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.
To protect NetZero’s integrity and stakeholders’ trust, NetZero is committed to identifying and appropriately managing conflicts of interest. A conflict of interest (COI) arises when personal interests (financial, relational, or other external commitments) interfere, can interfere, or appear to interfere with NetZero’s interests. COI often involve family and close relationships: spouses/partners, children, parents, siblings, and their respective spouses. Having a conflict of interest does not necessarily imply wrongdoing, but failing to disclose or manage it appropriately does.
This Policy aims to ensure that conflicts of interest are promptly disclosed to NetZero so that appropriate measures can be taken.
Statements and Directives
Below are a few examples of conflicts of interest:
- Financial interest in (or close relationship with) a supplier, customer, or competitor;
- Outside job/consulting that overlaps with NetZero’s business or working hours;
- Hiring or supervising family members or other close relationships;
- Accepting gifts/hospitality that could influence – or appear to influence – decisions;
- Access to non-public information used for personal gain.
To properly manage COIs, NetZero commits to maintain a dedicated register and to require staff members in decision-making positions to truthfully and comprehensively complete, at least once a year, a COI questionnaire.
NetZero further requires all its employees, directors, contractors, consultants, suppliers, and other third parties acting on behalf of NetZero, to follow the rules below at any point in time when a conflict of interest arises or is perceived:
- If concerning yourself, you must disclose the COI immediately using the dedicated online form at netzero.green/COI. You must also inform your direct NetZero manager or, if they are conflicted, another appropriate manager or the Group’s Compliance Officer. The current Compliance Officer is Olivier Reinaud.
- If concerning someone else, you must report it if the COI is material and not already disclosed; otherwise, reporting is optional but encouraged. Reports shall be submitted through the online form at netzero.green/COI; if anonymity is needed, use NetZero’s whistleblowing platform at netzero.green/whistleblowing.
In case of a doubt, disclose early to avoid any issue – transparency protects both you and NetZero. Concealing a COI or otherwise violating this Policy is considered a major compliance breach that may result in disciplinary action, up to and including termination.
Deployment and Training
This Policy shall be enforced in all countries where NetZero operates, for all applicable stakeholders, through a dedicated deployment standard, which shall include specific definitions, decision-making rules, and other operational provisions regarding COIs.
NetZero’s staff shall be trained on this Policy.
NetZero’s ESG Committee shall appoint a Compliance Officer who shall be in charge of managing conflicts of interest.
The Policy shall be considered inseparable from the Business Integrity Policy and shall be reviewed periodically to ensure its objectives are met.