--- title: "Evidence records" language: en canonical: https://dossiertwist.com/dossiers/trafigura/evidence-records/ as_of: 2026-10-16 keywords: ["Trafigura Pte Ltd","TPTE","UEN 199601595D","Trafigura Group Pte. Ltd.","Trafigura Beheer B.V.","Farringford Foundation","Trafigura Control Holdings","TPTE Holding Limited","Trafigura Funding S.A.","Trafigura Nat Gas Limited","SK.2023.49","Sonangol Distribuidora","Petrobras","CFTC","Prateek Gupta","Trafigura v Gupta","Lex Oil","Mongolia","Myra Falls","Volare Shipping"] --- # Evidence records **Question.** Which records support the articles? **Answer.** Full assertions with source references, qualifications, responses and known outcomes. The topic articles explain these records in context. ## Trafigura Pte Ltd: registration, branches and accounts - Documented: Trafigura Pte Ltd (TPTE) is a private company limited by shares incorporated in Singapore on 7 March 1996 and registered with the Accounting and Corporate Regulatory Authority (ACRA) under number 199601595D, for an indefinite duration and with no other commercial name. Its registered office and principal place of business is 10 Collyer Quay, #29-01/05 Ocean Financial Centre, Singapore 049315. Its Legal Entity Identifier is 549300Z2X1L1L3MID765, first registered on 28 May 2013; the GLEIF record of October 2026 is fully corroborated against the Singapore register and gives the same registry number and address. Corporate-data aggregators relaying ACRA data list it in September 2026 as a live company that filed its last annual return on 9 February 2026, with the primary activity code SSIC 46610 (wholesale of fuels and related products) and the secondary code SSIC 64202 (holding companies). [s-d4] [s-d8] [s-d285] - Documented: Trafigura's base prospectuses for its EUR 3,000,000,000 Euro Medium Term Note programme, dated 10 May 2023 and 27 June 2025, describe TPTE as a wholly owned indirect subsidiary of Trafigura Group Pte. Ltd. (TGPL) that buys and sells oil commodities, was established in Singapore as the regional headquarters of the group's oil trading, is the focal point of the group's Asian branch network (offices in Brisbane, Jakarta, Mumbai, Seoul, Shanghai, Singapore, Tokyo and Ulaanbaatar) and is the principal entity through which the group's trading transactions are booked. The 2025 prospectus adds that the programme's issuer, Trafigura Funding S.A., lends the proceeds of its debt issues principally to TPTE, 'which performs treasury functions for the Group'. In evidence relayed by the Court of Appeal of the Dubai International Financial Centre (DIFC) Courts in September 2025, the group's former head of nickel and cobalt trading described TPTE as the main trading entity within the group. [s-d4] [s-d170] [s-d64] - Documented: In its modern slavery statement for the financial year to 30 September 2024, signed in March 2025, TPTE described itself as a global commodities trading company of the Trafigura group, headquartered in Singapore, that directly employed around 1,000 people, all permanent and in professional roles, in six offices in five countries; as a trading entity it sources, transforms and delivers physical commodities, including oil and petroleum products and metals and minerals, and also trades power. [s-d133] - Documented: TPTE operates through foreign branches. Its Geneva branch at 1 rue de Jargonnant, 1207 Geneva, leases the office from which TPTE's Maltese subsidiary Trafigura Nat Gas Limited planned to trade gas and provides that subsidiary with IT and staff, according to a 2024 report of Bulgaria's Energy and Water Regulatory Commission; an English High Court judgment of July 2025 also describes TPTE as a Singaporean commodity trading company with a branch office in Geneva. On 16 January 2026 Singapore's Minister for Finance made the Income Tax (Trafigura Pte Ltd — Section 13(12) Exemption) Order 2026, exempting from Singapore tax the profits that TPTE receives on or after 2 January 2026 from its branches in Montevideo, Uruguay, and Dubai, United Arab Emirates, on conditions set in a letter from the Inland Revenue Authority of Singapore; the text of the order is relayed by a corporate-data aggregator. [s-d177] [s-d247] [s-d280] - Documented: A corporate-data aggregator lists TPTE as a registered dealer in precious stones and precious metals under number PS20200001995, a registration the Ministry of Law of Singapore keeps for anti-money-laundering purposes, and as a member of the Singapore Business Federation (C0056924). Another aggregator lists TPTE in Panama's public register as a foreign company (sociedad extranjera), Mercantile folio No. 2239 (E), taxpayer number (RUC) 2438967-1-2239, active and registered more than ten years earlier, with one court case whose details are only in a paid report. It names among the persons connected with that registration the law firm Arias, Fabrega & Fabrega and, as legal representative, Edmundo Abdon Vidal Cornelio, who is a director of TPTE; it also names Soong Cent-Young, Juan Diego Charles Hubert Olaechea and five other people without stating their roles. [s-d12] [s-d59] [s-d280] - Qualification: Both records come from corporate-data aggregators; the Panamanian registry entry itself and the court case were not obtained. - Documented: A corporate-data aggregator of Panamanian public registers lists Edmundo Abdon Vidal Cornelio as an officer of one active Panamanian organisation, and Soong Cent-Young and Juan Diego Charles Hubert Olaechea each as an officer of one inactive organisation, whose names begin with 'TRAFIGURA'; the full names are behind a paywall. For each of the three it shows the same 28 connected directors, most of them shared with an organisation named ARIAS, and no licences, sanctions or debarments in the Panamanian regulatory sources it consolidates. [s-d26] [s-d58] [s-d100] - Qualification: The organisations are not named in the retained pages, so the record does not show whether they are TPTE's own Panamanian registration or another group company. - Documented: Corporate-data aggregators relaying ACRA records give TPTE's paid-up capital as S$6,100,002 in 6,100,002 ordinary shares denominated in Singapore dollars, 506 registered charges and, in September 2026, 40 registered officers; the chargeholders, officers and shareholders are shown only to paying subscribers. [s-d8] [s-d12] - Qualification: The figures are aggregator relays of the register, not an ACRA extract; one aggregator gives five officers in the same period. - Documented: Two corporate-data aggregators give shareholder data for TPTE that do not match the group's description of it as wholly owned. One records changes in the number of shareholders from 5 to 6 on 28 December 2024, from 38 to 39 on 7 July 2025 and from 39 to 40 on 20 September 2026. The other, in a profile updated on 14 April 2026, shows three shareholders with 50%, 47.75% and 2.25% of the shares, without names. [s-d8] [s-d139] - Qualification: Neither aggregator names a shareholder or its source. The group's prospectuses describe TPTE as a wholly owned indirect subsidiary of TGPL, and the 2024 report of the Bulgarian energy regulator, based on documents the group supplied, names TPTE Holding Limited (Malta) as TPTE's sole shareholder; no ACRA shareholder extract was obtained, so the discrepancy remains unexplained. - Documented: A business-information aggregator, using TPTE's latest accounts for 2025 in Singapore dollars, shows year-on-year falls of 9.67% in net sales, 25.91% in net profit, 9.92% in total equity and 0.14% in total assets; the amounts themselves are in a paid report. [s-d139] - Qualification: Only percentage changes are visible in the retained page; TPTE's own financial statements were not obtained. - Documented: TPTE's financial year ends on 30 September. The 2025 base prospectus names PricewaterhouseCoopers LLP of 7 Straits View, Marina One, Singapore, registered with ACRA as public accountants and certified public accountants, as TPTE's auditor for the financial years ended 30 September 2023 and 2024. [s-d4] ## Who owns Trafigura Pte Ltd: from TGPL to the Farringford Foundation - Documented: Trafigura Group Pte. Ltd. (TGPL), a Singapore company registered with ACRA under number 201017488D (LEI 549300HJ8VS88NIO3006) at the same Collyer Quay address as TPTE, is the holding company of the Trafigura group and is described in the group's prospectuses as TPTE's indirect parent; a 2026 rating-agency presale report likewise calls TPTE, Trafigura Asia Trading and Trafigura Trading LLC wholly owned subsidiaries of TGPL. In the GLEIF register, TPTE's record names TGPL as its direct parent by accounting consolidation; TGPL's own record reports exceptions instead of naming any parent and lists 'PUMA ENERGY HOLDING (SINGAPORE) PTE. LTD.' as a trading or operating name. [s-d4] [s-d77] [s-d9] - Documented: A 2024 report by the staff of Bulgaria's Energy and Water Regulatory Commission (KEVR) on the gas-trading licence application of Trafigura Nat Gas Limited sets out, from documents the applicant supplied, the legal chain above TPTE. TPTE's sole shareholder is TPTE Holding Limited, registered in Malta; TPTE Holding's sole shareholder is Trafigura Holding Sàrl of Switzerland; Trafigura Holding Sàrl and Trafigura Electricity B.V. are both wholly owned by Cortes Holdings S.à r.l. of Luxembourg, itself wholly owned by Cortes Investments S.à r.l. of Luxembourg; Cortes Investments is wholly owned by Trafigura Holdings Pte. Ltd. of Singapore, which is wholly owned by TGPL, whose sole shareholder is Trafigura Beheer B.V. of the Netherlands. [s-d177] - Documented: The same KEVR report records that the members of Trafigura Beheer B.V. are Trafigura Control Holdings Pte. Ltd. of Singapore, with 99% of the voting rights, and three Jersey holders: BDFH 2016 Nominee, Trafigura Trustees (Jersey) Limited and Trafigura Nominees (Jersey) Limited. Trafigura Control Holdings is owned by Farringford Foundation of Panama, which, according to the applicant, is a private-interest foundation without shareholders, controlled by the members of its council: Jeremy Weir, Pierre Lorinet, Andrew Vickerman and Mark Irwin. The regulator concluded that the foundation is the legal entity exercising indirect control over the applicant. [s-d177] - Documented: Because Panama was on the European Union's list of non-cooperative tax jurisdictions adopted on 26 February 2024, the KEVR report treated Trafigura Nat Gas Limited as indirectly controlled from a preferential tax jurisdiction, which Bulgarian law bars from licensing unless an exception applies. It found the exception for economic groups with a Bulgarian subsidiary satisfied, because TPTE's Bulgarian subsidiary Trafigura Bulgaria EOOD had entered in the Bulgarian commercial register, before the application of 21 November 2023, the natural persons who are beneficial owners of Farringford Foundation. The report notes that KEVR had refused the same company a gas-trading licence on 16 August 2023 (decision No. O-035) and ends with a proposal for the commission to consider the new application at an open meeting. [s-d177] - Qualification: The report is a staff proposal; the commission's decision on the 2023 application is not in the retained record. - Documented: The group's own accounts and an EU notice name Farringford Foundation as the ultimate controller. TGPL's annual report for the year to 30 September 2022, approved on 7 December 2022, states that its immediate holding company is Trafigura Beheer B.V., which is ultimately controlled by Farringford Foundation, established under the laws of Panama. The European Commission's notice of 10 July 2024 on case M.11551 (Trafigura / Vilma Oil / Vilma Med Oil) describes TGPL as controlled by Farringford Foundation. TGPL's half-year report for the six months to 31 March 2026 names Trafigura Control Holdings Pte. Ltd. as TGPL's ultimate parent company and states that Farringford Foundation has decisive voting power over it without any exposure, or rights, to variable returns from its involvement. [s-d76] [s-d6] [s-d42] - Documented: A notification of major holdings published on 6 February 2026, after Urion Holdings (Malta) Limited sold part of its interest in the London-listed Atalaya Mining Copper, S.A. on 4 February 2026, gives the full chain of controlled undertakings starting from the ultimate controlling entity: Farringford Foundation (Panama), Trafigura Control Holdings Pte. Ltd. (Singapore), Trafigura Beheer B.V. (Schiphol, Netherlands), TGPL, Trafigura Holdings Pte. Ltd. (Singapore), Trafigura Holdings Limited (Marsa, Malta) and Urion Holdings (Malta) Limited, which then held 10.94% of Atalaya's voting rights (16,821,212 votes). No natural person is named in the chain. [s-d21] - Documented: A transparency notification to the Belgian zinc producer Nyrstar NV about a threshold crossed on 27 December 2018 described a restructuring of the Trafigura group in which Cortes Investments S.à r.l. directly, and Trafigura Holdings Pte. Ltd. indirectly, acquired control of Trafigura B.V. The attached chain of control then ran from Farringford N.V. (Curaçao) through Farringford Malta Limited, Beheer Malta Limited, Trafigura Control Holdings S.à r.l. (Luxembourg), Trafigura Control Holdings Pte. Ltd., Trafigura Beheer B.V., TGPL, Trafigura Holdings Pte. Ltd. and Cortes Investments S.à r.l. to Urion Holdings (Malta) Limited. The notification stated that Farringford N.V. remained the ultimate controlling company and that, following the death of Claude Dauphin in 2015, no person controlled Farringford N.V. [s-d116] - Documented: Farringford N.V. is a Curaçao company registered under number 61251, created on 24 September 1992, at Pareraweg 45, Willemstad. Its GLEIF record (LEI 549300NLDV8DQ5WTJ223) shows the company as active but the identifier as lapsed since its renewal date of 13 October 2022, with reporting exceptions instead of parents. Relationship events in the GLEIF data, relayed by a corporate-data aggregator, show Farringford N.V. ceasing to be recorded as the ultimate parent of Trafigura Asia Trading Pte. Ltd. on 5 February 2022 and of Beheer Malta Ltd on 31 July 2023. [s-d130] [s-d131] - Documented: Farringford Foundation is a Panamanian private foundation registered under number 25040243. Its GLEIF record (LEI 213800Z5SG67869MF746, first issued on 10 February 2025 and partially corroborated) gives its legal and head-office address in care of the Panamanian law firm Arias, Fabrega & Fabrega, PH Arifa, West Boulevard, Santa Maria Business District, Panama City, records a creation date of 20 September 2024 and reports exceptions instead of naming parents. A Panamanian registry aggregator shows it as incorporated about seven years before October 2026; its council, founder and protector are shown there only to subscribers. [s-d28] [s-d22] - Qualification: The GLEIF creation date of 2024 does not match the aggregator's age of about seven years or the group's naming of the foundation as ultimate controller in its 2022 annual report; the foundation's own register entry was not obtained. - Documented: The intermediate holding companies are registered as follows. TPTE Holding Limited is a Maltese holding company, registration C 92866, at Oyia Business Centre, Cross Roads, Marsa; a Maltese-register aggregator shows that documents on its continuation in Malta were filed on 11 September 2019, so it moved to Malta from another jurisdiction, and that it has since filed annual returns (the latest dated 30 September 2025) and consolidated accounts; TGPL's 2022 annual report lists it among the group's principal consolidated operating subsidiaries. Trafigura Holdings Limited, registration C 55541, a Maltese holding company recorded from 2012, has the same Marsa address. Trafigura Holdings Pte. Ltd. (ACRA 201539314D) was incorporated in Singapore on 30 October 2015, is a holding company with paid-up capital of S$2,723,135,150 and is audited by PricewaterhouseCoopers LLP; it is the direct shareholder of the group's bond issuer Trafigura Funding S.A. Trafigura Control Holdings Pte. Ltd. (ACRA 201132622H), formerly Trafigura (Singapore) Trading Pte. Ltd., was incorporated on 9 November 2011, is a holding company audited by PricewaterhouseCoopers LLP and is registered at the Collyer Quay address. [s-d205] [s-d276] [s-d76] [s-d225] [s-d109] [s-d12] [s-d278] [s-d4] - Qualification: The registration details come from corporate-data aggregators relaying the Maltese and Singapore registers. - Documented: The group describes itself as employee-owned. Its 2023 and 2025 base prospectuses state that it is owned by approximately 1,100 and 1,400 senior employees respectively, selected each year at management's discretion; shares are issued and redeemed by Trafigura Beheer B.V. (TBBV), shares of departing employees are repurchased under conditions (holdings above USD 1 million in five yearly instalments, according to the 2023 text), all redemptions are discretionary, can be deferred indefinitely and depend on the group meeting its financial covenants, and no dividend reaches the final shareholders except through redemptions at TBBV, with dividends paid first from TGPL to TBBV. TGPL's 2022 annual report states that TBBV is exclusively owned by employees of the group, that employees receive TBBV preference shares carrying economic rights with limited voting rights, and that the board of Trafigura Control Holdings Pte. Ltd., a parent company of TBBV, decides the share awards in consultation with TGPL's board. The 2026 half-year report repeats that TBBV, TGPL's immediate parent, runs the equity participation plan open to employees. [s-d4] [s-d64] [s-d76] [s-d6] - Documented: Trafigura Beheer B.V. (TBBV) is a Dutch company registered in the Netherlands trade register under number 33236939 (LEI PX7SUPU7HUNJBQ8BPI65). Its GLEIF record of October 2026, fully corroborated, gives its legal and head-office address as 10 Collyer Quay, #29-01/05 Ocean Financial Centre, Singapore, after a change of legal address recorded on 28 May 2024, and still gives the Netherlands as its jurisdiction. The group's 2025 base prospectus calls TBBV 'the former parent company of Trafigura Group', while its 2022 annual report and 2026 half-year report call it TGPL's immediate parent. [s-d218] [s-d6] [s-d4] - Attributed: In May 2026 Trafigura told a Bermuda newspaper that Trafigura Beheer B.V., 'a former parent company of the Trafigura Group', was considering moving its legal domicile from the Netherlands to Bermuda because of the island's political stability and legal framework, and that it would remain tax-resident in Singapore. The newspaper added that TBBV was set up in the Netherlands in 1993 by former employees of the trading house Marc Rich + Co, was the group's parent until a 2015 restructuring made a Singapore company the parent, and remains, according to a financial news agency, the structure through which about 1,400 employees own shares. [s-d44] [s-d218] - Qualification: The plan is the company's own statement relayed by the press; the GLEIF record of 15 October 2026 still shows TBBV as a Dutch company, and no completed change of domicile is recorded. - Outcome: Not completed in the record by 15 October 2026: the GLEIF record still gives the Netherlands as TBBV's jurisdiction. - Documented: The Bulgarian commercial register, as relayed by an aggregator, recorded Mark Irwin, Pierre Lorinet, Jeremy Weir and Andrew Vickerman as the beneficial owners of Trafigura Bulgaria EOOD from 16 October 2023, deleted all four on 4 September 2025, and on 26 January 2026 entered Pierre Lorinet, Mark Irwin, Richard Holtum and Jeremy Weir. The KEVR report of 2024 explains these entries as the declared natural persons behind Farringford Foundation, the Panamanian foundation at the top of the chain. [s-d63] - Qualification: A beneficial-owner entry is a declaration made for the register; it does not show that these people hold shares in the company. ## Directors and officers of Trafigura Pte Ltd - Documented: The base prospectus of 10 May 2023 lists TPTE's directors as Stephan Arjan Jansma, Edmundo Abdon Vidal Cornelio and Tan Chin Hwee; the base prospectus of 27 June 2025 lists Andrew Philip Starkey, Edmundo Abdon Vidal Cornelio and Soong Cent-Young, all with the business address 10 Collyer Quay and no principal activities outside the group, and states that TPTE knows of no potential conflicts of interest between their duties to TPTE and their private interests. Soong Cent-Young (Jeff) signed TPTE's modern slavery statements as a director on 24 March 2025 and 27 March 2026. In October 2026 Starkey still listed TPTE among his current directorships, and a business-information aggregator listed Vidal Cornelio as a current director. [s-d64] [s-d4] [s-d16] [s-d133] [s-d25] [s-d75] - Documented: Tan Chin Hwee was TPTE's chief executive from January 2016 to March 2024, after serving as chief executive of Apollo Singapore Pte Ltd from 2007 to 2015, according to the announcement of his appointment as an independent director of Elite UK REIT Management published on the Singapore Exchange on 7 August 2024. The announcement lists as his directorships in the previous five years TPTE, Trafigura Services Pte. Ltd., Trafigura Overseas Projects Pte. Ltd., Trafigura Holdings Pte. Ltd., Trafigura Carbon Trading Pte. Ltd., Pan-African Soleil Holdings Pte. Ltd., Tendril Ventures Pte. Ltd., Tendril Ventures 2 Pte. Ltd., Cuscaden Peak Investments Private Limited and Singapore Chinese High School, and as present ones Singapore Trade Data Exchange Services Pte. Ltd., Commonwealth Concepts Pte. Ltd., Mt Sinai Capital Pte. Ltd. and Nanyang Technological University. An author page of a Singapore news site described him in 2020 as Trafigura's Asia-Pacific chief executive and a member of the Nanyang Technological University board of trustees. [s-d114] [s-d261] - Documented: Andrew Philip Starkey became Trafigura's chief financial officer for Asia Pacific, based in Singapore, in October 2024; before joining he was an executive director of the investment group Provident Capital Partners and, from 2016 to 2022, a managing director and co-founder of the private credit firm Pierfront Capital, later acquired and renamed Keppel Credit, and his earlier career included Goldman Sachs, Macquarie Group (managing director, 2011–2012) and Presidio Capital in Singapore (2012–2016). The information document of Volare Shipping Ltd. of October 2026 lists his current directorships as TPTE, Trafigura Holdings Pte. Ltd., Singapore Trade Data Exchange Services Pte. Ltd., Trafigura West Africa Pte. Ltd., Volare Shipping Ltd. and ten other companies, among them Trafigura Hong Kong Limited, Trafigura Japan K.K., Trafigura Malaysia Sdn. Bhd., Trafigura Philippines Inc. and Trafigura Vietnam Limited Company; Volare names him its chief financial officer and a board member. At the Indonesian mining company PT Merdeka Copper Gold Tbk he was a director from 27 January 2022 to 10 June 2025 and has been a commissioner since 10 June 2025; he was also a director of PT Merdeka Battery Materials Tbk from 30 June 2023 to 6 December 2024. Merdeka states that he has no affiliation with its controlling shareholder. [s-d24] [s-d75] [s-d67] [s-d61] [s-d143] [s-d65] - Documented: Edmundo Abdon Vidal Cornelio, a director of TPTE since at least May 2023, is also recorded in other group roles: he is one of the representatives of TPTE's Bulgarian subsidiary Trafigura Bulgaria EOOD from 16 October 2023, and a corporate-data aggregator relaying Mexico's register of companies with foreign investment lists him as legal representative of the mining company Compañía Minera Nuevo Monte S.A. de C.V. (file 77381, capital from the Netherlands, Mexico City). [s-d63] [s-d138] - Qualification: The Mexican entry is an aggregator relay without a date; the Bulgarian roles come from an aggregator of the Bulgarian commercial register. - Documented: Soong Cent-Young, a TPTE director, chairs the executive board of the Danish bunker-procurement company TFG Marine ApS (CVR 41401605, formed on 1 June 2020), whose annual report for 1 October 2024 – 30 September 2025 names Trafigura Group Pte. Ltd. as the intermediate parent that consolidates it; he is also a representative of Trafigura Bulgaria EOOD from 17 April 2024. [s-d29] [s-d63] - Documented: Stephan Arjan Jansma, a TPTE director in May 2023, joined Trafigura in 2013, served as chief financial officer for Asia Pacific in Singapore and as global head of structured and trade finance, and has been the group's chief financial officer and a member of its executive committee since July 2024; on 23 June 2026 he was appointed an executive director of the group's board. He is a Class A director of the group's bond issuer Trafigura Funding S.A. (2025), a manager of Trafigura Bulgaria EOOD from 17 August 2023, and, according to the UK companies register, a director of Impala Terminals UK Ltd. since 28 June 2024 and of Greenergy Group Limited since 10 December 2024, having also been a director of Greenergy Fuels Holdings Limited from 31 July to 10 December 2024. [s-d68] [s-d4] [s-d63] [s-d99] - Documented: Vincent Eric Boyer headed the Prague branch of Trafigura Trading (Europe) Sàrl (identification number 06262341, registered on 14 July 2017 for gas trading) as a member of its statutory body from 10 May 2022 to 12 January 2026, when another manager replaced him, according to the Czech public register. He has also been a manager of TPTE's Bulgarian subsidiary Trafigura Bulgaria EOOD since 3 September 2024, replacing Christophe Thierry Marie Salmon. [s-d252] [s-d101] [s-d63] - Documented: Maciej Sciazko, who signed the modern slavery statements of March 2025 and March 2026 as a director of Breakwater Resources Ltd and Myra Falls Mine Ltd., is listed by a business-information aggregator as head of mining operations at Trafigura Group Pte. Ltd., vice president of mining operations at Nyrstar Australia Pty Ltd. and a non-executive director of Euromax Resources Ltd. since 2025, and formerly chief executive and general manager of Lumina Copper Corp., a non-executive director of Skylark Minerals Ltd. (2018 – 30 September 2021) and general manager of Sierra Gorda SCM. [s-d16] [s-d133] [s-d128] ## The board of Trafigura Group Pte. Ltd. - Documented: The board of TGPL that signed the annual report on 7 December 2022 consisted of Mark Irwin, Pierre Lorinet, Andrew Vickerman, Jeremy Weir, José Larocca, Sipko Schat and Mike Wainwright. The 2025 base prospectus lists the board as Andrew Vickerman, Jeremy Weir (chairman), Mark Irwin, Pierre Lorinet, Sipko Schat and Richard Holtum (chief executive), with 16, 25, 'since inception', 24, 10 and 12 years with the group respectively as at 1 January 2025. The half-year report signed on 4 June 2026 lists Richard Holtum, Mark Irwin, Pierre Lorinet, Sergio Agapito Lires Rial, Sipko Schat and Jeremy Weir; Andrew Vickerman is no longer among them. [s-d76] [s-d4] [s-d6] - Documented: Jeremy Weir became non-executive chairman of Trafigura on 1 January 2025 after more than a decade as group chief executive, including over six years as executive chairman and chief executive; Richard Holtum is the group's chief executive. Weir joined the group in 2001 as head of metals derivatives, structured products and risk management and, before becoming chief executive, was a management board director, head of risk and chief executive of Galena Asset Management and Trafigura Mining Group; from 1992 to 2000 he worked at NM Rothschild. Spain's official commercial-register gazette (BORME) recorded his appointment on 4 November 2019 as a director and chairman of Minas de Aguas Teñidas SA when its management changed to a board, and a corporate-data aggregator relaying BORME shows him as a director (from 20 April 2016) and chairman (from 4 December 2018) of TM Mining Ventures SL until that company was absorbed by Minas de Aguas Teñidas in 2019, and as chairman of Minas de Aguas Teñidas until 10 February 2022. [s-d216] [s-d274] [s-d107] [s-d293] - Documented: Mark Irwin, a TGPL director with the group since its inception, is listed by a business-information aggregator as a director of Trafigura Beheer B.V. and TGPL (both from 31 December 2003), chief executive or managing director of the investment holding company Farringford N.V., a director of Trafigura Holdings Ltd. and of Immerse Learning Ltd., and an independent director of SAIS Ltd. from 5 June 2018. The UK companies register records him as a director of Trafigura Limited from 5 October 2006 to 4 April 2007, and as secretary of Tag Eco Recycling (UK) Limited (2001–2005) and of Galena Asset Management Limited (2003–2005), both since dissolved. [s-d92] [s-d94] - Qualification: The aggregator matches the name 'Trafigura Holdings Ltd.' without a registry number, so which company of that name is meant is not certain. - Documented: Pierre Lorinet, a TGPL director with 24 years in the group as at 1 January 2025, was appointed on 26 February 2010 a director of five UK companies recorded in the UK companies register: Penguin Metals Limited, Puffin Properties (Durham) Limited and Rookmanor Limited (all since dissolved), Sir Tom Cowie Holdings Limited (resigned 30 September 2015; since dissolved) and Impala Terminals UK Ltd. (resigned from two appointments on 25 October 2013 and 30 September 2015). [s-d93] - Documented: Andrew Vickerman, a TGPL director with 16 years in the group as at 1 January 2025, is recorded in the UK companies register as a director of Cambridge Energy Limited since 28 April 2020 and a designated member of Woodhouse Partners LLP from 11 March 2010 (since dissolved), and formerly as a director of Petropavlovsk PLC (22 October 2015 – 22 June 2017; now in liquidation), Penta Group Europe Limited (21 April 2010 – 1 June 2017) and Rio Tinto Pension Fund Trustees Limited (1 May 2008 – 28 February 2009). [s-d96] - Documented: Richard Holtum, TGPL's chief executive, was a director of the UK group company Trafigura Limited from 1 June 2023 to 2 December 2024, according to the UK companies register. The Czech public register lists him, with Jeremy Weir, among the members of the statutory body of the Geneva company Trafigura Trading (Europe) Sàrl recorded in the file of its Prague branch: Weir from 14 July 2017 to 11 February 2025 and Holtum from 9 December 2024 to 11 February 2025. [s-d95] [s-d252] ## Subsidiaries and group companies of Trafigura Pte Ltd - Documented: The group's joint modern slavery statements, signed in March 2025 and March 2026, list TPTE's own wholly owned subsidiaries that report separately under the Australian, UK and Canadian laws: Trafigura Asia Trading Pte. Ltd. (TAT, Singapore), Trafigura Canada Limited (TCL) and Breakwater Resources Ltd (Canada); Myra Falls Mine Ltd. is a wholly owned subsidiary of Breakwater. The statements describe Trafigura Trading LLC, the fifth reporting company, as a wholly owned indirect subsidiary of Trafigura Holding Sàrl rather than of TPTE. They state that TPTE also owns or controls entities in several countries that support its trading business or own relevant assets, among them oil terminals and refineries, mines and smelters, warehouses, vessels and bunkering, and service companies for treasury and financing, and holds interests in fund-management and investment entities with interests in smelters, rail projects, metals, retail, vessels and land. [s-d16] [s-d133] - Documented: Trafigura Asia Trading Pte. Ltd. (ACRA 201735628E, LEI 549300XHGYJB34H74E81) was registered in Singapore on 11 December 2017 as a commodity and futures broker and dealer and gold bullion dealer, at TPTE's Collyer Quay address, with paid-up capital of USD 1,000,100, according to corporate-data aggregators relaying ACRA (which give 14 and 11 registered officers). Its director See Wei Pei signed the 2025 and 2026 modern slavery statements on its behalf. In the GLEIF register TGPL is TAT's direct and ultimate parent by accounting consolidation, a relationship recorded from 19 November 2022 and fully corroborated for the accounting period to 30 September 2025. [s-d46] [s-d129] [s-d16] [s-d133] [s-d250] - Documented: Trafigura Canada Limited is a federal corporation under the Canada Business Corporations Act, number 1372276-7 (business number 841623945RC0002), formed on 1 February 2022 by the amalgamation of Trafigura Calgary Ltd. (6384676) and the earlier Trafigura Canada Limited (6384668), with its registered office in Calgary, according to the Corporations Canada register. Its directors are Phillip Craig Robinson, Sean Joseph McGreal, Dereje Tedla and Robert Ashbridge Kreider (both at 845 Texas Avenue, Houston, the address of Trafigura Trading LLC); the register records no individual with significant control (confirmed on 5 February 2026). McGreal signed the 2025 and 2026 modern slavery statements as a TCL director. A related federal corporation, Trafigura Commodities Marketing Limited (1451846-2, incorporated on 9 November 2022 as Trafigura Commodity Marketing Limited and renamed on 6 December 2022, with the same Calgary address), has as directors Kreider, McGreal and Bryan Joseph Chismar and likewise no individual with significant control (confirmed on 18 November 2025). [s-d48] [s-d111] [s-d112] [s-d16] [s-d133] [s-d108] [s-d172] - Documented: Trafigura Trading LLC (TTL), a co-guarantor with TPTE of the group's EMTN programme, is a Delaware limited liability company formed on 31 January 2015, when the Swiss company Trafigura AG (incorporated on 14 July 1995) re-domesticated to Delaware as Trafigura Inc. and was converted into an LLC; its main office is at 845 Texas Avenue, Houston. The 2025 base prospectus lists its management as Corey Prologo (president), Robert Kreider (company secretary), Dereje Tedla (treasurer) and Trafigura US Inc. (managing member). Florida's Division of Corporations registers it as a foreign LLC, document number M15000001366, federal employer identification number 06-1436098, with Trafigura US Inc. as its only authorised person (member) and annual reports filed for 2024–2026. [s-d4] [s-d275] - Documented: Trafigura Maritime Logistics Pte. Ltd. (TML; ACRA 201119446G, registered on 16 August 2011 for ship management and chartering at the Collyer Quay address, paid-up capital USD 8,384,978) provides shipping and freight services to the group's trading teams. On 21 September 2026 Trafigura announced a new group company, Volare Shipping Ltd. (ACRA 202605581W, incorporated on 4 February 2026 at the same address), to own a fleet of oil tankers — six very large crude carriers on the water, financed by bareboat leases with Bank of Communications Financial Leasing Co., Ltd., and eight on order at Hantong Shipbuilding for about USD 913 million — commercially managed by TML. Volare's information document for its admission to Euronext Growth Oslo on 5 October 2026 charts the group from TPTE through TML and Trafigura Volare Holdings B.V. (Netherlands, 100% owned by TML) to Volare; Volare's immediate holding company was TML until 4 March 2026 and Trafigura Volare Holdings from 5 March 2026, which held about 56.3% of the shares (about 53% if the over-allotment option is fully used) after a private placement of about USD 500 million, with about 600 shareholders in total. The document states that neither Volare nor any member of its group had been involved in material legal, governmental or arbitration proceedings in the previous 12 months. [s-d16] [s-d12] [s-d118] [s-d75] [s-d258] - Qualification: Corporate details of TML come from a corporate-data aggregator relaying ACRA; the Volare ownership chain comes from Volare's own information document. - Documented: Trafigura Nat Gas Limited is a Maltese company, registration C 52686 (LEI 549300QPXOTNOKWW3587), registered on 27 April 2011 at the Oyia Business Centre in Marsa, which GLEIF records as a direct subsidiary of TPTE by accounting consolidation. According to the Maltese register extract cited in the 2024 KEVR report, TPTE holds 9,999 of its 10,000 shares (99.99%) and Trafigura Electricity B.V. one share, and its directors are Robert Alexander Maas, Elian Malia, Christophe Thierry Marie Salmon and Elizabeth Sammut Borg. Its audited accounts show revenue rising from USD 52.6 million in 2020 to USD 349.1 million in 2021 and USD 761.1 million in 2022, with a profit of USD 2.29 million in 2022. It applied on 21 November 2023 for a Bulgarian gas-trading licence, after KEVR refused an earlier application on 16 August 2023. [s-d177] [s-d286] - Documented: In the GLEIF register of 15 October 2026 six legal entities report TPTE as their direct parent by accounting consolidation: Trafigura Philippines Inc, Trafigura Trading (UK) Limited, Trafigura Global Services Private Limited (India), Lykos India Private Limited, Trafigura Ventures V B.V. and Trafigura Nat Gas Limited. The list covers only entities that hold an LEI and report a parent; other TPTE subsidiaries, such as Trafigura Asia Trading, report TGPL instead. [s-d286] - Documented: Trafigura Bulgaria EOOD (Trafigura Bulgaria LLC, UIC 207453172), a single-member limited company in Sofia, was registered on 12 July 2023 with Kamburov & Partners Co. EOOD (UIC 175160121) as sole owner; on 17 August 2023 TPTE became the sole owner and Stephan Jansma the manager, according to an aggregator of the Bulgarian commercial register. Edmundo Abdon Vidal Cornelio, Jansma and Tan Chin Hwee were entered as representatives on 16 October 2023; on 17 April 2024 Tan was replaced by Soong Cent-Young and Juan Diego Charles Hubert Olaechea. Christophe Thierry Marie Salmon was a manager from 18 October 2023 until 3 September 2024, when Vincent Eric Boyer took his place. The company's capital is 100 leva, converted to 51 euros in February 2026. [s-d63] [s-d263] - Documented: Other Singapore group companies at TPTE's Collyer Quay address are tied to it through services or officers. Trafigura Overseas Projects Pte. Ltd. (ACRA 200810372Z, registered on 27 May 2008, paid-up capital USD 1) records its activity as the provision of human resource services to its related company Trafigura Pte. Ltd.; Tan Chin Hwee was among its directors. Trafigura West Africa Pte. Ltd. (ACRA 202347908E), incorporated on 6 December 2023 for wholesale of fuels, has TPTE director Andrew Starkey among its directors. These details come from corporate-data aggregators relaying ACRA. [s-d256] [s-d224] - Documented: Two UK companies whose directors include group executives are recorded in UK companies-register data relayed by a corporate-data aggregator: Trafigura Limited (company number 02737924, LEI 549300CUMQGCKKDP0S73), an active private company incorporated on 6 August 1992, and Impala Terminals UK Ltd. (company number 01238849), incorporated on 30 December 1975 as North European Marine Services Limited, renamed in January 2014 and now subject to a proposal to strike it off the register. Their shareholders are not in the record. [s-d136] [s-d254] ## Breakwater Resources and the Myra Falls mine - Documented: Breakwater Resources Ltd, a Vancouver-based mining company wholly owned by TPTE, owns Myra Falls Mine Ltd., which owns the Myra Falls zinc, copper, lead, gold and silver mine on Vancouver Island; the underground mine operated from 1966 to 2023 and is in care and maintenance. The present Breakwater Resources Ltd (British Columbia number 0922691) was formed on 13 October 2011 by the amalgamation of Nyrstar Canada Resources Ltd. (0912819) and the earlier Breakwater Resources Ltd. (C0921454), according to a notice in the BC Gazette. In a sworn statement to the Supreme Court of British Columbia, Myra Falls' general manager said that TPTE became an indirect majority shareholder of Nyrstar, the mine's owner, in 2019, and that Myra Falls Mine Ltd. was continued from the federal statute to British Columbia in 2013 under the name Nyrstar Myra Falls Ltd. and renamed in 2021. [s-d16] [s-d133] [s-d135] [s-d110] - Documented: On 18 December 2023 the Supreme Court of British Columbia (Vancouver Registry, No. S238572) granted Myra Falls Mine Ltd. an initial order under the Companies' Creditors Arrangement Act (CCAA), staying proceedings against it; an amended order of 28 December 2023 extended the stay to 29 February 2024 and authorised borrowing of up to $21,000,000 from the interim (DIP) lender, Trafigura US Inc. According to the general manager's affidavits, the company's sole source of financing since 2019 had been the Trafigura group, which lent it more than $100 million as shareholder loans; at 30 September 2023 it had total assets of about $214 million against liabilities of about $326 million and was, in his view, insolvent. Breakwater was its lender under a 2012 loan agreement (about $76.58 million owed on 30 November 2023, plus $4.23 million of unsecured interest-free advances), and Trafigura Canada Limited bought all its zinc and lead concentrate and some of its copper concentrate under offtake contracts of 1 January 2022. In February 2024 the company asked the court to extend the stay to 30 June 2024 and approve a sale and investment solicitation process. [s-d110] - Outcome: The record does not show the outcome of the requested stay extension or of the sale and investment solicitation process. - Documented: Canada's environmental offenders register records that on 19 October 2020 Breakwater Resources Ltd. pleaded guilty before the Court of Quebec in Val-d'Or to one count under subsection 36(3) of the Fisheries Act: on 28 February 2018 a 500-litre spill of flocculant into a drain connected to the tailings site of the Langlois mine at Lebel-sur-Quévillon had discharged an acutely lethal effluent into the Wedding River. The company was fined $350,000, directed to the Government of Canada's Environmental Damages Fund. [s-d174] [s-d64] - Qualification: The offence took place in February 2018, while the mine belonged to the Nyrstar group; the record shows TPTE becoming Nyrstar's indirect majority shareholder in 2019, and the group's 2023 prospectus says the Myra Falls and Langlois mines were transferred from Nyrstar to Trafigura's mining group in October 2020. - Outcome: Guilty plea and fine of $350,000 on 19 October 2020. ## How Trafigura Pte Ltd finances the group - Documented: TPTE is one of three guarantors, with TGPL and Trafigura Trading LLC, of the EUR 3,000,000,000 Euro Medium Term Note programme of Trafigura Funding S.A., under base prospectuses approved by the Central Bank of Ireland in May 2023 and June 2025 for notes to be listed on Euronext Dublin; ING Bank N.V. is the arranger. Trafigura Funding S.A. is a Luxembourg public limited company incorporated on 13 December 2012 (trade register B 173718), a special-purpose financing entity of the group with no operations or employees of its own, whose direct shareholder is Trafigura Holdings Pte. Ltd. [s-d4] - Documented: TPTE is the seller in the group's trade-receivables securitisation programme, Trafigura Securitisation Finance (TSF), set up in 2004. In a presale report of 7 April 2026 on the 2026-1 series (closing expected in June 2026), a credit-rating agency describes TPTE, Trafigura Asia Trading and Trafigura Trading LLC as the originators, with the latter two selling their receivables to TPTE, which sells them into the programme; TGPL is master servicer, Société Générale back-up servicer, matching agent and arranger, and Standard Chartered Bank the collection and transaction account bank. The receivables, from sales of crude oil, oil products, non-ferrous metals and concentrates, iron ore, coal and refined metals, totalled USD 4,357.53 million. [s-d77] - Documented: TGPL's unaudited half-year report for the six months to 31 March 2026 gives group revenue of USD 141.9 billion (USD 119.1 billion a year earlier), underlying EBITDA of USD 7.9 billion (USD 3.9 billion), net profit of USD 4.1 billion (USD 1.5 billion), total assets of USD 111.3 billion (USD 79.5 billion at 30 September 2025) and total equity of USD 17.5 billion (USD 16.2 billion). Figures for TPTE alone are not published in the retained record. [s-d6] - Documented: The 2024 interim report of Weihai City Commercial Bank Co., Ltd., listed in Hong Kong, names TPTE as the beneficial owner of a long position of 74,581,000 H shares at 30 June 2024, equal to 1.25% of all the bank's shares and 7.39% of its H shares. [s-d105] - Documented: TPTE is named among the founding members of SGTraDex, a Singapore trade-data exchange set up as a public-private partnership with the Infocomm Media Development Authority, PSA International, DBS, Jurong Port, OCBC, Ocean Network Express, Oiltanking, Pacific International Lines, Standard Chartered and UOB, on a corporate-data aggregator's page for DEX Digital Technologies Pte. Ltd. (ACRA 202206928W, formerly Singapore Trade Data Exchange (SGTraDex) Technologies Pte. Ltd., incorporated on 28 February 2022). A separate company, Singapore Trade Data Exchange Services Pte. Ltd. (ACRA 202131751Z, incorporated on 10 September 2021), of which TPTE directors past and present Andrew Starkey and Tan Chin Hwee were directors, resolved at an extraordinary general meeting on 29 June 2026 to wind up voluntarily, according to notices in Singapore's Government Gazette of 7 July 2026 relayed by the aggregator. [s-d260] [s-d223] - Qualification: The founding-member list is the platform's own description relayed by a corporate-data aggregator; no shareholding of TPTE is shown. - Documented: In 2022 a 30-year concession to operate and renovate the 1,300-kilometre Lobito railway in Angola and an associated mineral port terminal was awarded to the Lobito Atlantic Railway joint venture, in which Trafigura holds 49.5%; the group puts the investment at about USD 800 million over the concession. On 5 June 2023 the European Commission was notified that Trafigura Lobito Investments Pte Ltd (Singapore), a subsidiary of TGPL, and ME Lobito SGPS, LDA, a subsidiary of the Portuguese Mota-Engil group, would acquire joint control of the new Portuguese company Lobito Atlantic Holdings SGPS, LDA, whose operating subsidiary Lobito Atlantic Railway, S.A. will build, maintain and run the Lobito–Luau line linking the port of Lobito with the copper belt of Zambia and the Democratic Republic of Congo. [s-d4] [s-d27] - Documented: Galena Asset Management, founded in 2003, is the group's wholly owned and regulated investment subsidiary; regulated by the Swiss Financial Market Supervisory Authority (FINMA), it runs funds linked to the group's investments in mining, metals, energy, shipping and infrastructure in which third-party investors invest alongside the group. [s-d4] ## The Swiss case over bribery in Angola - Attributed: On 5 December 2023 the Office of the Attorney General of Switzerland (OAG) indicted Trafigura Beheer B.V. (TBBV) and three individuals before the Federal Criminal Court — the first case in which that court was asked to judge a company's criminal liability for bribing foreign public officials. According to the indictment, a former chief executive and executive board member of Sonangol Distribuidora SA, a subsidiary of the Angolan state oil company Sonangol EP, accepted from the Trafigura group between April 2009 and October 2011 bank transfers of EUR 4,346,176.60 to an account in Geneva, cash of USD 604,000 in Angola and hotel and meal costs of CHF 797.25, and in return enabled eight ship-chartering contracts and one bunkering contract between the group and Sonangol Distribuidora from June 2009 to July 2010, on which the group made profits of USD 143.7 million. A former employee acting through an offshore company as the group's intermediary in Angola, and a former chief operating officer and management board member of TBBV based in Geneva, were charged with paying the advantages; TBBV, then the group's parent company with branches in Geneva and Lucerne, was charged with failing to take all reasonable and necessary organisational measures to prevent the bribery, its internal rules on intermediaries being, according to the indictment, below international standards and not applied. The OAG had opened the case against persons unknown in July 2020, and on 5 December 2023 dropped the money-laundering charge against the former official. [s-d60] - Qualification: These are the prosecutors' charges; the indictment was subject to the presumption of innocence until judgment. - Response: At the trial in December 2024 TBBV defended itself on the basis of the compliance and anti-bribery and corruption controls it had in place at the time; when the trial was announced the company said it would have preferred an agreement with the prosecutors, that those historical controls fell short of today's standards and that 'these historical incidents in no way represent the company we are today'. - Outcome: At first instance, on 31 January 2025, the Federal Criminal Court convicted TBBV and the three individuals (case SK.2023.49); the reasoned judgment was sent to the parties on 3 November 2025, and Trafigura was reported in December 2025 to have appealed. No appeal decision is in the record, so the judgment is not final. - Documented: On 31 January 2025 the Criminal Chamber of the Swiss Federal Criminal Court (case SK.2023.49) convicted one company and three individuals of bribing a foreign public official. It found that A., a former senior employee of the Angolan state fuel distributor, accepted from 7 April 2009 to 20 October 2011 bank transfers of more than EUR 4 million, cash of a little over USD 600,000 and hotel and meal costs of about CHF 800, paid mostly into the Swiss account of his offshore company after passing through two intermediary companies, the second owned by B.; B., a former employee of the group (1995–2002) who served it from 2006 to 2011 through a British Virgin Islands company with an address in the United Arab Emirates, and C., then a member of the management board and chief operating officer of the parent company with responsibility for group compliance and the central coordination of payments to intermediaries, organised the payments. The company D.a, the group's parent at the time, was held liable because it had no internal rules on monitoring intermediaries and the use of the money paid to them, although its own code of business conduct described that corruption risk as very high. Sentences: A. 36 months (14 to be served) with confiscation of EUR 3,903,862 and USD 1,177,430 from his Swiss account and a compensatory claim of EUR 481,872, USD 710,570 and CHF 797; B. 24 months suspended; C. 32 months (12 to be served); D.a a fine of CHF 3 million and a compensatory claim of USD 145,634,268 in favour of the Confederation. [s-d122] [s-d154] [s-d4] - Qualification: The court's documents are anonymised. D.a is identified as TBBV because TBBV itself disclosed the same CHF 3 million fine and USD 145.6 million forfeiture in its 2025 bond prospectus; A., B. and C. are identified as Paulo Gouveia Júnior, the intermediary Thierry P. and Mike Wainwright through a Swiss non-governmental organisation's case summary and press reports that give the same roles, sentences and defence counsel. - Response: At the trial in December 2024 TBBV defended itself on the basis of the compliance and anti-bribery and corruption controls it had in place at the time; when the trial was announced the company said it would have preferred an agreement with the prosecutors, that those historical controls fell short of today's standards and that 'these historical incidents in no way represent the company we are today'. - Outcome: At first instance, on 31 January 2025, the Federal Criminal Court convicted TBBV and the three individuals (case SK.2023.49); the reasoned judgment was sent to the parties on 3 November 2025, and Trafigura was reported in December 2025 to have appealed. No appeal decision is in the record, so the judgment is not final. - Attributed: A Swiss non-governmental organisation that documents bribery cases involving commodity traders names the defendants in the Angolan case as Trafigura Beheer BV, its former chief operating officer and board member Michael (Mike) Wainwright, whom Trafigura had placed in retirement, Paulo Gouveia Júnior, the former head of Sonangol Distribuidora, and a Geneva intermediary, Thierry P. It reports that the court found that Wainwright had approved some of the payments and deleted certain data, and that all those convicted except Thierry P. announced an appeal. It sets the case in the context of the group's position in Angola in 2009–2011: a de facto monopoly on imports of petroleum products, a market of about USD 3.3 billion a year, a network of petrol stations built by Pumangol, a subsidiary of Puma Energy, under investment contracts worth USD 931 million signed by the Angolan presidency, and the sale of 20% of Puma Energy to Sonangol in 2011. [s-d152] - Qualification: This is a non-governmental organisation's summary; it names the anonymised defendants of the court's documents. - Response: At the trial in December 2024 TBBV defended itself on the basis of the compliance and anti-bribery and corruption controls it had in place at the time; when the trial was announced the company said it would have preferred an agreement with the prosecutors, that those historical controls fell short of today's standards and that 'these historical incidents in no way represent the company we are today'. - Outcome: At first instance, on 31 January 2025, the Federal Criminal Court convicted TBBV and the three individuals (case SK.2023.49); the reasoned judgment was sent to the parties on 3 November 2025, and Trafigura was reported in December 2025 to have appealed. No appeal decision is in the record, so the judgment is not final. - Attributed: A Portuguese news-agency report on the verdict describes Paulo Gouveia Júnior as chairman of the executive committee and executive board member of Sonangol Distribuidora from 24 July 2008 to 22 July 2010 and then of Sonangol's gas subsidiary until 5 October 2012, and says that, according to the prosecutors, he received about EUR 4.8 million in bribes in exchange for approving eight ship-chartering contracts and one supply contract that earned Trafigura about USD 145 million; he was sentenced to 36 months, 14 of them to be served. The report adds that Mike Wainwright had retired at the beginning of 2024 and that, according to the prosecutors, the group's founder Claude Dauphin, who died in 2015, had been the 'architect' of the scheme. [s-d233] - Qualification: A press report relaying the prosecutors' case; the statement about the late founder is the prosecutors' allegation, not a finding of the court recorded here. - Outcome: At first instance, on 31 January 2025, the Federal Criminal Court convicted TBBV and the three individuals (case SK.2023.49); the reasoned judgment was sent to the parties on 3 November 2025, and Trafigura was reported in December 2025 to have appealed. No appeal decision is in the record, so the judgment is not final. - Attributed: A financial news agency reported on 10 December 2025 that Trafigura had appealed the Swiss court's decision finding it guilty of not having sufficient systems to prevent bribery, after the January 2025 convictions of the company and its former chief operating officer Mike Wainwright over cash and gifts to an Angolan official in return for contracts in 2009–2011. The court's reasoned judgment had been sent to the parties on 3 November 2025, opening the time limit for a written declaration of appeal to the Appeals Chamber of the Federal Criminal Court. [s-d197] [s-d154] - Qualification: The appeal is known from a press report; its grounds and its outcome are not in the retained record. - Outcome: No appeal decision is in the record as of 15 October 2026. - Documented: Sonangol — Sociedade Nacional de Combustíveis de Angola, E.P. is a public enterprise created by Decree No. 52/76 and wholly owned by the Angolan state, with share capital of 1 trillion kwanzas at 31 December 2024 according to its corporate governance report, which is published by Angola's Capital Markets Commission (CMC); the CMC registered it as a bond issuer on 1 August 2023, at Rua Rainha Ginga 29-31, Luanda, under taxpayer number 5410003284. A corporate-data aggregator describes it as a state oil and gas company founded in Luanda in 1976 with 35 branches, subsidiaries and associates. [s-d243] [s-d55] [s-d132] - Documented: On 30 September 2021, through a series of linked transactions, the group acquired control of Puma Energy Holdings Pte. Ltd., a non-listed Singapore company, raising its stake to 96.7% by 30 September 2022, according to TGPL's 2022 annual report. One of the linked transactions was the purchase of the Puma Energy shares held by Sonangol, signed together with a transaction in which Sonangol bought Puma Energy's business in Angola for USD 600 million adjusted for working capital; that sale completed in the first quarter of the 2022 financial year for a final net consideration of USD 647.9 million. [s-d76] - Documented: TGPL's 2022 annual report includes among the group's other non-current loans receivable a debt agreement with the Ministry of Finance of Angola relating to compensation, after a consolidated Angolan subsidiary was liquidated in 2016, for iron-ore investments made by the group. The agreement was renegotiated in 2019 with a new repayment schedule; the ministry was unable to meet all its obligations because of low oil prices, a lack of liquidity and COVID-19, and in the 2022 financial year began regular payments, totalling USD 69 million. [s-d76] ## Bribery at Petrobras: the US plea and the Brazilian settlement - Documented: On 28 March 2024 Trafigura Beheer B.V. pleaded guilty in the United States to conspiracy to violate the anti-bribery provisions of the Foreign Corrupt Practices Act and agreed to pay a criminal fine of $80,488,040 and forfeiture of $46,510,257, with up to $26,829,346 of the fine credited against amounts paid to resolve a Brazilian investigation of related conduct (Justice Department press release No. 24-367; the case was prosecuted by the Criminal Division's Fraud Section and the U.S. Attorney's Office for the Southern District of Florida). According to the court documents, between about 2003 and 2014 Trafigura and its co-conspirators paid bribes to officials of Brazil's state-controlled oil company Petróleo Brasileiro S.A. (Petrobras) to obtain and keep its business; from 2009 they agreed, at meetings in Miami, on payments of up to 20 cents per barrel of oil products bought from or sold to Petrobras, concealed through shell companies and intermediaries who used offshore accounts to deliver cash in Brazil, and Trafigura made about $61 million in profit. The department credited the company's cooperation and remediation, including ending the use of third-party agents for business origination, but said it had at first failed to preserve and produce certain documents in time, had taken positions inconsistent with full cooperation and had been slow to discipline employees. It counted as prior misconduct a 2006 guilty plea by Trafigura AG for entry of goods by means of false statements — Trafigura AG is the Swiss company that became Trafigura Trading LLC in 2015 — and a 2010 conviction in the Netherlands for breaches of export and environmental law over the discharge of petroleum waste in Côte d'Ivoire. [s-d120] [s-d4] - Response: In its 2025 bond prospectus the group said the conduct in Brazil was inconsistent with its principles, contractual terms and code of conduct, and noted that the Justice Department had credited its cooperation and its 2019 decision to stop using third-party agents for business origination. - Outcome: In March 2025 TBBV settled on the same facts with the Brazilian authorities: the Justice Department credited USD 26.8 million towards that resolution and TBBV agreed to pay an additional USD 49 million. - Attributed: On 28 March 2025 Brazil's Office of the Comptroller General (CGU) and Office of the Attorney General of the Union (AGU) signed a leniency agreement with Trafigura Beheer B.V. under the Anti-Corruption Law (Law No. 12,846/2013), according to a Brazilian business news site relaying their announcement: the company had made improper payments to public agents between 2003 and 2014 to obtain privileged information on operations with Petrobras, and agreed to pay R$ 435,410,672.26 in fines and compensation to the Union and to Petrobras and to strengthen its compliance programme. The group's 2025 prospectus describes the same March 2025 resolution with the Brazilian authorities, on the facts covered by the US plea, with a USD 26.8 million credit from the Justice Department and an additional USD 49 million payment by TBBV. [s-d241] [s-d4] - Qualification: The CGU and AGU announcement itself was not retained; its terms are known from a news site and from the group's own summary. - Response: In its 2025 bond prospectus the group said the conduct in Brazil was inconsistent with its principles, contractual terms and code of conduct, and noted that the Justice Department had credited its cooperation and its 2019 decision to stop using third-party agents for business origination. - Outcome: In March 2025 TBBV settled on the same facts with the Brazilian authorities: the Justice Department credited USD 26.8 million towards that resolution and TBBV agreed to pay an additional USD 49 million. - Attributed: According to a Swiss non-governmental organisation, Mariano Marcondes Ferraz, a Trafigura executive until November 2016 who also prospected for the group in Angola, was sentenced in Brazil on 5 March 2018 and 30 October 2019 to 10 years and 4 months in prison for eight corrupt payments to Petrobras made through his own company Decal do Brasil; his cooperation reduced the sentence, and the Office of the Attorney General of Switzerland later convicted him for a ninth bribe in the same Brazilian case. [s-d152] - Qualification: The convictions are known from a non-governmental organisation's summary; the Brazilian and Swiss judgments were not retained. - Documented: Petróleo Brasileiro S.A. (Petrobras) is controlled by the Brazilian state: in its September 2026 shareholder disclosure the controlling group holds 35.45% of the share capital, of which the federal government holds 29.02% of all shares and 50.26% of the ordinary shares, BNDESPar 5.38% and BNDES 1.05%. [s-d183] ## The CFTC order, the 2017 China case and the North Korea cargo - Documented: On 17 June 2024 the US Commodity Futures Trading Commission (CFTC) issued an order simultaneously filing and settling charges against Trafigura Trading LLC of Houston (docket No. 24-08), requiring a civil monetary penalty of $55 million and remedial measures. The order found three violations of the Commodity Exchange Act: trading gasoline from 2014 to April 2019 while in knowing possession of material non-public information misappropriated from a Mexican trading entity, obtained directly and through intermediaries; manipulating the US Gulf Coast high-sulphur fuel oil benchmark in February 2017 to benefit its futures and swaps positions; and requiring employees from 2017 to 2020 to sign non-disclosure terms with no exception for regulators, the first CFTC action against a company for impeding whistleblower communications. The order describes Trafigura Trading LLC as a related company of 'Trafigura PTE, Ltd.' ('PTE'), a commodity trading firm registered in Singapore, and records that in January 2017, under an export programme to exploit a fuel-oil price arbitrage between the US Gulf Coast and Singapore, its traders contracted to sell about 3.5 million barrels of high-sulphur fuel oil to PTE for delivery in Singapore in February to April 2017. [s-d175] [s-d4] [s-d211] - Response: Trafigura Trading LLC consented to the order without admitting or denying its findings; the order records its representation that it has since enhanced its market-integrity policies, communications controls, employee training and compliance testing, and the group says it has strengthened its compliance programme. - Outcome: Settled by the order of 17 June 2024, which requires the $55 million penalty within ten business days, a cease-and-desist order and remedial undertakings. - Attributed: A news agency reported on 24 August 2017, citing a letter of indictment, that prosecutors in Langfang, Hebei province, had on 4 August 2017 charged 'Trafigura (Singapore) Pte Ltd' and its Beijing-based oil marketer Tian Meng with fraudulently obtaining bank credit through fabricated gasoline deals with the private Chinese trader Qingdao United Energy, and a shareholder of that trader, Zhang Wei, with conspiring with Tian. The case began with Qingdao United Energy's complaint that it had lost $32 million in trade-financing deals arranged without its knowledge; Tian was arrested in August 2014 and released on bail two years later, and the Singapore entity was charged as the Qingdao firm's counterparty. As part of the probe, the report said, the Chinese authorities froze $32.9 million that Trafigura Pte Ltd had injected into a metals project in south-western China jointly owned with the metals producer Jinchuan Group Co Ltd, which the group's 2023 prospectus lists among the major clients of its metals business. [s-d210] [s-d64] [s-d278] - Qualification: The charges are known only from a press report of 2017; the indictment names 'Trafigura (Singapore) Pte Ltd' rather than TPTE's registered name — a corporate-data aggregator shows a newspaper version of the report on the page of Trafigura Control Holdings Pte. Ltd., formerly Trafigura (Singapore) Trading Pte. Ltd., without identifying the charged company — and the outcome of the case and of the asset freeze is not in the record. - Response: Trafigura declined to comment; senior sources at the company were reported to have repeatedly said it regarded the matter as a commercial dispute and not one for the police or prosecutors. - Attributed: In January 2018, according to a business news agency, South Korea's foreign ministry said that Trafigura Group owned the cargo of the tanker Lighthouse Winmore, suspected of transferring about 600 tonnes of oil products to the North Korean vessel Sam Jong 2 at sea on 19 October 2017 in breach of United Nations sanctions, and that it was investigating whether Trafigura had ordered the transfer; South Korea identified the ship's charterer as Billions Bunker Group of Taiwan. [s-d245] - Qualification: This is a government's statement relayed by the press during an investigation; no finding against the group is in the record. - Response: Within hours Trafigura denied any involvement: it neither owned nor chartered the ship, had sold the cargo to the Hong Kong company Global Commodities Consultants Ltd., which resold it to Oceanic Enterprise Ltd., and both sellers said their contracts required any resale to comply with international sanctions. - Unresolved: A research dataset on North Korean sanctions evasion, relayed by a sanctions-data aggregator and last changed on 25 March 2024, lists an entity named 'Trafigura Pte. Ltd.' as shipper of refined petroleum transferred to North Korea by the vessels Lighthouse Winmore (IMO 9635987) and Billions No. 18 (IMO 9191773), describing Trafigura as registered in the Netherlands, headquartered in Geneva, with its oil operations in Singapore. The entry carries no registry number and no sanctions or risk topic. [s-d244] [s-d10] [s-d245] - Qualification: The entry matches TPTE's name and the group's description but gives no registry number, so it does not establish that TPTE was the shipper; the government statement of January 2018 concerned 'Trafigura Group', which denied involvement. - Response: Trafigura denied any involvement in the Lighthouse Winmore transfer in January 2018, saying it neither owned nor chartered the ship and had sold the cargo to a Hong Kong company under a contract requiring sanctions compliance. - Documented: A name screening of 'Trafigura Pte. Ltd.' run on 15 October 2026 against a sanctions and politically-exposed-persons data aggregator returned one candidate, a record of Trafigura Group Pte Ltd (LEI 549300HJ8VS88NIO3006) drawn only from an energy-ownership dataset, with no sanctions, politically-exposed-person or other risk topic and no sanctions programme. [s-d10] - Qualification: A name screening returns candidates, not a complete search; it does not establish that no listing exists under another name or in another dataset. ## Other lawsuits of Trafigura Pte Ltd - Documented: In High Court Suit No 1055 of 2019 in Singapore, United Petroleum Trading Limited claimed from TPTE three sums – US$4.4 million, US$1.38 million and US$2.5 million – which it said it had paid as initial margin under an agreement for TPTE to trade gasoline futures on its behalf, seeking their return because the agreement was void for illegality or because TPTE had failed to trade, so that consideration had totally failed. TPTE denied the alleged agreement, said the three sums were owed to it under a different agreement and applied to strike out the claims. On 23 September 2021 the Appellate Division of the High Court ([2021] SGHC(A) 13, Civil Appeal No 48 of 2021) dismissed United Petroleum Trading's appeal against the striking out of the claims for the first two sums, which it held clearly time-barred, and ordered it to pay TPTE costs of $30,000; the claim for US$2.5 million was not time-barred and was proceeding to trial. [s-d12] [s-d49] - Qualification: The outcome of the trial of the remaining US$2.5 million claim is not in the record. - Response: TPTE denied that the alleged futures-trading agreement existed and said the sums were owed to it under another agreement. - Outcome: Appeal dismissed on 23 September 2021 with costs of $30,000 to TPTE; the US$2.5 million claim continued to trial. - Documented: TPTE, as owner of a bulk cargo of zinc calcine shipped on the Thorco Lineage from the United States to Australia under a bill of lading issued in Switzerland, claimed in arbitration against the carrier TKK Shipping Pte Ltd after the vessel lost power and grounded on Raroia Atoll in French Polynesia; for the question of law it was assumed that the carrier's breach had caused TPTE losses including a liability of USD 7,355,000 to the salvors and USD 723,831.85 of onshipment costs. On 13 January 2023 the English Commercial Court ([2023] EWHC 26 (Comm), Sir Nigel Teare) held that the carrier's limit of liability for TPTE's salvage liability and onshipment costs is calculated at 2 SDRs per kilo of the whole cargo, as TPTE had argued, rather than only of the physically damaged goods, and that this limit apparently exceeds the carrier's liability, according to a maritime-law case database's summary of the judgment. [s-d201] - Qualification: The judgment itself was not retained; its holding is taken from a case-law database's summary. - Documented: On 4 July 2025 Mr Justice Henshaw in the English Commercial Court ([2025] EWHC 1684 (Comm)) granted TPTE summary judgment, with interest and costs summarily assessed at £190,000, against El Soobat Energy Co Ltd, a private company registered in Sudan which did not appear and was not represented. TPTE had issued the claim on 28 May 2021 for sums due to it as seller under a contract of 17 January 2020 for the sale of gasoline; the amount claimed, originally USD 3,114,383.52, was revised to USD 2,118,534.49. [s-d247] - Outcome: Summary judgment for TPTE on its claims, including interest, and costs of £190,000. - Documented: Rasmala Trade Finance Fund sued TPTE in England to recover five payments totalling over $22.6 million that it made to TPTE between August 2017 and March 2018, believing it was financing coal-supply contracts between TPTE and the coal trader Farlin Energy & Commodities FZE. Farlin, a TPTE customer since September 2015 whose open credit limit TPTE raised from about $2 million to $11 million in December 2016, with half the limit insured, had forged both those contracts and the tri-partite agreements by which Rasmala appeared to consent to TPTE applying the money to Farlin's existing debts. Rasmala's pleaded case was that Trafigura was party to the fraud; at the start of the trial it withdrew most of its dishonesty allegations, and the judge rejected as hopeless the remaining contention that a Trafigura employee, and hence Trafigura, had acted dishonestly. In his judgment of 23 June 2025 ([2025] EWHC 1569 (Ch)) Rajah J accepted that TPTE had been enriched at Rasmala's expense but dismissed the claim on TPTE's defence of change of position: relying on the payments, TPTE had kept trading with Farlin, entering new contracts worth just under $60 million between September 2017 and May 2018, and when Farlin stopped trading it was owed slightly more than before the first payment. On 7 October 2026 the Court of Appeal (Baker, Nugee and Falk LJJ; [2026] EWCA Civ 1259) dismissed Rasmala's appeal. [s-d214] [s-d248] - Response: Rasmala alleged that Trafigura was party to Farlin's fraud; it withdrew most of those allegations at trial and the remaining allegation of dishonesty was rejected, without permission to appeal. - Outcome: Claim dismissed on 23 June 2025; appeal dismissed on 7 October 2026. - Documented: Hin Leong Trading (Pte.) Ltd., a Singapore wholesaler of fuels registered on 25 July 1973 (UEN 197301412M) and now in compulsory liquidation, applied through its liquidators, with two related companies, for schemes of arrangement (HC/OA 555/2024 and HC/OA 726/2024). In the High Court's judgment of 15 October 2024 ([2024] SGHC 256, Justice Andre Maniam) TPTE is listed among the named non-parties, with Skomer Investments Designated Activity Company and eight banks: HSBC, DBS, ING, Rabobank, Société Générale, Crédit Agricole, OCBC and ABN Amro. Under the scheme, US$80 million was to be distributed pari passu among all scheme creditors, who would recover about 1.7% of their admitted claims. [s-d12] [s-d106] [s-d140] - Qualification: The judgment lists TPTE as a named non-party without stating its interest; whether TPTE is a creditor of Hin Leong is not in the record. ## The Prateek Gupta nickel fraud against Trafigura Pte Ltd - Documented: In admiralty proceedings HC/ADM 14/2023 in the High Court of Singapore, Hyphen Trading Limited, a UK commodity trader, claimed title to a cargo of nickel briquettes held at a Henry Bath LME warehouse in Port Klang, Malaysia, against the carrier BLPL Singapore Pte Ltd and against TPTE and Trafigura India Pvt Ltd as second and third defendants. TPTE and Trafigura India contended that Trafigura India held the true original bills of lading, recognised by the carrier, for shipment from Pasir Gudang in Malaysia to Nhava Sheva in India; the bills held by Hyphen bore the same numbers but named a different shipper. The English High Court had granted TPTE and Trafigura India a worldwide freezing injunction against various parties, and on 10 February 2023 their English solicitors asked the carrier to let no one other than Trafigura India interfere with the cargo. After hearings on 18 August and 13 September 2023, Justice S Mohan dismissed Hyphen's application (SUM 2034) for the sale of the cargo pending trial and fixed costs of S$14,000 payable by Hyphen to Trafigura India, giving his grounds on 25 October 2023 ([2023] SGHC 302). The English Commercial Court's judgment of January 2026 records that Trafigura then settled with Hyphen under a confidential global settlement agreement and is entitled to recover the sum it paid from defendants in its nickel-fraud claim. Hyphen Trading Limited is registered in England and Wales (company number 09486089, formerly Broadlands Residential Limited until May 2016); according to UK companies-register data relayed by a corporate-data aggregator, its corporate person with significant control since 19 May 2016 is Hyphen Resources Limited, which the GLEIF register shows as renamed RB International (UK) Limited with effect from 28 March 2022. [s-d12] [s-d50] [s-d52] [s-d162] [s-d167] [s-d137] - Qualification: The amount of the settlement with Hyphen is confidential and is not in the record. - Outcome: Hyphen's application for sale of the cargo was dismissed on 13 September 2023 with costs of S$14,000 to Trafigura India; the dispute was later settled. - Documented: On 8 February 2023 TPTE and Trafigura India Pvt Ltd, the group's Indian trading subsidiary, sued Prateek Gupta and seven companies in the Commercial Court in London (claim CL-2023-000054): UIL (Singapore) Pte Ltd, UIL Malaysia Ltd, TMT Metals AG, TMT Metals (UK) Ltd, Spring Metal Ltd, Mine Craft Limited and New Alloys Trading Pte Ltd. Mr Justice Foxton granted a worldwide freezing order against the defendants the same day, continued by Mr Justice Bright on 24 February 2023; an application by Mr Gupta and four of the companies to discharge it was dismissed on 15 December 2023. The seven companies had signed master contracts with TPTE for the supply of nickel between 6 October 2021 and 17 August 2022; in the period at issue TPTE traded 542 cargoes of what purported to be nickel with them, worth about US$3.3 billion, and the claim concerned 107 cargoes for which TPTE paid them about US$500 million. In his judgment of 30 January 2026 ([2026] EWHC 159 (Comm)) Mr Justice Saini held that Trafigura had been the victim of a fraud on a grand scale devised and implemented by Mr Gupta using the corporate defendants, which had supplied cargoes of low-value or worthless material while purporting to sell LME-grade nickel. He upheld the claims in fraudulent misrepresentation, deceit and unlawful-means conspiracy, allowed TPTE to rescind 91 main trades and declared an equitable proprietary interest in a net US$489,786,311.72, into which tracing is left to a second phase, found Mr Gupta personally liable for around US$500 million, and awarded US$6,639,926.82 against Mr Gupta and UIL Malaysia over duplicate bills of lading. The judge found that Mr Gupta was the ultimate beneficial owner or controller of UD Trading Group Holding Pte Limited, the de facto or legal controller, an indirect shareholder and a director of UIL Singapore, UIL Malaysia and TMT Metals AG, and the de facto or legal controller of TMT Metals (UK); Spring Metal, Mine Craft and New Alloys, whose association Mr Gupta denied, were 'plainly fronts for him'. UIL Singapore was ordered wound up on 28 November 2025, TMT Metals AG and New Alloys are in liquidation, and UIL Malaysia and Spring Metal have been struck off the Labuan register. The group recorded a charge of USD 577 million for the fraud in the first half of 2023, which it estimated as its maximum loss exposure. [s-d64] [s-d4] [s-d167] [s-d170] [s-d124] - Response: Mr Gupta and four of the companies defended the claim on the basis of an 'Arrangement' which, they said, he had agreed with two Trafigura nickel traders at a meeting in Dubai on 5 June 2019: a scheme of false shipping documents under which Trafigura knowingly bought material that might not be nickel for later sale back under a repo financing structure. The judge found that there was no such Arrangement, only a scheme on its lines devised by Mr Gupta and hidden from Trafigura, and recorded that the two former Trafigura employees accused of taking part were wholly innocent of any wrongdoing. The group had said from the start that there was no evidence that anyone at Trafigura was involved or complicit. - Outcome: Judgment for TPTE on its principal causes of action on 30 January 2026; tracing of the proprietary funds and Trafigura India's related claim are left to a second phase. - Documented: To secure assets for the English claim, TPTE and Trafigura India obtained on 25 April 2023 an English 'Chabra' injunction over certain assets of Ginni Gupta, Prateek Gupta's wife, who is not a defendant in England and against whom no cause of action is pleaded, on the basis that they had reason to believe she held assets on his behalf. In the courts of the Dubai International Financial Centre (DIFC) freezing orders against both spouses were made on 26 April 2025; on 22 September 2025 the DIFC Court of Appeal ([2025] DIFC CA 001; Chief Justice Wayne Martin, Justice Robert French and Justice Sir Peter Gross) allowed the Trafigura companies' appeal, continued the orders and ordered the respondents to pay the costs of the adjourned hearing. In DIFC case CFI 040/2025 the claimants turned to the onshore Dubai courts: on 13 November 2025 they applied to the execution judge for a precautionary attachment of the defendants' funds up to USD 625,000,000, and on 19 December 2025 the execution judge authorised attachment of properties registered to Vision Investments Ltd, described as Ginni Gupta's company, which the Dubai Land Department reported on 8 January 2026 as executed, together with an attachment of 12 units belonging to Vision; on 12 February 2026 a Dubai judge rejected the claimants' application of the previous day for her arrest and summons. By an order with reasons issued on 9 September 2026 Justice Robert French continued the DIFC freezing order until 1 February 2027, adding a 21-day notice requirement for dealings in the scheduled assets, required the claimants to undertake not to enforce it outside the UAE without permission, dismissed their request for disclosure of the source of the defendants' legal fees, and dismissed Ginni Gupta's application to discharge the interim order, with costs against her. According to a barristers' chambers summarising that order, the court held that the so-called conduit jurisdiction is not available for the onshore enforcement of DIFC freezing orders, and the English judgment of January 2026 against Mr Gupta is for over $700 million. [s-d170] [s-d202] [s-d203] - Qualification: Ginni Gupta is not a defendant to the fraud claim; the orders against her rest on the claimants' belief that she holds assets for her husband, and the record contains no finding of wrongdoing against her. - Response: Ginni Gupta opposed the orders: she argued that the claimants had to show by solid evidence an objective risk that the Vision properties would be dissipated, that she had given the required notice before selling a Dubai villa and that the sale involved no dissipation, and that a freezing order, being an interim order and not final and executory, could not be enforced onshore as though she were a judgment debtor. - Outcome: The DIFC freezing order stands until 1 February 2027; onshore attachment was obtained over properties of Vision Investments Ltd, while the application for Ginni Gupta's arrest was rejected and the court held the conduit route unavailable for onshore enforcement. ## The USD 1.1 billion loss in Trafigura's Mongolian oil business - Documented: The group's 2025 bond prospectus states that an internal review and an external forensic investigation in the financial year to 30 September 2024 uncovered serious misconduct by individuals in its Mongolian petroleum products supply business, including deliberate manipulation of data and documents that inflated amounts paid by the group and deliberate concealment of overdue receivables, accumulated over about five years. It recorded a cumulative loss of USD 1.1 billion: USD 614.7 million for the 2022 and earlier financial years and USD 127.8 million for 2023 — together USD 742.5 million of write-offs (USD 533.6 million) and expected credit losses (USD 208.9 million), booked by restating the prior-year accounts — and USD 357.5 million for 2024 as an expected credit loss. Revenue for 2023 had been overstated by USD 1,407 million and was corrected. The prospectus adds that the misconduct involved a complex chain of transactions with a small number of local counterparties. A substantial proportion of the exposure has been acknowledged as a debt owed by the group's principal counterparty in Mongolia; the external investigation was continuing. [s-d4] [s-d230] [s-d291] - Response: Without naming the counterparty or any employee, the group said in October 2024 that it was taking appropriate disciplinary action and that a risk review of higher-risk locations in its network had produced no significant findings; in the 2024 annual report its chief executive said that, having reviewed other higher-risk offices and lines of business, the group was confident the issues were isolated to a self-contained operation in Mongolia. The 2025 prospectus says the group is implementing the recommendations of the external review undertaken in response. - Outcome: The group recorded the cumulative USD 1.1 billion loss, USD 357.5 million of it in the 2024 financial year and the rest by restating earlier years; the external investigation was still continuing in June 2025, and the record contains no court case or finding by an authority about the misconduct. - Attributed: According to an account by a business news agency republished by a mining news site on 3 November 2024, the group's main counterpart in Mongolia was the local distributor Lex Oil LLC, which took Trafigura's oil products on credit and sold them on to fuel retailers, paying later after deductions for customs and freight; Lex Oil's debt was said to be more than half of the $1.1 billion loss. Trafigura's main oil trader in Mongolia, Jononbayar Erdenesuren, with the company since 2012, was among employees suspended; the company stopped new business in the country and terminated the contract of its Singapore-based head of Mongolia, Mikhail Zeldovich, who declined to comment. Senior executive José Larocca had flown to Mongolia in February 2024 to meet Lex Oil, and the company said at the time that it had recently agreed debt repayment schedules with oil-products customers in Mongolia. Lex Oil did not respond to the agency's questions. [s-d124] - Qualification: These are press accounts based on unnamed people familiar with the matter; the group has not named its Mongolian counterparty or any employee, and the record contains no finding by a court or authority about any individual. - Response: A representative for Mr Jononbayar declined to comment in November 2024, saying he was still an employee of Trafigura and bound by a confidentiality agreement; in March 2025 he did not reply to requests for comment, and a Mongolian news site reported in April 2025 that he had complained to the courts and the police about publications on the missing $1.1 billion, which neither could confirm. Trafigura said it intended to hold its counterparty to its repayment obligation, and that with an external investigation under way it had not been in a position to comment on Mongolia earlier. - Outcome: According to the same account, Trafigura stopped new business in Mongolia, suspended Mr Jononbayar, terminated Mr Zeldovich's contract and recorded a provision of $1.1 billion, while still hoping to recover money from Lex Oil. - Attributed: A news agency reported on 25 March 2025, citing three sources close to Trafigura and an undated ownership document from Mongolia's state registration department, that Lex Oil, Trafigura's principal counterparty in Mongolia, had belonged to an aunt of the suspended local head Jononbayar Erdenesuren, who had sold fuel and lent over $500 million of Trafigura's money to the firm; according to a screenshot of the ownership document she sold Lex Oil in 2022 to her husband. A Mongolian government source told the agency that the government elected in 2024 had opened an investigation into the case, but that it was too early to disclose findings. A shipping news site relayed the report the next day. [s-d291] [s-d230] - Qualification: These are press accounts based on unnamed people familiar with the matter; the group has not named its Mongolian counterparty or any employee, and the record contains no finding by a court or authority about any individual. The agency was unable to find documents showing that Trafigura lent funds to Lex Oil. - Response: A Trafigura spokesperson said an external investigation was ongoing and declined to say which staff had been suspended or whether the company knew of the family link. Mr Jononbayar, his aunt, Lex Oil and a lawyer for the firm did not reply to requests for comment. - Outcome: A Mongolian government source said an investigation had been opened but that it was too early to disclose findings; no result is in the record. - Attributed: A Mongolian news site reported on 7 April 2025 that E. Jononbayar had been released from his post as executive director of Trafigura Mongolia, at about the time Richard Holtum succeeded Jeremy Weir as the group's chief executive on 1 January 2025, and that he was being named in the press as the person responsible for the $1.1 billion loss. Citing earlier reports, it wrote that Lex Oil had acknowledged owing Trafigura more than half of the $1.1 billion, that what had happened to the remaining roughly $500 million was unclear, and that Lex Oil was in court disputes with mining companies that owed it money; the authorities had not confirmed whether Mr Jononbayar was under investigation, and Trafigura's detailed investigation was continuing. [s-d206] - Qualification: These are press accounts based on unnamed people familiar with the matter; the group has not named its Mongolian counterparty or any employee, and the record contains no finding by a court or authority about any individual. - Response: A representative for Mr Jononbayar declined to comment in November 2024, saying he was still an employee of Trafigura and bound by a confidentiality agreement; in March 2025 he did not reply to requests for comment, and a Mongolian news site reported in April 2025 that he had complained to the courts and the police about publications on the missing $1.1 billion, which neither could confirm. - Documented: A Mongolian open-data aggregator's copy of the state register shows Eltranika LLC (registration 5114179, founded on 26 January 2007; foreign trade, road freight, import of mining equipment, lubricants and consumer goods, and warehousing), registered on the second floor of the Landmark tower on Chinggis Avenue in Ulaanbaatar, as owned since its foundation by the Mongolian legal entity Trafigura Mongolia LLC, which TGPL's 2022 annual report lists among the group's principal consolidated operating subsidiaries. Its executive directors were Mikhail Zeldovich, appointed on 19 September 2014 and since removed, and from 10 February 2025 Soong Cent-Young, a director of TPTE; Jeremy Weir is registered as its ultimate owner from 7 October 2024. The same aggregator shows Lex Oil LLC (registration 5623979, founded on 10 August 2012) registered in the Landmark office building on Chinggis Avenue until a change of 3 June 2025 moved it to Paradise Plaza; its register lists a corporate shareholder from 1 April 2019 and two successive individual shareholders, the second from 19 April 2023, who is also recorded as its ultimate owner. [s-d125] [s-d158] [s-d76] - Qualification: The register copy does not state the basis on which Jeremy Weir is recorded as ultimate owner; the registered shareholder is Trafigura Mongolia LLC, whose own shareholders are not in the record. - Documented: In a ruling of 25 January 2018 (001/ХТ2018/00158) in a wrongful-dismissal case, the Supreme Court of Mongolia reinstated a terminal manager of an employer anonymised as 'T LLC' and ordered it to pay her MNT 25,099,727, amending the lower courts' decisions. The employee had stated that she was dismissed on 1 February 2017 in the meeting room of Trafigura Mongolia LLC's Ulaanbaatar office, at a meeting with M.S. Zeldovich, director of Trafigura Mongolia LLC, and E. Jononbayar, director of 'T LLC', on the strength of an email from the Singapore office. [s-d161] - Qualification: The court record anonymises the employer; the director roles are as stated by the employee in her claim. ## Trafigura names in an offshore-leaks database - Documented: Maltese corporate-registry data to 2016, published in an offshore-leaks database, record 'Trafigura Pte Limited' of Singapore, with an address at 1 Marina Boulevard, as a shareholder of two Maltese companies: Trafigura Nat Gas Limited, incorporated on 27 April 2011, and Bulavista Limited, incorporated on 5 July 2007. The same Trafigura Nat Gas Limited, registered on 27 April 2011, is 99.99% owned by TPTE according to the Maltese register extract cited by the Bulgarian energy regulator in 2024. [s-d246] [s-d177] - Qualification: The records come from Maltese corporate-registry data to 2016 published in an offshore-leaks database of an investigative journalism consortium, which states that there are legitimate uses for offshore companies and that inclusion does not suggest illegal or improper conduct. The records carry no registry number for the officers. TPTE's registered office in 2025 is at 10 Collyer Quay, not 1 Marina Boulevard. - Documented: The same Maltese registry data record Mark Joseph Irwin, a TGPL director, as director, secretary, legal and judicial representative and shareholder of four Maltese companies incorporated on 8 March 2005 — Farringford Malta Limited and Beheer Malta Limited, both links in the group's 2018 chain of control, and Ecore Malta Limited and Ecore Malta Holding Limited — and as director and legal and judicial representative of Trafigura Holdings Limited (incorporated 6 March 2012), Trafigura Nat Gas Limited (27 April 2011), Trafigura Maritime Ventures Limited (15 September 2008), Galena Investments Limited (28 February 2012), Galena Investments 2 Limited (18 March 2014), Impala Holdings Limited (17 December 2012), Puma Energy (ZMT) Holdings Limited (22 October 2010) and two companies since struck off, ITH (Malta) Ltd and Puma Energy Holdings Malta 3 Limited. They also record him, with Jeremy Charles Weir, TGPL's chairman, as a shareholder of PE Investments Limited, incorporated on 9 September 2011. [s-d178] [s-d179] - Qualification: The records come from Maltese corporate-registry data to 2016 published in an offshore-leaks database of an investigative journalism consortium, which states that there are legitimate uses for offshore companies and that inclusion does not suggest illegal or improper conduct. The records carry no registry number for the officers. The identification of these officers with the TGPL directors rests on their full names and on the group companies named in the same records. - Documented: The Maltese registry data in the same database record Pierre Andre Jacques Lorinet, a TGPL director, as director and legal and judicial representative of Chuntile Holdings Malta Limited, incorporated on 15 March 2010 and since struck off, and Christophe Thierry Marie Salmon, a director of Trafigura Nat Gas Limited, as director and legal and judicial representative of Genghis Holding Company Limited, incorporated on 13 January 2012. A corporate-data aggregator's copy of the Maltese register, updated on 24 September 2020, shows Genghis Holding Company Limited (C 55007) in dissolution, with 7,700,000 issued shares held by Trafigura Holdings Limited, the Maltese company in the group's chain, and four directors including Christophe Salmon. [s-d180] [s-d231] [s-d253] - Qualification: The records come from Maltese corporate-registry data to 2016 published in an offshore-leaks database of an investigative journalism consortium, which states that there are legitimate uses for offshore companies and that inclusion does not suggest illegal or improper conduct. The records carry no registry number for the officers. The identification rests on full names matching other records of the same people. - Unresolved: Records from an offshore law firm's files to 2014, published in the same offshore-leaks database, list an officer named 'Trafigura Pte. Ltd', with an address at 1 Marina Boulevard, Singapore, as a shareholder of Damlos Investments Limited (British Virgin Islands, incorporated 12 July 2011) and Napoil Limited (Bermuda, incorporated 13 February 1992). [s-d232] [s-d12] - Qualification: The record carries no registry number. The same address appears for 'Trafigura Pte Limited' in the Maltese registry data, and a corporate-data aggregator gives it as the address of a struck-off Singapore group company, Trafigura Pacific Coal (Asia) Pte. Ltd.; but neither offshore record identifies the company by number, so it is not established that this officer is TPTE. The database states that inclusion does not suggest illegal or improper conduct. ## Sources - [s-d4] Company statement source · s-d4 - [s-d8] Corporate registry source · s-d8 - [s-d285] LEI record: Trafigura Pte Ltd (549300Z2X1L1L3MID765), Global Legal Entity Identifier Foundation (GLEIF), 2026-10-16 - [s-d170] Judgment: Trafigura Pte Ltd and Trafigura India Pvt Ltd v Prateek Gupta and Ginni Gupta [2025] DIFC CA 001, Dubai International Financial Centre Courts, 2025-09-22 - [s-d64] Company statement source · s-d64 - [s-d133] Company statement source · s-d133 - [s-d177] Report on the licence application of Trafigura Nat Gas Limited, Energy and Water Regulatory Commission of Bulgaria (KEVR), 2024 - [s-d247] Judgment: Trafigura Pte Ltd v El Soobat Energy Co Ltd [2025] EWHC 1684 (Comm), The National Archives, Find Case Law, 2025-07-04 - [s-d280] Corporate registry source · s-d280 - [s-d12] Corporate registry source · s-d12 - [s-d59] Corporate registry source · s-d59 - [s-d26] Corporate registry source · s-d26 - [s-d58] Corporate registry source · s-d58 - [s-d100] Corporate registry source · s-d100 - [s-d139] Corporate registry source · s-d139 - [s-d77] Research source · s-d77 - [s-d9] LEI record: Trafigura Pte Ltd (549300Z2X1L1L3MID765), direct parent, Global Legal Entity Identifier Foundation (GLEIF), 2026-10-16 - [s-d76] Company statement source · s-d76 - [s-d6] Company statement source · s-d6 - [s-d42] Prior notification of a concentration, Case M.11551, describing the Farringford Foundation as controlling the group, European Commission (Official Journal of the European Union, EUR-Lex), 2024 - [s-d21] Company statement source · s-d21 - [s-d116] Company statement source · s-d116 - [s-d130] Corporate registry source · s-d130 - [s-d131] LEI record: Farringford N.V. (549300NLDV8DQ5WTJ223), Global Legal Entity Identifier Foundation (GLEIF), 2026-10-16 - [s-d28] LEI record: Farringford Foundation (213800Z5SG67869MF746), Global Legal Entity Identifier Foundation (GLEIF), 2026-10-16 - [s-d22] Corporate registry source · s-d22 - [s-d205] Corporate registry source · s-d205 - [s-d276] Corporate registry source · s-d276 - [s-d225] Corporate registry source · s-d225 - [s-d109] Corporate registry source · s-d109 - [s-d278] Corporate registry source · s-d278 - [s-d218] LEI record: Trafigura Beheer B.V. (PX7SUPU7HUNJBQ8BPI65), Global Legal Entity Identifier Foundation (GLEIF), 2026-10-16 - [s-d44] Media source · s-d44 - [s-d63] Corporate registry source · s-d63 - [s-d16] Company statement source · s-d16 - [s-d25] Corporate registry source · s-d25 - [s-d75] Company statement source · s-d75 - [s-d114] Company statement source · s-d114 - [s-d261] Media source · s-d261 - [s-d24] Company statement source · s-d24 - [s-d67] Company statement source · s-d67 - [s-d61] Company statement source · s-d61 - [s-d143] Company statement source · s-d143 - [s-d65] Corporate registry source · s-d65 - [s-d138] Corporate registry source · s-d138 - [s-d29] Corporate registry source · s-d29 - [s-d68] Company statement source · s-d68 - [s-d99] Corporate registry source · s-d99 - [s-d252] Public-register record: Trafigura Trading (Europe) Sàrl, Czech branch (06262341), ARES, Ministry of Finance of the Czech Republic, 2026-10-16 - [s-d101] Corporate registry source · s-d101 - [s-d128] Corporate registry source · s-d128 - [s-d216] Company statement source · s-d216 - [s-d274] Commercial-registry gazette entry (BORME), 2019, on Minas de Aguas Teñidas, Agencia Estatal Boletín Oficial del Estado (Spain), 2019-11 - [s-d107] Corporate registry source · s-d107 - [s-d293] Corporate registry source · s-d293 - [s-d92] Corporate registry source · s-d92 - [s-d94] Corporate registry source · s-d94 - [s-d93] Corporate registry source · s-d93 - [s-d96] Corporate registry source · s-d96 - [s-d95] Corporate registry source · s-d95 - [s-d46] Corporate registry source · s-d46 - [s-d129] Corporate registry source · s-d129 - [s-d250] LEI record: Trafigura Asia Trading Pte. Ltd. (549300XHGYJB34H74E81), ultimate parent, Global Legal Entity Identifier Foundation (GLEIF), 2026-10-16 - [s-d48] Federal corporation record: Trafigura Canada Limited (13722767), Corporations Canada, Innovation, Science and Economic Development Canada, 2026-10-16 - [s-d111] Corporate registry source · s-d111 - [s-d112] Corporate registry source · s-d112 - [s-d108] Corporate registry source · s-d108 - [s-d172] Federal corporation record: Trafigura Commodities Marketing Limited (14518462), Corporations Canada, Innovation, Science and Economic Development Canada, 2026-10-16 - [s-d275] Company record: Trafigura Trading LLC (Florida), Florida Department of State, Division of Corporations, 2026-10-16 - [s-d118] Corporate registry source · s-d118 - [s-d258] Company statement source · s-d258 - [s-d286] LEI record: Trafigura Pte Ltd (549300Z2X1L1L3MID765), direct children, Global Legal Entity Identifier Foundation (GLEIF), 2026-10-16 - [s-d263] Corporate registry source · s-d263 - [s-d256] Corporate registry source · s-d256 - [s-d224] Corporate registry source · s-d224 - [s-d136] Corporate registry source · s-d136 - [s-d254] Corporate registry source · s-d254 - [s-d135] Amalgamation notice: Trafigura Canada Limited, BC Registries and Online Services (British Columbia Gazette publications), 2025 - [s-d110] Court record source · s-d110 - [s-d174] Environmental offenders register record: Breakwater Resources Ltd. (Fisheries Act), Environment and Climate Change Canada, 2020-10-19 - [s-d105] Company statement source · s-d105 - [s-d260] Corporate registry source · s-d260 - [s-d223] Corporate registry source · s-d223 - [s-d27] Prior notification of a concentration, Case M.11163 – Trafigura / Mota-Engil / Lobito Atlantic Holdings, European Commission (Official Journal of the European Union, EUR-Lex), 2023-06 - [s-d60] Press release: Trafigura Beheer BV and three individuals referred to the Federal Criminal Court, Office of the Attorney General of Switzerland (Swiss federal government news service), 2024-02-15 - [s-d122] Press release: judgment in case SK.2023.49 (Trafigura Beheer BV and others), Swiss Federal Criminal Court, 2025-01-31 - [s-d154] Court record source · s-d154 - [s-d152] Media source · s-d152 - [s-d233] Media source · s-d233 - [s-d197] Media source · s-d197 - [s-d243] Corporate governance report 2024 of Sonangol E.P., Comissão do Mercado de Capitais (Angolan capital-markets regulator), 2025-05 - [s-d55] Register of entities supervised: Sonangol, Comissão do Mercado de Capitais (Angolan capital-markets regulator), 2026 - [s-d132] Corporate registry source · s-d132 - [s-d120] Press release No. 24-367: Swiss commodities trading company pleads guilty to foreign bribery scheme, U.S. Department of Justice, Office of Public Affairs, 2024-03-28 - [s-d241] Media source · s-d241 - [s-d183] Company statement source · s-d183 - [s-d175] Press release 8921-24: CFTC orders Trafigura to pay $55 million, U.S. Commodity Futures Trading Commission, 2024-06-17 - [s-d211] Order instituting proceedings, CFTC Docket No. 24-08 (Trafigura Trading LLC), U.S. Commodity Futures Trading Commission, 2024-06-17 - [s-d210] Media source · s-d210 - [s-d245] Media source · s-d245 - [s-d244] Sanctions list source · s-d244 - [s-d10] Sanctions list source · s-d10 - [s-d49] Judgment: United Petroleum Trading Limited v Trafigura Pte Ltd [2021] SGHC(A) 13, Supreme Court of Singapore (eLitigation judgments), 2021-09-23 - [s-d201] Research source · s-d201 - [s-d214] Other source · s-d214 - [s-d248] Judgment: Rasmala Trade Finance Fund v Trafigura Pte Ltd [2026] EWCA Civ 1259, The National Archives, Find Case Law, 2026-10-07 - [s-d106] Corporate registry source · s-d106 - [s-d140] Judgment: Re Hin Leong Trading (Pte.) Ltd. (in compulsory liquidation) and others [2024] SGHC 256, Supreme Court of Singapore (eLitigation judgments), 2024-10-15 - [s-d50] Grounds of decision: Hyphen Trading Limited v BLPL Singapore Pte Ltd and others [2023] SGHC 302, Supreme Court of Singapore (eLitigation judgments), 2023-10-25 - [s-d52] Corporate registry source · s-d52 - [s-d162] Corporate registry source · s-d162 - [s-d167] Approved judgment: Trafigura Pte Ltd and Trafigura India Pvt Ltd v Prateek Gupta and others [2026] EWHC 159 (Comm), Courts and Tribunals Judiciary of England and Wales, 2026-01-30 - [s-d137] LEI record: RB International (UK) Limited, formerly Hyphen Resources Limited (549300QL91VUIW8ISB55), Global Legal Entity Identifier Foundation (GLEIF), 2024-12-16 - [s-d124] Media source · s-d124 - [s-d202] Other source · s-d202 - [s-d203] Order with reasons: Trafigura Pte Ltd and Trafigura India Pvt Ltd v Prateek Gupta and Ginni Gupta, CFI 040/2025, Dubai International Financial Centre Courts, 2026-09-09 - [s-d230] Media source · s-d230 - [s-d291] Media source · s-d291 - [s-d206] Media source · s-d206 - [s-d125] Corporate registry source · s-d125 - [s-d158] Corporate registry source · s-d158 - [s-d161] Ruling 001/ХТ2018/00158 of the Supreme Court of Mongolia in a wrongful-dismissal case, Judicial General Council of Mongolia (court-decisions database), 2018-01-25 - [s-d246] Research source · s-d246 - [s-d178] Research source · s-d178 - [s-d179] Research source · s-d179 - [s-d180] Research source · s-d180 - [s-d231] Research source · s-d231 - [s-d253] Corporate registry source · s-d253 - [s-d232] Research source · s-d232