Effective Date: May 7, 2026
Company: Allied Yacht Transport, LLC
Approved by: Vadim Yegudkin, President
Allied Yacht Transport, LLC is committed to conducting business honestly, ethically, and in compliance with applicable anti-bribery, anti-corruption, sanctions, trade, and financial crime laws.
This Policy sets out the Company's standards for preventing bribery, corruption, improper payments, kickbacks, facilitation payments, and other unethical conduct in connection with yacht transport, marine logistics, chartered vessel operations, port services, bunker procurement, customs, documentation, and related commercial activities.
This Policy applies to all officers, employees, contractors, representatives, consultants, vendors, suppliers, agents, intermediaries, and other third parties acting for or on behalf of the Company.
The Policy applies to dealings with both government officials and private commercial counterparties, including port authorities, customs officials, canal authorities, agents, vessel interests, suppliers, brokers, customers, and logistics providers.
The Company prohibits bribery and corruption in any form. No person acting for or on behalf of the Company may offer, promise, authorize, request, accept, or provide anything of value to improperly influence a business decision, secure an improper advantage, or obtain preferential treatment.
This prohibition applies regardless of whether the benefit is offered directly or through a third party.
The Company prohibits bribes, kickbacks, hidden commissions, improper rebates, facilitation payments, unofficial payments, and any other payment or benefit intended to improperly influence a decision or action.
Prohibited conduct includes improper payments or benefits connected to port services, customs clearance, canal transit, vessel scheduling, documentation, cargo handling, fuel supply, logistics services, vendor selection, or customer transactions.
False invoices, misleading descriptions of services, inflated charges, off-book payments, cash payments without documentation, and disguised commissions are prohibited.
No employee, contractor, agent, supplier, or representative may offer, promise, authorize, or provide anything of value to a government official, port official, customs official, canal authority representative, vessel representative, supplier, broker, customer, or commercial counterparty for the purpose of obtaining an improper advantage.
The term ‘anything of value’ includes money, gifts, hospitality, travel, entertainment, employment opportunities, discounts, charitable donations, sponsorships, favors, or any other benefit.
Reasonable and customary business hospitality may be permitted only when it is modest, transparent, lawful, properly recorded, and not intended to improperly influence a business decision.
Cash gifts, cash equivalents, excessive entertainment, luxury travel, hidden commissions, and hospitality connected to pending decisions or approvals are prohibited.
Any employee or representative who is unsure whether a gift or hospitality is appropriate must seek guidance from Company management before offering or accepting it.
Facilitation payments are prohibited. These include unofficial payments made to speed up, secure, or influence routine government or administrative actions such as port clearance, customs processing, document handling, inspections, or similar services.
If a payment is requested in circumstances involving personal safety or security concerns, the matter must be reported to Company management as soon as reasonably possible.
Charitable contributions and sponsorships must be legitimate, transparent, accurately recorded, and not used to obtain an improper advantage.
Political contributions on behalf of the Company require prior approval from Company management and must comply with applicable law.
The Company will not use charitable donations, sponsorships, or political contributions as a substitute for improper payments.
The Company expects its agents, vendors, suppliers, contractors, brokers, consultants, and other third parties to conduct business ethically and in compliance with applicable anti-bribery and anti-corruption laws.
The Company may conduct reasonable due diligence before engaging counterparties, particularly where services involve port operations, customs, canal transit, government interaction, bunker supply, vessel agency, or logistics services.
Third parties may not make payments or provide benefits on the Company's behalf that the Company would not be permitted to make or provide directly.
All transactions must be accurately and completely recorded in the Company's books and records. Payments must be supported by legitimate invoices, contracts, receipts, delivery confirmations, or other appropriate documentation.
The Company prohibits false, misleading, incomplete, or disguised accounting entries. Payments should be made to the contracted counterparty, through normal banking channels, and in accordance with approved commercial terms.
Unusual payment requests, including requests for cash, third-party payment accounts, unrelated jurisdictions, or vague service descriptions, must be escalated to Company management before payment.
The Company may review counterparties for compliance risk, including ownership, reputation, sanctions exposure, payment details, role in the transaction, and reasonableness of compensation or fees.
Higher-risk relationships may require additional review, documentation, contract protections, or management approval before engagement.
Employees, contractors, representatives, and business partners are expected to report suspected bribery, corruption, improper payments, unethical conduct, or violations of this Policy.
Reports may be made directly to the President or other Company management. The Company will review concerns in good faith and take appropriate action.
The Company prohibits retaliation against anyone who reports a concern in good faith, refuses to participate in improper conduct, or cooperates with a review of a compliance concern.
Good-faith reporting is protected even if the concern is not ultimately substantiated.
Violations of this Policy may result in disciplinary action, termination of employment or business relationships, cancellation of contracts, withholding of payment where permitted, and referral to legal counsel or authorities where appropriate.
Business partners that violate this Policy may be removed from consideration for future work with the Company.
The Company may communicate this Policy to employees, contractors, agents, suppliers, and other relevant business partners. Where appropriate, the Company may request acknowledgements, certifications, or contractual commitments regarding anti-bribery and anti-corruption compliance.
Company management is responsible for reinforcing the standards in this Policy and providing guidance when questions arise.
Company management is responsible for maintaining this Policy, reviewing compliance concerns, and ensuring that business is conducted in a lawful and ethical manner.
This Policy may be reviewed and updated periodically to reflect business needs, legal developments, and operational requirements.