Chapter 1: Amid compliance overhaul, COVID-19 hits hard
Carnival’s checkered past of violating environmental laws was no secret. The company pleaded guilty in federal court both in 2002 and 2017 to illegally discharging oily waste into the seas and falsifying records of oil-contaminated bilge water to cover its tracks. The first time the transgressions were caught on several ships in the Carnival Cruise Line fleet; the second time it was an insidious issue in the Princess fleet. According to the Department of Justice, the commonalities in widespread, covert misconduct over a 25-year stretch suggested the company harbored a systemic problem of ethics and culture that was never properly rooted out.
It was an overhaul that would take time, teamwork, patience, commitment, and a good amount of ingenuity. The newly minted E&C department was tasked with uniting the operating companies’ compliance functions, developing trust and rapport with shipboard and shoreside personnel, reinventing the company’s ethical culture, and last but certainly not least, abiding by a court-mandated and supervised five-year environmental compliance plan (ECP) that included a court-appointed monitor (CAM).
The terms stipulated by the ECP were a tall order. Peter Anderson, the new chief ethics and compliance officer (CECO) and a former federal prosecutor, was confident he could turn Carnival’s compliance woes around.