Code of Conduct

The Code of Conduct can be used by charterers/cargo owners to strengthen due diligence that in turn informs chartering-related decision-making. It will be supplemented by practical Self-Assessment Tool but provides an important set of commitments as is. It brings together shipowners, ship operators and charterers/cargo owners to drive positive change in the industry, through individual and collective action and increased transparency to deliver on seafarers’ rights. 

Given the rising attention to human rights, implementing this Code of Conduct is also a way of meeting the growing demands highlighted above and reducing risks through improved compliance.   

This Code is applicable to all Company employees, officers and directors, including non-employee directors. While this Code cannot possibly guide every practice related to ethical behavior, it includes certain specific concepts and practices regarding business conduct that deserve particular emphasis.

Violation of this Code may subject you to disciplinary action, up to and including suspension and/or termination of employment


Compliance with Applicable Laws

The Company expects you to comply with all of the laws, rules and regulations of the Republic of Bermuda, Greece, the United States and other countries, and the states, counties, cities and other jurisdictions applicable to the Company or its business. Violations of laws can damage the Company’s reputation and subject it to liability and may subject you to personal liability. The Company expects you to gain a basic awareness of the legal and regulatory requirements applicable to your duties and responsibilities and to obtain an appropriate level of guidance when doubts or uncertainties arise.
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Conflicts of Interests

You should avoid any direct or indirect, financial or non-financial relationships, including investments, associations or other relationships that would conflict, or appear to conflict, with your responsibility to make objective decisions in Company’s best interest.
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Money laundering and terrorist financing

Swisschemgas will not facilitate or support money laundering. Money laundering is the process by which individuals or entities try to conceal illicit funds, such as the proceeds of crime, or otherwise make such funds look legitimate. Terrorist financing means using the money to fund terrorism. Employees should consult the Anti Money Laundering and Terrorist Financing Policy and Compliance workspace on our company All potential new counterparties must satisfy the KYC due diligence process and be approved by Compliance before any payments can be made or received. Any failure to follow the KYC process is reported to the Compliance Committee and is treated as a serious breach of the Code.
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Sanctions and trade restrictions

There are a variety of international regulators who have the ability to impose sanctions. The rules are complex and can change very rapidly. Swisschemgas complies with all applicable sanction laws and regulation. All new counterparties must be screened as part of the KYC process for any sanction-related issues. Under no circumstances should employees seek to structure transactions or amend documentation in order to circumvent any applicable sanction or trade restriction or to otherwise attempt to disguise the true nature of a transaction.
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Business Entertainment and Gifts

It is Company policy that all solicitation of or dealings with suppliers, customers and others doing or seeking to do business with the Company will be conducted solely on the basis that reflects both the Company's best business interests and its high ethical standards. The providing of common courtesies, entertainment and occasional meals to individuals involved with aspects of Swisschemgas business in a manner appropriate to the business relationship and associated with business discussions is permitted, provided expenses incurred are reasonable, customary and authorized. No employee shall authorize any payment or use of any funds for a bribe, "kickback" or similar payment which is directly or indirectly for the benefit of any individual, Company or organization which is designed to secure favored treatment for Swisschemgas. Payments or gifts shall not be made directly or indirectly to any government official if such payment or gift is illegal under the laws of the applicable jurisdiction.
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Proprietary and confidential information

Employees’ contracts of employment contain detailed confidentiality terms. It is a breach of the Code to violate those terms. Employees may not use or disclose any such information other than as they are expressly authorised. Your obligations in this regard remain in effect even if you leave the Company. This part of the Code is not intended to modify any separate confidentiality obligations that the employee has to any part of the Company
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Political contributions and activities

The Company does not support individual political parties or individual politicians. Employees should not make direct or indirect contributions on behalf of the company to political parties, organisations or individuals engaged in politics. Employees are free to participate in democratic political activities, but this should be done in your own time, using your own money
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Equality, diversity and inclusion

Equality diversity and inclusion applies to all employees, both in terms of obligations and individual needs. Diversity is a source of richness that benefits all parties involved. Discrimination on any kind of form (e.g age, disability, gender reassignment, marriage and civil partnership, pregnancy & maternity, race, religion & belief, sex, and sexual orientation) is against company’s values and may result in dismissal at the first offence
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Obligation to Report Possible Violations

If you are aware of a possible violation of this Code, it is your responsibility to report it promptly. You may report it directly to the CFO or the CEO or, in the case of violations concerning accounting or auditing matters, such submissions may be made on a confidential and anonymous basis by mail.
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No Reprisals

If you have any questions regarding this code or need to report a violation of this code, you should contact the appropriate party as provided above, without fear of retaliation by the Company. Employees may not be fired, demoted, reprimanded or otherwise harmed for the reporting of the suspected violation, issues or concerns.
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No harassment and bullying

Harassment includes any inappropriate and unwelcome conduct which, whether intentionally or not, creates feelings of unease, humiliation, embarrassment or discomfort for the recipient, where sexual harassment is unwelcome sexual advances, requests for sexual favours and other verbal or physical conduct of a sexual nature. Bullying is a form of harassment that includes hostile or vindictive behaviour and results in a work environment in which a group of people or an individual may become threatened or intimidated because of the negative or hostile behaviour of another group of people or individual. Bulling, including cyber bulling, may involve a misuse of power or position and is often persistent and unpredictable. Harassment and bullying are examples of conduct that is unwanted and causes detrimental effects, which may include, stress, lack of motivation, reduced work performance, absence from duties and resignations. Company is committed to the elimination of harassment and bullying to ensuring a working environment in which everyone is respected. In order to tackle harassment Company actively encourages personnel to bring incidents, including those that affect others, to its attention without delay, adopting reporting procedures, conducted in absolute confidentiality, in which all seafarers should have confidence.
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Social Responsibility

Company operates in a socially responsible manner, ensuring the safety of people and the environment, through transparent and ethical behavior, respecting the following principles: • Accountability for the organization’s impacts on society and the environment. • Transparency in the organization’s decisions and activities that have impact on society and the environment. • Ethical behavior at all times. • Respect, consider and respond to the interests of the Company’s stakeholders and employees. • Accept that respect for the rule of law is mandatory. • Respect international norms of behavior, while adhering to the principle of respect for the rule of law, and • Respect human rights and recognize both their importance and their universality. • Invest on Competency, Training and Professional Development of its people • Invest & maintain on a Learning Organization • Promote a culture of supporting the health & wellbeing (physical & mental) issues of employees
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