Governance

Governance overview

Introduction

At Mercuria, governance is more than a compliance requirement; it is a core element of how we operate in complex global markets. It informs how we make decisions, manage risk, uphold integrity, and deliver long-term value to our stakeholders. Strong governance protects our reputation, supports sustainable growth, and helps us meet the expectations of a wide range of stakeholders, from local communities to international regulators and financial institutions.

Our approach combines robust governance structures with a deeply embedded culture of transparency, accountability, and ethical conduct. We engage openly with stakeholders, align with recognised international standards, and rely on specialised committees to provide oversight across our activities. Governance is fundamental to Mercuria’s long-term success and to our contribution to more responsible and resilient energy and commodities systems.

ESG reporting commitment

Mercuria supports the Stakeholder Capitalism Metrics developed by the World Economic Forum (WEF) and its International Business Council (IBC). These metrics provide a consistent and globally recognised framework for measuring and disclosing long-term value creation across a broad range of stakeholder interests.

What the Metrics Cover

The framework draws on established standards and comprises 21 core, comparable metrics across four pillars:

People: workforce composition, diversity, health and safety.
Planet: environmental impact, carbon footprint, resource usage.
Prosperity: economic contribution, innovation, investment, and tax transparency.
Principles of Governance: corporate behaviour, ethical conduct, and compliance oversight.

By adopting this framework, Mercuria aligns its reporting with a set of metrics intended to enhance transparency, comparability, and consistency across industries and jurisdictions.

“We see progress in standardisation and transparency as key to promoting and facilitating the energy transition through encouraging efficiencies and development. We welcome this initiative as an important step forward.”
— Marco Dunand, CEO, Mercuria

Our Approach

Mercuria implements the Stakeholder Capitalism Metrics through:

Integration into reporting: Incorporating relevant metrics into our CSR reporting, financial disclosures and broader stakeholder communications.
Materiality and relevance: Focusing on the metrics most applicable to our business model and activities.
Transparency in methodology: Clearly explaining any alternative approaches or methodologies used to ensure comparability.
Collaboration and advocacy: Supporting wider industry adoption and encouraging alignment across partners and stakeholders.
Continuous improvement: Evolving our reporting as standards develop to ensure data remains robust, decision-useful and reflective of our impact.

Through this approach, we aim to provide consistent, high-quality disclosures that support informed decision-making and strengthen stakeholder trust.

Swiss code of obligations

We also comply with the Swiss Code of Obligations (CO), related to the transparency on non-financial matters. Below, we provide a table with indications of where to locate the relevant sections of the reporting on this CSR website.

Swiss CO: Transparency on non-financial matters

Swiss CO: Transparency in raw material companies

Swiss CO: Due Diligence and Transparency in relation to Minerals and Metals from Conflict-Affected Areas and Child Labour

Business principles

Mercuria’s Business Principles provide the seven guiding principles for how we conduct business. 



We comply with all applicable laws, rules, and regulations.

Compliance is a fundamental part of how Mercuria operates across global markets. We are committed to complying with all applicable laws, rules, and regulations in every jurisdiction in which we do business, and to maintaining transparent and constructive engagement with regulators. These expectations apply across our organisation, with all employees accountable for understanding and adhering to the requirements relevant to their roles. We also expect our business partners and supply chain actors to uphold equivalent standards of compliance, integrity, and responsible business conduct.



We conduct ourselves with integrity and operate ethically.

Integrity and ethical conduct are central to the way Mercuria operates. We are committed to upholding the highest legal, ethical, and professional standards across our business, responsible sourcing standards, and in our relationships with counterparties and other stakeholders. We have signed the Commitment to Adopt and Implement the Stakeholder Capitalism Metrics of the International Business Council (IBC) of the World Economic Forum (WEF), supporting a more consistent and systemic approach to environmental, social, and governance considerations linked to long-term value creation.

We support these commitments through a robust Know Your Customer (KYC) process, which all counterparties must complete before any transaction can proceed. This process helps us assess alignment with our legal and ethical standards and supports the appropriate management of interactions involving governmental agencies and politically exposed persons. In doing so, it helps employees engage lawfully and professionally while avoiding any actual or perceived undue influence. Our due diligence also extends across our supply chains to help promote and ensure legal compliance, ethical conduct, and responsible business practices.



We act responsibly towards human rights, society, and the environment.

Mercuria is committed to respecting human rights and to conducting its business responsibly and with integrity across its operations and relationships. We maintain robust due diligence policies and procedures to identify, prevent, mitigate, and address risks across our operations, counterparties, and supply chains. Through this approach, we seek to promote responsible business conduct throughout our value chain.

We also recognise the importance of local engagement in supporting responsible operations. Where we operate facilities, we prioritise hiring local people, helping to support employment and economic development while ensuring our operations are informed by local knowledge and carried out with sensitivity to the communities in which we work.



We maintain accurate financial and non-financial records and reporting.

Accurate record-keeping and reporting are fundamental to Mercuria’s commitment to transparency, accountability, and integrity. We require that all financial and non-financial information be recorded, retained, and reported accurately, completely, and in accordance with applicable legal and internal requirements, including Mercuria’s Record Retention Policy. Mercuria has zero tolerance for the falsification of records or the submission of misleading information to regulatory authorities, financial institutions, or other stakeholders.



We value and respect our people, partners, and others connected to our business.

People are at the heart of Mercuria’s business. We value the diversity of our workforce across geographies, cultures, ages, educational backgrounds, and professional experience, and we believe that diverse perspectives contribute to stronger decision-making and better business outcomes. We promote an open and collaborative working environment that supports dialogue, inclusion, and effective teamwork across our business.

We are equally committed to protecting the health, safety, and security of our people. Supported by a dedicated health and safety team, we assess working conditions and implement appropriate safeguards across our operations and assets. We conduct due diligence on health, security, and safety aspects across our supply chains. Clear reporting channels, together with robust policies and standards, help us promote best practice and support a strong culture of health and safety.



We commit to driving sustainable change and innovation in our industry.

Mercuria supports sustainable change and innovation across the industry through investment, operational improvement, and responsible business practices. We achieved our commitment target to allocate more than 50% of our investments to innovative energy transition solutions by 2025 ahead of time, and have invested more than $2 billion to date in support of the energy transition. We continue to invest in technologies and businesses that contribute to a lower-carbon economy.

We also seek to embed environmental considerations into our day-to-day operations. Employees are expected to take environmental factors into account in procurement decisions, alongside price, performance, quality, and availability. Across our offices, we have introduced policies and practices covering office supplies, energy use, responsible paper consumption, and recycling. In parallel, our asset companies continue to enhance operational performance and reduce emissions, including through the use of carbon capture technologies at selected operations.



We protect Mercuria’s employees, assets, interests, and reputation.

Protecting Mercuria’s people, assets, interests, and reputation is a shared responsibility across the organisation. Our Business Principles and Code of Conduct set clear expectations that go beyond legal and regulatory compliance, requiring employees to safeguard our information, data, physical assets, and wider business interests. We also seek to uphold our responsibilities as a corporate citizen by acting with integrity in our business dealings and with respect for the communities and environments in which we operate.

Governance committees

Mercuria operates a number of number of key committees to support the Board of Directors in fulfilling its oversight responsibilities. These committees ensure that critical areas of the business are subject to rigorous review, challenge and accountability.

Executive Committee

The Executive Committee meets on a daily basis and is composed of senior management from across the firm’s commercial and Federation functions. It provides oversight across trading risk, deal execution, finance matters, current and future investments, as well as compliance and corporate governance.

Compliance & Business Ethics Committee

This committee supports the Board in overseeing the Company’s compliance and ethics framework, including policies, procedures and controls designed to ensure adherence to legal and regulatory requirements.

Group Audit Committee

The Group Audit Committee is responsible for financial governance and oversight across the Group. This includes ensuring the accuracy of financial reporting, compliance with regulatory standards and the effectiveness of internal controls and record-keeping systems.

Trading Risk Committee

The Trading Risk Committee meets weekly to review market and trading risks across the firm’s activities. It brings together senior risk managers from both commercial and Federation functions to ensure disciplined risk management.

Investment Committee

The Investment Committee reviews and provides oversight on all principal investments and material decisions related to the portfolio. It ensures that investments are aligned with the Group’s broader strategy, including its approach to the energy transition and the development of complementary assets.

Health, Safety, Security & Environmental Committee

The HSSE Committee plays a central role in overseeing health, safety, security and environmental performance across Mercuria’s operations and assets. Comprising senior executives from across the business, the committee ensures that robust policies, procedures and controls are in place and consistently applied.

Its work is guided by three core principles:

People welfare: prioritising the safety and well-being of employees, contractors and the communities in which we operate
Environmental responsibility: ensuring operations are conducted in line with environmental standards, permits and best practices, with prompt corrective action taken where required
Robust security: strengthening protection against physical and cyber threats through appropriate controls and vigilance

The committee’s oversight extends across a broad range of areas, including process safety, security, crisis and emergency management, regulatory compliance, environmental protection and continuous improvement of operational practices. Its mandate also allows it to address emerging risks and evolving requirements as they arise.

Together, these committees form a comprehensive governance framework that supports disciplined decision-making, effective risk management and responsible business practices across the Group.

Financial responsibility

Mercuria is dedicated to fulfilling its legal and social obligations when it comes to tax. We consistently strive for best practices in accuracy and timeliness, across the thousands of tax returns filed by our finance team each year.

Mercuria’s approach extends beyond regulatory compliance. We are committed to ensuring that our operations across all jurisdictions, including low-tax jurisdictions, are underpinned by genuine commercial substance and real economic activity. In situations involving complex tax issues or material uncertainty, we consult external advisers to support responsible, well-informed, and transparent outcomes.

We value open and trust-based relationships with tax authorities across all our operating jurisdictions. This commitment is reflected in our approach:

Diligent compliance: We adhere to all relevant tax legislation, regulations and obligations in each jurisdiction
Prompt and accurate filings: We ensure that all tax returns, filings and payments are completed accurately and on time
Responsible tax contribution: We pay the appropriate amount of tax in line with applicable laws and our business activities
Collaborative engagement: We work proactively with tax authorities to address material uncertainties and seek early alignment where appropriate
Zero tolerance for evasion: We do not tolerate any form of tax evasion, including by individuals acting on behalf of Mercuria

This approach is intended to ensure that our tax practices remain responsible, transparent, and aligned with the long-term sustainability of our business and the communities and jurisdictions in which we operate.

Code of conduct

Mercuria’s Code of Conduct is central to how we do business and underpins all activities across the Mercuria group of companies. Employees are expected to uphold Mercuria’s high ethical, legal, and professional standards, and to reflect these principles in all internal and external interactions. We also expect our partners and counterparties to adhere to equivalent standards of integrity and responsible business conduct.

Our Code of Conduct establishes a clear framework for how we do business, embedding ethical behaviour, compliance, and accountability across all areas of our operations. All employees are expected to uphold these standards and are supported by a global compliance training programme designed to ensure a consistent understanding of responsibilities and expectations across jurisdictions and functions.

New employees are introduced to the Code of Conduct through structured onboarding, with particular focus on key areas such as whistleblowing procedures and responsible business practices. Ongoing training is provided across topics including market conduct, regulatory compliance and ethical decision-making, ensuring that standards are consistently upheld across the organisation.

These principles are reinforced through our engagement with business partners. We have procedures in place to ensure that relevant counterparties are aware of Mercuria’s Business Principles and Code of Conduct, and we expect them to operate in line with these standards as part of our broader commitment to responsible and ethical trading.

As part of our whistleblowing framework, we maintain a Speak Up channel that reinforce our culture of openness, accountability, and trust. These processes provide employees and external stakeholders with clear and accessible channels, including the option to report anonymously where preferred, to raise concerns or report potential breaches of our Code of Conduct, internal policies, or applicable law. They cover both grievances and whistleblowing matters, ranging from workplace concerns to more serious issues, including unethical conduct, environmental impacts, and human rights risks along our supply chains.

All concerns are handled confidentially by our Corporate Responsibility and Compliance teams, with appropriate follow-up and investigation where required. Individuals may raise concerns anonymously, and Mercuria maintains a strict non-retaliation policy to protect those who speak up in good faith.

The Code of Conduct is made accessible across the organisation and externally, reinforcing our commitment to transparency, accountability and responsible business practices.