CSR Policy

Fred. Olsen Cruise Lines (‘FOCL’) takes its responsibility to be a good ‘corporate citizen' seriously, and does all that it can to be a considerate employer, generous benefactor and environmentally-conscious cruise operator.

Working Environment

Fred. Olsen Cruise Lines (‘FOCL’) places a high importance upon the Health, Safety and Environmental (‘HSE’) standards for all staff in every area of the Company, both ashore and on board its four vessels – Balmoral, Braemar, Boudicca and Black Watch.

Across the FOCL fleet, the safety and well-being of all guests and crew remains the Company’s utmost priority at all times.

The Company believes that the key to improvement in its safety culture is empowerment of the seafarers on board the vessel to identify ‘near miss’ events and to be able to implement preventative actions, as opposed to having to act in response to an incident, accident or hazardous situation.

A significant amount of time and resource is committed to ensuring that all FOCL staff are aware of their HSE responsibilities. By being open in its reporting and recording process, the Company strives for a continuous reduction in accidents and incidents, constantly working towards a ‘zero event’ workplace.

The Total Recordable Incident (‘TRI’) rate includes all accidents and incidents that have been reported from the vessels and offices, in three main categories: Safety, Security and Medical. These figures are disseminated to the relevant departments to aid the improvement of safety standards and to assist in the deployment of sufficient and appropriate resource to achieve reduced levels of TRIs.

TRIs (>10 hours) recorded were 23 (2012: 25) equating to 1.7273 (2012: 1.8725) lost days / per million working hours, providing a reduction of 7.75%.

FOCL attributes this improvement in TRIs to transparent reporting and active encouragement of ‘near miss’ reporting and ‘best practice’ recording, coupled with an open system, where all staff are encouraged to ‘speak out and be heard'.

In line with industry standards, Lost Time Incidents (‘LTI’) are recorded and based on incidents that accrue greater than one day of lost time. The calculation method employed assumes a ten-hour working day for each staff member, providing a more accurate reflection of working hours on board the vessels.

The total lost hours recorded for all incidents in 2013 was 982 hours (2012: 1,301 hours), equating to 98.2 days (2012: 130.1 days), assuming a ten-hour working day, out of a total of 554,800 (2012: 556,320) working days. This represents a 0.0177% loss (2012: 0.0234%) of the total days worked in the year.

Separate statistical information is drawn from accidents involving crew only. These fall into three levels of severity: Major, Serious or Minor, as defined in the Company Safety and Quality Manual (‘SQM’) and based upon the Bahamas Maritime Authority Flag and Marine Accident Investigation Branch definitions. The year-on-year accident analysis is provided below.

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The Company has developed a reporting system to capture data of any incident, accident or ‘near miss’. This has enabled the Company to identify accident ‘black spots’ more accurately and to be able to implement effective solutions and safety barriers to help to prevent any recurrences.

The Company has set high ‘Key Performance Indicator’ (‘KPI’) targets in relation to reporting, where it expects that 25% of all received reports will have identified ‘near miss’ events, where preventative action is required.

To encourage ‘buy-in’ from all staff and encourage proactive reporting of incidents, accidents or ‘near misses’, an incentive programme is being developed and planned to be implemented in 2014.

Internal audits have been conducted on all four vessels and across all offices, documenting the implementation of new procedures and identifying areas where non-compliance has occurred and has been rectified. All items identified within the internal and external audit process are recorded, tracked and presented to Senior Management. These are reviewed on a monthly basis and followed up to a satisfactory conclusion, with each being allocated a designated ‘responsible person’, or ‘owner’.

FOCL’s compliance to the Maritime Labour Convention (‘MLC’) 2006 statutory adoption in August 2013 consolidates the Company’s commitment to the improving environment for its workforce on board the vessels, with particular regard to the safety and welfare facilities available.

The recorded sick leave statistics show:

  • 2012 – 843 days out of 556,320 total work days (0.151%)
  • 2013 – 719 days out of 554,800 total work days (0.130%) 
These figures include extended sick leave in cases where crew members have been repatriated and maintained on sick leave, up to the 130-day provision provided by the Collective Bargaining Agreement (‘CBA’).

Human Rights, Equality & Diversity

At FOCL, we take pride in bringing together many different cultures and backgrounds as one team within our diverse company, working ashore in our offices and delivering world-class customer service at sea across our fleet.

There are currently 29 different nationalities working on board FOCL’s four vessels, presenting a cultural diversity, of which the Company is extremely proud and keen to encourage, to ensure a well-balanced and healthy workplace for all. The workforce is made up of 65% male and 35% female staff, with both genders represented at all levels of management.

The Company’s culture emphasises the respect for human rights and ethical behaviour. The published Ethics Policy and Article 1 of the CBA outlines and defines the Company’s commitment to human rights, equality and diversity.

Furthermore, all persons working for the Company, including subsidiaries, shall respect human rights, and under no circumstances take any actions that impact negatively upon others’ human rights.

FOCL ensures that equality is practised in recruitment, as follows:

  • Its recruitment database, Eploy, does not give Managers any indication of the gender/age/name of the individual who they are shortlisting until after they have come up with a shortlist.
  • In line with the Equality Act (2010), FOCL does not issue health questionnaires until after a candidate has been made a firm offer of employment.
  • If a candidate requires extra support to attend his/her interview because of a disability, FOCL will make reasonable adjustments to facilitate this. 
  • If a candidate with a disability, as recognised under the Equality Act (2010), is  appointed, FOCL will seek to make any reasonable adjustments to the job profile to enable him/her to carry out the role to the very best of his/her ability.
  • FOCL’s recruitment database, Eploy, also has an anonymous equal opportunities reporting facility, where candidates can give personal information about themselves, which is not seen by anyone involved in the recruitment process. The Human Resources Department are able to report on this, if requested.

Discrimination

As outlined in Article 1 of the CBA issued to all sea staff, and ‘Fred. Olsen Employee Handbook’ issued to all office-based staff, FOCL does not accept any form of discrimination or harassment, such as that based upon gender, creed, religion, race, national origin or sexual orientation.

Environment

FOCL operates within a strict environmental framework, and is committed to ensuring that it meets, and where possible, exceeds, regulatory requirements on marine and air pollution.

FOCL monitors – and regularly reviews – its management systems on board its fleet of four ships, to ensure compliance with international requirements.

The environmental policies contained within the Company’s SQM have been completely reviewed and replaced in 2013 to meet current and projected environmental requirements.

These policies cover the following core areas:

  • Handling and management of Hazardous Chemicals
  • Regulated and Hazardous Waste
  • Recyclable Materials
  • Management of waste streams

All FOCL vessels have implemented ‘Ship Energy Efficiency Management Plans’ (‘SEEMP’), in line with the Marine Environment Protection Committee (‘MEPC’) 63/23 Annex 9.

Fuel consumption across the FOCL fleet is based on the fuel consumed per Available Lower Berth Days (‘ALBD’). Fuel consumed was 48.25/kg per ALBD in 2013 (2012: 48.02/kg per ALBD).

Workers’ Rights & Social Aspects

The CBA with the Norwegian Seafarers Union cements FOCL’s commitment to supporting workers’ rights and social aspects. A copy of the CBA is issued to each seafarer upon appointment with the Company.

Office-based staff are issued with the ‘Fred. Olsen Employee Handbook’ upon joining FOCL, which outlines all the information relating to their employment with FOCL.

Anti-corruption Schemes

FOCL’s ‘Code of Conduct’ emphasises a strict adherence towards anti-corruption or bribery relating to any parts of its business or FOCL staff, clearly underlining that any form of corruption or bribery is strictly prohibited.

There shall be full transparency in all transactions conducted by FOCL and its representatives, and these shall be backed up by invoices.

FOCL operates within a strict ‘Code of Conduct’, as outlined herewith:

 

Fred. Olsen Cruise Lines’ ‘Code of Conduct’

1. Purpose and Scope

The purpose of this procedure is to ensure common commitments on rules, regulations and behaviour within FOCL. This includes a common standard for ethics and anti-corruption.

This procedure shall apply to all employees within FOCL and all hired personnel, consultants and others who act on behalf of FOCL.

Compliance with this procedure will ensure that all behaviour conducted on behalf of the Company is undertaken with the utmost honesty, high integrity and respect; this, in turn, creates an environment of trust, which is vital for good co-operation within the business. Trust is earned through long-term achievement, behaviour and accountability.

Employees who come forward with concerns play an important role in maintaining an ethical workplace and high-performance business.

Even though certain elements of ethics and behaviour are discussed within this procedure, it is not an exhaustive definition and does not remove the need for each person to exercise their own sound judgement when facing challenging ethical situations.

2. Ethics and Behaviour

Behaviour

All types of behaviour and actions must be within the law of the country of operation and within the parameters of that which is described in this procedure.

All persons working for FOCL must be open and honest with superiors in respect of challenging ethical situations. They shall respect human rights and under no circumstances take any actions that impact negatively upon other people’s human rights.

FOCL does not accept any form of discrimination or harassment.

No information obtained illegally or unintentionally from business partners shall be distributed or used by FOCL. The distribution or use of such information might be in breach of competition, civil or criminal laws.

Corruption

Certain behaviours are always unacceptable, such as offering gifts to public officials, gifts in relation to a bidding process, money gifts, improper entertainment and all forms of corruption and bribery.

All forms of corruption or bribery are strictly prohibited. These include any type of undue payment made to influence someone conducting their duties, and/or where someone is able to gain undue personal benefits, such an financial incentives or ‘kickbacks’, from suppliers. Such improper behaviour can take the form of cash payments, gifts, travel, accommodation or services.

FOCL encourages and requires transparency in all transactions undertaken when conducting business on behalf of FOCL. All business transactions shall be backed up by invoices between the parties involved to secure full transparency with respect to the person authorising the transaction and the receiver of the payment. No agreements shall be made with external agents in a way that can be interpreted as corruption or facilitating corruption.

Use of Intermediaries

Before intermediate companies, such as agents and consultants, are contracted, it must be ensured that the intermediate companies are involved in bona fide business activities and are a formally registered company. Agreements with intermediary companies shall be based on the internal procurement procedures established within FOCL, including written contracts.

It is emphasised that all contracts with intermediaries shall include a contract clause stating that any corrupt activities or unethical behaviour are prohibited whilst representing FOCL.

Conflict of Interest

All persons working for FOCL must act in the best interests of FOCL in all business dealings and not give any business partners, being companies or individuals, improper advantages, including relationships that could give rise to an actual, or perceived, conflict of interest.

No one working for the Company shall have a part-time job, board memberships, consultancy tasks or other financial interests, which may in any circumstances impact negatively upon the business of FOCL.

Employees of FOCL, or any of its closely related companies, must not receive loans from any of the Company’s business partners. This excludes regular loans to employees on market rates from banks or financial institutions.

Confidentiality

All persons working for FOCL shall be under the duty of confidentiality and shall prevent unauthorised persons gaining access to information not reported publicly or classified as confidential.

The duty of confidentiality continues to apply after termination of the contractual relationship between the individual and FOCL. The only exception is when disclosure of internal or confidential information is required by law.

Inside Information

All persons working for FOCL must not use or distribute inside information regarding FOCL, or any companies with which FOCL has business relations, e.g. clients, customers, suppliers, service companies or others. Any transactions of publicly-listed shares or other financial instruments based on inside information are prohibited by law.

Inside information is defined by law and comprises information not publicly known, which can affect the share price. For FOCL, examples of inside information can be financial numbers prior to public reporting, investment initiatives etc.

3. Intellectual Property

All development of new ideas, technology and/or products undertaken by persons working for FOCL is part of developing FOCL’s intellectual properties. These intellectual properties are the ownership of FOCL. The ownership of FOCL’s intellectual properties must be respected, as well as the property rights of others.

4. Gifts and Representation

Suppliers, customers or contacts may, from time to time, give FOCL management or staff gifts. Any item(s) under the value of £20.00 should be shared by the team for which it is intended.

Any item over £20.00 in value must be passed to the Managing Director’s Secretary in the instance of office gifts, and to your immediate Line Manager for ship-based staff. The details of these gifts and the origin will be registered and periodically the items will be made available as donations for a charity raffle (or similar). Intangible gifts, e.g. services, must always be politely refused.

Where appropriate, staff should advise their contacts politely that the Company has a strict policy on gifts and that individuals/departments can only retain small tokens of a low value. Failure to observe these rules may be considered gross misconduct.

Participation in various events may be acceptable if there is a clear business reason, but any travel, accommodation and other expenses for the individual participating in events must be paid by FOCL. This also goes in the reverse direction when FOCL invites external individuals to events.

All internal entertaining and representation of FOCL must be approved by your superior before it takes place. For both external and internal entertainment, the alcohol consumption shall be limited to normal consumption included within a meal. Excessive use of alcohol is not acceptable.

5. Compliance and Internal Control

The focus from the Senior Management Team is to encourage and foster a culture of ‘zero tolerance’ to infringements of the ‘Code of Conduct’ throughout the Company, and any such breach is taken extremely seriously. 

The Company ensures that all employees understand the strict regulations under which they are permitted to conduct business on behalf of the Company, and upon their appointment are given a copy of the CBA, for ship-based staff, and the ‘Fred. Olsen Employee handbook’, for office staff.

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