Introduction
This Code of Conduct sets out the fundamental principles that guide the activities, decisions, working relationships and business practices of Circular Covers B.V. (“Circular Covers”). It reflects our commitment to ethical conduct, safe working practices, environmental responsibility, legal compliance and respect for human and labor rights.
This Code applies to all employees, self-employed professionals and other persons working for or on behalf of Circular Covers. Relevant principles of this Code also apply to subcontractors, suppliers and other business partners where appropriate to their activities and relationship with Circular Covers.
Compliance with applicable laws and regulations is a minimum requirement. Circular Covers also seeks to conduct its activities in line with internationally recognized principles and standards, including relevant International Labour Organization (ILO) Conventions and the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct.
Everyone working for or with Circular Covers is expected to act responsibly, professionally and with integrity and to contribute to maintaining the standards described in this Code.
1. Health, Safety, and Environment
Our motto — “We work together and we work safe” — reflects our commitment to protecting the health, safety and well-being of everyone involved in our activities, including employees, self-employed professionals, subcontractors, visitors and other persons who may be affected by our work.
Circular Covers strives to provide and maintain a safe, healthy and supportive working environment and to prevent injuries, occupational illness, unsafe situations and unnecessary environmental impact.
Everyone working for or on behalf of Circular Covers is expected to comply with applicable health, safety and environmental requirements, site rules, risk control measures and reasonable safety instructions. Appropriate personal protective equipment must be used where required.
No commercial, operational or scheduling objective takes priority over the safe execution of work. Everyone has both the right and the responsibility to stop or report work that they reasonably believe cannot be performed safely. Safety concerns, incidents, near misses and hazardous conditions must be reported promptly so that appropriate action can be taken.
Circular Covers promotes cooperation, awareness and continuous improvement in health, safety and environmental performance. Everyone is expected to take responsibility not only for their own safety, but also to contribute to the safety and well-being of others.
2. Integrity and Anti-Corruption
Circular Covers conducts business honestly, transparently and with integrity and does not tolerate bribery, corruption, fraud or other improper business practices.
Employees, self-employed professionals and persons acting for or on behalf of Circular Covers must not directly or indirectly offer, promise, request, give or accept bribes, kickbacks or other improper advantages.
Gifts, hospitality and other business courtesies may only be offered or accepted where they are reasonable, proportionate, lawful and appropriate in the circumstances and cannot reasonably be perceived as improperly influencing a business decision.
Any suspected corruption, fraud or other unethical conduct must be reported. Where there is uncertainty about whether particular conduct is appropriate, guidance should be sought from the Managing Director before proceeding.
3. Conflict of Interest
Circular Covers treats employees, self-employed professionals, subcontractors, clients, suppliers and other business partners fairly and seeks to maintain relationships based on honesty, transparency and integrity.
Personal, financial or other interests must not improperly influence business decisions made on behalf of Circular Covers.
Any actual, potential or reasonably perceived conflict between personal interests and the interests of Circular Covers must be disclosed promptly so that it can be assessed and appropriately managed.
Persons working for or on behalf of Circular Covers must not misuse their position, company information, business opportunities or relationships for improper personal benefit.
Public statements, external communications or representations made on behalf of Circular Covers must be appropriately authorized. Where authorization is required, approval must be obtained from the Managing Director or another person expressly authorized for that purpose.
4. Employment and Labor Rights
Circular Covers respects internationally recognized human and labor rights and is committed to fair, lawful and responsible working relationships.
Employment and contracting arrangements must be transparent, lawful and appropriate to the manner in which the work is actually performed. Contractual descriptions or classifications must accurately reflect the practical working relationship.
Illegal child labor, forced labor, modern slavery, human trafficking and any other form of involuntary or exploitative labor are strictly prohibited. Young persons may only perform work where permitted by applicable law and under conditions appropriate to their age, safety, education and development.
Everyone performing work for or on behalf of Circular Covers must be treated with dignity and respect. Discrimination, harassment, bullying, intimidation, violence, retaliation and other inappropriate or abusive conduct are not accepted.
Circular Covers respects the lawful freedom of individuals to associate, organize and participate in worker organizations and collective representation.
Fair and Responsible Remuneration
Circular Covers is committed to fair and responsible remuneration throughout its operations and supply chain.
Employees, self-employed professionals and personnel engaged through subcontractors or other intermediaries must be compensated in accordance with applicable laws and regulations and in a manner consistent with responsible employment and contracting practices.
Where personnel are supplied through subcontractors or other intermediaries, commercial margins or fees must not result in unlawful, exploitative or unreasonably low remuneration for the individuals actually performing the work.
Circular Covers expects subcontractors and other intermediaries to maintain transparent and responsible employment, contracting and remuneration practices and may request reasonable information or evidence necessary to assess compliance with these principles.
Responsible Contracting
Circular Covers does not accept employment or contracting arrangements that circumvent or are inconsistent with applicable employment, tax, social security or labor legislation.
All parties are expected to ensure that the contractual arrangement reflects the manner in which the work is actually performed. Working relationships should be reviewed where relevant circumstances materially change.
Self-employed professionals must be engaged in a manner consistent with genuine independent contracting. The designation given to a contractual relationship does not by itself determine its legal nature.
Speak Up and Protection Against Retaliation
Employees, self-employed professionals and subcontractors are encouraged to raise employment-related, ethical, safety or other compliance concerns as soon as reasonably possible.
Concerns may be reported directly to the Managing Director or, where this would not be appropriate, through another reporting channel designated or made available by Circular Covers.
Reports will be taken seriously and handled respectfully and, where reasonably possible, confidentially and with due regard for the rights of all persons involved.
Circular Covers does not tolerate retaliation against anyone who raises a genuine concern in good faith or participates in an investigation or review.
Circular Covers promotes an open and supportive “speak up” culture in which concerns can be raised without fear of inappropriate negative consequences.
5. Material Responsibility, , Circularity and Recycling
Circularity is at the heart of Circular Covers’ business philosophy and product development.
Circular Covers seeks to use materials and resources responsibly, minimize waste and promote reuse, repair and recycling throughout the lifecycle of its products and activities.
Materials are selected with consideration for technical performance, durability, safety, environmental impact, responsible sourcing and their potential for reuse or recycling. Where reasonably practicable, Circular Covers seeks to reduce the environmental impact associated with the materials and processes used in its products.
The principles of Rethink, Reuse, Repair and Recycle form the foundation of our approach to circularity.
Reuse and design for longevity are integral to our product philosophy. Through continuous development and innovation, Circular Covers aims to extend product lifecycles, facilitate refurbishment and reuse, reduce waste and landfill disposal and conserve materials and resources through durable and adaptable design.
Environmental considerations should, where relevant, be taken into account in purchasing, design, production, logistics, operations and end-of-life decisions.
6. Product Quality and Innovation
Circular Covers is committed to developing and supplying high-quality, safe, reliable and reusable products.
Products and services must meet applicable legal, regulatory, contractual and technical requirements. Circular Covers seeks to apply recognized industry standards where relevant and continuously improve the quality, safety, sustainability and performance of its products, services and processes.
Quality is a shared responsibility. Employees, self-employed professionals and subcontractors involved in our activities are encouraged to identify improvements, report quality concerns and contribute ideas that can improve products, processes, safety, efficiency or sustainability.
Circular Covers values practical experience, technical expertise, collaboration and innovation and seeks to incorporate lessons learned into future products and activities.
7. Responsible Use of Facilities and Equipment
Everyone using Circular Covers’ facilities, equipment, vehicles, machinery, tools, systems or other property is expected to act as a responsible custodian.
Company property must be used safely, responsibly and for appropriate purposes and in accordance with applicable instructions, procedures and site requirements.
Equipment may only be operated by persons who are appropriately trained, instructed, qualified or authorized where this is required.
Facilities and equipment must be treated with due care and protected against unnecessary damage, misuse, loss or deterioration. Defects, damage or unsafe conditions that may affect safe or proper use must be reported promptly.
The same standard of care is expected when Circular Covers uses facilities, equipment or property belonging to clients, subcontractors, suppliers or other third parties.
8. Responsible Supply Chain and Oversight of Subcontractors
Circular Covers seeks to work with subcontractors, suppliers and business partners who share its commitment to ethical business conduct, safe working practices, environmental responsibility and respect for human and labor rights.
Subcontractors are expected to comply with the principles of this Code that are relevant to their activities and relationship with Circular Covers and to comply with all applicable laws and regulations.
Circular Covers also encourages subcontractors and suppliers to promote equivalent standards within their own operations and supply chains where reasonably practicable.
Circular Covers may take reasonable and proportionate steps to assess compliance with these principles, including requesting relevant information, documentation or other evidence where appropriate.
Where concerns or non-compliance are identified, Circular Covers will seek appropriate corrective action. Serious, repeated or unresolved violations may affect the continuation of the relevant business relationship.
Circular Covers recognizes that responsible supply chain management requires cooperation, transparency and continuous improvement and will seek to use its influence responsibly and proportionately.
9. Intellectual Property
Intellectual property, technical knowledge and innovation are important assets of Circular Covers.
Circular Covers is committed to identifying, protecting and appropriately securing intellectual property and other intellectual assets developed or used within its activities, including designs, inventions, technical solutions, drawings, models, documentation, trade secrets, know-how, trademarks, copyrights and other proprietary information.
Intellectual property and confidential technical information belonging to Circular Covers may only be used, disclosed, reproduced or transferred where properly authorized.
Circular Covers equally respects the intellectual property rights of clients, suppliers, subcontractors and other third parties. Third-party intellectual property may only be used in accordance with applicable laws, contractual rights, licenses and permissions.
Nothing in this Code alters the ownership of intellectual property as determined by applicable law or contractual arrangements.
10. Confidentiality, Information Security and Personal Data
Confidentiality is fundamental to Circular Covers’ operations and to maintaining the trust of clients, employees, subcontractors, suppliers and other business partners.
Everyone working for or on behalf of Circular Covers is responsible for protecting confidential and commercially sensitive information, including proprietary information, technical data, designs, drawings, pricing, client information, trade secrets, business plans, personal data and other information that is not intended for public disclosure.
Confidential information may only be accessed, used and shared where there is a legitimate business need and appropriate authorization.
Contractual confidentiality obligations and non-disclosure agreements must be respected at all times.
Reasonable measures must be taken to protect information against unauthorized access, loss, disclosure, alteration or misuse. Suspected or actual breaches of confidentiality or information security must be reported promptly.
Personal data must be handled lawfully, fairly and responsibly and only for legitimate purposes, in accordance with applicable data protection and privacy requirements.
Confidentiality obligations continue after employment, engagement or a business relationship ends to the extent required by law or contract.
11. Review, Compliance and Accountability
This Code of Conduct reflects Circular Covers’ continuing commitment to ethical business conduct, health and safety, human and labor rights, environmental responsibility, circularity, quality and transparency.
Everyone to whom this Code applies is expected to understand and comply with the principles relevant to their role and activities and to seek guidance where there is uncertainty.
Failure to comply with this Code may result in appropriate corrective measures and, where warranted, consequences under the applicable employment, contractual, supplier or other business relationship. Any measures taken will be proportionate to the nature and seriousness of the circumstances and subject to applicable law and contractual arrangements.
Nothing in this Code is intended to limit rights or obligations arising under applicable law, employment agreements, commercial contracts or other binding arrangements. Where applicable law imposes a higher or more specific standard, that requirement prevails.
This Code will be reviewed periodically and at least annually where appropriate to ensure that it remains relevant and aligned with applicable laws, recognized standards, Circular Covers’ activities and evolving good practices.
By following these principles, everyone working for or with Circular Covers contributes to a culture of integrity, safety, responsibility, sustainability and mutual respect and supports our objective of building a genuinely circular and responsible business.
Den Helder, 24 September 2026
Circular Covers B.V.
Michiel Kraak
Managing Director
