Corporate Policies & Compliance

At Emerald Supply, our operations are governed by the highest standards of integrity, transparency, and international maritime law. As a Direct Mandate working with Refinery-linked ATC holders, we maintain a zero-tolerance policy toward non-compliant trading practices.

1. Know Your Customer (KYC) & Due Diligence

To protect the integrity of our supply chain and our refinery partners, we perform rigorous due diligence on all prospective buyers and intermediaries.

Mandatory Documentation: No soft offers or SCOs are issued without a fresh ICPO and a complete CIS.
Verification: We verify the financial capability and past performance of buyers to ensure a 100% success rate for lifting.
Corporate Identity: We require clear passport identification of the signatory to prevent "daisy-chain" brokerage and unauthorised document circulation.

2. Anti-Money Laundering (AML) & Sanctions

Emerald Supply strictly adheres to FATF (Financial Action Task Force) guidelines and international AML regulations.

Sanction Checks: We do not engage with entities or vessels listed on OFAC, EU, or UN sanction lists.
Transaction Transparency: All financial transactions must flow through recognised Tier-1 or Tier-2 international banks. We do not accept third-party payments or non-transparent financial instruments.

3. Product Quality & Inspection (SGS/Saybolt)

We guarantee that all EN590 10PPM, LPG, and Sulphur meet the specific technical benchmarks promised.

Independent Verification: Quantity and quality (Q&A) are verified by independent inspectors such as SGS, Saybolt, or Intertek at the port of loading.
Fresh Analysis: We ensure that the Analysis Report (Quality Certificate) provided to the buyer is recent and specific to the current batch being lifted.

4. Non-Circumvention & Non-Disclosure (NCNDA)

We value our relationships with intermediaries and facilitators.

Protection: We operate under ICC 600/800 rules regarding non-circumvention.
Confidentiality: All proprietary procedures, refinery-direct information, and ATC details remain strictly confidential until the final contract (SPA) stage.

5. Ethics & Professional Conduct

Emerald Supply prohibits any form of bribery, corruption, or unethical facilitation payments. We follow the UK Bribery Act and U.S. Foreign Corrupt Practices Act (FCPA) standards in all international dealings.

Notice to Intermediaries: We only recognise "Direct" or "Level 1" intermediaries. We do not participate in long chains of brokers. Our goal is to connect the Buyer’s Mandate to the Seller’s Mandate directly.

Our Transaction Standard (Incoterms 2020)

All our policies are aligned with Incoterms 2020 for international trade, primarily focusing on:

FOB (Free On Board)
CIF (Cost, Insurance, and Freight)
TTT / TTV (Tank-to-Tank / Tank-to-Vessel)

Intermediary & Broker Code of Conduct

Emerald Supply values the role of professional intermediaries in the global energy markets. However, to protect our direct relationships with ATC Holders and Refineries, we enforce a strict protocol for all facilitators.

By engaging with us, you agree to the following standards of professional conduct:

1. Direct Connectivity Requirement

We only engage with Level 1 Intermediaries. You must be in direct contact with either the End Buyer or the Buyer’s Mandate.

No Broker Chains: We do not participate in "circular" or "daisy-chain" groups.
Transparency: You must be prepared to identify your position in the transaction immediately upon initial contact.

2. Document Integrity & "Ghost" Offers

The circulation of "fake" or "photoshopped" documents is a serious offence in international trade.

Fresh Paperwork only: All ICPOs must be fresh (dated within 3-5 days), on company letterhead, and signed/stamped by the CEO or authorised signatory.
No Speculative Requests: Do not request "Soft Offers" or "SOPs" without a specific, ready-to-act Buyer. We do not provide "price lists" for fishing expeditions.

3. Verification of "Ready, Willing, and Able" (RWA)

Before we move to the ATC Holder or refinery level, the Intermediary must confirm the Buyer’s financial capability.

POF (Proof of Funds): While we do not ask for POF in the first five minutes, the Intermediary must guarantee that the Buyer can issue a standard financial instrument (SBLC/DLC/MT103) from a Top 25/50 Western Bank.
KYC/CIS: The Intermediary must ensure the CIS is complete and accurate. An incomplete KYC will result in an immediate rejection of the file.

4. Non-Circumvention & Fees (NCNDA/IMFPA)

We respect the right of the Intermediary to be protected.

Protection: We work within the framework of ICC 600/800 for Non-Circumvention and Non-Disclosure.
Fee Protection: Paymaster agreements (IMFPA) are only executed at the contract (SPA) stage once the Seller/ATC Holder has vetted the Buyer. We do not discuss "commissions" until a valid ICPO is on the table.

5. Zero Tolerance for "Joker" Activity

Emerald Supply maintains a "Blacklist" of brokers who submit fraudulent documents, expired passports, or non-existent buyers.

Consequences: If a document is found to be forged or a Buyer is found to be "blacklisted" by the refinery, the Intermediary will be permanently barred from all future Emerald Supply allocations.
Professionalism: High-level energy trade is conducted with brevity and facts. We do not engage in long, speculative WhatsApp chats or unofficial communication regarding refinery procedures.

How to Submit a Lead Successfully:

Identify Yourself: State clearly if you are the Buyer’s Mandate or a Direct Intermediary.
Submit the Package: Provide a fresh ICPO + CIS + Scanned Passport of the Buyer.
Wait for Compliance: Our compliance desk will review the file within 24–48 hours.
Soft Probe/Call: If the file is clean, we will initiate a call between Mandates to align on the SOP.

"In this industry, time is more valuable than the commodity itself. If you bring us a real Buyer, we will bring you a real Seller. No exceptions."