Frequently Asked Questions

About Responsible Business Conduct

What exactly is Responsible Business Conduct (RBC) or Corporate Social Responsibility (CSR)?

Going above basic legal compliance with local and international laws and regulations, CSR or RBC requires corporations to work with the ten internationally-agreed principles of the UN Global Compact and:

• Regularly manage their operational adverse impacts on these principles, as dictated by the UN Guiding Principles on Business and Human Rights (UNGPs) and the OECD Guidelines for Multinational Enterprises (OECD-GME), and
• Positively contribute to these principles, as guided by the 17 Sustainable Development Goals (widely considered the "blueprint to achieve a better and more sustainable future for all").

In a nutshell, RBC or CSR is how corporations take responsibility for contributing to – while managing their adverse impacts on – internationally-agreed principles for sustainable social, environmental and economic development. To put simply, responsible companies need to make sure that (1) their operations do not negatively impact human (including labour) rights, environment (and climate) and anti-corruption principles, and (2) they proactively contribute to furthering the sustainable development goals.

How does RBC or CSR looks like in a practical context?

In a practical context, a company that implements Responsible Business Conduct standards has succesfully:

• Established a policy commitment that outlines and embeds the company's responsibility to respect human rights, the environment and anti-corruption principles.
• Created a continuous process of due diligence that addresses and documents the company's actual adverse impacts or potential adverse impacts (risks) on the internationally-endorsed principles for sustainable social, environmental and economic development.
• Set up a or been actively participating in a remediation system that enables the remediation of any adverse human rights, environmental or economic impacts the company causes or to which it contributes.

This due diligence process also involves embedding the RBC commitment in all contracts governing relations with the company's business relationship and extending the same requirements of RBC standards to all business relationships. This is known as Responsible Supply Chain Management and the best way to do this is through a process of active collaboration and knowledge exchange, such as the one facilitated by the IMPA ACT initiative.

A company that implements Responsible Business Conduct standards as described above can indisputably claim that it meets the globally-agreed minimum standard for social, environmental and economic sustainability, i.e. the UNGPs and the OECD-GME. The company has, in other words, "a social licence to operate".

What constitute business relationships for the purpose of meeting the minimum standard?

The shipping industry has a global nature and companies build relationships both with their upstream value chain (suppliers) and the downstream value chain (distributors, customers and clients). While a company’s supply chain is usually understood to only be limited to the upstream value chain, the UNGPs and OECD-GME extended the responsibility to respect internationally-endorsed principles for human rights, environment and anti-corruption to all business relationships established by acompany.

Thus, a corporation’s duty to work with CSR covers suppliers, distributors, customers and clients. In the process of responsible supply chain management, however, it is often the case that a company's suppliers will often demand the most resources, so it is a good idea to prioritise this engagement. This is why IMPA ACT primarily facilitates collaboration around CSR between all companies in maritime and their suppliers. This includes collaborative work between ship-owners and their first-tier suppliers, as well as between maritime suppliers and their own suppliers.

Why is meeting the minimum standard for Responsible Business Conduct important?

RBC - when done correctly and in alignment with the globally-endorsed minimum standard (UNGPs and OECD-GME), such as through IMPA ACT - hugely increases a company's visibility in its value chain and allows the company to identify current and potential risks that could endanger its reputation or financial success. Here are some more benefits:

• Fulfil global expectations on CSR - By implementing the UNGPs and OECD-GME, you are complying with the globally-endorsed standard on business and human rights, environment and anti-corruption.
• Manage risks in your supply chain - Regular social, environmental and economic due diligence is preventative and can give you the knowledge to foreseerisks and end, mitigate or prevent them from materialising.
• Ride the wave - Identifying your impacts on human rights, environment andanti-corruption will help you avoid unpleasant surprises andenable you to show how your company respects these.
• Prevent near misses - By regularly identifying impacts on all rights and principles,you become aware of those you may have overlooked andcan prevent them from escalating.

Is the minimum standard on RBC difficult to meet?

Many companies find it challenging to navigate the guides and principles, especially where they cannot benefit from internal CSR expertise. This is where IMPA ACT comes in, a platform for the global shipping industry that not only helps you implement RBC standards internally through in-depth guidance and a state-of-the-art online platform, but also provides an ecosystem for collaborating with your business relationships towards doing the same.

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About IMPA ACT and its Code of Conduct

What exactly is IMPA ACT?

IMPA ACT is a comprehensive initiative offering state-of-the-art support to companies wanting to meet the globally-agreed minimum standard for social, environmental and economic sustainability. Established more than ten years ago under the umbrella of the International Marine Purchasing Association (IMPA), IMPA ACT has been assisting its member companies (ship-owners, ship-operators and maritime suppliers and manufacturers) implementing Responsible Business Conduct standards within their own operations and extending these requirements to and collaborating with their business relationships (primarily suppliers) through Responsible Supply Chain Management. For more information on IMPA ACT, visit here.

What exactly is the IMPA ACT Code of Conduct for Business Relationships?

The Code is a set of social, environmental and economic principles and standards that are based on internationally-endorsed UN minimum expectations for businesses and represent current best practice. The Code is fully based on the UN Global Compact’s ten principle, as derived from the International Bill of Human Rights, ILO’s Declaration on Fundamental Principles and Rights at Work, the Rio Declaration on Environment and Development, the Paris Agreement, and the UN Convention Against Corruption, and made operational by the UNGPs and the OECD Guidelines. In full reflection of the universally-agreed principles for sustainable social, environmental and economic development, the IMPA ACT Code of Conduct is intended to be used as best practice and covers all the requirements that businesses need to meet in order to implement Responsible Business Conduct standards (internally and within their supply chain). More information on the IMPA ACT Code of Conduct can be found here.

Why are there so many principles in the IMPA ACT Code of Conduct for Business Relationships?

It may indeed seem that the IMPA ACT Code of Conduct has a lot of principles and rights included in it. This is mainly because the Code is 100% based on the minimum expectations placed on all businesses to respect human rights, the environment and anti-corruption principles, as endorsed by the international community through the UNGPs and OECD-GME.

This being said, while companies are expected to assess themselves against all principles and rights in order to identify whether they have direct or indirect adverse impacts on them, the vast majority of companies will only negatively impact and therefore need to remediate some of them.

In addition to this, many of these impacts will have already been addressed by most companies, such as occupational health and safety and the protection of labour rights. There are however new challenges covered by the IMPA ACT Code of Conduct that are not traditionally addressed in codes of conduct. For example, the right to privacy can be relevant for companies in respecting their employees' rights and protecting their clients' data.

How can our company and business relationships understand what these rights and principles listed in the IMPA ACT Code of Conduct actually mean and their relevance to the shipping industry?

We know that many of these rights and principles are new and it will take time to understand them all. But not being able to understand a right does not mean that an IMPA ACT member will stop having an adverse impact on that right or that it will not pose a risk to the company in question.

All IMPA ACT members are given access to the SEE impacts Online Platform that helps them conduct regular impact assessments on all these rights and principles, and each right, area and principle is explained at length within the platform.

For those who are still unsure despite the guidance within the platform, IMPA ACT works in collaboration with sustainability consultancy Alexony, and offers member companies a full onboarding process (with a dedicated template for companies operating in the shipping industry), and can also answer questions ad hoc during separate consultancy sessions (separate fees apply in this case).

In what concerns business relationships, your company will be able to share its own impact assessment with your closer partners (directly from the SEE impacts system), and this will allow them to learn from you as they go along and work towards meeting the minimum standard for RBC themselves. Additionally, they are also welcome to become members of the IMPA ACT initiative, thus gaining access to the SEE impacts system and the additional guidance that comes with membership.

Will the IMPA ACT process cause a lot of work internally?

Meeting the minimum standard for RBC is a commitment that needs both time and resources; it is not something that happens overnight. That being said, IMPA ACT is extremely practical and provides step-by-step guidance to members on how to work towards meeting the standard, as well as offers a unified and secure online platform that helps our members conduct their regular impact assessments (due diligence).

The initiative also provides a vast array of resources that come to your support; these can range from knowledge resources that allow you to familiarise yourself with sustainability issues, all the way to tools, calculators and draft content to use while embedding this commitment internally, as well as while working with your business relationships.

Can an IMPA ACT member company provide a simpler Code of Conduct to its business relationships, with only a handful of the rights originally listed?

No. The IMPA ACT Code of Conduct should be provided in its complete form to all suppliers. Changing or removing parts of the code will mean that the member's new code will not be in alignment with international human rights law or the latest UN Guidance on international corporate governance.

Of course, as long as all principles and process requirements of the IMPA ACT Code of Conduct are respected and incorporated into a company's ethical code, the company in question is free to change the layout and wording of the IMPA ACT Code and, where needed, add to it, as long as IMPA ACT is credited.

What happens if a business relationship has a policy of not signing new codes of conduct, such as the IMPA ACT Code of Conduct?

In the vast majority of cases, business relationships are happy to return a signed IMPA ACT Code of Conduct and begin collaboration with their business partner who offered them the opportunity to collaborate. They will commit to working towards the implementation of the necessary policies and procedures to meet - in time - the minimum standard for RBC.

However, in some instances, a supplier, for example, will revert saying that they are unable to return a signed Code because, for example, it is against the policy of the company. In this case, the IMPA ACT member should request a written acknowledgement of the IMPA ACT Code and a commitment to work with its principles (or, if already working with these principles, their latest impact assessment across all human rights, environmental areas and anti-corruption principles). If the supplier is unwilling to do this, it is up to the IMPA ACT member to make an individual assessment of the feasibility of a commercial relationship with a supplier that is unwilling to engage in improving impacts on human rights, the environment and anti-corruption principles.

Do I have to stop engaging with a business relationship if I find out that they have severe issues with their social, economic and environmental compliance?

IMPA ACT is not prescriptive in nature and will not tell you what to do; this is a decision that your company must ultimately make. However, the IMPA ACT system will provide you with a structure to identify blips on your company’s radar and you should be aware that refusing to identify potential impacts means that your company will be navigating blindly. It is naturally expected that all companies will have some adverse impacts on human and labour rights, the environment and anti-corruption principles, and it is understandable that both time and resources have to be allocated in the process of driving social change. What is important here is that you, as a company, are able to clearly communicate to your stakeholders, and know and show that you are working to improve your track record. 

How does IMPA ACT differ from the various ISO standards?

The ISO standards that fall within the remit of the key elements of sustainable development - e.g. ISO 14001 (env) ISO 45001 (H&S) ISO 37001 (corruption) - will tell any collaboration partner that the company have in place a management system covering the area and that a third-party auditor has approved the management system. None of the systems enable transparency about the impacts themselves – this is the main difference – that UNGPs/OECD require a higher level of transparency (about the impacts themselves and not the mere fact that they are managed). Hence many IMPA ACT adopters stop their ISO certification because it is not bringing any value compared to the transparency enabled through the regular operational level impact assessments, i.e. IMPA ACT.

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Questions about IMPA ACT membership

How can I become involved with IMPA ACT?

The easiest way to become part of our initiative is to join us as an IMPA ACT member. Membership fees are proportional to the size of the company and membership unlocks access to the SEE impacts Due Diligence Online Platform, as well a host of tools and documents that help your company meet - in time - the minimum standard for Responsible Business Conduct (and extend the same standard to your business relationships).

IMPA ACT members can also access - outside their membership and at separate fees - options such as a full onboarding service, hours of consultancy and certifications of their work with CSR (once their impact assessments are done).

Membership of IMPA ACT is open to ship-owners, ship-managers, ship-operators, as well as maritime suppliers and manufacturers.

You will sometimes see our database includes some companies that are not IMPA ACT fee-paying members. This is because they are part of the IMPA ACT network by virtue of their partnership with some of their business relationships.

You used to have a supporter status available for free. Why is this not the case anymore?

Behind IMPA ACT is a very small team and, while remaining non-profit, it has become more and more difficult to manage an initiative that was increasingly welcoming a large number of supporters that would not pay into the initiative. It is why we have decided to revert to the old model, where only members get access to all our tools, resources and platforms, and only those who are members or are in an active partnership can become listed in the IMPA ACT Directory. This will mean the IMPA ACT team will have more time to work on new opportunities for knowledge exchange and make sure that - at all times - the initiative maintains its state-of-the-art status.

Does becoming engaged in the IMPA ACT process mean that I will have to audit my suppliers yearly?

No, not at all. In fact, IMPA ACT tries to take the focus away from the ‘check-box’ system of auditing and increase companies' trust in their business relationships. By regularly documenting operational impacts and being willing to share these with one's business relationships, companies simply choose to put their trust with their business relationship rather than a third-party auditor.

All companies are welcome to come to IMPA ACT and ask for a certification of their current impact assessment; what this means is that the IMPA ACT team will have a look at their current impact assessment and carry out a few spot checks to ensure the assessment is done well, truthfully and in a comprehensive manner. This, however, is not a pre-requisite to meet the minimum standard and it is simply for those companies who want to "officially" certify their commitment. A company can meet the minimum standard for Responsible Business Conduct by simply documenting their operational impacts regularly and being transparent about these with all business relationships.

Resources and Guidance

• Ten Principles of the UN Global Compact
• UN Guiding Principles on Business and Human Rights
• OECD Guidelines for Multinational Enterprises