OPEN
REPORTING
LINE

Our Open Reporting Line Program is fundamental to the Company’s professional integrity.

OPEN REPORTING LINE

Introduction

As a means of accountability and transparency, the Company has introduced this Program to enable all individuals to voice concerns internally in a responsible and effective manner when they discover information which they believe indicates malpractice.

Individuals who are faced with a difficult ethical situation/dilemma and feel uncomfortable about raising the matter through the Company’s normal reporting process, will be able to address it through this procedure.

Our Open Reporting Line is fundamental to the Company’s professional integrity. In addition, it reinforces the value the Company places on personnel to be honest and transparent. It provides a method of properly addressing, in good faith, concerns that individuals might have, while also offering open reporters protection from victimization, harassment or disciplinary proceedings.

What is Open Reporting?

Open Reporting is the confidential disclosure by an individual (the open reporter) of any concern relating to a risk, malpractice or perceived wrongdoing that affects others (such as clients, suppliers, the Company, other employees or the public interest). The Company considers such wrongdoing to include:

  • Bribery or money laundering;
  • General malpractice – such as immoral, illegal or unethical conduct; (including instances where someone’s health, property and/or safety has been put in danger)
  • Gross misconduct;
  • Potential infringement / breach of the Company’s policies;
  • Potential infringement / breach of the Company’s Code of Conduct.

Who does this procedure apply to?

This procedure applies to everyone who carries out work for and everyone who does business with the Company including:

All employees;

All seafarers serving on board vessels managed by the Company;

Contractors and sub-contractors;

Agencies;

Partners;

Consultants.

What are the fundamental elements of this program?

All individuals who raise a concern are protected from victimization, harassment or disciplinary action as a result of such disclosure. All information will be carefully investigated and interviews with all witnesses and other parties involved will take place.

Open Reporters might wish either to identify themselves or to remain anonymous. In both cases, the open reporters will be protected at all stages. However, the Company is not accountable for maintaining anonymity in case the open reporters has told others of the alleged wrongdoing.

Possible outcome after reporting a concern

Anyone who reports a concern shall be protected and all relevant information disclosed will remain confidential;

The following actions may be taken after investigation of the alleged wrongdoing;

  • Disciplinary action (up to and including dismissal) against the wrongdoer depending on the results of the investigation; or;
  • No action if the allegation proves unfounded.

The open reporter will be kept informed of the progress and the outcome of the investigation, within the constraints of confidentiality.

Reporting methods

Open Reporting Line’s reports are confidential. If the reporter wishes to remain anonymous he may do so. Minerva Gas Inc. has selected “Falcony”, an independent third party to handle the reports and to ensure the highest level of security and confidentiality.