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.
Maritime Cyber Risk Management has been incorporated by the International Maritime Organization (IMO) into a global standard for the safe management and operations of ships. Carnival is expanding and implementing additional cyber security related processes and procedures for inclusion into our shipboard Safety Management System. A Maritime Cyber Security team has been formed and will continue to assess our ships and measure the operational impact and overall effectiveness of our procedures. Several additional processes and technical systems and equipment have been introduced onboard our ships and are expected to significantly reduce cyber risks.
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 continue to align welfare standards for broiler chicken, ensuring that 100% of chicken sourced will be certified by the Global Animal Partnership by 2024.
- We continue our partnership with the Association of British Travel Agents (ABTA) to help us ensure we are responsibly managing excursions involving animals.
- We started to audit the dolphin in captivity tour encounters used by our cruise brands in 2018 and our goal is to complete the process in 2019.
FY2018 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 2018, we opened our third state-of-the-art Fleet Operations Center (FOC) in Miami, U.S. The first FOC was opened in Hamburg, Germany in 2015 and the second was opened in Seattle, U.S. in 2016. Our three 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
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 and/or compliance audits Health, Environment, Safety and Security (HESS) are conducted annually of each brand’s head offices, 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 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 and investigation results. HESS audit and investigation results are used to determine compliance, improve effectiveness and efficiency, analyze trends, support newbuild and retrofit decisions, and promote best management practices.
Data aggregation and Analysis Platform – Neptune
In 2018, 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. Our 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, safety and security 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 2018, the system expanded its aggregation and analysis in three areas:
- Engine: Enhancements are planned to start monitoring Liquefied Natural Gas (LNG) ships starting in 2019. The live dashboard will be modified to monitor engines’ technical parameters behavior when ships use LNG fuel.
- Advanced Air Quality Systems (AAQS): Additional special geographical areas have been added to Neptune with the aim to align the analysis according to international/local environmental restrictions.
- Energy Efficiency: Analytics for basic energy usage data are now available for 95 ships in the fleet. Remaining ships are scheduled for completion in 2019.
Arison Maritime Center
We continue to train our officers in our world-class facility equipped with the latest maritime simulation technology and equipment. The Center provides rigorous safety training for bridge, engineering and environmental officers responsible for the navigation, operation and environmental compliance 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 2018, the Environmental Officer (EO) training program was expanded to include a second course for continuous professional development.
We continued our global travel risk management program, named travelSEACURE. This program aims to support all employees, both shoreside and onboard, with security, health and unforeseen event assistance while on business travel. In 2018, travelSEACURE captured travel data for over 60,000 employees traveling on nearly 200,000 flights around the globe. This data was used to analyze travel risk patterns in order to keep our employees safe and secure.
VISIBLE BODY WORN CAMERAS
In 2018, three additional 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
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 roles, a variety of psychometric evaluations, both online and in person with psychologists are 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. In 2018, a new program designed to evaluate new hire Environmental Officer candidates was implemented.
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. In 2018, a new program designed to evaluate new hire Environmental Officer candidates was implemented.
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, investigations, 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. Upper management and the Boards of Directors are regularly advised on corporate risk management issues and on the status 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 detection, prevention, implementation, feedback and improvement. We plan and establish objectives and processes necessary to achieve the required and expected results. We then implement the 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.