OECD Paris 26 June 2018 Odile Roy de Puyfontaine Head of Compliance 1 Offices in 40 countries conducting business in many more Subject to multiple regulatory and legal regimes Diverse and complex compliance risks ID: 1018501
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1. Vitol’s Compliance systems against bribery and corruptionOECD – Paris 26 June 2018Odile Roy de Puyfontaine – Head of Compliance1
2. Offices in 40 countries, conducting business in many moreSubject to multiple regulatory and legal regimesDiverse and complex compliance risksRobust compliance approach requires:Application of multiple standardsClose collaboration of Compliance with businessIntegration of Compliance procedures into business practicesRegular reviews and vigilanceA global business requiring a multifaceted approach to compliance2
3. Key policies, systems and controls:Know Your Customer and Your Business PolicyEnhanced due diligence of all third party agents (questionnaires, interviews, agreements)Anti Bribery and Corruption Policy (inc G&E, relationships with PEPs)Controls around third party paymentsSegregation of duties across multiple functionsKey tools:Independent third party supplier integral to:On boarding processOngoing review of existing counterparties (trading and non-trading)Daily monitoring of adverse newsAutomatic screening of all payments made by VitolExternal advisors for enhanced due diligenceTrade AssociationsResources on the groundA robust Due Diligence Compliance programme 3
4. Identifying and managing risksAdditional policies and controls for all interactions with counterparts that fall within the following categories:State owned companiesCompanies with state owned ownership (% depends on risk matrix)Companies with PEPs exposure either by way of ownership and/or board or senior-level managementCompliance integral to payment processControl within the payment process to ensure no payment made to a party that is not the contracting partyCall back processDue diligence on the third party itselfDocumentation executed between all parties to support rational and legal framework of the third party paymentCompliance working alongside Legal in review of documentation Key aspects of Due Diligence Compliance programme 4
5. A Compliance culture underpins our reputation, upon which our business is built5GovernmentsRegulatorsCustomers & counterpartiesCo-Investors / partnersBanks Employees / potential employeesPressPublicNGOsThird party shareholders / pensions fundsCompliance / sustainability departmentsRegulatorsGovernmentsDirect stakeholdersIndirect stakeholders