Mantovani Navigation


of Policy

Mantovani Navigation (the Organisation) is committed to operating in an ethical manner and in compliance with applicable anti-bribery laws and regulations in Cyprus and other jurisdictions in which it operates. It is the policy of MANTOVANI NAVIGATION to prohibit the direct or indirect giving or receiving of improper payments or other benefits for purposes of obtaining any advantage. More specifically, members of Mantovani Navigation may not directly or indirectly:

1. make, promise, approve, authorize, or offer to give to anyone anything of value (including but not limited to cash payments) for the purpose of improperly inducing the recipient to take (or to refrain from taking) action that would bestow a benefit on MANTOVANI NAVIGATION or any other party; or

2. receive or accept anything of value (including but not limited to cash payments), if such item of value is intended to induce or reward improper performance of one’s responsibilities or duties or to gain an improper advantage.

Members of the Organisation should not take any actions for the purpose of evading the requirements of this policy.

For example, a person should not use a Third Party to do anything that is forbidden by this policy. Applicable anti-bribery laws include the Foreign Corrupt Practices Act (“FCPA”), which is a U.S. law that prohibits bribery of foreign officials. The FCPA is interpreted broadly to include not only government personnel but also employees of state-owned entities (e.g., universities, hospitals, and media outlets) and public international organizations (e.g., the United Nations, World Bank Group, and the International Committee of the Red Cross). Various federal and state laws also prohibit bribery of U.S. public officials as well as commercial bribery in the private sector. Some jurisdictions prohibit gifts of any kind to public officials. Many countries in which MANTOVANI NAVIGATION operates also have anti-bribery laws. The anti-bribery laws in jurisdictions such as the United Kingdom and People’s Republic of China can be even more expansive than the laws of the Republic of Cyprus..

Individuals found to violate this policy may be subject to disciplinary action by MANTOVANI NAVIGATION and also may subject themselves and MANTOVANI NAVIGATION to civil and criminal fines and prosecution and significant reputational damage.

of this Policy

The purpose of this policy is to ensure that members of the Organisation conduct business in an ethical manner and understand and adhere to the requirements of all applicable anti-bribery laws and best practices.

of this Policy

This policy applies to all members of the Organisation, wherever located, with respect to their activities for or on behalf of MANTOVANI NAVIGATION or otherwise in connection with MANTOVANI NAVIGATION activities.

for implementation
Dealing with Public Officials
(Including Gifts to / from Public Officials)

While it is the policy of MANTOVANI NAVIGATION to prohibit the provision of improper payments or other benefits to all individuals (in both the private and public sectors), interactions with Public Officials are of heightened concern due to the increased risk for violations of applicable anti-bribery laws. Bribery of Public Officials is against the law in many countries and can result in criminal penalties for the individuals involved as well as for MANTOVANI NAVIGATION.

Public Officials: For such reasons any direct or indirect dealings with Public Officials that involve the provision of anything of value to a Public Official, including, but not limited to, the provision of any Gift/Favor, must be approved in advance by organisation’s compliance.

Non- Public Officials: A Gift/Favor to or from a non- Public Official that meets all of the following criteria is generally permitted:

a) It does not include cash or a cash equivalent (e.g., gift certificates, vouchers, or other items that can be readily exchanged for cash);

b) It is not intended to improperly influence or reward any person regarding any matter or transaction involving MANTOVANI NAVIGATION or another party;

c) It is unsolicited, given infrequently, and given openly, not secretly;

d) It does not breach any other law or MANTOVANI NAVIGATION policy;

e) It is given or received in MANTOVANI NAVIGATION’s name and not in the name of the individual member of the Organisation;

f) It is of an appropriate type and value, given at an appropriate time, taking into account the motive, local custom and laws, and the rules of the employer of the Third Party making or receiving the Gift / Favor; and

g) It has a value of less than US$100.If there are questions about whether a Gift / Favor meets all of the criteria, please contact the Compliance / Legal Advisor.


Facilitating payments are not permissible under this policy other than as specified below. A facilitating payment is a payment made to a Public Official to further routine governmental action (e.g., processing visas, clearing customs, providing police protection, or providing mail services) that is of a non-discretionary nature (i.e., that the official is already bound to perform). A legally mandated administrative fee for expediting government services is not a prohibited facilitating payment (in such cases, a proper receipt should be retained). A facilitating payment may be made by a member of the Organisation or on that person’s behalf to secure the personal health or safety of members of the Organisation from imminent threats of physical harm (mere economic coercion does not satisfy this criterion). Any such payment should be reported to the Compliance / Legal Advisor.

Third Parties

MANTOVANI NAVIGATION may be held liable for the actions of Third Parties acting for or on its behalf. Thus, Third Parties may not engage in activities in which a member of the Organisation may not engage when acting for or on MANTOVANI NAVIGATION’s behalf. To minimize the risk of potential liability resulting from the acts of others, a Third Party may only be engaged after the business unit engaging the Third Party on MANTOVANI NAVIGATION’s behalf performs due diligence to verify that the Third Party is reputable and committed to operating in an ethical and legally compliant manner. Where appropriate based on an assessment of risk, this policy will be communicated to Third Parties and appropriate contractual arrangements will be implemented to ensure compliance by such Third Parties.


To promote this policy, members of the Organisation, including, but not limited to, Senior Administrators, and other staff who may have interactions with Public Officials or Third Parties in the performance of their activities, will undergo periodic compliance training. MANTOVANI NAVIGATION will provide and make available appropriate educational and training programs and resources.

Accounting Books
and Records

Compliance with the accounting and internal control procedures of MANTOVANI NAVIGATION, including, but not limited to, MANTOVANI NAVIGATION’s Business Expenses Policy, Expense Reimbursement Policy, Petty Cash Funds Policy, Purchasing Policies and Procedures Manual, and Sponsored Programs Administration Post-Award Handbook, is mandatory to ensure all accounting records, payments by or on behalf of MANTOVANI NAVIGATION, expenditures, expense reports, invoices, vouchers, Gifts, and any other business expenses are accurately and reliably reported and recorded. False or misleading entries or invoices are prohibited. In addition to being required and governed by applicable accounting standards, maintaining accurate books and records and adequate internal accounting controls is required under many anti-bribery laws and is an international best practice for preventing improper behavior.


Members of the Organisation should report immediately any suspected or actual violations of this policy or anti-bribery laws.

of Violation

Any member of the Organisation who violates this policy may be subject to disciplinary action, up to and including dismissal or expulsion, as applicable. Third Parties who violate this policy are subject to termination of all relationships with MANTOVANI NAVIGATION. Violations of this policy may also result in civil and criminal penalties for such individuals in multiple jurisdictions.


• “Gift/Favor” means anything of value, including, but not limited to, money, stored-value cards, gratuities, commissions, rebates, loans, loan guarantees, payment of debts, transportation, use of property, charitable donations, medical treatments, medication, entertainment, hospitality, travel, internships (paid or unpaid), employment opportunities, admission opportunities, goods, or services.

• “MANTOVANI NAVIGATION” means Mantovani Navigation ltd.

• “Public Official” means (i) any officer or employee of a government or any department, agency or instrumentality thereof (which includes a government-owned or government-controlled state enterprise) or of a public international organization, such as the United Nations; (ii) any person acting in an official capacity for or on behalf of a government or government entity or of a public international organization, any political party or party official or any candidate for

political office (including, for example, consultants who hold government positions or act in an official capacity on behalf of a government, employees of companies owned or controlled by governments, civil servants, administrative and judicial officers, political candidates and members of the military); and (iii) family members and close personal friends of any of the foregoing, even if they are not otherwise associated with a government or public office.

• “Senior Administrators” means, with respect to Mantovani Navigation, the members of Mantovani Navigation‘s leadership team, the directors, officers, and key employees.

• “Third Party(ies)” includes all joint venture partners, agents, contractors, distributors, consultants, vendors, individuals and any other third party representatives retained in connection with the operations of Mantovani Navigation.