BENLAJU MARINE CONSTRUCTION
COMPANY LIMITED
*COMPLIANCE*
CODE OF BUSINESS CONDUCT
INTRODUCTION
1. This Code of Business Conduct and Ethics (the “Code”)has been adopted by the Board of Directors (the “Board”) of
BENLAJU MARINE CONSTRUCTION COMPANY and is intended to assists all its employees, managers and executives
to maintain the highest standard of ethical conduct within in all its facilities and vessels.
2. The Board is responsible for the adoption and approval of this code and has designated the manager to carry out the day-
to-day implementation and administration of this code to ensure compliance.
3. This code is aimed at providing our employees a clear and helpful guide to what is acceptable conduct and Working here
means making a commitment to uphold our company values and following the code of conduct outlined in this document. .
4. Noncompliance or violation of this Code may result in putting us or you at risk and any such violation is therefore likely
to result in disciplinary action, up to and including suspension and/or termination of employment.
CORE VALUES
At Benlaju, the beliefs and principles that drive us are:
* Integrity: Building trust builds a better company.
* Empathy: inclusion and caring about others’ success are a defining part of our identity.
* Teamwork: We only win when we unite to deliver results for our company.
* Innovative: We are a perceptual work in progress always striving to be better.
* Collaboration: We deliver more success through shared goals and mutual support.
* Result oriented: Take action and deliver results.
* Employee development: We encourage employees’ growth.
* Get it right the first time: Precision and spontaneity drive efficiency and reduce waste.
DECISION MAKING
All heads of department including (but not restricted to ) the captains , engineers , dredging masters and other employees
in our facilities especially (but not restricted to) our marine vessels are expected to promote honest and ethical conduct
in decision making, including the ethical handling of actual or apparent conflicts of interest between personal and
professional relationships. When making a decision, ask yourself the following:
* is it legal?
* Does it comply with the code?
* Does it reflect our company values and ethics?
* Does it respect the rights of others?
* If you are unsure about any of the answers, ask your manager.
COMPLIANCE WITH LAWS
5. All Employees are expected to comply with all government laws, including anti-bribery, maritime, environmental
and safety laws, and all rules and regulations applicable to the
Company in all jurisdictions where it operates.
6. All Employees are expected to act with integrity, use good judgment and common sense in seeking to comply
with all applicable laws, rules and regulations, and in particular those relating to accounting and auditing matters
(income tax inclusive), and to ask for advice from the management if there is any uncertainty whether a situation
may violate any applicable laws
CONFLICT OF INTEREST
A conflict of interest can occur when an employee’s personal activities, investments or associations compromises
their judgment or ability to act in the company’s best interests.
No employee should take unfair advantage of anyone through manipulation, concealment, misrepresentation,
inappropriate threats, fraud, abuse of confidential information or any other intentional unfair-dealing practice.
Employees should avoid the types of situations that can give rise to conflicts of interest.
OPERATIONAL CONDUCT
THE MANAGEMENT: The Board is responsible for making available the company’s values, vision statements
and mission statements while the manager is responsible for their implementation and making sure every employee
works in synchrony with them. The Board is also responsible for any change or adjustment to the code of conduct as
required by the demands of the business.
It is the responsibility of the management to provide all the necessary resources and assistance to all employees in
their various department to carry out their duties optimally for the smooth operation of the business.
It is the responsibility of the operations manager to formulate strategy and improve performance. As a member of
each crew, the manager is responsible for planning, organizing, staffing, leading, and controlling the operations of
each department in line with the company’s missions and visions.
The manager must work collaboratively with every employee to enable them carry out their duties efficiently. He’s
also expected to carry out routine inspection and audit of all the company’s facilities and equipment.
EMPLOYEES:
1. Performance: All employees are expected to fulfill their job duties with efficiency,
quality and consistency. There will be routine evaluation of employees’ performance as preference will be given to
employees with exceptional performance and there will also be consequences for continuous under performance and
negligence of duties. Any employee that displays extra-ordinary expertise in their job delivery is entitled to some form of
incentive as encouragement.
A high-performing employee is extremely valuable to a company. An experience
Captain is expected to study the weather and tide before casting out in order to envisage what challenges he is likely to
encounter. Likewise, a competent engineer should be to foresee some likely engine breakdown before they occur so as to
tackle it to avoid escalation and possible down-time.
2. Accountability: All employees are responsible for their actions, behaviors, performance and decisions while on duty
and any form of misconduct or gross negligence resulting to damage or destruction of the company’s equipment or
facility (industrial and marine vessels) will no longer be condoled as there will be penalty except equipment faults that
you have no control over.
3. Accidents: While it is true that some accidents are the result of unforeseeable ‘freak’ incidents, it cannot be denied
that many workplace accidents can be prevented. Unfortunately, many workplace accidents especially in our marine
facilities as a result of negligence on the part of the whole crew or some members of the crew involved. Any accident
involving any of our vessels will be repair by those involved and if any boat hit you, should repair the damage else the
whole crew will repair it with their salary.
4. Time-off: Hence forth the company will be responsible for all employees’ time-off schedule. Please note that there
must be proper handing-over to all employees’ replacement before going on time-off and while on time-off, you have no
affiliation whatsoever with the operations of the boat as every responsibility falls on your replacement s including any
surplus (diesel) that will result from the operation.
3. Personal Income Tax (PIT): The management has been instructed by the Federal Inland Revenue Service (FIRS) to
comply with the payment of both the ‘Personal Income Tax ‘ of all employees and the ‘company Income Tax’ to avoid
sanctions and possible jail term.
Henceforth the total monthly tax of every employee will be remitted to the Government.
REPORTING AND COMPLIANCE PROCEDURES
Every Employee has the responsibility to ask questions, seek guidance and to report suspected violations and express
concerns regarding compliance with this Code
ZERO TOLERANCE ON RETALIATION
1. We believe that speaking up is always the right thing to do.
2. Employees will not be disciplined, discriminated against, or subjected to adverse personnel action or reprisal by
reason of having made a report in good faith regarding a potential violation of this Code or any other of the Company’s
policies or for cooperating in any investigation or inquiry regarding such conduct.
3. Under no circumstances will the Company tolerate any retaliation against Employees. We consider acts of reprisal or
retaliation to be acts of gross misconduct and will investigate any such reports thoroughly. If substantiated, claims of
retaliation could result in disciplinary action and even dismissal.
CODE OF CONDUCT ACKNOWLEDGEMENT
By certifying to the company code of conduct, you acknowledge that:
1. You have read the entire code of conduct and understand your responsibilities related to it.
2. You have had the opportunity to ask questions to clarify any unclear aspects of the code.
3. You agree to abide by its principles.
4. You agree to report to the company any violations of the code.
5. You agree to cooperate in any investigations of violations of the code.
NAME & SIGN:
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