Strategic Shipping Company Limited


Bribery Policy


The Directors of Strategic Shipping Co Ltd hereby state:


-          The management shall prohibit bribery in any form whether direct or indirect.


-          The management shall commit to the implementation of a policy to counter bribery. That is the purpose of this document.



Purpose of the Policy.


To provide a framework for good business practices and risk management strategies to countering bribery.



Scope of the Policy.


The Directors state that, all departments and all employees of the Company will be governed by the Policy and the underlying principles contained herein.



The Policy.


 The organisation will not tolerate its employees, business partners such as suppliers or contractors or any third parties representing Strategic Shipping Co Ltd, being involved in Bribery, whether by offering, soliciting for, demanding or accepting bribes.


 This policy will include “Kickbacks”, which are a form of bribe, and are often accepted by a corrupt employee for the benefit of themselves, their family or a person/party with which they are involved, without the knowledge of the employer and normally such instances occur simultaneously with the completion of a business transaction. Therefore, the acceptance of a “Kickback”, gift or invitation to an event must be notified to the accountant for consideration as to whether it is allowable. This must recorded, and the decision logged.



            Political Contributions.


            The Organisation, its employees or agents should not make direct or indirect contributions to political parties, organisations or individuals engaged in politics,

as a way of obtaining advantage in business transactions.



            Charitable Contributions or Sponsorships.


            Arrangements for sponsorship and charitable donations can be made providing that they are made without the intent to subterfuge bribery.


            That any donations / sponsorship arrangements are made with the agreement of the Directors.



            Facilitation Payments.


            The Organisation forbids such payments to be made, unless that the payment is a standard charge in relation to that activity, such as profit share or commission.



            Entertaining, Gifts and Hospitality.


            Employees who offer persons or body corporate, entertainment, gifts or hospitality events which are wholly paid for, must obtain authorisation from a Director.

The Director will consider whether such an arrangement could constitute bribery or is a bona fide business expense.



Policing the Policy


Due to the stringent financial controls operated by the Company all funds leaving the Companies accounts are vouched and approved by an officer of the business. All expense payments are authorised by a senior official prior to reimbursement to employees.


The Companies financial records are Audited on an annual basis with all records being available for scrutiny and verification. Audit reports not in the public domain can be obtained by request from the business’s accountant.





Should an employee be implicated in any of the above, disciplinary proceedings will be instigated and could, upon the investigation, result in instant dismissal, dependant upon the severity of the matter.


Should a third party, supplier or contractor be found to be in breach of this policy, an immediate review must be carried out and that party requested to explain the situation.

Dependant upon the findings the parties’ services may be terminated, and the local enforcing authorities informed, if a breach of UK/EU Law is deemed to have been occurred.