Standard Operating procedure

SOVERTRADE PTE LTD.

100, Pasir Panjang Road, #06-08, Singapore 118518
Tel: +65 6476 8263 Fax: +65 6475 6192

Scope:
Trader (without Storage)

Version Date:
Version 2 (Oct 2021)

Confidentiality Disclaimer:
This documented procedure includes information that shall not be disclosed to third parties
and shall not be duplicated, used, or disclosed - in whole or in part - for any purpose.
 TABLE OF CONTENTS
1.0 INTRODUCTION 1
2.0 ISCC MINIMUM REQUIREMENTS FOR MANAGEMENT 2
3.0 SYSTEM CHAIN OF CUSTODY PROCEDURES 5
4.0 GREENHOUSE GAS CALCULATION PROCEDURE 11
5.0 CRITICAL CONTROL POINT 11

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 1.0 INTRODUCTION
International Sustainability and Carbon Certification (ISCC) is an independent multi-
stakeholder organisation that provides a globally applicable certification system for the
sustainability of raw materials and products, traceability through the supply chain and the
determination of greenhouse gas emissions and savings.
ISCC is a multi-feedstock system and covers agricultural, forestry and alternative raw
materials. The ISCC certification system ensures the sustainability of raw materials and
products for various markets, including bioenergy (liquid and gaseous biofuels and bio-
liquids), food, feed, and chemical/technical markets. In the bioenergy and
chemical/technical markets, renewable raw materials are increasingly regardedas a feasible
and climate friendly alternative to fossil feedstock. If fossil feedstocks are replaced with
renewable feedstock of biological origin the sustainability of these raw materials should be
ensured. This also applies to agricultural raw materials used in food and feed markets.
Every element of a supply chain for sustainable materials must provide evidence of
compliance with the sustainability criteria of the Renewable Energy Directive 2009/28/EC
amended through Directive (EU) 2015/1513 and the Fuel Quality Directive 2009/30/EC (FQD)
amended through Directive (EU) 2015/1513. ‘Chain of custody’ is a general term for making
a connection between sustainability information and claims regarding raw materials,
intermediate and final products. Different chains of custody methods are available for the
handling of sustainable materials along the supply chain.
This documented procedure defines the operation of SOVERTRADE PTE LTD located at 100,
Pasir Panjang Road, #06-08, Singapore 118518 to address requirements spelled in ISCC 203
(Version 3.1). Activities conducted by this company are trading of various feedstock from
vegetable oil-based waste and residue materials such as POME, RPOME, Bleaching Earth Oil
and PFAD. Due to the growing demands on sustainable materials throughout the world, the
company decided to maintain certified as International Sustainable Carbon Certification
(ISCC) certificate holder.
ISCC registration number for the company is ISCC-REG-5342 as a Trader (without warehouse)
under ISCC-EU system. The company shall meet and always in compliance with the relevant
ISCC documents as below:
a. ISCC EU 201: System Basics (V4.0)
b. ISCC EU 202-5: Waste and Residues (V4.0)
c. ISCC EU 203: Traceability and Chain of Custody (V4.0)
d. ISCC EU 204: Risk Management (V4.0)
e. ISCC EU 205: Greenhouse Gas Emissions (V4.0)
Definitions of Trading Unit: Traders without physical contact to the sustainable material (i.e. no
use of own or rented storage facilites) have to be certified under the scope ‘trader’.

100, Pasir Panjang Road, #06-08, Singapore 118518

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 2.0 ISCC MINIMUM REQUIREMENTS FOR MANAGEMENT SYSTEM
This management system documents describes the scope of responsibilities and internal
company processes and procedures for ensuring that SOVERTRADE PTE LTD is able to
implement and update all of the requirements for achieving the objectives of the ISCC-EU
standards. The company shall ensure good management practices are implemented at all
time with respect to sustainability, greenhouse gases, traceability and chain of custody
requirements are applied at every critical control point.
In case the company outsource any part of the related chain of custody activities to any
service providers (e.g. transport, collection and storage of sustainable materials); the
company shall ensure that the service providers are also comply with the ISCC requirements.
This shall be ensured by providing those service providers with sufficient training related to this
ISCC-EU requirement. Contractual agreements and evidence of the distribution of relevant
information and documentation between the company and the service providers shall be
clearly maintained.
The management system is adequate to the nature, scope and quantity of the required
activities conducted within the premises of this company. According to ISCC Document 204:
Risk Assessment and Audit Requirements; the risk factor for SOVERTRADE PTE LTD is considered
as Regular Risk. The risk factors is considered as such based on availability of documentation
control system, complexity of the business module, sufficient resources for the
implementation and adequate facilities for handling of sustainable and non-sustainable
materials.

2.1. Responsibilities of the Management

2.1.1. SOVERTRADE PTE LTD is committed to comply with ISCC requirements as described in
this procedure and by signing latest ISCC Term of Use (Appendix 1). These documents
shall be made available to all interested parties (upon request).
Distribution of any ISCC related documentation and information to staffs, contractors,
suppliers, buyers, or any interested parties shall be recorded into documents
distribution list (Appendix 2).
2.1.2. SOVERTRADE PTE LTD shall conduct regular inspections regarding compliance with this
standard (e.g. Internal Audit) at least once a year. The inspection shall be conducted
by authorized personnel identified by the company. The appointed internal auditor is
indicated in the Organization Chart (Appendix 5).
2.1.3. SOVERTRADE PTE LTD shall identify and nominate a Management Representative to
monitor the implementation and maintenance of a traceability and chain of
custody. The appointed Management Representative (MR) is indicated in the
Organization Chart. The company shall allocate adequate training for the MR and
recorded in ISCC Training Record (Appendix 14). Responsibilities of the Management
Representative (among others) is to ensure the following activities are performed
appropriately according to the standard requirements:
1. Sourcing and register incoming sustainable products, identification of origin and
evaluation of the quantity of sustainable products and related GHG emissions
2. Delivery, storage, sales and distribution of sustainable products and evaluation of
the quantity of sustainable products and related GHG emissions
3. Reporting, documentation, issuing Sustainability Declaration Form or other
documents within the scope of the company
4. Planning and/or execution of self-assessments and internal audits

100, Pasir Panjang Road, #06-08, Singapore 118518

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 2.2. Procedures, Reporting and Documentations
2.2.1. SOVERTRADE PTE LTD has established documented procedures with respect
to the sustainability requirements as below:
1. Trading of Sustainable Materials Process Flow Chart (Appendix 4)
2. Organization Chart (Appendix 5)
3. Job Responsibilities and Authorities related to COC (Appendix 3)
4. Procedures on the traceability and COC regarding ISCC certified materials (This
document).
2.2.2. The company shall establish and maintain reporting system which satisfies the ISCC
requirements and operates them both effectively and efficiently.
Relevant records shall be kept for all critical control points (CCP). Records showing a
clear link between products, product flow and documentation shall be maintained
at all times.
2.2.3. The company shall identify relevant records to maintain the traceability and COC at
all time (not necessary limited to):
1. Plant operation permit:
a. Business License: 200504662G (Registered on 08 Apr 2005)
2. Plant layout plan and capacities of storage facilities (Not applicable as the
company is Trader without any storage)
3. Records of incoming and outgoing sustainable products (e.g. Self-Declaration,
Weighbridge Tickets, Sustainability Declarations, etc.)
4. Records of Mass Balance Table (periodic reporting on opening and closing stock
for incoming and outgoing sustainable and non-sustainable material) – (Appendix
9).
5. List of Suppliers and Recipients of Sustainable Materials
6. Sales Contracts with all suppliers and recipients of Sustainable Material
7. List and contracts with subcontractors and service providers related to sustainable
products
8. Records of sustainable materials delivered (ISCC Reporting Template, Mass
Balance Table, etc.)
9. Records on Internal Audits, Non-Conformity and Corrective Actions
10. Records on Management Review Meeting
11. ISCC Terms of Use
2.2.4. SOVERTRADE PTE LTD is obliged to provide the buyers with all of the necessary
documents and sustainability information upon request.
2.2.5. All records and documents (hard copies and/or electronically) relevant for ISCC
certification shall be maintained for at least five (5) years and shall be treated as
CONFIDENTIAL. These documents shall not be made accessible to unauthorized third
parties.

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 2.3. Qualification and Training of Employees
2.3.1. SOVERTRADE PTE LTD shall ensure that all members or staff responsible for; and working
on the implementation and maintenance of the sustainability, traceability and chain
of custody shall be competent and have undergone appropriate training,
education, skills and experience. The training can be conducted internally or by
appointed consultant(s).
2.3.2. The company shall establish a training plan and implement accordingly. Training plan
shall covers all operation at identified Critical Control Points involved in its chain of
custody system, which should be conducted at a minimum of once a year.
2.3.3. All training conducted by the company shall be recorded and materials delivered
during the training shall be kept and maintained by the company.

2.4. Technical Equipment

2.4.1. SOVERTRADE PTE LTD shall identify necessary technical equipment(s), provide and
maintain the infrastructure and technical facilities needed for effective
implementation and maintenance of the company's traceability system with the
requirements of this standard.
2.4.2. List of technical equipment(s) (when applicable) available in the company's premises
is listed in (Appendix 16).
2.4.3. There is no technical equipment available within the company's premises as the
company is only paper Trader interface.

2.5. Internal Audit and Management Review

2.5.1. SOVERTRADE PTE LTD shall conduct internal audits at least once a year covering all
relevant requirements of ISCC standard requirements and establish corrective and
preventive measures (if required).
2.5.2. The appointed internal auditor shall use latest version of ISCC Checklist (Appendix 11)
in accordance to the applicable scope(s) of certification. All findings or lapse (if any)
shall be presented at the end of the audit.
2.5.3. Action plan for corrective action on the identified findings shall be taken by relevant
department within 14 days from the closing meeting.
2.5.4. Internal Audit Report (Appendix 12) shall be made available for review by top
management of SOVERTRADE PTE LTD at least once a year. Outcome of the
management review shall be recorded and maintained.

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 3.0 Chain of Custody Procedures
3.1. Scope of Certification
3.1.1. Scope of certification of SOVERTRADE PTE LTD is a Trader (without
warehouse) for feedstock from Waste and Residue.
3.1.2. For incoming and outgoing sustainable materials, SOVERTRADE PTE LTD shall
receiveand provide the following records:
1. List with names and addresses of suppliers of sustainable products
2. List with names and addresses of recipients of sustainable products
3. Contracts with relevant subcontractors/service providers, suppliers and recipients
of sustainable products
4. Sustainability Declarations, weighbridge tickets, bills of lading or other
documentation for all incoming and outgoing sustainable material
5. Mass Balance Calculation
6. In the case of individual GHG calculations, the GHG calculation itself as well as
the input data used for the calculation

Additional Requirements for Storage Facilities

3.1.3. In case where SOVERTRADE PTE LTD is leasing any external storage facilities to store
ISCC sustainable materials, the company shall make the following information
available:
1. List of all the storage facilities where sustainable material is stored, including
names and addresses
2. Plant layout plan
3. Contracts between the storage facility and clients
4. Relevant technical equipment and infrastructure to determine the flow of
incoming and outgoing material
5. Documentation of the data flows between the storage facility and client (i.e.:
loading instruction)
6. Documentation of the periodical inventory of the incoming and outgoing
material per contract/client, including weighbridge protocols
7. Contractual agreement providing access for certification bodies

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 3.2. Chain of Custody Method (MASS BALANCE)
According to the RED and FQD, SOVERTRADE PTE LTD shall demonstrate that the sustainability
criteria of the RED and FQD have been fulfilled. The sustainability criterion of biofuels/bio
liquids includes:
a. description of the raw material
b. country of origin of the raw materials
c. GHG emissions
d. evidence of the sustainability of the material
The traceability and evidence of the sustainability characteristics of a material are achieved
through:
 the application of the traceability measures and ensures that the sustainability
characteristics remain assigned to batch(es) of material; and
 the amount of material withdrawn at any stage of the supply chain does not exceed the
amount supplied.
Note: The term ‘batch’ describes a specific amount of material with the same
sustainability characteristics.
SOVERTRADE PTE LTD has decided to go for Mass Balance COC options where the company
shallalways ensure:
 Mass balance allows the physical mix of sustainable materials with different sustainability
characteristics and non-sustainable materials.
 The information about the sustainability characteristics and the size of the batches with
differing sustainability characteristics must remain assigned to the mixture.
Sustainability Characteristic
3.2.1. Upon receiving sustainable materials, the company shall distinguish/identify
the
materials according to the category below:
1. Raw material/feedstock type (e.g. corn, canola, FFB, POME, SBEO, etc.)
2. Country of origin of the raw material
3. Information on GHG emissions
4. Claim “ISCC compliant” or “EU RED compliant” (if applicable)
Receiving Batches with Different GHG Emissions
3.2.2. When batches with different sustainability characteristics are physically mixed, the
respective sizes and sustainability characteristics of each batch remain assigned to
the batches in the calculation for either mass balance or segregation.
This means, for example, if batches with different figures on GHG emissions are
physically mixed, the batches have to be kept separate in the quantity bookkeeping.
Creating an average of the GHG emissions of different batches is NOT ALLOWED.
3.2.3. If batches with the same sustainability characteristics are physically mixed, the size of
the batches can be summarised accordingly in the quantity bookkeeping.
3.2.4. Sustainability characteristics are likely to be the same, for example, if the same kind of
raw material from the same country of origin and with the GHG emissions statements
‘default values’ is used. If materials are processed or losses of material occur due to
internal company processes, the appropriate conversion factors shall be used to
adjust the size of batches accordingly.
Split up of Mixture
3.2.5. If a mixture is split up, a set of sustainability characteristics can be assigned to any
batch that is taken out. The sum of all batches withdrawn from the mixture must have
the same sustainability characteristics in equal quantities, as the sum of all the
batches added to the mixture.

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 Separate book-keeping
3.2.6. SOVERTRADE PTE LTD must split the quantity bookkeeping for all materials with different
sets of sustainability characteristics even if the chain of custody method allows for the
physical mix of material.
The bookkeeping must be separated according to:
1. Different types of input materials (this also refers to the type of initial raw
material/feedstock)
2. Different sustainability characteristics (e.g. type of raw material, feedstock,
country of origin of the raw material, GHG emissions, application of land related
sustainability criteria according to Art. 17 (3) to (6) RED, “ISCC compliance”)
3. If more than one chain of custody option is applied at the site, separate quantity
bookkeeping has to be kept for each chain of custody option
3.2.7. Within the quantity bookkeeping, batches of input material can be merged if they
have the same sustainability characteristics and are handled under the same chain
of custody option.
Batches of input materials cannot be merged within the bookkeeping if they have
different sustainability characteristics or none at all or are handled under different
chain of custody options.
Deviations
3.2.8. A deviation of up to 0.5% between the physical stock and the stock according to the
quantity bookkeeping can be accepted. Any deviations greater than 0.5% have to
be documented appropriately and verified during the audit.
Double Accounting
3.2.9. If SOVERTRADE PTE LTD happen to be certified under more than one certification
scheme, no double accounting is allowed on the declared sustainable materials
volumes.
3.2.10. In order to ensure that no double accounting takes place, it must be checked during
the internal audit to confirm that the company is also certified under more than one
certification scheme.
SOVERTRADE PTE LTD shall declare to its certification body the names of all schemes
they participate in and have to provide the auditor with all relevant information,
including the audit reports and chain of custody information, such as mass balances,
for verification.
3.2.11. The company has to operate an information system which is able to keep track of the
amounts of sustainable material sourced and sold. This could include, inter alia, a
digital database, documentation with unique reference numbers for batches or
similar.
3.2.12. The quantity bookkeeping and physical mixture of sustainable material is limited to
certain periodical and spatial boundaries.

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 Periodical Boundaries
3.2.13. SOVERTRADE PTE LTD shall ensure the input and output of materials with specific
sustainability characteristics are balance in the Mass Balance Table (Appendix 9)
within three (3) months’ timeframe. Appropriate arrangements are necessary to
ensure that the balance is respected.
3.2.14. If more sustainable material (including existing inventory of sustainable material) was
received within one mass balance period than was dispatched, the surplus of
sustainable material in the bookkeeping is called the ‘positive credit’.
IMPORTANT NOTE: It is only possible to transfer positive credits from one mass balance
period to the next if at least the equivalent amount of physical material (sustainable
and non-sustainable) is in stock, as positive credits are stated in the bookkeeping. It is
not possible to transfer more positive credits into the next mass balance period than
the quantity that is physically in stock at the end of the mass balance period.
3.2.15. Negative credits would occur if at the end of a mass balance period less sustainable
material (including existing stock) was received than dispatched. This would be
equivalent to a negative mass balance, which is not allowed under ISCC. If negative
credits occur at the end of a mass balance period, SOVERTRADE PTE LTD must inform
the certification body immediately without being requested.

3.3. Requirements for issuance of Sustainability Declarations

5.3.1. SOVERTRADE PTE LTD shall issue Sustainability Declarations containing all relevant
information stated in ISCC EU standard (V4.0) for every physical delivery of
sustainable materials. Sustainability Declaration should reflect the product group of
the delivered product.
Note: A product group is defined by similar physical or chemical characteristics,
heating values and/or conversion factors (i.e. PME is a different product group than
Glycerin).
3.3.2. The company shall ensure that the supplier of sustainable material is holding a valid
certificate at the date of the dispatch of the sustainable material. All valid ISCC
certificates are displayed on the ISCC website and can be checked through
https://www.iscc-system.org/certificates/valid-certificates/. This verification shall be
done by Management Representatives.
3.3.3. Upon receipt of sustainable materials, the company shall verify, whether the supplier
is holding a valid ISCC certificate at the date of the dispatch of the sustainable
material.
3.3.4. SOVERTRADE PTE LTD shall check whether all of the relevant information according to
the RED, FQD and this standard are available and consistent in the Sustainability
Declaration issued by the supplier. Sustainability Declarations that contains lacking or
inconsistent information should not be accepted by the company.
3.3.5. The company shall ensure that they or the supplier issued Sustainability Declarations
(Appendix 17) not later than 30 days after the date of the physical dispatch of the
sustainable material.
3.3.6. It is possible to aggregate Sustainability Declarations for a number of deliveries of
batches with the same sustainability characteristics under one contract. In this case,
the whole delivery period shall be stated on the Sustainability Declaration. Each
individual delivery must be documented by weighbridge tickets or similar documents
to allow the verification of the overall amount and the delivery dates of the entire
batch.

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 3.3.7. The following general information must be made available on Sustainability
Declarations for all incoming and outgoing sustainable material in case the company
decided not to use the template provided by ISCC:
1. Name and address of the supplier
2. Name and address of the recipient
3. Related contract number
4. Date of the physical dispatch of the sustainable material
5. Name of the certification system and certificate number of the supplier
6. Date of the issuance of the Sustainability Declaration
7. Unique number of the Sustainability Declaration (running number)
8. Incoming or outgoing sustainable material, indicating the raw material (i.e.: crude
oil from rapeseed, ethanol from corn)
9. Country of origin of the materials (for waste and residues; country where material
originated from)
10. Quantity of incoming and outgoing sustainable products (in metric tons or m³ at
15°C)
11. “ISCC Compliant” statement
12. GHG Statement: “Use of disaggregated default value for transportation”

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 3.4. Requirements on Waste and Residue (ISCC 201-1)
This procedure provides the principles for the identification of raw materials and feedstocks
qualifying as “waste” or “residue”; as their supply chains and specific certification
requirements may differ from those of the conventional crop-based biomass. The verification
and assessment of a material and its waste or residue status is important as there are no EU
wide harmonised lists defining waste or residues. Only a consistent verification can avoid a
deliberate increase in the production of waste or residues. It is necessary to ensure
traceability of a waste or residue back to its origin, along the entire chain of custody.
Waste
3.4.1. “Waste” shall be defined as in Article 3 (1) of the Waste Framework Directive
2008/98/EC (WFD2). According to this definition a “waste” can be understood as “any
substance or object which the holder discards; or intends; or is required to discard”.
3.4.2. Raw materials or substances that have been intentionally modified or contaminated
to meet this definition are not covered by this definition. This means that substances
which are intentionally produced or modified to count as waste (e.g. by adding
waste material to a material that was not waste) do not qualify as waste. The concept
of “discarding” a material according to the WFD requires a consideration of all
relevant circumstances at the point of origin of a material.
Residues
3.4.3. In the context of the RED and FQD, “residues” are “substances not being the end
product(s) that a production process directly seeks to produce”. Residues include:
1. Agricultural, aquaculture, fisheries and forestry residues: Residues directly deriving
from or generated by agriculture (agricultural crop residues, e.g. straw, bagasse,
husks), aquaculture, fisheries and forestry. These residues do not include residues
from related industries or processing.
2. Processing residue: A substance that is not the end product that a production
process directly seeks to produce; the production of the residue or substance is
not the primary aim of the production process and the process has not been
deliberately modified to produce it. Examples of processing residues include
crude glycerine, tall oil pitch and manure.
3.4.4. SOVERTRADE PTE LTD shall ensure that waste and residues materials entering the
premises are directly derived from agriculture, aquaculture, fisheries and forestry.
Waste, agricultural crop residues, including straw, bagasse, husks, cobs and nut shells
and residues from processing, including crude glycerine (glycerine that is not refined),
are considered to have zero life-cycle greenhouse gas emissions up to the point of
collection of those materials.

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 3.4.5. Traceability of waste and residues starts at the point where the waste or residue is
generated (point of origin) and the entire supply chain. Traceability is achieved by
using systems for traceability (mass balance) using Sustainability Declarations which
contains information of:
1. Identification numbers (running numbers)
2. Country of origin (i.e. the country where the waste/residue was generated)
3. Product type
4. Amount delivered (MT)
5. GHG emissions of a material

3.4.6. SOVERTRADE PTE LTD is a trader without handling physical materials

therefore responsible to maintain the traceability information from the
suppliers.

4.0 Greenhouse Gas Calculation Procedure

4.1. SOVERTRADE PTE LTD is as Trader without handling physical materials. Therefore, no GHG
calculation is required. However, information of GHG provided by the suppliers shall be
communicated to the next interface.

5.0 Critical Control Point

5.1

End of Document
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