CSR Mercuria 2019 - Flipbook - Page 49
COMPLIANCE TRAINING
Mercuria is committed to conducting its business with integrity, engaging in all transactions at armslength. Mercuria’s Anti-Bribery and Corruption Policy establishes a comprehensive set of mandatory
guidelines and procedures for Mercuria, including all of its employees, subsidiaries, and intermediaries, to establish guidelines for how to handle situations that could potentially be construed as bribery.
It is the policy of Mercuria to comply with the United Kingdom Bribery Act of 2010 (UKBA), the United
States Foreign Corrupt Practices Act (FCPA), as well as anti-corruption laws and regulations of all other countries in which the firm conducts business. Mercuria complies with anti-bribery and corruption
legislation and guidelines to ensure fair and proper business conduct in the marketplace.
In July of 2019, Mercuria added to its Compliance Program a policy and procedure governing the
onboarding process for brokers, intermediaries, and the formation of joint ventures. The process
implemented an enhanced KYC process for these categories of counterparties, and requires smaller, unregulated counterparties to take Mercuria’s Anti-Bribery/Anti-Corruption training module before
they can be set up in Mercuria’s systems to transact or make or receive payment. This ensures that
anyone undertaking or facilitating business activity on behalf of Mercuria understands Mercuria’s Anti-Bribery/Anti-Corruption policy, is able to identify actions that could be considered to be bribery or
corrupt in nature, and agree to not engage in such actions.
Compliance
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.
It Mercuria’s strict policy to comply with the
United Kingdom Bribery Act of 2010 (UKBA) and
the United States Foreign Corrupt Practices Act
(FCPA), as well as anticorruption laws and regulations of all other countries in which the firm
conducts business. The Company’s Anti-Bribery and Anti-Corruption policy help to ensure
that Mercuria is doing its part to ensure fair and
proper business conduct in the marketplace.
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