Anti-Bribery & Anti-Corruption Policy

SBS Bioenergy Trading, Lda, trading as “SBS – Sustainable Bioenergy Suppliers” (“SBS”), has zero tolerance for bribery and corruption in any form, in any jurisdiction where we operate. This policy applies to all team members and to any third party acting on our behalf. We comply with applicable anti-bribery and anti-corruption laws, including the Portuguese Criminal Code and, where applicable, international frameworks such as the UK Bribery Act and the US Foreign Corrupt Practices Act.

• Bribes: we do not offer, promise, give, request, accept or solicit any financial or other advantage intended to obtain or retain business or an improper advantage.
• Facilitation payments: we do not make unofficial payments to secure or expedite routine actions by officials.
• Kickbacks: we do not participate in arrangements returning part of a payment or contract value to a counterparty representative.

Modest, occasional gifts and business hospitality are acceptable only where they are legal, proportionate, transparent and not intended to influence a business decision. Cash or cash-equivalent gifts are never acceptable. Team members must exercise judgement and decline or return anything that could reasonably be perceived as influencing a decision.

Personal, financial or family interests that conflict, or could appear to conflict, with SBS’s interests must be disclosed to management before entering into any related arrangement. Undisclosed conflicts of interest in procurement, sales or logistics decisions are treated as serious violations.

We engage agents, consultants, brokers and other intermediaries only where a legitimate business need exists. Before engagement, we carry out proportionate due diligence into the intermediary’s reputation, ownership and integrity. Intermediary compensation must be proportionate to the services legitimately provided, and agreements must prohibit corrupt conduct.

Interactions with government officials, state-owned entities and public servants — including in permitting, customs and certification matters — require heightened care. Gifts, hospitality or anything of value must not be offered to officials, and any such interaction should be reviewed with management where there is any doubt.

SBS does not make political contributions. Charitable donations and sponsorships are made only where legitimate, transparent, properly documented and never used as a means of obtaining improper advantage.

All payments, gifts, hospitality, commissions and expenses must be accurately recorded in our books and records. No undisclosed, unrecorded or misleading accounts may be created for any purpose.

Suspected bribery or corruption must be reported to SBS management. Reports made in good faith will be treated confidentially and reviewed promptly, and no one will suffer retaliation for reporting in good faith.

We promote awareness of this policy among our team and in our onboarding of partners. Violations may result in disciplinary action up to termination, termination of the relationship with the third party involved, and reporting to the competent authorities where required.

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