Skip to content

Policies

QHSE POLICY STATEMENT

Quality, Occupational Health, Safety and Environment Policy

POSIDONIA Shipping & Trading Ltda., a company specialized in chartering and ship management, through its Board of Directors, establishes the QHSE Policy aligned with its strategic direction and guiding its Integrated Management System, maintaining the commitment to ensure and request their employees to comply with the following:

  • Satisfy its customers and stakeholders, if possible exceeding their expectations, especially with regards to preserving the integrity of the cargo and delivery time commitment;

  • Ensure that its activities on shore and during the navigation of its fleet are carried out with adequate security, preserving the integrity of people, properties and protection of the environment;

  • Make use of methods of assessment, analysis, reduction and elimination, where possible, of significant environmental aspects, including solid waste generation and water and atmospheric pollution, with a commitment to reducing emissions of greenhouse gases, based on corporate goals, so that in this way it can contribute to the protection of the global climate system, as well as the elimination of hazards and the reduction of health and safety risks of the workforce, especially those associated to the activities of operation in navigation;

  • Encourage the motivation and dedication of its employees, giving opportunities for everyone to receive adequate training;

  • Encourage interaction between all involved, whether employees, outsourced or visitors, in the consultation, participation and proposal of ideas and/or suggestions;

  • Preserve its assets, carrying out adequate maintenance on its vessels and equipment, so they fulfill its commitments with safety and quality;

  • To comply with the legislation in force, norms and requirements applicable to the business of the company;

  • Continuously improve its processes and indicators, aiming at satisfied customers, safe and agile operations.

ANTI-BRIBERY CODE OF CONDUCT

POSIDONIA Shipping & Trading Ltda hereby adopts the following code of conduct with respect to all commercial transactions, whether local or international:

LOCAL AND FOREIGN LAWS: Neither POSIDONIA Shipping & Trading nor anyone acting on behalf of POSIDONIA Shipping & Trading may, directly or indirectly, disobey or attempt to evade compliance with the laws and regulations of any country in which, with which or through which POSIDONIA Shipping & Trading seeks to do business. The fact that an unlawful act is a “usual business practice” in any country is not justification enough for non-compliance with this provision.

BRIBES AND PAYMENTS FOR BRIBERY: Neither POSIDONIA Shipping & Trading nor anyone acting on behalf of POSIDONIA Shipping & Trading may directly or indirectly offer or provide bribes, and all solicitations for bribes must be expressly rejected.

Bribery includes any offer, promise or gift of any pecuniary or other advantage, directly or through intermediaries, to public officials, political parties, candidates for elective office or party leader, or to private sector employee, for such officer or employee to perform or cease to perform obligation to obtain or maintain business or any other commercial advantage.

Neither POSIDONIA Shipping & Trading nor anyone acting on behalf of POSIDONIA Shipping & Trading may offer or make payments to public officials in order to encourage them to expedite routine official services that they are in any way required to perform. POSIDONIA Shipping & Trading, or anyone acting on behalf of POSIDONIA Shipping & Trading, will have discretion to breach this prohibition if it believes there is an immediate threat to your health or safety, or anyone else. The circumstances of such payment should be reported as soon as possible after the event, and the payment should be properly recorded. POSIDONIA Shipping & Trading recognizes that the practice of extortion is widespread, and that the involvement of the business community increases the demand for bribe payments.

BRIBES: Neither POSIDONIA Shipping & Trading nor anyone acting on behalf of POSIDONIA Shipping & Trading may offer or accept “kickbacks” as part of a contract payment from third party employees or other means, such as subcontracts, purchase orders, or consulting contracts, in order to direct payments to public officials, candidates for elective office, third party employees on a contract, their relatives, or business partners.

“Kickback” is a particular form of bribery that occurs when a person trusted by the employer or who is in a public office has some responsibility for providing a benefit and does so in order to secure a return (kickback) of part of the value of the transaction, benefiting that person without the knowledge or authorization of the employer or the public authority to whom the person answers.

CONFLICTS OF INTEREST: POSIDONIA Shipping & Trading and anyone acting on behalf of POSIDONIA Shipping & Trading will avoid any relationship or activity that might impair or appear to impair your ability to make objective and appropriate business decisions in the performance of our duties.

POLITICAL CONTRIBUTIONS: Neither POSIDONIA Shipping & Trading nor anyone acting on behalf of POSIDONIA Shipping & Trading may make political contributions in order to gain an unlawful business advantage. POSIDONIA Shipping & Trading shall comply with all public disclosure requirements.

PHILANTHROPIC CONTRIBUTIONS: POSIDONIA Shipping & Trading and anyone acting on behalf of POSIDONIA Shipping & Trading may make contributions only for bona fide charitable purposes and only when permitted by the laws of the country where the contribution is made. Contributions made to obtain an illicit commercial advantage are prohibited.

EXTORTION: POSIDONIA Shipping & Trading and anyone acting on behalf of POSIDONIA Shipping & Trading will reject any direct or indirect request from public officials, political parties, party leaders or private sector employees for a pecuniary or other advantage to perform or fail to perform their obligations.

GIFTS, HOSPITALITY AND ENTERTAINMENT: POSIDONIA Shipping & Trading and anyone acting on behalf of POSIDONIA Shipping & Trading shall refrain from offering or receiving gifts, meals, entertainment, hospitality, or payment of expenses where such items could significantly affect the outcome of business transactions, are not reasonable and good faith expenditures, or violate the laws of the recipient’s country.

REPORTING REQUIREMENT: All directors and employees of POSIDONIA Shipping & Trading and anyone acting on behalf of POSIDONIA Shipping & Trading shall promptly report to the board of directors any actual or potential violation of this Code of Conduct, including any situation in which they are subjected to any form of extortion or asked to participate in any way in a bribery scheme, without fear that their business relationships or employment will be adversely affected. Reports shall be treated confidentially as far as possible, consistent with the need for a full investigation.

COMPANY RESPONSE: No employee will suffer demotions, penalties or other negative consequences for not paying bribes, even though POSIDONIA Shipping & Trading may lose business due to the employee’s refusal to participate in the scheme. Employees must report alleged violations of this code of Conduct to the board, and no employee will suffer demotion, penalties or negative consequences due to their reports.

POSIDONIA Shipping & Trading will, where appropriate, apply sanctions to employees, suppliers or other business partners for violations of this code of Conduct.

ACCOUNTING: POSIDONIA Shipping & Trading shall keep complete and accurate financial records, ensuring that all transactions are recorded correctly, accurately and reasonably in a single set of books.