HSSE and Product Quality

1 Purpose

The purpose of this Policy is to protect people, communities, the environment, cargo integrity and business continuity. No commercial objective justifies knowingly exposing people or the environment to uncontrolled risk or accepting product that does not meet agreed requirements.

2 Scope and principles

This Policy applies to DE Trading personnel and to the selection and oversight of material service providers involved in storage, handling, loading, transport, inspection and delivery. Each party remains responsible for its own legal and operational duties.

Activities must comply with applicable law, permit conditions, terminal and vessel rules, transport requirements and agreed product specifications. Controls should be proportionate to the product, route, mode, facility and credible hazards.

• Plan work before execution and identify material hazards, interfaces and emergency arrangements.
• Use competent, appropriately authorised contractors and service providers.
• Stop or pause work where there is a reasonable belief of imminent danger, uncontrolled environmental risk or material product-quality failure.
• Report incidents, near misses, spills, security events and quality deviations promptly.

3 Contractor and logistics controls

Before appointment, material logistics and handling providers should be assessed for legal authority, relevant experience, equipment suitability, insurance, safety performance and ability to meet contractual requirements. The depth of assessment should reflect the risk and DE Trading's influence over the activity.

Operational instructions should clearly state product, quantity, specification, route, delivery window, nominated facilities, interfaces, required documents, incident contacts and escalation points. DE Trading personnel must not direct unsafe work or override a facility's lawful safety rules.

• Road transport should address driver competence, vehicle suitability, loading limits, route and emergency response.
• Marine movements should address vessel and terminal acceptance, cargo compatibility, security and transfer arrangements.
• Storage and transfers should address segregation, contamination prevention, tank suitability, sampling and reconciliation.

4 Product quality and quantity assurance

The contract or recap should define the applicable specification, test method, quantity basis, tolerance, inspection point, independent inspector where required, document set and process for off-specification or quantity disputes.

Certificates of quality, quantity and origin should be reviewed for consistency with contractual requirements. Representative sampling, sample custody and retention should be agreed where quality risk is material. Suspected contamination, adulteration or document irregularity must be escalated before release or onward delivery where practicable.

• Product substitutions or specification changes require written commercial and technical agreement.
• Blending or additive use must be lawful, technically suitable and expressly authorised where applicable.
• Quantity differences and losses must be investigated against the agreed measurement basis.

5 Incidents emergencies and environment

Relevant emergency contacts and roles should be identified before higher-risk operations. Any serious injury, spill, fire, security event, product release or major quality issue involving a DE Trading transaction must be reported immediately to a Director and the responsible operator.

The operational party should take immediate action within its competence to protect life, prevent escalation and notify authorities where required. DE Trading should preserve evidence, cooperate with lawful investigations, support corrective actions and avoid public statements by unauthorised persons. Environmental considerations should include spill prevention, waste handling, emissions and responsible use of resources where DE Trading can exert influence.

6 Roles and reporting

The Directors should approve this Policy and material risk exceptions. A Director or designated responsible person should coordinate risk-based contractor assessment, incident escalation and lessons learned. Deal owners must ensure that applicable HSSE and quality requirements are included in transaction planning and documentation.

Anyone may raise a safety, security, environmental or quality concern without fear of retaliation for a good-faith report. Concerns should be directed to the operational controller and a DE Trading Director or designated contact.

7 Records awareness and breaches

Risk reviews, provider assessments, instructions, permits or approvals supplied to DE Trading, inspection and quality documents, incident records, investigations and corrective actions should be retained with the deal file and under the records policy.

Awareness should be proportionate to each person's operational exposure. A material breach may require work to stop, replacement of a provider, quarantine or rejection of product, contractual remedies, corrective action and legal or regulatory advice.

8 Review

This Policy should be reviewed at least annually and after any serious incident, recurring quality issue, material regulatory change or expansion into a new operating model. This Policy does not state or imply certification to any external standard.

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.