INTEGRITY AND COMPLIANCE

 MSC Cruises Code of Conduct

As an international cruise line company, MSC Cruises earns its reputation and trust everyday by providing unparalleled services to its guests and by conducting business fairly and ethically. Our reputation for trust and integrity relies also upon every action by every employee every day and in order to ensure this is embraced across the organization, we have a comprehensive Code of Ethical Business Conduct in place.

Fostering an Ethical Corporate Culture

The MSC Cruises’ Code of Conduct for its employees is a guideline to help all employees run their part of the business ethically, both ashore as well as on our ships, and aims at ensuring that business practices comply with applicable laws, regulations and ethical business principles, as well as upholding a culture of integrity.

While our Code sets forth a common standard of approved behavior, regardless of the location of the employee, these standards are a complement to applicable laws and regulations in many countries where MSC Cruises operates and often exceed local or international standards. All our onshore or shipboard employees are required to adhere to the Code. We are committed to making sure the Code of Ethical Business Conduct is respected.

Our 9 areas of focus

While our Code of Conduct for our employees provides a meaningful starting point, it may not answer all questions, or ensure compliance with the various legal requirements applicable to its business and environment. Therefore, we have defined 9 critical areas where we aim to heighten sensitivity among all staff and install a strong culture of compliance and integrity. All these areas are featured in our Code of Conduct for employees.

Our areas of focus include:
1. Respect for the environment
2. Human rights and labour standards
3. Anti-bribery
4. Conflict of interest
5. Sanctions regulations
6. Anti-money laundering
7. Fair competition
8. Accuracy and maintenance of business and financial records
9. Data privacy and protection

CODES OF CONDUCT

Find below the Corporate Code of Conduct for employees  and the MSC Cruises Business Partner (Supplier) Code of Conduct.

BUSINESS PARTNER (SUPPLIER)
EMPLOYEES

INTEGRITY SPEAK-UP

At MSC Cruises, we live our company purpose with our values rooted in respect.
MSC Cruises principles and values reflect our commitment to a strong ethical culture as a non-negotiable foundation of how we do business.
Therefore, it is crucial for our company to have a robust reporting system that enables us to listen to anyone along our value chain about any compliance concern.
This is where Integrity Speak Up, our dedicated reporting channel, comes into play.

Speak up!

We encourage our employees to Speak Up if they notice any incidents of wrongdoing pertaining compliance matters such anti-bribery and corruption, fraud, conflicts of interest, or any incidents of harassment, discrimination, abuse of power, bullying or mobbing. This includes any behaviors that go against out Corporate Code of Conduct for employees or the MSC Cruises Business Partner (Supplier) Code of Conduct.

We do whatever we can to ensure our company is managed in line with our ethical commitments. You can help us by reporting any compliance related issues through our Speak Up system. This is independently operated by a third party and offers you anonymity if you wish.

 HOW TO REPORT A COMPLIANCE CONCERN

Here you’ll find all the information you need to Speak Up about non-compliance, 24/7, 365 days a year.

1. Submit your report via a webform or call a toll-free number to leave a message.

2. Include a detailed description of your concern (who, what, when, how) and add supporting evidence, e.g., copies of documents or names of witnesses, that can corroborate your report. Please note that general assertions can’t be investigated.

3. Once you’ve submitted your report, you’ll receive an individual case number. You’ll need this number each time you access the system.

4. We take all non-compliance concerns seriously and will carry out the appropriate action on each report. We’ll keep you informed on our progress accordingly.

5. You can track progress by going back into the website using your case number.

What happens after you submit a report?

Once you’ve submitted your report, it’ll go through a few stages. Here’s what will happen next.

We’ll acknowledge receipt of your message within five working days. If your initial report doesn’t include enough actionable information / evidence, you’ll be asked to provide more information / evidence.

Each report is reviewed carefully. We’ll open a case if your report includes minimum actionable information and evidence. The investigation will be managed by our Corporate Compliance Organization.

Reports that contain allegations in one of these sensitive categories will be escalated to the Operative Compliance Committee.

  1. Abuse of power and/or Bullying
  2. Antitrust and fair dealing
  3. Bribery and corruption
  4. Confidential information, Privacy policy
  5. Discrimination, harassment, and violence
  6. Executive Board Members / Senior managers in Switzerland
  7. Fraud
  8. Human rights
  9. Sexual harassment

To ensure the investigation is confidential, we’ll only involve people who need to be involved. Our Compliance Organization may conduct confidential interviews with employees, contractors, or anybody they feel is relevant to the investigation.

As a general practice, it takes around 60 days for an investigation to be concluded. However, we may need more time for complex matters.

After reviewing all the findings of the investigation, we’ll decide if any further action needs to be taken. When appropriate, we’ll keep you informed of progress and will send you a final reply outlining the outcome of the investigation.

MSC Cruises prohibits any retaliation against an employee, individual or entity who has made a report. We’ll also protect the rights of any implicated person.