EnerGiants Trading - energiantstrading

CODE OF ETHICS

1. Purpose and Scope

The Energiants Trading Code of Ethics sets forth the fundamental principles that guide our business conduct. It applies to all employees, contractors, officers, directors, and any third party acting on behalf of Energiants Trading, regardless of location or function.

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2. Integrity and Compliance with Laws

We are committed to conducting business with integrity and in full compliance with all applicable laws and regulations, including but not limited to:
    •    Local and international trade laws
    •    Anti-corruption and anti-bribery regulations
    •    Sanctions and export control laws
    •    Environmental and labor regulations

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3. Anti-Corruption and Anti-Bribery

Energiants Trading strictly prohibits all forms of corruption and bribery. This includes:
    •    Offering, giving, soliciting, or receiving bribes in any form, whether monetary or in-kind.
    •    Facilitating payments to public officials, customs officers, or other entities to expedite or influence decisions.
    •    Using third parties or intermediaries to perform acts that would be illegal if done directly by Energiants Trading personnel.

All business dealings must be transparent, documented, and auditable.

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4. Equal Opportunity, Diversity, and Inclusion

Energiants Trading fosters an inclusive workplace that values diversity of gender, race, ethnicity, religion, age, sexual orientation, disability, and cultural background.

We do not tolerate discrimination or harassment of any kind.
    •    Hiring, promotion, and compensation decisions are based solely on merit, qualifications, and performance.
    •    We respect religious practices and accommodate them where reasonable.
    •    We support gender equality in all roles, including leadership and decision-making positions.

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5. Health, Safety, and Environmental Responsibility

We prioritize the health and safety of our employees, partners, and the communities in which we operate. We are committed to:
    •    Maintaining a safe and healthy working environment.
    •    Minimizing our environmental impact through responsible energy trading practices.
    •    Promoting sustainability and carbon-conscious operations whenever possible.

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6. Confidentiality and Data Protection

All employees must protect sensitive information related to:
    •    Clients, partners, and transactions
    •    Commercial strategies and trading data
    •    Personal data of employees and third parties

We comply with all applicable data protection regulations and commit to safeguarding digital and physical records.

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7. Conflicts of Interest

Employees must avoid situations where personal interests conflict with those of the company. This includes:
    •    Personal trading in commodities or financial instruments related to our business
    •    Accepting gifts or hospitality that could influence business decisions
    •    Having undisclosed financial or personal relationships with clients, suppliers, or competitors

Any potential conflict must be disclosed promptly to Compliance.

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8. Fair Competition and Market Conduct

We conduct our business fairly and in accordance with anti-trust and market abuse laws. This includes:
    •    No collusion or price-fixing with competitors
    •    No insider trading or manipulation of market information
    •    Respecting confidential information and boundaries in negotiations

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9. Reporting Misconduct

Energiants Trading encourages a culture of openness and accountability. We provide multiple channels to report unethical behavior, including:
    •    Anonymous whistleblower channels
    •    Direct contact with Compliance or HR
    •    No retaliation for good faith reporting

All reports will be investigated thoroughly and confidentially.

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10. Commitment and Accountability

All employees are required to:
    •    Read, understand, and comply with this Code of Ethics
    •    Participate in regular compliance training
    •    Seek guidance when unsure of the ethical implications of any action

Violations of this Code may result in disciplinary action, including termination and legal proceedings where applicable.

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11. Continuous Improvement

We commit to regularly reviewing and updating this Code to reflect evolving best practices, legal requirements, and social standards.

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Approved by: Energiants Trading Executive Committee
Effective Date: June 4, 2025

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