Whistleblowing Policy

Our Policies

Whistleblowing Policy

Black Pearl Maritime Security Management Limited is committed to the highest standards of openness, integrity and accountability. This Whistleblowing Policy encourages and enables every member of our personnel — employees, contracted operatives and those working on our behalf — to raise serious concerns about wrongdoing safely, in confidence and without fear of reprisal. Given the nature of our work as a Private Maritime Security Company operating armed teams in High Risk Areas, the willingness of personnel to speak up is a vital safeguard for the safety of crews, the lawful conduct of operations and the reputation of the company.

What Should Be Reported

This policy covers concerns about malpractice or wrongdoing that go beyond an individual's own employment grievance. Examples relevant to our operations include the unlawful or unauthorised use of force, the unsafe handling, storage or accounting of firearms and ammunition, breaches of the Rules for the Use of Force, falsification of incident reports or transit records, bribery or facilitation payments, human rights abuses, and any danger to the health and safety of personnel or seafarers.

• A criminal offence has been, is being or is likely to be committed.
• A person has failed, is failing or is likely to fail to comply with a legal or regulatory obligation.
• The health or safety of any individual has been, is being or is likely to be endangered.
• An attempt has been or is being made to conceal any of the above.

How to Raise a Concern

Concerns should normally be raised first with line management or a Team Leader. Where that is not appropriate — for example because the concern relates to a manager, or has not been addressed — concerns may be raised directly with senior management in writing or by telephone, in confidence. A concern raised aboard a vessel may be reported on return to port or, where the matter is urgent and serious, by the most secure means available at the time.

Confidentiality and Protection

We will treat all disclosures in confidence and will make every effort to protect the identity of anyone who raises a concern in good faith. This policy reflects the protections afforded to workers under the UK Public Interest Disclosure Act 1998. No person who makes a disclosure in good faith will suffer dismissal, disciplinary action, detriment or any other form of retaliation, even if the concern later proves to be mistaken. Deliberately raising false or malicious allegations, however, is itself a disciplinary matter. Concerns may be raised anonymously, although this may limit our ability to investigate.

How We Respond

All disclosures are acknowledged, assessed and, where warranted, investigated promptly and impartially by a person independent of the matter. The whistleblower will be kept informed of the handling of their concern so far as confidentiality and legal constraints allow. Where wrongdoing is found, we will take appropriate corrective, disciplinary or legal action, and will report matters to flag States, certification bodies or law-enforcement authorities where required.

This Whistleblowing Policy is communicated to all personnel and reviewed at least annually to ensure it remains effective and accessible.