Centalion has established clear policies for ABC, AML, market conduct, market abuse, economic sanctions, and other risk areas. They have been communicated from the top-down. Importantly, we have also created a whistleblowing policy that has been clearly communicated by the CEO to all our employees.

Specifically regarding ABC, policies and procedures and systems and controls meet standards put forth by the U.S. Foreign Corrupt Practices Act, UK Bribery Act and those propagated by the OECD. With respect to breaches, Centalion maintains a zero-tolerance approach.

In the context of Centalion’s Payments to Governments Policy, the company has expressed support for the Extractive Industries Transparency Initiative (EITI) to establish a consistent means by which to reliably report on its payments to governments, with the aim to improve transparency and reduce the potential for corruption in cooperation with these governments.

Centalion’s reporting includes purchases of crude oil and refined oil products acquired from state-owned enterprises in EITI implementing countries.

Documents

Code of Conduct

The Code of Conduct & Ethics exists to provide clarity with respect to the expectations Centalion has of its employees and contractors and of what they can expect of Centalion.

Privacy Policy

The collection and processing of personal data by Centalion Group Ltd is in full compliance with the EU General Data Protection Regulations 2016/679 and other applicable privacy laws.

Payments to Governments

We expressed support for the Extractive Industries Transparency Initiative (EITI) to establish a consistent means by which to reliably report on its payments to governments.

Modern Slavery Policy

We have a zero-tolerance approach to modern slavery and are committed to acting ethically and with transparency in all business relationships.

Code of Conduct & Ethics for Centalion’s Business Partners 

Our Code of Conduct & Ethics for our Business Partners establishes the standards for how those working with and for Centalion interact with customers, colleagues, investors, business partners and regulators. 

Candidate Privacy Policy 

We use Workday, an online application provided by Workday Inc., to assist with our recruitment process. We use Workday to process personal information as a data processor on our behalf. Workday is only entitled to process your personal data in accordance with our instructions.

Privacy Notice for Suppliers, Clients, Counterparties & Prospects 

This privacy notice describes how Centalion Group Ltd and other group companies may collect and use personal data about you pursuant to your working relationship with us, in accordance with applicable data protection law. In particular, it applies to all suppliers, clients, counterparties and prospects.

Health, Safety, Environment, Human Rights & Communities (HSEC) Policy

The effective management of health and safety, the environment, human rights and community engagement (collectively called “HSEC”) is essential to growing our business in a sustainable and responsible manner.

SpeakUp Policy

This policy aims to encourage and support individuals who report concerns related to misconduct. It also lays out principles, reporting procedures as well as the process and responsibilities for handling reports on misconduct.

Tax Governance Framework

Our Group Tax Policy sets out our approach to tax strategy and approach in conducting its tax affairs and dealing with tax compliance risk.

Responsible Sourcing Policy

Centalion has developed a Responsible Sourcing Policy for its metals and minerals business that aligns with best standards, including the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

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