Operating Policy Statement

Last updated: 14 May 2025

1. Introduction

Commodexa (Pty) Ltd (“the Company”) is unequivocally committed to conducting its physical commodities trading operations in strict accordance with the highest ethical standards and all applicable international laws and regulations. This policy statement outlines our unwavering dedication to responsible trading practices, ensuring full compliance with Anti-Money Laundering and Combatting Terrorism Financing (“AML/CFT”) regulations, the Conflict Minerals Regulation, relevant industry standards, and data privacy legislation, including the South African Protection of Personal Information Act (“POPIA”) and the European Union’s General Data Protection Regulation (“GDPR”).

These standards are binding on all parties engaging with Commodexa (Pty) Ltd in any capacity, thereby extending our commitment to ethical, transparent, and legally compliant trading practices beyond our immediate organisation.

2. Policy Principles

Commodexa (Pty) Ltd requires all material trades conducted through the Company to adhere to the following principles without exception:

  • Non-Conflict: Commodities traded shall not originate from regions affected by armed conflict or civil unrest, thereby avoiding the financing of violence or human suffering.
  • Non-Sanctioned: No transactions shall be facilitated with countries, entities, or individuals subject to international sanctions imposed by recognised authorities.
  • No Child Labour: The Company prohibits trade in commodities produced through the labour of children, thereby supporting international conventions on child rights.
  • Safe Working Conditions: Commodities traded must not be derived from sources that tolerate unsafe or unhealthy working environments.
  • No Labour Abuse: Commodexa expressly rejects any commodities produced under forced labour, human trafficking, or other forms of labour exploitation.
  • Responsible Sourcing: All commodities must be procured from suppliers demonstrably meeting stringent social and environmental responsibility standards.
  • No Money Laundering: The Company enforces strict protocols to ensure that trades are not utilised in the facilitation or concealment of unlawful financial activities.
  • No Proceeds of Crime: Commodities originating from criminal enterprises such as drug trafficking or terrorism financing are strictly prohibited.
  • Environmental Compliance: Commodexa prohibits trade in commodities produced from toxic or environmentally harmful materials unless these are in full compliance with internationally recognised legislative regulations.
  • AML/CFT Compliance: All parties involved with the Company’s trading activities must comply with prevailing AML/CFT laws, including the obligation to identify, report, and mitigate suspicious activities.
  • Conflict Minerals Regulation Compliance: Traders shall disclose the provenance of any conflict minerals involved in their products, ensuring adherence to specific regulations governing such materials.
  • Industry Standards Conformance: Trades must comply with accepted industry standards encompassing quality, safety, and environmental impact considerations.

3. Implementation Measures

To ensure effective enforcement of this policy, Commodexa (Pty) Ltd has instituted the following robust measures:

  • Supplier Audits: Periodic and rigorous audits of suppliers to confirm ongoing compliance with our standards.
  • Due Diligence: Comprehensive due diligence procedures undertaken as necessary to verify parties are not engaged in prohibited or illegal activities.
  • Risk Assessment: Detailed risk assessments to proactively identify and address potential exposures or violations.
  • Violation Reporting: A formalised and confidential mechanism enabling the reporting, investigation, and resolution of any policy breaches.
  • Confidentiality Agreements: Mandatory confidentiality undertakings, consistent with International Chamber of Commerce guidelines, for all trading participants.
  • Know Your Client (KYC) Information: Collection of KYC documentation through the Client Information Sheet (KYC-CIS FORM) to authenticate and monitor entities engaged in transactions.

4. Privacy and Data Protection

Commodexa (Pty) Ltd acknowledges the fundamental importance of protecting personal information and complying with global data privacy laws, specifically the South African Protection of Personal Information Act (POPIA) and the European Union’s General Data Protection Regulation (GDPR).

  • Lawful Processing: Personal data collected for KYC, transaction processing, and compliance purposes will be processed lawfully, fairly, and transparently, with explicit consent obtained where required.
  • Purpose Limitation: Personal information will be processed strictly for purposes of trade verification, AML/CFT compliance, and regulatory reporting, and not for unrelated uses.
  • Data Minimisation: Only the minimum personal data necessary to fulfil regulatory and operational obligations will be collected and retained.
  • Accuracy and Quality: The Company will take all reasonable steps to ensure that personal information held is accurate, complete, and up to date.
  • Security Safeguards: Appropriate technical and organisational measures will be implemented to protect personal data against unauthorised access, loss, or damage.
  • Data Subject Rights: Individuals have the right to access, rectify, or request deletion of their personal information in accordance with POPIA and GDPR provisions, subject to legal and regulatory constraints.
  • Cross-Border Transfers: Personal information transferred across borders will receive protection at least equivalent to that afforded by South African and European data protection laws, ensuring compliance with international data transfer requirements.
  • Retention and Disposal: Personal data will be retained only for as long as necessary to meet legal and regulatory obligations, after which it will be securely disposed of.
  • Accountability and Governance: The Company is committed to ongoing training, monitoring, and enforcement to ensure full compliance with all applicable data protection frameworks.

5. Conclusion

By adhering to these principles and measures, Commodexa (Pty) Ltd endeavours to foster a responsible, transparent, and legally compliant environment conducive to ethical physical commodities trading. We pledge to continuously uphold the highest ethical standards, prevent misuse of the Company’s operations for illegal activities, and protect the privacy and rights of all participants in accordance with prevailing data protection legislation.

Contact Us

For privacy-related inquiries, data rights, or more information, please reach us at:
📧 Email: info@commodexa.co.za
📞 Tel: +2782 455 1002
📍 Johannesburg 2001, Gauteng Province , Republic of South Africa