Norwegian Hull Club constantly monitors the risk of impairment to the organisation’s business model, reputation and financial condition, from a failure to meet laws, regulations, internal standards and policies.
The company operates within a low overall risk range; the lowest risk appetite relates to compliance where the risk level is set to a minimum. The risk tolerance level regarding HSE issues is zero.
Foreign Account Tax Compliance Act (FATCA)
FATCA is a new US law established to prevent tax avoidance by US tax payers and will come into effect from the 1st July 2014.
The legislation impacts Insurance and Reinsurance premium payments for US-sourced business and requires all non-US carriers which underwrite such business to demonstrate their compliance with the law. Failure to do so will result in 30% of the premium having to be withheld by way of a Withholding Tax. Compliance can be demonstrated by completion and submission of the W-8 BEN-E form.
According to EIOPAs "Guidelines on Complaints-Handling by Insurance undertakings" published 16th of November (EIOPA-BoS-12/069) and directive "Retningslinjer for forsikringsselskapers interne klagebehandling" published by The Financial Supervisory Authority of Norway (Rundskriv 4/2013), all insurance companies are to have in place a well functioning complaints handling process and they are also obliged to make this information public.
A complaint is a formal document in writing from the assured to the insurer that expresses dissatisfaction associated with the insurance policy or services delivered. The complaint is to set out the facts and reasons that the filing party or parties believes are sufficient to support the complaint. Complaints handling do not involve regular claims-handling or cases referred to an adjuster for his opinion or subject to legal proceedings by way of arbitration or before any court in Norway or any other country. Nor does complaints handling involve request for execution of the insurance contract, information or clarification.
The Compliance Officer is responsible for the complaints-handling process within Norwegian Hull Club and all complaints are to be directed, in writing, to the following email address: firstname.lastname@example.org
All complaints received by the Compliance Officer are to be investigated fairly and possible conflicts of interest to be identified and mitigated. The Compliance Officer is also responsible for issuing a receipt for received complaints including an indicative handling timeline. The Compliance Officer is also responsible for communicating with the complainant, in a clear and accurate manner and also communicates the outcome of the complaint-handling process.
The Compliance Officer is to analyze, on an on-going basis, complaints-handling data to ensure that we identify and address any recurring or systematic problems, and potential legal and operational risk, for example, by:
- Analysing the causes of individual complaints so as to identify root causes common to types of complaint;
- Considering whether such root causes may also affect other processes or products, including those not directly subject to complaints; and
- Correcting, where reasonable to do so, such root causes.
Code of Conduct
The Code of Conduct defines the professional ethical standards that apply to all employees of Norwegian Hull Club and its subsidiaries. It helps to inspire and build confidence in the company, its people, products and services, both internally and externally among – for example - clients and supervisory authorities, as well as day-to-day business contacts.
Business Partner Code of Conduct Clause
Norwegian Hull Club’s mission is to secure lives, health, environment and property to help protect both people and the planet. As such, The Club require its business partners and suppliers;
- to conduct their enterprise in line with this mission with the utmost integrity and highest standards of business ethics, and
- to promote sustainable principles and comply with applicable environmental, social and governance laws and regulations.
Suppliers and business partners;
- are required to operate in full compliance with all applicable laws and regulations including, but not limited to, those relating to bribery and corruption, money laundering, sanctions, human rights and labor conditions,
- have a duty of confidentiality for all client-related information,
- shall make sure that their subsidiaries, affiliates, and subcontractors providing services to The Club comply with this clause.
Any violation of this clause may jeopardize the business relationship with Norwegian Hull Club, including termination of this instruction.
Norwegian Transparency Act
The Transparency Act relates to companies' transparency and work on fundamental human rights and decent working conditions.
The Act shall promote companies' respect for fundamental human rights and decent working conditions in connection with the provision of services and ensure that the general public's has access to information regarding how companies address negative impacts on fundamental human rights and decent working conditions. The Act came into force on July 1, 2022.
The new act obligates companies to conduct due-diligence into human rights and decent working conditions and follow-ups throughout their supply chain and business relationships. Due diligence shall be carried out in proportion to the size and nature of the company, the context of its operations, and the severity and probability of adverse impacts on fundamental human rights and decent working conditions.
Norwegian Hull Cub has implemented new internal policies and guidelines regarding the Transparency Act. The Club has identified and assessed actual and potential negative impacts through our own operations and also our value chains and business partners' operations and several mitigants have been identified.
The Club's Transparency Act report is available in our latest, published Annual Report.
- If you have any questions regarding this act, you can contact Birger Christian Kindt, Compliance Officer, at email@example.com
If you have any queries about Norwegian Hull Club’s use of personal data, please contact us as at:
Norwegian Hull Club
Telephone no: +47 55 55 95 00
Data Processor Officer:
Birger Christian Kindt
Office: +47 55 55 95 27
Mobile: +47 476 86 490
THE NORWEGIAN HULL CLUB WEBSITE
Norwegian Hull Club takes a proactive approach to user privacy. We ensure that the necessary steps are taken to protect the privacy of users of this website throughout their visiting experience. Our website complies with all Norwegian and UK national laws and requirements for user privacy.
What are cookies?
Cookies are small files saved to the user’s computer’s hard drive that track, save and store information about the user’s interactions and usage of a website. This allows the website, through its server, to provide users with a tailored experience.
We use anonymous session cookies (short-term cookies that disappear when you close your browser) to help you navigate the website and make the most of the features. If you log into the website, application or a course as a registered user, your session cookie will also contain your user ID so that we can check which services you are allowed to access.
HOW TO OPT OUT OF COOKIES
Whilst using our website, software applications or services, you may be required to provide personal information (name, address, email, account details, etc.). We will use this information to administer our website, applications, client databases and marketing material. We will ensure that all personal information supplied is held securely in accordance with the General Data Protection Regulation (EU) 2016/679, as adopted into law of the Norway and United Kingdom in the Data Protection Act 2018. Further, by providing telephone, fax and email details, you consent to Norwegian Hull Club contacting you using that method. You have the right at any time to request a copy of the personal information we hold on you.
INFORMATION COLLECTION AND USE
How do we collect information?
Norwegian Hull Club collects information in several ways:
We collect information such as your name and email address when you sign up to our newsletter(s). Your data will be enrolled via the newsletter provider Campaign Monitor and also stored in our CRM system.
We collect information such as your name, email address, phone number and practical details connected to the event such allergies, diet requirements or special needs. The practical details will be deleted no later than 14 days after the event has ended. We use the third-party provider proviso.no. as a data processor.
We collect information such as the responder’s preferences and satisfaction with Norwegian Hull Club in order to be able to improve our services. The responses will be handled confidentially and without the intent to identify the responder. We use the third-party survey provider Netigate as a data processor.
Your given information is stored, either by us or the party responsible for the service, when you sign up for or log into our War Web, Survey, and Claim Statement products.
USE OF CLIENT INFORMATION
Personal data collected outside of our website may be uploaded and used for online activities.
This may be related to, for example; contests, newsletter sign ups, purchases and reservations.
Depending on your settings or the privacy policies for other online services, you may give us permission to obtain information from your account with those other services. For example, this can be via social media or by choosing to send us your location data when accessing our website from your smartphone.
How long do we keep your data for?
Norwegian Hull Club will not retain your personal information longer than necessary. We will hold onto the information you provide either while your account is in existence, or as needed to be able to provide services to you, or (in the case of any contact you may have with our employees) for as long as is necessary to provide support-related reporting and trend analysis only.
If legally required or if it is reasonably necessary to meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our Terms and Conditions, we may also retain some of your information for a limited period of time as required, even after you have closed your account, or it is no longer needed to provide services to you.
Norwegian Hull Club will not sell or rent your personally identifiable information, gathered as a result of filling out the site registration form, to anyone.
CHOOSING HOW WE USE YOUR DATA
We understand that you trust us with your personal information and we are committed to ensuring you can manage the privacy and security of your personal information yourself.
With respect to the information relating to you that ends up in our possession, and recognising that it is your choice to provide us with your personally identifiable information, we commit to giving you the ability to do all of the following:
- You can verify the details you have submitted to Norwegian Hull Club by contacting our DPO as listed above. Our security procedures mean that we may request proof of identity before we reveal information, including your e-mail address and possibly your address
- You can also contact us by the same method to change, correct, or delete your personal information controlled by Norwegian Hull Club regarding your profile at any time.
- You can always feel free to update us on your details at any point by contacting us by email.
- You can unsubscribe from receiving marketing emails from us by clicking the “unsubscribe” link at the bottom of any newsletter. Once you do this, you will no longer receive any newsletters from us.
- You can request a readable copy of the personal data we hold on you at any time. To do this, please contact us.
Please note, we are constantly reviewing how we process and protect data. Therefore, changes to our policy may occur at any time. We will endeavour to publicise any changes.
The material and information contained in this website is provided without warranties of any kind. Norwegian Hull Club accepts no responsibility for any loss whatsoever, direct or consequential, arising out of or in connection with the use of this website.
This website also contains information supplied by third parties, and provides links to other websites. Norwegian Hull Club does not guarantee the accuracy of such information, and do not accept any liability or responsibility which might arise as a consequence of relying upon it.