Ethics and compliance
Overview
Our commitment to ethics and compliance begins with our executives. Our senior management sets the standard for all of our staff to follow. Every member of the leadership team participates in and supports the compliance programme, which is integrated into the company’s day-to-day business activities.
A worldwide compliance team based in Sweden oversees the management of compliance risk. All of our workers are responsible for ensuring compliance with laws, regulations, and industry standards. We are all accountable for carrying out our business in a way that fulfills our commitments and strengthens compliance throughout the company.
The compliance programme
The compliance programme is a critical component of Vitol’s commitment to the highest levels of corporate responsibility and doing business with honesty. It is intended to reflect Vitol’s high ethical standards, the complex and multifaceted nature of its company, and conformity with applicable laws, regulations, and international standards. To meet changing compliance requirements, the compliance programme, as well as policies, processes, and controls, are constantly reviewed and improved.
The worldwide compliance team consists of 20 seasoned experts that specialize in regulatory and business compliance. In addition to these dedicated compliance professionals, Vitol has established a strategy to produce 37 ‘compliance champions’ in local offices and Triventus Biogas AB-owned enterprises that do not already have a local compliance team.
Key policies and procedures
Know Your Customer (KYC) Policy
The policy is based on the Joint Money Laundering Steering Group (JMLSG) guidelines. In addition, the policy and accompanying controls draw on resources and suggestions 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 strategy was developed utilizing resources such as UK Ministry of Justice and US Department of Justice guidelines, as well as international standards issued by the OECD and the United Nations. It was created after an exhaustive process of mapping the ABC risks Triventus Biogas AB faces globally, taking into account its activities, countries of operation, Vitol's transacting style, and how it maintains its relationships with its intermediaries and trading counterparties.
Sanctions Policy
The primary goal of Triventus Biogas AB's sanctions policy is to ensure compliance with applicable laws and to offer a framework for workers to seek guidance from compliance and legal on a transaction or potential transaction. Changes in all relevant sanction regimes, including but not limited to US OFAC, EU Official Journal, Swiss SECO, and UK HM Treasury, are watched and recorded on a daily basis.
Train
Training is essential to the implementation of the compliance framework.
The compliance team is in charge of establishing and delivering a worldwide and regional training program that addresses critical compliance concerns while also including the technical, complex, and ever-changing laws and regulations that govern our industry. Because compliance requirements vary by position and jurisdiction, training is customized and delivered both online and in person.
Monitor
Compliance has a mandate to monitor and evaluate the programme.
This monitoring seeks to determine the effectiveness of controls while reducing the danger of violations of laws, regulations, or procedures. The frequency and scope of monitoring are risk-based. When compliance-led evaluations or internal audits reveal flaws in the programme, appropriate corrective action is done.
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, along with the legal team, may conduct an inquiry into suspected breaches or areas of concern. Employees who have failed to comply with the code of conduct, policies, and procedures may be subject to disciplinary actions.