Code of Conduct

IN COMPLIANCE WITH MLC GUIDELINES FOR RECRUITMENT AND PLACEMENT AGENCIES

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This section describes how our Recruitment and Placement agency operates daily to comply with the
International Labour Organization’s (ILO) Maritime Labour Convention 2006 (MLC), ITF Agreement
(International Transport Workers’ Federation), and British Maritime and Coastguard guidelines according to
Merchant Shipping 2014.

1. We do not use means, mechanisms or black-lists intended to prevent or deter seafarers from gaining
employment for which they are qualified. [re. MLC A1.4 para 5 (a)]
2. We make sure that no fees or other charges for providing employment to Seafarers are borne directly or
indirectly by the Seafarer, other than the cost of the seafarer obtaining a national statutory medical
certificate, the national seafarer’s book or the Panama Book (if working on a ship flying Panama flag) and a
passport or other similar personal travel documents, not including, however, the cost of visas. [re. MLC A1.4
para 5 (b)]
3. We maintain an up-to-date register of all Seafarers recruited or placed through us, to be available for
inspection by the competent authority. [re. MLC A1.4 para 5 (c) i]
4. We inform Seafarers of their rights and duties under their employment agreements in the process of
engagement. The Seafarer can examine their employment agreements before and after they are signed as
they receive a copy of it on board the ship. [re. MLC A1.4 para 5 (c) ii]
5. We verify that Seafarers recruited or placed by us are qualified and hold the documents necessary for the
job concerned (including STCW-95 compliant Training Certificates, that are at Seafarer’s expenses). All
Seafarers’ Employment Agreements are in accordance with applicable laws and regulations and the
collective bargaining agreement that forms part of the employment agreement. [re. MLC A1.4 para 5 (c) iii]
6. We examine and respond to any complaint concerning our activity in compliance with our Complaint
Handling Policy. [re. MLC A1.4 para 5 (c) v]
7. We are contactable in an emergency at all hours. [re. MLC B1.4 para 2 (c)]
8. We strictly follow our GDPR Policy and we always send the GDPR Notice and Consent Letter at the
beginning of our recruiting process. [re MLC B1.4 para 1 (d)]
9. No transaction between us and the Shipowner is permitted in regards to our placement and recruitment
activity promoting the exploitation of Seafarers. [re. MLC B1.4 para 2 8 (e)]
10. Our Staff responsible for the supervision of Seafarers’ Recruitment and Placement Service (General
Manager) has an adequate training, approved sea experience and relevant knowledge of the maritime
industry including the relevant maritime international instruments on training, certification and labour
standards. [re. MLC B1.4 para 1 (f)]