Mercuria CSR Report 2020 - Flipbook - Page 45
| GOVERNANCE
MERCURIA’S CODE OF CONDUCT
Mercuria’s Code of Conduct details the principles
that guide Mercuria employees’ conduct in order
to ensure the company upholds the highest legal,
ethical and moral standards. In the last year, Mercuria
has taken incremental steps to ensure that these
principles also guide the conduct of our business
partners and intermediaries by implementing various
procedures for different parties which include requiring
acknowledgement of the receipt of Mercuria’s Code of
Conduct and in some instances requiring completion
of our Anti-Bribery and Anti-Corruption training before
Mercuria will engage in any business transactions with
them.
During 2020, Mercuria transitioned to a primarily remote
working environment due to the Covid-19 pandemic.
In order to maintain its compliance training program, the
Global Compliance group implemented virtual trainings
and conducted its internal Market Abuse training
program virtually to continue to ensure that all trading
activity is executed in an appropriate manner and never
with the intention to manipulate the market. In addition
to targeted training for traders, the Global Compliance
team also implemented virtual new-hire Compliance
orientation to provide a personal introduction to the
Compliance team in the relevant jurisdiction, to cover
certain aspects of the Code of Conduct, and to explain
the Whistleblower policy, as well as how and what
should be escalated to Compliance, Legal and/or
Management.
Mercuria continues to constantly evaluate and,
where necessary, modify its contract clauses to ensure
Mercuria and its counterparties must comply with all
applicable laws, rules and regulations throughout the
entire lifecycle of every transaction. One of the most
dynamic international set of laws governing Mercuria’s
business is sanctions. In recognition of the critical
importance of and challenges with complying with
international sanctions, Mercuria has added a member
to its compliance team who is responsible for leading
the vessel and products vetting function. Mercuria’s
vessel and products vetting policies and procedures
are among the most sophisticated in the industry;
Mercuria conducts its activities in full compliance with
all international sanctions on a global basis.
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