Human Rights & Responsible Supply Chain Policy

SBS Bioenergy Trading, Lda, trading as “SBS – Sustainable Bioenergy Suppliers” (“SBS”), respects internationally recognised human rights and expects the same of its suppliers, partners and counterparties. This policy describes the standards we apply within our own operations and across our supply chain. It is designed to support supplier onboarding and European customer due diligence requirements.

We are committed to respecting human rights as expressed in internationally recognised frameworks, including the UN Guiding Principles on Business and Human Rights and the fundamental conventions of the International Labour Organization (ILO), as applicable to our activities.

• No forced labour: we do not tolerate any form of forced, bonded, indentured or involuntary labour, or retention of identity documents, wages or movement.
• No child labour: we do not tolerate the employment of children in any manner inconsistent with applicable law and international standards.
• No human trafficking: we do not tolerate recruitment or employment arrangements involving deception, coercion or exploitation.
• No discrimination: we do not tolerate discrimination in employment or business dealings on the basis of nationality, gender, age, religion, ethnicity, disability or any other protected characteristic.

We expect working conditions in our own operations and those of our suppliers to be respectful and lawful, with appropriate health and safety measures, reasonable working hours and fair remuneration, and a workplace free from harassment, intimidation or degrading treatment.

Suppliers are expected to operate in accordance with these standards, to comply with applicable labour and human rights law, and to communicate these expectations to their own suppliers and subcontractors where relevant.

As part of supplier qualification, we consider human rights and labour-related risk factors — including the nature of the industry, the generating process of the material, the jurisdictions involved and the supplier’s documentation practices. The depth of assessment is proportionate to the identified risk.

Where concerns arise regarding working conditions or human rights in a supply chain, we seek first to understand and address them with the supplier. Where concerns are serious or cannot be satisfactorily resolved, we may adjust, pause or discontinue the sourcing relationship.

Concerns raised by suppliers, employees, buyers or other stakeholders are escalated to SBS management for review. Where our conduct or our supply chain causes or contributes to adverse human rights impacts, we will cooperate in remediation where appropriate. We treat this policy as a standard for continuous improvement, not a one-off compliance exercise.

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