COMPLIANCE TRAININGMercuria 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 mandatoryguidelines 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 UnitedStates 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 corruptionlegislation 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 theonboarding process for brokers, intermediaries, and the formation of joint ventures. The processimplemented an enhanced KYC process for these categories of counterparties, and requires smaller, unregulated counterparties to take Mercuria’s Anti-Bribery/Anti-Corruption training module beforethey can be set up in Mercuria’s systems to transact or make or receive payment. This ensures thatanyone 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 orcorrupt in nature, and agree to not engage in such actions.ComplianceCODE OF CONDUCTMercuria’s Code of Conduct (“The Code”) outlines the principles and core values to whichall employees are required to adhere. The Codere-affirms our commitment to uphold the highest ethical standards at all times. The Codeclearly defines expected behaviors and providesguidance 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 theUnited Kingdom Bribery Act of 2010 (UKBA) andthe United States Foreign Corrupt Practices Act(FCPA), as well as anticorruption laws and regulations of all other countries in which the firmconducts business. The Company’s Anti-Bribery and Anti-Corruption policy help to ensurethat Mercuria is doing its part to ensure fair andproper business conduct in the marketplace.49
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