Responsible Trading & Business Principles

Equinox Growth Commodity Trading

1. Introduction

Equinox Growth Commodity Trading is committed to conducting its commercial activities according to the highest standards of professionalism, responsibility, and ethical conduct. As a participant in global commodity markets, the company recognizes that responsible trading practices contribute not only to the stability of markets but also to the sustainability of global supply chains and commercial relationships.

Commodity trading plays a vital role in connecting producers, processors, distributors, and industrial consumers across international markets. With this role comes a responsibility to operate transparently, comply with applicable laws, and maintain strong ethical standards.

This document outlines the Responsible Trading & Business Principles that guide the activities of Equinox Growth Commodity Trading in its interactions with counterparties, partners, financial institutions, and other market participants.

These principles reflect the company’s commitment to responsible participation in international trade and adherence to the legal and regulatory frameworks applicable within the European Union and the French Republic.

 

2. Commitment to Ethical Business Conduct

Equinox Growth Commodity Trading believes that integrity and ethical conduct are essential foundations for sustainable commercial success.

All employees, representatives, and partners acting on behalf of the company are expected to conduct business with honesty, transparency, and professionalism.

This includes:

• maintaining truthful communication with counterparties

• avoiding misleading or deceptive commercial practices

• respecting contractual obligations

• conducting negotiations in good faith

The company does not tolerate fraudulent, deceptive, or unethical business practices.

 

3. Compliance with Laws and Regulations

Equinox Growth Commodity Trading operates in compliance with applicable legal and regulatory frameworks governing international trade and commercial activity.

This includes adherence to:

• European Union regulatory standards

• French commercial and financial regulations

• international trade rules

• sanctions and export control regimes

• financial crime prevention requirements

The company continuously seeks to ensure that its operations align with the legal frameworks applicable to the jurisdictions in which it operates.

Where necessary, transactions may be reviewed to ensure regulatory compliance before proceeding.

 

4. Transparency in Commercial Transactions

Transparency is a key component of responsible commodity trading.

Equinox Growth Commodity Trading promotes clear and transparent communication throughout the commercial transaction process.

This includes transparency regarding:

• product specifications

• commercial terms and pricing structures

• contractual obligations

• logistics arrangements

• transaction documentation

Clear communication reduces misunderstandings, strengthens trust between trading partners, and contributes to efficient transaction execution.

 

5. Responsible Counterparty Selection

Selecting reliable and reputable business partners is essential for maintaining responsible trading practices.

Equinox Growth Commodity Trading implements procedures designed to verify the identity and credibility of potential counterparties before entering into commercial relationships.

Counterparty assessment may include:

• verification of corporate registration and legal status

• review of ownership structures

• sanctions and compliance screening

• evaluation of operational capabilities and reputation

These procedures help ensure that the company engages with legitimate and responsible market participants.

​

6. Fair Competition and Market Integrity

Equinox Growth Commodity Trading supports fair competition and transparent market practices.

The company does not participate in activities that could distort commodity markets or undermine market integrity.

Prohibited practices include:

• market manipulation

• collusion with competitors

• dissemination of false or misleading market information

• misuse of confidential commercial data

The company encourages responsible participation in commodity markets that promotes stability and fair pricing mechanisms.

 

7. Anti-Corruption and Anti-Bribery Standards

Equinox Growth Commodity Trading maintains a zero-tolerance approach to bribery and corruption.

The company prohibits the offering, giving, requesting, or accepting of any improper advantage intended to influence commercial decisions.

Examples of prohibited conduct include:

• bribery of public officials

• undisclosed commissions or kickbacks

• improper facilitation payments

• hidden financial incentives

Employees and representatives must ensure that business interactions remain transparent and compliant with applicable anti-corruption regulations.

 

8. Environmental and Social Responsibility

Commodity trading intersects with global supply chains that can have environmental and social impacts.

While Equinox Growth Commodity Trading does not directly control upstream production activities, the company recognizes the importance of promoting responsible business practices within the markets in which it operates.

The company seeks to engage with partners who respect:

• applicable environmental regulations

• responsible labor practices

• internationally recognized business ethics standards

Responsible trade contributes to sustainable long-term economic development and market stability.

 

9. Confidentiality and Data Protection

Protecting confidential information is an important aspect of responsible trading.

Equinox Growth Commodity Trading takes reasonable steps to safeguard commercially sensitive information relating to:

• clients and trading partners

• transaction details

• pricing and negotiation strategies

• logistics arrangements

Information obtained during commercial activities is used only for legitimate business purposes and handled in accordance with applicable confidentiality and data protection standards.

 

10. Risk Awareness and Responsible Decision-Making

Commodity markets can be affected by a wide range of economic, geopolitical, and logistical factors.

Equinox Growth Commodity Trading encourages responsible decision-making and prudent risk management in its commercial operations.

Before entering into transactions, the company may evaluate factors such as:

• market conditions

• counterparty reliability

• logistics feasibility

• regulatory compliance considerations

Responsible trading requires careful evaluation of risks and the implementation of appropriate safeguards where necessary.

 

11. Accountability and Internal Governance

The management of Equinox Growth Commodity Trading is responsible for promoting a culture of compliance, professionalism, and responsible conduct throughout the organization.

Employees and representatives are expected to adhere to the principles described in this document.

Where potential ethical or compliance concerns arise, they should be addressed promptly through appropriate internal channels.

Maintaining strong governance structures supports the company’s long-term credibility and operational reliability.

 

12. Continuous Improvement

Global commodity markets evolve in response to economic developments, technological innovation, and regulatory changes.

Equinox Growth Commodity Trading remains committed to periodically reviewing its internal policies and operational practices to ensure alignment with evolving market standards and regulatory expectations.

Continuous improvement supports responsible participation in international trade and strengthens the company’s ability to operate effectively in complex global markets.

 

13. Commitment to Responsible Trade

Equinox Growth Commodity Trading believes that responsible business conduct is fundamental to the long-term stability and credibility of global commodity markets.

By adhering to the principles outlined in this document, the company aims to promote:

• ethical commercial relationships

• transparent market participation

• responsible supply chain engagement

• compliance with applicable legal frameworks

Through these principles, Equinox Growth Commodity Trading seeks to contribute to professional, transparent, and sustainable international trade.

 

Equinox Growth Commodity Trading
Responsible Trading & Business Principles
European Union – France