Governance

Responsible Sourcing & Compliance

Governance and responsible sourcing are embedded within Sphere's commercial operations.

Sphere operates within recognised regulatory and responsible sourcing frameworks across the jurisdictions where it participates in material aggregation and international trade.

Compliance ensures material flows are managed responsibly and in alignment with applicable regulatory requirements.

Regulatory Alignment

Where applicable, operations align with recognised international and national frameworks including:

Basel Convention controls on transboundary movement of materials
OECD guidance on responsible mineral supply chains
National licensing and export control regimes
Customs and international trade reporting requirements

Regional operating businesses function under applicable local permits and regulatory oversight.

Responsible Recovery

Sphere supports responsible recovery practices across its supply network.

Operational priorities include:

Reuse and refurbishment where viable
Controlled material recovery
Documented routing into recognised refining markets

These practices align with recognised recovery principles and support responsible participation in international supply chains.

Supply Chain Integrity

Sphere maintains defined operational controls across its aggregation and trade activities.

These include:

Intake and grading standards
Chain-of-custody documentation
Export compliance verification
Counterparty due diligence

These controls support transparency, compliance and long-term market participation.

Governance Oversight

Compliance oversight is maintained at the parent-enterprise level and extends to regional operating businesses through defined reporting structures.
This governance framework supports transaction integrity, audit readiness and responsible participation in global commodities markets.

Regional operations

Government & Institutional Engagement

Sphere engages constructively with regulatory authorities and industry development bodies in jurisdictions where it operates.

The Group's role is commercial in nature — coordinating responsible aggregation, recovery alignment and compliant international trade.

Engagement with government stakeholders is conducted with transparency and respect for established regulatory frameworks.

View Policies & Standards

Sphere COmmodities Group