PETROLODEX

1. Introduction and Commitment

Petrolodex is a global wholesale fuel supply and trading company headquartered in Dubai, UAE. We connect verified buyers and sellers of petroleum products — including gasoline, diesel, jet fuel, marine gas oil, and heavy fuel oil — across North and South America, EMEA, and Asia-Pacific.

We recognize that our operations and supply chain carry inherent human rights responsibilities. This Human Rights Policy Statement sets out Petrolodex's commitment to respecting and upholding human rights throughout our business activities and commercial relationships.

This policy applies to all Petrolodex employees, directors, officers, contractors, consultants, and business partners. We expect our suppliers, trading counterparts, and logistics providers to uphold the same standards.

2. Guiding Principles and Standards

This policy is guided by and aligned with the following international frameworks:

• The United Nations Universal Declaration of Human Rights (UDHR)
• The United Nations Guiding Principles on Business and Human Rights (UNGPs)
• The International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work
• The UN Global Compact Ten Principles
• The OECD Guidelines for Multinational Enterprises on Responsible Business Conduct
• Applicable laws and regulations of the jurisdictions in which we operate, including UAE Federal Labour Law

3. Key Commitments

3.1 Prohibition of Forced Labor and Human Trafficking

Petrolodex prohibits forced labor, bonded labor, indentured servitude, and human trafficking in all forms. We do not retain workers' identity documents or personal belongings. All employment is voluntary, and workers are free to terminate their employment with reasonable notice in accordance with applicable law.

3.2 Prohibition of Child Labor

Petrolodex does not employ anyone below the minimum working age established by local law or 18 years of age for hazardous work, whichever standard provides greater protection. We require the same of our suppliers and business partners.

3.3 Non-Discrimination and Equal Opportunity

We are committed to maintaining a workplace free from discrimination, harassment, and retaliation. Employment decisions are based on merit, qualifications, and business needs — without regard to race, color, religion, sex, national origin, age, disability, sexual orientation, gender identity, marital status, or any other protected characteristic under applicable law.

3.4 Fair Wages and Working Hours

Petrolodex is committed to compensating employees fairly and in compliance with all applicable wage and hour laws. We respect maximum working hour limits and ensure that employees receive mandated rest periods and breaks. Overtime is voluntary and compensated in accordance with local law.

3.5 Freedom of Association and Collective Bargaining

We respect our employees' right to freedom of association and collective bargaining to the extent permitted by applicable law. Where such rights are restricted by local legislation, we seek to provide employees with alternative channels to raise concerns and engage in dialogue with management.

3.6 Health and Safety

Petrolodex provides a safe and healthy working environment for all employees and contractors. Given the nature of fuel supply and trading, we maintain rigorous safety standards across our operations and expect the same of our logistics and supply chain partners. We track and report health and safety incidents and work continuously to reduce workplace risks.

3.7 Security Forces

Where security personnel are engaged to protect our people, assets, or operations, we require that they act in a manner consistent with applicable laws and with respect for human rights. We prohibit the use of excessive force and require training on human rights standards for any security personnel deployed in connection with our operations.

3.8 Land Rights and Indigenous Peoples

Petrolodex respects the land, forest, and water rights of communities affected by our operations or those of our supply chain partners. We do not engage in or support unlawful eviction or unauthorized appropriation of land. Where indigenous communities may be impacted, we are committed to meaningful consultation and engagement.

3.9 Environmental Stewardship and Human Rights

We recognize the connection between environmental degradation and human rights. Petrolodex is committed to operating in an environmentally responsible manner and to minimizing the environmental impact of our activities. We comply with applicable environmental regulations and seek to prevent pollution that could harm the health and well-being of workers and communities.

4. Human Rights Due Diligence

Petrolodex is committed to implementing a human rights due diligence process that includes:

• Identifying and assessing actual and potential human rights impacts across our operations and value chain
• Integrating findings into decision-making and taking appropriate action to address identified risks
• Tracking the effectiveness of our responses and measures
• Communicating how impacts are addressed to relevant stakeholders
• Prioritizing risks based on severity and likelihood, with particular attention to vulnerable groups including women, children, migrant workers, and indigenous peoples

We are in the process of formalizing our human rights risk analysis framework and will schedule regular reviews to ensure it remains current and effective.

5. Supply Chain Expectations

Petrolodex works with refiners, national oil companies, distributors, and logistics providers worldwide. Every supplier is vetted for compliance and traceability. We extend the principles of this policy to our business relationships and expect our partners to:

• Respect the human rights outlined in this policy
• Comply with all applicable labor, health and safety, and environmental laws
• Prohibit forced labor, child labor, and discrimination in their own operations
• Allow Petrolodex reasonable access for the purposes of monitoring and assessing compliance
• Promptly disclose and remediate any human rights violations identified in their operations

When deciding to engage or terminate business relationships, Petrolodex considers human rights performance as a material factor.

6. Grievance Mechanism

Petrolodex is committed to providing accessible and effective channels through which employees, business partners, and external stakeholders can report human rights concerns without fear of retaliation. Our grievance mechanism is designed to:

• Be accessible to all potentially affected parties, including workers in our supply chain
• Ensure confidentiality and protect the identity of complainants
• Investigate complaints promptly and impartially
• Provide timely updates to complainants on the status and outcome of investigations
• Prohibit any form of retaliation against individuals who raise concerns in good faith

Concerns can be reported to compliance@petrolodex.com or through the contact channels listed on our website at petrolodex.com/contact.

7. Remediation

Where Petrolodex identifies that it has caused or contributed to adverse human rights impacts, we are committed to providing for or cooperating in remediation through legitimate processes. This may include apology, restitution, rehabilitation, financial or non-financial compensation, and measures to prevent recurrence.

Where adverse impacts are directly linked to our operations or business relationships, we will use our leverage to encourage responsible parties to provide effective remedy.

8. Governance and Accountability

Responsibility for oversight of this policy rests with Petrolodex's senior management. The company's leadership is responsible for:

• Ensuring adequate resources are allocated to implement this policy
• Reviewing this policy at least annually and updating it as necessary
• Monitoring compliance and the effectiveness of measures taken
• Reporting on human rights performance to relevant stakeholders

As the organization grows, Petrolodex intends to designate a dedicated human rights officer and to incorporate human rights performance into management incentive structures.

9. Training and Awareness

Petrolodex will provide training to all employees on human rights topics relevant to their roles, including:

• Awareness of this policy and related company standards
• Recognition and prevention of forced labor, child labor, and trafficking
• Non-discrimination and harassment prevention
• Health and safety protocols
• Reporting obligations and use of the grievance mechanism

Training will be provided to new hires upon joining and refreshed on a regular basis for all personnel.

10. Reporting and Transparency

Petrolodex is committed to transparency in our human rights efforts. We will report on the implementation of this policy and our due diligence activities. As our program matures, we will work toward making our human rights due diligence reporting publicly available and increasing the frequency and depth of disclosure.

Documentation and data relating to risk analysis, preventive and remedial measures, and complaints received will be retained for a minimum of seven years.

11. Review and Approval

This policy has been approved by the senior management of Petrolodex and is effective as of the date stated on the cover page. It will be reviewed at least annually and updated as necessary to reflect changes in our operations, risk profile, legal requirements, and stakeholder expectations.