...Gunvor fully complies with all applicable international economic sanctions. Through the company’s counterparty due diligence process, sanctions checks are carried out both through third-party systems and internal processes. Gunvor daily vets its entire list of business counterparties and relevant associated individuals. Gunvor’s team further regularly engages directly with governments, including the U.S. and EU, that impose sanctions to ensure we understand the latest developments and actions. Moreover, Gunvor conducts no business in the regions mentioned. In addition, Human Rights due diligence is a part of Gunvor’s Know Your Customer (KYC) process during counterparty onboarding and then daily through the company’s ongoing screening system...

Gunvor took immediate steps to condemn the war, while moving to limit ongoing activities where contractually possible. This was a top-down decision, taken with full support of the company’s Executive Committee and management team. As stated, Gunvor’s sole asset in Russia, a minority, non-controlling stake in an oil products terminal, is under review...

In addition, Gunvor has invested millions of dollars in the latest IT systems to assist with counterparty due diligence and tracking, ensuring all employees have access to system data. Counterparties and related parties in the company’s Counterparty Management System (CMS) are also screened daily against external, third-party vendor systems, which monitor for such information as sanctions violations and PEP exposure, or other relevant events. The same applies for Gunvor’s vessel screening...

...Specifically, such due diligence framework includes:

• Risk-based assessments
• Collection and review of documents on counterparties enabling the identification of ultimate beneficial owners and intermediate layers
• Screening via two reputable external databases used by most external stakeholders of the banking and commodity trading sectors; these databases include adverse events linked to human rights violations
• Daily screening of active counterparties and the relevant entities and individuals related to them
• Targeted media checks, including by specialized engines/databases
• External enhanced due diligence reports as and when needed...