1. Collaboration Framework and Allocation of Roles

In connection with its international business intermediation and petroleum transaction coordination activities, AFETOP works closely with a group comprising two international companies:

• one U.S.-based company; and
• one Spanish company.

This group officially represents 25 refineries and operates under a predefined organizational framework for processing petroleum purchase requests.

To ensure a structured process, preliminary counterparty verification, controlled disclosure of sensitive commercial information, and proper transaction traceability, the responsibilities of the different participants are clearly allocated.

Spanish Company — Preliminary Buyer Due Diligence

The Spanish company is involved at the initial stage of the process. Following receipt of the buyer's request and confirmation of the buyer's intention to proceed, the Spanish company conducts the preliminary due diligence of the buyer, including through the required Bank-to-Bank MT199 communication. This stage is a prerequisite for the effective opening of the transaction file.

U.S. Company — Transaction & Documentation

Following confirmation by the Spanish company that the preliminary MT199 verification has been satisfactorily completed, the U.S. company takes over the transaction process. Depending on the transaction and in accordance with the applicable procedure, it coordinates the release of the information and documentation required to proceed, which may include:

• draft Sales and Purchase Agreement (SPA);
• Proof of Product / Partial PPOP at the applicable stage;
• identification of the supplying refinery at the appropriate stage;
• loading port;
• commercial and technical documents;
• logistics and proof-of-product documentation;
• other documents required for the transaction to progress.

AFETOP — Commercial Coordination & Intermediation

AFETOP acts as the commercial partner and intermediary/coordinator of the transaction, within the framework agreed for each operation. AFETOP:

• receives and initially qualifies the purchase request;
• coordinates communications with the buyer or its representative;
• communicates preliminary commercial terms;
• explains the applicable procedure;
• coordinates the progression of the file between the relevant parties;
• maintains commercial communication throughout the process;
• ensures appropriate confidentiality and non-circumvention arrangements.

This allocation of responsibilities allows each participant to operate within its designated role.

2. Core Principle of the Process

The process is deliberately structured in stages. Sensitive commercial information is not disclosed in full at the initial contact stage.

This approach is designed to:

• qualify serious purchase requests;
• protect confidential information;
• conduct preliminary counterparty verification;
• preserve the confidentiality of refineries and contractual parties;
• maintain proper traceability of introductions;
• reduce circumvention risks;
• allow the parties to proceed on a professional and documented basis.

3. Overall Process

The general sequence is as follows:

1. Purchase request received by AFETOP
2. Preliminary commercial qualification
3. Net seller price and applicable procedure communicated
4. Buyer's official confirmation by LOI / ICPO / corporate communication, as applicable
5. Confidentiality, non-circumvention and intermediary protection arrangements
6. Spanish company's banking coordinates provided in accordance with the applicable instructions
7. MT199 Bank-to-Bank communication sent by the Buyer's bank
8. Preliminary Buyer Due Diligence by the Spanish company
9. Confirmation of successful MT199 verification
10. Handover to the U.S. company
11. Progressive release of transaction information and documentation
12. SPA / contractual documentation
13. PPOP and financial instruments in accordance with the procedure
14. Logistics, delivery and final payment

4. Step 1 — Initial Purchase Request

The buyer, its authorized representative, or one or more intermediaries submit a purchase request to AFETOP, including, where available:

• product;
• specification;
• quantity;
• destination;
• discharge port;
• frequency or supply duration;
• required terms;
• buyer's corporate identity;
• identity and capacity of its representative, if applicable.

AFETOP conducts an initial review of the request.

5. Step 2 — Preliminary Commercial Presentation

Where the available opportunity corresponds to the buyer's requirements, AFETOP provides the commercial information available at the initial stage. Depending on the transaction, this may include:

• product;
• specifications;
• quantity;
• destination;
• CIF terms;
• net seller price;
• transaction procedure;
• qualification requirements;
• preliminary banking requirements.

Applicable intermediary commissions are treated separately from the net seller price and in accordance with the arrangements agreed with the relevant parties.

At this stage, information that would directly identify or enable direct contact with a protected refinery or other protected counterparty may not yet be disclosed.

6. Step 3 — Buyer's Official Confirmation

If the buyer wishes to proceed, it provides AFETOP with an official confirmation in the appropriate form, including:

• LOI;
• ICPO;
• official corporate letter;
• or corporate email issued by an authorized representative.

This confirmation establishes the buyer's genuine commercial intention and allows the next stages of the process to be initiated in accordance with the applicable procedure.

7. Step 4 — Confidentiality, Non-Circumvention and Intermediary Protection

Before disclosure of sensitive information that could permit direct identification or contact with protected counterparties, the applicable arrangements concerning:

• confidentiality;
• non-circumvention;
• recognition of the commercial introduction;
• protection of the economic rights of intermediaries;

are established through the appropriate documentation.

Where commissions are payable by the buyer, their recognition and protection are agreed directly between the buyer and the relevant intermediary beneficiaries, including AFETOP and, where applicable, the other authorized intermediaries participating in the transaction.

The seller, refinery, or entity responsible for the banking procedure is not deemed to guarantee such commissions unless it has expressly undertaken such an obligation in writing.

8. Step 5 — Initiation of the Preliminary Banking Process

Once the applicable preliminary conditions have been satisfied, AFETOP provides the instructions required for the buyer to initiate the first banking stage. The banking coordinates of the Spanish company are provided in accordance with the applicable instructions. Such banking coordinates are provided solely for the purposes of the prescribed preliminary verification process.

9. Step 6 — MT199: Prerequisite for File Opening

The Bank-to-Bank MT199 constitutes a mandatory preliminary qualification step. The buyer instructs its bank to send the required banking communication to the Spanish company in accordance with the instructions provided. The Spanish company uses this communication for its preliminary Buyer Due Diligence and the verification required before the transaction file is effectively opened.

10. Step 7 — MT199 Validation and Handover to the U.S. Company

Following receipt and review of the MT199, the Spanish company confirms the outcome of the preliminary due diligence process. Where the verification is satisfactory, the U.S. company takes over the transaction file in accordance with the organizational framework established by the group.

From this stage onward, transaction information is progressively released in accordance with the applicable procedure. Depending on the transaction, this stage may include:

• draft SPA;
• Partial PPOP at the applicable stage;
• Refinery Commitment to Supply;
• Certificate of Origin;
• Seller Certificate of Incorporation;
• Quality and Quantity Report / Product Passport;
• Statement of Product Availability;
• Export Certificate;
• Commercial Invoice;
• identification of the supplying refinery;
• loading port;
• logistics documentation and other documents предусмотрed by the procedure.

The disclosure of such information takes place at the appropriate stage of the process and is not automatically triggered solely by MT199 validation.

11. Step 8 — Contractual CIF Buying Procedure

Following completion of the preliminary process, the transaction proceeds in accordance with the applicable CIF Buying Procedure.

The reference procedure provides, in particular, for the following phases:

Phase 1 — Initiation and Contracting

1. Offer Confirmation & ICPO
2. Draft SPA
3. Letter of Guarantee
4. SPA Execution
5. Legalization

Phase 2 — PPOP & Financial Instruments

6. Partial PPOP Release
7. Bank Instrument Issuance

Phase 3 — Financial Default Protocols

Application of the mechanisms provided for in the procedure in the event of delay or default in the issuance of the required financial instrument.

Phase 4 — Full POP, Performance Bond & Logistics

8. CPA Signature
9. Full POP & Performance Bond

Phase 5 — Delivery & Final Payment

10. Customs Clearance
11. Shipping Confirmation
12. Delivery
13. Discharge & Final Payment

12. Non-Modification Principle

The CIF procedure communicated by the seller is presented as STRICTLY NON-NEGOTIABLE. Any modification, substitution or deviation from the prescribed steps must be submitted for prior authorization by the duly authorized parties.

Where the seller's procedure provides that any modification automatically results in rejection of the offer or transaction file, that provision shall apply in accordance with the instructions received.

AFETOP does not unilaterally amend a procedure established by the relevant contractual party.

13. Commissions and Intermediary Fee Protection

Intermediary commissions are separate from the net seller price. Where such commissions are payable by the buyer, they are subject to a specific arrangement between:

The Buyer

and

AFETOP and the other relevant intermediary beneficiaries.

The applicable documentation may specify:

• identity of the beneficiaries;
• amount or calculation formula;
• currency;
• payment-triggering event;
• payment schedule;
• settlement mechanism;
• banking coordinates of the beneficiaries;
• protection period;
• repeat transactions or renewals covered;
• applicable dispute-resolution provisions.

This protection is separate from the sale and purchase agreement between the buyer and the seller.

14. Confidentiality and Controlled Disclosure

Protection of commercial information is an essential component of the process. Sensitive information may include:

• refinery identity;
• title holder identity;
• loading port;
• direct contact details;
• proof-of-product documents;
• banking information;
• contractual documents;
• allocation information;
• information concerning other transaction participants.

Such information is disclosed progressively, according to the actual progress of the file and the requirements of the applicable procedure.

Disclosure of confidential information does not constitute a waiver of the confidentiality, non-circumvention or commission rights of the protected parties.

15. Responsibility Matrix

16. Process Flow — At a Glance

17. Important Note Regarding MT199

The MT199 is presented here as a requirement of the transaction procedure established by the relevant parties. It should not be construed as:

• a payment instrument;
• a funds transfer;
• or an autonomous financial guarantee.

Its purpose is limited to the bank-to-bank communication and preliminary verification contemplated by the applicable process.

The exact transmission requirements must always be confirmed with the banks involved and in accordance with the official banking instructions applicable to the specific transaction.

18. Conclusion

AFETOP follows a structured approach whereby each stage is initiated only after the corresponding preliminary requirements have been satisfied.

This framework is designed to provide the buyer with:

• a clearly defined process;
• preliminary qualification;
• controlled documentary progression;
• appropriate counterparty traceability;
• confidentiality;
• coordinated interaction between the relevant participants;
• and a clear framework for the economic rights of the intermediaries.

The objective is to enable serious buyers to progress efficiently while preserving the confidentiality, integrity and legitimate interests of every authorized participant in the transaction.

Frequently Asked Questions — CIF Purchase Process