Introduction
NetZero is a global company specializing in the long-term removal of carbon dioxide from the atmosphere. To do so, we turn crop residues into biochar, a very stable form of carbon then used as a soil amendment in agriculture. NetZero's mission is to bring biochar at scale in the tropics, with the greater purpose of helping build a more sustainable world.
At its core, sustainability is about not abusing systems. Corruption (abusing a position for private gain, with or without bribery), money laundering (concealing the illicit nature of funds) and financing of terrorism (providing resources to armed terror groups) are therefore structurally incompatible with NetZero's mission, in addition to being illegal in all jurisdictions.
This Policy formalises NetZero's commitment to do business with integrity by actively detecting, preventing, and responding to corruption, money laundering, and terrorism financing through clear, practical, and enforceable rules.
Statements and Directives
Core principle: refuse and notify. When faced with any situation that may reasonably indicate corruption, bribery, money laundering, or financing of terrorism, you must refuse and notify in accordance with the instructions below. When in doubt, always refuse and notify.
You must always refuse any request, instruction, arrangement, threat, or similar situation — whether direct or indirect, and whether or not it involves money or favours of any kind — that may result in:
- undue facilitation of government or regulatory processes involving NetZero;
- improper gifts, hospitality, benefits, or advantages offered or received in connection with NetZero's activities, whether involving public officials or private parties;
- circumvention or breach of NetZero's procurement, hiring, or contracting rules;
- abnormal, opaque, unexplained, or unusually structured financial transactions involving NetZero;
- concealment or misrepresentation of conflicts of interest towards NetZero;
- falsification, omission, or improper reporting of information relevant to NetZero's activities;
- financial donations, sponsorships, or contributions by NetZero not aligned with approved charitable or research purposes;
- provision of any financial, intellectual, or material contributions to terrorist groups.
These rules are absolute and apply regardless of local customs, practices, or expectations. They apply to all NetZero employees, officers, directors, and any third party acting for or on behalf of NetZero, including contractors, agents, and intermediaries.
You must immediately notify:
- your direct NetZero supervisor;
- another NetZero representative in a higher position, including outside of your department;
- NetZero's Compliance Officer (the current Compliance Officer is Olivier Reinaud); or
- if needed, use instead NetZero's anonymous whistleblowing platform (link: netzero.green/whistleblowing).
Notification is mandatory:
- whether the situation involves you or any other person;
- whether or not a transaction or favour ultimately occurred; and
- even if the situation was resolved by refusal.
Failure to notify a situation that reasonably falls under this Policy constitutes a breach of this Policy and may result in disciplinary measures, up to and including termination of employment or contract and referral to relevant authorities.
NetZero strictly prohibits any form of retaliation against notifications made in good faith.
Deployment and Training
NetZero’s ESG Committee shall appoint a Compliance Officer who shall be in charge of managing business integrity topics.
This Policy shall be implemented through dedicated deployment standards, which shall include processes and tools designed to structurally reduce the risk of corruption, money laundering, and the financing of terrorism. Role-appropriate training shall be provided for all staff and relevant third parties.
The Policy shall be considered inseparable from the Conflict of Interest Policy and shall be reviewed periodically to ensure its objectives are met.