Overview of Commodities Act and its Mechanics
Prohibitions Dealing in Commodities without License Illegal Commodities Illegally obtained Commodities Violation of Human Rights Violation Environmental Norms Violation of Trade Sanctions Not Paying Due Compensation Aggressive Tax Avoidance Name-Lending Dealing without Consent with:
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Disclosure Obligations
Conduct Supply Chain Due Diligence Know & Document Business Partners Appoint Responsible Persons Implement Whistleblowing Procedures Integrate Findings from Audits Cooperate & Provide all Requested Information Communicate on Policies and Findings Proper Business Conduct Duty to Report ROHMA Breaches by Third Parties
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Disclose all Beneficial Owners Disclose all Payments to Governments Disclose all Contracts made with Governments Disclose all Licenses obtained from Governments
Politically Exposed Persons (PEPs) Commodities from Conflict Zones Commodities from Failed States Commodities from Occupied Territories
Industry-Specific Audit Are all prohibitions observed and all duties met?
YES
NO
Auditors to report immediately to ROHMA
Review of Industry-Specific Audit by ROHMA
Info incomplete? Info questionable? Suspicions of potential breaches?
NO
YES
Further Investigation by ROHMA
No breaches identified
Ongoing Monitoring by ROHMA
Breaches identified
Breach of Prohibitions Persistent Breaches of Duties Serious Breaches of Duties
Breach of Duties
Financial Penalties Revoke License Wind-up or force Liquidation Names on Blacklist Individuals up to three years Prison
Financial Penalties Revoke License Names on Watchlist
ROHMA | Area of Influence | 2014
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Duties