Third Party Code of Conduct

[Last updated: 1 April 2025]

As we work to fulfil our mission to rid the world’s oceans of plastic, Stichting The Ocean Cleanup (together with each of its affiliates, “The Ocean Cleanup”) is committed to ensuring that every activity we are involved in is performed in a safe, responsible, and sustainable manner.

WHAT WE EXPECT FROM THIRD PARTIES

To help achieve this, this Code of Conduct sets out the standards that apply to all product suppliers, funding partners, donors, sponsors, and service providers (together, “Third Parties”) of The Ocean Cleanup. The Ocean Cleanup expects Third Parties to adhere to this Code of Conduct and to take appropriate steps to ensure that their own supply chains, affiliates, and employees comply. The Ocean Cleanup reviews compliance with the Code of Conduct and has the right to undertake a compliance audit on Third Parties.

Third Parties shall immediately report any actual or threatened non-compliance with the Code of Conduct to The Ocean Cleanup. In the event of such non-compliance, The Ocean Cleanup will work together with Third Parties in support of corrective measures to be undertaken. If a Third Party fails (i) immediately to report non-compliance, or (ii) to comply with such corrective action, The Ocean Cleanup may terminate the relationship with immediate effect.

COMPLIANCE WITH LAWS

The Ocean Cleanup requires Third Parties to comply with all applicable laws and regulations, including the local laws and regulations of all countries outside their home country in which their operations are managed or services are provided. Additionally, Third Parties are expected to comply with the standards set out in this document (which may, in some cases, go beyond applicable legal requirements).

RESPECT FOR HUMAN RIGHTS

The Ocean Cleanup is committed to acting with respect to all human rights. Third Parties shall act in a manner supportive of our commitment in this regard and in compliance with all applicable human rights obligations. We expect Third Parties to take responsibility for avoiding any infringement of human rights on assignments performed for us and in conducting their business in general.

 

CHILD LABOR

Child labor must not be used under any circumstances. Third Parties shall comply with the Convention on the Rights of the Child and must not employ anyone under the age of 15, under the age of completing compulsory education, or under the legal minimum working age for employment, whichever requirement is most restrictive. A risk assessment and monitoring of working conditions, health, and hours of work shall be performed for all persons under the age of 18. All workers under the age of 18 must be protected from
performing work that is likely to be hazardous or that may be harmful to their health, physical, mental, social, spiritual, or moral development.

 

FORCED LABOR, PRISON LABOR, AND TRAFFICKING IN PERSONS

Third Parties must prevent any involvement in all forms of modern slavery, including human trafficking, forced, bonded, or indentured labor, and Third Parties are prohibited from using involuntary prison labor. All work should be voluntary on the part of the employee. Third Parties are expected to provide all employees with a written contract in a language they understand, indicating their rights and responsibilities with regard to wages, working hours, benefits, and other working and employment conditions. Third Parties must not charge fees, recruitment costs, or deposits, directly or indirectly, as a precondition of work to employees. Third Parties must respect the right of workers to terminate their employment after reasonable notice and to receive all owed salary.

 

INTEGRITY & ETHICS

Third Parties are expected to work with integrity, fairness, and accountability in their relationship with The Ocean Cleanup and all aspects of professional conduct. We expect Third Parties to refrain from acting fraudulently, deceiving, making false claims, or allowing others to do so.

 

ANTI-BRIBERY AND CORRUPTION

No form of bribery or corruption is tolerated in our business practices. Third Parties must not offer, promise, make, accept, or agree to accept any improper payments of money or anything of value to government officials, political parties, candidates for public office, or other persons. Third Parties must comply with all applicable laws and regulations that prevent bribery and corruption. With bribery and corruption, we mean, amongst other things, giving or receiving anything of value to or from any person to obtain or retain business, secure an improper advantage, influence decisions, exert undue influence, or any other improper inducements for business or financial gain. This prohibition applies even in locations where such activity may not violate local law.
Third Parties will be intolerant of corrupt activities and have policies and procedures in place to prevent and combat such activities. In addition, we expect Third Parties to promptly report relevant concerns to their contact at The Ocean Cleanup

 

TRADE SANCTIONS AND CUSTOMS REGULATIONS

Third Parties must ensure that their business practices are in accordance with all applicable laws, directives, and regulations governing the import of parts, components, technical data, and services. Third Parties will not conduct business, either directly or indirectly, in countries or with companies and/or individuals who are subject to United Nations, European Union, United States, United Kingdom, and/or otherwise applicable sanctions or embargoes.

 

ANTITRUST AND COMPETITION

Third Parties must not enter into anti-competitive arrangements that fix prices, collude, rig bids, limit supply, or allocate/control markets or other arrangements that restrict competition. They must not exchange current, recent, or future pricing information with competitors. Third Parties shall conduct business in accordance with all applicable competition and anti-trust laws and regulations.

 

CONFLICT OF INTEREST

Third Parties should avoid situations that are, or give the appearance of, an actual or potential conflict of interest in their dealings with The Ocean Cleanup. A conflict of interest is a situation in which a person is in a position to derive personal benefit from actions or decisions made in their official capacity. If a Third Party suspects that a conflict of interest may have (intentionally or accidentally) occurred, the Third Party shall disclose such conflict to The Ocean Cleanup in a timely manner and cooperate in finding a solution.

 

EMPLOYMENT PRACTICES

Employees of The Ocean Cleanup are one of our greatest resources, and we believe they must be treated with respect and dignity. Our Third Parties are expected to uphold the same principles.

 

WAGES AND BENEFITS

Third Parties must provide fair compensation for all employees and workers, apprentices, and contract workers. Third Parties must pay at least the minimum compensation required by local law and provide all legally mandated benefits. If such a statutory minimum wage does not exist or does not meet basic needs, Third Parties should strive to pay employees, as a minimum, enough to satisfy their basic needs. The rights of individuals to join trade unions and participate in collective bargaining must be respected, and employees must be provided with access to adequate reporting channels to seek advice or raise concerns about unethical conduct in the workplace, including opportunities for anonymous reporting. Third Party must take action to prevent, detect, and correct retaliatory actions against employees. Third Parties must comply with applicable laws and regulations on working hours and overtime. Third Parties are prohibited from requiring workers to work more than the maximum hours as set by international standards, including those provided
by the International Labour Organization (ILO).

 

NON-DISCRIMINATION

Working with a diverse group of professionals is one of the strengths of The Ocean Cleanup. We respect individual and cultural diversity and encourage inclusiveness. We award, hire, and promote on the principle of equal chances. We do not discriminate based on (without limitation) race, color, ethnicity, religion, political opinion, social origin, disability, age, sexual orientation, gender, gender identity, or expression, or marital status. We commit to a workplace free of harassment and abuse. We expect the same from our Third Parties.

 

HEALTH AND SAFETY

At The Ocean Cleanup, we are committed to prioritizing the health and safety of all individuals involved in our operations. Third Parties are expected to uphold the same commitment to occupational health and safety, ensuring a safe and healthy working environment for their employees by adhering to the following principles as applicable to the risk level of their operations and type of service:

  • Comply with all applicable health and safety laws, regulations, generally accepted industry standards, and The Ocean Cleanup’s health and safety plans and work instructions, adhering to whichever is more stringent;
  • Establish a comprehensive health and safety management system to identify, assess, and mitigate risks associated with workplace hazards;
  • Provide a safe working environment, including proper maintenance of facilities and equipment, and the provision of necessary personal protective equipment (PPE);
  • Provide regular safety training and education to all employees to ensure they are aware of potential hazards and safe work practices;
  • Report and investigate all incidents, injuries, and near-misses to prevent recurrence.
  • Establish emergency response plans, including procedures for evacuation, medical emergencies, emergency equipment, and natural disaster preparedness;
  • Ensure the continuous improvement of their health and safety performance through
    regular audits, inspections, feedback mechanisms, and maintenance of records.

 

ENVIRONMENT

Protecting the environment is the main driver behind our work. We therefore expect Third Parties to strive for sustainable products and services that have the lowest possible environmental impact. Third Parties are expected to reduce their climate change impact, improve efficiency in energy use, minimize waste, and foster reusable packaging materials.

 

ENVIRONMENTAL PROTECTION

Third Parties are expected to operate in an environmentally responsible and sustainable manner. This includes compliance with all applicable environmental laws, regulations, and standards as well as the implementation of an effective system to identify and eliminate potential hazards to the environment. Third Parties are expected to adhere to the following principles as applicable to their type of product or service:

  • Work in accordance with applicable international standards related to waste, chemicals and hazardous materials, wastewater, solid waste, and air emissions;
  • Avoid any negative impact on critical habitats, on legally protected areas, and areas recognized for high biodiversity value;
  • Avoid harm to critically endangered, endangered, vulnerable, or restricted-range species and avoid introduction or utilization of invasive species;
  • Avoid any unwarranted greenhouse gas emissions;
  • Strive to achieve net-zero emissions by 2050 with a clear and verifiable path and ambitious intermediate steps;
  • Comply with any additional environmental requirements specific to the products or services being provided, and as contractually agreed with The Ocean Cleanup; maintain records regarding each of the above.

 

PLASTIC REDUCTION

To help us achieve our mission, plastic use should be carefully considered. Initiatives such as plastic reduction goals can facilitate action and change throughout a company or organization. Third Parties shall be transparent about the use of plastic, work to reduce their plastic usage, and where plastic usage cannot be avoided, undertake best-available recycling practices.

 

RECORDS AND INFORMATION PROTECTION

 

ACCURATE RECORD-KEEPING

As a non-profit organization, we must regularly report our activities to our many stakeholders. To ensure proper compliance with its obligations to The Ocean Cleanup, Third Parties must ensure that all records are retained and disposed of in accordance with all applicable laws and regulations.

 

CONFIDENTIAL, PROPRIETARY, AND PERSONAL INFORMATION

Third Parties should always safely manage all exchanged sensitive information (including confidential, proprietary, and personal information) of everyone they do business with and comply with privacy and data protection laws. When data is stored or sent digitally, our Third Parties must have suitable cybersecurity systems in place. In case of security breaches, the appropriate authorities and The Ocean Cleanup must be notified promptly.
Third Parties should respect all applicable intellectual property rights, including those of The Ocean Cleanup.

 

PROCEDURE FOR REPORTING COMPLAINTS

Third Parties can raise concerns or report suspected misconduct or irregularities related to the cooperation with The Ocean Cleanup, including giving any notice under the Code of Conduct via:

  • Online communications channel available at the Contact Page (choose topic “Other”);
  • Letter or hand delivery to The Ocean Cleanup HQ, attn: Compliance Officer, located at Coolsingel 6, 5 & 6th floor, 3011 AD Rotterdam, The Netherlands. The Ocean Cleanup will investigate, address, and respond to any concerns and will take appropriate corrective action.

 

AMENDMENTS AND UPDATES

The Code of Conduct may be amended by The Ocean Cleanup at any time without prior notification. The Code of Conduct, as amended from time to time, shall apply.