Anti-Money Laundering Declaration

I, Joaquín Valcarce Lledo, with DNI [Spanish ID] 07224392T, on behalf of, according to the title of representation that I will show at the request of the administration or of the interested party in my accreditation, of VIROQUE PETROLEUM, S.L., a company with NIF [Tax Identification Number] B67927061, as a newly constituted company in the energy and hydrocarbons sector, but already obliged to provide a guarantee of compliance with the legislation in force in relation to each of the aspects of the implementation of the business management in which its performance will consist and, in particular, in application of the legislation in force on hydrocarbons, the core regulator of its product and service.

STATE THAT

ONE: Since its incorporation until the present time, it has been complying with all its contractual and legal obligations, including commercial and fiscal, labour and in all legal areas, without having incurred in sanctioning or warning proceedings and that, furthermore, it has observed diligence in order to prevent non-compliance by commissioning the design and implementation of a Compliance System, as the consultancy firm contracted for this purpose certifies in the document that I attach under Doc. No. 1.

TWO: That the said VIROQUE PETROLEUM, S.L. Compliance System refers to all the activity of this company, including a Crime Prevention Plan that is implemented as Criminal Compliance and, within which, the corresponding assessment of the risk of committing money laundering and financing of terrorism as one of the criminal offences for the prevention of which the following controls must be established:

1. Training of staff and management on their responsibilities for approving income and expenditure.

2. Monitoring and intervention in financial performance, i.e., sources of funding and accounting and tax returns.

3. Reporting of operations (balance sheets) and verification of operations.

THREE:  That regardless of said evaluation and criminal controls as well as the linking of my client as a subject obliged to the requirements of the current legislation on Prevention of Money Laundering and Financing of Terrorism (hereinafter PML and TF), VIROQUE PETROLEUM, S.L. is incorporating in its routines all the protocols that, in application of such legislation, correspond to the provision of the collaboration that, in administrative order, involves the avoidance of necessary collaboration or complicity with possible perpetrators of such crime and, all of them gathered or referenced by the PML and TF Manual refer to:

a. Due diligence relating to the investigation or verification of the identity and credentials of parties involved in wholesale petroleum product supply transactions as agents.

b. Verification of actual transactions, with follow-up of collections.

c. Collaboration with SEPBLAC.

FOURTH: That in support of the effective application of all the aforementioned procedures, my client is setting up a Whistleblower Channel whose operation, whether internal or outsourced, will consist of:

i. Dissemination and Reception with a guarantee of confidentiality without reprisals for the whistleblower.

ii. Investigation and Report on incidences and conclusions.

iii. Application of or waiver of disciplinary measures, with communication of the appropriate action to the whistleblower.

FIVE: That in addition to the Whistleblower Channel, VIROQUE PETROLEUM, S.L.’s Compliance Department incorporates the following as a support tool:

  • Risk matrix by process in support of the distribution of hydrocarbons for energy production.
  • General and working procedures with Codes of Conduct that include Compliance Indicators.
  • Compliance Reporting and Auditing.

SIX: That in support of the use of the aforementioned tools and the effective and efficient application of the entire VIROQUE PETROLEUM, S.L. Compliance system, my client makes its Compliance Policy available to its employees and interested parties, summarising a commitment whose lines of force are intended to be based on ESG criteria, emphasising in this respect:

– Environmental sustainability within the supply chain.

– Social sustainability in terms of personnel and supply agent with a view to contributing to the fight against energy poverty.

– Good corporate governance in relation to transparency of management decisions vis-à-vis stakeholders, and the prevention of corporate crime in general, and of money laundering and terrorist financing, as well as corruption in particular.

In witness whereof and for the appropriate purposes, I sign this in

Madrid, on 24 October 2022