The regulatory environment in which TREE operates has become structured & wide-ranging with a future-forward approach.

Physical fuel traders are subject to oversight from more than 70 regulatory authorities worldwide. Virtually every aspect of our business is affected to a greater or lesser degree by regulations covering health and safety, insurance, emission and environmental control, product, cargo and financial crime, international trade and sanctions, and banking, exchange and derivatives market rules.

To ensure compliance within such an extensive and constantly evolving regulatory environment, we maintain rigorous corporate protocols and a strict compliance program. This activity is overseen by our Compliance Department, which provides oversight, advice and training for FuelBank traders worldwide. In all operations, FuelBank adheres to the laws and regulations to which it is subject, both international and local, in the jurisdictions in which it operates.

FuelBank is proactive in addressing evolving compliance standards. This includes taking steps to strengthen contract language with counter-parties to enhance contractual prohibitions against trading with countries and entities under economic sanctions.

E&C Governance

TREE’s Compliance Department is bound by strong corporate governance, which provides a robust process for identifying risks and sound oversight to ensure effective risk mitigation. The Group Compliance Committee (GCC) serves as the main point of accountability for the Group’s Compliance activities. The GCC includes senior members of TREE’s Executive Committee, as well as representatives from Legal and Compliance. It reviews all aspects of the Compliance risk mitigation plan and acts as a point of escalation.

In addition to TREE’s Compliance Director, the company has a dedicated Director position for anti-bribery and corruption (ABC) and anti-money laundering (AML), as well as compliance officers located directly on trading floors next to trading personnel. They work in conjunction with Risk Officers providing oversight for every trading desk. TREE’s Compliance Directors further lead the company’s Compliance training program. TREE Compliance Committee oversees the effectiveness of the program.

Personnel

Internal Audits

To test our internal functions across the exchange, TREE has established an Internal Audit Department to provide independent and objective assessments of business activities, operations, financial systems, and the internal control environment of TREE. Our internal audit scope, covering activities such trading desks, assets, central functions and processes, joint-ventures and advisory mandates are designed to for the reduction of overall risk and the correction of inefficiencies through enhanced controls .

Our Trade Process

Buyer & FuelBank Trader

After submitting an Order and KYC analysis is conducted, the Buyer engages FuelBank by delivering specifics on needs - fuel type, quantity, CIF destination, and trading model.

Trade System

Once compliance is complete and the Trader is approved, FuelBank moves quickly to either secure the fuels needed (either on-site - in tanks) or delivered FOB and begin the scheduling process.

Trade Contracts & Tickets

Once the Trade Contract is delivered to the trade party, and the Trade Ticket is issued upon endorsement, then necessary logistics procedures are completed and ships ordered for delivery.

Logistics

Upon ordering vessels, screening is conducted to ensure they are non-sanctioned and all anti-bribery, anti-corruption checks on both counterparties (Trader & Shipper) are complete.

Settlement

The FuelBank Automated Trade System then allows payment settlement to be approved and completed and shipment commences to the Buyuer's destination port.

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