Ensuring compliance with laws, regulations and standards is the responsibility of all our employees and our management. We are all responsible for conducting our business in a way that meets our commitment and strengthens compliance across the organization.
Ethics & Compliance
Our commitment to ethics and compliance starts with leadership. Our senior management leads by example, acting in the manner expected of all our employees. Every member of the leadership team is engaged in and supportive of the compliance program which is embedded in the company’s day-to-day business practices.
ETHOS’s Compliance Philosophy
Ethics & Compliance
Commitment to Ethics
The Compliance Program
Our extensive network supports our ability to identify and capture trading opportunities and leverages our business responsiveness. Wherever we are present, we are aiming at long-term partnerships based on transparency and compliance. We aim to share market expertise, provide intelligence, and build local capabilities so that our investments deliver benefits to the local communities and businesses we serve and partner with.
The compliance program is a key pillar underpinning ETHOS’s commitment to the highest standards of corporate responsibility and to doing business with integrity. It is designed to reflect the high standard of ethics to which ETHOS holds itself, the complex and multi-faceted business in which it operates and to ensure compliance with appropriate laws, regulations and international standards. The compliance program is continuously reviewed and enhanced, alongside policies, processes and controls, to meet evolving compliance needs.
Know Your Customer (KYC) Policy
The policy and related controls use resources and recommendations from international standards such as the OECD and UN Principles, as well as Transparency International’s Corruption Perception Index, Know Your Country Rating and Control Risks Corruption Index.
Anti‐Bribery & Corruption (ABC) Policy
The policy adheres by using resources such as the UK Ministry of Justice and the US Department of Justice guidelines, as well as international standards published by the OECD and the UN. It is designed following an extensive process to map the ABC risks ETHOS faces globally, and takes into consideration its activities, countries of operation, the way we transact, how we manage our relationships with our intermediaries and our trading counterparties.
Sanctions Policy
The principal objective of ETHOS’s sanctions policy is to ensure compliance with relevant laws and provide a framework for employees to seek advice from compliance and legal in relation to a transaction or potential transaction.
Changes to all relevant sanction regimes, including but not limited to US OFAC, EU Official Journal, Swiss SECO, and UK HM Treasury are monitored and tracked constantly.
Investigation and consequence of non-compliance
Compliance, alongside our legal team, may investigate of potential breaches or areas of concern. Employees who have failed to comply with the code of conduct, policies and procedures might be subject to disciplinary action.
All employees are shielded by our commitment to protect whistle-blowers.
Employees are required to report any breach, or the risk of any breach, of the laws, ETHOS policies or procedures. We have in place an integrity hotline. Operated by an independent third party, the hotline enables employees to raise any issues of concern with senior management, anonymously and in confidence.
We are a leading independent commodity trading and logistics house in Cyprus with operational offices in Athens, Greece, at the heart of the global seaborne energy transportation economy.
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