Ethics & compliance

Our commitment to ethics and compliance starts with the leadership. Our senior management leads by example, acting in the manner expected of all our employees.

Overview

Our commitment to ethics and compliance starts with the leadership. Our senior management leads by example, acting in the manner expected of all our employees. Every member of the leadership team is engaged in and supportive of the compliance programme which is embedded in the company’s day to day business practices.

Vitol’s compliance philosophy

The management of the compliance risk is overseen by a global compliance team located in London, Houston and Singapore. Ensuring compliance with laws, regulations and standards is the responsibility of all our employees. We are all responsible for conducting our business in a way that meets our commitment and strengthens compliance across the organisation.

The compliance programme

The compliance programme is a key pillar underpinning Vitol’s commitment to the highest standards of corporate responsibility and to doing business with integrity. It is designed to reflect the high standard of ethics to which Vitol holds itself, the complex and multi-faceted business in which it operates and to ensure compliance with appropriate laws, regulations and international standards. The compliance programme is continuously reviewed and enhanced, alongside policies, processes and controls, to meet evolving compliance needs.

The compliance organisation

The global compliance team comprises 20 experienced professionals with expertise in regulatory and corporate compliance. In addition to these dedicated compliance professionals, Vitol has implemented a programme to create 37 ‘compliance champions’ in local offices and Vitol-controlled businesses that do not otherwise have a local compliance team. The compliance champions programme is designed to make compliance more accessible to all our employees, as well as articulating feedback to compliance suggestions and challenges faced by local offices. In addition, compliance liaises with, and draws additional resources from, other risk functions to ensure an integrated approach to implementing the compliance programme.

Key policies and procedures

Know Your Customer (KYC) Policy

The policy has been designed based on the Joint Money Laundering Steering Group (JMLSG) guidance. In addition, the policy and related controls use resources and recommendations from international standards such as the OECD and UN Principles, as well as Transparency International’s Corruption Perception Index, Know Your Country Rating and Control Risks Corruption Index.

Anti‐Bribery & Corruption (ABC) Policy

The policy was designed using resources such as the UK Ministry of Justice and the US Department of Justice guidelines, as well as international standards published by the OECD and the UN. It was designed following an extensive process to map the ABC risks Vitol faces globally, and takes into consideration its activities, countries of operation, the way Vitol transacts, how it manages its relationships with its intermediaries and its trading counterparties.

Sanctions Policy

The principal objective of Vitol’s sanctions policy is to ensure compliance with relevant laws and provide a framework for employees to seek advice from compliance and legal in relation to a transaction or potential transaction.
Changes to all relevant sanction regimes, including but not limited to US OFAC, EU Official Journal, Swiss SECO, and UK HM Treasury are monitored and tracked on a daily basis.

Train

Training is essential to the implementation of the compliance framework.

The compliance team is responsible for developing and implementing a global and regional training programme which covers key compliance risks and incoporates the technical, complex and ever-changing laws and regulations that govern our business. Because different roles and jurisdictions have different compliance requirements, training is tailored as required and uses online tools as well as face-to-face delivery.

Monitor

Compliance has a mandate to monitor and evaluate the programme.

This monitoring aims to identify the effectiveness of controls and reduces the risks of breaches of laws, regulations or procedures. The frequency and extent of the monitoring is risk-based. When compliance-lead reviews or internal audit detect weaknesses with the programme, the appropriate corrective action is taken.

Report

All employees are shielded by our commitment to protect whistle-blowers.

Employees are required to report any breach, or the risk of any breach, of the laws, Vitol policies or procedures. We have in place a global integrity hotline. Operated by an independent third party, the hotline enables employees to raise any issues of concern with senior management, anonymously and in confidence.

Investigate

Investigation and consequence of non-compliance

Compliance, alongside the legal team, may conduct an investigation of potential breaches or areas of concern. Employees who have failed to comply with the code of conduct, policies and procedures might be subject to disciplinary action

Our compliance programme in action

“Our compliance culture is as an ethical compass that helps colleagues interpret business decisions in the best interests of the organisation and each other.”

“Vitol’s focus is on embedding a compliance culture across the company, a culture which relies on people’s judgement and not just box ticking.”

“We empower colleagues to take decisions, encourage them to think about how their decisions impact other people, the reputation of the company and the legacy that they will leave behind. Our leadership team strongly believe in this and set the culture from the very top: that we operate as a collective and the dissemination of this culture is facilitated by our flat management structure and the visibility of the leadership throughout the business.

“There is such a thing as a bad transaction and our role is to make sure that this is ingrained in our decision making.”

“The key to communicating our compliance culture successfully is positivity. “business prevention unit” to compliance as a “business enabler”.”

One of the core ways Vitol has embedded compliance into its operations is by articulating all the ways we have been successful by doing things in the right way. Ensuring that compliance frames the way we conduct business makes us a reliable, professional company who partners want to engage with and people want to join. By focusing on the commercial benefits, we have been able to raise the profile of compliance within the organisation not just as a necessary partner but a strategic one, which generates greater impact because our colleagues want to engage with us.”

“Our business, and the people who make up that business are changing.”

“We’ve expanded into new areas in the last two years and its compliance’s role to bring new colleagues on board and help explain who we are and what our company values are. In addition, we need to understand and adapt to the compliance challenges and risk these new businesses bring, as well as to the expectations of the new generation and how they view compliance culture in their company. This is a very interesting new horizon for the team. which is getting stronger year-on-year. We have a global team of colleagues who have a shared ethos around what compliance is and how we can support the business.”

Odile Roy de Puyfontaine, Global Head of Compliance

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