Environmental, Health, Safety, and Ethical Assurances and Policies

Quality, Environmental, Health and Safety Policy

It is the policy of Colt Recycling to operate its business as a sound corporate citizen in compliance with ISO 9001, ISO 14001, ISO 45001, R2. We will maintain a health & safety program conforming to the best practices within the scrap recycling industry. Our goal is to ensure the covered facilities and operations are in compliance with federal, state and local environmental, health and safety standards, other compliance obligations and to continually improve the overall system. We believe that balance can and should be sustained between quality, environmental, safety and health goals and the facility’s economic health. We intend to be a leader in responsible management throughout our industry. The QEHS management system will define objectives for the prevention and reduction of pollution associated with recycling and related processes, to safeguard against adverse impact on the environment, and to protect worker wellness and safety. This requires each Colt employee to participate in and accept responsibility for achieving the following objectives:

  • Meet our customer requirements
  • Operate in a responsible manner and in compliance with applicable laws and regulations
  • Minimize or eliminate waste generation and emissions released to air, water & land including specific hazardous materials
  • Protect the environment through the promotion of efficient recycling & reuse practices
  • Provide safe and healthy working conditions for the prevention of injury and ill health and control occupational health and safety risks using the hierarchy of controls.
  • Worker participation and consultation, and where they exist, workers’ representatives, in the decision-making processes in the QEHS management system.
  • Respect and preserve worker health and safety

In compliance with R2, Colt’s practices are based on reuse, recover and disposal of end of life electronics equipment, and covers materials management on-site and throughout the recycling chain. This policy will be communicated to all parties interested in the performance of our Quality, Environmental, Health & Safety management system.

 

Data Security Policy

Colt Recycling is committed to data security and protecting our client’s assets.

  • Colt Recycling prohibits unauthorized individuals from accessing or handling equipment containing data.
  • Colt Recycling has assigned Data Protection Representatives with overall responsibility and authority for Colt Recycling’s data security and legal compliance, including oversight of all related duties otherwise assigned.
  • Colt Recycling mandates reporting of known and suspected breaches of security and data to the Data Protection Representative.
  • Colt Recycling requires completed training and confidentiality agreements prior to individual authorization to handle equipment containing data.
  • Employees found to violate this policy will be subject to disciplinary action that could include immediate dismissal.
  • Employees found to violate this policy or found to have conducted a criminal act related to data security will be held financially and criminally responsible for damages and/or material loss to Colt Recycling and its clients to the extent allowed by law.

 

Whistleblower Policy

A whistleblower system has been introduced in the Elemental Capital Group and is dedicated to report personally or anonymously any irregularities noticed. One of the elements in preventing corrupt practices is their detection by immediate reporting. Any incident of a corrupt nature should be straight away referred to competent parties designated in the Whistleblowing procedure and any evidence related to such events should be secured, as far as possible. As an Organization, we would like to remind you that the system of reporting violations should be used to report any doubts in cases of fraud, workplace harassment, corrupt practices, conflicts of interest, unfair competition, and other forms of unethical conduct.

Go to Elemental Whistlelink to find the forms for reporting.

Full policy:  Whistleblowing Procedure

 

Code of Conduct, Supply Chain and Ethics

Colt Recycling, as part of the Elemental Holding Group, is committed to the highest standards of integrity, transparency, and ethical conduct in all aspects of our business. We adhere to the corporate ethics and compliance framework established by Elemental Holding and operate in full alignment with its Code of Conduct and Anti-Corruption Policy. Our success is built on trust—earned through consistent, lawful, and responsible behavior across our organization and in every business relationship.

We enforce a strict zero-tolerance policy toward corruption, bribery, and unethical practices. Employees and business partners are prohibited from conduct that could improperly influence decision-making or create even the appearance of a conflict of interest. All business courtesies must be reasonable, transparent, and compliant with both company and legal standards. We prohibit forms of misconduct that undermine ethical business operations.

Colt Recycling fosters a culture of accountability and compliance. Through Elemental Holding’s whistleblowing system, all employees and stakeholders are encouraged to report any suspected violations or unethical behavior confidentially and without fear of retaliation. By upholding these principles, we protect our people, our partners, and the integrity of the Elemental Group as a whole.

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