Code Of Ethics
GNMTC role is to make sure that all of its employees who works for the Company understands that unlawful or unethical business practices will not be tolerated and also that they should strive to be professional and accountable in everything that they do in their professional capacity.
GNMTC aims to be open, honest, fair and professional in dealing with everyone, includes colleagues, associates customers and suppliers. This extends to our public communications and our reports and accounts, which we work to ensure that they are fair, accurate, timely and understandable.
Employees of GNMTC will not use their knowledge or position within GNMTC for our own private or personal advantage. We will not accept anything that could be construed as a bribe, anything that is of more than a symbolic value or that is not normal in the course of doing business.
GNMTC will use information only for the purposes for which it was obtained. Shall take all reasonable steps to prevent accidental disclosure or unauthorised access to confidential information.
GNMTC always act with care, competence, honour and responsibility with the aims of upholding the reputation, standing and dignity of the organisation.
The acts of harassment or bullying on ships should not be allowed. The company will deal with such matters very seriously.
Health, Safety & Quality Policy
GNMTC ensures that Health, Safety, Environmental and Quality responsibilities are integral to the way we conduct our business.
GNMTC has developed and implemented Integrated Management System (IMS), which has the objectives of:
- Promoting and ensuring safety and prevention of human injury, ill health or loss of life.
- Avoiding damage to the environment and property, in particular to the marine environment.
- Enhancing customer satisfaction by determining and meeting their requirements.
GNMTC in order to pursuit the above, is committed to:
- Satisfy the applicable requirements and comply with the relevant national and international rules and regulations governing the maritime industry.
- Continually improve the integrated (health, safety, environment and quality) management system.
- Assess all identified risks to ships, personnel health & safety and the environment and establish appropriate safeguards.
- Provide safe and healthy work environment and ensure the welfare of the staff.
- Provide for safe practices in ship operation and establish safeguards against all identified risks by adequate contingency planning.
- Undivided commitment from management and all employees to high standards in respect of occupational health, safety and protection to ensure that they have the skills and support to achieve the long-term goal of “zero accidents”.
- Ensure all employees have the appropriate training, the required skills and experience necessary to perform their jobs in safe and environmentally friendly manner.
- Provide and ensure the availability of the essential resources and support, including funding, necessary to establish, maintain, and improve the Integrated Management System.
- Use, as far as practicable, Suppliers and Contractors whose standards conforms to Company’s standards.
- Ensure compliance with the applicable standards through regular and independent internal audits.
The responsibility and accountability for the performance lies with the departments’ managers and ships’ masters and with every employee.
GNMTC policies are the framework for setting and reviewing the Company’s objectives and targets and shall be reviewed annually to ensure that it remains relevant.
GNMTC policy shall be available and maintained as documented information; communicated, understood and applied within the Company, and shall be available to relevant interested parties, as appropriate.
Environmental And Conservation Of Energy Policy
The GNMTC is committed to delivering the highest quality services to the shipping industry with absolute regard for safety and the environment.
The Company operates a zero tolerance policy for deliberate discharges in breach of MARPOL. misuse of the Oily Water Separator (OWS) by any form of tampering and/or the use of by-pass pipes (‘magic pipes’) is strictly forbidden.
All log books, environmental records and working record books must be carefully and accurately maintained and be in agreement where applicable. This includes (but is not limited to) Deck and Engine Room logbooks, oil record books, garbage record books, ballast management records, seal records and sounding books.
Energy conservation is an essential part of environmental protection, and all vessels are to be provided with the Company’s Ship’s Energy Efficiency Management Plan (SEEMP). It is policy that the requirements of this plan are complied with in order to reduce the damaging emissions from burning of fossil fuels. Pollutants such as the oxides of Carbon, Nitrogen and Sulphur emitted to the atmosphere contribute to the effects of greenhouse gases and acid rain. Records of energy conservation are to be maintained and periodically reviewed. Any non-conformities relating to energy conservation shall be identified and corrected.
Through commitment to continual improvement in energy performance and development of environmental management skills of its staff, the Company pursues the goal of zero spills to the sea and minimal emissions to the environment. The Company recognizes that operational efficiencies make an invaluable contribution to reducing global carbon emissions and is committed to improving energy efficiency throughout its operation.
- Compliance with mandatory rules and regulations, taking into account codes, guidelines and standards from maritime organisations.
- Actively promoting environmental and energy awareness through training and education.
- Operation of ships as efficiently as possible adopting the principles of re-use and recycling.
- Focussing on minimising pollutants at source through effective maintenance and supply of spares.
- Ensuring that residual wastes are disposed of in a safe and responsible manner, paying special attention to hazardous waste generated on board.
- Suppliers and contractors working under its direct control and affiliated companies to apply environmental standards consistent with its own.
- Wherever possible, suppliers provide the most energy efficient product or service in line with GNMTC Energy Management Procedures.
- Benchmarking environmental and energy performance.
- Verification of compliance by undertaking regular inspections and audits and rectifying non-compliance.
Energy Management Systems, Where Applicable:
- Environmental or Energy objectives and targets are to be set and processes implemented to achieve them.
- Audits are required to ensure that the policy is complied with and that the environmental / energy management system remains appropriate and is capable of adapting to changing circumstances.
Risk Mitigation Policy
GNMTC faces many types of risks that could affect business objectives. We are committed to promote awareness and mitigation of these risks, to ensure that we:
- fulfil our obligations to customers, employees, stakeholders and marine industry in general, with minimum exposure to risks.
- Preserve the Company’s reputation and brand values.
- Achieve the Company’s strategic and operational objectives.
- Ensure the Company’s sustainability.
GNMTC will achieve this by implementing processes to identify unintended or unexpected risks to our environment or business objectives which could affect our ability to achieve our strategic and operational objectives.
GNMTC will manage and report the identified risks as part of the integrated management system, audit and review the processes, and report and review changes to the identified risks as part of the Management Review.
Human Resource Policy
GNMTC recognizes that people are the most important asset of the Company and that the effective planning and management of human resources is an essential part of providing quality service.
- Office-based employees to be qualified in relation to their specific job tasks and responsibilities.
- All positions must have a detailed job description with the minimum required education standards and experience level clearly specified.
- The maintenance of accurate employee records and effective application of the performance appraisal system.
- The provision of a training and development programme. Managers adopt good management skills.
- Company’s vessels are to be manned with qualified, experienced, medically fit and competent officers and crew.
- Operating an effective Familiarisation processes, which ensures that all onboard are conversant with the Company’s IMS.
- Compliance with the crew recruitment procedure contained in the IMS.
- Ensuring that systematic plans for training and development of seafarers are in place, implemented and followed-up.
- Trainings shall be properly documented, recorded and evaluated.
- Encouraging individuals to improve and update their knowledge and to upgrade their certificates.
GNMTC is committed to seafarers’ basic rights including health, welfare and working conditions.
When supplying products (spare parts, materials, provisions, etc.) and services (maintenance, repair, dry-docking, etc.), GNMTC is committed to:
- Ensure that products and services (especially business critical) are managed well, and vendors are controlled to ensure reliability and quality.
- Managing cost to ensure that funds are available to support our mission.
- Minimising our impact on the environment and maintaining the quality of our services.
- Using professional and approved suppliers and dealing with them fairly.
- The supply of materials and services is governed by procedures to ensure that quality, value for money and good service are obtained.
Our selection of suppliers is based on an evaluation of their ability to meet our requirements in terms of price, quality and timing.
Drug And Alcohol Policy
The possession, use, distribution or sale of controlled drugs by employees is strictly prohibited and is ground for immediate dismissal.
- Being unfit for work because of drugs or alcohol abuse is strictly prohibited and is ground for immediate dismissal.
- A positive test result or refusal to submit to the drug and alcohol test is ground for disciplinary action including immediate dismissal.
- The Company may require the ship staff TESTING for alcohol and/or drugs if there is any reasonable cause to believe that they are / or have been under the influence of alcohol and / or drugs at any time whilst onboard a vessel or immediately prior to reporting for duty on a vessel.
- Un- announced alcohol tests will be carried out regularly on the instructions of the company by the master and on the Master by both Chief Officer and Chief Engineer.
- Un-announced drug and alcohol tests will be carried out every year by a shore facility on tanker vessels.
- Pilots, office personnel, guests, contractors, vendors and any other person on board shall be required to comply with the policy restrictions concerning use, possession, distribution and sale of alcohol and drugs and shall comply with provisions regarding searches.
- Those who violate the policy shall be sent away from the vessel and may be denied future access. In compliance with the Company Rules regarding Alcohol on board all vessels shall be declared as “DRY VESSELS”
It is the policy of GNMTC to provide a secure working environment, by establishing and maintaining the required security measure to prevent unlawful acts against ships, which endanger the safety and security of persons and property on board Company ships.
- Provide security procedures and practices for ship operations to protect the security of the ship, ports and the wide community.
- Establish safeguards to reduce the risk to crew and port personnel on board Company ships.
- Improve the security skills and awareness of Company personnel ashore and onboard ship.
- Prepare contingency measures for emergencies relating to possible security incidents.
- These objectives will be achieved by A Ship Security Assessment and a Ship Security Plan specific to each individual ship.
- Comprehensive training for Company personnel.
- Actively promoting security awareness amongst Company personnel.
- Regular documented reviews and internal audits of security procedures and plans, in order to allow for constant update and improvement to the plan.
All employees are expected to comply with the required procedures within the Ship Security Plan and should be familiar with the relevant security duties required of them and the measures required to protect the ship from any unlawful act.
The Company shall ensure that the Company security officer, the Master and the ship security officer are given the necessary support to fulfil their duties and responsibilities in accordance with Chapter XI-2 of the 1974 SOLAS Convention and ISPS code.
The Company is fully committed to conducting its business in compliance with all applicable laws and trade restrictions imposed by United Nations, United States, European Union and other national and supranational authorities and legislators.
This Sanctions Policy encapsulates restrictive measures imposed, which bounds the Company and its employees to not to undertake any activity in the areas targeted by the sanctions.
This Policy also outlines the actions and protective measures to be consistently followed by all employees of the Company.
The Policy establishes minimum expectations of risk management and compliance with Company’s obligations and sets out the tactics of the Company for its responsibilities, mitigating the risk of potential breach of sanctions, consequences of failing, reporting on violation, training of employees and company’s commitment.
- The Company maintains this sanctions policy in order to meet its obligations effective in relevant jurisdictions of business operations.
- This Policy is applicable to all employees (onboard ships and ashore), charter/sub-charter, brokers, shippers, agents, sub-contractors and stakeholders.
- Company will ensure that its business and transactions do not breach any applicable lawful sanctions.
- Employees are regularly educated on the updates regarding the sanctions.
- Employees are required to report any breach or potential breach of the Policy.
- The contents of this Policy will prevail in case of any conflict.
- The Company and its Employees shall not maintain, permit or undertake any activity or conduct any business which would result in breaching this Policy.
- The Company shall not directly or indirectly do business or enter into any transaction, activities, trade, or investments with any affected entities.
- The Company shall ensure that its Employees refrain from doing business with sanctions restricted entities in a manner that would be in breach of any applicable sanction laws and regulations.
- The Company shall not directly or indirectly use or permit to be used any funds of, or received by, contribute or otherwise make available such funds directly or indirectly to any entity.
- The Company shall not use any revenue that is directly or indirectly derived from transactions which would be prohibited by applicable sanctions.
- The Company shall not do business in the sanctions restricted country (as defined in the sanctions procedures) and shall cooperate with governmental agencies for any suspected breach.
- The Company shall ensure that its employees refrain from making business trips or doing business with any entity located within the sanctions restricted country.
- Employees shall not breach company’s sanction obligations.
- It is important to keep in mind that sanctions imposed by one country (for example, the United States), may have an effect on individuals and companies both inside and outside its borders.
- The CEO of the company shall be responsible for compliance with all activities pertaining to this policy.
- The CEO shall be responsible for implementation and incorporating the policy into the employee training program and relevant HR policies and standards.
Information Systems & Cyber Security Policy
General National Maritime Transport Company understands and recognizes the importance of “information” to its business operation and success, hence it is committed to safeguard the information, maintain privacy and adapt secure information security practices to provide its customers, stakeholders, business partners and employees a secure information processing environment.
General National Maritime Transport Company understands and recognizes the importance of “information” to its business operation and success, hence it is committed to safeguard the information, maintain privacy and adapt secure information security practices to provide its customers, stakeholders, business partners and employees a secure information processing environment. The Management of GNMTC committed to continuously manage risk to its information at an acceptable level through the implementation and maintenance of an effective Information Security Management system that fully complies with applicable laws and regulation of the maritime industry.
GNMTC takes a holistic approach to information security, implementing a multi-layered defence security strategy where network, operating system, database, and software security practices and procedures complement one another with strong internal controls, governance, and oversight. These measures, which are generally aligned with the ISO/IEC 27001:2013 & ISO 27032 standard, govern all areas of security applicable to services, including physical access, logical access, input, transmission, storage, enforcement etc., for both Information Technology and Operational Technology Systems.
It is the policy of GNMTC to prohibit unauthorized access, disclosure, duplication, modification, diversion, destruction, loss, misuse, or theft of this information. In addition, it is the policy of GNMTC to protect information belonging to third parties that has been entrusted to GNMTC in a manner consistent with its sensitivity as well as in accordance with all applicable agreements, regulations and law.
Information and information processing systems shall be used in a manner that supports the strategic goals and objectives of GNMTC.
All critical information, information processing systems and ship operational systems shall be identified, valued and classified to ensure adequate protection.
All risks related to information, information processing systems and ship operational systems shall be identified and mitigated on a timely basis.
Employees and non-employees who interact directly with GNMTC information and systems shall adhere to the information security policies, procedures, standards, guidelines etc. approved by the management of GNMTC
Information and corresponding systems shall be managed and handled in a secured manner to avoid any loss of confidentiality, integrity, and availability during its creation, storage, processing, transmission and disposal.
Information, information processing systems and ship operational systems shall be accessible to the authorized users as per their business needs.
Information, information processing systems and ship operational systems shall be physically secured from any loss of confidentiality, integrity & availability.
All information security incidents shall be reported and managed in a timely manner.
Continuity Plans shall be defined, implemented and tested adequately to ensure availability of information and information processing systems during any emergency.
Information security posture shall be continuously reviewed and improved to ensure continuous adherence to this policy.
Adequate emphasis shall be placed on personnel security including personnel screening, security awareness and enforcement of disciplinary actions. Use Cybersecurity best practices and recommendations for the marine industry.
Social Media Policy
The company realizes the importance of social media as a forum for employees to publish their opinions and ideas.
Where the policy provides guidance for GNMTC employees the use of social media, which should be broadly understood for the purposes of this policy to include blogs , wikis , microblogs, message boards , chat rooms, online forums , social network platforms and other sites and services that permit users to share information with others in a contemporaneous manner.
In a way that is appropriate to the particular circumstances , workers onshore/offshore are required to follow certain rules when publishing an article and/or pictures related to the company or any ship owned by the General National Maritime Transport Company, as the materials published on the Internet may affect the reputation of the company and/or customers and at a time when the company welcomes the participation of the public through social media as the company has adopted this as a strong opportunity for development and interaction, at the same time the company is obliged and has the full right to block any comments and interactions that are inconsistent with GNMTC policy ; and specially the following principles apply to professional use of social media on behalf of GNMTC as well as personal use of social media when referring to GNMTC including but not limited to :
GNMTC shall not be made liable, under any circumstances, for any errors, omissions, loss or damages claimed or incurred due to any of your postings in social media forum unless explicitly authorized by the management/media office.
Use of GNMTC Logos/Trademarks/Copyright materials is prohibited without explicit authorization.
A post / article, etc.…may cause a threat of cyber / information security.
Violation of public morals.
Insulting or defaming others.
Promoting destructive ideas.
Violates the laws and regulations in force in the state or company.
Violate freedom of opinion and expression.
Spreading racism based on religion, race, or color.
Comments and posts that violate any legal rights or intellectual property rights.
Spreading false and unreliable information.