Speak-Up Policy

1. Who can speak up

Anyone: Registry staff, contractors, applicants, code holders, counterparties, suppliers and members of the public.

2. What to report

• Fraud, impersonation or forged documents that use EBRICS codes or seals
• Bribery or corruption, including any attempt to influence a Registry decision
• Sanctions evasion, money laundering or terrorist financing
• Misuse of personal data or a security weakness (vulnerabilities should be reported under the Responsible Disclosure policy)
• Breaches of the Registry Charter, including conflicts of interest or unfair treatment
• Modern slavery or other serious human-rights abuses
• Any attempt to cover up the above

3. How to report

• Email: speakup@eurabeltfuels.com, which is read only by the designated Speak-Up officer and the chair of the board's audit function.
• Anonymously: from an email account that does not identify you. Anonymous reports are investigated, but the more detail you give, the more we can do.
• Escalation: if the concern involves the Speak-Up officer, write to the board at Flat 11 Clothier House, Kinveachy Gardens, London SE7 8EF, United Kingdom, marked "Private — Board".

Please include what happened, when, who was involved, how you know, and any evidence, such as codes, Seal IDs, verification references or documents.

4. What happens next

1. Acknowledgement within 5 business days.
2. Assessment and, where warranted, an independent investigation.
3. Where possible, we will tell you the outcome, within the limits of confidentiality and the law.

5. Protection

Retaliation against anyone who reports in good faith is prohibited and is treated as serious misconduct. Identities are kept confidential and shared only where the law requires or with the reporter's consent. In the UK, workers are protected by the Public Interest Disclosure Act 1998. Equivalent protections apply under the Protected Disclosures Act 26 of 2000 in South Africa, and under whistleblower provisions in Canada and in Trinidad and Tobago where applicable.

6. External reporting

Nothing in this policy prevents anyone from reporting directly to a regulator, a financial intelligence unit or law enforcement.