Response to the Public Eye report of 14th November 2018

Vitol’s compliance framework

Vitol is already obliged to implement robust due diligence and anti-bribery procedures under the UK Bribery Act 2010 and other similar legislation.

In common with financial institutions, commodity traders such as Vitol are subject to stringent laws in their dealings with Politically Exposed Persons (PEPs) including those relating to anti-bribery and anti-money laundering.

Vitol has implemented a rigorous compliance framework, to ensure that it complies with its legal obligations. This framework includes robust anti-bribery controls as well as due diligence processes relating to counterparties and other commercial contacts that are based on requirements set out in the EU’s 5th Anti-Money Laundering Regulations and the UK Bribery Act 2010.

Furthermore, Vitol has implemented systems and controls in line with the JMLSG guidelines and the Guidance from the UK Ministry of Justice.

Vitol regularly reviews its compliance policies and procedures to ensure that they remain robust and up to the standards required by our many partners and financiers.

Vitol engaged with Public Eye in respect of its investigation into activities in Kazakhstan and responded to its queries. Had Public Eye asked Vitol about its compliance procedures ahead of publishing its report, Vitol would have been pleased to provide this information.

Vitol’s activities in Kazakhstan

Vitol’s activities in Kazakhstan are fully compliant with the law and all applicable regulations.

Vitol SA’s pre-financing arrangements with KMG were awarded after open and competitive tenders.

Vitol’s joint venture, which operates in Kazakhstan, is not involved in the pre-financing arrangements with KMG.

We also note that there are some inaccuracies and misrepresentations in the report.

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