Compliance

Anti-Bribery & Corruption

• Every country has different challenges and risks from an Anti-Bribery and Corruption perspective, no one policy or checklist can encompass multiple countries.

• Our network has a local presence in >490 ports in >90 countries, as such, we understand the local nuances and conditions that either promote or condone non-compliant practices in individual locations.

• In many countries, these practices are simply accepted as a ‘custom of the port’ and are often overlooked or ‘buried in the DA’, particularly when the dollar amounts are small.

• We take a ZERO TOLERANCE approach.

• We use our local knowledge in each location to determine the locally prevalent practices in each location.

• We make our clients aware of the typical risks and problems encountered in each location.

• We work with our local network to find ways to avoid these practices. We implement location-specific checklists, so as to be on the lookout for specific local practices.

• We Ensure that the local agents and vendors that we are appointing on our client’s behalf, understand and acknowledge our ZERO TOLERANCE policy.

• We ensure that the local agents and vendors know we are aware of the local nuances and practices and that we have pro-active measures in place to monitor, identify, address, and report these practices.

• We ensure that when non-conformances are identified by our hub, we can withhold payment to the local agent or vendors.

• We ‘black-list’ the local agents/vendors that permitted these practices and if need be engage with the local authorities to address these practices.

Sanctions and Trade Compliance

• Sanctions and Trade Compliance is a top-level priority at WaterFront.
• We have an Agency Management System that is workflow based and thus enables us to manage and coordinate all aspects of a port call anywhere in the world.
• An integral component/module within our Agency Management System manages Sanction and Trade Compliance across all workstreams in a port call.
• We have a thorough and detailed process for scanning every appointment (port call) we handle.
• Our Agency Management System automatically scans all parties and vessels on our database, any matches on a vessel, company, or person that has an 85% match on the system, is escalated for manual review by our compliance team.
• Sanctions Checks at a company, material shareholder, and director-level are automatically run by our Agency Management System every 24hrs against updated 3rd party databases including OFAC. Ensuring that any previously cleared parties that may have been added to a sanctions watch list are immediately identified.

Vendor Vetting (KYC)

• We provide clients with the full transparency and peace of mind that local agents and vendors are strictly vetted so as not to inadvertently expose our client, while we remain sensitive to the commercial relationship that our client has with the party who may have nominated or appointed the individual local agent or vendor.

• We conduct extensive vetting on all local port agents, including agents that are appointed by our clients as well as agents that are nominated by our clients’ commercial counterparties.

• The vetting can be extended to cover individual local vendors in individual ports or countries, where the client’s annual spend with a vendor exceeds a client-defined dollar amount.

• We collect specific ‘KYC’ type of information from the local Agents and Vendors.

• The data received from the agents/vendors are processed by our Agency Management System and exceptions to predefined criteria are flagged by the system.

• Prior to approval the exceptions are examined and evaluated by our staff and escalated through our management and to our client if need be.

• All supporting documentation that has been validated is uploaded into our Agency Management System.

• We can offer clients full real-time visibility and transparency to the process, status, data, audit trail of any agent or vendors via access to our Agency Management System.

• Sanctions Checks at a company, material shareholder, and director-level are automatically run by our Agency Management System every 24hrs against updated 3rd party databases.

• The entire Vendor Due Diligence is reviewed at least every 24 months. Individual aspects are evaluated as and when there are exceptions or expiries.

• Bank Account validation is performed for every single remittance we make to local agents or vendors on our client’s behalf.