Compliance

Ameritank LLC and TRAK Commercial LP

Effective Date: January 28, 2026
Last Updated: January 28, 2026

1. Our Commitment to Compliance

Ameritank LLC and TRAK Commercial LP (collectively referred to as "Ameritank," "TRAK," "we," "us," or "our") are committed to conducting our business with the highest standards of integrity, ethics, and regulatory compliance. We recognize that our operations in the energy terminal and commercial real estate sectors carry significant responsibilities to our stakeholders, communities, and the environment.

This Compliance page outlines our approach to regulatory compliance, the standards we adhere to, and our commitment to responsible business practices. We believe that strong compliance is not merely a legal obligation but a fundamental component of sustainable business operations.

2. Regulatory Framework

Our operations are subject to extensive federal, state, and local regulations. We maintain comprehensive compliance programs to ensure adherence to all applicable laws and regulations governing our business activities.

2.1 Federal Regulatory Oversight

Our terminal and real estate operations are subject to oversight by numerous federal agencies, including:

U.S. Environmental Protection Agency (EPA): Clean Air Act, Clean Water Act, Resource Conservation and Recovery Act (RCRA), and Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
U.S. Department of Transportation (DOT): Pipeline and Hazardous Materials Safety Administration (PHMSA) regulations governing hazardous materials transportation and storage
U.S. Coast Guard (USCG): Maritime Transportation Security Act (MTSA) and facility security requirements
Occupational Safety and Health Administration (OSHA): Process Safety Management (PSM) standards and workplace safety regulations
U.S. Customs and Border Protection (CBP): Foreign Trade Zone regulations and customs compliance
Department of Homeland Security (DHS): Chemical Facility Anti-Terrorism Standards (CFATS)
Federal Energy Regulatory Commission (FERC): Energy infrastructure regulations where applicable

2.2 State and Local Regulations

In addition to federal requirements, we comply with all applicable Texas state regulations, including those administered by:

Texas Commission on Environmental Quality (TCEQ): Air quality permits, water discharge permits, and waste management requirements
Texas Railroad Commission (RRC): LPG storage and handling regulations
Texas Department of Licensing and Regulation (TDLR): Boiler and pressure vessel safety
Harris County and City of La Porte: Local zoning, permitting, and fire safety requirements

3. Environmental Compliance

Environmental stewardship is central to our operations. We are committed to minimizing our environmental footprint and operating in a manner that protects air, water, and land resources.

3.1 Air Quality

We maintain all required air quality permits and implement emission control technologies and practices to meet or exceed regulatory standards. Our air quality compliance program includes:

Continuous emissions monitoring systems where required
Regular leak detection and repair (LDAR) programs
Vapor recovery systems on storage tanks and loading operations
Periodic source testing and emissions inventories
Compliance with National Emission Standards for Hazardous Air Pollutants (NESHAP)

3.2 Water Quality

We implement comprehensive water management practices to protect surface water and groundwater resources, including:

Stormwater Pollution Prevention Plans (SWPPP)
Spill Prevention, Control, and Countermeasure (SPCC) Plans
Wastewater treatment and discharge monitoring
Secondary containment systems for storage areas
Regular inspections and maintenance of water management infrastructure

3.3 Waste Management

We manage all waste streams in accordance with applicable regulations, including:

Proper characterization, storage, and disposal of hazardous and non-hazardous wastes
Waste minimization and recycling programs
Documentation and recordkeeping for all waste streams
Use of licensed and permitted waste transporters and disposal facilities

3.4 Environmental Reporting

We fulfill all environmental reporting obligations, including Toxic Release Inventory (TRI) reports, Tier II chemical inventory reports, greenhouse gas emissions reports, and annual emissions inventories as required by permit conditions.

4. Health and Safety

The health and safety of our employees, contractors, visitors, and neighboring communities is our highest priority. We maintain rigorous safety programs that meet or exceed regulatory requirements.

4.1 Process Safety Management

Our LPG terminal operations are subject to OSHA's Process Safety Management (PSM) standard. Our PSM program includes:

Comprehensive process hazard analyses
Written operating procedures for all covered processes
Employee training and competency verification
Mechanical integrity programs for critical equipment
Management of change procedures
Pre-startup safety reviews
Incident investigation and corrective action programs
Emergency response planning and coordination
Compliance audits conducted at least every three years

4.2 Occupational Safety

We maintain comprehensive occupational safety programs, including:

Personal protective equipment (PPE) requirements
Confined space entry procedures
Hot work permit systems
Lockout/tagout (LOTO) procedures
Fall protection programs
Respiratory protection programs
Hearing conservation programs
Regular safety training and competency assessments

4.3 Emergency Preparedness

We maintain comprehensive emergency response capabilities, including:

Written emergency response plans
Trained emergency response teams
Fire suppression and detection systems
Emergency shutdown systems
Regular emergency drills and exercises
Coordination with local emergency responders and mutual aid organizations
Community notification procedures

5. Maritime and Transportation Security

As a facility located on the Houston Ship Channel, we comply with all applicable maritime security requirements.

5.1 Maritime Transportation Security Act (MTSA)

Our facility maintains a U.S. Coast Guard-approved Facility Security Plan (FSP) that addresses:

Physical security measures and access control
Security personnel and training requirements
Security monitoring and surveillance systems
Procedures for responding to security threats at various Maritime Security (MARSEC) levels
Coordination with the Captain of the Port and local law enforcement

5.2 Transportation Worker Identification Credential (TWIC)

All personnel requiring unescorted access to secure areas of our facility must possess a valid TWIC issued by the Transportation Security Administration (TSA). We maintain TWIC readers and verification procedures to ensure compliance with access control requirements.

5.3 Chemical Facility Anti-Terrorism Standards (CFATS)

We comply with DHS CFATS requirements, including facility security assessments, site security plans, and inspections as applicable to our operations.

6. Trade Compliance

We are committed to full compliance with all applicable trade laws and regulations.

6.1 Foreign Trade Zone Operations

Our facility operates within or adjacent to Foreign Trade Zone areas. We maintain compliance with all U.S. Customs and Border Protection regulations governing FTZ operations, including:

Proper documentation and recordkeeping
Inventory control and accountability procedures
Customs entry and admission requirements
Zone activity reporting

6.2 Export Controls and Sanctions

We maintain programs to ensure compliance with U.S. export control laws and economic sanctions programs administered by the Bureau of Industry and Security (BIS) and the Office of Foreign Assets Control (OFAC). Our compliance measures include:

Screening of counterparties against restricted party lists
Due diligence on customers and business partners
End-use and end-user verification procedures
Training for personnel involved in international transactions

7. Anti-Corruption and Business Ethics

We conduct our business with integrity and in compliance with all applicable anti-corruption laws.

7.1 Foreign Corrupt Practices Act (FCPA)

We maintain policies and procedures to ensure compliance with the U.S. Foreign Corrupt Practices Act, including:

Prohibition on bribery of foreign officials
Due diligence on agents and intermediaries
Accurate books and records requirements
Training for employees and representatives

7.2 Business Ethics

Our commitment to ethical business practices extends beyond legal compliance. We expect all employees, contractors, and business partners to:

Act with honesty and integrity in all business dealings
Avoid conflicts of interest
Protect confidential information
Maintain accurate records and documentation
Report suspected violations of law or company policy

8. Anti-Money Laundering

We are committed to preventing the use of our operations for money laundering or terrorist financing. Our anti-money laundering (AML) compliance program includes:

Know Your Customer (KYC) due diligence procedures
Customer identification and verification
Beneficial ownership identification
Ongoing monitoring of business relationships
Suspicious activity reporting as required by law
Recordkeeping and documentation requirements

9. Data Protection and Privacy

We are committed to protecting the personal information of our employees, customers, suppliers, and other stakeholders. Our data protection practices are described in detail in our Privacy Policy, which addresses:

Collection and use of personal information
Data security measures
Individual rights regarding personal data
Compliance with applicable privacy laws, including the California Consumer Privacy Act (CCPA), California Privacy Rights Act (CPRA), and Texas Data Privacy and Security Act (TDPSA)

10. Employment and Labor Practices

We are committed to fair and lawful employment practices and compliance with all applicable labor and employment laws.

10.1 Equal Employment Opportunity

We provide equal employment opportunities to all employees and applicants without regard to race, color, religion, sex, national origin, age, disability, genetic information, veteran status, sexual orientation, gender identity, or any other characteristic protected by law.

10.2 Harassment-Free Workplace

We maintain a workplace free from harassment, discrimination, and retaliation. We do not tolerate harassment of any kind and provide mechanisms for employees to report concerns without fear of retaliation.

10.3 Fair Labor Standards

We comply with all applicable wage and hour laws, including the Fair Labor Standards Act (FLSA) and Texas labor laws, ensuring proper classification of employees, accurate timekeeping, and payment of all wages owed.

11. Compliance Governance

We maintain a robust compliance governance structure to ensure effective implementation and oversight of our compliance programs.

11.1 Compliance Oversight

Our compliance function reports to senior management and maintains independence from business operations. Compliance matters are regularly reviewed at the management level to ensure appropriate oversight and resource allocation.

11.2 Policies and Procedures

We maintain written policies and procedures covering all significant compliance areas. These policies are reviewed and updated regularly to reflect changes in laws, regulations, and business operations.

11.3 Training and Communication

We provide regular compliance training to employees based on their roles and responsibilities. Training programs cover regulatory requirements, company policies, and ethical business practices.

11.4 Monitoring and Auditing

We conduct regular monitoring and auditing activities to assess compliance with laws, regulations, and company policies. Audit findings are reported to management and tracked to ensure timely corrective action.

12. Reporting Concerns

We encourage employees, contractors, customers, and other stakeholders to report any suspected violations of law, regulation, or company policy.

12.1 How to Report

Concerns may be reported through the following channels:

Direct communication with supervisors or management
Email to compliance@ameritank.com
Written correspondence to the Compliance Department at our principal office

12.2 Non-Retaliation

We prohibit retaliation against any individual who, in good faith, reports a suspected violation or participates in an investigation. Any employee who engages in retaliation will be subject to disciplinary action.

12.3 Confidentiality

We will maintain the confidentiality of reports to the extent possible, consistent with our obligation to investigate and address concerns and comply with applicable law.

13. Certifications and Industry Standards

In addition to regulatory compliance, we pursue industry certifications and adhere to recognized standards that demonstrate our commitment to operational excellence:

American Petroleum Institute (API) standards for terminal operations
National Fire Protection Association (NFPA) codes and standards
American Society of Mechanical Engineers (ASME) standards for pressure vessels
Industry best practices as promulgated by trade associations

14. Continuous Improvement

We are committed to continuous improvement in our compliance programs. We regularly assess our compliance processes, incorporate lessons learned from internal and external events, and implement enhancements to strengthen our compliance posture.

15. Contact Information

If you have questions about our compliance programs or wish to report a concern, please contact us:

Compliance Inquiries:
Email: compliance@ameritank.com

Mailing Address:
Ameritank LLC / TRAK Commercial LP
Attn: Compliance Department
2012 Miller Cut Off Road
La Porte, Texas 77571
United States

This Compliance page is provided for informational purposes and does not constitute legal advice or create any contractual obligations.