Conflict of Interest

This policy applies to all employees, directors and officers, as well as contractors under PetroUSA’s direct supervision, working for a TradEx or FuelBank office or industrial asset directly or indirectly controlled or operated by PetroUSA worldwide. We assert our influence over joint ventures we don’t control or operate to encourage them to act in a manner consistent with the intent of this policy.

Our Commitment

Undeclared or mismanaged conflicts of interest can lead to: reputational damage; loss of trust and confidence in our internal controls; a perceived or actual risk of corruption or bribery; loss of our stakeholders’ confidence in the integrity of our decisionmaking; and substandard services and products at inflated prices. It can also lead to investigations, fines and/or other penalties for the company and/or individuals. We always act in PetroUSA’s best interests, try to avoid actual, potential or perceived conflicts of interest and implement procedures to ensure we manage conflicts of interest appropriately. This Conflict of Interest Policy sets out PetroUSA’s approach to:

• recognizing and avoiding conflicts of interest; and

• declaring conflicts of interest.