KYC & Due Diligence Policy

This KYC & Due Diligence Policy sets out the standards and procedures applied by NaviTrade Energy Ltd ("NaviTrade", "we", "us") when onboarding and transacting with buyers, suppliers, intermediaries, mandates and all commercial counterparties. Compliance with this policy is mandatory for all engagements facilitated through NaviTrade Energy Ltd.

This Policy applies to all commercial counterparties engaging with NaviTrade Energy Ltd, including but not limited to:

• Buyers (Receivers) and Sellers (Suppliers) of petroleum products, crude oil, LPG/LNG, marine fuels and related commodities.
• Intermediaries, brokers, agents and mandate holders.
• Any third party introduced into a transaction facilitated by NaviTrade Energy Ltd.

The Policy ensures NaviTrade Energy Ltd meets its obligations under applicable UK, EU and international anti-money laundering (AML), counter-terrorist financing (ATF), sanctions and due diligence frameworks.

All counterparties are required to provide the following before any transaction is progressed:

• Government-issued passport copy of the authorised representative.
• Certificate of Incorporation or equivalent company registration document.
• Tax Certificate / VAT Registration document.
• UBO (Ultimate Beneficial Owner) Declaration or shareholder structure document / company extract.
• Proof of Registered Address — company utility bill, bank statement or equivalent.
• Board Resolution or Power of Attorney authorising the representative to act on behalf of the entity.

Enhanced Due Diligence is applied in the following circumstances:

• Counterparties from high-risk jurisdictions as identified by FATF, EU or UK authorities.
• Politically Exposed Persons (PEPs) or entities with PEP-related ownership or control.
• Transactions above defined volume or value thresholds.
• Any engagement where risk indicators are identified during initial screening.
• State-owned or government-affiliated entities.

EDD may include source of funds verification, enhanced ownership documentation, third-party references and additional background checks as determined by our compliance desk.

NaviTrade Energy Ltd conducts sanctions screening against the following frameworks as standard:

• UK sanctions lists — Office of Financial Sanctions Implementation (OFSI).
• EU sanctions regulations — European External Action Service (EEAS) consolidated list.
• US sanctions — OFAC (Office of Foreign Assets Control) SDN and blocked persons lists.
• UN sanctions — United Nations Security Council consolidated sanctions list.

Screening is conducted at onboarding and re-screening is applied on a risk-assessed basis or when material changes occur. Any match or potential match results in immediate suspension of engagement pending further review.

NaviTrade Energy Ltd applies the following AML/ATF controls across all engagements:

• Risk-based assessment of all counterparties prior to transaction commencement.
• Ongoing monitoring of transaction patterns and counterparty behaviour.
• Verification of source of funds for transactions above applicable thresholds.
• Suspicious Activity Reporting (SAR) obligations where legally required.
• Staff awareness and compliance training aligned with UK AML regulations.
• Record-keeping in line with statutory requirements (minimum 5 years).

NaviTrade Energy Ltd operates a strict maximum two-intermediary structure. All intermediaries and mandate holders are subject to the same KYC requirements as direct counterparties. In addition:

• All intermediaries must operate under verified corporate email addresses.
• NCNDA/IMFPA structures are required where intermediary interests are to be protected.
• Chain of authority must be clearly documented and verifiable.
• Undisclosed principals or anonymous introductions will not be accepted.

Upon successful KYC submission and preliminary review, NaviTrade Energy Ltd will issue a Non-Circumvention Non-Disclosure Agreement (NCNDA) and/or Commercial Mandate & Representation Agreement (CMRA) within 48–72 business hours to the registered email address of the authorised representative.

All KYC documentation submitted to NaviTrade Energy Ltd is handled in accordance with our Privacy Policy and applicable GDPR/UK-GDPR obligations:

• Documents are stored on secure, encrypted servers with restricted access controls.
• KYC records are retained for a minimum of 5 years from the end of the business relationship, in line with UK AML regulations.
• Data is not shared with third parties except where required for compliance, legal or regulatory purposes.
• Counterparties have the right to request access to their data subject to applicable legal frameworks.

NaviTrade Energy Ltd reserves the absolute right to:

• Decline any onboarding application without obligation to provide reasons.
• Terminate any engagement at any stage where compliance concerns are identified.
• Request additional documentation beyond the standard KYC package at any time.
• Re-screen any counterparty where material changes in risk profile are identified.

This Policy is reviewed periodically and updated in line with changes to applicable law, regulatory guidance and internal risk assessments. The current signed version of this Policy is available at all times via the link above. Continued engagement with NaviTrade Energy Ltd constitutes acceptance of the current Policy.

Compliance enquiries, KYC submissions and related correspondence should be directed to: