1. Understanding conflict of interest: the accumulation of functions

1.1. Support and evaluation: two opposing approaches

Support involves helping a project succeed. Evaluation involves objectively assessing its compliance.

These are two incompatible professional practices when they concern the same project.

A conflict of interest arises as soon as the same person or the same structure:

• advises,
• optimizes,
• ease,
• produced the evidence,
• interprets the reference framework,

then evaluates the project or contributes to the decision.

1.2. Why this is incompatible with international standards

The ISO 17065, ISO 17020 and ISO 19011 standards require:

• the separation between support and evaluation,
• the absence of an economic link between advisor and evaluator,
• the complete neutrality of the decision,
• a system governed by an independent entity.

These requirements are considered the minimum necessary to avoid any undue influence.

2. The diversity of appellations changes nothing: what matters is independence

The market offers a multitude of securities from various participants:

• Environmental initiative facilitator,
• Quality or biodiversity expert,
• Independent consultant
• Design office or subject matter expert,
• Project quality manager,
• Sustainable facilitator or coordinator,
• Environmental technical advisor,
• Environmental Project Manager,
• Subject matter expert
• Internal evaluator (self-assessment).

This semantic diversity might suggest that some roles are “neutral”. This is not the case.

Regardless of the title, a mentor is still a mentor. And a mentor can never evaluate.

3. Fundamental rules: what international standardization says

3.1. A facilitator can only advise → never evaluate

Its role is to:

• to help understand the criteria,
• structure the evidence,
• to guide the project owner,
• optimize the file,
• integrate the technical solutions.

It directly influences the content being evaluated.

Support → influence → total incompatibility with assessment.

3.2. An evaluator can never accompany → zero influence

An impartial evaluator:

• I do not recommend it.
• does not participate in the design
• does not offer any solutions.
• does not produce evidence
• does not train the operator on the current project.

As soon as an evaluator gives advice, even on a one-off basis: → 0 impartiality → 0 regulatory compliance

3.3. Economic link = impossible impartiality

When an appraiser is paid or commissioned by:

• a design office,
• an AMO (Assistance to Municipal Employees),
• a consultant,
• or any entity that supported the project,

Independence can no longer be demonstrated.

From a regulatory standpoint, this invalidates the assessment.

4. Outsourcing the evaluation is not enough: the decision must be independent

4.1. Outsourcing of evaluation is common

Some private devices:

• design their own reference framework,
• retain the interpretation of the rules,
• they outsource the analysis to an external firm,
• but retain the final decision.

It's a common model, but not an independent one.

4.2. Why this model does not guarantee any impartiality

In an impartial system, the decision is separate from:

• the design of the reference framework,
• support,
• the evaluation,
• the training,
• commercial activities.

When the label owner retains the final decision, the evaluation remains, strictly speaking, not independent.

4.3. Accreditation: what European law says

Regulation (EC) 765/2008 clearly defines:

• Accreditation applies only to organizations, never to individuals.
• The decision must be made by an accredited body.
• Outsourcing an evaluation does not provide any indirect accreditation.

A label that outsources the evaluation but retains the decision does not fall within the scope of accreditation.

5. The IRICE architecture: a strict separation of functions

5.1. Support: Biodiversity Partners

They only produce:

• the audience,
• support,
• the production of evidence,
• document structuring.

They do not carry out any assessments.

5.2. Assessment: IRICE evaluators

IRICE evaluators:

• do not recommend
• do not participate in the design.
• they only analyze the evidence submitted.
• they produce a neutral report
• do not depend on any BE or any AMO.

5.3. Independent decision

The final decision:

• is decided exclusively by the President.
• unrelated to support,
• without intervention in the evaluation,
• in accordance with the procedure (PROC 02-I).

It is the separation “support → assessment → decision” that creates structural impartiality.

6. Why is this separation essential for project owners?

6.1. ESG credibility and European compliance

The CSRD, Taxonomy, and ESMA frameworks require:

• verifiable data
• independent appraiser,
• independent decision.

Systems where the AMO or BE participates in the evaluation do not meet these requirements.

6.2. Legal value and enforceability

An impartial assessment protects:

• the project owner,
• project management,
• the financial partners.

6.3. Securing the project

An independent evaluation:

• reduces the risk of doubt or dispute,
• strengthens internal and external confidence
• clarifies responsibilities,
• facilitates ESG integration.

Conclusion

The strict separation of support, evaluation, and decision-making functions is the foundation of credible approaches. A system where the project management consultant, the design office, the subject matter expert, or the labeling body directly influences the evaluation or retains control over the decision is not an independent system as defined by international standards. The IRICE architecture, based on complete separation and compliant with PROC 02 requirements, guarantees genuine impartiality, protecting project owners and recognized by sustainable finance stakeholders.