1. Purpose of this Policy

Shipping transactions and advisory enquiries often involve information that can affect vessel value, negotiation position, chartering strategy, market perception, financing discussions, compliance review, or counterparty reputation.

RdM’s approach is built around clarity before commitment. That means information shared with us is not treated casually or circulated indiscriminately. We aim to handle confidential information with care, commercial discretion, and appropriate professional discipline.

2. Scope

This policy applies to confidential, commercially sensitive, or restricted information shared with RdM through this website, email, WhatsApp, telephone, meetings, Google Forms, intake forms, document links, valuation requests, chartering check submissions, advisory engagements, broking discussions, or other business communications.

It applies across RdM’s work, including:

3. What We Treat as Confidential Information

Depending on the nature of the enquiry or engagement, confidential information may include:

• Vessel name, IMO number, specifications, class status, survey status, inspection information, trading history, photos, reports, Q88 / Form C / technical particulars, or similar vessel data.
• Ship valuation instructions, value expectations, price guidance, asking levels, offer levels, negotiation comments, and valuation assumptions.
• Chartering requirements, cargo details, parcel size, route, ports, laycan, loading / discharging assumptions, freight expectations, vessel-fit information, and commercial constraints.
• Buyer, seller, owner, charterer, financier, broker, intermediary, or mandate details.
• KYC / KYB documents, authority-chain information, company profiles, beneficial ownership details, sanctions or compliance-related confirmations, where requested.
• Commercial strategy, transaction discussions, internal decision-making context, financing discussions, dispute-sensitive material, and confidential communications.
• Personal data and business contact details shared as part of an enquiry or engagement.

Some vessel and market information may already be available from public or commercial sources. However, the fact that a particular party is reviewing, buying, selling, valuing, financing, chartering, inspecting, negotiating, or considering a vessel or transaction may itself be commercially sensitive.

4. Our Confidentiality Commitment

RdM will use confidential information only for the purpose for which it was provided, or for a closely related professional purpose connected with the relevant enquiry, advisory work, valuation, chartering check, broking discussion, compliance review, or transaction support.

We aim to:

• Handle confidential information with commercial discretion.
• Restrict internal access to personnel who reasonably need to know the information.
• Avoid unnecessary circulation of vessel, counterparty, mandate, pricing, or transaction information.
• Clarify disclosure boundaries before approaching owners, buyers, charterers, co-brokers, surveyors, financiers, or other third parties where appropriate.
• Use secure or commercially sensible communication channels where practical.
• Maintain written records where needed for clarity, audit trail, compliance, and proper review.

5. Information That May Not Be Treated as Confidential

Confidentiality obligations under this policy do not apply to information that:

• Is or becomes publicly available through no breach by RdM.
• Was already known to RdM before disclosure without an obligation of confidentiality.
• Is lawfully received from a third party without confidentiality restrictions.
• Is independently developed by RdM without use of the confidential information.
• Is approved in writing by the disclosing party for release or wider circulation.
• Is required to be disclosed by law, regulation, court order, sanctions / AML requirement, or competent authority.
• Is aggregated or de-identified so that it does not reasonably identify the client, counterparty, vessel, transaction, or confidential commercial situation.

6. Permitted Use

RdM may use confidential information for legitimate maritime business purposes connected with the relevant enquiry or engagement, including:

• Assessing whether RdM can assist with a matter.
• Preparing ship valuations, chartering checks, feasibility snapshots, pre-deal assessments, or advisory outputs.
• Reviewing vessel details, pricing logic, commercial assumptions, cargo movement feasibility, or chartering workability.
• Understanding mandate, authority, role, counterparty credibility, and commercial alignment.
• Conducting proportionate KYC / KYB, sanctions, AML, fraud-prevention, or compliance-related review.
• Communicating with the client, authorised representative, or agreed parties involved in the matter.
• Maintaining business records, audit trail, engagement history, accounting records, and internal workflow discipline.
• Protecting RdM’s legitimate business interests, legal rights, professional reputation, and compliance position.

7. Permitted Disclosure

RdM may disclose confidential information where reasonably necessary for the relevant matter and consistent with the purpose for which the information was shared. Such disclosure may include:

• Disclosure to RdM personnel, representatives, or support team members who need access for the relevant work.
• Disclosure to service providers such as secure cloud storage, email, website hosting, forms, payment, document management, analytics, CRM, accounting, or communication tools acting in support of RdM’s work.
• Disclosure to professional advisers such as lawyers, accountants, compliance advisers, insurers, technical consultants, surveyors, or other specialists under appropriate confidentiality expectations.
• Disclosure to shipowners, buyers, sellers, charterers, operators, managers, financiers, escrow agents, co-brokers, or other transaction parties where the disclosure is necessary and commercially appropriate for the intended purpose.
• Disclosure required by law, regulation, sanctions / AML obligations, court order, arbitration, regulator, government authority, or law enforcement agency.
• Disclosure necessary to pursue, defend, or preserve legal, contractual, commercial, or professional rights.

RdM does not sell confidential information. RdM does not knowingly circulate confidential transaction information as general market gossip or speculative market material.

8. NDA, NCNDA & Formal Confidentiality Agreements

This Confidentiality Policy provides a general framework for how RdM handles information. It does not replace a formal Non-Disclosure Agreement, Non-Circumvention / Non-Disclosure Agreement, engagement letter, mandate, recap, charterparty, memorandum of agreement, or other written transaction document.

Where a matter involves sensitive commercial exposure, vessel identity, buyer / seller identity, charterer identity, pricing strategy, financing information, inspection access, negotiation position, or multi-party brokerage chain, RdM may request or agree to a suitable written confidentiality arrangement before further disclosure or circulation.

If you require a formal NDA before sharing information, please inform us before submitting sensitive material.

9. Security & Information Handling

RdM takes reasonable administrative, technical, and organisational steps to protect confidential information in its possession or control against unauthorised access, collection, use, disclosure, copying, modification, disposal, loss, or similar risks.

These steps may include:

• Need-to-know internal access.
• Careful handling of sensitive vessel, counterparty, and transaction information.
• Use of email, cloud storage, forms, CRM, and communication tools with reasonable access controls.
• Password protection or restricted sharing where appropriate.
• Separation of advisory review, broking execution, and internal workflow records where practical.
• Caution when forwarding documents, screenshots, reports, valuation material, or WhatsApp messages.

No electronic communication or storage method is completely secure. Please avoid sending passports, bank statements, personal identification documents, crew lists, or highly sensitive financial documents unless specifically requested and unless the handling basis is clear.

10. Cross-Border Handling

Maritime business is international by nature. Confidential information may be received from, stored in, accessed from, or shared with parties located outside Singapore, including India and other jurisdictions connected with the vessel, owner, charterer, buyer, seller, financing, inspection, port, cargo, or advisory matter.

Where confidential information includes personal data, the handling of such personal data is also subject to our Privacy Policy. Where information is transferred outside Singapore, RdM will take reasonable steps to apply appropriate confidentiality, contractual, operational, or data protection safeguards, depending on the circumstances.

11. Return, Deletion & Retention

You may request in writing that RdM return or delete confidential information that you have provided. RdM will consider such requests reasonably, subject to legal, regulatory, accounting, audit, compliance, tax, dispute-resolution, contractual, insurance, operational, or legitimate business record requirements.

RdM may retain copies of information where necessary to:

• Document the basis of advisory work, valuation, chartering check, broking discussion, or transaction communication.
• Comply with legal, tax, accounting, audit, KYC / KYB, sanctions, AML, or regulatory obligations.
• Preserve evidence of instructions, authority, disclosures, communications, or commercial decisions.
• Protect legitimate business interests or defend against claims.

When confidential information is no longer required, RdM will take reasonable steps to delete, anonymise, archive, or securely dispose of it, subject to operational and legal requirements.

12. Duration of Confidentiality

Unless a separate written agreement provides otherwise, RdM’s confidentiality approach under this policy applies during the relevant enquiry or engagement and for a reasonable period thereafter.

As a practical baseline, RdM treats confidential information as confidential for three (3) years after the relevant enquiry or engagement ends. Information that qualifies as trade secrets, highly sensitive commercial information, restricted compliance material, or information that remains non-public and commercially sensitive may be treated with confidentiality for a longer period where appropriate.

13. No Waiver, No Agency & No Professional Advice

Nothing in this policy creates an agency, partnership, fiduciary relationship, exclusive mandate, brokerage entitlement, commission agreement, or transaction obligation unless separately agreed in writing.

RdM provides commercial maritime views, advisory observations, valuation opinions, chartering checks, and broking support based on available information and professional judgement. Unless specifically agreed in writing, RdM does not provide legal, tax, accounting, regulated financial, insurance, sanctions, or formal compliance advice.

This policy does not waive any rights, remedies, privileges, or protections available to RdM or any other party under applicable law, contract, confidentiality agreement, or transaction documentation.

14. Changes to this Policy

RdM may update this Confidentiality Policy from time to time to reflect changes in our services, website, business processes, technology, legal requirements, commercial practice, or maritime industry expectations.

The updated version will be posted on this page with a revised “Last updated” date.

15. Contact

For confidentiality-related questions, NDA requests, or concerns about information handling, please contact:

Please do not send highly sensitive documents unless requested. If you require a formal NDA before sharing information, please state this clearly at the start of the communication.