Our reputation and the trust of our customers, shareholders, and employees are vital assets for an international company that operates across many economic, social and political contexts.
GoodBulk Limited (hereinafter “GoodBulk”) is committed to conducting its business in accordance with the highest ethical standards and in compliance with the laws of the countries where we operate. Ethical business conduct is critical to our business and is a shared responsibility of all GoodBulk stakeholders–whether that be our employees, our directors, our shareholders, or our executive team.
Who does the Code of Business Conduct apply to?
This Code of Conduct (hereinafter the “Code”) applies to all our employees and directors, and to anyone conducting business on behalf of GoodBulk. The Code seeks to promote:
- Honest and transparent conduct including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships;
- Compliance with applicable laws, rules and regulations of the jurisdictions of where GoodBulk does business; and
- The accuracy and integrity of our records and financial information.
The Code does not cover every issue that may arise. Rather, it sets out basic principles and a methodology to help guide you in the attainment of this common goal. Whenever there may be conflicting imperatives, we expect and will strive to choose the higher ethical standard.
GOODBULK’S GUIDING PRINCIPLES
GoodBulk’s Guiding Principles are to create value for our shareholders and customers, and to do so according to the highest ethical standards and practices.
Our success depends on the trust and confidence of our shareholders, customers, and employees, as well as the public.
By following our Guiding Principles, GoodBulk will:
- Pursue excellence in the marketplace by offering quality services;
- Always seek to conduct our business in an ethical, fair and competitive manner;
- Be committed to respecting all laws and regulations applicable wherever we do business and to following principles such as honesty, transparency and loyalty; and
- Take necessary actions to prevent misconduct or otherwise falling short of our high ethical standards.
GoodBulk is committed to a culture inside the company that encourages employees to speak up and we recognize that doing so can take courage. GoodBulk will always take reports of potential misconduct seriously and we will always handle such allegations promptly, in a fair manner and with confidentiality. We will never tolerate any retaliation against anyone who, in good faith, reports a concern.
RESPECT FOR INDIVIDUALS
We believe in respect for individuals and respect and tolerance of differences between people and cultures.
We recognize the fundamental dignity of human beings and we strive to treat people with the greatest care. Wherever we do business, we will strive to be good citizens of the local community.
CONFLICTS OF INTEREST
Anyone conducting business on behalf of GoodBulk shall avoid any relationship or activity that might impair, or appear to impair, their ability to be objective and to render appropriate business decisions. Avoiding actual and perceived conflicts of interest must be a constant concern for all our employees. No employee may use or attempt to use their position with GoodBulk to obtain improper personal benefits for themselves.
GoodBulk is committed to the values of fair competition. We are committed to making a positive contribution to society and to establishing and maintaining fair and trusted business relations with all our business partners.
Business relations with customers and suppliers require careful adherence to the rules of competition wherever we do business.
GoodBulk’s executives and management must exhibit and promote their personal integrity and courage to uphold their convictions by doing things they perceive to be right even when facing pressure favoring the opposite.
GoodBulk is committed to promoting a safe and stable workplace for all of our employees. Our people are our most important assets. The professional contributions of our employees and the crews of our vessels, working together in an environment of mutual trust, is the essential ingredient for our success.
BUSINESS DATA & FINANCIAL REPORTING
GoodBulk is committed to creating, retaining and disposing of all business records in compliance with applicable regulatory and legal requirements.
GoodBulk shall maintain complete and accurate financial records and ensure that all transactions are properly, accurately, and fairly recorded in a single set of books, which are audited by an independent top-tier auditor.
SAFEGUARDING OF ASSETS
GoodBulk is committed to preventing any illicit acts designed to deceive or mislead others in connection with our business. Employees may only make use of GoodBulk property and assets for business purposes. GoodBulk is also committed to ensuring that our clients’ assets are properly used, protected and, where necessary, properly maintained.
HEALTH, SAFETY, ENVIRONMENT AND QUALITY
GoodBulk’s activities shall be carried out in compliance with applicable health and safety, environmental procedures, international standards and laws, regulations and national practices of the countries where it operates and to which the flags belong.
GoodBulk is committed to complying with the provisions of the International Safety Management Code (ISM), as well as ISO 9001 and ISO 14001 Standards, and other applicable national and international rules and legal requirements. As a company we are committed to continually improving the effectiveness of our integrated QSE management system and to ensuring that our QSE management system is documented, implemented and maintained within the organization to the standards that we and our customers expect.
COMPLIANCE WITH LAWS
Because we do business globally, our activities may be subject to different laws in different countries. Everyone at GoodBulk is responsible for complying with the laws, rules and regulations in different countries that apply to GoodBulk’s business – this extends to our business partners, joint ventures, agents, and affiliates.
Some laws may extend beyond a country’s borders, for example the laws prohibiting bribery or prohibiting dealings with individuals or companies that have been placed under sanctions, including by the United Nations. GoodBulk’s Code requires that we comply with laws that apply where we do business and operate. GoodBulk does not offer, pay or accept bribes, kickbacks or other types of corrupt payments. We do not permit even small so-called “facilitation” payments that the laws of some countries permit.
GoodBulk does not offer, pay or accept bribes, kickbacks or other types of corrupt payments. We do not permit even so-called “facilitation” payments that the laws of some countries permit.
To ensure that GoodBulk complies with applicable anti-corruption laws and international trade laws, such as those imposing sanctions or export controls, the Company has adopted specific policies and procedures. All employees and third parties doing business with GoodBulk are required to comply with these policies and procedures as well as the applicable laws.
GoodBulk and its employees will always act with the utmost care in any dealings with a government official or a state-owned company to ensure not just compliance with applicable laws but avoiding even the appearance of any impropriety.
We recognize that even companies with the strongest guiding principles and ethics will experience problems and even misconduct—no company, not even GoodBulk, is immune to such challenges. What matters is how we respond when confronted with such challenges.
We also recognize that coming forward to report a problem, particularly misconduct by others, is difficult and requires courage. The Company is committed to supporting our employees when they raise a concern or bring attention to a problem, in good faith.
You should raise any concerns with your direct supervisor or manager, if you feel comfortable doing so. If the issue of concern is one that you do not feel comfortable about raising with your supervisor, you should instead contact either the Human Resources or Legal Departments. Alternatively, you can contact our Company’s Global Hotline, which is available for reporting any issues whether they involve compliance with these policies, safety or health or other areas of concern. Reports to the Global Hotline may be made anonymously.
COMPLIANCE AND ETHICS HOTLINE SERVICE
GoodBulk has adopted a compliance and ethics Hotline service, administered by NAVEX Global, to allow employees, officers, directors, crew members of managed vessels, to report in an anonymous way any concern about potential violation of ethics, laws, rules and regulations.
- Online Report Portal: goodbulk.ethicspoint.com
NO RETALIATION POLICY
GoodBulk will not tolerate any retaliation against employees who report misconduct, even if the allegation is not corroborated but was done in good faith. The Company will treat allegations of misconduct seriously and will handle them as expeditiously and confidentially as possible.
IMPLEMENTATION OF RELEVANT POLICIES
GoodBulk’s Board has placed primary responsibility for the implementation of the polices that flow from the Code of Conduct with our Chief Legal Officer. The Chief Legal Officer is also charged with ensuring that the Code of Conduct and relevant GoodBulk Policies will be kept current and up to date with relevant applicable laws and regulations that govern our business conduct.