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.
As part of our supply chain initiatives to improve sustainability performance:
- We revised our Business Partner Code of 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 Corporate Governance & Ethics Performance
Boards of Directors
Quarterly performance data, including relevant summaries and trends, are reported to our corporate and brand management, Board-level Committees and Boards of Directors. Specifically, the health, environment, safety and security (HESS) committees are briefed by management on the status, progress of and plans for HESS and sustainability related matters as well as on HESS audit results.
As part of our transparency efforts, we disclose key environmental and social data in our annual reports as well as in the performance summary on pages 80-83 of this report.
We revised our corporate Health, Environmental, Safety, Security (HESS) and Sustainability policy (see page 107) to further detail our commitment to risk mitigation, business partner compliance, prohibition of retaliation and to require employees to report any inability to comply with requirements (company, legal or statutory).
Fines and Sanctions
- We did not receive any sanctions or significant fines for non-compliance with non-environmental laws and regulations.
- On December 1, 2016, Princess Cruises, one of our brands entered into a plea agreement with the U.S. Department of Justice with respect to environmental violations of federal laws by the Caribbean Princess. As part of the plea agreement, Princess will pay a $40 million fine. For more details please visit: www.princess.com/news/notices_and_advisories/cbresponse
Board Member Diversity
Our Boards are comprised of ten Directors, two with Executive functions and eight Non-Executive Directors. In 2016, a female Non-Executive Director joined the Boards, increasing the number of female Board members to three, representing 30% of board members. For profiles of all the current members, please visit our website at www.CarnivalCorp.com.
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. With its new scale, technology and equipment, and innovative training approach, the new facility is the most progressive maritime center of its kind in the world for training. It will enable us to continuously improve upon our industry-leading safety and excellence practices.
Boards of Directors Spotlight
Sir John Parker – Chairman, HESS Committee
Sir John Parker has served on Carnival Corporation & plc’s Boards of Directors since 2003. Sir John’s qualifications to serve on the Boards include an extensive international background and wealth of corporate experience. He has served as CEO, Chairman or Non-Executive Director in over 20 major UK and global companies and chaired five FTSE 100 companies. He studied naval architecture and mechanical engineering at the Belfast College of Technology and Queens University in Belfast, Northern Ireland. He has also received honorary doctorates from a number of universities in the UK and Ireland and in 1983 was elected a Fellow of the Royal Academy of Engineering and was president of the Academy from 2011 to 2014. He was Knighted in 2001 for services to shipbuilding and the defense industries and in 2012 was made a Knight Grand Cross of the order of the British Empire (GBE) for services to industry and the voluntary sector.
Sir John first served on the Carnival Corporation & plc Boards of Directors Audit Committees. He was later instrumental in consultation with the chairman Micky Arison in identifying the need for and the establishment of a Health, Environment, Safety and Security (HESS) Committees of the Carnival Corporation & plc Boards of Directors. He has been the Chair of the HESS Committees for over 10 years and is also a member of the Nominating & Governance Committee of the Boards.
Throughout his years of service to the Boards of Directors, his vision and foresight have been a significant influence on the Carnival Corporation & plc management team, in many cases resulting in positive changes in the HESS area. Sir John was an early advocate for the development of the Arison Maritime Center and a driving force behind management’s decision to integrate best practices and procedures into a single corporate-wide safety management and audit tracking system. These examples are a reality today in large part due to Sir John’s leadership and highlight his significant contributions to the success of the Carnival Corporation & plc organization.
We recognize our responsibility to provide industry leadership and to conduct our business as a responsible corporate citizen. We are committed to achieving and maintaining the highest standards of professional and ethical conduct. Adherence to the rule of law, ethical working practices, good corporate governance and transparency are extremely important to our stakeholders, and they are central to our sustainable business success.
Our ships are regulated by the various international, national, state and local laws, regulations and treaties in force in the jurisdictions in which our ships operate. Our ships are registered in the Bahamas, Bermuda, Italy, Malta, the Netherlands, Panama and the UK. They are regulated by these countries and by the international conventions that govern health, environmental, safety and security matters in relation to guests, crew members and the ships themselves.
Representatives of each “Flag,” or country of registry, conduct periodic inspections, surveys and audits to verify compliance with these regulations. In addition, we are subject to the decrees, directives, regulations and other requirements of the more than 700 ports that our ships visit every year as they apply to the various aspects of our ships’ operations. The Summary of Key Regulations Governing Our Operations summarizes the principal laws, acts, codes, directives, legislation, protocols, statutes, rules, regulations and voluntary guidelines related to international environmental, maritime safety and labor requirements with which we comply.
The daily operations of our company are executed by our employees under the direction and supervision of our President and Chief Executive Officer, Arnold W. Donald, and the CEOs and Presidents of each of our brands. Micky Arison is Chairman of the Boards. Our Boards of Directors are responsible for governance of our performance and strategies. We provide further details in the Corporate Governance section on our website and in the annual Proxy Statement at www.CarnivalCorp.com, including:
- Mechanisms for shareholders and employees to provide recommendations or direction to the
Boards of Directors.
- The processes for the Boards of Directors to ensure conflicts of interest are avoided.
- The process for determining the required qualifications and expertise of the members
of the Boards of Directors.
- The processes for evaluating the performance of the Boards of Directors.
- Linkages between compensation for members of the Boards of Directors, Executives and Senior Managers, and the company’s performance.
We have policies and safeguards in place and promote high ethical standards. Our policies meet or exceed regulatory requirements. Our leadership is committed to our Code of Business Conduct and Ethics and our Business Partner Code of Business Conduct and Ethics, which require that every employee, members of the Boards of Directors, and business partners use sound judgment, maintain high ethical standards and demonstrate honesty in all business dealings. As part of our ethics program, we conduct periodic risk assessments and audits that cover our corporate entity, as well as our brands and business units. Risk assessment and audit results help us direct and focus our compliance resources and work plans to address identified compliance risk.
Integrity is a fundamental value for all business units. Our employees are informed about our Code of Business Conduct and Ethics when they are hired and are required to complete training to aid in their understanding of the company’s expected standards of behavior.
To read more about our Corporate Governance practices please see the latest annual Proxy Statement and the Corporate Governance section of our website at www.CarnivalCorp.com
In addition, all shoreside employees at the director level and above, or the local equivalent, and personnel in purchasing or recruiting roles, complete and sign a Business Ethics Disclosure Form at least once annually, indicating that they have read, understood and agree to comply with our Code of Business Conduct and Ethics. To reinforce our commitment to ethical business behavior, we also provide issue-specific ethics training to employees and board members on the basis of their roles and responsibilities in relation to identified compliance risk.
Transparency and disclosure are key to our corporate governance and ethics strategy. We monitor, track and report grievances, environmental incidents and other incidents. To facilitate reporting, we have established formal procedures to report concerns in person or via a dedicated hotline telephone number and website. We have a rigorous internal incident reporting system that requires the reporting of spills, releases or discharges internal within the ship or external to the ship. Spills, releases or discharges are reported to external authorities as required by applicable regulations.
We occasionally receive grievances about labor practices, human rights, impacts on society, environment, guest privacy and guest relations, among others. We evaluate all grievances that we receive. Our goal is to complete their evaluation within a reasonable time frame based on circumstances and legal complexity. However, thorough investigation may require an extended period of time to close some complaints.
Mission & Values
Our mission is to take the world on vacation and deliver exceptional experiences through many of the world’s best known cruise brands that cater to a variety of different geographic regions and lifestyles, all at an outstanding value unrivaled on land or at sea.
Given our global reach and impact, we are committed to the following health, environment, safety, security and sustainability core values:
- Protecting the health, safety and security of our passengers, guests, employees and all others working on our behalf, thereby promoting an organization that always strives to be free of injuries, illness and loss.
- Protecting the environment, including the marine environment in which our vessels sail and the communities in which we operate, striving to prevent adverse environmental consequences and using resources efficiently and sustainably.
- Complying with or exceeding all legal and statutory requirements related to health, environment, safety, security and sustainability throughout our business activities.
- Assigning health, environment, safety, security (HESS)and sustainability matters the same priority as other critical business matters.
Our management ensures that the values and objectives stated in our HESS Policy are clearly understood by everyone in the organization and articulated on a regular basis. Senior management reviews this HESS Policy at least annually. If changes are warranted, it will be updated; otherwise the policy remains unchanged.