CODE OF CONDUCT AND ETHICS

APPLICABLE TO COMMODITY PORT, ITS BUSINESS PARTNERS, AND SUPPLIERS

Last update: January 2, 2026

Commodity Port Limited is one of Sub-Saharan Africa’s independent commodities trading businesses, ensuring value is created and added along the entire commodities value chain.

Commodity Port’s Code of Conduct & Ethics establishes the standards for how those working with and for Commodity Port interact with customers, colleagues, investors, business partners, and regulators. We adopt internationally recognized standards to comply with both the letter and the spirit of the law. We expect our business partners and suppliers to uphold similar levels of best business practices.

  1. ANTI-BRIBERY & CORRUPTION

We expect our business partners and suppliers to comply with all local and international laws against any form of corruption, bribery, facilitation payments and extortion. While we acknowledge local customs and traditions may differ, we do not condone engaging in corrupt practices. Our business partners and suppliers must ensure that they have appropriate Anti-Bribery & Corruption policies and procedures in place to ensure that relevant laws are complied with at all times.

 

  1. GIFTS & ENTERTAINMENT

Corporate entertainment in connection with legitimate business activities can serve to develop commercial relationships. However, we insist that any gifts and entertainment given or received by Commodity Port employees must be appropriate. We expect our business partners and suppliers to maintain the same high standards. Gifts and entertainment should never be used to obtain preferential treatment.

 

  1. ANTI-MONEY LAUNDERING

We do not support, facilitate or permit money laundering, terrorist financing or any other fraudulent activities. Our business partners and suppliers should be similarly vigilant against schemes that attempt to conceal the proceeds of a crime within their financial transactions.

 

  1. SANCTIONS

We conduct our business in line with applicable international economic sanctions programmes. All Commodity Port business partners and suppliers must ensure that all their operations are in compliance with applicable sanctions regulations.

 

 

 

  1. MARKET CONDUCT

All trading activities must be performed for genuine economic reasons and not to mislead or manipulate the market. We expect our business partners to abide by the rules and regulations applicable to our markets. We do not condone collusive or abusive strategies, or trading whilst in possession of inside information. We remind our business partners that anti-competition and market abuse regulations exist in many of the markets that we operate in and must be adhered to at all times.

 

  1. CONFLICTS OF INTEREST

We appreciate that conflicts of interest can arise through personal and commercial activities. Commodity Port employees and our business partners and suppliers must proactively identify and manage potential, perceived and actual conflicts, and notify the relevant personnel within Commodity Port of these conflicts, if in relation to Commodity Port business.

 

  1. HEALTH, SAFETY, ENVIRONMENT, HUMAN RIGHTS & COMMUNITIES (HSEC)

We assign the highest priority to preserving the health, rights and safety of our employees, and respecting the environment and communities where we do business. Our aim is to work in harmony with our surroundings, to prevent pollution, and to provide benefit to our stakeholders. Commodity Port has Group HSE expectations which define the standards that we apply. We require that our business partners adopt similar standards in accordance with local and international laws.

 

  1. DIGNITY AND RESPECT

Promoting fairness, dignity, trust and respect amongst all employees is our key commitment, as is striving towards a workplace that is free of discrimination and harassment. Commodity Port believes in equal opportunity and fair reward for individual contributions. We request that our business partners comport themselves respectably and treat all individuals, including Commodity Port employees, professionally.

 

Any concerns related to the conduct of Commodiity Port Ltd employees should be reported immediately to the Compliance Department compliance@commodity-port.com.