Table of Contents
Recruitment and Placement Service Licensees (RPSLs) play a significant part in ensuring compliance with the Seafarers Code of Conduct, as per the Directorate General of Shipping guidelines, which will come into effect from January 1, 2026. The whole system described within the DGS Seafarers Code of Conduct Compliance Enforcement Manual states strict disciplinary action for defaulting in terms of safety, harassment, or violation of the Maritime Labour Convention 2006. The awareness of measures taken by RPSL against seafarers for violation of codes helps in maintaining safety and professional standards within Indian operations, which relates to overall compliance requirements mentioned in DGS Order 2025 and RPSL licensing.
Why do RPSLs Enforce Seafarer Code Violations?
RPSLs enforce breaches in an attempt to promote voluntary compliance, protect maritime security, and implement conformity with international frameworks such as STCW, SOLAS, and MLC 2006 in conformity with the guidelines under the Merchant Shipping Act. The framework for enforcing breaches focuses on transparency, proportionality, and natural justice, allowing RPSLs to handle minor issues in-house with their Safety Management Systems (SMS) before referring them to DGS. This also helps RPSLs prevent deliberate non-compliance that may threaten life, environment, and reputation in line with the key principles illustrated in the manual guidelines for RPSLs listed within the INDOSearch RPSL directory.

What Violations Trigger RPSL Actions Against Seafarers?
Examples of these are: violation of the Drug & Alcohol rule, harassment, bullying, tampering of records in the logbook, acts of sabotage, unauthorized absences, or disobedience of the MARPOL rules. The level of gravity ranges from less serious offenses, such as retaliatory reporting, suspension for 3-12 months, while the opposite end covers the most serious ones, for example, gross acts involving death or pollution, resulting in permanent blacklisting. Reports should be submitted using the form for the Initial Violation Process by RPSLs, beginning procedures for investigations connected with MLC 2006 certification for complete welfare standard compliance.
| Violation | 1st Offense Penalty | 2nd Offense | 3rd Offense | Relevance to RPSL |
| DA Policy on Duty | 1 year suspension | Permanent | N/A | Internal Probe, DGS Report |
| Harrasment/ Assault | 1 year | 2 years | 3 years | Zero tolerance, grievance office |
| Ship Sabotage | 1 year | 3 years | 5 years | Risk matrix escalation |
| Desertion | 2 years | 3 years | Permanent | License impact per MS RPSL Rules |
How Do RPSLs Initiate Disciplinary Actions?
The Form of Initial Violation Process Forms is normally completed by RPSLs after making an initial detection, either by inspection, complaints, or surveillance, which indicates WHO, WHAT, WHEN, WHY, and HOW. There is also an extensive investigative stage, which involves analyzing witnesses, defenses of necessity, due diligence, and obtaining evidence before carrying out another remedy, which may be counseling, warning, fines, or suspension. Show Cause Notices have 15 days to be responded to before appeals go to higher officials of DGS, which is very essential for RPSLs relating to new RPSL Companies.

When Are Severe Penalties Like Blacklisting Applied?
Consecutive and high-hazard activities entail severe sentencing: smuggling, 3 years to permanent, accidents committed under influence, 3- 5 years/lifetime, and environmental sabotage, permanent. Risk Matrix follows the assessment of severity levels: people, environment, assets, and reputation, thus following the Sanction Matrix for penalties involving suspension over a period of more than 1 year or cancellation outright. Judicial action will go through the FIR/court for cognizable offenses. RPSLs run the danger of losing their licenses on grounds of abandonment; review the medical reports coming from the DGS-approved doctors for PEME in order to ward off fake medical claims.
What Role Does the Star System Play in Enforcement?
The proposed handbook recommends a star system for the seafarers, wherein stars would be gained by rewarding and acknowledging safety, skill, and professionalism, and reduced for lapses that result in loss or reduced pay, career development, and deployment. Established thresholds ensure the prevention of poor conduct; open monitoring ensures accountability, a significant element in addition to the Maritime Labour Convention Amendments. RPSLs monitor and record the same for deployments, thus ensuring better compliance.
What Role Does the Star System Play in Enforcement?
The proposed handbook recommends a star system for the seafarers, wherein stars would be gained by rewarding and acknowledging safety, skill, and professionalism, and reduced for lapses that result in loss or reduced pay, career development, and deployment. Established thresholds ensure the prevention of poor conduct; open monitoring ensures accountability, a significant element in addition to the Maritime Labour Convention Amendments. RPSLs monitor and record the same for deployments, thus ensuring better compliance.

How Can Seafarers Avoid RPSL Actions?
Seafarers follow guidelines, including environmental protection, safety regulations, and reporting protocols, such as the DA policy, to prevent risks and ensure a safe working environment. Training throughMTIs and unions, approved by DGS, increases awareness; RPSLs provide support via QHSE initiatives. For startups, seek advice from a maritime consultancy regarding RPSL.
What is the first step RPSLs take for code violations?
RPSLs then fill out the Initial Violation Process Form and send it to DGS to further investigate the violation.
Can seafarers appeal RPSL disciplinary actions?
Within the timeframe of 30 days, the appeal can be made to the appellate officers, following the principles of natural justice.
What penalties do RPSLs face for mishandling violations?
Suspensions, penalties as fines, as well as revocation of license, as per MS RPSL Rules, such as cases about seafarer abandonment, etc.
How does MLC 2006 link to these RPSL actions?
The Minimum Living Conditions specify the welfare standards to be adhered to; failure to which the code being enforced.
When did the Seafarers Code Enforcement Manual start?
DGS Order No. 10 of 2025 will come into effect from January 1, 2026.
What Happens After DGS Receives an RPSL Complaint?
DGS assigns investigators, conducts probes, issues Show Cause Notices, and decides on actions like NFA or penalties
Can Seafarers Appeal Lodged Complaints?
Yes, within 30 days to the appellate authorities, ensuring natural justice and review of evidence.
What Is the Role of VDR in Complaints?
Voyage Data Recorder provides critical evidence for safety breach investigations post-RPSL lodging.
How Do Repeat Violations Affect Future Complaints?
Recurrent cases lead to escalated sanctions, star system deductions, and potential license revocation.