Gunvor Group’s downstream exposure to consumers and end-users operates through two principal channels. Our entity, Gunvor Deutschland GmbH (GDG) manages the delivery of energy products, including refined petroleum products, heating oil, and natural gas to business customers and, through the supply chain, to end-users. In addition, PGL operates a downstream network of retail service stations, through which Gunvor has indirect exposure to private consumers; PGL is held as a 50% joint venture and is therefore not under Gunvor’s sole operational control, as the vast majority of the retail petrol stations are Dealer Owned Dealer Operated (DODOs). Together, these activities represent Gunvor’s most direct points of contact with end-users and require careful stewardship in terms of product safety, quality assurance, and responsible commercial conduct.
S4-1Policies related to consumers and end-users:
Gunvor’s conduct towards consumers and end-users is governed by its Code of Conduct and Ethics, which applies to all employees and commercial counterparties across the Group. In the context of downstream product responsibility, the Code establishes clear expectations across four dimensions:
- Product quality and safety all products must conform to applicable safety standards, with accurate Safety Data Sheets (SDS) and transport compliance documentation provided to customers.
- Labelling and classification compliance full adherence to product labelling and classification laws across all jurisdictions in which Gunvor operates.
- Fair commercial practice prohibition of misleading marketing, misrepresentation of product characteristics, or engagement in unfair competition.
- End-user due diligence appropriate diligence obligations for the protection of downstream customers and end-users, including where B2C exposure exists indirectly through GDG’s distribution activities.
Gunvor’s HSEC Policy further reinforces product responsibility through its requirements for compliance with applicable laws and regulations and the promotion of Gunvor’s standards across its supply chain where possible.
Processes for engaging with
consumers:
Gunvor maintains structured engagement mechanisms with its business customers and logistics partners through GDG’s[BY1.1] downstream operations. These include:
- Product quality assurance processes systematic quality verification at point of delivery, ensuring products meet contractual and regulatory specifications.
- Customer helpline a dedicated channel accessible to business customers covering product queries, delivery issues, safety information requests, and contractual matters.
- Client workshops and industry forums periodic engagement with customers and sector stakeholders on topics including health and safety, product handling, and regulatory developments affecting energy product distribution.
The insights gathered through these channels are reviewed operationally and, where relevant, feed into refinements to GDG’s product handling, logistics, and customer communication practices.
Processes to remediate negative
impacts:
Gunvor provides accessible remediation channels for customers and end-users who wish to raise concerns relating to product quality, safety, contractual performance, or ethical conduct:
- Local stakeholder helpline accessible to any party, including end-users, to report potential quality issues, ethics, or product responsibility obligations; concerns raised are triaged and escalated in accordance with Gunvor’s incident management procedures.
- Dedicated account manager resolution process complaints relating to product quality, logistics failures, or contractual delivery are assigned to account managers and subject to documented resolution procedures with defined response timelines.
- Certification and sustainability claims escalation for certified products, dedicated escalation channels investigate and resolve issues relating to certification integrity, origin claims, or sustainability misrepresentation.
- Corrective remediation in the event of substantiated incidents involving consumer harm, product misrepresentation, or safety failures, Gunvor applies documented corrective actions and, where required, engages with relevant regulatory authorities.
Gunvor is committed to ensuring that remediation processes are accessible, transparent, and effective, and that no customer or end-user faces barriers to raising legitimate concerns.
Taking action on material impacts:
Gunvor recognizes several material risks and opportunities in its relationships with consumers and end-users, including:
1. Risk of health and safety impacts associated with energy products:
The products we refine are then traded and delivered; these petroleum products can pose risks if not handled properly. We apply stringent product classification and packaging standards ensuring that clients receive accurate safety data sheets (SDS) and transport compliance documentation. Operational safety standards are upheld across logistic partners and storage facilities under the entity’s control.
2. Data confidentiality and reputational risk:
While Gunvor’s exposure to consumer data is limited, it adheres to GDPR and local data protection rules where applicable. IT security policies ensure integrity and confidentiality of counterparty data and communications.
3. Opportunity to support decarbonization and energy access:
Gunvor is active in supplying low-carbon products, and advanced biofuels. These contribute to the decarbonization efforts of downstream customers and, indirectly, to end-user benefits (e.g., cleaner transport fuels). In emerging markets, Gunvor’s trading of LPG and low-Sulphur fuels supports more affordable and less polluting household energy alternatives, especially in regions with constrained energy access.
Gunvor also undertakes GHG intensity calculations for its traded commodities, enabling the group to quantify and manage its Scope 3 emissions.