It is the policy of the Company to provide our employees with a positive, cooperative, non-coercive work environment that is free of harassment, discrimination, and retaliation. 

This policy recognizes that harassment, discrimination, or retaliation of any kind directed at a company employee (either onboard or ashore), including harassment of a sexual nature, is improper and will not be tolerated. The Company prohibits retaliation and discrimination, or harassment. Verbal, visual, or physical conduct that creates an intimidating, hostile, or offensive work environment is an example of the type of conduct that is prohibited by this policy. 

Each employee has not only a right, but also a duty, to report conduct which he/she believes may constitute harassment, discrimination, or retaliation. The Company will not condone or authorize any kind of retaliation against any employee who has made a good faith report of conduct which he/she believes may constitute harassment, discrimination, or retaliation in violation of this policy. 

All employees of the Company are responsible for helping to ensure that we avoid discrimination, harassment, and retaliation. If, as a crewmember, you have been subjected to any type of discrimination, harassment, or retaliation, it is your responsibility to notify someone who can address this issue. Any grievances regarding harassment, discrimination, or retaliation, and/or general grievances by any supervisor, manager, or fellow seafarer should be immediately reported following Company’s procedures for onboard complaints. 

If you have been subjected to any type of discrimination, harassment, or retaliation while at sea, you should immediately report your grievance to your superior. He/she will record the grievance in writing and provide a copy to the employee, shall communicate within 24 hours to the Group Operational Excellence Manager the nature of the grievance, and shall report, investigate, and respond to the grievance to the best of his/her ability under the circumstances. As soon as reasonably possible under the circumstances, but no later than 24 hours from the time that the grievance is reported, he/she shall provide the reporting employee. 

If the person or one of the people accused of harassment, discrimination, or retaliation, the Chief Officer (onboard) and Group Operational Excellence Manager (ashore) will be the designated recipient of the grievance and will follow the procedures designated above. The individual who receives grievance, as stated above, shall provide protection to the reporting employee, under the circumstances. 

The Company will further respond to the harassment, discrimination, or retaliation grievances that were made by continuing the investigation into the grievance(s). If a violation is found, the Company will ensure that appropriate corrective action(s) is taken in response to the grievance(s). 

Employees who believe that they have been subjected to a violation of this policy by a member of management have the right to contact the Group Operational Excellence Manager to seek information or to file a charge of discrimination, in addition to any internal administrative remedies they may have made. 

Our policy is to investigate all such grievances thoroughly and promptly, to the fullest extent practicable, while keeping the grievance(s) confidential. If an investigation confirms the harassment, discrimination, or retaliation has occurred, the Company will take appropriate corrective action, which may include termination. Likewise, false accusations may result in disciplinary action, up to and including termination.