Anti-bribery and Corruption Compliance
During the last decade, Gunvor has highly invested into building an industry-leading Compliance Department. Our teams work continuously to improve company procedures to mitigate and anticipate risks that exist within the commodity trading sector. Our goal is to maintain the highest ethical standards and comply with all relevant rules and regulations wherever we operate.
Governance – Transparency
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)
serves as the main point of accountability for the 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.
Gunvor Compliance Department oversees all of Gunvor Group’s operations, ensuring that all activities are conducted within the requirements of applicable laws, regulations and Gunvor’s own principles of Ethics and Integrity, as stipulated in the Code of Conduct & Ethics.
As a fully integrated risk management department within Gunvor, the Compliance Department operates control systems, which allow Gunvor to identify and effectively manage compliance risks in a timely manner.
At year-end 2023, Gunvor’s Compliance Department is staffed with 32 professionals from various backgrounds, including Finance and Legal. They provide Gunvor with the best advice and risk management, drawn from a very
broad knowledge and experience base.
As Gunvor has an existing, well established, Compliance program, the Compliance department continues to reassess the risks and mitigation processes to ensure optimal risk mitigation and adapts quickly to changing business needs.
For more information on our compliance governance framework, please visit our dedicated webpage.
Gunvor compliance year in numbers
2023 Compliance
Programme in Focus
In 2023, the Compliance Department continued to apply, review, and reinforce the Know Your Customer (KYC) and Anti Bribery and Corruption (ABC) programs. We invested in training our teams, both internally and externally as well as learning from past cases to improve the quality and consistency of the due diligence. Quantity and quality due diligence management is key for our Compliance Department.
Anti-bribery & Corruption
As a company active in the global commodities markets, bribery, corruption and money laundering are major risks for the company and require significant resources.
Following our decision to cease the use of agents for business development, Gunvor now works with a limited number of consultants that focus on post-transaction or ancillary support such as technical operational service providers, whose services entail greater transparency and a different, lower risk profile. At the end of 2023, Gunvor was only working with three logistic agents, globally. Gunvor maintains strict controls to ensure they don’t provide any origination or business development-related services, in addition to the compliance protocols previously implemented (including inter alia enhanced due diligence, strict contractual framework and invoice control, monitoring of fees, review of activity reports, compliance training).
Following the end of external origination, Gunvor has wanted to ensure the appropriate level of controls and assurance is applied on internal business developers, as was applied to third party agents/consultants. Gunvor has thus developed a framework of controls on internal business developers. This framework is articulated around four pillars:
- Onboarding: there should be a specific mandate as part of the hiring of new business developers. Enhanced due diligence and a review of the potential conflicts of interest is also conducted.
- Training: Enhanced Anti-Bribery training is provided for onboarding of new business developers. Regular refresher training is also provided to business developers and their managers.
- Manager oversight: activity reports must be provided to the management of business developers and to Compliance. Senior members of the Compliance team also schedule meetings with business developers to better understand better their activity and the risk landscape of their scope.
- Monitoring and Surveillance: in line with the Business Communications Policy, communications of the Business Developers are monitored in case of need. Compliance also performs reviews of the expenses of business development staff as needed.
In 2023, Gunvor Compliance continued reinforcing its joint-venture procedures to ensure adequacy of review and monitoring.
Counterparty Due Diligence
All counterparty due diligence is centralised in a single compliance-controlled system, our “Counterparty Management System” or “CMS”, which ensures uniformity of processes, oversight, and control.
Gunvor continues to push forward with more automated and sophisticated controls, with improved ongoing screening tools connected with CMS.
As a player with mutliple counterparties in a dynamic industry, Gunvor must ensure that KYC reviews are regularly refreshed. To optimize this process, Gunvor has conducted 2 phases of deactivation in 2023, in both CMS and trading systems, for business counterparties that had not been used in a few years. To reactivate such counterparties in our systems, their KYC file needs to be refreshed. A dedicated team of KYC analyst has been hired to improve efficiency.
Due diligence quality is key to meet existing best practices and follow the evolution of the risk landscape. Internal audits are conducted at regular intervals, leading to recommendations that are implemented in relevant policies and procedures.