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ALBA TANKERS – ANTI-BRIBERY & ANTI-CORRUPTION POLICY

 

1. ABOUT THIS POLICY

1.1 Commitment to integrity

Alba Tankers is committed to operating always with honesty, integrity and transparency. We will not tolerate any form of bribery, corruption or facilitation payments. We expect all employees, officers, crew (via our management/crewing partners), contractors, sub-contractors, agents, suppliers and partners to comply fully with this policy.

We operate in multiple jurisdictions and recognise that the shipping industry may involve heightened risk due to varied local practices and interactions. We therefore take a zero-tolerance approach and require strict adherence by all involved.

This policy supports our obligations under Danish law and relevant EU rules and reflects recognized best practice within the maritime sector.

 

1.2 Scope of the Policy

This policy applies to all individuals who work for or on behalf of Alba Tankers, including:

  • Shore-based employees
  • Vessel-based employees (all crew, no matter the rank, including those supplied through crewing partners)
  • Management
  • Board members
  • Interns and trainees
  • Consultants
  • Contractors and subcontractors
  • Agents, brokers and charterers
  • Any person or entity acting for or representing Alba Tankers

All must comply with this policy regardless of local customs or business expectations.

 

1.3 Definitions

  • Bribery: offering, promising, giving, accepting or soliciting anything of value to influence improperly the actions of another. Anything of value includes money, gifts, hospitality, services, advantages, or any benefit intended to influence a decision.
  • Corruption: abuse of entrusted power for private gain.
  • Facilitation payments: small unofficial payments to secure or expedite routine governmental actions.
  • Kick-back: return of part of a payment as reward for favourable treatment.

 

2. PROHIBITED CONDUCT

Under this policy, the following conduct is prohibited:

  • Giving or accepting bribes in any form – direct or indirect.
  • Payment or receipt of facilitation payments.
  • Offering or receiving kick-backs or undue commissions.
  • Mis-characterising payments in records or hiding the true purpose of a transaction.
  • Acting in a way that creates, or appears to create, a conflict of interest.
  • Attempting to conceal, encourage, or approve any bribery or corruption.
  • Failing to report suspected bribery or corruption.

 

3. RESPONSIBILITIES

  • Managers and senior crew must ensure compliance in day-to-day operations and promote a culture of integrity.
  • The Compliance Committee and Officers oversee the policy, provide guidance and investigate concerns.
  • All individuals are required to read, understand and abide by this policy.
  • Agents and third parties acting on our behalf must comply with this policy and our Third-Party Due Diligence process.

No employee will suffer retaliation for refusing to pay a bribe or for raising a concern in good faith.

 

4. THIRD-PARTY DUE DILIGENCE

Before engaging agents, brokers, suppliers or any third party, Alba Tankers will carry out due diligence which considers:

  • Ownership, reputation and licence status.
  • Any history of bribery, corruption or sanctions violations.
  • Geographical risk based on country and operations.
  • Payment terms, commissions or third-party fees.
  • Contracts with third parties will contain anti-bribery and corruption clauses, right to audit, termination rights and representations of compliance. Third parties must never be used to circumvent this policy.

 

5. GIFTS, ENTERTAINMENT & HOSPITALITY

Hospitality may form part of professional interactions in the maritime sector; however, it must remain reasonable, transparent, and for legitimate business purposes only.
Gifts or hospitality that may influence, or be perceived to influence, a business decision are strictly prohibited.

Employees are required to seek prior written approval for any gift or hospitality with a value exceeding EUR 100, or any updated threshold communicated by the company.

 

6. RECORD-KEEPING, REPORTING & AUDITING

  • All payments, purchases and commissions must be properly documented and accounted for.
  • Financial records and expense reports must be accurate and reflect the true nature of the transactions.
  • The internal audit function will periodically review compliance with this policy.

 

7. TRAINING & COMMUNICATION

Regular training will be provided to all shore-based staff, vessel officers and key third parties (agents/brokers) covering:

  • Anti-bribery and corruption risks in shipping
  • Identifying red flags
  • Reporting procedures

The Compliance Committee will oversee and ensure training is delivered and logged.

 

8. SANCTIONS FOR BREACH

Any breach of this policy may result in disciplinary action, up to and including termination of employment or contracts.
In addition, Alba Tankers may report serious misconduct to the relevant authorities and may pursue civil or criminal remedies.

 

9. MONITORING & REVIEW

Regular reviews will take into account changes in legal requirements, operational risk areas and any lessons learned from reported incidents. Changes will be communicated to all stakeholders.

 

10. CONTACT & ESCALATION

For questions, concerns or to report suspected wrongdoing contact:

COO: Håkan Kalmerlind – email: HKL@albatankers.com

CFO: Morten Dodensig – email: MDO@albatankers.com

CEO: Jørgen Olesen – email: JOL@albatankers.com

Compliance Committee Chair: Håkan Kalmerlind – phone: +46 763102087

Reports can also be made via the Whistleblower Policy channels (see separate document).