Anti-Bribery, Anti-Corruption, Gifts & Hospitality Policy

Purpose: At Varuna Ship Repair and Drydocking Services Inc., we are committed to conducting all business dealings with integrity, honesty, and transparency. This policy ensures that we maintain the highest ethical standards by preventing bribery, corruption, and unethical practices within our organization and across all business activities. We aim to foster a culture of trust and integrity among employees, contractors, and third-party partners.

Scope: This policy applies to all employees, contractors, agents, and third-party partners of Varuna Ship Repair and Drydocking Services Inc., including those operating in Tuzla and Yalova, and any other locations where we conduct business.

Main Guidelines:

ISO Compliance: Comply with ISO 37001 (Anti-Bribery Management System) to detect, prevent, and address bribery and corruption risks within all aspects of our operations.

Zero Tolerance for Bribery and Corruption: Varuna maintains a zero-tolerance approach to any form of bribery or corruption. Employees, contractors, and third parties must not offer, give, solicit, or accept any bribes, whether in cash, goods, or services, to influence business decisions.

Gifts & Hospitality: Gifts and hospitality may only be given or received if they are appropriate, infrequent, and not intended to influence or appear to influence business decisions. All gifts and hospitality must comply with applicable laws, regulations, and Varuna’s internal guidelines.

Conflict of Interest: Employees must avoid situations where personal interests may conflict with the interests of the company. Any potential or actual conflicts of interest must be disclosed to the management immediately.

Third-Party Due Diligence: Conduct due diligence on all third-party partners, including suppliers, agents, and contractors, to ensure they adhere to anti-bribery and anti-corruption standards. Varuna will only engage with third parties who share our commitment to ethical business practices.

Employee Training: Regular training will be provided to all employees on anti-bribery, anti-corruption practices, and the proper management of gifts and hospitality. This ensures that employees are fully aware of the importance of complying with this policy and the legal consequences of violations.

Whistleblower Protection: Encourage employees and third parties to report any suspicions of bribery, corruption, or unethical behavior without fear of retaliation. A confidential reporting mechanism will be provided, and all reports will be investigated promptly and thoroughly.

Record Keeping: Maintain accurate and complete records of all transactions involving gifts, hospitality, and payments to third parties to ensure transparency and accountability. Regular audits will be conducted to ensure compliance with this policy.

Reporting Violations: Any employee found to be engaging in or facilitating bribery, corruption, or violating this policy in any way will face disciplinary action, which may include termination of employment and legal consequences. Varuna is committed to taking immediate corrective actions when violations occur.

Commitment: At Varuna Ship Repair and Drydocking Services Inc., we are fully committed to ethical business practices and fostering a culture where bribery, corruption, and unethical behavior have no place. We hold ourselves and our partners to the highest standards of integrity and compliance with both national and international anti-bribery laws.