COMPLIANCE & ETHICS
During the last decade, Gunvor has spent millions of dollars building an industry-leading Compliance Department. Our teams work continuously to improve company procedures to mitigate risks and anticipate others that exist within the commodities trading sector. Our goal is to maintain the highest ethical standards and comply with all relevant rules and regulations wherever we operate.
GOVERNANCE
Gunvor’s Compliance Department is bound by strong corporate governance, which provides a robust process for identifying risks and sound oversight to ensure effective risk mitigation. The Group Compliance Committee (GCC) oversees Group’s Compliance activities. The GCC includes senior members of Gunvor’s Executive Committee, as well as representatives from Legal and Compliance. It reviews all aspects of the Compliance risk mitigation plan and acts as a point of escalation.
PERSONNEL
In addition to Gunvor’s Group Compliance Director, the company has a dedicated Director position for anti-bribery and corruption (ABC) and anti-money laundering (AML), as well as compliance officers located directly on trading floors next to trading personnel. They work in conjunction with Risk Officers providing oversight for every trading desk. Gunvor’s Compliance Directors further lead the company’s Compliance training program. Gunvor’s Group Compliance Committee oversees the effectiveness of the program.
CEASED USING AGENTS FOR BUSINESS DEVELOPMENT
EDUCATION &
AWARENESS
Gunvor has mandatory annual training for every employee covering many areas such as ABC, AML, market abuse and market conduct, economic sanctions, and other topics. Risks and related policies are discussed. The latest developments in Compliance thinking are addressed. These sessions are complemented by regular communications from Gunvor’s Compliance team to the company, highlighting topical compliance-related issues, such as market news of breaches and fines, and the latest developments around the world. All relevant staff must complete the training. Gunvor’s business partners also undergo training.
THIRD-PARTY
AUDITS
Gunvor hired international compliance experts to assist with enhancing Gunvor’s global program. To ensure consistent growth in line the latest regulatory and market developments, Gunvor’s Compliance Department also undergoes regular external audits, for benchmarking and assessment, that are conducted by Big Four firms.
INTERNAL
AUDITS
To test our internal functions across the Group, Gunvor has established an Internal Audit Department to provide independent and objective assessments of business activities, operations, financial systems, and the internal control environment of Gunvor. During the last 5 years, the Audit team has conducted about 65 internal audit engagements, covering activities such trading desks, assets, central functions and processes, joint-ventures and advisory mandates. Findings have resulted in the reduction of overall risk and the correction of insufficiencies through enhanced controls and greater overall awareness about the seriousness with which Gunvor takes adherence to policy.
TECHNOLOGY
Gunvor has invested millions of dollars in the latest IT systems to assist with counterparty and agent due diligence and tracking, ensuring all employees have access to system data. Counterparties and related parties in CMS are also screened daily against external, third-party vendor systems, which monitor for such information as sanctions violations and PEP exposure, or other relevant events. The same applies for Gunvor’s vessel screening.
CMS
All Gunvor trading and operational systems are linked with the Counterparty Management System (CMS), centralizing all counterparty due diligence within a single, controlled environment. CMS ensures uniformity of processes and oversight. For example, all payments for the company are checked against CMS before any transfer of funds can be made. Due to the centralized nature of the system, Compliance can react to any new information and, if required, deactivate a counterparty in all company systems within minutes. Vessels and owners are also screened daily through the CMS process.
VESSEL
SCREENING
Gunvor works with Pole Star for vessel screening. The PurpleTrac system is fully integrated within Gunvor’s CMS, leveraging its interface and escalation technology. On any single day, approximately 15 vessels are screened by Gunvor’s chartering teams. Compliance vessel screening is also integrated with the operational vessel vetting process, which ensures that comprehensive vessel screening must be completed prior to any vessel chartering.
SANCTIONS
Gunvor takes sanctions obligations very seriously. Throughout the counterparty due diligence process, sanctions checks are carried out both through third-party systems and our own internal processes. On a daily basis, Gunvor vets its entire list of business counterparties and relevant associated individuals. Gunvor’s team further regularly engages directly with governments that impose sanctions to ensure we understand the latest developments and actions.
paid to governments in 2021
POLICIES
Gunvor has established clear policies for ABC, AML, market conduct, market abuse, economic sanctions, and other risk areas. They have been communicated from the topdown. Importantly, we have also created a whistleblowing policy that has been clearly communicated by the CEO to all Gunvor employees. Specifically regarding ABC, policies and procedures and systems and controls meet standards put forth by the US. Foreign Corrupt Practices Act, UK Bribery Act and those propagated by the OECD. With respect to breaches, Gunvor maintains a zero-tolerance approach.
TRANSPARENCY
Gunvor has expressed support for the Extractive Industries Transparency Initiative (EITI) to establish a consistent means by which to reliably report on its payments to governments, with the aim to improve transparency and reduce the potential for corruption in cooperation with these governments. Gunvor’s reporting includes purchases of crude oil and refined oil products acquired from state-owned enterprises in EITI implementing countries.
TRADE PROCESS
