Marex Group is a diversified global financial services platform, providing essential liquidity, market access and infrastructure services to clients in the energy, commodities, and financial markets.
In our own business, Marex applies high legal and ethical standards and expects the same of our suppliers. Marex’s Supplier Code of Conduct reflects evolving regulations, Marex’s own principles and values, and the expectations of our stakeholders.
The Marex Supplier Code of Conduct (the ‘Code of Conduct’) lays out the minimum standards and expectations for all suppliers of goods and services which Marex engages with and uses on a one-off or continuing basis (‘Suppliers’). Suppliers are deemed to have read, understood, and consented to this Code of Conduct when contracting with Marex. Suppliers must ensure that their own subcontractors and supply chain partners are aware of, and operate in a manner consistent with, the standards set out in this code of conduct.
The highest standards of integrity, honesty, and ethical conduct are expected by Marex of all suppliers in their business practices and dealings with or on behalf of Marex. Suppliers are expected to have policies, systems and/or procedures in place to ensure the prevention of unethical business practices.
Gifts and Hospitality
Suppliers shall not offer or accept any gift or anything else of value to obtain improper advantages or influence for the Supplier, Marex (including Marex employees and/or their family members and associates), or for any third party. Such gifts may include but are not limited to benefits, fees, commissions, dividends, cash, gratuities, services, or any inducements.
Conflict of Interest
If there is a pre-existing relationship between a person linked to/associated with the supplier and a Marex employee holding a decision-making or managerial position, a conflict of interest may arise. Any potential conflict of interest between Marex and a Supplier (including their relatives, friends, agents, or associates) must be declared and reviewed by Marex accordingly.
Resilience, continuity and contingency planning
Marex expects all Suppliers to maintain robust business resilience arrangements to ensure the continuity of operations and the protection of Marex’s interests and reputation. Suppliers must have documented recovery plans in place that account for severe, but plausible scenarios, and are expected to regularly test and validate their resilience capabilities to ensure their effectiveness.
In the event of a crisis or major incident, Suppliers must continue delivering services to Marex with minimal disruption. Resilience arrangements should be sufficiently comprehensive to safeguard the confidentiality, integrity, and availability of all services provided to Marex.
Suppliers are required to promptly notify Marex of any cybersecurity or business continuity incidents that may impact the confidentiality, integrity, availability, or delivery of services. Timely and transparent communication in such circumstances is essential to enable Marex to take appropriate mitigating action.
Suppliers may be requested to share with Marex their business resilience, continuity and contingency plans and the status of their Disaster Recovery (DR) testing periodically and should promptly assist with answering any further questions.
Exit Management
Suppliers, where determined, through risk assessments, shall have plans documented in the event of contract termination (planned and unplanned) for Marex’s transition to an alternative supplier. These plans should consider how Marex’s ability to deliver continuous and satisfactory services to its customers and clients would be managed, how Marex will retrieve its data and other assets, and how any transferred workforce will be affected. Suppliers may be requested to provide evidence that these plans are in place and tested to ensure effectiveness.
Regulatory Due Diligence and Performance Management
Marex is subject to regulatory requirements to identify, monitor, and audit the performance of Suppliers that are deemed material and critical to Marex’s operations.
In line with Marex’s regulatory requirements, Marex is responsible for conducting appropriate due diligence on its suppliers, who shall respond to requests promptly. It is expected that Suppliers shall likewise conduct appropriate due diligence on their supply chain and subcontractors.
Suppliers shall provide all performance management information and participate in reviews when requested. Suppliers shall notify Marex promptly of any material changes to their business, ownership structure, regulatory status, licenses, regulatory investigations, enforcement actions, or operational capability that may affect their ability to perform contractual obligations.
Compliance with Marex’s Supplier Code of Conduct
By entering and continuing a relationship with us, Marex’s Suppliers are required to agree to comply with this Code of Conduct. Marex may at any time audit, observe or conduct surveys to confirm compliance with this Supplier Code of Conduct, and Marex expects Suppliers to actively audit and monitor their day-to-day management processes as relates to this Code of Conduct and, upon request, provide evidence.
In the event of a breach to this code, the Supplier shall notify Marex in writing to suppliermanagement@marex.com. Marex will take whatever action is deemed necessary against a supplier if any breach is found. Such action could result in termination of the business relationship.
Marex’s whistleblowing policy enables concerns to be raised confidentially, including crime, fraud, regulatory breaches, or criminal behavior. Suppliers should immediately raise concerns about inappropriate conduct by Marex, its employees or supply chain either to Whistleblowing@marex.com or to their contact at Marex. Marex will not tolerate any form of retaliation against individuals who raise concerns in good faith, consistent with the EU Whistleblower Protection Directive and equivalent applicable legislation.
Marex expects all its Suppliers to comply with all applicable regulations in the regions and jurisdictions in which they operate.
Anti-Money Laundering and Counter-Terrorist Financing
Suppliers shall comply in all respects with any applicable anti-money laundering regulations and laws applicable to any jurisdiction in which they are established or in which they undertake their business activities and shall ensure they have in place appropriate corresponding policies and procedures reasonably designed to facilitate compliance.
Anti-Bribery and Anti-Corruption
Suppliers shall comply in all respects with any applicable anti-bribery and anti-corruption laws relating to any jurisdiction in which it is established or in which they undertake their business activities, including but not limited to the U.S. Foreign Corrupt Practices Act and the UK Bribery Act. Suppliers shall ensure they have appropriate corresponding policies and procedures reasonably designed to facilitate compliance. Suppliers shall take appropriate steps to ensure that all who act for or on their behalf also comply with such obligations.
Maintaining Confidential Information
Suppliers are expected to recognize that confidential and proprietary information may be disclosed to them by Marex in the normal course of business and to respect and protect the confidentiality of our data and communications. Confidentiality obligations shall survive the termination of any commercial relationship between the Supplier and Marex. Suppliers must not disclose any Marex confidential information to third parties without Marex’s prior written consent.
Intellectual Property Protection
Suppliers must respect and protect Marex’s intellectual property rights, including trademarks, copyrights, patents, and proprietary data and methodologies. Suppliers must not use Marex’s name, logo, or branding in any marketing materials, press releases, case studies, or public communications without Marex’s prior written consent. Any intellectual property created by a Supplier while delivering services to Marex shall vest in Marex unless otherwise agreed in writing.
Social Media & Public Communications
Suppliers must not make any public statements, social media posts, press releases, or other external communications referencing Marex, the commercial relationship, or any Marex project or initiative without prior written approval from Marex’s Communications team. This includes references on the Supplier’s website, LinkedIn, or any other public-facing platform.
Information Security and Data Privacy
Suppliers must ensure all Marex information and data is protected from any unauthorised access, destruction, use, modification, and disclosure, through appropriate organisational and technical measures and controls. If identified as a requirement, suppliers must evidence relevant certification and commit to maintaining this certification throughout any contractual relationship with Marex.
Suppliers must comply with data privacy and information security laws and regulations in the jurisdictions in which they operate, including the EU and UK General Data Protection Regulation (GDPR), the Singaporean Personal Data Protection Act, the Australian federal Privacy Act 1988, the Brazilian General Data Protection Law (LGPD), Dubai International Financial Centre’s Data Protection Law, the U.S.’s Gramm–Leach–Bliley Act (GLBA), and the California Consumer Privacy Act (CCPA).
Suppliers must protect all Marex information and adopt appropriate security protocols, systems processes, and practices to do so. Should any form of data breach occur or other types of incidents affecting Marex data, users, or its clients, Marex must be notified without undue delay and within legal requirements by contacting dpo@marex.com and irs@marex.com.
Physical Security
Suppliers and their personnel who have access to Marex premises or physical assets must comply with Marex’s physical security requirements, including visitor management procedures, access controls, and the secure handling and disposal of physical materials containing confidential or sensitive information. Suppliers must ensure that any Marex assets in their custody are protected from loss, theft, or unauthorised access.
Tax Evasion
Suppliers must comply fully with all their obligations in relation to all taxes due within the territories in which they operate or make supplies. Suppliers must not participate in tax evasion nor facilitate tax evasion by others. Suppliers shall ensure they have appropriate corresponding policies and procedures reasonably designed to prevent facilitation of tax evasion. Suppliers shall take appropriate steps to ensure that all who act for or on their behalf also comply with such obligations. This includes compliance with the UK Criminal Finances Act 2017 and any equivalent legislation in other applicable jurisdictions.
Prevention of Fraud
Suppliers shall comply fully with all their obligations to prevent fraud. Suppliers must be vigilant regarding fraud risks to which they may be exposed and must not engage in any acts of fraud or the facilitation of fraud acts. Suppliers shall ensure they have appropriate corresponding policies and procedures reasonably designed to prevent fraud and facilitation of fraud. Suppliers shall take appropriate steps to ensure that all who act for or on their behalf also comply with such obligations. Suppliers must promptly report to Marex any actual or suspected fraud involving Marex, its data, or its assets.
Financial Sanctions and Embargoes
Suppliers shall comply with applicable laws executing foreign policy, security, sanction, trade embargo or anti-terrorism objectives or similar restrictions imposed, administered or enforced from time to time by: (i) the United Kingdom of Great Britain and Northern Ireland, the United Nations, the European Union, the United States of America or other applicable local regimes as relevant to Marex’s subsidiaries and branches in the countries in which the company operates; (ii) any of their successors; (iii) any other relevant governmental authority; and/or (iv) the relevant authority of any jurisdiction in which the Supplier operates.
Insurance
Suppliers should hold and evidence upon request adequate insurance to cover the losses that Marex might reasonably experience from Supplier’s and/or its subcontractors’ supply chain failure to perform obligations.
Artificial Intelligence & Emerging Technology
Suppliers that use Artificial Intelligence (AI) or Machine Learning (ML) tools, including third-party platforms in the delivery of services to Marex, must disclose this prior to deployment or upon request. Marex data must not be used to train AI or ML models without Marex’s prior written consent, and suppliers must ensure that appropriate human oversight and accountability is maintained over all AI-generated outputs. Suppliers are expected to comply with all applicable AI regulations, including the EU AI Act and any relevant guidance issued by the FCA or PRA, and must notify Marex promptly of any known model failures, errors, or unintended outputs that may affect services delivered to Marex.
Marex supports the protection of human rights and labour practices across the world and complies with all applicable laws and regulations (including but not limited to the UK Modern Slavery Act 2015).
Suppliers must adhere to appropriate human rights and ethical standards in all jurisdictions where they are established, carry out business activities, or deliver services to Marex. All suppliers are expected to have the appropriate policies, processes and procedures in place to follow labour and human rights regulations which should apply to all employees, subcontractors and supply chain providers.
Wages, Working Hours, and Benefits
Suppliers shall comply with all applicable laws regarding wages, working hours, and benefits requirements (including but not limited to pension, statutory insurance, health benefits, paid leave, parental leave, maternity leave, family care leave, childcare benefits and overtime compensation). Marex, where applicable, encourages our supply chain to use living wage standards relevant to their jurisdiction/country, to pay all wages in a timely manner and to ensure that working hours and overtime is limited to humane and productive working conditions.
Anti-Human Trafficking and Modern Slavery
Suppliers shall act in accordance with anti-human trafficking and modern slavery jurisdictional laws. Marex will not knowingly work with Suppliers who commit abuses of anti-human trafficking and/or modern slavery laws, or allow their supply chain or subcontractors to abuse these laws, or use forced or bonded labour. Individuals hired by Suppliers or in their supply chain, shall freely choose all employment and be free to leave at any time which shall not be subject to any restrictions or coercion practices, and may be subject to reasonable and paid notice periods.
Child Labour Practices
Suppliers must have the appropriate processes, policies, and procedures in place to mitigate abuse of child labour practices in their organization and supply chain. Suppliers, their supply chain, and their subcontractors, must not use child labour and must regularly ensure all employees are over the relevant legal minimum age of employment in the relevant country in which they work.
Freedom of Association
Suppliers are expected to meet relevant jurisdictional requirements on workers’ rights to freedom of association and collective bargaining. Suppliers must not take any action to discourage, penalise or interfere with workers’ lawful exercise of these rights.
Workplace Health and Safety
Suppliers shall comply with applicable Health and Safety laws, for example, but not limited to, the UK Health and Safety at Work Act 1974. Suppliers should have systems, policies, and procedures in place, and share policies upon request, to support safety for all workers (including subcontractors).
Marex expects Suppliers to provide safe, healthy, and hygienic working environments for employees and visitors to minimize the risk of injury to health, and appropriate first aid emergency facilities.
Risk and Incident Monitoring, Management and Right to Audit
Suppliers are expected to monitor social risks in their supply chain including but not limited to human trafficking, modern slavery, child labour and workplace health and safety.
Suppliers are expected to be able to audit their supply chain to assess the extent to which workers’ human and labour rights are being upheld and working conditions met. When an incident of human trafficking, forced labour, bonded labour, child labour or a breach of workplace health and safety is identified, Suppliers shall take appropriate action to remediate the incident and disclose the incident and/or high risk to the relevant authorities and Marex.
Supply Chain Transparency & Mapping
Suppliers are encouraged, and where required by applicable law are obliged, to maintain a clear map of their material supply chains and make this available to Marex upon reasonable request to support Marex’s due diligence and ESG reporting obligations. Suppliers should be able to identify the origin of materials and services used in the delivery of goods and services to Marex and demonstrate that these have been sourced responsibly and ethically.
Marex strongly encourages our suppliers to respect human rights and the diversity of cultural, social, and political norms around the world. Marex expects Suppliers to promote diversity, equity and inclusion, and equal opportunities and to have policies in place to protect against discrimination, harassment or victimization including but not limited to gender, race, colour, ethnicity, religion, nationality, sexual orientation, marital or civil partnership status, age, or disability. Suppliers will be required to meet the requirements of any applicable discrimination legislation.
Suppliers may be required to disclose their Diversity, Equity & Inclusion data and performance dependent on jurisdictional requirements, and policies to Marex and its ESG platform upon request. Marex expects its suppliers to actively promote diversity within their own supply chains. Suppliers should make every effort to engage businesses from a broad range of backgrounds, including enterprises defined by their nature (such as social enterprises) and/or size (such as small and medium-sized enterprises).
Marex is committed to supporting the green transition, including becoming a Net Zero business by 2050 and reducing our environmental impact and carbon footprint.
Suppliers must comply with relevant environmental legislation or regulatory requirements and must demonstrate to Marex an understanding of the environmental risks, impacts and responsibilities associated with the products and services they provide. Depending on business size, Marex expects larger suppliers to have a documented environmental policy and be able to evidence their approach to Marex upon request. Smaller Suppliers may be asked about their environmental practices and should be prepared to provide details, if requested.
Responsible Sourcing
Marex encourages its suppliers and their supply chain to source their products and services whilst considering their social and environmental responsibilities.
Energy and Greenhouse Gas Emissions
Depending on size and at a minimum, suppliers are expected to measure scopes 1 and 2 greenhouse gas emissions (‘GHG’) for their operations, and when appropriate or required, to set reduction targets, to be realized through efficiency measures and other initiatives. Larger Suppliers are expected to share their reduction strategies upon request and show progress in their calculation of scope 3 emissions.
Water
Suppliers are encouraged to conserve and reduce the use of water within their and their supply chains’ operations.
Waste
Marex expects suppliers to minimise or eliminate waste during their and their supply chains’ operations. Waste, including hazardous waste, must be managed in a responsible manner including handling, storage, movement, recycling, and disposal. Suppliers, including their supply chain and subcontractors, must comply with all relevant laws, and workers should be trained comprehensively.
Suppliers will be required upon request to disclose their energy, GHG emissions, Water and Waste performance and targets to Marex and Marex’s ESG platform for emissions measurement, reduction and reporting.