Company Policy

GENERAL GUIDELINES FOR SEAROCK OFFHORE SERVICES LIMITED

1. Preamble

These Rules and Regulations embody the Terms and conditions in SeaRock Offshore Services Limited and shall apply to all officers and staff. The Company maintains certain policies to guide its employees with respect to standards of conduct expected in areas where improper activities could damage the Company's reputation and otherwise result in serious adverse consequences to the Company and to employees involved. The purpose of this Policy is to affirm, in a comprehensive statement, required standards of conduct and practices with respect to certain type of payments and political contributions.

2. Purpose And Intention

It is the intention and purpose of the company to promote orderly and peaceful staff/management relations, to have full understanding of and regard for the respective rights and responsibilities of one another and of individual officers

3. Accounts

Searock Offshore Services shall organize its accounting system to conform to the International accounting standard (I.A.S).  The company shall maintain both electronic and paper version of the records and shall be subject to audit each year.

4. Prohibition Of Improper Payments

The Company expects all employees to use only legitimate practices in commercial operations and in promoting the Company position on issues before governmental Authorities. As stated below, "kickbacks" or "bribes" intended to induce or reward favorable buying decisions and governmental actions are unacceptable and prohibited.

No employee of the Company or any Controlled Affiliate acting on the Company's behalf shall offer or make directly or indirectly through any other person or firm any payment or anything of value (in the form of compensation, gift, contribution or otherwise) to any:

  1. person or firm employed by or acting for or on behalf of any customer, whether private or governmental, for the purpose of inducing or rewarding any favorable action by the customer in any commercial transaction; or any governmental entity, for the purpose of inducing or rewarding action (or withholding of action) by a governmental entity in any governmental matter;

 

  1. Government official, political party or official of such party, or any candidate for political office, for the purpose of inducing or rewarding favorable action (or withholding of action) or the exercise of influence by such official, party or candidate in any commercial transaction or in any governmental matter.

In utilizing consultants, agents, sales representatives or others, the Company will employ only reputable, qualified individuals or firms under compensation arrangements, which are reasonable in relation to the services performed.The  Manager’s office will issue from time to time criteria and procedures to be utilized in international transactions with respect to the selection and compensation of sales representatives. Consultants, agents or representatives retained in relation to the provision of goods or services to the Offshore Business must agree to comply with all laws, regulations and Company policies governing employee conduct.

When customer organizations, governmental agencies, or others have published policies intended to provide guidance with respect to acceptance of entertainment, gifts, or other business courtesies by their employees, such policies shall be respected.

5. Political Contributions

The Company will not make any contribution to any political party or to any candidate for political office in support of such candidate, anything of value, in accordance with Article 55(15) of the Constitution of Ghana.

This Policy is not intended to prevent the communication of Company views to legislators, governmental agencies, or to the general public with respect to existing or proposed legislation or governmental policies or practices affecting business operations. Moreover, under this Policy, reasonable costs incurred by the Company to establish or administer political action committees or activities organized to solicit voluntary political contributions from individual employees are not regarded as contributions to political parties or candidates, where the Company may lawfully incur such costs.

6. Reports And Periodic Reviews

Any employee who is requested to make, authorize, or agree to any offer or payment which is, or may be, contrary to this Policy will promptly report such information to the General for redress

Any employee who acquires information (for example, print and electronic media, reports from customers, or statements of individuals involved) that gives the employee reason to believe that any employee is engaged in conduct forbidden by Company Policy, or that any sales representative, distributor, or other person representing the Company in any transaction is engaged in the type of conduct (whether or not in connection with a transaction involving the Company or its products) which, if engaged in by an employee of the Company, would violate this Policy, will promptly report such information to the employee's manager, to assigned company legal counsel, or to the manager in the component having responsibility for financial activity.

Any manager receiving a report as cited above will promptly consult with assigned Company legal counsel and thereafter will, after appropriate investigation, take timely remedial or other action as warranted under the provisions of this Policy. Such manager will also promptly report the matter to higher management.

Specifically in furtherance of compliance with the Sherman Act:

  1. No employee shall enter into any understanding or agreement, whether expressed or implied, formal or informal, written or oral with a competitor limiting or restricting any of the following aspects of the competitive strategy of either party or of the business offering of either party to any third party or parties:-

Price
cost
profit
product or service offering
terms or conditions of sale
production or sales volume
production facilities or capacity
market share
decisions to quote or not to quote
customer or supplier classification or selection
sales territories
distribution methods

  1. Employees should also be aware that participation in standard development and product certification activities, which impact competitors or suppliers, may raise antitrust concerns. Before participating in committees or organizations, which develop standards or certify products, employees should consult with Company legal counsel.

 

7. Discusions And Exchange of Information With Competitors

 

Communication with a competitor on subjects as to which an understanding with the competitor would be illegal is, in antitrust litigation, likely to serve as important evidence of the existence of an understanding, particularly if the communication is accompanied or followed by similarity of action. The prohibitions set forth below are thus intended to avoid antitrust prosecutions which, though based on merely circumstantial evidence, may nevertheless be difficult to defend successfully.

Accordingly, no employee shall discuss with a competitor or any third party acting for a competitor, or otherwise furnish to or accept from a competitor or any third party acting for a competitor, information on any subject as to which an understanding with the competitor is prohibited by paragraph A above on compliance with the Sherman Act unless, in the opinion of Company legal counsel, such discussions or transmittal of information would neither violate the antitrust laws nor furnish a reasonable basis for inferring such a violation. This paragraph does not preclude obtaining competitive information from independent third-party sources who are not acting for a competitor in transmitting the information. However, certain other legal and policy restrictions applicable to transactions with government limit the competitive information that may be obtained from a third-party source.

8. Equal Opportunities

Searock Offshore Services is committed to compliance with laws and regulations designed to prevent discrimination against any individual because of sex, race, color, creed, or age. This includes maintaining an environment which promotes equal employment opportunity and maintaining a work atmosphere free of behavior that is or may be viewed as offensive to any other employee or group of employees. It also includes the right of an employee to be free from sexual harassment, intimidation, hatred and to have the ability to report such incidents without fear of reprisal.

9. Bank Accounts

The company shall operate an Offshore Dollar Account as well as Local Ghana Cedi Account with ECOBANK GHANA.  Signatories to the account shall be by power of attorney.

10. Procurement

All purchases including stationery must be preceded by Local Purchase Order (LPO) duly signed by Manager Authority.  Where the product is to be delivered to a third party, the product must be recorded and accompanied by a Waybill to be signed by receiving officer as prove of delivery

11. Recruitment

All officers appointed into the Company shall undergo a medical examination conducted by a Medical Officer appointed by the Company.

Searock Offshore Services Limited shall have permanent offices at Tema and Takoradi.  Any officer employed by the company shall be deemed to be servant of the two sites.  Any movement between the two sites shall be seen as a transfer without lost of benefit.

12. Hours Of Work

Normal hours of work shall be from 8: am – 4.00 pm with 60 minutes lunch break.  However, marine operation involves 24-hour readiness.  Officers and staff are therefore requested to hold themselves ready for duty even at odd hours.

13. Duties

The duties of an officer/staff shall include the normal duties of the office to which he/she has been appointed and any other duties the Company may call upon him/her to perform.  An officer therefore, shall devote such time as the company directs to the fulfillment of the duties and at all times use his utmost endeavors to promote the interest of the company.

14. Education And Training

The company recognizes the importance of training as a means of improving the efficiency of staff.  The company may undertake to train officers/staff through in-service training, other management and productivity courses both in Ghana and abroad.

15. Travel Expenses, Baggage/Personal Effects

Officers travelling on official duties shall have all expenses associated with the travel including per-diem paid by the company.  These include air fares,limited baggage, and accommodation etc. Other staff/drivers shall also receive per-diem when away from duty station.  Management shall determine the rate of per-diem for each category.

16. Annual Leave

All officers shall be entitled to 45 working days annual leave per annum from 1st January to 31st December.  Staff shall be entitled to 30 working days. Expatriate officers shall be entitled to 20 working days rotational leave every 90 days to visit their family.  The company will decide when leave is to be taken in accordance with operational requirements, although every effort shall be made to follow all requests.  A leave roster will be maintained and made available to officers/staff at any time so that they may have advance notice when leave will be due.  Officers/staff must be prepared to take their leave in piecemeal and submit leave request forms for the approval by the Manager at least 5 days before commencement of leave.17. Casual 17. Leave

An officer may be granted 10 days casual leave annually, if the need arises.  This shall be approved by Manager.  Casual leave may be granted after the annual leave has been exhausted, and shall be set off against leave days earned in the subsequent year.

18. Interrupted Leave

The Company shall endeavor and adhere to leave proposals.  However, if it becomes necessary to interrupt an officer’s leave, he/she shall be paid an allowance equivalent to 50% of his monthly basic salary in addition to transportation to and from office.  All such recalls shall be approved by Manager.

19. Housing

Officers shall be considered for duty post housing and be entitled to accommodation as described in Appendix A.  All other staff shall be paid 20% of basic monthly salary as housing subsidy.

20. Duty Transport

The company shall endeavor to provide transport, if funds are available, to each department for smooth running of the department.

21. Medical Attention

Medical, optical and dental attention for officers/staff, his/her spouse and 3 children up to the age of 18 years shall be provided at the company’s expense.  Such attention shall be provided at any company approved hospital/clinic

22. Group Personal Insurance

The company shall insure all officers against accident and death.  The sum insured for each officer shall not be less than two years salary for the officer concerned.  The company will pursue all claims arising out of the group personal insurance with the insurers on behalf of the insured to ensure fulfillment of the terms of the policy.

When an officer is involved in an accident or injured during and in the course of his employment, declared unfit for work by medical doctor he or she shall continue to receive basic salary up to 1 year and thereafter declared redundant..  In case of death, partial or permanent incapacity as a result of an industrial illness or an accident arising out of and in the course of his employment, an officer, or in the case of death, his next of kin as authorized by court shall receive the entitlements under the group personal accident insurance policy held by the company.

23. Ex-Gratia Awards

When an officer retired on grounds of invalidation or natural death, he shall receive an equivalent of two years’ salary   Staff who leaves the company after five (5) and above years service shall receive 3 months basic salary for each completed year of service

24. Clothing

In order to promote decent dressing within the company, management shall prescribe attire which shall serve as official uniform for all officers and staff.

25. Social Security

The Social Security Scheme shall be applied in accordance with the Social Security Act or any amendment hereof for the time being in force in the country.

26. Provident Fund

Apart from the Social Security Scheme, the company shall institute the Provident Fund which both employee and employer shall contribute for the benefit of all employees.

27. Personal Loans

The company may grant loans/advances to officers/staff to purchase household consumer durables, such as refrigerator, deep freezer, gas/electric cooker, television set, furniture etc. The company may grant loan only to the limit of the float and such loan shall not exceed 50% of officer/staff entitlement.

the company

29. Annual Bonus And Special Awards

The Company will depend largely on 13th month payment to compensate for annual bonus but may grant special awards to deserving staff annually.

 

30. Violation Of The Policy

Violations of the Policy are grounds for discharge or other disciplinary action, adapted to the circumstances of the particular violation and having as a primary objective furtherance of the Company's interest in preventing violations and making clear that violations are neither tolerated nor condoned.

Disciplinary action will be taken, not only against individuals who authorize or participate directly in a violation of the Policy, but also against:

a. Any employee who may have deliberately failed to report a violation of the Policy;

b.Any employee who may have deliberately withheld relevant and material information concerning a violation of this Policy

c.where an employee is accused of violating the antitrust laws, and the employee has relied in good faith on the advice of Company legal counsel after full disclosure of the material facts, no disciplinary action may be taken against the employee under this Policy; and the Company may, within the limits permitted by law, assist in the employee's defense.