Anti-Corruption Policy

1. Introduction 

Combating Corruption. Global Fishing Watch (GFW) operates in a wide range of legal and business environments, and throughout its operations, is committed to avoiding both actual and appearances of impropriety in the actions of its directors, officers, employees and agents.

Global Fishing Watch requires its staff which includes directors, officers, employees and contractors to observe high standards of business and personal ethics in the conduct of their duties and responsibilities.  Any GFW agent is also required to observe this policy. 

Accordingly, this Anti-Corruption Policy reiterates our commitment to integrity and explains the specific requirements and prohibitions applicable to our operations under our ethical standards and the anti-corruption laws in place in every country where we have a presence.  Such laws include, but are not limited to, the U.S. Foreign Corrupt Practices Act, the Canadian Corruption of Foreign Public Officials Act, Mexico’s Law Against Corruption in Public Procurement, the U.K. Bribery Act, and Brazil’s Clean Company Act.  This Policy contains information intended to reduce the risk of corruption and bribery from occurring in Global Fishing Watch’s activities. Global Fishing Watch strictly prohibits all forms of corruption and bribery and will take all necessary steps to ensure that corruption and bribery do not occur in its activities. 

It is illegal for Global Fishing Watch and its subsidiaries, directors, officers, employees and agents, to bribe government officials. The concept of prohibiting bribery is simple.  However, understanding the details of what constitutes a bribe is essential as it directly affects everyday interactions between Global Fishing Watch and governments, and government-owned or government-controlled entities. 

Bribery violations can also result in violations of other laws, including anti-money laundering, mail and wire fraud, and conspiracy laws. The penalties for violating anti-corruption laws are severe. In addition to being subject to Global Fishing Watch’s disciplinary policies, individuals who violate anti-corruption laws may also be subject to criminal penalties, such as imprisonment and fines. 

If you have any questions about a transaction with a government official, or any aspect of this Policy, please consult Global Fishing Watch’s Director of Risk and Compliance.

2. Definitions

a. Corruption. The misuse of public power for private profit, or the misuse of entrusted power for private gain.

b. Bribery. The offer, promise, or payment of cash, gifts, or even excessive entertainment, or an inducement of any kind offered or given to a person in a position of trust to influence that person’s views or conduct or to obtain an improper advantage.

c. Third party. Any individual or organization you come into contact with during the course of your work for GFW, including actual and potential donors, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisor, representatives and officials, politicians and political parties.

d. Gift. Any promotional products or gifts, sometimes referred to as swag. Frequent flyer miles or bonus hotel points earned on company business do not count as gifts.

3. Scope

This Policy is applicable to all Global Fishing Watch staff worldwide, including Global Fishing Watch’s directors, officers and employees.  This Policy also applies to Global Fishing Watch’s agents, consultants, external partners, and any other third-party representatives that, on behalf of Global Fishing Watch, conduct business or interact with government officials or are likely to conduct business or interact with government officials. (External Partners are our funders and collaborators including, Donors, Research Programs, Industry, Academic Institutions, International bodies including Civil Society and non-profit organizations and Government agencies etc, with whom we have a formal relationship, a Memorandum of Understanding (MOU), a funded project or some threshold of work that we are doing with them).

4. Prohibited Payments

Global Fishing Watch employees, agents and external partners are prohibited from directly or indirectly making, promising, authorizing or offering anything of value to a government official on behalf of Global Fishing Watch to secure an improper advantage, obtain or retain business, or direct business to any other person or entity. This prohibition includes payments to third-parties where the Global Fishing Watch employee or agent knows, or has reason to know, that the third-party will use any part of the payment for bribes. 

a. Political and Charitable Contributions. Contributions, whether in cash or in kind, in support of any political parties or to candidates are prohibited, as this can be perceived as an attempt to gain improper business advantage or influence decision-making. Charitable support and donations to GFW are acceptable, whether of in-kind services, knowledge, time or money. However, employees must be careful to ensure that charitable contributions made to GFW are not used as a scheme to conceal bribery and must be pre- approved by Global Fishing Watch’s Director of Risk and Compliance.

b.  Cash and Non-Cash Payments. “Anything of Value.”  Payments that violate this prohibition may arise in a variety of settings and include a broad range of payments beyond the obvious cash bribe or kickback. This term is very broad and may include, depending on the circumstances, but is not limited to:

  1. Gifts
  2. Travel, meals, lodging, entertainment or gift cards
  3. Loans or non-arm’s length transactions
  4. Charitable or political donations
  5. Business, employment or investment opportunities

c.  Government Official. The term ‘government official’ includes:

  1. Officers or employees of a government or any department, agency or instrumentality thereof, including professors or other employees of government universities.
  2. Officers or employees of a company or business owned in whole or in part by a government (a state owned or controlled enterprise) 
  3. Officers or employees of a public international organization, such as the United Nations, World Bank or the European Union 
  4. Political parties or officials thereof 
  5. Candidates for political office 

This term also includes anyone acting on behalf of any of the above.

d. Facilitating Payments and Kickbacks. This policy also prohibits “facilitating payments.”  Although facilitating payments may be permissible under the laws of some countries, other jurisdictions in which Global Fishing Watch operates forbid facilitating payments. Accordingly, the Policy prohibits employees and agents from making even a nominal payment to a low-level government official to ensure or speed the proper performance of a government official’s routine, non-discretionary duties or actions, such as: 

  1. Clearing customs
  2. Processing governmental papers such as visas, permits or licenses 
  3. Providing police protection 
  4. Providing mail, telephone or utility services 

Occasionally, a government official may attempt to solicit or extort improper payments or something of value from Global Fishing Watch employees or agents. Such employees or agents must inform the government official that Global Fishing Watch does not engage in such conduct and immediately contact Global Fishing Watch’s Director of Risk and Compliance.  

e. Commercial Bribery. Bribery involving commercial (non-governmental parties) is also prohibited under this Policy.  To this end, Global Fishing Watch employees and agents shall not offer, promise, authorize the payment of, or pay or provide anything of value to, any employee, agent, or representative of another company to induce or reward the improper performance of any function or any business-related activity. Global Fishing Watch employees and agents also shall not request, agree to receive, or accept anything of value from any employee, agent, or representative of another company or entity as an inducement or reward for the improper performance of any function or business-related activity. 

5. Gifts and Hospitality Payments

This policy does not prohibit all payments to government officials. Employees and agents may be allowed to make certain kinds of promotional payments, consistent with local laws. You must obtain prior approval in writing from Global Fishing Watch’s Chief Operations Officer and Director of Risk and Compliance (or his or her designee) if the expense is greater than $100. 

a. Promotional Hospitality and Marketing Expenses or Pursuant to a Contract. Global Fishing Watch may pay for the reasonable cost of a government official’s meals, lodging, or travel if, and only if, the expenses are bona fide, reasonable, and directly related to the promotion, demonstration, or explanation of Global Fishing Watch activities, or the execution of a contract with a government or agency. 

b. Promotional Gifts. Promotional gifts of nominal value may be given to a government official as a courtesy in recognition of services rendered or to promote goodwill.  These gifts must be nominal in value and should generally bear the logo of Global Fishing Watch or one of its activities.

6. Record Keeping

It is Global Fishing Watch’s policy to implement and maintain internal accounting controls based upon sound accounting principles.  All accounting entries in Global Fishing Watch’s books and records must be timely and accurately recorded and include reasonable detail to fairly reflect transactions. These accounting entries (and supporting documentation) must be periodically reviewed to identify and correct discrepancies, errors and omissions. 

a. Authorization for Transactions.  All transactions involving the provision of anything over $100 per person to a government official must occur only with appropriate Global Fishing Watch authorization.

 b. Recording Transactions.  All transactions involving the provision of anything of value to a government official must be recorded in accordance with generally accepted accounting principles (GAAP). 

c. Tracking Transactions.  All transactions involving the provision of anything of value to a government official must be tracked in a separate log or record, with supporting documentation identifying: 

  1. The name and position of the employee requesting and authorizing the transaction.
  2. The name and position of the government official involved in the transaction.
  3. A description, including the value, of the payment or provision of anything of value, and where applicable, a description of Global Fishing Watch’s activities being promoted or the relevant contractual provision if the payment was made pursuant to a contract.

This log must be shared with the Director of Risk and Compliance and the CFO each time it is updated.

7. Cash Payments

Cash payments of any kind to a third-party, other than documented petty cash disbursements or other valid and approved payments, are prohibited. Global Fishing Watch checks shall not be written to “cash,” “bearer” or anyone other than the party entitled to payment except to replenish properly used petty cash funds. 

8. Compliance 

Global Fishing Watch employees and agents must be familiar with and perform their duties according to the requirements set out in this Policy. Global Fishing Watch employees or agents who violate this Policy may be subject to disciplinary action, up to and including dismissal. Third-party representatives and external partners who violate this Policy may be subject to termination of all commercial relationships with Global Fishing Watch. 

Any Global Fishing Watch employee or agent who suspects that this Policy may have been violated must immediately notify Global Fishing Watch as specified in the GFW Whistleblowing Policy.  Any Global Fishing Watch employee who, in good faith, reports suspected legal, ethical or Policy violations will not suffer any adverse consequence for doing so.  When in doubt about the appropriateness of any conduct, Global Fishing Watch requires that you seek additional guidance before taking any action that may subject Global Fishing Watch to potential anti-corruption liability. 

9.  Duty to Cooperate 

Global Fishing Watch may at times undertake a more detailed review of certain transactions. As part of these reviews, Global Fishing Watch requires all employees, agents and third-party representatives to cooperate with Global Fishing Watch, outside legal counsel, outside auditors, or other similar parties. Global Fishing Watch views failure to cooperate in an internal review as a breach of your obligations to Global Fishing Watch and will deal with this failure in accordance with Global Fishing Watch’s policies and any local laws or regulations. 

10. Questions About the Policy 

If you have any questions relating to this Policy, please contact the Director of Risk and Compliance or the Director Financial Accounting. 

11. Reporting Policy Violations 

To report actual or potential violations of this Policy, please notify the Director of Risk and Compliance or the Chief Financial Officer as expeditiously as possible

This Policy was adopted by Global Fishing Watch’s Board of Directors at its meeting on 21 Aug 2025.

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