MCC-ESS — Environmental & Social Safeguards Policy

Document control

Field	Value
Document code	MCC-ESS (short code listed in MCC-001 v3.0-draft clause 12.1, Tier 3 row)
Title	Environmental & Social Safeguards Policy
Version	2.0-draft
Status	DRAFT — FOR CONSULTATION
Date of this draft	3 September 2026
Tier	Tier 3 (Document Hierarchy & Precedence Register, per FD-2026-09-03 item D5; MCC-001 clause 12.1)
Effective date	None. This document is not in force. It takes effect only on approval under clause 26.1.
Document owner	Programme Administrator (transitional, until a Secretariat is staffed — FD-2026-10-01 Schedule 1, C3)
Approved by	Not approved. Prepared for public consultation.
Decision basis	Founder Decisions FD-2026-09-03, items D1–D8 (adopted 3 September 2026 in the programme working channel; tabled for ratification by the Governing Board). FD-2026-09-03 is recorded in the decision register as attested by the founder on 7 September 2026; no executed copy has been filed (the register at /governance/decisions shows its status).
Supersedes	The circulated file "MCC Environmental and Social Safeguards Policy v1.0" (Document Reference MCC-ESS-v1.0, "Date: March 2026", printed status APPROVED), reclassified by FD-2026-09-03 item D5; the document register records v1.0 as in force until this version is adopted, when its withdrawal as a controlled copy is executed (FD-2026-09-07 item A8: scheduled, not executed). See the baseline declaration below.
Language convention	British English; RFC-style normative verbs (SHALL/MUST = mandatory; SHOULD = recommended, deviation to be documented; MAY = optional). Canonical registry enumeration values and status labels are quoted verbatim from the adopted control tables and the platform data model and retain their spelling (for example "CATEGORY_A", "AUTHORIZED").
Classification	Public — consultation draft
Consultation period	30 days (FD-2026-10-01 Schedule 1, C4), from the opening recorded on the consultation register (FD-2026-09-04 item 2; FD-2026-10-01 item 5)

Baseline declaration and version-identity resolution

The predecessor file carried no document-control apparatus whatsoever: no version table, no owner, no approval body, no decision record and no effective date, while displaying the status "APPROVED" (Phase 0 source inventory, 3 September 2026, which identifies MCC-ESS as one of seven such files; audit finding SYS-06/SYS-14). No signed approval instrument for v1.0 exists in the programme record. This version 2.0-draft is therefore declared the new baseline of the Environmental & Social Safeguards Policy: it supplies the complete document-control block the predecessor lacked, and, when it is adopted, executes the withdrawal of the predecessor as a controlled copy and its archiving as a superseded record (clause 26.2; FD-2026-09-03 item D5). The predecessor's printed "APPROVED" status is not carried forward; no approval is asserted for this draft.

Title and code note. The document is a "Policy"; the predecessor was cited elsewhere in the corpus as both "Environmental and Social Safeguards Policy" and "Environmental and Social Safeguards Standard" (Phase 0). The controlled title is Environmental & Social Safeguards Policy, short code MCC-ESS, exactly as listed in MCC-001 v3.0-draft clause 12.1; no other title or code SHALL be used.

Change history

Version	Date	Change	Instrument
1.0	March 2026 (printed)	Base text; printed status APPROVED; no document-control table, owner, approval body, decision record or effective date existed	No such instrument is in the programme record (Evidence Register ER-2026-001 §B3).
2.0-draft	3 September 2026	Full rewrite against the independent audit of 3 September 2026 (findings ESS-01 to ESS-10, SYS-01 to SYS-15) and Founder Decisions FD-2026-09-03 D1–D8: one canonical safeguards taxonomy (twelve requirement areas) replacing the conflicting eight/nine-principle counts; normative exclusion list added (Annex A); do-no-harm decoupled from net-positive framing, with non-offsettable impacts defined; marine tenure, customary fishing rights, access restrictions, resettlement, security personnel, community health and safety, GBV/SEA/SH, cultural heritage and chance-find, critical habitat, supply-chain labour and benefit-sharing requirements added; FPIC re-scoped to identified rights-holders with a documented consent status; Category C self-declaration replaced by independently validated categorisation; grievance acknowledgement accelerated and urgent-harm triage made immediate; fixed 180-day cure replaced by severity-proportionate response with immediate stop-work; screening aligned to the single lifecycle state machine (SAFEGUARDS_SCREENING, MCC-700 Annex B) and the v1.0 "SAFEGUARDS_REVIEW" state abolished; remedy framework added with obligations surviving the crediting period; disclosure made subject to redaction protections; document-control block created	FD-2026-09-03 items D1–D8

NOTE (non-normative). This document is issued for public consultation. Nothing in it asserts that any approval, accreditation, eligibility, registration, issuance or operational history exists unless a linked record is identified in the MCC Evidence Register. Points the Programme has not decided, or on which it proposes a rule for comment, are listed under Consultation questions below and marked in the text.

Consultation questions

Each point below is open for comment. A proposal is the administration's proposal, put to consultation under founder direction FD-2026-10-01; it is not a rule in force. The suite is to be adopted as one instrument once its longest consultation period has closed (FD-2026-10-01 Schedule 1, C4). Because it includes the Constitution, whose amendment is within the competence of the constituted Governing Board (FD-2026-08-24 item D11, recorded in the decision register as attested by the founder, with no executed copy filed), each point below is decided by the Governing Board on adoption of the suite; a clause of this text that provides another route for adopting it alone is itself open to comment.

1. Section 12, NOTE after clause 12.7 — A standalone Marine Rights and Livelihoods Standard. Proposed: the marine rights and livelihoods requirements of Sections 11, 12 and 18 stay in this Policy, which is their single authoritative location until it is decided whether to split them into a standalone Tier 3 Marine Rights and Livelihoods Standard. Basis: audit finding ESS-03; open decision put to public consultation (FDP-2026-001 Part 3). Decided by: the Governing Board on adoption of the suite. Comments are invited on whether a standalone standard is needed.

2. Clauses 20.4 to 20.6 — Grievance service levels. Proposed: acknowledgement within five business days of receipt; triage on receipt, with same-business-day escalation to Programme level of any grievance disclosing a risk of severe or ongoing harm; a reasoned written outcome within sixty calendar days of acknowledgement, with interim updates at least every thirty calendar days where resolution takes longer. Basis: these replace the 30-day acknowledgement and 90-day resolution of MCC-ESS v1.0 (audit finding ESS-07) and match the five-business-day acknowledgement convention of MCC-700 clauses 12.3 and 13.4; service-level values are proposed for consultation and confirmed or varied on approval (MCC-700 Annex B rule B-3; FDP-2026-001 Part 3). Decided by: the Governing Board on adoption of the suite. Comments are invited on whether these service levels are achievable for project-level grievance mechanisms.

3. Annex B, B-3.2 — Record granularity of safeguards clearances. Proposed: no choice is proposed between one clearance record per gate (registration clearance and each issuance clearance as separate records) and a single mutable clearance field with history; either form must record the determinations of clause 23.7 at each gate and keep an auditable history of every determination. Basis: open decision put to public consultation (FDP-2026-001 Part 3). Decided by: the Governing Board on adoption of the suite; the record granularity is then an implementation choice for the Registry Oversight Committee with the register owner (Annex B, B-3.2). No such Committee is yet constituted: under the transitional appointments schedule proposed in FD-2026-10-01 Schedule 1 (C5) its functions would be exercised by the Governing Board until it is, whereas MCC-700 v4.0-draft clause 23.2 places the functions of a body not yet constituted with the founder. Comments are invited on which form better serves auditability.

Table of contents

1. Purpose, scope and application
2. Normative references, definitions and interpretation
3. Roles and responsibilities
4. Safeguards taxonomy
5. Exclusion list
6. Risk categorisation and screening
7. Assessment and management instruments
8. SR1 — Impact assessment, mitigation hierarchy and do no harm
9. SR2 — Labour and working conditions
10. SR3 — Community health, safety and security personnel
11. SR4 — Land and marine access restrictions, displacement and resettlement
12. SR5 — Marine tenure, customary fishing rights and livelihoods
13. SR6 — Indigenous Peoples and Free, Prior and Informed Consent
14. SR7 — Biodiversity and critical habitat
15. SR8 — Cultural heritage and chance finds
16. SR9 — Gender equality and GBV/SEA/SH prevention and response
17. SR10 — Stakeholder engagement and disclosure
18. SR11 — Benefit sharing
19. SR12 — Climate and disaster resilience
20. Grievance mechanism
21. Urgent harm, stop-work and suspension
22. Remedy framework
23. Monitoring, assurance and non-conformity
24. Safeguards data protection and safe disclosure
25. Review and amendment
26. Entry into force

Annex A — Programme exclusion list (normative) Annex B — Safeguards data model and screening schema (normative field semantics)

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1. Purpose, scope and application

1.1 This Policy (MCC-ESS) SHALL establish the mandatory environmental and social safeguards requirements of the MCC Programme, including the safeguards taxonomy, the exclusion list, risk categorisation, assessment and management instruments, requirement areas, grievance mechanics, urgent-harm response, remedy and safeguards assurance.

1.2 This Policy SHALL apply to every project seeking or holding listing, registration or issuance under the MCC Programme, throughout the project lifecycle from design to the end of all monitoring and remedy obligations, for both MCC-CC and MCC-MOU activities and for any activity carrying an MCC-CB label.

1.3 This Policy is the authoritative Tier 3 safeguards framework of the Programme (MCC-001 clause 12.1); the programme-level conditions binding every project are stated in MCC-100 Section 14, and in case of conflict between any restatement elsewhere and this Policy, the safeguards taxonomy and requirements of this Policy prevail, subject to the tier precedence rule of MCC-001 clause 2.2.

1.4 Safeguards conformity SHALL be a condition of registration and of every issuance (MCC-001 clause 10.2; MCC-100 clause 14.2); conformity SHALL NOT be waived, in whole or in part, for any project, including pilot projects (MCC-700 Annex B rule B-6).

1.5 A methodology MAY add activity-specific safeguards requirements through its safeguards module (MCC-200 Section 15, MOD-09) but SHALL NOT relieve, weaken or substitute for any requirement of this Policy.

1.6 A requirement of this Policy that depends on an instrument not yet published under document control (identified in the NOTE to clause 2.1) SHALL NOT take effect until that instrument is published; the dependency SHALL be recorded in the Document Register (MCC-001 clause 12.6) and the requirement SHALL NOT be treated as silently effective.

1.7 Where this Policy prescribes an outcome without prescribing a method, the proponent SHALL select and document a method consistent with good international industry practice for environmental and social risk management.

NOTE (non-normative). The benchmark frameworks the independent audit directs this Policy to map to are the World Bank Environmental and Social Framework and the IFC Performance Standards, including Performance Standard 7 on Indigenous Peoples (audit sources [E17]–[E19]). These are design benchmarks; no conformity, equivalence or approval claim with respect to them is made or permitted.

2. Normative references, definitions and interpretation

2.1 The following Programme documents are normatively referenced: MCC-001 Constitution; MCC-100 Programme Standard; MCC-700 Governance and Appeals (including Annex A and Annex B); MCC-200 Methodology Framework; MCC-400 VVB Standard; MCC-850 AI Governance; MCC-600 Claims Code; and the MCC Record Retention Schedule.

NOTE. The following referenced instruments are not yet published under document control: the Record Retention Schedule; MCC-600 (Claims Code); the reissued MCC-400 and MCC-850; the safeguards screening form and assessment templates (Tier 5); and the platform implementation of the safeguards data model in Annex B. Each dependent requirement is deferred under clause 1.6, never silently effective.

2.2 Terms defined in the Definitions Register, which is in force as MCC-100 Annex v1.0 (FD-2026-08-24 item D12, recorded in the decision register as attested by the founder, with no executed copy filed), SHALL bear their registered meanings; where the Definitions Register does not define a term, the definitions in clauses 2.3 to 2.16 apply and SHALL be tendered to the Definitions Register for registration.

2.3 "Affected community" means a community, or an identifiable group within a community, whose rights, resources, access, livelihoods, health, safety, culture or environment may be materially affected by a project.

2.4 "Project-affected person" means a natural person within an affected community, including workers engaged by or on behalf of the project.

2.5 "Rights-holder" means a person, community or people holding legal or legitimate customary rights over land, waters, foreshore, seabed, resources or cultural heritage within or affected by the project boundary, whether or not those rights are formally registered.

2.6 "Indigenous Peoples" means peoples identified in accordance with the characteristics used in international practice — including self-identification; collective attachment to lands, territories, waters or natural resources; customary cultural, economic, social or political institutions distinct from mainstream society; and a distinct language or dialect — applied on the facts of each project area; the term is applied without prejudice to national terminology.

2.7 "Marine tenure" means the system of rights, rules and institutions — statutory or customary — governing who may access, use, manage or exclude others from marine and coastal areas and resources, including foreshore, seabed, water column, fishing grounds and gleaning areas.

2.8 "Customary fishing rights" means fishing, gleaning, harvesting or navigation rights held by a community or its members under custom, tradition or long usage, whether or not recognised in statute.

2.9 "Critical habitat" means an area of high biodiversity value, including habitat of significant importance to threatened or endemic species, habitats supporting globally or nationally significant concentrations of migratory or congregatory species, highly threatened or unique ecosystems, and areas associated with key evolutionary processes.

2.10 "Chance find" means tangible cultural heritage encountered unexpectedly during project implementation.

2.11 "GBV/SEA/SH" means gender-based violence, sexual exploitation and abuse, and sexual harassment.

2.12 "Non-offsettable impact" means an adverse impact listed in clause 8.7 that SHALL NOT be treated as compensable by offsetting or by unrelated benefits.

2.13 "Remedy" means the process and outcome of making good harm attributable to a project or to the Programme, including as applicable restitution, rehabilitation, restoration, compensation, satisfaction and guarantees of non-repetition.

2.14 "Stop-work order" means an order under MCC-700 clause 14.3 and Annex A row 12a requiring the immediate cessation of a specified activity.

2.15 "Safeguards clearance" means the recorded determination, under Section 23 and Annex B, that a project's safeguards requirements are met or that outstanding conditions are defined, time-bound and compatible with the gate concerned (MCC-100 clauses 13.9 and 14.13).

2.16 "Vulnerable persons" means persons who, by reason of circumstance — including Indigenous identity, ethnicity, gender, age, disability, poverty, landlessness, statelessness, displacement or dependence on threatened resources — may be disproportionately affected by a project or disadvantaged in accessing its processes and benefits.

2.17 Headings and NOTE and GUIDANCE blocks are non-normative; numbered clauses are normative.

3. Roles and responsibilities

3.1 Programme-level safeguards governance SHALL be exercised by the bodies designated in MCC-700, including the Safeguards & Rights Panel for high-risk environmental and social review, remedy oversight and grievance oversight (MCC-700 clause 4.9), with the decision rights fixed in MCC-700 Annex A; this Policy SHALL NOT reassign or restate those decision rights.

3.2 The proponent SHALL be responsible for conducting the safeguards assessments, implementing the management measures, operating the project-level grievance mechanism and delivering the remedies required by this Policy, and SHALL resource each of these functions in the project budget.

3.3 Every safeguards assessment, categorisation validation, and safeguards monitoring engagement required by this Policy to be independent SHALL be performed by persons with relevant environmental and social competence who are independent of the proponent and free of conflicting interests, and their independence and competence SHALL be documented.

3.4 Validation and verification bodies SHALL assess safeguards conformity as a mandatory component of every validation and verification (MCC-100 clauses 18.3 and 18.4), under the competence and impartiality requirements of MCC-400.

3.5 An AI system SHALL NOT perform, and SHALL NOT be the deciding input to, any safeguards assessment, risk categorisation, clearance, grievance determination or enforcement decision (MCC-001 clause 5.4; MCC-100 clauses 22.1 and 22.5).

3.6 The proponent SHALL maintain and apply anti-bribery and anti-corruption controls proportionate to project scale, covering at minimum benefit-sharing payments, community agreements, procurement and dealings with public officials; breach of this clause is a material breach enforceable under MCC-100 Section 23.

3.7 The proponent SHALL notify the Programme Secretariat in writing within five business days of becoming aware of any serious safeguards incident, being any death, serious injury, credible GBV/SEA/SH allegation connected to the project, forced displacement, destruction of cultural heritage, or significant damage to critical habitat, without prejudice to the immediate triage duty of clause 21.2.

3.8 Obstruction of access by an assessor, monitor, VVB or auditor to project documentation, sites or persons necessary for safeguards assurance is a material breach enforceable under MCC-100 Section 23 (MCC-100 clause 18.10).

4. Safeguards taxonomy

4.1 The Programme SHALL operate one and only one safeguards taxonomy, consisting of the twelve safeguards requirement areas SR1 to SR12 defined in this Policy; no other count, list or naming of safeguards principles SHALL be used in any Programme document, rubric, screening tool or platform configuration.

Code	Requirement area	Governing section
SR1	Impact assessment, mitigation hierarchy and do no harm	Section 8
SR2	Labour and working conditions	Section 9
SR3	Community health, safety and security personnel	Section 10
SR4	Land and marine access restrictions, displacement and resettlement	Section 11
SR5	Marine tenure, customary fishing rights and livelihoods	Section 12
SR6	Indigenous Peoples and Free, Prior and Informed Consent	Section 13
SR7	Biodiversity and critical habitat	Section 14
SR8	Cultural heritage and chance finds	Section 15
SR9	Gender equality and GBV/SEA/SH prevention and response	Section 16
SR10	Stakeholder engagement and disclosure	Section 17
SR11	Benefit sharing	Section 18
SR12	Climate and disaster resilience	Section 19

4.2 The taxonomy of clause 4.1 supersedes the eight-principle list of MCC-ESS v1.0 and the nine-principle safeguards rubric of MCC-850 (audit finding ESS-01); every screening checklist, assessment template, AI-assistive rubric and platform schema that references safeguards principles SHALL be regenerated from clause 4.1 and Annex B before use.

NOTE. MCC-850's safeguards rubric is conformed to this taxonomy by MCC-850 v2.0-draft, whose Annex C generates its safeguards questions from Annex B of this Policy and limits AI output to presence, coverage and consistency; no AI-assistive safeguards rubric output may be relied on for any decision (clause 3.5).

4.3 Each requirement area SHALL be screened for every project using the screening schema of Annex B, and each area determined applicable SHALL be addressed in the project's assessment and management instruments under Section 7.

4.4 A determination that a requirement area is not applicable to a project SHALL be recorded with written reasons and SHALL be subject to the same independent validation as the risk categorisation (clause 6.8).

5. Exclusion list

5.1 The Programme exclusion list in Annex A is normative; an activity falling within any Annex A entry SHALL be refused and SHALL NOT be listed, registered or credited.

5.2 Every project SHALL be screened against Annex A before risk categorisation (MCC-100 clause 14.3), and the screening outcome SHALL be recorded with reasons for each entry.

5.3 Where an excluded activity is identified after registration or issuance, the matter SHALL be processed under MCC-100 Section 23, and no further issuance SHALL occur while the matter is unresolved.

5.4 Exclusion screening SHALL be repeated whenever the project design, boundary or activities materially change, and at each verification.

5.5 No waiver of, or exception to, Annex A SHALL be granted by any Programme body.

6. Risk categorisation and screening

6.1 Safeguards screening SHALL take place at the SAFEGUARDS_SCREENING lifecycle state of the single lifecycle state machine defined in MCC-700 Annex B (transitions T3 and T4), and at no other point in the workflow; the "SAFEGUARDS_REVIEW" state created by MCC-ESS v1.0 clause 0168 is abolished and SHALL NOT be implemented.

6.2 Every project SHALL be assigned exactly one environmental and social risk category — CATEGORY_A (high risk), CATEGORY_B (medium risk) or CATEGORY_C (low risk), recorded using the Annex B values — with written reasons addressing the nature, location, scale, sensitivity, reversibility and complexity of its potential adverse impacts.

6.3 CATEGORY_A SHALL be assigned where potential adverse environmental or social impacts are significant, sensitive, diverse, irreversible or unprecedented, including in every case where the project: may affect critical habitat; may affect Indigenous Peoples' rights, lands, waters, resources or cultural heritage; involves physical or economic displacement; involves material restriction of access to marine or coastal resources on which livelihoods depend; may affect known cultural heritage of significance; or will engage armed or public security personnel.

6.4 CATEGORY_B SHALL be assigned where potential adverse impacts are moderate, site-specific, largely reversible and readily addressed through known mitigation measures.

6.5 CATEGORY_C SHALL be assigned only where potential adverse impacts are minimal or negligible.

6.6 Where the criteria of clauses 6.3 to 6.5 could support more than one category, the higher-risk category SHALL be assigned.

6.7 The category assignment, with its reasons, SHALL be made at the SAFEGUARDS_SCREENING gate by the gate owner designated in MCC-700 Annex B T3, with Safeguards & Rights Panel review for CATEGORY_A as that row requires.

6.8 Every risk categorisation, including CATEGORY_C, SHALL be independently validated before the project passes SAFEGUARDS_SCREENING; a proponent self-declaration SHALL NOT of itself establish any category (MCC-100 clause 14.6).

6.9 A risk category MAY be raised at any time on new information, with written reasons and notice to the proponent; it SHALL NOT be lowered except on independent re-validation showing that the circumstances that grounded the higher category have permanently ceased.

6.10 A change of risk category SHALL trigger a proportionate reassessment of the project's assessment and management instruments under Section 7 within a deadline fixed in the change decision.

6.11 Category assignments and screening refusals SHALL carry the appeal rights fixed in MCC-700 Annex B T3 (de novo, per MCC-700 clause 12.5).

6.12 Screening timelines SHALL be those fixed in MCC-700 Annex B (T3); this Policy states no separate screening deadline.

7. Assessment and management instruments

7.1 Every CATEGORY_A project SHALL complete a full Environmental and Social Impact Assessment (ESIA) covering every applicable requirement area, conducted by qualified independent specialists per clause 3.3.

7.2 The ESIA SHALL include: environmental and social baseline conditions; impact identification and prediction for each applicable requirement area; significance assessment under clause 8.4; cumulative impacts with other existing or planned activities in the same seascape; project alternatives considered; and the mitigation measures carried into the ESMP.

7.3 Every CATEGORY_B project SHALL complete an environmental and social assessment proportionate to its identified risks, addressing each applicable requirement area and documenting why any dimension is assessed in less depth.

7.4 Every CATEGORY_C project SHALL complete the standardised safeguards conformity statement addressing each requirement area's screening questions in Annex B, and that statement SHALL be independently validated under clause 6.8; the unvalidated self-declaration instrument of MCC-ESS v1.0 clause 0068 is abolished.

7.5 Every CATEGORY_A and CATEGORY_B project SHALL adopt, before registration, an Environmental and Social Management Plan (ESMP) specifying, for each identified impact: the mitigation-hierarchy measure applied; the responsible person; the timeline; the budget; the monitoring indicator and target; and the corrective-action trigger.

7.6 A CATEGORY_C project SHALL adopt an ESMP limited to the measures its validated conformity statement identifies as necessary, or record with reasons that none is required.

7.7 The ESMP SHALL designate a named implementation officer or committee accountable for its delivery and adaptive management.

7.8 The ESMP SHALL be prepared in consultation with affected communities, SHALL record how their input was reflected, and SHALL be disclosed under Section 17 subject to the redaction rules of Section 24.

7.9 Assessment reports SHALL be made available to affected communities in accessible formats and in languages they understand, before the consultation on them closes.

7.10 The ESMP SHALL be reviewed at least annually against monitoring results and updated where measures prove ineffective; each update SHALL be versioned and disclosed under Section 17.

7.11 Assessment and ESMP documentation SHALL be retained per the MCC Record Retention Schedule and SHALL be available to VVBs, monitors, auditors and the Safeguards & Rights Panel on request.

8. SR1 — Impact assessment, mitigation hierarchy and do no harm

8.1 Every project SHALL identify, assess and manage its potential adverse environmental and social impacts through the instruments of Section 7, so that no significant adverse impact remains unaddressed.

8.2 The mitigation hierarchy SHALL be applied strictly and in order: avoidance first; then minimisation; then restoration; and offsetting of residual impacts only last.

8.3 Avoidance SHALL be examined and documented as the first option for every significant impact; minimisation, restoration or offset measures SHALL be adopted only with a written demonstration that the preceding step of the hierarchy is not feasible.

8.4 Impact significance SHALL be assessed using a documented method considering at minimum likelihood, magnitude, duration, irreversibility, and the sensitivity and vulnerability of the affected resources and populations.

8.5 A project SHALL NOT proceed, and SHALL NOT be registered or credited, while a significant adverse impact remains that has not been avoided, minimised or restored and is not covered by a compliant offset under clause 8.6.

8.6 An offset MAY be applied only to a residual impact that is not listed in clause 8.7, and SHALL deliver outcomes of the same type as the impact offset (like-for-like or better), be additional, be secured for at least the duration of the impact, and be monitored under Section 23.

8.7 The following are non-offsettable and SHALL be addressed only by avoidance, or by minimisation and restoration combined with remedy under Section 22: (a) harm to human life, health or bodily integrity; (b) violation of human rights, including forced displacement and violations of labour rights under Section 9; (c) loss of, or severe damage to, critical habitat values for which no ecologically equivalent offset is demonstrably feasible; (d) destruction of, or severe damage to, cultural heritage of unique or irreplaceable significance; and (e) loss of resources or areas indispensable to the cultural or physical survival of Indigenous Peoples.

8.8 Compliance with this Policy SHALL be assessed as the absence of unmanaged harm under clauses 8.1 to 8.7; a projected net-positive or co-benefit outcome SHALL NOT be accepted as compensating for, or as evidence of the management of, any adverse impact (audit finding ESS-02).

8.9 Every finding, decision and feasibility demonstration under this Section SHALL be documented with supporting evidence.

9. SR2 — Labour and working conditions

9.1 Every project SHALL respect the ILO core labour standards for all project workers: freedom of association and collective bargaining; elimination of forced labour; abolition of child labour; non-discrimination; and a safe and healthy working environment.

9.2 Child labour and forced labour, as screened under Annex A, SHALL be prohibited in the project and in its primary supply chain.

9.3 Project workers SHALL be engaged on documented terms, paid at least the applicable legal minimum (or, absent one, a documented fair local wage), and SHALL NOT be charged recruitment fees.

9.4 Every project SHALL implement occupational health and safety measures proportionate to its hazards, including for hazards specific to marine work such as diving, small-vessel operations, gear retrieval and severe-weather exposure.

9.5 Work-related fatalities and serious injuries SHALL be recorded, reported under clause 3.7 and investigated, with corrective actions documented.

9.6 The proponent SHALL assess labour risks in its primary supply chain — including vessel crews, gear handling, processing and transport services — and SHALL NOT use suppliers where forced or child labour is identified and not remediated.

9.7 Project workers SHALL have access to the grievance mechanism of Section 20, without retaliation, for labour concerns.

10. SR3 — Community health, safety and security personnel

10.1 Every project SHALL assess and manage its risks to community health and safety, including at minimum: navigational and water-safety hazards created by project structures or activities; disease vectors; pollution and hazardous-materials exposure; food-security effects of changed resource access; influx of project workers; and traffic and transport hazards.

10.2 Project infrastructure and works SHALL be designed, built and operated by competent persons in accordance with applicable law and good international industry practice for safety.

10.3 Emergency preparedness and response arrangements SHALL be established for project hazards with credible community consequences, and affected communities SHALL be informed of them in an accessible form.

10.4 A project SHALL engage security personnel (private or public) only after a documented security risk assessment covering risks to and from the security arrangement, including risks to communities.

10.5 Security personnel engaged by or for a project SHALL be screened for credible allegations of past abuse, trained in proportionate use of force and appropriate conduct toward communities, and contractually bound to those standards; force SHALL NOT be sanctioned except when used for preventive or defensive purposes in proportion to the threat.

10.6 Where public security forces are deployed in connection with a project, the proponent SHALL communicate its conduct standards to the deploying authority, document that communication, and assess and manage the residual risk.

10.7 Every allegation of unlawful or abusive conduct by security personnel connected to a project SHALL be recorded, reported under clause 3.7 where serious, investigated, and where warranted referred to competent authorities; the affected persons SHALL have access to the grievance mechanism and to remedy under Section 22.

10.8 Enforcement activities within a project area (including fisheries or protected-area enforcement supported by the project) SHALL NOT be designed or implemented so as to target the subsistence activities of communities whose rights are recognised under Sections 11 to 13, except under a lawful, consulted and documented management arrangement.

11. SR4 — Land and marine access restrictions, displacement and resettlement

11.1 Every project SHALL identify, before registration, all land, foreshore, seabed and marine-area rights and uses — statutory and customary — within and adjacent to the project boundary, and all restrictions of access or use the project would introduce.

11.2 Physical displacement of Indigenous Peoples from their lands, territories or waters SHALL NOT occur under any project (Annex A entry A.9).

11.3 Any other involuntary physical displacement SHALL be avoided; where, exceptionally, it is demonstrably unavoidable, the project SHALL be CATEGORY_A and SHALL NOT proceed without a resettlement plan providing consultation, fair and prompt compensation at full replacement cost, relocation assistance, and livelihood restoration to at least pre-project levels, implemented before the displacement occurs.

11.4 Economic displacement — loss of income, assets or access to resources without physical relocation, including through restrictions on fishing, gleaning, navigation or coastal access — SHALL be treated as an impact requiring the full mitigation hierarchy of Section 8 and, where it cannot be avoided, a documented livelihood-restoration plan.

11.5 Restrictions of access to marine or coastal resources SHALL be designed and implemented with the participation of the affected communities, and the restriction rules, their rationale and any phase-in SHALL be documented and communicated in accessible form before taking effect.

11.6 A project SHALL NOT proceed on land or marine areas subject to an unresolved tenure dispute material to the project boundary, unless the affected parties have agreed in writing to an interim arrangement that preserves their claims and the arrangement is recorded in the ESMP.

11.7 Compensation and livelihood-restoration measures under this Section SHALL be monitored under Section 23 until the affected persons' livelihoods are restored to at least pre-project levels, and the monitoring results SHALL be reported in the annual safeguards report.

12. SR5 — Marine tenure, customary fishing rights and livelihoods

12.1 Every project SHALL complete, before registration, a marine tenure and customary rights assessment identifying: the holders of statutory and customary rights over the project's marine and coastal areas and resources; customary fishing rights and their seasonal and gear patterns; small-scale fisheries and gleaning livelihoods dependent on the project area; and any competing claims.

12.2 The assessment under clause 12.1 SHALL be conducted using participatory methods with the communities concerned and SHALL be validated with the identified rights-holders before use.

12.3 The project design SHALL recognise and respect identified marine tenure and customary fishing rights; a project SHALL NOT extinguish, suspend or materially restrict such rights except through a lawful process to which the affected rights-holders have agreed under clause 12.4 or, where Section 13 applies, with FPIC.

12.4 Any restriction of customary fishing or resource rights SHALL be recorded in a written, lawful agreement with the affected rights-holders specifying the restriction, its duration, the mitigation and benefit-sharing measures under Sections 11 and 18, and the review mechanism.

12.5 Where the project affects small-scale fishers or gleaners, the assessment and ESMP SHALL address their livelihoods expressly, including access to alternative grounds, seasonality, gender-differentiated roles in the value chain, and post-harvest activities.

12.6 Benefit or carbon rights asserted by the proponent over the project's marine areas or outcomes SHALL be documented against the identified tenure and rights baseline, and any conflict between asserted project rights and identified community rights SHALL be resolved under clauses 12.3 to 12.4 before registration.

12.7 The marine tenure and customary rights assessment SHALL be updated whenever the project boundary or restrictions change, and reviewed at least once per crediting period.

NOTE. This Section, with Sections 11 and 18, implements the audit's required "Marine Rights and Livelihoods Standard" (finding ESS-03) inside this Policy. Whether these requirements are later split into a standalone Tier 3 Marine Rights and Livelihoods Standard is put to consultation; until decided, this Policy is the single authoritative location. (Consultation question 1.)

13. SR6 — Indigenous Peoples and Free, Prior and Informed Consent

13.1 Every project SHALL determine, through the screening of Annex B and the assessments of Sections 7 and 12, whether Indigenous Peoples are present in, or hold collective attachment to, the project area or may be affected by the project.

13.2 Where clause 13.1 is answered in the affirmative, the project SHALL identify the affected Indigenous Peoples and their representative institutions and decision-making processes, and SHALL record that identification in the ESIA.

13.3 Free, Prior and Informed Consent (FPIC) SHALL be obtained from the affected Indigenous Peoples, before registration, in each of the following circumstances: (a) the project may have adverse impacts on lands, territories, waters or resources subject to traditional ownership or under customary use or occupation; (b) the project may cause relocation of Indigenous Peoples from such lands, territories or waters (noting that physical displacement is in any event excluded by clause 11.2); or (c) the project may significantly impact cultural heritage that is material to the identity or cultural, ceremonial or spiritual aspects of the affected Indigenous Peoples' lives.

13.4 FPIC SHALL be sought through the affected peoples' own representative institutions and decision-making processes, free of coercion, intimidation, manipulation or inducement conditioned on consent, on the basis of complete, accurate and understandable information provided in appropriate languages and formats, and before the activities concerned commence.

13.5 FPIC SHALL be documented in a written agreement or, where the community prefers, an alternative record it approves (oral record, video, community certificate), specifying the matters consented to, the agreed mitigation and benefit-sharing arrangements, and the process for reviewing consent.

13.6 The FPIC status of each project SHALL be recorded using the Annex B values: NOT_REQUIRED (no clause 13.3 circumstance exists, with reasons recorded and independently validated), PENDING (a clause 13.3 circumstance exists and consent has not yet been obtained), OBTAINED (consent documented under clause 13.5), or DENIED (consent has been sought and refused, or withdrawn under clause 13.8).

13.7 A project with FPIC status PENDING SHALL NOT pass GOVERNANCE_REVIEW, and a project with FPIC status DENIED SHALL NOT proceed with the activities to which the denial relates; a denial SHALL be recorded without adverse inference against the community, and the project MAY proceed only if redesigned so that no clause 13.3 circumstance remains, with the redesign independently validated and the FPIC determination made afresh.

13.8 Consent MAY be withdrawn where the project materially departs from the agreement under clause 13.5; a withdrawal SHALL be processed as a grievance under Section 20, SHALL set the FPIC status to DENIED pending resolution, and SHALL be an urgent-harm trigger under Section 21 where continuing activity risks severe harm.

13.9 For affected communities that are not Indigenous Peoples, FPIC is not required, but meaningful consultation under Section 17 and a lawful, documented agreement under clauses 12.4 and 18.3 SHALL be required wherever the project restricts their rights, resources or access (MCC-100 clause 14.7).

13.10 Indigenous Peoples affected by a project SHALL benefit equitably from it under Section 18, and the benefit-sharing arrangement SHALL form part of the FPIC agreement where FPIC applies.

14. SR7 — Biodiversity and critical habitat

14.1 Every project SHALL assess its potential impacts on marine, coastal, freshwater and terrestrial ecosystems, habitats and species within its area of influence, as part of the Section 7 instruments.

14.2 Habitat within the project's area of influence SHALL be classified in the assessment as modified, natural or critical habitat, with the basis for classification documented.

14.3 A project SHALL NOT be implemented in critical habitat unless the assessment demonstrates, with independent expert input, that: no other viable alternative exists; the project will not lead to measurable adverse effects on the biodiversity values for which the critical habitat was designated, nor to a net reduction in the population of any critically endangered or endangered species; and a robust, long-term biodiversity monitoring and evaluation programme is integrated into the ESMP.

14.4 Conversion or degradation of critical habitat, as defined in Annex A entry A.7, SHALL be refused under Section 5.

14.5 In natural habitat, significant conversion or degradation SHALL be avoided; where avoidance is demonstrably infeasible, impacts SHALL be minimised and residual impacts offset under clauses 8.6 and 8.7(c) so that no net loss of the affected biodiversity values results.

14.6 Projects in or adjacent to legally protected areas or internationally recognised areas of biodiversity value SHALL comply with the area's legal designation and management objectives, and SHALL consult the area's managers.

14.7 A project SHALL NOT intentionally introduce invasive alien species, and SHALL assess and manage the risk of unintentional introduction through vessels, gear, substrate or restoration materials.

14.8 Biodiversity claims associated with a project SHALL be made only through the instruments and claim rules of the Programme (MCC-600 and the Claims Matrix); this Policy governs the safeguarding of biodiversity, not the crediting of it.

15. SR8 — Cultural heritage and chance finds

15.1 Every project SHALL identify, through the Section 7 assessment and consultation under Section 17, any tangible or intangible cultural heritage — including sacred sites, wrecks, underwater and coastal archaeological sites, culturally significant seascapes and species, and traditional knowledge — that the project may affect.

15.2 A cultural heritage assessment by qualified specialists SHALL be completed for every project in or near areas of known cultural, historical, archaeological or spiritual significance, and an archaeological survey SHALL be commissioned where the assessment identifies a material likelihood of impact on heritage sites, including submerged sites.

15.3 The project SHALL apply the mitigation hierarchy of Section 8 to cultural heritage impacts, and impacts within clause 8.7(d) SHALL NOT be offset.

15.4 Every project SHALL adopt, in its ESMP, a chance-find procedure requiring that on any chance find: work that could affect the find stops immediately in the affected area; the find is protected from damage, disturbance and unauthorised access; the competent authorities and, where relevant, the affected communities are notified; and work in the affected area does not resume until a qualified assessment has been made and any required measures are in place.

15.5 Access of communities to cultural sites within the project area SHALL be preserved, or an alternative access arrangement agreed with the affected communities, and sacred sites SHALL be protected from unauthorised access attributable to the project.

15.6 Traditional knowledge SHALL NOT be used, published or commercialised by the project without the documented agreement of its holders, and its disclosure SHALL be subject to Section 24.

16. SR9 — Gender equality and GBV/SEA/SH prevention and response

16.1 Every project SHALL assess potential gender-differentiated impacts — including on access to marine resources, workloads, incomes, participation and safety — and address identified disparities in project design and in benefit sharing under Section 18.

16.2 Consultation, participation and grievance processes SHALL be designed so that women and girls can participate safely and effectively, including through separate or facilitated formats where consultation under Section 17 identifies barriers.

16.3 Sex-disaggregated data SHALL be collected and reported for participation, benefits and safeguards monitoring indicators wherever personal-level data is collected, subject to Section 24.

16.4 Every project SHALL assess GBV/SEA/SH risks arising from or exacerbated by the project — including risks associated with worker influx, security personnel, enforcement activity, and control over benefit distributions — and SHALL include proportionate prevention measures in the ESMP.

16.5 All project workers, contractors and security personnel SHALL be bound by a code of conduct prohibiting sexual exploitation, abuse and harassment, SHALL be trained on it, and SHALL be subject to documented sanctions for breach.

16.6 The grievance mechanism under Section 20 SHALL provide a survivor-centred channel for GBV/SEA/SH reports that: permits confidential and anonymous reporting; limits information sharing to those who need it to respond; obtains the survivor's informed consent before any referral or investigative step involving them; and provides information on available medical, psychosocial and legal support services.

16.7 A credible GBV/SEA/SH allegation connected to a project SHALL be reported under clause 3.7 in anonymised, non-identifying form, SHALL be treated as an urgent-harm trigger under Section 21 where risk of further harm exists, and SHALL NOT be resolved by any settlement that suppresses the survivor's access to authorities or remedies.

17. SR10 — Stakeholder engagement and disclosure

17.1 Every project SHALL identify its stakeholders — affected communities, rights-holders, vulnerable persons, workers, local authorities and other interested parties — and maintain a stakeholder engagement plan proportionate to project risk.

17.2 Consultation SHALL be meaningful: conducted before decisions that affect stakeholders are taken; based on prior disclosure of relevant, understandable information in appropriate languages and formats; free of coercion; inclusive of vulnerable persons; and documented, with the influence of stakeholder input on project decisions recorded.

17.3 Consultation SHALL occur, at minimum, during project design, during the Section 7 assessments, before adoption of the ESMP and of any benefit-sharing or access-restriction agreement, at each ESMP update, and periodically during monitoring under Section 23.

17.4 The project-level public consultation required in the lifecycle SHALL be conducted at the STAKEHOLDER_CONSULTATION state per MCC-700 Annex B (T5) and MCC-100 clause 13.8; this Policy adds no separate consultation gate.

17.5 The following SHALL be publicly disclosed, subject to Section 24: the project's risk category and its reasons; the ESIA or assessment summary; the ESMP and its updates; the FPIC status (as an Annex B value, without disclosure of protected content); annual safeguards monitoring reports; and grievance-mechanism performance statistics under clause 20.12.

17.6 Disclosure SHALL be in accessible formats, and documents material to affected communities SHALL additionally be made available locally in languages and forms they understand.

17.7 Vulnerable persons SHALL be identified in the stakeholder engagement plan, and engagement methods SHALL be adapted so that they can participate and access benefits and remedies on an equitable basis.

18. SR11 — Benefit sharing

18.1 Every project that restricts community access or use, uses community or customary resources, or generates credited outcomes from areas over which communities hold rights, SHALL establish a documented benefit-sharing arrangement with the affected communities.

18.2 Benefit-sharing arrangements SHALL be negotiated directly with the affected communities through their legitimate representatives, on the basis of prior disclosure of the project's expected revenues or benefits, and free of the practices prohibited by clause 13.4.

18.3 Each benefit-sharing arrangement SHALL be recorded in a written, lawful agreement specifying: the benefits and their basis of calculation; the distribution mechanism and its governance, including measures for equitable access by women and vulnerable persons; timing; transparency and audit provisions; and the review and dispute process.

18.4 Benefit-sharing agreements SHALL be summarised in the ESMP and disclosed under clause 17.5, with commercial terms redactable under Section 24.

18.5 Delivery of benefit-sharing commitments SHALL be a monitored safeguards indicator under Section 23, and material non-delivery SHALL be treated as a non-conformity under clause 23.9.

18.6 Benefit-sharing payments and distributions SHALL be subject to the anti-corruption controls of clause 3.6.

19. SR12 — Climate and disaster resilience

19.1 Every project SHALL assess climate-related and disaster risks — including sea-level rise, storm intensity, flooding, erosion, marine heatwaves and ecosystem shifts — to its activities, its intended outcomes and the affected communities' exposure as altered by the project.

19.2 Material climate and disaster risks identified under clause 19.1 SHALL be addressed through design and adaptive-management measures recorded in the ESMP.

19.3 A project SHALL NOT materially increase the exposure or vulnerability of affected communities to climate-related hazards; any residual increase SHALL be treated as an impact under Section 8.

19.4 Climate-resilience indicators SHALL be included in safeguards monitoring where clause 19.1 identifies material risks.

NOTE. Permanence and reversal-risk management of credited carbon is governed by MCC-100 Section 11 and the Tier 3 permanence and buffer standard, not by this Section; this Section safeguards people and ecosystems, not credit durability.

20. Grievance mechanism

20.1 Every project SHALL establish, before any implementation activity and before registration, a grievance mechanism that is accessible, culturally appropriate, free of charge, and publicised locally in the languages of affected communities.

20.2 The grievance mechanism SHALL accept grievances through multiple channels (at minimum: in person, by telephone, in writing, and through community representatives), SHALL accept anonymous grievances, and SHALL process them with the same rigour as attributed grievances.

20.3 The grievance mechanism SHALL operate independently of day-to-day project management, and no person who is the subject of a grievance SHALL take part in handling it.

20.4 Every grievance SHALL be acknowledged in writing (or in the form in which it was received, for oral submissions) within five business days of receipt, describing the grievance, the process and the expected timeline.

20.5 Every grievance SHALL, on receipt, be triaged for risk of severe or ongoing harm; a grievance disclosing such risk SHALL be escalated the same business day to the Programme level, where it SHALL be handled under MCC-700 clause 14.3 and Section 21.

20.6 The project SHALL make good-faith resolution efforts and communicate a reasoned written outcome within sixty calendar days of acknowledgement, with interim updates at least every thirty calendar days where resolution takes longer.

20.7 Grievance outcomes SHALL state the findings, the remedial measures under Section 22, and the escalation and appeal routes available.

20.8 A grievance unresolved at project level, or concerning the project mechanism itself, MAY be escalated by the complainant to the Programme-level grievance channel, which MCC SHALL maintain as a public, free channel; escalated grievances SHALL be handled under MCC-700 Section 14 (investigation by the compliance monitoring function under Safeguards & Rights Panel oversight).

20.9 A grievance outcome that is a Programme decision SHALL carry the independent review and appeal rights of MCC-700 Sections 11 and 12 (MCC-700 clause 14.4).

20.10 Retaliation against any person for raising, supporting or participating in a grievance SHALL be prohibited; credible retaliation SHALL itself be treated as a grievance with urgent-harm triage under clause 20.5, and is a material breach enforceable under MCC-100 Section 23.

20.11 A grievance register SHALL be maintained for every project recording each grievance's receipt date, channel, description, triage outcome, investigation, resolution, remedy and closure date, and SHALL be auditable by monitors, VVBs, auditors and the Safeguards & Rights Panel.

20.12 Grievance-mechanism performance — numbers received, categories, timeliness against clauses 20.4 and 20.6, and outcomes — SHALL be reported annually in anonymised form and disclosed under clause 17.5.

20.13 The grievance mechanism SHALL NOT restrict access to judicial or administrative remedies, and use of the mechanism SHALL NOT be a precondition to such access.

NOTE. The service levels in clauses 20.4 and 20.6 replace the 30-day acknowledgement and 90-day resolution design of MCC-ESS v1.0 (audit finding ESS-07) and match the five-business-day acknowledgement convention of MCC-700 clauses 12.3 and 13.4. The SLA values in clauses 20.4 to 20.6 are proposed for consultation and are confirmed or varied on approval, consistent with MCC-700 Annex B rule B-3. (Consultation question 2.)

21. Urgent harm, stop-work and suspension

21.1 An urgent-harm situation exists where a project activity presents a risk of severe or ongoing harm to persons, communities, cultural heritage or critical habitat.

21.2 Any person MAY report an urgent-harm situation through any grievance channel or directly to the Programme-level channel; every such report SHALL be triaged immediately on receipt (MCC-700 clause 14.3).

21.3 In an urgent-harm situation, an immediate stop-work order or project suspension MAY be issued under MCC-700 clause 14.3 and Annex A row 12a, without awaiting any cure period, notice period or completion of investigation (MCC-100 clause 14.11).

21.4 Confirmation or lifting of an urgent-harm stop-work or suspension SHALL follow MCC-700 clause 14.6 and Annex A row 12b; this Policy does not restate the accountable bodies, controls or appeal routes those rows fix.

21.5 While a stop-work order or safeguards suspension is in effect: the activities it covers SHALL cease; no issuance for the project SHALL proceed (MCC-700 Annex B T9); and the proponent SHALL take the interim protective measures the order specifies.

21.6 A stop-work order or suspension SHALL be recorded in the registry and reflected in the project's public record (MCC-100 clause 20.3).

21.7 An appeal against an urgent-harm suspension SHALL NOT of itself lift the suspension pending decision (MCC-700 Annex B T9).

21.8 Lifting of an urgent-harm measure SHALL require documented verification that the risk has been removed or controlled and that any interim remedy ordered under Section 22 is in progress.

22. Remedy framework

22.1 Where a project causes, contributes to, or is directly linked to environmental or social harm in breach of this Policy, the proponent SHALL provide or enable remedy to the harmed persons or communities.

22.2 Remedy SHALL be proportionate to the harm and MAY comprise restitution, rehabilitation, restoration, compensation, satisfaction (including acknowledgement and apology) and guarantees of non-repetition; the form of remedy SHALL be determined in consultation with the harmed persons.

22.3 Harm within clause 8.7 SHALL NOT be remedied by unrelated benefits or by set-off against project co-benefits; monetary compensation alone SHALL NOT be treated as sufficient remedy where restoration or rehabilitation is feasible.

22.4 Remedial measures, their deadlines and their verification method SHALL be recorded in a written remedy determination, disclosed to the harmed persons, and tracked to completion in the grievance register and monitoring reports.

22.5 Remedy obligations SHALL survive the end of the crediting period, the completion, withdrawal or revocation of the project, and the exit of the proponent from the Programme (MCC-700 clause 14.5; MCC-100 clause 14.12).

22.6 CATEGORY_A and CATEGORY_B projects SHALL demonstrate, before registration, the financial and operational capacity to deliver foreseeable remedies, and SHALL maintain that capacity for the life of their obligations; the demonstration SHALL be reviewed at each verification.

22.7 Programme-level remedy oversight SHALL be exercised by the Safeguards & Rights Panel (MCC-700 clause 4.9.1); a remedy determination that is a Programme decision carries the review and appeal rights of MCC-700 Sections 11 and 12.

22.8 Buffer-pool resources SHALL NOT be used to fund safeguards remedy (MCC-700 clause 16.3); remedy SHALL be funded by the responsible participant, the capacity maintained under clause 22.6, or enforcement outcomes under MCC-100 Section 23.

23. Monitoring, assurance and non-conformity

23.1 Safeguards monitoring SHALL be conducted at least annually for every CATEGORY_A and CATEGORY_B project throughout the crediting period and for as long as ESMP or remedy obligations remain open.

23.2 Every CATEGORY_C project SHALL be subject, at minimum, to annual surveillance comprising: confirmation that its validated conformity statement remains accurate; review of its grievance register; and re-screening under clause 5.4 and Annex B — with a documented spot-check programme covering a sample of CATEGORY_C projects each year.

23.3 Safeguards monitoring of CATEGORY_A and CATEGORY_B projects SHALL be performed by monitors independent of the proponent (clause 3.3); CATEGORY_C surveillance MAY use proponent self-reporting verified by the spot-check programme of clause 23.2.

23.4 Monitoring SHALL cover both implementation of ESMP measures (process indicators) and safeguards outcomes (outcome indicators), including the indicators required by clauses 11.7, 16.3, 18.5 and 19.4 and vulnerable-group outcomes under clause 17.7.

23.5 An annual safeguards report SHALL be submitted for every project with the project's monitoring reporting (MCC-100 clause 12.7), addressing each applicable requirement area, grievances and their outcomes, remedial actions, and community feedback where consultation occurred.

23.6 Safeguards monitoring reports SHALL accompany every verification, and the VVB SHALL assess safeguards implementation at every verification (MCC-100 clauses 14.10 and 18.4).

23.7 A safeguards clearance SHALL be recorded before registration (MCC-100 clause 13.9) and confirmed before every issuance (MCC-100 clauses 14.13 and 19.2(b)), using the Annex B clearance values; a clearance with status CONDITIONAL SHALL specify each condition, its deadline and its verification method, and SHALL NOT support issuance unless every condition due by the issuance date is verified as met.

23.8 An independent safeguards audit SHALL be conducted at least every three years for every active CATEGORY_A and CATEGORY_B project, by auditors independent of both the proponent and MCC staff, covering safeguards compliance, mitigation effectiveness and grievance-mechanism functionality; audit reports SHALL be shared with affected communities and the proponent for input before finalisation.

23.9 A safeguards non-conformity SHALL trigger a corrective action plan with deadlines proportionate to the severity and reversibility of the actual or potential harm; no fixed cure period SHALL apply, and severe or ongoing harm SHALL be handled under Section 21 immediately rather than through any cure period.

23.10 While a material safeguards non-conformity is unresolved, safeguards clearance SHALL NOT be granted or SHALL be limited to CONDITIONAL, and issuance SHALL be withheld accordingly (clause 23.7).

23.11 Failure to complete corrective actions by their deadlines SHALL be escalated under MCC-100 Section 23, and suspension, revocation and unit cancellation SHALL follow the decision types, due process and defect rules of MCC-100 clauses 23.2 to 23.6 and MCC-700 Annex A; this Policy creates no separate sanctions ladder.

23.12 Safeguards records — screenings, categorisations, assessments, ESMPs, FPIC documentation, grievance registers, monitoring and audit reports, and remedy determinations — SHALL be retained per the MCC Record Retention Schedule and SHALL survive project completion or withdrawal.

23.13 Programme-wide safeguards performance — projects by risk category, clearance statuses, grievance statistics, urgent-harm measures and audit findings — SHALL be reported in the Programme's periodic transparency reporting (MCC-100 clause 20.8; MCC-700 clause 21.5).

24. Safeguards data protection and safe disclosure

24.1 Disclosure under this Policy SHALL be subject to redaction of: personal data; information that would endanger any person, including grievants, survivors and human-rights defenders; sensitive traditional knowledge (clause 15.6); the locations of vulnerable communities, sacred sites or threatened species where publication would create risk; and commercially confidential or legally privileged material — applying the redaction rules of MCC-100 clause 20.7.

24.2 Where a document is redacted, a meaningful public summary SHALL be published so that the substance of the safeguards information remains accessible.

24.3 Grievance and FPIC records SHALL be stored with access limited to those who need them for handling, oversight, assurance or appeal, and anonymous grievants' identities SHALL NOT be sought.

24.4 GBV/SEA/SH records SHALL be maintained under survivor-centred confidentiality (clause 16.6), and no report or disclosure under this Policy SHALL identify a survivor without their informed consent.

24.5 Personal data processed under this Policy SHALL be processed lawfully, minimised to what each purpose requires, and retained no longer than the MCC Record Retention Schedule requires.

25. Review and amendment

25.1 This Policy SHALL be reviewed at least every three years, and earlier whenever monitoring, audits, grievances or urgent-harm events identify a material gap.

25.2 Amendment of this Policy SHALL follow the Tier 3 amendment authority and minimum public-notice period of MCC-001 clause 12.3.

25.3 An amendment SHALL NOT reduce protection for affected communities of projects already registered without transitional provisions preserving their existing protections and remedies.

26. Entry into force

26.1 This version 2.0-draft has no effective date; it enters into force only upon approval by the amendment authority of MCC-001 clause 12.3 following the public consultation, with the approval decision linked in the Evidence Register (MCC-001 clause 12.5).

26.2 On entry into force, this Policy supersedes MCC-ESS v1.0 in its entirety, and every project then in the pipeline SHALL be brought into conformity at its next lifecycle gate, with the conformity plan for registered projects fixed in the approval decision.

26.3 Until entry into force, the v1.0 text — reclassified by FD-2026-09-03 item D5; the document register records v1.0 as in force until this version is adopted, when its withdrawal as a controlled copy is executed (FD-2026-09-07 item A8: scheduled, not executed) — remains in force, and safeguards conditions applied in the interim follow MCC-100 Section 14 and MCC-700.

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Annex A — Programme exclusion list (normative)

A.0 An activity within any entry A.1 to A.12 SHALL be refused under Section 5. Entries apply to the project activity and, where stated, to its primary supply chain.

Entry	Excluded activity
A.1	Any activity unlawful under applicable host-country law or under international conventions binding on the host country
A.2	Any activity using forced labour or child labour, including in the primary supply chain
A.3	Fishing or harvesting using explosives, poisons or other destructive methods prohibited by applicable law, or deliberately targeting species whose taking is prohibited
A.4	Trade in wildlife or wildlife products in breach of CITES, or in fish or marine products from vessels or operators subject to applicable IUU-fishing sanctions
A.5	Production of, or trade in, substances subject to international phase-out or prohibition (including persistent organic pollutants and unlawful ozone-depleting substances), or radioactive materials, as a project activity
A.6	Deliberate release of untreated hazardous waste, or dumping at sea in breach of applicable law
A.7	Conversion or degradation of critical habitat, or of natural habitat where prohibited by the area's legal designation
A.8	Activities within a World Heritage site or legally protected area that are incompatible with its designation or management objectives
A.9	Physical displacement of Indigenous Peoples from their lands, territories or waters
A.10	Any activity for which a clause 13.3 circumstance exists and FPIC has been sought and DENIED, to the extent of the denial (clause 13.7)
A.11	Production of, or trade in, weapons or munitions as a project activity
A.12	Any activity that would require, as designed, a non-offsettable impact under clause 8.7 to occur

A.13 Amendment of this Annex is amendment of this Policy under Section 25; no waiver of this Annex is permitted (clause 5.5).

Annex B — Safeguards data model and screening schema (normative field semantics)

GENERATED CONTENT. The enumeration values in tables B-1 to B-3 are reproduced from the platform's safeguards_assessments data model so that this Policy and the platform use one vocabulary; the platform SHALL implement only these values for the fields shown, and any divergence found in implementation SHALL be reconciled to this Annex, not the reverse. The lifecycle states referenced are owned by MCC-700 Annex B and are cited, not restated, here.

B-1 Risk category field

Field	Values	Semantics fixed by
risk category	CATEGORY_A | CATEGORY_B | CATEGORY_C	Clauses 6.2 to 6.6

B-1.1 Exactly one value SHALL be recorded per project, with the reasons and validation records of clauses 6.2 and 6.8 linked.

B-2 FPIC status field

Field	Values	Semantics fixed by
fpic	NOT_REQUIRED | PENDING | OBTAINED | DENIED	Clauses 13.6 to 13.8

B-2.1 NOT_REQUIRED SHALL be recorded only with the validated reasons of clause 13.6; DENIED SHALL block the affected activities per clause 13.7.

B-3 Safeguards clearance field

Field	Values	Semantics fixed by
clearance	PENDING | CLEARED | CONDITIONAL | REJECTED	Clause 23.7

B-3.1 PENDING means no clearance determination has been made for the gate concerned; CLEARED means requirements are met; CONDITIONAL means clearance subject to the specified, time-bound conditions of clause 23.7; REJECTED means clearance refused, with reasons, carrying the appeal rights of MCC-700 Annex A row 8.

B-3.2 Whether the platform records one clearance per gate (registration clearance and each issuance clearance as separate records) or a single mutable clearance field with history is put to consultation. This Policy requires the determinations of clause 23.7 at each gate and an auditable history of every determination; the record granularity is an implementation choice for the Registry Oversight Committee with the register owner. (Consultation question 3.)

B-4 Screening schema

B-4.1 The screening schema SHALL present, for each requirement area SR1 to SR12, the screening questions below (elaborated in the Tier 5 screening form), and each answer SHALL be recorded with evidence references; an affirmative answer marks the area applicable under clause 4.3.

Area	Minimum screening questions
SR1	Could the activity cause significant adverse environmental or social impacts? Are any potential impacts within clause 8.7 (non-offsettable)?
SR2	Will the project engage workers (direct, contracted or primary supply chain)? Are there marine-work hazards (diving, vessels, gear)?
SR3	Could the project create community health or safety hazards? Will security personnel be engaged, or public security forces be deployed?
SR4	Would the project restrict access to land, foreshore or marine areas or resources? Could it cause physical or economic displacement? Is any tenure dispute known?
SR5	Do communities hold marine tenure or customary fishing rights in the project area? Do small-scale fisheries or gleaning livelihoods depend on it?
SR6	Are Indigenous Peoples present in, or collectively attached to, the project area? Does any clause 13.3 circumstance potentially arise?
SR7	Is the project in or near critical habitat, natural habitat, or a protected or internationally recognised area? Is there an invasive-species pathway?
SR8	Is there known or likely tangible or intangible cultural heritage, including submerged heritage, in the area of influence?
SR9	Are there gender-differentiated impacts or participation barriers? Are there GBV/SEA/SH risk factors (worker influx, security, enforcement, benefit control)?
SR10	Have all stakeholder groups, including vulnerable persons, been identified and can they be meaningfully consulted?
SR11	Will the project restrict access, use community or customary resources, or generate credited outcomes from areas under community rights?
SR12	Do climate or disaster hazards materially affect the project, its outcomes or the exposure of affected communities?

B-4.2 The screening form implementing this schema is a Tier 5 instrument; it SHALL be generated from this Annex and SHALL NOT alter the taxonomy or the questions' substance.

B-4.3 Grievance records SHALL capture, at minimum: receipt date; channel; anonymity flag; description; urgent-harm triage outcome and time; investigation status; resolution; remedy reference; and closure date (clause 20.11).

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End of MCC-ESS version 2.0-draft. DRAFT — FOR CONSULTATION. This document is not in force.