Anti-Bribery and Corruption Policy

Policy statement

Global Chartering Limited (GCL) has zero tolerance for all forms of corruption and performs its business in an honest and fair manner. This is achieved by adhering to applicable laws and regulations, creating a company culture of high business ethics standards, as well as maintaining good relationships with Ship Managers, and other business partners.

Policy context

This Anti-Bribery and Corruption Policy reflects GCL’s commitment to a culture of honesty, integrity and accountability and outlines the basic principles which everyone at the Company is expected to comply.

This Anti-Bribery and Corruption Policy is supported by our Business Code of Conduct.

Requirements

GCL prohibits all employees from accepting, promising, or requesting an improper benefit for the performance of their professional duties. It is also strictly prohibited to give, promise, or offer an improper benefit to someone else for the performance of the recipient’s or a third person’s professional duty. Facilitation payments are prohibited.

In relation to governmental decision making, benefits must never be offered to public sector representatives, their associates, or any other party with the intent of influencing a decision.

Hospitality and events (such as a dinner, entertainment event, or attendance at a seminar) involving government officials must demonstrate reasonable expenditure and be only provided where the officials are not involved in any ongoing government approval or decision-making process. Gifts are never allowed to be provided to employees or representatives of the public sector.

Employees may attend corporate events and seminars that have a clear and legitimate business purpose.

GCL can make charitable donations for which no tangible business advantage or benefit is expected or received. Donations shall be made in a transparent manner and made public on our website.

Monitoring and reporting

This Anti-Bribery and Corruption Policy shall be implemented through our employee induction and training activities, internal audit, and through the use of external auditors.

Should any employee, Ship Manager, seafarer, or other stakeholder identify a potential breach of the requirements of this Anti-Bribery and Corruption Policy, they must immediately report the occurrence using our Whistleblower Policy.

We will include details of how this Anti-Bribery and Corruption Policy is being implemented in our Annual Environmental and Social Report. This shall include details of the steps taken to raise awareness of this Anti-Bribery and Corruption Policy.

Consequence of breach

Violations of this Anti-Bribery and Corruption Policy by our employees may subject the person or organisation involved to disciplinary actions and other consequences as prescribed by law.

Violations of this Anti-Bribery and Corruption Policy by contracted parties will lead to contract termination and
other penalties. GCL shall cooperate with all government authorities and may commence legal actions against employees or companies found guilty of inappropriate behaviour covered by the Anti-Bribery and Corruption Policy.

Internal references

  • ArcelorMittal Human Rights Policy
  • ArcelorMittal Code of Business Conduct
  • DryLog Limited Anti-Bribery & Anti-Corruption Policy
  • Global Chartering Limited Whistleblower Policy
  • Global Chartering Limited Business Code of Conduct
  • Global Chartering Limited Supplier Code of Conduct

External references

This Anti-Bribery and Corruption Policy is derived from the: The United Kingdom Bribery Act 2010

Self-certification process

To demonstrate implementation of this Anti-Bribery and Corruption Policy GCL shall undertake an annual audit to check that our requirements are being implemented internally amongst employees, but also by Ship Managers who will also be required to self-certify their compliance with the Anti-Bribery and Corruption Policy.

Further information

For more information about this Anti-Bribery and Corruption Policy, its content and/or application, please contact: [email protected]