| GOVERNANCEMERCURIA’S CODE OF CONDUCTMercuria’s Code of Conduct details the principlesthat guide Mercuria employees’ conduct in orderto ensure the company upholds the highest legal,ethical and moral standards. In the last year, Mercuriahas taken incremental steps to ensure that theseprinciples also guide the conduct of our businesspartners and intermediaries by implementing variousprocedures for different parties which include requiringacknowledgement of the receipt of Mercuria’s Code ofConduct and in some instances requiring completionof our Anti-Bribery and Anti-Corruption training beforeMercuria will engage in any business transactions withthem.During 2020, Mercuria transitioned to a primarily remoteworking environment due to the Covid-19 pandemic.In order to maintain its compliance training program, theGlobal Compliance group implemented virtual trainingsand conducted its internal Market Abuse trainingprogram virtually to continue to ensure that all tradingactivity is executed in an appropriate manner and neverwith the intention to manipulate the market. In additionto targeted training for traders, the Global Complianceteam also implemented virtual new-hire Complianceorientation to provide a personal introduction to theCompliance team in the relevant jurisdiction, to covercertain aspects of the Code of Conduct, and to explainthe Whistleblower policy, as well as how and whatshould be escalated to Compliance, Legal and/orManagement.Mercuria continues to constantly evaluate and,where necessary, modify its contract clauses to ensureMercuria and its counterparties must comply with allapplicable laws, rules and regulations throughout theentire lifecycle of every transaction. One of the mostdynamic international set of laws governing Mercuria’sbusiness is sanctions. In recognition of the criticalimportance of and challenges with complying withinternational sanctions, Mercuria has added a memberto its compliance team who is responsible for leadingthe vessel and products vetting function. Mercuria’svessel and products vetting policies and proceduresare among the most sophisticated in the industry;Mercuria conducts its activities in full compliance withall international sanctions on a global basis.45
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