How we do business

Quality policy

Navium Maritime is committed to achieving business excellence through the effective implementation and continual improvement of our quality management system, in accordance with applicable regulatory requirements. We are committed to:

• Customer satisfaction: understanding and meeting customer needs through quality products and services.
• Compliance: fulfilling all applicable legal, regulatory and contractual requirements.
• Business ethics: conducting business with integrity, transparency and fair competition.
• Continuous improvement: enhancing our processes, performance and the effectiveness of our quality management system.
• Employee involvement: encouraging all personnel to contribute to quality objectives and organisational success.

Management is fully committed to providing the leadership, resources and support needed to achieve these objectives. The Managing Director, Mr. Sukhbir Singh, is responsible for implementing this policy, and the CEO maintains the quality management system.

Anti-bribery and anti-corruption policy

Navium is committed to the highest standards of transparency, integrity and accountability. We do not tolerate bribery, embezzlement or corruption in any of our dealings, and we uphold all applicable laws countering bribery, fraud and corruption.

• Navium will not offer, give, request or accept any bribe or unethical inducement, including facilitation payments and kickbacks.
• The policy applies to all employees, consultants, advisers, suppliers, partners and anyone acting on Navium's behalf, wherever they are.
• We expect suppliers and partners to act with integrity, and include relevant clauses in contracts where appropriate.
• Proportionate gifts and hospitality given without improper intent, where nothing is expected in return, are permitted and recorded.

Raising a concern: anyone offered or asked for a bribe in connection with Navium should report it to the CEO, or to the Managing Director if the CEO is implicated, or to the local anti-corruption authorities. Concerns can be raised in confidence through operations@naviumship.com. No one will be treated unfairly for reporting a concern in good faith. The policy is reviewed by top management at least every three years.

Anti-money laundering and counter-terrorism financing statement

India addresses money laundering and terrorism financing principally through the Prevention of Money Laundering Act, 2002. Although Navium is a marine consultancy and training company rather than a financial institution, we work with clients across many countries and take care that our business relationships are never used to facilitate money laundering or terrorism financing.

• We assess the risk of our services being misused every year, considering our clients, the countries we work in and the nature of our engagements.
• Before entering a business relationship, we identify and verify the client and, where relevant, its representatives and beneficial owners, and understand the purpose of the engagement.
• We decline or end relationships where a client cannot be verified, the source of funds cannot be reasonably explained, the purpose of the engagement is not legitimate, or there is credible adverse information about the client's integrity.
• We monitor engagements and payments for unusual activity, such as payments from unrelated third parties or requests to bypass normal invoicing.

The CEO and Managing Director are jointly responsible for company-wide adherence to our AML/CTF obligations.

Modern slavery policy

Navium Maritime is committed to conducting business ethically and responsibly, and in compliance with applicable Indian laws on modern slavery and human trafficking. We have a zero-tolerance approach to modern slavery in all its forms, including forced, compulsory and bonded labour, child labour, servitude and human trafficking.

• The policy applies to our directors, employees and temporary personnel, and to contractors, consultants, suppliers and business partners acting on our behalf.
• We assess risks periodically, apply due diligence when engaging suppliers and partners, and encourage them to adopt equivalent policies.
• Our recruitment practices comply with applicable labour laws and prohibit forced or child labour.
• We may end business relationships with any party found to have engaged in or supported modern slavery or human trafficking.

Reporting concerns: employees, contractors, suppliers, business partners and members of the public can report suspected modern slavery confidentially by email to operations@naviumship.com or in writing to our registered office. We treat reports confidentially wherever possible, investigate them promptly and fairly, and protect anyone who reports in good faith from retaliation.

These are public summaries. The full policies form part of Navium Maritime's company business and policies manual and are available to clients on request.