Code of Conduct update

Code of Conduct update

By Jamie Morgan Ramsamy, Head of HSSEQ | September 15, 2022


The complexity of business risks is ever-increasing in a dynamic world so being agile to react to those changes is vital for any organization. Complimentary to external factors is an organization’s ability to review internal risks and address those challenges to mitigate future threats. These are the reasons that the guidelines of our Code of Conduct were revamped at the beginning of the year to reflect the myriad of needs that a global maritime services company needs to have.

Since the first quarter of 2022, we formed a Code of Conduct led by the Head of Legal, Head of HR, and Head of HSSEQ. This committee reviews all Code of Conduct matters across the Group to ensure that policies are effectively implemented, roll out plans for future controls and processes are uniformly handled and cascaded, in addition to handling and reviewing whistleblowing cases.

An additional sub-committee, the Advisory Committee, was created simultaneously to address the implementation of policies by way of processes and controls. This committee reviews the effectiveness of strategies such as customer due diligence (know your customer – KYC), third-party risks such as supplier due diligence, and operational risks such as vessel sanctions screening measures. Quarterly reviews will be carried out to ensure that organizational risks are adequately addressed, measured, risk assessed, and recommendations are escalated to the Code of Conduct Committee.

The guidelines were updated to adequately cascade the requirements for each of the areas under both the Code of Conduct and Advisory Committees to ensure employee awareness is of the highest priority. Similarly, training programs for each code of conduct area are currently being reviewed to ensure that it is adequately updated to address the needs and challenges of an ever-increasing maritime compliance environment.


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