CSR Mercuria 2018 - Flipbook - Page 18
To ensure we are compliant with the many laws
and regulations applicable to us Mercuria has an
extensive Compliance Programme, which is mandated and endorsed by Mercuria’s management
team and implemented and overseen by the Mercuria Compliance team.
Integrated with our vision and our expectation of
compliance, Mercuria creates through its employee training, and an internal system of governance
policies; a framework to guide its business conduct around the globe
CODE OF CONDUCT
Mercuria’s Code of Conduct (“The Code”) outlines
the principles and core values to which all employees are required to adhere. The Code re-affirms
our commitment to uphold the highest ethical
standards at all times. The Code clearly defines
expected behaviors and provides guidance to employees as to Mercuria’s principles and how and
what employees should escalate to Compliance
and or Management.
The Code of Conduct serves as the hallmark of
Mercuria’s commitment to ensuring that all employees maintain the highest level of integrity and
transparency in the performance of their individual and collective roles and responsibilities.
In all of our businesses, we expect the partners
that we work with to operate to international standards in all areas and to share our commitment to
full compliance with our Code of Conduct.
Mercuria has a whistleblowing policy and procedure, which allows any individual within the organization to raise a concern (as well setting out the
expectation for them to do so) about a situation
that might represent a breach of our Code of Conduct or any other company policy. Concerns can
be brought to the person’s immediate supervisor,
another appropriate manager, the local Compliance Officer, or reported to the company’s ethic’s
hotline (by either email or phone).
The company has in place a clear policy of no
retaliation for any issues reported in good faith.
Mercuria’s Compliance and Management team
are committed to ensuring any issues reported
are taken seriously, and are followed through to
resolution.
18
MEASURING AND REPORTING ON PROGRESS
All of Mercuria’s assets develop and implement
measures and report performance against the
priorities and targets agreed at Group and operating levels. These targets, which are separated
under different categories within this document,
were a key focus for 2018 and will serve as a foundation for reference looking forward. Better collation of consistent KPIs across assets is one of our
identified progress targets for this year.
Mercuria tracks the direct performance of Mercuria Energy Group, including all of its subsidiaries
and also of all assets owned fully or partially by
Mercuria.
While continuously evolving, key HSE related
metrics that we track include:
• New employees joining the organization
• Employees changing roles within the organization
• Percentage of new employees receiving orientation training
• Percentage of employees receiving annual refresher training
• Certain employee groups who may receive additional specialized or targeted training programs
• Training on the European Union’s CLP / REACH
regulations
• Training required under the US DOT’s 8-hr
Hazwoper Awareness program
• Company-wide communications on broad business related HSE topics
• Due diligence of new facilities / new business
ventures
• KYC reviews of potential counterparties
• Work-related illness / injuries / fatalities
• Reports of environmental incidents such as
spills / releases / fires
• Transportation related incidents (motor vehicle
crashes, train derailments, etc.)
• Incidents of theft / vandalism
• Reports of improper activities / lawsuits / allegations from regulators
• HSE related inquiries to our 24/7 Emergency Call
Centers
