AML, Sanctions & Counterparty Due Diligence Policy

SBS Bioenergy Trading, Lda, trading as “SBS – Sustainable Bioenergy Suppliers” (“SBS”), is a feedstock origination and trading company — not a regulated financial institution. We are nonetheless committed to preventing our business from being used for money laundering, terrorist financing, sanctions evasion or trade-based money laundering, and to complying with applicable anti-money laundering (AML), sanctions and trade control laws in every jurisdiction where we operate.

Before entering into a transaction, we seek to understand who we are dealing with:

• Identification of counterparties: legal name, registration details, address, operating activity and the individuals authorised to act for the counterparty.
• Beneficial ownership: identification of the natural persons who ultimately own or control the counterparty, where appropriate to the transaction.
• Corporate documentation: registration extracts, powers of attorney and other evidence of legitimacy and authority.

The depth of due diligence is proportionate to the counterparty, the material, the transaction value and the jurisdictions involved.

Counterparties, their beneficial owners and, where relevant, vessels, ports and other transaction parties are screened against applicable sanctions lists before a transaction proceeds. We do not enter into transactions with sanctioned persons or entities, or in breach of applicable trade restrictions, export controls or embargoes.

Transactions involving higher-risk jurisdictions or politically exposed persons (PEPs), where applicable, are subject to enhanced review and senior approval before proceeding.

We remain alert to indicators of financial crime, including:

• Suspicious transactions or commercial terms that lack a clear economic rationale.
• Unusual payment structures, including pressure to route payments through third parties or jurisdictions unrelated to the transaction.
• Third-party payments where the payer is not a party to the contract, absent a legitimate and documented reason.
• Trade-based money laundering indicators, such as over- or under-invoicing, mismatched cargo documentation, or circular trades lacking commercial substance.
• Reluctance to provide origin documentation or beneficial ownership information.

Before entering into a transaction, SBS may request identification documents, corporate documents, beneficial ownership information, banking information, origin documentation and other due diligence information. Failure or refusal to provide such information on reasonable request may prevent a transaction from proceeding.

SBS may decline, suspend or terminate any transaction or counterparty relationship where due diligence cannot be completed satisfactorily, where red flags cannot be resolved, or where legal or compliance concerns arise. We are not obliged to explain internal compliance decisions beyond what applicable law requires.

Due diligence records, transaction documentation and compliance decisions are retained in line with applicable legal requirements. Suspected money laundering, sanctions issues or other financial crime concerns are escalated internally for review and, where legally required, reported to the competent authorities.

Questions about this policy may be sent to manuel.cosme@sbsbioenergy.pt or nelson.biel@sbsbioenergy.pt.