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4. Our governance policies

NOWOS’s approach to sustainable urban mining is governed by our own principles and standards and is in line with good corporate governance as laid down in the Governance Code and B Corp code.

Business principles
Our Business principles guide us in carrying out our mission. They provide the framework that supports not only our strategic future, but also the code of conduct that underlies our day-to-day business operations.

The Business principles are an integral part of the contracts of employment of all NOWOS co-workers. In addition, the Business principles are included in the introduction program for new co-workers. The principles have been drawn up in consultation with the Board of SAAN.

In addition to the broad vision that underpins our business, we have a number of Principles and Values that guide and support our day-to-day decision-making. Our business principles and Colleague Values apply to everyone who works for NOWOS, in any capacity. They serve as a code of conduct, and also set the standard by which internal and external stakeholders can judge us.

Minimum standards
To assess clients, suppliers and investors, our relationship managers and fund managers refer to our Business Principles in the first instance. Then, the Lending criteria which specify how NOWOS’s vision and mission are translated into urban mining practice are applied. The NOWOS Minimum standards set out the absolute minimum requirements that NOWOS applies for its activities.

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Compliance related documents and other policies

Next to our Business principles and our Governance we are guided by several compliance related documents and other policies. For an overview of these documents and other relevant internal regulations see below:

Bilateral contacts with Depository Receipt Holders policy
In accordance with best practice provision IV.3.13 of the Dutch Corporate Governance Code, NOWOS has formulated a policy on bilateral contacts between NOWOS and its (potential) Depository Receipt Holders and other parties. NOWOS aims to maintain an open and constructive dialogue with existing and (potential) Depository Receipt Holders. (Bilateral) Meetings are arranged to connect directly with existing investors and to offer further insights into publicly available information, ask questions and acquire a better understanding of the business.

Complaints handling policy
For NOWOS having good and transparent relationships with its stakeholders is very important. The company therefore attaches great value to being well informed on possible sources of complaints, and to get in contact with any dissatisfied person so that suitable solutions can be found, and products, activities and services can be improved. This policy describes the measures that we take to ensure that an effective and transparent policy and related procedures for the prompt handling of complaints are in place. It provides clear, accurate and up-to-date guidelines in respect of the complaints handling process.

Recruitment of Executive Board members
NOWOS aims to attract and recruit qualified people with a strong affinity with the mission and values of NOWOS. We believe that a strong connection to the mission combined with diverse backgrounds, skills, and abilities, will enhance the quality of service to our clients. This is also applicable for Executive Board members.

Whistleblower policy
Our Whistleblower policy ensures that co-workers have access (anonymously or otherwise) to the board of NOWOS or the board of SAAN, in case of alleged irregularities of a general, operational and financial nature within our company. It defines the rules and procedures for the proper handling of such allegations.

Position statements

NOWOS and human rights
NOWOS has had a strong commitment to human rights since its inception. Our business principles make a specific commitment to respecting human rights: ‘We respect people, society and different cultures and support the aims of the United Nation’s Universal Declaration of Human Rights’.

NOWOS is working towards reporting in line with, or equivalent to, the UN Guiding Principles Reporting Framework on international responsible business conduct regarding human rights.

NOWOS’s vision on respecting privacy
Data can be used to better understand our world and each other. At the same time, NOWOS is aware of the fact that the (personal) data it processes can be sensitive and can impact the privacy of our clients and co-workers. NOWOS is committed to respecting privacy and ensuring data protection.​​​​​​​

NOWOS position on publication of tax ruling
A tax ruling is a written confirmation from tax authorities that provides upfront clarity on the tax treatment of company structures or transactions. Such a ruling usually spans a number of years and in the Netherlands is referred to as an Advance Tax Ruling (ATR) or an Advance Pricing Agreement (APA). Transparency is one of NOWOS’s core values. Our principle is to publish any company-specific ATR or APA provided publication that is approved by the relevant tax authority.


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