Nedcon Maritime is committed to observing the laws which govern our activities. This policy sets out Nedcon Maritime’s policies to prevent acts of bribery and corruption, it helps you identify the situations in which you deal with bribery and corruption in order to avoid bad practices and being outside the law.

Nedcon Maritime strives to undertake business in a fair and honest manner, acting with integrity in all our dealings. All our activities are conducted in accordance with all applicable legal and regulatory requirements. Nedcon Maritime does not tolerate any form of bribery and corruption.

Nedcon Maritime’s Policy on Bribery and Corruption

We have a zero tolerance stance towards bribery by our employees, agents, consultants, suppliers, joint venture partners or anyone working on our behalf. As such, it is our policy to comply with all rules and legislation governing anti-bribery and corruption law in all the countries in which we operate.

All our employees are required to comply with our anti-bribery policy and this requirement is extended to our agents, consultants, third parties or anyone acting on our behalf.

We periodically review and verify our procedures to ensure compliance and efficacy.

We also have a strong culture in place where employees feel empowered to report any conduct that they believe to be in breach of our policy.

It is a condition of employment that all staff comply with this policy. We also require those agents, consultants and business partners who work on our behalf to comply with this policy.

What is Bribery?

Bribery is offering, receiving, giving, promising or soliciting of a financial or other non-financial advantage to somebody for the purpose of influencing their actions in the discharge of their public or legal duties. The law defines improper performance as a breach of trust, lack of impartiality or performance in bad faith.

Bribes can take many forms, for example:
• cash;
• unreasonable gifts, entertainment or hospitality;
• kickbacks;
• unwarranted rebates or excessive commissions;
• facilitation payments;
• payments made to perform their normal job;
• prioritise a particular person;
• personal favors;
• political/charitable contributions;or
• anything else of value.

Gifts and Hospitality

Nedcon Maritime does not prohibit giving and receiving promotional gifts of low value and normal and appropriate hospitality. However, all gifts and hospitality should be for a genuine purpose, reasonable, given in the ordinary course of business and should comply with the Nedcon Maritime’s Policy and local laws.

Facilitation payments

Facilitation payments are small unofficial payments to ensure or speed up performance of routine or necessary action. These will be seen as bribes by the law and are against Nedcon Maritime’s policy.

We do not make, and will not accept, facilitation payments of any kind. No Nedcon Maritime employee may willingly make or accept a facilitation payment.

Anti-bribery measures

Bribery is wrong. We aim to protect our reputation for integrity by:
• Having a clear anti-bribery policy which focuses on the key areas of risk for our business
• Training all employees so that they understand our anti-bribery policy and are able to recognise and avoid the use of bribery by themselves and others
• Making it easy for our employees to report any suspicion of bribery by providing them with suitable communication channels and handling information provided by them in a sensitive and appropriate way
• Properly investigating instances of alleged bribery and fully assisting with any resulting prosecution process
• Monitoring the effectiveness of our policies and procedures

Concerns

If you are concerned about possible improper conduct, please refer your concerns directly to our Director, or on our Contact Page.