Transparent Marine Procurement & Vendor Compliance

1. Legal Framework Compliance

• Full compliance with the UK Bribery Act 2010 — including Section 7 "failure to prevent bribery" with adequate procedures defence documented.

• US Foreign Corrupt Practices Act (FCPA) aligned — applicable to all transactions involving US-dollar denominated payments or US-connected counterparties.

• UAE Federal Decree-Law No. 20/2018 on Anti-Money Laundering — KYC procedures for all vendors, beneficial ownership verification, and suspicious transaction reporting protocols.

• EU Anti-Money Laundering Directives (AMLD 5/6) compliance for European operations and banking relationships.

2. Vendor Due Diligence & Screening

• All new vendors undergo tiered due diligence — Level 1 standard vendors, Level 2 agents and intermediaries, Level 3 high-risk jurisdictions and government-connected entities.

• Sanctions screening against OFAC SDN List, EU Consolidated Sanctions List, UK OFSI, and UN Security Council sanctions — automated daily rescreening of entire vendor database.

• PEP (Politically Exposed Persons) screening for all agents, consultants, and intermediaries using World-Check and Dow Jones risk databases.

• Beneficial ownership verification to ultimate controlling person — no shell company vendors accepted without full transparency.

• Annual vendor recertification — compliance questionnaires, updated corporate documents, and refreshed sanctions screening for all active suppliers.

3. Financial Controls & Audit Trail

• Segregation of duties — no single individual can approve a vendor, raise a purchase order, and authorise payment.

• Dual-signature authorisation required for all payments exceeding $10,000 — with independent verification by compliance officer for payments to high-risk jurisdictions.

• Complete digital audit trail — every procurement transaction from requisition to payment is documented with timestamps, approvals, and supporting evidence.

• No cash payments under any circumstances — all vendor payments via bank transfer with clear beneficiary identification.

• Commission and agency fee caps — all intermediary payments benchmarked against market rates with independent justification documented.

• Quarterly internal audit of procurement transactions — random sampling of 20% of purchase orders for compliance verification.

4. Training & Awareness

• Annual anti-bribery training for all shore-based staff with purchasing authority — completion tracked and certificated.

• Vessel Masters and Chief Engineers receive dedicated procurement compliance briefing during annual officer conference.

• Red flag recognition training — identifying indicators of corruption including unusual payment routing, offshore intermediaries, and excessive hospitality requests.

• Whistleblower protection — confidential reporting channel with guaranteed non-retaliation policy, reports investigated by independent compliance committee.

5. Sanctions & Trade Compliance

• Pre-fixture sanctions screening for all voyage charter and cargo nominations — vessel, cargo, counterparty, and port checked against all applicable sanctions lists.

• STS (ship-to-ship) transfer compliance — enhanced due diligence for all STS operations including AIS monitoring for dark activity and flag state verification.

• Iranian, Russian, North Korean, and Venezuelan oil trade restrictions fully implemented with specific compliance procedures for each sanctions regime.

• War risk and designated area compliance — real-time monitoring of vessel positions against sanctioned zones with automated alert systems.

• Annual compliance certification submitted to P&I clubs and flag state administrations confirming adherence to all applicable sanctions regimes.

Our compliance record stands at zero sanctions violations, zero bribery incidents, and zero regulatory enforcement actions since inception. This record is not a coincidence — it is the result of a deliberately engineered compliance architecture that we continuously strengthen.