Who we are
Physical commodity trade carries real compliance risk. These are the controls our procedures require on counterparties, cargoes and payments, and the policies that sit behind them.
A counterparty that cannot be verified, a vessel that does not clear screening or a payment route that does not match the contract stops a trade, whatever its commercial merit.
Framework
Compliance is part of how a transaction is built at Montage, not a check applied to it afterwards.
We seek to conduct our business in line with the ten principles of the UN Global Compact. Our wider approach to people, safety, the environment and the communities we work in is set out under responsibility.
How we control risk
Our procedures require each counterparty to be screened before we contract with it. We identify the legal entity, its ownership and control, its beneficial owners and the jurisdictions it operates in, and check that information against independent sources where they are available.
Due diligence is risk-based: higher-risk jurisdictions, structures and trade routes attract deeper checks and senior approval. Records are retained, and counterparties re-screened, in line with our compliance policy.
Montage complies with the sanctions regimes that apply to our business, including those administered by the United Nations, the United States, the European Union and the United Kingdom, alongside applicable United Arab Emirates requirements.
Our procedures require counterparties, banks, vessels, ports and cargo origins to be screened against current sanctions and watch lists before a transaction is confirmed, and vessels to be re-checked before fixture. Where a check raises a question, the transaction stops until it is resolved.
We do not trade product of sanctioned origin in breach of applicable measures, and we do not structure transactions to obscure origin, ownership or destination.
We do not offer, promise, give, request or accept bribes, kickbacks or facilitation payments, whether directly or through a third party, and we do not tolerate them anywhere in our supply chain.
Agents, brokers and intermediaries are subject to due diligence before appointment and are paid on documented terms for services actually performed. Gifts and hospitality must be proportionate, transparent and recorded. Conflicts of interest must be declared.
Commodity trade finance is exposed to money-laundering and trade-based laundering risk, and we treat it accordingly. Payments must follow the contractual flow: we pay and are paid by the contracting counterparty, through banking channels, in the currency and to the account set out in the contract.
We do not accept cash, third-party payments that lack a documented commercial rationale, or instructions to re-route funds. Invoicing must reflect the goods actually shipped, and unusual pricing, duplicated documentation or unexplained changes in payment routing are escalated and, where required, reported.
We expect the counterparties we buy from to meet the same standards we hold ourselves to on legal compliance, labour and human rights, health and safety, and environmental practice. Those expectations are set out in our supplier code.
Where a supplier falls short and is willing to address it, we prefer engagement and a corrective plan to walking away. Where they are not, we end the relationship.
Anyone, inside or outside the company, can raise a concern about conduct, compliance or safety. Reports can be sent to [email protected] with the subject line "Speak up", and are reviewed by senior management.
Concerns can be raised confidentially. Montage does not tolerate retaliation against anyone who reports a concern in good faith, whether or not the concern is ultimately substantiated.
Our code of conduct sets out how the company and everyone acting on its behalf is expected to behave: integrity in business dealings, respect for people, care for health, safety and the environment, and compliance with the law wherever we operate.
The code is supported by our compliance policy, which sets out the procedures behind it, and by the supplier code that we ask our counterparties to meet.
Policy documents
Published in full so counterparties, banks and suppliers can see the standards we work to. Each opens in the browser as a PDF.
Zero tolerance for bribery and corruption: prohibited conduct, gifts, hospitality and entertainment, third-party due diligence, books and records, trade sanctions and export controls, reporting and whistleblowing, training, and the consequences of non-compliance.
The regulatory framework the company follows, sanctions screening and due diligence, customer due diligence and know your customer, transaction monitoring and record keeping, reporting obligations, prohibited activities, training, and the consequences of non-compliance.
Our code of conduct and supplier code are with the board for adoption and will be published here once adopted, with their effective and review dates.
Banks, counterparties and suppliers are welcome to ask for the detail behind any of these controls.