At INTEGRITY COMMODITIES TRADING we believe that ethical business conduct is the foundation of long-term success. Therefore, this Code of Ethics and Compliance reflects our values and a clear statement of our intention to uphold them consistently across our business activities.

As a company engaged in the global trade of fertilizers, related chemical products, and grains, INTEGRITY COMMODITIES TRADING operates in an interconnected marketplace, building long-term partnerships with producers, distributors, and importers worldwide.

In this complex and dynamic environment, our achievements are not measured solely by financial results, but also by the way we conduct ourselves in our relationships with partners, authorities, and communities.

For this reason, the Code outlines the principles and expectations that guide our behavior with clients, suppliers, public institutions, and among colleagues. It is designed to be a practical resource that helps all members of the INTEGRITY COMMODITIES TRADING team make ethical and thoughtful decisions, while reinforcing a culture of honesty, transparency, and mutual accountability.

• Promote a culture of ethical business conduct across all areas of our operations.
• Ensure a consistent and principled approach to how we interact with clients, suppliers, partners, and authorities.
• Define the roles and responsibilities of those entrusted with supervising and ensuring compliance with this Program.
• Establish clear channels for reporting concerns or violations and outline the procedures individuals must follow when facing potential breaches of our Code, applicable laws, or INTEGRITY COMMODITIES TRADING’s compliance program.
• Foster accountability at every level of the company by reinforcing our zero-tolerance stance against bribery, corruption, and any improper business practices.

This Code of Ethics and Compliance applies to all individuals who represent INTEGRITY COMMODITIES TRADING regardlessof their role, location, or contractual status. This includes employees, officers, directors, contractors, and any third parties who act on behalf of the company or are engaged in our operations.

It is also intended to serve as a point of reference for our clients, business partners, suppliers, service providers, and other external collaborators. While they may not be directly bound by the Code, we expect them to share our commitment to ethical business practices and to conduct their activities in a manner that aligns with the principles described here.

The Code applies across all jurisdictions where INTEGRITY COMMODITIES TRADING operates, whether through physical presence, commercial activity, or business relationships. Although laws and regulations may differ between countries, our ethical expectations remain consistent and are meant to support full compliance with local, regional, and international standards.

In this regard, this Code is not intended to replace local laws, internal policies, or specific contractual obligations. Instead, it complements them by reinforcing a unified ethical standard that reflects INTEGRITY COMMODITIES TRADING’s values across all our activities.

At INTEGRITY COMMODITIES TRADING, our mission is to add value to the global metals supply chain by delivering high-quality fertilizers and grains through responsible, transparent, and efficient trading practices.

We work to support the growth and productivity of metals producers, distributors, and importers by combining deep market knowledge with logistical precision and a firm ethical foundation.

Our vision is to be recognized as a global leader in the ethical and responsible trade of fertilizers and metals commodities. We aim to grow our presence in key international markets while reinforcing our reputation as a trustworthy, agile, and value-driven organization.

A message from our CEO and Founder Luca Di Gaetano.

At INTEGRITY COMMODITIES TRADING, we firmly believe that integrity, honesty, and ethics must guide every business decision we make.

Our principles are non-negotiable, and we want them to be the first thing our customers and suppliers associate with the name INTEGRITY COMMODITIES TRADING.

Our values are at the heart of the company, and every INTEGRITY COMMODITIES TRADING employee is expected to act with respect and responsibility, safeguarding the company’s good name and reputation.

INTEGRITY COMMODITIES TRADING maintains a structured compliance framework designed to ensure that all business activities are conducted in accordance with applicable laws, ethical standards, and internal company policies.

This structure is supported by the Compliance Committee, a collegiate body that acts as the highest authority for compliance within INTEGRITY COMMODITIES TRADING. The Committee is entrusted with the development, supervision, and enforcement of the company’s compliance policies and procedures. 

Its composition and internal functioning are defined in the Compliance Committee Charter, which establishes the roles of its members, the scope of their responsibilities, and the frequency of their meetings.

By meeting periodically, the Compliance Committee defines and updates the company’s compliance policies, monitors their effective implementation, and ensures that INTEGRITY COMMODITIES TRADING consistently upholds the highest standards of integrity, legality, and ethical conduct.

Its main responsibilities include:

• Defining, updating, and approving INTEGRITY COMMODITIES TRADING’s compliance policies and procedures.
• Providing day-to-day guidance on compliance-related questions.
• Monitoring changes in legal and regulatory environments that affect company operations.
• Conducting internal reviews and assessments to ensure alignment with legal and ethical standards.
• Delivering training sessions and awareness programs for employees and collaborators.
• Supporting the development and enforcement of internal controls and compliance procedures.
• Coordinating the investigation and resolution of reports of suspected misconduct.
• Ensuring effective communication of reporting channels and procedures for addressing potential breaches of the Code or the compliance program.

However, Compliance is not the sole responsibility of the Compliance Committee. It is a shared obligation across all functions and levels of INTEGRITY COMMODITIES TRADING. Managers and supervisors are expected to reinforce compliance practices within their teams and ensure that the Code is applied consistently in daily operations.

All employees, contractors, representatives, agents, and business partners of INTEGRITY COMMODITIES TRADING are required to:

• Read, understand, and adhere to this Code of Ethics and Compliance.
• Carry out their duties in accordance with applicable laws, company policies, and ethical principles.
• Promptly report any conduct that may violate the Code or applicable legal standards.
• Cooperate fully with any internal reviews, audits, or investigations related to compliance matters.
• Act with particular diligence in all interactions, both internal and external, especially in dealings involving public officials, commercial partners, or third parties.

All internal and external stakeholders must understand that compliance is a non-negotiable part of our operational model. Adhering to this structure is essential to protect the company, its reputation, and its long-term success.

All business activities carried out under the name of INTEGRITY COMMODITIES TRADINGmust comply with applicable laws, regulations, and international standards in every jurisdiction where the company operates or maintains commercial relations. This includes, but is not limited to, legal frameworks related to international trade, customs, sanctions, anti-corruption, anti-money laundering, and tax compliance.

Key Areas of Legal Compliance. INTEGRITY COMMODITIES TRADING is particularly subject to the following regulatory areas:

• Customs and International Trade Regulations: All imports and exports must comply with applicable customs laws, documentation requirements, and tariff classifications in the countries involved.

• Economic Sanctions and Export Controls: No transaction may involve parties or jurisdictions subject to international sanctions or embargoes. It is strictly prohibited to conduct business with entities or individuals listed by sanctioning bodies such as the United Nations, European Union, or U.S. OFAC.

• Anti-Bribery and Anti-Corruption Laws: All forms of bribery, facilitation payments, or unlawful advantages are strictly prohibited. This includes compliance with international standards such as the U.S. Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act, regardless of whether the transaction takes place in those jurisdictions.

• Anti-Money Laundering (AML): All financial transactions must be legitimate, traceable, and supported by proper documentation. Any suspicious activity must be reported immediately to the compliance function.

• Tax and Financial Reporting Requirements: All records, invoices, and contracts must be accurate, complete, and maintained in accordance with applicable tax and financial laws.

• Applicable Local Regulations: In addition to international laws, all employees and representatives must follow local laws and regulatory requirements in any country where INTEGRITY COMMODITIES TRADING conducts business.

INTEGRITY COMMODITIES TRADING applies a strict zero-tolerance policy toward any form of bribery, corruption, or undue influence in the course of its business activities. Compliance with anti-corruption principles is mandatory for all employees, agents, contractors, and third parties working on behalf of the company.

Bribery is defined as offering, giving, requesting, or receiving anything of value with the intention of influencing a business or institutional decision to obtain an improper advantage. Such actions are strictly prohibited, whether they occur directly or indirectly, and regardless of local customs or business practices.

Employees and representatives of INTEGRITY COMMODITIES TRADING must not offer, accept, authorize, or promise any benefit, payment, or advantage intended to improperly influence business decisions. This applies to relationships with both public authorities and private-sector entities.

All third parties who work with or represent INTEGRITY COMMODITIES TRADING are expected to act in full alignment with the company’s ethical standards. Before establishing a commercial relationship, the company will assess the reputation and reliability of the third party.

Any individual or organization that refuses to commit to anti-corruption standards, or that has a history of misconduct, will not be permitted to represent INTEGRITY COMMODITIES TRADING in any capacity.

Furthermore, the use of third parties, such as consultants or intermediaries, to carry out actions that would not be permitted directly is equally prohibited. All third parties acting on behalf of INTEGRITY COMMODITIES TRADING must operate in full alignment with our ethical and compliance standards.

The following guidelines regarding gifts and business courtesies must be observed by all personnel:

• Gifts or promotional items must only be given or received when they are intended to promote the image and reputation of INTEGRITY COMMODITIES TRADING. Under no circumstances may gifts, favors, or any form of compensation be offered or accepted with the intention of unlawfully influencing a business relationship.
• The giving or acceptance of gifts is only permitted when the value is symbolic or limited, and when such gestures are considered standard acts of courtesy or part of a usual business relationship.
• If a gift or benefit does not meet the criteria stated above, it must be politely refused or returned.
• In certain cultural or business contexts, refusing a gift offered in good faith may be considered disrespectful or potentially damaging to a professional relationship. In such cases, the gift may be accepted on behalf of INTEGRITY COMMODITIES TRADING. The recipient must immediately inform their direct manager and the Compliance Function, issue a receipt, and submit the item to the designated internal department.

INTEGRITY COMMODITIES TRADING encourages all employees and collaborators to consult with the compliance team before taking any action that could raise questions about ethical or legal appropriateness. Any suspicion of misconduct must be reported promptly.

Violations of this policy may result in disciplinary action, contract termination, and legal consequences, depending on the severity of the infraction. Such violations may also give rise to liability under UAE law or under the laws of any jurisdiction where the misconduct occurs or has an effect.

At INTEGRITY COMMODITIES TRADING, we believe in doing business with honesty, and full respect for the law. We only work with individuals and organizations that share this commitment. We do not knowingly engage with anyone involved in illegal activities such as bribery, fraud, terrorist financing, or money laundering.

Money laundering happens when funds obtained through criminal activities are moved through legitimate business transactions to hide their true origin. Hence, preventing this kind of misuse is essential to maintaining trust, supporting the global economy, and contributing to a safer business environment.

Signs that may be indications of money laundering activity include:

• Attempts by a customer to provide false or anonymous information to open an account, or refusal to provide requested information.
• Payments made or requested in currencies other than those specified in the contract, or requests to pay more than provided for in the contract.
• Orders, purchases, or payments that are unusual or inconsistent with a customer’s trade or business.
• Payments on behalf of a customer from an unknown or anonymous person or from an unusual non-business account.
• Transactions structured to evade reporting requirements in any jurisdiction.
• An unusual pattern of transactions, such as bulk purchases of products or gift cards, or repetitive cash payments.

We comply fully with anti-money laundering laws in all the countries where we operate. Therefore, our processes are designed to help us know our customers and partners, understand the nature of our transactions, and ensure that everything we do meets legal and ethical expectations.

Furthermore, as we will elaborate on in this document, the company has implemented a “Know Your Customer” (KYC) policy, which is part of the Anti-Money Laundering policy, and all employees and collaborators are expected to adhere to it and assist in its implementation, which is an integral part of our compliance framework.

If at any time something feels unclear or inconsistent, the best approach is to ask questions or consult with the compliance team. This commitment to anti-money laundering is not only a regulatory requirement, but also part of how we protect our reputation, build lasting partnerships, and stay true to our values.

A conflict of interest occurs when personal, financial, or external interests compromise, or could reasonably appear to compromise, an individual’s ability to make objective decisions in the best interests of INTEGRITY COMMODITIES TRADING. Ensuring impartiality in all actions and decisions is essential to maintaining the integrity, trust, and professionalism that define the company.

All employees, contractors, agents, and business partners are expected to avoid situations where their private interests might interfere with their responsibilities to INTEGRITY COMMODITIES TRADING. This includes any circumstance that could affect decision-making, weaken internal controls, or undermine confidence in the fairness of our operations.

Personnel must always act independently and prioritize the company’s interests. Even if no actual conflict exists, the appearance of a conflict can damage reputations and business relationships. For this reason, potential conflicts must be identified and addressed proactively.

Examples of situations that may lead to a conflict of interest include participating in decisions involving companies in which the individual or their close relatives have a financial interest, using company information or resources for personal benefit, engaging in external business activities that compete with INTEGRITY COMMODITIES TRADING, or supervising someone with whom they have a close personal relationship.

Anyone who becomes aware of a potential conflict must report it promptly to their direct supervisor or to the Compliance Committee. The situation will be reviewed objectively, and, if necessary, appropriate measures will be taken to mitigate or eliminate the conflict. This may include recusal from decision-making processes, changes in reporting lines, or restrictions on certain activities.

INTEGRITY COMMODITIES TRADING is committed to competing in the global market through honest and lawful business practices. We respect all applicable competition and antitrust laws in every country where we conduct business and do not tolerate any action that could restrict fair market conditions or distort competition.

All employees, agents, and third parties acting on behalf of the company are expected to engage in business activities that promote open and fair competition. This includes avoiding any agreements, informal understandings, or coordinated actions with competitors that could limit pricing, divide markets, restrict supply, or exclude other players from the market.

The following actions are strictly prohibited:

• Discussing or agreeing with competitors on prices, pricing strategies, discounts, or terms of sale.
• Allocating customers, territories, or markets in coordination with competitors
• Coordinating bids or offers in public or private tenders.
• Sharing sensitive commercial information with competitors without a legitimate and legal reason.
• Using third parties to indirectly engage in any of the prohibited behaviors above.

INTEGRITY COMMODITIES TRADING also prohibits any attempt to abuse a dominant market position or to interfere with the business relationships of competitors, clients, or partners through coercion, misinformation, or manipulation.

We believe that fair competition benefits our clients, partners, and the markets in which we operate. All decisions regarding pricing, customers, and commercial strategy must be made independently, based on legitimate business considerations and in accordance with the law.

INTEGRITY COMMODITIES TRADING is committed to full compliance with all trade laws, customs regulations, and international sanctions applicable in any country where we do business. As a global trader of fertilizers, metals products, and chemical materials, our operations are subject to a wide range of controls designed to ensure the safety, legality, and transparency of international commerce.

All employees, agents, and third parties involved in cross-border transactions must understand and follow the rules that apply to imports, exports, transportation, and product classification. This includes verifying whether a product, destination, customer, or transaction is subject to any form of restriction or control.

No business activity may proceed if it involves countries, individuals, or entities that are subject to sanctions, embargoes, or trade restrictions imposed by national or international authorities.

In particular, INTEGRITY COMMODITIES TRADING requires mandatory compliance with the following frameworks:

• United States (OFAC – Office of Foreign Assets Control): All operations must be screened against the Specially Designated Nationals and Blocked Persons List (SDN List) and any other OFAC lists.
• European Union (EU Sanctions): Compliance with all restrictive measures imposed by the EU, including financial, trade, and sectoral sanctions under Council Regulations and Decisions.
• United Nations (UN Sanctions): Respect for all Security Council sanctions, including embargoes, trade restrictions, and asset freezes.
• Local and Country-Specific Sanctions: Compliance with the national sanctions regimes of the jurisdictions where INTEGRITY COMMODITIES TRADING operates, including both destination countries and countries involved in the transaction.

All shipments must be accompanied by accurate and complete documentation. It is strictly prohibited to falsify or omit information for the purpose of avoiding customs duties, bypassing export controls, or misrepresenting the nature or origin of a product.

When a product is subject to export control regulations or requires an export license, shipments must not be made until the proper authorization has been obtained. All relevant documentation must be stored and accessible for audit purposes.

Employees involved in trade operations must:

• Accurately declare goods, quantities, values, and classifications.
• Respect all customs and import/export requirements for each jurisdiction.
• Report any delays, discrepancies, or red flags to the compliance function immediately.
• Refuse to participate in transactions that could violate applicable trade laws or sanctions.

The Compliance Committee is available to provide training and operational support to all areas of the company. Any uncertainty regarding a transaction, destination, or counterpart must be escalated before proceeding.

INTEGRITY COMMODITIES TRADING is committed to protecting the confidentiality and availability of all information entrusted to the company. This includes commercial data, financial records, contracts, trade documentation, internal communications, and other sensitive information generated or received in the course of business.

While the company does not typically process large volumes of personal data, it handles a significant amount of confidential and business-critical information that must be protected against unauthorized access, disclosure, loss, or misuse. These protections apply to all formats, whether physical or digital, and across all areas of the business.

All employees, contractors, and third parties working with INTEGRITY COMMODITIES TRADING must ensure that information is accessed, stored, and shared only when necessary and with proper authorization. Information may not be used for purposes unrelated to company operations, nor may it be disclosed to unauthorized individuals inside or outside the organization.

All personnel are expected to:

• Access only the information required for their job duties.
• Use secure, company-approved systems and platforms for communication and data storage.
• Protect devices, login credentials, and access cards from misuse.
• Avoid transmitting sensitive documents over unsecured channels.
• Store both digital and physical information in safe and controlled environments.
• Immediately report any suspected loss, leak, or unauthorized access to the compliance function.

Particular attention must be paid when working remotely or in public settings. Confidential conversations should be held in private, and sensitive documents should never be left unattended or transported without proper safeguards.

No business information, including details about clients, suppliers, transactions, pricing, or internal decisions, may be shared with external parties unless there is a clear business need and appropriate authorization. Even in those cases, care must be taken to ensure the information is transmitted securely and legally.

INTEGRITY COMMODITIES TRADING encourages a culture of openness and accountability. All employees, contractors, and business partners are expected to report any behavior or situation that may violate this Code of Ethics, applicable laws, or the company’s internal policies.

The Company provides a safe and confidential Whistleblowing Channel, which is available on INTEGRITY COMMODITIES TRADING’s official website together with the internal regulations governing its use. Reports may be submitted anonymously or with identification, and all submissions will be treated seriously, impartially, and with the appropriate level of confidentiality.

Whistleblowing refers to the act of reporting unethical, illegal, or suspicious conduct that affects the company, its stakeholders, or the public interest. Examples may include:

• Fraud or financial manipulation
• Bribery or corruption
• Violations of trade laws or sanctions
• Unsafe business practices
• Harassment or discrimination
• Retaliation against someone who has reported wrongdoing

INTEGRITY COMMODITIES TRADING prohibits any form of retaliation against individuals who report concerns in good faith. No employee or collaborator will be penalized, dismissed, demoted, or discriminated against for raising a concern or participating in an investigation. Retaliation itself is a violation of this Code and will be subject to disciplinary action.

All reports will be reviewed promptly and, when necessary, followed by an internal investigation as defined in the whistleblowing channel rules. The company will take appropriate corrective actions based on the findings, and the whistleblower will be informed of the outcome.

INTEGRITY COMMODITIES TRADING is committed to maintaining a workplace where ethical conduct is recognized and protected. Reporting misconduct is not only a right but a responsibility shared by everyone who represents the company.

INTEGRITY COMMODITIES TRADING is committed to maintaining a respectful, safe, and inclusive work environment for all employees and collaborators. We proudly adhere to the principles of the United Nations Global Compact, which promote respect for human rights, fair labor conditions, environmental responsibility, and anti-corruption practices.

Discrimination, harassment, or any form of abuse is not tolerated under any circumstance. All individuals must be treated fairly and with dignity, regardless of background or personal characteristics.

We fully reject child labor, forced labor, and any practices that compromise individual freedom, safety, or human dignity. These expectations extend to all our business partners and suppliers.

INTEGRITY COMMODITIES TRADING is committed to conducting its business in a way that is environmentally responsible and socially conscious. As part of our adherence to the United Nations Global Compact, we actively promote sustainability, respect for communities, and the responsible use of natural resources in all areas of our operations.

We recognize that our activities, particularly those related to global trade and logistics, can have an environmental and social impact. Therefore, we seek to minimize negative effects and contribute positively wherever possible.

All employees and business partners are expected to:

• Comply with applicable environmental laws and regulations
• Use resources efficiently and avoid unnecessary waste
• Respect the communities and environments where we operate
• Report any activities or situations that may pose environmental or social risks

We also encourage our suppliers and collaborators to adopt responsible practices and to support local development whenever feasible.

INTEGRITY COMMODITIES TRADING engages with external parties who contribute to specific aspects of its international operations. These relationships may involve suppliers, logistics partners, or service providers supporting the company’s commercial activities.

To support this approach, INTEGRITY COMMODITIES TRADING has implemented a formal Know Your Customer (KYC) program. This process ensures that all external parties are properly identified, evaluated, and approved in accordance with the company’s compliance requirements.

As part of the KYC process, INTEGRITY COMMODITIES TRADING requests clear and relevant information from each partner. This may include confirmation of legal identity, understanding the nature of their business, reviewing ownership structures, and verifying that there are no sanctions or other regulatory concerns.

This process is designed to:

• Strengthen trust and transparency in business relationships.
• Ensure alignment with anti-corruption, anti-money laundering, labor, trade, and environmental standards.
• Support responsible growth and reduce exposure to unethical practices.

All third parties are expected to conduct their activities in accordance with the law and in line with INTEGRITY COMMODITIES TRADING’s values. They shall provide accurate information during the due diligence process and cooperate fully if additional documentation or clarification is required.

Contracts with third parties include provisions related to ethics, compliance, and the company’s right to monitor or end the relationship if violations are identified. These clauses are not optional and reflect INTEGRITY COMMODITIES TRADING’s strong commitment to responsible business conduct.

Employees responsible for managing or approving external relationships must ensure that the KYC process is completed and properly documented. In cases involving sensitive operations or higher risk, additional review or ongoing monitoring may be necessary.

INTEGRITY COMMODITIES TRADING monitors compliance with this Code through internal controls, ongoing supervision, and, when necessary, formal audits. These efforts help ensure that policies are being followed and that ethical practices are embedded across daily operations.

The company may review activities, processes, and third-party relationships to verify alignment with legal and internal standards. These reviews may be conducted periodically or in response to concerns or incidents.

Employees and partners are expected to cooperate fully with any review or audit. Providing accurate information and maintaining proper records is essential.

If violations of this Code or applicable laws are identified, INTEGRITY COMMODITIES TRADING will take appropriate action. This may include internal disciplinary measures, contract termination, or reporting to authorities when required.

INTEGRITY COMMODITIES TRADING is committed to ensuring that all employees and relevant third parties understand this Code of Ethics and know how to apply it in practice. To support this, the company provides training and guidance adapted to each role and level of responsibility.

New employees receive an introduction to the Code as part of their onboarding process. Additional training may be delivered periodically or in response to updates in regulations, internal policies, or operational needs.

Communication about ethics and compliance is continuous. Internal messages, reminders, and resources are used to reinforce awareness, encourage responsible decision-making and maintain a culture of integrity across the organization.

In addition to internal efforts, INTEGRITY COMMODITIES TRADING also considers it a responsibility to communicate the existence of its compliance program to clients, suppliers, and business partners. Sharing our standards and expectations helps ensure that all parties understand our ethical commitments and contributes to transparency in our commercial relationships.

This Code of Ethics becomes effective from the date of its formal approval by the management of INTEGRITY COMMODITIES TRADING and applies to all employees, contractors, and individuals acting on behalf of the company.

INTEGRITY COMMODITIES TRADING reserves the right to update, modify, or expand this Code at any time in response to changes in applicable laws, internal policies, or business needs. All updates will be communicated appropriately, and employees are expected to stay informed and comply with the most current version.

In case of conflict between this Code and local customs, informal practices, or previous internal guidelines, the principles set forth in this document shall prevail.

The interpretation and enforcement of this Code is the responsibility of the designated compliance function or other authorized body within INTEGRITY COMMODITIES TRADING. Any questions regarding its application must be referred to the appropriate point of contact.

This Code reflects the values and commitments that define INTEGRITY COMMODITIES TRADING. Upholding it is essential to maintaining the trust of our clients, partners, and communities around the world.