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MPMoojin Park · ESG PortfolioEconomics · Evidence · Executive learning
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Evidence, Compliance & Claims

How to Build a Claim-to-Evidence Ledger

A credible ESG sentence links the claim, source, verification date, owner and disproof condition.

A claim-to-evidence ledger prevents polished proposals and ESG copy from moving ahead of the underlying records.

Polished documents can increase claim risk

When design and copy are completed quickly, an unverified relationship or expected result can look like an established fact. The relevant risk is not the writer's intention but the reader's reasonable impression. Each material public statement should therefore be linked directly to its supporting record.

Minimum fields

Record the exact claim, claim type, source file or URL, verification date, evidence level, claim owner, disproof condition and next review date. If a third-party name appears, add the relationship status and the basis for public use. For any number, retain the measurement conditions and population.

Three evidence levels

L1 is direct evidence such as legislation, an official page or a measured source record. L2 is an established method or a reliable secondary explanation. L3 is a hypothesis, estimate or item requiring confirmation. The level describes verification depth, not the importance of the idea. L3 can guide investigation but should not be presented as operating performance.

The publication gate

If a material claim lacks evidence, its verification date has expired or its disproof condition has been met, weaken or remove the sentence. Updating the evidence behind an existing statement usually creates more value than producing another polished document.

A ledger row that another reviewer can reproduce

Use these fields: claim ID; exact public wording; implied meaning; claim class; product, geography and period; numerator and denominator; baseline and comparison; source URL or file plus page; source owner; verification date; evidence level; calculation file; relationship status where a third party is named; publication owner; disproof condition; review date; and public status. Store the source snapshot or immutable record separately from the presentation. A URL alone is not evidence if the cited passage, date and calculation cannot be reconstructed.

Score readiness without turning it into truth

Use Red when the source is absent, the relationship is unconfirmed or the calculation cannot be reproduced. Use Amber when the source exists but scope, date, denominator or approval is incomplete. Use Green only when a reviewer can reproduce the statement and its qualifications from the retained record. The colour controls publication; it does not certify that the underlying activity is environmentally beneficial. A Green claim can still be immaterial or misleading if the wording omits a significant trade-off.

Review loop and kill conditions

Before publication, have a person other than the drafter read the sentence without the source and write down the impression it creates. Then compare that impression with the evidence. Remove or qualify the claim if the source changed, the measured population differs from the public scope, an expected result is presented as achieved, a third party has not approved the relationship wording, or a known adverse trade-off would alter the overall impression. Log the change instead of silently replacing the old sentence.

Primary sources

The US Federal Trade Commission Green Guides explain substantiation and qualification of environmental marketing claims: https://www.ftc.gov/legal-library/browse/rules/green-guides. The EU European Sustainability Reporting Standards are in Commission Delegated Regulation (EU) 2023/2772: https://eur-lex.europa.eu/eli/reg_del/2023/2772/oj. These are jurisdiction-specific primary materials, not a universal assurance opinion. The ledger is UAMKT's editorial control for connecting a claim to the evidence and review applicable to it.

ESG claimsclaim evidence ledgergreen claimsESG assurance
Editorial note. This article provides a general operating framework. Classification, permits and legal duties should be confirmed for the relevant jurisdiction and facts.
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