Introduction

Purpose of the Customs and Global Trade Control Framework

The Customs and Global Trade Control Framework is designed to ensure that all cross-border movements of goods?particularly energy products stored and processed at our terminals?are conducted in full compliance with applicable customs laws, excise duties, international trade regulations, and sanctions regimes. Given the highly regulated nature of the energy sector and the strategic importance of customs and trade compliance, the framework serves as a governance structure that enables:

• Regulatory Compliance: Ensuring the organization meets all legal obligations related to customs, excise, VAT, and international trade, including accurate tariff classification, valuation, and origin management.

• Risk Management: Identifying, assessing, and mitigating customs and trade-related risks, such as incorrect declarations, duty shortfalls, or breaches of export controls and sanctions.

• Operational Efficiency: Facilitating smooth and timely customs processes to prevent delays at borders, minimize costs, and avoid supply chain disruptions.

• Strategic Trade Enablement: Supporting commercial objectives through the optimal use of customs regimes (e.g., customs warehousing, transit, duty reliefs), trade agreements, and efficient structure of supply chains.

• Governance and Accountability: Providing clear roles, responsibilities, and oversight mechanisms to ensure consistency, accountability, and continuous improvement across all business units involved in international trade.

This framework integrates customs and trade compliance into the broader internal control environment of the group and contributes to its license to operate?especially important in a sector where reputational and regulatory risks are high.