Crew induction programme: gifts, commissions and kickbacks (facilitator pack)

Every new crew member, however experienced, should hear this in their first week. Most of the people who get into trouble were never told where the line is. Run this session on board or ashore, for new joiners and again each season. It takes an hour. Print the handout and keep the sign-off sheet with the crew file.

Who leads: the captain or the head of department, with the compliance lead if there is one. Who attends: everyone who orders, receives, pays for or approves anything: captain, officers, chief engineer, purser, chief stew, chef, bosun, and anyone else who deals with suppliers. Bring: the register, the supplier declaration, and the yacht's or company's policy.

Part 1. Whose money? (10 minutes)

Say, in your own words:

"Almost everything we spend on this yacht, we spend for someone else: the owner, the charterer, or the guests. That makes each of us an agent. An agent owes the person whose money it is a duty of loyalty. In plain terms, we spend it as if they were watching."

Then ask the group: "If a supplier gave you a personal benefit because you chose them, who would you be working for?" Let them answer.

Key points to make:

• The APA is the guest's money, held to be spent for them and accounted for with receipts.
• A secret benefit from the other side of a purchase breaks the duty of loyalty, even if the price is fair.
• In most countries where yachts are supplied, giving and receiving such a benefit is a crime, and so is asking.
• See Commission or kickback? and How the APA works.

Part 2. The line (10 minutes)

Draw this on a whiteboard:

	Disclosed commission	Kickback
Does the person whose money it is know?	Yes, in advance	No
Is it written down?	Yes	No
Paid to	The firm	A person
Does it affect your advice?	The client can weigh it	Yes, you are paid by the other side

Ask: "Which side is a case of wine for the crew mess after a big order?" (The right-hand side.)

Part 3. Gifts and hospitality (10 minutes)

Walk through the five tests in Gifts and hospitality: where the line is: disclosure, timing, value and frequency, recipient, form.

Hand out the green / amber / red list. Make the rule on this vessel or in this company clear:

• What is the register, and where is it?
• Who approves an amber item?
• What is the logging limit?
• What happens if you accept something you should not have? (You tell your captain. You will not be punished for telling.)

Part 4. When you are asked or offered (10 minutes)

Teach the three words: refuse, record, report.

1. Refuse. "I can't accept anything personally on an order. If there's a discount, it goes on the owner's invoice."
2. Record. In the register, the same day.
3. Report. To the captain or the compliance lead, and, if it was money or a threat, the same day.

Then read out If someone asks you for a bribe and say clearly: asking is an offence even if nothing is paid. You will never be in trouble for telling us.

Part 5. Scenarios by department (10 minutes)

Split into pairs. Give each pair one card. Ask what they would do, then read the answer.

Card 1: Chef. A fish supplier says that if you keep ordering from him, he will "look after" you at the end of the season with a case of something nice. Answer: decline. A benefit connected to ordering. Record it. Tell the captain.

Card 2: Chief stewardess. A wine broker's sales rep says other yachts get a 10% credit for the stew "for the extra work". Answer: decline. Ask for the discount on the owner's invoice instead. Record the request.

Card 3: Chief engineer. A fuel agent offers a small payment per tonne "for your trouble". Answer: decline. Any rebate belongs to the owner. Record, report. Tell the captain.

Card 4: Bosun. A tender supplier invites you and your partner to a weekend at an event, "all paid". Answer: decline. A personal benefit connected to equipment decisions.

Card 5: Purser. A broker asks you to pay an invoice to a different account, "it's the same company, new bank". Answer: stop. Verify independently with the captain. Possible fraud or diverted funds.

Card 6: Captain. A yard offers a "referral fee" for the refit you have recommended to the owner. Answer: decline. Any such fee belongs to the owner and must be disclosed. Tell the management company.

Card 7: Deckhand. A supplier offers a few bottles to the crew "for helping unload". Answer: a small token for a team is different from a gift for a purchase decision, but if in doubt, ask the captain and log it.

Card 8: Any crew member. A colleague tells you he has an "arrangement" with a supplier and you shouldn't mention it to the owner. Answer: do not take part, and do not ignore it. Report it to the captain, the management company or through us.

Part 6. Quiz and sign-off (10 minutes)

Use the quiz in the training pack. Mark it together. Everyone signs below.

Handout: the crew card

Cut this out and keep it with the register.

We spend other people's money. Take nothing for an order. Not cash, not a case, not a trip. Pass on every discount to the owner's account. Refuse. Record. Report. Asking for a commission is a crime, even if nothing is paid. You will never be in trouble for telling. Captain: [name, contact]. Compliance: [name, contact]. Private help: [TransparentSea portal].

Sign-off sheet

Date	Name	Position	Quiz score	Signature	Led by

General information, not legal advice.