Whistleblower Policy

STX’s Whistleblowing Policy for Third Parties

This Policy outlines how third parties, such as counterparties, brokers, suppliers, and job applicants, can report incidents (whistleblowing) while interacting with STX(i). The policy also explains how STX handles these incidents.
STX will handle any report of a (possible) incident with utmost confidentiality.

What is an Incident?

Any (suspicion of) wrongdoing or abuse that could potentially harm STX’s ethical and controlled business operations, or observe any undesirable behavior, including a (suspected) breach of (EU) law by or within STX, including but not limited to the following cases:

  • Accounting, internal accounting controls or auditing matters
  • Bribery or corruption
  • Competition or anti-trust
  • Data or privacy breach
  • Fraud or theft
  • Market abuse
  • Money laundering or terrorist financing
  • Discrimination
  • Health hazards
  • Sexual harassment

How should you report?

You should report an Incident by completing and submitting the Incident Reporting form, which you can access via the following link:

  1. You should click on “+ New report”
  2. Select the language you would like to leave your message
  3. Note down your unique “Report Number” and create a password for your report
  4. Type your message and click “Send message.”
  5. You have the option to leave your email address; after adding your email address, you’ll be asked to type the verifying code sent to the provided email address

When an Incident has been reported, STX will conduct a review and decide whether the issues raised should be further investigated. If so, STX will conduct or commission an investigation. STX will inform you about the investigation’s results. For legal reasons, not all information may be shared with you.

Any third party who reported an Incident will not be victimized, or treated less favorably, by STX. You should not make a report which is not true or is misleading. STX will consider that a serious matter which may have legal consequences.

[i] STX includes STX Commodities Holding B.V. and its subsidiaries, including but not limited to STX Commodities B.V., STX Commodities LLC and STX Commodities S. de R.L. de C.V.