Carbon check to inform the UNFCCC and its representative auditors about their HR practices. Carboncheck management headed by Adam Simcock is indulging in illegal HR and labour practices by violating the local laws and statutory requirements of the government of South Africa. This is a serious lapse and must be corrected immediately Carboncheck management. The corrective actions, clean up and preventive actions must be taken immediately with respect to this issue. Local government must take appropriate actions on Carboncheck in this respect. As a matter of information this information is copied to UNFCCC. Carboncheck is keeping some individuals illegally in its office who are foreigners and do not have any work permit as per South African government stipulations. One such person is Ravishankar from India who is paid his salary every month in the form of cash by Adam Simcock. This is a serious lapse from the Directors of the Carboncheck and must be probed by the local government and appropriate action to be taken. How come Carbon check board of Directors allowing this kind of statutory and legal lapse? It is nothing short of human rights and domestic laws violation and all Directors of Carbon check must be accounted for this serious lapse. Additionally Ravishankar is forcing and enticing the project owner’s singed with Carbon check to hire only the consultants referred by him only. By violating the code of conduct Ravishankar is particularly encouraging and marketing an Indian based CDM consulting company named ”Core CarbonX  Solutions Pvt. Ltd” from Hyderabad, India. No corrective actions are being taken by Carbon Check management in this regard, which is highly objectionable and unacceptable. This kind of illegal and unacceptable practices must be stopped. 
   

 

Has the PP considered the CDM revenues while envisaging the project? Without CDM the
project was not viable, is it right? This project is having a debt component? Then how bankers
or lenders gave the loan? Have the bankers or lenders considered the CDM revenues while
agreeing to give loan to this projects? If not this project should be rejected right away by DOE
by terminating the contract forthwith. If yes, where is the proof? What is the date of the
evidence document from bank? Is this document printed now a days or earlier. DOE to
independently check the same. If the document is available from Bank it must be checked
from all angles so that it is genuine and not forged and date changed by putting back dated.
This is normally done, DOE to be aware of this please. Please check the communication the PP
had during that time with banks, emails and postal receipts and the weights and dates
mentioned on the receipts. Do not believe in courier bills and receipts since these can be
cooked up easily. Insist on government owned postal service receipts only. If the project is
fully equity project then on what basis the PP has invested full equity in to the project while
considering the CDM revenue? DOE to check the same in detail and bring out the facts. Is
there any past record of this PP to invest or not to invest at returns what he is talking about in
this project? Proper evidences must be reviewed and digged out by the DOE and take decision
on the project based on established facts. Do not ask documents from PP, DOE to collect the
same from different sources to do independent evaluation.
 Is the project equipment purchased second hand equipment or sourced from cheap foreign
sources? If yes, the issue must be probed by DOE since invoices will invariably be inflated and
forged. Total project costs mentioned by PP will not be the same as originals. Hence no
additionality. These facts must be probed in full by DOE by checking all documents and money
transactions along with bank statements and certified accounts by a legally acceptable
financial analyst.
 From DOE side which auditor has done marketing and business development for acquiring this
business of validating this project? With whom he or she was co-ordinating at PP or CER
buyer? The same person who has done the marketing and business development to acquire
the business do validation or participate in any manner what so ever in the validation process?
One cannot do like that. It is against the accreditation rules and norms followed since ages.
DOE should send auditors from different offices or countries to do this validation audit. DOE
must take care of impartiality and accreditation rules. Due to the targets set by the DOE
managements auditors are doing marketing and meeting clients and giving promises that the
project will be taken care. Is it acceptable and fair? This must be stopped. No auditor should
do marketing. Only non-auditing staff should do marketing. DOE to ensure the same please.
 If applicable only: Is these machines, equipment was a part of any bundle of CDM activity
envisaged and developed earlier. DOE to check the same through independent sources also.
Once some bundles are non-additional and getting negative validation from a DOE, PP is
rolling out the same project as an individual project which is not a CDM project at all. DOE to
verify the same from independent sources and also take undertaking in the form of an
affidavit from the PP’s that any misrepresentation or false statement with respect this would
attract strict legal action from UNFCCC and DOE. Furthermore the registered project must be
de-registered in case of any future findings contradicting the submissions made by the project
owner.
 DOE to ensure that the PDD values are consistent and ensure that the CDM project is a
genuine project
 DoE to check the Detailed Project Report and Feasibility Report which is submitted to the
other agencies and Banks by Project owner and ensure that the values match with the DPR/FR
submitted to DoE also.
 Careful study must be done so that the DPR/FR is not in different versions made and
submitted with different purposes to different agencies, which is totally unacceptable, illegal
and unethical.
 DPR/FR values must be probed fully. DOE must take a written undertaking from the
PP/Consultant about the list of parties to whom this DPR/FR is submitted and for what
purposes. Then DOE should cross check with all the parties and confirm that the same DPR/FR
is submitted to all the parties correctly without any changes. DOE must not accept any reports
and undertakings from PP/Consultant. DOE must make independent evaluation and use totally
different parties without informing the PP or Consultant to cross check the facts.
 DOE to write to the party who prepared the DPR/FR which is submitted to the banks and
other agencies and the same is verified against the one submitted to the DOE by
PP/Consultant.
 DOE must not entertain this project any more if found the DPR/FR is tamprered with at any
point in time. PP can not give different DPR’s and FR’s. They must submit only the one given to
Banks and other agencies while obtaining loans and decision making time.
 How is the base line defined in this project? Is Base line hypothetically defined with no proper
evidences and proper justification? In such case, DOE cannot take the base line as suggested
by the PDD. Please check that there are real emission reductions beyond the real and factual
base line. It may so happen that this project qualifies for no CER’s. DOE cannot assume values
and things as giving by this PP. Whatever values are considered throughout the project in all
documents including the real DPR (not the one prepared for CDM, the one given to the banks
and others), they must be validated, verified and double checked. Do not ask PP for DPR. Ask
the parties who have been given DPR by the PP. Get directly from the bank and others by each
page of the DPR and Feasibility report signed. Such document can be considered as a real DPR
or FR. UNFCCC CDM process cannot be degraded by fabricating and misinterpreting the
project base line and additionality.
 DOE to be more careful so that this is a genuine CDM project. What is the exact project cost?
The project cost is covering what? Each value considered must be validated with proof. The
machinery is second hand purchased or fresh and new from an OEM? In either case DOE to
check all the quotations, proposals, purchase orders, invoices, way bills, transport bills, proof
of payments like bank statements. DOE to check with banks by way of written confirmation
the amount transacted, to whom the money is paid, when the money is paid, is the party paid
is the correct party as shown in the purchase orders. It may so happen that the values, party
names, dates are fabricated and misrepresented in this project. DOE should terminate their
contract for this project immediately. This is the only way out to protect the value of CDM
process. If the PP is purchasing second hand or second quality equipment and inflating the
purchase order values and invoices, this must be probed thoroughly and real values to taken
for additionality calculation. Then I’m sure the additionality is not there at all in such a
situation.
 Project owner should show some undertaking letter from bank manager to DoE stating that
both DPR’s are same. These kinds of letters should not be accepted and entertained by DoE at
face value, but must be checked independently. While collecting the DPR/FR from banks and
other agencies, all DPR/FR pages should be counter signed by Banks and other agencies so
that the real DPR/FR given to other parties by the PP/Consultant is same as the one submitted
to DOE.