Governance & Compliance

KS Capital Partners operates within a comprehensive governance and compliance framework designed to support institutional-grade physical commodity brokerage across multiple sectors and jurisdictions. Our mandate-driven model is underpinned by regulatory discipline, counterparty integrity, and controlled execution standards aligned with internationally recognised trade and compliance principles.

We engage exclusively in physical commodity trade and do not participate in speculative activity, retail brokerage, or financial market dealing.

Governance Framework & Oversight

Our governance framework establishes clear oversight, accountability, and control across the full lifecycle of every mandate. Governance and compliance are treated as strategic priorities and integrated into decision-making, mandate acceptance, and execution oversight.

Key elements of our governance framework include:

• • Defined mandate acceptance criteria and internal approval processes
  • Clear allocation of responsibilities across execution stages
  • Documented commercial terms, delivery obligations, and contractual structures
  • Ongoing oversight of execution performance and contractual compliance

• Record-keeping to support auditability, traceability, and regulatory review

This framework enables consistent, disciplined execution across complex, multi-party and multi-jurisdictional transactions.

Code of Business Conduct & Professional Standards

KS Capital Partners operates under a formal Code of Business Conduct that defines the professional, ethical, and integrity standards expected across all engagements. This Code underpins our approach to responsible brokerage and applies to all activities undertaken on behalf of the firm.

The Code establishes expectations relating to:

• Ethical conduct and integrity
• Compliance with applicable laws and regulations
• Fair dealing and professional behaviour
• Prevention of misconduct and conflicts of interest

Compliance with the Code and supporting policies is mandatory and reinforced through governance oversight and internal controls.

Counterparty Standards & Due Diligence

We work exclusively with established, professional, and verifiable counterparties. Counterparty integrity is central to risk management and execution certainty.

Prior to engagement, counterparties are assessed on a risk-sensitive basis, which may include:

• Verification of corporate identity, ownership, and legal structure
• Assessment of operational capability and relevant sector experience
• Review of trading history, reputation, and market standing
• Confirmation of legal authority to enter into binding commercial agreements
• Alignment with applicable sanctions, export controls, and trade restrictions

Counterparty relationships are reviewed on an ongoing basis, and engagements may be declined or discontinued where compliance concerns cannot be satisfactorily addressed.

Regulatory & Trade Compliance

All mandates are executed in accordance with applicable international trade laws, regulations, and sector-specific requirements relevant to the product, jurisdiction, and delivery structure.

This includes adherence to, where applicable:

• Import and export control regimes
• Customs, documentation, and clearance requirements
• Environmental and waste shipment regulations
• Product-specific regulatory standards and certifications
• Competition law and market conduct requirements

Contracts are structured to reflect these obligations, and execution is aligned to ensure lawful and compliant movement of goods across borders.

Anti-Money Laundering (AML) & Financial Controls

KS Capital Partners maintains financial control procedures designed to mitigate the risk of money laundering, fraud, bribery, and illicit financial activity.

These controls include:

• Appropriate Know Your Customer (KYC) and Know Your Business (KYB) procedures
• Risk-based assessment of counterparties and transaction structures
• Review and approval of payment methods and settlement mechanisms
• Use of recognised commercial banking channels
• Refusal to engage in opaque, non-standard, or high-risk payment practices

Settlement structures are contractually defined and aligned with accepted international commercial standards.

Sanctions, Embargoes & Restricted Activities

We do not engage in transactions that breach applicable sanctions, embargoes, or restricted trade frameworks.

This includes restrictions relating to:

• Sanctioned jurisdictions
• Sanctioned entities or individuals
• Prohibited or restricted goods
• Circumvention or avoidance of regulatory controls

Mandates are assessed with appropriate sensitivity to geopolitical risk, sanctions exposure, and regulatory developments. Engagements presenting unacceptable risk are not pursued.

Ethical & Responsible Trading

KS Capital Partners is committed to responsible trading practices across all sectors in which we operate. While we are not a producer or asset owner, we seek to engage with counterparties that demonstrate:

• Lawful sourcing and production practices
• Compliance with applicable environmental and regulatory standards
• Responsible handling, processing, and transportation of materials
• Professional conduct and commercial integrity

Where sector-specific ethical or regulatory considerations apply, these are incorporated into mandate assessment and execution planning.

Confidentiality & Information Security

Confidentiality is fundamental to our operating model. All commercial discussions, mandate details, and transaction information are treated as strictly confidential.

Information is:

• Disclosed only on a need-to-know basis
• Shared solely for execution, compliance, or contractual purposes
• Not publicly disclosed without explicit authorisation

We do not publish client identities, transaction details, pricing, or volumes.

Speak-Up & Reporting Culture

KS Capital Partners promotes a culture of transparency and accountability. Secure and confidential channels are maintained to allow concerns relating to conduct or compliance to be raised appropriately.

Issues are assessed discreetly and addressed in a manner that supports early resolution, protects integrity, and mitigates risk.

Scope of Engagement

KS Capital Partners engages exclusively on a mandate basis with institutional and professional counterparties.

We do not provide:

• Retail brokerage services
• Investment advice or financial promotion
• Speculative trading, derivatives, or financial instruments
• Public pricing or inventory listings

All engagements are assessed individually and accepted at our discretion.

Ongoing Oversight & Review

Governance and compliance are subject to continuous review. Execution practices, counterparty relationships, and regulatory developments are monitored to ensure frameworks remain effective and proportionate to evolving risk environments.

Processes are updated where necessary to maintain alignment with best practice and regulatory expectations.

Engaging with KS Capital Partners

Governance and compliance considerations are integral to every mandate we accept. Counterparties seeking to engage should be prepared to operate within a structured, transparent, and professional execution framework.

Mandate-based enquiries across any sector may be initiated via our intake process. All enquiries are assessed in line with the governance and compliance standards outlined above and treated with strict confidentiality.