1) Policy Statement

1.1 Front Line Forwarding & Agency Ltd. is committed to applying the highest standards of ethical conduct and integrity in its business activities in Greece and overseas. Every employee and individual acting on Front Line Forwarding & Agency Ltd.’s behalf is responsible for maintaining our reputation and for conducting company business honestly and professionally. The prevention, detection and reporting of bribery and other forms of corruption is the responsibility of all those working for us, or supplying services to us, or under our control.
1.2 We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate.
1.3 The purpose of this policy statement is to:
a) set out our responsibilities, and of employees or those providing services for us, (which for the purpose of the Bribery Act includes service providers of the Front Line Forwarding & Agency Ltd.), in observing and upholding our position on bribery and corruption;
b) provide information and guidance as to how we expect those working for us to conduct themselves and how to recognize and deal with bribery and corruption issues; and
c) how to raise concerns with us including any breaches of this policy statement. Front Line Front Line Forwarding & Agency Ltd.’s Management is committed to implementing and enforcing effective systems throughout Front Line Forwarding & Agency Ltd.

2) Corruption & Bribery

2.1 What is corruption?
Corruption is the abuse of entrusted power of private gain.

2.2 What is bribery?
A bribe, broadly, is an inducement or reward offered, requested, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage. This can be in the context of giving or receiving. An offence is committed when the bribe is coupled with an intention of inducing, a reward for or in anticipation for a person to improperly perform their function or if the request, agreement to accept or acceptance of the bribe itself constitutes or is believed to constitute the improper performance of an activity.

2.3 Government / Public Officials
Offering a bribe to a “government official” or a local/foreign public official aiming to obtain or retain business or an advantage in the conduct of business (and that is not permitted by local laws), is prohibited by Front Line Forwarding & Agency Ltd.
A “government official” means:

  • any officer or employee of a foreign, national, local or municipal government whether elected or appointed;
  • any person acting in an official capacity or exercising a public function for or on behalf of any government or its instrumentality;
  • any officer or employee of a public international organization such as the UN or the World Bank;
  • a member of a legislative branch, judge, customs official, or taxing official;
  • political parties, their officials, and candidates for public office;
  • or employees of state-owned or state controlled commercial enterprises.

2.4 Facilitation payments and kickbacks
2.4.1 We and our service providers should not make, and should not accept, facilitation payments or «kickbacks» of any kind. Facilitation payments are typically small, unofficial payments made to secure or expedite a routine government action by a government official. Kickbacks are typically payments made in return for a business favour or advantage. We expect all employees and service providers must avoid any activity that might lead to, or suggest, that a facilitation payment or kickback will be made or accepted by us.
2.4.2 If you are asked to make a payment on behalf of Front Line Forwarding & Agency Ltd. you should always be mindful of what the payment is for and whether the amount requested is proportionate to the goods or services provided. You should always ask for a receipt which details the reason for the payment.
2.4.3 Any transactions in contracts and documentation must be recorded so that there is never any attempt to hide the way a contract will work.

2.5 Charitable & Political Contributions
Front Line Forwarding & Agency Ltd. Conducts business activities so that inappropriate charitable and political activities or statements do not affect Company’s best interests. Front Line Forwarding & Agency Ltd. is not involved in political matters, and all of us must follow all financial, ethical laws and regulations on political activities. Privately, we may all participate in political activities and make contributions on our own time and with our own money, as long as it does not involve Front Line Forwarding and Agency Ltd.’s money, resources or time to do that.

2.6 Third Party Relationships
Front Line Forwarding & Agency Ltd. uses the services of third parties (agents, consultants or joint venture partners), as it is an essential element of doing business. They are generally retained by Front Line Forwarding & Agency Ltd. for the expertise and services, they may offer. Front Line Forwarding & Agency Ltd. must be alert to avoid situations involving the services of third parties that might lead to any violation of anticorruption laws.
Front Line Forwarding & Agency Ltd.’s Policy statement is available in company’s website and a copy of it will be attached to any newly signed contracts.

3) Gifts and Hospitality

3.1 Front Line Forwarding & Agency Ltd. permits normal and appropriate corporate entertainment, gifts, hospitality and promotional expenditure (given and received) to or from our customers, vendors and suppliers as well as a third party that is undertaken:
a) for the purpose of establishing and maintaining good business relationships
b) to improve the image and reputation of Front Line Forwarding & Agency Ltd.
c) to present Front Line Forwarding & Agency Ltd.’s goods/services effectively.
Provided that it is:
a) in good faith
b) not offered, promised or accepted to secure an advantage for the its employees or associated persons or to influence the impartiality of the recipient.
3.2 The giving of gifts by Front Line Forwarding & Agency Ltd. employees with an approximate value of 50 Euro or higher is prohibited unless they have been given prior approval by their Head of Department. With regard to our employees receiving gifts, unless approval has been provided by the appropriate Head of Department, gifts that exceed a 50 Euro threshold must be declined and will be recorded. Gifts in the form of cash must never be accepted by our employees or service providers and therefore must not be offered and any offers of cash must be immediately reported to Front Line Forwarding & Agency Ltd.’s Assistant Manager. The giving or receiving of promotional material or sponsorship is not considered a gift.
3.3 The giving and receiving of corporate entertainment and hospitality for our employees should not exceed an approximate value of 50 Euro per head without prior approval by a Front Line Forwarding & Agency Ltd. Assistant Manager where possible and reasonable to do so in the circumstances.
3.4 The test to be applied is whether in all the circumstances, the gift, entertainment or hospitality is reasonable and justifiable. We expect the intention behind the gift to always be considered.
3.5 What is not acceptable?
Below are some non-exhaustive scenarios as to we think is not acceptable for employees or service providers of Front Line Forwarding & Agency Ltd. to do, namely:
a) give, promise to give, or offer, a payment, gift or hospitality to customers, vendors and suppliers as well as a third party with the expectation or hope that a business advantage will be received, or to reward a business advantage already given;
b) give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to «facilitate» or expedite a routine procedure;
c) give, offer or promise to a government official or a local/foreign public official to induce that government official or public official to obtain or retain business or an advantage in the conduct of business (and that is not permitted by local laws), request, agrees to receive or accept payment from a third party knowing or suspecting it is offered with the expectation that it will obtain a business advantage for them;
d) request, agrees to receive or accept payment from customers, vendors and suppliers as well as a third party knowing or suspecting it is offered with the expectation that it will obtain a business advantage for them;
e) accept a gift or hospitality from customers, vendors and suppliers as well as a third party knowing or suspecting that it is offered or provided with an expectation that a business advantage will be provided by Front Line Forwarding & Agency Ltd. in return;
f) threaten or retaliate against another worker who has refused to commit a bribery offence or who has raised concerns under this policy; and
g) engage in any activity that might lead to a breach of this policy

4) Accounting Requirements

FRONT LINE Forwarding & Agency Ltd. makes and keeps books, records, and accounts, which, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of Front Line Forwarding & Agency Ltd.
The use of false documents and invoices is prohibited, as is the making of inadequate, ambiguous or deceptive bookkeeping entries and any other accounting procedure, technique or device that would hide or otherwise disguise illegal payments.

5) Reporting & Handling Allegations

Following our Policy Statement, we encourage every employee and individual acting on Front Line Forwarding & Agency Ltd.’s behalf to report violations or suspected violations ensuring conducting company business honestly and professionally.
5.1 How to report
If you believe this policy has been breached, or suspect it may have been breached, in any way please contact the Front Line Forwarding & Agency Ltd. using whatever method, you are most comfortable with:
* Management. Tell your manager if he or she is not involved in the alleged misconduct and you are comfortable doing so. Or another member of management if you think that will be more effective.
* Assistant Manager (management@frontline-ltd.com).
It would be preferable whether you could give your name when reporting a violation or a suspected violation, however you can remain anonymous. You may report in whatever way you feel more comfortable with and in case you do not receive a response, please report again.
5.2 What are the consequences of non-compliance?
Failure to comply with Anticorruption laws could cause Front Line Forwarding & Agency Ltd. and employees individually to pay heavy fines and could be also very time-consuming. It could harm the image of the Company and of the ones involved. Front Line Forwarding & Agency Ltd. may suffer in connection with misconduct, individuals may need to bear imprisonment and other restrictions as a result of legal actions.
At Front Line Forwarding & Agency Ltd., subject to and to the fullest extent allowed by applicable law, violation of Front Line Forwarding & Agency Ltd.’s Anti-bribery and corruption Policy as well as violation to other policies and procedures may result in disciplinary action, including possible termination.
5.3 Investigating of reports
In case an anti-bribery and corruption case is reported, Front Line Forwarding & Agency Ltd will call an independent investigator to perform the investigation. Results of analysis will be adequately reviewed and basis on the company’s commitment for continued improvement Anti-bribery and corruption Policy will be amended, as required.

6) Periodic Auditing

It is FRONT LINE Forwarding & Agency Ltd.’s intent to establish barriers that enhance anti-bribery and corruption policy procedures. Therefore, periodical auditing of company’s books and records is conducted (at least once per year or whenever needed), in order to detect/identify any potential corruption violation.

7) Acknowledgement

Each newly joined employee receives proper familiarization/ training of Front Line Forwarding & Agency Ltd.’s Anti-bribery and corruption policy. Also, in frequent intervals, Anti-bribery and corruption policy is reviewed and discussed with all employees as part of the agenda, during departmental meetings.
A copy of Anti-bribery and corruption policy statement duly signed by each employee is kept in company’s records as evidence of familiarization/commitment.
Acknowledgement
Subject to and to the fullest extent allowed by applicable law, I hereby:
• acknowledge that I have received, reviewed, understand, and will comply with Front Line Forwarding & Agency Ltd.;
• understand that violation of the Global Anticorruption Policy or Front Line Forwarding & Agency Ltd.’s other policies may result in disciplinary action, including possible termination; and
• agree that I will promptly report any known or suspected violations of the Global Anticorruption Policy, other Front Line Forwarding & Agency Ltd. policies, applicable laws or regulations, and any actual (or apparent) conflicts of interest.
Name: ______________________________________________
Title: ______________________________________________
Signature: ______________________________________________
Date: ______________________________________________