Targray Group Ltd. and its subsidiaries affiliated or associated entities (together referred to herein as “Targray” or the “Company”) is a global leader in the sourcing, transportation, storage, trading and distribution of commodities and advanced materials for a broad range of industry sectors.

At Targray, we believe in building sustainable businesses that not only create economic value but do so in a way that benefits our stakeholders. We are committed to working with Partners (as defined below) who share the same principles of sustainability and ethical behavior as we do. We aim to collaborate with our Partners to maintain a resilient and sustainable supply chain. The expectations set forth herein draw upon international standards and best practices in the area of human rights and sustainability and are designed to provide Partners with a clear understanding of how they can meet Targray’s standards and conduct their business activities in accordance therewith.

Capitalized terms used herein shall have the meaning assigned to them in the Code (as defined below) or in the Glossary of terms attached hereto as Schedule B to form an integral part hereof. Complete links to any reference to a Targray policy or external standard used herein are provided in the attached Schedule A to form an integral part hereof.

Scope and Application

This Code of Conduct (the “Code”) defines the standards of business behavior that Targray expects from its Partners to adhere to when doing business with Targray. Targray requires its Partners to respect and comply with this Code, as amended or modified from time to time by Targray.

This Code applies to any party doing business with Targray, including its Suppliers, customers, partners, as well as their directors, officers, employees, agents, partners, Suppliers, affiliates (collectively, the “Partners”).

Targray reserves the right to modify the provisions in this Code as it deems fit, including but not limited in order to comply with changes of laws, rules or regulations or changes in its compliance program. In such event, the Company will notify its Partner’s in written form, providing clear notification of the changes that were made to this Code and the Partner will be bound by such changes upon delivery of such notice without the need for Partner’s consent or acknowledgment, unless Partner provides a written notice that it does not agree with the proposed changes within ten (10) business days following receipt of such notification. The undersigned Partner hereby declares, on behalf of itself and its directors, officers, employees, agents, partners, Suppliers and affiliates that it will fully comply with the provisions set forth below.

Targray will monitor the implementation of this Code and the performance of the Partner against its requirements. For example, Partner may be required to complete a self-assessment questionnaire, provide proof of statements made and demonstrate that this Code is adhered to. The Company also reserves the right to conduct Partner audits to verify compliance with this Code.

While Targray recognizes that its Partner operate in different legal and cultural environments, the standards set forth in this Code operate as a benchmark for acceptable conduct. Where applicable local laws impose less restrictive obligations on a Partner, the Partner is expected to adhere to the standards of this Code. Where applicable local laws impose greater obligations on a Partner, the Partner must comply with such laws and regulations.

Targray Expectations of Partners

This Code has been created based on internationally recognized principles and standards such as the United Nations Declaration of Human Rights and the International Labor Organization (ILO) Conventions and includes requirement in the following areas:



Compliance with Laws

Partners must comply with relevant local laws, rules and regulations in the countries where they operate. Where the provision of the law and this Code address the same topic, Partners are encouraged to follow the requirements that promote higher standards. If a Partner has any concerns regarding the application of this Code in light of local laws, we expect them to communicate with Targray at We are committed to working with all our Partners to implement the highest standards wherever possible.


Business Ethics

Targray expects its Partners to abide by the following:

Anti-bribery and Anti-corruption

Partners must comply with Targray’s Anti-Corruption Policy ( and ensure they do not, directly or indirectly, engage in any form of corruption, Bribery, facilitation payments,  fraud, kickbacks, Money Laundering, embezzlement, extortion or any other form of Bribery or corruption. Partners may not, directly or indirectly, give or receive improper business advantage or anything of value in exchange for preferential treatment. Partners may not offer, directly or indirectly, any gifts or other benefits to Targray employees, and / or anyone acting on Targray’s behalf that could improperly influence that employee or person. Targray also prohibits anyone from engaging in Bribery and corruption on its behalf. Partners must comply with all applicable laws related to anti-corruption and anti-Bribery.

Fair Competition

Competition and antitrust laws generally: (i) prohibit any type of agreement between competitors that is likely to undermine, restrict or lessen competition or affect prices and (ii) prohibit companies in a dominant or strong market position from abusing their market power by practicing anticompetitive or monopolistic behaviour by using predatory pricing practices, pricing below cost, or exclusionary practices such as tying services to eliminate or exclude competitors and thus threaten to create a monopoly position. Partners must compete fairly and must comply with all applicable antitrust and competition laws.

Privacy, Information Security, Confidential Information and Intellectual Property

In conducting all activities, Partners are expected to protect Targray’s confidential information against theft, loss, destruction, unauthorized access/release or misuse. confidential information includes without limitation, proprietary, technical, business, financial, and personal information of Targray, as well as client information, legal documents, contracts, proposals, information about a specific client or employee, intellectual property, trade secrets and personal data (the “Confidential information”). Except as required by law, Partner must not disclose Targray’s Confidential information to anyone outside Targray, without prior written approval from Targray or unless otherwise stated in a signed agreement relating thereto between Partner and Targray. Partner must not use Targray Confidential information for any improper purpose. This applies even after the Partner’s contract is complete. Unauthorized disclosure of Confidential information is a violation of this Code, any contractual requirements, and, potentially, applicable law. Partner shall report any actual or suspected data breach immediately following detection to:

Furthermore, Suppliers must comply with all applicable privacy laws, as well as Targray’s privacy policy located at:, regarding the protection and security of the personal data of Targray and Targray’s employees, clients, service providers and others. Partners must protect Targray’s intellectual property such as copyrighted information, trademarks and logos, patents, and trade secrets against loss or infringement, and use them only for Targray business or as otherwise specified in a signed agreement relating thereto between Partner and Targray.

Conflict of Interest

Partners must avoid situations where a Conflict of Interest may occur, real or perceived. Partners’ relationship with Targray should also be guided by acting in the best interests of Targray. Partners must immediately disclose to Targray any Conflict of Interest that does arise Furthermore, any situation involving a Partner that may reasonably create even an appearance of Conflict of Interest should immediately be disclosed to Targray. Such conflicts of interest could include cases where a Partner’s employee or professional under contract may have an interest or business relationship of any kind with Targray’s business or where that Partner may be acting on behalf of Targray and / or a competitor of Targray. Targray recognizes that Partner may be involved in business relationships with other companies, including Targray’s competitors. These relationships should however never interfere, or appear to interfere, with the Partner’s ability to make an objective business decision regarding Targray and to fulfil its responsibilities towards Targray.

Company Assets

Partners are entrusted with the care and use of Company assets with the expectation that they will be used for the benefit of, and as directed by, the Company. Partner must protect Company assets from fraud, theft and destruction (e.g. by vandalism or neglect) and never use the Company assets for personal use.


Labour and Human Rights

Targray supports the Universal Declaration of Human Rights and its implementation through the United Nations (UN) Guiding Principles on Business and Human Rights. As such, we expect Partners to respect all human rights, including labour rights, throughout their business activities.

Equality and no Discrimination and no Harassment

Partners are required to promote a fair and equitable work environment that is free from Discrimination and Harassment for all employees. Partners must comply with local laws in this regard.

Modern Slavery

Partners must prevent all forms of modern slavery from taking place in their operations. Modern slavery includes Human Trafficking, Forced and Compulsory Labour, slavery, Child Labour, Bonded labour and any other form of modern slavery applicable to local law. Use of Forced and Compulsory Labour by the Partner is strictly prohibited. This includes work or services not voluntarily performed that is exacted or coerced from a person under threat, force or penalty, or threatened abuse of law or legal process, including any kind of involuntary or compulsory, indentured or Bonded labour, slavery, servitude or other slavery-like circumstances. Workers must not be required, as a condition of employment, to make a deposit of or surrender any government-issued identification, passports, work permits or any other documents necessary for free movement and termination of employment. Partners must allow their workers the right to leave work and freely terminate their employment, taking into account legal notice period requirements.

Child Labour

Partners must ensure their operations are free from the exploitation of Child Labour. Partners must not employ individuals below the minimum age permitted by local law. Partners must operate in compliance with local laws and the core ILO standards regarding child labour.

Minimum Wage, Working Hours and Equal Remuneration

Wage payments, working hours and benefits must comply with all applicable laws and regulations, collective agreements. Partner will abide by applicable employment and residency laws, including visa and work permits.

Freedom of Association and Collective Bargaining

Partners must respect the right of employees to join trade unions, and associations and assemble freely without fear of reprisal, intimidation or harassment. Partners must comply with local law regarding the activities of trade unions and works and associations.

Rights of Local Communities

Partners must respect the land, resource and cultural rights of local communities and indigenous groups.


Health, Safety and Quality

Partners are required to prevent and manage health and safety risks associated with their activities, products and services. Partners should provide a safe, clean and healthy work environment and abide by all applicable laws with respect to health, safety and the environment. Partners should also comply with all applicable laws relating to product safety and quality.

Workplace Health and Safety

Partners are required to implement effective and appropriate health and safety procedures, training, preventive maintenance, protective equipment. Partners must comply with industry standards as to this matter, as well as applicable law. This also includes taking reasonable care to ensure all workers are protected against processes, substances and work methods which are unsafe. Partners should ensure that actual and potential risks to worker health and safety are identified, assessed and eliminated or managed in order to mitigate their impacts and ensure preparedness. Partners should strive for continual improvement in safety performance and regularly review and update their safety programs and practices in a manner that ensures ongoing compliance with law and industry standards.

Work Environment and Housing Facilities

Partners must provide a safe, clean, comfortable and hygienic working environment and, if applicable, residential or overnight facilities that meet the basic needs of the workers.

Product Safety and Quality

Partners are required to deliver products and services that meet the needs of Targray and that are in line with recognized and contractually agreed safety and quality requirements as well as (as a minimum) comply with the local laws in the country in which they are provided to Targray or Targray’s customers (please refer to the section entitled “Compliance with laws” above).



Targray expect all Partners in all their operations, products and services to minimize their impact on the environment and shall adhere to all environmental laws, statutes and regulations of the jurisdiction in which they operate and any additional environmental requirements and meet all legal requirements and strive to prevent or mitigate adverse effects on the environment with a long-term objective of continual improvements.

Do not Pollute the Environment, Waste Resources and Climate Change Mitigation

Partners shall ensure that they identify the environmental impacts of their operations, products and/or services. In addition, and where possible, Partners shall investigate ways to improve energy efficiency and reduce greenhouse gas emissions and water consumption, as well as ways to minimize waste generation and promote reuse and recycling.

Partners shall endeavor to minimize air pollution. Partners shall characterize, monitor, control and treat as required prior to discharge air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals and combustion by-products generated from operations.

Control Hazardous Substances and Implement Proper Waste Management System

Partners shall ensure that chemical and other materials – that pose a hazard if released to the environment – are identified and managed to ensure their safe handling, movement, storage, use, recycling or reuse and disposal.

Partners shall treat wastewater and solid waste generated from operations and sanitation facilities according to legal requirements and good environmental practices.

Environmental Standards and Regulations

Partners are required to ensure that they comply with all applicable and site-specific environmental standards of the jurisdiction in which they operate when conducting work.

Obtain Necessary Permits and Observe Reporting Requirements

Partners must obtain, maintain, and keep current all applicable environmental permits, approvals, and registrations required under applicable law. Partners shall abide by and follow relevant operational and reporting requirements.


Management Systems

Partners shall establish and maintain a management system that ensures compliance with this Code and applicable laws, identifies and mitigates related operational risks, and facilitates continuous improvement and prompt corrective action. The management system must be designed to ensure ongoing compliance with applicable laws, regulations, requirements related to Partner operations and products; as well as conformance with this Code evidenced by documentation and records. Partners must ensure that this Code is appropriately communicated to all of its directors, officers, employees, agents, partners, Suppliers, affiliates.

Responsibility and Obligation

Partners shall identify who is responsible for ensuring implementation of their management systems and associated programs in their company. Partners shall ensure that they have adequate processes in place for identifying, monitoring, and understanding applicable laws, regulations, and Targray’s requirements, including the requirements of this Code.

Risk Management

Partners shall have adequate processes in place for identifying risks (such as the environmental, health and safety, labor and human rights, ethics and legal compliance) associated with their operations and have appropriate procedural and controls to manage such risks and ensure regulatory compliance.

Proper Documentation and Records

Partners shall ensure that they have adequate processes for the creation and maintenance of documents and records designed to ensure regulatory compliance and conformity to this Code and all applicable laws and regulations.

Suppliers of the Partner

Partners will, at a minimum, require its own Suppliers who provide goods and services to Targray, to act in a manner that is consistent with and at least as strict as the standards and requirements set forth in this Code and the policies referred to herein.


Additional Requirements

Export Sanctions / Anti-Money laundering/ Terrorism Activities

Partners should not perform their obligations in any way that would cause Targray or themselves to be in violation of all local and International Export Controls (including U.S.), economic sanctions and anti-boycott laws and regulations in all jurisdictions where they do business. Neither Partners nor any of their directors, officers, employees, agents, partners, Suppliers and affiliates, should be included on any lists of terrorists or terrorist organizations compiled by the U.S. government or any other national or international body. Partners must:

  1. comply with the Canadian, U.S. and all applicable international economic sanctions laws and regulations, as well as all applicable Canada, U.S. and international export controls applicable to Targray or Partner;
  2. not conduct business with individuals, entities, organizations, or countries that are the targets of the Canadian, U.S. or applicable international economic sanctions laws and regulations;
  3. never participate in any boycott or restrictive trade practice in violation of the Canada or U.S. antiboycott laws; and
  4. not directly or indirectly engage in or support any terrorist activity or Money Laundering activities.
Sourcing and Supply chain

Targray Partners should source materials in an environmentally responsible manner and in safe working conditions where work is chosen freely. Partners shall make reasonable efforts to ensure that the materials they source are produced or mined in accordance with local, national and international laws.

As applicable Partner shall have a Supply Chain Policy and system in place in line with the Organization for Economic Cooperation and Development (OECD) Due Diligence Guidelines for Responsible Supply Chains. Partners shall reasonably assure that the materials and minerals in the products they manufacture does not directly or indirectly finance or benefit armed groups or other criminal organizations that are preparators of human rights abuses. Partners shall exercise due diligence in the sourcing of these materials and minerals and make available the evidence of the due diligence measures they have taken on request.

Handling of Non-Compliance and Violations of this Code

While Targray will endeavour to work with Partners through remedial action wherever possible, Targray reserves the right to terminate a contract with any Partner who does not comply with the Code. Where we believe our standards are not being effectively applied, we also reserve the right to suspend that Partner’s contracts until satisfactory progress has been made or the issue has been resolved.

Any violation of this Code may result in corrective remedial action. The appropriate action in a particular case depends on the nature and severity of the Code violation and the circumstances surrounding the situation. Failure to comply with this Code and/or any additional requirements set forth by Targray, or any applicable laws and regulations may result in the termination of any agreement with a Partner and referral of the matter to local authorities. Targray reserves the right (in addition to all other legal and contractual rights) to disqualify any potential Partner or terminate any relationship with any current Partner found to be in violation of the Code without liability to Targray.

Reporting Concerns

We want to hear from any individual or organization who wishes to raise a query or concern or report a possible violation or breach to this Code. We expect Partners to ensure that there will be no retaliation against any employees and subcontractors who make a report in good faith.

Reports can be raised via email at:

Targray will conduct each case with impartiality, fairness and confidentiality. Each report will be considered seriously and will undergo an investigation. We expect full Partner cooperation with any such investigation. We will clarify the alleged violations against a Partner within a stipulated period of time and take appropriate remedial action for proven violations.


Acknowledgement of the Code is a prerequisite in every Targray contract for supply, sale, etc. Through the signature of the contract, acceptance of the purchase order and the carrying of business transactions with Targray, the Partner confirms that its operations fulfil the requirements contained in this Code and it shall be deemed incorporated and form a part of any contract or relevant order with Targray.

Schedule A | Reference to Targray Policies and External Policies

The following have been used as reference points and may be referred to by Partners if additional detail is required:

Targray Policies
• Anti- Corruption Policy:
• Privacy Policy:
Note: Targray’s rights under this Code are in addition to (and without prejudice to) any other rights reserved by Targray under those policies or any others or contained directly in the contract.

Labour standards
• United Nations Universal Declaration of Human Rights:
• ILO International Labor Standards:–en/index.htm

Human Rights
• United Nations Guiding Principles on Business and Human Rights:

Other standards
• OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict:

Schedule B | Glossary of Terms

Bonded Labour:
A person becomes a bonded labourer when their labour is demanded as a means of repayment for a loan. The person is then tricked or trapped into working for very little or no pay.

Anti-Slavery International, Debt Bondage:


Bribery means directly or indirectly making a payment or giving a reward, advantage, kickback or benefit or anything of value to a foreign government official or to a government official of one’s own country to obtain or retain business or any other improper advantage or for any improper or corrupt purpose, for the benefit of a Partner. This includes directly or indirectly making a payment to a person knowing, or being reasonably expected to know, that the person will forward it, or have it forwarded, to a foreign or domestic government official. Commercial bribery means paying a secret bribe or commission to or conferring a secret benefit on an employee, representative or agent of any third party, without that company’s knowledge, to induce the recipient to act or forbear to act in relation to that company’s affairs.

Child Labour:

Work that deprives children of their childhood, their potential and their dignity, and that is harmful to physical and mental development. It refers to work that is mentally, physically, socially or morally dangerous and harmful to children and/or interferes with their schooling by: depriving them of the opportunity to attend school; obliging them to leave school prematurely; or requiring them to attempt to combine school attendance with excessively long and heavy work.

International Labour Organization, “What is Child Labour”:–en/index.htm

Conflict of Interest:

A conflict of interest is a situation in which competing loyalties could cause an individual to take advantage of a personal benefit for him/herself, his/her friends or family at the expense of Targray or our business partners.

GRI Standards:


In employment means any distinction, exclusion or preference with respect to recruitment, hiring, firing, wages, working conditions or terms of employment made on the basis of personal characteristics unrelated to inherent job requirements, that impairs equality of opportunity or treatment in employment. This means ensuring terms of employment and its employment practices do not discriminate upon grounds of gender, race, color, religion, national or ethnic origin, sexual orientation, marital status and / or any other characteristic protected by applicable local law. Partners must comply with local laws in this regard.

Forced and Compulsory Labour:

All work or service which is exacted from any person under the threat of a penalty and for which the person has not offered himself or herself voluntarily. The definition of forced labour encompasses “traditional practices of forced labour, such as vestiges of slavery or slave-like practices, and various forms of debt bondage, as well as new forms of forced labour that have emerged in recent decades, such as Human Trafficking.”

International Labour Organization, “What is forced labour, modern slavery and human trafficking”:–en/index.htm


Harassment is a behavior or communications, whether written, physical or verbal, which a reasonable person would consider to cause offence or humiliation or affect the dignity of a person and, in the context of employment, results in an intimidating, hostile or offensive atmosphere. Partners must not engage in physical, mental, verbal, sexual or any other abuse, inhumane or degrading treatment, corporal punishment or any form of harassment. This includes verbal, physical and written conduct.

Human Trafficking:

The recruitment, transportation, transfer, harbouring or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person, for the purpose of exploitation.

United Nations Office on Drugs and Crime, “Human Trafficking”:

Money Laundering:

Money laundering is a crime involving disguising the source of money connected with criminal activity, such as terrorism, drug trafficking or Bribery. The crime occurs when criminally derived money is integrated into the stream of commerce so that it appears legitimate or its true source or owner cannot be identified.


Organisation or person that provides a product or service used in the supply chain of an organisation. A supplier is further characterized by a genuine direct or indirect commercial relationship with the organisation. Examples of suppliers can include, but are not limited to: brokers, consultants, contractors, distributors, franchisees or licensees, home workers, independent contractors, manufacturers, primary producers, subcontractors, and wholesalers.

GRI Standards: