Ultranav insist on honesty, integrity and fairness in all aspects of our business and we expect the same in our relationships with all those with whom we do business.
Ultranav employees must avoid conflicts of interest between their private activities and their part in the conduct of company business. Employees must also declare to their superior any situation that may endanger the objectivity to act in line with the interests of Ultranav. We comply with all applicable laws and regulations of the countries in which we operate.
We are especially committed to a strict compliance worldwide with relevant laws prohibiting bribery, defined as “any conduct to influence the decision-making of public officials, government authorities or to an employee, agent, partner or other auxiliary person of a third party in the private sector - be it directly or through agents or other intermediaries - with the purpose of securing an undue action or advantage”. No Ultranav employee at any level may offer, promise, authorize or give anything of value to any public official in any country, or to any third party in the private sector, in order to gain any improper business advantage of any kind. Nor may any employee solicit or accept any form of bribe from any person.
We are furthermore committed to the elimination of facilitation payments, defined as “small value payments or gifts (e.g. cigarettes, soft drinks, cash or other items of value) to low-level public officials in order for him or her to perform a task that the payer is already entitled to receive.”
However, we recognize a very limited exception in certain parts of the world where facilitation payments are lawful, where for extraordinary circumstances a payment appears unavoidable in order to obtain something to which we already have a legal entitlement.
In that case, when a public official abuses his/her public position by requesting something of value that is not clearly grounded in law, and the request or solicitation is made in such terms that it causes Ultranav employees to fear that a retaliatory action or an evil will be caused by not complying, employees are allowed to comply with such solicitation or request, provided such response is adequately documented, approved by a superior and reported to the Compliance Department. As a member of Maritime Anti-Corruption Network (MACN), in Ultranav we fight for a maritime industry free of corruption that enables fair trade to the benefit of society at large, in that respect we are committed to resist, record and report any request of a facilitation payment.
Ultranav employees shall not accept or offer gifts, hospitality, promotional benefits or other expenditure that may undermine the recipient’s integrity during execution of business or influence negotiations in an unethical, inappropriate or illegal manner. Offering or accepting reasonable hospitality, promotional benefits or similar business activities or expenditures within recognized practice or industry norms are permitted, but, as much in the case of facilitation payments, should be reported to and be approved by a superior.
Av. El Bosque Norte 500 20th Floor, 7550092
Las Condes, Santiago, Chile.
Phone: +56 2 2630 1100