Plastic Bank’s Business Ethics Policy

Purpose

This policy states the company’s stand, its qualitative and quantitative goals, its governance and allocation of responsibilities, review mechanism, and specific scope on the following topics – Anti-Corruption (Bribery, Fraud, Conflict of Interest, Money Laundering), Fair Competitive Practices, and Responsible Information Management . This is created to ensure it is communicated clearly to all employees and external stakeholders, and to ensure that accountabilities on monitoring and reporting are clear to achieve the goals. 

It is important to state that Plastic Bank does not own and operate any recycling facilities, aggregation centers, collection facilities and any other type of manufacturing facilities. It partners with existing plastic collection and recycling ecosystems.

Scope of the company

All of Plastic Bank’s operating sites; all employees under Plastic Bank in Canada, and all other countries of operation where the business is registered; agents, contractors, subcontractors,consultants, business partners and any other parties (including individuals,partnerships and corporate bodies) associated with the Company.

Distribution

Internal: Read and approved by ELT, read and understood by each employee via DEEL

External: Plastic Bank Website

Policy Statement

Plastic Bank is committed to the practice of responsible corporate behaviour, and compliance to all laws and regulations.

Plastic Bank is fully committed to instilling a strong anti-corruption culture and is fully committed to compliance with all anti-bribery and anti-corruption legislation including, but not limited to, the Bribery Act 2010 (“theAct”) and ensures that no bribes or other corrupt payments, inducements or similar are made, offered, sought or obtained by us or anyone working on our behalf.

We are committed to the following, and ensure monitoring and reporting of progress annually.

	Quantitative Goal	Strategies
Corruption	Zero confirmed incidents of corruption starting 2024	Awareness trainings Anti-corruption due diligence and risk assessment for third parties Whistleblower procedure cascade to report unethical business practices. Internal audits to prevent corruption and bribery Special approval procedures for sensitive transactions (e.g. gifts, travel)
Fair Competitive Practices	Zero confirmed incidents of anti-competitive incidents starting 2024	Policy on Advocacy and Communication distribution via DEEL
Responsible Information Management	Our employees and external parties’ information and data will be properly protected. We strive for zero security breaches from 2024 onwards.	Awareness training to prevent information security breaches Information security due diligence program on third parties in place Information Security Risk Assessment Audits of control procedures to prevent information security breaches Incident response procedure (IRP) to manage breaches of confidential information Implementation of a records retention schedule Measures to protect third party data from unauthorized access or disclosure Measures for gaining stakeholder consent regarding the processing, sharing and retention of confidential information

Any non-compliance can be reported by any employee or other stakeholders via our Whistleblower Procedure.

Detailed Guidelines

Bribery

1.1 No party within the scope of this policy may give or promise any financial or other advantage to another party (or use a third party to do the same) on the Company’s behalf where that advantage is intended to induce the other party to perform a particular function improperly, to reward them for the same, or where the acceptance of that advantage will in itself constitute improper conduct; 

1.2 No party within the scope of this policy may request or agree to receive any financial or other advantage from another party where that advantage is intended to induce the improper performance of a particular function, where the acceptance of that advantage will in itself constitute improper conduct, or where the recipient intends to act improperly in anticipation of such an advantage.

1.3 Receiving gifts and/or giveaways from partners, customers and suppliers in any form whatsoever is highly discouraged and in some cases prohibited. 

Gifts/giveaways that are prohibited:

1.3.1 Cash 

1.3.2 Gifts valued at USD $25 or more.  If approached with a gift that exceeds this value, you must alert local finance/HR and your manager

1.3.3 Gifts exclusive and beneficial to an individual person or a small group of individuals (e.g. hotel stay)

Gifts/giveaways that may be accepted:

1.3.4 Gifts valued at less than USD $25 with manager approval

1.3.5 Gifts in which the whole organization receives or benefits from

1.4 Gifts and giveaways that are to be received or have been received must be declared. In most cases, the People and Culture Manager and the Senior Leader involved (e.g. Functional Leader or Country Manager) should be consulted.

1.5 For employees of the Company, failure to comply with this Policy and/or with the Act may result in:

disciplinary action which may include dismissal; and criminal penalties which may result in a fine and/or imprisonment .

1.6 For the Company, any breach of this Policy by any employee or business associate may result in:

the Company being deemed in breach of the Act;

the Company being subject to fines; and

the Company getting negative publicity and further associated damage as a result of such breach.

1.7 The following issues should be considered with care in any and all transactions, dealings with officials, and other business matters concerning third parties:

1.7.1 Territorial risks, particularly the prevalence of bribery and corruption in a particular country

1.7.2 Cross-border payments, particularly those involving territories falling under scope

1.7.3 Requests for cash payment, payment through intermediaries or other unusual methods of payment

1.7.4 Activities requiring the Company and / or any associated party to obtain permits or other forms of official authorisation

1.7.5 Transactions involving the import or export of goods

Fraud

2.1 Fraud generally involves taking something you are not entitled to, or lying to receive something of benefit for yourself. It is prohibited, both within the Company and in all external dealings.

2.2 Fraud examples:

• Theft of Company property

• Forgery

• Misappropriation of funds, securities, supplies, or any other Company asset

• Irregularities involving money transactions

• Falsification of expense statements, time records or any other Company record

• Improper financial reporting or recording fictitious or misleading transactions in financial records

• Bribery

• Tax evasion

• Providing false or misleading information or scenarios to gain favors or approvals

2.3 Fraud also includes any irregularity or suspicion of any irregularity involving vendors, customers, Company personnel, agencies, unknown parties, or Company property. Incidents should be formalized in a report with an action plan, followed through and stored in a centralized repository folder, and reviewed regularly.

Conflict of Interest

3.1 Conflict of interest is any situation involving our business in which there is actual impairment, or a reasonable appearance of impairment, of an employee’s ability to act, objectively and independently, in the best interest of Plastic Bank. These are also situations in which an individual, organization or entity is given an unfair and undue advantage over the best interests of Plastic Bank.

3.2 We must avoid situations where a conflict of interest may occur and mandatorily must disclose to Plastic Bank any potential conflicts of interest to Plastic Bank before engaging such parties. Our Conflict of Interest Policy covers our employees/contractors, partners, clients and communities:

3.3 To avoid potential conflicts, it is essential to keep the best interests of Plastic Bank before the interest of an individual, organization, or entity in circumstances such as—but not limited to—Conflict of interest include/may arise from but are not limited to the following:

For Employees/Contractors:

3.3.1 Employees related up to the 2nd degree who directly report to the same supervisor or manager

3.3.2 Employees related up to the 2nd degree in which one of the individuals report to the other or has an influence in his or her promotion, salary increase or other benefits

3.3.3 Employees who are in a romantic relationship in which one of the individuals directly or indirectly report to the other or has an influence in his or her promotion, salary increase or other benefits

3.3.4 Employees who are part of (e.g. as an owner, director, investor) or actively involved in (e.g. as an employee, consultant, advisor) of an organization who is directly or indirectly in competition with Plastic Bank.

3.3.5 Employees who are related up to the 2nd degree to a Business partner, partner branch or member collector.

3.3.6 An individual who was endorsed by a manager or Senior leader to be hired by them in their team.can also be a potential conflict of interest. In this situation, the applicant must go through the same process as all candidates do. The manager or Senior leader who endorsed the individual must step aside from the hiring process and must not be part of the final decision making process.

For Business Partners:

3.3.7 Pirating of an  active employees or influencing an active employee to join an organization

3.3.8 Hiring a former employee who has resentments towards his/her former employer

3.3.9 A family member or relative endorsed by a partner or plastic bank to be hired

For Suppliers/Collection Branches and Member Collectors

3.3.10 Member Collector who is related up to the 2nd degree to owner or manager of the partner branch he or she delivers to.

3.3.11 Collection Branches who are related up to the 2nd degree to a Plastic Bank employee

3.3.12 The collection branch and collection point MOA should indicate if the following: 

“By accepting this Agreement, the SECOND PARTY is hereby confirms that he/she is not related within the 2nd civil degree of consanguinity or affinity to any Plastic Bank collector/member or other accredited Partners and Collection Points”

Money Laundering:

4.1 Money laundering is an attempt by individuals or organizations to hide the proceeds of their crimes by making those proceeds look legitimate. Money laundering is against the laws and we abide by them. We shall not accept, facilitate or support money laundering. Our approved payment and sales practices are designed to ensure not to violate these laws.

4.2 With our clients, we confirm business registration using identification evidence (e.g Passport) of business and owners.

4.3 We use this identification with the likes of “equifax” to ensure validity.

Fair Competition:

5.1 We compete fairly. We abide by competition laws (also referred to as “antitrust” laws). These laws can vary from market to market, but their common goal is to preserve free and open competition and to promote a competitive marketplace.

5.2 Competition laws are designed to encourage competition in business for the benefit of the consumer. It is Plastic Bank’s policy to comply fully with all applicable competition laws.

5.3 Because Plastic Bank is committed to competing based on the quality of our products and services, we will avoid engaging in or supporting unfair or predatory business practices or any activities that would improperly restrain trade. It is also critical that we avoid any activity that could violate or give the appearance of violating competition laws.

5.4 In all contact with competitors, we refrain from any conduct that suggests an understanding or agreement exists with respect to prices, terms of sale, production for third parties, or allocation of customers, markets, or territories. To this end, avoid any discussion or communication with any representative of a competitor concerning the following:

• Prices
• Pricing policies
• Discounts, rebates, royalties, or promotions
• Credit or shipment terms, or other conditions of sale
• Choice of customers or allocating customers between competitors
• Dividing up a territory between competitors
• Products to be manufactured or sold production quantities or quotas (that is, agreements between competitors as to the amount of products to be manufactured and/or sold by each or the addition of new capacity)
• Employee compensation practices

5.5 The following are practical suggestions:

• Avoid discussions on  pricing or other prohibited subjects, 
• Avoid exchanging price lists, terms, or conditions of sale with a competitor.
• Avoid asking someone to determine what competitors will do in response to a proposed price move if obtaining an answer would involve contacting a competitor. Do not do anything indirectly that would be a violation of law if done directly.

Data Privacy:

6.1 Protection of Personal and confidential information of all individuals involved and engaged with Plastic Bank is of extreme importance. For this matter a number of measures are put in place:

6.2 Gathering of personal data and information will be limited to those which are essential to an employee’s function and compliance. These include but are not limited to the following:

• Legal name (as reflected on a government issued document)
• Birthday
• Mobile number
• Email address
• Government ID numbers (those needed to comply with government regulations)

6.3 Any need for an individual’s personal information must be requested from the People and Culture Manager. The P&C manager has the right to deny release of information if he or she deems the request unreasonable and unreasonable.

6.4 Any internal release of any personal information not readily available is subject to the consent and approval of the concerned individual.

6.5 Any release, especially externally, of confidential information must be with the approval of the People and Culture Manager. Any information irrelevant to the request for information must be concealed. 

Governance and Allocation of Responsibilities

This policy and its implementation is governed by the Human Resources Team, with support from the Chief Technology officer,  the Chief Supply Chain Officer, and the Chief Marketing Officer forming the ELT ethics governance committee. 

The policy is authored by the sustainability director in collaboration with the human resources team, market supply chain, and marketing. 

For employees, the HR team is responsible for disseminating this policy dia each employee’s DEEL account for record keeping.

For Collection Centers, Processors and Members,  the country supply chain lead  is responsible for training/onboarding and implementation.

Review Mechanism, Monitoring and Reporting

This policy must be reviewed every 3 years under the leadership of the sustainability director. All changes must be communicated to all relevant parties. Contact the HR Committee if you have any questions or feedback

The following (not limiting) must be annually reported and monitored for improvements:

% Employees trained on ethics

# Reports related to whistleblower procedure 

# Confirmed incidents of unfair competition incidents

# Confirmed corruption incidents

# Confirmed information security incidents

Refer to the Crisis Communications Protocol below link, and the Risk Management Protocol link below.

Reports are processed according to the Crisis Communications Protocol.

Crisis Communication Protocol

https://docs.google.com/presentation/d/1L2B1pHm1PdBsZNQjZYXktRKnp4LA13R_2gOWHV5_Qys/edit?usp=sharing

Remediation :

In case of any violation of this Policy by  suppliers, branches, processors, sub-contractors or business partners, the following actions shall be taken: Field coordinator reports the branch , processor or third party committing this violation (whether child or forced labor) to the community supervisor who then reports to the operations manager who terminates the contract instantly with the breacher.

Revision History

Version #	Date	Reason for Revision
1	15 Feb 2023	Original
2	2 Oct 2024	Qualitative goals, scope, purpose, strategies