Anti-bribery and anti-corruption
What we will not pay, what a technician does when a payment is demanded in a port, and what we require of the agents and partner firms who act for us.
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Our position
ShipCertify does not offer, pay, request or accept bribes — in any port, in any country, and whatever the local practice. The rule applies to every technician, operations director, documentation and logistics member of staff, and to anyone acting for us: port agents, partner firms, brokers and forwarders. We would rather lose an attendance, or watch a vessel sail before we have finished, than obtain the work or the access that way. This policy is owned by the operations director accountable for compliance, who answers for it at all six bases. It is reviewed every twelve months, and again after any reported demand for a payment or any change in the law it relies on.
The law we work under
We operate through a Turkish legal entity, Ekinek Tarım Gıda ve Denizcilik Ltd Şti, and from a registered office in England, so two bodies of criminal law bear on the same attendance, whatever law is chosen to govern a contract. Section 7 of the UK Bribery Act 2010 creates a corporate offence of failing to prevent bribery by a person who performs services for the organisation. Under section 7(5)(b) it applies to a company incorporated outside the United Kingdom that carries on part of a business there, which we do, from London; and under section 12(5) it is committed irrespective of whether the acts take place in the United Kingdom or elsewhere. The only defence is having adequate procedures in place, measured against the six principles in the guidance published under section 9 of the Act: proportionate procedures, top-level commitment, risk assessment, due diligence, communication including training, and monitoring and review. In Türkiye, bribery is an offence under Article 252 of the Turkish Criminal Code (Law No. 5237), which extends to foreign public officials, and Article 253 provides for measures against legal persons. Neither body of law recognises a facilitation-payment exception. Both the United Kingdom and Türkiye are parties to the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions. This page states the procedures we work to. Behind it sit a signed copy of the policy, a training record showing that each member of staff worked through it on joining and has done so again within the last twelve months, and a register of every payment demand reported to us. The documentation staff hold all three at İstanbul, and a customer completing a supplier questionnaire can request them in writing from compliance@shipcertify.com.
What is prohibited
Offering, giving, promising, requesting, agreeing to receive or accepting anything of value in order to win work, keep work, secure access or influence a decision — directly or through a third party, and whether the other person is a public official or a private one. That includes a kickback on a purchase order for parts or consumables, a payment or favour to a superintendent or a buyer for placing an attendance with us, and anything whatever offered to change the result of an operational test, to keep a finding off a report, or to have a certificate issued that the equipment does not warrant. A report states what was found on board. Nothing in it is for sale.
Facilitation payments
In some ports a small unofficial payment is expected before a boarding is allowed, a gate pass is issued, a launch runs, a consignment is released or an inspection is signed off. A facilitation payment is a bribe. We do not make them, and no coordinator or operations director has the authority to approve one. A technician who refuses a demand is supported: the delay is the company’s cost and not theirs, it counts against no target, and nobody is penalised for an attendance that slipped or was lost because a payment was refused. The demand itself is recorded — the port, the date, who asked, and for what — and reported to the operations director for the base and to compliance within 24 hours of the demand being made, and in any event before the attendance is closed. The one exception is a payment made under duress where a person’s safety is at immediate risk; that is not a disciplinary matter, but it is reported and recorded as soon as the person is safe.
Gifts and hospitality
Modest, proportionate hospitality is a normal part of commercial life and is not prohibited: a meal, a coffee ashore, a small item carrying a company mark. It has to be open, recorded, and never offered or accepted while a tender, a quotation, a purchase order or an inspection outcome is live between the two parties. Cash and cash equivalents are never given or accepted, in any amount and for any reason. Anything worth more than EUR 100 to one person on one occasion is approved by an operations director before it is given or accepted. Everything given or accepted is entered in the gifts and hospitality register either way, approved or not: the documentation staff maintain the register at İstanbul, an entry is made within five working days, and an operations director reads the register every three months.
Port agents and others acting for us
A port agent normally acts for the vessel rather than for us, but the agent is often the person who arranges our boarding, our gate passes and our launch, and who settles a port charge on our behalf. Where any third party acts for us or in our name — an agent, a customs broker, a freight forwarder, a local fixer — we are answerable for what is done on that instruction. So the rules are simple: they do nothing on our behalf that we could not lawfully do ourselves; we pay against an invoice that describes a service actually provided at a rate that reflects it; we do not pay in cash; and we do not pay into an account in a different name, or a different country, from the party we contracted with. Every third party that acts for us or in our name is sent this policy in writing before it first acts on our instruction and confirms in writing that it will work to it; the confirmation is renewed every two years and whenever the policy changes, and a party that will not give it is not instructed.
Customs, spares and calibration standards
Parts and consumables are shipped to vessels across borders, and our reference standards and test equipment travel with the technicians who use them, so a customs entry is where this policy is tested most often. Declarations state the true description, value and origin of the goods; nothing is under-declared, split or described as something else to reduce duty or to move a consignment faster. Under-declaring or misdescribing a customs value is not bribery: it is facilitation of tax evasion, and sections 45 and 46 of the Criminal Finances Act 2017 create corporate offences of failing to prevent it, with no turnover or size threshold at all. Where a broker or forwarder clears goods for us, that clearance is covered by the same rules as any other third party acting on our behalf. An unofficial payment to release a held shipment, to avoid an examination or to obtain a document out of turn is refused, and the delay is planned around: a reference standard stuck in clearance means the attendance is re-planned, not that the work is recorded as done without it. Test equipment and reference standards that travel with a technician are declared on the way in and on the way out under the temporary-admission route the destination customs authority accepts — an ATA carnet where the country and the goods qualify for one, a declared temporary import where they do not — at their true value and against their serial numbers, so that the same items leave on the same documents. A broker or forwarder that clears goods for us is instructed under the same written confirmation as any other third party acting on our behalf, and is named on the file for the consignment it clears.
Partner firms and subcontracted attendances
We have six service bases — İstanbul, İzmir, İskenderun, Varna, Constanța and London — and the coverage index lists 299 ports. Work is therefore delivered from an own base, by mobilising a team from a base, or through a partner firm at a port where we have none, and we say so rather than let a customer assume every attendance is our own crew. When a partner firm attends in our name the rule travels with the work: the same prohibition applies, the firm may not subcontract further without telling us, and it invoices us for the work actually done. That is the honest limit of the arrangement — there is no operations director standing on every gangway, so what holds the line is what we require in writing, what we check, and what a technician or a customer tells us afterwards. Before a partner firm attends in our name for the first time, we establish who owns and runs it, check the firm and its principals against the sanctions and debarment lists, ask what authorisations it holds for the scope it would cover, and take its written confirmation of this policy; a firm that will not answer is not used. The check is repeated every two years, and immediately after any payment demand reported at a port that firm covers.
Records, accounts and expenses
Every payment is recorded in the books of the entity that made it, under a description of what it actually was. There are no off-book accounts, no undisclosed funds and no unrecorded cash held to settle demands in a port. An expense is reimbursed against a receipt or an invoice; a line described only as a port expense, an attendance fee or a gratuity, with nothing behind it, is not approved, and is itself treated as something to be reported. An attending technician carries no cash float. Travel, launch hire, gate passes and port charges are paid by company card or against an invoice raised to the entity that owes them, and anything a technician pays out of pocket is reimbursed against a receipt within ten working days of the claim reaching accounts@shipcertify.com. Where an official charge in a port can be settled in no other way than cash, the technician pays it, obtains a receipt, and reports it to the operations director for the base the same day.
Raising a concern
If you are asked for a payment, offered one, or you see something that looks like either, write to compliance@shipcertify.com. It makes no difference whether you are our employee, a partner firm’s technician, a port agent, a crew member or a customer. You can also tell the operations director for the base, or call the 24/7 hotline on +90 532 657 48 78. compliance@shipcertify.com, the hotline and WhatsApp are not anonymous channels: an email carries your address, and a call or a WhatsApp message carries your number. We do not disclose a reporter’s identity outside the people looking into the report without their agreement. A report that names nobody can be sent on paper to Office 7408, 58 Peregrine Road, Hainault, Ilford, Essex IG6 3SZ, marked for compliance; it is looked into in the same way, with the one limit that we cannot come back to the sender for the detail that usually decides a case. Anyone who reports on reasonable grounds is protected — no dismissal, no removal from a rota, no cancelled order — and that protection holds even if the concern turns out to be mistaken. A report is acknowledged within the period set out in the complaints and appeals procedure on this site, and is looked into by an operations director with no involvement in the attendance, the port or the relationship it concerns. Where the report is about an operations director, another operations director outside that person’s line of management looks into it, and the person the report concerns takes no part in the decision or in any review of it.
What happens when the rule is broken
For a member of staff, a breach is a disciplinary matter that can end in dismissal, and where an offence may have been committed the matter goes to the authorities with jurisdiction over it. The exposure is personal as well as corporate. An individual convicted under the Bribery Act 2010 faces up to ten years’ imprisonment on conviction on indictment, or an unlimited fine, or both; a company convicted under section 7 faces an unlimited fine on indictment, and exclusion from public procurement. For a partner firm, an agent or a supplier, it means the attendance or the order is stopped and the relationship ends; losing a firm can leave a port uncovered until we find another, and that is a cost we accept rather than keep a firm that buys its access. Every partner, agent and supplier agreement carries a right for us to end it immediately for a breach of this policy. Removal from the network is authorised by an operations director who had no part in bringing the firm in, the reasons are recorded, and the firm is told in writing and may put its answer to an operations director who took no part in the decision.
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