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Ethical Trading & ESG Statement

Last updated: January 2026

Naucom L.L.C. (“Naucomllc”, “we”, “us”, “our”) is committed to conducting its business responsibly, ethically, and in a manner that respects applicable environmental, social, and governance (ESG) principles.

This statement outlines our high-level approach to ethical trading and ESG considerations and is intended for public informational purposes.

1. Ethical Trading Principles

Naucom L.L.C. is committed to:

  • acting with integrity, transparency, and professionalism in all business dealings;
  • complying with applicable laws, regulations, and recognised international standards;
  • engaging only with legitimate and appropriately verified counterparties; and
  • rejecting unethical, deceptive, or unlawful practices.

Ethical conduct is a foundational expectation across all Naucom L.L.C. activities and relationships.

2. Environmental Considerations

Naucom L.L.C. recognises the importance of environmental responsibility and the global transition toward more sustainable practices.

While our activities primarily involve international trade and facilitation rather than direct industrial operations, we seek to:

  • support lawful and responsible supply chains;
  • consider environmental risks where relevant to our business engagements; and
  • avoid misrepresentation or greenwashing in relation to environmental claims.

Environmental initiatives are approached pragmatically and in line with regulatory and commercial realities.

3. Social Responsibility

Naucom L.L.C. respects fundamental human rights and supports responsible labour practices.

We:

  • oppose forced labour, child labour, and human trafficking in all forms;
  • expect business partners to comply with applicable labour and human rights laws; and
  • promote fair, lawful, and respectful business relationships.

Our approach is aligned with internationally recognised principles of responsible business conduct.

4. Governance & Compliance

Strong governance underpins ethical trading.

Naucom L.L.C. maintains:

  • compliance frameworks addressing AML, KYC, sanctions, and anti-bribery requirements;
  • clear accountability and oversight within the organisation; and
  • risk-based decision-making to support lawful and ethical outcomes.

We do not participate in arrangements designed to circumvent regulatory, banking, or compliance controls.

5. Counterparty Expectations

Naucom L.L.C. expects counterparties, partners, and service providers to:

  • act in accordance with applicable laws and ethical standards;
  • cooperate with reasonable due diligence and compliance requests; and
  • refrain from conduct that could expose Naucom L.L.C. or others to legal, reputational, or ethical risk.

Where material concerns arise, Naucom L.L.C. reserves the right to decline or terminate engagements.

6. Continuous Review

Naucom L.L.C. recognises that ethical and ESG expectations evolve. We review our approach periodically and seek to improve alignment with relevant standards and best practices, taking into account the nature and scale of our business.

7. No Reliance

This statement:

  • does not constitute legal, environmental, or investment advice;
  • does not create contractual rights or obligations; and
  • should not be interpreted as a guarantee of ESG outcomes.

8. Contact

For general questions regarding this Ethical Trading & ESG Statement, please contact:

Naucom L.L.C.
Email: services@naucomllc.com



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