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COMMITMENT 33

Ethics and corporate governance limiting or prohibiting business and procedures, as well as laws and
transactions with countries for which regulations. Management reviews
Costa Cruises’ determination to operate the Code of Business Conduct and economic sanctions are in place. the assessments and updates thereto
ethically and transparently is a pillar of Ethics, which provides the framework With specific regard to compliance, with the Audit Committee.
its model of sustainable development for the formulation of corporate in 2017 we increased the amount In 2017 audits were held fleetwide
and creation of value. In the cruise policies and procedures, thereby of employee training dealing with (15 HESS Audits, one on each ship,
industry, reputation and trust are vital ensuring that various material issues business ethics; this tuition was both and 9 Verification Visits to certify
to success; this also explains why we pay (e.g. diversity and inclusion, business online (mandatory courses for all the progress/closure of corrective
so much attention to ethical standards integrity, conflicts of interest, forms of employees) and offline. actions).
of conduct. The Company operates corruption, environmental protection
by means of investments which, from and sustainability) are always Managing risks
the planning stages to complete considered when making Company and internal auditing SHORE
implementation, typically cover lengthy decisions.
STRATEGIC
periods and accordingly require a long- an Ethics Committee, appointed In Costa Cruises the risk prevention DEVELOPMENT & DIGITAL
term vision and approach. to deal with ethical questions and to and management policy is based
Costa Cruises’ corporate governance prevent - or if necessary manage - on a model developed globally by HUMAN RESOURCES
system is based on international best conflicts of interest, identifying any risk Carnival Corporation and taking CARNIVAL
practices and follows the principles and situations with consequent mapping into account the main international CEAT MARITIME
directives of Carnival Corporation’s and monitoring. Enterprise Risk Management CORPORATE
Code of Business Conduct and an integrated whistleblowing (ERM) standards. FINANCIAL CEO COSTA
Ethics. This Code sets out the system (protected disclosure of any Among the factors occupying a ADMINISTRATION CRUISES
basic principles underpinning the wrongdoing in the workplace) serving prominent position in the risk matrix & CONTROL AIDA
commitment to maintaining the as a hotline between the Company and is accident prevention and – more SHARED SERVICES
highest ethical standards and it is fully its employees. In the last year alone, 77 generally – guest and crew health
embraced and applied by Costa Cruises. reports were received; of these, 26 were and safety, as well as regulatory RISK ADVISORY
found to be partly or wholly substantiated compliance, especially with regard to AND ASSURANCE
Our corporate governance model covers (Data as of april 2018). At the same environmental laws. Other variables SERVICE
four areas: time, in accordance with the MLC2006 include the growing concern
5
and with the specific procedure for with risk factors arising from the CEO
the Business Management Model onboard complaints, any grievances are changing geopolitical situation
(in accordance with the provisions handled autonomously by the shipboard internationally, directly impacting
of Legislative Decree no. 231/2001), HR Director and discussed with the the assessment and management of
which plays a part both in clearly employee concerned; depending on the routes, itineraries and destinations. CARNIVAL MARITIME
allocating responsibility and power nature of the complaint, intervention by Our risk framework is part of the
within the organization and in Costa Headquarters may be required. ERM program, which is facilitated by STAFF ENVIRONMENTAL
guaranteeing the transparency 26 such cases were dealt with in 2017. the Risk Advisory and Assurance CAPTAIN COMPLIANCE
of decision-making and control Services (RAAS) Department. OFFICER
processes. Costa Cruises periodically Our governance model also takes This department works closely HOTEL HR
updates the model to take account account of the ILO core conventions and with management to perform DIRECTOR MASTER DIRECTOR
of critical issues arising from time the OECD Guidelines for Multinational annual assessments, identify risks
CHIEF
to time and to ensure continuous Enterprises, as well as OFAC directives and evaluate controls to ensure ENGINEER CHIEF
SHIP’S DOCTOR
improvement. 5 ILO Convention on maritime labor. compliance with Company policies
SHIP