Feedstock Sustainability & Traceability Policy

This policy describes how SBS Bioenergy Trading, Lda, trading as “SBS – Sustainable Bioenergy Suppliers” (“SBS”), qualifies feedstocks and maintains traceability across the materials we originate and trade — including acid oils, esterified fatty acids, refined oils and used cooking oil (UCO) — for renewable fuel applications such as biodiesel and HVO.

Our qualification and traceability approach follows the commercial workflow we apply to every material: Origin → Supplier Qualification → Product Characterisation → Traceability → Compliance → Logistics → European Market. Each stage is described below.

• Understanding where the material is generated and by whom.
• Understanding the industrial or commercial process that produces the material.
• Identifying the supplier and the point of origin, so that commercial, quality and regulatory characteristics can be assessed from the outset.

• Supplier identity, ownership and operating activity.
• Production capability and capacity.
• Historical quality and reliability performance.
• Documentation practices and availability.
• Sustainability and regulatory information where relevant to the intended market.

• Product specification definition for each material.
• Sampling and laboratory analysis.
• Assessment of key technical parameters relevant to the intended application.
• Batch consistency review across deliveries.
• Quality documentation, including certificates of analysis where available.

• Origin records linking the material to its source.
• Movement records across the supply chain.
• Supplier documentation.
• Transaction records.
• Batch or cargo documentation for each shipment.
• Sustainability documentation where applicable to the transaction.

For each transaction, we assess the regulatory and sustainability requirements applicable to the material, its origin, its destination market and the buyer’s programme. This assessment is verified transaction by transaction.

“Feedstock sustainability status, certification eligibility and regulatory classification are assessed on a product-specific, origin-specific and transaction-specific basis. SBS does not assume or represent that any feedstock automatically qualifies under RED III, Annex IX, ISCC or any equivalent sustainability framework unless this has been appropriately verified and documented.”

• Chain of custody arrangements from origin to delivery point.
• Storage conditions appropriate to the material.
• Transport planning and coordination.
• Export and import documentation.
• Cargo identification so that each delivery remains traceable to its documentation.

• Matching product specifications with buyer requirements for biodiesel, HVO and other renewable fuel applications.
• Customer approval processes, including samples, documentation and trial deliveries where required.
• Contractual quality requirements agreed per transaction.
• Documentation supporting each transaction, assembled from the records maintained through the earlier stages.

We review our qualification and traceability practices as materials, origins and market requirements evolve, and we work with suppliers and buyers to strengthen documentation and verification over time.

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