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Effective Date: October 18, 2025

Approved by: The Legal  Department of LOBCHANGE Inc. 

Jurisdiction: United States of America

Applies to: All employees, officers, partners, contractors, intermediaries, brokers, and representatives acting on behalf of LOBCHANGE Inc.

 

1. PURPOSE OF THE POLICY

• Protect LOBCHANGE Inc. from fraud, corruption, forgery, identity misuse, and unauthorized actions.

• Ensure compliance with U.S. law, international trade regulations, and industry standards.

• Establish a clear framework for detection, reporting, investigation, and sanction of fraudulent activities.

• Safeguard the reputation, integrity, and financial interests of the company and its partners.

• LOBCHANGE Inc. enforces a Zero‑Tolerance Policy toward any type of fraud.

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2. SCOPE

• This policy applies to all subsidiaries, employees, agents, brokers, consultants, and third-party representatives.

• Covers all petroleum, energy trading, tank storage, and business development operations.

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3. DEFINITION OF FRAUD

• Document Fraud: unauthorized modification or distribution of LOBCHANGE documents.

• Financial Fraud: misrepresentation of POF, bank instruments, commissions.

• Transactional Fraud: fake allocations, POP/PPOP, tank storage documents.

• Corruption & Bribery: offering or accepting unauthorized incentives.

• Identity Fraud: impersonating LOBCHANGE representatives.

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4. PROHIBITED ACTIONS

• Issuing documents not from @lobchange.com.

• Signing agreements without authorization.

• Requesting upfront payments without official proof.

• Using fraudulent procedures to obtain commissions.

• Disclosing confidential information without permission.

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5. VERIFICATION & AUTHENTICITY RULES

• Documents must originate from official LOBCHANGE emails.

• Only approved executives may sign contracts.

• Partners may verify documents via development@lobchange.com.

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6. REPORTING FRAUD

• Fraud must be reported to the Compliance Department or CEO Office.

• External partners may report via development@lobchange.com.

• Anonymous reports are allowed.

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7. INVESTIGATION PROCEDURES

• Initial assessment.

• Formal investigation.

• Immediate action if needed.

• Final report to the LEGAL DEPARTMENT OF LOBCHANGE .

• Sanctions and corrective measures.

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8. SANCTIONS

• Contract termination.

• Blacklisting.

• Legal action.

• Notification to authorities.

• Public fraud warning if necessary.

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9. PREVENTIVE MEASURES

• Authentication of documents.

• Digital signatures.

• KYC/AML checks.

• Compliance audits.

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10. POLICY REVIEW

• Policy reviewed annually by CEO, Compliance Officer, and Legal Department.

 

11. ACKNOWLEDGMENT

• All collaborators must sign acknowledgment of this policy.