Ethics and compliance
Standards supporting responsible conduct and consistent execution
Ethics and compliance standards supporting responsible business conduct, risk management, and integrity across our activities.
We assess partners, service providers, and other stakeholders through a risk-based KYC process. The aim is to develop a clear view of ownership, commercial standing, and compliance posture before any formal engagement.
Reviews combine document collection, screening, and context-based assessment that scales with the nature of the activity. Where relevant, this may include beneficial ownership checks, sanctions and adverse media screening, and enhanced due diligence for higher-risk jurisdictions or structures. Outcomes are documented, and escalation routes are available when additional review is required.
What it means in practice
- Confidential handling. Reports are handled with sensitivity and appropriate discretion.
- Non-retaliation expectations. Concerns raised in good faith should not result in adverse consequences.
- Clear case workflow. Intake, triage, investigation, and closure steps are documented.
Policy coverage aligned with practical risks and responsibilities
The Document Center contains the current policy set. Items below mirror core coverage areas used across major energy and commodities groups.
Code of conduct
Legacy Energies' Code of Conduct defines the standards that guide professional behaviour, ethical decision‑making, and accountability across the organisation. It addresses conflicts of interest, responsible use of information, and appropriate business interactions, and sets out practical routes to seek advice, raise questions, or escalate concerns. The aim is consistent judgement in day‑to‑day work, supported by clear expectations and leadership reinforcement.
Anti-bribery and corruption
Legacy Energies maintains a zero‑tolerance approach to bribery, facilitation payments, and improper influence, whether direct or indirect. Controls are designed to be practical and risk‑based, including training, documented approvals, and enhanced review for higher‑risk relationships, third‑party arrangements, or government‑facing activity. Where concerns arise, escalation and refusal options are built into the process.
Sanctions and trade controls
Sanctions and trade controls are addressed through screening and documented checks designed to comply with applicable restrictive measures, export controls, and trade limitations. Reviews consider relevant parties and ownership, products and end‑use context, routing and destination, and other risk indicators that may require additional scrutiny. Where uncertainty exists, matters are escalated for review and, where needed, approval before proceeding.
Anti-money laundering
Risk‑based anti‑money laundering measures support the integrity of Legacy Energies' activities by helping identify unusual patterns and reducing exposure to illicit finance. Due diligence is designed to build a clear understanding of identity, ownership and control, the legitimacy of the activity, and, where relevant, source‑of‑funds context before formal engagement. Suspicious concerns can be escalated and handled through documented review pathways.
Market and conduct risk
Market and conduct risk is managed through standards, monitoring, and controls intended to support disciplined execution and market integrity. This includes documented approvals, segregation of duties, and periodic review of key controls and behaviours across the lifecycle of activity. The objective is consistency, transparency of decisioning, and a clear record of how material risks are identified and managed.
Reporting and speaking up
Channels are available for employees and stakeholders to raise concerns in good faith, including confidential options where permitted by law. Reports are handled through a structured workflow, including intake, triage, review, and closure, with appropriate discretion and documentation. Non‑retaliation expectations underpin the process, and issues can be raised through line management, compliance contacts, or designated reporting routes.
Know-your-counterparty processes
Prior to execution of contracts or formal engagements, we apply proportionate checks designed to confirm identity, ownership and control, sanctions and reputational risk, and the nature of the proposed transaction.
Enhanced measures may be applied based on jurisdiction, sector, or transaction characteristics, including documentary review, escalation, and approval routing.
Our approach is designed to be measured and conservative. Reviews consider commercial strength and compliance standing, including indications of legal restrictions, sanctions, or other integrity concerns.
We apply similar discipline prior to investments, acquisitions, or joint ventures. Where supply chains touch higher-risk environments, additional due diligence may be used to help reduce exposure to corruption, violence, or human rights abuses.
