Anti -Trust Policy
1. Purpose and scope
ID Shipping Agency is committed to fair competition and independent commercial
decision-making. This policy applies to its owner, managers, employees and persons acting on its
behalf in ship agency, shipyard coordination, procurement and related services. The Company
shall comply with applicable competition laws, including Turkish, European Union, United Kingdom
and United States rules where applicable to its activities.
2. Independent pricing and commercial decisions
Agency fees, discounts, margins, quotations, service terms and tender participation shall be
determined independently. No employee or representative may agree with a competitor to fix or
coordinate prices, surcharges, discounts, output or other competitive terms. Public information
and the Company's own costs may inform independent decisions.
3. Prohibited arrangements
The Company prohibits agreements or understandings with competitors to divide customers,
vessels, ports, shipyards, territories or services; rig bids or submit cover bids; rotate tender
winners; withdraw bids by agreement; or unlawfully coordinate refusals to deal. Informal
discussions, verbal arrangements and messages are covered equally with written agreements.
4. Commercially sensitive information
Non-public current or future fees, quotations, costs, margins, customer plans, tender strategies
and capacity plans shall not be exchanged with competitors without prior management approval
and appropriate legal review. Information received from customers or suppliers shall not be used
to coordinate competing offers. Publicly available information may be used lawfully.
5. Industry meetings and competitor contacts
At trade association meetings, maritime events and other competitor contacts, discussions shall
remain within legitimate business purposes. If an inappropriate topic arises, the representative
must clearly object, end the discussion or leave, record what happened and promptly report it to
management
6. Suppliers, subcontractors and cooperation
Supplier and subcontractor selection shall be based on independent commercial criteria, including
quality, reliability, safety and value. Representatives must not use an intermediary to arrange
prohibited coordination. Joint bids, exclusivity, competitor cooperation and information-sharing
arrangements require management review and specialist advice where needed. The Company
shall not engage in unlawful exclusionary conduct or abuse a dominant market position.
7. Reporting and incident response
Suspected breaches and questionable requests must be reported promptly to the Owner / General
Manager. If that person is involved, the concern may be raised with an independent external
adviser or the relevant authority. Good-faith reporting shall not result in retaliation. Management
shall preserve relevant records, investigate promptly and obtain specialist advice when required.
No person may conceal, destroy or alter evidence or obstruct a lawful investigation.
8. Implementation, training and records
Following approval, management shall communicate this policy to relevant employees and
representatives and obtain acknowledgements. Relevant personnel shall receive induction
guidance and refresher training at least annually, with additional guidance when risks change.
Attendance and signed completion records shall be maintained. This policy establishes
requirements from its effective date and does not certify that training or controls existed before
adoption.
9. Responsibility, review and enforcement
The Owner / General Manager is responsible for implementation, reviewing relevant competitor
contacts and tender practices, maintaining policy and training records, and addressing concerns.
This policy shall be reviewed at least annually and following a significant incident or legal change.
Breaches may result in corrective measures, disciplinary action or termination of a business
relationship, subject to applicable law.
10. Management approval
By signing below, management adopts this policy and commits to communicating and
implementing its requirements. The policy becomes effective on the actual date of signature.
ID Shipping Agency | IDSA-COMP-001 | Version 1.0