Responsibility

# Conduct, compliance and sourcing

Physical trading carries obligations to the people who handle our cargoes and the places they pass through.

### Conduct & Anti-Corruption

A group Code of Conduct supported by anti-bribery and corruption, anti-money-laundering and anti-trust policies, with mandatory training across every desk.

### Counterparty Due Diligence

KYC at onboarding and on a rolling basis. Counterparties, directors and beneficial owners are screened against sanctions and adverse-media databases, with enhanced diligence for higher-risk relationships.

### Sanctions & Export Controls

Rathmar applies U.S. sanctions and export controls (OFAC and BIS) across all of its business, respects UN Security Council measures, and applies EU, UK, Swiss (SECO) and Turkish measures wherever they apply to our offices, staff or transactions. Counterparties, their owners and directors, banks, vessels, ports and cargoes are screened before a contract is signed and again before nomination, loading and payment. Rathmar does not trade with persons designated under the regimes that apply, or with entities they own or control, and does not trade into comprehensively sanctioned countries or regions. Business touching jurisdictions subject to targeted measures proceeds only where the transaction is permitted, including under humanitarian authorizations, and only after enhanced due diligence and Compliance sign-off. Dual-use and controlled goods are classified, and licensed where required, before shipment. See our [Sanctions & Trade Controls Policy](https://rathmar.com/sanctions-policy).

### End-Use & Diversion Controls

For sensitive goods and higher-risk destinations, including fertilizers, fuels, chemicals and dual-use items, Rathmar obtains end-use and end-user statements, screens the named consignee and receiver, and checks discharge and delivery documents against the contracted destination. Changes of destination, transshipment and ship-to-ship transfers need Compliance approval. Signs of diversion stop the trade.

### Health, Safety & Environment

Safe-handling requirements are written into every contract and verified with logistics providers: vessel vetting, tank and container standards, and dangerous-goods documentation on every movement.

### Product Stewardship

Safety data sheets and product documentation accompany every cargo; REACH, TSCA and food-safety registrations are maintained per market and per commodity. Metals shipments carry assay certificates and chain-of-custody documentation.

### Responsible Sourcing

Due diligence extends beyond sanctions. Across every book we assess the provenance of cargoes, with attention to traceability in agricultural supply chains and to provenance and chain of custody for mined material. Artisanal and small-scale mining, and sources in conflict-affected and high-risk areas, receive enhanced diligence. We decline business that fails our standards.

### Speak Up

Employees, counterparties, suppliers and anyone else may report suspected bribery, fraud, sanctions or export-control breaches, cargo diversion, money laundering, human-rights abuses or other misconduct to [speakup@rathmar.com](mailto:speakup@rathmar.com). Reports go to Compliance, are handled in confidence and need not include your name. Rathmar does not tolerate retaliation against anyone who raises a concern in good faith.

## Have a cargo to place or a supply chain to build?

[Contact a trading desk](https://rathmar.com/contact)

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Source: https://rathmar.com/responsibility