AKRON Prepared by: SQD Document 002 Page 1 of 4

Vessel Operations Manual Approved by: MD Issue 2, Rev. 0 Eff. Date: 15/05/2013

1. VESSEL MANAGEMENT 6. ONBOARD COMPLAINT PROCEDURES Chapter 1, Section 6

 

6 : ONBOARD COMPLAINT PROCEDURES

The procedure address the requirements of MLC ‘2006 Standard A 5.1.5

1. Aim
The purpose of this procedure is to ensure that grievances/ complaints alleging breaches of
the requirements of the Seafarer’s rights as contained in the Maritime Labour Convention
2006 are fairly dealt with speedily, effectively and in compliance with the ML C 2006.

2. Complaint Policy
1) All sea staff has the right to lodge a complaint by bringing it to the attention of the proper
authority on board or ashore and have it properly investigated (Complainant).

2) Although justified complaints shall be handled and resolved on board, at the lowest
possible level of authority, seafarers can complain directly to the Master, the Company or
to external competent authorities where necessary.

3) Seafarers at all times, have the right to be accompanied and be represented by another
seafarer of their choice onboard the ship concerned (Representative).

4) At any time sea staff can discuss a complaint confidentially with any of the ships officers
who will advise/ assist them impartially in the complaints procedures and can also ( if
requested ) attend any investigation hearings/ meetings.

5) Company nominates the Master, as the person who can, on a confidential basis, provide
impartial advice to the seafarer about the procedures involved, if he lodges a complaint
about matters under the MLC Convention, and if requested by the seafarer, attend any
meetings or hearings into the subject matter of the complaint. Additionally, if the
complaint is against the Master (on matters pertaining to this Convention), the seafarer
can approach the Chief Engineer who will advise and assist him on the procedures to be
followed for reporting the complaint.

6) In all cases the confidentiality of the complaint and complainant will be respected.

7) Any victimization of a seafarer for filing a complaint is strictly prohibited. Victimization is

understood to mean any adverse action taken or threatened by any person with respect
to a seafarer for lodging a complaint which is not manifestly vexatious or maliciously
made. The seafarer subject to, or witnessing victimization or harassment can directly
report it to the DPA, who will investigate it and undertake disciplinary actions. All acts of
harassment may be penalized pursuant to the provisions of national laws.

8) Except where National, Flag or specific CBA requirements exist, or specific procedures
are laid down in an individual seafarer’s contract of employment, the Company’s
complaint procedures shall be observed.

3. Reporting
1) It is expected that justified complaints will be handled and resolved on board, at the
lowest possible level of authority. “Onboard Complaint Form” shall be used for reporting.

When a member of sea staff has a complaint on any matter alleging breaches of the
requirements of the Seafarer’s rights as per MLC’ 2006, their first action is to inform their
immediate supervisor, as given below:
 AKRON Prepared by: SQD Document 002 Page 2 of 4
Vessel Operations Manual Approved by: MD Issue 2, Rev. 0 Eff. Date: 15/05/2013

1. VESSEL MANAGEMENT 6. ONBOARD COMPLAINT PROCEDURES Chapter 1, Section 6

 
Deck Ratings Inform Bosun
Engine Room Ratings Inform 3rd Engineer
Catering Crew Inform Chief Cook
Junior Officers Inform Chief Officer
Junior Engineers Inform 2nd Engineer
2nd Officer / 2nd Engineer Chief Officer / Chief Engineer
Ch. Officer / Ch. Engineer / Ch. Cook Master
(Department Heads)

Alternatively, the seafarer can directly report the complaint to the head of the department.

2) The supervisor receiving the complaint shall pass immediately matters beyond his
capability to the appropriate Head of Department (Chief Officer / Chief Engineer) for their
consideration and action as necessary.

3) If the head of Department cannot resolve the issue to the satisfaction of the complainant,
it should be reported immediately to the master who must handle the matter personally.
Seafarers should at all times have the right to be accompanied by another seafarer of
their choice on board the ship concerned.

4) If the Master cannot reconcile the complaint, the matter should be formally referred at the
earliest opportunity to the concerned authority at shore office – Crewing Manager or DPA.

5) Matters concerning feeding on board should be passed to the Master. On no account are
officers or crew to approach the Chief Cook directly on matters concerning feeding, food
quality or quantity.

6) Where the crew member feels the complaint is serious enough or inadequately
addressed, he may bring it directly to the attention of the Master, the Crewing Manager
or the DPA, or competent external authorities.

7) Where appropriate, complaints may be addressed through discussion during shipboard

management meetings.

4. Resolution
1) The immediate supervisor, upon receipt of the complaint, shall discuss it with the
complainant and then, provided the complaint is justified and it is of a relatively minor
nature, should take the appropriate action to rectify the situation as soon as possible, but
not later than five (5) days.

2) Department heads, upon receipt of the complaint shall investigate them, as appropriate,
determine corrective actions and assign responsibilities.  

In all circumstances complaints reaching the level of department heads should be

resolved as early as possible, but no later than five (5) days from the report. 

3) Should a complaint reach the level of the Master, the Master shall:
- Conduct an investigation or inquiry, as appropriate;
- Refer, as appropriate, the terms and conditions of employment, Maritime Labour
Convention and Flag State requirements, as set out in the DMLC Part I; and
- Seek the advice of the appropriate shore based authority, such as Crewing Manager
or Company DPA.
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Vessel Operations Manual Approved by: MD Issue 2, Rev. 0 Eff. Date: 15/05/2013

1. VESSEL MANAGEMENT 6. ONBOARD COMPLAINT PROCEDURES Chapter 1, Section 6

 
- Determine actions to resolve the complaint within five (5) days of receipt of complaint
and assign responsibilities.
4) If the matter reaches the shore office authority, the person responsible shall : UD
- Conciliate the matter, in accordance with the terms and conditions of employment. An
investigation may be conducted, where appropriate.
- Notify competent external authority, as necessary, as per the prevailing regulations.
- Resolve the matter within eight (8) days of receipt of the complaint letter, where
appropriate, in consultation with the seafarers concerned, or their appointed
representatives.
If the complaint on board has not been resolved within the period of eight (8) days ,
then the period shall be extended for twenty two (22) more additional days, with the
sole purpose to find a favorable solution, which shall be recorded on the Onboard
Complaint Form onboard and be available to the competent authorities.

Complaints not resolved within the above time period to be reported to the Flag
Administration, if required so by the concerned Flag of the vessel.

5) All complaints and the decisions on them should be recorded in the “Onboard Complaint
Form”, and filed onboard, attached with a copy of the ship’s Crew List. A copy shall be
provided to the seafarer concerned.

6) In the unlikely event that a crewman is not satisfied with the action taken, he should re-
submit the complaint to the Master, stating the reasons why any action already taken to
resolve the problem is insufficient. The Master shall then take actions as given in item 3).

7) The Shore Office contact details are found in the Company Contacts list posted
onboard as well as provided in the Appendix 2 of Emergency Response Plans /
SOPEP kept onboard.

5. External Competent Authorities

1) Seafarers have the right to file a complaint directly with appropriate competent external
authority such as:
 Flag administration / Nautical inspector
 Flag administration RO inspector
 Flag State General Directorate of Seafarers
 Port state control official
 Representatives of Competent Authority / Labour office
2) This should be considered as a last resort only. The company believes that this
complaints procedure should be able to deal with all arising matters without the need for
external assistance.

3) Contact details for external authorities can be found in the Appendix 3 of

Emergency Response Plans / SOPEP kept onboard.

6. Records
 Onboard Complaint Form

7. References
 MLC ‘2006 – Standard A 5.1.5
 Onboard Complaint Procedures – Flag Administration
 AKRON Prepared by: SQD Document 002 Page 4 of 4
Vessel Operations Manual Approved by: MD Issue 2, Rev. 0 Eff. Date: 15/05/2013

1. VESSEL MANAGEMENT 6. ONBOARD COMPLAINT PROCEDURES Chapter 1, Section 6

 
8. COMPLAINT PROCEDURE – FLOW CHART

Grievance from  Grievance from  Grievance from  Grievance from 

Grievance from  nd
Engine Rating  Catering Crew  Junior  Officers /  2  Engineer / 
Deck Rating 
Junior Engineers  2nd  Officer 

Bosun  3rd Engineer  Chief Cook  C/O /  2nd Engr 

Yes  Within 5 days of 
Investigation  Reporting  
Grievance Closed 
Resolved

No 
Head of Department 
(Dk/Eng/Cater) 

Yes 
Investigation  Within 5 days of 
Grievance Closed 
Resolved  Reporting to Head of 
Department 

No 

Master 
No

Yes  Within 5 days of 
Investigation 
Grievance Closed  Reporting to Master 
Resolved 

No 
Shore Office Authority 
(DPA/Crew Manager etc.)   External Authority Report 
a Grievance

Yes 
Investigation  Within 8 days of Reporting 
Grievance Closed  Resolved to Company 

No 

Extend time to resolve     
up to 22 days 

Grievance Closed 

If Grievance is considered serious enough all seafarers can report it directly to the Master or Shore Office 
Authorities  for their investigation. 
 2. MLC 2006 – CONTACT POINTS FOR COMPLAINTS ( STANDARD 5.1.5 )
FOR REPORTING COMPLAINTS TO
FLAG ADMINISTRATION & SEAFARER’S NATIONAL AUTHORITIES

FLAG ADMINISTARTION
a. PANAMA

General Directorate of Seafarers : General Directorate of Merchant Marine:

Department of Maritime Labour Affairs International Technical Office of Segumar

Tel. (507) 501-5059 Tel. (507) 501-4241

labormar@amp.gob.pa mlcsegumar@amp.gob.pa
afundora@amp.gob.pa mlc@segumar.com

b. ST. KITTS & NEVIS

St. Kitts and Nevis International Ship Registry Email:mail@stkittsnevisregistry.net

West Wing, York House Tel: +44 1708 380400
48-50 Western Road Fax + 44 1708 380408
Romford
RM1 3LP
United Kingdom

c. U.A.E

National Transport Authority, Marine Affairs Tel : +971 2 4490088, +971 2 4182124
Department Fax : +971 2 4491 500
PO Box 900 Abu Dhabi
United Arab Emirates
Abu Dhabi United Arab Emirates

SEAFARER’S NATIONAL AUTHORITY

PHILIPPINES
 
PHILIPPINES OVERSEAS EMPLOYMENT E-mail address : onboardconci@poea.gov.ph
ASSOCIATION (POEA)
Tel. : +6328336992, +6325516641, +6325511560,
Postal mail address : and +6391789869

POEA administrator,
Blas F. Ople Building
Corner Edsa and Ortigas Avenue,
Mandaluyong City,
Philippines 1501

ERP / SOPEP / SMPEP Appx. 3 Page 2 01/01/2014