Due diligence

Our operations rest on a prudent “Know-Your-Counterparty” (KYC) evaluation prior to execution of any contract or engagement in formal business dealings. In so doing, we seek to take a measured and conservative approach to our risk management.
Our KYC evaluation is multifaceted, designed to understand our counterparty’s commercial strength, compliance standing, and extending to incorporate our own sense of ethics into our assessment.
Similarly, Apogee prudently follows a program to conduct appropriate due diligence prior to entering any investments, acquisitions or other transactions.
We recognize the challenges that can arise in sourcing commodities in areas affected by conflict and/or other governance issues, including various sanctions. In this regard, we have implemented procedures to conduct various degrees of enhanced due diligence in all its business dealings in or around specific jurisdictions and seek to regularly investigate our commodities supply chains.


As a physical commodity trader, Apogee is subject to oversight from regulatory authorities of various countries. Many aspects of our business are affected by regulations covering health and safety, insurance, emission and environmental control, product, cargo and financial crime, international trade and sanctions, and banking,
exchange and derivatives market rules.
To ensure compliance within such an extensive and constantly evolving regulatory environment, we maintain rigorous corporate protocols and a strict compliance program. Compliance is the responsibility of each and every one of our employees. In all operations we adhere to the laws and regulations to which it is subject, both international and local, in the jurisdictions in which it operates.