Mercuria Code-of-Conduct Web - Flipbook - Page 12
Failure to report – not reporting to a Money Laundering reporting officer when there are
reasonable grounds to suspect someone is laundering money.
Breaches of anti-money laundering or terrorist financing laws can result in criminal liabilities
for corporations and employees.
ANTI-BRIBERY AND CORRUPTION
Bribery is illegal in most of the jurisdictions in which we conduct our business. Corruption
and bribery, whether in the public or the private sector and regardless of location, are not
tolerated at Mercuria.
Bribes can take many forms, including cash, credits, discounts, gifts, travel or anything else
of value. Bribery is promising, offering, giving or receiving an undue reward or advantage
to influence the behaviour of someone in government or business in order to obtain
commercial advantages, whether directly or through an intermediary.
Mercuria has dedicated policies, procedures and training in place to ensure that employees
fully understand the laws around anti-bribery and corruption and understand how to
conduct business appropriately. Any breaches of these policies and procedures would cause
severe damage to the reputation of Mercuria and potentially have legal and / or criminal
consequences for the company and the employee.
It is Mercuria’s expectation that its business partners will act in full compliance with global
anti-bribery and corruption laws. Mercuria will only conduct business with entities who
contractually commit to this expectation.
Mercuria expects all employees to conduct themselves appropriately at all times, to be aware
of Mercuria’s policies and procedures and act in full compliance with such policies and all
applicable laws.
GIFTS AND ENTERTAINMENT
The exchange of gifts and entertainment can build goodwill in business relationships, but
some gifts can create improper influence (or the appearance of improper influence). Some
can even be seen as bribes that tarnish Mercuria’s reputation for fair dealing, or break
the anti-bribery and corruption laws. Care should always be taken to ensure that all gifts
and 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 any
government official or employee.
The laws in respect of government officials or representatives are, in many cases, particularly
stringent. In many jurisdictions it is illegal to give anything of value to or to entertain a
government official. Those dealing with government officials therefore need to be particularly
cautious and familiar with the local laws in the jurisdiction in which they are dealing.
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