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

2. 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

3. 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

4. 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

5. 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