Compliance and ethics policy

Our strict commitment to running an honest, transparent and ethical business, without exception

Compliance and Ethics Committee

Permanent members:

Wilson Nobre

Wilson is the Commercial Manager of the Westshore Companies in Brazil and a permanent member of the Compliance and Ethics Committee since 2020

Alexandre Vilela

Alexandre is co-founder of the first Westshore company in Brazil within shipbroking and founder of the other Westshore companies within consulting and engineering. Permanent member of the Compliance and Ethics Committee since 2017, year of the publishing of our Company Policy.

Luiz Monteiro

Luiz is the Head of Consultancy from Westshore and our Senior Advisor for all divisions of the company and for our Compliance and Ethics Committee. Luiz is a permanent member since 2019.

Our Company Policy statement:

To comply entails that every WESTSHORE employee and business associate will adhere to the applicable laws and regulations and further to the policies and procedures that are self-regulating, internal directives of WESTSHORE. The COMPLIANCE AND ETHICS POLICY is an integral part of the Westshore business. It is the backbone of our business sustainability. WESTSHORE is committed to conduct its business respecting its core values which are detached and displayed with highest priority in this Policy. The principles of our policies are equaly valid and shall be disseminated in due course of business to all business partners and third parties engaged, and the society.

The Business Values

Honesty: Westshore and its employees are honest, straight-forward, transparent professionals, ethical on their business and

personal behaviours, compliant with the law and regulations.

 

Commitment: Westshore and its employees are committed with the customer, with the society, with the objective to deliver what is agreed.

 

Trust: Westshore and its employees will work to be perceived by the customers as an organization and people that can be trusted, that say the truth. Our word is our bond.

 

Knowledge: Westshore and its employees are differentiated by their knowledge, extensive experience, comprehensive fields of expertise to enable the customer to take the best informed decision.

 

Innovation: Westshore and its employees are engaged in developing and applying the most innovative solutions to the market, created in-house, delivering product that is second-to-none.

The Course of Business / Compliance Programme

These are the directives and practices that every WESTSHORE employee or business associate shall adhere to:

 

Lead by example – the compliance culture: The business decision process in WESTSHORE is ethical, and shall observe the applicable laws and regulations.

 

Directives and procedures: All employees and all business associates shall observe the following principles: WESTSHORE does not deviate from standard business practice. WESTSHORE engages as consultants and/or brokers following the strict principle of independency and transparency. WESTSHORE maintains records of all processes, in corporate accessible data rooms, which can be audited and verified directly by its customers and authorities. WESTSHORE adopts an open book policy for verification of its commissions and business expenses. WESTSHORE does not engage in political activities, does not sponsor political parties. Employment or working directly or indirectly with policitally exposed personnel is subject to authorization by Managing Partners and communication to all involved parties. WESTSHORE treats at the highest level (partners) any complex situation as for instance bribery and corruption, facilitation payments, gifts and courtesies, travel expenses, sponsorship, donations, abuse of priviledged information. WESTSHORE participates and incentives the participation on all third party compliance events as means to build and maintain a sustainable business community. WESTSHORE will not tolerate any deviation from this policy.

 

Anti-bribery and anti-corruption: WESTSHORE splicitly prohibits the offering, acceptance or solicitation of any payments outside regular and formal business course, in any shape or form be it gifts, donation, sponsorship, facilitation payments, objective or subjective confict of interests, deviation to usual brokerage remuneration policies as standard, made, due or made due directly or indirectly, as means to influence any decision or action seeking to obtain or effectively obtain any business.

 

Risk evaluation: At each business opportunity the Compliance Officer must oversee, evaluate and validate the business risk exposure in relation to the Directives and Procedures of this policy, and communicate either verbally or in writing the business decision to engage in each of these opportunities in face of the compliance policy.

 

Communication and training: The commercial and administrative meetings shall all feature a Compliance Moment, where the Commercial and Administration teams may freely speak about business conduct of any opportunity and, if applicable, raise a compliance issue.

 

Registration: Any compliance issue raised shall be registered and treated.


Monitoring and review: The compliance programme is directed by the Managing Partner of each business unit and reviewed by

its peer from the other business unit. The ultimate responsible person for any and all compliance issues is the Group CEO.

 

Sanctions: WESTSHORE has zero tolerance to fraud and corruption. Any violation will consequently be treated with the strictiest actions and adequate to its place of business in conformance with all applicable laws and regulations.

The Course of Business / Ethics Policy

Relationship with business partners (clients, peers, consultants and suppliers):

 

Clients: WESTSHORE is committed to serve its clients in the most appropriate business format observing and respecting the business principles of each clients. Differences and gaps between WESTSHORE policies and clients policies must be treated and agreed. All confidential information must be protected by a formal agreement, and shall be equaly respected and protected.

 

Corruption and bribery prevention: WESTSHORE is committed to preventing corruption and bribery. Gratuities, given or received shall be equally treated. WESTSHORE will not be more tolerable to giving as it is to receiving. As a threshold of our gratuity policy, any and all gratuity received irrespective of value shall be communicated by the party involved to the Compliance Officer for acceptance, but as a rule denied immediately. Gratuities in excess of USD 200,00 are not permitted unless if approved by a Managing Partner and duly recorded, for both giving and receiving. WESTSHORE shall pay its own costs with lunches and other social gathering where one or more employee or partner is present. WESTSHORE shall incentivize that the other business parties do the same. If a courtesy to a business partner is extended, the courtesy must respect the prederemined value of USD 200,00 and be recorded, with formal receipt delivered and registered by the Administrator for open book policy check by any auditor, internal or external.

 

Suppliers: WESTSHORE is committed to treating suppliers as clients are treated. The Compliance rules shall equaly apply and be especially disseminated. Contracts shall be respected and the suppliers must adhere to the WESTSHORE business principles in full.

WSB | Westshore Brazil Compliance and Ethics | Ver 20.1.0 Review March 2020, Original date August 2017

Prepared by: Managing Director (Compliance Officer), Approved by: Managing Partners Westshore Brasil, Validated by: Commercial Manager WSB.