We,
Liberty Blue Shipmanagement GmbH & Co. KG or any company represented by us
have issued the following Company Policy on Sanctions Compliance. The policy is designed to ensure that sanctions issued by sanctions authorities are not violated.
The objectives of the Company are:
- To comply with sanctions issued by sanctions authorities and mitigate against the risk of a violation;
- To protect company personnel, clients, owned and managed vessels and legitimate cargo interests;
These objectives will be achieved by:
- Assigning adequate expertise and resources to the Company’s compliance section;
- Identifying the sanctions regimes that are applicable to the Company, considering all mandatory regulations, guidelines and standards
- Assessing all identified risks to the ships, shipowners and personnel by frequently screening counterparts, supply chains, cargo interests as well as geographic locations;
- Reporting sanctions violation to the competent authorities;
- Monitoring effective sanctions compliance by auditing to identify deficiencies and be able to rectify any sanctions compliance gaps;
- Implementing an effective training program for employees and promoting their participation in the Sanctions Compliance Program;
This policy is implemented and maintained at all levels of the organization, ashore and onboard, by means of a Company Sanctions Program, training, and auditing.
Under this policy, Sanctioned Activities are any activities, services, carriage, trade or voyage subject to sanctions imposed by a Sanctioning Authority including, but not limited to The United Nations, European Union, United Kingdom, United States of America or any other applicable competent authority or government. Sanctioned Parties are persons, entities, bodies, or vessels designated by a Sanctioning Authority.
Legal transactions with Liberty Blue Shipmanagement GmbH & Co. KG or a company represented by Liberty Blue Shipmanagement GmbH & Co. KG shall only become legally binding if the contracting party confirms that they have implemented sanctions compliance policies and procedures with respect to sanctions imposed by sanctioning authorities and guarantees that they will, throughout the contractual cooperation with Liberty Blue Shipmanagement GmbH & Co. KG or any company represented by Liberty Blue Shipmanagement GmbH & Co. KG are not sanctioned. All contractual partners who are directly or indirectly involved in any contractual relationship with Liberty Blue Shipmanagement GmbH & Co. KG or a company represented by Liberty Blue Shipmanagement GmbH & Co. KG are not Sanctioned Parties.
Thank you for your cooperation in difficult times.