ANNUAL REPORTMaritime Anti-Corruption Network2017 Annual Report

MARCH 2018

Letter from the Chair

Contents

Dear colleagues,

Letter from the Chair2

About MACN

3

MACN: Connected to the SDGs

5

MACN’s Scope of Work

72017 in Numbers

9

goods, or favors to carry out business-as-usual operations. These demands have many names: chai (which

Progress on Capability Building

10

means “tea” in Hindi), shai bil yasmeen (Arabic for “jasmine tea”), a refresco (Spanish for “soda”), or even for

Progress on Collective Action

11

Progress on Culture of Integrity

18

I am very excited to be taking on the role of Chair at this critical time for MACN.
Through the efforts of each one of you, we have made great strides in 2017 in our fightagainst corruption in the maritime industry. Many challenges, however, still exist.
Our seafarers and those working in maritime business operations continue to face demands for payments,

an extra schmear (Yiddish for “spread”)—but the effect is the same. These demands are unethical and illegal,
and they endanger the men and women onboard our vessels. But we know that if we work together—andwith a range of stakeholders around the world—we can reduce and eliminate these demands. That is MACN’s
mandate. Collectively, MACN can have a game-changing effect on corruption and bribery around the world,
and that is what we are: a game-changing organization.
The good news is that we made major progress in 2017.
Through our Collective Actions, we have inspired and delivered increased participation in the Suez Canal Say
No campaign; developed a new regulatory framework for the dry-bulk vessel clearance process in Argentina,
trained over 400 stakeholders, and open-sourced guidance to support implementation; enhanced container
tracking in Indonesia; and delivered ethics training for close to 600 government officials in Nigeria.
Our anonymous incident reporting has continued to grow substantially. With over 19,000 incidents of corrupt
practices reported to date, MACN has a strong platform to better understand the challenges and to engage
with stakeholders, including governments, on shared solutions. MACN has also collaborated with othershipping organizations to address the issue of maritime corruption more broadly in the industry and withmaritime regulators.
Last but not least, we now have over 90 companies in our network. Our collective voice and influence grows
with our membership.
As I stated when I was elected chair: “We have a lot of work ahead of us but we have the energy, ideas, andmotivation to get it done.” I look forward to an exciting 2018.
With warm regards,

John Sypnowich, The CSL Group Inc. and Chair of MACN

1.

MACN IMPACT REPORT 20172.

About MACN
Who We Are
MACN was established in 2011 as an industry-led collective action initiative, to stamp out corruption in the

The Maritime
Anti-Corruption
Network (MACN)
is a global business network that provides aunique forum for business to contribute to theelimination of corrupt practices in the maritime
industry. MACN is composed of vessel-owningcompanies within the main sectors of themaritime industry and other companies in theindustry, including cargo owners and service
providers.

maritime industry and to promote inclusive trade. With over 90 companies across the maritime industry,
MACN’s members represent a significant percentage of the total global tonnage and play a key role inocean transport. Since its inception, MACN has become one of the preeminent examples of an industry led
network taking tangible collective action to eliminate corruption across the wider supply chain. By working in
partnership with the industry, governments, and civil society we have been successful in tackling corruption
through country-specific actions in locations as diverse as Nigeria, Indonesia, Egypt, and Argentina.
MACN’s initiatives have been welcomed by these stakeholders and have resulted in tangible outcomes suchas the removal of trade barriers, strengthened governance frameworks, and substantially lower levelsof corruption in maritime trade.

Our Vision
A maritime industry free of corruption that enables fair trade to the benefit of society at large.

Our Mission
To work towards the elimination of all forms of maritime corruption by: raising awareness of the challenges
faced; implementing the MACN Anti-Corruption Principles and co-developing and sharing best practices;collaborating with governments, non-governmental organizations, and civil society to identify and mitigate
the root causes of corruption; and creating a culture of integrity within the maritime community.

MACN Governance
MACN is an initiative under BSR (www.bsr.org), a global business network focused on sustainability. BSR(hereafter referred to as “MACN Secretariat”) provides the secretariat function for MACN.
The MACN Secretariat is responsible for progressing MACN’s strategic workplans (including our 2020
strategy), ensuring good governance, and managing MACN’s “day-to-day” work with its members, third
parties, and funders. MACN’s activities are overseen by the MACN Steering Committee, with active
participation of the full MACN membership.

3.

MACN IMPACT REPORT 2017

4.

MACN: Connected to the SDGs
By engaging in partnerships, conducting capacity building in the shipping industry, andtackling trade barriers, MACN’s activities align closely with the United Nations’ Sustainable
Development Goals (SDGs).

PARTNERSHIPS
SDG 17 | MACN works in collaboration with industry players,

In 2017, MACN mapped its impact and links to

Expanding trade opportunities for low andthe implementation of the SDGs. This work will

middle-income countries by reducing corruption

continue in 2018, but the initial results show thatin the maritime supply chain is an essential part

MACN supports several of the SDGs at both microof integrating these communities into global

and macro levels.

value chains and attracting much-needed capital,

Through the nature of its operations, MACN

technology, and know-how.

is a good example of SDG 17 (Partnerships

At a micro level, we have created a better workfor the Goals), while tackling corruption has aenvironment for seafarers on the trades wherestrong alignment to SDG 16 (Peace, Justice and

MACN has taken action, for example in the Suez

Strong Institutions). Further, at a macro level,

Canal, and have directly promoted responsible

corruption in the maritime sector constitutes

business practices in our industry.

governments, and international bodies to tackle corruption.

PROMOTING RESPONSIBLE PRACTICESSDG 16 | MACN brings a unique business understanding of thedrivers of corruption and can act as a catalyst for change. MACN
works to eliminate opportunities for corruption in ports.

a non-tariff trade barrier that is driving up
trade costs and impeding economic andsocial development, particularly in developing
countries where trade costs are the highest.

CREATING A SUSTAINABLE FUTURE FOR
THE GLOBAL ECONOMY
SDG 2 | MACN strengthens access to food markets by improving
port operations.
SDG 8 | MACN helps local business to develop by making export
and import procedures easier in ports and by being present inchallenging locations.
SDG 9 | MACN supports implementation of new systems to
reduce trade barriers e.g. system upgrades for customs.

5.

MACN IMPACT REPORT 2017

6.

MACN’s Scope of Work
MACN’s work is organized under three key pillars that guide our 2017-2020 Strategy:
Collective Action, Capability Building, and Culture of Integrity. Guided by these focus areas,
members engage at a segment or country level. MACN runs two full group “in-person”
meetings every year (in Dubai and London in 2017). These meetings serve as an important
forum to actively share best-practice, develop group cohesiveness, and move the groupforward on key decision points.

Collective Action:

Culture of Integrity:

Driving and Leading Change in
the Operating Environment
Even if all companies have an internal defense

Being a Recognized Contributor
to Integrity Standards in the
Industry and Society

against unethical practices, these challenges will

Culture of Integrity is an attempt not just tocontinue to exist in the operating environment

generate change for specific stakeholders (e.g.

as long as the root causes of corruption go

Captains or port authorities) in specific corruption

unaddressed. Collective Action is an important

hot-spots, but to drive fundamental change intool to help the private sector take proactive

deep-seated attitudes regarding corruption,

steps to tackle corruption, with companies

creating a permanent trend towards thejoining forces and engaging governments anderadication of facilitation demands.

civil society as a group. In MACN collective
action projects, member companies unite

governments. It has been a successful way towith stakeholders including port and customs

facilitate a constructive dialogue in meetings withauthorities, NGOs, and local governments

governments and other stakeholders. Reporting is

to undertake root cause analyses and thenanonymous and non-attributable: It is not possible

implement a range of “recommended actions”

for anyone to identify who has submitted a report,

to tackle corruption in ports and across theand the incident does not include details thatmaritime supply chain.

would identify specific dates, ships, or individuals.

The essence of the MACN collective action

and stakeholders to all actors in the maritime

approach is that successful, lasting, changes inindustry, and encourage sector-wide alignment

the operating environment will take effect only

on anti-corruption thinking.

Capability Building:
Anonymous Incident Reporting

7.

Providing Industry-Leading
Innovative Solutions to ourMembers
In order for captains and other private sector

MACN’s anonymous incident reporting system

actors to be able to say no to demands forenables maritime players to submit reports on

facilitation payments, they must feel supported

corrupt demands they have faced during port

by strong policies and principles. MACN provides

operation. The outputs of the anonymous incident

a safe forum for engagement through which

reporting allow members to learn from eachmembers can share challenges and best-practice,other to potentially avoid similar incidents in theircollectively assessing the areas for improvement

own operations. The use of the mechanism hasin their internal procedures and approaches, andsignificantly increased over the years. To date,developing open-sourced solutions. Following the

MACN has collected over 19,000 reports of corrupt

MACN Anti-Corruption Principles, MACN develops

demands globally.

shared methodologies, frameworks, trainings,

MACN uses this data to analyze trends inand campaigns, helping each member company tofrequency of incidents, allowing MACN to

While it is vital to address both corporate

target collective action efforts and engage withcapacity to reject payment demands andspecific actors that cause problems for shipping
companies, MACN members recognize that
culture governs the success of achieving deepseated change. To achieve its vision of a maritime
industry free of corruption, MACN must reach out
beyond the collective action of its membershipif they are enabled, supported, and beneficial
to key stakeholders. Through collective action,
MACN members work in partnership with local
authorities to develop solutions that are bothbeneficial to all and realistic to implement.
MACN also recognizes that collective actions
can have a positive impact well beyond our own
industry—due to the volume of world trade thatpasses through ports. Anti-corruption initiatives
targeting ports can have a positive outcome for awide range of industries across the supply chain
and for society as a whole.

strengthen its approach to tackling corruption.

MACN IMPACT REPORT 2017

8.

MACN in 201710

INCREASE IN
MEMBERSHIP

10%
8,600

ANONYMOUS INCIDENTREPORTS+
900

Progress on Capability Building
THE MACN ANTI-CORRUPTION
PRINCIPLES

implementation of anti-corruption complianceFollowing the MACN Anti-Corruption
Principles, MACN develops shared
methodologies, frameworks, trainings,
and campaigns, helping each member
company to strengthen its approach to
tackling corruption.

that are beginning their journey to improve their1.

Compliance Program Requirements

2.

Proportionate Procedures

3.

Risk Assessment

4.

Training & Communications

5.

Monitoring & Internal Controls

6.

Reporting, Discipline & Incentives

7.

Due Diligence

STRENGTHENING PEER
DIALOGUE
maritime industry segment andallowing the industry to discuss

262

REPORTS DIRECTLYRELATED TO THE SAFETY
OF THE SHIP OR CREW

companies that have just joined the network or
anti-corruption and compliance programs.
In 2017, MACN formalized the working group
activities and defined common outcomes.
These activities included:• Best-practice sharing to implement
compliance programs.
• Addressing compliance issues inhot-spot locations.
• Collaborating to develop tools on
ethical conduct.
Participation in these working groups
increased over 2017. In addition, MACN
re-established its tool development andcapability building working group.

DEVELOPING FIT-FOR-PURPOSE
ANTI-CORRUPTION TOOLS
During 2017, MACN completed therevision of tools under the first of

By engaging companies in each

GOVERNMENT OFFICIALS
TRAINED ON INTEGRITY IN
NIGERIA AND ARGENTINA

programs. This has been particularly useful for

specific tools or tackle specific issues, MACN canmore effectively execute its strategy. MACN has
therefore developed industry-specific working
groups to strengthen peer-to-peer dialogue
and address the challenges of corruption. The
purpose of the working groups is to develop
consistent integrity standards defined in
MACN’s anti-corruption principles.

seven MACN principles. These tools
included a Code of Integrity Blueprint, which was
created with input from members, underwent
an external legal review, and was benchmarked
against industry leaders outside the maritime
industry. MACN developed several frontline tools,
including guidance for crew to reject corrupt
demands and placards and posters for the ships.
MACN also began developing a complianceroadmap, which will focus on helping members to
implement anti-corruption compliance programs
and increasing the understanding of all elementsof anti-corruption programs. This work will befinalized in 2018.

The working groups allow members to share
their success stories and lessons learned fromMACN IMPACT REPORT 201710.

SUEZ CANAL, EGYPTProgress on Collective Action

1

The collective actions that MACN has implemented to date have proven to be an impactful,effective, and cost-efficient way to promote trade and transparency and to drive privatesector leadership on combating corruption in the ports and maritime sector.

Focus: Tackle facilitation
demands during Suez Canaltransits by implementing acollective “Say No” campaign.

The following MACN collective action projects in Nigeria, Argentina, Indonesia, and Egypt illustrate theactivities implemented and the results achieved. In addition, MACN has started to map a potential collective
action with the government of India and has gained support for the project from local Indian stakeholders.

Start date: 2015

Challenge: The Suez Canal has been a consistent hotspot for corruption, with Captains facing regular demands
for facilitation payments for passage. Incident data has
further confirmed that transits can be challenging and

SUEZ CANAL

associated with safety hazards to both crew and vessel

Collective ‘Say No’Campaign implemented

when pilots do not cooperate. To tackle challenges likethis MACN launched a “Say No” campaign for the Suez

ARGENTINA
New regulatory
framework, enteredinto force on
November 2017

Canal on International Anti-Corruption Day in 2015.

INDONESIANIGERIA

Implementationof new procedures
and in-port Integrity
Training for over 570
government officials*INDIA

Next project in
the pipeline

New container
tracking IT system
implementationand education

What We Did: The campaign was a true collective

Kevin Leach-Smith, Vice President Operation,
Masterbulk, and MACN Steerco member has beenmonitoring the campaign closely with Masterbulk’s
fleet and shares input from the frontline:“Explaining MACN and the company’s
anti-corruption policy significantly reduces
the risk of demands for cash or in-kindpayments during transits. Our Captains
are relieved of the pressure of dealing withthese corrupt practices and can focus on
the safe navigation of the vessel in the
Canal. Overall, our vessels have had smoothtransits and, with the support of our agents,
they have rejected any type of demand”.

effort, with MACN member companies agreeing toreject demands by using a coordinated zero tolerance
policy, communication material, and an onboard
communication toolkit for Captains developed by MACN.

Overall results:

Progress: Since the launch in 2015, MACN has assessed

Frequency of demands has decreased

the impact of the campaign by surveying members andand it is a sustainable improvementby collecting incident data. The situation has improved
every year, and feedback in 2017 showed that companies
taking part in the campaign are transiting Suez without
any delays or issues. Demands for cigarettes havedecreased dramatically, or have been eliminated, while
threats to the safety of both crew and vessel have also
decreased significantly.

Companies of all sizes are successful
in saying no
Companies across industry segments
are successful in saying no
Nationality of crew is not a barrier
to being successful
Captains find it easier to refuse demands
Pilots are less aggressive andmore forthcoming
Increased participation in the campaign
from MACN members

11.

MACN IMPACT REPORT 2017

12.

2

ARGENTINA
Start date: 2014

Focus: Redrafting
regulations for approvalof a vessel’s holds ortanks for the loading ofagricultural products,
and developing a new IT
system for processing
and registering hold/tankinspections.
Challenge:
Shipping companies operating in Argentina faced
challenges in connection with the inspectionof holds and tanks, customs declarations, andon-board inspection practices. Data from MACN
member companies highlighted a systemic issue
with demands for payment for unclean grain holds,
including cases of extortion.

Partner:
Governance Latam - Guillermo Jorge, Fernando
Basch & Asoc.—a local law firm and wellrecognized integrity champion.

What We Did:
MACN and Governance Latam conducted a factfinding mission to fully understand the natureof the problem before building a strong coalitionof local and global stakeholders. Together, thiscoalition developed and agreed on the key
points for a new regulatory framework thatwould improve operating practices for the vessel
inspection process. This framework was officiallyadopted in 2017—a major success for MACN’scollective action program.

Progress:
The new regulatory framework, which entered into
force on November 1, 2017:• limits inspectors’ discretion by having more
precise definitions and objective criteria for holdor tank rejection.
• introduced inspector rotation in ports andof improper arrangements in certain ports andclient interactions.
• increased the timeframe allowed for remedying
hold deficiencies.
• strengthened control mechanisms by creatinga new Technical Appeals Tribunal, developing
a risk matrix based on which inspections will
be supervised, and established a trustworthy
whistleblowing hotline.
MACN’s local partner also conducted training
around integrity and on the new regulations forhull cleaning and inspections. Over 400 private andgovernment surveyors, private maritime agents,and maritime authorities attended the trainings.

13.

Fernando Basch, Partner at Governance Latam said:

terminals, to reduce collusion and development
Lilian Hansen, MACN member company
representative, commented:“MACN’s project in Argentina has
improved the operating environment
for dry bulk carriers. By changing theprocess and reforming the vesselclearance process for loading grains,
the opportunities for unethical practices
have been eliminated. The process has
increased the efficiency, integrity, andtransparency of inspections, and reduced
the possibility of ships being delayed for
unclear or unfounded reasons. Norden
is proud to have been engaged in thisproject and we encourage customers,
peers and supply chain partners totake part in this positive change.”“The results of the collective action
process started in late 2014 were finallyseen in 2017, with the formalization of
the government’s decision to reformthe system of inspections of vessels
exporting grain, and the implementationof a number of public-private measures
to improve transparency and integrity.
This included the training of surveyors,
maritime agents, and government
officials in the most important Argentine
ports. Implementation has so far beenin line with our expectations, andwe’ll keep working with the different
collective action stakeholders to ensure
the sustainability of this change, which
benefits the maritime industry andArgentina’s foreign trade prospects.”

MACN IMPACT REPORT 2017

14.

3

NIGERIA

Start date: 2012

Focus: Face-to-face
integrity training,
harmonizing operational
procedures in ports, andestablishing grievancemechanisms.

Progress:

Challenge:

MACN’s integrity training program has been

MACN identified Nigeria as one of the mostand private sector stakeholders (for example, 90

challenging countries in which to do business,with corrupt demands posing a major risk tomember companies, and with cases of extortion,harassment, and threats of violence. Moreover,regulations and procedures in ports were lacking
in detail and consistency, giving authorities wide

In 2017, MACN pushed for implementation of
the harmonized procedures in port and vesselclearance procedures (which were launched in2016 as part of this project), and MACN’s local
partner conducted integrity training in the ports
included in the project.
In 2017 we trained over 570 government
officials in the ports of Lagos (Apapa), Lagos(Tin Can), Calabar, Onne, and Port-Harcourt.
welcomed and received high ratings from public
percent felt this exercise was useful or relevant
for their work). The training covered integrity,
corruption prevention, the rationale behind the
new harmonized procedures in the port andvessel clearance procedures, and the Grievance
Mechanism. The training linked well with thediscretionary powers.

Nigerian Presidency’s Executive Orders in 2017,

Partner:

Nigeria.

The Convention on Business Integrity

which focused on ease of doing business inSurveys of MACN members demonstrate
this project is having a positive effect on the

What We Did:

operating environment. For example, MACN

MACN launched its first collective action

a zero-tolerance approach to corrupt demands

project in Nigeria in partnership with the UN
Development Program (UNDP) in 2012. The
project was developed on a multi-stakeholder
approach, involving stakeholders from boththe private and public sectors, and from civilsociety. Guided by UNDP’s risk assessment
methodology, a comprehensive risk assessment
was conducted to identify specific forms ofcorruption, underlying drivers, and actions tomember companies are periodically achieving

Tim Morris, Marine Operations,
Ridgebury Tankers:

Soji Apampa, Convention on Business
Integrity“We were positively surprised that wegot such a prompt reply from the local
authorities through MACN’s local partner.
It really helps to escalate the issues andthese practices need to get attention
from senior government representatives.
We will continue to challenge and escalate
these issues. We are happy that we could
support our Captain in this situation.”“The MACN training for port officials isquite innovative and I think it will leavea lasting impression with the attendees.
We have a few who have asked to be
mentored. This is a great compliment to
the learning experience!”

Member Testimony
A member company called a port in Nigeria andwas cited by authorities for alleged infractions ofimmigration regulations. The Captain found theallegations groundless and suspected that thefines were not valid. The issue was escalated tothe senior government representative through
MACN and our local partner. The unethicalpractices of the port officials were challenged
by senior authority representatives and the ship
sailed promptly and without consequences.

without threats or delays.
However, ensuring sustainable change is an
ongoing challenge. Creating sustainable change
in this operating environment will be a key focus
in 2018. Further, MACN conducted extensive
research on the impact of our activities in Nigeria(government and industry), with these results
expected to be published in 2018.

address root causes across six ports. Since 2013,
MACN has been working with local stakeholders
from the private and public sectors to implement
the actions identified in the assessment.

15.

MACN IMPACT REPORT 2017

16.

4

INDONESIA

Progress on Culture of Integrity

Start date: 2015

Focus: Improving container tracking IT systems,
promoting an e-governance system for cashless
export licenses, integrating whistleblowing into existingprocedures, establishing a stakeholder discussion
forum, and raising awareness of laws and regulationsin Indonesia’s largest container port, Tanjung Priok.
Challenge:

Progress:

The MACN membership reported a lack of

After successfully supporting the upgrade ofawareness of container tracking systems in

JICT’s online system for container tracking,general and a lack of transparency regarding how

MACN published a summary overview of thecontainers are prioritized and when they need to

new container tracking system in the port ofbe relocated.

Jakarta (Tanjung Priok). The summary briefly

Partner:
Kemitraan - The Partnership for Governanceexplained how to track containers in the port
and has been shared with MACN members andrelevant chambers of commerce in Jakarta, with

One of MACN’s strategic priorities is to engage organizations, associations, governments,
and civil society in the fight against corruption. By engaging with other industry
organizations, the shipping industry can gain support to tackle corruption and raiseawareness of the challenges we all face.
In 2017, MACN together with the International Chamber of Shipping (ICS), initiated a cross-industry working
group with the ambition of attracting engagement from traditional industry organizations and associations tocollaborate and address key corruption issues in the shipping industry. By the end of 2017, the working groupwas well established and in 2018 will continue to work on raising awareness of maritime corruption. MACN
also started to explore partnerships with cadet schools in India to share MACN’s Anti-corruption eLearning
designed for Captains, and worked with the World Maritime University on a study to measure ethicalcorporate behavior.

“ICS is a strong supporter of MACN’s work and initiated the cross industry
working group as a joint action with MACN in 2017. By forming thisalliance, the industry will be in a stronger position to leverage its voice
when engaging with the IMO and other institutions on the fight against
maritime corruption, and to demonstrate that corruption can present asafety risk for seafarers as well as being a trade barrier.”
John Murray, Marine Director and Head of the Marine Department f

a view to raising awareness of the new system.

ReformWhat We Did:
To address these issues, MACN and Kemitraan
collaborated with Pelindo II and its subsidiary,
Jakarta International Container Terminal (JICT),
both to consolidate information on existing
resources to support container tracking and to
upgrade JICT’s online system.

17.

MACN IMPACT REPORT 201718.

If you would like more information about how to join MACN, please reach out to the
MACN secretariat: macn@bsr.org.

MACN Members
Regular Members
AET
Ardmore Shipping
BP Shipping
BSM
BW Maritime
CargillCarnival Corporation & plc
China Navigation Ltd.
Clipper GroupCMA CGM
Cosco
Concordia Maritime
CPO Containerschiffreederei
CSSA
CSL Group Inc.
Danish Shipping
Epic Gas
Evergas A/SFednav
Gearbulk
Grieg Star
Hafnia Tankers
Hamburg Sud
Höegh Autoliners
Höegh LNG AS
J.P. Morgan Asset Management
J. Lauritzen
Klaveness AS
K-lineKnutsen OAS Shipping
Kristian Gerhard Jensen Skipsrederi
Maersk Line
Maersk Tankers
Masterbulk Ship Management Plt Ltd
Mitsui O.S.K. Liners Ltd.

Associate Members
Monjasa A/SMSC
MUR Shipping Holdings B.V.
Neptune Lines
NordenNordic Tankers A/SNorvic Shipping
NYK Line
Odfjell Management AS
Petroleum Geo Services (PGS)
Ridgebury Tankers
Rio Tinto Marine
RWE Supply & Trading
Saga
Seaspan
Scorpio Group
Shell International
Solvang ASA
Stena Bulk
Stena Sonangol
Taylor Maritime
Teekay Corporation
TORM
Ultranav
Unifeeder
Union Maritime
UtkilenV.Ships
WallemVroon B.V.
Wallenius Marine AB
Wallenius Wilhelmsen Logistics
Western Bulk A/S
Wilh. Wilhelmsen ASA

Anglo American
Ben Line Agencies Ltd.
BHP Billiton
Bunker Holding
DA-Desk
Danish Shipowners Association
Engie
GAC - Global Hub Services
Glencore
Hydro
Inchcape Shipping Services
Intertanko
Louis Dreyfuss Commodities
Maritima Heinlein S.A.
MF Shipping Group
Norwegian Ship Owners Association
Wallem Shipping Services
Waterfront
World Fuel Services
Yara International ASA

Wilhelmsen Ships Services A/S

www.maritime-acn.org