PLASTX POLICIES

Code of Ethics

CODE OF ETHICS STATEMENT

Updated November 2023

STATEMENT

PlastX is founded on principles of social responsibility, mutual trust, and integrity.

We believe that the way we conduct ourselves is fundamental to the success of the business, and central to our social obligations.

This Code of Ethics Statement is the over-arching policy that informs the way we transact with business entities, governments, and individuals on a day-to-day basis.

Following are the principles that guide the behaviours expected at all times from PlastX directors, managers, staff, and business partners:

Honesty – to observe the law (including federal, regional, provincial, and state laws) at all times; to demonstrate correctness in all business transactions

Integrity – to be trustworthy, and to always follow through on commitments

Respect – to demonstrate respect for human dignity, acceptance of religious and/or cultural traditions, and tolerance of personal choices

Fairness – to eliminate inequities in the workplace, and to deal justly with violations

Accountability – to accept responsibility, and to visibly uphold compliance standards.

More detail can be found in the PlastX suite of Policies. If you have any questions or concerns, please contact PlastX Chief Operations Officer, Gillian Hyde.

Download the PlastX Code of Ethics Statement

HUMAN RIGHTS POLICY

Updated November 2023

This policy applies to all PlastX personnel, our in-country partners, and any other third-party representatives acting for or on behalf of PlastX.

SUMMARY

PlastX is founded on principles of social responsibility, mutual trust, and integrity. Respect for – and the promotion of – Human Rights is central to our business ethos and our operational activities.

In accordance with the UN Guiding Principles on Business and Human Rights, we commit to upholding all internationally recognised human rights standards, including those enshrined in the International Bill of Rights, and the International Labour Organization’s 1998 Declaration on Fundamental Principles and Rights at Work.

While compliance with the ILO’s core labour standards (the elimination of all forms of forced or compulsory labour; the abolition of child labour; freedom of association and recognition of the right to collective bargaining; the elimination of discrimination in employment and occupation; and equal remuneration for work of equal value) is a minimum mandate for us, we believe our main responsibilities lie in the following critical areas:

the prevention of child exploitation
the establishment of equal and non-discriminatory opportunities; and
the provision of dignified work, with fair and just conditions for workers.

We use due diligence to identify and prevent human rights risks to people in our business and supply chain. If we identify adverse human rights impacts resulting from our business activities, we will provide fair and equitable remediation.

Our in-country partners are engaged based on their social justice and human rights track records. If any in-country partner fails to support human rights in the communities in which we operate, PlastX will take steps to remedy - including the possible dissolution of the commercial relationship.

It is our stated intention to proactively make a positive contribution to the communities in which we work.

Child Labour

Wheresoever in the world we operate, children below legal working age for that country are prohibited from registering – and therefore from working – as PlastX Collectors. This policy is supported by our internal processes and the PlastX technology, which provides photo ID, name and age of all registered collectors - verified and audited by our in-country partners.

Just and Favourable Conditions

PlastX employees and associates – and in particular, PlastX Collectors, will be treated with dignity and, in accordance with PlastX’s policy, in a work environment free of all forms of abuse or harassment, whether physical, verbal or psychological.

Non-Discrimination/ Equality of Opportunity

We will treat individuals justly. We will recruit, train and compensate individuals according to their ability to meet the standards of their role. We will not discriminate on the basis of race, gender, religion, age, marital status, sexual orientation, or any other ‘defining’ factor.

Community and Stakeholder Engagement

In-country partners are our direct link to the communities in which we work. We maintain strong relationships with our partners, and encourage social dialogue in the community, through frequent, frank communication, and by listening and responding to concerns. We ensure stakeholder alignment through regular discussions with as Government, regulators, community partners, trade associations as well as environmental, human rights and welfare groups.

The Plastics Circle (PlastX’s parent company) is a WEP (Women’s Empowerment Principles) signatory: https://www.weps.org/company/plastics-circle

This policy was developed at senior level: overseen and approved by PlastX’s Directors including the Chief Executive Officer.

If you have any questions, or would like to confidentially report a potential human rights violation, please contact PlastX Chief Operations Officer, Gillian Hyde.

Download the PlastX Human Rights Policy

Human Righs Policy

Anti Bribery Policy

ANTI BRIBERY POLICY

Updated November 2023

SUMMARY

PlastX is founded on principles of social responsibility, trust, and integrity. We are deeply committed to the highest ethical standards, and the scrupulous conduct of our business.

As a result, PlastX expressly prohibits all forms of bribery and corruption.

This Policy prohibits bribery (defined as the offer, payment or provision of a benefit to any person or entity in order to induce or reward the improper performance of an activity connected with the business) of government officials or private sector individuals or entities wheresoever we operate.

A violation of this Policy, or of PlastX’s Code of Business Ethics could result in disciplinary actions including, but not limited to, termination of employment, or, in the case of our in-country partners, dissolution of the commercial relationship.

It is therefore vital that employees and in-country partners not only understand and appreciate the importance of this Policy, but also comply with it in their daily work. If you have any questions about this Policy or applicable Anti-Bribery laws generally, please contact PlastX Chief Operations Officer, Gillian Hyde.

Purpose & Goals

This Policy is intended to outline the Business’ risks related to bribery and corruption, to highlight your responsibilities under both the relevant anti-corruption laws and Company policies, and to provide you with the tools and support necessary to identify and combat those anti-corruption risks.

Risks and/or consequences of non-compliance

Any violation of relevant anti-corruption laws can lead to civil and criminal penalties and reputational damage to PlastX. Employees or in-country partners who violate these laws may face severe civil and criminal penalties, including incarceration. The prohibition against bribery is incorporated into our Code of Business Conduct. Thus, a violation of this Policy may also result in disciplinary actions including, but not limited to, termination of employment or dissolution of the commercial relationship.

Scope and Range of application

PlastX expects all directors, employees, in-country partners and third parties working on its behalf to refrain from engaging in any form of bribery or corruption, irrespective of citizenship, domicile, or location.

POLICY DETAILS

Applicable Laws –

PlastX employees and in-country partners must abide by all applicable Australian Anti-Bribery laws, and the local laws in every country in which we operate (including federal, regional, provincial, and state laws). These laws generally prohibit both bribery of government officials and private sector (commercial) bribery. Additionally, under Australian law, it is an offence to alter, destroy or conceal any accounting document with the intention to conceal or disguise such activity.

Prohibition of Bribery -

Government Bribery - PlastX and its employees and partners are prohibited from giving, promising, offering, or authorising payment of anything of value to any government official to obtain or retain business, to secure some other improper advantage, or to improperly influence a government official’s actions. Additionally, PlastX associates must also avoid the appearance of improper interactions with government officials.

Commercial Bribery -

In addition to the prohibitions on bribing government officials, PlastX prohibits employees and in-country partners from offering or providing corrupt payments and other advantages to - or accepting the same - from private (non-government) persons and entities. These “kickbacks” constitute commercial bribery, and are prohibited.

Facilitation Payments –

Facilitation payments refer to small payments to government officials to expedite or facilitate non-discretionary actions or services, such as obtaining an ordinary license or business permit, processing government papers such as visas, customs clearance, or providing telephone, power or water services. While Facilitation Payments remain defensible in some circumstances under Australian law, generally such payments are prohibited by this Policy, except for a very limited set of circumstances - for which prior written approval must be obtained*.

Providing Items of Value to Government Officials –

Government Dealings Approval - Before providing an item of value to any government official or entity, employees/partners must first obtain prior written approval*. Items of value provided to government officials must also be accounted for.

Gifts, Meals, Travel and Entertainment (‘GME’) - It is never permissible to provide gifts, meals, travel, or entertainment to anyone (government officials or commercial partners) in exchange for any improper favour or benefit. Additionally, gifts of cash or cash equivalents, such as gift cards, are never permissible. Prior approval* is required before providing any GME to a government official or entity.

Donations - It is never permissible to provide a donation to improperly influence a government official, or in exchange for any improper favour or benefit. It may, however, be permissible to make donations directly to a government agency (rather than to an individual government official) as part of a charitable activity. Prior approval* is required before making such a donation.

Promoting, Demonstrating, or Explaining Products - It is never permissible to direct promotional expenses or activities to a government official to improperly influence them, or in exchange for any improper favour or benefit. In some cases, however, it may be appropriate to direct such expenses to a government official or entity in order to promote, demonstrate, or explain the Company’s products and services. Before doing so, Company associates must seek prior approval*.

Hiring or Engaging Government Officials - It is never permissible to hire or engage a government official, or their immediate family members, to improperly influence the official - or in exchange for any improper favour or benefit. Note that before hiring a government official (or relative thereof) Company associates must first receive approval*.

Third-Party Management -

Applicability to Third Parties – In-country partners, consultants, or any other third-party representatives acting for or on behalf of PlastX are prohibited from making corrupt payments on the Company’s behalf. This prohibition also applies to subcontractors hired by third parties to perform work on the Company’s behalf. Any and all payments made to third parties, including commissions, compensation, reimbursements, must be customary and reasonable in relation to the services provided and accurately documented in the Company’s books and records. These payments must not be made in cash without prior written approval*; or to bank accounts that are not in the third party’s name, unless otherwise approved in advance and in writing*.

Training - PlastX Managers and in-country partner managers are required to undergo in-person or online Anti-Bribery training prior to commencing operations.

For information on applicable training, contact PlastX Chief Operations Officer, Gillian Hyde.

Auditing - PlastX will conduct periodic internal audits of relevant Company operations to help ensure the Company’s continued compliance with applicable Anti-Bribery laws and this Policy. It is the duty of all employees to cooperate with—and never interfere with or obstruct—such audit activities or Company investigations.

Reporting Violations - If you observe conduct that may violate this Policy, contact PlastX Chief Operations Officer, Gillian Hyde. Suspected violations will be reviewed and investigated as appropriate and may lead to disciplinary action. Any such reporting will be treated as confidential to the extent permitted by law. The Company strictly prohibits retaliation for good faith reports of suspected misconduct. Failure to report a violation of this Policy constitutes an independent violation of this Policy and is subject to discipline, up to and including termination of employment.

For further information, or to request approval for any payments, gifts, travel, meals or entertainment, please contact PlastX Chief Operations Officer, Gillian Hyde.

Download the PlastX Anti Bribery Policy

Privacy

Updated November 2023

This Privacy Policy explains how we use the personal data we collect from you, offline or online, including through our website (Site). In this Privacy Policy ‘Company’, ‘we’, ‘us’ or ‘our’ means PlastX Pty Ltd A.B.N. 24 627 003 810

What data do we collect?

We collect the following data:
Personal identification information (Name, email address, phone number, etc.)
Your preferences, opinions, or information you provide to us
Your use of our products and services
Internet protocol (IP) address used to connect your computer to the Internet
computer and connection information and purchase history.

WHY do we collect personal information?

To provide and operate our services
To be able to contact our Visitors and Users with general or personalized service-related notices and promotional messages
To create aggregated statistical data and other aggregated and/or inferred Non-personal Information, which we or our business partners may use to provide and improve our respective services;
To comply with any applicable laws and regulations.

How do we collect your data?

You directly provide us with most of the data we collect. We collect data and process data when you:

Register or order, online or in person, for any of our products or services
Use or view any of our websites via your browser's cookies

In addition, we may use software tools to measure and collect session information, including page response times, length of visits to certain pages, page interaction information, and methods used to browse away from the page.

How will we use your data?

We may use your data to:

Process your order and fulfil the services and products you selected
Contact and communicate with you, including keeping you informed about new products and services
Email you with special offers on other products and services we think you might like
Improve our Site, our services and product offerings

When we process your order, we may send your data to, and also use the resulting information from:

credit reference agencies to prevent fraudulent purchases
marketing applications to manage mailings, analyse data and fulfil the service or deliver the product you selected.

How do we store your data?

We securely store your data in the servers of reputable data service providers, including HubSpot, Zoho, Microsoft Azure, and AWS (CRM & Mailings), e-SurveyPro (Surveys), Dropbox (Record keeping), and Wix (Websites).

We will keep your personal information and transaction data for a minimum of 9 years after your last transaction with us. Once this time period has expired, we will delete your digital data.

Marketing

We would like to send you information about products, news, and services of ours that we think you might like. If you have agreed to receive marketing, you may opt out at any time.

You have the right at any time to stop us from contacting you for marketing purposes or giving your data to others in the Company group.

If you no longer wish to be contacted for marketing purposes, please click here.

What are your data protection rights?

We would like to make sure you are fully aware of all of your data protection rights.

Every user is entitled to the following:

The right to access - You have the right to request us for copies of your personal data. We may charge you a small fee for this service.
The right to rectification - You have the right to request that we correct any information you believe is inaccurate. You also have the right to request us to complete information you believe is incomplete.
The right to erasure - You have the right to request that we erase your personal data, under certain conditions.
The right to restrict processing - You have the right to request that we restrict the processing of your personal data, under certain conditions.
The right to object to processing - You have the right to object to us processing your personal data, under certain conditions.
The right to data portability - You have the right to request that we transfer the data that we have collected to another organisation, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you.

If you would like to exercise any of these rights, please contact us here.

What are cookies?

Cookies are text files placed on your computer to collect standard Internet log information and visitor behaviour information. When you visit our websites, we may collect information from you automatically through cookies or similar technology.

For further information, visit allaboutcookies.org.

How do we use cookies?

We use cookies in a range of ways to improve your experience on our website, including:

Keeping you signed in
Understanding how you use our website
Ensuring our platform is secure and safe to use

What types of cookies do we use?

There are a number of different types of cookies, however, our website uses:

Functionality – We use these cookies so that we recognise you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.
Advertising – We use these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address. We sometimes share some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website.

How to manage your cookies

You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.

Privacy policies of other websites

Our website contains links to other websites. Our privacy policy applies only to our website, so if you click on a link to another website, you should read their privacy policy.

Changes to our privacy policy

We keep our privacy policy under regular review and place any updates on this web page. This privacy policy was last updated on 14 September 2022.

How to contact us

If you have any questions about our privacy policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us. Email us here.

How to contact the appropriate authorities

If you have complained to us, but you feel that we have not addressed your concerns in a satisfactory manner, you may lodge an online complaint with the Information Commissioner's Office here or Phone: +61 2 9284 9749, or 1300 363 992 from within Australia.

Updated: 14 September, 2022

Terms of Use

Updated November 2023

This website (Site) is operated by PlastX Pty Ltd ABN 24 627 003 810 (we, our or us). It is available at: www.PlastX.co and may be available through other addresses or channels.

Consent: By accessing and/or using our Site, you agree to these terms of use and our Privacy Policy (available on our Site) (Terms). Please read these Terms carefully and immediately cease using our Site if you do not agree to them.

Variations: We may, at any time and at our discretion, vary these Terms by publishing the varied terms on our Site. We recommend you check our Site regularly to ensure you are aware of our current terms. Materials and information on this Site (Content) are subject to change without notice. We do not undertake to keep our Site up-to-date and we are not liable if any Content is inaccurate or out-of-date.

Licence to use our Site: We grant you a non-exclusive, royalty-free, revocable, worldwide, non-transferable licence to use our Site in accordance with these Terms. All other uses are prohibited without our prior written consent.

Prohibited conduct: You must not do or attempt to do anything: that is unlawful; prohibited by any laws applicable to our Site; which we would consider inappropriate; or which might bring us or our Site into disrepute, including (without limitation):

anything that would constitute a breach of an individual’s privacy (including uploading private or personal information without an individual's consent) or any other legal rights;
using our Site to defame, harass, threaten, menace or offend any person;
interfering with any user using our Site;
tampering with or modifying our Site, knowingly transmitting viruses or other disabling features, or damaging or interfering with our Site, including (without limitation) using trojan horses, viruses or piracy or programming routines that may damage or interfere with our Site;
using our Site to send unsolicited email messages; or
facilitating or assisting a third party to do any of the above acts.

Exclusion of competitors: You are prohibited from using our Site, including the Content, in any way that competes with our business.

Information: The Content is not comprehensive and is for general information purposes only. It does not take into account your specific needs, objectives or circumstances, and it is not advice. While we use reasonable attempts to ensure the accuracy and completeness of the Content, we make no representation or warranty in relation to it, to the maximum extent permitted by law.

Intellectual Property rights: Unless otherwise indicated, we own or licence all rights, title and interest (including intellectual property rights) in our Site and all of the Content. Your use of our Site and your use of and access to any Content does not grant or transfer to you any rights, title or interest in relation to our Site or the Content. You must not:

copy or use, in whole or in part, any Content;
reproduce, retransmit, distribute, disseminate, sell, publish, broadcast or circulate any Content to any third party; or
breach any intellectual property rights connected with our Site or the Content, including (without limitation) altering or modifying any of the Content, causing any of the Content to be framed or embedded in another website or platform, or creating derivative works from the Content.

User Content: You may be permitted to post, upload, publish, submit or transmit relevant information and content (User Content) on our Site. By making available any User Content on or through our Site, you grant to us a worldwide, irrevocable, perpetual, non-exclusive, transferable, royalty-free licence to use the User Content, with the right to use, view, copy, adapt, modify, distribute, license, sell, transfer, communicate, publicly display, publicly perform, transmit, stream, broadcast, access, or otherwise exploit such User Content on, through or by means of our Site.

You agree that you are solely responsible for all User Content that you make available on or through our Site. You represent and warrant that:

you are either the sole and exclusive owner of all User Content or you have all rights, licences, consents and releases that are necessary to grant to us the rights in such User Content (as contemplated by these Terms); and
neither the User Content nor the posting, uploading, publication, submission or transmission of the User Content or our use of the User Content on, through or by means of our Site will infringe, misappropriate or violate a third party’s intellectual property rights, or rights of publicity or privacy, or result in the violation of any applicable law or regulation.

We do not endorse or approve, and are not responsible for, any User Content. We may, at any time (at our sole discretion), remove any User Content.

Third party sites: Our Site may contain links to websites operated by third parties. Unless expressly stated otherwise, we do not control, endorse or approve, and are not responsible for, the content on those websites. You should make your own investigations with respect to the suitability of those websites.

Discontinuance: We may, at any time and without notice to you, discontinue our Site, in whole or in part. We may also exclude any person from using our Site, at any time and at our sole discretion. We are not responsible for any Liability you may suffer arising from or in connection with any such discontinuance or exclusion.

Warranties and disclaimers: To the maximum extent permitted by law, we make no representations or warranties about our Site or the Content, including (without limitation) that:

they are complete, accurate, reliable, up-to-date and suitable for any particular purpose;
access will be uninterrupted, error-free or free from viruses; or
our Site will be secure.

You read, use and act on our Site and the Content at your own risk.

Limitation of liability: To the maximum extent permitted by law, we are not responsible for any loss, damage or expense, howsoever arising, whether direct or indirect and/or whether present, unascertained, future or contingent (Liability) suffered by you or any third party, arising from or in connection with your use of our Site and/or the Content and/or any inaccessibility of, interruption to or outage of our Site and/or any loss or corruption of data and/or the fact that the Content is incorrect, incomplete or out-of-date.

Indemnity: To the maximum extent permitted by law, you must indemnify us, and hold us harmless, against any Liability suffered or incurred by us arising from or in connection with your use of our Site or any breach of these Terms or any applicable laws by you. This indemnity is a continuing obligation, independent from the other obligations under these Terms, and continues after these Terms end. It is not necessary for us to suffer or incur any Liability before enforcing a right of indemnity under these Terms.

Termination: These Terms are effective until terminated by us, which we may do at any time and without notice to you. In the event of termination, all restrictions imposed on you by these Terms and limitations of liability set out in these Terms will survive.

Disputes: In the event of any dispute arising from, or in connection with, these Terms (Dispute), the party claiming there is a Dispute must give written notice to the other party setting out the details of the Dispute and proposing a resolution. Within 7 days after receiving the notice, the parties must, by their senior executives or senior managers (who have the authority to reach a resolution on behalf of the party), meet at least once to attempt to resolve the Dispute or agree on the method of resolving the Dispute by other means, in good faith. All aspects of every such conference, except the fact of the occurrence of the conference, will be privileged. If the parties do not resolve the Dispute, or (if the Dispute is not resolved) agree on an alternate method to resolve the Dispute, within 21 days after receipt of the notice, the Dispute may be referred by either party (by notice in writing to the other party) to litigation.

Severance: If a provision of these Terms is held to be void, invalid, illegal or unenforceable, that provision must be read down as narrowly as necessary to allow it to be valid or enforceable. If it is not possible to read down a provision (in whole or in part), that provision (or that part of that provision) is severed from these Terms without affecting the validity or enforceability of the remainder of that provision or the other provisions in these Terms.

Jurisdiction: Your use of our Site and these Terms are governed by the laws of New South Wales. You irrevocably and unconditionally submit to the exclusive jurisdiction of the courts operating in New South Wales and any courts entitled to hear appeals from those courts and waive any right to object to proceedings being brought in those courts.

Our Site may be accessed throughout Australia and overseas. We make no representation that our Site complies with the laws (including intellectual property laws) of any country outside Australia. If you access our Site from outside Australia, you do so at your own risk and are responsible for complying with the laws of the jurisdiction where you access our Site.

For any questions and notices, please contact us at:

PlastX Pty Ltd ABN 24 627 003 810

Email: hello@plastx.co

Tel: +61 409 860 506

Updated 14 September, 2022