Mercuria Code-of-Conduct Web - Flipbook - Page 7
If you are in any doubt as to whether a trade or activity would be potentially prohibited or
could be perceived as market abuse, you should consult Compliance immediately.
TRADE SANCTIONS
Trade restrictions are put into place by various countries and organisations against certain
countries, entities and individuals. Some sanctions apply more broadly than just to the
country on which they are imposed. Sanctions are applied in a number of different ways,
from bans on all transactions to restrictions on certain types of transactions and activities.
It is important to remember that sanctions can change frequently and quickly, and that a
transaction that was previously permissible may no longer be allowed.
Mercuria does not do business with any country, entity or individual if it would breach
international sanctions laws.
Mercuria commits to full compliance with all applicable international sanctions laws and has
strict policies and procedures in place to ensure compliance.
Mercuria expects all employees to act in full compliance with its sanctions-related policies.
ANTITRUST AND COMPETITION LAW
Mercuria competes vigorously and creatively in its business activities and aims to outperform
competitors with honesty and fairness. Mercuria’s efforts and activities are always carried out
in strict compliance with all applicable laws and regulations covering fair competition.
Generally, competition (antitrust) laws prohibit combinations of entities or individuals from
acting together for the purpose or effect of controlling prices and / or reducing competition.
Relevant enforcement agencies have extensive powers, and breaches of antitrust laws can
result in criminal prosecution.
Both informal and formal agreements and arrangements fall under the scope of the antitrust
laws. Examples of activities that violate antitrust laws include:
Price fixing – entering into an agreement or arrangement with a third party (or parties) to
adhere to certain prices;
Sharing or dividing markets or territories – entering into an agreement or arrangement
with third parties that results in a division or apportionment of customers or territories, or a
limitation on goods or products;
Boycotting – an agreement to boycott competitors, customers, suppliers or other third
parties or jurisdiction;
Collusive behaviour in relation to tenders or auctions;
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