Code of Conduct


Circle to Zero Pty Ltd is committed to conducting business in an ethical, responsible, and transparent manner that upholds human rights and promotes sustainability. The purpose of this Code of Conduct is to provide guidance to our employees, suppliers, and other stakeholders on the principles and standards we expect them to adhere to in their daily work.

Compliance with Laws and Regulations

All employees, suppliers, and stakeholders must comply with all applicable laws, regulations, and industry standards. This includes, but is not limited to, compliance with labor laws, environmental regulations, anti-corruption legislation, and the Modern Slavery Act 2018.

Respect for Human Rights

We are committed to respecting and promoting human rights in all aspects of our business. This includes:

  • Providing fair wages, reasonable working hours, and safe working conditions for all employees.
  • Ensuring equal opportunities for all employees, regardless of their race, color, religion, gender, sexual orientation, age, disability, or nationality.
  • Prohibiting any form of forced labor, child labor, or human trafficking in our operations and supply chain.

Ethical Sourcing

We expect our suppliers to uphold the same high standards of ethical sourcing as we do. Our suppliers must:

  • Comply with all applicable laws, regulations, and industry standards.
  • Treat their employees fairly and with respect.
  • Protect the environment and minimise any negative impacts on local communities.

Environmental Sustainability

We are committed to reducing our environmental footprint and promoting sustainable practices in our operations and supply chain. This includes:

  • Minimising waste, energy consumption, and greenhouse gas emissions.
  • Implementing environmentally responsible sourcing practices.
  • Encouraging our employees, suppliers, and stakeholders to adopt sustainable practices in their own operations.

Anti-Corruption and Bribery

Circle to Zero Pty Ltd has a zero-tolerance policy towards corruption and bribery. All employees, suppliers, and stakeholders must:

  • Not offer, give, request, or accept any form of bribe, kickback, or other improper payment.
  • Act in a transparent and accountable manner in all business dealings.
  • Report any suspected incidents of corruption or bribery through our whistleblowing channel.

Conflicts of Interest

All employees must act in the best interests of Circle to Zero Pty Ltd and avoid any situation that may create a conflict of interest or the appearance of a conflict of interest. Employees must disclose any potential conflicts of interest to their supervisor or the company's management.

Confidentiality and Data Protection

All employees, suppliers, and stakeholders must protect the confidentiality of company information and respect the privacy of individuals. This includes:

  • Not disclosing confidential information to unauthorised parties.
  • Safeguarding personal data and complying with applicable data protection laws and regulations.
  • Reporting any suspected data breaches or security incidents.


We encourage employees and stakeholders to report any concerns or suspected violations of this Code of Conduct through our confidential whistleblowing channel. We are committed to protecting whistleblowers from retaliation and ensuring that all reports are thoroughly investigated and addressed.

Compliance and Enforcement

All employees, suppliers, and stakeholders are expected to comply with this Code of Conduct. Failure to do so may result in disciplinary action, up to and including termination of employment or termination of the business relationship.

Circle to Zero Pty Ltd is committed to regularly reviewing and updating this Code of Conduct to ensure its continued relevance and effectiveness in promoting ethical business practices and upholding human rights