Code of Business Ethics and Conduct

This document is the policy of Priavo Maritime Security Incorporated  (hereafter the “Company”) to conduct its business at all times and throughout the world with honesty and integrity. It is part of our mission statement that we have pledged that, “we will continue to be an ethical and responsible company.

The Company recognises it has a responsibility for all the actions of its employees in connection with the activities of the organisation. In view of this, the Company believes that the ethics demonstrated by our employees and indeed any persons providing services on our behalf should give all customers, shareholders, suppliers, colleagues, business partners and regulators confidence that the Company operates in a way that avoids any suggestion of improper or personal motives or actions.

Therefore, all employees and any persons providing services on our behalf are expected to conduct themselves in accordance with this Code at all times. This Code is to be read in conjunction with our Bribery and Corruption Policy, Non Disclosure Agreement (including Conflict of interest warranty) as part of the companies approach to ethical commercial approach and also alongside its other polices concerning ethical conduct in the wider delivery of its services by all employees and other 3rd parties on its behalf.

The Company believes that all its stakeholders wish to be associated with an ethical organisation which publicises and upholds high standards in all that it does, in particular:-

  • We will comply with the law in each country in which we do business including laws relating to unfair competition/anti-trust.
  • We will not offer to pay, solicit or accept bribes in any form whether directly or indirectly. This includes payment or receipt of “facilitation payments” which are small payments or gifts made as common practice in some countries to obtain approvals, permits, etc more speedily – they are still bribes. The Company promotes measures to eliminate these types of payment. All personnel (including those 3rd party providers delivering services to it or on its behalf) should ensure they comply with all local laws and regulations. If you are requested to make a payment which you believe may be a facilitation payment you should consult your line manager/team leader or Designated Operations Manager (as appropriate). All payments made by deployed personnel should be recorded and a receipt requested if possible.
  • We will only give or receive gifts and entertainment that are not material or regular. Local management in each country will establish guidelines reflecting local custom as to the maximum permitted value and the circumstances in which such gifts and entertainment are acceptable.
  • We will record in our published accounts all material assets and liabilities and not maintain secret accounts.
  • We will not make political donations anywhere in the world.
  • We will not engage in commercial espionage or covert surveillance of our competitors.
  • We will not seek or continue to work where there is a potential or actual conflict of interest unless this is fully disclosed to the affected party(s) and their written consent first obtained.

Agents and contracted third parties in countries where Company is not directly represented are expected to comply with this Code in all matters in which they are acting on Company’s behalf. Local management and all deployed personnel are expected to monitor compliance and to report any significant breach to the Director of Priavo Maritime Security Incorporated. In case of uncertainty in interpretation, employees and our contractors including deployed personnel should seek clarification from their line managers and operations managers respectively.

All employees and 3rd party providers of services on its behalf have the right to make confidential reports directly to the Group General Counsel, c/o Priavo Security Ltd, 84 Brook Street, Mayfair, London, W1K 5EH United Kingdom or, without fear of detrimental action being taken against them. Failure to adhere to this Code may result in disciplinary action or are removing you as an approved supplier/contractor.

This Code will be applied in the same fair and consistent way to all employees and contractors in accordance with all other relevant policy documents.

Director of Priavo Maritime Security Incorporated

Date: 26/02/2018

Review Date: 25/02/2019