EURABELT FUELS · LEGAL
Effective 30 April 2026 Version 1.0 Document Trade Disclaimer

Trade Disclaimer

Limitations on the commercial weight of information published on the Eurabelt Fuels Trade Portal and websites, and the basis on which Eurabelt Fuels Ltd engages with counterparties in the international physical-oil market.

1. Nature of the Sites

The Eurabelt Fuels Trade Portal and the websites operated under the Eurabelt Fuels brand are a controlled-access workspace for counterparties admitted by Eurabelt Fuels Ltd. They are not a marketplace, an exchange, a bulletin board, an inter-broker network, a price-discovery service, or a public information service. They are not open to the general public.

2. Reproduced documents

Where the Sites display documents issued by third parties — including, without limitation, the PT KILANG PERTAMINA INTERNASIONAL Crude Oil Purchase General Terms and Conditions 2024, the PT KILANG PERTAMINA Crude List, and certain Confirmation and Purchase Order documents — the documents are reproduced for the convenience of authorised counterparties and are believed to be accurate at the moment of publication. Eurabelt does not represent that any reproduction is the current version, that the issuing party will not amend it without notice, or that the issuing party will accept any term derived from it. Where there is any difference between the version held by the issuing party and the version on the Sites, the version held by the issuing party prevails. Counterparties are responsible for confirming the current version with the issuing party before any binding act.

3. No offer or solicitation

Nothing on the Sites is, or is to be construed as:

  1. an offer to buy or sell any commodity, financial instrument, or security;
  2. an invitation to treat or solicitation in any jurisdiction;
  3. an undertaking to enter into any transaction;
  4. a representation that any cargo of any grade is currently available, allocated, lifted, in transit, or otherwise in existence; or
  5. a representation that Eurabelt has any particular procurement requirement.

Any commercial commitment by Eurabelt is conclusively given only by an authorised signatory in a written contract that expressly identifies its governing law and arbitration mechanism. No employee, agent, or representative has authority to bind Eurabelt through these Sites, by chat, by email signature, by social media, or by any other informal channel.

4. No advice

Information published on the Sites is general in nature and does not take account of the particular circumstances of any user. It does not constitute investment advice, legal advice, tax advice, accounting advice, regulatory advice, or commercial advice. Counterparties must obtain advice from suitably qualified professionals before taking any action.

5. Counterparty engagement

Eurabelt engages only with counterparties admitted through its onboarding process. Onboarding requires, without limitation: administrator-issued whitelisting; a full Know-Your-Counterparty pack including ultimate-beneficial-ownership disclosure to twenty-five per cent (25%) ownership; clearance against consolidated sanctions lists administered by OFAC, the United Nations, the European Union, the United Kingdom (OFSI), Switzerland (SECO), Singapore (MAS), and Hong Kong (HKMA); banking and instrument-capability confirmation; and successful completion of the Pre-qualification Gauntlet recorded in the Trade Portal.

6. Patterns we will not engage with

Eurabelt does not engage with, and the Sites are not directed to, any party that operates by reference to the following patterns. The list is not exhaustive and is given without prejudice to the analytical work that Eurabelt's compliance, operations, and trade-finance teams undertake on each counterparty:

  1. requests for "soft probes", "ICPOs", "RWA messages", "POF" or "POP" documents as a pre-condition to issuing an offer;
  2. requests for an MT103 cash transfer, "BG plus 2 per cent cash deposit", or similar pre-loading payment in lieu of an irrevocable confirmed Documentary Letter of Credit issued under UCP 600;
  3. title chains evidenced only by a "Soft Corporate Offer", a "Tank Storage Receipt" not endorsed by the named loading-terminal operator, a "Letter of Intent", or a "confidential mandate";
  4. "24-hour delivery" claims, claims that a cargo is "already on the water and waiting for any buyer", or claims of access to refinery feedstock crude on the open market;
  5. "Procedure-2" or any sequence in which the buyer is expected to issue a payment instrument before the seller has demonstrated title to a specific cargo, vessel, and laycan;
  6. discounts to a published Platts assessment of fifteen per cent (15%) or more, or any pricing mechanic that bears no relationship to the relevant published benchmark for the relevant grade;
  7. insistence on instant-messaging channels for formal contractual notices;
  8. refusal to disclose ultimate beneficial owners or to consent to continuous sanctions screening; and
  9. any other conduct identified by Eurabelt in its sole judgement as inconsistent with the published General Terms and Conditions and the international standards Eurabelt operates to.

Communications matching these patterns are recorded for the protection of Eurabelt and the wider market. Persistent attempts to engage Eurabelt on these patterns may be reported to relevant authorities.

7. No agency, no facilitation

Eurabelt acts as principal. It is not an agent, broker, mandate, facilitator, intermediary, finder, or introducer for any third party, save where it has expressly agreed to act in such capacity in a written agreement signed by an authorised signatory. Holding an account on the Trade Portal does not confer any agency, partnership, or joint-venture relationship with Eurabelt. No commission, finder's fee, success fee, or other consideration is payable by Eurabelt to any party in respect of an introduction made through, or by reference to, the Sites unless Eurabelt has expressly agreed to such payment in writing in advance.

8. Pricing and benchmarks

Where Eurabelt or any third-party document on the Sites refers to a published benchmark — such as Dated Brent (PCAAS03), WTI Cushing (AAJOZ00), or another assessment by S&P Global Platts, ICE, NYMEX, OPIS, or Argus — the reference is a description of pricing mechanics only. The benchmark publishers are the proprietors of those data. Eurabelt makes no representation as to the accuracy or fitness for purpose of any third-party benchmark, and assumes no responsibility for changes in publication methodology or for the discontinuance of any benchmark.

9. Third-party links

The Sites may from time to time include hyperlinks to websites operated by third parties. Such links are provided for convenience only. Eurabelt does not endorse the linked content, has no control over it, and accepts no liability for it.

10. Forward-looking statements

Statements on the Sites that are not statements of historical fact may be forward-looking statements. Forward-looking statements involve known and unknown risks, uncertainties, and other factors that may cause actual results to differ materially from those expressed or implied. Eurabelt undertakes no obligation to update any forward-looking statement.

11. Press & media

Press and media enquiries should be addressed to [SUPPORT_EMAIL], marked for the attention of the Press Office. Eurabelt does not, by reason of any media engagement, waive the confidentiality, sanctions, or anti-bribery undertakings owed to its counterparties under their respective contracts.

12. Reliance

No party may rely on any statement on the Sites for the purpose of taking any commercial, legal, financial, or operational decision. Reliance is at the reliant party's sole risk. To the fullest extent permitted by law, Eurabelt excludes all liability for any loss arising from such reliance, save for fraud, fraudulent misrepresentation, or matters in respect of which liability may not lawfully be excluded.

This Disclaimer is a working draft prepared for the establishment of the Eurabelt Fuels Trade Portal. It must be reviewed by qualified legal counsel before publication. The placeholders shown in dotted boxes must be filled in.