Counterparty Due Diligence, AML and Sanctions

1 Purpose

The purpose of this Policy is to prevent DE Trading from entering or facilitating transactions involving concealed ownership, illicit funds, sanctioned parties, prohibited trade, fraud or other unacceptable risk. Commercial urgency does not override due diligence or escalation requirements.

2 Scope and risk based approach

This Policy applies before onboarding and throughout relationships with customers, suppliers, brokers, agents, logistics providers and other material transaction parties. It also applies to relevant vessels, cargoes, banks, payment routes, origin, destination and end use.

Checks should be proportionate to risk. Factors include jurisdiction, ownership complexity, public-sector exposure, adverse information, product and route, sanctions sensitivity, unusual payment terms and the counterparty's role. Applicable law and binding sanctions restrictions always take precedence.

3 Minimum due diligence

Before commitment, DE Trading should obtain and assess enough reliable information to identify the counterparty, verify authority and understand the commercial purpose of the relationship. Information should be current, consistent and supported by independent or official sources where practicable.

• Legal name, registration number, registered and operating address, jurisdiction and business activity.
• Directors or managers, authorised signatories, ownership and ultimate beneficial owners.
• Bank-account details in the counterparty's name and verification of any change through an independently sourced contact route.
• Transaction purpose, expected volumes, product, origin, destination, end user and logistics chain.
• Sanctions, politically exposed person and material adverse-media screening for relevant parties and beneficial owners.
• Licences, permits, tax or customs information where material to the proposed transaction.

4 Enhanced due diligence and prohibited circumstances

Enhanced due diligence is required where risk is elevated or information is incomplete. It may include additional ownership evidence, source-of-funds or source-of-wealth information, legal advice, trade documentation, vessel and cargo checks, references, site verification or senior approval.

No transaction may proceed while a true sanctions match, prohibited jurisdiction or goods restriction, unexplained beneficial ownership, suspected document fraud, unexplained third-party payment, or other material red flag remains unresolved. A close or uncertain match must be paused and escalated rather than dismissed informally.

• Heightened attention is required for shell companies, opaque structures, state-linked parties, politically exposed persons and high-risk jurisdictions.
• Vessels and maritime trades should be checked for ownership, flag, recent name changes, routing anomalies, disabling of tracking and other evasion indicators where relevant.
• Any reliance on another party's due diligence must be documented and does not remove DE Trading's responsibility for its own risk decision.

5 Approval and ongoing monitoring

A Director or designated responsible person should confirm that required due diligence is complete before a relationship or transaction is approved. Higher-risk relationships and any exception require documented Director approval and, where appropriate, legal advice.

Information should be refreshed when circumstances change and at intervals proportionate to risk. New parties, banks, vessels, routes, end users and payment instructions require screening before use. Material adverse developments must trigger reassessment.

6 Escalation and reporting

Suspected money laundering, sanctions evasion, fraud or other criminal conduct must be escalated immediately to a Director or designated responsible person. No one may alert a counterparty to a possible regulatory report where that could amount to unlawful tipping off.

External reporting, asset-freezing, rejection or blocking steps must be determined under the law applicable to the relevant entity, bank and transaction, with specialist advice where necessary.

7 Records awareness and breaches

Due-diligence documents, screening results, risk assessments, approvals, transaction records and escalation outcomes should be retained securely for at least five years after the relationship or transaction ends, or longer where applicable law or contract requires. Access should be restricted to those with a legitimate need.

Role-based awareness should cover common energy-trading red flags, sanctions changes, payment fraud and escalation. Bypassing checks, concealing information or proceeding without required approval may result in removal from the transaction, contractual or disciplinary action and referral for legal advice.

8 Review

This Policy should be reviewed at least annually and sooner when sanctions regimes, applicable law, business geographies, products or transaction channels change materially.

Implementation note. This policy should be read with the other DE Trading corporate policies, transaction-specific approvals and the law applicable to the relevant contracting entity and transaction.