wwwharvestenergycouk

RTFO Year 4a

An Annual Report to the Department forTransport prepared by Harvest Energy

15th April 2011 ndash 14th December 2011

1

2

3

4

5

6

15th April 2011 ndash 14th December 2011

Introduction and Scope

Biofuel Supply

Summary of Biofuel Supplied

Summary of Carbon and Sustainability Characteristics

General Information

Verifierrsquos Opinion Statement

RTFO Year 4a 2

deg The Department for Transport (DfT) requires obligated companies under the Renewable

Introduction amp Scope

Transport Fuels Obligation (RTFO) to submit a report detailing the carbon and

sustainability statistics of all Biofuels supplied which are used for transport in the UK

deg As an obligated supplier under the RTFO Harvest Energy has presented this data within

this report which is in a format requested by the DfT This report is for the period 15th

April 2011 ndash 14th December 2011 (Year 4a) and is verified and signed off by

Inspectorate our independent auditor for the RTFO Year 4a period

deg Harvest Energy is pleased to report that we have improved our performance across all

areas relative to Year 3 - Data Capture uarr37 Environmental Performance uarr101

Social Performance uarr129 and Average GHG Savings uarr78

deg Biofuel supplied by Harvest Energy in Year 4a achieved an average GHG saving of 637

compared with fossil fuels RTFO Year 4a 3

deg Harvest Energy is one of Europes largest independent suppliers and blenders of motor

Biofuel Supply

fuels with operations in the UK Holland and Germany As per EU amp Government mandates a proportion of the fuel supplied by the company is made up of Biofuels -Ethanol amp Biodiesel from a combination of feedstocks

deg Harvest Energy has focused on using Biofuel from waste streams and recycled feedstocks as this helps to reduce conflict with other feedstock uses and gives better GHG saving performance

deg Harvest Energy has its own biodiesel producing facility focusing on waste streams The manufacturing plant is based in Teesside UK and is one of the largest biofuel producing plants in the UK with a capacity of 250000 mt per year

deg The National Non-Food Crops Centre (NNFCC) the leading international consultancy that advises on the conversion of biomass to bioenergy biofuels and bio-based products has rated Harvest Energy as one of Britains top ten most progressive biofuels and

RTFO Year 4a biochemical companies 4

deg Harvest Energy blends and supplies biodiesel to the wider oil industry from tanks in

Biofuel Supply to Industry

Amsterdam-Rotterdam-Antwerp (ARA) region in Europe

deg Harvest Energy has developed and runs accurate and appropriate systems to track the origin and sustainability details of the product it markets to other oil companies

deg Harvest Energy is certified under the International Sustainability amp Carbon Certification scheme (EU) as a biofuel producer trader logistic centre and warehouse with the identifier EU-ISCC-Cert-DE105-81814501

deg Harvest also supplies its own products into the Dutch market in compliance with the appropriate sustainability regulations

RTFO Year 4a 5

RTFO Year 4a

Supplier Information

deg Harvest Energy has continued to maximise ldquoRecycled Biofuel Feedstocksrdquo to

further increase GHG savings in Year 4

deg Harvest Energy continues to purchase product directly from producers to

maintain better supply chain transparency and to capture more data Since year

3 of the RTFO the positive results of this strategy have become clear as data

capture has increased

6

Aggregate 4a Carbon and Sustainability Overview

Table 1 Summary of Biofuel Supplied

Feedstock

General

Fuel supplied by feedstock type (by

volume)

Data reported on biofuel

characteristics

Environmental

Meeting Qualifying andor

RTFO standard

Social

Meeting Qualifying andor

RTFO standard

Carbon

Average carbon intensity

g CO2e MJ

Average GHG saving

Biodiesel UCO

Used Cooking Oil 100 100 100 100 141 831

Bioethanol

Corn (Produced outside the EC)

Wheat

939 707

61 80

0

477

00

00

532 365

44 475

Biodiesel ME

Soya Beans

Tallow - Category 3 or Unknown

0 603

100 100

0

100

0

100

58 308

18 785

Weighted Average (All Fuels) 879 59 577 304 637

RTFO Year 4a 7

Aggregate 4a Used Cooking Oil

Table 2 Carbon and Sustainability Characteristics by Feedstock

General Information Sustainability Information Average Carbon Information

of Total of Feedstock Type

Feedstock Origin Standard Env Level Social Level

Land Use on 01 Jan 2008 Carbon intensity incl

LUC (g CO2e MJ) GHG saving ()

Used Cooking Oil

317 Germany

290 Netherlands

190 Spain

66 Italy

63 Belgium

19 Austria

17 Denmark

12 France

12 United Kingdom

06 Slovakia

03 Portugal

02 Czech Republic

02 Ireland

02 Poland

00 Luxembourg

00 Switzerland

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

By-product 14

By-product 14

By-product 14

By-product 161

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

833

833

833

807

833

833

833

833

833

833

833

833

833

833

833

833

RTFO Year 4a 8

-

Aggregate 4a Corn Soya Beans Tallow and Wheat

General Information Sustainability Information Average Carbon Information

of Total Feedstock Type Feedstock

Origin Standard

Env Level

Social Level

Land Use on 01 Jan 2008

Carbon intensity incl LUC (g CO2e

MJ)

GHG saving ()

Corn (Produced Outside the EC)

339 United States None - - Unknown 60 284

209 United States None - - Cropland - protection status unknown 60 284

167 United States Unknown - - Cropland - protection status unknown 488 417

160 United States ISCC - - Cropland - protection status unknown 414 506

65 United States Unknown - - Cropland - protection status unknown 41 511

6 United States Unknown - - Unknown 477 431

Soya Beans

588 Argentina Unknown - - Unknown 58 308

412 Argentina Unknown - - Cropland - protection status unknown 58 308

Tallow Category 3 or Unknown

823 United Kingdom By-product QS QS By-product 18 785

177 Netherlands By-product QS QS By-product 18 785

Wheat

477 United Kingdom Unknown QS - Cropland - protection status unknown 44 475

397 United Kingdom Unknown - - Unknown 44 475

12 United Kingdom Scottish Quality Crops - - Unknown 44 475

05 United Kingdom None - - Cropland - protection status unknown 44 475

Table 2 Carbon and Sustainability Characteristics by Feedstock

ndash = Unknown

9

Voluntary Scheme Developments

deg Since the RTFO order implemented the Renewable Energy Directive (RED) sustainability criteria Harvest Energy has purchased the majority of its product from feedstocks certified under approved voluntary schemes such as the International Sustainability amp Carbon Certification scheme (ISCC)

deg In the past Harvest Energy has worked with the RSPO (Roundtable on sustainable Palm Oil) and declared some material grown however during year 4 no palm feedstocks have been purchased

deg Harvest Energy has been purchasing more feedstock for biofuel processing in its Teesside plant This is material is only grown to ldquoRTFO environmental qualifying farming standardsrdquo and only from countries with low risk of deforestation and environmental damage Feedstocks have been purchased to both ISCC and the Assured Combinable Crops (ACCS) standard now known as Red Tractor

RTFO Year 4a 10

deg Harvest Energy has had no prosecutions against it for breaches in compliance with any

Other Information

environmental and or social regulations relating to biofuel activities

deg Harvest Energy is committed to being a first class operator in the Biofuel market Harvestrsquos ambitions are to remain amongst the best performers of GHG saving Biofuel providers and is continuing to build and advance its robust data systems to handle chain of custody

deg Harvestrsquos more recent moves into feedstock procurement and processing has significantly improved GHG savings and ldquoqualifying standardrdquo biofuel in the fuel chain for Year 4 and Year 5

deg Harvest Energy is currently collaborating with the University of Durham and the Plymouth Marine Laboratory in a project aimed at developing the next generation of feedstocks for biofuel production from algae The work is supported by a pound22m LINK grant from the Biotechnology and Biological Sciences Research Council and the Department of Energy and Climate Change

RTFO Year 4a 11

deg In the RTFO Year 4 (20112012) Harvest has employed the international inspection

Data Verification

company ldquoInspectoraterdquo to perform verification of Carbon and Sustainability datareported under the RTFO

deg Inspectorate is one of the worldrsquos leading inspection and testing organisations with more

than 11000 experienced members of staff Their biofuels department provides expertise

in analytical and inspection services to biofuel producers and suppliers in accordance with

the framework of ISAE 3000 Inspectorate has international commodity coverage and

experience and as such is a suitable and qualified verifier for the RTFO

deg Further to minimum requirements Harvest has employed voluntary 3rd party verification

and assurance of its largest biofuels suppliers

deg A verifierrsquos assurance statement will accompany this report RTFO Year 4a 12

Statement Reference Number IIL-CampS-2012-HE05 v1 Date 21

st September 2012

To Mr James Ross Head of Trading Harvest Energy Limited 2 Cavendish Square London W1G 0PU

Independent Limited Assurance Opinion Statement

1 RESPONSIBILITIES

It was the responsibility of Harvest Energy Limited to prepare the Annual CampS Report for the period 15 April to 14 December 2011 of year four χΊχΜ ΑF Χι 4΄ Σ ΣΣϢΜ ζΪιχ χΪ χ DζιχΣχ Ϊι ΑιΣνζΪιχ ζιζι ϴ Hιϭνχ EΣιͽϴ χ 1492012

It is the responsibility of Inspectorate International to provide the client with assurance conclusions and a limited assurance opinion on this report

ΣνζχΪιχ Ίν ΪΣ Ϊ χ ϮΪιΜν ΜΊΣͽ ΊΣνζχΊΪΣ Σ χνχΊΣͽ organisations Our independent inspection and testing services are delivered at key trading locations across the world and we have more than 11000 experienced members of staff Our biofuels departments provide expertise in analytical and inspection services to biofuel producers and suppliers Inspectorate International affirms our independence from Harvest Energy Limited being free from bias and conflicts of interest with the organisation its subsidiaries and stakeholders

Inspectorate considers the auditor to be competent to perform assurance projects in accordance with ISAE 3000 and understand the CampS data reported in the ROS system The auditor has the following qualifications AIEMA BEng MSc

2 ASSURANCE CRITERIA

The assurance was performed against the following criteria and in accordance with the ISAE 3000 to verify the stated consignments of Harvest Energy ΊΊχ ΊΪϢΜ Camp χ νϢΊννΊΪΣν ΪΣ χ DΑν system

Carbon and Sustainability Reporting within the Renewable Transport Fuel Obligation Technical Guidance Part One (Version 43 Nov 2011)

Carbon and Sustainability Reporting within the Renewable Transport Fuel Obligation Technical Guidance Part Two Carbon Reporting ndash Default Values and Fuel Chains (Version 42 May 2011)

The following principles were used to assess the CampS data bull Traceability bull Completeness bull Consistency bull Accuracy

Page 1 of 3

3 WORK PERFORMED

Reported Carbon and Sustainability Data

The ROS entries for the period 15 April to 14 December were subject to risk based sampling in order to verify compliance to RTFO technical guidance with respect to the criteria as detailed in section 2 of this report

Supporting Documentation

Using interviews of relevant personnel review of data CampS data and supporting management process documentation the following activities were conducted to verify the reported CampS data for the consignments sampled

Personnel interviews o Mr James Ross ndash Biofuels Trader o Mr Umang Patel ndash Biofuels Analyst

Review of document control processes o RTFO Procedures

Review of Mass balance spreadsheets o Harvest Mass Balance Amsterdam Storage o Harvest Mass Balance Teesside o Harvest Mass Balance Teesside refinery o Harvest Mass Balance Grangemouth o Harvest Mass Balance ThamesVopak o Harvest Mass Balance Standic Dordrecht

Review of Feedstock records (as available) o Contract Documents o Supplier Data o Shipping Documents o Third Party Outturn Certificates o Voluntary Scheme Certificates and proofs of conformity

Review of independent third party verification reports (as available)

Review of CampS records o As relevant to ROS entries

Review of ROS CampS data o 15 April 2011 to 14 December 2011

Chain of Custody

Data samples were reviewed from primary source along the chain of custody using production records supplier and seller certificates of authenticity and ROS report entries as relevant to Harvest Energy Limited operations These were in turn verified againsχ χ χ ιζΪιχ ΊΣ χ DΑν νϴνχ΅

The CampS data submissions for the sampled consignments were reviewed and found to contain all sections and content in line with requirements

All observations and opportunities for improvement raised throughout this limited assurance audit were effectively actioned by the client and closed out

Controls

Inspectorate did not rely on Harvest Energy ΊΊχν νϴνχν Σ Ϊι ΪΣχιΪΜν Ϊϭι Camp χ ΊΣ ΪιΊΣͽ our audit conclusion

Page 2 of 3

4 LIMITATIONS

VerificχΊΪΣ Ϊ χ νχΪΙ χ Ϊι Ϣν ΊΣ Hιϭνχ EΣιͽϴν ΪϮΣ ζΜΣχ ΪϢχνΊ Ϊ χ χιΊΜ Μι in ROS was not assessed as a part of this report claims relating to this feedstock are not included as a part of this verification

The limited assurance engagement contains the risk of verifying data using a review of a risk based selected sample of CampS data

Where presented independent 3rd party verification reports were relied upon as a part of the evidence to support CampS claims

The accuracy of the reported data is dependent on the accuracy of metering and other production measurement arrangements employed at site

5 LIMITED ASSURANCE CONCLUSION amp OPINION STATEMENT

Nothing has come to our attention to cause us to believe that the data presented in χ ιζΪιχ RTFO Χι 4΄ Σ ΣΣϢΜ ζΪιχ χΪ χ DζιχΣχ Ϊι ΑιΣνζΪιχ ζιζι ϴ Hιϭνχ EΣιͽϴ χ 1492012 has not been prepared in all material respects in accordance with the criteria

This report was prepared by Dominik Tichar Lead Verifier

Inspectorate International Limited 2 Perry Road Witham Essex CM8 3TU United Kingdom

Page 3 of 3

deg The Department for Transport (DfT) requires obligated companies under the Renewable

Introduction amp Scope

Transport Fuels Obligation (RTFO) to submit a report detailing the carbon and

sustainability statistics of all Biofuels supplied which are used for transport in the UK

deg As an obligated supplier under the RTFO Harvest Energy has presented this data within

this report which is in a format requested by the DfT This report is for the period 15th

April 2011 ndash 14th December 2011 (Year 4a) and is verified and signed off by

Inspectorate our independent auditor for the RTFO Year 4a period

deg Harvest Energy is pleased to report that we have improved our performance across all

areas relative to Year 3 - Data Capture uarr37 Environmental Performance uarr101

Social Performance uarr129 and Average GHG Savings uarr78

deg Biofuel supplied by Harvest Energy in Year 4a achieved an average GHG saving of 637

compared with fossil fuels RTFO Year 4a 3

deg Harvest Energy is one of Europes largest independent suppliers and blenders of motor

Biofuel Supply

fuels with operations in the UK Holland and Germany As per EU amp Government mandates a proportion of the fuel supplied by the company is made up of Biofuels -Ethanol amp Biodiesel from a combination of feedstocks

deg Harvest Energy has focused on using Biofuel from waste streams and recycled feedstocks as this helps to reduce conflict with other feedstock uses and gives better GHG saving performance

deg Harvest Energy has its own biodiesel producing facility focusing on waste streams The manufacturing plant is based in Teesside UK and is one of the largest biofuel producing plants in the UK with a capacity of 250000 mt per year

deg The National Non-Food Crops Centre (NNFCC) the leading international consultancy that advises on the conversion of biomass to bioenergy biofuels and bio-based products has rated Harvest Energy as one of Britains top ten most progressive biofuels and

RTFO Year 4a biochemical companies 4

deg Harvest Energy blends and supplies biodiesel to the wider oil industry from tanks in

Biofuel Supply to Industry

Amsterdam-Rotterdam-Antwerp (ARA) region in Europe

deg Harvest Energy has developed and runs accurate and appropriate systems to track the origin and sustainability details of the product it markets to other oil companies

deg Harvest Energy is certified under the International Sustainability amp Carbon Certification scheme (EU) as a biofuel producer trader logistic centre and warehouse with the identifier EU-ISCC-Cert-DE105-81814501

deg Harvest also supplies its own products into the Dutch market in compliance with the appropriate sustainability regulations

RTFO Year 4a 5

RTFO Year 4a

Supplier Information

deg Harvest Energy has continued to maximise ldquoRecycled Biofuel Feedstocksrdquo to

further increase GHG savings in Year 4

deg Harvest Energy continues to purchase product directly from producers to

maintain better supply chain transparency and to capture more data Since year

3 of the RTFO the positive results of this strategy have become clear as data

capture has increased

6

Aggregate 4a Carbon and Sustainability Overview

Table 1 Summary of Biofuel Supplied

Feedstock

General

Fuel supplied by feedstock type (by

volume)

Data reported on biofuel

characteristics

Environmental

Meeting Qualifying andor

RTFO standard

Social

Meeting Qualifying andor

RTFO standard

Carbon

Average carbon intensity

g CO2e MJ

Average GHG saving

Biodiesel UCO

Used Cooking Oil 100 100 100 100 141 831

Bioethanol

Corn (Produced outside the EC)

Wheat

939 707

61 80

0

477

00

00

532 365

44 475

Biodiesel ME

Soya Beans

Tallow - Category 3 or Unknown

0 603

100 100

0

100

0

100

58 308

18 785

Weighted Average (All Fuels) 879 59 577 304 637

RTFO Year 4a 7

Aggregate 4a Used Cooking Oil

Table 2 Carbon and Sustainability Characteristics by Feedstock

General Information Sustainability Information Average Carbon Information

of Total of Feedstock Type

Feedstock Origin Standard Env Level Social Level

Land Use on 01 Jan 2008 Carbon intensity incl

LUC (g CO2e MJ) GHG saving ()

Used Cooking Oil

317 Germany

290 Netherlands

190 Spain

66 Italy

63 Belgium

19 Austria

17 Denmark

12 France

12 United Kingdom

06 Slovakia

03 Portugal

02 Czech Republic

02 Ireland

02 Poland

00 Luxembourg

00 Switzerland

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

By-product 14

By-product 14

By-product 14

By-product 161

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

833

833

833

807

833

833

833

833

833

833

833

833

833

833

833

833

RTFO Year 4a 8

-

Aggregate 4a Corn Soya Beans Tallow and Wheat

General Information Sustainability Information Average Carbon Information

of Total Feedstock Type Feedstock

Origin Standard

Env Level

Social Level

Land Use on 01 Jan 2008

Carbon intensity incl LUC (g CO2e

MJ)

GHG saving ()

Corn (Produced Outside the EC)

339 United States None - - Unknown 60 284

209 United States None - - Cropland - protection status unknown 60 284

167 United States Unknown - - Cropland - protection status unknown 488 417

160 United States ISCC - - Cropland - protection status unknown 414 506

65 United States Unknown - - Cropland - protection status unknown 41 511

6 United States Unknown - - Unknown 477 431

Soya Beans

588 Argentina Unknown - - Unknown 58 308

412 Argentina Unknown - - Cropland - protection status unknown 58 308

Tallow Category 3 or Unknown

823 United Kingdom By-product QS QS By-product 18 785

177 Netherlands By-product QS QS By-product 18 785

Wheat

477 United Kingdom Unknown QS - Cropland - protection status unknown 44 475

397 United Kingdom Unknown - - Unknown 44 475

12 United Kingdom Scottish Quality Crops - - Unknown 44 475

05 United Kingdom None - - Cropland - protection status unknown 44 475

Table 2 Carbon and Sustainability Characteristics by Feedstock

ndash = Unknown

9

Voluntary Scheme Developments

deg Since the RTFO order implemented the Renewable Energy Directive (RED) sustainability criteria Harvest Energy has purchased the majority of its product from feedstocks certified under approved voluntary schemes such as the International Sustainability amp Carbon Certification scheme (ISCC)

deg In the past Harvest Energy has worked with the RSPO (Roundtable on sustainable Palm Oil) and declared some material grown however during year 4 no palm feedstocks have been purchased

deg Harvest Energy has been purchasing more feedstock for biofuel processing in its Teesside plant This is material is only grown to ldquoRTFO environmental qualifying farming standardsrdquo and only from countries with low risk of deforestation and environmental damage Feedstocks have been purchased to both ISCC and the Assured Combinable Crops (ACCS) standard now known as Red Tractor

RTFO Year 4a 10

deg Harvest Energy has had no prosecutions against it for breaches in compliance with any

Other Information

environmental and or social regulations relating to biofuel activities

deg Harvest Energy is committed to being a first class operator in the Biofuel market Harvestrsquos ambitions are to remain amongst the best performers of GHG saving Biofuel providers and is continuing to build and advance its robust data systems to handle chain of custody

deg Harvestrsquos more recent moves into feedstock procurement and processing has significantly improved GHG savings and ldquoqualifying standardrdquo biofuel in the fuel chain for Year 4 and Year 5

deg Harvest Energy is currently collaborating with the University of Durham and the Plymouth Marine Laboratory in a project aimed at developing the next generation of feedstocks for biofuel production from algae The work is supported by a pound22m LINK grant from the Biotechnology and Biological Sciences Research Council and the Department of Energy and Climate Change

RTFO Year 4a 11

deg In the RTFO Year 4 (20112012) Harvest has employed the international inspection

Data Verification

company ldquoInspectoraterdquo to perform verification of Carbon and Sustainability datareported under the RTFO

deg Inspectorate is one of the worldrsquos leading inspection and testing organisations with more

than 11000 experienced members of staff Their biofuels department provides expertise

in analytical and inspection services to biofuel producers and suppliers in accordance with

the framework of ISAE 3000 Inspectorate has international commodity coverage and

experience and as such is a suitable and qualified verifier for the RTFO

deg Further to minimum requirements Harvest has employed voluntary 3rd party verification

and assurance of its largest biofuels suppliers

deg A verifierrsquos assurance statement will accompany this report RTFO Year 4a 12

Statement Reference Number IIL-CampS-2012-HE05 v1 Date 21

st September 2012

To Mr James Ross Head of Trading Harvest Energy Limited 2 Cavendish Square London W1G 0PU

Independent Limited Assurance Opinion Statement

1 RESPONSIBILITIES

It was the responsibility of Harvest Energy Limited to prepare the Annual CampS Report for the period 15 April to 14 December 2011 of year four χΊχΜ ΑF Χι 4΄ Σ ΣΣϢΜ ζΪιχ χΪ χ DζιχΣχ Ϊι ΑιΣνζΪιχ ζιζι ϴ Hιϭνχ EΣιͽϴ χ 1492012

It is the responsibility of Inspectorate International to provide the client with assurance conclusions and a limited assurance opinion on this report

ΣνζχΪιχ Ίν ΪΣ Ϊ χ ϮΪιΜν ΜΊΣͽ ΊΣνζχΊΪΣ Σ χνχΊΣͽ organisations Our independent inspection and testing services are delivered at key trading locations across the world and we have more than 11000 experienced members of staff Our biofuels departments provide expertise in analytical and inspection services to biofuel producers and suppliers Inspectorate International affirms our independence from Harvest Energy Limited being free from bias and conflicts of interest with the organisation its subsidiaries and stakeholders

Inspectorate considers the auditor to be competent to perform assurance projects in accordance with ISAE 3000 and understand the CampS data reported in the ROS system The auditor has the following qualifications AIEMA BEng MSc

2 ASSURANCE CRITERIA

The assurance was performed against the following criteria and in accordance with the ISAE 3000 to verify the stated consignments of Harvest Energy ΊΊχ ΊΪϢΜ Camp χ νϢΊννΊΪΣν ΪΣ χ DΑν system

Carbon and Sustainability Reporting within the Renewable Transport Fuel Obligation Technical Guidance Part One (Version 43 Nov 2011)

Carbon and Sustainability Reporting within the Renewable Transport Fuel Obligation Technical Guidance Part Two Carbon Reporting ndash Default Values and Fuel Chains (Version 42 May 2011)

The following principles were used to assess the CampS data bull Traceability bull Completeness bull Consistency bull Accuracy

Page 1 of 3

3 WORK PERFORMED

Reported Carbon and Sustainability Data

The ROS entries for the period 15 April to 14 December were subject to risk based sampling in order to verify compliance to RTFO technical guidance with respect to the criteria as detailed in section 2 of this report

Supporting Documentation

Using interviews of relevant personnel review of data CampS data and supporting management process documentation the following activities were conducted to verify the reported CampS data for the consignments sampled

Personnel interviews o Mr James Ross ndash Biofuels Trader o Mr Umang Patel ndash Biofuels Analyst

Review of document control processes o RTFO Procedures

Review of Mass balance spreadsheets o Harvest Mass Balance Amsterdam Storage o Harvest Mass Balance Teesside o Harvest Mass Balance Teesside refinery o Harvest Mass Balance Grangemouth o Harvest Mass Balance ThamesVopak o Harvest Mass Balance Standic Dordrecht

Review of Feedstock records (as available) o Contract Documents o Supplier Data o Shipping Documents o Third Party Outturn Certificates o Voluntary Scheme Certificates and proofs of conformity

Review of independent third party verification reports (as available)

Review of CampS records o As relevant to ROS entries

Review of ROS CampS data o 15 April 2011 to 14 December 2011

Chain of Custody

Data samples were reviewed from primary source along the chain of custody using production records supplier and seller certificates of authenticity and ROS report entries as relevant to Harvest Energy Limited operations These were in turn verified againsχ χ χ ιζΪιχ ΊΣ χ DΑν νϴνχ΅

The CampS data submissions for the sampled consignments were reviewed and found to contain all sections and content in line with requirements

All observations and opportunities for improvement raised throughout this limited assurance audit were effectively actioned by the client and closed out

Controls

Inspectorate did not rely on Harvest Energy ΊΊχν νϴνχν Σ Ϊι ΪΣχιΪΜν Ϊϭι Camp χ ΊΣ ΪιΊΣͽ our audit conclusion

Page 2 of 3

4 LIMITATIONS

VerificχΊΪΣ Ϊ χ νχΪΙ χ Ϊι Ϣν ΊΣ Hιϭνχ EΣιͽϴν ΪϮΣ ζΜΣχ ΪϢχνΊ Ϊ χ χιΊΜ Μι in ROS was not assessed as a part of this report claims relating to this feedstock are not included as a part of this verification

The limited assurance engagement contains the risk of verifying data using a review of a risk based selected sample of CampS data

Where presented independent 3rd party verification reports were relied upon as a part of the evidence to support CampS claims

The accuracy of the reported data is dependent on the accuracy of metering and other production measurement arrangements employed at site

5 LIMITED ASSURANCE CONCLUSION amp OPINION STATEMENT

Nothing has come to our attention to cause us to believe that the data presented in χ ιζΪιχ RTFO Χι 4΄ Σ ΣΣϢΜ ζΪιχ χΪ χ DζιχΣχ Ϊι ΑιΣνζΪιχ ζιζι ϴ Hιϭνχ EΣιͽϴ χ 1492012 has not been prepared in all material respects in accordance with the criteria

This report was prepared by Dominik Tichar Lead Verifier

Inspectorate International Limited 2 Perry Road Witham Essex CM8 3TU United Kingdom

Page 3 of 3

deg Harvest Energy is one of Europes largest independent suppliers and blenders of motor

Biofuel Supply

fuels with operations in the UK Holland and Germany As per EU amp Government mandates a proportion of the fuel supplied by the company is made up of Biofuels -Ethanol amp Biodiesel from a combination of feedstocks

deg Harvest Energy has focused on using Biofuel from waste streams and recycled feedstocks as this helps to reduce conflict with other feedstock uses and gives better GHG saving performance

deg Harvest Energy has its own biodiesel producing facility focusing on waste streams The manufacturing plant is based in Teesside UK and is one of the largest biofuel producing plants in the UK with a capacity of 250000 mt per year

deg The National Non-Food Crops Centre (NNFCC) the leading international consultancy that advises on the conversion of biomass to bioenergy biofuels and bio-based products has rated Harvest Energy as one of Britains top ten most progressive biofuels and

RTFO Year 4a biochemical companies 4

deg Harvest Energy blends and supplies biodiesel to the wider oil industry from tanks in

Biofuel Supply to Industry

Amsterdam-Rotterdam-Antwerp (ARA) region in Europe

deg Harvest Energy has developed and runs accurate and appropriate systems to track the origin and sustainability details of the product it markets to other oil companies

deg Harvest Energy is certified under the International Sustainability amp Carbon Certification scheme (EU) as a biofuel producer trader logistic centre and warehouse with the identifier EU-ISCC-Cert-DE105-81814501

deg Harvest also supplies its own products into the Dutch market in compliance with the appropriate sustainability regulations

RTFO Year 4a 5

RTFO Year 4a

Supplier Information

deg Harvest Energy has continued to maximise ldquoRecycled Biofuel Feedstocksrdquo to

further increase GHG savings in Year 4

deg Harvest Energy continues to purchase product directly from producers to

maintain better supply chain transparency and to capture more data Since year

3 of the RTFO the positive results of this strategy have become clear as data

capture has increased

6

Aggregate 4a Carbon and Sustainability Overview

Table 1 Summary of Biofuel Supplied

Feedstock

General

Fuel supplied by feedstock type (by

volume)

Data reported on biofuel

characteristics

Environmental

Meeting Qualifying andor

RTFO standard

Social

Meeting Qualifying andor

RTFO standard

Carbon

Average carbon intensity

g CO2e MJ

Average GHG saving

Biodiesel UCO

Used Cooking Oil 100 100 100 100 141 831

Bioethanol

Corn (Produced outside the EC)

Wheat

939 707

61 80

0

477

00

00

532 365

44 475

Biodiesel ME

Soya Beans

Tallow - Category 3 or Unknown

0 603

100 100

0

100

0

100

58 308

18 785

Weighted Average (All Fuels) 879 59 577 304 637

RTFO Year 4a 7

Aggregate 4a Used Cooking Oil

Table 2 Carbon and Sustainability Characteristics by Feedstock

General Information Sustainability Information Average Carbon Information

of Total of Feedstock Type

Feedstock Origin Standard Env Level Social Level

Land Use on 01 Jan 2008 Carbon intensity incl

LUC (g CO2e MJ) GHG saving ()

Used Cooking Oil

317 Germany

290 Netherlands

190 Spain

66 Italy

63 Belgium

19 Austria

17 Denmark

12 France

12 United Kingdom

06 Slovakia

03 Portugal

02 Czech Republic

02 Ireland

02 Poland

00 Luxembourg

00 Switzerland

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

By-product 14

By-product 14

By-product 14

By-product 161

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

833

833

833

807

833

833

833

833

833

833

833

833

833

833

833

833

RTFO Year 4a 8

-

Aggregate 4a Corn Soya Beans Tallow and Wheat

General Information Sustainability Information Average Carbon Information

of Total Feedstock Type Feedstock

Origin Standard

Env Level

Social Level

Land Use on 01 Jan 2008

Carbon intensity incl LUC (g CO2e

MJ)

GHG saving ()

Corn (Produced Outside the EC)

339 United States None - - Unknown 60 284

209 United States None - - Cropland - protection status unknown 60 284

167 United States Unknown - - Cropland - protection status unknown 488 417

160 United States ISCC - - Cropland - protection status unknown 414 506

65 United States Unknown - - Cropland - protection status unknown 41 511

6 United States Unknown - - Unknown 477 431

Soya Beans

588 Argentina Unknown - - Unknown 58 308

412 Argentina Unknown - - Cropland - protection status unknown 58 308

Tallow Category 3 or Unknown

823 United Kingdom By-product QS QS By-product 18 785

177 Netherlands By-product QS QS By-product 18 785

Wheat

477 United Kingdom Unknown QS - Cropland - protection status unknown 44 475

397 United Kingdom Unknown - - Unknown 44 475

12 United Kingdom Scottish Quality Crops - - Unknown 44 475

05 United Kingdom None - - Cropland - protection status unknown 44 475

Table 2 Carbon and Sustainability Characteristics by Feedstock

ndash = Unknown

9

Voluntary Scheme Developments

deg Since the RTFO order implemented the Renewable Energy Directive (RED) sustainability criteria Harvest Energy has purchased the majority of its product from feedstocks certified under approved voluntary schemes such as the International Sustainability amp Carbon Certification scheme (ISCC)

deg In the past Harvest Energy has worked with the RSPO (Roundtable on sustainable Palm Oil) and declared some material grown however during year 4 no palm feedstocks have been purchased

deg Harvest Energy has been purchasing more feedstock for biofuel processing in its Teesside plant This is material is only grown to ldquoRTFO environmental qualifying farming standardsrdquo and only from countries with low risk of deforestation and environmental damage Feedstocks have been purchased to both ISCC and the Assured Combinable Crops (ACCS) standard now known as Red Tractor

RTFO Year 4a 10

deg Harvest Energy has had no prosecutions against it for breaches in compliance with any

Other Information

environmental and or social regulations relating to biofuel activities

deg Harvest Energy is committed to being a first class operator in the Biofuel market Harvestrsquos ambitions are to remain amongst the best performers of GHG saving Biofuel providers and is continuing to build and advance its robust data systems to handle chain of custody

deg Harvestrsquos more recent moves into feedstock procurement and processing has significantly improved GHG savings and ldquoqualifying standardrdquo biofuel in the fuel chain for Year 4 and Year 5

deg Harvest Energy is currently collaborating with the University of Durham and the Plymouth Marine Laboratory in a project aimed at developing the next generation of feedstocks for biofuel production from algae The work is supported by a pound22m LINK grant from the Biotechnology and Biological Sciences Research Council and the Department of Energy and Climate Change

RTFO Year 4a 11

deg In the RTFO Year 4 (20112012) Harvest has employed the international inspection

Data Verification

company ldquoInspectoraterdquo to perform verification of Carbon and Sustainability datareported under the RTFO

deg Inspectorate is one of the worldrsquos leading inspection and testing organisations with more

than 11000 experienced members of staff Their biofuels department provides expertise

in analytical and inspection services to biofuel producers and suppliers in accordance with

the framework of ISAE 3000 Inspectorate has international commodity coverage and

experience and as such is a suitable and qualified verifier for the RTFO

deg Further to minimum requirements Harvest has employed voluntary 3rd party verification

and assurance of its largest biofuels suppliers

deg A verifierrsquos assurance statement will accompany this report RTFO Year 4a 12

Statement Reference Number IIL-CampS-2012-HE05 v1 Date 21

st September 2012

To Mr James Ross Head of Trading Harvest Energy Limited 2 Cavendish Square London W1G 0PU

Independent Limited Assurance Opinion Statement

1 RESPONSIBILITIES

It was the responsibility of Harvest Energy Limited to prepare the Annual CampS Report for the period 15 April to 14 December 2011 of year four χΊχΜ ΑF Χι 4΄ Σ ΣΣϢΜ ζΪιχ χΪ χ DζιχΣχ Ϊι ΑιΣνζΪιχ ζιζι ϴ Hιϭνχ EΣιͽϴ χ 1492012

It is the responsibility of Inspectorate International to provide the client with assurance conclusions and a limited assurance opinion on this report

ΣνζχΪιχ Ίν ΪΣ Ϊ χ ϮΪιΜν ΜΊΣͽ ΊΣνζχΊΪΣ Σ χνχΊΣͽ organisations Our independent inspection and testing services are delivered at key trading locations across the world and we have more than 11000 experienced members of staff Our biofuels departments provide expertise in analytical and inspection services to biofuel producers and suppliers Inspectorate International affirms our independence from Harvest Energy Limited being free from bias and conflicts of interest with the organisation its subsidiaries and stakeholders

Inspectorate considers the auditor to be competent to perform assurance projects in accordance with ISAE 3000 and understand the CampS data reported in the ROS system The auditor has the following qualifications AIEMA BEng MSc

2 ASSURANCE CRITERIA

The assurance was performed against the following criteria and in accordance with the ISAE 3000 to verify the stated consignments of Harvest Energy ΊΊχ ΊΪϢΜ Camp χ νϢΊννΊΪΣν ΪΣ χ DΑν system

Carbon and Sustainability Reporting within the Renewable Transport Fuel Obligation Technical Guidance Part One (Version 43 Nov 2011)

Carbon and Sustainability Reporting within the Renewable Transport Fuel Obligation Technical Guidance Part Two Carbon Reporting ndash Default Values and Fuel Chains (Version 42 May 2011)

The following principles were used to assess the CampS data bull Traceability bull Completeness bull Consistency bull Accuracy

Page 1 of 3

3 WORK PERFORMED

Reported Carbon and Sustainability Data

The ROS entries for the period 15 April to 14 December were subject to risk based sampling in order to verify compliance to RTFO technical guidance with respect to the criteria as detailed in section 2 of this report

Supporting Documentation

Using interviews of relevant personnel review of data CampS data and supporting management process documentation the following activities were conducted to verify the reported CampS data for the consignments sampled

Personnel interviews o Mr James Ross ndash Biofuels Trader o Mr Umang Patel ndash Biofuels Analyst

Review of document control processes o RTFO Procedures

Review of Mass balance spreadsheets o Harvest Mass Balance Amsterdam Storage o Harvest Mass Balance Teesside o Harvest Mass Balance Teesside refinery o Harvest Mass Balance Grangemouth o Harvest Mass Balance ThamesVopak o Harvest Mass Balance Standic Dordrecht

Review of Feedstock records (as available) o Contract Documents o Supplier Data o Shipping Documents o Third Party Outturn Certificates o Voluntary Scheme Certificates and proofs of conformity

Review of independent third party verification reports (as available)

Review of CampS records o As relevant to ROS entries

Review of ROS CampS data o 15 April 2011 to 14 December 2011

Chain of Custody

Data samples were reviewed from primary source along the chain of custody using production records supplier and seller certificates of authenticity and ROS report entries as relevant to Harvest Energy Limited operations These were in turn verified againsχ χ χ ιζΪιχ ΊΣ χ DΑν νϴνχ΅

The CampS data submissions for the sampled consignments were reviewed and found to contain all sections and content in line with requirements

All observations and opportunities for improvement raised throughout this limited assurance audit were effectively actioned by the client and closed out

Controls

Inspectorate did not rely on Harvest Energy ΊΊχν νϴνχν Σ Ϊι ΪΣχιΪΜν Ϊϭι Camp χ ΊΣ ΪιΊΣͽ our audit conclusion

Page 2 of 3

4 LIMITATIONS

VerificχΊΪΣ Ϊ χ νχΪΙ χ Ϊι Ϣν ΊΣ Hιϭνχ EΣιͽϴν ΪϮΣ ζΜΣχ ΪϢχνΊ Ϊ χ χιΊΜ Μι in ROS was not assessed as a part of this report claims relating to this feedstock are not included as a part of this verification

The limited assurance engagement contains the risk of verifying data using a review of a risk based selected sample of CampS data

Where presented independent 3rd party verification reports were relied upon as a part of the evidence to support CampS claims

The accuracy of the reported data is dependent on the accuracy of metering and other production measurement arrangements employed at site

5 LIMITED ASSURANCE CONCLUSION amp OPINION STATEMENT

Nothing has come to our attention to cause us to believe that the data presented in χ ιζΪιχ RTFO Χι 4΄ Σ ΣΣϢΜ ζΪιχ χΪ χ DζιχΣχ Ϊι ΑιΣνζΪιχ ζιζι ϴ Hιϭνχ EΣιͽϴ χ 1492012 has not been prepared in all material respects in accordance with the criteria

This report was prepared by Dominik Tichar Lead Verifier

Inspectorate International Limited 2 Perry Road Witham Essex CM8 3TU United Kingdom

Page 3 of 3

deg Harvest Energy blends and supplies biodiesel to the wider oil industry from tanks in

Biofuel Supply to Industry

Amsterdam-Rotterdam-Antwerp (ARA) region in Europe

deg Harvest Energy has developed and runs accurate and appropriate systems to track the origin and sustainability details of the product it markets to other oil companies

deg Harvest Energy is certified under the International Sustainability amp Carbon Certification scheme (EU) as a biofuel producer trader logistic centre and warehouse with the identifier EU-ISCC-Cert-DE105-81814501

deg Harvest also supplies its own products into the Dutch market in compliance with the appropriate sustainability regulations

RTFO Year 4a 5

RTFO Year 4a

Supplier Information

deg Harvest Energy has continued to maximise ldquoRecycled Biofuel Feedstocksrdquo to

further increase GHG savings in Year 4

deg Harvest Energy continues to purchase product directly from producers to

maintain better supply chain transparency and to capture more data Since year

3 of the RTFO the positive results of this strategy have become clear as data

capture has increased

6

Aggregate 4a Carbon and Sustainability Overview

Table 1 Summary of Biofuel Supplied

Feedstock

General

Fuel supplied by feedstock type (by

volume)

Data reported on biofuel

characteristics

Environmental

Meeting Qualifying andor

RTFO standard

Social

Meeting Qualifying andor

RTFO standard

Carbon

Average carbon intensity

g CO2e MJ

Average GHG saving

Biodiesel UCO

Used Cooking Oil 100 100 100 100 141 831

Bioethanol

Corn (Produced outside the EC)

Wheat

939 707

61 80

0

477

00

00

532 365

44 475

Biodiesel ME

Soya Beans

Tallow - Category 3 or Unknown

0 603

100 100

0

100

0

100

58 308

18 785

Weighted Average (All Fuels) 879 59 577 304 637

RTFO Year 4a 7

Aggregate 4a Used Cooking Oil

Table 2 Carbon and Sustainability Characteristics by Feedstock

General Information Sustainability Information Average Carbon Information

of Total of Feedstock Type

Feedstock Origin Standard Env Level Social Level

Land Use on 01 Jan 2008 Carbon intensity incl

LUC (g CO2e MJ) GHG saving ()

Used Cooking Oil

317 Germany

290 Netherlands

190 Spain

66 Italy

63 Belgium

19 Austria

17 Denmark

12 France

12 United Kingdom

06 Slovakia

03 Portugal

02 Czech Republic

02 Ireland

02 Poland

00 Luxembourg

00 Switzerland

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

By-product 14

By-product 14

By-product 14

By-product 161

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

833

833

833

807

833

833

833

833

833

833

833

833

833

833

833

833

RTFO Year 4a 8

-

Aggregate 4a Corn Soya Beans Tallow and Wheat

General Information Sustainability Information Average Carbon Information

of Total Feedstock Type Feedstock

Origin Standard

Env Level

Social Level

Land Use on 01 Jan 2008

Carbon intensity incl LUC (g CO2e

MJ)

GHG saving ()

Corn (Produced Outside the EC)

339 United States None - - Unknown 60 284

209 United States None - - Cropland - protection status unknown 60 284

167 United States Unknown - - Cropland - protection status unknown 488 417

160 United States ISCC - - Cropland - protection status unknown 414 506

65 United States Unknown - - Cropland - protection status unknown 41 511

6 United States Unknown - - Unknown 477 431

Soya Beans

588 Argentina Unknown - - Unknown 58 308

412 Argentina Unknown - - Cropland - protection status unknown 58 308

Tallow Category 3 or Unknown

823 United Kingdom By-product QS QS By-product 18 785

177 Netherlands By-product QS QS By-product 18 785

Wheat

477 United Kingdom Unknown QS - Cropland - protection status unknown 44 475

397 United Kingdom Unknown - - Unknown 44 475

12 United Kingdom Scottish Quality Crops - - Unknown 44 475

05 United Kingdom None - - Cropland - protection status unknown 44 475

Table 2 Carbon and Sustainability Characteristics by Feedstock

ndash = Unknown

9

Voluntary Scheme Developments

deg Since the RTFO order implemented the Renewable Energy Directive (RED) sustainability criteria Harvest Energy has purchased the majority of its product from feedstocks certified under approved voluntary schemes such as the International Sustainability amp Carbon Certification scheme (ISCC)

deg In the past Harvest Energy has worked with the RSPO (Roundtable on sustainable Palm Oil) and declared some material grown however during year 4 no palm feedstocks have been purchased

deg Harvest Energy has been purchasing more feedstock for biofuel processing in its Teesside plant This is material is only grown to ldquoRTFO environmental qualifying farming standardsrdquo and only from countries with low risk of deforestation and environmental damage Feedstocks have been purchased to both ISCC and the Assured Combinable Crops (ACCS) standard now known as Red Tractor

RTFO Year 4a 10

deg Harvest Energy has had no prosecutions against it for breaches in compliance with any

Other Information

environmental and or social regulations relating to biofuel activities

deg Harvest Energy is committed to being a first class operator in the Biofuel market Harvestrsquos ambitions are to remain amongst the best performers of GHG saving Biofuel providers and is continuing to build and advance its robust data systems to handle chain of custody

deg Harvestrsquos more recent moves into feedstock procurement and processing has significantly improved GHG savings and ldquoqualifying standardrdquo biofuel in the fuel chain for Year 4 and Year 5

deg Harvest Energy is currently collaborating with the University of Durham and the Plymouth Marine Laboratory in a project aimed at developing the next generation of feedstocks for biofuel production from algae The work is supported by a pound22m LINK grant from the Biotechnology and Biological Sciences Research Council and the Department of Energy and Climate Change

RTFO Year 4a 11

deg In the RTFO Year 4 (20112012) Harvest has employed the international inspection

Data Verification

company ldquoInspectoraterdquo to perform verification of Carbon and Sustainability datareported under the RTFO

deg Inspectorate is one of the worldrsquos leading inspection and testing organisations with more

than 11000 experienced members of staff Their biofuels department provides expertise

in analytical and inspection services to biofuel producers and suppliers in accordance with

the framework of ISAE 3000 Inspectorate has international commodity coverage and

experience and as such is a suitable and qualified verifier for the RTFO

deg Further to minimum requirements Harvest has employed voluntary 3rd party verification

and assurance of its largest biofuels suppliers

deg A verifierrsquos assurance statement will accompany this report RTFO Year 4a 12

Statement Reference Number IIL-CampS-2012-HE05 v1 Date 21

st September 2012

To Mr James Ross Head of Trading Harvest Energy Limited 2 Cavendish Square London W1G 0PU

Independent Limited Assurance Opinion Statement

1 RESPONSIBILITIES

It was the responsibility of Harvest Energy Limited to prepare the Annual CampS Report for the period 15 April to 14 December 2011 of year four χΊχΜ ΑF Χι 4΄ Σ ΣΣϢΜ ζΪιχ χΪ χ DζιχΣχ Ϊι ΑιΣνζΪιχ ζιζι ϴ Hιϭνχ EΣιͽϴ χ 1492012

It is the responsibility of Inspectorate International to provide the client with assurance conclusions and a limited assurance opinion on this report

ΣνζχΪιχ Ίν ΪΣ Ϊ χ ϮΪιΜν ΜΊΣͽ ΊΣνζχΊΪΣ Σ χνχΊΣͽ organisations Our independent inspection and testing services are delivered at key trading locations across the world and we have more than 11000 experienced members of staff Our biofuels departments provide expertise in analytical and inspection services to biofuel producers and suppliers Inspectorate International affirms our independence from Harvest Energy Limited being free from bias and conflicts of interest with the organisation its subsidiaries and stakeholders

Inspectorate considers the auditor to be competent to perform assurance projects in accordance with ISAE 3000 and understand the CampS data reported in the ROS system The auditor has the following qualifications AIEMA BEng MSc

2 ASSURANCE CRITERIA

The assurance was performed against the following criteria and in accordance with the ISAE 3000 to verify the stated consignments of Harvest Energy ΊΊχ ΊΪϢΜ Camp χ νϢΊννΊΪΣν ΪΣ χ DΑν system

Carbon and Sustainability Reporting within the Renewable Transport Fuel Obligation Technical Guidance Part One (Version 43 Nov 2011)

Carbon and Sustainability Reporting within the Renewable Transport Fuel Obligation Technical Guidance Part Two Carbon Reporting ndash Default Values and Fuel Chains (Version 42 May 2011)

The following principles were used to assess the CampS data bull Traceability bull Completeness bull Consistency bull Accuracy

Page 1 of 3

3 WORK PERFORMED

Reported Carbon and Sustainability Data

The ROS entries for the period 15 April to 14 December were subject to risk based sampling in order to verify compliance to RTFO technical guidance with respect to the criteria as detailed in section 2 of this report

Supporting Documentation

Using interviews of relevant personnel review of data CampS data and supporting management process documentation the following activities were conducted to verify the reported CampS data for the consignments sampled

Personnel interviews o Mr James Ross ndash Biofuels Trader o Mr Umang Patel ndash Biofuels Analyst

Review of document control processes o RTFO Procedures

Review of Mass balance spreadsheets o Harvest Mass Balance Amsterdam Storage o Harvest Mass Balance Teesside o Harvest Mass Balance Teesside refinery o Harvest Mass Balance Grangemouth o Harvest Mass Balance ThamesVopak o Harvest Mass Balance Standic Dordrecht

Review of Feedstock records (as available) o Contract Documents o Supplier Data o Shipping Documents o Third Party Outturn Certificates o Voluntary Scheme Certificates and proofs of conformity

Review of independent third party verification reports (as available)

Review of CampS records o As relevant to ROS entries

Review of ROS CampS data o 15 April 2011 to 14 December 2011

Chain of Custody

Data samples were reviewed from primary source along the chain of custody using production records supplier and seller certificates of authenticity and ROS report entries as relevant to Harvest Energy Limited operations These were in turn verified againsχ χ χ ιζΪιχ ΊΣ χ DΑν νϴνχ΅

The CampS data submissions for the sampled consignments were reviewed and found to contain all sections and content in line with requirements

All observations and opportunities for improvement raised throughout this limited assurance audit were effectively actioned by the client and closed out

Controls

Inspectorate did not rely on Harvest Energy ΊΊχν νϴνχν Σ Ϊι ΪΣχιΪΜν Ϊϭι Camp χ ΊΣ ΪιΊΣͽ our audit conclusion

Page 2 of 3

4 LIMITATIONS

VerificχΊΪΣ Ϊ χ νχΪΙ χ Ϊι Ϣν ΊΣ Hιϭνχ EΣιͽϴν ΪϮΣ ζΜΣχ ΪϢχνΊ Ϊ χ χιΊΜ Μι in ROS was not assessed as a part of this report claims relating to this feedstock are not included as a part of this verification

The limited assurance engagement contains the risk of verifying data using a review of a risk based selected sample of CampS data

Where presented independent 3rd party verification reports were relied upon as a part of the evidence to support CampS claims

The accuracy of the reported data is dependent on the accuracy of metering and other production measurement arrangements employed at site

5 LIMITED ASSURANCE CONCLUSION amp OPINION STATEMENT

Nothing has come to our attention to cause us to believe that the data presented in χ ιζΪιχ RTFO Χι 4΄ Σ ΣΣϢΜ ζΪιχ χΪ χ DζιχΣχ Ϊι ΑιΣνζΪιχ ζιζι ϴ Hιϭνχ EΣιͽϴ χ 1492012 has not been prepared in all material respects in accordance with the criteria

This report was prepared by Dominik Tichar Lead Verifier

Inspectorate International Limited 2 Perry Road Witham Essex CM8 3TU United Kingdom

Page 3 of 3

RTFO Year 4a

Supplier Information

deg Harvest Energy has continued to maximise ldquoRecycled Biofuel Feedstocksrdquo to

further increase GHG savings in Year 4

deg Harvest Energy continues to purchase product directly from producers to

maintain better supply chain transparency and to capture more data Since year

3 of the RTFO the positive results of this strategy have become clear as data

capture has increased

6

Aggregate 4a Carbon and Sustainability Overview

Table 1 Summary of Biofuel Supplied

Feedstock

General

Fuel supplied by feedstock type (by

volume)

Data reported on biofuel

characteristics

Environmental

Meeting Qualifying andor

RTFO standard

Social

Meeting Qualifying andor

RTFO standard

Carbon

Average carbon intensity

g CO2e MJ

Average GHG saving

Biodiesel UCO

Used Cooking Oil 100 100 100 100 141 831

Bioethanol

Corn (Produced outside the EC)

Wheat

939 707

61 80

0

477

00

00

532 365

44 475

Biodiesel ME

Soya Beans

Tallow - Category 3 or Unknown

0 603

100 100

0

100

0

100

58 308

18 785

Weighted Average (All Fuels) 879 59 577 304 637

RTFO Year 4a 7

Aggregate 4a Used Cooking Oil

Table 2 Carbon and Sustainability Characteristics by Feedstock

General Information Sustainability Information Average Carbon Information

of Total of Feedstock Type

Feedstock Origin Standard Env Level Social Level

Land Use on 01 Jan 2008 Carbon intensity incl

LUC (g CO2e MJ) GHG saving ()

Used Cooking Oil

317 Germany

290 Netherlands

190 Spain

66 Italy

63 Belgium

19 Austria

17 Denmark

12 France

12 United Kingdom

06 Slovakia

03 Portugal

02 Czech Republic

02 Ireland

02 Poland

00 Luxembourg

00 Switzerland

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

By-product 14

By-product 14

By-product 14

By-product 161

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

833

833

833

807

833

833

833

833

833

833

833

833

833

833

833

833

RTFO Year 4a 8

-

Aggregate 4a Corn Soya Beans Tallow and Wheat

General Information Sustainability Information Average Carbon Information

of Total Feedstock Type Feedstock

Origin Standard

Env Level

Social Level

Land Use on 01 Jan 2008

Carbon intensity incl LUC (g CO2e

MJ)

GHG saving ()

Corn (Produced Outside the EC)

339 United States None - - Unknown 60 284

209 United States None - - Cropland - protection status unknown 60 284

167 United States Unknown - - Cropland - protection status unknown 488 417

160 United States ISCC - - Cropland - protection status unknown 414 506

65 United States Unknown - - Cropland - protection status unknown 41 511

6 United States Unknown - - Unknown 477 431

Soya Beans

588 Argentina Unknown - - Unknown 58 308

412 Argentina Unknown - - Cropland - protection status unknown 58 308

Tallow Category 3 or Unknown

823 United Kingdom By-product QS QS By-product 18 785

177 Netherlands By-product QS QS By-product 18 785

Wheat

477 United Kingdom Unknown QS - Cropland - protection status unknown 44 475

397 United Kingdom Unknown - - Unknown 44 475

12 United Kingdom Scottish Quality Crops - - Unknown 44 475

05 United Kingdom None - - Cropland - protection status unknown 44 475

Table 2 Carbon and Sustainability Characteristics by Feedstock

ndash = Unknown

9

Voluntary Scheme Developments

deg Since the RTFO order implemented the Renewable Energy Directive (RED) sustainability criteria Harvest Energy has purchased the majority of its product from feedstocks certified under approved voluntary schemes such as the International Sustainability amp Carbon Certification scheme (ISCC)

deg In the past Harvest Energy has worked with the RSPO (Roundtable on sustainable Palm Oil) and declared some material grown however during year 4 no palm feedstocks have been purchased

deg Harvest Energy has been purchasing more feedstock for biofuel processing in its Teesside plant This is material is only grown to ldquoRTFO environmental qualifying farming standardsrdquo and only from countries with low risk of deforestation and environmental damage Feedstocks have been purchased to both ISCC and the Assured Combinable Crops (ACCS) standard now known as Red Tractor

RTFO Year 4a 10

deg Harvest Energy has had no prosecutions against it for breaches in compliance with any

Other Information

environmental and or social regulations relating to biofuel activities

deg Harvest Energy is committed to being a first class operator in the Biofuel market Harvestrsquos ambitions are to remain amongst the best performers of GHG saving Biofuel providers and is continuing to build and advance its robust data systems to handle chain of custody

deg Harvestrsquos more recent moves into feedstock procurement and processing has significantly improved GHG savings and ldquoqualifying standardrdquo biofuel in the fuel chain for Year 4 and Year 5

deg Harvest Energy is currently collaborating with the University of Durham and the Plymouth Marine Laboratory in a project aimed at developing the next generation of feedstocks for biofuel production from algae The work is supported by a pound22m LINK grant from the Biotechnology and Biological Sciences Research Council and the Department of Energy and Climate Change

RTFO Year 4a 11

deg In the RTFO Year 4 (20112012) Harvest has employed the international inspection

Data Verification

company ldquoInspectoraterdquo to perform verification of Carbon and Sustainability datareported under the RTFO

deg Inspectorate is one of the worldrsquos leading inspection and testing organisations with more

than 11000 experienced members of staff Their biofuels department provides expertise

in analytical and inspection services to biofuel producers and suppliers in accordance with

the framework of ISAE 3000 Inspectorate has international commodity coverage and

experience and as such is a suitable and qualified verifier for the RTFO

deg Further to minimum requirements Harvest has employed voluntary 3rd party verification

and assurance of its largest biofuels suppliers

deg A verifierrsquos assurance statement will accompany this report RTFO Year 4a 12

Statement Reference Number IIL-CampS-2012-HE05 v1 Date 21

st September 2012

To Mr James Ross Head of Trading Harvest Energy Limited 2 Cavendish Square London W1G 0PU

Independent Limited Assurance Opinion Statement

1 RESPONSIBILITIES

It was the responsibility of Harvest Energy Limited to prepare the Annual CampS Report for the period 15 April to 14 December 2011 of year four χΊχΜ ΑF Χι 4΄ Σ ΣΣϢΜ ζΪιχ χΪ χ DζιχΣχ Ϊι ΑιΣνζΪιχ ζιζι ϴ Hιϭνχ EΣιͽϴ χ 1492012

It is the responsibility of Inspectorate International to provide the client with assurance conclusions and a limited assurance opinion on this report

ΣνζχΪιχ Ίν ΪΣ Ϊ χ ϮΪιΜν ΜΊΣͽ ΊΣνζχΊΪΣ Σ χνχΊΣͽ organisations Our independent inspection and testing services are delivered at key trading locations across the world and we have more than 11000 experienced members of staff Our biofuels departments provide expertise in analytical and inspection services to biofuel producers and suppliers Inspectorate International affirms our independence from Harvest Energy Limited being free from bias and conflicts of interest with the organisation its subsidiaries and stakeholders

Inspectorate considers the auditor to be competent to perform assurance projects in accordance with ISAE 3000 and understand the CampS data reported in the ROS system The auditor has the following qualifications AIEMA BEng MSc

2 ASSURANCE CRITERIA

The assurance was performed against the following criteria and in accordance with the ISAE 3000 to verify the stated consignments of Harvest Energy ΊΊχ ΊΪϢΜ Camp χ νϢΊννΊΪΣν ΪΣ χ DΑν system

Carbon and Sustainability Reporting within the Renewable Transport Fuel Obligation Technical Guidance Part One (Version 43 Nov 2011)

Carbon and Sustainability Reporting within the Renewable Transport Fuel Obligation Technical Guidance Part Two Carbon Reporting ndash Default Values and Fuel Chains (Version 42 May 2011)

The following principles were used to assess the CampS data bull Traceability bull Completeness bull Consistency bull Accuracy

Page 1 of 3

3 WORK PERFORMED

Reported Carbon and Sustainability Data

The ROS entries for the period 15 April to 14 December were subject to risk based sampling in order to verify compliance to RTFO technical guidance with respect to the criteria as detailed in section 2 of this report

Supporting Documentation

Using interviews of relevant personnel review of data CampS data and supporting management process documentation the following activities were conducted to verify the reported CampS data for the consignments sampled

Personnel interviews o Mr James Ross ndash Biofuels Trader o Mr Umang Patel ndash Biofuels Analyst

Review of document control processes o RTFO Procedures

Review of Mass balance spreadsheets o Harvest Mass Balance Amsterdam Storage o Harvest Mass Balance Teesside o Harvest Mass Balance Teesside refinery o Harvest Mass Balance Grangemouth o Harvest Mass Balance ThamesVopak o Harvest Mass Balance Standic Dordrecht

Review of Feedstock records (as available) o Contract Documents o Supplier Data o Shipping Documents o Third Party Outturn Certificates o Voluntary Scheme Certificates and proofs of conformity

Review of independent third party verification reports (as available)

Review of CampS records o As relevant to ROS entries

Review of ROS CampS data o 15 April 2011 to 14 December 2011

Chain of Custody

Data samples were reviewed from primary source along the chain of custody using production records supplier and seller certificates of authenticity and ROS report entries as relevant to Harvest Energy Limited operations These were in turn verified againsχ χ χ ιζΪιχ ΊΣ χ DΑν νϴνχ΅

The CampS data submissions for the sampled consignments were reviewed and found to contain all sections and content in line with requirements

All observations and opportunities for improvement raised throughout this limited assurance audit were effectively actioned by the client and closed out

Controls

Inspectorate did not rely on Harvest Energy ΊΊχν νϴνχν Σ Ϊι ΪΣχιΪΜν Ϊϭι Camp χ ΊΣ ΪιΊΣͽ our audit conclusion

Page 2 of 3

4 LIMITATIONS

VerificχΊΪΣ Ϊ χ νχΪΙ χ Ϊι Ϣν ΊΣ Hιϭνχ EΣιͽϴν ΪϮΣ ζΜΣχ ΪϢχνΊ Ϊ χ χιΊΜ Μι in ROS was not assessed as a part of this report claims relating to this feedstock are not included as a part of this verification

The limited assurance engagement contains the risk of verifying data using a review of a risk based selected sample of CampS data

Where presented independent 3rd party verification reports were relied upon as a part of the evidence to support CampS claims

The accuracy of the reported data is dependent on the accuracy of metering and other production measurement arrangements employed at site

5 LIMITED ASSURANCE CONCLUSION amp OPINION STATEMENT

Nothing has come to our attention to cause us to believe that the data presented in χ ιζΪιχ RTFO Χι 4΄ Σ ΣΣϢΜ ζΪιχ χΪ χ DζιχΣχ Ϊι ΑιΣνζΪιχ ζιζι ϴ Hιϭνχ EΣιͽϴ χ 1492012 has not been prepared in all material respects in accordance with the criteria

This report was prepared by Dominik Tichar Lead Verifier

Inspectorate International Limited 2 Perry Road Witham Essex CM8 3TU United Kingdom

Page 3 of 3

Aggregate 4a Carbon and Sustainability Overview

Table 1 Summary of Biofuel Supplied

Feedstock

General

Fuel supplied by feedstock type (by

volume)

Data reported on biofuel

characteristics

Environmental

Meeting Qualifying andor

RTFO standard

Social

Meeting Qualifying andor

RTFO standard

Carbon

Average carbon intensity

g CO2e MJ

Average GHG saving

Biodiesel UCO

Used Cooking Oil 100 100 100 100 141 831

Bioethanol

Corn (Produced outside the EC)

Wheat

939 707

61 80

0

477

00

00

532 365

44 475

Biodiesel ME

Soya Beans

Tallow - Category 3 or Unknown

0 603

100 100

0

100

0

100

58 308

18 785

Weighted Average (All Fuels) 879 59 577 304 637

RTFO Year 4a 7

Aggregate 4a Used Cooking Oil

Table 2 Carbon and Sustainability Characteristics by Feedstock

General Information Sustainability Information Average Carbon Information

of Total of Feedstock Type

Feedstock Origin Standard Env Level Social Level

Land Use on 01 Jan 2008 Carbon intensity incl

LUC (g CO2e MJ) GHG saving ()

Used Cooking Oil

317 Germany

290 Netherlands

190 Spain

66 Italy

63 Belgium

19 Austria

17 Denmark

12 France

12 United Kingdom

06 Slovakia

03 Portugal

02 Czech Republic

02 Ireland

02 Poland

00 Luxembourg

00 Switzerland

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

By-product 14

By-product 14

By-product 14

By-product 161

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

833

833

833

807

833

833

833

833

833

833

833

833

833

833

833

833

RTFO Year 4a 8

-

Aggregate 4a Corn Soya Beans Tallow and Wheat

General Information Sustainability Information Average Carbon Information

of Total Feedstock Type Feedstock

Origin Standard

Env Level

Social Level

Land Use on 01 Jan 2008

Carbon intensity incl LUC (g CO2e

MJ)

GHG saving ()

Corn (Produced Outside the EC)

339 United States None - - Unknown 60 284

209 United States None - - Cropland - protection status unknown 60 284

167 United States Unknown - - Cropland - protection status unknown 488 417

160 United States ISCC - - Cropland - protection status unknown 414 506

65 United States Unknown - - Cropland - protection status unknown 41 511

6 United States Unknown - - Unknown 477 431

Soya Beans

588 Argentina Unknown - - Unknown 58 308

412 Argentina Unknown - - Cropland - protection status unknown 58 308

Tallow Category 3 or Unknown

823 United Kingdom By-product QS QS By-product 18 785

177 Netherlands By-product QS QS By-product 18 785

Wheat

477 United Kingdom Unknown QS - Cropland - protection status unknown 44 475

397 United Kingdom Unknown - - Unknown 44 475

12 United Kingdom Scottish Quality Crops - - Unknown 44 475

05 United Kingdom None - - Cropland - protection status unknown 44 475

Table 2 Carbon and Sustainability Characteristics by Feedstock

ndash = Unknown

9

Voluntary Scheme Developments

deg Since the RTFO order implemented the Renewable Energy Directive (RED) sustainability criteria Harvest Energy has purchased the majority of its product from feedstocks certified under approved voluntary schemes such as the International Sustainability amp Carbon Certification scheme (ISCC)

deg In the past Harvest Energy has worked with the RSPO (Roundtable on sustainable Palm Oil) and declared some material grown however during year 4 no palm feedstocks have been purchased

deg Harvest Energy has been purchasing more feedstock for biofuel processing in its Teesside plant This is material is only grown to ldquoRTFO environmental qualifying farming standardsrdquo and only from countries with low risk of deforestation and environmental damage Feedstocks have been purchased to both ISCC and the Assured Combinable Crops (ACCS) standard now known as Red Tractor

RTFO Year 4a 10

deg Harvest Energy has had no prosecutions against it for breaches in compliance with any

Other Information

environmental and or social regulations relating to biofuel activities

deg Harvest Energy is committed to being a first class operator in the Biofuel market Harvestrsquos ambitions are to remain amongst the best performers of GHG saving Biofuel providers and is continuing to build and advance its robust data systems to handle chain of custody

deg Harvestrsquos more recent moves into feedstock procurement and processing has significantly improved GHG savings and ldquoqualifying standardrdquo biofuel in the fuel chain for Year 4 and Year 5

deg Harvest Energy is currently collaborating with the University of Durham and the Plymouth Marine Laboratory in a project aimed at developing the next generation of feedstocks for biofuel production from algae The work is supported by a pound22m LINK grant from the Biotechnology and Biological Sciences Research Council and the Department of Energy and Climate Change

RTFO Year 4a 11

deg In the RTFO Year 4 (20112012) Harvest has employed the international inspection

Data Verification

company ldquoInspectoraterdquo to perform verification of Carbon and Sustainability datareported under the RTFO

deg Inspectorate is one of the worldrsquos leading inspection and testing organisations with more

than 11000 experienced members of staff Their biofuels department provides expertise

in analytical and inspection services to biofuel producers and suppliers in accordance with

the framework of ISAE 3000 Inspectorate has international commodity coverage and

experience and as such is a suitable and qualified verifier for the RTFO

deg Further to minimum requirements Harvest has employed voluntary 3rd party verification

and assurance of its largest biofuels suppliers

deg A verifierrsquos assurance statement will accompany this report RTFO Year 4a 12

Statement Reference Number IIL-CampS-2012-HE05 v1 Date 21

st September 2012

To Mr James Ross Head of Trading Harvest Energy Limited 2 Cavendish Square London W1G 0PU

Independent Limited Assurance Opinion Statement

1 RESPONSIBILITIES

It was the responsibility of Harvest Energy Limited to prepare the Annual CampS Report for the period 15 April to 14 December 2011 of year four χΊχΜ ΑF Χι 4΄ Σ ΣΣϢΜ ζΪιχ χΪ χ DζιχΣχ Ϊι ΑιΣνζΪιχ ζιζι ϴ Hιϭνχ EΣιͽϴ χ 1492012

It is the responsibility of Inspectorate International to provide the client with assurance conclusions and a limited assurance opinion on this report

ΣνζχΪιχ Ίν ΪΣ Ϊ χ ϮΪιΜν ΜΊΣͽ ΊΣνζχΊΪΣ Σ χνχΊΣͽ organisations Our independent inspection and testing services are delivered at key trading locations across the world and we have more than 11000 experienced members of staff Our biofuels departments provide expertise in analytical and inspection services to biofuel producers and suppliers Inspectorate International affirms our independence from Harvest Energy Limited being free from bias and conflicts of interest with the organisation its subsidiaries and stakeholders

Inspectorate considers the auditor to be competent to perform assurance projects in accordance with ISAE 3000 and understand the CampS data reported in the ROS system The auditor has the following qualifications AIEMA BEng MSc

2 ASSURANCE CRITERIA

The assurance was performed against the following criteria and in accordance with the ISAE 3000 to verify the stated consignments of Harvest Energy ΊΊχ ΊΪϢΜ Camp χ νϢΊννΊΪΣν ΪΣ χ DΑν system

Carbon and Sustainability Reporting within the Renewable Transport Fuel Obligation Technical Guidance Part One (Version 43 Nov 2011)

Carbon and Sustainability Reporting within the Renewable Transport Fuel Obligation Technical Guidance Part Two Carbon Reporting ndash Default Values and Fuel Chains (Version 42 May 2011)

The following principles were used to assess the CampS data bull Traceability bull Completeness bull Consistency bull Accuracy

Page 1 of 3

3 WORK PERFORMED

Reported Carbon and Sustainability Data

The ROS entries for the period 15 April to 14 December were subject to risk based sampling in order to verify compliance to RTFO technical guidance with respect to the criteria as detailed in section 2 of this report

Supporting Documentation

Using interviews of relevant personnel review of data CampS data and supporting management process documentation the following activities were conducted to verify the reported CampS data for the consignments sampled

Personnel interviews o Mr James Ross ndash Biofuels Trader o Mr Umang Patel ndash Biofuels Analyst

Review of document control processes o RTFO Procedures

Review of Mass balance spreadsheets o Harvest Mass Balance Amsterdam Storage o Harvest Mass Balance Teesside o Harvest Mass Balance Teesside refinery o Harvest Mass Balance Grangemouth o Harvest Mass Balance ThamesVopak o Harvest Mass Balance Standic Dordrecht

Review of Feedstock records (as available) o Contract Documents o Supplier Data o Shipping Documents o Third Party Outturn Certificates o Voluntary Scheme Certificates and proofs of conformity

Review of independent third party verification reports (as available)

Review of CampS records o As relevant to ROS entries

Review of ROS CampS data o 15 April 2011 to 14 December 2011

Chain of Custody

Data samples were reviewed from primary source along the chain of custody using production records supplier and seller certificates of authenticity and ROS report entries as relevant to Harvest Energy Limited operations These were in turn verified againsχ χ χ ιζΪιχ ΊΣ χ DΑν νϴνχ΅

The CampS data submissions for the sampled consignments were reviewed and found to contain all sections and content in line with requirements

All observations and opportunities for improvement raised throughout this limited assurance audit were effectively actioned by the client and closed out

Controls

Inspectorate did not rely on Harvest Energy ΊΊχν νϴνχν Σ Ϊι ΪΣχιΪΜν Ϊϭι Camp χ ΊΣ ΪιΊΣͽ our audit conclusion

Page 2 of 3

4 LIMITATIONS

VerificχΊΪΣ Ϊ χ νχΪΙ χ Ϊι Ϣν ΊΣ Hιϭνχ EΣιͽϴν ΪϮΣ ζΜΣχ ΪϢχνΊ Ϊ χ χιΊΜ Μι in ROS was not assessed as a part of this report claims relating to this feedstock are not included as a part of this verification

The limited assurance engagement contains the risk of verifying data using a review of a risk based selected sample of CampS data

Where presented independent 3rd party verification reports were relied upon as a part of the evidence to support CampS claims

The accuracy of the reported data is dependent on the accuracy of metering and other production measurement arrangements employed at site

5 LIMITED ASSURANCE CONCLUSION amp OPINION STATEMENT

Nothing has come to our attention to cause us to believe that the data presented in χ ιζΪιχ RTFO Χι 4΄ Σ ΣΣϢΜ ζΪιχ χΪ χ DζιχΣχ Ϊι ΑιΣνζΪιχ ζιζι ϴ Hιϭνχ EΣιͽϴ χ 1492012 has not been prepared in all material respects in accordance with the criteria

This report was prepared by Dominik Tichar Lead Verifier

Inspectorate International Limited 2 Perry Road Witham Essex CM8 3TU United Kingdom

Page 3 of 3

Aggregate 4a Used Cooking Oil

Table 2 Carbon and Sustainability Characteristics by Feedstock

General Information Sustainability Information Average Carbon Information

of Total of Feedstock Type

Feedstock Origin Standard Env Level Social Level

Land Use on 01 Jan 2008 Carbon intensity incl

LUC (g CO2e MJ) GHG saving ()

Used Cooking Oil

317 Germany

290 Netherlands

190 Spain

66 Italy

63 Belgium

19 Austria

17 Denmark

12 France

12 United Kingdom

06 Slovakia

03 Portugal

02 Czech Republic

02 Ireland

02 Poland

00 Luxembourg

00 Switzerland

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

By-product QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

QS

By-product 14

By-product 14

By-product 14

By-product 161

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

By-product 14

833

833

833

807

833

833

833

833

833

833

833

833

833

833

833

833

RTFO Year 4a 8

-

Aggregate 4a Corn Soya Beans Tallow and Wheat

General Information Sustainability Information Average Carbon Information

of Total Feedstock Type Feedstock

Origin Standard

Env Level

Social Level

Land Use on 01 Jan 2008

Carbon intensity incl LUC (g CO2e

MJ)

GHG saving ()

Corn (Produced Outside the EC)

339 United States None - - Unknown 60 284

209 United States None - - Cropland - protection status unknown 60 284

167 United States Unknown - - Cropland - protection status unknown 488 417

160 United States ISCC - - Cropland - protection status unknown 414 506

65 United States Unknown - - Cropland - protection status unknown 41 511

6 United States Unknown - - Unknown 477 431

Soya Beans

588 Argentina Unknown - - Unknown 58 308

412 Argentina Unknown - - Cropland - protection status unknown 58 308

Tallow Category 3 or Unknown

823 United Kingdom By-product QS QS By-product 18 785

177 Netherlands By-product QS QS By-product 18 785

Wheat

477 United Kingdom Unknown QS - Cropland - protection status unknown 44 475

397 United Kingdom Unknown - - Unknown 44 475

12 United Kingdom Scottish Quality Crops - - Unknown 44 475

05 United Kingdom None - - Cropland - protection status unknown 44 475

Table 2 Carbon and Sustainability Characteristics by Feedstock

ndash = Unknown

9

Voluntary Scheme Developments

deg Since the RTFO order implemented the Renewable Energy Directive (RED) sustainability criteria Harvest Energy has purchased the majority of its product from feedstocks certified under approved voluntary schemes such as the International Sustainability amp Carbon Certification scheme (ISCC)

deg In the past Harvest Energy has worked with the RSPO (Roundtable on sustainable Palm Oil) and declared some material grown however during year 4 no palm feedstocks have been purchased

deg Harvest Energy has been purchasing more feedstock for biofuel processing in its Teesside plant This is material is only grown to ldquoRTFO environmental qualifying farming standardsrdquo and only from countries with low risk of deforestation and environmental damage Feedstocks have been purchased to both ISCC and the Assured Combinable Crops (ACCS) standard now known as Red Tractor

RTFO Year 4a 10

deg Harvest Energy has had no prosecutions against it for breaches in compliance with any

Other Information

environmental and or social regulations relating to biofuel activities

deg Harvest Energy is committed to being a first class operator in the Biofuel market Harvestrsquos ambitions are to remain amongst the best performers of GHG saving Biofuel providers and is continuing to build and advance its robust data systems to handle chain of custody

deg Harvestrsquos more recent moves into feedstock procurement and processing has significantly improved GHG savings and ldquoqualifying standardrdquo biofuel in the fuel chain for Year 4 and Year 5

deg Harvest Energy is currently collaborating with the University of Durham and the Plymouth Marine Laboratory in a project aimed at developing the next generation of feedstocks for biofuel production from algae The work is supported by a pound22m LINK grant from the Biotechnology and Biological Sciences Research Council and the Department of Energy and Climate Change

RTFO Year 4a 11

deg In the RTFO Year 4 (20112012) Harvest has employed the international inspection

Data Verification

company ldquoInspectoraterdquo to perform verification of Carbon and Sustainability datareported under the RTFO

deg Inspectorate is one of the worldrsquos leading inspection and testing organisations with more

than 11000 experienced members of staff Their biofuels department provides expertise

in analytical and inspection services to biofuel producers and suppliers in accordance with

the framework of ISAE 3000 Inspectorate has international commodity coverage and

experience and as such is a suitable and qualified verifier for the RTFO

deg Further to minimum requirements Harvest has employed voluntary 3rd party verification

and assurance of its largest biofuels suppliers

deg A verifierrsquos assurance statement will accompany this report RTFO Year 4a 12

Statement Reference Number IIL-CampS-2012-HE05 v1 Date 21

st September 2012

To Mr James Ross Head of Trading Harvest Energy Limited 2 Cavendish Square London W1G 0PU

Independent Limited Assurance Opinion Statement

1 RESPONSIBILITIES

It was the responsibility of Harvest Energy Limited to prepare the Annual CampS Report for the period 15 April to 14 December 2011 of year four χΊχΜ ΑF Χι 4΄ Σ ΣΣϢΜ ζΪιχ χΪ χ DζιχΣχ Ϊι ΑιΣνζΪιχ ζιζι ϴ Hιϭνχ EΣιͽϴ χ 1492012

It is the responsibility of Inspectorate International to provide the client with assurance conclusions and a limited assurance opinion on this report

ΣνζχΪιχ Ίν ΪΣ Ϊ χ ϮΪιΜν ΜΊΣͽ ΊΣνζχΊΪΣ Σ χνχΊΣͽ organisations Our independent inspection and testing services are delivered at key trading locations across the world and we have more than 11000 experienced members of staff Our biofuels departments provide expertise in analytical and inspection services to biofuel producers and suppliers Inspectorate International affirms our independence from Harvest Energy Limited being free from bias and conflicts of interest with the organisation its subsidiaries and stakeholders

Inspectorate considers the auditor to be competent to perform assurance projects in accordance with ISAE 3000 and understand the CampS data reported in the ROS system The auditor has the following qualifications AIEMA BEng MSc

2 ASSURANCE CRITERIA

The assurance was performed against the following criteria and in accordance with the ISAE 3000 to verify the stated consignments of Harvest Energy ΊΊχ ΊΪϢΜ Camp χ νϢΊννΊΪΣν ΪΣ χ DΑν system

Carbon and Sustainability Reporting within the Renewable Transport Fuel Obligation Technical Guidance Part One (Version 43 Nov 2011)

Carbon and Sustainability Reporting within the Renewable Transport Fuel Obligation Technical Guidance Part Two Carbon Reporting ndash Default Values and Fuel Chains (Version 42 May 2011)

The following principles were used to assess the CampS data bull Traceability bull Completeness bull Consistency bull Accuracy

Page 1 of 3

3 WORK PERFORMED

Reported Carbon and Sustainability Data

The ROS entries for the period 15 April to 14 December were subject to risk based sampling in order to verify compliance to RTFO technical guidance with respect to the criteria as detailed in section 2 of this report

Supporting Documentation

Using interviews of relevant personnel review of data CampS data and supporting management process documentation the following activities were conducted to verify the reported CampS data for the consignments sampled

Personnel interviews o Mr James Ross ndash Biofuels Trader o Mr Umang Patel ndash Biofuels Analyst

Review of document control processes o RTFO Procedures

Review of Mass balance spreadsheets o Harvest Mass Balance Amsterdam Storage o Harvest Mass Balance Teesside o Harvest Mass Balance Teesside refinery o Harvest Mass Balance Grangemouth o Harvest Mass Balance ThamesVopak o Harvest Mass Balance Standic Dordrecht

Review of Feedstock records (as available) o Contract Documents o Supplier Data o Shipping Documents o Third Party Outturn Certificates o Voluntary Scheme Certificates and proofs of conformity

Review of independent third party verification reports (as available)

Review of CampS records o As relevant to ROS entries

Review of ROS CampS data o 15 April 2011 to 14 December 2011

Chain of Custody

Data samples were reviewed from primary source along the chain of custody using production records supplier and seller certificates of authenticity and ROS report entries as relevant to Harvest Energy Limited operations These were in turn verified againsχ χ χ ιζΪιχ ΊΣ χ DΑν νϴνχ΅

The CampS data submissions for the sampled consignments were reviewed and found to contain all sections and content in line with requirements

All observations and opportunities for improvement raised throughout this limited assurance audit were effectively actioned by the client and closed out

Controls

Inspectorate did not rely on Harvest Energy ΊΊχν νϴνχν Σ Ϊι ΪΣχιΪΜν Ϊϭι Camp χ ΊΣ ΪιΊΣͽ our audit conclusion

Page 2 of 3

4 LIMITATIONS

VerificχΊΪΣ Ϊ χ νχΪΙ χ Ϊι Ϣν ΊΣ Hιϭνχ EΣιͽϴν ΪϮΣ ζΜΣχ ΪϢχνΊ Ϊ χ χιΊΜ Μι in ROS was not assessed as a part of this report claims relating to this feedstock are not included as a part of this verification

The limited assurance engagement contains the risk of verifying data using a review of a risk based selected sample of CampS data

Where presented independent 3rd party verification reports were relied upon as a part of the evidence to support CampS claims

The accuracy of the reported data is dependent on the accuracy of metering and other production measurement arrangements employed at site

5 LIMITED ASSURANCE CONCLUSION amp OPINION STATEMENT

Nothing has come to our attention to cause us to believe that the data presented in χ ιζΪιχ RTFO Χι 4΄ Σ ΣΣϢΜ ζΪιχ χΪ χ DζιχΣχ Ϊι ΑιΣνζΪιχ ζιζι ϴ Hιϭνχ EΣιͽϴ χ 1492012 has not been prepared in all material respects in accordance with the criteria

This report was prepared by Dominik Tichar Lead Verifier

Inspectorate International Limited 2 Perry Road Witham Essex CM8 3TU United Kingdom

Page 3 of 3

-

Aggregate 4a Corn Soya Beans Tallow and Wheat

General Information Sustainability Information Average Carbon Information

of Total Feedstock Type Feedstock

Origin Standard

Env Level

Social Level

Land Use on 01 Jan 2008

Carbon intensity incl LUC (g CO2e

MJ)

GHG saving ()

Corn (Produced Outside the EC)

339 United States None - - Unknown 60 284

209 United States None - - Cropland - protection status unknown 60 284

167 United States Unknown - - Cropland - protection status unknown 488 417

160 United States ISCC - - Cropland - protection status unknown 414 506

65 United States Unknown - - Cropland - protection status unknown 41 511

6 United States Unknown - - Unknown 477 431

Soya Beans

588 Argentina Unknown - - Unknown 58 308

412 Argentina Unknown - - Cropland - protection status unknown 58 308

Tallow Category 3 or Unknown

823 United Kingdom By-product QS QS By-product 18 785

177 Netherlands By-product QS QS By-product 18 785

Wheat

477 United Kingdom Unknown QS - Cropland - protection status unknown 44 475

397 United Kingdom Unknown - - Unknown 44 475

12 United Kingdom Scottish Quality Crops - - Unknown 44 475

05 United Kingdom None - - Cropland - protection status unknown 44 475

Table 2 Carbon and Sustainability Characteristics by Feedstock

ndash = Unknown

9

Voluntary Scheme Developments

deg Since the RTFO order implemented the Renewable Energy Directive (RED) sustainability criteria Harvest Energy has purchased the majority of its product from feedstocks certified under approved voluntary schemes such as the International Sustainability amp Carbon Certification scheme (ISCC)

deg In the past Harvest Energy has worked with the RSPO (Roundtable on sustainable Palm Oil) and declared some material grown however during year 4 no palm feedstocks have been purchased

deg Harvest Energy has been purchasing more feedstock for biofuel processing in its Teesside plant This is material is only grown to ldquoRTFO environmental qualifying farming standardsrdquo and only from countries with low risk of deforestation and environmental damage Feedstocks have been purchased to both ISCC and the Assured Combinable Crops (ACCS) standard now known as Red Tractor

RTFO Year 4a 10

deg Harvest Energy has had no prosecutions against it for breaches in compliance with any

Other Information

environmental and or social regulations relating to biofuel activities

deg Harvest Energy is committed to being a first class operator in the Biofuel market Harvestrsquos ambitions are to remain amongst the best performers of GHG saving Biofuel providers and is continuing to build and advance its robust data systems to handle chain of custody

deg Harvestrsquos more recent moves into feedstock procurement and processing has significantly improved GHG savings and ldquoqualifying standardrdquo biofuel in the fuel chain for Year 4 and Year 5

deg Harvest Energy is currently collaborating with the University of Durham and the Plymouth Marine Laboratory in a project aimed at developing the next generation of feedstocks for biofuel production from algae The work is supported by a pound22m LINK grant from the Biotechnology and Biological Sciences Research Council and the Department of Energy and Climate Change

RTFO Year 4a 11

deg In the RTFO Year 4 (20112012) Harvest has employed the international inspection

Data Verification

company ldquoInspectoraterdquo to perform verification of Carbon and Sustainability datareported under the RTFO

deg Inspectorate is one of the worldrsquos leading inspection and testing organisations with more

than 11000 experienced members of staff Their biofuels department provides expertise

in analytical and inspection services to biofuel producers and suppliers in accordance with

the framework of ISAE 3000 Inspectorate has international commodity coverage and

experience and as such is a suitable and qualified verifier for the RTFO

deg Further to minimum requirements Harvest has employed voluntary 3rd party verification

and assurance of its largest biofuels suppliers

deg A verifierrsquos assurance statement will accompany this report RTFO Year 4a 12

Statement Reference Number IIL-CampS-2012-HE05 v1 Date 21

st September 2012

To Mr James Ross Head of Trading Harvest Energy Limited 2 Cavendish Square London W1G 0PU

Independent Limited Assurance Opinion Statement

1 RESPONSIBILITIES

It was the responsibility of Harvest Energy Limited to prepare the Annual CampS Report for the period 15 April to 14 December 2011 of year four χΊχΜ ΑF Χι 4΄ Σ ΣΣϢΜ ζΪιχ χΪ χ DζιχΣχ Ϊι ΑιΣνζΪιχ ζιζι ϴ Hιϭνχ EΣιͽϴ χ 1492012

It is the responsibility of Inspectorate International to provide the client with assurance conclusions and a limited assurance opinion on this report

ΣνζχΪιχ Ίν ΪΣ Ϊ χ ϮΪιΜν ΜΊΣͽ ΊΣνζχΊΪΣ Σ χνχΊΣͽ organisations Our independent inspection and testing services are delivered at key trading locations across the world and we have more than 11000 experienced members of staff Our biofuels departments provide expertise in analytical and inspection services to biofuel producers and suppliers Inspectorate International affirms our independence from Harvest Energy Limited being free from bias and conflicts of interest with the organisation its subsidiaries and stakeholders

Inspectorate considers the auditor to be competent to perform assurance projects in accordance with ISAE 3000 and understand the CampS data reported in the ROS system The auditor has the following qualifications AIEMA BEng MSc

2 ASSURANCE CRITERIA

The assurance was performed against the following criteria and in accordance with the ISAE 3000 to verify the stated consignments of Harvest Energy ΊΊχ ΊΪϢΜ Camp χ νϢΊννΊΪΣν ΪΣ χ DΑν system

Carbon and Sustainability Reporting within the Renewable Transport Fuel Obligation Technical Guidance Part One (Version 43 Nov 2011)

Carbon and Sustainability Reporting within the Renewable Transport Fuel Obligation Technical Guidance Part Two Carbon Reporting ndash Default Values and Fuel Chains (Version 42 May 2011)

The following principles were used to assess the CampS data bull Traceability bull Completeness bull Consistency bull Accuracy

Page 1 of 3

3 WORK PERFORMED

Reported Carbon and Sustainability Data

The ROS entries for the period 15 April to 14 December were subject to risk based sampling in order to verify compliance to RTFO technical guidance with respect to the criteria as detailed in section 2 of this report

Supporting Documentation

Using interviews of relevant personnel review of data CampS data and supporting management process documentation the following activities were conducted to verify the reported CampS data for the consignments sampled

Personnel interviews o Mr James Ross ndash Biofuels Trader o Mr Umang Patel ndash Biofuels Analyst

Review of document control processes o RTFO Procedures

Review of Mass balance spreadsheets o Harvest Mass Balance Amsterdam Storage o Harvest Mass Balance Teesside o Harvest Mass Balance Teesside refinery o Harvest Mass Balance Grangemouth o Harvest Mass Balance ThamesVopak o Harvest Mass Balance Standic Dordrecht

Review of Feedstock records (as available) o Contract Documents o Supplier Data o Shipping Documents o Third Party Outturn Certificates o Voluntary Scheme Certificates and proofs of conformity

Review of independent third party verification reports (as available)

Review of CampS records o As relevant to ROS entries

Review of ROS CampS data o 15 April 2011 to 14 December 2011

Chain of Custody

Data samples were reviewed from primary source along the chain of custody using production records supplier and seller certificates of authenticity and ROS report entries as relevant to Harvest Energy Limited operations These were in turn verified againsχ χ χ ιζΪιχ ΊΣ χ DΑν νϴνχ΅

The CampS data submissions for the sampled consignments were reviewed and found to contain all sections and content in line with requirements

All observations and opportunities for improvement raised throughout this limited assurance audit were effectively actioned by the client and closed out

Controls

Inspectorate did not rely on Harvest Energy ΊΊχν νϴνχν Σ Ϊι ΪΣχιΪΜν Ϊϭι Camp χ ΊΣ ΪιΊΣͽ our audit conclusion

Page 2 of 3

4 LIMITATIONS

VerificχΊΪΣ Ϊ χ νχΪΙ χ Ϊι Ϣν ΊΣ Hιϭνχ EΣιͽϴν ΪϮΣ ζΜΣχ ΪϢχνΊ Ϊ χ χιΊΜ Μι in ROS was not assessed as a part of this report claims relating to this feedstock are not included as a part of this verification

The limited assurance engagement contains the risk of verifying data using a review of a risk based selected sample of CampS data

Where presented independent 3rd party verification reports were relied upon as a part of the evidence to support CampS claims

The accuracy of the reported data is dependent on the accuracy of metering and other production measurement arrangements employed at site

5 LIMITED ASSURANCE CONCLUSION amp OPINION STATEMENT

Nothing has come to our attention to cause us to believe that the data presented in χ ιζΪιχ RTFO Χι 4΄ Σ ΣΣϢΜ ζΪιχ χΪ χ DζιχΣχ Ϊι ΑιΣνζΪιχ ζιζι ϴ Hιϭνχ EΣιͽϴ χ 1492012 has not been prepared in all material respects in accordance with the criteria

This report was prepared by Dominik Tichar Lead Verifier

Inspectorate International Limited 2 Perry Road Witham Essex CM8 3TU United Kingdom

Page 3 of 3

Voluntary Scheme Developments

deg Since the RTFO order implemented the Renewable Energy Directive (RED) sustainability criteria Harvest Energy has purchased the majority of its product from feedstocks certified under approved voluntary schemes such as the International Sustainability amp Carbon Certification scheme (ISCC)

deg In the past Harvest Energy has worked with the RSPO (Roundtable on sustainable Palm Oil) and declared some material grown however during year 4 no palm feedstocks have been purchased

deg Harvest Energy has been purchasing more feedstock for biofuel processing in its Teesside plant This is material is only grown to ldquoRTFO environmental qualifying farming standardsrdquo and only from countries with low risk of deforestation and environmental damage Feedstocks have been purchased to both ISCC and the Assured Combinable Crops (ACCS) standard now known as Red Tractor

RTFO Year 4a 10

deg Harvest Energy has had no prosecutions against it for breaches in compliance with any

Other Information

environmental and or social regulations relating to biofuel activities

deg Harvest Energy is committed to being a first class operator in the Biofuel market Harvestrsquos ambitions are to remain amongst the best performers of GHG saving Biofuel providers and is continuing to build and advance its robust data systems to handle chain of custody

deg Harvestrsquos more recent moves into feedstock procurement and processing has significantly improved GHG savings and ldquoqualifying standardrdquo biofuel in the fuel chain for Year 4 and Year 5

deg Harvest Energy is currently collaborating with the University of Durham and the Plymouth Marine Laboratory in a project aimed at developing the next generation of feedstocks for biofuel production from algae The work is supported by a pound22m LINK grant from the Biotechnology and Biological Sciences Research Council and the Department of Energy and Climate Change

RTFO Year 4a 11

deg In the RTFO Year 4 (20112012) Harvest has employed the international inspection

Data Verification

company ldquoInspectoraterdquo to perform verification of Carbon and Sustainability datareported under the RTFO

deg Inspectorate is one of the worldrsquos leading inspection and testing organisations with more

than 11000 experienced members of staff Their biofuels department provides expertise

in analytical and inspection services to biofuel producers and suppliers in accordance with

the framework of ISAE 3000 Inspectorate has international commodity coverage and

experience and as such is a suitable and qualified verifier for the RTFO

deg Further to minimum requirements Harvest has employed voluntary 3rd party verification

and assurance of its largest biofuels suppliers

deg A verifierrsquos assurance statement will accompany this report RTFO Year 4a 12

Statement Reference Number IIL-CampS-2012-HE05 v1 Date 21

st September 2012

To Mr James Ross Head of Trading Harvest Energy Limited 2 Cavendish Square London W1G 0PU

Independent Limited Assurance Opinion Statement

1 RESPONSIBILITIES

It was the responsibility of Harvest Energy Limited to prepare the Annual CampS Report for the period 15 April to 14 December 2011 of year four χΊχΜ ΑF Χι 4΄ Σ ΣΣϢΜ ζΪιχ χΪ χ DζιχΣχ Ϊι ΑιΣνζΪιχ ζιζι ϴ Hιϭνχ EΣιͽϴ χ 1492012

It is the responsibility of Inspectorate International to provide the client with assurance conclusions and a limited assurance opinion on this report

ΣνζχΪιχ Ίν ΪΣ Ϊ χ ϮΪιΜν ΜΊΣͽ ΊΣνζχΊΪΣ Σ χνχΊΣͽ organisations Our independent inspection and testing services are delivered at key trading locations across the world and we have more than 11000 experienced members of staff Our biofuels departments provide expertise in analytical and inspection services to biofuel producers and suppliers Inspectorate International affirms our independence from Harvest Energy Limited being free from bias and conflicts of interest with the organisation its subsidiaries and stakeholders

Inspectorate considers the auditor to be competent to perform assurance projects in accordance with ISAE 3000 and understand the CampS data reported in the ROS system The auditor has the following qualifications AIEMA BEng MSc

2 ASSURANCE CRITERIA

The assurance was performed against the following criteria and in accordance with the ISAE 3000 to verify the stated consignments of Harvest Energy ΊΊχ ΊΪϢΜ Camp χ νϢΊννΊΪΣν ΪΣ χ DΑν system

Carbon and Sustainability Reporting within the Renewable Transport Fuel Obligation Technical Guidance Part One (Version 43 Nov 2011)

Carbon and Sustainability Reporting within the Renewable Transport Fuel Obligation Technical Guidance Part Two Carbon Reporting ndash Default Values and Fuel Chains (Version 42 May 2011)

The following principles were used to assess the CampS data bull Traceability bull Completeness bull Consistency bull Accuracy

Page 1 of 3

3 WORK PERFORMED

Reported Carbon and Sustainability Data

The ROS entries for the period 15 April to 14 December were subject to risk based sampling in order to verify compliance to RTFO technical guidance with respect to the criteria as detailed in section 2 of this report

Supporting Documentation

Using interviews of relevant personnel review of data CampS data and supporting management process documentation the following activities were conducted to verify the reported CampS data for the consignments sampled

Personnel interviews o Mr James Ross ndash Biofuels Trader o Mr Umang Patel ndash Biofuels Analyst

Review of document control processes o RTFO Procedures

Review of Mass balance spreadsheets o Harvest Mass Balance Amsterdam Storage o Harvest Mass Balance Teesside o Harvest Mass Balance Teesside refinery o Harvest Mass Balance Grangemouth o Harvest Mass Balance ThamesVopak o Harvest Mass Balance Standic Dordrecht

Review of Feedstock records (as available) o Contract Documents o Supplier Data o Shipping Documents o Third Party Outturn Certificates o Voluntary Scheme Certificates and proofs of conformity

Review of independent third party verification reports (as available)

Review of CampS records o As relevant to ROS entries

Review of ROS CampS data o 15 April 2011 to 14 December 2011

Chain of Custody

Data samples were reviewed from primary source along the chain of custody using production records supplier and seller certificates of authenticity and ROS report entries as relevant to Harvest Energy Limited operations These were in turn verified againsχ χ χ ιζΪιχ ΊΣ χ DΑν νϴνχ΅

The CampS data submissions for the sampled consignments were reviewed and found to contain all sections and content in line with requirements

All observations and opportunities for improvement raised throughout this limited assurance audit were effectively actioned by the client and closed out

Controls

Inspectorate did not rely on Harvest Energy ΊΊχν νϴνχν Σ Ϊι ΪΣχιΪΜν Ϊϭι Camp χ ΊΣ ΪιΊΣͽ our audit conclusion

Page 2 of 3

4 LIMITATIONS

VerificχΊΪΣ Ϊ χ νχΪΙ χ Ϊι Ϣν ΊΣ Hιϭνχ EΣιͽϴν ΪϮΣ ζΜΣχ ΪϢχνΊ Ϊ χ χιΊΜ Μι in ROS was not assessed as a part of this report claims relating to this feedstock are not included as a part of this verification

The limited assurance engagement contains the risk of verifying data using a review of a risk based selected sample of CampS data

Where presented independent 3rd party verification reports were relied upon as a part of the evidence to support CampS claims

The accuracy of the reported data is dependent on the accuracy of metering and other production measurement arrangements employed at site

5 LIMITED ASSURANCE CONCLUSION amp OPINION STATEMENT

Nothing has come to our attention to cause us to believe that the data presented in χ ιζΪιχ RTFO Χι 4΄ Σ ΣΣϢΜ ζΪιχ χΪ χ DζιχΣχ Ϊι ΑιΣνζΪιχ ζιζι ϴ Hιϭνχ EΣιͽϴ χ 1492012 has not been prepared in all material respects in accordance with the criteria

This report was prepared by Dominik Tichar Lead Verifier

Inspectorate International Limited 2 Perry Road Witham Essex CM8 3TU United Kingdom

Page 3 of 3

deg Harvest Energy has had no prosecutions against it for breaches in compliance with any

Other Information

environmental and or social regulations relating to biofuel activities

deg Harvest Energy is committed to being a first class operator in the Biofuel market Harvestrsquos ambitions are to remain amongst the best performers of GHG saving Biofuel providers and is continuing to build and advance its robust data systems to handle chain of custody

deg Harvestrsquos more recent moves into feedstock procurement and processing has significantly improved GHG savings and ldquoqualifying standardrdquo biofuel in the fuel chain for Year 4 and Year 5

deg Harvest Energy is currently collaborating with the University of Durham and the Plymouth Marine Laboratory in a project aimed at developing the next generation of feedstocks for biofuel production from algae The work is supported by a pound22m LINK grant from the Biotechnology and Biological Sciences Research Council and the Department of Energy and Climate Change

RTFO Year 4a 11

deg In the RTFO Year 4 (20112012) Harvest has employed the international inspection

Data Verification

company ldquoInspectoraterdquo to perform verification of Carbon and Sustainability datareported under the RTFO

deg Inspectorate is one of the worldrsquos leading inspection and testing organisations with more

than 11000 experienced members of staff Their biofuels department provides expertise

in analytical and inspection services to biofuel producers and suppliers in accordance with

the framework of ISAE 3000 Inspectorate has international commodity coverage and

experience and as such is a suitable and qualified verifier for the RTFO

deg Further to minimum requirements Harvest has employed voluntary 3rd party verification

and assurance of its largest biofuels suppliers

deg A verifierrsquos assurance statement will accompany this report RTFO Year 4a 12

Statement Reference Number IIL-CampS-2012-HE05 v1 Date 21

st September 2012

To Mr James Ross Head of Trading Harvest Energy Limited 2 Cavendish Square London W1G 0PU

Independent Limited Assurance Opinion Statement

1 RESPONSIBILITIES

It was the responsibility of Harvest Energy Limited to prepare the Annual CampS Report for the period 15 April to 14 December 2011 of year four χΊχΜ ΑF Χι 4΄ Σ ΣΣϢΜ ζΪιχ χΪ χ DζιχΣχ Ϊι ΑιΣνζΪιχ ζιζι ϴ Hιϭνχ EΣιͽϴ χ 1492012

It is the responsibility of Inspectorate International to provide the client with assurance conclusions and a limited assurance opinion on this report

ΣνζχΪιχ Ίν ΪΣ Ϊ χ ϮΪιΜν ΜΊΣͽ ΊΣνζχΊΪΣ Σ χνχΊΣͽ organisations Our independent inspection and testing services are delivered at key trading locations across the world and we have more than 11000 experienced members of staff Our biofuels departments provide expertise in analytical and inspection services to biofuel producers and suppliers Inspectorate International affirms our independence from Harvest Energy Limited being free from bias and conflicts of interest with the organisation its subsidiaries and stakeholders

Inspectorate considers the auditor to be competent to perform assurance projects in accordance with ISAE 3000 and understand the CampS data reported in the ROS system The auditor has the following qualifications AIEMA BEng MSc

2 ASSURANCE CRITERIA

The assurance was performed against the following criteria and in accordance with the ISAE 3000 to verify the stated consignments of Harvest Energy ΊΊχ ΊΪϢΜ Camp χ νϢΊννΊΪΣν ΪΣ χ DΑν system

Carbon and Sustainability Reporting within the Renewable Transport Fuel Obligation Technical Guidance Part One (Version 43 Nov 2011)

Carbon and Sustainability Reporting within the Renewable Transport Fuel Obligation Technical Guidance Part Two Carbon Reporting ndash Default Values and Fuel Chains (Version 42 May 2011)

The following principles were used to assess the CampS data bull Traceability bull Completeness bull Consistency bull Accuracy

Page 1 of 3

3 WORK PERFORMED

Reported Carbon and Sustainability Data

The ROS entries for the period 15 April to 14 December were subject to risk based sampling in order to verify compliance to RTFO technical guidance with respect to the criteria as detailed in section 2 of this report

Supporting Documentation

Using interviews of relevant personnel review of data CampS data and supporting management process documentation the following activities were conducted to verify the reported CampS data for the consignments sampled

Personnel interviews o Mr James Ross ndash Biofuels Trader o Mr Umang Patel ndash Biofuels Analyst

Review of document control processes o RTFO Procedures

Review of Mass balance spreadsheets o Harvest Mass Balance Amsterdam Storage o Harvest Mass Balance Teesside o Harvest Mass Balance Teesside refinery o Harvest Mass Balance Grangemouth o Harvest Mass Balance ThamesVopak o Harvest Mass Balance Standic Dordrecht

Review of Feedstock records (as available) o Contract Documents o Supplier Data o Shipping Documents o Third Party Outturn Certificates o Voluntary Scheme Certificates and proofs of conformity

Review of independent third party verification reports (as available)

Review of CampS records o As relevant to ROS entries

Review of ROS CampS data o 15 April 2011 to 14 December 2011

Chain of Custody

Data samples were reviewed from primary source along the chain of custody using production records supplier and seller certificates of authenticity and ROS report entries as relevant to Harvest Energy Limited operations These were in turn verified againsχ χ χ ιζΪιχ ΊΣ χ DΑν νϴνχ΅

The CampS data submissions for the sampled consignments were reviewed and found to contain all sections and content in line with requirements

All observations and opportunities for improvement raised throughout this limited assurance audit were effectively actioned by the client and closed out

Controls

Inspectorate did not rely on Harvest Energy ΊΊχν νϴνχν Σ Ϊι ΪΣχιΪΜν Ϊϭι Camp χ ΊΣ ΪιΊΣͽ our audit conclusion

Page 2 of 3

4 LIMITATIONS

VerificχΊΪΣ Ϊ χ νχΪΙ χ Ϊι Ϣν ΊΣ Hιϭνχ EΣιͽϴν ΪϮΣ ζΜΣχ ΪϢχνΊ Ϊ χ χιΊΜ Μι in ROS was not assessed as a part of this report claims relating to this feedstock are not included as a part of this verification

The limited assurance engagement contains the risk of verifying data using a review of a risk based selected sample of CampS data

Where presented independent 3rd party verification reports were relied upon as a part of the evidence to support CampS claims

The accuracy of the reported data is dependent on the accuracy of metering and other production measurement arrangements employed at site

5 LIMITED ASSURANCE CONCLUSION amp OPINION STATEMENT

Nothing has come to our attention to cause us to believe that the data presented in χ ιζΪιχ RTFO Χι 4΄ Σ ΣΣϢΜ ζΪιχ χΪ χ DζιχΣχ Ϊι ΑιΣνζΪιχ ζιζι ϴ Hιϭνχ EΣιͽϴ χ 1492012 has not been prepared in all material respects in accordance with the criteria

This report was prepared by Dominik Tichar Lead Verifier

Inspectorate International Limited 2 Perry Road Witham Essex CM8 3TU United Kingdom

Page 3 of 3

deg In the RTFO Year 4 (20112012) Harvest has employed the international inspection

Data Verification

company ldquoInspectoraterdquo to perform verification of Carbon and Sustainability datareported under the RTFO

deg Inspectorate is one of the worldrsquos leading inspection and testing organisations with more

than 11000 experienced members of staff Their biofuels department provides expertise

in analytical and inspection services to biofuel producers and suppliers in accordance with

the framework of ISAE 3000 Inspectorate has international commodity coverage and

experience and as such is a suitable and qualified verifier for the RTFO

deg Further to minimum requirements Harvest has employed voluntary 3rd party verification

and assurance of its largest biofuels suppliers

deg A verifierrsquos assurance statement will accompany this report RTFO Year 4a 12

Statement Reference Number IIL-CampS-2012-HE05 v1 Date 21

st September 2012

To Mr James Ross Head of Trading Harvest Energy Limited 2 Cavendish Square London W1G 0PU

Independent Limited Assurance Opinion Statement

1 RESPONSIBILITIES

It was the responsibility of Harvest Energy Limited to prepare the Annual CampS Report for the period 15 April to 14 December 2011 of year four χΊχΜ ΑF Χι 4΄ Σ ΣΣϢΜ ζΪιχ χΪ χ DζιχΣχ Ϊι ΑιΣνζΪιχ ζιζι ϴ Hιϭνχ EΣιͽϴ χ 1492012

It is the responsibility of Inspectorate International to provide the client with assurance conclusions and a limited assurance opinion on this report

ΣνζχΪιχ Ίν ΪΣ Ϊ χ ϮΪιΜν ΜΊΣͽ ΊΣνζχΊΪΣ Σ χνχΊΣͽ organisations Our independent inspection and testing services are delivered at key trading locations across the world and we have more than 11000 experienced members of staff Our biofuels departments provide expertise in analytical and inspection services to biofuel producers and suppliers Inspectorate International affirms our independence from Harvest Energy Limited being free from bias and conflicts of interest with the organisation its subsidiaries and stakeholders

Inspectorate considers the auditor to be competent to perform assurance projects in accordance with ISAE 3000 and understand the CampS data reported in the ROS system The auditor has the following qualifications AIEMA BEng MSc

2 ASSURANCE CRITERIA

The assurance was performed against the following criteria and in accordance with the ISAE 3000 to verify the stated consignments of Harvest Energy ΊΊχ ΊΪϢΜ Camp χ νϢΊννΊΪΣν ΪΣ χ DΑν system

Carbon and Sustainability Reporting within the Renewable Transport Fuel Obligation Technical Guidance Part One (Version 43 Nov 2011)

Carbon and Sustainability Reporting within the Renewable Transport Fuel Obligation Technical Guidance Part Two Carbon Reporting ndash Default Values and Fuel Chains (Version 42 May 2011)

The following principles were used to assess the CampS data bull Traceability bull Completeness bull Consistency bull Accuracy

Page 1 of 3

3 WORK PERFORMED

Reported Carbon and Sustainability Data

The ROS entries for the period 15 April to 14 December were subject to risk based sampling in order to verify compliance to RTFO technical guidance with respect to the criteria as detailed in section 2 of this report

Supporting Documentation

Using interviews of relevant personnel review of data CampS data and supporting management process documentation the following activities were conducted to verify the reported CampS data for the consignments sampled

Personnel interviews o Mr James Ross ndash Biofuels Trader o Mr Umang Patel ndash Biofuels Analyst

Review of document control processes o RTFO Procedures

Review of Mass balance spreadsheets o Harvest Mass Balance Amsterdam Storage o Harvest Mass Balance Teesside o Harvest Mass Balance Teesside refinery o Harvest Mass Balance Grangemouth o Harvest Mass Balance ThamesVopak o Harvest Mass Balance Standic Dordrecht

Review of Feedstock records (as available) o Contract Documents o Supplier Data o Shipping Documents o Third Party Outturn Certificates o Voluntary Scheme Certificates and proofs of conformity

Review of independent third party verification reports (as available)

Review of CampS records o As relevant to ROS entries

Review of ROS CampS data o 15 April 2011 to 14 December 2011

Chain of Custody

Data samples were reviewed from primary source along the chain of custody using production records supplier and seller certificates of authenticity and ROS report entries as relevant to Harvest Energy Limited operations These were in turn verified againsχ χ χ ιζΪιχ ΊΣ χ DΑν νϴνχ΅

The CampS data submissions for the sampled consignments were reviewed and found to contain all sections and content in line with requirements

All observations and opportunities for improvement raised throughout this limited assurance audit were effectively actioned by the client and closed out

Controls

Inspectorate did not rely on Harvest Energy ΊΊχν νϴνχν Σ Ϊι ΪΣχιΪΜν Ϊϭι Camp χ ΊΣ ΪιΊΣͽ our audit conclusion

Page 2 of 3

4 LIMITATIONS

VerificχΊΪΣ Ϊ χ νχΪΙ χ Ϊι Ϣν ΊΣ Hιϭνχ EΣιͽϴν ΪϮΣ ζΜΣχ ΪϢχνΊ Ϊ χ χιΊΜ Μι in ROS was not assessed as a part of this report claims relating to this feedstock are not included as a part of this verification

The limited assurance engagement contains the risk of verifying data using a review of a risk based selected sample of CampS data

Where presented independent 3rd party verification reports were relied upon as a part of the evidence to support CampS claims

The accuracy of the reported data is dependent on the accuracy of metering and other production measurement arrangements employed at site

5 LIMITED ASSURANCE CONCLUSION amp OPINION STATEMENT

Nothing has come to our attention to cause us to believe that the data presented in χ ιζΪιχ RTFO Χι 4΄ Σ ΣΣϢΜ ζΪιχ χΪ χ DζιχΣχ Ϊι ΑιΣνζΪιχ ζιζι ϴ Hιϭνχ EΣιͽϴ χ 1492012 has not been prepared in all material respects in accordance with the criteria

This report was prepared by Dominik Tichar Lead Verifier

Inspectorate International Limited 2 Perry Road Witham Essex CM8 3TU United Kingdom

Page 3 of 3

Statement Reference Number IIL-CampS-2012-HE05 v1 Date 21

st September 2012

To Mr James Ross Head of Trading Harvest Energy Limited 2 Cavendish Square London W1G 0PU

Independent Limited Assurance Opinion Statement

1 RESPONSIBILITIES

It was the responsibility of Harvest Energy Limited to prepare the Annual CampS Report for the period 15 April to 14 December 2011 of year four χΊχΜ ΑF Χι 4΄ Σ ΣΣϢΜ ζΪιχ χΪ χ DζιχΣχ Ϊι ΑιΣνζΪιχ ζιζι ϴ Hιϭνχ EΣιͽϴ χ 1492012

It is the responsibility of Inspectorate International to provide the client with assurance conclusions and a limited assurance opinion on this report

ΣνζχΪιχ Ίν ΪΣ Ϊ χ ϮΪιΜν ΜΊΣͽ ΊΣνζχΊΪΣ Σ χνχΊΣͽ organisations Our independent inspection and testing services are delivered at key trading locations across the world and we have more than 11000 experienced members of staff Our biofuels departments provide expertise in analytical and inspection services to biofuel producers and suppliers Inspectorate International affirms our independence from Harvest Energy Limited being free from bias and conflicts of interest with the organisation its subsidiaries and stakeholders

Inspectorate considers the auditor to be competent to perform assurance projects in accordance with ISAE 3000 and understand the CampS data reported in the ROS system The auditor has the following qualifications AIEMA BEng MSc

2 ASSURANCE CRITERIA

The assurance was performed against the following criteria and in accordance with the ISAE 3000 to verify the stated consignments of Harvest Energy ΊΊχ ΊΪϢΜ Camp χ νϢΊννΊΪΣν ΪΣ χ DΑν system

Carbon and Sustainability Reporting within the Renewable Transport Fuel Obligation Technical Guidance Part One (Version 43 Nov 2011)

Carbon and Sustainability Reporting within the Renewable Transport Fuel Obligation Technical Guidance Part Two Carbon Reporting ndash Default Values and Fuel Chains (Version 42 May 2011)

The following principles were used to assess the CampS data bull Traceability bull Completeness bull Consistency bull Accuracy

Page 1 of 3

3 WORK PERFORMED

Reported Carbon and Sustainability Data

The ROS entries for the period 15 April to 14 December were subject to risk based sampling in order to verify compliance to RTFO technical guidance with respect to the criteria as detailed in section 2 of this report

Supporting Documentation

Using interviews of relevant personnel review of data CampS data and supporting management process documentation the following activities were conducted to verify the reported CampS data for the consignments sampled

Personnel interviews o Mr James Ross ndash Biofuels Trader o Mr Umang Patel ndash Biofuels Analyst

Review of document control processes o RTFO Procedures

Review of Mass balance spreadsheets o Harvest Mass Balance Amsterdam Storage o Harvest Mass Balance Teesside o Harvest Mass Balance Teesside refinery o Harvest Mass Balance Grangemouth o Harvest Mass Balance ThamesVopak o Harvest Mass Balance Standic Dordrecht

Review of Feedstock records (as available) o Contract Documents o Supplier Data o Shipping Documents o Third Party Outturn Certificates o Voluntary Scheme Certificates and proofs of conformity

Review of independent third party verification reports (as available)

Review of CampS records o As relevant to ROS entries

Review of ROS CampS data o 15 April 2011 to 14 December 2011

Chain of Custody

Data samples were reviewed from primary source along the chain of custody using production records supplier and seller certificates of authenticity and ROS report entries as relevant to Harvest Energy Limited operations These were in turn verified againsχ χ χ ιζΪιχ ΊΣ χ DΑν νϴνχ΅

The CampS data submissions for the sampled consignments were reviewed and found to contain all sections and content in line with requirements

All observations and opportunities for improvement raised throughout this limited assurance audit were effectively actioned by the client and closed out

Controls

Inspectorate did not rely on Harvest Energy ΊΊχν νϴνχν Σ Ϊι ΪΣχιΪΜν Ϊϭι Camp χ ΊΣ ΪιΊΣͽ our audit conclusion

Page 2 of 3

4 LIMITATIONS

VerificχΊΪΣ Ϊ χ νχΪΙ χ Ϊι Ϣν ΊΣ Hιϭνχ EΣιͽϴν ΪϮΣ ζΜΣχ ΪϢχνΊ Ϊ χ χιΊΜ Μι in ROS was not assessed as a part of this report claims relating to this feedstock are not included as a part of this verification

The limited assurance engagement contains the risk of verifying data using a review of a risk based selected sample of CampS data

Where presented independent 3rd party verification reports were relied upon as a part of the evidence to support CampS claims

The accuracy of the reported data is dependent on the accuracy of metering and other production measurement arrangements employed at site

5 LIMITED ASSURANCE CONCLUSION amp OPINION STATEMENT

Nothing has come to our attention to cause us to believe that the data presented in χ ιζΪιχ RTFO Χι 4΄ Σ ΣΣϢΜ ζΪιχ χΪ χ DζιχΣχ Ϊι ΑιΣνζΪιχ ζιζι ϴ Hιϭνχ EΣιͽϴ χ 1492012 has not been prepared in all material respects in accordance with the criteria

This report was prepared by Dominik Tichar Lead Verifier

Inspectorate International Limited 2 Perry Road Witham Essex CM8 3TU United Kingdom

Page 3 of 3

3 WORK PERFORMED

Reported Carbon and Sustainability Data

The ROS entries for the period 15 April to 14 December were subject to risk based sampling in order to verify compliance to RTFO technical guidance with respect to the criteria as detailed in section 2 of this report

Supporting Documentation

Using interviews of relevant personnel review of data CampS data and supporting management process documentation the following activities were conducted to verify the reported CampS data for the consignments sampled

Personnel interviews o Mr James Ross ndash Biofuels Trader o Mr Umang Patel ndash Biofuels Analyst

Review of document control processes o RTFO Procedures

Review of Mass balance spreadsheets o Harvest Mass Balance Amsterdam Storage o Harvest Mass Balance Teesside o Harvest Mass Balance Teesside refinery o Harvest Mass Balance Grangemouth o Harvest Mass Balance ThamesVopak o Harvest Mass Balance Standic Dordrecht

Review of Feedstock records (as available) o Contract Documents o Supplier Data o Shipping Documents o Third Party Outturn Certificates o Voluntary Scheme Certificates and proofs of conformity

Review of independent third party verification reports (as available)

Review of CampS records o As relevant to ROS entries

Review of ROS CampS data o 15 April 2011 to 14 December 2011

Chain of Custody

Data samples were reviewed from primary source along the chain of custody using production records supplier and seller certificates of authenticity and ROS report entries as relevant to Harvest Energy Limited operations These were in turn verified againsχ χ χ ιζΪιχ ΊΣ χ DΑν νϴνχ΅

The CampS data submissions for the sampled consignments were reviewed and found to contain all sections and content in line with requirements

All observations and opportunities for improvement raised throughout this limited assurance audit were effectively actioned by the client and closed out

Controls

Inspectorate did not rely on Harvest Energy ΊΊχν νϴνχν Σ Ϊι ΪΣχιΪΜν Ϊϭι Camp χ ΊΣ ΪιΊΣͽ our audit conclusion

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4 LIMITATIONS

VerificχΊΪΣ Ϊ χ νχΪΙ χ Ϊι Ϣν ΊΣ Hιϭνχ EΣιͽϴν ΪϮΣ ζΜΣχ ΪϢχνΊ Ϊ χ χιΊΜ Μι in ROS was not assessed as a part of this report claims relating to this feedstock are not included as a part of this verification

The limited assurance engagement contains the risk of verifying data using a review of a risk based selected sample of CampS data

Where presented independent 3rd party verification reports were relied upon as a part of the evidence to support CampS claims

The accuracy of the reported data is dependent on the accuracy of metering and other production measurement arrangements employed at site

5 LIMITED ASSURANCE CONCLUSION amp OPINION STATEMENT

Nothing has come to our attention to cause us to believe that the data presented in χ ιζΪιχ RTFO Χι 4΄ Σ ΣΣϢΜ ζΪιχ χΪ χ DζιχΣχ Ϊι ΑιΣνζΪιχ ζιζι ϴ Hιϭνχ EΣιͽϴ χ 1492012 has not been prepared in all material respects in accordance with the criteria

This report was prepared by Dominik Tichar Lead Verifier

Inspectorate International Limited 2 Perry Road Witham Essex CM8 3TU United Kingdom

Page 3 of 3

4 LIMITATIONS

VerificχΊΪΣ Ϊ χ νχΪΙ χ Ϊι Ϣν ΊΣ Hιϭνχ EΣιͽϴν ΪϮΣ ζΜΣχ ΪϢχνΊ Ϊ χ χιΊΜ Μι in ROS was not assessed as a part of this report claims relating to this feedstock are not included as a part of this verification

The limited assurance engagement contains the risk of verifying data using a review of a risk based selected sample of CampS data

Where presented independent 3rd party verification reports were relied upon as a part of the evidence to support CampS claims

The accuracy of the reported data is dependent on the accuracy of metering and other production measurement arrangements employed at site

5 LIMITED ASSURANCE CONCLUSION amp OPINION STATEMENT

Nothing has come to our attention to cause us to believe that the data presented in χ ιζΪιχ RTFO Χι 4΄ Σ ΣΣϢΜ ζΪιχ χΪ χ DζιχΣχ Ϊι ΑιΣνζΪιχ ζιζι ϴ Hιϭνχ EΣιͽϴ χ 1492012 has not been prepared in all material respects in accordance with the criteria

This report was prepared by Dominik Tichar Lead Verifier

Inspectorate International Limited 2 Perry Road Witham Essex CM8 3TU United Kingdom

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