Codes of Conduct
Explora Journeys, a division of MSC Cruises SA, the world's largest privately- owned cruise company, is committed to undertaking business fairly and upholding al applicable laws, including but not limited to anti-bribery, sanctions and forced labour and underage employment laws.
Ashore and onboard, Explora Journeys is committed to reducing its impact on the environment, the seas, and oceans that it sails and to comply with all applicable laws and regulations in the countries in which it operates.
Furthermore, through different projects, investments, and initiatives, Explora Journeys is truly engaged in preserving the marine environment and relies on sound environmental practices to ensure protection of the environment. Explora Journeys expects its Business Partners to share the above commitment by operating cleanly, efficiently, and sustainably and by complying with all applicable environmental laws.
Explora Journeys respects all people and supports their human rights. Our Business Partners help fulfill this commitment by also protecting anyone who does work on their behalf by following employment laws, by supporting employee rights to unionize, by providing fair wages and working hours, by ensuring safe working conditions and by prohibiting harmful practices like underage employment, forced labour, physical punishment, or abuse. Furthermore, Explora Journeys Business Partners do this by choosing their own business partners responsibly, by using appropriate due diligence processes, by establishing clear policies to ensure their compliance with the requirements of this Code as well as regularly monitoring their ongoing performance. Explora Journeys Business Partners help maintain a safe environment for everyone and we rely on them to follow all applicable safety laws, regulations, guidelines, and industry codes especially when carrying out work on Explora Journeys premises.
We expect that Explora Journeys Business Partners will implement their own safety and health practices and training to minimize and avoid any injuries.
Non-Discrimination
Diversity is one of Explora Journeys’ greatest assets. We think that different profiles and backgrounds offer great opportunities and added value to Explora Journeys. To ensure that each person’s individuality is respected, Explora Journeys does not tolerate any discrimination based on sex, race, religion, language, gender, national origin, age, disability, political or ideological beliefs, marital status, and sexual orientation or family responsibilities.
Explora Journeys strictly complies with applicable laws in all aspects of employment, in particular those laws related to elimination of discrimination in respect of employment. Therefore, Explora Journeys is firmly committed to support equal employment opportunity and diversity by ensuring that all decisions to recruit and promote are based on merit.
Protection of Children and Adolescents
Explora Journeys strongly opposes the use of child labour (underage employment) and complies with all applicable laws related thereto.
For the purpose of this Code, “Child Labour” is defined as any illegal form of child labour as determined under the ILO Conventions no. 138 of June 1973 and no. 182 of 17 June 1999. Work by children under the age of 16 is strictly prohibited. In countries where local laws set a higher age for child labour or set an age for completion of compulsory education higher than 16, the highest age is applicable. Workers under the age of 18 shall not perform any overtime or hazardous work or work a night shift. Suppliers may use lawful, legitimate, properly managed workplace apprenticeship programs, such as student internships.
Working Conditions
Explora Journeys supports and respects internationally recognized human rights in conducting its business relationship and activities worldwide. Explora Journeys believes that each person deserves to be treated equally and properly and this responsibility lies also with every employee.
Explora Journeys condemns forced labour and any form of exploitation or slavery and complies with all applicable laws. Explora Journeys Business Partners are expected to comply with all the above mentioned or otherwise applicable laws pertaining to human rights.
Harassment and Other Abusive Conduct
Explora Journeys believes in and supports the fundamental dignity of all Employees and does not tolerate any form of harassment or abusive conduct. Harassment and abusive conduct can include acts or threats of violence to another person (including gestures, language, and physical contact), the intentional damaging of Explora Journeys’ property or the property of another person, or any other behavior that causes others to feel unsafe in Explora Journeys’ workplace. Explora Journeys does not tolerate retaliation against any Employee who complains of harassment or who participates in an investigation.
Explora Journeys Business Partners are expected to comply with all the above mentioned or otherwise applicable employment laws pertaining to relevant jurisdictions.
Health and Safety
Explora Journeys’ priority is to provide a safe and healthy onboard environment to its guests and a safe and healthy workplace to its Employees whether working onshore or onboard. To meet this goal, Explora Journeys complies with all applicable health and safety regulations, including
with the strict requirements of the Safety of Life at Sea (SOLAS) Convention and, in some cases, goes beyond by implementing CLIA’s policies in relation to operational safety, fire protection, shipboard security and health.
Explora Journeys Business Partners are expected to comply with all the above mentioned or otherwise applicable health and safety laws and regulations.
Explora Journeys is committed to undertaking business fairly and to upholding all applicable anti-bribery laws in its business dealings worldwide. Explora Journeys strictly prohibits all Corruption, Passive and Active Bribery, and Facilitation Payments.
The Business Partner, its employees, directors and any other person or entity acting on its behalf (“Related Parties”) shall comply with all applicable anti-corruption laws and best practices including but not limited to Swiss Penal Code, and where applicable the U.S. Foreign Corrupt Practices Act and the UK Bribery Act 2010 (“Anti-Corruption Laws”).
The Business Partner agrees that it, and its Related Parties have not, and will not, offer, promise, pay or authorize the payment of money or anything of value, or take any action in furtherance of such a payment, whether by direct or indirect means, to any Government Official, employee of Explora Journeys or any other private individual to influence the decision of such person in the performance of their duties.
The Business Partner and its Related Parties shall not accept any bribe or kickback in return for facilitation of a transaction or taking a decision.
A conflict of interest occurs when Business Partners’ commercial interests interferes with, or appears to interfere with, in any way with the commercial interests of Explora Journeys.
Business Partners should actively avoid any situation that could impact on their ability to act in the best interests of Explora Journeys or that may make it difficult to carry out the agreed work/services objectively and effectively. Explora Journeys requires that its Business Partners should fully disclose any situations that could reasonably be expected to give rise to a conflict of interest. If a Business Partner suspects that there may be a conflict of interest, or a situation that others could reasonably perceive as a conflict of interest, such Business Partner must report it immediately to Explora Journeys. Explora Journeys expects its Business Partners to put in place appropriate internal procedures to enable the identification, disclosure and management of any such conflicts of interest.
Sanctions regulations are prohibitions against engaging in specified international transactions involving certain individuals, entities, countries, to achieve a national security and/or political objective.
Explora Journeys complies with Swiss and European Union sanctions regulations as well as with any other sanctions regulations applicable to its activities and business dealings worldwide. Explora Journeys Business Partners are expected to comply with all the above mentioned or other wise applicable sanctions law.
Explora Journeys is committed to complying with the applicable competition regulations (also known as “Antitrust Laws”) at any time, regardless of the location. We expect our Business Partners to do the same. Violations of Antitrust Laws are strictly penalized by law, including in many countries by criminal sanctions.
Explora Journeys expects its Business Partners to never make an agreement (or even appear to agree) with competitors to restrict trade, limit production or boycott others, and never exchange sensitive information with competitors (like prices, bids or costs).
MSC Business Partners are requested to be honest about their relationships and transparent in all their dealings.
The accuracy and maintenance of Explora Journeys’ business and financial records is crucial and must be ensured. Explora Journeys is committed to complying with all applicable financial and tax rules and avoiding the commission or facilitation of any form of tax evasion under any applicable legislation, including but not limited to the scope of the UK Criminal Finance Act 2017. Explora Journeys expects its Business Partners’ records and practices to reflect the same high standards. Business Partners documentation should always comply with applicable laws, regulations, guidelines, industry codes and corporate codes, focused on accuracy and transparency. Information should never be falsified, destroyed or misrepresented.
Confidentiality
Business Partners must safeguard all Explora Journeys’ Confidential Information as well as any Confidential Information received from Explora Journeys’ guests, suppliers and any other third parties.
Failure to do so could result in a breach of obligations arising under contracts or laws protecting business secrets, data protection, and privacy. Confidential Information must not, in any case, be disclosed to anyone outside of Explora Journeys, including to family and friends, except if legally required. Confidential Information must not be shared with others inside Explora Journeys except on a “need to know” basis.
All Business Partners are obliged to protect Confidential Information, even after business ends as required by contracts or law.
If Business Partners have access to Explora Journeys Confidential Information or intellectual property, it is paramount that they collect, use and handle it responsibly. The information should never be disclosed in public (even inadvertently) or to anyone outside of Explora Journeys without prior written approval.
Explora Journeys’ name and reputation
Business Partners shall not, without Explora Journeys’ prior written consent,
(i) use MSC’s name or logo in any promotional or advertising materials;
(ii) use their business-relationship with MSC to imply an endorsement by MSC of their goods or services, and
(iii) make any representation or statement for or on behalf of MSC.
Explora Journeys shall be entitled to terminate an agreement and/or a business relationship with a Business Partner if the Business Partner has become involved in any situation or activity which tends, in the reasonable opinion of Explora Journeys, to have a negative effect on the reputation of Explora Journeys or any aspect of its business or would expose Explora Journeys or any aspect of its business to disrepute, scandal, ridicule or contempt.
Data Protection
Explora Journeys respects and protects the privacy of its employees, guests, and business partners, processing the personal information in accordance with the requirements established by applicable data protection laws. Personal information is processed fairly and lawfully and for specified and legitimate purposes. Explora Journeys stores the personal information securely and takes precautions to prevent unauthorized disclosure.
Any unlawful processing of personal information could be damaging to both the natural person from whom the information is collected and Explora Journeys. Explora Journeys expect its Business Partners to implement similar high standards, to train their employees and to always respect all applicable laws and regulations.
Explora Journeys is committed to provide its guests the best available experiences while travelling on Explora Journeys itineraries, including safe and high-quality services. Explora Journeys Business Partner must also commit to the same standard: safe, reliable products and services
and technologies that meet the quality expectations as per the terms and conditions of their respective contracts. Business Partners should always label their products, deliver them on time and ensure that they meet inspection, testing quality and safety regulations as per their respective contracts.
Although Explora Journeys operates on the assumption that its ships and operations never stop, Explora Journeys is always ready for any challenge or emergency affecting them. Explora Journeys Business Partners must be equally prepared for these circumstances by having contingency plans in place to ensure recovery and restoration of their critical business functions during an emergency.
Explora Journeys Business Partners could become aware of inside information about Explora Journeys or another company that could influence an investor’s decision to buy, sell or hold stock or securities. If Business Partners have such information, they must keep them confidential and never use them to make investment decisions or tip it to anyone else for their benefit.
Delivering consistent and accurate messaging about Explora Journeys is very important, especially in difficult or in unusual circumstances. Business Partners shall never speak publicly on Explora Journeys’ behalf and refer any requests for information to Explora Journeys directly.
Explora Journeys is committed to conducting business ethically.
An important aspect of accountability and transparency is enabling our Business Partners to voice any compliance concerns in a responsible and effective manner. Business Partners are encouraged and expected to report any compliance violations or suspected violations of MSC employees that become known to them through:
- Whistleblowing Platform at
- https://msccexplora.integrityline.com/frontpage
- Email to hotline@msccruises.com
Ashore and onboard, MSC Cruises is committed to reduce its impact on the environment, the seas and oceans that it sails and complies with all applicable laws and regulations in the countries in which it operates.
Furthermore, through different projects, investments and initiatives, MSC Cruises is truly engaged in preserving the marine environment and relies on sound environmental practices to ensure protection of the environment.
We expect you to share the above commitment by operating cleanly, efficiently and sustainably and by complying with environmental laws.
We respect all people and support their human rights.
MSC Cruises protects its Employees anyone who does work on our behalf following employment laws, supporting employee rights to unionize, providing fair wages and working hours, ensuring safe working conditions and prohibiting harmful practices like underage employment, forced labor, physical punishment or abuse.
Non-Discrimination
Diversity is one of MSC Cruises’ greatest assets. We think that different profiles and backgrounds offer great opportunities and added value to MSC Cruises.
To make sure that each person’s individuality is respected MSC Cruises does not tolerate any discrimination based on sex, race, religion, language, gender, national origin, age, disability, political or ideological beliefs, marital status, and sexual orientation or family responsibilities. MSC Cruises strictly complies with applicable laws in all aspects of employment, in particular those laws related to elimination of discrimination in respect of employment. Therefore, MSC Cruises is firmly committed to support equal employment opportunity and diversity by ensuring that all decisions to recruit and promote are based on merit.
Protection of Children and Adolescents
MSC Cruises strongly opposes the use of child labour and complies with all applicable laws related thereto. For the of this Code, “Child Labour” is defined as any illegal form of child labour as determined under the ILO Conventions no. 138 of June 1973 and no. 182 of 17 June 1999. Work by children under the age of 16 is strictly prohibited. In countries where local laws set a higher age for child labour or set an age for completion of compulsory education higher than 16, the highest age is applicable.
Workers under the age of 18 shall not perform any overtime or hazardous work or work a night shift.
Working Conditions
MSC Cruises supports and respects internationally recognized human rights in conducting its business relationships and activities worldwide.
MSC Cruises believes that each person deserves to be treated equally and properly and this responsibility lies also with every employee. MSC Cruises condemns forced labor and any form of exploitation or slavery and complies with all applicable laws thereto.
Harassment and Other Abusive Conduct
MSC Cruises believes in and supports the fundamental dignity of all Employees and does not tolerate any form of harassment or abusive conduct. Harassment and abusive conduct can include acts or threats of violence to another person (including gestures, language and physical contact), the intentional damaging of MSC Cruises’ property or the property of another person, or any other behavior that causes others to feel unsafe in MSC Cruises’ workplace.
MSC Cruises does not tolerate retaliation against any Employee who complains of harassment or who participates in an investigation.
Health and Safety
MSC Cruises’ priority is to provide a safe and healthy onboard environment to its guests and a safe and healthy workplace to its Employees whether working onshore or onboard. To meet this goal, MSC Cruises complies with all applicable health and safety regulations, including with the strict requirements of the Safety of Life at Sea (SOLAS) Convention and, in some cases, goes even beyond, by implementing CLIA’s policies in relation to operational safety, fire protection, shipboard security and health.
MSC Cruises is committed to undertake business fairly and to uphold all applicable anti- bribery laws in its business dealings worldwide. MSC Cruises strictly prohibits all Corruption, Passive and Active Bribery, and Facilitation Payments.
Employees shall comply with all applicable anti-corruption laws and best practices including but not limited to Swiss Penal Code, and where applicable the U.S. Foreign Corrupt Practices Act and the UK Bribery Act 2010 (hereinafter referred to as “Anti-Corruption Laws”). Employees agree that they will not, offer, promise, pay or authorize the payment of money or anything of value, or take any action in furtherance of such a payment, whether by direct or indirect means to any Government Official or any other private individual to influence the decision of such person in the performance of his duties. Employees shall not accept any bribe or kickback in return for facilitation of a transaction or taking a decision.
A conflict of interest occurs when an Employee’s personal interest interferes with, or appears to interfere with, in any way with the commercial interests of MSC Cruises. Employees should actively avoid any situation that could impact on their ability to act in the best interests of MSC Cruises or that may make it difficult to carry out the agreed work/services objectively and effectively. MSC Cruises requires that its Employees should fully disclose to the MSC Cruises any situations that could reasonably be expected to give rise to a conflict of interest. If an Employee suspects that there may be a conflict of interest, or a situation that others could reasonably perceive as a conflict of interest, such Employee must report it immediately to MSC Cruises.
Sanctions regulations are prohibitions against engaging in specified international transactions involving certain individuals, entities, countries to achieve a national security and/or political objective.
MSC Cruises complies with Swiss and European Union sanctions regulations as well as with any other sanctions regulations applicable to its activities and business dealings worldwide. We expect Employees to comply with all the above mentioned or otherwise applicable sanctions law.
MSC Cruises is committed to complying with the applicable competition regulations (also known as “Antitrust Laws”) at any time, regardless of the location. We expect our Employees to do the same.
Violations of Antitrust Laws are strictly penalized by law, including in many countries by criminal sanctions.
Never make an agreement with competitors (or even appear to agree) to restrict trade, limit production or boycott others, and never exchange sensitive information with competitors (like prices, bids or costs). Be honest about the relationship and transparent in all your dealings.
The accuracy and maintenance of MSC Cruises’ business and financial records is crucial and must be ensured. MSC Cruises is committed to complying with all applicable financial and tax rules and avoiding the commission or facilitation of any form of tax evasion under any applicable legislation, including but not limited to the scope of the UK Criminal Finance Act 2017.
Confidentiality
All Employees must safeguard all of MSC Cruises’ Confidential Information as well as any Confidential Information received from MSC Cruises’ guests, suppliers and any other third parties. Failure to do so could result in a breach of obligations arising under contracts or laws protecting business secrets, data protection, and privacy.
Confidential Information must not in any case be disclosed to anyone outside of MSC Cruises, including to family and friends, except if legally required.
Confidential Information must not be shared with others inside MSC Cruises except on a “need to know” basis. All Employees are obliged to protect Confidential Information, even after business ends.
If you have access to our Confidential Information or intellectual property, it is paramount that you collect, use, and handle it responsibly. Never disclose this information in public (even inadvertently) or to anyone outside of MSC Cruises without our approval.
MSC Cruises’ name and reputation
Employees shall not, without MSC Cruises’ prior written consent,
(i) use MSC’s name or logo in any promotional or advertising materials;
(ii) use their business-relationship with MSC to imply an endorsement by MSC of their goods or services, and
(iii) make any representation or statement for or on behalf of MSC.
MSC Cruises respects and protects the privacy of its Employees, guests, and Business Partners, processing the personal information in accordance with the requirements established by applicable data protection laws.
Personal information is processed fairly and lawfully and for specified and legitimate purposes. MSC Cruises stores the personal information securely and takes precautions to prevent unauthorized disclosure. Any unlawful processing of personal information could be damaging to both the natural person from whom the information is collected and MSC Cruises.
Although at MSC Cruises we operate on the assumption that our ships and our operations never stop, we must always be ready for any challenge or emergency affecting us. Employees must be equally prepared for these circumstances by having contingency plans in place to ensure recovery and restoration of critical business functions during an emergency.
You, as an Employee, could become aware of inside information about us or another company that could influence an investor’s decision to buy, sell or hold stock or securities. If you have information like this, you must keep it confidential and never use it to make investment decisions or tip it to anyone else for their benefit.
Delivering consistent and accurate messaging about us is very important, especially in difficult or in unusual circumstances. Never speak publicly on our Company’s behalf and refer any requests for information to us.
MSC Cruises is committed to conducting business ethically.
An important aspect of accountability and transparency is enabling our Business Partners to voice any compliance concerns in a responsible and effective manner.
Business Partners are encouraged and expected to report any compliance violations or suspected violations of MSC employees that become known to them through:
- Whistleblowing Platform at https://msccexplora.integrityline.com/frontpage
- Email to hotline@msccruises.com