The reason people trade with us.

No trade is executed with a counterparty that has not completed onboarding. We verify legal identity and good standing, establish ultimate beneficial ownership, identify politically exposed persons, and check the parties and their directors against sanctions and adverse-media sources.

Files are refreshed on a risk-based cycle, and immediately on any change of ownership or control. Higher-risk relationships require enhanced due diligence and sign-off above desk level.

We screen counterparties, cargo origin, vessels, owners, operators and flag against applicable sanctions regimes before fixture — not after loading. Vessel checks include ownership structure, port-call history and AIS gaps that could indicate concealed movements.

We do not deal in cargo of sanctioned or undeterminable origin. Where provenance cannot be evidenced to our satisfaction, the transaction is declined, and that decision is not subject to commercial appeal.

We prohibit bribery in every form, direct or through a third party, including facilitation payments. Agents, brokers and intermediaries are diligenced before appointment, paid at defensible commercial rates against a written contract, and required to accept our standards in turn.

Gifts and hospitality are subject to thresholds and a register. Political donations are not made on behalf of the company.

Payments are made and received only to and from the contracting counterparty, through accounts in the jurisdiction of that entity. We decline third-party payment requests and unexplained routing through unrelated jurisdictions.

Transactions are monitored for patterns inconsistent with the commercial rationale of the trade, and suspicious activity is escalated and reported as required by law.

We compete on merit. Our people are prohibited from exchanging commercially sensitive information with competitors, coordinating on price or allocating markets, and from trading on the basis of material non-public information.

Any submission to a price reporting agency must be accurate and reflect genuine transactions. Attempting to influence a benchmark is a dismissible offence.

Market, credit, country, liquidity and operational risk limits are set by management independently of the trading desk and monitored daily. Breaches are escalated rather than netted away.

Deal capture, confirmation, settlement and accounting are separated from execution. No individual can originate, confirm and pay for the same transaction.

Counterparty terms, volumes and pricing are treated as confidential and shared internally only where there is a need to know. Personal data is processed lawfully, kept only as long as required, and protected by access controls appropriate to its sensitivity.