Fraud Policy

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

Fraudulent activity is unethical and can be illegal. Failure to address the risk of fraud may undermine our reputation and lead to investigations, fines and/or other penalties for the company and/or individuals. This Fraud Policy sets out PetroUSA’s approach to prohibiting and preventing fraud.

We do not engage in fraudulent behavior and we do not knowingly assist or facilitate any third party to commit fraud. Fraud is the act of engaging in deceptive or intentionally misleading activity in order to obtain an unfair or illegal financial or personal gain. The following activities, amongst others, may constitute fraud:

• destroying, manipulating, altering, or forging company records

• manipulating financial or accounting records

• knowingly creating ’fake’ contracts which do not reflect the true nature of the contractual relationship, such as contracts that we have no intention of performing, or contracts that do not accurately describe the intended transaction

• backdating contracts to misrepresent the signature date

• knowingly creating or paying false claims or invoices

• falsifying or duplicating expense claims, and

• deliberately misrepresenting, concealing or not disclosing material facts relevant to a decision or transaction. We require employees to be alert to any unusual or suspicious arrangements which could expose us to the risk of fraud and to report any such arrangements to Compliance.