Anti-Bribery and Anti-Corruption Declaration
Issued by: Seachios® Marine Services
Effective Date: January 1, 2024
Last Updated: January 1, 2025
Seachios® Marine Services, a globally recognized leader in maritime services, hereby issues this Anti-Bribery and Anti-Corruption Declaration as an unequivocal and binding affirmation of our zero-tolerance policy against bribery, corruption, and unethical conduct. This declaration reflects our highest commitment to operational integrity, ethical governance, and regulatory compliance, ensuring unparalleled trust, transparency, and accountability across all facets of our business.
This document is a cornerstone of our corporate integrity framework, designed to not only meet but exceed the expectations of national and international laws, global maritime industry standards, and the ethical benchmarks demanded by our clients, partners, and stakeholders.
1. Absolute Zero-Tolerance Policy
At Seachios® Marine Services, we categorically condemn and prohibit all forms of bribery, corruption, coercion, or undue influence in any and all business dealings. This policy extends to:
Bribery and Improper Payments: Prohibiting the offering, giving, soliciting, or receiving of any financial or other advantage to secure or influence improper actions or decisions.
Facilitation Payments: Absolute prohibition of unofficial payments made to expedite routine administrative actions, regardless of jurisdiction.
Kickbacks and Extortion: Denouncing and combating any form of extortion, coercion, or kickbacks in commercial and governmental interactions.
Conflict of Interest: Mandating full disclosure of any personal or professional interests that could conflict with corporate responsibilities.
Gifts, Entertainment, and Hospitality: Enforcing strict limits on giving or accepting gifts, hospitality, or entertainment to ensure they cannot be misconstrued as attempts to influence business outcomes.
We hold all individuals and entities operating under our name to this standard, without exception.
2. Comprehensive Legal and Regulatory Compliance
This declaration enforces compliance with the most stringent anti-corruption laws and standards worldwide, including but not limited to:
Brazilian Clean Company Act (Law No. 12.846/2013): Enabling enforcement against corrupt practices and ensuring corporate accountability.
United Nations Convention Against Corruption (UNCAC): Complying with global anti-corruption principles in international business activities.
U.S. Foreign Corrupt Practices Act (FCPA): Strictly prohibiting improper payments to foreign officials and ensuring accurate corporate financial reporting.
UK Bribery Act 2010: Addressing both domestic and international bribery, including criminalizing the failure to prevent bribery.
OECD Anti-Bribery Convention: Supporting the fight against corruption in international business transactions.
Seachios® Marine Services exceeds compliance with these frameworks, demonstrating leadership in fostering corruption-free environments in all jurisdictions of operation.
3. Binding Scope of Application
This declaration applies universally to all individuals and entities associated with Seachios® Marine Services, encompassing:
Employees, officers, and directors.
Contractors, subcontractors, and consultants.
Agents, intermediaries, and representatives.
Suppliers, business partners, and affiliates.
No individual or entity, regardless of position or relationship, is exempt from these obligations.
4. Governance and Enforcement Framework
We implement a rigorous governance structure to ensure that anti-bribery and anti-corruption measures are deeply embedded in all aspects of our operations:
4.1. Corporate Governance and Oversight
Our Board of Directors and Executive Leadership bear ultimate responsibility for enforcing this declaration. The Compliance Office, led by a dedicated Chief Compliance Officer (CCO), oversees day-to-day enforcement, supported by a robust network of compliance monitors.
4.2. Policies and Internal Controls
Strict Financial Oversight: Ensuring all transactions are meticulously documented, auditable, and compliant with applicable regulations.
Third-Party Due Diligence: Conducting exhaustive background checks and risk assessments for all third parties engaged in business with us.
Contractual Safeguards: Embedding anti-bribery and anti-corruption clauses in all agreements with partners, contractors, and suppliers.
4.3. Whistleblower Protection and Reporting Channels
Seachios® Marine Services provides secure, anonymous, and confidential channels for reporting suspected violations. Our policies guarantee:
Absolute Confidentiality: All reports are handled with the utmost discretion.
Non-Retaliation Assurance: Ensuring protection from retaliation for individuals reporting in good faith.
Rapid Investigation and Remediation: Prompt and thorough investigations of all reported incidents, followed by decisive action.
5. Education and Awareness Programs
We invest in comprehensive and continuous training to ensure all stakeholders understand their obligations under this declaration:
Mandatory Compliance Training: Required for all employees and relevant third parties upon onboarding and on a recurring basis.
Role-Specific Programs: Tailored training for high-risk roles, such as procurement, sales, and government relations.
Cultural Alignment Initiatives: Fostering a corporate culture where integrity and compliance are core values.
6. Enforcement and Disciplinary Measures
Violations of this declaration are met with immediate and uncompromising action, including:
Internal Disciplinary Actions: Including suspension, termination of employment, and contract cancellations.
External Legal Remedies: Referral to regulatory authorities and initiation of criminal or civil proceedings where applicable.
Contractual Remedies: Termination of business relationships with third parties found in violation of this declaration.
These measures ensure that all violations are addressed with the gravity they warrant, reinforcing our commitment to integrity.
7. Monitoring, Auditing, and Continuous Improvement
Seachios® Marine Services is committed to continuously improving its anti-bribery and anti-corruption measures through:
Periodic Audits: Independent internal and external audits to evaluate compliance.
Risk Assessments: Ongoing analysis of vulnerabilities to strengthen controls and protocols.
Policy Revisions: Regular updates to this declaration to reflect evolving legal standards and best practices.
8. Affirmation of Ethical Leadership
As a trusted leader in the maritime services industry, Seachios® Marine Services affirms its absolute dedication to eradicating bribery and corruption. By upholding the highest ethical standards, we ensure trust, reliability, and excellence in all business engagements.
9. Contact Information
For inquiries, concerns, or to report violations, please contact:
Email: [email protected]
Phone: +55 11 3042-0019
Address: Compliance Office, Seachios® Marine Services, R. Visc. de Rio Branco, 67 - Centro, Santos - SP, 11013-030
10. Final Declaration
This Anti-Bribery and Anti-Corruption Declaration is issued as an unequivocal commitment by Seachios® Marine Services to maintain an operational environment free of corruption and unethical practices. It serves as a binding document for all stakeholders, ensuring compliance, integrity, and excellence in every aspect of our global operations.
We hold this declaration as a pillar of our corporate ethos, setting the benchmark for ethical leadership within the maritime services sector and beyond.
