;

#### *<mark style="color:red;">**5.4.2. Validation Process**</mark>*

Includes checks for data format, spatial integrity, and attribute consistency.

#### *<mark style="color:red;">**5.4.3. Notifications**</mark>*

Status updates provided to Account Holders regarding the validation of their submissions.

### 5.5.   Validation Checks

Data validation and handling by METI systems includes, but is not limited to:&#x20;

**(a) Entity Validation:** Confirms the reporting Custodian is authorized to submit data.

**(b) Data Format Compliance:** Ensures data consistency and scalability.

**(c) Spatial, Temporal, and Attribute Integrity:** Validates non-duplication and complete coverage.

**(d) Aggregation Handling:** Processes shared ownership data accurately.

### 5.6.   Compliance with Sanctions and Access Restrictions

#### *<mark style="color:red;">**5.6.1. Restricted Access**</mark>*

METI will ensure compliance with applicable sanctions laws, restricting access to sanctioned parties or jurisdictions as defined by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and other relevant bodies.

#### *<mark style="color:red;">**5.6.2. Responsibility of Custodians**</mark>*

Custodians must confirm that no data is maintained on behalf of any party subject to sanctions. Any identified violation must result in immediate action, including cancellation of access and written notification to METI.

### 5.7.   Prohibition of Disruptive Practices

#### *<mark style="color:red;">**5.7.1. Data Submission Integrity**</mark>*

All data must be submitted in good faith for legitimate purposes and should not disrupt the orderly conduct of the platform.

#### *<mark style="color:red;">**5.7.2. Prohibited Practices**</mark>*

Submission of data with the intent to mislead or overload METI’s systems or those of participants is forbidden. Reckless or intentional practices that could disrupt METI’s operations or clearing services are prohibited.

## 6.     CHAIN OF CUSTODY DOCUMENTATION REQUIREMENTS

The Chain of Custody Documentation section outlines the essential practices and requirements for maintaining verifiable records and audit trails for data associated with Secure Source Identifiers (SSIDs) and Environmental Attribute Certificates (EACs). These practices ensure the integrity of data submissions, support compliance with METI standards, and promote transparency and trust within the platform. Members, including Custodians and Market Participants, are obligated to follow these protocols to demonstrate clear data provenance and comply with regulatory and platform-specific guidelines.

### 6.1.   Verification Protocols

#### *<mark style="color:red;">**6.1.1. Authentication of Data**</mark>*

Each data submission must be verifiable to, upon request from METI Administrator, confirm its authenticity and alignment with its designated SSID.

#### *<mark style="color:red;">**6.1.2. Custodial Validation**</mark>*

Custodians must submit, upon request, supporting documentation that evidences a clear chain of custody and legal entitlement for administration and creation of SSIDs on METI’s Source Ledger.

### 6.2.   Audit Trail Requirements

#### *<mark style="color:red;">**6.2.1. Detailed Records**</mark>*

Custodians and Market Participants must maintain comprehensive records of all data submissions, transactions, and modifications, ensuring these records align with affiliated data on METI.

#### *<mark style="color:red;">**6.2.2. Access to Records**</mark>*

Proprietary data or personal information collected for compliance purposes shall ONLY be used to the extent they are required to verify compliance with Terms of Use and relevant Rulebook protocols. Records must be made available to METI Administrators or upon request by relevant authorities for compliance and audit purposes.

### 6.3.   Audit Trail Components

Maintaining a reliable audit trail requires both electronic and physical documentation to support the integrity of data related to SSIDs.

#### *<mark style="color:red;">**6.3.1. Electronic Logs**</mark>*

Logs must capture essential data such as timestamps, identifiers, details of involved parties, and any modifications or cancellations to submissions or claims.

#### *<mark style="color:red;">**6.3.2. Physical Documentation**</mark>*

Original documents such as contracts, agreements, and proof of ownership or entitlement related to EACs must be retained. These documents should support the data recorded in the electronic logs.

#### *<mark style="color:red;">**6.3.3. Data Protection and Access**</mark>*

**(a)** **Electronic Records:** Electronic records should be securely stored to prevent unauthorized access and prevent tampering, ensuring data integrity and protection.

**(b) Physical Records:** Physical records must be stored in a secure, accessible location and made available for inspection upon request by METI Administrators or relevant authorities. Custodians must implement practices to protect physical records from damage, loss, or unauthorized access, ensuring they remain intact for at least five (5) years or as required by applicable regulations.

**(c) Confidentiality:** Records related to environmental claims must be protected to ensure proprietary and personal information is not publicly disclosed, except in an aggregated or anonymized manner or when legally mandated.

**(d) Compliance with Regulations:** Both electronic and physical records must comply with regulatory requirements, ensuring comprehensive audit trails are maintained to support transparency and traceability.

## 7.     ANNUAL COMPLIANCE VERIFICATION

Section 7 outlines the annual compliance verification standards that Custodians must adhere to, ensuring the integrity and reliability of data submissions and operations. These standards align with METI’s commitment to transparency, accuracy, and adherence to the leading standards.

### 7.1.   Compliance Verification

#### *<mark style="color:red;">**7.1.1. Annual Compliance Review**</mark>*

METI Administration will conduct regular annual audits to ensure that members uphold Rulebook standards and comply with the framework. This process verifies the accuracy and legitimacy of data and member activities according to [Section 4](#id-4.-custodian-responsibilities-and-requirements) , [Section 5](#id-5.-source-ledger-and-data-submission-requirements), and [Section 6](#id-6.-chain-of-custody-documentation-requirements).

#### *<mark style="color:red;">**7.1.2. Randomized Audit Sampling**</mark>*

METI Administrators will perform audits based on a randomized selection process to create a statistically significant sample of SSID claims and Member operations. This method helps monitor platform activity effectively and ensures that the Rulebook’s standards are being met consistently across all member operations.

#### *<mark style="color:red;">**7.1.3. Member Participation**</mark>*

Custodians selected for audits are required to submit supporting records and cooperate with METI Administrators, providing additional documentation as needed.

#### *<mark style="color:red;">**7.1.4. Audit Reporting**</mark>*

The results of these audits will be communicated back to the Custodian. Custodians identified as non-compliant may be issued a corrective action plan, which must be addressed within thirty (30) days to maintain Membership accreditation.

#### *<mark style="color:red;">**7.1.5. Additional Compliance Checks**</mark>*

Specific triggers for additional compliance checks include, but are not limited to:

**(a)** Changes in Source ownership or management;

**(b)** Significant modifications to SSID data;

**(c)** Periodic intervals based on previous audit outcomes or known risk factors.

## &#x20;8.     DATA SECURITY AND OPERATIONAL INTEGRITY

This section outlines the security protocols and operational measures necessary for maintaining the confidentiality, integrity, and availability of data managed within the METI Platform. These guidelines support platform resilience and the protection of sensitive information related to SSIDs and EACs through best-practice industry standards.

### &#x20;8.1.   Encryption and Anonymization

#### *<mark style="color:red;">**8.1.1. Data Protection**</mark>*

All data within the METI Platform is protected using advanced encryption protocols, both at rest and in transit, to prevent unauthorized access and tampering. These include but are not limited to:

**(a) Encryption:** All sensitive data within METI is encrypted at rest and in transit using advanced encryption protocols to protect against unauthorized access and data tampering.

**(b) Access Controls:** Data access is restricted to authorized members based on role-specific permissions. Multi-factor authentication is required for members accessing confidential information related to SSIDs.

**(c) Confidentiality of Environmental Claims:** Proprietary data related to environmental claims will be anonymized or aggregated for public reporting unless specific disclosure is legally mandated.

#### *<mark style="color:red;">**8.1.3. Anonymization Protocols**</mark>*

Personal and proprietary data collected for regulatory and operational purposes is anonymized or aggregated before public disclosure, except when legally mandated, to maintain confidentiality and compliance.

### 8.2. Access Controls

#### *<mark style="color:red;">**8.2.1. Authorized Access Only**</mark>*

Data access is restricted to authorized members based on their roles. METI Administrators manage access controls to ensure only approved users can interact with sensitive data.

#### *<mark style="color:red;">**8.2.2. Authentication Measures**</mark>*&#x20;

Strong authentication protocols, such as multi-factor authentication, are employed to reinforce security.

### 8.3.   Business Continuity

#### *<mark style="color:red;">**8.3.1. High Availability and Redundancy**</mark>*

The METI Platform architecture ensures data redundancy and supports automatic failover to secondary and tertiary systems for minimal disruptions. If a primary node fails, a secondary node is automatically promoted to maintain service continuity.

#### *<mark style="color:red;">**8.3.2. Distributed Database Architecture**</mark>*

The platform uses a distributed architecture to spread data across multiple servers, enhancing scalability and continuous availability.

#### *<mark style="color:red;">**8.3.3. Geo-Distribution**</mark>*

Cross-region data replication is used to withstand regional outages, supporting consistent service availability.

### 8.4.   Backup and Disaster Recovery

Backup and disaster recovery measures of METI include, but are not limited to:&#x20;

**(a) Automated Backups:** Scheduled, automated backups are conducted to enable quick data restoration in case of loss or corruption.

**(b) Point-in-Time Recovery:** This feature allows data to be restored to a specific moment in time, protecting against unintended data loss.

**(c) Data Snapshot Capabilities:** The platform supports secure data snapshots to create recovery points for reliable backup solutions.

### 8.5.   Data Integrity and Security Measures

#### *<mark style="color:red;">**8.5.1. Continuous Data Monitoring**</mark>*

The platform includes monitoring tools that provide real-time oversight of database health, including logging and alerting for potential issues.

## 9.     SSID CONFLICT RESOLUTION PROCESS

The SSID Conflict Resolution Process is a structured approach to resolving disputes involving SSIDs. Steps include:

**(a) Pre-Dispute Communication:** Encourage members to resolve potential conflicts through prompt internal discussions.

**(b) Formal METI Review:** Submit a conflict resolution request to METI, which will acknowledge and review the submission within five (5) business days.

**(c) Investigation and Resolution Timeline:** METI aims to provide an initial resolution within forty-five (45) business days of acknowledgment. For emergencies or expedited requests, METI may target an initial resolution within twelve (12) business days, subject to the METI Administrator’s capacity, issue complexity, information availability, and necessary party participation. If additional time is needed, METI will inform the parties of an updated timeline. Parties dissatisfied with the initial resolution may enter mediation or proceed to arbitration under METI’s Terms of Use.

Since the MSL permits conflicting SSIDs to exist in an encumbered state until the parties resolve the overlap, Members are encouraged but not obligated to proceed through each of these stages. This flexible, non-binding process allows members to manage their conflicts efficiently while ensuring fairness and transparency within the METI ecosystem.

### 9.1.   Pre-Dispute Assessment and Acting Quickly

Before a conflict arises, members are encouraged to conduct regular assessments of their data submissions and understand their obligations and potential risk areas. This proactive approach allows members to anticipate issues, and in cases where a conflict may arise, METI recommends these initial steps:

#### *<mark style="color:red;">**9.1.1. Prompt Communication**</mark>*

Members should immediately discuss potential conflicts with their internal teams and, where relevant, with land stewards or operators. Prompt action can prevent escalation and the loss of critical information.

#### *<mark style="color:red;">9.1.2. Engagement with Farm Partners, MRV Providers, and Value Chain Members</mark>*

When a potential conflict is identified, members should reach out to involved farm partners or MRV providers to clarify any discrepancies. Many conflicts can be quickly resolved at this stage by allowing these parties the chance to review and correct data.

#### *<mark style="color:red;">**9.1.3. Initiating METI’s SSID Conflict Resolution Program**</mark>*

If direct discussions do not resolve the issue, members may proceed voluntarily to METI’s formal conflict resolution process as outlined below.

### 9.2.   Formal SSID Conflict Resolution by METI Administration

If members choose to use METI’s structured conflict resolution process, METI Administrators oversee the following steps:

#### *<mark style="color:red;">**9.2.1. Submission of Conflicts**</mark>*

Members submit a formal SSID conflict resolution request via METI’s designated [electronic form](/meti-operative-documents/ssid-conflict-resolution-request-form) (See METI Operative Documents). The request should detail the conflict, SSID identifiers, involved parties, and relevant evidence as outlined in [Section 6](#id-6.-chain-of-custody-documentation-requirements). METI reserves the right to evaluate and respond to the conflict submission as appropriate.

#### *<mark style="color:red;">**9.2.2. Review and Acknowledgment**</mark>*

METI will acknowledge receipt of the conflict submission within five (5) business days and conduct an initial review to assess whether the conflict is eligible for METI’s resolution process or requires a different approach.

#### *<mark style="color:red;">**9.2.3. Investigation Period**</mark>*

METI Administrators conduct an investigation to assess the validity of the conflict, which may involve reviewing relevant data and records and requesting further information from members.

#### *<mark style="color:red;">**9.2.4. Resolution Timeline**</mark>*

METI aims to provide an initial resolution within forty-five (45) business days of acknowledgment. Upon request, METI may provide an expedited initial resolution target of twelve (12) business days for emergencies or other time-sensitive matters, subject to the METI Administrator’s capacity, the complexity of the issue, the completeness of the information provided, and any required participation by affected parties. If additional time is needed, METI will inform the parties of an updated timeline.

### 9.3.   Negotiation

If the initial METI review does not resolve the conflict to the parties' satisfaction, members may voluntarily move to the Negotiation phase, a direct, collaborative approach aimed at reaching a mutually agreeable solution.

#### *<mark style="color:red;">**9.3.1. Negotiation Procedure**</mark>*

By mutual agreement, METI Administrators may introduce members to engage directly in discussions to explore resolutions. This stage encourages parties to exchange ideas, explore solutions, and work toward a compromise that addresses both parties’ interests.

#### *<mark style="color:red;">9.3.2. Escalation Trigger</mark>*&#x20;

If negotiation is unsuccessful within thirty (30) business days, or the parties prefer an alternative approach, they may proceed to mediation or arbitration.

### 9.4.   Mediation by METI Administrator or Neutral Third-Party

#### *<mark style="color:red;">**9.4.1. Mediation Options**</mark>*

Mediation can be facilitated by METI Administrator, a member of the METI Governance Committee (not involved in the dispute), another METI Member (not involved in the dispute), or a qualified third-party mediator approved by METI Administrators. All costs of mediation, including fees, are borne by the disputing parties.

#### *<mark style="color:red;">**9.4.2. Mediation Procedure**</mark>*

The mediator facilitates discussions to help parties reach a collaborative, non-binding solution. Mediation remains voluntary throughout, allowing parties to opt out if preferred.

*<mark style="color:red;">**9.4.3. Confidentiality**</mark>*

All information shared during mediation remains confidential to protect member privacy and encourage open dialogue. Neither the METI Administrator nor the mediator will disclose details unless legally mandated.

### 9.5.   Transition to Arbitration&#x20;

If mediation does not yield a resolution or the parties opt to proceed without mediation, Members may voluntarily elect to move to arbitration in accordance with the procedures described in METI’s Terms of Use [Section 20](https://docs.millpont.com/meti-operative-documents/pages/xPG0F2pSgiLptt5NN6Qe#id-20.3.-arbitration).

#### *<mark style="color:red;">**9.5.1. Arbitration Administration**</mark>*

Arbitration is administered by the American Arbitration Association (AAA), with options tailored to the size of the dispute:

**(a)** Expedited Commercial Rules for disputes up to $100,000.

**(b)** Commercial Arbitration Rules for disputes exceeding $100,000.

#### *<mark style="color:red;">**9.5.2. Arbitration Procedures**</mark>*

(a) Limited Disclosures: Disclosure is restricted and managed by agreement or as ordered by the arbitrator.

(b) Confidentiality and Finality: Arbitration proceedings and awards are confidential. A final award may be confirmed in an appropriate court, ensuring the privacy and finality of the process.

### 9.6.   Documentation and Recordkeeping

#### *<mark style="color:red;">**9.6.1. Record of Proceedings**</mark>*

All stages of conflict resolution, from initial METI review to negotiation, mediation, and arbitration, will be documented. Records will be securely stored and disclosed only when legally required or to parties directly involved.

#### *<mark style="color:red;">**9.6.2. Confidentiality Assurance**</mark>*

METI ensures that all dispute-related records remain confidential and only disclosed to the extent legally mandated.

### 9.7.   Unresolved SSID Conflicts

For conflicts that remain unresolved, METI allows conflicting SSIDs to exist in an encumbered Conflict status on the Source Ledger.

*<mark style="color:red;">**9.7.1. Encumbered Conflict Status**</mark>*

Unresolved SSID conflicts will maintain an encumbered status on the Source Ledger until the conflict is resolved.

*<mark style="color:red;">**9.8. Final Authority**</mark>*

METI Administration reserves the right to determine the handling of unresolved SSIDs in Conflict status.

## 10.     RULEBOOK GOVERNANCE&#x20;

The METI Governance Committee (The “Governance Committee”) plays a crucial role in overseeing the development and implementation of operating governance procedures outlined in the METI Rulebook. This committee ensures the integrity, effectiveness, and transparency of METI's operations, guiding the organization towards achieving its mission and vision.

### 10.1.   METI Governance Committee’s Mission

The Governance Committee’ mission is to establish and maintain robust governance structures that support METI's commitment to sustainability, transparency, and innovation in environmental markets. The Governance Committee will oversee the creation and implementation of policies and procedures that ensure the credibility and reliability of METI's services and products.

### 10.2.   Tasks

The METI Governance Committee will meet regularly with METI Administration to review the development of METI's programs and address strategic and major operational issues. The committee members fulfill the following tasks:

#### *<mark style="color:red;">10.2.1. Rulebook Oversight</mark>*

Oversee the development, implementation and refinement of the METI Rulebook and its operational procedures, including but not limited to formation of an industry accepted dispute resolution mechanism, core principles of governance, and the orientation of procedures and processes to meet an evolving regulatory landscape.

#### *<mark style="color:red;">**10.2.2. Exchange, Discuss, and Advise**</mark>*

Support strategic, future-oriented developments of METI with professional expertise and scientific background.

#### *<mark style="color:red;">**10.2.3.  Program Review**</mark>*

Regularly review the progress and development of METI's programs.

#### *<mark style="color:red;">**10.2.4.  Operational Involvement**</mark>*

Participate in strategic and major operational issues and their respective implementation measures.

#### *<mark style="color:red;">**10.2.5. Stakeholder Communication**</mark>*

Network and communicate with relevant stakeholders, including researchers, civil society, and private sector entities, to enhance the publicity and credibility of METI's programs.

### 10.3.   Composition

The METI Governance Committee will comprise a minimum of three and up to eight Market Participants, and or, expert industry stakeholders. Key stakeholder groups, such as regulators, carbon accountants, traders, CPGs, retailers, researchers, NGOs, and civil society organizations, will be represented in the committee. The composition of the external members will be equally distributed among different stakeholder groups, with an emphasis on representation and experience.

#### *<mark style="color:red;">**10.3.1.  Individual Roles**</mark>*

Members will hold individual positions, not representing their companies.

#### *<mark style="color:red;">**10.3.2. Leadership**</mark>*

The committee will be chaired by an independent Chairperson, supported by a Vice Chairperson. These positions will be elected by the committee members immediately after its formation, with each term lasting three years.

### 10.4.   Tenure

#### *<mark style="color:red;">10.4.1.  Appointment of New Members</mark>*

New members are elected to the Governance Committee by a simple majority vote of the current members. Abstaining from a vote is counted as a no-vote. Nominations for the Governance Committee are for a term of three years, with the possibility of re-nomination for subsequent terms.

#### *<mark style="color:red;">10.4.2. Termination</mark>*

Governance Committee members may resign at any time by submitting written notice to the Chairperson. Members are expected to uphold and act in alignment with the mission and objectives of the METI. A member can only be dismissed for a valid reason and requires two-thirds majority of existing Governance Members for removal. Valid reasons include, but are not limited to:

**(a) Breach of Fiduciary Duty:** Failure to act in METI's best interests, including neglect of duties, misuse of METI information, or personal gain at METI’s expense.

(**b) Conflict of Interest:** Engaging in activities that directly compete with or undermine METI’s mission or create an unresolved conflict of interest.

**(c) Unethical Conduct or Reputational Risk:** Actions that compromise METI's reputation or conflict with its values, such as violations of legal or ethical standards.

**(d) Failure to Participate:** Repeated failure to participate in committee activities or fulfill agreed-upon responsibilities, impacting the committee's function.

### 10.5.   Meeting and Voting Procedures

#### *<mark style="color:red;">**10.5.1.  Meeting Requirements**</mark>*

The Governance Committee is required to meet in person at least once a year. Additional quarterly meetings are held virtually (e.g., via telephone conference or shared screen session) with specific thematic focuses, coordinated with Governance Committee members.

#### *<mark style="color:red;">**10.5.2.  Voting Procedures**</mark>*

Each Advisory Board member holds one seat and one vote. Voting is conducted by a show of hands with an abstaining vote considered a no-vote.

## 11.     RULEBOOK UPDATE PROCEDURES

### 11.1.   Update Schedule

#### *<mark style="color:red;">11.1.1. Quarterly Updates</mark>*

The METI Rulebook is updated quarterly to incorporate minor adjustments, clarifications, and non-substantive changes. These updates are intended to enhance clarity, ensure compliance, and support efficient operations.

#### *<mark style="color:red;">11.1.2. Annual Comprehensive Update</mark>*

Once a year, METI Administration conducts a comprehensive review of the Rulebook to incorporate substantial updates, strategic improvements, and necessary regulatory changes. This annual update serves as a broader opportunity to address significant policy changes and refine the Rulebook to align with METI’s long-term goals and evolving standards in the environmental markets sector.

### 11.2.   Update Procedures

#### *<mark style="color:red;">11.2.1. Proposal Collection and Compilation</mark>*

METI Administration collects proposed updates from a variety of sources, including regulatory changes, internal audits, member feedback, and operational reviews. Each proposal is documented in a Change Proposal Document, detailing the rationale, anticipated impact, and any regulatory or operational requirements. Administration presents the compiled proposals and feedback to the Governance Committee for review and prioritization thirty (30) days prior to scheduled quarterly meetings.

#### *<mark style="color:red;">11.2.2. Review and Vetting by Governance Committee</mark>*

The Governance Committee, consisting of legal, compliance, METI members, and subject matter experts, reviews each proposal to ensure alignment with METI’s mission, regulatory standards, and the Rulebook’s objectives.

#### *<mark style="color:red;">11.2.3. Preliminary Assessment and Voting</mark>*

The Committee conducts a preliminary assessment of each proposal to determine its relevance and potential impact. Proposals that receive a simple majority in a preliminary vote proceed to the next stage, the public comment period.

#### *<mark style="color:red;">11.2.4. Public Comment Period</mark>*

METI Administration posts the proposed updates on the Service Site under “Notice of Proposed Rulebook Updates for Public Comment.” A 30-day comment period allows members and stakeholders to review and provide feedback. During the public comment period, METI facilitates engagement opportunities, such as Q\&A sessions, to provide members with clarity on proposed changes and gather stakeholder insights on potential impacts.

#### *<mark style="color:red;">11.2.5. Final Review, Adjustment, and Voting</mark>*

The Governance Committee reviews feedback from the public comment period and incorporates relevant adjustments into the proposed updates to improve clarity, address operational concerns, or refine compliance measures. The Governance Committee holds a final vote on the adjusted updates. A two-thirds majority is required for approval, and significant updates require endorsement by the METI Executive Board to ensure strategic alignment.

#### *<mark style="color:red;">11.2.6. Monitoring and Adjustment</mark>*

Following implementation, the METI Administrator initiates a 60-day Cure Period to monitor the effectiveness of the updates, ensuring that they meet their intended objectives without unintended impacts. During this Cure Period, METI Administration gathers additional feedback from members regarding any challenges or unforeseen issues. If necessary, METI Administration will make adjustments to ensure compliance and support alignment with the Rulebook’s standards.

### 11.3.   Effective Date

Quarterly updates take effect on the first day of the following quarter. Annual updates are implemented at the beginning of the second quarter of the calendar year, allowing adequate time for members to prepare.

### 11.4.   Documentation and Changelog Entry

#### *<mark style="color:red;">11.4.1. Entry into Change Log</mark>*

Approved updates are recorded in the METI Rulebook Changelog, accessible on the Service Site. Each entry includes the effective date, rationale, and a summary of feedback responses.

#### *<mark style="color:red;">11.4.2. Member Notification</mark>*

METI Administration sends a formal notification to all members via email, detailing the approved updates and providing any necessary.


# Membership Fee Schedule

## Fee Schedule

Annual Subscription Plans & Fees are based on the \*quantity (or anticipated quantity) of a Custodian’s Sources under management, and are structured as follows:&#x20;

<table><thead><tr><th width="164">Plan</th><th>Basic</th><th>Standard</th><th>Enterprise</th></tr></thead><tbody><tr><td><strong>Description</strong></td><td>Ideal for Small Projects &#x26; Pilots </td><td>Designed for Growing Businesses </td><td>Built for High-Volume Registries &#x26; Marketplaces</td></tr><tr><td><strong>Annual Subscription</strong></td><td>$1,800 </td><td>$10,750</td><td>$32,250</td></tr><tr><td><strong>Includes</strong></td><td>100 Secure Source IDs</td><td>15,000 Secure Source IDs, API Access</td><td>95,000 Secure Source IDs, API Access, Advisory Support </td></tr><tr><td><strong>Additional Usage</strong></td><td>$2.00 per source </td><td>$0.30 per source </td><td><em>Negotiable rates based on volumes and utilization</em> </td></tr></tbody></table>

\**If usage scales, consider upgrading plans to benefit from lower unit costs and additional features like API access and advisory support.*&#x20;

## Pricing Calculator

Explore the **METI Pricing Calculator** to find the tier that best fits your needs. Simply input your project's details to receive a tailored recommendation based on your expected usage.

{% file src="/files/5qNRktipoXXLogFL53I6" %}

## Source Definition  &#x20;

A Source refers to the point of origin of an environmental benefit. For METI, source is considered an individual contiguous parcel that is the smallest unit of land with 1) A permanent, contiguous boundary, 2) Common land cover and land management, 3) Common ownership or group of owners/land managers, and 4) A common project administrator (i.e. Custodian).


# Declaration of Agency Form

{% file src="/files/OfN7IdJFPPAIEAzAzFIV" %}
Download and Complete Form
{% endfile %}

## **About the Declaration of Agency Form**

The METI Declaration of Agency Form in METI is required when a user registers an Omnibus Account or designates a third-party service provider to access METI on its behalf. The Authorization identifies the Principal (the METI account holder) and the Agent (the authorized third party) and defines the limited scope under which the Agent may act within the METI system.

The Authorization is intended to provide clarity and operational transparency for METI, the Principal, and the Agent. It does not transfer ownership or control of data or environmental claims and does not modify the Principal’s underlying METI account terms, except as expressly stated in the Authorization.

## **Who Needs to Complete This Form?**

* **Principals**: METI account holders who wish to authorize a third-party user or data service provider (Agent) to manage specific activities within their account.
* **Agents**: Third-party users or service providers acting on behalf of a Principal within the METI system.

The form must be completed by both the Principal and the Agent. Either party may submit the completed form in the following cases:

1. **The Principal**: When adding a third-party user or data service provider to their METI account.
2. **The Agent**: When registering a new Custodian Omnibus account on behalf of a Principal.&#x20;

## **What Information Will You Need to Provide?**

* Details of the Principal (company or individual account holder).
* Details of the Agent (third party authorized to act on the Principal's behalf).
* Signatures of both the Principal and the Agent, agreeing to the terms outlined in the form.

## **Key Points to Know Before Filling Out the Form**

1. **Principal Responsibilities Remain:** Authorizing an Agent allows the Agent to act on the Principal’s behalf within METI, but does not transfer ownership of data or environmental claims, nor relieve the Principal of its obligations under the METI Terms of Use.
2. **Confidentiality and Proper Use:** The Agent may access confidential information within METI solely to perform the authorized activities and is required to protect such information in accordance with the METI Agreements.
3. **Keeping Information Current:** The Principal or Agent should notify METI if there are material changes to the information provided in this Authorization, including changes to the authorized Agent or scope of authorization.

## **Next Steps**

1. Download the Declaration of Agency form.
2. Review the [METI Terms of Use](/meti-operative-documents/terms-of-use) and [Data Privacy Policy](/) for additional context.
3. Complete the form with the required information and signatures.
4. The Agent should submit the signed form as part of your SSID Registration Order Form. Principals should email completed forms to METI Administrators at <membership@millpont.com>.  &#x20;


# SSID Conflict Resolution Request Form

Fill out the form below to request an administrative review of SSID conflicts

{% embed url="<https://share.hsforms.com/1rxrpu1S0Qq-f3B4uTL05Kwrt6sg>" %}


# Introduction

Welcome to the METI API Documentation. This guide is designed to help you integrate with METI's cutting-edge geospatial infrastructure for managing and monitoring environmental assets. The METI API enables seamless interaction with our platform, offering tools to create, retrieve, and manage SSID data with precision and security.

## What You Can Do with the METI API

* **Register Sources**: Upload and manage geospatial and temporal data representing environmental assets.
* **Retrieve Data**: Access detailed information on registered SSIDs.
* **Conflict Management**: Ensure data integrity and resolve conflicts in a transparent - but confidential - system.
* **Scalable Interactions**: Build integrations that support automated workflows and real-time analytics.

## Key Features

* **RESTful Design**: Simple and intuitive endpoints using REST principles.
* **GeoJSON Support**: Native support for GeoJSON data formats for spatial features.
* **Secure Authentication**: Token-based authentication to ensure secure API access.
* **Transparent Data Management**: Tools for tracking and validating geospatial data integrity.

## Base URL

All requests to the METI API should start with:

```http
 
https://api.millpont.com

```

## How to Use This Documentation

* Start with **Authentication** to learn how to obtain a token and authenticate your requests.
* Explore the **Endpoints** section for detailed API operations, including request and response examples.
* Refer to **Error Handling** for common issues and their solutions.


# Authentication

## Authentication

To interact with the METI API, you must receive a client id and client secret for your Custodian account from MillPont administrators.\
\
This API uses **Auth0 JWT Bearer tokens** for authentication. Each client gets dedicated credentials with account-specific access.

### 1. Get an Access Token (Auth0)

#### Request

**URL:** https\://\<AUTH0\_DOMAIN>/oauth/token\
**Method:** POST\
**Headers:** Content-Type: application/json\
**Body**\
`{ "client_id": "<YOUR_CLIENT_ID>", "client_secret": "<YOUR_CLIENT_SECRET>", "audience": "https://api.meti.millpont.com", "grant_type": "client_credentials", "scope": "read:sources write:sources delete:sources" }`

#### Example (cURL)

```
curl -X POST "https://<AUTH0_DOMAIN>/oauth/token" \
  -H "Content-Type: application/json" \
  -d '{
    "client_id": "<YOUR_CLIENT_ID>",
    "client_secret": "<YOUR_CLIENT_SECRET>",
    "audience": "https://api.meti.millpont.com",
    "grant_type": "client_credentials",
    "scope": "read:sources write:sources delete:sources"
  }'

```

#### **Response**

`{`\
`"access_token": "eyJhbGciOiJIUzI1NiIsInR5cCI6IkpXVCJ9...",`\
`"token_type": "Bearer",`\
`"expires_in": 3600,`\
`"scope": "read:sources write:sources delete:sources"`\
`}`

Key fields:

* `access_token` (string): The JWT used to authenticate with the METI API.
* `token_type` (string): Always `Bearer`.
* `expires_in` (integer): Lifetime of the token in seconds.
* `scope` (string): Space-separated API permissions granted to this token.

Depending on your Auth0 configuration, the token may also include custom METI claims such as:

* `https://api.meti.millpont.com/account_id`
* `https://api.meti.millpont.com/role`
* `https://api.meti.millpont.com/client_name`
* `https://api.meti.millpont.com/v1_client_id`

These are used by the API to associate requests with accounts and roles.

### 2. Using the Access Token with METI API

Once you have an `access_token`, include it in the `Authorization` header for all METI API requests.

**Format**

```
Authorization: Bearer <access_token>
```

#### Example: List Sources

```bash
curl -X GET "https://api.meti.millpont.com/sources" \
  -H "Authorization: Bearer eyJhbGciOiJIUzI1NiIsInR5cCI6IkpXVCJ9..."
```

#### Example: Filtered by Methodology

```bash
curl -X GET "https://api.meti.millpont.com/sources?methodology=Agriculture" \
  -H "Authorization: Bearer <access_token>"
```

***

### 3. Token Expiration & Automated Workflows

Access tokens are valid for the duration specified in `expires_in`.\
For long-running or automated workflows, you should:

1. **Store the token and its expiry time**.
2. **Check validity before each request**.
3. **Request a new token automatically when needed**.

#### Steps for Token Renewal

1. **Track Token Expiration**
   * When you receive `expires_in`, compute an expiry timestamp, e.g.:

     ```python
     expiry_timestamp = time.time() + response_data["expires_in"]
     ```
2. **Check Before Each API Call**
   * If `time.time() >= expiry_timestamp`, request a new token from Auth0.
3. **Automate Token Requests**
   * Implement a helper that handles token fetching and refreshing, and reuse it across your application.

***

### 4. Minimal Python Example (Client Credentials + Auth Header)

Below is a simplified example inspired by your test script that:

* Requests an access token from Auth0.
* Automatically refreshes it when expired.
* Calls the METI API `/sources` endpoint.

```python
import time
import os
import requests

AUTH0_DOMAIN = os.getenv("AUTH0_DOMAIN")
AUTH0_AUDIENCE = os.getenv("AUTH0_AUDIENCE", "https://api.meti.millpont.com")
CLIENT_ID = os.getenv("ARVA_CLIENT_ID")       # or generic CLIENT_ID
CLIENT_SECRET = os.getenv("ARVA_CLIENT_SECRET")
BASE_URL = "https://api.meti.millpont.com"

token = None
token_expiry = 0  # epoch seconds

def get_access_token():
    global token, token_expiry

    token_url = f"https://{AUTH0_DOMAIN}/oauth/token"
    payload = {
        "client_id": CLIENT_ID,
        "client_secret": CLIENT_SECRET,
        "audience": AUTH0_AUDIENCE,
        "grant_type": "client_credentials",
        "scope": "read:sources write:sources delete:sources"
    }

    response = requests.post(token_url, json=payload, timeout=10)
    response.raise_for_status()
    data = response.json()

    token = data["access_token"]
    # Subtract a small buffer so we refresh slightly before actual expiration
    token_expiry = time.time() + data["expires_in"] - 30

def get_auth_headers():
    global token, token_expiry

    if token is None or time.time() >= token_expiry:
        get_access_token()

    return {
        "Authorization": f"Bearer {token}",
        "Content-Type": "application/json"
    }

def get_sources():
    headers = get_auth_headers()
    response = requests.get(f"{BASE_URL}/sources", headers=headers, timeout=10)
    response.raise_for_status()
    return response.json()

if __name__ == "__main__":
    sources = get_sources()
    print(f"Found {len(sources)} sources")
```

**Benefits of this pattern**

* Prevents downtime due to expired tokens.
* Keeps API access continuous for long-running or large-scale jobs.
* Centralizes authentication logic in one place.

***

### 5. Scopes & Permissions

Certain endpoints require specific scopes. For example:

* `read:sources` – read access to sources
* `write:sources` – create/update sources
* `delete:sources` – delete sources

If your token does not include the necessary scopes, calls may fail with `403 Forbidden`.\
Your Auth0 administrator must grant the appropriate scopes to your application in the Auth0 dashboard.

***

### 6. Common Errors

* **401 Unauthorized**
  * Missing `Authorization` header.
  * Malformed token.
  * Expired token.
  * Using the wrong Auth0 domain or audience when requesting the token.
* **403 Forbidden**
  * Token is valid, but does not have the required scopes (permissions) for the endpoint.
  * Ask your Auth0 administrator to update the application’s API permissions (e.g., `read:sources`, `write:sources`, `delete:sources`).

***

By integrating Auth0 client-credentials authentication and automated token management as shown above, you can maintain secure, uninterrupted access to the METI API—even for complex, long-running workflows.


# Endpoints

## **Endpoints**

This section describes all available endpoints in the **METI API v2.0.0**.\
Each endpoint includes authentication requirements, usage details, parameters, and examples.

***

## **Base URL**

All API requests use the following base URL:

```
https://api.millpont.com
```

***

## **Authentication (Required)**

The METI API now uses **Auth0 OAuth2 Client Credentials**.\
You must obtain an access token and include it in every request:

```
Authorization: Bearer <access_token>
```

#### **How to Get a Token**

```bash
curl -X POST "https://<AUTH0_DOMAIN>/oauth/token" \
  -H "Content-Type: application/json" \
  -d '{
    "client_id": "<YOUR_CLIENT_ID>",
    "client_secret": "<YOUR_CLIENT_SECRET>",
    "audience": "https://api.meti.millpont.com",
    "grant_type": "client_credentials"
  }'
```

#### Example Token Response

```json
{
  "access_token": "eyJhbGc...etc",
  "expires_in": 3600,
  "token_type": "Bearer",
  "scope": "read:sources write:sources delete:sources"
}
```

***

## **Account Isolation**

* Every token contains an `account_id`.
* All queries automatically filter to your account.
* Clients **cannot access** other accounts.
* Admin tokens may access all accounts.

***

## **Endpoints Overview**

| Endpoint               | Method | Description                   |
| ---------------------- | ------ | ----------------------------- |
| `/sources`             | GET    | List sources for your account |
| `/sources`             | POST   | Create one or more sources    |
| `/sources/{source_id}` | GET    | Retrieve a single source      |
| `/sources/{source_id}` | DELETE | Delete a single source        |
| `/sources` (query)     | DELETE | Delete by `alt_id`            |

***

## **GET /sources**

#### **List All Sources (Account-Filtered)**

**URL**

```
GET https://api.millpont.com/sources
```

**Headers**

```
Authorization: Bearer <access_token>
```

**Query Parameters (optional)**

| Parameter                | Type             | Description                                                                    |
| ------------------------ | ---------------- | ------------------------------------------------------------------------------ |
| `methodology`            | string           | Filter by methodology                                                          |
| `limit`                  | integer          | Pagination size                                                                |
| `offset`                 | integer          | Pagination offset                                                              |
| `steward_id`             | string           | ID of producer / grower                                                        |
| `project_id`             | string           | Group sources by project                                                       |
| `outcome_reporting_year` | integer          | The calendar year a source's environmental outcomes are tied to.               |
| `source_type`            | string           | Filter by source type (e.g., `FACILITY`, `FIELD`, `SITE`)                      |
| `attribute_type`         | array of strings | Filter by one or more attribute types (e.g., `CARBON_REMOVAL`, `BIODIVERSITY`) |
| `geometry_source`        | string           | Filter by how the geometry was created (e.g., `CUSTODIAN_DRAWN`, `DERIVED`)    |

#### **Example Request**

```bash
curl -X GET "https://api.millpont.com/sources" \
  -H "Authorization: Bearer <token>"
```

#### **Example Response**

```json
[
  {
[
  {
    "id": "src_abc123",
    "account_id": "8e05e670-65df-4e7e-b2f1-31e0b3094bcf",
    "methodology": "Agriculture",
    "source_type": "FACILITY",
    "attribute_type": ["CARBON_REMOVAL", "BIODIVERSITY"],
    "geometry_source": "CUSTODIAN_DRAWN",
    "country": "United States",
    "hectares": 124.5,
    "geojson": { ... }
  }
]
```

***

## **GET /sources/{source\_id}**

Retrieve a single source by its unique ID.

**URL**

```
GET https://api.millpont.com/sources/{source_id}
```

**Optional Parameters Example**\
\
`GET https://api.millpont.com/sources?steward_id=GM-Producer-1&source_type=FACILITY&attribute_type=CARBON_REMOVAL&attribute_type=BIODIVERSITY`\
\
**Headers**

```
Authorization: Bearer <access_token>
```

**Path Parameter**

| Name        | Type   | Description                           |
| ----------- | ------ | ------------------------------------- |
| `source_id` | string | Source ID (e.g., `src_6ETupIGAbhjb7`) |

#### **Example Request**

```bash
curl -X GET "https://api.millpont.com/sources/src_6ETupIGAbhjb7" \
  -H "Authorization: Bearer <token>"
```

***

## **POST /sources**

#### **Create One or More Sources**

Your request must include:

* A valid **GeoJSON FeatureCollection**
* Each Feature includes:
  * `id`
  * `properties.start_at`
  * `properties.end_at`
  * `geometry` (Polygon or MultiPolygon)
* Optional parameters:
  * `methodology`
  * `tags`
  * `steward_id`
  * `project_id`
  * `outcome_reporting_year`
  * `source_type` : Describes the physical or organizational nature of the source (e.g., `FIELD`, `FACILITY`, `DEVICE`, `PROGRAM`, `JURISDICTIONAL`). Useful for distinguishing point-of-origin contexts within the source ledger.
  * `attribute_type` : An array of one or more environmental attribute classifications associated with the source (e.g., `CARBON_REMOVAL`, `CARBON_AVOIDANCE` ,  `CI_SCORE` , `BIODIVERSITY`, `RENEWABLE_ENERGY` , `WATER_QUALITY` , `WATER_QUANTITY` . Supports multi-attribute sources.
  * `geometry_source` : Indicates how the source geometry was generated (e.g., `CUSTODIAN_DRAWN`, `AUTHORITATIVE_GIS`,  `EXTERNAL_REGISTRY` ). Helps document provenance of spatial boundaries.

Note: Methodology (i.e. "Nature Restoration | Production to Conservation") can provide useful context when overlaps arise in the Source ledger. Tags are used to support additional context. A common use case is to denote the function(s) of the area of interest, for example: "production", "processing", "storage", "transportation".  Steward ID allows you to group sources by producer. Project ID is another way to subgroup your sources. Outcome reporting year is the calendar year environmental outcomes are associated with.

The API automatically attaches:

* `account_id` (from JWT)
* `created_by` and `updated_by` (from JWT metadata)

**URL**

```
POST https://api.millpont.com/sources
```

**Headers**

```
Content-Type: application/json
Authorization: Bearer <access_token>
```

***

#### **Example Request**

```bash
curl -X POST "https://api.millpont.com/sources" \
  -H "Authorization: Bearer <token>" \
  -H "Content-Type: application/json" \
  -d '{
    "feature_collection": {
      "type": "FeatureCollection",
      "features": [
        {
          "type": "Feature",
          "id": "APITEST2",
          "properties": {
            "start_at": "2024-11-01T16:25:00.000Z",
            "end_at": "2024-11-10T16:25:00.000Z"
          },
          "geometry": {
            "type": "Polygon",
            "coordinates": [
              [
                [-95.9915183, 32.7766954],
                [-95.9915183, 32.7706437],
                [-95.9849752, 32.7706437],
                [-95.9849752, 32.7766954],
                [-95.9915183, 32.7766954]
              ]
            ]
          }
        }
      ]
    },
    "methodology": "Agriculture",
    "source_type": "FACILITY",
    "attribute_type": ["RENEWABLE_ENERGY", "BIODIVERSITY"],
    "geometry_source": "CUSTODIAN_DRAWN",
    "tags": ["test", "api"],
    "steward_id": "GM-Producer-1",
    "project_id": "General Mills",
    "outcome_reporting_year": 2024
  }'
```

#### **Example Response**

```json
[
  {
    "id": "src_6ETupIGAbhjb7",
    "alt_id": "APITEST2",
    "message": "Source created successfully."
  }
]
```

***

## **DELETE /sources/{source\_id}**

Delete a source by its ID.

**URL**

```
DELETE https://api.millpont.com/sources/{source_id}
```

**Headers**

```
Authorization: Bearer <access_token>
```

#### **Example Request**

```bash
curl -X DELETE "https://api.millpont.com/sources/src_tJsijx0UmuGE9" \
  -H "Authorization: Bearer <token>"
```

#### **Example Response**

```json
{
  "message": "Source deleted successfully."
}
```

***

## **DELETE /sources (Delete by alt\_id)**

You may also delete by **alt\_id**:

**URL**

```
DELETE https://api.millpont.com/sources?alt_id=<my_alt_id>
```

**Example**

```bash
curl -X DELETE "https://api.millpont.com/sources?alt_id=APITEST2" \
  -H "Authorization: Bearer <token>"

```


# Error Handling

## **Error Handling**

Common errors include:

#### **401 – Unauthorized**

* Missing or invalid token
* Expired token
* Token not intended for this API (`audience` mismatch)

#### **403 – Forbidden**

* Token does not include required scopes
* Client attempting to access data in another account

#### **404 – Not Found**

* Source ID does not exist
* Or does not belong to your account

#### **422 – Validation Error**

* Bad GeoJSON
* Missing fields
* Invalid date formats

***

## **Support**

For API access or help:

* **Website:** METI API Support
* **Email:** <admin@millpont.com>


# Sandbox

The sandbox lets you test your integration against the full `/sources` API without affecting production data. Requests are validated exactly as they would be in production - same authentication, same request bodies, same response shapes - but nothing is persisted. Data exists only for the duration of your session.

Use the sandbox to verify request formatting, test error handling, and validate your workflow end-to-end before going live.

### 1. Base URL

All sandbox endpoints are prefixed with `/sandbox`:

```
https://api.meti.millpont.com/sandbox/sources
```

### 2. Authentication

The sandbox uses the same Auth0 credentials and scopes as the production API. No separate keys are required. See [Authentication](https://claude.ai/meti-api-documents/authentication) for setup.

### 3. Create a Source

`POST /sandbox/sources`

**Scope:** `write:sources`

Accepts the same `SourceCreateRequest` body as the production endpoint. All fields are validated identically - geometry, dates, `alt_id`, and account resolution. If your request would succeed in production, it will succeed here.

Sandbox sources are assigned an ID prefixed with `sandbox_` so they are clearly distinguishable from production records.

> **Note:** Spatial analysis fields such as `conflict`, and `unep_overlap`, return default values (`false` / `null`) in the sandbox.

Example

```
curl -X POST "https://api.meti.millpont.com/sandbox/sources" \
  -H "Authorization: Bearer <access_token>" \
  -H "Content-Type: application/json" \
  -d '{
    "alt_id": "test-field-001",
    "methodology": "Agriculture",
    "geometry": {
      "type": "Polygon",
      "coordinates": [[[...], [...], [...], [...]]]
    }
  }'
```

Response - `List[SourceResponse]`

```json
[
  {
    "id": "sandbox_a3f1c8e2b04d7a916e5f2d3c1b8e0f47",
    "alt_id": "test-field-001",
    "methodology": "Agriculture",
    "created_at": "2026-04-13T14:22:01.000Z",
    "updated_at": "2026-04-13T14:22:01.000Z",
    "conflict": false,
    "unep_overlap": null,
    "h3_indexes": null
  }
]
```

### 4. Retrieve Sources

#### Get a single source

`GET /sandbox/sources/{source_id}`

**Scope:** `read:sources`

Returns `SourceResponse` or `404`.

```
curl -X GET "https://api.meti.millpont.com/sandbox/sources/sandbox_a3f1c8e2b04d7a916e5f2d3c1b8e0f47" \
  -H "Authorization: Bearer <access_token>"
```

#### List sources

`GET /sandbox/sources`

**Scope:** `read:sources`

Returns all sandbox sources for your account. Supports the same query parameters as the production list endpoint:

`id` · `alt_id` · `methodology` · `steward_id` · `project_id` · `outcome_reporting_year` · `limit` · `offset`

```
curl -X GET "https://api.meti.millpont.com/sandbox/sources?methodology=Agriculture&limit=10" \
  -H "Authorization: Bearer <access_token>"
```

Response — `List[SourceResponse]`

### 5. Delete Sources

#### By ID

`DELETE /sandbox/sources/{source_id}`

#### By alt\_id

`DELETE /sandbox/sources?alt_id=...`

```
curl -X DELETE "https://api.meti.millpont.com/sandbox/sources?alt_id=test-field-001" \
  -H "Authorization: Bearer <access_token>"
```

You can only delete sources that belong to your account.

### 6. Sandbox Source IDs

Sandbox source IDs use the format `sandbox_<uuid>`:

```
sandbox_a3f1c8e2b04d7a916e5f2d3c1b8e0f47
```

The `sandbox_` prefix ensures these IDs are immediately recognizable and will not resolve against the production `/sources/{id}` endpoint.

### 7. Errors

The sandbox returns the same error codes and formats as the production API.

| Code  | Meaning                                                                  |
| ----- | ------------------------------------------------------------------------ |
| `401` | Missing, malformed, or expired token.                                    |
| `403` | Valid token, but missing the required scope.                             |
| `404` | Source ID not found, or belongs to a different account.                  |
| `422` | Request body failed validation — invalid geometry, malformed dates, etc. |


# Source Data Dictionary

Purpose: Represents a location or entity that is the origin of an environmental impact measurement (e.g., a field, a factory, well, or farm).

| Field                  | Data Type      | Description                                                                  | Example                                      | Constraints/Notes                                                                   |
| ---------------------- | -------------- | ---------------------------------------------------------------------------- | -------------------------------------------- | ----------------------------------------------------------------------------------- |
| **Secure Source ID**   | String         | Unique public identifier for the Source in the METI system                   | `src_83AskOwkQXm6E`                          | Generated by METI, and globally unique                                              |
| **Internal ID**        | String / UUID  | Internal reference ID used to map the Source to user/org databases.          | `87d9fabc-1234-...`                          | Distinct from SSID, used only for internal linking.                                 |
| **Location (GeoJSON)** | GeoJSON Object | Geospatial data describing the physical location/footprint of the Source.    | See [GeoJSON](https://geojson.org/) example. | Must be valid GeoJSON (e.g., point, polygon). Can store coordinates, polygons, etc. |
| **Valid From**         | Date/DateTime  | The date/time from which the Source’s location or definition is valid.       | `2025-01-01T00:00:00Z`                       | Required                                                                            |
| **Valid To**           | Date/DateTime  | The date/time until which the Source’s location or definition remains valid. | `2030-12-31T23:59:59Z`                       | Required                                                                            |


# Deposits Data Dictionary (Beta)

Purpose: Represents reported environmental commodities, their volumes, and measurements (e.g., carbon, Scope 3 totals, Low-CI commodities).

| Field                                               | Data Type             | Description                                                                                          | Example                       | Constraints/Notes                                                              |
| --------------------------------------------------- | --------------------- | ---------------------------------------------------------------------------------------------------- | ----------------------------- | ------------------------------------------------------------------------------ |
| **Deposit ID**                                      | String / UUID         | A unique identifier for the Deposit record.                                                          | `dep_A7KpM6bPQrW2e`           | Generated by METI, the primary key for the deposit. Globally unique            |
| **Secure Source ID**                                | String (FK to Source) | SSID that this Deposit is associated with.                                                           | `src_83AskOwkQXm6E`           | Must match a valid SSID.                                                       |
| **Commodity → Type**                                | String (enum)         | The name/category of the commodity (e.g., “carbon,” “corn,” “beef”).                                 | `corn`                        | Constrained to Commodities Catalog                                             |
| **Commodity → Unit**                                | String (enum)         | The measurement unit for the commodity (e.g., “ton,” “kg,” “bushel”).                                | `metric ton`                  | Constrained to Unit & Unit Rates Catalog                                       |
| **Commodity → Volume**                              | Decimal / Float       | The quantity of the commodity reported.                                                              | `100.50`                      | Must align with the **Unit** (e.g., 100.50 metric tons).                       |
| **Commodity → Date/Time (Harvest/Production Year)** | Date/DateTime         | The date/time (or year) of the commodity’s production or harvest.                                    | `2024` or `2024-05-10T12:00Z` | May store a single year or a full date/time, depending on precision needed.    |
| **Impact → Type**                                   | String (enum)         | Category or name of the measured impact (e.g., “GHG,” “Water,” “Biodiversity”).                      | `GHG`                         | Should align with a controlled vocabulary for impact types.                    |
| **Impact → Unit (or Unit Rate)**                    | String                | Measurement unit or ratio for the impact (e.g., “kg CO₂e per ton of product”).                       | `kgCO2e/ton`                  | Constrained to Unit & Unit Rates Catalog                                       |
| **Impact Coefficient → Numerator**                  | Decimal / Float       | Numerator portion of the impact rate, if using a rate                                                | `0.50`                        | For example, 0.50 kg CO₂e per ton of product                                   |
| **Impact → Volume**                                 | Decimal / Float       | The quantity of environmental attributes reported.                                                   | `100`                         | For example, “100 ton of product"                                              |
| **Impact → Method**                                 | String                | The methodology or standard used for calculating the impact (e.g., “ISO 14064,” “VM0042”).           | `ISO 14064`                   | Helps identify the reporting or calculation standard.                          |
| **Impact → Practice/Intervention**                  | String                | Brief descriptor for how the commodity was produced or the impact reduced (e.g., “no-till farming”). | `no-till farming`             | Useful for capturing relevant production or mitigation details.                |
| **Impact → Date/Time (Measurement Event)**          | Date/DateTime         | The date/time the impact was measured or verified.                                                   | `2025-03-15T09:00:00Z`        | Different from commodity production date; specifically for measurement events. |
| **Verification Status**                             | String (enum)         | Indicates if the Deposit is Unverified, Self-verified, or Third-Party Verified.                      | `Third-Party Verified`        | Could be linked to distinct verification states or certificates.               |
| **Third-Party Verifier Name & ID**                  | String                | Information about the external verifier or auditing agency.                                          | `VeriCheck Inc. (ID# 555)`    | Could be separated into multiple fields (name, ID, accreditation) if needed.   |


# Repositories Data Dictionary (Beta)

Purpose: Facilitates exchange, storage, or sharing of the Source and Deposits data. May represent external data registries, transaction/delivery, or verification workflow.

<table data-header-hidden><thead><tr><th width="165"></th><th></th><th></th><th></th><th></th></tr></thead><tbody><tr><td><strong>Field</strong></td><td><strong>Data Type</strong></td><td><strong>Description</strong></td><td><strong>Example</strong></td><td><strong>Constraints / Notes</strong></td></tr><tr><td><strong>Repo ID</strong></td><td>String / UUID</td><td>A unique identifier for the Repository record.</td><td><code>REPO-789456</code></td><td>Primary key for the repository; must be unique.</td></tr><tr><td><strong>Custodian ID</strong></td><td>String / UUID</td><td>Identifies the entity/account responsible for this repository.</td><td><code>CUST-001</code></td><td>Maps to an internal or external “custodian” entity.</td></tr><tr><td><strong>Type/s of Repo</strong></td><td>String (enum/set)</td><td>Indicates the repository’s use-cases (e.g., Verification, Transaction, Audit).</td><td><code>["Verification","Audit"]</code></td><td>Could be a list/array if multiple roles apply.</td></tr><tr><td><strong>Counterparty ID</strong></td><td>String / UUID</td><td>Identifier for additional party(ies) involved (custodian, verifier, owner, auditor).</td><td><code>USER-12345</code></td><td>May need multiple references if multiple parties exist.</td></tr><tr><td><strong>Counterparty Role</strong></td><td>String (enum)</td><td>The specific role(s) the counterparty plays in this repository (e.g., verifier, auditor).</td><td><code>verifier</code></td><td>Could be “custodian,” “verifier,” “owner,” or “auditor.”</td></tr><tr><td><strong>Counterparty Permissions</strong></td><td>String (enum)</td><td>Level of access granted (e.g., read, write, verify).</td><td><code>read, verify</code></td><td>Reflects the system’s access control model.</td></tr><tr><td><strong>Counterparty Email</strong></td><td>String (email format)</td><td>Contact email address for the counterparty.</td><td><code>verifier@example.com</code></td><td>Optional but useful for notifications.</td></tr><tr><td><strong>Transaction/Contract ID</strong></td><td>String / UUID</td><td>Identifier for transactions or contracts relevant to this repository.</td><td><code>TX-000999</code></td><td>Could link to a separate ledger or contract management system.</td></tr><tr><td><strong>Volume/Quantity → Deposits</strong></td><td>Array of Deposit IDs</td><td>References to Deposit ID(s) stored/transacted in this repository.</td><td><code>["DEP-456789","DEP-1122"]</code></td><td>Must match existing Deposit records.</td></tr><tr><td><strong>Volume/Quantity → SSIDs</strong></td><td>Array of Source SSIDs</td><td>References to Source SSIDs relevant to the deposits or data in this repository.</td><td><code>["SRC-000123","SRC-005"]</code></td><td>Must match existing Source records.</td></tr><tr><td><strong>Settlement Info → Price</strong></td><td>Decimal / Float</td><td>Monetary amount or price for a transaction in the repository.</td><td><code>1000.00</code></td><td>Could store currency code separately (e.g., “USD 1000.00”).</td></tr><tr><td><strong>Settlement Info → Method</strong></td><td>String (enum)</td><td>How payment or settlement is conducted (e.g., “cash,” “token,” “credit”).</td><td><code>token</code></td><td>Could reflect fiat, on-chain tokens, or other payment methods.</td></tr><tr><td><strong>Access Controls &#x26; Encryption Keys</strong></td><td>String / Object</td><td>Security fields for read/write or cryptographic permissions.</td><td>JSON object of key data</td><td>May store references to actual public keys or hashed credentials.</td></tr><tr><td><strong>Audit Logs</strong></td><td>Array / Log object</td><td>Record of actions/events performed in the repository (access, edits, verifications).</td><td><code>[{"action":"create",...}]</code></td><td>Could be stored as a structured log with timestamps, user IDs, etc.</td></tr></tbody></table>


# Introduction Presentation

2025 METI Introduction Presentation

{% embed url="<https://docs.google.com/presentation/d/e/2PACX-1vRNovfawP9lXjX0CPaeIYSh9wqmLoV8GgN4c9l8zNsxDohLSwE_rZNwQqM2Fq-PcMWUUa8zUtS6YQII/pub?delayms=3000&loop=false&start=false>" %}


# What is a Source?

Description of a Source in the METI framework

## Definition

A **Source** refers to the point of origin of an environmental benefit. For METI, a Source is considered an individual contiguous parcel or facility that is the smallest unit of land with the following characteristics:

1. **A permanent, contiguous boundary**\
   *Example:* A 40-acre field used for regenerative grazing, surrounded by roads or fences that clearly define its edges.
2. **A common land cover and land management**\
   *Example:* A corn field with cover cropping and no-till practices applied across the entire parcel.
3. **Common ownership or group of owners/land managers**\
   *Example:* A pasture owned by a farming cooperative or managed jointly by a family under a single operational agreement.
4. **A common project administrator or project proponent (i.e., Custodian)**\
   *Example:* A reforestation project led by a local conservation NGO overseeing multiple parcels within a watershed program.

These criteria ensure that each Source is distinctly identifiable, manageable, and accurately linked to its environmental outcomes.

## Example

Below is an example of three fields that meet METI’s definition of a Source. Each field represents a distinct, contiguous parcel of land with a defined boundary, consistent land cover and management practices, and shared oversight by a common project administrator (i.e. Custodian). These fields demonstrate how Sources are clearly delineated and aligned with METI’s standards for secure environmental asset tracking.

* **Field ID: 1**\
  *Crop Type:* Corn\
  *Management Practices:* No-Till
* **Field ID: 2**\
  *Crop Type:* Soybeans\
  *Management Practices:* No-Till & Cover Crops
* **Field ID: 3**\
  *Crop Type:* Wheat\
  *Management Practices:* No-Till & Cover Crops

<figure><img src="https://935478215-files.gitbook.io/~/files/v0/b/gitbook-x-prod.appspot.com/o/spaces%2FsOHSoZVLzSuaTRyLHoDS%2Fuploads%2FYhJ55hfPaHEitcsfdh9W%2FScreenshot%202024-11-22%20140553.jpg?alt=media&amp;token=71748cd1-405c-4417-9d86-1af7d9880908" alt=""><figcaption></figcaption></figure>

This example highlights how Sources are identified and differentiated based on specific attributes, ensuring accurate and consistent tracking of environmental outcomes.


# How METI Source Network Works

The process for embedding verifiable trust in sustainable exchange

METI™ (MillPont Environmental Trust Infrastructure) operates as a geospatial clearinghouse and trust network, transforming environmental data management in nature-based raw material supply chains. At its core, METI  introduces **Secure Source IDs (SSIDs) -** digital deeds linked to [Sources ](/meti-resources/what-is-a-source)of environmental outcomes. These digital deeds provide a secure, dynamic, and interoperable network for connecting nature-based raw material value chains with environmental data markets.

## **Secure Source IDs (SSIDs)**&#x20;

SSIDs are **digital deeds** that transform how environmental outcomes are tracked, verified, and managed. By linking each Source to an SSID, METI enables:

* **Ownership Verification & Validation**: Each SSID is tied to a specific Source and its environmental outcomes, ensuring accurate claims and compliance with market standards - mitigating double-counting and greenwashing.
* **Security**: Encrypted identifiers protect data integrity and ownership while safeguarding against fraud or duplication.
* **Interoperability**: SSIDs are designed to integrate seamlessly with multiple platforms, markets, and regulatory frameworks, reducing friction across supply chains, registries, and marketplaces.
* **Dynamic Functionality**: SSIDs evolve over time, capturing updates to claims, monitoring status changes, and ensuring outcomes remain relevant and actionable.

***

## How METI Works: Step-by-Step Process

<figure><img src="https://935478215-files.gitbook.io/~/files/v0/b/gitbook-x-prod.appspot.com/o/spaces%2FsOHSoZVLzSuaTRyLHoDS%2Fuploads%2FZad3mrRy7GuPMVeMhrRD%2FMillPont%20Investor%20Deck%20-%202025%20(1).png?alt=media&amp;token=f6b978d0-bab3-4aac-b365-663c63afc1c7" alt=""><figcaption></figcaption></figure>

{% stepper %}
{% step %}
**Submission of Sources**

METI Members (e.g., Perdue) submit **Sources** from agricultural, forestry and land-use projects to METI’s Clearinghouse. These Sources include:

* Geospatial boundaries of project fields. (*required)*
* Management timelines - Valid From: Valid To - specifying the duration of claims (*required)*
* Project Methodology, Practice Data, and Verification Status (*optional*)&#x20;

***

{% endstep %}

{% step %}
**Process & Validate**

The Clearinghouse reformats and encrypts incoming data, checks for consistency and privacy protection, and validates exclusivity by comparing submissions against the METI Network, Protected Areas, and public registries (e.g., Verra, CAR, ACR, Gold Standard, etc.).

***

{% endstep %}

{% step %}
**Issue SSIDs & Linking to Outcomes**

Validated Sources receive an encrypted Secure Source Identifier (SSID) - a *digital deed* - which members attach to verified outcomes and move through their supply chain. The SSID ensures traceability, prevents double-counting, and gives buyers confidence in each transaction and link in the supply chain.

***

{% endstep %}

{% step %}
**Authenticate & Monitor**

Buyers and auditors authenticate claims through the Source Ledger. METI continuously monitors SSIDs for ongoing exclusivity, compliance with Rulebook standards, and integrity until the claim expires.
{% endstep %}
{% endstepper %}

***

## **Key Benefits**&#x20;

* **Trust, Transparency & Data Privacy**: SSIDs provide verifiable and traceable assurance of environmental claims ownership, while protecting the privacy of farmers and land-owners.&#x20;
* **Scalable Market Integration**: Interoperability ensures compatibility across platforms, registries, and value chains.
* **Dynamic Accountability**: SSIDs adapt to updates in environmental outcomes and ownership, ensuring continuous relevance and detection of conflicts - historically and on an ongoing basis. &#x20;
* **Efficient Ownership Management**: SSIDs simplify complex transactions by creating a secure, traceable link between Sources and outcomes, ensuring claims are unique, exclusive, and readily auditable.&#x20;

METI empowers stakeholders to connect raw material value chains with climate markets, fostering a sustainable future. By leveraging SSIDs as digital deeds, METI ensures that environmental claims are not just credible but also verifiable, authentic, and traceable - to the source - at scale. &#x20;


# Frequently Asked Questions

## **What does METI provide that other platforms do not?**

METI is an agricultural industry-first digital claims clearinghouse, utilizing [advance encryption](https://csrc.nist.gov/Presentations/2023/stppa6-iso-iec-fhe) techniques to assign unique identifiers, or “thumbprints,” to data. This ensures data confidentiality while enabling third-party verification, making environmental claims in agricultural supply chains and landscapes credible, comparable, and traceable - while privacy preserving. Additionally, METI integrates a strong governance framework and efficient conflict resolution process, reducing duplication of claims across platforms, projects, and registries allowing members to trust the integrity and exclusivity of their environmental claims without compromise.

## What specific services does METI offer?

METI offers foundational services to support secure environmental claims in agricultural supply chains and landscapes:&#x20;

* **Data Transparency and Management**: A digital ledger that enables access to reliable, privacy-preserving data.
* **Conflict Resolution:** A streamlined process to resolve overlapping claims, reducing duplicated assets across projects, programs, and registries.
* **Verification and Auditing:** Comprehensive tools to track and make agricultural climate project data reviewable by third parties and regulatory bodies.
* **Integration with Financial Processes:** Connection to financial systems to facilitate project financing and provide a trusted foundation for climate markets​.

## **What is METI’s business model?**

MillPont operates a membership-based program, METI Originate, with [options](/meti-operative-documents/membership-fee-schedule) suited for a range of organizational structures and scales:

* **Basic:** Ideal for small projects and pilots, offering 100 secure sources per year, with an option to add more at a per-source fee.
* **Standard:** For growing businesses, including 15,000 secure sources and API access with scalable fees for additional sources.
* **Enterprise:** Designed for high-volume marketplaces and registries, offering 95,000 secure sources, API access, and advisory support, with customizable fees based on usage​.&#x20;

## What data does METI store, and what measures does it take to protect data?

METI stores essential metadata related to the [Source](#what-are-secure-source-ids-ssids) of environmental benefits, such as the geospatial and temporal extent of a project claim (e.g., a field from an agricultural project from 2020 to 2030). Each source is unique per environmental attribute (e.g., carbon, biodiversity), mitigating duplicated assets. METI only stores data needed for uniqueness and provenance, preserving privacy and competitive information, while promoting transparency with easy validation and verification.&#x20;

To safeguard and handle data, MillPont has developed proprietary applications of  [Fully Homomorphic Encryption (FHE)](https://csrc.nist.gov/Presentations/2023/stppa6-iso-iec-fhe), an advanced encryption technology allowing computations on encrypted data without exposing  [Personally Identifiable Information (PII)](https://www.nrcs.usda.gov/sites/default/files/2022-10/Safeguarding_PII_Fact_Sheet_Fillable_1_3_22.pdf). This means that METI can securely process and validate environmental claims without compromising individual privacy or disclosing sensitive project information. By using advanced encryption, METI maintains data integrity and transparency for verification while ensuring that personal and location-specific details remain protected and private.

Additionally, MillPont’s pursuit of SOC 2 compliance underscores its commitment to industry-leading standards in data security and privacy management.

## If I am already using blockchain, do I need to use METI Originate?

Blockchain tokenization can be powerful but does not inherently prevent double-counting. Only tokens with cryptographically-linked MRV (Monitoring, Reporting, and Verification) audit trails provide full claims integrity. METI Originate complements blockchain by offering a cryptographic bridge across diverse on- and off-chain solutions, providing a unified checkpoint for data verification across protocols, platforms, and systems, enhancing the security and reliability of existing blockchain applications​.

## Who is a Custodian?

A Custodian holds ownership and or administrative authority over the data required to produce, and or underwrite, an environmental asset connected to Secure Source IDs (SSIDs) and Environmental Attribute Certificates (EACs). Custodians, typically project developers or program administrators, are responsible for the management of SSIDs and issuance of EACs, ensuring claims data is governed with the highest standards of accountability and exclusivity.

## What are Secure Source IDs (SSIDs)?

SSIDs are unique 16-character identifiers embedded in digital certificates for sustainable projects. As digital identifiers, SSIDs create unique, comparable claim fingerprints, blending geospatial, temporal, and environmental data. These identifiers enable efficient underwriting, verification, and secure data comparison across platforms​ and data systems.

## What are Environmental Attribute Certificates (EACs)?

EACs are market instruments that represent the intangible property rights to claim the quantified environmental benefits generated by sustainable practices and ecosystem services connected to water, carbon, and biodiversity. Issued and managed by Custodians, they can includes one or more SSIDs, providing integrity, exclusivity and traceability. EACs are mediums of exchange for the transfer of environmental assets across platforms and between counterparties.

## What is METI’s long-term vision for agricultural climate markets?

MillPont is building resilient infrastructure designed to attract institutional investment, drive market innovation, and enable scalable, regulation-ready environments. By proactively engaging with agricultural market participants and regulators, METI is developing a system that can evolve to support the scale and rigor of regulated markets like commodities, equities, and interest rates. This adaptable, scalable infrastructure uniquely positions METI to meet the rising accountability standards in global agricultural climate markets, including insets, biofuels, climate-smart commodities, and offsets.

## Why do we need agricultural climate markets?

To achieve global climate goals, companies need to reduce emissions quickly and effectively. However, decarbonizing at the necessary pace remains challenging, and climate markets are essential for directing capital toward projects that reduce and remove emissions worldwide. These markets—driven by insetting, offsetting, low-carbon biofuels and climate-smart —can scale to remove billions of tons of carbon annually, far beyond current trading levels.&#x20;


# Registration Application

{% embed url="<https://share.hsforms.com/19XPn4rrFQ_SN6p_If2Yx0wrt6sg>" %}


# Source Rulebook Draft 30-day Public Comment

Public comment open through July 20, 2025.

Your feedback helps us build a transparent, credible Source Ledger.

{% embed url="<https://form.typeform.com/to/rhc2a9jC>" %}


# Public Comments

{% file src="/files/khqbr7x7yd9or2mzbRLz" %}


