Transparency
What we disclose, to whom, and why.
Transparency in a privately held merchant is not the same thing as public reporting, and we do not present it as such. It is the practical willingness to let counterparties, banks and suppliers see how the business is structured, how decisions are made and how the firm conducts itself — in enough detail for them to reach an informed judgement about trading with us.
Disclosure as routine, not as a request
We treat disclosure as something counterparties, banks and inspection agencies should get as a matter of onboarding, not something they have to chase us for. The sections below set out what that looks like in practice — corporate structure, standing documentation, how we price, and where the limits of disclosure sit.
Corporate Disclosure
We are registered in England and Wales and file the information required of us under the Companies Act. Ownership and corporate structure are disclosed to counterparties, financing banks and inspection agencies as a matter of routine onboarding rather than on request.
Counterparty Documentation
We maintain a standing due diligence pack — corporate documentation, ownership disclosure, banking and trade references, and our compliance policies — and make it available to counterparties assessing us. A counterparty should not have to pursue a merchant for the documents that allow it to open a credit file.
Commercial Terms
We price transparently. Where a recognised international reference exists for a commodity, positions are priced against it and the basis is stated. Where no liquid benchmark exists, we set out the reference we are pricing from. A counterparty should be able to see what it is paying for and why.
Tax
We meet our tax obligations in the jurisdictions in which we operate and structure our activities according to their commercial substance.
What we bring to a trade
The Limits of Disclosure
There is information we do not publish: counterparty identities, positions, margins and commercial terms. That reflects obligations to the parties we trade with rather than reluctance on our part. We apply the same discretion to a counterparty's information as we expect for our own, and we would not trade with a merchant who did otherwise.