Compliance & Responsible Trading

Boreal Commodities is committed to conducting its business in accordance with applicable laws and regulations, contractual obligations, and recognized standards of ethical business conduct. This page provides a general overview of the principles that guide our approach to international commodity trading.

We may conduct risk-based due diligence on customers, suppliers, intermediaries, freight providers, agents, and other business partners. Depending on the transaction, this may include verification of:

• legal identity and corporate registration;
• corporate ownership and beneficial ownership;
• nature of business activities;
• trade and bank references;
• banking information;
• destination and intended end use;
• sanctions and restricted-party exposure;
• relevant adverse information.

Our transactions may be subject to review against applicable sanctions programs, trade restrictions, embargoes, export controls, and restricted-party requirements administered by the authorities of Canada, the United States, and other relevant jurisdictions. Boreal Commodities reserves the right to decline, suspend, or unwind any transaction where legal, regulatory, or compliance concerns arise.

Boreal Commodities is committed to preventing money laundering, terrorist financing, fraud, and the misuse of international trade and payment channels. We expect our counterparties to maintain appropriate controls to identify and prevent such activity in their own operations.

Boreal Commodities does not tolerate bribery, kickbacks, facilitation payments, corruption, or improper influence in any form. Our employees, representatives, and counterparties are expected to conduct business ethically and in accordance with applicable anti-corruption laws.

We seek to work with reputable suppliers and responsible supply chain partners. In our sourcing activities, we are committed to:

• product integrity and accurate specifications;
• traceability of origin where reasonably available;
• lawful sourcing that respects applicable regulation;
• environmental responsibility in the operations we control;
• respect for internationally recognized labour standards;
• respect for internationally recognized human rights;
• accurate transaction and shipping documentation.

Product specifications, quality certificates, laboratory analyses, certificates of origin, phytosanitary documents, bills of lading, customs declarations, and other transaction records are handled in accordance with the requirements of the applicable contract, market, and jurisdiction.

We expect employees, representatives, and counterparties to disclose actual or potential conflicts of interest so that they can be managed appropriately and transparently.

Commercial, supplier, customer, pricing, and transaction information is treated as confidential and handled with appropriate care, in line with our internal practices and applicable legal and contractual obligations. Personal information is handled in accordance with our Privacy Policy.

Employees, suppliers, customers, and other partners are encouraged to raise questions and report suspected misconduct or compliance concerns relating to Boreal Commodities’ activities. Reports may be submitted through:

• the general contact channels listed on our contact page;
• Boreal Commodities Ltd., 49 St. Clair Avenue W, Toronto, ON M4V 1K6, Canada;
• Telephone: +1 (647) 410-4247.

We will treat reports with appropriate confidentiality, to the extent permitted by law.

Our policies and procedures may be reviewed and updated from time to time as our business, the markets we serve, and applicable regulatory requirements evolve.

This page is a general statement of principles that guide the way Boreal Commodities seeks to conduct its business. It does not constitute a contract, warranty, representation, or guarantee, and it does not create any legal rights in favour of any person.