CA AB-1305 Applicable Rules and Langan Responses
Response to Applicable Rule 44475.1.
We have received a commitment from our carbon credit broker, ClimeCo as follows:
“We also are working on our compliance with California AB1305, which our General Counsel and Leadership are interpreting as broadly applicable to any company marketing/selling carbon offsets, or any company making any claims of net zero, carbon neutrality, etc. through the use of carbon offsets, and doing business in California. Our intent is to provide all of the required carbon offset project information for all of the projects from which ClimeCo sells credits on our website, so that our clients only will need to link to the project(s) information for any purchases of carbon offsets through ClimeCo.”
This means Langan will be secure regarding its upcoming purchase to offset 2023 GHG emissions. However, this purchase is in process and will not be executed by the website publication deadline of January 1, 2024. Offsets purchased to cover 2022 GHG emissions will have ClimeCo links if the relevant projects are still offering sales but will not if the projects are closed. For the time period between January 1, 2024, and the posting of data for 2023 offset purchases, the Langan website will include an explanation of Langan’s current offset situation and a statement of intent to comply with data disclosure requirements for all offsets purchased after January 1, 2024.
Response to Applicable Rule 44475.2.
Langan will post similar language to the following on the sustainability page of the Langan website. Language is subject to marketing editing and approval:
Since 2018, Langan has operated as a carbon-neutral firm for scope 1, scope 2 and the scope 3 carbon emission categories tracked by Langan. Currently, Langan tracks scope 3 emissions from business travel and fully remote employee operations. Langan achieves carbon-neutral status by calculating its annual carbon emissions inventory and purchasing high-quality carbon offsets in the amount indicated by each annual inventory from a reputable carbon offset broker, CarbonFund/Climeco). Langan plans to continue achieving carbon neutral status by the same method for the foreseeable future.
Langan aims to continuously reduce the carbon intensity of our operations by executing carbon reductions projects outlined in our annual Sustainability Plan. Langan does not set specific carbon emission reduction targets either informally or formally through the Science Based Target Initiative.
Since 2021, Langan’s carbon inventory has been calculated in alignment with the World Resource Institutes’ Greenhouse Gas Protocol Corporate Accounting and Reporting Standard (the “GHG Protocol”). Langan’s carbon inventory is compiled and calculated by the same Environmental Social and Governance (ESG) and sustainability professionals who serve our ESG and sustainability clients. Information for the carbon inventory is obtained from Langan’s accounting and human resources teams as well as Langan’s sustainability-focused “Green Teams” that are organized in Langan’s various offices. The carbon inventory is subjected to the same internal Langan quality assurance and quality control procedures that are applied to the work products for our ESG and sustainability clients. Langan’s carbon inventory is not verified by an independent third party.
Langan’s annual carbon inventories compile emissions from January 1 to December 31 of the calendar year. Langan typically completes its carbon inventory by the end of January for the prior year and executes its purchase of carbon offsets by the end of February for the prior year. For compliance with California AB-1305 rule 44475.1, which is effective January 1, 2024, Langan will publish on this website relevant, required information regarding its carbon offset purchase to cover the 2023 carbon inventory results as soon as it is available. In subsequent years, Langan will update this website annually to reflect its most recent offset purchase.