Anti-Bribery & Anti-Corruption Policy
Last Updated : 17 April 2020
1. Vantage Shipbrokers is committed to running our business operations on a foundation of Integrity, Transparency and Honesty. Our Company will devise and improve our processes continuously to prevent direct or indirect bribery, in order to safeguard and uphold our values.
2. Vantage Shipbrokers adopts a zero-tolerance policy towards any forms of corruption and bribery in our business. Our Company and employees have to observe the anti-bribery and anti-corruption legislations and regulations in the countries where we have business activities in and undertake ourselves to not engage in any corrupt or improper practices, nor facilitate any such practices.
3. Vantage Shipbrokers does not allow our employees to solicit or accept any benefits such as commissions, gifts in cash or kind, gifts that are more than nominal value, or any other service, favour or advantage of any description whatsoever, from any organisation, firm or individual or government officials with whom they deal with in the course of the employment. The use of other routes, channels or person(s) for provision of improper benefits to, or receipt of improper benefits are prohibited as well.
4. Vantage Shipbrokers does not allow our employees to promise or offer or to give any benefits such as commissions, gifts in cash or kind, gifts that are more than nominal value, or any other service, favour or advantage of any description whatsoever, to any individual of external parties with whom they deal with in the course of the employment, including government officials. The use of other routes, channels or person(s) for provision of improper benefits to, or receipt of improper benefits are prohibited as well.
5. Vantage Shipbrokers has clear guidelines with regard to the declaration of conflict of interest and the receipt of corporate gifts and any other benefits from our business partners which our employees are obliged to adhere to.
6. Vantage Shipbrokers has an internal reporting structure, procedures and channels that are secure and accessible for our employees to raise concerns and report violations or suspicious activity.
7. If our employees are established to have been involved in prohibited practices, they may be subjected to disciplinary actions, including immediate dismissal of employment and/or referral to relevant law enforcement authorities.
8. Vantage Shipbrokers will also strive to ensure that our business partners share our zero tolerance policy against corruption and bribery. Vantage Shipbrokers will avoid engaging in business dealings with those known or reasonably suspected to be engaging in corruption and bribery.
9. Procurements by Vantage Shipbrokers are conducted in a fair and transparent manner.
Last Updated : 17 April 2020
Purpose & Scope
Vantage Shipbrokers is committed to a high standard of corporate governance. As one of the elements of corporate governance, the Whistleblowing Policy ("Policy") aims to:
provide a trusted avenue for employees, vendors, customers and other stakeholders to report serious wrongdoing or concerns, particularly in relation to fraud, controls or ethics, without fear of reprisals when whistleblowing in good faith; and
ensure that robust arrangements are in place to facilitate independent investigation of the reported concern and for the appropriate follow up actions to be taken.
The Policy is intended to facilitate whistleblowing relating to improper, unethical or fraudulent conduct in the following general areas:
financial reporting, accounting or other financial matters;
corruption, misappropriation or blackmail;
any criminal offence or failure to comply with a legal or regulatory obligation;
significant breaches of Vantage Shipbrokers’ or internal controls, including the Code of Conduct and Ethics and Anti-Bribery and Anti- Corruption Policy;
endangerment of the health and safety of an individual;
serious conflict of interests without disclosure; or
concealment of any of the above.
Vantage Shipbrokers will not tolerate the harassment or victimization of anyone reporting a genuine concern. Furthermore, no person should suffer reprisal as a result of reporting a genuine concern, even if they are mistaken. However, this assurance does not extend to any person who intentionally provides information in a report which they know or reasonably believe to be untrue. If an employee has made an allegation frivolously, maliciously or for personal gain, disciplinary action may be taken against him or her. Likewise, if investigations reveal that the External Party making the complaint had done so maliciously or for personal gain, appropriate action, including reporting the matter to the police, may be taken.
All information disclosed during the course of investigation will remain confidential, except as necessary or appropriate to conduct the investigation and to take any remedial action, in accordance with any applicable laws and regulations.
Whistleblowing Reporting & Communication Channels
The individual should report his/her concern to the Head of Human Resource, who is responsible for handling all reported cases and ensuring that issues raised are properly resolved by the Management or such parties as appropriate. Concerns may be raised verbally or in writing. As it is essential for Vantage Shipbrokers to have all critical information in order to be able to effectively evaluate and investigate a complaint, the report made should provide as much detail and be as specific as possible. The channels of reporting to the Head of Human Resource are as follows:
Mail : Head of Human Resource
51 Cuppage Road, #05-06
Tel : +65 737 2221
All concerns raised will be independently assessed by Head of Human Resource to ensure that they are fairly and properly considered. Any individual making a whistleblowing report will retain his/her anonymity unless he/she agrees otherwise. He/she will also be kept informed of who is handling the matter.
Vantage Shipbrokers reserves the right to refer any concerns or complaints to appropriate external regulatory authorities. Depending on the nature of the complaint, the subject of the complaint may be informed of the allegations against him or her and be provided with an opportunity to reply to such allegations. Employees who fail to cooperate in an investigation, or deliberately provide false information during an investigation, shall be subject to strict disciplinary action up to, and including, immediate dismissal.
If, at the conclusion of an investigation, Vantage Shipbrokers determines that a violation has occurred or the allegations are substantiated, appropriate disciplinary action in accordance with the Fair Employment Policy will be taken. Non-anonymous whistle blowers will be informed that action has been taken at the conclusion of the investigation, without divulging confidential information.
All records will be retained and kept strictly confidential by the Head of Internal Audit, in accordance with Vantage Shipbrokers Document Retention and Destruction Policy.
Last Updated : 17 April 2020
Commitment to harassment-free workplace
Vantage Shipbrokers seeks to provide a harassment-free workplace that promotes the confidence to perform without the fear of harassment. We believe that every individual should be treated with dignity and respect. We will not tolerate any harassment and will take immediate action upon becoming aware of such cases.
Illustrations of workplace harassment
Workplace harassment can include unwanted physical contact, bullying, intimidation or offensive jokes, and may relate to a form of discrimination.
Reporting incidents of harassment
Individuals are encouraged to report incidents of workplace harassment. Informants will not be subject to any retaliation on the part of the Management, or other employees. The Management will investigate, and deal with all concerns, complaints and incidents of workplace harassment in a fair and timely manner.
Action against harassers
Any individual, who is found guilty of acts of harassment, shall be subject to corrective or disciplinary action, which may include termination from service.