Ethics and compliance, in practice rather than in policy

Anti-bribery

We do not make facilitation payments. The position is stated to suppliers and agents in writing before work begins, and it forms part of the engagement terms rather than a declaration filed somewhere.

Where a port, an agent or an official expects a payment we will not make, the client is told. This is the part that is easy to get wrong: quiet accommodation looks like good service on the day and becomes the client’s problem later, usually during an audit and usually at the worst moment. A delay we have explained is recoverable. A payment we have concealed is not.

Staff and subcontractors can report a concern without going through the coordinator holding the file. Write to ops@247div.com without the detail, and we will agree how the rest should reach us.

Sanctions screening

Every supplier, agent and subcontractor is screened against the applicable sanctions lists before it is engaged. Screening is repeated when ownership changes, because a counterparty that was clear when it was engaged may not stay clear, and ownership changes are not announced.

Screening records are kept for each engagement and stay available to the client. They are part of the file, not something we hold on the client’s behalf.

Counterparty checks

Before a supplier is used we establish who owns it, who controls it and whether it is capable of the work. In destinations where corporate records are thin, that means asking directly and documenting the answer, including where the answer was incomplete.

Where we cannot establish ownership to a standard we are comfortable with, we say so and propose an alternative, rather than proceeding and leaving the exposure with the client.

Framework agreements and tenders

We support tender submissions and manage framework agreements once they are in place, including the reporting obligations that come with them. Those obligations tend to be the part that lapses quietly, so they are tracked as deliverables rather than left to the end of the period.

Records

Every disbursement traces to a delivery note, a receipt or a certificate. Consolidated invoicing does not mean an opaque total: the underlying documents are available behind every line, in the form an auditor will ask for.