Stakeholder Participation Guidelines. One set of rules, for everyone.

The MPRP is a donation-funded programme in which every tonne of plastic is verified from collection to recycled material, and the proceeds of each recycling certificate are distributed to the parties who made that tonne happen. Participation is open — but conditional. Every stakeholder must meet the criteria below before joining the ecosystem, and must keep meeting them to remain in it.

The guidelines cover every role in the chain:

• Collectors — NGOs and organised groups gathering plastic from beaches, the sea and fishing activity (e.g. our collection partner Żibel), and individual donors of plastic.
• Sources / waste managers — established waste-management operators supplying plastic to recyclers (e.g. WasteServ, GreenPak).
• Transporters and sorters — the parties moving and separating material between hand-offs.
• Recyclers — the operators that process verified plastic into recycled material and confirm completion of each batch, across any stream: from valuable plastics such as PET, HDPE and PP to mixed rigids, film, and marine and fishing-gear plastic.
• Mission NGOs — environmental NGOs pursuing the Programme's mission, admitted to the Mission NGO Group.

1. Legal standing and good conduct. The applicant is lawfully constituted, holds the permits and licences its activity requires in Malta (or its jurisdiction of operation), and is not subject to proceedings that would call its participation into question. Evidence: registration documents, applicable permits, declarations of good standing.
2. Full participation in workflow verification. The stakeholder completes its step in the chain on the Programme's verification infrastructure, operated by Carrot: chain-of-custody records at every hand-off, weights for mass-balance reconciliation, and confirmation of its own completed step. A stakeholder that cannot or will not evidence its step cannot be paid for it — by design, not by discretion.
3. Truthful declaration of origin and revenue. Where the stakeholder is the source of a batch, it provides Proof of Origin; where it has paid or been paid for material, it declares that amount accurately. Declarations are reconciled two-sided — against the counterparty's own records.
4. Disclosure of relationships with the Foundation. Every applicant must declare, at application and on any later change, any connection to a MARE Foundation founder, administrator, Supervisory Board member, or related entity. Non-disclosure of a relationship is itself grounds for exclusion. Disclosure does not disadvantage an applicant — it triggers the related-party safeguards in sections 07–08, nothing more and nothing less.
5. Acceptance of published parameters. Fees, premiums and percentages are set per period under the published methodology and are not negotiable bilaterally. No stakeholder may seek, and the Foundation will not grant, individually negotiated economic terms.
6. Cooperation with audit. The stakeholder accepts independent annual audit of Programme flows it participates in, and retains its records for reconciliation.
7. Mission compatibility. The stakeholder's participation must advance, and must not undermine, the Programme's purpose of making every kind of plastic worth recycling in Malta.

The Regeneration Fund is the engine of the Programme, and access to it is governed by one rule above all: every recycler is subject to exactly the same criteria. There is no separate track, no negotiated deal, and no version of these rules that varies by applicant.

The Programme is open to recyclers working on any plastic stream, and it supports the two kinds of stream through two distinct, published formulas. Negative-value streams — mixed rigids, film, marine and fishing-net plastic — are supported through the Tipping Fee, which covers the net cost of recycling. Positive-value streams — such as PET, HDPE and PP, which a recycler purchases from a waste manager — are supported through a separate, ICIS-referenced reward that offsets the scale disadvantage of Malta's small volumes, so a Maltese recycler's output can compete in European markets. Both formulas are rule-based, capped, set per period from the ICIS European market reference, and identical for every recycler.

What every recycler must meet

1. Operational capability per stream. The recycler demonstrates the technical capacity to process the plastic streams it applies for — whether valuable streams like PET, HDPE or PP, or the degraded, salt-laden marine and fishing-net streams the market otherwise leaves behind. Each stream applied for is assessed on its own evidence.
2. Completion is confirmed, not assumed. The recycler confirms Completion for each batch only when the plastic has genuinely been recycled; that confirmation triggers certificate issuance and is verified against the rest of the chain.
3. Acceptance of the capped, rule-based support. The recycler is a workflow participant, not a payee with a fixed share of certificate proceeds. It is paid only under the published formula for the stream in question — the Tipping Fee for negative-value streams, the ICIS-referenced competitiveness reward for positive-value streams — capped at that level, and the same for every recycler.
4. Accurate Source Revenue declarations. Any amount already received from a source for a batch is declared and netted off, so no recycler is paid twice for the same tonne.
5. Indifference to the certificate buyer. The recycler's receipt is identical whether its certificate sells at the Floor Price or far above it, and whoever buys it. A recycler may not condition participation on who purchases or at what price.
6. Intake within funded capacity. Programme intake carrying the Floor Price is issued in line with committed funds, per period and per recycler. Plastic beyond that capacity may still be recycled and certificated, but carries ordinary market risk, clearly flagged.

The Regeneration Fund does more than pay per-tonne support. Accumulated surplus in the Fund is the revolving capital from which it advances capital-expenditure financing to recyclers establishing or expanding operations in Malta — the mechanism by which the Programme actually brings recycling capacity to the island. Because a financed recycler's loan is repaid through the redirected value of its own certificates, the capital returns to the Fund and can be lent again.

Financing is one of the most consequential decisions the Foundation makes, so it is the most tightly rule-bound. Every financing application — from every applicant, related or not — is assessed against the same published criteria and approved by the Project Approval Committee.

Eligibility and assessment criteria

1. All baseline and recycler criteria met first. A financing applicant must already qualify as a recycler under sections 03 and 05. Financing is not a route around participation criteria; it is available only to stakeholders who would qualify to participate without it.
2. Additionality to Malta. The financing must establish new, or expand existing, recycling capacity in Malta — capacity that would not otherwise happen on market terms. Funds may not be used to relocate value off the island or to subsidise activity that would proceed regardless.
3. Credible operating and repayment plan. The applicant provides a plan showing the streams to be processed, expected verified tonnage, and how the redirected certificate value is projected to retire the loan within a defined term. Supplier-neutral technical specifications are required for any equipment financed.
4. Loan-flagged, self-amortising structure. Financed certificates are Loan-Flagged: on each such certificate the recycler receives no per-tonne support, and the corresponding value is instead applied to reduce the outstanding loan at a fixed value per certificate until it is extinguished, after which the flag is removed. This closes the circular-payment leak whereby a financed recycler could otherwise recover the same money twice.
5. Proportionate, capped exposure. Financing is sized to the demonstrated need and to what the Fund's accumulated surplus and smoothing reserve can support without compromising the Programme's ability to keep purchasing certificates. No single financing may concentrate the Fund's capital to the detriment of other stakeholders.
6. Security and legal form as advised by counsel. The loan's security, documentation and legal form follow professional legal advice; the exact structure is reserved for counsel (see section 10) and must be settled before funds are advanced.
7. Ongoing conditions and audit. Continued access to financing is conditional on the recycler continuing to meet all participation criteria and cooperating with the independent annual audit of Fund flows.

How a financing decision is made

An eligible application is assessed by the Project Approval Committee against the criteria above — in the order received and on the same terms for every applicant. Where the applicant is a party related to the Foundation, the additional safeguards in section 08 apply in full and on top of this process; they neither replace the criteria above nor soften them. Every financing decision — related or not — and every loan advanced and repaid, is disclosed in the Foundation's annual report.

Section 06 sets the criteria and process for financing from the Regeneration Fund; section 07 guarantees equal treatment for every stakeholder. This section adds the one further layer that applies when the Foundation extends financial support — a loan, grant or other financial investment — to an entity related to its founders, administrators or board members. It applies on top of sections 06 and 07, never instead of them.

The statutory basis

The Foundation's power to support related entities, and the conditions on it, come directly from its own deed:

The safeguards that apply

1. All ordinary criteria met first. The related applicant qualifies as a recycler and satisfies the financing criteria in sections 03, 05 and 06 exactly as an unrelated applicant would. This layer adds scrutiny; it removes none.
2. Approval by the Project Approval Committee. The support is assessed and approved under the Foundation's published rules, like any other financing application.
3. Independent written confirmation. At least two independent members of the Supervisory Board confirm in writing that the support meets the Foundation's criteria and charitable purpose.
4. Recusal of conflicted administrators. Any administrator connected to the applicant takes no part in the evaluation or the decision.
5. Commissioner approval and proactive notification. Financial support to a related entity is duly approved by the Commissioner for Voluntary Organisations under the Foundation's governance procedures, and the Foundation notifies the Commissioner proactively.
6. Returns serve the mission alone. Any returns generated are applied solely in furtherance of the Foundation's purposes.
7. Full disclosure. The decision, and every loan advanced and repaid, is disclosed in the Foundation's annual report.

These safeguards mean a related applicant should expect a heavier file, not a lighter one. And because financed certificates are Loan-Flagged (section 06), the capital advanced returns to the Fund as the loan amortises and can be lent again — related-party support is a revolving instrument for building recycling capacity in Malta, never a transfer of value out of the mission.

No stakeholder is paid on self-declaration alone. Every figure the distribution relies on — tonnage, origin, source revenue — is reconciled across the chain before a certificate issues.

1. Continuing obligations. The criteria in these guidelines apply for as long as a stakeholder participates, not only at admission. Material changes — ownership, permits, relationships with the Foundation — must be notified without delay.
2. Annual review. Parameters, and each stakeholder's continued eligibility, are reviewed annually alongside the published parameter review.
3. Consequences of breach. Misdeclaration of origin or revenue, obstruction of verification or audit, or failure to disclose a related-party connection may lead to withheld settlement on affected batches, suspension, or exclusion from the Programme. Verified, completed work by other stakeholders in the same chain is not forfeited by one party's breach.
4. Voluntary exit. A stakeholder may exit at the end of any period; batches already in the verified workflow are settled under the rules in force when they entered it.

These guidelines are published, versioned and reviewed annually together with the Programme's parameters. The Foundation's annual report discloses fund inflows and outflows, standing distributions, any exceptional surplus allocation, and every related-party transaction — public reporting is what converts "trust us" into "check us." The tax, VAT, state-aid and legal-form questions raised by the Programme are reserved for external professional advice before finalisation.