Why this exists
Environmental certificates only work if trust is absolute. If someone tries to tilt the table — with gifts, favours, “informal payments” or pressure — the integrity of the market breaks.
We don’t let that happen.
This policy explains exactly what we stand for, what we won’t tolerate, and what happens if a line gets crossed.
Our commitment
We will not, under any circumstances, offer, request, give, receive or tolerate:
- bribes
- kickbacks
- facilitation payments
- “thank-you” gifts intended to influence a decision
- preferential treatment in exchange for money, favours, information or certificates
No exceptions. Not for a deal, not for a target, not for a relationship.
Your commitment (if you work with us)
If you buy, sell, broker, issue or redeem certificates with us, you confirm that:
- You will not offer us or anyone connected to us anything that could influence a trading decision.
- You will not request anything improper from us, including side arrangements, off-book payments, or “quiet” amendments that circumvent market rules.
- You will report any suspicious behaviour you see in the market — including from other parties.
If you need to check whether something is acceptable, ask.
If you’re wondering if something “counts,” it probably does.
Gifts and hospitality
Reasonable, proportionate hospitality is fine.
Attempts to tilt a commercial decision are not.
Acceptable:
- a coffee or lunch when meeting a counterparty
- a modest thank-you after a project is complete
Not acceptable:
- anything expensive
- anything frequent
- anything offered while a deal is live
- anything with strings attached
- anything that would make you embarrassed if it appeared on the front page of the FT
If uncertainty exists, decline it and notify us.
Scope
This policy covers:
- employees
- directors
- contractors
- agents
- introducers
- TPIs acting on our behalf
- anyone representing us in certificate markets
It applies in all countries and all markets we operate in.
Zero-tolerance approach
If we suspect bribery:
- we stop the transaction
- we investigate
- we report to relevant authorities if required
- we terminate relationships where necessary
- we reserve the right to seek damages
We publish a redacted summary of confirmed breaches annually — not because we enjoy it, but because sunlight is the strongest disinfectant.
How to report concerns
Email: compliance@energymarketingandtrading.com
Anonymous reporting is available through [anonymous channel].
Every report is investigated.
No retaliation. Ever.
Why this matters
Certificate markets depend on:
- accurate tracking
- honest reporting
- fair counterparties
- clean data
- clean processes
- clean people
Bribery contaminates everything.
Our stance is simple: it doesn’t happen here.