Failure to report – not reporting to a Money Laundering reporting officer when there arereasonable grounds to suspect someone is laundering money.Breaches of anti-money laundering or terrorist financing laws can result in criminal liabilitiesfor corporations and employees.ANTI-BRIBERY AND CORRUPTIONBribery is illegal in most of the jurisdictions in which we conduct our business. Corruptionand bribery, whether in the public or the private sector and regardless of location, are nottolerated at Mercuria.Bribes can take many forms, including cash, credits, discounts, gifts, travel or anything elseof value. Bribery is promising, offering, giving or receiving an undue reward or advantageto influence the behaviour of someone in government or business in order to obtaincommercial advantages, whether directly or through an intermediary.Mercuria has dedicated policies, procedures and training in place to ensure that employeesfully understand the laws around anti-bribery and corruption and understand how toconduct business appropriately. Any breaches of these policies and procedures would causesevere damage to the reputation of Mercuria and potentially have legal and / or criminalconsequences for the company and the employee.It is Mercuria’s expectation that its business partners will act in full compliance with globalanti-bribery and corruption laws. Mercuria will only conduct business with entities whocontractually commit to this expectation.Mercuria expects all employees to conduct themselves appropriately at all times, to be awareof Mercuria’s policies and procedures and act in full compliance with such policies and allapplicable laws.GIFTS AND ENTERTAINMENTThe exchange of gifts and entertainment can build goodwill in business relationships, butsome gifts can create improper influence (or the appearance of improper influence). Somecan even be seen as bribes that tarnish Mercuria’s reputation for fair dealing, or breakthe anti-bribery and corruption laws. Care should always be taken to ensure that all giftsand hospitality are of an appropriate nature and will not damage Mercuria’s reputation.Extra care should be taken when considering the provision of hospitality or gifts to anygovernment official or employee.The laws in respect of government officials or representatives are, in many cases, particularlystringent. In many jurisdictions it is illegal to give anything of value to or to entertain agovernment official. Those dealing with government officials therefore need to be particularlycautious and familiar with the local laws in the jurisdiction in which they are dealing.11
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