Business Partner Code of Conduct and Ethics
Further develop and implement vendor assurance procedures ensuring compliance with Carnival Corporation & plc’s Business Partner Code of Conduct and Ethics.
- We revised our Business Partner Code of Business Conduct and Ethics to include our commitment to comply with the United Kingdom’s Modern Slavery Act of 2015. This Act requires companies to disclose information regarding their efforts to combat slavery and human trafficking in their supply chain and within their business. Our employees are subject to and are expected to follow our Code of Business Conduct and Ethics. We also expect our business partners to adopt and incorporate these commitments into their own organizations.
- Our purchasing and sourcing departments began utilizing a Supplier Evaluation Questionnaire (SEQ) to assist our evaluation of business partner ethics, compliance, sustainability and other risks.
FY2016 Risk Management Performance
Quarterly, the Boards of Directors Health, Environment, Safety and Security (HESS) Committee is briefed by management on the status, progress of and plans for HESS and sustainability-related matters, as well as on HESS audit results. HESS audit results are used to determine compliance, improve effectiveness and efficiency, analyze trends, support new-build and retrofit decisions, and promote best management practices.
Fleet Captain and Fleet Engineer Program
We continue our Fleet Captain and Fleet Chief Engineer mentoring program, which provides regular training and mentoring for our shipboard staff, provided by our top shipboard officer performers who rotate through the program.
Fleet Operations Center
We opened the second of three planned state of the art Fleet Operations Centers (FOC) in Seattle, U.S. This FOC is equipped with the most advanced ship to shore communications technologies available. The first FOC, was opened in Hamburg, Germany in 2015. The third FOC will be located in Miami, U.S. and is expected to open by the end of 2017. These centers are designed to assist our captains, chief engineers, and deck and engineering officers with digital support, control and planning of all nautical and technical operations. The centers are staffed 24 hours a day, allowing for improved communications between the ship and shore, and providing immediate support to our ships for route planning, maritime safety and risk management.
Our ships are regulated by various international, national, state and local laws, regulations and treaties enforced in the jurisdictions in which they operate. Compliance with these laws and regulations is verified through inspections, surveys and audits:
- Independent third-party regulatory compliance is performed periodically through inspections, surveys and audits conducted by representatives from each ship’s country of registry, Port State and Classification Societies.
- Internal regulatory compliance audits are conducted annually on each brand’s head office and 100% of our fleet by Carnival Corporation & plc’s Risk Advisory and Assurance Services department. All audit observations, findings and non-conformities are reported to the brands and to relevant corporate groups for review and resolution. Internal regulatory compliance audits are also performed on a rotational basis across our ports, hotels and land transport assets.
- Specific internal focus reviews designed to mitigate identified risks are performed based on a combination of incidents root cause analysis, prior audit results and discussion with management.
Tracking and Data-Analysis Program
We implemented a state of the art tracking and data-analysis platform that enables real-time information sharing between our ships and shoreside teams trained to support fleet operations. The proprietary system significantly improves communication from ship to shore, providing new capabilities for enhancing the safe passage of ships at sea while improving operational efficiencies and supporting overall environmental initiatives. The platform manages risks by providing the company visual representations of ships routing, real-time navigational notification, integrated weather data and traffic information.
Arison Maritime Center
We opened the Arison Maritime Center, the new home of the Center for Simulator Maritime Training Academy, also known as the CSMART Academy. CSMART’s mission is to be a leader in developing and delivering the best professional training in the maritime industry. This world-class facility equipped with the latest technology and equipment provides rigorous safety training for bridge and engineering officers responsible for the navigation and operation of the world’s largest fleet of cruise ships. CSMART participants receive a maritime training experience that fosters critical thinking, problem solving, ethical decision making and skill development.
Like companies in any industry, we face a number of challenges and opportunities related to our performance, including the regulatory environment, global political and socioeconomic landscape and the advancement of science and technology. We take an active approach to identifying risks and opportunities and use a variety of strategies to manage and take advantage of them. We work to identify the best approaches to managing these issues, while simultaneously focusing on our sustainability performance and addressing the interests of our stakeholders.
Risk management is embedded throughout our organization. Our strategy to manage our risks and seek out opportunities consists of a system of internal controls comprised of our management systems, organizational structures, audit processes, standard, and our Code of Business Conduct & Ethics. Risks are managed at every level of the organization and discussed openly with leadership in order to minimize the impact of foreseen and unforeseen events. We also have dedicated departments with responsibility for advising and assisting upper management and the Boards of Directors on corporate risk management issues and for providing assurance of compliance with our health, environment, safety, security and sustainability policies and procedures.
Our key impacts, risks and opportunities are addressed throughout this report. The following is a partial list of our impacts, risks and opportunities:
- Protecting the health and safety of our guests and crew.
- Ensuring the security of our guests, crew and ships.
- Building and maintaining trust and integrity in our supply chain.
- Preserving the natural environment.
- Remaining transparent in our sustainability performance accountability and reporting.
- Recruiting, training and retaining qualified employees.
- Operating in a changing geopolitical climate.
- Improving our performance through technological solutions and initiatives.
- Conserving fuel and minimizing engine emissions.
- Climate change – reducing greenhouse gas (GHG) emissions.
- Operating in an evolving regulatory landscape.
- Improving natural resource management.
- Strengthening stakeholder engagement.
- Partnering with communities/ports-of-call.
Our health, environment, safety, security and sustainability principles focus on prevention, implementation, detection, feedback and improvement. We plan and establish objectives and processes necessary to achieve the required and expected results. We then implement the established plan and processes. Studying the actual results of implementation and comparing against the expected results, we then take action on significant differences between actual and planned results. Finally we analyze these differences to determine their root causes and then determine where to apply changes that will improve the process or results.
Risks and opportunities are identified by management using a holistic risk framework and a risk management capability model aligned with the organization’s strategy and Board/management priorities. This framework is part of the Enterprise Risk Management (ERM) program, which is facilitated by the Risk Advisory and Assurance Services (RAAS) department.
Risk prioritization occurs by actively engaging management and the Boards of Directors to determine which risks within the ERM risk framework are appropriate for further evaluation. Therefore, the ERM program acts as a catalyst for supporting the business to recognize and manage risks that could affect the ability to achieve objectives, as well as to identify the capabilities needed to effectively manage those risks, which in turn increase the chance of success. It is through this evaluation process that opportunities to manage risks are identified.
Pursuant to this program, the RAAS department works closely with management to perform annual assessments, identify risks and evaluate controls to ensure compliance with company policies and procedures, as well as laws and regulations. Management reviews the assessments and updates with the Audit Committee.
Enhancing Safety and Improving Operational Excellence
Safety is paramount to our business and our Fleet Operation Centers (FOC) are an essential component of our safety strategy. A first in the cruise and commercial maritime industry, our FOCs are designed to assist our captains, chief engineers, and deck and engineering officers with digital support, control and planning of all nautical and technical operations. We currently have two FOCs in operation. The first FOC was opened in Hamburg, Germany in 2015 and the second was opened in Seattle, U.S. in 2016. Both centers provide real-time support for our fleet of 102 ships. A third FOC will be added to the global network by the end of 2017 and will be located in Miami, U.S.
The centers are staffed 24 hours a day, allowing for improved communications between the ship and shore, and providing immediate support to our ships. The FOCs are also equipped with a state of the art tracking and data-analysis platform that enables real-time information sharing between our ships and shoreside teams trained to support fleet operations. The system provides new capabilities for enhancing the safe passage of ships at sea while improving operational efficiencies and supporting overall environmental initiatives. The system also manages risks by providing the company with visual representations of ships routing, real-time navigational notifications, integrated weather data and traffic information.
The advanced system captures thousands of data points and provides real-time analytics for distinct parameters for navigational safety from each ship, and focuses on the following strategic areas to optimize safety, efficiency and overall fleet performance:
- Nautical Operations & Safety – including the capability to see real-time radar visuals, stability conditions, automation, the Safety Management and Command System, and webcams from each ship, along with GPS location, routing, ship conditions and weather data.
- Procedural Optimization & Efficiency – including speeds, navigational data and engine conditions.
- Environmental Performance – including fuel and energy usage, emissions levels and water and waste management.
Our teams have done a remarkable job in developing the FOCs and the data analysis and tracking platform. Together they enable us to further enhance safety and improve operational excellence using real-time data in ways that have never been done in the cruising and commercial maritime industries.