Commitments of all Facilitators
There are commitments that apply to all Faciliators and there are additional commitments for the different categories of Facilitators.
No pre-requisite applies to an Applicant for Signatory status as a Facilitator, other than a recycling company. As a pre-requisite, a recycling company applying for Signatory status as a Facilitator is required to self certify and, if required by the Administrator, to demonstrate that it is licensed to recycle mercury-containing waste and operates under the relevant licence conditions.
An Applicant for Signatory status as a Facilitator is required to submit an application link to Facilitator Online Application Form accompanied by a simple Action Plan. The Action Plan outlines the timeline and the steps that the Applicant proposes to undertake to meet the commitments of the Category/ies nominated by the Applicant.
When the application has been approved, an Applicant for Signatory status as a Facilitator is required to provide a signed statement of commitment as a condition of becoming a Signatory.
A Facilitator, upon becoming a Signatory, is required to meet the following commitments to the FluoroCycle scheme:
- provide information about FluoroCycle and promote the scheme to suppliers, customers or members, and potential suppliers, customers or members, contributing to the Outreach Strategy described in Section 3
- perform the activities set out in the accepted Action Plan submitted with the Application for Signatory status
- adhere to the Signatory commitments set out in these Guidelines and the Signatory Guide to FluoroCycle Branding
- cooperate with surveys that are undertaken from time to time, and with random or risk-based audits, as instigated by the Administrator
- provide accurate, annual statements (using the template) that self certify compliance with the commitments that apply to Facilitators, the first annual statement being due 12 months from the date on which Signatory status was awarded, and
- provide annual updates of the Action Plan, to accompany the statements self certifying compliance.
Commitments that relate to audits are set out in Section 4.4 of the FluoroCycle Guidelines:
As one of their commitments, Signatories are required to cooperate with audits that will be undertaken in reasonable business hours and after reasonable notice.
The Administrator may undertake random or risk based audits of the activities of Signatories to ensure compliance with commitments to FluoroCycle. This means that, in any one year, a subset of Signatories are likely to be audited. An audit also includes an assessment of adherence with these Guidelines and the Signatory Guide to FluoroCycle Branding.
In the case of a Facilitator, an audit includes an assessment of the steps taken to implement the Facilitator's Action Plan and a visual inspection of evidence that FluoroCycle has been promoted adequately, eg through publications or reports.
A Signatory who fails to cooperate with an audit will be asked to explain why their Signatory status should not be revoked. An explanation which is either insufficient or inappropriate will result in action that may include revocation of the Signatory status. (See Section 2.4 of the Guidelines)
