Company Ethics

Symphony Shipping Code of Conduct is based on our commitment to honesty, integrity and a diverse corporate culture. It contains an overview of key information, including the business principles and directives, which are applicable to management and employees. The Code of Conduct governs the business decisions and actions throughout the world and applies equally to corporate actions and to individual employees conducting Symphony Shipping business. 

Symphony Shipping requires its employees to act to the highest standards of professional business conduct and according to applicable national and/or international law and regulations. 

Symphony Shipping will monitor, evaluate and act on its performance under this Code of Conduct and encourages employees to report any (suspected) breach of this code immediately, ensuring at the same time that such reporting will not harm the employee. Any questions, breaches and/or guidance in respect of the Code of Conduct’s rights and obligations set out below should be raised with management (or one of its team members). 

 

People, safety and conflict of interest 

Symphony Shipping is committed to maintaining a working environment where there is mutual trust and respect and where everyone feels responsible for the performance and reputation of the company.Symphony Shipping is committed to provide a safe working environment and safe practices for all employees. Thereto, Symphony Shipping has set up a Safety Management System based on the ISM Code and other applicable national and international legislation. 

Symphony Shipping will ensure that its employment-related decisions are based on relevant qualifications, skills, performances and other job-related factors.Symphony Shipping shall not tolerate unlawful discrimination nor any action, conduct or behavior that is humiliating, intimidating or hostile. 

Conflict of interest situations are to be avoided. Employees have the obligation to notify management (or one of its team members) whenever a relationship could create a conflict of interest. A conflict of interest occurs when an employee’s personal relationships, participation in external activities or interest in another venture could influence the employee’s decisions in conducting Symphony Shipping's business. 

 

Bribery & hospitality 

Symphony Shipping condemns any act of bribery. Employees shall not offer, promise or give a bribe either directly or indirectly to a person in a position of trust whether in government or in private business (active bribery), nor shall they request or receive a bribe (passive bribery). Bribe is a financial payment or gift to another person in order to induce or reward a person for the improper performance of his function or activity and thereby to secure business or a business advantage. A breach of the expectation that a person will act in good faith, impartiality or in accordance with a position of trust counts as improper performance. 

Corporate gifts and hospitality (like meals, travel or entertainment) can be offered/received in order to develop and strengthen business relationships. They are only allowed if the expenditure is not excessive and consistent with the accepted legitimate business practice in the relevant country. Symphony Shipping expects that employees have an open discussion about these items, in case of doubt. As a general rule, employees should refrain from offering/accepting gifts and hospitality to/from public/governmental officials. 

 

Competition 

Symphony Shipping’s continued success depends on competing fairly and in full compliance with the applicable laws. Business relationships founded on trust and mutual benefits are vital to our success, and we will strive to develop mutual advantages by understanding the needs of our customers, contractors, suppliers and joint ventures. 

Competition law protects free enterprise and prohibits behavior that limits trade or that restricts fair competition. These laws apply to every level of business and combat illegal practices like price-fixing, market-sharing or behavior that aims to achieve or maintain monopoly. 

No employee shall engage in price fixing, allocation of market or customers, or similar illegal anti-competitive activities. As a general rule, the employee is to avoid customer-related discussions with competitors. If the employee is at a meeting or conference where competitors are also present, the employee is to object to the discussion of any anti-competition information and leave the meeting if the discussion continues. The employee is to make sure that employee’s departure is correctly noted in the minutes of the meeting and that management (or one of its team members) is informed immediately. 

 

Confidential information, information technology and social media 

Employees must maintain the confidentiality of proprietary information entrusted to them by Symphony Shipping or its customers and suppliers, except when disclosure is authorized in writing by the head of department, or required by law and regulations. Proprietary information includes all non-public information that might be of use to competitors or harmful to the Group or its customers or suppliers, if disclosed. 

IT and communication technology include, but is not limited to, personal computers, desk top computers, mobile and desk phones. A limited use of Symphony Shipping’s IT and communication technology for personal use is generally acceptable. 

IT and communication technology should not be used in any way that is unethical or illegal, or that could embarrass, misrepresent, or give an unjust or unfavorable impression of Symphony Shipping or its business affairs, employees, suppliers, customers, competitors or stakeholders. 

Employees shall use social media for their personal social communication only. 

Disclosure of project information, commercial information, operational activities or confidential information is not allowed and can only be communicated through Symphony Shippings’s official (social) media channels.

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