Anti-Bribery & Anti-Corruption Declaration (ABAC)

1. Zero-tolerance commitment

1.1. CARGOWARD maintains a strict zero-tolerance position toward bribery, corruption, kickbacks, facilitation payments, improper influence, and any form of unethical advantage.

1.2. No commercial objective, operational urgency, schedule pressure, port constraint, or “local practice” may justify conduct that is unlawful, deceptive, or inconsistent with this Declaration.

1.3. CARGOWARD requires transparent, traceable, and documented operations—particularly where public officials, port authorities, terminals, customs, immigration, police, health authorities, environmental agencies, and port state control may be involved.

2. Legal and standards alignment (multi-jurisdiction)

2.1. This Declaration is intended to align with applicable anti-corruption frameworks and laws, including, where relevant to a given transaction or jurisdiction:

• Brazil: Clean Company Act (Law 12.846/2013) and related regulations;

• United States: U.S. Foreign Corrupt Practices Act (FCPA);

• United Kingdom: UK Bribery Act 2010;

• European Union / EEA / UK: applicable anti-corruption and integrity obligations and procurement requirements;

• Other anti-bribery and anti-corruption laws applicable in the Operation Location.

2.2. Where legal standards differ, CARGOWARD applies a highest-standard approach to the extent permitted by law.

3. Scope and persons covered

3.1. This Declaration applies to: directors, officers, employees, trainees, contractors, subcontractors, consultants, agents, intermediaries, and any third party acting for or on behalf of CARGOWARD (collectively, “Covered Persons”).

3.2. This Declaration applies to all services and operational contexts, including (without limitation): port agency & clearance, port operations support, cargo hold cleaning, tank cleaning / sludge support, gas-free readiness / PTW interfaces, underwater operations, technical attendance, surveys, logistics coordination, documentation, and evidence packs.

3.3. Covered Persons must comply with this Declaration as a condition of engagement. Non-compliance may result in removal from assignments, termination, and referral to competent authorities where required.

4. Core prohibitions

4.1. Covered Persons must never, directly or indirectly:
(a) offer, promise, authorize, give, request, solicit, accept, or receive a bribe or improper advantage;
(b) provide anything of value to influence any decision, approval, clearance, inspection outcome, access authorization, scheduling priority, or enforcement discretion;
(c) make or accept kickbacks, secret commissions, rebates, side payments, “success fees” not contractually disclosed, or benefits routed through third parties;
(d) conceal, misclassify, falsify, backdate, or omit records to disguise improper conduct;
(e) use agents, intermediaries, vendors, or subcontractors to perform prohibited actions.

4.2. “Anything of value” includes cash, cash equivalents, gifts, hospitality, travel, entertainment, employment offers, internships, vendor benefits, charitable donations, sponsorships, discounts, debt forgiveness, preferential pricing, or any benefit to an individual or related party.

5. Public officials and authority interfaces (high-risk environment)

5.1. Interactions with public officials and authority representatives (customs, immigration, police, health/sanitary authorities, environmental agencies, port authorities, and similar bodies) must be lawful, transparent, and conducted through official channels.

5.2. Covered Persons must not attempt to influence official acts through unofficial payments, benefits, intermediaries, or non-transparent arrangements.

5.3. Any request—explicit or implied—for an unofficial payment, personal benefit, or “expedited outcome” must be refused and escalated as per Section 14.

6. Facilitation payments (prohibited)

6.1. Facilitation payments (often described as “speed money” or unofficial payments to accelerate routine actions) are prohibited.

6.2. CARGOWARD does not permit facilitation payments through third parties, “cash handling,” or “miscellaneous” expense lines.

7. Extortion, coercion, and personal safety

7.1. If a Covered Person faces a credible, immediate threat to life, physical safety, or unlawful detention, safety is the priority.

7.2. Any safety-driven exception must be:

• strictly limited to removing the immediate threat,

• documented as soon as safely possible, and

• reported promptly to CARGOWARD via contact@cargoward.com with details (date, location, parties, facts).

7.3. Commercial pressure, delay risk, berth windows, or operational inconvenience are never valid justifications.

8. Gifts, hospitality, meals, and business courtesies

8.1. Gifts and hospitality must be modest, lawful, infrequent, and directly linked to legitimate business purposes.

8.2. Covered Persons must not offer or accept:

• cash or cash equivalents;

• lavish hospitality or entertainment;

• personal travel unrelated to legitimate business;

• anything that creates (or appears to create) influence over decisions.

8.3. Any questionable courtesy must be declined and escalated.

9. Political contributions, donations, and sponsorships

9.1. CARGOWARD does not permit political contributions intended to influence business outcomes, clearances, access, inspections, or enforcement decisions.

9.2. Charitable donations and sponsorships must not be used as a substitute channel for improper influence and must be subject to internal review and documentation.

10. Conflicts of interest and improper influence

10.1. Covered Persons must avoid conflicts of interest that could compromise procurement integrity, operational decisions, or authority interactions.

10.2. Conflicts include undisclosed relationships with officials, terminal stakeholders, vendors, intermediaries, or client counterparties; financial interests; or personal benefits linked to nominations, approvals, or supplier selection.

10.3. Conflicts must be disclosed promptly. Undisclosed conflicts may be treated as serious misconduct.

11. Third parties (agents, vendors, subcontractors) — due diligence & controls

11.1. Third parties are a primary ABAC risk vector. CARGOWARD applies controls consistent with operational risk, including:

• onboarding checks (identity, reputation, capability, scope legitimacy);

• written scope definition and payment terms;

• prohibition of cash payments and undocumented “extras”;

• requirement for adequate documentation/receipts and traceable billing;

• monitoring of red flags and escalation.

11.2. CARGOWARD will not knowingly engage a third party that:

• requests cash or offshore payments without justification;

• refuses to provide documentation;

• demands vague “handling fees” for authority outcomes;

• proposes “guaranteed approvals” or “special access” without lawful basis;

• has credible indications of unethical conduct.

11.3. Payments to third parties must be commensurate with legitimate services actually performed and supported by appropriate documentation.

12. Procurement integrity, expense governance, and cash restrictions

12.1. CARGOWARD requires disciplined procurement and expense controls, including segregation of duties where practical and review of high-risk expense categories.

12.2. Cash payments, personal reimbursements without documentation, and “miscellaneous” entries used to mask improper payments are prohibited.

12.3. Expense descriptions must be accurate and specific. Improper or vague accounting is treated as a compliance breach.

13. Books, records, and transparency (non-negotiable)

13.1. CARGOWARD requires complete, accurate, and traceable books and records for all transactions, including invoices, disbursements, advances, receipts, and service logs.

13.2. False entries, misclassification, backdating, off-book accounts, or concealed payments are prohibited.

13.3. Records must be retained in accordance with operational needs, legal obligations, and internal governance requirements.

14. Reporting, escalation, and non-retaliation

14.1. Any suspected misconduct, red flag, extortion attempt, bribe request, suspicious vendor demand, or unethical instruction must be reported promptly to: contact@cargoward.com.

14.2. Reports should include: date/time, location, parties involved, what was requested/said, and any supporting evidence.

14.3. CARGOWARD prohibits retaliation against any person who raises a concern in good faith or participates in an investigation.

15. Investigations, corrective action, and enforcement

15.1. CARGOWARD may investigate allegations, preserve records, interview relevant personnel, and engage professional advisors where required.

15.2. Confirmed violations may lead to disciplinary action up to and including termination of employment/engagement, contract termination, removal of access, and notification to competent authorities where required.

15.3. Failure to cooperate with investigations may itself constitute a violation.

16. Training and operational readiness

16.1. CARGOWARD may require ABAC training for roles exposed to higher risk, including: port/authority interface, clearance coordination, procurement, vendor management, cash-handling exposure, and field supervision.

16.2. Operational teams must be able to recognize and escalate red flags, including improper requests tied to: access approvals, immigration/customs processes, terminal gate clearances, scheduling priority, survey outcomes, waste reception/disposal channels, or documentation issuance.

17. Client alignment and contractual integration

17.1. This Declaration is intended to complement clients’ vendor compliance requirements and may be incorporated by reference into quotations, purchase orders, and service agreements, where applicable.

17.2. Where a client requires additional ABAC undertakings (e.g., certifications, questionnaires, vendor onboarding packs), CARGOWARD may provide reasonable confirmation consistent with this Declaration.

18. Updates

CARGOWARD may update this Declaration to reflect legal developments, operational learnings, and governance best practices. The “Last Updated” date indicates the current version.