ANSUD Shipping Agency

SHIPPING AGENCY

ANSUD Shipping Agency - Policies

Our comprehensive policies ensure compliance with international standards and best practices in the shipping industry.

1. QHSE (QUALITY, HEALTH, SAFETY, ENVIRONMENT) POLICY

Mandate Basis: Industry Best Practice & ISO Standards

Policy Statement: The company is committed to delivering services without causing harm to individuals or the environment. We adhere to the highest quality standards in port agency representation.

Mandated Procedures & Commitments:

  • Management Systems: We shall establish, implement, and maintain compliance with ISO 9001:2015 (Quality), ISO 14001:2015 (Environment), and ISO 45001:2018 (OHSMS)
  • Risk Assessment: We conduct proactive risk assessments for every port call to eliminate hazards and reduce work-related injury/ill health.
  • Safety Culture (Stop Work Authority): All employees and contractors are mandated to exercise "Stop Work Authority" when unsafe conditions are observed, without fear of retaliation.
  • PPE & Access Control: Mandatory Personnel Protective Equipment (PPE) for all terminal visits. No Access ID card, No entry.
  • Incident Investigation: All accidents, incidents, and near misses must be reported promptly. Fatalities/serious incidents must be investigated at the highest organizational level to identify root causes.

2. DRUG AND ALCOHOL (D&A) POLICY

Mandate Basis: International Chamber of Shipping (ICS) 2025-2026 Guidelines

Policy Statement: The company maintains a zero-tolerance approach to drug abuse and drug trafficking facilitation. We recognize our shared responsibility to prevent ships from being used as cover for illicit drug smuggling.

Mandated Procedures & Commitments:

  • Prohibited Substances: The carrying or use of "khat," narcotics, or illegal substances on port premises or while on board vessels is strictly prohibited.
  • Search Procedures: Agents must be familiar with ship search procedures and common concealment methods to assist principals during customs or security interventions.
  • Incident Response: Clear protocols for actions to be taken if drugs are suspected/found on board, including immediate notification of the Master and relevant customs authorities.
  • Training: Mandatory annual familiarization training for all staff on "Drug Trafficking and Drug Abuse Awareness".

3. COMPETITION LAW & DIVERGENCE POLICY (Conflict of Interest)

Mandate Basis: FONASBA/BIMCO Agency Standards & Competition Law

Policy Statement: The company acts exclusively as agent for and on behalf of the principal (the party paying our fee). Where a Charterer nominates us, our legal duty remains solely to the Shipowner who appointed us. Any divergence from the principal's instructions constitutes a fundamental breach of contract.

Mandated Procedures & Commitments:

  • Duty of Principal: The agent shall not neglect the ship's business in favour of the charterer's business, even under long-standing commercial pressure.
  • Prohibited Conduct with Competitors: We strictly prohibit price-fixing, market allocation, bid rigging, or boycotting of specific customers with competitors.
  • Email & Communication Auditing: To prevent improper information exchange with competitors, we maintain an email auditing system to monitor business communications regarding commercial terms.
  • Divergence Resolution: Where a conflict of interest cannot be resolved, the agent must immediately notify the principal to facilitate the appointment of a Protecting Agent (Husbandry Agent).

4. ANTI-CORRUPTION & ANTI-BRIBERY POLICY

Mandate Basis: FCPA, UK Bribery Act & Evergreen Integrity Policy

Policy Statement: The company does not tolerate any form of bribery, corruption, or fraudulent conduct. We comply with the U.S. Foreign Corrupt Practices Act (FCPA) and the U.K. Bribery Act.

Mandated Procedures & Commitments:

  • Prohibited Actions
    • Offering or receiving "facilitation payments" (even if customary or "small").
    • Lavish hospitality, travel, or gifts that may impair fairness.
    • Using intermediaries to carry out prohibited actions.
  • Fraud Prevention: Strict prohibition of embezzlement, false expense claims, document forgery, and misrepresentation of facts in business negotiations.
  • Managerial Responsibility: Managers are the first line of defence. They must demonstrate ethical leadership and ensure no misconduct is overlooked.

5. HUMAN RIGHTS & SEAFARER WELFARE POLICY

Mandate Basis: UN Guiding Principles on Business and Human Rights (UNGP) & Port of Rotterdam

Policy Statement: The company respects human rights in accordance with the OECD Guidelines and the UN Guiding Principles. We recognize that seafarers are key workers and must be treated with dignity.

Mandated Procedures & Commitments:

  • Crew Welfare: We actively facilitate crew changes, medical assistance, and shore leave without undue delay. We participate in port welfare committee initiatives to support seafarer wellbeing.
  • Due Diligence: We apply human rights due diligence to identify risks in our own activities and value chains (e.g., suppliers using forced labour).
  • Non-Discrimination: Commitment to diversity and inclusion; zero tolerance for harassment or discrimination based on race, gender, religion, or nationality.

6. CYBER-SECURITY POLICY

Mandate Basis: IMO Guidelines

Policy Statement: The company implements robust technical and organizational measures to protect against cyber-enabled crime and data breaches, recognizing that agents are prime targets for social engineering attacks aimed at facilitating drug trafficking or cargo theft.

Mandated Procedures & Commitments:

  • Cyber Risk Management: Formal integration of cyber risk measures into operational procedures, including prevention, detection, response, and recovery processes.
  • Social Engineering Defense: Mandatory training to identify and prevent "social engineering" attacks (e.g., phishing attempts to gain ship schedules or cargo data).
  • Access Control: Strict controls on access to vessel itineraries, crew lists, and cargo documentation.

7. PHYSICAL SECURITY & VESSEL SECURITY POLICY

Mandate Basis: ISPS Code

Policy Statement: The company supports the Ship Security Officer (SSO) in maintaining the integrity of the Ship Security Plan. We act as the critical link between the vessel and port facility security.

Mandated Procedures & Commitments:

  • Access Control: Verification of visitor identity and authorization prior to facilitating boarding.
  • Hostile Reconnaissance: Staff are trained to identify and report "hostile reconnaissance" activities by individuals scouting port security or vessel vulnerabilities.

8. SHIP OWNERS DEALING POLICY (Disbursement & Financial Integrity)

Mandate Basis: FONASBA/BIMCO Standard Agency Agreement

Policy Statement: The company acts as the fiduciary of the Shipowner's funds. We manage Disbursement Accounts with the utmost care, skill, and diligence.

Mandated Procedures & Commitments:

  • Disbursement Accounting: Proforma disbursement accounts are estimates only. The principal is liable for actual costs. We shall provide prompt and accurate final accounts.
  • Payment & Lien: If the Principal fails to put the Agent in funds, the Agent retains the right to detain the Vessel and retain documents pending payment, strictly in accordance with BIMCO terms.
  • P&I & H&M Verification: Prior to vessel attendance, we shall verify and retain copies of the vessel's current P&I Club and Hull & Machinery (H&M) cover.
  • Supplier Payments: We shall use best endeavours to encourage port service providers to render invoices timely and shall not delay payments to suppliers on behalf of the Principals.

9. PERSONAL DATA PROTECTION & PRIVACY POLICY

Mandate Basis: GDPR / PDPA

Policy Statement: The company complies with applicable Personal Data Protection Acts. We respect the privacy of crew members, customers, and business partners.

Mandated Procedures & Commitments:

  • Lawful Processing: Personal data (crew passports, seafarer books, addresses) is collected, processed, and utilized lawfully and securely.
  • Breach Response: Formal incident response procedure for personal data breaches, including mandatory notification to competent authorities and affected individuals.
  • Data Minimization: Access to personal data is restricted to personnel who require it to perform statutory port clearance duties.