Counterparty Due Diligence Policy

Equinox Growth Commodity Trading

1. Purpose of the Policy

Equinox Growth Commodity Trading operates in global commodity markets where transactions often involve multiple jurisdictions, logistics chains, financial intermediaries, and commercial counterparties. In such an environment, robust due diligence procedures are essential to ensure that the company conducts business only with reputable, compliant, and financially sound partners.

The purpose of this Counterparty Due Diligence Policy is to establish the framework through which Equinox Growth Commodity Trading evaluates and approves business relationships with suppliers, buyers, brokers, logistics partners, financial institutions, and other commercial counterparties.

This policy supports the company's commitment to:

• Regulatory compliance within the European Union and the French Republic

• Prevention of financial crime, fraud, and corruption

• Responsible participation in international commodity markets

• Protection of the company’s reputation and operational integrity

All business relationships must comply with the standards outlined in this policy before commercial engagement is initiated.

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2. Scope of the Policy

This policy applies to all entities and individuals with whom Equinox Growth Commodity Trading conducts or intends to conduct business, including but not limited to:

• Commodity buyers and sellers

• Trading partners and brokers

• Freight operators and logistics companies

• Warehousing and storage providers

• Financial institutions and payment intermediaries

• Consultants, agents, and intermediaries acting on behalf of counterparties

Due diligence procedures must be completed before:

• entering into new commercial relationships

• executing commodity trading transactions

• engaging brokers or intermediaries

• forming strategic partnerships

Enhanced due diligence may be required for higher-risk jurisdictions, industries, or transaction structures.

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3. Principles of Counterparty Risk Management

Equinox Growth Commodity Trading applies a risk-based approach to counterparty due diligence.

This means that the level of investigation and verification conducted depends on several factors, including:

• Geographic location of the counterparty

• Nature and scale of the transaction

• Commodity type and market exposure

• Reputation and operational history of the counterparty

• Regulatory or sanctions risks associated with the jurisdiction

The company seeks to ensure that each counterparty meets reasonable standards of financial credibility, legal legitimacy, and ethical conduct.

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4. Counterparty Identification and Verification

Before entering into a commercial relationship, Equinox Growth Commodity Trading will verify the identity and legitimacy of the counterparty.

Key information typically required includes:

Corporate Information

• Full legal name of the entity

• Registered address and country of incorporation

• Company registration number

• Legal form of the organization

• Business licenses or permits where applicable

Ownership Structure

Where possible, the company seeks to identify the ultimate beneficial owners (UBOs) of the counterparty.

Understanding ownership structures helps ensure transparency and reduces the risk of engaging with entities involved in financial crime, sanctions evasion, or other prohibited activities.

Management and Key Personnel

Information about senior management, directors, and authorized signatories may be reviewed to assess operational legitimacy and governance standards.

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5. Financial and Operational Assessment

As part of the due diligence process, Equinox Growth Commodity Trading may evaluate the financial and operational credibility of a counterparty.

This may include reviewing:

• Financial statements where available

• Credit reports or commercial references

• Transaction history and market reputation

• Operational capacity related to commodity production, storage, or distribution

For commodity suppliers or buyers, additional considerations may include:

• Supply chain reliability

• logistics capabilities

• regulatory compliance in export or import activities

The objective is to ensure that the counterparty has the operational capacity and financial reliability to fulfill contractual obligations.

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6. Sanctions and Compliance Screening

Equinox Growth Commodity Trading conducts compliance checks to ensure that counterparties do not appear on international sanctions or restricted party lists.

Sanctions screening may include review of databases associated with:

• European Union sanctions lists

• United Nations sanctions programs

• Other relevant international regulatory authorities

The company may decline or terminate business relationships with entities or individuals that raise sanctions or compliance concerns.

This policy is aligned with the company's broader Sanctions and AML Compliance Framework.

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7. Anti-Money Laundering and Financial Crime Prevention

Commodity trading can involve large financial flows across borders. As a result, it is essential to prevent the misuse of commercial transactions for money laundering, fraud, or illicit financing.

Equinox Growth Commodity Trading applies appropriate measures to detect and mitigate such risks.

These measures may include:

• verification of counterparties' legal status

• review of transaction structures

• assessment of payment channels

• monitoring of unusual or suspicious commercial behavior

Transactions that raise compliance concerns may be delayed, reviewed further, or declined.

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8. Risk-Based Due Diligence Levels

The company may apply different levels of due diligence depending on the assessed risk level of the counterparty.

Standard Due Diligence

Applied to counterparties operating in lower-risk jurisdictions with transparent corporate structures and established reputations.

Typical checks include identity verification, corporate registration review, and basic sanctions screening.

Enhanced Due Diligence

Applied in situations where risk factors are elevated, such as:

• counterparties located in higher-risk jurisdictions

• complex ownership structures

• transactions involving significant financial value

• use of intermediaries or agents

Enhanced due diligence may include additional verification steps and internal compliance review.

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9. Ongoing Monitoring

Due diligence is not limited to the onboarding stage. Equinox Growth Commodity Trading recognizes that risks may evolve over time.

For this reason, the company may periodically review existing counterparties to ensure continued compliance with internal standards.

Monitoring activities may include:

• review of updated corporate information

• sanctions list updates

• transaction monitoring

• evaluation of operational performance

If material concerns arise during the course of a business relationship, the company may reassess or terminate the relationship where necessary.

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10. Documentation and Record Keeping

To maintain transparency and accountability, Equinox Growth Commodity Trading may retain records related to due diligence assessments and counterparty verification processes.

Such records may include:

• corporate documentation

• identification records

• compliance screening results

• internal risk assessments

Records are maintained in accordance with applicable legal requirements and internal data protection standards.

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11. Responsibility and Governance

Responsibility for implementing this policy lies with the management of Equinox Growth Commodity Trading and individuals responsible for commercial transactions.

All personnel involved in negotiating or executing transactions must ensure that appropriate due diligence procedures have been completed prior to engagement with a new counterparty.

Failure to follow due diligence procedures may expose the company to financial, regulatory, or reputational risk and may result in internal disciplinary action.

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12. Policy Review

Equinox Growth Commodity Trading reserves the right to update this Counterparty Due Diligence Policy periodically to reflect changes in regulatory requirements, market conditions, or internal risk management practices.

Updated versions of this policy may be published on the company's website where appropriate.

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13. Commitment to Responsible Trading

Equinox Growth Commodity Trading believes that responsible counterparty selection is a critical component of ethical and sustainable commodity trading.

By implementing structured due diligence procedures, the company seeks to contribute to transparent global trade, responsible market participation, and long-term commercial reliability.

 

Equinox Growth Commodity Trading
Counterparty Due Diligence Policy
European Union – France