CASE STUDY
Compliance investing in human capital
Transparency Compliance
Training
To enhance adherence and diversify the format of the delivery of the Compliance annual training, Gunvor decided to provide the 2023 Compliance Training online. This online training, provided in English and Spanish, included modules covering:
The training also included Compliance acknowledgments and knowledge tests, to ensure employees’ understanding was at the required level and get confirmation on their adherence to Compliance policies and procedures.
Sanctions
As a significant participant in the global commodities markets, Gunvor takes its sanctions obligations very seriously. Throughout the counterparty due diligence process, sanctions checks are carried out by third-party systems and via Gunvor’s own internal processes.
Modern sanction restrictive measures are varied in scope and applicability, however, they are commonly designed to support foreign policy and national security objectives of the implementing States and entities. Sanctions could be either comprehensive or selective, i.e., either prohibiting all transactions with sanctioned persons and goods or only prohibiting certain types of business and still accepting others. Depending on particulars of each transaction, various sanctions compliance regimes of different countries may apply separately or simultaneously.
A dedicated case study in the 2022 report provides more details on how it is implemented.
Trading Compliance
Along with the other Compliance functions, Trading & Advisory Compliance has continuously improved to keep pace with changes in technology and trading activity.
Trading & Advisory Compliance ensures that Gunvor is up to date with legal and regulatory developments, as well as assessing their impact group-wide:
As a participant in the global physical and financial markets, it is important that Gunvor participates in the debates and discussions, to ensure the continued orderly functioning of the markets. Gunvor participates in industry bodies, as we see this as the best method to achieve meaningful engagement. Gunvor is presently a member of The International Swaps and Derivatives Association (ISDA), The European Federation of Energy Traders (EFET), SUISSENEGOCE and The Commodity Markets Council Europe (CMCE), as well as its direct representation to relevant regulatory and governing organizations.
An expanded size and coverage of the Compliance Department
In 2023, Gunvor focused investment in human capital to reinforce the global Compliance team, in line with the continuous efforts over the years, resulting in the Compliance Department almost doubling in size since 2020, from 17 to 32 employees.
Beyond the numbers, Gunvor also invested into hiring Senior Compliance Officers, including in the Geneva headquarters, coming from banks or the Big 4 (Deloitte, EY, PwC and KPMG), and with legal background.
In 2023 we strengthened the London Compliance hub
Reinforcing the team with the hiring of a Junior Sanctions officer to support the Global Head of Sanctions
CASE STUDY
Investing in continuous training of the Compliance team
Gunvor wants to ensure its Compliance team is well equipped to conduct its mission to protect the company and its stakeholders. It thus invests in the internal and external training of its team.
Gunvor sponsors participation in Compliance or KYC trainings by reputable and well-known providers of specialized training. It included the payment of training programs from the International Compliance Association (ICA). This training proposal was well received by the team who worked hard to obtain the certifications.
Beyond external training, we believe it is important to share knowledge within the team. Gunvor Compliance conducts “Quality Checks” controls, consisting in a second review of the KYC conducted by Senior Compliance Officers. As part of the Quality Checks, beyond the specific case, the team reuses the lessons learnt from this second review to share with the rest of the team the possible improvements, using anonymized examples. The goal of this exercise is to ensure we are consistent in our approach and continuously working on improving the quality of the KYC and the detection and management of red flags, together with an increased understanding of the legitimacy of the onboarding of counterparties in our systems.
December 2023: creation of the Ethics and Sustainability department
To respond to the evolving needs of our commercial activities and an ever-changing regulatory environment, Gunvor announced, in December 2023, an update to the structure of the Compliance Department, which is now incorporated into a new department called “Ethics & Sustainability” led by a Global Head of Ethics and Sustainability, reporting to the Chief Legal Officer.
This department covers Anti-Bribery & Corruption including KYC, and Sustainability including Human Rights.
With the December 2023 reorganization, both the Global Head of Trading Compliance and Global Head of Sanctions continue to report to the Chief Legal Officer.
These changes reflect the growing importance of sustainability to every aspect of our business, while accommodating the shifting regulatory landscape and expanding nature of international economic sanctions. Our goal is to ensure our commercial activities are managed in the most efficient and compliant manner possible.
It will also enable to increase and optimize the synergies between Compliance, Ethics and Sustainability.
Within the new organization, Gunvor created a function dedicated to the Anti-bribery and Anti-Corruption framework, with the mission to constantly improve our policies and processes.
As part of the newly created department, the Deputy Head of Ethics & Sustainability will focus on improving our compliance processes and procedures, while continuing to oversee and develop our compliance training program globally. This function will work in close collaboration with the “field” compliance function working on counterparties, transactions and projects.