Code of Business Ethics and Conduct

Our Policies

Code of Business Ethics and Conduct

Black Pearl Maritime Security Management Limited conducts its business with honesty, integrity and accountability. This Code of Business Ethics and Conduct establishes the standards of behaviour expected of every director, employee and contracted operative, whether ashore in our offices or deployed aboard client vessels in High Risk Areas. As a Private Maritime Security Company, our reputation and our licence to operate depend on the trust placed in us by clients, flag States and the maritime community, and that trust is earned through consistent ethical conduct.

Integrity and Lawful Conduct

We comply with all applicable laws and regulations in every jurisdiction in which we operate, including UK law, the laws of relevant flag and coastal States, and international instruments such as the ISPS Code. We operate in line with the International Code of Conduct for Private Security Service Providers (ICoC) and the principles of the Montreux Document. Personnel must never knowingly act outside the law, and any instruction to do so must be refused and reported.

Anti-Bribery and Corruption

We maintain a zero-tolerance stance towards bribery and corruption in compliance with the UK Bribery Act 2010. Personnel must not offer, give, solicit or accept any bribe, facilitation payment or improper advantage, whether directly or through third parties such as agents or port officials. We recognise that operations in certain ports carry a heightened risk of demands for facilitation payments, and personnel are trained to resist and report such demands.

• Gifts and hospitality must be modest, transparent and never given or received to influence a business decision.
• Conflicts of interest must be declared promptly and managed openly.
• We keep accurate, complete and honest records of all transactions and operations.
• We comply with applicable sanctions, export-control and anti-money-laundering requirements.

Professional Conduct

Our personnel are expected to behave professionally and respectfully at all times, to follow the lawful instructions of the Master while embarked, and to maintain the standards of discipline appropriate to the carriage and use of firearms. We treat clients, crews, colleagues and members of the public with courtesy and without discrimination, and we safeguard confidential and commercially sensitive information entrusted to us.

Accountability and Reporting

Every individual is responsible for upholding this Code and for reporting any suspected breach through their line management or, where appropriate, through our confidential Whistleblowing Policy. Reports are taken seriously, investigated fairly and dealt with without retaliation against the person raising the concern. Breaches of this Code may result in disciplinary action up to and including dismissal, and may be referred to the relevant authorities.

This Code of Business Ethics and Conduct is approved by the Board, issued to all personnel on engagement, and reviewed at least annually.