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Response to Public Eye – 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 that apply to financial institutions.

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.

Response to Global Witness – November 2018

Vitol has a zero tolerance policy in respect of bribery and corruption. Its business is managed in full compliance with all relevant legislation. Vitol was contacted in September 2018 by Global Witness and has since liaised extensively with it. The Global Witness report contains no evidence of any wrongdoing by Vitol.

In respect of Cockett: The arrangements in question were made three years prior to Vitol’s investment in Cockett in July 2012. Cockett cooperated fully with the Brazilian authorities in 2015 and no charges of bribery have been brought. Cockett understands the matter to be closed.

In respect of Encom: Vitol believes its dealings with, Mr Ljungberg, Encom Trading SA and Petrobras to be fully compliant with all relevant legislation. Appropriate due diligence was carried out prior to Encom’s appointment in 2011. At this time, there was no information in the public domain linking Mr Ljungberg with any of the alleged conduct referred to in the Global Witness report or anything else to suggest he may have been involved in criminal activity.