Business Integrity
& Compliance Statement

Integrity before commercial outcome.

Kitivo Mercantile Group conducts business in accordance with applicable law and expects the same standard from directors, personnel, representatives, counterparties and operating partners.

KMG does not knowingly participate in bribery, corruption, fraud, money laundering, terrorist financing, sanctions evasion, tax evasion facilitation, deliberate misrepresentation or other unlawful conduct. No expected revenue, relationship or instruction justifies bypassing an integrity control.

Responsibility across the relationship.

This statement applies to KMG’s directors, personnel and authorised representatives. KMG also expects suppliers, customers, advisers, agents, transporters, inspectors, joint-venture participants and other operating partners to act consistently with its principles when working on a KMG transaction.

Leaders are responsible for setting expectations, supporting good-faith escalation and ensuring that commercial pressure does not override compliance decisions. Individuals involved in a transaction are expected to understand the counterparty, commercial rationale, payment structure, commodity, origin, route and delivery obligations relevant to their role.

No bribes, kickbacks or facilitation payments.

KMG prohibits offering, promising, authorising, giving, requesting or accepting anything of value to improperly influence a decision, obtain an unlawful advantage, conceal information or reward improper conduct.

This prohibition applies to public officials and private-sector counterparties. It includes bribes, kickbacks, secret commissions and facilitation payments, whether made directly or through an agent, consultant, family member, intermediary, community organisation or other third party.

Legitimate taxes, royalties, customs charges, port fees and public-service payments must be supported by appropriate documentation and paid through authorised channels. Requests for undocumented, personal or unusual payments must be escalated and must not be paid merely to avoid delay.

Gifts, hospitality and conflicts of interest.

Gifts and hospitality must be lawful, reasonable, infrequent, transparent and connected to a legitimate business purpose. They must not create an obligation, influence an active decision or be provided in cash or cash-equivalent form.

Actual, potential or perceived conflicts of interest must be disclosed promptly. This includes personal, family, financial or outside-business interests that could affect, or appear to affect, objective decision-making.

Political and charitable contributions must never be used to obtain an improper commercial advantage or disguise a payment connected to a transaction.

Risk-based counterparty due diligence.

Before entering a material relationship, KMG seeks to understand who it is dealing with, who ultimately owns or controls the counterparty and whether the proposed activity has a legitimate commercial basis.

Depending on risk, due diligence may consider:

• Legal identity, registration, operating address and authorised representatives.
• Direct and ultimate beneficial ownership, control and connected parties.
• Business activity, licences, regulatory status, operating history and reputation.
• Commodity, origin, destination, route, end use and transaction rationale.
• Sanctions, politically exposed person, adverse-media, litigation and enforcement indicators.
• Expected payment flows, funding source, banking counterparties and consistency with the proposed trade.
• Relevant human-rights, responsible-sourcing, environmental and jurisdictional risks.

Enhanced review may be required for higher-risk jurisdictions, complex ownership, public-official connections, unusual payment structures, conflict-affected areas or information that cannot be independently corroborated.

Counterparty approval is not permanent. KMG may refresh due diligence when circumstances, ownership, routes, transaction patterns or external risk information change.

Sanctions and restricted activity.

KMG is committed to complying with sanctions and trade-control requirements applicable to its business, transactions, banks, carriers and delivery routes. KMG does not knowingly participate in a transaction designed to evade, circumvent or conceal the involvement of a sanctioned party, restricted territory, controlled item or prohibited activity.

Risk-based screening may extend to counterparties, beneficial owners, directors, authorised representatives, banks, vessels, carriers, ports, jurisdictions and other parties connected to a proposed transaction.

Warning signs requiring review can include:

• Reluctance to disclose ownership, source, destination, end use or transaction parties.
• Unexplained intermediaries, routing changes or requests to remove information from documents.
• Payments involving unrelated third parties, high-risk jurisdictions or accounts inconsistent with the contract.
• Unusual pricing, volumes, invoicing, shipping instructions or document discrepancies.
• Possible direct or indirect involvement of a sanctioned party, restricted territory or controlled activity.

A potential sanctions match or evasion concern must be investigated and resolved before KMG proceeds.

Payments must follow the transaction.

Commercial terms, invoices, goods, shipping documents and payment flows should tell the same coherent story. KMG does not accept or make unexplained third-party payments or use payment structures that lack a legitimate commercial rationale.

Payment instructions and material amendments must be authorised, documented and independently verified through an established communication channel. KMG may request evidence concerning source of funds, source of wealth, banking authority or the reason for a payment route where risk warrants it.

Suspected fraud, document falsification, money laundering, terrorist financing, tax evasion facilitation or misappropriation must be escalated. Funds or goods must not be moved while a material concern remains unresolved.

Accurate records and accountable third parties.

KMG requires business records to reflect transactions accurately and with sufficient detail. False, incomplete, misleading or off-book records are prohibited. Relevant contracts, approvals, due-diligence records, invoices, payment evidence and material communications are retained in accordance with applicable requirements and KMG’s recordkeeping needs.

KMG may use agents, advisers, inspectors, logistics providers and other specialists, but will not use a third party to perform conduct that KMG would not undertake itself. The degree of diligence, written instruction and oversight applied to a third party is proportionate to its role and risk.

Confidential and commercially sensitive information must be used only for authorised purposes and protected against improper disclosure or market abuse.

Questions, concerns and enforcement.

Anyone working with KMG is expected to raise a concern when conduct appears inconsistent with this statement or applicable law. Reports should be made in good faith and will be handled as confidentially as reasonably possible. Retaliation for a good-faith report is not acceptable.

Concerns may be submitted through the institutional enquiry form by selecting “Privacy or governance request”. Do not submit identity records, banking information or confidential evidence through the public form. KMG will provide an appropriate channel where further information is required.

A substantiated breach may result in corrective action, additional controls, suspension, termination, recovery action or referral to an appropriate authority, depending on the circumstances.

KMG’s risk-based approach is informed by recognised principles concerning anti-corruption, beneficial-ownership transparency and counterparty diligence, including the Financial Action Task Force’s work on beneficial ownership. These references do not imply membership, certification or supervision by the referenced bodies.