Vitol’s Compliance systems against bribery and corruption OECD – Paris 26 June 2018 Odile Roy de Puyfontaine – Head of Compliance

A global business requiring a multifaceted approach to compliance Offices in 40 countries, conducting business in many more Subject to multiple regulatory and legal regimes Diverse and complex compliance risks Robust compliance approach requires: Application of multiple standards Close collaboration of Compliance with business Integration of Compliance procedures into business practices Regular reviews and vigilance

A robust Due Diligence Compliance programme Key policies, systems and controls: Know Your Customer and Your Business Policy Enhanced 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 payments Segregation of duties across multiple functions Key tools: Independent third party supplier integral to: On boarding process Ongoing review of existing counterparties (trading and non-trading) Daily monitoring of adverse news Automatic screening of all payments made by Vitol External advisors for enhanced due diligence Trade Associations Resources on the ground

Key aspects of Due Diligence Compliance programme Identifying and managing risks Additional policies and controls for all interactions with counterparts that fall within the following categories: State owned companies Companies with state owned ownership (% depends on risk matrix) Companies with PEPs exposure either by way of ownership and/or board or senior-level management Compliance integral to payment process Control within the payment process to ensure no payment made to a party that is not the contracting party Call back process Due diligence on the third party itself Documentation executed between all parties to support rational and legal framework of the third party payment Compliance working alongside Legal in review of documentation

Indirect stakeholders A Compliance culture underpins our reputation, upon which our business is built Direct stakeholders Indirect stakeholders Governments Regulators Customers & counterparties Co-Investors / partners Banks Employees / potential employees Press Public NGOs Third party shareholders / pensions funds Compliance / sustainability departments Regulators Governments