Bribery Prevention Policy

The Bribery Act 2010 (the “Act”) came into force in the UK on 1st July 2011. 


The Act represents the most extensive anti-bribery law in the world, and it is SMT's policy to comply strictly with the Act and to require the same from everyone we do business with. 


The Offences of Bribery

What follows is a summary of the provisions of the Act but, as with any summary, not all possible issues that might arise are covered. If you have any questions, please contact


Bribery may include the offering, promising, giving, accepting or soliciting of a financial or other advantage (often on an undisclosed or secret basis) as an inducement or reward for an action which is illegal, improper or a breach of trust. 


Corruption is the type of relationship brought about by bribery.


There are four offences under the Act: two general offences of offering, promising or giving of a bribe (active bribery) and the requesting, agreeing to receive or accepting of a bribe (passive bribery); another separate offence of bribing foreign public officials with the intention of securing business or a business advantage, and a new strict liability “corporate offence” concerning the failure of companies to prevent bribery. 


It should be noted that “facilitation payments” (i.e., small bribes or “grease payments” to facilitate routine government or official action) are clearly prohibited under the Act. This is the case no matter how small the payment or how well-established the practice is in any jurisdiction, unless permitted by applicable written local law, which will be rare.


The Act does not make corporate hospitality illegal, but care must be taken to ensure that such hospitality is not disproportionate. Genuine hospitality and other promotional or business expenditure which seeks to improve the image of a commercial organisation, or to establish friendly relations, is acceptable and reasonable expenditure will not be viewed as bribery. On the other hand, hospitality that is excessive in value or frequency, too lavish according to the usual standards of the industry or leaves the recipient in a position of obligation, may be viewed as bribery. Gifts, hospitality or expenses must be reasonable and proportionate, and must not be offered secretly. Nor should they be made as part of any arrangement where the recipient or donor agrees or expects or has negotiated a particular advantage to be provided in return.


SMT's Policy

SMT has a zero tolerance to bribery and corruption. We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships, implementing effective systems to counter bribery. SMT is pleased to be a member of the Maritime Anti-Corruption Network (MACN). 


Our Suppliers' Code of Conduct outlines what we expect of our suppliers (including all contracting parties, service providers and agents).


The bribery threat and your obligations

SMT's zero tolerance towards bribery extends to all business dealings and transactions in all countries in which we operate.


All employees, consultants, directors, crew and any other service providers engaged by SMT in relation to any matter should be aware of and understand our Bribery Prevention Policy and comply. 


You may be affected by other anti-bribery laws, whether in your own country or another, which may, in some respects, be stricter than the requirements of the Act. You must therefore carefully consider the need to take your own additional measures to ensure that your actions comply not only with our Bribery Prevention Policy and the principles of the Act, but also those other laws.


You must report any suspected instances of bribery or attempted bribery in any matter in which you are acting to your manager, or  so that we can direct you as to the appropriate response. 


All invoices must contain a clear summary of the services performed and claims for disbursements must be fully supported by vouchers and explained.


No act of bribery or corruption can or will be tolerated, bearing in mind that any such act may of course lead to criminal penalties against you and SMT.


If you have any questions, please contact or .


The SMT Board and Legal department safeguard the commitment in this policy to eliminate bribery in all forms supported by: 

  • Code of conduct.
  • Suppliers’ code of conduct.
  • Anti-trust Policy
  • Whistleblower Policy.