OQT is committed to high standards of governance and compliance, adhering to international best practices, standards, principles and regulations. We recognise the importance of maintaining the highest degree of confidence and reliability amongst our stakeholders and endeavour to conduct our business responsibly, with accountability, transparency and integrity.
We uphold the highest standards of corporate governance, fostering transparency, and accountability in all our operations. OQT is governed by its Board of Directors (the Board), whose members include representatives from the shareholder, OQ S.A.O.C., as well as independent industry experts. The Board is responsible for setting OQT’s strategic agenda and ensuring that appropriate frameworks and delegations are in place relating to risk management, finance, compliance and new business. The Board is supported by a dedicated Audit & Risk Management Committee (ARMC) with representatives from the OQT Board and OQ Group Risk & Assurance teams. The ARMC is responsible for providing independent oversight of OQT’s Executive Management Team (EMT) and supports the Board in overseeing governance, risk management and internal audit as well as advising on risk and internal control related matters.
OQT complies with all statutory government laws, rules and regulations applicable to OQT’s business and the jurisdictions in which it operates. Reporting to the CEO and Board through the OQT General Counsel, the Compliance function works to ensure OQT is meeting its compliance obligations. Relationships with external legal counsel are maintained, providing expertise in all required jurisdictions aligned to OQT’s current and future business.
The OQT Code of Conduct establishes a set of principles of business conduct that apply to all its personnel, including anti-bribery & corruption, trade restrictions & sanctions, anti-money laundering and whistleblowing. Where local law is less stringent than OQT’s Code of Conduct, the latter is followed.
OQT maintains a zero-tolerance policy towards bribery and corruption, prohibiting all employees, officers, and directors from engaging in such acts. This prohibition extends to both government officials and non-government officials. We expect third parties associated with the OQT Group to adhere to the same level of compliance. Our policy explicitly forbids the direct or indirect offer, payment, solicitation, or acceptance of bribes in any form, and prohibits facilitation payments.
In addition to the Code of Conduct, we continue to implement an Anti-Bribery and Corruption Programme applicable to all OQT businesses and functions across their operations. This programme is designed to mitigate various corruption-related risks by directing resources and attention to areas of higher risk.
We ensure the communication of our anti-corruption policies, standards, and procedures to all directors, officers, employees, and, when deemed necessary and appropriate, to agents and business partners.
We consistently examine and update these procedures, controls, and risk criteria to ensure their alignment with current laws, regulations, and best practices.
Compliance, in collaboration with the Legal department, may conduct investigations into potential breaches or areas of concern. If any individual associated with OQT, whether an employee or a third party engaged in our operations, faces allegations of misconduct, we undertake a thorough review of our relationship with the implicated party and take appropriate actions.
At OQT, we are committed to the highest standards of integrity and financial transparency. Our Anti-Money Laundering (AML) compliance framework is designed to prevent and detect any potential risks associated with money laundering or illicit financial activities. We prioritise strict adherence to AML regulations, employing robust measures to verify the identity of counterparties and affiliated individuals, conducting comprehensive due diligence focused on money laundering and related predicate offenses, monitoring transactions, and investigating suspicious activities. OQT’s Legal & Compliance function may report a suspicious activity to a relevant authority, if deemed appropriate. Our proactive approach to AML compliance ensures the safeguarding of our business operations and upholds the trust our counterparties and business partners place in us.
OQT complies with all trade restrictions and sanction controls applicable to its business and the jurisdictions in which it operates. As a group that operates in a high-risk environment when it comes to potential exposure to sanctions issues, we have implemented robust policies and procedures (which are regularly reviewed and updated) to ensure we strictly adhere to relevant sanctions regimes. This includes front-end due diligence on our potential counterparties, utilising third-party screening tools, and extends through to transaction-specific review and approval of deals that may have a sanctions-related nexus.
We also ensure all our contractual arrangements include appropriate sanctions provisions.
Any potential sanctions issues are escalated to our Legal department, who draw on the expertise of external legal counsel where relevant.
OQT is dedicated to fostering an environment that encourages open dialogue about its business practices. Our commitment involves adhering to all applicable laws, rules, regulations, and standards to safeguard our personnel against discrimination or retaliation when reporting information or participating in investigations related to potential Code of Conduct violations. OQT has established a whistleblowing process that empowers all employees as well as any third parties to voice their concerns through certain whistleblowing channels while ensuring protection for the whistleblower. Concerns can be raised with the Legal department or the Chairman of the ARMC. The Legal department will conduct a thorough review of the concerns and recommend appropriate measures. As the CEO holds the primary responsibility for implementing the Code, recommendations from the Legal department will be submitted for action. Periodic reports on Code matters will be provided by the CEO to the ARMC. Commitment to ethical standards is crucial for maintaining a transparent and accountable work environment. This proactive approach enables OQT to address and rectify issues before they escalate into legal violations or pose risks to health, security, or our reputation.
Prior to entering into any form of binding transaction or obligation with any business counterparty, OQT conducts appropriate risk-based due diligence to satisfy Anti-Money Laundering, Anti-Bribery and Corruption, Fraud, and Sanctions requirements. This process extends beyond trading counterparts to include comprehensive KYC assessments for shipping-related entities such as ship owners, agents, brokers, custom agents, inspectors, and other service providers. In tandem with the broader KYC process, we conduct a specific risk-based KYC assessment focused on the counterparty itself, its managers, directors, direct and indirect owners, controlling persons, the geographical location of its business operations and nature of envisaged business with OQT. This KYC process relies on official corporate documentation and independently verifiable commercial data from commercial registers.
In addition to the initial KYC during the onboarding stage, OQT conducts on-going screening of all active business counterparties, including associated individuals and parent entities, via an external service provider for real-time monitoring.
To ensure the KYC documentation is up-to-date, we allocate resources to facilitate regular KYC refresh on our active business counterparties.
In addition to conducting KYC procedures for shipping counterparties and leveraging industry-leading vetting tools, all vessels and related parties (registered owners, technical and commercial operators etc.) are thoroughly vetted for both sanctions and technical considerations. This comprehensive approach enables an accurate and current assessment of a vessel’s risk profile, helping to reduce the risk of non-compliance and operational issues. To ensure vessel vetting practices in accordance with industry standards, OQT’s vessel vetting policy contains the following:
Although the fundamental ethical and legal grounds of Compliance remain steadfast, the yearly enactment of new law and updates to regulations contribute to the progression and transformation of how aspects of Compliance are put into practice.
To ensure our employees stay well-informed, the Compliance team is responsible for developing and implementing annual training for all staff. This training covers a range of areas, including KYC, ABC, AML, economic sanctions, and other relevant topics. These sessions involve discussions on risks and related policies, incorporating the latest developments in compliance practices. Participation in the training is mandatory for all relevant employees, and depending on their location and role, OQT utilises online tools as well as face-to-face delivery.