The Company has zero tolerance towards corruption and anti-competitive behaviour. CNCo's Corporate Code of Conduct (CoC) is a comprehensive governance document that defines how employees must behave in the course of their duties. Our anti-corruption, anti-money laundering and anti-trust governance processes are also covered within this Code. The CoC was reviewed and updated during 2018 to better reflect changing regulations and procedures.
The CoC, together with internal controls, sets a strong foundation to prevent any corruption and anti-competitive / anti-trust behaviours. The Company carries out training for all employees within the CNCo group, testing their understanding of these principles and how they apply to our employees’ daily work / duties.
Any and all incidents of potential or actual non-compliance are reported to the CNCo Audit Committee and investigated.
In 2018, as in the previous years: CNCo was not involved in any legal actions for anti-competitive behaviour, anti-money laundering, anti-trust, or monopolistic practices.
We also have a stand-alone Competition and Anti-Trust Policy coupled with an online anti-trust training for relevant employees to ensure understanding and compliance.
Our governance compliance training programme covers:
In early 2018 we have added two more compliance training modules for specific employees / functions:
This training is held biennially for existing employees, and is part of the induction programme for new employees.
Like many other shipping companies globally, one of the challenges that CNCo faces is the expectation in some ports for “benefits” for the processing of work that should be undertaken as a matter of course. CNCo has been working hard for over six years now to eliminate these demands for “facilitation payments” completely and we have seen significant reduction in the value of gifts over the years.
Facilitation payments risk is covered under CNCo’s Business Unit Risk Register. All vessels are required to report all such requests and such reports are reviewed biannually by the Audit Committees.
CNCo has been a member of the Maritime Anti-Corruption Network (MACN) since 2015 and continues to contribute towards the maritime industry’s vision and aim of being free of corruption. MACN works closely with key stakeholders, including governments and international organisations, to identify and mitigate not only the symptoms, but also the root causes of corruption in the maritime industry. We participate in MACNs members’ self-assessment every year. More information about MACN can be found at www.maritime-acn.org