Partner Due Diligence and Sanctions Screening Policy

1Purpose and scope

1.1This policy sets out the checks that Eurabelt Fuels Ltd carries out before approving any organisation as a partner under its CSR framework, and throughout every partnership. It gives effect to the principles of structured partnerships, complete auditability and sanctions compliance set out in the CSR Framework Policy (EBF-CSR-POL-06).

1.2It applies to every applicant and partner organisation, and to the individuals who own, control or direct them.

2Eligibility requirements

2.1An applicant must show that it:

• is legally registered as a non-profit or NGO in its jurisdiction;
• has annual audited financial statements available;
• is in good standing with its regulatory authorities;
• is not on any international sanctions list, and is not owned or controlled by a sanctioned person;
• has a minimum of two years of documented operations;
• has a mission aligned with one or more of the three pillars of the framework.

3Verification

3.1Compliance verifies the information in each application against independent and official sources. Verification normally includes:

• confirmation of registration and status with the relevant company, charity or NGO register;
• review of governing documents and of the most recent audited financial statements;
• identification of trustees, directors and senior officers;
• confirmation of the organisation’s operating history and of the activities it describes;
• review of public information, including adverse media.

4Beneficial ownership and control

4.1Eurabelt identifies the individuals who ultimately own or control each applicant, including any person holding, directly or indirectly, more than 25 per cent of its shares or voting rights, any person with the right to appoint or remove a majority of its board, and any person who otherwise exercises significant influence or control over it. Where an applicant has no owners in that sense, its controlling trustees or directors are treated as its controllers.

4.2Where ownership or control cannot be established with reasonable certainty, the application is not approved.

5Sanctions screening

5.1Before approval, the organisation, its controllers, its trustees, directors and senior officers, and its bank where relevant, are screened against:

• the United Nations Security Council Consolidated List;
• the UK Sanctions List;
• the consolidated list of persons, groups and entities subject to EU financial sanctions;
• the lists maintained by the US Office of Foreign Assets Control (OFAC), including the Specially Designated Nationals and Blocked Persons List;
• the sanctions lists of Canada, and any other list applicable in a jurisdiction in which Eurabelt is registered or in which the partner operates.

5.2Screening also identifies politically exposed persons, so that any additional risk can be assessed. A potential match is reviewed by a person before any decision is taken, and the result and reasons are recorded.

5.3Eurabelt will not enter into any CSR arrangement with an organisation or individual appearing on an international sanctions list, or with an organisation owned or controlled by such a person.

6Decision and record

6.1Compliance records the checks carried out, their results and the decision taken. Approval is at the discretion of Eurabelt and may be refused without reasons, as set out in EBF-CSR-POL-04.

7Ongoing monitoring

7.1Approved partners are re-screened at least once a year, whenever the sanctions lists are materially updated, and whenever the partner reports a change of trustees, directors, controllers or bank. Partners must also provide their annual audited financial statements and operational reports, and must tell Eurabelt promptly of any material change, investigation or regulatory action.

8Suspension and termination

8.1Where a potential sanctions match, a material breach of these requirements, a safeguarding concern or credible evidence of misconduct arises, Eurabelt may suspend the partnership immediately, including any listing and any pending support, while the matter is reviewed.

8.2Where the concern is confirmed, the partnership is ended and the partner is removed from the register. Where the law requires it, Eurabelt reports the matter to the competent authority.

9Records and review

9.1Due diligence records are kept for the duration of the partnership and six years after it ends, as set out in the Privacy Notice (EBF-CSR-POL-02). This policy is owned by Compliance and reviewed at least once a year.