Bullying on Ships — Step-by-Step SOP for Indian Cadets and Junior Officers

Before You Read Further — Emergency Contacts

If the situation is immediate and involves physical danger:

DGS India Grievance: 9004048406
ISWAN 24hr: +44 20 7323 2737
WhatsApp Chief: +91 99581 10235

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What This SOP Is For

This is a procedure document. It gives you exact steps, exact language, and exact contacts.

It exists because:

1. Most Indian seafarers — especially cadets and junior officers — do not know the formal process
2. Not knowing the process means not using it
3. Not using it means the bullying continues and your health deteriorates

The law is already on your side. You just need to know how to use it.

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What Counts as Bullying — The Legal Definition

Under MLC 2006 and the ISM Code, the following are reportable violations:

Physical:

• Any physical contact intended to harm or intimidate
• Physical threats — including gestures and implied threats
• Deliberate obstruction that creates physical danger

Verbal and Psychological:

• Systematic verbal abuse, humiliation, or shouting that is personal rather than job-related
• Public humiliation in front of crew members
• Deliberate social exclusion — meals, recreation, information
• Persistent criticism that has no basis in actual work performance

Operational:

• Forced extra work beyond STCW rest hour limits without compensation
• Exclusion from shore leave without legitimate operational reason
• Withholding of documents (CDC, passport) — this is also a criminal matter in most jurisdictions
• Assignment of dangerous tasks as punishment rather than legitimate operational need

Sexual harassment:

• Unwanted physical contact
• Sexual comments, gestures, or messages
• Requests for sexual acts in exchange for career advancement or protection

What is NOT bullying:

• Direct, firm correction of work errors during watch
• High standards of watchkeeping and maintenance
• Assigning physically demanding work as normal operational duty
• Criticism of specific actions accompanied by instruction on how to improve

The distinction: addressing the work versus attacking the person.

A senior officer who shouts “that mooring approach was wrong, here is what should have happened” is doing their job.
A senior officer who shouts “you are useless, you will never make officer, why are you even here” is bullying.

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STEP 1 — Documentation

Start before anything else. Start now.

For every incident, record within 24 hours:

DATE: [DD/MM/YYYY]
TIME: [HH:MM]  
LOCATION: [Specific location on vessel — engine room, bridge, mess room, etc.]
PERSONS PRESENT: [Name and rank of all present, including witnesses]
DESCRIPTION: [Exact words and/or actions — as close to verbatim as possible]
IMPACT: [Any physical injury, sleep disruption, missed meals, etc.]

Storage: Personal phone or device. Personal email account. NOT a ship system. NOT a notebook that can be confiscated.

Why this matters: In any DGS inquiry, arbitration, or legal proceeding, evidence is everything. A complaint without documentation is much harder to pursue. Documented complaints with dates, times, witnesses, and specific language are far more actionable.

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STEP 2 — Informal Resolution Attempt (Optional but Recommended)

Before formal complaint, an informal approach is sometimes appropriate — and is often required to show you tried.

If the situation is not severe and the person involved is accessible:

Speak to the person directly, calmly, with a witness if possible:

“On [date], when you said [specific words] in front of [names], that crossed a line. I am asking you directly to stop. I am documenting this conversation.”

This accomplishes two things:

1. It puts the person on notice that you are documenting
2. It creates a record that informal resolution was attempted before formal complaint

Skip this step if:

• Physical threat or assault has occurred
• Sexual harassment has occurred
• You do not feel safe raising it directly
• A previous informal attempt has been ignored

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STEP 3 — Formal Written Complaint

If the bully is any officer other than the Master:

Email to: Master AND DPA simultaneously

If the bully is the Master:

Email to: DPA only — do not involve the Master

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Complaint Template

TO: [Master name and email] / [DPA name and email — from your SEA or crew list]
CC: [Your personal email — send a copy to yourself]
DATE: [Date]
SUBJECT: Formal Complaint — Harassment/Bullying — MLC 2006 Regulation 4.3

Dear [Title/Name],

I am writing to formally report incidents of [bullying/harassment/physical intimidation] 
in violation of MLC 2006 Regulation 4.3 (Occupational Health and Safety) and the 
vessel's SMS anti-harassment procedures.

INCIDENTS:

[Incident 1]
Date: [Date]  
Time: [Time]  
Location: [Location]  
Description: [Specific words/actions]  
Witnesses: [Names if applicable]

[Incident 2 — repeat as needed]

REQUESTED RESPONSE:
1. Written acknowledgement of this complaint within 48 hours
2. Investigation in accordance with the SMS procedure
3. Written outcome of the investigation within [14 days]

I reserve the right to escalate this complaint to DGS India (9004048406) and the 
ITF if a satisfactory resolution is not reached within the stated timeframe.

[Your Name]
[Your Rank]
[Vessel Name]
[Date]

Send from your personal email account, not ship systems.
BCC your personal email so you have a sent copy.

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STEP 4 — Escalation if No Response

If no written acknowledgement within 48 hours, or no investigation outcome within 14 days:

DGS India

Helpline: 9004048406
Email: secy-dgs@nic.in

Send your complete complaint with all documentation. State that you have sent a formal complaint to the Master/DPA on [date] and have received no adequate response.

DGS has authority under the Merchant Shipping Act to investigate and take action against the vessel, the company, and/or the individuals involved.

ITF Inspector at Port

Website: itfglobal.org/ITF/iportal/en/inspectors

Find the nearest inspector to your next port of call. ITF inspectors can:

• Board the vessel
• Speak with crew confidentially
• Apply direct pressure on the company
• Assist with repatriation if the situation requires it

This is particularly effective for salary/contract disputes but also works for harassment cases. ITF has a strong track record of action on Indian seafarer complaints.

Port State Control

If there is an immediate safety risk — physical assault, threats, an environment where you genuinely cannot perform watchkeeping safely:

At any major port, PSC officers can be contacted. They have authority to:

• Board and inspect for ISM Code compliance
• Detain the vessel
• Require crew changes

This is the most aggressive escalation. Use it for situations that are genuinely dangerous, not as a first step.

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If You Are a Cadet — Specific Guidance

Cadets are in the most vulnerable position: no rank authority, entirely dependent on the company for their training record book completion, and often unaware of their rights.

What you need to know specifically:

1. Your TRB completion is not held hostage by the Master. The DPA and company training department have authority over TRB signing, not just the Master. A Master who threatens to fail your TRB as retaliation for a complaint is committing a separate MLC 2006 violation.

2. Contact your institute’s placement coordinator. Your training institute placed you on this vessel. They have a relationship with the company and a responsibility for your welfare. Email them directly with your documented complaint. They have leverage the company cares about.

3. ISWAN specifically supports cadets. +44 20 7323 2737. Maritime welfare counsellors who understand the TRB, the cadet position, and the specific power dynamics.

4. WhatsApp Chief at Sailor Success. +91 99581 10235. Confidential. If you are a cadet in a difficult situation and you do not know where to start — start here.

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What Happens to Your Career

The fear that derails most complaints is: “if I report, my career is over.”

This fear is understandable. It is also statistically wrong when the process is used correctly.

What actually happens:

• MLC 2006 explicitly prohibits retaliation against complainants. A company that retaliates is committing a separate MLC violation that is itself reportable to DGS.

• Companies are more exposed to regulatory risk than individual seafarers think. A DGS investigation creates liability. Most complaints, when escalated to the DPA level, result in the vessel removing the problem officer — not the complainant.

• Blacklisting is a real but overstated risk. It applies primarily in cases where the seafarer has made multiple complaints across companies with no substance. A single documented, legitimate complaint against a specific senior officer does not blacklist you.

• The seafarers who suffer most long-term are those who endure without reporting. The unresolved trauma from sustained bullying accumulates across contracts and eventually forces them out of the industry anyway — on worse terms.

The honest answer: Using the formal process, correctly, with documentation, is the path with the lowest long-term career risk. Not using it, and suffering for months or years, is the higher risk path.

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Immediate Wellbeing — While the Process Runs

Formal complaints take time. While waiting:

ISWAN 24hr: +44 20 7323 2737 — talk to a maritime welfare counsellor about your current situation. They can provide support and also advise on the complaint process.

SailorGPT: sailorsuccess.online/sailorgpt — discuss your specific situation. Available 24/7.

WhatsApp Chief: +91 99581 10235 — confidential.

Do not carry this alone while the process works. Get support in parallel.