Human rights

Operating across the global market, our activities and supply chains intersect with various societies, each governed by its own set of laws and regulations. At Mercuria, we comply with all the local laws and regulations in the jurisdictions we operate in, while also adhering to internationally recognized human rights standards.

Our commitment to respecting human rights is aligned with international best practices, including the UN Guiding Principles (UNGPs) on Business and Human Rights and the Ten Principles of the UN Global Compact. These principles are embedded in our policies and processes and help shape the actions of our employees and stakeholders across our business activities and supply chains. 

Our Modern Slavery, Conflict Minerals, and Supply Chains & Responsible Sourcing policies are in accordance with the Swiss Ordinance on Due Diligence and Transparency for Minerals and Metals from Conflict-Affected Areas and Child Labour (DDTrO), in specific Articles 10 and 11.

More broadly, we regularly review and update our policies and practices to reflect evolving legal requirements, international standards, and emerging best practices in the field of human rights. In line with applicable UK Modern Slavery Act 2015, we review and update our Human Rights Policy annually. Through this ongoing process, we seek to ensure that our operations remain aligned with current expectations and continue to support the promotion and respect of human rights within our area of influence.

Mercuria maintains a zero-tolerance policy on modern slavery and child labour. We are
committed to combating all forms of exploitation, in line with the UK Modern Slavery Act
2015 and the International Labour Organization’s Conventions on child labour. We expect
all our employees, assets, suppliers, supply chains, counterparties, vendors, and partners
to uphold these principles and conduct business in alignment with our standards. This commitment translates into concrete actions: 

• Rigorous due diligence: We assess potential and existing investments, acquisitions, business partners, suppliers, and customers to identify, prevent, and address risks related to modern slavery.
• Contractual safeguards: Our contracts include clear requirements to comply with applicable anti-slavery laws and standards, helping to ensure that all counterparties are held to high ethical expectations.
• Comprehensive policies: We maintain dedicated policies that set out the responsibilities of our employees in preventing modern slavery across our operations. These policies are reviewed and updated regularly to reflect developments in relevant laws, regulations, and international frameworks.
• Training and awareness: Mercuria employees are provided with the knowledge and tools needed to identify, escalate, and report potential indicators of modern slavery.
• Stakeholder collaboration: We engage with a range of stakeholders, including NGOs, universities, and industry partners, to share best practices, raise awareness, and contribute to collective efforts to address modern slavery.

We apply a systematic, layered approach to risk assessment and due diligence across our
operations and business relationships. This approach spans multiple levels:

• Country risk which covers risks such as child labour (based on UNICEF’s Children’s
  Rights in the Workplace Index), conflict-affected and high-risk areas
  (CAHRAs), corruption, and forced labour;
• Jurisdictional risk within specific regions or provinces where risks such as forced labour and child labour may be heightened;
• Counterparty risk with all counterparties subject to KYC checks in line with Mercuria’s KYC Policy;
• Operation- or product-specific risk can be independent of the counterparty and is specific to human rights and environmental risks at the operations; and
• Supply chain risk including human rights risks associated with upstream suppliers and with affected communities.

Mercuria believes that eradicating modern slavery requires collective action. We are committed to playing our part in promoting respect for human dignity and fundamental rights.

Our Modern Slavery policy reflects our zero-tolerance approach to child labour and our commitment to helping eliminate it. The policy is aligned with ILO Convention No. 138 on minimum age for employment, ILO Convention No. 182 on the worst forms of child labour, and the UN Guiding Principles on Business and Human Rights.

In addition to the rigorous child labour due diligence conducted during the onboarding of assets and counterparties prior to trades and investments, we maintain ongoing monitoring of supply chain actors to help ensure that child labour is not present after onboarding. We give additional attention to product supply chains originating from countries classified as having “enhanced” or “heightened” child labour concerns under UNICEF’s Children’s Rights in the Workplace Index, as reflected in the Swiss DDTrO. Based on our review of current and historical trades, we have identified no grounds to suspect that child labour has been linked to our activities.

We are further align with the ILO-IOE Child Labour Guidance Tool for Business into our supply chain system to strengthen human rights risk identification and mitigation.

Although Mercuria does not trade in quantities of significance relative to the conflict minerals (tin, tantalum, tungsten, and gold, collectively known as “3TG”) as outlined in Annex 1 of the DDTrO, our Supply Chains & Responsible Sourcing and Conflict Mineral policies reinforce our alignment with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.  

All our mineral supply chains undergo our rigorous supply chain due diligence, including those from conflict-affected and high-risk areas, as highlighted in our Responsible Sourcing section.

We proactively engage with NGOs, universities, researchers, and other relevant stakeholders, recognising the value of their perspectives and incorporating their insights into our decision-making. Through constructive dialogue and collaborative initiatives, we seek to promote respect for human rights and environmental sustainability across our operations and value chains.

Minerva Bunkering’s fleet management division, MM Marine, joined more than 600 companies and organizations in signing the Neptune Declaration on Seafarer Wellbeing and Crew Change. 

The Declaration sets out four key actions: recognizing seafarers as key workers, implementing robust health protocols, strengthening collaboration between ship operators and charterers, and improving air connectivity between major maritime hubs.

Mercuria and Minerva are committed to supporting seafarer welfare and ensuring safe, effective crew changes that help maintain resilient global supply chains.

Mercuria continues to partner with the Institute for Human Rights and Business (IHRB), engaging actively in its work through participation in roundtables and discussions, as well as contributions to research through interviews. Key areas of engagement included seafarer recruitment fees and the human rights implications of the green transition for affected communities. This partnership strengthens our responsible business network, helps us stay informed of emerging human rights issues, and supports the integration of relevant insights into our risk monitoring and mitigation measures across our operations.

Mercuria partnered with the University of Geneva’s Geneva Center for Business and Human Rights (GCBHR) through the Business and Human Rights (BHR) Clinic, where nine students collaborated with us on the topic of responsible artisanal mining in the Democratic Republic of the Congo. Drawing on independent research, Mercuria’s practical experience in the metals sector, expert input, and external sources, the collaboration developed a risk framework for artisanal mining formalization and project-based training grounded in real-world sector practice. The final training product places learners in realistic scenarios, exposing them to the real-world challenges and pressures involved in ASM formalization.