Do Not Ask. We Will Not Give.

BW LPG has zero tolerance towards bribery and corruption, and we expect all employees and crew to conduct themselves with the highest standard of integrity. Our Anti-Bribery and Anti-Corruption (ABAC) policy abides by the principles set out in the UK Bribery Act 2020 and is applicable to all employees including the highest levels of leadership, crew at sea and dealings with our business partners.

We monitor corruption incident statistics and raise the alert when we conduct business in higher risk regions. We collaborate to eliminate corruption risks through our membership in the Maritime Anti-Corruption Network (MACN) and participate in a quarterly roundtable with our BW affiliates to share best practices, resources and reinforce learnings with corrective actions learnings.

All suppliers engaged by BW LPG must comply with our Supplier Code of Ethics and Business Conduct, which forms a part of every supplier purchase order and contractual agreement. Our Anti-Bribery and Anti-Corruption policy is communicated to all employees and crew through online training and assessment, and to our business partners through our contractual agreements. 

To commemorate the United Nation’s International Anti-Corruption Day annually, we issue a formal communication to crew and colleagues to remind everyone of the Company’s stand against bribery and corruption. 

Encouraging Colleagues to Speak Up

At BW LPG, we have a supportive andopen culture. Crew and colleagues donot have to worry about reprisals if theyreport misconduct, challenge currentprocesses or raise critical concerns. We are safe not because we have no incidents. We are safe because we dare to speak up when we are concerned about current work processes. 

Byflagging concerns for attention, we canpositively manage incidents before theybecome bigger issues.Employees can either approach theirLine manager, an HR representative, ortheir Head of Department. Employeesare assured of a fair review and assessment for required corrective action. Depending on the matter, this can be escalated to the highest level of authority for attention. 

Compliance and Approval

We have an internal reporting process in place for disclosure of any interested party transactions. Every year, all BW LPG employees must declare any interested party transactions, acknowledge their understanding of BW LPG’s stand against bribery and corruption, and commit to comply with all policies. All encountered incidents of bribery and corruption are reported in our vessel corruption incidents form with oversight by two internal ABAC representatives. A corrective action procedure is set out in our Quality Management System which guides our crew in appropriate responses and resistance when receiving demands for bribes. 

Our internal checks and balances ensure we are always ready for audits and reviews by our customers in areas including environmental performance, human rights, ethics and compliance and anti-bribery and anti-corruption. 

Whistle-Blowing Channel

BW LPG has an external whistle-blowing channel which provides a safe and confidential avenue for employees to report suspected misconduct. Employees reporting in good faith is assured that anonymity is preserved according to applicable jurisdictions and the employee will not suffer retaliation or detriment. The hotline is available on our intranet, and reports can be made in multiple languages. 

We strive to maintain open channels of communication with our stakeholders, and remain open to feedback, complaints or reports of misconduct. A contact form is available on our website for external parties to reach us. 

Training

All crew and employees (including contract staff) must undergo ABAC training. Training, together with our annual reminder on our ABAC policy, ensure that all staff (including contract staff) are clear of our policies and aware of the available channels to report incidents of bribery or corruption and non-compliance. 

ABAC Survey

We conduct biennial anonymous ABAC surveys on crew to assess our crew’s knowledge on ABAC best practices, and understand any challenges faced by our frontline staff. Results from this longitudinal study enable us to formulate better policies and initiatives to improve how we support seafarers. We are proud to report that for all years we have initiated surveys to understand the situation onboard, we have received 100% response from our vessels, and responses indicate high levels of understanding of our Anti-Bribery and Anti-Corruption Policy.