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Vitol’s Compliance systems against bribery and corruption OECD – Paris 26 June 2018

Vitol’s Compliance systems against bribery and corruption OECD – Paris 26 June 2018 Odile Roy de Puyfontaine – Head of Compliance. A global business requiring a multifaceted approach to compliance. Offices in 40 countries, conducting business in many more

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Vitol’s Compliance systems against bribery and corruption OECD – Paris 26 June 2018

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  1. Vitol’s Compliance systems against bribery and corruption OECD – Paris 26 June 2018 Odile Roy de Puyfontaine – Head of Compliance

  2. A global business requiring a multifaceted approach to compliance • Offices in 40 countries, conducting business in many more • Subject to multiple regulatory and legal regimes • Diverse and complex compliance risks • Robust compliance approach requires: • Application of multiple standards • Close collaboration of Compliance with business • Integration of Compliance procedures into business practices • Regular reviews and vigilance

  3. A robust Due Diligence Compliance programme • Key policies, systems and controls: • Know Your Customer and Your Business Policy • Enhanced due diligence of all third party agents (questionnaires, interviews, agreements) • Anti Bribery and Corruption Policy (inc G&E, relationships with PEPs) • Controls around third party payments • Segregation of duties across multiple functions • Key tools: • Independent third party supplier integral to: • On boarding process • Ongoing review of existing counterparties (trading and non-trading) • Daily monitoring of adverse news • Automatic screening of all payments made by Vitol • External advisors for enhanced due diligence • Trade Associations • Resources on the ground

  4. Key aspects of Due Diligence Compliance programme • Identifying and managing risks • Additional policies and controls for all interactions with counterparts that fall within the following categories: • State owned companies • Companies with state owned ownership (% depends on risk matrix) • Companies with PEPs exposure either by way of ownership and/or board or senior-level management • Compliance integral to payment process • Control within the payment process to ensure no payment made to a party that is not the contracting party • Call back process • Due diligence on the third party itself • Documentation executed between all parties to support rational and legal framework of the third party payment • Compliance working alongside Legal in review of documentation

  5. A Compliance culture underpins our reputation, upon which our business is built Direct stakeholders Indirect stakeholders

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