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 comply with regulatory requirements and follow best management practices addressing human rights, ethics, and environmental protection throughout our operations and expect our business partners to adopt and incorporate these into their own organization.
Modern Slavery Act
Our Code of Business Conduct & Ethics explicitly condemns all forms of child exploitation and forced labor and states our intent to comply with and support laws and regulations relevant to slavery and human trafficking. For more information please see the Statement Pursuant to Modern Slavery Act 2015 in the Appendix.
- We continue to work on expanding our sourcing of cage free eggs. Our goal is to be 100% cage free by 2025.
- We committed to aligning to welfare standards for broiler chicken by 2024.
- We partnered with the Association of British Travel Agents (ABTA) to help us ensure we are responsibly managing excursions involving animals. We are leveraging their global welfare guidelines for animals in tourism.
- We identified a third party auditor to audit attractions involving animals.
- Starting in 2018, we will commence audits on all dolphin in captivity tour encounters used by our brands.
FY2017 Risk Management Performance
FLEET CAPTAIN and fleet engineer program
We continue our Fleet Captain and Fleet Chief Engineer 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
In 2017, we began construction on the third of three planned state of the art Fleet Operations Centers (FOC) in Miami, U.S. The Miami FOC is scheduled to commence operations in 2018. The first FOC was opened in Hamburg, Germany in 2015 and the second was opened in Seattle, U.S. in 2016. The FOCs are equipped with the most advanced ship to shore communications technologies available. These centers are designed to assist our captains, chief engineers, and deck and engineering officers with all aspects of operations, including digital support, planning, routing and any other nautical and/or technical operational need. The centers are staffed 24 hours a day, allowing for continuous communications between the ship and shore, and providing real-time support to our ships in order to minimize risk and improve operational efficiency.
Audit and Investigations
Internal regulatory compliance audits and/or Health, Environment, Safety and Security (HESS) investigations are conducted annually of each brand’s head office, 100% of our fleet, our ports, hotels and land transport assets. All incident investigation recommendations, audit observations, findings and non-conformities are reported to the brands and to relevant corporate groups for review and resolution. Additionally, internal focus reviews are performed based on identified root causes from incident investigations, audits, and management’s risk assessments.
- Quarterly, the Board of Directors HESS Committees are briefed on the status and progress of 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.
- 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.
- In 2013 an environmental crime was committed on one of our ships by individuals who violated our company values and policies. We took responsibility, signed a plea agreement, and are now on probation. Our probation is in the form of a five year Environmental Compliance Plan (ECP) that began on April 19, 2017. The ECP requires third party audits and oversight visits by a Court Appointed Monitor.
For further details please visit: www.princess.com/news/notices_and_advisories/cbresponse
Data aggregation and Analysis Platform – Neptune
In 2017, we continued the implementation of a state-of-the-art data aggregation and analysis platform called Neptune that enables real-time information transfer and sharing between our ships and shoreside teams supporting 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 provides visual representations of ships routing, real-time navigational notifications, integrated weather data and traffic information and major equipment performance data, all which support operational efficiencies and minimize risk.
In 2017, the system expanded its aggregation and analysis in three areas:
- Engine performance: Engine data is monitored in real-time and shared with Wärtsilä, the engine manufacturer, to allow performance deviations to be detected and measures initiated to ensure that the engines are maintained at their optimal levels, thus reducing fuel consumption and providing significant emission reduction benefits.
- Exhaust Gas Cleaning Systems (EGCS): Operating parameters from the EGCS are checked every 3 minutes and sent ashore to teams who monitor to ensure that the systems are operating correctly and in the appropriate areas.
- Energy efficiency: Data is being collected across a broad range of energy consumption measurements. This allows us to analyze and benchmark key performance indicators for many different aspects of energy efficiency to direct and drive forward our program for efficiency improvements and help us reach our greenhouse gas reduction targets.
Arison Maritime Center
We continue training our officers in our world-class facility equipped with the latest technology and equipment. The Center provides rigorous safety training for bridge and engineering officers responsible for the navigation and operation of the world’s largest fleet of cruise ships. Participants receive a maritime training experience that fosters critical thinking, problem solving, ethical decision making and skill development. For more information please visit www.csmartalmere.com
ENVIRONMENTAL OFFICER TRAINING
In 2017, a global training program was developed and implemented for all Environmental Officers (EO) fleet-wide. The annually required weeklong training course is conducted at Carnival’s Arison Maritime Center in the Netherlands. This program is designed to further develop EO environmental and technical knowledge and skills and to provide professional development opportunities to the over 200 EOs that support our fleet around the world.
We continued our global travel risk management program, named travelSEACURE. This program aims to support all employees, both shoreside and on board, with security, health and unforeseen event assistance while on business travel. In 2017, travelSEACURE was expanded across all brands and it covered over all employees.
We continued to develop and implement a standard electronic health record (EHR) platform across our fleet. This program is enhancing many aspects of our medical operations and services. The implementation of this platform, known as SeaCare, is over 90% complete and is expected to be fully implemented fleet wide by mid-2018.
BODY WORN CAMERAS
Two of our brands implemented the use of Body Worn Cameras by their security teams to record their interactions with passengers and gather video evidence of developing security situations. The use of cameras is clearly marked on the security officer’s uniforms. These cameras have proven to be very useful in capturing interactions between guests and crew members and in preventing confrontations by defusing tense situations.
PORT VULNERABILITY AND THREAT ASSESSMENTS
We regularly conduct port vulnerability and threat assessments to ensure the safety and well-being of our passengers and crew. These assessments document a port’s physical security, vulnerabilities, and any threats specific to the location. The assessments dictate the risk mitigation actions that must be taken by ships calling on the port.
PSYCHOMETRIC EVALUATION PROGRAM
Carnival Corporation implemented a Psychometric Evaluation Program for its Deck and Technical Officers in January 2017. The Program is utilized across all Brands for the selection and promotion of Deck and Technical Officers through the evaluation of specific psychological attributes at certain career stages. To ensure that all Officers possess the attributes required for each of their role, a variety of psychometric evaluations, both online and in person with psychologists is used. The program includes a series of online and proctored evaluations as part of the new hire process, a comprehensive day long in person evaluation as part of the senior officer promotion process and ongoing “check in” evaluations of our senior officers.
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, standards, and our Code of Business Conduct and 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.
Identification and mitigation of risks is a management responsibility. To facilitate this process, the Risk Advisory and Assurance Services department (RAAS) provides the enterprise with a holistic risk framework and methodology for quantifying risk and assessing management’s capabilities for improving risk management. RAAS also provides services via their internal audit program that can provide assurance that risk mitigations are designed and operating effectively.
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 Committees.
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 103 ships. The third FOC will be added to the global network in 2018 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.