Informal comments will normally be received via email or telephone by the Senior Freight Market Reporter or the Baltic Exchange Chief Executive. They will agree together how to respond and whether any escalation of the comment is required. If they feel the comment should be escalated then the Chairman of Baltic Exchange Information Services should be consulted and if deemed necessary, the comment and the response can be reviewed at the next Board meeting.
If the informal comment is not resolved to the satisfaction of the originator then they will be provided with information setting out how to initiate a formal complaint if they wish. This procedure is set out below.
This should be addressed by email to email@example.com. The email will automatically be copied on to both the Baltic Exchange Chief Executive and the Chairman. The Board will consider whether the complaint has merit and what action if any should be taken. The Chairman will send a response to the complainant outlining the position of the Company and any action agreed upon. The complaint will be treated in confidence, but must contain the full name and company details of the originator as well as all available evidence to support the complaint.
Any formal complaints received will be reported on to the Board at its next meeting.
The Baltic Exchange Ltd and its affiliates have been producing market benchmarks since 1985 and although there has never been any suggestion of serious irregularity, it is appropriate to ensure that anyone with knowledge of such irregularity has the opportunity to report it on a confidential basis at the highest possible level. The primary recipient for any such “whistle-blowing” should be the Baltic Exchange Chief Executive. If the whistle-blower does not wish to make use of this route then the Chairman of BEISL is an alternative. Failing him then the Chairman of the Baltic Exchange Ltd is also able to receive such information. For reasons of confidentiality and to ensure the approach is not missed, the preferred way of approaching the matter is by telephone.
All three of these individuals are aware of the need to deal promptly and vigorously with such matters and to protect the interest and identity of the complainant in all circumstances. They will record in writing details of both the initial contact from the whistle-blower and any subsequent contact. Any details of the whistle-blower and the nature of the concern will be kept strictly confidential.
A whistle-blower may make a complaint on an anonymous basis. However, it will always be easier to investigate the matter if the details of the initiator are known.