The guidelines in this policy can be used by organizations looking to optimize their trading and commodity risk management activities. This policy establishes the roles, responsibilities and protocols necessary for managing these activities effectively and details various aspects such as approved risk limits, transaction authority limits, daily reporting procedures, data handling and record retention policies. It also outlines specific transaction types and limits, providing a robust framework for managing risks associated with physical and financial transactions.

Furthermore, it emphasizes the importance of governance and oversight, stating that any changes to the policy must be approved by the board of directors and the risk management committee. The document also includes a sample certificate of acknowledgment, emphasizing the importance of compliance with the policy. Lastly, it specifies authorized products, instruments and markets, ensuring that companies operate within their defined scope of activities. Overall, this policy document is a valuable tool for companies to manage their trading and commodity risks effectively and efficiently.

According to this policy, the following minimum segregation of duty standards should be maintained at all times:

• Only authorized traders and risk managers may execute transactions covered by this policy.
• Middle-office and back-office personnel may not execute any transactions covered by this policy.
• Front-office personnel are responsible for complying with the limits set forth in this policy. Middle-office personnel are responsible for assessing compliance with this policy.