Compliance & Ethics

Anti-Human Trafficking & Smuggling of Migrants Policy

Nautical Resources Sdn Bhd adopts a zero-tolerance approach to human trafficking, forced labour, and smuggling of migrants in all its operations and supply chains.

Sections

  1. Introduction
  2. Objectives
  3. Scope
  4. Definitions
  5. Our Principles
  6. Bribery & Corruption
  7. Gifts, Entertainment & Hospitality
  8. Political Contributions
  9. Donations & Sponsorships
  10. Due Diligence
  11. Record Keeping & Training
  12. Reporting & Whistleblower

Sections

  1. Introduction
  2. Objectives
  3. Scope
  4. Definitions
  5. Our Principles
  6. Prohibited Activities
  7. Recruitment Practices
  8. Supplier Compliance
  9. Due Diligence
  10. Training & Awareness
  11. Record Keeping
  12. Reporting & Whistleblower

1. Introduction

Nautical Resources Sdn Bhd adopts a zero-tolerance approach to human trafficking, forced labour, and smuggling of migrants. Nautical is committed to conducting business ethically and responsibly while respecting and protecting human rights in all its operations.

Human trafficking and the smuggling of migrants are serious criminal offences and violations of fundamental human rights. Nautical is committed to ensuring that its business operations, employment practices, and supply chains are free from exploitation, coercion, or illegal recruitment practices.

Any employee, director, or person associated with Nautical who participates in or facilitates human trafficking, forced labour, or smuggling of migrants will be subject to disciplinary action in accordance with Nautical’s policies, procedures, directives, guidelines, and contractual agreements, including termination of employment or business relationship where appropriate.

2. Objectives

The objectives of this Policy are to:

  • Demonstrate Nautical’s commitment to preventing human trafficking and the smuggling of migrants.
  • Ensure employees and associated persons understand their responsibilities in preventing and identifying exploitative practices.
  • Promote ethical recruitment practices and lawful employment.
  • Provide guidance to employees on how to recognize and report potential human trafficking or migrant smuggling activities.

3. Scope

This Policy applies to ALL employees and directors of Nautical Resources Sdn Bhd, regardless of position, department, or location. Nautical also expects that persons associated performing work or services with, for, or on behalf of Nautical comply with the relevant provisions of this Policy. This includes:
  • Contractors
  • Suppliers
  • Vendors
  • Consultants
  • Recruitment agencies
  • Agents and representatives

4. Definitions

In this Policy, unless the context otherwise requires, the following terms shall have the meanings respectively assigned to them:

Human Trafficking

Refers to the recruitment, transportation, transfer, harbouring, or receipt of persons through the use of force, coercion, deception, fraud, abuse of power, or vulnerability for the purpose of exploitation.

Smuggling of Migrants

Refers to the act of facilitating or arranging the illegal entry of a person into a country of which the person is not a citizen or permanent resident, in order to obtain financial or other material benefit.

Forced Labour

Any work or service that is extracted from a person under the threat of penalty and for which the person has not voluntarily offered themselves.

Exploitation

Includes forced labour, sexual exploitation, debt bondage, servitude, child labour, or other forms of abuse of vulnerable individuals.

Person Associated

Refers to external parties with whom Nautical has or intends to establish a business relationship, including partners, contractors, suppliers, vendors, advisors, consultants, agents, and representatives.

5. Our Principles

  • Nautical conducts all business in a fair, ethical, and responsible manner, respecting the rights and dignity of all individuals.
  • Nautical has a zero-tolerance policy towards human trafficking, forced labour, and the smuggling of migrants.
  • Nautical is committed to complying with all applicable labour laws, immigration laws, and human rights regulations in every jurisdiction where the company operates.
  • Nautical promotes ethical recruitment practices and fair employment conditions for all employees, including migrant workers.

6. Human Trafficking C Smuggling of Migrants

All forms of human trafficking, forced labour, and migrant smuggling are strictly prohibited within Nautical’s operations and supply chains.

Employees, directors, and persons associated with Nautical must not:

  • Participate in or facilitate human trafficking activities
  • Engage in the smuggling of migrants into any country illegally
  • Use coercion, threats, deception, or abuse of power to exploit workers
  • Confiscate passports or personal identification documents of employees
  • Employ workers without proper legal documentation or permits
Any violation of this Policy may result in disciplinary action, termination of employment, termination of contracts, and reporting to the relevant authorities.

7. Recruitment and Employment Practices

Nautical is committed to ethical and transparent recruitment practices. Key principles include:
  • Workers must be recruited lawfully and voluntarily.
  • Workers must not be charged unlawful recruitment or placement fees.
  • Employees must retain control of their passports, identification documents, and work permits.
  • Employment contracts must clearly outline job roles, wages, working hours, and employment conditions.
  • All workers must be treated fairly, respectfully, and without discrimination.

8. Supplier and Contractor Compliance

Nautical expects all suppliers, contractors, and business partners to adhere to ethical labour practices and comply with this Policy. Suppliers and contractors must:
  • Ensure that their operations are free from human trafficking, forced labour, and migrant smuggling
  • Comply with applicable labour and immigration laws
  • Maintain fair working conditions and lawful employment practices
  • Cooperate with Nautical in any investigation or compliance assessment Failure to comply may result in termination of the business relationship.

9. Due Diligence

Departments and relevant units are required to conduct appropriate due
diligence before engaging with third parties such as:

  • Recruitment agencies
  • Contractors
  • Suppliers
  • Vendors
Due diligence may include:
  • Verification of labour practices
  • Background checks on recruitment agencies
  • Compliance verification with labour and immigration laws
  • Review of employment documentation

10. Training and Awareness

Nautical may conduct training and awareness programs to ensure employees understand:
  • The risks and indicators of human trafficking
  • Ethical recruitment practices
  • Responsibilities under this Policy
Employees are required to participate in relevant compliance training when required.

11. Record Keeping

Nautical maintains accurate records relating to:
  • Recruitment processes
  • Employment contracts
  • Worker documentation and permits
  • Compliance with labour and immigration laws
All records must be maintained accurately and in accordance with company policies and applicable legal requirements.

12. Reporting Violations C Whistleblower Protection

Employees and other relevant persons are encouraged to report suspected violations of this Policy, including any incidents related to human trafficking or migrant smuggling.

Reports may be made to:

  • Immediate Supervisor
  • Head of Department
  • Administrative Department
  • Legal Department
  • Internal Audit
Employees reporting violations must ensure that:
  • Reports are made in good faith and based on reasonable grounds
  • They cooperate with any investigation if required
  • Reports are not made with malicious intent
Nautical guarantees that no retaliation or adverse action will be taken against individuals who report concerns in good faith. All reports will be treated with strict confidentiality and investigated appropriately.