Safety Policy
The Management of BENETECH SHIPPING S.A. is committed to take all reasonable
precautions and measures, during the operation of managed vessels, in order to ensure safety
at sea, prevention of human injury or loss of life and avoidance of damage to property.
The Company’s goal is to achieve ZERO incidents through continuous improvement.
To fulfil these objectives, the management is committed to the following approach:
▪ Compliance with mandatory rules and regulations and taking into consideration the Codes
guidelines and standards recommended by the IMO, Flag Administrations, Class Societies
and Industry organizations, applicable to operations of managed vessels.
▪ Adherence to an Integrated Management System (IMS) by all Company’s employees,
including managed vessels, which promotes the concept of HSSQEEn excellence,
continuous improvement and enhancement of personnel skills.
▪ Assigning employees possessing sound skills and capabilities in required areas of
responsibility, including adequate verification resources.
▪ Defining the organization, responsibility, authority and interfacing of the various
management functions within the frame of the IMS.
▪ Providing for safe and environmentally sound practices in the operation of managed
vessels.
▪ Providing and maintaining a safe working environment onboard to assist in preventing
human injury and loss of life.
▪ Providing the necessary training to ensure that Company’s employees are capable of
achieving safety and pollution prevention objectives in the work they perform.
▪ Providing facilities, systems/equipment and a maintenance system that is suited for the
purpose of achieving objectives.
▪ Conducting management review meetings and management system audits.
This Policy has the full support of Top Management and applies to all Company’s employees.
Quality Policy
BENETECH SHIPPING S.A. endeavours to earn the confidence of the shipowners, charterers,
seafarers and the marine industry and be recognized as a high quality, trustworthy international
ship manager. This can only be achieved by providing flawless services that satisfy all relevant
requirements. The Company shall always provide professional ship management services to
owners and charterers, protect their interests and assets under its care, and fulfil all their
expectations.
The Company:
• Is committed to always comply with all applicable legal and other requirements that relate to
the pertinent hazards and to continually improve the effectiveness of its IMS.
• Adopts a proactive approach concerning the needs of its clients and is responsive to their
requests, suggestions or complaints, always trying to improve the value of its services.
• Encourages employee teamwork, personal improvement, cooperation, innovative thinking,
initiative, leadership, decisiveness and focus on client’s needs and satisfaction.
• Sets measurable and meaningful objectives and targets and reviews them when appropriate.
• Addresses the needs of interested parties who receive its services or who may be impacted
by them.
In order to objectively assess its performance, the Company:
• Establishes criteria for the quality of its services.
• Monitors, measures and analyses its objectives and targets for continual suitability to verify
that processes are effectively implemented.
• Identifies and manages the risks and opportunities of its services.
The IMS defines the methods used to achieve Company’s Policies and the associated objectives
and targets. Its implementation ensures that all applicable requirements related to managing
ships will be satisfied, thus providing the necessary confidence between the Company and its
customers.
The Company’s management considers its IMS as the basic tool for providing consistent and
effective ship management service and improvement, provides sufficient resources and reviews it
regularly to ensure its continuous suitability and effectiveness. The management commits itself in
active implementation of the IMS and requires all involved personnel to do the same.
Every suggestion for improvement will be given full attention and will be brought to the highest
level of the management.
All Company’s employees, ashore and at sea, are expected to comply with this policy and work
towards achieving Company’s objectives. The success of the Company depends on the
commitment and involvement of each individual employee.
This policy is continuously reviewed for its suitability and is available to the public and the
Company’s customers, vendors and suppliers.
Environmental Policy
BENETECH SHIPPING S.A. is committed through continuous efforts to improve environmental
performance in all areas required by the international regulations and laws and Company’s IMS
and EMS and to ensure:
▪ Pollution prevention that emphasizes source reduction, including necessary funding and
human resources, to effectively maintain the on board systems, equipment and components.
▪ Continuous reduction of environmental risks.
▪ Sharing information on environmental performance with external stakeholders.
▪ Minimizing the environmental impact of its operations
The Company’s goal is to achieve Zero spills or releases to the environment and reduction
in permitted emissions through continuous improvement.
For achieving this goal, the Company:
▪ Complies with all applicable environmental laws, regulations and requirements and applies
responsible standards where laws, regulations and requirements do not exist.
▪ Responds quickly and effectively to environmental incidents resulting from its operations, in
co-operation with industry organizations and authorized government agencies.
▪ Assesses all identified risks to the environment and establishes appropriate safeguards.
▪ Shows concern and respect for the environment, emphasizes every employee’s
responsibility in environmental performance and fosters appropriate operating practices and
training.
▪ Undertakes appropriate reviews and evaluations of its operations to measure progress and
to foster compliance with this Policy.
▪ Conducts and supports research to improve understanding of the impact of its business on
the environment, to improve methods of environmental protection and to enhance its
capability to make operations compatible with the environment.
▪ Manages its business with the goal of preventing environmental incidents and of controlling
emissions and wastes to below harmful levels.
▪ Designs, operates and maintains facilities to this end.
▪ Shares its experience with others to facilitate improvements in industry performance.
This Policy has the full support of Top Management, is available to the public and applies to all
Company’s employees ashore and onboard.
Health and Hygiene Policy
BENETECH SHIPPING S.A. holds health and hygiene as first priority in its operations, while its
outmost concern is to always ensure that all employees execute their work under safe and
hygienic conditions. In order to ensure high standards of health and hygiene, the Company:
▪ Complies with all applicable legislation and regulations, observes relevant guidelines, and
applies responsible standards where laws and regulations do not exist.
▪ Seeks to identify and evaluate health and hygiene risks related to its operations that
potentially affect employees, contractors or the public and establishes appropriate
safeguards.
▪ Communicates knowledge about health and hygiene risks to individuals in potential risk or
organizations and the scientific community.
▪ Determines at the time of employment and thereafter, as appropriate, the medical fitness of
employees to perform their work without undue risk to themselves or others.
▪ Implements programs and appropriate protective measures to control such risks, including
appropriate monitoring of employees in potential risk.
▪ Provides or arranges, as appropriate, for medical services necessary for the treatment of
employee occupational illnesses or injuries and for the handling of medical emergencies.
▪ Provides voluntary health and hygiene promotion programs designed to enhance employees’
well-being and personal safety. These programs should supplement, but not interfere with,
the responsibility of employees over their own health care.
▪ Undertakes appropriate reviews and evaluations of its operations to measure progress and
to foster compliance with this Policy.
The Company’s goal is to achieve the highest standards of health and personal hygiene
through continuous improvement.
Information about employees are confidential and should not be revealed to non-medical
personnel except at the request of the employee concerned, or when required by law, when
dictated by overriding public health considerations, or when necessitated by the Company’s Drug
and Alcohol Policy.
This Policy has the full support of Top Management, is available to the public and applies to all
Company’s employees.
Energy Efficiency Management Policy
BENETECH SHIPPING S.A, having established and implementing an Environmental
Management System in accordance with ISO 14001, believes that although shipping is by far the
most fuel-efficient mode of transport, nevertheless additional action has to be taken to further
improve the energy efficiency of ship related operations. The increased energy efficiency
eventually results in increased environmental protection by reducing air emissions.
Energy efficiency is controlled primarily through well-planned and properly managed ship
operations and needs the personal commitment of everyone involved in the above tasks. To be
successful, energy efficiency and conservation must become part of the day to day operation and
living onboard.
In our efforts to enhance the energy efficiency on the shipboard operations, the Company is
committed to:
▪ Establishing and maintaining a Ship Energy Efficiency Management Plan (SEEMP) which is
regularly reviewed by all concerned departments and approved by the management of the
Company. This Plan, which applies to all fleet vessels, provides standard procedures and
practices on best energy management under the various operational modes of the vessel.
▪ Implementing an Environmental Management System supported with several environmental
programs with the objective of continually increasing energy efficiency and minimizing
energy waste. A set of time-specific, measurable – whenever practicable – and achievable
targets shall be established and maintained, which shall relate to a combination of design
optimization, in-service performance monitoring and best-practice operational management
processes.
▪ Promoting energy efficiency awareness through training to the shore and sea-going
personnel and implementing energy related Campaigns and other personnel
incentive/motivating programs.
▪ Monitoring and complying with all applicable legal requirements related to ship energy
efficiency management.
This Policy shall be periodically reviewed with the aim of being kept always updated so as to
function as the “leading light” towards a continual energy efficiency improved performance.
Drug and Alcohol Policy
It is the Company’s Policy that NO seafarer, whatever rank, will navigate the vessel or will
operate its equipment while impaired by drugs or alcohol or where there is any risk of such
impairment.
In following this Policy, BENETECH SHIPPING S.A.:
▪ Has banned all alcoholic beverages from its managed vessels.
▪ Has banned any form of drug, with the exception of prescribed drugs, as well as the misuse
of legitimate drugs. If a crewmember is found in possession of drugs then the Local
Authorities will be contacted immediately.
▪ Has implemented random testing of all crew for banned substances and alcohol.
▪ Controls the use of all medical supplies on board the managed vessels.
▪ Will dismiss and impose penalty, as per National and International regulations, to anybody:
- using alcohol or banned substances on board the vessel;
- caught in possession of alcohol or banned substances;
- found to have been instrumental in bringing alcohol or banned substances on board;
- found to have a positive trace in any random testing sample, unless prior notice with
authorisation for use, had been given to the Master. - On no account shall a person under the influence of drugs or alcohol, be allowed to stand
watch or perform any other duty, involving the safety of the vessel, her crew or cargo, and
the public. - Will take all disciplinary action, including dismissal, against anybody consuming alcohol,
while ashore, for at least 4 hrs prior scheduled watchkeeping duties or work period. - Any crewmember suspected for being under the influence of drugs or alcohol, while on duty,
shall be immediately relieved from his duty and placed under observation until the influence
of drugs or alcohol subsides. - All crewmembers understand that it is their duty and benefit, to report immediately to the
appropriate Officer or the Master, if they suspect or have evidence that one of their fellow
crewmembers is intoxicated. - The use of alcohol on the part of the pilot while performing his duties is strictly prohibited; if a
pilot is noticed to be under the influence of substances resulting to the incapability of
performing his duties will not be allowed to be part of the bridge team. - Requires all new recruits, prior their embarkation, to undergo a Drug and Alcohol test.
All employees must be adequately informed on the provisions of this Policy and must comply with
their intent. This Policy has the full support of Top Management and applies to all employees.
Cyber Security Policy
BENETECH SHIPPING S.A. aims to:
▪ Protect information assets – including data printed or written on paper, stored electronically,
transmitted by post or electronic means, stored on tape or video, or spoken in conversation –
from all threats, whether internal or external, deliberate or accidental.
▪ Make sure operations continuity.
The Company’s management, to fulfill these objectives, is committed to ensure:
▪ Compliance with regulatory requirements
▪ Protection of information and systems identified as vulnerable to cyberattacks from loss of
confidentiality (information accessibility only to authorized individuals), integrity (safeguard
accuracy and completeness of information and processing methods), and availability (authorized
individuals have access to relevant information when required)
▪ Preparation of cybersecurity contingency plans
▪ Cybersecurity training to all staff
▪ Reporting and investigation of all security breaches, actual or suspected.
To support this Policy, there are procedures in place, including incident handling, information backup,
system access, antivirus controls, passwords, and encryption
Social Media Policy
This policy outlines the necessary principles that users of social media shall observe, the
conditions in which Internet activity will be monitored and actions to be taken upon violation of the
established policy. The Company, expects all individuals to comply with this policy at all times
and to protect the Company’s reputation.
This policy deals with the use and misuse of social media platforms and other websites including
but not limited to:
• Social networking websites such as Facebook, CrewToo, MySpace, LinkedIn, Yahoo!
Groups, QQ.com, VK.com .
• Micromedia / Microblogging websites such as Twitter.
• Multimedia websites such as YouTube and Instagram.
• Wikis such as Wikipedia.
• Blogs and
• News sites where content and comments can be posted.
• Any other website where user-generated content can be posted for wider sharing.
This policy applies to all individuals working at all levels in the Company, either in the office or on
board the vessels and covers the use of social media (as outlined above) during work and nonwork
hours, on personal and Company supplied equipment such as laptop computers and
cellular / smart phones.
The Managing Director, Heads of Departments and ships’ Masters are responsible for ensuring
that the standards set forth by this policy are communicated to their teams and that their own
conduct sets a good example in this respect.
The Company recognizes the value of social media and expects all staff to use these tools
responsibly.
The following basic principles should be observed:
• Be responsible. As an employee, any user-generated content could have an impact on the
Company’s reputation, so give careful thought before sharing photographs or video of the
Company assets, particularly our ships, facilities or people in uniform. For example, images
taken during an incident could potentially be detrimental to an investigation.
• Be accurate and honest. In any circumstance in which you are in doubt, or you are uncertain
about how to respond to a post, contact the Company for guidance.
• Do not make posts or comments that may be considered defamatory, obscene, libellous,
threatening, harassing or embarrassing to others.
• Before you post photographs of other people, get their permission first.
• Never use someone else’s copyrights, copyrighted material, trademarks, service marks or
other intellectual property.
• If you see comments relating to the Company that you think should be addressed, contact
the Company for guidance.
• Do not use the Company’s logo (in any form) on any personal social media platform. Use of
any Company logo must be approved by the Company.
• Respect others in any online social interaction. Do not use social media or any similar form
of communication to attack or insult the Company, fellow employees, customers, vendors,
contractors, suppliers, competitors or others.
• Do not disclose any confidential, proprietary or sensitive information about the Company as
well as names of our employees, customers, vendors, contractors, suppliers, competitors or
others. Employees are reminded of Company’s policy on public statements / media
response.
Social Responsibility Policy
BENETECH SHIPPING S.A operates in a socially responsible manner, ensuring the safety of people and the environment, through transparent and ethical behavior, respecting the following principles:
- Accountability for the organization’s impacts on society and the environment;
- Transparency in the organization’s decisions and activities that have impact on society and the environment;
- Ethical behavior at all times;
- Respect, consider and respond to the interests of the Company’s stakeholders and employees;
- Accept that respect for the rule of law is mandatory;
- Respect international norms of behavior, while adhering to the principle of respect for the rule of law; and
- Respect human rights and recognize both their importance and their universality.
The Company addresses the following core subjects in order to identify the issues and priorities that are relevant for the organization: Organizational governance; Human rights; Labor practices; Environment.
Our commitment to this objective is underscored by the daily actions of our employees and their dedication to the numerous programs and practices we have implemented.
We aim to integrate sustainable thinking and corporate social responsibility into all our business processes and business relationships. Employee skills and competencies are developed by continually raising awareness and impartment of training.
We recognize that our operations have a global influence. With this in mind, we work diligently with our employees, local communities and internationally recognized bodies to ensure that social factors are integral to our business principles.
We promote continual improvement as a principal driver by knowledge-sharing practices and the timely review of our management systems while always meeting or exceeding all applicable legislative and regulatory requirements.
Whistleblowing Policy
The Company is confident in the comprehensiveness and effectiveness of its Management System and its role in ensuring the safety of people and the environment, as well as in the effectiveness of its existing reporting channels.
Furthermore, the Company is committed to a workplace characterized by open communication regarding its business practices. As such, this Whistleblowing Policy has been developed to provide a means for employees and seafarers to raise concerns that cannot be, or have not been, adequately addressed via usual reporting channels without fear of retaliation or discrimination over such reports made in good faith.
The Whistleblowing Policy addresses concerns related to issues of public interest, including, but not limited to, the following:
- A criminal offence;
- Non-compliance with legislation and/or Company procedures, particularly in relation to health and safety at work or environmental protection;
- Dishonesty, either verbal or written (including intentionally maintaining official log books or records inaccurately);
- Malpractice or unethical conduct;
- Financial or non-financial misadministration or malpractice or impropriety or fraud;
- A safety and/or security risk or hazardous condition that may impact the life or health of individuals on board the vessel;
- Miscarriages of justice; and
- The deliberate concealment of any of the above.
If an employee has a legitimate concern in (and holds reasonable belief that the information he has relates to) one of the above areas and wishes to raise the concern in good faith, it should be raised with the Master, DPA or other Company’s representative who may be able to agree a way of resolving the concern quickly and effectively.
Although the Company’s Top Management maintains an open-door policy endeavouring to address individuals’ concerns internally, a concern can also be raised through the following channels:
E-mail: whistleblowing@benetechsa.com
Reports can be made without fear of retaliation and be even anonymous. Upon receipt of a report, same will be assessed by the Company’s Top Management and an investigation may commence, if deemed necessary. Any victimization of a member of staff who “whistle-blows”, or any attempt to deter him from reporting, will be regarded as a serious disciplinary offense and will result in action under the Disciplinary Procedures.
Sanction Policy
The Company operates tanker vessels providing worldwide sea transportation services for various cargoes and is subject to multi-jurisdictional (and often extra-territorial) laws regulations, restrictions and/or sanctions to which is committed to identify and comply with as well as maintain objective evidence of compliance with them.
While the Company retains only limited control of the routes or ports of call made by any of its vessels, and the cargo carries, it imposes on the charter party contract restrictions and prohibitions against trade with certain entities or natural persons, and certain cargos and calls at any ports located in countries which are sanctioned by, amongst others, the United Nations, the United States and/or the European Union.
The Company does not have in contravention of such relevant laws, regulations, restrictions and/or sanctions knowingly entered into, or intend in the future to enter into, directly or indirectly, any contracts, agreements or other arrangements involving prohibited cargoes, trade and/or transactions with the governments of, or prohibited entities or natural persons within, Iran, Syria, Sudan, Yemen, Libya, Cuba, Russia & Ukraine, Venezuela or North Korea. As a result, the Company has never knowingly earned and does not intend to earn in the future any revenues resulting from activities that contravene such relevant laws, regulations, restrictions and/or sanctions.
The Company ensures that it is in a position to identity and comply with such relevant laws, regulations, restrictions and/or sanctions, and that it can evidence such compliance. The Operations Department is responsible for monitoring and maintaining copies of such relevant laws, regulations, restrictions and/or sanctions and shipping practices, as well by consultation with the Company’s external Lawyers and Advisors. It is also responsible for procuring appropriate opinions and guidance when presented with a question on whether or not to engage in a particular fixture.
In this respect, prior to engaging in a contractual relationship, the Company’s potential counterparty is screened for acceptance in the following way:
- UK P&I Club website: https://www.ukpandi.com/knowledge-publications/industry-issues/industry-developments/international-sanctions/
- London P&I Club website: https://www.londonpandi.com/knowledge/sanctions/
- SDN (Specially Designated Nationals) search list: http://sdnsearch.ofac.treas.gov/Default.aspx
- Denied Person list: www.bis.doc.gov/index.php/the-denied-persons-list
- Entity list: www.bis.doc.gov/index.php/policy-guidance/lists-of-parties-of-concern/entity-list
- Cyber-Related sanctions program: https://www.treasury.gov/ofac/d
This Policy has the full support of Top Management and applies to all Company’s employees..
Human Factors Policy
BENETECH SHIPPING S.A is committed to the below provisions aiming to minimize human error, optimize human performance and promote safe and efficient operations:
- Enhances understanding of human factors (HFs) and how they are managed.
- Recognizes the link between HFs and safety performance.
- Considers error as normal and an opportunity to learn and improve.
- Creates a safe, healthy, and sustainable work environment from a holistic perspective, understanding and providing for human needs.
- Ensures personnel safety, health, and wellbeing in the optimization of work systems and operations as a top priority.
- Designs and manages work systems and operations to ensure organizational and personnel alignment, minimize risk, continuous evaluation, learning and sustainability.
- Accounts for individual differences and organizational contingencies in the design of work systems and operations.
- Utilizes collective, trans-disciplinary knowledge and full participation of personnel for designing systems, detecting problems and creating solutions for human factor/element in work systems and operations.
- Promotes non-blame culture and speaking up so that everyone feels empowered to highlight issues.
- Encourages everyone to feel they can act to resolve safety issues.
- Promotes, supports and communicates continuous proactive improvement.
- Commits to two-way engagement with the personnel by:
a. Gathering opinions and feedback from frontline personnel.
- Discussing company and leadership values, expectations, and standards.
- Encouraging personnel to speak up about concerns.
- Requiring from Leaders to make themselves available to the workforce through walkabouts and discussions, with the aim of understanding what makes work difficult.
- Respecting and acting on concerns of more junior team members.
- Engages specialists and train personnel to conducting technical, task, behavioural, cognitive and workload assessments and apply results, to minimize the risk that human performance requirements will not be met under all expected conditions.
- Assesses the impact of Company’s culture, leadership, activities, tasks and processes on human situation awareness, motivation, workload, task performance, error, and physical well-being, and implements design changes to minimize negative impacts and improve outcomes.
- Documents HFs plans, activities and results.
All personnel and hired contractors are required to comply with this policy.
Code of Ethics and Code of Conduct
- NEVER be involved in harassment, abuse, discrimination, or child pornography.
- NEVER conceal any identified unsafe act or event which affects or could affect health, safety, the environment, and property.
- Impartially perform their duties and act in honesty and good faith.
- Treat all information regarding operations, projects, or any other work carried out as confidential to the extent that such information does not conflict with Company Policies and is not already disseminated or made generally available to third parties.
- Read, understand, and comply with the information contained in these Codes and with any training or other anti-bribery and anti-corruption information they are given.
- Avoid any activity that is contrary to the spirit and letter of these Codes and that could lead to, or imply, a breach of these Codes.
BENETECH SHIPPING S.A.:
- Commits to carry out its business fairly, honestly, openly and with integrity in all business transactions and relationships, wherever it may operate.
- Does not tolerate bribery, i.e. any type of financial or other advantage of any kind offered, promised or given, whether directly or indirectly, to a Government Official or any other person with the intention to induce or reward the recipient to misuse their position, improperly to perform a function or to provide an unfair business advantage (including facilitation payments, i.e. small bribes to facilitate routine government action).
- Has zero tolerance against fraud and corruption, and any allegations of such conduct by any person performing duties on behalf of the Company will be treated with the utmost seriousness. By avoiding bribery, fraud and corruption, the Company can enjoy enhanced reputation, legal compliance, customer and business partner confidence and in general have a competitive advantage in the market.
- Strongly prohibits any offer, gift or bribe in any form, including kickbacks in all operations as well as the use of other routes or channels for provision of improper benefits to, or receipt of improper benefits from agents, contractors, suppliers, or employees of any such party or government officials.
- Ensures compliance with institutional and regulatory framework regarding measures for the avoidance of bribery.
- Creates actions and procedures that reflect the “zero tolerance” stance of the Company towards any corruption practices and commits to the prevention, detection and proper investigation of bribery, corruption and fraud.
- Records all reports of bribery, corruption and fraud in an official Log, together with relevant information on the event, payment made and individuals involved, which is monitored quarterly so that targeted actions can be taken, and reports them officially.
- Aims to be a pioneer in the industry with respect to its initiatives against bribery, fraud and corruption, and participates in industry fora, thus ensuring it has access to the most recent developments in the field of Ethics and Compliance.
Gifts, Corporate Hospitality and Travel Expenses
The following areas are potentially vulnerable to allegations of bribery:
- Dealings with service providers and suppliers to the Company
- Facilitation payments
- Gifts, Corporate Hospitality and Travel Expenses
- Political and Charitable Donations
- Dealings with foreign public officials
- Introductions and referrals.
Persons representing the Company must not accept or offer gifts (including corporate hospitality and travel expenses payments). The Company prohibits employees from directly or indirectly seeking or accepting payments, fees, services or other gratuities outside the normal course of business duties from any person, company or organization. Gifts or cash or cash equivalents (checks, gift certificates etc.) or other assets of any amount are strictly prohibited. The receipt of sale promotion items of nominal value, occasional meals and reasonable entertainment appropriate to a business relationship are generally acceptable.
All solicitation of or dealings with suppliers, customers and others doing or seeking to do business with the Company will be conducted solely on the basis that reflects both the Company’s best business interests and its high ethical standards. Providing common courtesies, entertainment and occasional meals to individuals involved with aspects of Company’s business in a manner appropriate to the business relationship and associated with business discussions is permitted, provided expenses incurred are reasonable, customary and authorized. No employee shall authorize any payment or use of any funds for a bribe, “kickback” or similar payment, which is directly or indirectly for the benefit of any individual, company or organization, or which is designed to secure favored treatment for the Company. Payments or gifts shall not be made directly or indirectly to any government official if such payment or gift is illegal under the laws of the applicable jurisdiction.
Anti-Money Laundering and Combating Terrorist Financing
Money laundering generally refers to financial transactions in which criminals, including terrorist organizations, attempt to disguise the proceeds, sources or nature of their illicit activities. Money laundering includes all forms of handling or possessing criminal property, including possessing the proceeds of one’s own crime, and facilitating any handling or possession of criminal property. BENETECH SHIPPING S.A.:
- Prohibits any type of activity that constitutes money laundering.
- Requires all its employees to report any suspected event of such nature to the DPA.
- Has a very strict sanctions policy in line with the latest requirements of OFAC, OFSI, AMSA, DFAT, EU, Paris PSC MoU, etc. and complies with all applicable laws, regulations and industry recommendations in relation to anti-money laundering and combating terrorist financing.
- Regularly reviews information of existing and potential business partners and customers and ensures that persons listed in the OFAC (USA), UN and EU sanctions lists are identified and no business is conducted with them.
Prevention of Tax Evasion
Tax evasion is the offense of not paying or underpaying tax that is due. BENETECH SHIPPING S.A.:
- Prohibits any type of activity that constitutes tax evasion or facilitation thereof.
- Requires all employees to report any request from a third party to facilitate tax evasion or any suspected tax evasion to the Company’s DPA.
- Prepares all accounts, invoices and other records relating to dealings with third parties, including suppliers and customers, with strict accuracy and completeness. Accounts are never kept “off-book” to facilitate and never conceal improper payments.
Conflicts of Interests
A conflict of interests occurs when an entity or individual becomes unreliable because of a clash between personal (or self-serving) interests (e.g. money, status, knowledge, relationships or reputation) and professional duties or responsibilities, which clash puts into question whether their actions, judgment or decision-making can be unbiased. BENETECH SHIPPING S.A. requires all employees, crew members and directors to:
- Perform their duties and activities relating to their position with the highest level of integrity and independence, in a professional and ethical manner.
- Not take part or attempt to influence the Company’s decisions to serve their personal interests, if these are not aligned with the Company’s interests.
- Not use their position in the Company or information that they become aware of due to their position in the Company to promote their personal interests.
- Not engage in activities that will bring profit to a competitor of the Company.
- Not act in ways that compromise the Company’s compliance with the applicable laws.
- Report any conflicts of interest that they may face or that other persons relating to the Company are facing as soon as these may arise or come to their attention.
If a conflict comes to the Company’s attention, the Company will attempt to resolve it in a fair and reasonable manner, after assessing all available facts, including by:
- Recusing the conflicted employee from certain decision-making processes
- Transferring the conflicted employee to another position or department
- If the conflict is unavoidable, creating a mitigation plan to manage the effects of the conflict on the Company
- In case of a failure to report a conflict, or in any event of fraudulent behavior, taking disciplinary action
- With respect to a conflicted transaction, engaging in such transaction only if after review it has been deemed to be to the best interest of the Company.