Our CEOs are the ones that drive our commitment to ethics and compliance. Our senior management sets the standard that all of our employees must follow. Every member of the leadership team takes part in and supports the compliance programme, which is integrated into the company’s day-to-day operations. A worldwide compliance team based in Kazakhstan manages the compliance risk. Our entire workforce is in charge of ensuring compliance with laws, regulations, and industry standards. We are all responsible for carrying out our business in a way that meets our commitments and strengthens compliance across the organization.

The compliance programme is a crucial component of LLP Expressoil’s commitment to the highest standards of corporate responsibility and ethical business practices. It is designed to reflect LLP Expressoil’s high ethical standards, the complex and multidimensional nature of its operations, and adherence to relevant laws, regulations, and international standards. To meet evolving compliance requirements, the compliance program, policies, processes, and controls are regularly reviewed and enhanced.

The global compliance team comprises of 20 experienced professionals that specialize in regulatory and corporate compliance. In addition to these specialized compliance professionals, LLP Expressoil has developed a program to train 37 ‘compliance champions’ in local offices and LLP Expressoil-owned firms that do not yet have a local compliance team. The compliance champions program aims to make compliance more accessible to all of our employees while also providing feedback on compliance suggestions and issues faced by local offices. Furthermore, compliance works with and draws on resources from other risk functions to establish an integrated approach to implementing the compliance program.

The policy is based on the Joint Money Laundering Steering Group (JMLSG) guidelines. In addition, the policy and accompanying controls draw on resources and suggestions 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.

The approach was based on recommendations from Kazakhstan’s Ministry of Justice and Department of Justice, as well as worldwide norms issued by the OECD and the United Nations. It was developed following an extensive mapping of the ABC risks Vitol faces globally, taking into consideration its activities, countries of operation, the way LLP Expressoil transacts, and how it manages its connections with intermediaries and trading counterparties.