Gifts and entertainment provided by Mercuria employees must not be excessive or providedto create an obligation and must be consistent with customary business practices.All gifts and entertainment must be provided in accordance with our policies and procedures.CONFLICTS OF INTERESTMercuria recognises that conflicts of interest and potential conflicts of interest can ariseduring the course of business activities, and that those conflicts need to be identified andmanaged when they occur. A conflict of interest can occur in any situation where eitherthe aims or concerns of two parties are incompatible or where a person is in a position toderive personal benefit from their official capacity. Conflicts can exist, for example, betweenMercuria and an employee or Mercuria and one or more business partner.Conflicts of interest exist where you, or someone close to you, could benefit at the expenseof Mercuria, you are in a situation that could result in lost opportunity for Mercuria, or youare in a situation that has the potential to affect your objectivity and work performance.Examples of potential or actual conflicts of interest include having a personal financialinterest in a company that operates in an area directly related to your responsibilities atMercuria or to which you give business, conducting business on behalf of Mercuria with acompany owned or managed by a friend or relative, using Mercuria resources for personalbenefit or for an outside business, and receiving discounts or anything of value from a partywith whom Mercuria does business.All employees are required to ensure that any conflicts of interest or potential conflicts ofinterest are identified and reported as soon as reasonably possible.CONFIDENTIALITYMercuria takes its confidentiality obligations very seriously and respects the confidentiality ofits business partners at all times. Mercuria complies with confidentiality laws and obligationsand requires all of its employees not to disclose confidential information that comes intothe employee’s possession as a result of employment at Mercuria at any time during orafter their employment with Mercuria. Confidentiality obligations apply to confidentialinformation belonging to Mercuria, its employees, its investors and shareholders and itsbusiness associates, vendors and customers.Mercuria has specific policies and procedures relating to confidentiality in respect of certainaspects of its businesses restricting the flow of information within Mercuria. These policiesand procedures must be adhered to at all times.Any breach or potential breach, including erroneous or inadvertent breaches, must bereported immediately.12
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