Business Code of Conduct

Policy statement

Global Chartering Limited (GCL) has prepared this Business Code of Conduct that applies to everybody we have a contractual relationship with, including our employees, senior management, customers, and Ship Managers.

Policy context

This Business Code of Conduct 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.

Adherence to this Business Code of Conduct is mandatory; there are no exceptions.

Requirements

GCL requires the highest standards of professional and ethical conduct. No one at the Company is permitted to achieve results through violations of laws or regulations, or through unscrupulous dealings.

GCL is committed to undertaking its business activities in accordance with our Human Rights Policy, Modern Slavery Statement, Health and Safety Policy, Environmental Policy, and Whistleblower Policy.

GCL aims for its business practices to be compatible with, and sensitive to, the economic and social priorities of each location in which it operates. Although customs vary from country to country, and standards of ethics may vary in different business environments, honesty and integrity must always characterise the Company’s business activity.

Where there is uncertainty as to how employees should proceed with the application of this Business Code of Conduct, they must request guidance, so that we can act in an open and transparent manner.

GCL commits to undertaking business activities in compliance with applicable laws, rules and regulations in applicable jurisdictions, and international maritime conventions.

Activities that generate a conflict of interest are prohibited, unless specifically approved in advance by senior management and independent legal counsel.

Insider trading is prohibited, along with the improper communication of undisclosed material regarding the Company.

The Company, and its directors, officers, employees, consultants, and contractors are prohibited from trading in securities of any company while in possession of material non-public information regarding that company. It is prohibited to ‘tip’ or pass on inside information to any person who might make an investment decision based on that information or pass the information on to a third-party.

Offering or receiving any gift, gratuity, or entertainment that influences, or might be perceived to unfairly influence a business relationship, should be avoided. The value of gifts should be nominal with respect to their frequency and amount. All gifts must be recorded in a Gift Register.

It is prohibited for any employee to offer, to obtain or retain an advantage during business, directly or indirectly, a loan, reward, advantage or benefit of any kind to a foreign public official, or to any person for the benefit of a public official. The use of facilitation payments by employees is prohibited.

An employee is prohibited from engaging in public relation activities, including contact with the media or other external organisation, without the prior authorisation of senior management.

The confidentiality of data held by the company must be maintained in accordance with our Cyber Security Policy.
Company assets including laptops, phones, funds, and other types must be held securely by employees, and used primarily for the purpose of Company business.

E-Mail systems and internet services are provided to facilitate and perform the affairs of the Company. Incidental and occasional personal use is permitted but shall not interfere with an individual’s employment duties.

Employees must not access, send or download any information that could be insulting or offensive to another person, such as sexually explicit messages, ethnic or racial slurs, or messages that could be viewed as discriminatory or harassment.

Social media should not be used at any time during working hours unless specifically part of an employee’s work description. It is prohibited to comment about the Company or its subsidiaries and their assets on social media at any time unless part of a pre-approved activity.

Monitoring and reporting

This Business Code of Conduct shall be implemented through our employee induction and training activities, internal due diligence procedure, internal audit, and from the use of external auditors.

Should any employee, seafarer, or other stakeholder identify a potential breach of the requirements of this Business Code of Conduct, they must immediately report the occurrence using our Whistleblowing Policy.

We will include details of how this Business Code of Conduct is being implemented in our Annual Environmental and Social Report. This shall include details of the steps taken to raise awareness of this Business Code of Conduct.

Consequence of breach

Violations of this Business Code of Conduct by our employees may subject the person involved to disciplinary actions and other consequences as prescribed by law.

Violations of this Business Code of Conduct by contracted parties may 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 this Business Code of Conduct.

Internal references

  • ArcelorMittal Code of Business Conduct
  • DryLog Ltd Market Abuse Policy External references

This Code of Business Conduct is derived from the:

  • United Nations Universal Declaration of Human Rights and the International Bill of Human Rights
  • International Labour Organisation Declaration of Fundamental Principles and Rights at Work
  • The General Data Protection Regulation (GDPR)
  • The United Kingdom Bribery Act 2010

Management review

This Business Code of Conduct, together with all other aspects of the GCL Environmental and Social Management System (ESMS) will undergo annual review by the GCL senior leadership team.

Further information

For more information about this Business Code of Conduct, its content and/or application, please contact: [email protected]