Ethics & Compliance
The regulatory environment in which subsidiaries of DMH operates has become structured & wide-ranging with a future-forward approach.
Ethics, Compliance & Transparency
For example, many of our corporate divisions are subject to oversight from more than 70 regulatory authorities worldwide. Virtually every aspect of our business is affected to a greater or lesser degree by regulations covering health and safety, insurance, emission and environmental control, product, cargo and financial crime, international trade and sanctions, and banking, exchange and derivatives market rules.
To ensure compliance within such an extensive and constantly evolving regulatory environment, we maintain rigorous corporate protocols and a strict compliance program. This activity is overseen by our Compliance Department, which provides oversight, advice and training for FuelBank traders worldwide. In all operations, FuelBank adheres to the laws and regulations to which it is subject, both international and local, in the jurisdictions in which it operates.
All of our subsidiaries are proactive in addressing evolving compliance standards. This includes taking steps to strengthen contract language with counter-parties to enhance contractual prohibitions against trading with countries and entities under economic sanctions.
Our Commitment
Our Ethical Guidelines and Moral Principles guide our compliance in adhering to external rules, laws, and regulations. Our Ethics are often about the "spirit of the law" and doing what is morally correct, whereas our Compliance is the "letter of the law," focusing on meeting mandatory requirements to avoid penalties. Both are essential for our organization to build trust, reduce risk, and operate responsibly.
E&C Governance
DMH’s Compliance Department is bound by strong corporate governance, which provides a robust process for identifying risks & sound oversight to ensure effective risk mitigation. The Group Compliance Committee (GCC) serves as the point of accountability for the Group’s Compliance activities. The GCC includes senior members of DMH’s Executive Committee, as well as representatives from Legal and Compliance. It reviews all aspects of the Compliance risk mitigation plan and acts as a point of escalation.
Personnel
In addition to DMH’s Compliance Director, the company has a dedicated Director position for anti-bribery and corruption (ABC) and anti-money laundering (AML), as well as compliance officers located directly on trading floors next to trading personnel. They work in conjunction with Risk Officers providing oversight for every trading desk. DMH’s Compliance Directors further lead the company’s Compliance training program. DMH Compliance Committee oversees the effectiveness of the program.
Internal Audits
To test our internal functions across the organization, DMH has established an Internal Audit Department to provide independent and objective assessments of business activities, operations, financial systems, and the internal control environment of DMH. Our internal audit scope, covers activities such trading desks, assets, central functions and processes, joint-ventures and advisory mandates are designed to for the reduction of overall risk and the correction of inefficiencies through enhanced controls .