Policies & Compliance
GenPro’s policies supporting ethical, transparent, and sustainable procurement.
GenPro’s policies supporting ethical, transparent, and sustainable procurement.
They guide our approach to ethical business practices, sustainability, and responsible procurement, supporting long-term partnerships built on transparency and integrity.
The purpose of this Quality Policy is to establish GENPRO’s commitment to delivering consistent, high-quality and ethical services to its Members, while ensuring continual improvement and compliance with applicable regulatory, contractual, and international standard requirements.
This policy applies to all employees, and any other parties acting on behalf of or in connection with GENPRO’s activities.
GENPRO is dedicated to ensuring that this policy is effectively communicated to all employees, as well as to any contractors working with or on behalf of the company, and to the general public. Moreover, the company pledges to allocate all required resources for the successful implementation of this policy in line with the Management System.
This policy covers all processes related to supplier selection and evaluation, framework agreements, performance monitoring, sustainability initiatives, and value-added services delivered to Members.
Quality: The degree to which GENPRO’s procurement services consistently meet Members’ requirements, applicable standards, and regulatory obligations while delivering measurable value.
Quality Management System (QMS): The part of GENPRO’s Management System that establishes policies, processes, objectives, and controls to ensure consistent service quality and continual improvement.
Management System (MS): An integrated system that combines GENPRO’s quality, compliance, anti-bribery, sustainability, and operational controls to ensure effective, ethical, and transparent business operations.
Members: Ship management companies and related entities that have entered into a Membership Agreement with GENPRO.
Contracted Suppliers: External entities contracted by GENPRO to provide goods or services to its Members under approved agreements.
Service Providers: Any individual or entity, other than GENPRO employees, providing services to or on behalf of GENPRO.
GENPRO is committed to being the best independent procurement company, delivering the highest standard of quality and ethical services to its Members. In pursuit of excellence, GENPRO upholds the following principles:
Building Comprehensive Quality Repositories: GENPRO endeavors to establish and maintain the most relevant, competitive, and comprehensive quality repository of supply contracts worldwide to support Members’ operational needs.
Ensuring Honest and Transparent Dealings: GENPRO upholds honesty and transparency in all business dealings, fostering ethical conduct and fair competition among Suppliers, Service Partners, and all business associates.
Strengthening Sustainable Partnerships: GENPRO is committed to developing and sustaining partnerships built on mutual benefit through innovative and tailored solutions.
Trust and Integrity: Trust is the cornerstone of our relationships. GENPRO is dedicated to creating and upholding relationships of complete trust between all partners, conducting itself with integrity at all times.
GENPRO aims to capitalize on the “Best Practices” and “Collective Strengths” of its Members by commercializing the procurement of maritime products and services.
GENPRO strives to enhance procurement efficiency, drive cost efficiencies for Members’ vessels, and return real value to vessel owners through transparent and auditable volume-related discounts.
Respect: GENPRO treats employees, clients, Suppliers, and business partners with respect and dignity. We respect and protect the environment and are socially responsible.
Trust: GENPRO builds trust through transparency and ethical conduct, maintaining integrity at all times.
Accountability: GENPRO takes responsibility for its actions and results while actively seeking solutions that benefit the Company and its Members.
Teamwork: GENPRO believes collaboration strengthens performance. Employees support one another personally and professionally.
Passion: GENPRO takes pride in its work and remains dedicated to understanding Members’ needs through quality, commitment, and determination.
Responsible for understanding and complying with this Policy, performing duties in accordance with approved procedures, contributing to continual improvement, and reporting quality issues and improvement opportunities.
Responsible for implementing this Policy within their departments, ensuring employee awareness and compliance, monitoring operational performance, and initiating corrective and preventive actions where required.
Accountable for approving and endorsing this Quality Policy, ensuring alignment with GENPRO’s strategic direction, providing adequate resources, and reviewing quality performance during Management Reviews.
Expected to comply with applicable quality, ethical, and contractual requirements, support GENPRO’s quality objectives, and cooperate in audits, reviews, and corrective actions.
The effectiveness of this Policy shall be monitored through:
This Policy shall be reviewed at least annually, or as needed due to organizational, regulatory, or operational changes.
Records related to this Policy include:
All records shall be securely maintained and protected against unauthorized access in accordance with GENPRO’s document control and retention procedures.
GENPRO is committed to conducting its business in a manner that supports long-term economic viability, social responsibility, and environmental stewardship, while maintaining the highest standards of ethical conduct, transparency, and compliance.
This includes a commitment to conduct all sustainability initiatives in accordance with GENPRO’s Anti-Bribery Policies, ensuring that environmental and social goals are achieved without compromise to ethical standards or compliance obligations.
This Policy establishes the principles that guide GENPRO’s sustainability approach and provides the framework within which sustainability strategies, initiatives, and action plans are developed and implemented.
This Sustainability Policy applies to GENPRO, its employees, Members, Contracted Suppliers, and Service Providers, and covers all activities related to procurement, supplier engagement, operations, and stakeholder interaction conducted by or on behalf of the Company.
The Policy applies at all times during employment, membership, or contractual engagement with GENPRO and across all geographical locations where the Company operates.
Sustainability Strategy: The structured set of objectives, principles, initiatives, and action plans developed by GENPRO to integrate sustainability considerations into its procurement activities, operations, and stakeholder engagements.
Social Responsibility: GENPRO’s commitment to respecting human rights, promoting fair labor practices, supporting employee well-being, and contributing positively to the communities and stakeholders impacted by its operations.
Sustainability Initiative: Any program, activity, or action undertaken by GENPRO to advance environmental protection, social responsibility, ethical sourcing, or responsible business practices in line with this Policy.
Stakeholders: Individuals or organizations that can affect, be affected by, or perceive themselves to be affected by GENPRO’s activities, including employees, Members, Contracted Suppliers, Service Providers, regulators, and business partners.
Non-Financial Controls: Policies, procedures, processes, and governance measures implemented to manage risks, particularly bribery, related to procurement, operational, commercial, human resources, legal, regulatory, and other non-financial activities.
Ethical Conduct: Behavior that aligns with GENPRO’s Code of Business Ethics and Conduct, Anti-Bribery Policy, and applicable laws and regulations, emphasizing integrity, transparency, and accountability.
Members: Ship management companies and related entities that have formally joined GENPRO under a Membership Agreement to benefit from its centralized procurement services, volume-related discount, supplier management, and related activities.
Contracted Suppliers: Companies or entities that have entered into an agreement with GENPRO to provide goods, materials, equipment, or services to its Members.
Service Providers: Any individual or legal entity, other than GENPRO employees, that provides goods or services to or on behalf of GENPRO under a contractual agreement. This includes, but is not limited to, consultants, outsourced contractors, professional service firms, and third-party companies offering specialized or general support services.
For GENPRO, sustainability is defined as:
“The profitable, socially responsible, and ethical coexistence of GENPRO, its Members, and its contracted Suppliers.”
This definition reflects GENPRO’s role as a procurement organization operating within a complex global supply chain and emphasizes value creation without compromising ethical standards or compliance obligations.
To become the socially and environmentally responsible procurement partner of choice within the marine and trading ecosystem.
GENPRO’s mission is to embed sustainability principles throughout the procurement lifecycle, generating measurable value and efficiencies for its Members and Suppliers through a transparent, responsible, and sustainable manner.
GENPRO’s sustainability approach is guided by the following core principles:
Transparency: GENPRO operates in a transparent and measurable manner, ensuring openness in decision-making, supplier engagement, and stakeholder communication.
Consistency: GENPRO applies sustainability principles consistently across all operations, relationships, and geographical regions, fostering trust and long-term partnerships.
Innovation: GENPRO encourages innovation and the responsible use of technology to enhance sustainability performance across procurement and supply chain activities.
Excellence: GENPRO strives for continuous improvement and service excellence, supporting sustainable growth for the Company and its stakeholders. This commitment is reinforced through investment in talent development, enhancement of digital skills, and the strengthening of cross-functional capabilities among GENPRO employees.
Ethical Conduct and Anti-Bribery Commitment: GENPRO applies non-financial controls to ensure that sustainability objectives are pursued ethically, transparently, and without exposure to bribery or corruption risks, in line with ISO 37001 requirements.
No sustainability objective, environmental benefit, or social initiative may justify or excuse unethical conduct or non-compliance.
This Policy is a controlled document within GENPRO’s Management System and shall be:
Line Managers are responsible for ensuring that each employee under their supervision signs the Policies Acknowledgment Form (Form-015).
In the absence of a dedicated HR Department, Top Management will ensure that all signed and completed Policies Acknowledgment Forms are held on individual personnel files.
The Company is responsible for recording any details relating to employees who have not adhered to this Policy in the respective employee’s personnel file, maintained in Cyprus, Singapore, and India.
The purpose of this Policy is to establish a commitment and controls to ensure full compliance with applicable anti-bribery laws, including the UK Bribery Act (UKBA), U.S. Foreign Corrupt Practices Act (FCPA), ISO 37001 standards, and relevant local regulations, and to promote a culture of ethical conduct within GP General Procurement Company Limited (GENPRO)’s business operations and its dealings with Members, Suppliers, service providers, and other third parties.
This Policy applies to all GENPRO employees (permanent and temporary), Service Providers, consultants, Contracted Suppliers, Members, and any other party acting on behalf of GENPRO or any other person associated with the company.
It also covers different form of bribery as follows:
Permitted expenditures such as business meals, modest hospitality, or customary social amenities are acceptable only if these are reasonable, transparent, and approved by the Top Management in compliant with company procedures.
Bribery: Offering, promising, giving, accepting, or soliciting of an inducement or reward, loan, advantage, or benefit of any kind to a person in a position of trust or power, including a public official, with the intent to influence that person’s judgment, decision, or conduct, or to obtain an improper advantage for GENPRO or any related party. It may be monetary or non-monetary and includes gifts, hospitality, employment offers, or facilitation payments.
Direct bribery: When a GENPRO employee personally request or offers a bribe.
Indirect bribery: The bribe is offered through a third party such as a service provider, consultant, supplier, or business partner.
Facilitation payments: Sometimes called “grease payments,” are small unofficial payments made to secure or expedite routine governmental actions such as processing permits, customs clearance. These kinds of payments are strictly prohibited under this Policy, regardless of local practices or customs.
Business Associate: Any external individual or entity with whom GENPRO has or intends to establish a business relationship such as Members, Suppliers, service providers, consultants, and joint-venture partners.
Members: Ship management companies and related entities that have formally joined GENPRO under a Membership Agreement to benefit from its centralized procurement services, volume related discount, supplier management, and related activities.
Contracted Suppliers: Companies or entities that have entered into an agreement with GENPRO to provide goods, materials, equipment, or services to its Members.
Goods and Service Providers: Any individual or legal entity, other than GENPRO employees, that provides goods or services to or on behalf of GENPRO under a contractual agreement. This includes, but is not limited to, consultants, outsourced contractors, professional service firms, and third-party companies offering specialized or general support services.
Anti-Bribery Function: A designated person or department responsible for overseeing the implementation, monitoring, and continual improvement of the Company’s Anti-Bribery Management System (ABMS). For GENPRO, this responsibility is given to the Compliance and Sustainability Department.
The company do not tolerate any form of bribery, whether direct or indirect, involving employees, public officials, private entities, or business partners. This includes offering, giving, requesting, or accepting payments or benefits intended to influence decisions or secure an improper advantage. GENPRO is committed to:
The Company also recognizes that it may be held liable for bribery committed or attempted by the third-party representatives, consultants, agents, or business partners with whom it does business. All medium to high-risk third parties are therefore subject to risk-based due diligence while third parties at all risk levels must agree to comply with GENPRO’s Anti-Bribery Policy, Code of Conduct, and contractual compliance clauses.
The company’s commitment to ethical business is strongly established in its existing Anti-Bribery Policy, which has been a part of the company’s Management System. To further reinforce this commitment, GENPRO has integrated the Anti-Bribery Management System (ABMS) into its Management System (MS) in alignment with ISO 37001.
The ABMS introduces a more systematic and risk-based methods in managing bribery risks within the company’s business operations and third-party engagements. It also reflects the company’s strategic direction, obligations, and is structured around the following key principles:
To ensure effective implementation, the ABMS includes the following operational mechanisms:
While the Compliance & Sustainability Department facilitates and monitors ABMS implementation, every employee remains responsible for complying with this policy and the related controls, in accordance with their role and exposure to bribery risk.
A visual overview of how the ABMS connects with these responsibilities is available in the ABMS Process Diagram (Rec-012).
Facilitation payments or “grease” are a form of bribery made for the purpose of expediting or facilitating the performance of a public official for a routine governmental action, and not to obtain or retain business or any improper business advantage.
GENPRO strictly prohibits these kinds of payments, regardless of local customs or practices.
GENPRO employees are strictly prohibited from requesting, offering or accepting any gifts, regardless of value (zero-tolerance).
Similarly, its business associates and any third parties doing business with or seeking to do business with GENPRO must not, under any circumstance, offer, give, request, or accept any gift, entertainment, hospitality, or other similar benefit whether monetary or non-monetary that could reasonably be perceived as intended to influence, or capable of influencing, any business decision or relationship with GENPRO.
Corporate courtesies are subject to assessment by the Line Manager, while acceptance may be permitted only for customary corporate gifts of negligible value, such as seasonal courtesy gifts, provided that transparency, assessment, and recording requirements are met.
GENPRO recognizes that improper or unauthorized financial transactions can be used as a means of concealing bribery. To prevent such risks, all financial transactions must be authorized, accurately recorded, and traceable in GENPRO’s accounting system. Dual approvals, segregation of duties, and periodic audits are implemented.
Improper financial transactions and accounting irregularities include, but are not limited to:
Any suspected or confirmed case of financial irregularity must be reported immediately to the Anti-Bribery Function (ABF) and the Top Management through the official report or whistleblowing channels.
Failure to comply with these provisions is a serious breach of GENPRO’s Anti-Bribery Management System (ABMS) and may lead to disciplinary action, up to and including termination of employment, contract suspension, or legal proceedings.
GENPRO does not make political donations or contributions, whether in cash or kind, as these may be perceived as attempts to gain improper advantage.
GENPRO supports ethical and transparent charitable activities, but it ensures that all donations are:
All employees and business associates must:
Line Managers/Department Heads are responsible for promoting an ethical work culture and ensuring that their teams understand and comply with this Policy.
The Top Management has overall accountability for ensuring this Policy complies with legal and ISO 37001 requirements.
The Compliance & Sustainability Department, as the designated Anti-Bribery Function (ABF), holds day-to-day responsibility for monitoring, implementation, and continuous improvement of this Policy.
All Members are responsible for ensuring that any recommended Suppliers meet GENPRO’s ethical and anti-bribery standards.
All Contracted Suppliers are responsible for complying with this policy, implementing effective controls to prevent bribery within their operations, ensuring that all dealings with GENPRO and its Members are ethical and transparent, and promptly reporting any suspected or actual bribery connected to their engagement with GENPRO.
All Goods and Service Providers are responsible for complying with this policy, conducting their services with integrity, avoiding any improper advantages, and ensuring that their employees and subcontractors always meet GENPRO’s anti-bribery expectations.
Violations of this Policy or applicable laws may result in disciplinary action, including termination of employment or contract agreement, and may expose individuals and GENPRO to legal liability.
The Company may, under certain circumstances, be liable for bribes, or attempted bribes, made or offered by third-party agents, representatives, consultants and other Business Partners (including joint venture partners) with whom it does business.
The Company may also be liable for the prior acts or omissions of businesses that the Company acquires or with which it enters into joint ventures. Corrupt offers and payments through intermediaries, agents (indirect payments) may also create liabilities for the Company.
Every employee must remain vigilant to ensure third parties’ compliance with this policy. In addition, no employee of the Company may make payments to any third party if they have any understanding that the payment will be used in full or partly for an act of Bribery.
As a company’s commitment to anti-bribery, it shall implement a decision-making process when due diligence reveals that the existing anti-bribery controls are inadequate to mitigate the risks. It applies to any transaction, projects, activities and relationships by GENPRO to its business associates or third parties acting on its behalf.
All decisions shall be documented and communicated formally to the third party and recorded in accordance with Termination of GENPRO Supplier Agreement (Section 23.8) and/or ABMS High-Bribery Risks Escalation (Section 23.66).
Concerns or suspicions of bribery should be reported immediately through any of the following channels:
Reports made in good faith will be treated confidentially and protected under the Whistleblower Policy (Section 8.14).
All employees shall undergo mandatory ABMS training during onboarding and periodic refreshers thereafter.
High-risk roles in Commercial, Accounts, Compliance & Sustainability, HR, and Business Development and the Top Management receive targeted training on anti-bribery controls.
This Policy shall be communicated to all employees, Contracted Suppliers, Members, Good/Service Providers and business partners at the start of each engagement and contract renewal.
The Compliance & Sustainability Department monitors the effectiveness of this Policy and review it annually, or as needed based on legal, regulatory, or operational changes. Internal audits and Management Reviews shall evaluate compliance performance and identify areas for improvement.
The Compliance & Sustainability Department shall maintain, secure, and manage this Policy and all Anti-Bribery-related records, such as approvals, declarations, due diligence documentation, risk assessments, gifts and hospitality registers, training evidence, and investigation files, in line with GENPRO’s document control and retention procedures.
At GENPRO, we are committed to upholding the highest standards of integrity, professionalism, and sustainability in the maritime procurement industry.
The GENPRO Code of Conduct establishes our principles and expectations from all our stakeholders when working with or on behalf of GENPRO. These standards reflect GENPRO’s unwavering commitment to ethical practices, mutual respect, and long-term value creation.