Simplified Due Diligence Guide for Refineries
When someone claims to be a refinery or connected to a refinery (as owner, operator, or authorised seller), you must verify they are real, legally allowed to operate, and not carrying hidden risks. Due diligence is simply checking their papers and records carefully before any deal.
This process protects you from fake claims, expired licences, safety problems, environmental fines, or legal trouble later.
Core Documents the Seller / Refinery Company Must Provide
Ask for clear, coloured scans or originals of the following. Prefer documents issued in the last 3–5 years, with visible issue and expiry dates.
1. Company Identity & Ownership Papers
- Certificate of Incorporation / Company Registration
- Memorandum & Articles of Association
- Latest shareholding structure / ownership chart
- Board resolution authorising the person dealing with you
- Tax registration and VAT/GST certificates (country-specific)
2. Key Operating Licences & Permits
| Document | Why it matters | What to check |
|---|---|---|
| Industrial / Operational Safety Permit | Confirms the plant is allowed to run high-risk units | Validity dates, any suspensions |
| Environmental / Ecological Permit + EIA approval | Shows they meet emission, waste and water rules | EIA approval letter + recent monitoring reports |
| Fire Safety Certificate | Critical for flammable operations | Latest audit and training records |
| Hazardous Substances / Chemical Handling Licence | Allows storage and processing of crude and products | Storage and transport compliance |
| Construction & Operation Permits | Proves the plant itself is legally built and running | Land-use and building approvals |
| Energy Efficiency Certificate (if required in that country) | Shows they meet energy standards | Latest audit |
* EIA means Environmental Impact Assessment. The government (Ministry of Environment / Ecology) reviews the EIA report and either approves, rejects, or asks for changes. The EIA report typically includes:
-
- Description of the project
- Baseline environmental conditions (current air/water quality)
- Predicted impacts
- Mitigation plans
- Public consultation (sometimes)
- Monitoring plan after approval
3. Special Licences (only if applicable)
- Subsoil / Mining / Upstream licence (only if they extract crude themselves)
- Local Content Compliance certificates (required in many countries for state-linked refineries)
- Foreign investment / national security approvals (if foreign ownership is involved)
- Antimonopoly / competition authority approvals (if there was a recent sale or merger)
4. Compliance & History Records (very important)
- Environmental monitoring reports for the last 3–5 years
- Safety audit reports for the last 3–5 years
- List of any fines, violations, suspensions or corrective actions in the last 5 years
- Proof that all major permits have been renewed on time
- Central Bank / currency control registration (for large foreign-currency deals)
5. Supporting Commercial Documents
- Current feedstock supply contracts or offtake agreements
- Insurance policies (property, liability, environmental)
- Recent independent third-party inspection or technical audit reports (if available)
Simple Step-by-Step Process
- Request the full set Send a clear checklist and give a firm deadline (usually 7–10 days).
- Verify authenticity Check dates, stamps, and issuing authority. Where possible, confirm the document number on the official government portal or by writing to the ministry.
- Look for red flags
- Expired or soon-to-expire licences
- Repeated environmental or safety fines
- Missing local content or ownership papers
- Person signing has no board authority
- Use local experts if needed For important deals, engage a local lawyer or consultant who knows that country’s energy regulator.
- Keep everything organised Put all received documents in one secure folder (data room) with a simple index.
Quick Priority Order
Focus first on these three:
- Industrial Safety Permit
- Environmental Permit + recent reports
- Company ownership and authorisation papers
If these three are clean and valid, the rest of the checks become much easier.
