Other

CLIA recognizes the need to provide practical assistance and emotional support during times of significant stress or crisis. CLIA encourages each of its members to develop these capabilities in-house or by partnering with outside sources to provide for this assistance.

All CLIA cruise lines are encouraged to determine, as soon as possible after a traumatic incident involving any guest, whether additional assistance or accommodation is needed from the cruise line. Many of our lines have specified, trained, and organized care teams or company designated personnel who are equipped to handle critical, unexpected incidents and provide the assistance needed.

This policy is intended to identify actions to be considered by all of CLIA's members when responding to a critical incident or implementing guest care response plans. CLIA does not advocate a one-size-fits-all approach as varying levels of guest care support will be needed depending upon each situation. CLIA cruise lines should develop their own detailed procedures, and they will vary based on vessel size, passenger and crew demographics, itinerary, and other factors.

CLIA believes the following practices should, whenever possible under the circumstances, be considered in addition to any other assistance that may be appropriate.

Initial responders

Ship's officers and crew offer immediate assistance to guest and family/traveling companions and determine the level of assistance that may be needed. Shore-based care teams or company designated personnel and other land-based resources, as and when appropriate, coordinate support and determine what is available and what is needed. Shore-based care teams or designated personnel coordinate with ship's crew and reach out to guest's shore-based relatives who are listed as an emergency contact, as appropriate.

Guest assistance considerations

Depending upon the circumstances of each situation, the following considerations should be evaluated:

• Provide immediate, complimentary communications to shore.
• Inquire about guests and family logistical needs (move to another stateroom, port of departure, landing of remains, etc.)
• Provide family assistance support, such as providing a private dining area or conference room, retrieving onboard portraits, and assisting with packing of personal belongings or other practical support, as warranted.
• Determine if male or female Guest Services staff is appropriate to provide support.
• Assign care team or company designated personnel to join guest/family on ship or land, as needed and taking visa restrictions into account.
• Determine whether any accompanying relative who disembarks after the loss of a loved one requires assistance from the ship, port agent, care team and/or designated shore-based personnel.
• Refer guest and family to assistance counseling (either onboard or telephonically) depending upon the situation and need.
• Support guest and family/companions with travel insurance paperwork and other documentation necessary to obtain available benefits.
• Serve as liaison with U.S. embassy or local governments, when appropriate.

Post incident considerations

Following the immediate response, additional post incident considerations should be evaluated on a case by case basis and dependent upon the guest's and family's wishes.

• Assess guest's need for assistance with air, hotel, and transportation arrangements.
• Consider contacting guest/family once they have returned home to determine if they require additional support.
• Consider whether guest's name should be removed from marketing/promotional communication lists.

CLIA's members have adopted a policy that all equipment purchased and installed on cruise vessels will meet the regulatory standards of the Nevada Gaming Control Board or other licensed jurisdiction for payback and internal software.

Rules of play

The policy is that each line will provide a gaming guide setting forth the rules of play for their casino, and that these rules of play shall generally follow those established for casinos in Nevada, New Jersey, or England. To comply with CLIA's policy:

• These house rules must be made available in every casino.
• Each member is to post at every gaming table minimum and maximum betting limits for each game.
• Only adults are allowed to play the slots or the tables.

Internal controls

CLIA's member-approved policy is that all shipboard gambling operations be inspected by each member through its internal audit department on a regular basis, not to exceed 12 months.¹

Further, all casinos are directed by the policy to have detailed internal control procedures concerning the cash and coin counts, casino cage procedures and other processes, similar to licensed jurisdictions.

To comply with the policy each line must employ some form of surveillance to assure operations are fair and equitable for all parties.

The policy states that each line should separate the operation of the casino from the financial aspects of the casino as clearly as possible including specific duties for cashiers and table gaming staff.

Customer service

CLIA's policy is that onboard casino operations are the overall responsibility of the Hotel Manager or Director, or similar individual(s) charged with ensuring the highest level of conduct for casino staff.

In case of a gaming dispute, any passenger who feels he or she has an issue that cannot be resolved by the Casino Manager should be able to bring it up to the Hotel Manager, and CLIA's members have agreed that every effort should be made to resolve the problem. If the issue is not resolved on board the vessel, the policy is that each ship have at the casino cage a current list of contact information for their home office or casino operator where the passenger can pursue their dispute.

CLIA's policy is that cruise vessels have onboard comment cards for the inclusion of any comment, concern, or means to improve the gambling system on board the vessel. Gambling is strictly for the enjoyment of the passengers who choose to avail themselves of this form of entertainment.

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¹Inspection provision applies to shipboard gambling operations as a whole as opposed to individual ships.

CLIA members are committed to ethical business conduct and compliance with all applicable laws. Members may be subject to certain local, national and international anti-corruption laws, including the U.S. Foreign Corrupt Practices Act and the U.K. Bribery Act 2010. Violations could result in significant fines, penalties and even imprisonment. To enhance compliance with all such laws, Members need to commit themselves to the Anti-Corruption Principles set forth below.

Prohibit bribery and corruption
Prohibit the offering, giving or accepting of bribes, including payments, favors or anything of value to government officials or others to induce them to engage in improper or unlawful conduct or to improperly secure business or a business advantage. Promote a culture where the board, senior management, all employees and the entire organization are committed to honesty, integrity and preventing bribery.

Facilitation payments
Payments in cash or in kind (e.g. liquor, cigarettes, etc.) to government officials or others in a position of authority (e.g. customs, immigration, port and canal officials, pilots, etc.) intended to facilitate or expedite the performance of routine government action (e.g. clearing customs, processing visas, assigning berths, etc.) are prohibited, unless expressly permitted or required by local written law. Payment of fees to government agencies for legally required administrative services or an officially recognized "fast-track" process is permitted.

Hospitality
Ensure that hospitality (e.g. airfare, lodging, meals, etc.), gifts, entertainment and promotional expenditures provided to government officials or others, when permissible, are offered in good faith for legitimate business purposes (e.g. establishing cordial relations, promoting goodwill, demonstrating or explaining products and services, etc.) and are transparent, proportionate and reasonable.

Associate with ethical employees and business partners
Endeavour to associate with employees and business partners (e.g. agents, brokers, suppliers, subcontractors, etc.) who are ethical and do not engage in bribery. Strive to prevent bribery and corruption by employees, business partners and others performing services for or on behalf of the Member. Impose appropriate discipline or consequences for violations of relevant policies and procedures.

Adopt policies and procedures
Adopt, implement and enforce appropriate policies and procedures to prevent bribery and corruption. Educate officers, employees and business partners on such policies and procedures through appropriate communication and/or training. Periodically review and improve such policies and procedures as necessary.

Collaborate with governments, business partners and others
Collaborate with governments, business partners and relevant international organizations to support Members' efforts to prevent, detect, and combat corruption.

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