Approach
Compliance philosophy
Our commitment to ethics and compliance starts with the leadership. Our management leads by example, acting in the manner expected of all our employees. Every member of the leadership team is engaged in and supportive of the compliance program which is embedded in the company’s day to day business practices.
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 organization.
The compliance program is a key pillar underpinning Greenstone Trading’s commitment to the highest standards of corporate responsibility and to doing business with integrity. It is designed to reflect the high standards of ethics to which Greenstone Trading holds itself, the complex and multi-faceted business in which it operates and to ensure compliance with appropriate laws, regulations and international standards. The compliance program is continuously reviewed and enhanced, alongside policies, processes and controls, to meet evolving compliance needs.
Key policies and procedures
Know Your Customer (KYC) Policy
The policy has been designed using the best international practices. In addition, the policy and related controls use resources and recommendations 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 policy was designed using international standards published by the OECD and the UN. It was designed following an extensive process to map the ABC risks Greenstone Trading faces and will face globally, and taking into consideration its activities, countries of operation. It reflects the way how Greenstone Trading transacts, how it manages its relationships with its intermediaries and its trading counterparties.
Prohibited transactions, trade restrictions and anti-boycotts policy
The principal objective of Greenstone Trading’s sanctions policy is to ensure compliance with relevant laws and provide a framework for employees to seek advice from compliance and legal team in relation to a transaction or potential transaction.
Changes to all relevant sanction regimes, including but not limited to US OFAC, EU Official Journal, UN and others are monitored and tracked constantly.
AML & CFT Policy
The Policy on Anti-Money Laundering, Combatting the Financing of Terrorism and the Proliferation of Weapons of Mass Destruction (AML & CFT) of Greenstone Trading has been designed in line with international standards in the area of AML/CFT control. The Policy applies to all company’s employees and executives doing business in Russian Federation and globally.
Conflict-of-Interest Management Policy
Greenstone Trading policy on conflict-of-interest management defines the main goals, objectives and general principles of the conflict-of-interest management system applied in the company, to its employees, their functions as well as the stages of conflict-of-interest management. The Policy is part of the compliance risk system management and sets out our approach to recognizing and avoiding conflicts of interest and declaring conflicts of interest. We always act in Greenstone Trading’s best interests, try to avoid actual, potential or perceived conflicts of interest.
Risk management
Our ability to effectively manage the risk inherent in commodities trading is fundamental to Greenstone’s continued development and stability.
Financial, operational and market risks are an integral element of structured financing, commodities trading and physical supply. They cannot be wholly avoided, but can be planned for and managed. Risk assessment procedures are determined centrally, exposures are analyzed daily, and our procedures are continuously reviewed and updated.
Greenstone applies a range of risk management tools to minimize overall exposure at any one point in time. These include:
- Financial derivative instruments to hedge commodity price and foreign currency exchange rate risks
- Insurance to hedge various operational risks including freight-related and other risks
- Ready access to sufficient capital and funding to hedge liquidity risk
- Comprehensive credit analysis, strict policies and procedures to manage counterparty exposure risk, fraud and regulatory risks (including ESG compliance)