Milestone 04


Leighon Estate – Oxygen Conservation


Identify and Work with Buyers


Project Summary

Oxygen Conservation is a UK-based company that invests in land to protect and restore natural capital. Oxygen Conservation draws on a variety of income streams to generate a financial return, including natural capital credits (carbon, biodiversity, and water), as well as renewable energy, regenerative agriculture, ecotourism, and sustainable property development. As of December 2025, Oxygen Conservation has 12 estates in its portfolio that it manages for nature restoration.

Oxygen Conservation is managing the Leighon Estate, owned by The Dixon Foundation, to restore and protect its rare Atlantic temperate rainforest. In addition to the conservation activities at the Estate, Oxygen Conservation is appointed as a natural capital asset manager, broker, and project developer to structure the Estate’s natural capital partnerships. In 2025, Oxygen Conservation completed a deal with UK law firm Burges Salmon for the Estate’s 8,000 woodland carbon credits at £125 per tonne.

Milestone 1: Initial Project Scoping

Often the initial task is to understand the site(s) you want to use and the land use change needed for nature restoration or creation. This includes considering the goals of the land managers involved, the vision within the wider catchment or neighbouring area, and whether there are permits or planning consent needed for any proposed changes.

At this stage, you can also conduct a high-level assessment to determine which revenue streams can be generated from ecosystem services , e.g. carbon credits, flood reduction cost savings, or biodiversity units, which will be crucial for identifying buyer interest.

Finally, it is useful to have an idea of the costs of the project and potential grant funding that may be available to support initial development.

Milestone 2: Identify and Work with Sellers

Initial ownership of the ecosystem services will belong to the landowners or, in some cases, the tenants of the sites that the project is using. However, these can be passed onto others, such as third-party project developers, with appropriate legal arrangements and compensation. In some cases, there may be a sole seller of the ecosystem services, where the site or landholding is large enough that it delivers the volume of ecosystem services needed to cover the costs of the project and attract buyers.

However, in order to achieve scale and impact, a project will likely involve multiple sellers, such as neighbouring farmers and estate managers. Scale of land is often needed to deliver significant environmental outcomes, and also to attract private finance.

Where they are not the land managers in question, project developers must plan how they initially contact and engage with these sellers going forward, building their wants and needs into the project.

Milestone 3: Baseline and Estimate Ecosystem Services

At this point, you will have understood the vision for the project and identified a particular ecosystem service or set of services to be sold. The next step will be to carry out detailed analysis – baselining each ecosystem service and quantifying what will be able to be delivered from the interventions, as well as planning how to monitor and maintain these interventions. You will need to rely heavily on ecological expertise for this more scientific Milestone.

At this step, standards, verification and accreditation methods will be considered in more depth.

Milestone 4: Identify and Work with Buyers

Based on your earlier market analysis in initial project scoping, you will have identified one or more groups of beneficiaries who may be willing to ‘buy’ or pay for the ecosystem service(s) to be created, restored or maintained. Buyers vary – as do their requirements – but at this step, greater buyer engagement is now needed to develop a deal that channels money towards the nature-positive outcomes that your project wants to deliver.

 

 

Milestone 5: Develop Business Case and Financial Model

You’ll have started building your business case and financial model in earlier steps – laying out your project’s vision, the market proposition and estimating costs and income. This step offers a review, in addition to providing details needed to build out the financial model and business case more fully. Both of these key documents will be iterated throughout project development, and will likely be altered during project delivery as new information emerges. These documents are interlinked and, if developed correctly, will ensure your project’s viability and help you with discussions with stakeholders – including sellers, buyers and future investors.

The financial model will also enable you to better understand the type of structure your project may take to attract investment (i.e.a loan, an equity investment, a bond) and what sort of returns you can afford to pay/offer.

Milestone 6: Develop a Governance Structure

A governance structure will inform the way in which the project is run when fully operational and for what purpose. It identifies appropriate decision making processes, who is responsible for what actions, and what controls are in place to make sure that the project is meeting its stated goals, all while abiding by the risk appetite of its engaged stakeholders. The legal entity to host the project will be a key driver in this, and the appropriate choice of entity will be dependent on several factors that are outlined below.

Your governance structure should align with and underpin your business case, as a necessary component of how the project will deliver its environmental outcomes and other strategic targets.

Milestone 7: Identify and Work with Investors

It is important to note that not all projects will need up-front investment, but for those that do, this section provides a framework for thinking around the development of the investment model. This does not constitute financial advice – as the GFI is not licensed to do so. However these considerations are based on the insight offered by project developers and other market stakeholders.

An investor will be a new core stakeholder in your project, and it’s just as important to think of what you require from investors, as much as what they require from you – so that you can build a positive and collaborative relationship with them.

This entails defining the investment ask (in line with the financial model), the strategy for approaching the right investors, and the negotiation of terms that can then be formalised in contract development (Milestone 8).

 

Milestone 8: Establish Legal Contracts and Closing

When all relevant stakeholders have been engaged and their terms of engagement are clarified as much as possible, this is the time to fully develop the legal contracts and close the deal. This stage is positioned with in the Toolkit as last because legal fees are expensive, and it is generally advised to determine as much as possible in previous stages before starting to draw up contracts in earnest. However, you may have engaged legal advisors ahead of contract design on issues like tax, permitting and effective governance structures, which are covered in previous Milestones.

Note: The information in this Milestone does not constitute any form of legal advice but instead serves as practical advice on how to manage engagement with lawyers and the process of contract development. The Green Finance Institute is not a firm of solicitors or connected in any way with the courts. The information and opinions we provide in this section and across the Toolkit do not address your individual requirements and are for informational purposes only. They do not constitute any form of legal advice. We recommend that appropriate legal advice should be taken from a qualified solicitor before taking or refraining from taking any action.

Community Engagement

Community engagement is highly advisable for any project that aims to sell ecosystem services, to ensure fair outcomes for local communities and the long-term success of the project. Project developers can build connections with local stakeholder groups early on to spot both risks and opportunities.

Policy and Regulation

Project developers and enterprises will need to keep a continuous check on how current and future policy may affect the project, and also opportunities for the project to inform policy. The role of private finance for nature across the UK is being encouraged by the UK government and its devolved administrations, and new rules, standards and markets are being developed.

 
Quick Stats
  • Location: Bovey Valley, Dartmoor National Park
  • Size of Land: 861 acres
  • Tenancy & Ownership: Estate owned by UK-registered charity
  • Nature Market Focus: Woodland Carbon Code, Biodiversity Net Gain
  • Project partners: The Dixon Foundation, Burges Salmon LLP, Soil Association, Forestry Commission

 

Acknowledgements 

With thanks for giving their time and insight to this case study:

Chris Winter, Director of Natural Capital, Oxygen Conservation

 

Gabi Gershuny, Associate, Burges Salmon LLP

 

James Thorniley, Associate Director, Mixology PR

 

 

 

 

Date Published: 12/02/2026

 

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Key Points

  • Oxygen Conservation is using a dual-market design (WCC + BNG) to maximise the regeneration of the Estate and the natural capital value for newly planted areas and existing habitat uplift respectively.
  • Pricing for the carbon units (£125/t) was achieved due to the role they play in protecting and expanding the rare Atlantic Rainforest habitat on the Estate, quality positioning with buyers, and higher costs from quality assurance, more complex ecological planning and restoration work, and advanced monitoring.
  • The buyer strategy focused on finding one UK-based, values-aligned buyer with strong decarbonisation commitments and long-term partnership potential.
  • Oxygen Conservation used a marketing-led approach in early engagement (branding, imagery, storytelling) which replaced upfront technical packs. Outreach was handled in-house via one-to-one conversations and curated estate visits.
  • Negotiations were bespoke, particularly around risk allocation, annual offtake scheduling, and carbon/financial modelling to meet both parties’ needs.
  • Real-time ecological monitoring via a digital dashboard was a key differentiator, strengthening claims of transparency and high integrity.
  • Landowner governance (UK-registered charity) required formal trustee approvals and valuation checks to understand the impact on the underlying land value.

 

Defining the Offer

The Leighon Estate is an 861-acre estate privately owned by a UK-registered charity – The Dixon Foundation – which it acquired to further conservation and regenerative agriculture programmes that support sustainable development, local communities, and green revenue generation. At Leighon, the protection and restoration of 92 acres of temperate Atlantic rainforest, and creation of 64 acres of new rainforest through planting and natural regeneration to reconnect the existing fragments is being delivered amongst its large-scale natural capital plans.

Oxygen Conservation (OC) partnered with the Estate’s owners in 2022 to help design this project and develop a premium natural capital offering that would avoid risks of greenwashing with the partnership marking OC’s first major project.

After baselining the Estate’s various habitats, it was decided that the Leighon Estate could use two market mechanisms to uplift its natural capital:

  • Woodland Carbon Code (WCC) unit sales would be used for newly planted and naturally regenerating areas adjacent to existing rainforest habitats – capturing greater carbon gains from a grassland habitat baseline over 100 years.
  • Biodiversity Net Gain (BNG) unit sales would be used to restore the condition of existing rainforest habitats, due to the BNG metric’s recognition of the habitat as rare and highly beneficial for species diversity.

While this ability to operate across different nature markets gave the project an advantage, it also presented the team with “complex landscape recovery” requirements according to Chris Winter, Director of Natural Capital at Oxygen Conservation.

The uniqueness of the habitats at Leighon, the focus on delivering landscape-wide biodiversity impact rather than maximising carbon yields, OC’s work in showing how the project contributes to the UN Sustainability Goals, and a real-time digital monitoring and reporting system (see below), distinguished this project in the voluntary carbon market. The nature of uplifting and expanding sensitive rainforest habitat, together with the extensive due diligence and monitoring required meant that the project faced higher planning and management costs than typical woodland creation schemes. All these factors contributed to the higher price of £125 per tonne.

 Leighon Estate

 

Identifying potential buyers

Winter comments that OC was selective in which buyers it decided to pursue. It sought to partner with just one buyer that recognised the value of securing the rights to purchase the entire credit offering and working in partnership to deliver impact that goes beyond carbon. OC also targeted a UK-based buyer that would be able to visit the Estate and have a “tangible connection” to it, according to Chris Winter – helping to maintain transparency between the buyer and seller.

OC decided to look for corporates that had a public decarbonisation strategy and demonstrated leadership role in environmental sustainability. Its overall ambition was to create a partnership that would extend beyond the transaction of carbon credits and allow the buyer to meaningfully engage with the project in the long term.

Rather than proactively approaching buyers, OC focused on creating a product with a higher premium that buyers would actively look for in the market.

 

Approaching buyers

For its carbon offering, OC did not produce an initial price list, fact sheet, or technical data to share with buyers. Instead, the team focused on highlighting the rarity of the Estate’s habitat in early buyer engagement. This led to a strong focus on marketing – such as imagery and stories.

OC decided not to use an external party for its potential carbon unit sales. This process was kept in-house, as Winter explains that the “young and new” nature of natural capital markets meant that OC did not feel confident in working with a third party to convey the complexity and uniqueness of its offering.

OC’s relationship with Burges Salmon extends to over four years, with the law firm providing legal advice for the acquisition of each of OC’s twelve estates, including the first estate purchased on behalf of The Dixon Foundation, Leighon. Working together over this extended period gave Burges Salmon the opportunity to understand Oxygen Conservation’s business and team, providing transparency and trust in the project itself.

Several years into this relationship, the opportunity arose for Burges Salmon and OC to discuss the firm’s need for premium quality carbon credits backed by a trusted verification standard such as the Woodland Carbon Code. Burges Salmon were interested in a project which could provide meaningful opportunities for employee engagement and demonstrate outcomes beyond carbon sequestration. The firm has an established environmental law practice, and this partnership with OC is aligned to its ‘Six Pillars of ESG’ legal services offering. This all gave the firm’s senior leadership confidence that its people would be supportive and enthusiastic about the partnership.

After several conservations, OC hosted Burges Salmon, headquartered in nearby Bristol, for a tour of the Estate to help their team to better understand and experience the project in person. As part of this, OC organised a pop-up café and tree planting session to engage the team and immerse them within the landscape.

 

Negotiations

Moving from the engagement phase and initial site visit, Burges Salmon and OC negotiated a Pending Issuance Unit (PIU) deal and partnership over the course of 12 months.

OC first shared an information pack with the law firm that included structured information on its approach to carbon sequestration and credit production. This was followed by more formal in-office and virtual meetings to discuss pricing, the number of credits to be purchased, and the wider goals of the partnership beyond carbon. Gabi Gershuny, Associate at Burges Salmon, described the negotiation process as “highly collaborative… It required considerable time to address the bespoke elements of the deal.”

One of the most challenging aspects of negotiations was risk allocation – such as how delivery risk should be dealt with differently in fault-based and no fault scenarios, and how the apportionment of risk between the parties should change over the 100-year period of the project to reflect the evolving maturity of the woodland and different phases of Oxygen Conservation’s management plan. Gershuny comments from a legal perspective that the risk profile of every carbon project is different, so determining how risk should be appropriately and fairly allocated was among the most time-consuming parts of the negotiations. There was significant involvement from the firm’s Senior Partner Ross Fairley, who is an experienced environmental and clean energy lawyer and Chairs the Firm’s Responsible Business Committee. “The Burges Salmon team was able to harness its strong expertise in crafting contracts for natural capital projects, which we have developed since the first wave of tree planting agreements for carbon offsetting nearly 20 years ago,” says Gershuny.

Burges Salmon was comfortable paying a premium for the carbon credits due to its knowledge of the voluntary carbon market and future predictions around the rise in average pricing. Burges Salmon therefore recognised the advantage of fixing a price early to hedge against future inflation and secure supply. The firm also had prior experience purchasing carbon credits from a separate source, providing a benchmark for comparison. Ross Fairley, Senior Partner at Burges Salmon, states: “The firm views this partnership as a way of demonstrating the value of commitment to and investment in natural capital. Burges Salmon aims to lead the market towards greater investment in high quality nature-based solutions and to show that going ‘beyond carbon’ brings tangible benefits that justify a higher premium.”

 

Ecological Monitoring and Data sharing

A distinguishing feature offered was the real-time ecological monitoring and data sharing from the project itself. To ensure constant and freely available data sharing, OC has developed a bespoke digital dashboard that will show Burges Salmon how carbon stocks in the rainforests are changing over time together with a geo-locational tag for each of their credits, mapping each credit to the underlying natural capital asset. The dashboard also measures wider environmental change beyond carbon including biodiversity, ecosystems, soil quality, and water quality, and the contribution the project is making each year to nine of the UN Sustainable Development Goals.

Figure 1: Each of Oxygen Conservation’s carbon projects aim to grow the natural capital of the whole estate and deliver positive environmental and social impact through the UN Sustainable Development Goals framework.

Winter says that monitoring and data transparency was an important element for the Estate’s claim to high-integrity practices, noting that lack of transparency and poor monitoring is a common source of greenwashing accusations in the wider market.

 

Working with the landowner

Due to the Leighon Estate being owned by The Dixon Foundation, OC needed to consult with and receive formal permission from the charity before the credit purchase could be completed. Its governance process included scrutiny of the alignment of the deal with its charitable objectives and charity law. For example, legal and land valuation advice was sought to understand if the sale of carbon credits amounted to a disposal of land, and how the carbon credit sale might impact the value of the underlying asset (the land itself).

 

Continuing the Partnership

Having signed the agreement in October 2025, Burges Salmon and Oxygen Conservation have continued conversations on ways to collaborate beyond the sale of the carbon credits.

For example, as part of the agreement, Burges Salmon will have the opportunity to hold events on the Estate for internal volunteering so that their employees can build a long-term tangible connection to the project, and for external clients to showcase the impact Burges Salmon is having as a company to key stakeholders. Provisions have been included to ensure these visits do not coincide with sensitive periods for wildlife or critical stages of restoration work.