Q&A

1: Compliance and sustainability tend to converge in their concerns for safeguarding reputation, transparency, supply chain oversight, and third-party risk management. Which priorities are more important than others?

Supply chain oversight. This is the number one priority as it is comprised of all those other components such as reputation, transparency, and third-party risk management. The way we maintain oversight is through the transparent exchange of information. This requires us to understand our counterparties through third-party risk management and the composition of their products. We have a system in place to archive this information for our internal and external use. This system helps us ensure that our reputation is safeguarded.

2: Since sustainability and compliance are nominally interconnected, how, do you think, they can be more practically integrated?

We do everything that a regular compliance department does – monitoring relevant regulations, implementing policies, providing training, following “know your customer” guidelines – but we have the added responsibility associated with the physical products we deliver, such as biodiesel and biomethane. This makes things a little more complicated. We are also responsible for making sure that regulatory compliance is operational, as with the exchange of necessary documents based on physical product deliveries. Unsurprisingly, there are many restrictions on physical products based on regulations such as the Renewable Energy Directive, Fuels Quality Directive, REACH, and IMO.

3: How effective is external business ethics in motivating this integration?

It is beyond external business ethics. Sustainability compliance is an absolute requirement for the biofuels, fuels, and energy markets and for ACT especially. Having grown so much in such a short time, mistakes can be a lot more significant if everything we are required to do is not appropriately managed.

4: Crime often depends on gaps in enforcement. What can organizations do to protect themselves against so-called green crime?

Having a strong compliance team definitely increases the protection. Nevertheless, at ACT, we believe this is a shared responsibility, compliance cooperating with front-office, operations, finance, and risk. An integrated approach, starting with sharing relevant information and knowledge, enables us to be proactive and decreases the likelihood of becoming a victim of green crime. These actions ensure a more effective, efficient, and sustainable compliance model.

5: Regulatory compliance has, generally, served as a red line for organizations. With expectations changing about what organizations should be doing, specifically concerning their records on human rights and environmental protection, how close are we to parity between regulatory compliance and public pressure?

​We exceed regulatory compliance requirements. However, public pressure remains strong due to increased transparency in organizations and in global supply chains. As such, we remain vigilant, have imposed strict requirements, and deal only with other certified organizations.