Our approach to compliance
Trafigura’s Compliance department oversees the Group’s global activities. It operates in partnership with front- and back-office functions to ensure that our controls are relevant, robust and aligned with the latest international standards. Trafigura’s Head of Compliance reports directly to the Group’s Chief Operating Officer and the Group’s Compliance Committee.
We maintain a responsible compliance culture where all staff recognise personal and collective responsibility. The high standard of behaviour we expect from all of our people is enshrined in our Code of Business Conduct (the Code) which is based on the highest standards of international law.
Principles of sound business conduct
Every member of staff must attest to receiving, understanding and complying with the Code, which sets out expected behaviours in all our business activities. All management teams are charged with promoting these behaviours across the Group. They are supported by our Compliance department.
External review of Trafigura’s Compliance programme
Leading external US law firm, with an extensive Compliance and Regulatory department, Quinn Emanuel Urquhart & Sullivan LLP, recently conducted a review of Trafigura Group’s compliance policies and procedures. The key findings were reported to the Trafigura Board of Directors as follows:
“Based on the materials we have reviewed, the briefings provided and our experience advising companies in various industries on compliance best practices, we consider the Compliance Function to represent an appropriate and proportionate approach to the compliance risks faced by Trafigura, which adequately seeks to minimise the risk of compliance failures.
As with any compliance programme, a continual system of review and incremental improvement should be adopted and it was encouraging to see the Compliance Function continue to improve and update its policies by, for example, reviewing and ensuring the programme had been tested against the DOJ’s latest guidance issued on 25 November 2020 and requesting and implementing advice even during the course of our review.
We consider the Compliance Function, as designed, to adequately meet the applicable standards and requirements of the UK Bribery Act 2010, the U.S. Foreign Corrupt Practices Act, and the European Anti-Money Laundering and Terrorist Financing Directives. We note that the compliance function adopts the universal application of the highest standard of compliance required by law across all jurisdictions in which it operates, even where those standards are higher than those imposed at a domestic level. We consider this to be the appropriate benchmark to ensure a thorough approach to risk mitigation is achieved.”