Responsible Business Practices

Strong corporate ethics and sensible business values

In the pursuit of our vision and objectives, we always seek to apply sound and internationally accepted business ethics and principles. Our business principles cover a range of tenets and traits designed to maximise the trust, respect and friendship between the Company and its stakeholders, highlighting the fairness and responsibility with which we approach our business.


Our Code of Conduct prohibits our staff from offering or accepting bribes or engaging in fraud, forgery, collusion, anti-competitive behaviour or other forms of corruption. To bolster the Company’s anti-corruption culture and maintain a zero corruption record, we continually review our anti-corruption policies and practices which we convey to our staff via regular training.

We require our staff to abide fully by local anti-corruption laws such as the Prevention of Bribery Ordinance under Hong Kong law for staff in our Hong Kong headquarters. Similar anti-corruption laws (such as the UK Bribery Act 2010) and expectations apply to all our staff around the world.

We provide anti-corruption training for our directors and shore-based and seafaring staff by means of an online e-learning portal and inhouse workshops. Every new joiner receives training in anti-corruption, whistleblowing and our Code of Conduct in our orientation programme. Anti-corruption refresher training is arranged for all staff every three years to ensure they are updated on the subject.

In 2023, 100% of our new joiners completed anti-corruption training. All of our directors received anti-corruption training in the past three years.

During the reporting period, we were not, are not and have never been involved in any legal cases regarding corrupt practices.

0 Cases of Corrupt practices

Pacific Basin has been certified by globally recognised anti-bribery organisation TRACE since 2017, signifying that our Company has been thoroughly vetted and certified by TRACE in anti-bribery matters.

Pacific Basin has been an active member of the Maritime Anti-Corruption Network (MACN) which strives through collective action to eliminate all forms of corruption in the maritime industry. MACN does this by:

  • raising awareness of the challenges faced
  • implementing the MACN anti-corruption principles and co-developing and sharing best practices
  • collaborating with governments, NGOs and civil society to identify and mitigate the root causes of corruption
  • creating a culture of integrity within the maritime community

Through adopting the MACN anti-corruption principles and MACN’s toolkits, we are better able to avoid, respond to and report incidents of bribery, facilitation payments and other forms of corruption through appropriate monitoring, comprehensive risk assessment and training.

Our ships' officers occasionally encounter the need to make facilitations payments under duress - essentially extortion in which local officials threaten harm to our crews and/or improper fines and delays to our vessels. Our ships' captains will always refuse such extortion attempts, but payments are not always avoidable when our crews' safety is at real risk. All incidents of attempted or successful extortion are reported to our head office and recorded in MACN’s Incident Reporting System.

In 2023, we registered 7 incidents of facilitation payments under duress on our owned vessels involving total payments of about US$7,340 in cash or in kind.

Anti-Collusive Behaviour

We operate in highly competitive and fragmented markets and we do not collude with competitors or otherwise cooperate in a covert manner to gain unfair pricing advantage. The size and market share of our dry bulk fleet and the nature of our dry bulk freight activity are deemed not to breach competition regulations in any markets in which we are engaged.


Our ships operate globally and we engage in trades that comply with international laws and do not contravene international trade sanctions or relevant local or national laws.

Our customers are required not to ship illegal goods on our vessels, and our global chartering organisation follows the key rule of “knowing your customer and their business” which enhances our understanding of their cargo.

Our customers are reputable organisations, including many blue-chip companies, who we know well. Nevertheless, our customers are required to commit to the expectations and requirements of our Counterparty Code of Conduct (including no contravention of sanctions) and for newer potential customers in particular, we may seek advice on their background, verbal and written references, formal counterparty risk appraisals, and we check if they appear on US, UK, EU and UN sanction lists.

We also consider where voyages are from and to, and monitor the layers of sanctions prevailing around the world so as not to risk exposure to criminal penalties.

In 2023, we implemented automated sanctions screening to further enhance our sanctions checking programme that we previously upgraded in 2022. Our company conducts thorough due diligence and background checks of all chartering counterparties through a specialised team, utilising third-party due diligence reports and a comprehensive sanctions screening platform provided by a reputable risk intelligence provider.

In addition to our own sanctions due diligence, banks that our customers transact through also conduct checks and do not provide letters of credit or finance to, or otherwise transact with, customers if the cargo or trade breach sanctions, thus preventing the customer from executing a freight contract with us. A second check arises when the cargo and/or freight invoice is payable, at which point banking systems automatically vet the countries and counterparts involved in the transaction.

Responsible Cargo Carriage

Our commitment to responsible cargo carriage and sustainable trade is reflected in our Trading Restrictions Policy which sets out restricted trading activities and areas, and related procedures and approval requirements. We plan to develop a more thorough responsible cargo carriage policy to enhance our positive contribution to sustainable shipping.

We know our customers and their business and adhere to trading practices that follow the letter of local, regional and international maritime law and do not contravene sanctions


We are committed to providing a workplace free of dishonest, illegal or discriminatory activities. As part of our efforts in this area, we have whistle-blowing procedures in place for seafarers, shore-based staff and external stakeholders to raise serious and genuine concerns, in confidence, following procedures that are published on our intranet (for our shorebased staff) and on our website (for external stakeholders).

Whistleblowers can raise their concerns without fear of victimisation, discrimination or disadvantage to the Chairman of the Audit Committee, who is an independent non-executive director of the Company.
Attention: John Williamson, Audit Committee Chairman
Tel: +852 2233 7296

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