This guideline is created to provide examples and to clarify the Company Ethical Code and the expectation of ethical behaviour by our Employees, Vendors and Subcontractors. It, however, does not cover every situation to which the Code applies. It also defines the disciplinary procedure imposed for the violation.
3.1 GIFTS, REBATES OR COMMISSIONS FROM THE SUPPLIER/BUSINESS PARTNERS
Gifts which are prohibited refer to any kind of money, goods, service or treatment given or received by personnel with the purpose of personal gain, or with the intention of changing an outcome.
Rebates, Discounts or Commissions
All rebates or discounts given by the vendor, supplier/subcontractor/third party belongs to the Company. All Crew and Employees are prohibited to accept any commission/complimentary in cash or in kind, directly or indirectly (via bank transfer or a third party) for personal gain.
Vendors and Subcontractors are expected to comply by not offering or giving any gifts, favours, entertainment, rebates, commissions or discounts to the Company’s employees or crew outside the acceptable norms defined in this Code.
The guidelines include goods and services provided by the supplier/business partner to the company personnel unless given to on behalf of the company, not individually or personally.
Examples of prohibited gifts are as follows:
- All gifts received at home and office including hampers, parcels of food.
- Commissions, discounts, rebates or “thank you” gifts to employees or crew.
Any sexually oriented or immoral activity or gift.
- Service for free or special offers from the vendor, supplier/subcontractor/third parties.
- Cell phone vouchers or credit
Examples of allowable gifts are as follows:
- Donation or sponsorship for company event from vendor, supplier/subcontractor.
- Compassionate gift of modest value that is given to a personnel during illness/maternity (such as bouquet, cake,fruits) gifts that has been declared by the personnel to the superior.
- Promotional merchandise such as calendars, agendas, pens and t-shirts bearing the logo of the vendor,supplier/subcontractor.
3.2 BUSINESS TRIP / ACCOMMODATION EXPENSES
Example of prohibited actions:
- Accept payment for business trips, hotel expenses, domestic or international by vendor, supplier, shipyard or subcontractors that have not been previously approved and agreed in writing between the Companies.
- Providing fake receipts of any purchases, expenses, including hotel bills, meals, transport etc.
- Marking up actual costs.
- Conduct unnecessary trips during business trips.
- Giving to or receiving money or gifts from vessel crew.
- Include company expenses, unrelated personal or family member expenses during business trips.
Example of non- prohibited actions:
Business trip expenses where a charterer/business party requires for the personnel to be represented by the company.
Such trip is allowed after proper procedures have been carried out.
Although general modest/reasonable entertainment are normal business/social behaviour, personnel should refuse a dining invitation or other treats which are offered either in excess of social norm or too frequent in order to avoid dishonour or to maintain objectivity in carrying out Company duties.
In cases where it would be impolite to refuse an invitation, personnel must seek prior approval from direct superior before accepting.
Examples of prohibited entertainment are as follows:
- Accepting any ticket to events with or without the provider present.
- Using provider’s facilities such as: house, villa for personal use.
- Any kind of entertainment (meals, services, tickets) outside the limits of proper business hospitality.
- Any form of sexual or immoral activity.
Examples of non- prohibited entertainment are as follows:
- Business related, modest and infrequent meals
- An entertainment with the presence of the giver and within the limits of proper business hospitality eg. modest dining.
- Entertainment should be reported in the entertainment register.
3.4 LOAN TO/ FROM THE VENDOR, SUPPLIER OR SUBCONTRACTOR
All personnel or his/her relatives are prohibited to offer, guarantee or receive a loan to or from any business entity or their intermediary or anyone who has a business relation with the Company