Compliance & Ethics Policy

Equinox Growth Commodity Trading

1. Introduction

Equinox Growth Commodity Trading is committed to conducting its business in accordance with the highest standards of integrity, transparency, and professionalism. Operating within the regulatory framework of the European Union and the French Republic, the company recognizes that ethical conduct and regulatory compliance are essential pillars of responsible commodity trading.

This Compliance & Ethics Policy establishes the principles and standards that govern how Equinox Growth Commodity Trading conducts its operations, interacts with partners and counterparties, and manages its responsibilities toward regulators, clients, and the market.

Commodity trading operates at the intersection of global supply chains, financial markets, and geopolitical realities. Because of this, companies active in this sector must maintain rigorous internal standards designed to prevent misconduct, ensure transparency, and promote fair market practices.

This policy applies to:

• Directors and managers

• Employees and contractors

• Consultants and external representatives

• Business partners acting on behalf of the company

All individuals representing Equinox Growth Commodity Trading are expected to understand and adhere to the principles set out in this document.

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2. Core Ethical Principles

Equinox Growth Commodity Trading operates according to several fundamental ethical principles that guide every aspect of its business activity.

Integrity

All business activities must be conducted honestly, transparently, and in good faith. The company rejects any practice that could undermine trust in markets, distort fair competition, or compromise the reputation of the company.

Compliance with Laws and Regulations

The company strictly adheres to all applicable laws and regulations in the jurisdictions where it operates. This includes, but is not limited to:

• European Union regulatory frameworks

• French commercial and financial regulations

• International trade laws and sanctions regimes

• Anti-money laundering and financial crime regulations

Employees and representatives must ensure that their actions comply not only with the letter of the law but also with its spirit.

Accountability

Each individual within the organization is responsible for ensuring that their actions reflect the company’s ethical standards. Decisions must be documented where appropriate and conducted in a transparent manner.

Professional Conduct

Employees and representatives are expected to maintain the highest standards of professionalism when interacting with:

• Clients

• Suppliers

• Brokers

• Logistics partners

• Financial institutions

• Regulatory authorities

 

3. Regulatory Compliance

As a company established in the European Union and operating under French jurisdiction, Equinox Growth Commodity Trading adheres to applicable regulatory requirements governing commodity trading, brokerage activities, and international commerce.

Key regulatory areas include:

Financial and Commercial Regulations

The company complies with relevant European and French regulatory frameworks governing commercial activities, financial transactions, and brokerage operations.

Data Protection and Privacy

Equinox Growth Commodity Trading respects the principles established under the General Data Protection Regulation (GDPR) and applicable French data protection laws.

Personal and commercial data are processed only when necessary and are handled securely and confidentially.

Market Conduct

The company strictly prohibits:

• Market manipulation

• Insider trading

• Dissemination of misleading information

• Abuse of confidential market data

Equinox Growth Commodity Trading supports fair and transparent market practices and seeks to contribute to stable and reliable commodity markets.

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4. Anti-Corruption and Anti-Bribery

Equinox Growth Commodity Trading maintains a zero-tolerance policy toward bribery and corruption.

Employees and representatives are strictly prohibited from offering, promising, giving, requesting, or accepting any improper advantage in order to obtain or retain business.

Prohibited actions include:

• Bribes or kickbacks

• Undisclosed commissions

• Improper facilitation payments

• Hidden benefits offered through intermediaries

Any gifts or hospitality offered or received must remain reasonable, transparent, and compliant with applicable regulations.

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5. Conflicts of Interest

A conflict of interest arises when personal interests interfere with the interests of the company or its clients.

Employees and representatives must avoid situations in which personal financial interests, family relationships, or external activities could influence business decisions.

Examples of potential conflicts include:

• Personal investments in counterparties

• Undisclosed relationships with suppliers or brokers

• Using confidential company information for personal benefit

All potential conflicts must be disclosed to management promptly.

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6. Fair Trading Practices

Equinox Growth Commodity Trading is committed to fair and responsible trading practices within global commodity markets.

The company promotes:

• Transparent negotiation processes

• Respect for contractual obligations

• Responsible sourcing and trading

• Professional engagement with counterparties

The company does not participate in practices designed to artificially distort commodity prices or manipulate markets.

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7. Confidentiality and Information Protection

Commodity trading involves access to commercially sensitive information. Protecting such information is essential for maintaining trust and market integrity.

Employees and representatives must ensure that confidential information relating to:

• Clients

• Counterparties

• Trading strategies

• Market intelligence

• Logistics operations

is protected from unauthorized disclosure.

Confidential information must not be shared outside the company unless required for legitimate business purposes or by law.

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8. Sanctions and International Trade Compliance

Equinox Growth Commodity Trading respects international sanctions regimes and export control regulations.

The company conducts its activities in compliance with sanctions frameworks established by:

• The European Union

• The United Nations

• Applicable international authorities

The company may decline or terminate business relationships if a transaction or counterparty raises compliance concerns.

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9. Reporting Concerns and Ethical Violations

Maintaining ethical standards requires active participation from all members of the organization.

Employees, partners, or contractors who become aware of potential violations of this policy are encouraged to report concerns promptly.

Reports may involve issues such as:

• Fraud or financial misconduct

• Corruption or bribery

• Regulatory violations

• Breaches of confidentiality

• Unethical market practices

Reports will be handled confidentially and investigated appropriately.

Retaliation against individuals who report concerns in good faith will not be tolerated.

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10. Policy Enforcement

Violations of this Compliance & Ethics Policy may result in disciplinary action, including termination of employment or contractual relationships.

In certain cases, violations may also be reported to relevant regulatory authorities where required by law.

Equinox Growth Commodity Trading reserves the right to review and update this policy periodically to reflect changes in legal requirements or business practices.

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11. Commitment to Ethical Business

Equinox Growth Commodity Trading believes that sustainable success in the commodity sector depends on trust, transparency, and ethical conduct.

The company is committed to operating as a responsible participant in global commodity markets and to maintaining a culture of compliance and integrity across all areas of its business.

 

Equinox Growth Commodity Trading
Compliance & Ethics Policy
European Union – France