Our supply chain

Our sustainable supply chain

The sustainability of our supply chain is a key element of our commitment to responsible business practices. At Trans-Oil, we aim to build a transparent, resilient, and responsibly managed supply chain by working with suppliers who share our commitment to ethical business conduct, environmental stewardship, respect for human rights, occupational health and safety, and product integrity.

Our Responsible Sourcing Approach is based on clear sustainability expectations communicated through our Corporate Sustainability Policies, Supplier Code of Conduct, and contractual sustainability commitments. We work with suppliers to promote compliance with applicable laws, respect for human rights, responsible environmental practices, safe working conditions, ethical business conduct, and continuous improvement of sustainability performance.

Corporate Sustainability Policies / Politicile Corporative de Sustenabilitate / Корпоративные Политика Устойчивости / Politike Korporativne Održivosti	EN	RO	RU	RS
Corporate Sustainable Sourcing Policy	📜	📜	📜	📜
Corporate Human Rights Policy	📜	📜	📜	📜
Corporate Equality and Anti-Discrimination Policy	📜	📜	📜	📜
Deforestation-Free Supply Chain Policy	📜	📜	📜	📜
Corporate Biodiversity Conservation Policy	📜	📜	📜	📜
Corporate Responsible Crop Protection Products and Fertiliser Usage Policy	📜	📜	📜	📜
Corporate Responsible Agricultural Commodities Supply Policy	📜	📜	📜	📜
Corporate Diversity and Inclusion Policy	📜	📜	📜	📜

SUPPLIER CODE OF CONDUCT

КОДЕКС ПОВЕДЕНИЯ ПОСТАВЩИКА

CONTRACTOR CODE OF CONDUCT

Corporate Sustainability Development Strategy (2025–2030) Targets:

We target 80% of commodity suppliers to accept and sign our Supplier Code of Conduct with ESG principles by the end of 2027, vs. 2022-2023 baseline.
We target 80% of new suppliers to provide/fill-in ESG self-assessment by the end of 2027, vs. 2022-2023 baseline.
We target 500 farmers to be trained on conservation and regenerative agriculture by the end of 2028, vs. 2022-2023 baseline.
We will facilitate 500 extensive soil sampling and analysis on farmland by the end of 2028, vs. 2022-2023 baseline.
We target 500 primary suppliers of key commodities to be audited on ESG principles and criteria at least once by the end of 2030 (2025 performance: 0).
We target 20% of key agricultural commodities to be sourced in line with sustainable agricultural principles¹ by the end of 2030 (2025 performance: 0.5%).
We target 80% of crushing plants raw materials to be sourced locally² by the end of 2030, vs. 2022-2023 baseline.
We are committed to ensuring that 100% of the commodities sourced are deforestation-free and conversion-free (2025 performance: 100%).

¹Any of third-party certifications: ISCC, Global GAP, GRASP, GMP, Organic, Rainforest Alliance, Fair Trade International, etc.

² Withing a radius of less than 500 km.

Our responsible sourcing approach:

Responsible sourcing is an integral part of Trans-Oil's sustainability strategy and procurement practices. We are committed to ensuring that commodities, goods, and services are sourced responsibly through a structured approach that identifies, assesses, and manages environmental, social, and governance (ESG) risks throughout the supplier lifecycle.

We apply a risk-based approach to supplier management, integrating sustainability considerations into supplier selection, onboarding, assessment, monitoring, and continuous improvement processes. Through collaboration with our suppliers, we promote responsible sourcing practices, strengthen supply chain transparency, and contribute to long-term value creation for our business, partners, communities, and the environment.

The supplier assessment and monitoring process includes the following key stages:

1.Sourcing Region/Country ESG Risk Assessment
🌍	Prior to engaging with potential suppliers, Trans-Oil assesses the sustainability risk profile of the sourcing country or region. This assessment helps identify geographic areas with elevated environmental, social, governance (ESG), human rights, regulatory or geopolitical risks and determines the level of due diligence required before sourcing activities commence. The assessment considers publicly available information, internationally recognized indices, applicable sanctions, corruption perceptions, conflict status, human rights performance, environmental risks, deforestation exposure, and other relevant sustainability factors. The results determine whether sourcing may proceed under the standard process, requires enhanced due diligence, or should not be pursued due to unacceptable ESG risks.
2.Supplier Initial ESG Pre-assessment
📋	Potential suppliers that successfully pass the sourcing region assessment are invited to complete a brief ESG Pre-assessment Questionnaire (self-assessment). This initial screening enables Trans-Oil to identify potential sustainability risks and verify that suppliers meet the Company's minimum ESG expectations before entering the supplier onboarding process. The ESG Pre-assessment consists of a concise self-assessment questionnaire covering key sustainability topics, including legal compliance, environmental management, labor and human rights, occupational health and safety, business ethics and integrity, and product traceability, where applicable. Responses are reviewed to determine whether the supplier: meets the minimum requirements and may proceed to onboarding; requires additional clarification or supporting documentation; or presents unacceptable ESG risks that preclude further engagement. The pre-assessment serves as an initial screening tool and does not replace the more comprehensive ESG due diligence activities performed following supplier onboarding.
3.Supplier Onboarding & Sustainability Commitment
🤝	Suppliers that successfully complete the initial screening are formally onboarded into Trans-Oil's Responsible Sourcing Program and are expected to commit to the Company's sustainability principles and responsible business practices. As part of the onboarding process, suppliers are provided with, or granted access to, Trans-Oil's relevant sustainability policies and Supplier Code of Conduct. Suppliers are requested to: review the Company's sustainability requirements; acknowledge their understanding and commitment by signing the Sustainability Policies and Supplier Code of Conduct Acknowledgment Statement; provide any additional onboarding documentation requested by Trans-Oil; and accept contractual sustainability obligations incorporated into supplier agreements. Where applicable, supply contracts include binding sustainability clauses requiring suppliers to comply with Trans-Oil's relevant sustainability policies and Supplier Code of Conduct, maintain compliance with applicable legal requirements, cooperate with ESG assessments and audits, implement corrective actions where required, and promptly notify Trans-Oil of any significant sustainability-related non-compliance. Suppliers that successfully complete the onboarding process are included in the Approved Supplier List and become eligible for commercial engagement.
4.Supplier ESG Due Diligence
🔍	Following onboarding, suppliers are subject to a risk-based ESG due diligence process to evaluate their sustainability performance, identify actual or potential ESG risks, and determine the appropriate level of oversight. Depending on the supplier's risk profile, sourcing region, products or services provided, and previous performance, due diligence may include: comprehensive supplier ESG self-assessment questionnaire; desktop reviews of policies, procedures and supporting documentation; ESG risk screening using publicly available information; risk-based on-site or remote ESG audits; review of regulatory compliance and certifications; evaluation of traceability and supply chain transparency. The depth of due diligence is proportionate to the level of identified ESG risk.
5.ESG Risk Analysis & Continuous Improvement
📈	The results of ESG due diligence are evaluated to determine supplier risk levels and identify opportunities for continuous improvement. Trans-Oil analyses the assessment results to identify strengths, gaps and areas requiring improvement. Where necessary, suppliers are requested to develop and implement Corrective Action Plans (CAPs) with agreed responsibilities and implementation timelines. Trans-Oil works collaboratively with suppliers to encourage continuous improvement, strengthen ESG management practices and progressively enhance sustainability performance throughout the supply chain.
6.Monitoring & Re-assessment
🔄	Supplier ESG performance is monitored throughout the business relationship to verify continued compliance and support continuous improvement. Monitoring activities are conducted using a risk-based approach and may include: periodic supplier ESG self-assessments; follow-up reviews of corrective actions; scheduled or unannounced ESG audits; review of ESG incidents, complaints and regulatory findings; performance monitoring against agreed sustainability requirements; and periodic supplier re-assessments based on risk level or significant changes in operations.

Suppliers’ risk classifications are reviewed periodically and may be adjusted based on assessment results, audit findings, supplier performance, or emerging ESG risks. Suppliers demonstrating sustained non-compliance or unwillingness to implement agreed corrective actions may be subject to escalation measures, including suspension or termination of the business relationship.