Sustainability & Responsible Sourcing Policy

This policy describes how SBS Bioenergy Trading, Lda, trading as “SBS – Sustainable Bioenergy Suppliers” (“SBS”), approaches sustainable and responsible sourcing of feedstocks — including acid oils, esterified fatty acids, refined oils and used cooking oil (UCO) — for renewable fuel applications such as biodiesel and HVO. It applies to our origination, supplier qualification, trading and logistics activities.

We seek to source materials whose origin and generating process we understand. Before engaging with a supplier, we work to identify where the material is generated, the industrial or commercial process that produces it, and the identity of the supplier and point of origin. We do not engage in sourcing arrangements whose origins cannot be reasonably established or documented.

Suppliers are assessed on a risk basis, considering their identity, ownership, operating activity, production capability, historical quality performance, documentation practices and relevant regulatory or sustainability information. The depth of assessment is proportionate to the material, its origin and the intended market. Qualification is reviewed as relationships develop or as risk factors change.

We work to maintain records linking materials to their origin, supplier and movement through the supply chain — including supplier documentation, transaction records and batch or cargo documentation. Traceability requirements are integrated from the start of a commercial engagement rather than addressed afterwards.

Our business model converts residues and by-products that would otherwise be discarded into inputs for renewable fuel production. We expect suppliers to manage their operations in compliance with applicable environmental law, and we take environmental considerations into account when selecting origins and designing supply chains.

Materials are characterised through specifications, sampling and analysis, with attention to key technical parameters and batch consistency. Quality documentation — including certificates of analysis where available — accompanies our commercial processes so that buyers receive materials matching agreed specifications.

Sustainability status, RED III eligibility, Annex IX classification, certification status (such as ISCC or equivalent schemes) and any other regulatory characterisation depend on the specific feedstock, its origin, the supply chain and the applicable documentation. SBS does not make automatic or blanket claims of sustainability eligibility. Eligibility and certification are assessed and confirmed on a product-specific, origin-specific and transaction-specific basis, and are subject to appropriate verification and documentation for each transaction.

We communicate about sustainability factually and proportionately. We do not present materials as certified or regulation-eligible without supporting documentation for the specific transaction, and we avoid vague, unsubstantiated or misleading environmental claims in our marketing, documentation and communications.

Where sustainability documentation is required for a transaction — for example proof of origin, process descriptions, certification records or mass balance documentation — we work with suppliers and counterparties to obtain, verify and transfer the documentation appropriate to that transaction and to the applicable regulatory framework.

We comply with applicable laws and regulations in every jurisdiction where we operate, including trade, customs, environmental and commercial law. Our commercial practices are based on fair dealing, accurate representation of products and transparency towards both suppliers and buyers.

We engage constructively with suppliers to improve documentation, quality and traceability practices over time. Where gaps are identified, we work with the supplier to address them; where they cannot be resolved satisfactorily, we may adjust or discontinue the relationship.

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