Compliance

We conduct our business in an honest and ethical manner and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate. We take our legal responsibilities very seriously and always act in accordance with applicable law. To ensure compliance with these high standards, we maintain policies that embody our shared principles, including with respect to: •anti-bribery and corruption; •anti-money laundering and countering terrorist financing; •market abuse; •anti-slavery and human trafficking; •sanctions and trade controls; and •competition law. Our policies are supported by detailed procedures, carefully tailored to our business. These include our risk-based Know Your Counterparty procedure to ensure that we know who our business partners are before we enter into a relationship with them. Our commitment to acting with integrity then continues through our risk-based due diligence and monitoring controls and procedures. To ensure our policies and procedures remain fit for purpose and appropriate for the group’s constantly evolving business, they are reviewed on a continuous basis by our Compliance Committee, which is comprised of senior executives from across the group’s commercial and control functions to guarantee that a wide range of perspectives is considered. The Compliance Committee is, in turn, able to draw on the expertise of the group’s Compliance and Legal functions. Ultimately, however, upholding our principles is the responsibility of all of our employees and other stakeholders. We therefore provide regular training to ensure they understand our policies and procedures, encourage them to provide feedback and create a culture where all stakeholders feel a sense of responsibility for acting in accordance with our shared principles.