1. Purpose and Scope

Bio Green Wax Ltd (the "Company") trades industrial waxes, oleochemicals, edible oils and fats, and renewable fuel feedstocks across international borders. Goods of this kind move through many jurisdictions, are frequently transhipped, and in some cases have origins or end uses that attract restrictive measures. A single unchecked shipment can expose the Company to criminal liability, asset freezes and the loss of banking and insurance relationships.

This policy sets out how the Company identifies and complies with financial sanctions, trade sanctions and export control obligations. It applies to every transaction, every counterparty and every person listed under "Applies to" in the document control table above, regardless of location or the brand under which the trade is conducted.

Where the law of a jurisdiction in which the Company operates imposes a stricter standard than this policy, that stricter standard applies. Where two applicable regimes conflict, the matter must be escalated to the Compliance Officer before the transaction proceeds.

2. Policy Statement

The Company will not deal, directly or indirectly, with any person, entity, vessel, port or territory that is the target of applicable restrictive measures, and will not supply goods where it knows or suspects that they are destined for a prohibited end use or end user.

The Company will not participate in any arrangement designed to conceal the origin, ownership, destination or end use of goods or funds in order to evade sanctions or export controls. This includes falsifying documentation, disguising the origin of a cargo, using an intermediary to break the audit trail, or structuring a transaction to fall outside a reporting threshold.

3. Roles and Responsibilities

Every person within scope is individually responsible for compliance. Delegating a check does not transfer responsibility for the outcome.

4. Restricted Parties and Territories

The Company maintains a restricted list built from the following sources, refreshed before each screening run:

• The UK Sanctions List and the OFSI Consolidated List of Financial Sanctions Targets.
• The EU Consolidated List of Persons, Groups and Entities Subject to EU Financial Sanctions.
• The US OFAC Specially Designated Nationals and Blocked Persons List, the Sectoral Sanctions Identifications List, and the BIS Entity, Denied Persons and Unverified Lists.
• The United Nations Security Council Consolidated List.
• Any additional list applicable to the jurisdiction of the counterparty, the goods, the currency of settlement or the shipping route.

Comprehensively restricted territories

The Company does not trade with, or route goods through, territories subject to comprehensive embargoes under applicable regimes. The current list is maintained by the Compliance Officer and reviewed at least quarterly, because designations change frequently. Any enquiry originating from, or naming a destination in, such a territory is declined and recorded.

Ownership and control

A counterparty that is not itself designated may still be caught where a designated person owns more than 50 per cent of it, or otherwise controls it directly or indirectly. Screening therefore extends to shareholders, ultimate beneficial owners, directors and, where relevant, the counterparty's own principals. Where ownership cannot be established to the Company's satisfaction, the transaction does not proceed.

5. Counterparty Screening Procedure

No offer is confirmed, no contract is signed and no cargo is booked before screening is complete and recorded.

1. Collect the counterparty's full legal name, registered address, country of incorporation, company registration number, and the names of its directors and ultimate beneficial owners.
2. Screen the counterparty, its owners and its directors against every list in section 4, including reasonable spelling variants and transliterations.
3. Screen the notify party, the consignee, the end user (where different), the freight forwarder, the shipping line, the vessel and its registered owner and operator, and the discharge and transhipment ports.
4. Screen the receiving and intermediary banks and confirm that the settlement currency and payment route do not involve a restricted institution.
5. Record the date, the lists used, the search terms, the result and the name of the person who ran the check.
6. Re-screen before each subsequent shipment for an existing counterparty, and immediately on notification of a change of ownership, banking details, vessel or destination.

6. Goods, End Use and Export Licensing

The great majority of the Company's product range consists of non-controlled commodities. That does not remove the obligation to check. Controls attach to the destination, the end use and the end user as well as to the goods themselves.

• Before shipment, the responsible trader confirms the commodity classification of the goods and whether any dual-use or military end-use control applies to the specific destination.
• Where an end-use statement is required, it is obtained in writing from the end user before the goods are released, and retained with the transaction file.
• Where a licence is required, no goods are shipped until the licence is granted and its conditions are recorded and understood by the operations team.
• Licence conditions, including quantity limits, validity periods and reporting requirements, are tracked by the Compliance Officer and reported on as the licence requires.

Where a customer declines to state the end use, states an end use inconsistent with the product's technical characteristics, or asks for the end use to be omitted from documentation, the transaction is escalated under section 8 and does not proceed without the Compliance Officer's written approval.

7. Origin, Vessels and Shipping Controls

Several product groups the Company trades — including petroleum-derived waxes, slack wax and renewable fuel feedstocks — carry an elevated risk of origin misdeclaration. The following controls apply to every cargo:

• The country of origin is evidenced by a certificate of origin or equivalent documentation from the producer, not by the seller's assertion alone.
• Where goods are blended, processed or transhipped, the Company obtains sufficient information to establish that the underlying material is not of restricted origin.
• Vessel checks include the IMO number, flag, registered owner, operator and, where available, recent port-call history. Evidence of AIS gaps, ship-to-ship transfers in unusual locations or repeated flag changes is treated as a red flag.
• Price is a control, not just a commercial term: a price materially below the prevailing market for the stated origin is treated as an indicator of misdeclared origin and must be escalated.
• Contracts include a sanctions representation and warranty, a right to suspend or terminate performance where a restriction applies, and an obligation on the counterparty to notify any change in ownership or control.

8. Red Flags and Escalation

The following are treated as red flags requiring escalation to the Compliance Officer before the transaction continues:

• A counterparty, owner, vessel or bank that produces a possible list match.
• A newly incorporated counterparty with no trading history seeking a disproportionately large first shipment.
• A request to route goods, documents or payments through a jurisdiction with no commercial connection to the trade.
• A request to change the discharge port, consignee or vessel after contract, particularly at short notice or while the cargo is afloat.
• Reluctance to identify the end user, or an end user that appears to have no use for the product.
• A request to alter, split, backdate or omit documentation, or to describe the goods inaccurately.
• Payment offered from, or to, a third party unconnected to the contract, or in a currency or through a route inconsistent with the counterparty's location.
• Any indication that the counterparty is acting as a front for a restricted person.

Escalation is made in writing to the Compliance Officer, using the contact details at the end of this policy. Work on the transaction stops until a written decision is given. The decision, and the reasons for it, are recorded on the transaction file.

9. Reporting and Freezing Obligations

Where the Company knows or has reasonable cause to suspect that it holds funds or economic resources belonging to a designated person, or that it has dealt with a designated person, the Compliance Officer will ensure that the relevant assets are frozen and that a report is made to the competent authority — in the United Kingdom, the Office of Financial Sanctions Implementation — within the period the law requires.

No person may notify a counterparty that a report has been made or is contemplated where doing so would prejudice an investigation. Questions about what may be disclosed must be directed to the Compliance Officer.

10. Training and Awareness

All commercial, logistics and finance staff receive sanctions and export controls training on joining and at least annually thereafter. Training covers the screening procedure, the red flags in section 8, the escalation route, and the personal criminal liability that can follow from a breach. Attendance records are retained by the Compliance Officer.

Agents, brokers and introducers acting for the Company are provided with this policy and must confirm in writing that they will comply with it.

11. Records and Retention

Screening results, end-use documentation, licences, origin evidence, vessel checks, escalations and decisions are retained for at least six years from the end of the calendar year in which the transaction completed, or longer where a licence, contract or investigation requires it. Records are held so that a complete transaction history can be reconstructed and produced to a regulator on request.

12. Breach, Consequences and Review

A breach of this policy is a disciplinary matter and may amount to gross misconduct. Contracts with agents, brokers and suppliers permit termination for breach of this policy. A breach may also constitute a criminal offence for which the individual concerned, as well as the Company, can be prosecuted.

Anyone who becomes aware of an actual or suspected breach must report it immediately to the Compliance Officer. Reports may be made in confidence and the Company will not tolerate retaliation against a person who reports in good faith.

This policy is reviewed at least annually, and sooner where a change in law, in the Company's product range or in its trading footprint requires it. The version and review dates are recorded in the document control table.