In the context of Social Responsibility and Corporate Governance, the Board of Directors of Safe Bulkers, Inc. has adopted Company policies presented below in brief, for all of the Company’s employees, directors, officers and agents.
Code of Business Conduct and Ethics
In order for the Company to promote a business culture of honesty, fairness and ethical behavior and to encourage employees to report evidence of illegal or unethical behavior, the Company has adopted the Code of Business Conduct and Ethics. Safe Bulkers’ officers endeavor to deal honestly, ethically and fairly with the Company’s customers, suppliers, competitors and are urged to maintain the highest degree of confidentiality complying with the various laws, rules and regulations of the countries and regulatory authorities that affect the Company’s business. Our Management setting the tone at the top promotes a culture of zero tolerance towards fraud, unfair advantage, manipulation, concealment, abuse of privileged proprietary and confidential information, misrepresentation of material facts, or any other unfair-dealing practice.
All such cases are reported directly to the independent Audit Committee of the Company. The Company at every instance promotes honest conduct that is free from fraud or deception and ethical conduct conforming to accepted professional standards of conduct and does not retaliate or allow any form of retaliation for reports made.
Ethics and Whistleblowing Policy
This policy outlines the Company’s principles with respect to receiving and retaining information about and treating alleged incidents involving the Company regarding accounting, internal accounting controls or auditing matters and details procedures for officers to report incidents involving the Company regarding accounting, internal accounting controls or auditing matters and describes actions to be taken by the Company.
To that end, the Company has established a dedicated Whistleblower and Ethics Hotline for all inquiries to report possible misconduct related accessible only to the Company’s independent Audit Committee members.
Corporate Information Security Policy
The purpose of this policy is to formulate, develop, document, train and communicate policies, procedures, control mechanisms and standards governing key IT function activities and protection of key IT systems and infrastructure from operational, cyber, physical access and other risks. Periodic independent review of such policy, procedures, and controls is performed to assure such policy remains commensurate with risks involved in the Company’s operations.
It is the policy of the Company to provide timely, transparent, consistent and credible information to the investing public in conformity with legal and regulatory requirements. These disclosure guidelines set forth the Company’s intentions regarding how employees, officers, directors, agents and affiliates of the Company may communicate with outside parties, particularly securities market professionals and those who may own or trade in our stock.
The goal of these disclosure guidelines is to develop and maintain realistic investor expectations by making all required disclosures on a broadly disseminated basis as required by the rules and regulations of the U.S. Securities and Exchange Commission, the New York Stock Exchange -listed company disclosure requirements, and any laws that the Company may be subject to.
Foreign Corrupt Practices Act and Anti-Bribery Policy
The Foreign Corrupt Practices Act of 1977 (FCPA) is a United States federal law known primarily for two of its main provisions, one that concerns bribery of foreign officials, and another that addresses accounting transparency requirements under the Securities Exchange Act of 1934. The FCPA makes it unlawful to bribe foreign government officials to obtain or retain business. It is the Company’s policy to strictly adhere to the requirements of the FCPA and the anti-bribery laws of all jurisdictions in which the Company conducts its business.
The Company is committed to the highest possible standards of openness, probity, and accountability in all its affairs through the creation of the appropriate “tone at the top”. It is determined to maintain a culture of honesty and opposition to fraud and corruption, reinforced through the establishment and maintenance of an effective system of internal controls. In line with that commitment, the Company’s FCPA Policy outlines the principles it is committed to in relation to preventing and reporting fraud and corruption. We had zero legal and regulatory fines and settlements associated with bribery and corruption in 2020, or any year before that.
Social Media Policy
Social media is an essential tool for communicating with our family and friends. Social media platforms and many others are fantastic for keeping in touch, sharing information and general entertainment. The Company has come up with a few guidelines and a social media check-list to provide helpful and practical advice for its seafarers and office personnel when operating on the internet as an identifiable employee of the Company. Social media is an innovation available to seafarers. It can close the distance between ship and shore and bring their family into their cabin and if used carefully and sensibly, it can enhance the quality of life on board.
European Union data protection law in the form of the General Data Protection Regulation, (GDPR)
We are dedicated to protecting the confidentiality and privacy of information entrusted to us and comply with Personal Data Privacy legislation as currently in force. To that end we have adopted a Data Protection Policy for Privacy and Protections of Personal Data describing and informing our shore employees and seafarers, candidates and third parties what information we may collect directly or by cooperation with any third party, how to protect, how we collect, store, use, share and protect the information/personal data that we obtain.
Furthermore, we inform all interested parties about their rights over their personal data such as the right to be informed and right to gain access to the data being processed, the right to erasure or right to be forgotten, right to portability, right not be subject to a decision based solely on automated processing, right to object to the processing of personal data and to rectify the data processed if relevant. As part of this fundamental obligation, we are committed to the appropriate protection and use of personal information/data. Generally, our intent is to collect only the personal information that is provided voluntarily by Seafarers for employment purposes. We recognize and respect the privacy of our applicants, current employees and former employees.
We recognize our responsibility to safeguard the environment and give great prominence to improving our environmental performance. To this end, we have implemented an Environmental Management System whose pillars are shown below:
Ensuring that all vessels under our management comply with all environmental regulations.
Constantly evaluating our environmental performance for continuous improvement and prevention of any kind of pollution by setting and reviewing environmental targets.
Reducing our carbon footprint by investing in new building vessels, energy saving devices, new sensor technologies and emission abatement technologies.
Reducing to the extent possible garbage produced from our ships and promote recycling practices to our offices
Raising the environmental consciousness of our per sonnel and investing in their training in environmental programs
We regularly review our environmental policy, ensuring that it is up to date with our operation’s scale and potential environmental impacts. Our environmental policy is made public on-board all our vessels in an effort to increase the environmental awareness of our crew.
Safety and Health Policy
It is our policy to promote safety at sea, health and prevention of human injury, illness or loss of life and avoidance of damage to the environment, particularly the marine environment and property. The Company’s objectives regarding Safety Management are: To provide for Safe Practices in ship Operation and a safe working environment.
To prevent damage to the ship, her cargo and the environment
To assess all identified risks to its ships, personnel and the environment and establish appropriate safeguards
To prevent loss of human life and personal injury or illness
To continuously improve Safety Management skills of personnel ashore and aboard ships, including preparing for emergencies related both to Safety & Environmental Protection.
We are committed to the elimination of harassment and bullying and to ensuring a working environment in which everyone is respected. In order to tackle harassment and bullying, the Company actively encourages its seafarers to bring incidents, including those that affect others, to its attention without delay, adopting reporting procedures conducted in absolute confidentiality, in which all seafarers should have confidence.
No Company employee shall harass or bully another Company employee. All seafarers have the right to work without suffering harassment and bullying. For the dignity and well-being of all seafarers, the Company is committed to the elimination of harassment and bullying in vessels and to ensuring a working environment in which everyone is respected. Harassment and bullying are examples of conduct that is unwanted and can have detrimental impacts, including stress, lack of motivation, reduced work performance, absence from duties and resignations.
In order to tackle harassment and bullying, the Company actively encourages its seafarers to bring incidents, including those that affect others, to its attention without delay, adopting reporting procedures conducted in absolute confidentiality, in which all seafarers should have confidence.
It is the Company’s policy that no seafarer, in whatever capacity or rank, shall undertake duties, or operate any equipment, or navigate a vessel while under the influence of drugs or alcohol or while there is any risk of impairment.