Supply Chain Transparency in Maritime: IMPA ACT and Anti-Fraud Practices

Supply chain transparency in maritime procurement is no longer only a sustainability topic. It is now a governance, compliance, risk management and operational reliability issue for ship owners, ship managers, compliance officers, procurement directors and supplier governance teams.

Marine procurement involves many stakeholders: ship chandlers, technical suppliers, manufacturers, port agents, logistics providers, subcontractors, warehouses, vessel crews and purchasing departments. Without a clear due diligence process, this chain can create risks related to corruption, hidden commissions, false documentation, poor labour practices, weak environmental controls, conflicts of interest and unreliable suppliers.

This is why supply chain transparency maritime IMPA ACT practices are becoming more important. Programmes such as IMPA ACT help maritime companies structure supplier due diligence, responsible sourcing and business conduct expectations in a practical way.

For procurement teams, transparency is not only about asking for a certificate. It is about knowing who supplies the vessel, how the supplier manages risk, whether documentation is reliable, whether employees and subcontractors are treated properly, and whether the commercial relationship is protected from fraud and corruption.

AVS Global Ship Supply & Catering supports ship owners, ship managers and procurement teams with Global Ship Supply, supplier coordination, technical stores, provisions, bonded stores and multi-port delivery support. For wider sustainability context, see ESG in maritime procurement.

For transparent and documentation-sensitive ship supply requirements, submit your request through Quick Quote.

IMPA ACT Programme Overview

IMPA ACT is a responsible supply chain management programme developed for the maritime industry. It helps ship owners, ship managers, ship suppliers and manufacturers align business relationships with responsible business conduct expectations.

In marine procurement, this is important because supplier risk is rarely limited to one transaction. A supplier may affect vessel operations, crew welfare, regulatory compliance, financial controls, environmental performance and the company’s reputation.

What IMPA ACT Tries to Improve

IMPA ACT supports a more structured approach to responsible supply chain management. It encourages companies to assess business relationships, improve transparency and work with suppliers on key risk areas.

The programme is relevant to:

Ship owners
Ship managers
Ship suppliers
Marine manufacturers
Procurement teams
Compliance officers
Sustainability teams
HSEQ managers
Governance teams

For procurement directors, IMPA ACT can help turn supplier due diligence from an informal checklist into a repeatable process.

Why It Matters in Ship Supply

Ship supply can involve urgent purchasing, local port conditions, last-minute substitutions and multiple intermediaries. These conditions make transparency especially important.

Typical ship supply risks may include:

Inflated prices
Undisclosed commissions
Fake or weak supplier documentation
Unclear subcontracting
Poor product traceability
Conflicts of interest
Gifts or hospitality pressure
Unsafe labour practices
Poor environmental handling
Weak anti-corruption controls
Repeated use of unverified suppliers

A responsible supply chain programme helps procurement teams identify these risks earlier.

IMPA, ISSA and Industry Alignment

Industry bodies and purchasing references can support common expectations in marine procurement. IMPA is especially relevant for marine purchasing practice, while ISSA supports the ship supply industry more broadly.

A common language around supplier conduct helps buyers and suppliers work with clearer expectations.

Due Diligence Pillars: Human Rights, Labour, Environment and Anti-Corruption

Supplier due diligence is not only a financial or commercial review. In responsible maritime procurement, supplier evaluation should cover people, labour standards, environmental impact and business integrity.

These pillars are closely aligned with widely used responsible business conduct principles.

Human Rights

Human rights due diligence looks at how a supplier’s operations may affect workers, communities, subcontractors and vulnerable groups.

In maritime procurement, human rights risks may arise in:

Warehouses
Local delivery teams
Manufacturing sites
Subcontracted labour
Port handling
Cleaning and maintenance services
Catering supply chains
Security or access control
Logistics providers

A buyer may ask whether the supplier has policies and controls around forced labour, child labour, discrimination, harassment, working conditions and grievance channels.

Labour Standards

Labour due diligence focuses on the people working inside the supplier’s business and across its subcontractor network.

Important labour topics include:

Written employment terms
Working hours
Wage practices
Occupational health and safety
Freedom of association
No forced labour
No child labour
Non-discrimination
Training and competence
Contractor management

For maritime context, MLC 2006 is an important reference for seafarer welfare, although supplier due diligence often extends beyond seafarers to shore-based and subcontracted workers.

Environment

Environmental due diligence checks whether suppliers understand and control their operational environmental impact.

This may include:

Waste handling
Packaging reduction
Spill prevention
Chemical storage
Fuel use and delivery emissions
Recycling practices
Hazardous material handling
Compliance with local environmental rules
Environmental incident response
Documentation and reporting

For maritime pollution prevention context, MARPOL and IMO provide useful background for procurement and compliance teams.

Anti-Corruption

Anti-corruption is a central governance pillar. Marine procurement can be exposed to bribery, facilitation payments, gifts, conflict of interest, hidden commissions and invoice manipulation.

Anti-corruption due diligence should check:

Anti-bribery policy
Gift and hospitality rules
Conflict of interest declaration
Approval limits
Supplier ownership transparency
Payment controls
Invoice verification
Whistleblowing channel
Training records
Disciplinary process
Third-party agent controls

A supplier that cannot explain its anti-corruption controls may create risk for the buyer.

Audit Workflow: Self-Assessment, Improvement and Verification

Supplier due diligence should be practical. Not every supplier needs the same level of review, but every supplier should be assessed in a structured and risk-based way.

A good audit workflow usually moves through self-assessment, document review, improvement planning and verification.

Step 1: Supplier Segmentation

Procurement teams should first segment suppliers by risk and importance.

High-attention suppliers may include:

High-spend suppliers
Critical technical suppliers
Suppliers in higher-risk locations
Suppliers handling chemicals
Suppliers using subcontractors
Repeated port suppliers
Suppliers with weak documentation
Suppliers involved in urgent vessel deliveries
Suppliers providing labour-intensive services
Suppliers with previous quality or invoice issues

Supplier segmentation helps teams focus audit effort where it matters most.

Step 2: Self-Assessment Questionnaire

A self-assessment questionnaire is a structured form that asks suppliers to explain their policies, controls, documents and practices.

It may include questions about:

Company ownership
Business licences
Human rights policy
Labour practices
Health and safety controls
Environmental procedures
Anti-corruption policy
Gifts and hospitality
Conflicts of interest
Whistleblowing
Subcontractor management
Document retention
Training
Previous incidents
Certifications
Corrective action process

The goal is not only to collect answers, but to identify risk and improvement needs.

Step 3: Document Review

Self-assessment answers should be supported with documents where appropriate.

Useful documents may include:

Code of conduct
Anti-bribery policy
HSEQ policy
Environmental policy
Labour policy
Supplier declaration
Business registration
Tax registration
Insurance documents
Certifications
Training records
Audit reports
Incident records
Corrective action plans
Sustainability report
Whistleblowing procedure

Documents should be checked for relevance, date, consistency and completeness.

Step 4: Improvement Plan

If gaps are found, the buyer should not automatically remove every supplier. In many cases, improvement is more realistic and more useful.

An improvement plan may include:

Policy update
Training requirement
Better invoice control
Gift declaration procedure
Conflict of interest form
Environmental handling procedure
Updated safety documentation
Subcontractor disclosure
Better record keeping
Corrective action deadline
Follow-up review date

This approach supports responsible sourcing without disrupting vessel operations unnecessarily.

Step 5: Verification

Verification checks whether the supplier’s claims are reliable.

This may include:

Follow-up questionnaire
Document sampling
Remote interview
Site visit
Third-party verification
Internal audit
Invoice testing
Delivery record review
Complaint review
Corrective action closure

For strategic or high-risk suppliers, verification should be repeated periodically.

Anti-Fraud Practices in Marine Procurement

Anti-fraud controls protect both the buyer and the supplier. In marine procurement, fraud can appear through pricing, invoicing, product substitution, documentation, delivery records, commissions or conflicts of interest.

Because ship supply often happens under time pressure, controls must be clear and easy to apply.

Common Fraud Risks

Marine procurement teams should watch for:

Duplicate invoices
Inflated quantities
Fake delivery notes
False certificates
Unapproved substitutions
Split invoices to avoid approval limits
Shell companies
Undisclosed related parties
Excessive urgency pressure
Bank account changes
Price manipulation
False freight charges
Hidden commissions
Goods charged but not delivered
Repeated single-source purchasing without justification

These red flags do not always prove fraud, but they require review.

Practical Anti-Fraud Controls

A strong anti-fraud approach may include:

Supplier onboarding checks
Segregation of duties
Purchase order approval limits
Three-way matching of PO, invoice and delivery note
Bank account verification
Conflict of interest declarations
Gift and hospitality register
Sanctions and watchlist screening where applicable
Delivery photo evidence
Vessel confirmation of receipt
Random invoice audits
Price benchmarking
Approved supplier lists
Substitution approval workflow
Whistleblowing channel

Controls should be proportionate to risk and value.

Fraud Prevention in Urgent Ship Supply

Urgent deliveries are common in maritime operations. However, urgency should not remove all controls.

For urgent RFQs, teams can still apply basic checks:

Confirm supplier identity
Use approved payment route
Require written quotation
Confirm delivery scope
Ask for delivery proof
Record approval reason
Check unusual price changes
Confirm product substitution in writing
Request vessel receipt confirmation

Fast does not need to mean uncontrolled.

Documentation and Traceability

Good documentation is one of the strongest anti-fraud tools.

Procurement records should show:

RFQ
Supplier quotation
Purchase order
Approval trail
Product specification
Delivery note
Vessel receipt confirmation
Invoice
Payment approval
Any substitution approval
Any exception explanation

A clean audit trail protects governance teams and supports supplier accountability.

Conflict of Interest and Gifts Policies

Conflicts of interest and gifts can damage procurement integrity. Even small informal benefits can create pressure, bias or the appearance of unfair supplier selection.

Marine procurement teams should handle these topics clearly and consistently.

What Is a Conflict of Interest?

A conflict of interest occurs when a personal, financial or relationship-based interest may influence a business decision.

Examples include:

Buyer has a family connection with a supplier
Employee owns shares in a supplier
Supplier offers a private benefit
Buyer receives personal travel support
Employee directs business to a related company
Supplier gives repeated hospitality before tender decisions
Technical approver has a side agreement with a vendor

Conflicts should be declared and managed before they affect purchasing decisions.

Gifts and Hospitality

Gifts and hospitality policies should define what is acceptable, what must be declared and what is prohibited.

A practical policy may include:

Monetary limits
Approval requirements
Registering gifts
Ban on cash or cash equivalents
Rules for meals and events
Restrictions during tenders
Treatment of travel and accommodation offers
Reporting channel for inappropriate offers
Consequences for breach

The safest approach is transparency. If a gift or invitation could influence a purchasing decision, it should be declined or formally reviewed.

Supplier Expectations

Suppliers should also understand the buyer’s expectations.

A supplier code of conduct may state:

No bribery
No facilitation payments
No hidden commissions
No inappropriate gifts
No conflicts of interest
Accurate invoicing
Accurate documentation
Transparent subcontracting
Cooperation with audits
Reporting of suspected misconduct

These expectations should be included in onboarding and supplier reviews.

Reporting and Governance Integration

Supply chain transparency must connect with governance reporting. If due diligence stays only inside procurement inboxes, it becomes weak and hard to audit.

Governance teams need usable data, trends, risk indicators and corrective action records.

What Should Be Reported?

A marine procurement governance report may include:

Number of assessed suppliers
High-risk supplier count
Completed self-assessments
Open corrective actions
Closed corrective actions
Supplier audit results
Fraud red flags
Conflict of interest declarations
Gifts and hospitality declarations
Whistleblowing cases
Supplier terminations
ESG supplier performance
Training completion
Policy breaches
Repeated invoice exceptions

These indicators help management see whether supply chain controls are actually working.

ESG Reporting Alignment

IMPA ACT-style supplier due diligence supports ESG reporting by giving structure to responsible sourcing, labour standards, environmental controls and anti-corruption practices.

For sustainability officers, supplier due diligence can support:

ESG disclosures
Supplier engagement metrics
Responsible sourcing evidence
Human rights risk mapping
Environmental supplier controls
Anti-corruption reporting
Audit trail development
Corrective action tracking

For more detail on the wider sustainability context, review ESG in maritime procurement.

Whistleblowing and Speak-Up Channels

A strong governance system should allow employees, suppliers and stakeholders to report concerns safely.

Whistleblowing channels should be:

Accessible
Confidential
Protected from retaliation
Available to relevant stakeholders
Clearly communicated
Monitored by responsible teams
Linked to investigation procedure
Supported by record keeping

Whistleblower protection is essential because many fraud or corruption issues are discovered through internal reporting.

Management Review

Supplier due diligence results should be reviewed by management periodically.

Management review may consider:

Supplier risk trends
Audit outcomes
High-risk locations
Repeated non-conformities
Corrective action delays
Fraud incidents
Policy exceptions
Governance weaknesses
Supplier improvement progress

This turns due diligence from a form-filling exercise into a management control system.

Common Red Flags in Supplier Vetting

Supplier vetting is more effective when teams know what to look for. Red flags should trigger more review, not automatic rejection in every case.

Commercial Red Flags

Commercial red flags may include:

Supplier refuses to provide company registration
Supplier changes bank account suddenly
Pricing is far above or below market without explanation
Supplier pressures for urgent payment
Supplier avoids written quotation
Supplier refuses normal PO process
Supplier has unclear ownership
Supplier requests payment to unrelated entity
Supplier repeatedly uses vague invoice descriptions

Documentation Red Flags

Documentation red flags may include:

Certificates look altered
Different company names appear across documents
Missing delivery note
Missing batch or product reference
No SDS for chemical products
No proof of delivery
Inconsistent quantities
Product photos do not match order
Expired certificates
Unclear country of origin

Conduct Red Flags

Conduct red flags may include:

Frequent gifts or hospitality
Personal contact outside official channels
Pressure to bypass procurement process
Requests for cash payments
Unexplained agent involvement
Refusal to disclose subcontractors
Evasive answers on labour or environmental controls
Repeated quality issues
Complaint history

Each red flag should be recorded and reviewed under the company’s supplier risk process.

IMPA ACT and EcoVadis: What Is the Difference?

IMPA ACT and EcoVadis can both support responsible sourcing, but they are not the same tool.

IMPA ACT

IMPA ACT is designed for the maritime supply chain and focuses on responsible supply chain management in the shipping industry. It is especially relevant for ship owners, ship managers, suppliers and manufacturers that want a sector-specific approach to due diligence.

It helps companies work with business relationships on issues such as human rights, labour, environment and anti-corruption.

EcoVadis

EcoVadis is a broader sustainability rating platform used across many industries. It evaluates a company’s sustainability management system through themes and indicators related to policies, actions and results.

EcoVadis can be useful when a buyer wants a third-party sustainability scorecard across a wider supplier base.

Practical Difference for Procurement Teams

For maritime procurement teams:

IMPA ACT is more shipping-specific.
EcoVadis is broader and cross-industry.
IMPA ACT may fit marine supplier engagement and industry alignment.
EcoVadis may fit group-level sustainability rating and supplier comparison.
Both can support due diligence, but neither replaces internal procurement controls.
Anti-fraud controls, PO approvals, invoice checks and conflict of interest rules are still needed.

The best approach depends on company size, supplier base, governance maturity and buyer requirements.

How AVS Supports Transparent Maritime Supply

AVS supports procurement teams and governance-focused buyers by helping build clearer communication, better documentation and reliable vessel supply coordination across international ports.

AVS can support:

Global ship supply coordination
Supplier communication
Technical and commercial documentation
Delivery traceability
Product specification control
Quotation clarification
Proof of delivery
Multi-port procurement support
Documentation-sensitive supply
Technical stores and provisions coordination
Buyer and vessel communication
RFQ clarification before order confirmation
Supplier transparency expectations where applicable

In maritime procurement, transparency is not only a compliance exercise. It directly supports reliable vessel operations, cost control, supplier accountability and long-term business trust.

Conclusion: Transparency Protects Maritime Procurement

Supply chain transparency in maritime procurement is essential for governance, ESG, anti-fraud control and operational reliability. IMPA ACT gives the industry a practical way to structure responsible supply chain management, while internal anti-fraud practices protect daily purchasing decisions.

For compliance officers, procurement directors and governance teams, the goal is not to make supplier management unnecessarily complex. The goal is to make supplier risk visible, documented and manageable.

Strong supplier due diligence should cover human rights, labour, environment and anti-corruption. Anti-fraud controls should cover invoice checks, supplier onboarding, conflict of interest, gifts, payment changes and delivery proof. Governance reporting should turn supplier data into management action.

AVS Global Ship Supply & Catering supports ship owners, ship managers and procurement teams with global ship supply, supplier coordination, documentation support and reliable vessel delivery across international ports.

For transparent ship supply, documentation-sensitive procurement, technical stores, provisions or multi-port vessel supply requirements, submit your request through Quick Quote.

FAQ

What is IMPA ACT?

IMPA ACT is a responsible supply chain management programme for the maritime industry. It helps ship owners, ship managers, suppliers and manufacturers structure due diligence around human rights, labour, environment and anti-corruption.

Is participation mandatory?

Participation in IMPA ACT is not automatically mandatory for every maritime company. However, buyers, ship managers or corporate governance policies may require suppliers to participate in certain due diligence programmes or follow similar responsible sourcing standards.

How is supplier due diligence performed?

Supplier due diligence is usually performed through supplier segmentation, self-assessment questionnaires, document review, risk scoring, improvement plans, verification and periodic monitoring.

What is a self-assessment questionnaire?

A self-assessment questionnaire is a structured form that asks suppliers to explain their policies, controls, documentation and risk management practices across areas such as labour, environment, anti-corruption and governance.

What are common red flags in supplier vetting?

Common red flags include unclear ownership, sudden bank account changes, missing documents, inflated prices, fake certificates, refusal to follow PO process, undisclosed subcontractors, excessive gifts or pressure for urgent payment.

How does AVS approach anti-fraud?

AVS supports transparent procurement through clear RFQ communication, quotation clarification, delivery documentation, product specification control, supplier coordination and proof of delivery processes where applicable.

Are gifts to buyers acceptable?

Small business courtesies may be allowed under some company policies, but gifts must never influence purchasing decisions. Cash, hidden benefits, tender-related gifts and personal payments should be prohibited.

What is a corruption risk assessment?

A corruption risk assessment identifies where bribery, facilitation payments, conflicts of interest, hidden commissions or improper supplier influence may occur in the procurement process.

How are whistleblowers protected?

Whistleblowers should be protected through confidential reporting channels, non-retaliation rules, clear investigation procedures and secure record keeping.

How does ESG reporting align with IMPA ACT?

IMPA ACT-style supplier due diligence can support ESG reporting by providing evidence on supplier engagement, responsible sourcing, labour standards, environmental controls and anti-corruption practices.

Do small suppliers participate?

Yes. Small suppliers can participate in responsible sourcing programmes, although the level of documentation and review should be proportionate to supplier size, risk and business criticality.

What is the difference between IMPA ACT and EcoVadis?

IMPA ACT is maritime-specific and designed for responsible supply chain management in shipping. EcoVadis is a broader cross-industry sustainability rating platform. Both can support due diligence, but they serve different use cases.

Supply Chain Transparency in Maritime