Corporate Governance

Closing the Loop strives to be an example to the IT sector in all regions of the world. We run our business on some key principles and standards. Our governance documentation lays out the industry and other standards with which we comply.

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 and adhere 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 that applies to 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 (see the Grievance Policy document). It includes how to file a grievance as well as what someone can expect after filing such a grievance.

Child Labor

Closing the Loop is active on a continent that is known to have high risks of child labor. For this reason, we have adopted a specific policy for child labor 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 we 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 on Business and Human Rights. We do not allow any children under the age of 15 years to work anywhere in our supply chain, and young workers (aged 15–18) are only permitted in the supply chain if performing light, non-hazardous work under supervision.

Processes that are at high risk of using child labor are usually also detrimental to the environment and impede the effective development of the whole waste management industry, so we work to eliminate them.

Our full child labor policy is here.


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

CTL’s full Anticorruption and Bribery policy is published in the General Business Principles.

Supply Chain Due Diligence

All policies and procedures Closing the Loop adopts relate to the supply chain, and therefore can be seen as part of the overall management system supporting the due diligence efforts on the supply chain. In addition to this, as part of the Dutch Gold Sector IRBC agreement, and in line with recommendations from OECD, Closing the Loop aims to publish a Supply Chain Due Diligence Report every year. These reports can be found through the links below:

2017 - 2018 Report

2018 - 2020 Report

2020 - 2021 Report

2021 - 2022 Report

Partnerships & Collaboration

We believe that collaboration and partnership are key to 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 website.

Terms & Privacy

Closing the Loop’s Privacy Statement is here.

Closing the Loop's General Sales Terms & Conditions can be downloaded here.