Corporate Governance

Closing the Loop strives to be an example to the ICT sector across continents. We therefore have some key principles and high standards for our business. We comply with several industry and other standards, as mentioned in our governance documentation.

General Business Principles

We have defined General Business Principles that we apply to everything we do. These principles are shared with all our stakeholders. Some of our stakeholders (most notably our direct supply chain for collection) are contractually required to agree to these principles.

The most recent version of our General Business Principles can be downloaded here.

Code of Conduct

In addition to our General Business Principles, we adhere to a strict Code of Conduct to which we hold all our suppliers. The Code of Conduct is a central guide and reference for our partners and employees and can be found here. Our Code is largely based on the Responsible Business Alliances Code of Conduct (RBA Code) which is a set of social, environmental and ethical industry standards. The RBA Code and standards reference international norms and standards including the Universal Declaration of Human Rights, ILO International Labor Standards, OECD Guidelines for Multinational Enterprises, ISO and SA standards, and many more.

We respect all basic human rights as set forth in the United Nations Guiding Principles on Business and Human Rights.


CTL has a Grievance Policy that can be found in the Grievance Policy document. It also includes the steps to take in order to file a grievance, as well as what someone can expect after filing such a grievance.

Child Labour

Closing the Loop is active on a continent that is known to have high risks of child labour. For this reason, we have adopted a specific policy for child labour, and identified our main risks and mitigating factors. CTL has been advised by Hivos/Stop Child Labour in the making and developing of this policy, and will continue to work with them to ensure that we are constantly improving and evaluating our policies and procedures.

In addition to the guidelines of the RBA Code of Conduct, Closing the Loop’s commitment also references the International Bill of Human Rights, the ILO's Declaration on Fundamental Principles and Rights at Work, the UN Convention on the Rights of the Child as well as the United Nations Guiding Principles and Human Rights. We do not allow any children under the age of 15 years in our entire supply chain, and young workers (aged 15-18) are only permitted in the supply chain if performing light, non-hazardous work under supervision.

Our main mitigating factor for reducing the risk of child labour the elimination of processes that pose high risk from our supply chain, as these processes are usually also detrimental to the environment and the effective development of a waste management industry.

Our full child labour policy can be read here.


Closing the Loop adopted an anti-corruption and bribery policy to prevent and detect any form of bribery or corruption. Reducing corruption is at the heart of the realisation of the Sustainable Development Goals; SDG 16 includes commitments to fight corruption, increase transparency, tackle illicit financial flows and improve access to information, and we fully support that.

CTL’s full Anti-Corruption & Bribery policy can be found in the General Business Principles.

Partnerships & Collaboration

We believe that collaboration and partnership is key in doing business in a responsible and proper manner. We therefore seek out useful and effective partnerships and strive to take an active role in these partnerships.

Dutch Gold Sector IRBC Agreement

In a joint effort, parties to the IRBC Agreement are working towards a responsible gold value chain and reduced adverse human rights impacts and environmental impacts.

More information about the agreement can be found on the official website.


Closing the Loop’s Privacy Statement can be read here.