Terms of Use

1. About these Terms

These Terms of Use govern the relationship between Eurabelt Fuels Ltd ("Eurabelt", "we", "us") and you ("you", "the User"), in your use of the Eurabelt Fuels Trade Portal and any website operated under the Eurabelt Fuels brand (together, the "Sites"). By accessing the Sites, signing in to the Trade Portal, or submitting any information through the Sites, you accept these Terms in full. If you do not accept them, you must not use the Sites.

These Terms do not constitute a contract for the sale or purchase of any commodity. Any such contract is concluded separately, in writing, on terms and conditions that are expressly identified in that contract and that prevail over these Terms in all matters of commercial performance.

2. Who we are

Eurabelt Fuels Ltd is a private company limited by shares, registered in England and Wales under company number [COMPANY_NUMBER], with its registered office at [REGISTERED_OFFICE]. Where applicable we are registered for VAT under [VAT_NUMBER] and with the UK Information Commissioner's Office under [ICO_REGISTRATION]. Where assigned, our Legal Entity Identifier (ISO 17442) is [LEI_CODE].

3. Access and accounts

Access to the Trade Portal is by administrator invitation only. Self-registration is not permitted. To use the Trade Portal you must:

1. be at least eighteen (18) years of age and legally competent to enter into binding contracts under the law of your jurisdiction;
2. be a duly authorised representative of an organisation that has been admitted as a counterparty by Eurabelt;
3. have an active whitelisted email address issued by your organisation;
4. set and maintain a strong password compliant with the password policy notified to you on first sign-in; and
5. enrol and maintain the Eurabelt Fuels Authenticator as your second factor.

You are responsible for the confidentiality of your credentials. You must not share your password, recovery codes, or authenticator with any other person. You must notify your Eurabelt administrator immediately if you suspect that your account has been accessed without authorisation. We may suspend or revoke any account at any time where we reasonably consider it necessary to protect the integrity of the Sites.

4. Acceptable use

You must not, in connection with the Sites:

1. provide false, misleading, or impersonating information about yourself, your organisation, your principals, your beneficial owners, your bankers, your cargo, your vessel, or any other matter material to a transaction;
2. use the Sites to circulate, market, or solicit on behalf of any third party, or to operate as a broker, intermediary, or facilitator other than as expressly authorised by Eurabelt in writing;
3. upload, transmit, or display any content that is unlawful, defamatory, infringing, obscene, harassing, or that contains malware or any code intended to disrupt, disable, or compromise the Sites;
4. circumvent, attempt to circumvent, or test any security or access control measure; probe, scan, or perform vulnerability assessments without our prior written consent; or interfere with the operation of the Sites for other Users;
5. scrape, copy, or otherwise extract data from the Sites in bulk or for the purpose of building a competing service or any aggregated database;
6. use the Sites in any manner that breaches sanctions, export controls, anti-bribery laws, anti-money-laundering laws, or any other applicable law.

5. Pre-qualification and onboarding

Counterparties are required to complete the structured pre-qualification process, including the Terms Library acknowledgements and the Pre-qualification Gauntlet, before any commercial discussion is initiated by Eurabelt. The pre-qualification process is designed to verify each counterparty's understanding of the contractual standards under which Eurabelt operates and to identify counterparties whose responses match documented patterns of misrepresentation in the international physical-oil market.

Outcomes of the pre-qualification process are recorded permanently against the counterparty record, time-stamped, and signed by cryptographic hash. They form part of the audit trail that is annexed to any subsequent Deal Recap. False or misleading responses are grounds for immediate disqualification, contract termination, and the call of any Performance Bond posted by the counterparty in connection with a related transaction.

6. Information published

The Trade Portal reproduces certain documents issued by third parties, including 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. These materials are reproduced for the convenience of authorised counterparties and are believed to be accurate at the time of publication on the Sites. Where the version of any such document held by the issuing party differs from the version displayed on the Sites, the version held by the issuing party prevails.

Where the Sites apply mechanical computations to third-party data (for example, the classification of a crude grade as light-sweet, medium-sour, or condensate based on its API gravity and sulphur content), those computations are made by Eurabelt for filtering and navigation purposes only. They are not part of the source document and have no contractual weight.

7. No offer or advice

Nothing on the Sites constitutes:

1. an offer to buy or sell any commodity, financial instrument, or security;
2. an invitation to treat in any jurisdiction;
3. a solicitation of any nature whatsoever;
4. investment, legal, tax, accounting, or commercial advice; or
5. a recommendation to enter into any transaction.

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 of Eurabelt has authority to bind the company through these Sites.

8. Intellectual property

The Sites, the Eurabelt Fuels brand, the Eurabelt Fuels Authenticator name and device, and the structure, sequence, presentation, code, and original content of the Sites are the property of Eurabelt or its licensors and are protected under the Copyright, Designs and Patents Act 1988 and all other applicable laws. You are granted a limited, revocable, non-exclusive, non-transferable licence to access the Sites for the purpose contemplated by these Terms, and for no other purpose.

Documents reproduced from third parties remain the property of those third parties. You must not use Eurabelt's marks or any third-party marks displayed on the Sites without the prior written consent of the relevant proprietor.

9. Confidentiality

All information made available through the Trade Portal — including counterparty records, deal recaps, draft contractual instruments, document uploads, audit logs, and the structured contents of the Approved Crude List — is confidential. You must treat it with at least the same degree of care as you would your own most sensitive commercial information, and not less than reasonable care. You must not disclose it to any third party except as required by law, regulator, court of competent jurisdiction, or with our prior written consent. The confidentiality obligation survives termination of these Terms and any related contract.

10. Sanctions and trade controls

You confirm that, in connection with your use of the Sites and any contract contemplated through them, neither you nor your organisation, nor any of its directors, officers, ultimate beneficial owners, banks, vessels, or affiliates, is the subject of measures administered by the U.S. Department of the Treasury Office of Foreign Assets Control, the United Nations Security Council, the European Union, His Majesty's Treasury and the Foreign, Commonwealth and Development Office of the United Kingdom, the Swiss State Secretariat for Economic Affairs, the Monetary Authority of Singapore, the Hong Kong Monetary Authority, or any other sanctions authority of competent jurisdiction. You must notify Eurabelt immediately in writing if any such measure is, or is likely to become, applicable to you. Eurabelt screens counterparties continuously against consolidated sanctions lists and reserves the right to suspend or terminate access without notice on the basis of such screening.

11. Anti-bribery and anti-money-laundering

You confirm compliance with the Bribery Act 2010, the Proceeds of Crime Act 2002, the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, and equivalent legislation in your jurisdiction. You will not, directly or indirectly, offer, give, request, or accept any bribe, kickback, facilitation payment, or improper advantage in connection with any matter on the Sites. Eurabelt operates a zero-tolerance policy: any breach is grounds for immediate termination and reporting to the relevant authorities.

12. Disclaimers and warranties

The Sites are provided "as available" and on an "as is" basis. To the fullest extent permitted by law, Eurabelt disclaims all conditions, warranties, and other terms which might otherwise be implied by statute, common law, or the law of equity. Without limiting the generality of the foregoing, Eurabelt does not warrant that the Sites will be uninterrupted, error-free, or free from viruses or other harmful components, nor that any information made available through the Sites is current, complete, or accurate at the moment of access.

13. Liability

Nothing in these Terms excludes or limits liability for: (a) death or personal injury caused by negligence; (b) fraud or fraudulent misrepresentation; or (c) any other matter for which liability cannot be excluded or limited under English law. Subject to that:

1. Eurabelt is not liable for any loss of profit, loss of business, loss of revenue, loss of goodwill, loss of anticipated savings, business interruption, loss or corruption of data, or any indirect or consequential loss, however arising, whether in contract, tort (including negligence), breach of statutory duty, or otherwise.
2. Eurabelt's aggregate liability to you under or in connection with these Terms, whether in contract, tort, or otherwise, is capped at one thousand pounds sterling (£1,000).

This clause is independent of any liability cap or allocation in any commercial contract you may enter into with Eurabelt or with any third party introduced through the Sites; that contract governs commercial liability under it.

14. Suspension and termination

Eurabelt may suspend or terminate your access to the Sites at any time, with or without notice, where we reasonably consider that you have breached these Terms, applicable law, or any contractual obligation owed to Eurabelt or to a third party introduced through the Sites; that the integrity of the Sites or another User requires it; or that an instruction has been received from a regulator, sanctions authority, or law-enforcement body of competent jurisdiction. Termination does not affect rights and obligations that have accrued before termination, including audit records and confidentiality obligations.

15. Notices

Routine operational communications about your use of the Sites may be sent to the email address registered against your account. Formal notices to Eurabelt, including notices of breach, must be sent by registered post or international courier to the registered office address shown above, marked for the attention of "The Company Secretary, Eurabelt Fuels Ltd", with a copy by email to [SUPPORT_EMAIL]. Instant-messaging channels are not valid for formal notices.

16. Changes

Eurabelt may amend these Terms at any time by publishing the revised version on the Sites with an updated "Effective" date and version number. Material changes will be notified by email to whitelisted Users. Continued use of the Sites after the effective date of a revision constitutes acceptance of the revised Terms.

17. Governing law

These Terms and any non-contractual obligations arising out of or in connection with them are governed by the law of England and Wales. The courts of England and Wales have exclusive jurisdiction in respect of any dispute arising out of or in connection with these Terms, save that Eurabelt may bring proceedings in any other jurisdiction where you, your assets, or your principal place of business are located.

18. Contact

Questions about these Terms should be addressed to the Company Secretary at [REGISTERED_OFFICE], with an email copy to [SUPPORT_EMAIL].

These Terms are a working draft prepared for the establishment of the Eurabelt Fuels Trade Portal. They must be reviewed by qualified legal counsel before publication. The placeholders shown in dotted boxes must be filled in with the company's registered details.