LP-840: Impact Disclosure & Anti-Greenwashing Policy

Abstract

This LP establishes the standards and processes for making sustainability and impact claims. It ensures all environmental and social claims made by Lux Network are accurate, verifiable, and not misleading. This policy prevents greenwashing and maintains stakeholder trust.

Motivation

Greenwashing has become rampant in the blockchain industry, eroding stakeholder trust. Lux Network must:

1. Maintain credibility by backing every claim with evidence
2. Avoid regulatory action as greenwashing regulations tighten globally
3. Protect stakeholders from making decisions based on misleading information
4. Set industry standards by demonstrating what responsible claims look like

This LP creates the internal controls necessary to ensure that Lux Network's sustainability communications are always accurate, complete, and verifiable. It protects both stakeholders and the network's reputation.

Definitions

Greenwashing: Making misleading, unsubstantiated, or exaggerated claims about environmental or social benefits.

Material Claim: A sustainability statement that could influence stakeholder decisions.

Substantiated Claim: A claim backed by verifiable evidence and sound methodology.

Core Principles

1. Accuracy: Claims must be factually correct
2. Completeness: Don't cherry-pick favorable data
3. Clarity: Use plain language, avoid jargon
4. Comparability: Provide context for metrics
5. Currency: Use up-to-date information
6. Verifiability: Claims must be auditable

Claim Categories

Permitted Claims

Claim Type	Requirements	Example
Quantified	Specific numbers with methodology	"Network uses 65% renewable energy"
Comparative	Fair comparison, same methodology	"50% more efficient than 2023"
Directional	Clear trend with data	"Emissions decreasing year-over-year"
Certified	Third-party verification	"ISO 14001 certified operations"

Prohibited Claims

Claim Type	Problem	Example
Vague	No specific meaning	"Eco-friendly blockchain"
Unsubstantiated	No evidence	"Zero environmental impact"
Misleading comparison	Unfair baseline	"99% more efficient than Bitcoin" (without context)
Future-as-present	Aspirational as achieved	"Carbon neutral network" (before achieved)
Irrelevant	True but misleading	"No coal mining" (we never mined)

Claim Verification Process

Pre-Publication Review

Required for all material sustainability claims:

1. Draft claim: Author prepares claim with supporting data
2. Data verification: Sustainability team verifies underlying data
3. Methodology check: Confirm calculation methodology
4. Legal review: For significant claims (>$1M impact or prominent placement)
5. Approval: Sign-off by Sustainability Lead

Review Criteria

Criterion	Question
Truthful	Is the claim factually accurate?
Clear	Will average reader understand correctly?
Complete	Are important caveats included?
Current	Is the data recent enough?
Substantiated	Can we provide evidence if challenged?
Contextual	Is appropriate context provided?

Approval Authority

Claim Prominence	Approver
Website/marketing	Communications + Sustainability Lead
Press releases	Communications + Legal + ESG Committee
Regulatory filings	Legal + ESG Committee
Annual report	ESG Committee + Board review

Language Standards

Required Qualifiers

Situation	Required Qualifier
Estimates	"Estimated", "approximately"
Partial data	"Based on X% of validators"
Projections	"Target", "goal", "projected"
Self-reported	"Self-reported by validators"
Third-party data	Source attribution

Recommended Phrasing

Instead of: "We are carbon neutral" Use: "We offset 100% of estimated Scope 2 emissions through verified carbon credits"

Instead of: "Green blockchain" Use: "65% of our validator network runs on renewable energy"

Instead of: "Sustainable by design" Use: "Our proof-of-stake consensus uses 99.9% less energy than proof-of-work"

Prohibited Terms (Without Substantiation)

• "Sustainable" (without specific context)
• "Green" (without specific context)
• "Eco-friendly"
• "Carbon neutral" / "Net zero" (before verified achievement)
• "Clean" energy (without renewable %)
• "Zero impact"

Data Standards

Data Quality Requirements

Claim Type	Minimum Data Quality
Quantified claims	Primary data or verified secondary
Trend claims	≥3 data points, consistent methodology
Comparative claims	Same methodology, same time period
Third-party claims	Verification documentation

Data Currency

Data Type	Maximum Age
Real-time metrics	Current
Quarterly reports	<6 months
Annual reports	<18 months
Methodologies	Current (update on change)

Uncertainty Disclosure

For estimates and projections:

• State confidence level or range
• Explain key assumptions
• Note limitations

Example: "Network energy consumption is estimated at 1.3 GWh annually (±20%), based on validator survey data covering 65% of stake."

Comparative Claims

Fair Comparison Requirements

1. Same scope: Compare equivalent metrics
2. Same methodology: Use consistent calculations
3. Same time period: Compare same dates/periods
4. Provide context: Explain what's being compared
5. Acknowledge limitations: Note methodology differences

Network Comparisons

When comparing to other blockchain networks:

Required:

• Note consensus mechanism differences
• Use finality-adjusted metrics
• Cite data sources
• Acknowledge methodology limitations

Example: "Lux uses approximately 0.02 Wh per final transaction, compared to Bitcoin's estimated 700,000 Wh per final transaction (sources: [Lux methodology], [CBECI]). Note: Different consensus mechanisms make direct comparison imperfect."

Offset & Credit Claims

Carbon Offset Claims

Claim	Requirements
"Offset X tonnes"	Registry documentation, retirement proof
"Carbon neutral"	100% of calculated emissions offset, third-party verification
"Net zero"	Reduction pathway + residual offsets, SBTi-aligned

Renewable Energy Claims

Claim	Requirements
"X% renewable"	REC/GO certificates OR direct measurement
"100% renewable"	Full coverage with certificates, third-party verification
"Powered by renewable energy"	Majority (>50%) renewable + disclosed

Credit Quality Standards

Only claim credits that are:

• Additional: Would not have happened without the credit
• Verified: By recognized standard (Gold Standard, Verra VCS)
• Permanent: Long-term carbon storage (for removals)
• Not double-counted: Exclusive claim rights

Correction & Retraction

Error Discovery

When an error in sustainability claims is discovered:

1. Assess materiality: Determine impact on stakeholder decisions
2. Correct promptly: Update incorrect information
3. Disclose correction: Publish correction notice
4. Explain impact: Quantify effect of error
5. Prevent recurrence: Update processes

Correction Notice Requirements

Error Type	Correction Action
Minor (typo, rounding)	Silent correction, note in next report
Moderate (metric error)	Correction notice, update all instances
Material (significant misstatement)	Public correction, stakeholder notification

Retraction

If a claim cannot be substantiated:

1. Remove claim from all materials
2. Issue retraction statement
3. Explain why claim was made
4. Describe prevention measures

Training & Compliance

Required Training

Role	Training Requirement
Communications team	Annual greenwashing prevention
Marketing team	Annual claim verification
Executive team	ESG claims awareness
All employees	Basic sustainability communications

Compliance Monitoring

• Quarterly audit of published sustainability claims
• Annual review of marketing materials
• Stakeholder feedback monitoring
• Regulatory update tracking

External Claims

Ecosystem Project Claims

Projects in the Lux ecosystem making sustainability claims must:

1. Not imply Lux endorsement without permission
2. Substantiate their own claims
3. Not make claims about Lux network without verification

Partner & Validator Claims

• Lux does not endorse unverified sustainability claims by partners
• Validator green claims must meet LP-810 standards
• Co-branded materials require claim review

Regulatory Alignment

Applicable Regulations

Jurisdiction	Regulation	Relevance
EU	Green Claims Directive	Substantiation requirements
EU	CSRD	Disclosure standards
US	FTC Green Guides	Marketing claim standards
UK	CMA Green Claims Code	Consumer protection

Compliance Approach

• Monitor regulatory developments
• Apply most stringent applicable standard
• Seek legal review for novel claims
• Maintain evidence for all claims

Related LPs

• LP-800: ESG Principles and Commitments
• LP-801: Carbon Accounting Methodology
• LP-820: Network Energy Transparency
• LP-830: ESG Risk Management
• LP-850: ESG Standards Alignment Matrix
• LP-860: Evidence Locker Index

Changelog

Version	Date	Changes
1.0	2025-12-17	Initial draft

Copyright

Copyright and related rights waived via CC0.