Anti-Bribery and Anti-Corruption

COMPANY POLICY ON CORRUPTION AND ANTI-BRIBERY

Eleen Marine JSC is committed to complying with the laws and regulations of the countries in which it operates in accordance with United Nations Convention against Corruption (UNCAC) 2005, IMO regulations-requirements and the guidelines of Maritime Anti-Corruption Network (MACN).

Eleen Marine JSC., its employees, officers and crew members onboard our vessels under management will perform all business activities acting in an ethical manner, consistent with the principles of honesty, integrity, fairness and respect.

Bribery and the related improper conduct referred to in this Regulation are serious criminal offences for both the company and any individuals involved. They are also inconsistent with Eleen Marine JSC values. Laws prohibiting the types of improper payments covered by this policy apply in all of the countries in which Eleen Marine JSC, have operations in, or engage within trading activities.

Eleen Marine JSC, employees and officers and crew members on board vessels under management must:

Understand and comply with this policy;

  • Not give, offer, accept or request bribes, facilitation payments, secret commissions or other prohibited payments or engage in money laundering or cause any of them to be given, offered, accepted or requested;
  • Not approve any offers, or make, accept or request an irregular payment or other miss of value, to win business or influence a business decision in favor of the Eleen Marine JSC;
  • Comply with any reporting and approval processes for gifts, entertainment or hospitality;
  • Not offer or receive any gifts, entertainment or hospitality to or from public, private or government officials or politicians;
  • Obtain required approvals for donations and sponsorship;
  • Maintain accurate records of dealings with third parties;
  • Be vigilant and report any breaches of, or suspicious behavior related to, this policy.

In order to achieve this, Eleen Marine JSC will:

  • Provide training, guidance to employees on Eleen Marine JSC., anti-bribery & anti-corruption policy.
  • Require all shore-based employees to report gifts and entertainment offered.
  • Record all gifts and entertainment received or given on board.
  • Appoint an Anti-Bribery & Anti-Corruption Representative to ensure adherence and compliance to the policy.

This policy cannot be amended without approval from the Eleen Marine JSC board or its authorized representative/s.

COMPANY POLICY ON HARASSMENT AND BULLYING

We stand up against discrimination of religion, race or sexual orientation.

No seafarer should be harassed or bullied onboard of any ship. There is no different person from anyone else onboard. All of our employees and seafarers employed on vessels take the responsibility to ensure that their ship is free of harassment and bullying.

Harassment is considered any act which creates feelings of unease, humiliation, embarrassment, intimidation, or discomfort to any employee.

The Company treats all complaints of harassment, bullying or cyber-bullying strictly and considers them a legal matter.