NORDEN’s Anti-Corruption Compliance Programme was anchored in the organisation in the beginning of 2015. In connection with the risk assessment conducted when developing the programme, employees have been divided into groups based on the corruption risks they faced in connection with their daily tasks and job function.
12 different e-learning courses have been developed for land-based employees, each tailor-made to address the specific identified challenges faced by these groups. All 12 e-learning courses were launched end March, and by end December, 87% of NORDEN's land-based employees, both at the headquarter and overseas offices, had passed the training. NORDEN’s Board of Directors and Executive Management also underwent anti-corruption training in the form of a tailor-made workshop. In addition to the 12 e-learning courses, an e-learning targeting frontline operators as well as a workshop for Senior Management was developed within the Maritime Anti-Corruption Network and implemented in NORDEN in October 2014. As mentioned in NORDEN’s CSR report 2014, end year 2014 all Senior Management and operators had passed the training.
NORDEN’s seafarers had already received e-learning training developed within the Maritime Anti-Corruption Network in October 2014. Every time a senior officer, junior officer or cadet sign on a vessel, they are required to take the training. As illustrated by NORDEN's performance results above, however, this has not been carried out. The majority of NORDEN's seafarers have still not taken the training, only 14% have done so. In the second and third quarter of 2015, NORDEN increased awareness and outreach to the vessels highlighting the importance of taking the mandatory training. Moreover, at NORDEN's bi-annual officer seminars in Copenhagen, Mumbai and Manila, anti-corruption workshops were held to emphasise the importance of this issue and the strong focus NORDEN has on this area. Real-life cases and situations were discussed and feedback was given, which is of great value to ensure relevant and updated training material. NORDEN expects the increased efforts to be visible in our 2016 training performance results.
18 out of 52 of NORDEN's owned vessels are in external technical management, which means that the seafarers on these vessels are employed by a third party. NORDEN has decided that these seafarers should receive the same training as NORDEN own seafarers. Therefore, the vessels have received the anti-corruption e-learning course, and the seafarers are expected to take the course as soon as they sign on the vessel. However, the training results are lower than for NORDEN's own seafarers, 8% have taken the training, so NORDEN will continue to increase awareness on the importance of anti-corruption.
Every 3 months, NORDEN updates the anti-corruption IT system with new employees, both at sea and on shore, to ensure that all employees receive the training. The e-learning courses are updated every 2 years, and high-risk employees receive an annual workshop in addition to the e-learning, where concrete incidents and dilemmas are discussed.
NORDEN has a zero tolerance towards bribery and endeavours to reduce facilitation payments. In the third quarter of 2015, NORDEN launched an automated facilitation and bribery registration system. Facilitation payments can be defined as small payments in cash or in kind made for a service to which NORDEN has a legal right or other entitlement. The registration system enables NORDEN to better identify challenges and pinpoint trends and patterns. The Captain, Operator or Superintendent log into the system and report if a demand for facilitation payment or bribery payment has been made, who made it, what they asked for and if the demand was successfully resisted. The reason why they must still report a demand even though they did not end up paying is because NORDEN needs to be able to calculate whether we have successfully reduced facilitation payments by comparing how many demands were made in a given year, with how many we ended up paying.
A description of all the projects that MACN and its members are working on within the network can be found here.