Ethics & Compliance

Our commitment to ethics and compliance starts at the top. Our senior management leads by example and behaves in a way that is expected of all our team members. Each member of the leadership team is involved in and supports the compliance programme, which is embedded in the company’s day-to-day business practices.

Compliance philosophy

The management of the compliance risk is overseen by the whole management structure of the company.   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.

Our Ethics and Compliance Framework includes our Values, Code of Conduct and a range of policies, standards, procedures and guidelines on various key issues and risks for AGORA Commoditiies & Logistic. This framework reflects our commitment to responsible and ethical business practices.

 

Conflict of Interest

Even if we believe that we are acting in the best interests of AGORA Commodities & Logistic, the mere appearance of a conflict can undermine confidence in both AGORA and us as individuals, as well as undermine Agora’s internal controls.
We must try to avoid conflicts where possible. If we are unsure about whether a situation presents a conflict, we consult Compliance.

Types of conflicts we must declare are:
• having an ownership, a shareholding and/or a directorship in a third party

• having a personal or business relationship with a third party

• acting as a consultant, employee, director, officer or manager for another company or organisation where the outside activity or employment will conflict with the performance of our job at AGORA, or could affect our objectivity

• working with or considering hiring a relative or close personal relation (e.g. considering a job application from one of our relatives or close personal relations or being in a position to influence factors surrounding the application such as direct and indirect reporting relationships, remuneration and promotion)

• offering, providing or accepting gifts or entertainment, to or from a third party while we are evaluating whether to enter into an agreement or transaction with such third party

• managing, directly or indirectly, a close personal relation.

Once we have declared a conflict, steps will be taken to ensure that the conflict is managed appropriately. We may be required to relinquish a position or have our work activities restricted (e.g. preventing us from taking part in decisions, joining meetings on the conflicting subject matter or receiving certain information).

 

Information governance

We differentiate between various types of information to enable data identification and define ownership, sensitivity, management and appropriate protection during its life cycle.  We implement procedures and systems to ensure that we manage and protect company information properly.

We do not share confidential company information, unless we are entitled to do so and it is required for our business activities, or to comply with legal or regulatory obligations. We only retain company information for as long as it has value to the business and where it is required for legal or regulatory purposes.

Protection of personal data
We collect, use and keep personal data only for lawful purposes and as required to meet business requirements. We follow applicable procedures when dealing with personal data and we promptly report any personal data breaches to the local data protection contact person or to Human Resources, Legal, Compliance, or Information Technology.

Information retention and destruction
We are committed to complying with applicable data retention and destruction obligations which require us to retain company information for as long as required for legal, compliance or business purposes and to destroy information – in particular personal data – after expiry of the applicable retention period.

Information security
We safeguard company information and are careful who can access it. We recognise the value of company information and work in a secure way to protect and ensure its integrity.
We recognise the cyber risks we face and use tools, systems and processes with clear ownership and accountability to adequately protect our information, based on its commercial value and sensitivity. We are committed to protecting AGORA’s information as well as the information relating to our workforce, former employees, business partners and other stakeholders and to complying with all legal requirements regarding its identification, protection, use, retention and destruction.

Fraud Policy

We do not engage in fraudulent behaviour and we do not knowingly assist or facilitate any third party to commit fraud.
Fraud is the act of engaging in deceptive or intentionally misleading activity in order to obtain an unfair or illegal financial or personal gain.

The following activities, amongst others, may constitute fraud:
• destroying, manipulating, altering, or forging company records
• manipulating financial or accounting  records
• knowingly creating ’fake’ contracts which do not reflect the true nature of the contractual relationship, such as contracts that we have no intention of performing, or contracts that do not accurately describe the intended transaction
• backdating contracts to misrepresent the signature date
• knowingly creating or paying false claims or invoices
• falsifying or duplicating expense claims, and
• deliberately misrepresenting, concealing or not disclosing material facts relevant to a decision or transaction.

We require team members and employees to be alert to any unusual or suspicious arrangements which could expose us to the risk of fraud and to report any such arrangements to Compliance.

Anti-Corruption and Bribery

We do not tolerate bribery of any kind, whether to a public official or a private individual.
We never offer, provide or authorise bribes of any kind, including facilitation payments, either directly or indirectly, to a public official or a private individual.

We never request or accept bribes of any kind, either directly or indirectly.

A bribe may be monetary or non-monetary, tangible or intangible. A bribe may take the form of, or be facilitated through:

  •  payments of money
  •  gifts or entertainment
  •  discounts, loans and/or financing given on non-commercial terms
  •  rebates or kickbacks in relation to services provided
  • overpayments to business partners
  • use of assets at a discount or free of charge
  • sponsorships, charitable contributions and community investments
  • political contributions
  • employment or internships, or
  • information or assistance.

To manage our bribery and corruption risk, we implement a range of procedures and controls relating to dealings with public officials, gifts and entertainment, our business partners, sponsorships and donations, political contributions and record keeping.

We remain alert to corruption and bribery red flags and report them to Compliance.

 

Public officials
Dealing with public officials brings a higher risk of corruption or the perception of corruption.
We are especially careful when communicating with public officials, exchanging gifts and entertainment with public officials or providing assistance to public officials.

 

Gifts and entertainment
The proper management of the giving and acceptance of gifts and entertainment is key to avoiding the risk they present of actual or perceived bribery or corruption.

We only give or accept gifts and entertainment that are:
• in good faith, occasional, reasonable and appropriate
• a normal business courtesy, and
• transparent.

We don’t give or accept gifts and entertainment:
• with the intent or prospect of influencing decision-making or other conduct
• with the intent obtaining any improper or undue advantage
• which are reasonably capable of being regarded in any way as a bribe, or
• in the form of cash, which includes pre-paid cards or gift cards which can be redeemed for cash.