Business Ethics & Code of Conduct

This Code of Conduct sets out the standards of behaviour expected of everyone acting for SBS Bioenergy Trading, Lda, trading as “SBS – Sustainable Bioenergy Suppliers” (“SBS”). As a small but internationally active feedstock origination and trading company, our reputation depends on conducting business with integrity in every market where we operate.

• Integrity: we act honestly, fairly and transparently in all our dealings.
• Compliance with laws: we comply with applicable laws and regulations in every jurisdiction where we operate, including trade, customs, environmental, tax and data protection law.
• Ethical business conduct: we avoid arrangements that create improper advantage, and we do not tolerate unethical practices by those acting on our behalf.
• Fair dealing: we represent our products, capabilities and counterparties accurately, and we honour our commercial commitments.

Team members must avoid situations where personal interests conflict, or appear to conflict, with the interests of SBS. Potential conflicts — including personal or family interests in counterparties, outside engagements or competing activities — must be disclosed to management.

We protect confidential information belonging to SBS, its counterparties and its partners. Personal data is processed in accordance with applicable data protection law and our Privacy Policy. Confidential and commercial information is used only for legitimate business purposes.

We compete fairly and comply with applicable competition law. We do not enter into agreements or exchanges of information with competitors concerning prices, customers, markets or other competitive matters, and we do not abuse positions of commercial strength.

We provide a workplace based on respect, professionalism and equal treatment. We do not tolerate discrimination, harassment, bullying or any form of degrading treatment, regardless of nationality, gender, age, religion, disability or any other characteristic.

We deal with suppliers fairly, pay in accordance with agreed terms, and treat supplier concerns seriously. We take environmental responsibility into account in our operations and sourcing decisions, consistent with our Sustainability & Responsible Sourcing Policy.

Our books, records and accounts must accurately reflect transactions and must not contain false or misleading entries. We do not tolerate fraud, misrepresentation of quality or volumes, falsification of documentation, or concealment of material information.

Anyone who becomes aware of suspected violations of this Code — or is pressured to act against it — should raise the concern with SBS management. Concerns raised in good faith will be reviewed fairly, and no one will suffer retaliation for reporting in good faith.

SBS management is responsible for promoting this Code, addressing violations appropriately, and ensuring that business practices remain consistent with the standards set out here. Serious violations may result in termination of employment or engagement and, where applicable, reporting to the competent authorities.

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