Upon identification or notification of anincident, we will:• Ensure adequate resources are available or offerto activate additional responders if necessary tohelp address and control an immediate issue.• Confirm that appropriate 3rd party / regulatorynotifications have been made, as required.• If appropriate, we will notify our insurers andsend representatives to provide first-hand feedback / observations of response efforts.• Work to develop objective analysis and understanding of any incident to confirm that the underlying cause(s) have been identified, and appropriate measures taken to guard against futurerecurrence.• Information concerning individual events is ofcourse appropriately provided to key leadershipwithin Mercuria at the time it is initially reported.Additionally, Mercuria’s leadership has as a regular part of its frequent corporate meetings, anoverview review of any significant events that mayhave occurred since the last meeting. As part ofthese reports, the leadership looks for its technical specialists to advise of corrective actions taken or remaining concerns or issues.FORMAL DUE DILIGENCEWithin our role as a global energy and commodities trader, Mercuria recognizes that we are potentially exposed to various human rights andother issues across a range of jurisdictions. Weface an array of potential risks across our supplychain and therefore, Mercuria has varying levelsof due diligence procedures depending on thepotential for exposure to issues including, but notlimited to, security of persons, rights of workers,environmental protection and equal opportunity /non-discrimination.In relation to our facilities and operations due diligence efforts are intended to be objective, identifying potential risks and liabilities which maybe associated with properties or operations. Ingeneral, for transactions involving real properties,Mercuria references ASTM Method E1528 – Standard Practice for Limited Environmental Due Diligence which may be further coupled with Mercuria’s questionnaires in reference to a particularoperation’s operational practices.Our supply chain due diligence procedures include reviews of issues concerning human rightsas well as compliance history in relation to subjects such as health and safety, the environmentand financial crime.Mercuria is pleased that it has had no major workrelated injuries or fatalities in any of its facilitiesduring the last year and only a minimal number ofminor incidents.19
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