Anti-Bribery & Anti-Corruption Policy

Draft policy: for review and approval by Anik Shipping Lines management and its legal adviser before publication.

Purpose

To make sure we never offer, pay, request or accept bribes, and that every payment we make is legitimate and recorded.

Scope

All employees, directors and anyone acting on behalf of Anik Shipping Lines.

Our commitments

• Never offer, pay, request or accept a bribe or improper advantage, in cash or in kind.
• Make no facilitation or "speed" payments to officials.
• Record every payment made for a principal, with a receipt, on the disbursement account.
• Keep gifts and hospitality modest, transparent and recorded.
• Check the integrity of the suppliers and agents we work with.
• Protect anyone who reports a concern in good faith.

Responsibilities

• Management sets the example and approves any exception to the gifts rules.
• Every employee reports any request for a bribe to management immediately.

Review

This policy is reviewed at least once a year by management, and whenever operations, regulations or risks change.