In 2019, we focused on enhancing our compliance framework by developing a dedicated ethics and compliance program and corresponding strategic plan. Through this, we were able to significantly increase the resources devoted to our compliance function. Our Chief Ethics and Compliance Officer (CECO), a member of the executive leadership team, leads the effort to further develop our ethics and compliance program across the entire corporation. The CECO is assisted by other leaders who focus on key areas (including environmental, health, safety and various general compliance issues), as well as important processes (investigations, compliance training, risks, and communications). It is important to note that the Ethics & Compliance is not just a single Department within All Brands Groups - but rather a corporate-wide program - with key Ethics & Compliance Officers (also known as “ECO’s”) who help shape and implement the program initiatives in each of the operating companies.

Through the collective efforts of these leaders,
this corporate-wide program involves compliance risk management, improved compliance training programs for our employees, thorough investigations and remedial actions relating to health, environmental and safety incidents, and efforts to strengthen our corporate culture. To further heighten the focus on ethics and compliance, the Boards of Directors established Compliance Committees to oversee the ethics and compliance program, maintain regular communications with the Chief Ethics and Compliance Officer, and ensure implementation of the ethics and compliance program’s strategic plan across the corporation.

Addressing climate change is one of our top priorities and we are committed to continue to lead the path within the cruise industry. Our entire management team, including our Board of Directors, is committed to addressing climate change. Our path to decarbonization involves multimillion-dollar investments and a multi-faceted strategy. Key components of this strategy include adopting international frameworks and working with industry regulatory bodies to: address upcoming regulatory requirements and conditions, maximize efficiency opportunities/gains, implement low carbon fuels, invest in carbon-efficient technologies, support and accelerate industry-specific research & development projects, establish internal goals supporting the path as well as partner with other companies, NGOs, and relevant stakeholders. In the coming years, we are likely to see an array of emerging technological innovations as currently there is not a single (nor a combination of technologies) that can move the maritime industry straight into a decarbonization path. As we navigate this journey, we are committed to evaluate options, work with various stakeholders, and adjust our path as needed.

Throughout the world in 2019, as countries experienced outbreaks of civil unrest, we worked closely with industry partners and regional governments. We implemented appropriate security measures which allowed us to navigate through protests with limited impact.

Most of our onboard security teams now use Body Worn Cameras to record interactions with guests and gather video evidence of developing security situations. The use of cameras is clearly marked on the security officer’s uniform. These cameras have proven useful in capturing interactions between guests and crew members and in preventing confrontations by defusing tense situations.

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.

• 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 regular third-party inspections, surveys, and audits.

• Internal Health, Environment, Safety and Security (HESS) compliance audits are conducted annually of each of our brands’ head offices, 100% of our fleet, our ports, hotels, and land transport assets.

• HESS investigations are also carried out as needed to determine the root cause of incidents and identify corrective and preventative actions that will reduce the risk of future occurrences. In 2019, we made a number of improvements to our investigative function, which included: a) adding additional investigators; b) revising our investigation policies to reduce the tendency to place blame and to emphasize the need to learn from incidents; c) improving investigative training on root cause analysis; d) reducing the backlog of investigations. Additional improvements to the investigation program are planned and on- going throughout 2020.

• To better promote sharing of “lessons learned” throughout the corporation, all incident investigation recommendations, audit observations, findings and non-conformities are periodically reviewed by HESS leaders, 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.

In 2019, we continued to enhance cybersecurity capabilities and data privacy initiatives to protect the fleet, employees and our guests from any threats that could impact operational technology systems and data privacy. We introduced data privacy and cybersecurity training for applicable shipboard staff and shoreside employees. Cybersecurity policies and procedures were introduced into our Global Health, Environment, Safety and Security (HESS) management system. We also have implemented procedures to ensure compliance with applicable data privacy laws in various jurisdictions.

We continue to evaluate our Deck, Technical and Environmental Officers through a Psychometric Evaluation Program. The program is utilized across all brands for the selection and promotion of 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 utilized. The program includes a series of online and proctored evaluations as part of the new hire process including a comprehensive in-person evaluation as part of the senior officer promotion process and ongoing “check in” evaluations of our senior officers.

In 2019, we completed the fleetwide rollout of a new health, environment, safety and security (HESS) event reporting system. This platform has allowed us to standardize our HESS event reporting and analysis capabilities across the entire fleet.

As part of our ongoing efforts and support for human rights, we are committed to develop a human rights policy that will be in alignment with the Universal Declaration of Human Rights in 2020.

• We continue our partnership with the Association of British Travel Agents (ABTA) to help us ensure we are responsibly managing excursions involving animals.

• We continue to work with third-party animal welfare auditor.

• Completed 100% of animal welfare audits for tour encounters offering dog sledding in Alaska.

• Completed more than 50% of animal welfare audits for tour encounters with dolphins in captivity between FY2018 and FY2019.

The Ethisphere® Institute is a global leader in defining and advancing standards of ethical business practices that fuel corporate character, marketplace trust, and business success. We are honored to be a member of The Business Ethics Leadership Alliance (BELA) within the Ethisphere organization. BELA supports the sharing of experiences and best practices within its members to improve ethics and compliance programs globally.

• 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. Click here for more information.

• Carnival Corporation’s CSMART Training Center received the 2019 SAFETY4SEA Training Award, for providing high-quality maritime training services for industry-wide safety, sustainability and operational excellence. Read more here.