Trading and Transaction Controls

1 Purpose

The purpose of this Policy is to ensure that DE Trading enters only transactions it understands, can perform and has properly authorised. It aims to reduce exposure to unauthorised commitments, credit loss, fraud, documentary error, price-basis mismatch, operational failure and avoidable disputes.

2 Scope and control principles

This Policy applies to spot, term, tender, agency, brokerage, storage, transport and related physical energy activities of DE Trading. It covers the full transaction cycle from opportunity screening through settlement, claims and record closure.

Controls should be proportionate to value, complexity and risk. Where full segregation of duties is impractical, a documented independent review or Director approval should compensate. No one may create an unauthorised commitment in DE Trading's name.

3 Pre trade assessment

Before a binding bid, offer, purchase, sale or charter commitment, the responsible person should document the commercial rationale, contracting entities, product and specification, quantity tolerance, origin and destination, delivery basis, timing, pricing basis, taxes and duties, logistics, inspection, title and risk transfer, payment security, credit exposure and material conditions precedent.

• Counterparty, sanctions and intermediary checks must be complete or explicitly approved as a documented condition before commitment.
• Purchase and sale economics must use comparable units, currency, incoterms, quality and pricing periods and identify unpriced or unassessed costs.
• Availability, title, required permits, logistics capacity and authority to transact must be supported by credible evidence.
• Known legal, tax, customs, foreign-exchange, HSSE and product-quality risks must be assessed and escalated where material.

4 Approval and confirmation

Delegated authorities, credit limits and approval thresholds should be set separately by the Directors. Until those limits are formally adopted, binding commitments should receive written Director approval.

Each transaction should be recorded in a clear written recap or contract. It must reflect the agreed commercial terms, conditions, dispute provisions and authorised parties. Differences between recap, contract, nomination, invoice and operational instructions must be resolved before performance where practicable.

• Oral agreements and messaging-platform instructions must be confirmed in an approved written record.
• Material amendments, extensions and waivers require the same level of approval as the original commitment unless an approved authority schedule states otherwise.
• Contracts must identify the actual DE Trading entity; marketing shorthand must not replace the legal contracting name.

5 Payment and fraud controls

Payment terms, security and exposure must be approved before commitment. New bank instructions and changes to existing instructions must be verified through an independently sourced contact method, not solely through the message requesting the change.

Payments should be made only against approved contractual obligations, matching invoices and supporting evidence. Payments to third parties, personal accounts or unrelated jurisdictions require a clear lawful reason, enhanced verification and written Director approval.

• Where practical, one person prepares and another reviews payment details and supporting documents.
• Urgency, secrecy, late bank changes, mismatched account names and pressure to bypass controls are fraud red flags.
• Suspected fraud must be escalated immediately and the transaction or payment paused.

6 Execution exceptions and close out

Operational milestones, nominations, inspection, documents, title, delivery, invoicing, payment, claims and exposures should be tracked through closure. Material deviations must be recorded and escalated promptly.

An exception must state the requirement, reason, risk, compensating control, approver and expiry. Exceptions may not be used to bypass law, sanctions or prohibitions. After completion, quantities, pricing, invoices, payments, claims and outstanding obligations should be reconciled.

7 Roles records awareness and breaches

The Directors should approve this Policy, authority schedules and material exceptions. The deal originator remains responsible for complete and accurate information; reviewers and approvers must challenge assumptions within their remit. A designated responsible person may maintain deal records and control checklists without displacing individual accountability.

Deal files should contain due diligence, approvals, quotes, recaps, contracts, amendments, logistics and inspection records, invoices, payment evidence, correspondence, claims and close-out records. Role-based training should cover pricing-basis risk, authority, fraud and documentation. Unauthorised trading, concealment or falsification may lead to removal of authority, disciplinary or contractual action and legal escalation.

8 Review

This Policy should be reviewed at least annually and after any material loss, control failure, change in business model or entry into a new product, geography or transaction structure.

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.