Compliance & conduct
The trades we decline define us more than the ones we do.
Screening happens before we quote, not after we are committed. Where an origin, a counterparty or an end use cannot be cleared, we decline it rather than structure around it.
Framework
What we check, and when.
Compliance sequenced after commercial agreement is not compliance — it is a negotiation about how much risk to accept. We run it first, which occasionally costs us a trade and has never cost us a counterparty.
Counterparty due diligence
Know Your Counterparty completed on both sides of every trade — corporate registration, ownership and control, ultimate beneficial ownership, and adverse media review. Refreshed periodically rather than once at onboarding.
Sanctions screening
Counterparty, vessel, origin and destination screened against applicable sanctions regimes before indication. Ownership thresholds and control tests are applied, not just name matching.
Origin clearance
Every origin is cleared before it is offered. Multi-origin feedstock sourcing — carbon black feedstock in particular — is screened per consignment rather than per relationship.
End-use verification
Regulated products require an end-use declaration and, where applicable, evidence of permitting, site handling competence and destination-country licensing before any indication is given.
Responsible sourcing
Precious metals are traded only where refiner accreditation and chain of custody can be evidenced. Enhanced due diligence applies across the whole precious metals book.
Trade documentation integrity
Certificates of origin, quality certificates and inspection reports are obtained from the issuing party or an independent surveyor. We do not accept counterparty-prepared substitutes for either.
Controlled lines
Products carrying additional requirements.
| Product | Control | Required before indication |
|---|---|---|
| Sodium cyanide | UN 1689, Class 6.1 — acute toxicity | Verified end use, import licence, site handling capability, permitting |
| Ammonium nitrate | Security-sensitive; oxidising | End-use declaration, security screening, destination licensing |
| Nitric acid | Explosives precursor | End-use declaration and screening |
| Ammonia | Toxic gas; regulated feedstock | End-use declaration, receiving site capability |
| Precious metals | Responsible sourcing | Refiner accreditation, chain of custody, enhanced due diligence |
| CIS-origin fuels | Origin compliance | Origin clearance per consignment |
| Carbon black feedstock | Multi-origin refinery sourcing | Origin clearance per consignment |
| Sodium chlorate | UN 1495, Class 5.1 oxidiser | End-use declaration, transport and storage compatibility |
Speak Up
Raising a concern.
If you have reason to believe someone acting for or on behalf of NJORD has behaved improperly — in relation to bribery, sanctions, fraud, misrepresentation of cargo, health and safety, or human rights — we want to hear about it.
Concerns can be raised in confidence to [email protected]. Reports may be made anonymously, and we do not tolerate retaliation against anyone who raises a concern in good faith.
Policies
Published documents.
Code of Conduct
Anti-Bribery & Corruption Policy
Sanctions Compliance Policy
Modern Slavery Statement
Enquiries
Every enquiry is answered by a trader.
Send the product, quantity, delivery basis, destination and timing. We revert with availability, an indication and the documentation that accompanies it. Specifications are released once we know who we are speaking with.