Compliance

At Alkagesta, compliance is not just a department – it is a core mindset embedded into every aspect of our operations.

Our Legal & Compliance Division ensures that integrity, transparency, and accountability define how we conduct business across all markets and subsidiaries.

Through a comprehensive compliance framework aligned with international best practices, we uphold the highest standards in:

Anti-bribery and anti-corruption (ABC)
Anti-money laundering (AML)
Counter-terrorist financing (CFT)
Sanctions compliance and trade controls

This integrated approach reflects Alkagesta’s commitment to ethical, lawful, and transparent trading practices across its global operations.

Anti-bribery and anti-corruption (ABC)

Anti-money laundering (AML)

Counter-terrorist financing (CFT)

Sanctions compliance and trade controls

Compliance, Integrity & Responsible Business Conduct

At Alkagesta, compliance, integrity and responsible business conduct are fundamental to how we operate. Our compliance framework is designed to support responsible trading, effective risk management, regulatory compliance and ethical decision-making across all aspects of our business.

Through strong governance, comprehensive policies, advanced due diligence technologies, ongoing employee training and independent oversight mechanisms, we seek to maintain high standards of transparency, accountability and corporate responsibility.

Governance and Oversight

Oversight of Alkagesta’s compliance program is exercised by the ESG & Compliance Committee, which reports directly to the Executive Board.

The Committee oversees the implementation and effectiveness of the Group’s compliance framework and supports the consistent application of compliance standards across all group entities.

The Committee’s mandate includes policy oversight, risk assessment, and implementation monitoring across all group entities — maintaining consistency and accountability in every operational layer.

The Committee regularly reviews emerging regulatory developments, compliance risks, policy implementation and remediation measures where necessary.

Policy Framework and Standards

Alkagesta’s commitment to ethical, compliant, and responsible business practices is supported by a comprehensive policy framework, including:

Whistleblowing Policy
Anti-Bribery & Anti-Corruption Policy
Anti-Money Laundering & Countering Financing of Terrorism Policy
Human Rights and Anti-Modern Slavery Policy
Sanctions and Export Control Policy

To reinforce organizational awareness, we conduct mandatory compliance training focused on sanctions, AML/CFT, ABC, and circumvention risk. These sessions are delivered both periodically and ad hoc, ensuring staff remain alert to emerging regulations and enforcement trends.

In addition to these core policies, Alkagesta maintains internal procedures and controls covering due diligence, vessel vetting, data privacy, information security, business ethics and related compliance matters.

Note: These policies are available to stakeholders and can be shared upon request.

Culture of Ethical Accountability

Beyond policies and systems, Alkagesta fosters a culture of ethical accountability through transparent communication, regular training, and proactive risk assessment.

Compliance awareness forms an integral part of Alkagesta’s corporate culture and is reinforced through periodic training, targeted guidance, internal communications and management engagement.

We conduct internal compliance reviews, integrity assessments, and risk evaluations, supplemented by external advisory or assurance support where appropriate to detect and address potential vulnerabilities before they escalate.

This forward-looking and disciplined approach safeguards Alkagesta’s reputation and supports the confidence of regulators, financial institutions, and global trading partners.

Commitment to Responsible Trading

Compliance considerations form an integral part of Alkagesta’s commercial and operational decision-making processes.

Through investment in governance, compliance technology, training and risk management systems, Alkagesta seeks to conduct business responsibly, transparently and in accordance with applicable legal and regulatory requirements.

This commitment supports the confidence of counterparties, financial institutions, insurers, regulators and other stakeholders worldwide.

Implementing Effective Compliance Practices

Know Your Customer (KYC)

Alkagesta’s due diligence policy adheres to the highest industry standards. Our KYC questionnaires and document requirements are calibrated by counterparty type, risk classification, applicable legal requirements, and Group-level internal standards.

Due diligence measures may include corporate verification, beneficial ownership analysis, sanctions screening, adverse media review, financial crime risk assessment and ongoing monitoring where appropriate.

Anti-Bribery

Alkagesta maintains a zero-tolerance approach to bribery, corruption and facilitation payments.

Offering, giving, requesting, or receiving bribes in any form is strictly prohibited.

All employees, officers, and relevant third parties are required to comply with Alkagesta’s Anti-Bribery and Corruption Policy and applicable anti-bribery and anti-corruption laws in the markets where the Group operates.

Alkagesta maintains controls relating to gifts and hospitality, charitable contributions, sponsorships, conflicts of interest and interactions with public officials.

Vessel Vetting

Alkagesta is dedicated to carrying out shipping operations with responsibility and sustainability at the forefront.

We have established a comprehensive vessel vetting policy that assesses relevant safety, environmental, sanctions, ownership, operational, and maritime-risk indicators before vessels are approved for use.

The assessment incorporates sanctions-related considerations, ownership and management screening, vessel history reviews, safety performance indicators, classification status, environmental factors and indicators of elevated maritime risk.

Our vetting policy takes into account numerous factors, including the vessel’s age, flag, classification, management history, and environmental performance.

Additionally, we review the track records of vessel owners, operators, managers, and other relevant maritime parties to ensure their commitment to high safety and environmental standards.

Where appropriate, enhanced due diligence may include analysis of ownership structures, sanctions exposure, ship-to-ship transfer activity, AIS transmission anomalies and other indicators of deceptive shipping practices.

By adhering to our stringent vessel vetting policy, we can mitigate the risk of accidents, spills, and other incidents that could potentially harm the environment, local communities, or Alkagesta’s reputation.

Data Privacy & Security

Alkagesta is dedicated to carrying out shipping operations with responsibility and sustainability at the forefront.

Our vetting policy takes into account numerous factors, including the vessel’s age, flag, classification, management history, and environmental performance.

Additionally, we review the track records of vessel owners, operators, managers, and other relevant maritime parties to ensure their commitment to high safety and environmental standards.

Business Ethics

At Alkagesta, we are committed to conducting our business with integrity and transparency, underpinned by our core values of Unity, Continuous Learning and Development, Ownership, and Entrepreneurial Zeal.

These values guide our actions and decision-making, ensuring that we maintain the highest ethical standards across all operations.

Alkagesta expects employees, officers, directors and business partners to act honestly, responsibly and in accordance with applicable laws, regulations and ethical business standards.

Our Business Ethics Policy emphasizes:

Integrity in all dealings with stakeholders.
Accountability for our actions and decisions.
Transparency in our business practices and reporting.

By embedding these ethical principles into our corporate culture, we ensure that all employees and business partners align with Alkagesta’s commitment to responsible, sustainable, and compliant practices.

Trade Compliance & Responsible Supply Chains

Alkagesta seeks to conduct business with counterparties and service providers that share its commitment to lawful and responsible business conduct.Through risk-based due diligence and ongoing monitoring procedures, Alkagesta evaluates counterparties, vessels, logistics providers and other relevant stakeholders to identify and mitigate legal, sanctions, financial crime, operational and reputational risks.These measures support compliance with applicable sanctions, anti-money laundering, anti-corruption, export control and trade compliance requirements while facilitating responsible international trade.

Compliance Infrastructure and Tools

We employ advanced screening and monitoring systems such as World-Check, SeaSearcher, PurpleTrac, MarineTraffic, Kpler, Infospectrum, Dynamar, Windward and Moody’s to conduct comprehensive due diligence on counterparties, vessels, and transactions.

These tools enable continuous sanctions screening, vessel tracking, beneficial ownership verification, and both annual and event-driven KYC reviews, forming part of our multi-layered risk management process.

Our due diligence framework ensures that every transaction complies with applicable UN, EU, OFAC, OFSI, and SECO sanctions regimes and relevant national regulations in the jurisdictions where we operate.

These systems form part of a broader risk-based compliance framework designed to identify, assess and mitigate legal, regulatory, sanctions, financial crime, operational and reputational risks.

The use of multiple independent intelligence sources enhances transparency and supports informed decision-making throughout the transaction lifecycle.

Alkagesta applies a risk-based approach to sanctions compliance, screening counterparties, vessels, cargoes, ownership structures, jurisdictions and trade routes where appropriate. Potential compliance concerns are subject to escalation and enhanced review procedures before transactions may proceed.

Intelligence Platforms Supporting Due Diligence

World-Check

Alkagesta uses World-Check, a global risk intelligence database, to identify potential exposure to sanctions, financial crime, corruption, and reputational risks. Integration of World-Check enables early risk detection and supports compliance with international regulatory standards.

PurpleTrac

PurpleTRAC is a maritime compliance platform that enables Alkagesta to screen vessels against sanctions lists and monitor global shipping activity. It provides real-time data and risk alerts to support regulatory compliance while minimizing exposure to financial and reputational risks.

Kpler

Kpler is a data and analytics company delivering real-time intelligence on global commodity markets, including energy, shipping, and trade flows. Leveraging large-scale data and satellite tracking, it provides valuable insights that contribute to Alkagesta’s informed, risk-aware decision-making across its operations.

SeaSearcher

SeaSearcher, provided by Lloyd’s List Intelligence, supports maritime compliance validation, vessel analytics, and supply chain monitoring. The platform enhances operational transparency, reduces maritime risk, and reinforces Alkagesta’s commitment to responsible shipping practices.

Moody’s

Moody’s is a global provider of credit ratings, risk intelligence and business information. The platform enables Alkagesta to assess counterparty creditworthiness, financial strength, ownership structures and potential risk exposures, supporting informed credit decisions and enhanced due diligence across trading activities.

MarineTraffic

MarineTraffic is a maritime intelligence platform that provides near real-time tracking of vessels worldwide using AIS data. It enables Alkagesta to monitor vessel positions, movements, and port activity, supporting informed decision-making across its shipping and trading operations.

Infospectrum

Infospectrum is a global provider of counterparty risk appraisal reports, due diligence research, and KYC intelligence for the shipping, commodities, and energy sectors. Its detailed analysis on companies’ ownership, financial standing, and market position supports Alkagesta’s strong risk management and compliance standards, contributing to well-informed counterparty, trading, and credit decisions.

Dynamar

Dynamar is a maritime consultancy and research company providing market intelligence, risk appraisal reports, and analysis on global shipping and logistics. Its insights into market trends, company performance, and trade developments are utilized by Alkagesta to inform strategic decision-making across the maritime sector.

Windward

Windward is a maritime risk intelligence platform that utilizes advanced AI and vessel tracking data to identify shipping-related risks, sanctions exposure and suspicious maritime behaviour. The platform supports Alkagesta’s vessel screening and due diligence processes by enhancing transparency, strengthening compliance controls and mitigating maritime and sanctions-related risks.

Speak-Up & Whistleblowing

Alkagesta encourages employees, counterparties and other stakeholders to report concerns regarding potential misconduct, legal violations, unethical behaviour or breaches of Group policies.

Reports may be submitted through designated reporting channels and are reviewed in accordance with applicable laws and internal procedures.

Retaliation against individuals who raise concerns in good faith is prohibited.

Frequently Asked Questions

Alkagesta utilizes World-Check, PurpleTRAC, Kpler, SeaSearcher, MarineTraffic, Moody’s, Infospectrum, Dynamar and Windward to support compliance, due diligence, sanctions screening, vessel monitoring, and risk management activities.

Yes. Alkagesta applies a comprehensive vessel vetting process that evaluates safety, environmental, sanctions, ownership, operational, and maritime-risk indicators before vessels are approved for use.

Alkagesta conducts risk-based due diligence that includes identity verification, beneficial ownership analysis, sanctions screening, adverse media reviews, and ongoing monitoring where appropriate.

Yes. Alkagesta screens transactions, counterparties, and vessels against applicable sanctions regimes, including UN, EU, OFAC, OFSI, and SECO requirements.

Yes. Alkagesta maintains a zero-tolerance approach to bribery and corruption through its Anti-Bribery & Anti-Corruption Policy.

Yes. Alkagesta maintains a Human Rights and Anti-Modern Slavery Policy as part of its broader compliance framework.

Certain policies may be shared with stakeholders upon request, subject to applicable confidentiality requirements.

Alkagesta applies a risk-based due diligence process that may include corporate verification, beneficial ownership analysis, sanctions screening, adverse media review, financial crime risk assessment and ongoing monitoring where appropriate.

Yes. Alkagesta utilises a range of industry-leading compliance and intelligence platforms including World-Check, Windward, Kpler, PurpleTRAC, SeaSearcher, Moody’s, MarineTraffic, Infospectrum and Dynamar to support due diligence, sanctions compliance, vessel monitoring and risk management activities.

Yes. Alkagesta applies a risk-based approach to compliance and due diligence, allocating enhanced controls and monitoring measures where elevated risks are identified.