GOVERNANCE AND CONDUCT

CODE OF CONDUCT

Bulk Trading Code of Conduct

Bulk Trading Group is a dynamic and competitive trading group specializing in raw materials within the hydroelectricity, natural gas, and carbon fuels industries globally. We pride ourselves on our strategic position in production, marketing, and distribution. Our Code of Conduct sets the standards for interactions with customers, colleagues, investors, business partners, and regulators. Bulk Trading adheres to internationally recognized standards to ensure compliance with the law and expects its business partners to uphold similar best practices.

Compliance with Laws and Regulations

All business activities conducted on behalf of Bulk Trading must comply with applicable laws and regulations, including international sanctions. Employees are responsible for understanding and adhering to relevant legal requirements. In case of doubt, employees should consult with our Legal and Compliance team.

Compliance with Sanctions and Trade Restrictions

Bulk Trading does not engage in business with any country, entity, or individual if it would violate international sanctions laws. We are committed to full compliance with all applicable international sanctions laws and have strict policies and procedures in place to ensure compliance.

Compliance with Anti-Money Laundering Laws and Regulations

Bribery and Corruption

Bulk Trading and its affiliates are committed to conducting business ethically, honestly, and with integrity. Detailed guidance for employees is outlined in our “Anti-Corruption Policy”.

Commitment to Human Rights

We are dedicated to conducting our business in accordance with the UN Guiding Principles on Business and Human Rights. Bulk Trading believes in treating all individuals with respect and dignity, and our employees are expected to conduct themselves accordingly.

Commitment to the Environment

Bulk Trading strives for environmental sustainability in the production and sale of our products and services. We are committed to complying with all environmental laws and regulations and to improving the environment, particularly in reducing greenhouse gas emissions, conserving water and energy, and managing waste and hazardous materials.

Compliance with Health and Safety Laws and Regulations

Bulk Trading operates with the highest health and safety standards. We have a set of Health and Safety Principles and comply with all relevant laws and regulations. We select business partners who share our commitment to health and safety and expect them to operate to high standards.

Compliance with Anti-Trust and Competition Law

Bulk Trading competes vigorously and engages only in practices that are legal and ethical. We do not engage in activities that constrain competition or share sensitive information with competitors.

Conflict of Interests

Bulk Trading recognizes that conflicts of interest can arise and must be identified and managed. Employees are required to report any conflicts of interest or potential conflicts of interest as soon as possible.

Relationships with Counterparties and Partners

Bulk Trading values long-term relationships and conducts rigorous know your customer (KYC) procedures on all partners and counterparties. We respect the confidentiality of our commercial relationships and expect employees to comply with our KYC policy.

Relationships with Public Officials and Governments

Bulk Trading engages respectfully with authorities in all jurisdictions and respects the confidentiality of these relationships.

Accuracy of Books and Records

Employees must maintain accurate books and records of Bulk Trading ‘s business activities. It is crucial that documentation is not produced or amended with the intent to mislead.

Dignity and Respect

Bulk Trading is committed to promoting fairness, dignity, trust, and respect among all employees and strives for a workplace free of discrimination and harassment.

Confidentiality

Bulk Trading takes confidentiality seriously and expects employees to protect sensitive information. Any breach or potential breach must be reported immediately.

Enforcement of the Code

Bulk Trading takes breaches of the Code seriously and may take disciplinary action, including dismissal, in the event of a breach or attempted breach.

How to raise concerns

We encourage everyone to speak up

At Bulk Trading, we are committed to transparency and open communication. We encourage all employees, business partners, and stakeholders to raise concerns if there is an alleged violation of our Code of Conduct or other misconduct.
Bulk Trading has a Misconduct Reporting Mechanism where concerns can be raised confidentially.

You Speak, We Listen

For any questions or concerns regarding our Code of Conduct, please contact our Compliance team at compliance@bulktrading.ch.

Bulk Trading is committed to continuous improvement and welcomes feedback on our Code of Conduct and business practices.

Download our Code of Conduct

Supplier Code of Conduct and other Requirements