Equal Opportunity

inHOUSE Commodity Consulting is an equal opportunity employer and does not discriminate on grounds of age, sex, race or other protected categories.  It supports the concept of open society, critical  thinking and respect for other opinions  

It is the policy of INHOUSE COMMODITY CONSULTING Ltd to conduct business in an honest and ethical manner. As part of that, INHOUSE COMMODITY CONSULTING Ltd takes a zero-tolerance approach to bribery and corruption and is committed to acting professionally, fairly and with integrity in all its business dealings and relationships, wherever it operates, and implementing and enforcing effective systems to counter bribery.

INHOUSE COMMODITY CONSULTING Ltd will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which it conducts business, including, in the UK, the Bribery Act 2010 (the Act), which applies to conduct both in the UK and abroad.

This policy applies to all individuals working for or on behalf of INHOUSE COMMODITY CONSULTING Ltd. at all levels and grades, whether permanent, fixed term or temporary, and wherever located, including consultants, contractors, seconded staff, casual staff, agency staff, volunteers, agents, sponsors and any other person who performs services for or on behalf of the Firm, (collectively referred to as Workers in this policy).

In this policy, Third Party means any individual or organisation that Workers come into contact with during the course of work and the running of INHOUSE COMMODITY CONSULTING Ltd business, and includes actual and potential clients, intermediaries, referrers of work, suppliers, distributors, business contacts, agents, advisers, government and public bodies (including their advisers, representatives and officials), politicians and political parties.

A bribe is an inducement or reward offered, promised or provided to improperly gain any commercial, contractual, regulatory or personal advantage, which may constitute an offence under the Act, namely:

• giving or offering a      bribe;
• receiving or requesting      a bribe; or
• bribing a foreign public      official.

INHOUSE COMMODITY CONSULTING Ltd. may also be liable under the Act if it fails to prevent bribery by an associated person (including, but not limited to Workers).

This policy does not prohibit normal and appropriate gifts and hospitality (given and received) to or from Third Parties unless otherwise specifically stated. However, we have specific internal policies and procedures which provide guidance to Workers as to what is to be regarded as normal and appropriate gifts and hospitality in terms of financial limits, subject to the principles set out below (the Overriding Principles), namely that any gift or hospitality:

• must not be made with      the intention of improperly influencing a Third Party or Worker to obtain      or retain business or a business advantage, or to reward the provision or      retention of business or a business advantage, or in explicit or implicit      exchange for favours or benefits;
• must comply with local      law in all relevant countries;
• must be given in the      name of the organisation, not in an individual’s name;
• must not include cash or      a cash equivalent;
• must be appropriate in      the circumstances;
• must be of an      appropriate type and value and given at an appropriate time taking into      account the reason for the gift;
• must be given openly,      not secretly; and
• in the case of gifts,      they must not be offered to, or accepted from, government officials or      representatives, politicians or political parties, 

INHOUSE COMMODITY CONSULTING Ltd appreciates that the practice of giving business gifts varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable both in the UK and any other relevant country. The intention behind the gift should always be considered.

It is not acceptable for any Worker (or someone on their behalf) to:

• give, promise to give,      or offer, a payment, gift or hospitality with the expectation or hope that      they or the Firm will improperly be given a business advantage, or as a      reward for a business advantage already improperly given;
• give, promise to give,      or offer, a payment, gift or hospitality to a government official, agent      or representative to facilitate or expedite a routine procedure;
• accept payment from a      Third Party where it is known or suspected that it is offered or given      with the expectation that the Third Party will improperly obtain a      business advantage;
• accept a gift or      hospitality from a Third Party where it is known or suspected that it is      offered or provided with an expectation that a business advantage will be      improperly provided by the Firm in return;
• threaten or retaliate      against another Worker who has refused to commit a bribery offence or who      has raised concerns under this policy; or
• engage in any activity      that might lead to a breach of this policy.

We do not make, and will not accept, facilitation payments or “kickbacks” of any kind, such as small, unofficial payments made to secure or expedite a routine government action by a government official, or payments made in return for a business favour or advantage.

The Firm only makes charitable donations and provides sponsorship that are legal and ethical under local laws and practices and which are in accordance with the Firm’s internal policies and procedures.

We keep appropriate financial records and have appropriate internal controls in place which evidence the business reason for gifts, hospitality and payments made and received.

The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. All Workers are required to avoid any activity that might lead to, or suggest, a breach of this policy

Workers are required to notify us as soon as possible if it is believed or suspected that a conflict with this policy has occurred, or may occur in the future, or if they are offered a bribe, are asked to make one, suspect that this may happen in the future, or believe that they are a victim of another form of unlawful activity.

Any employee who breaches this policy may face disciplinary action, which could result in dismissal for gross misconduct. We reserve our right to terminate our contractual relationship with non-employee Workers if they breach this policy.

If any Third Party is aware of any activity by any Worker which might lead to, or suggest, a breach of this policy, they should raise their concerns with one, or all, of the Directors of the company. 

Training on this policy is provided for all Workers and our zero-tolerance approach to bribery and corruption will, where appropriate, be communicated to clients, suppliers, contractors, and business partners.

All Workers are aware that they are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing.

 At inHOUSE Commodity Consulting Ltd, we are committed to conducting business in an ethical and responsible manner. We strictly prohibit the use of forced labour in any form within our operations and supply chains. We are dedicated to ensuring that all workers within our company and our supply chains are treated with respect and dignity. Forced labour, human trafficking, and any form of modern slavery are unacceptable and will not be tolerated. 

This policy applies to all employees, contractors, suppliers, and business partners associated with inHOUSE Commodity Consulting Ltd. 

 Employees and stakeholders are encouraged to report any suspected instances of forced labour. Reports will be investigated promptly and thoroughly, and appropriate actions will be taken to address any violations. 

 All employees will receive training on identifying and preventing forced labour. We will also raise awareness among our stakeholders about the importance of ethical labour practices. 

We are committed to continuously improving our policies and practices to ensure the highest standards of ethical conduct. We will periodically review and, if considered necessary, update this policy to reflect new developments and best practices. 

All information and data will be treated in the strictest confidence.

The risk of loss associated with futures and options trading can be substantial. Opinions set forth by inHOUSE Commodity Consultants should not be viewed as an offer or solicitation to buy, sell or otherwise trade futures, options or securities. All opinions and information contained in this website, and all future correspondence constitute inHOUSE CC's judgment as of the date of this document and are subject to change without notice. inHOUSE CC and its respective directors and employees may effect or have effected a transaction for their own account in the investments referred to in the material contained herein before or after the material is published to any customer of a Group Company or may give advice to customers which may differ from or be inconsistent with the information and opinions contained herein. While the information contained herein was obtained from sources believed to be reliable, no Group Company accepts any liability whatsoever for any loss arising from any inaccuracy herein or from any use of this document or its contents. This document may not be reproduced, distributed or published in electronic, paper or other form for any purpose without the prior written consent of inHOUSE CC Ltd. Emails and this website are prepared without regard to the specific investment objectives, financial situation and needs of any particular recipient. Past performance is not indicative of future results.  inHOUSE Commodity Consulting, nor any of its Directors or Employees is liable either explicitly or implicitly for any losses either direct or indirect that are associated with its activities on behalf of clients or those entities or individuals that it has dealings with.