Under German law, there are no specific provisions for ship owners with respect to anti-bribery and corruption. However,ship owners are certainly subject to the general laws regarding sanctions, anti-bribery and anti-corruption. The making of bribery payments or gifts is a criminal offence under German law. This includes so-called facilitation payments, although these are not punishable under German law if paid to non-EU officials.
Many ship owning companies are becoming increasingly aware of these issues and are implementing internal anti-bribery and anti-corruption guidelines as well as including anti-bribery clauses in their contracts with freight forwarders and charterers in order to avoid prosecution. However, some of the standard clauses used in this context, and the duties of third parties stipulated within them, appear to be in conflict with certain provisions of German labour and data protection laws.