Ethics & compliance
We trade in a region where sanctions and origin rules matter on every shipment. We treat compliance as part of the job, not as paperwork.
Know the counterparty.
Know the cargo.
Know the money.
Before we commit to a deal, we check who we are dealing with, where the product comes from and how the payment will flow. If any of the three cannot be documented, we do not proceed.
These controls apply to every company in the Group and to everyone who acts on our behalf, including agents and intermediaries.
Six rules we do not bend
Sanctions screening
Counterparties, their owners and the vessels we use are screened before every deal.
Origin of product
Every cargo travels with origin documents. We do not trade products of Russian origin or refined from Russian crude.
Know your counterparty
Each new counterparty is checked for registration, ownership, management, sanctions exposure and reputation.
Anti-bribery and corruption
We do not offer, pay or accept bribes or facilitation payments, directly or through anyone acting for us.
Anti-money laundering
Payments follow the contract chain. We make and accept no payments for parties outside the deal.
One file per cargo
Contracts, invoices, transport documents and payments are filed together for every delivery, ready for our banks.
Four checks before every cargo
Counterparty
Registration, ultimate owners, management, sanctions lists and adverse media.
Cargo
Origin documents, quality certificates and screening of the vessel, route and terminals.
Payment
The banks involved, and a payment route that matches the contract chain.
File
Contract, invoices, transport documents and payments, filed together for the delivery.
KYC pack on request
We answer documentation requests in writing, with the supporting documents attached, so that a review can be completed without repeated rounds of questions. Our standard pack includes:
- Registry extracts for each company
- Ownership up to the ultimate owner
- Directors and signatories
- Sanctions and AML policies
- Recent financial statements
- Documents for a specific delivery
Requests: compliance@osagau.com
Raise a concern
If you have a concern about conduct at OSAGAU or by anyone acting for us, write to our compliance function at compliance@osagau.com. Concerns are handled confidentially, and we do not tolerate retaliation against anyone who raises one in good faith.