Compliance

Our commitment to compliance ensures fair and proper business conduct across our global activities.

This responsibility extends beyond our own employees to the third parties we work with, including brokers and joint ventures. Our Compliance Programme includes dedicated policies and procedures governing the onboarding of these partners, ensuring:

• Enhanced Know-Your-Counterparty (KYC) procedures: thorough vetting to verify legitimacy and ethical practices.
• Anti-bribery and corruption awareness: ensuring partners understand our ABC Policy, can identify potential risks and act accordingly.
• Proactive risk mitigation: reducing exposure to unethical conduct across our network.

We support our employees through ongoing compliance training across our global operations. Throughout the year, we deliver structured training covering:

• Regulatory and exchange updates: ensuring awareness of evolving rules and expectations.
• Internal policy developments: reinforcing understanding of our standards and procedures.
• Market and regulatory developments: providing insight into relevant external changes.

These programmes ensure that employees are equipped to navigate complex environments and uphold Mercuria’s standards of integrity and compliance in their day-to-day activities.

To uphold these standards, we implement trade, voice and electronic communications surveillance tools to:

• Scan for trade anomalies: identifying unusual behaviour and potential red flags to minimise the risk of undetected misconduct.
• Monitor communications: reviewing electronic and voice communications to detect behaviour that may not align with our ethical or regulatory obligations.
• Enhance controls: continuously refining our processes, systems and data sources to strengthen surveillance capabilities and improve efficiency in identifying and investigating alerts.

Our surveillance framework enables us to:

• Detect potential violations: identifying breaches of regulations, internal policies or expected standards of conduct.
• Conduct detailed analysis: ensuring that alerts are subject to appropriate review, escalation and, where necessary, remediation.
• Mitigate emerging risks: monitoring evolving market conditions and proactively addressing areas where market abuse or manipulation risks may arise.

We continue to invest in and enhance our surveillance capabilities to respond to increasingly complex regulatory requirements and evolving market risks, ensuring that our systems remain effective and aligned with best practice.

Through this comprehensive and evolving framework, we aim to safeguard the fairness, transparency and trust that underpin the markets in which we participate.

Mercuria’s commitment to ethical conduct begins with a comprehensive and structured counterparty due diligence process. Before establishing any new business relationship, we conduct a detailed Know-Your-Counterparty (KYC) assessment to ensure alignment with our standards and to identify and mitigate potential risks.

This framework safeguards Mercuria against a wide range of risks, including fraud, money laundering, corruption, human rights abuses and other forms of financial and operational risk.

Our multi-dimensional KYC programme assesses:

• Commercial strength: evaluating financial stability and operational capability to ensure counterparties can meet their obligations.
• Compliance standing: verifying adherence to applicable regulations and screening for sanctions, legal exposure and reputational risk.
• Ethical alignment: assessing whether business practices align with Mercuria’s standards on responsible conduct, including exposure to risks such as corruption, fraud or human rights violations.

By examining these dimensions, we gain a comprehensive understanding of potential counterparties, enabling informed decision-making that protects both our ethical standards and our business.

Recognising that risks, technologies and regulatory expectations continue to evolve, we maintain a dynamic approach to due diligence. This includes:

• Use of advanced tools and data analytics: enhancing risk identification and supporting real-time assessments.
• External data partnerships: working with established providers such as Dow Jones, WorldCheck and Polestar’s PurpleTRAC to supplement internal analysis.
• Continuous process review and enhancement: ensuring our methodologies remain aligned with international standards and best practices.

Our due diligence extends beyond counterparties to include contractors, service providers, vessels, products and storage facilities. This ensures a consistent and comprehensive approach to risk management across all areas of our operations.

We recognise that our reputation depends not only on our own conduct but also on the practices of those we work with. We therefore maintain a strong focus on continuous improvement, ensuring that we partner with organisations that share our commitment to ethical and responsible business practices.

Our internal supply chain system maps our supply chains and assigns risk levels to operations and trades, with a focus on issues such as forced labour and child labour. It is enhanced for our new metals and concentrates trading business, where human rights risks are elevated. The system registers potential risks and mitigation strategies. We continue to enhance the system as we expand to new products and regions.

By actively fostering ethical partnerships and collaborating with suppliers and contractors who share our values, we aim to build robust value chains that protect human rights and contribute to wider societal well-being.

Mercuria’s human rights due diligence framework rests on four fundamental pillars of action: 

1. Proactive risk identification: We proactively assess and identify any actual or potential human rights risks across our entire business ecosystem. This vigilance extends beyond our own practices and encompasses potential risks associated with our suppliers, contractors, and all other business partners.
2. Responsible action and leverage: Upon identifying risks, we rigorously assess our responsibilities and implement appropriate actions to mitigate them. This may involve collaborative efforts with partners to elevate their human rights practices, or internal measures to minimize our own footprint and potential impact.
3. Effective risk mitigation and protection: Once actions are taken, we remain vigilant in monitoring and reviewing our progress. This ensures continued risk mitigation and protects workers, communities, and all individuals potentially impacted by our operations.
4. Continuous vigilance and improvement: Recognizing the ever-evolving nature of human rights risks, we conduct continuous improvement. Our due diligence processes are constantly monitored, reviewed, and updated to ensure they remain effective in identifying and mitigating any contemporary human rights challenges.

Mercuria understands that respecting human rights is a core ethical imperative as well as a legal obligation. Through our robust due diligence framework, active collaboration with partners, and commitment to continuous improvement, we strive to make a positive impact in the communities where we operate and those that intersect with our supply chains, leaving a legacy of respect and empowerment.

More information on our supply chain due diligence process can be found in our Responsible Sourcing section.

Mercuria pursues investments, partnerships and financing opportunities that support operating assets and physical infrastructure aligned with our core energy and commodities activities, while also advancing the transition towards lower-carbon and more sustainable solutions.

Environmental, Social and Governance (ESG) considerations are embedded into our investment approach, supported by a company-wide commitment to achieving net-zero greenhouse gas emissions from our operations by 2050. This approach is driven by senior management, ensuring consistent oversight and alignment with our broader strategy.

All potential investments are subject to rigorous evaluation and due diligence. We assess not only counterparties, partners and service providers, but also the underlying ESG risks associated with each opportunity. Compliance with environmental, health and safety, and ethical standards—as set out in our Code of Conduct—is a core requirement. Our assessments are forward-looking, taking into account the full lifecycle of an asset and its long-term impact.

Mercuria’s Deal Execution Committee (DEC) provides a structured and collaborative framework for evaluating investments and associated risks. The committee brings together expertise from Finance, Credit, Corporate Responsibility & Compliance, Risk, Legal, Tax, Treasury, Operations and relevant Trading teams to assess each opportunity in detail.

Findings are consolidated into a comprehensive review and presented for final approval by senior leadership, including the CEO, President or Executive Vice President. This process ensures that all investment decisions are subject to appropriate challenge, oversight and alignment with Mercuria’s strategic objectives.

Through this disciplined and integrated approach, Mercuria supports responsible investment, effective risk management and long-term value creation across its asset portfolio.