Anti-Bribery and Anti-Corruption Policy

Purpose

BW LPG is committed to being the world’s leading provider of LPG maritime transportation services. The BW LPG Anti-Bribery & Anti-Corruption policy guides BW LPG’s interactions with suppliers, customers, members of the industry and other stakeholders at all levels within the organisation.  

Policy Statement

• BW LPG will comply with all anti-bribery and corruption laws in force in all jurisdictions in which we operate, as well as those which apply on a cross-border basis, including, but not limited to, the Bribery Act 2010 of the United Kingdom and the Foreign Corrupt Practices Act of 1977 (as amended) of the United States and any other applicable laws, regulations or codes.
• Expect all employees to conduct themselves with high standards of integrity. Employees must avoid any situation or activity that compromises, or may compromise, their judgment or ability to act in the best interests of BW LPG.
• Support any employee who passes up an opportunity or advantage that would compromise our standards.
• Ensure that our reputation for ethical behaviour and fair dealing with suppliers, customers, members of the industry and other stakeholders is maintained.
• Prohibit the giving or receiving of any gift, cash, entertainment or hospitality where the intention is to influence a business decision.
• Prohibit unofficial payments or gifts made to facilitate routine government action (facilitation payments) where there is an intention to influence a public official in the performance of his/her official function and gain an advantage in the conduct of business.
• Prohibit employees from asking for or suggesting any gifts and/or entertainment of any kind or amount from suppliers or any other person.
• Any gift, entertainment or hospitality that exceeds the monetary thresholds outlined in BW LPG’s Gift and Entertainment policy must be recorded.
• Employees are responsible for reporting infringements of any applicable laws in the jurisdictions in which BW LPG operates and in particular with respect to the UK Bribery Act 2010 and the United States Foreign Corrupt Practices Act 1977 (as amended).

In order to achieve this, BW LPG shall:

• Provide training, guidance to employees on BW LPG’s Anti-Bribery & Anti-Corruption policy.
• Require all shore-based employees to report gifts and entertainment according to BW LPG’s Gift and Entertainment policy.
• Record all gifts and entertainment received or given.
• Appoint an Anti-Bribery & Anti-Corruption Representative to ensure adherence and compliance to the policy.