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The Navigate Response newsletter March 2017

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Page 1: The Navigate Response newsletter · 2017-03-19 · Cyber-crime Verifiable cyber-attacks against ships have been even more remote. A survey published last year by IHS Fairplay (in

The Navigate Response newsletterMarch 2017

Page 2: The Navigate Response newsletter · 2017-03-19 · Cyber-crime Verifiable cyber-attacks against ships have been even more remote. A survey published last year by IHS Fairplay (in

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Terrorism and cyber-crime are scary subjects, aren’t they? Each new article, new comment, new blog highlighting the threat to shipping raises our collective anxiety half a notch and validates the calls for more counter-measures.

It’s no surprise that terrorism and cyber-crime attract media attention and feature on conference agendas regularly.

Regrettably, the emphasis placed on terrorist and cyber-threats is counter-productive. It distorts our perception of security risk. By focusing attention on extreme and, by definition, relatively unlikely events, commonly-prevailing problems are glossed-over and left unaddressed.

Terrorism To put it in perspective, there have been five validated terrorist attacks against merchant ships since 2001.

In 2002, there was the attack on the Limburg, during which one person lost their life. In 2004, there was the attack on the Superferry 14, off the Philippines, which killed 116 people and is the deadliest terrorist attack at sea to date.

In 2005, there was an attack on the passenger vessel Don Ramon, also in Filipino waters. In 2010, the tanker M Star was attacked in the Straits of Hormuz.

And lastly, in 2013, the box-ship Cosco Asia was hit by an RPG while it was transiting the Suez Canal.

In contrast, there were 11,774 land-based terrorist attacks in 2015 alone.*

Cyber-crime Verifiable cyber-attacks against ships have been even more remote. A survey published last year by IHS Fairplay (in association with

Navigate Response

Spring is on the horizon here in London and our team is growing. We are very pleased to announce the addition of two new colleagues to our team.

Jonathan Spencer, Crisis Response Manager, brings extensive experience of media management from the front lines of some of the largest stories of the last two decades from Afghanistan’s conflict to Zimbabwe’s economic collapse; from meeting survivors days after Typhoon Haiyan hit the Philippines, to advising ministers and the military at the highest level.

James Woods, Crisis Response Manager, specialises in African business development and communications and has extensive experience working closely with leading international government clients, including heads of state, key policy makers, and oil and gas firms to manage reputation, media response, political risk and stakeholder engagement.

As James and Jonathan settle into their new roles we look forward to introducing them to all of you.

To any of you who may find yourself in London over the coming months, we extend an open invitation. If you have a spare hour in our city, please drop us a line and we’d love to see you for a cup of coffee (or a more traditional pint) and a chat about our sector.

Here’s wishing you all the very best for Q2 and beyond!

Mark your calendars

Navigate/IPTA Chemical & Product Tanker Conference, London, UK. 14-15 March 2017 http://www.navigateevents.com/events.html

Swedish Club event in Athens. We will be speaking about the role of media management in loss prevention. 6th April 2017.

Asian Marine Casualty Forum (AMCF), Singapore. 27-28 April, 2017. http://loc-group.com/amcf/

RINA & IMarEst 85th Andrew Laing Lecture. Dustin Eno will be speaking on the role of external stakeholders in a crisis. 11 May 2017.

Maritime security: ‘Let’s deal with the nearest crocodile to the canoe’

By James Wilkes, Managing Director, Gray Page

Page 3: The Navigate Response newsletter · 2017-03-19 · Cyber-crime Verifiable cyber-attacks against ships have been even more remote. A survey published last year by IHS Fairplay (in

The nearest crocodile to the canoe While terrorism and cyber-crime are serious issues, they are not, to coin a phrase, the nearest crocodile to the canoe. Piracy - and violence against seafarers in particular – is that crocodile, despite an improvement in the statistics during 2016.

According to the ICC-IMB there were 191 incidents of piracy and armed robbery “on the world’s seas” in 2016 and this represents an 18-year low. However, look closely and you will see that those numbers include 15 incidents when pirates kidnapped a total of 62 seamen for ransom. It is also a certainty that in the other 176 incidents – as well as the incidents that don’t get reported – very many seamen were physically assaulted and robbed of their personal possessions.

Piracy is a shore-based problem, at least strategically-speaking. It is accepted that instability on land creates the permissive environment

for criminality to succeed at sea. Without a resolution to conflict and corruption ashore, the threat of piracy will not be extinguished. That makes dealing with the threat a matter for governments, their militaries and law enforcement agencies.

However, on the other side of the security risk equation sits the vulnerability of ships and their crews to criminal threats. This is unquestionably a matter for shipowners, operators and managers, and the broader shipping community too.

The good thing here is that we get to choose how far we want to go in protecting the ships and seafarers that serve us; we get to determine the security posture of our ships and the level of security we afford their crews. The corollary of that is that it makes us responsible for actually doing so as well. To borrow another phrase, we need to walk the talk.

We will, I suspect, also discover that the knowledge, technology and experience we accumulate in tackling the security risks we face presently is the best way to prepare for what could be still greater threats in the future.

*The figures for land-based terrorist attacks come from the U.S. State Department’s annual Country Reports on Terrorism 2015.

James is a co-founder and Managing Director of Gray Page, a specialist and advisory and consulting group that solves problems around the world for companies and organisations in shipping, insurance and international trade.

James has extensive experience investigating piracy and acting as an Expert in court proceedings on piracy and matters of ship security. James also heads up Gray Page’s Asset Protection division which provides crisis management and security consulting services to shipping and insurance clients.

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BIMCO) about cyber-attacks on shipping revealed that of the ‘attacks’ reported by the 300 or so respondents only 4 % had some impact on the functionality of shipborne systems.

Further, it seems likely that some, if not most of the ‘attacks’ were ‘user error’; as in the inadvertent downloading of a virus from the internet or ported from a USB stick.

That is not to say we should ignore the potential threat of cyber-crime but rather to point out that we’re likely still some way off ships being hijacked or bulk cargoes being stolen through computer hacking.

Why? Because old-school criminal methods are easier to execute and continue to be incredibly effective. The majority of bulk cargo thefts that take place each year are from land-based storage facilities and without the sophistication of hacking a single computer.

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Page 4: The Navigate Response newsletter · 2017-03-19 · Cyber-crime Verifiable cyber-attacks against ships have been even more remote. A survey published last year by IHS Fairplay (in

Keep an updated contact list of staff emails, phone numbers and addresses.

It sounds basic but mobile phones get lost, numbers change, this information needs to be constantly updated to ensure that your messages are getting to your people.

Establish quick and efficient means of communication.

While email is generally the most utilised tool for communicating with staff important messages can often get lost in the clamour of a cluttered inbox. Use multiple forms of communication to guarantee the message is heard, try modernising your approach with a group WhatsApp message that conveys the gravity of the situation and puts your staff on alert. In this digital age your staff would probably look at a WhatsApp message first thing in the morning before they troll through their emails.

Include in your communications a basic template for all staff on how to deal with a media enquiry and the name and contact details of your media handler that staff should be diverting media to.

Also, remember that nothing you share digitally is ever private, so only write what you’d be ok with a journalist seeing.

If it’s a serious crisis hold a “Town Hall” for the entire office at the start of the business day. Use a common space to explain what’s going on and how it’s being handled. Allow staff to ask questions or voice their concerns.

Re-iterate your social media policy.

Make it very clear to your staff that posting on social media about company related matters during a crisis is not allowed. Take the opportunity to explain that it is important to protect the company and staff, especially the seafarers that may be involved. You can also empower your staff to report any social media posts that may hurt the company so that these can be addressed immediately.

Be open and honest

Share with them the news you plan to share with the media and other stakeholders, update them regularly on the latest developments so they’re not getting the latest news from rumours and innuendo.

By empowering your staff with the truth and the company’s plans to deal with the crisis you are not only easing anxiety about the situation and the future, you are also arming them to deal with the media in a calm and professional manner. This makes the company as a whole look like it’s on top of the situation.

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When the proverbial hits the fan how do you warn your people that the media storm is coming? The secretary or switchboard operator that answers the ringing phone as they walk in the door, the manager that has a cousin in the media or the finance officer who’s about to be caught on camera out the front of the office.

Your most important stakeholders are your staff regardless of rank or title, informed and empowered staff can be among your greatest assets during this challenging time. So, while you may have well established lines of communications to your crisis response team, P&I clubs and major clients, can you instantly advise your staff?

Here are a couple of basic steps to ensure your internal comms are ship shape.

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Talk to your troops when trouble is afoot

By Andrew Leahy, Senior Consultant Navigate Response Asia

Page 5: The Navigate Response newsletter · 2017-03-19 · Cyber-crime Verifiable cyber-attacks against ships have been even more remote. A survey published last year by IHS Fairplay (in

Do your customers or other stakeholders use social media?

Yes. Get online. Social media is a great way of building connections. Set up social media accounts on the platforms your customers are using.

No

Do you manage your own recruiting?

Yes. Get online. Social media is where candidates research employers. It’s also a great tool for investigating candidates.

No

Are you worried about regulatory interference?

Yes. Get online. Increasing public engagement with your perspective on an issue can influence regulators.

No

Do you care about your company’s brand recognition?

Yes. Get online. Social media is a great way of enhancing positive brand visibility.

No

Would you like to increase your website’s search engine ranking?

Yes. Get online. Linking to your site from social media will increase your ranking on search engines.

No

Do you want to be seen as a modern company?

Yes. If you didn’t use email you’d be seen as antiquated. Social media is rapidly becoming “expected.”

No. You might still consider creating a social media presence, but the benefits to your company will be limited at this stage.

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Do you have time to post at least once a fortnight?

Yes

No. Stay off social media. A dead social media account makes you look like a dead company.

Can you respond to comments within one business day?

Yes

No. Stay off social media. People expect a rapid response online and if they don’t get one they’ll become resentful.

Could you manage online pressure in a crisis?

Yes

No. Consider strengthening your response capabilities. Don’t join social media until you have.

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Should my company have a social media presence?

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Page 6: The Navigate Response newsletter · 2017-03-19 · Cyber-crime Verifiable cyber-attacks against ships have been even more remote. A survey published last year by IHS Fairplay (in

Communications is for the whole team

Communications functions are usually delegated to a select group and this is as it should be (too many voices are a recipe for disaster), but the comms team needs the support of the whole team and the experience of the coverage certainly won’t be isolated to a few.

Seafarers on a stricken ship may watch live television coverage of their vessel on their phones, salvors and QI’s may look to social media for the latest pictures of the incident, back office staff may follow breaking coverage from their desktops.

We wouldn’t think of running a major drill without using email or telephone; we must add social media to this list – it won’t be realistic unless there are tweets on your phone and journalists on the line.

Exercise fatigue

Exercises should be fun, engaging and memorable, but too often every exercise starts to feel the same and instead of being something to look forward to, exercises become an operational requirement to be completed with the minimum effort.

This attitude isn’t conducive to good learning or practice.

It’s time to shake things up. Get out of the routine and practice like it’s real. The exercise should be engaging enough that people are still talking about it days later – this is the best way to make the learning stick.

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Prepare to interact

Exercises should feel like real crises and real crises should feel like exercises.

We got tired of exercise participants telling us, ‘well if it had been real I would have…’ But would they?

Drills and exercises are a routine part of working in the maritime sector (we participate in 60+ a year for our clients), but how often do they actually feel real?

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Maritime exercises need to be more realistic

Why communications must be part of your exercise

Media pressure changes the experience of any incident and if it’s not realistically included in an exercise then you’re not practicing for a real incident.

Journalist calls can clog phone lines. Key decision makers can be kept busy with media enquiries. Charterers and other stakeholders will start demanding responses.

An external media responder (such as Navigate Response) will help to keep the pressure off your teams, but it cannot eliminate all issues and, more importantly, it is essential that you have practiced working seamlessly with the external team.

Page 7: The Navigate Response newsletter · 2017-03-19 · Cyber-crime Verifiable cyber-attacks against ships have been even more remote. A survey published last year by IHS Fairplay (in

“It felt just like the real thing. Great fun and very exciting. Most importantly, Triton gives participants the ability to check on what everyone else is doing! And I must say, that’s an element of realism I’ve never experienced in an exercise before.” Chris Coneybeer, BBC Journalist

“The exercise was a lot of fun and got everyone involved in a realistic context. The stream of simulated content demonstrated how quickly a story can evolve and how easily statements can be taken out of context.” Wai Lin Tan, Head of Corporate Communications at AET Tankers Pte Ltd

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Case Study

For a major national exercise with over 40 organisations and 500 people involved, our media simulation helped to bring the exercise together. From the shipowner, to the UK Government to the RSPCA responding to oiled wildlife, everyone could follow what was happing on their screens and be part of something much larger than their area of responsibility.

Working with a team of national, international and specialist shipping journalists, Navigate Response provided a highly realistic simulation, using the Triton training platform, which became the most talked about part of the exercise.

More importantly, the realism of the simulation helped to identify some important areas for improvement. Equally, the realism of the platform gave organisations an opportunity to showcase the strengths of their plans and to learn from the strengths of others.

Over two days of exercising, there were thousands of social media posts, dozens of television news reports and high-profile interviews with key officials – all viewable in real time by everyone participating in the exercise, just as it would be in a real incident.

Introducing Triton, a media and social media simulator for all exercises.

Page 8: The Navigate Response newsletter · 2017-03-19 · Cyber-crime Verifiable cyber-attacks against ships have been even more remote. A survey published last year by IHS Fairplay (in

and the news agency will do the rest. Sure, they’ll get their second source a little later. They’re watching the news on a monitor and the trending feed. A producer has called her best shipping contacts – your office even – but the story is already running as your operations manager is just being told of the damage. And context is left playing catch-up for the rest of the morning.

When history is written by public opinion the truth loses its currency.

The smart phone of course doesn’t lie – the camera, that is – and the picture is the first thousand words of the story, but devoid of facts or context.

The image speaks for itself. No one disputes a big ship listing on its side – a gift to any picture editor. And broadcasters love an eyewitness. But without context any one image, or first-hand account, can tell a thousand different stories.

The myriad public opinions, though they be little more than fake views, risk being a first draft of history.

A crisis response needs to contextualise, contain and where necessary correct a story. Background briefing and access for a couple of trusted journalists means the context is multi-sourced, news editors can’t ignore it and the guy on the beach is, well, just a guy on a beach walking his dog.

Taking control of the narrative isn’t manipulating the truth. It is safeguarding it.

Managing the story is surfacing the facts so that all involved, concerned and generally interested get to the truth, and any consequences are quickly in the right hands for correct action to follow – and not the hype and scare stories that only pollute the picture.

When history is written by public opinion the truth loses its currency.

Never let the facts get in the way of a good story – is the old adage from tabloid hacks that sure sold enough papers. But it hasn’t yet salvaged a ship – or a story in distress.

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Context for the story in distress

Jonathan Spencer, Crisis Response Manager Navigate Response

Context is everything in a story, and in a crisis it’s vital; context is the key to taking the heat out of a negative agenda or a loose claim that can all too soon form a narrative.

Fake news is several steps beyond legitimate journalism – and isn’t the theme here – although fake news can sometimes blur with events so that even credible journalists and commentators may run with a story angle if verified information is scarce.

Facts are vital, and yet the seeing, thinking, tweeting, sharing, posting – not necessarily in that order – can run far ahead of them.

The fog of war is an easily quipped phrase, although commanders can’t ignore it. The uncertainty of tactics or mechanics in the battle-space is perilous at best. And it is the same with media when the mist descends on a shipping crisis – or any other – and we don’t have the full picture. It is then that the speculation builds and journalists turn to ‘informed opinion’ from ‘experts’ – a former first officer, a local sea dog, or just some guy on the beach with a smart phone.

The image is shared, a few clicks later journalists ask – are-you-in-the-area…? have-you-any-pictures…? –

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Page 9: The Navigate Response newsletter · 2017-03-19 · Cyber-crime Verifiable cyber-attacks against ships have been even more remote. A survey published last year by IHS Fairplay (in

liquefied natural gas (LNG) as a marine fuel. Names like Carnival Corporation, DNV GL, Mitsubishi Corporation, Wartsila and Shell have put their considerable weight behind LNG with a stated aim of working proactively across the whole marine LNG value chain to increase the LNG infrastructure for safe and cost effective bunkering.

Why are they doing this? Firstly, LNG is a very clean fuel compared to the heavy fuel that is currently favoured and it complies with the looming regulations, so making it cost effective would be a huge step forward. There are of course many hurdles apart from cost, including safety fears associated with the high-energy content of LNG tanks and concerns about explosion in case of leakage. The LNG Tanker industry already boasts an impressive safety record, however public concerns about safety still need to be addressed before LNG bunkering can become common practice in ports around the world.

It’s not just SEA\LNG trumpeting LNG’s benefits; others are looking further than cost effectiveness and seeing it as a profitable future. Bernhard Schulte Shipmanagement (BSM) recently announced a collaboration with Babcock International Group to develop a cutting-edge Gas Supply Vessel (GSV) to service the anticipated

expansion of the LNG bunkering market. The highly manoeuvrable 7,500m³ vessel is designed to deliver LNG ship-to-ship whilst the client vessel continues loading and unloading. Using newly developed FGSV0™ technology, the LNG will be transferred with zero emissions, minimising any environmental impact. BSM expect delivery of the GSV in September 2018, from the Hyundai Mipo Dockyard in Ulsan, South Korea. It’s the first of many say BSM who are looking to mobilise multiple GSV’s in multiple ports across the globe.

BSM are so confident in the future of LNG that they’ve also announced they’re moving into LNG tanker ownership with the order of their first 174,000 m³ vessel. Overall, it’s a significant investment but also a significant statement by BSM that LNG is the future fuel of the shipping industry.

It seems all but certain that change through the sulphur cap is coming – an enforced evolution in an industry that is usually slow to change. Warren Buffet once said “Predicting rain doesn’t count. Building arks does.” So, should more of us be taking heed of the Noah’s in our ranks who are championing LNG?

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Forward thinking on fuels future

Andrew Leahy, Senior Consultant Navigate Response Asia

Whilst survival and consolidation are at the forefront of thinking across much of the shipping industry, forward thinkers also have an eye on the challenges looming ahead and the opportunities that lie within them.

One such challenge comes in the form of the IMO’s changing regulations on fuel and, in particular the planned implementation in 2020 of a global sulphur cap of 0.50%. That’s less than three years away, but many are choosing to sit back and wait for a process they argue will actually take many years longer…but not everyone!

Seven months ago, some of the shipping industry’s heaviest hitters set up SEA\LNG, a cross industry initiative to accelerate the use of

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Page 10: The Navigate Response newsletter · 2017-03-19 · Cyber-crime Verifiable cyber-attacks against ships have been even more remote. A survey published last year by IHS Fairplay (in

Media accessibility is a fact of life, so protocols need to be in place to ensure we equip our employees with the necessary skills to:

• Handle the media, should they be contacted.

• Be aware of how their posts could expose the company to scrutiny.

• Know who to contact in a crisis, should they be contacted.

This is where crisis communications and the need to engage with employees comes in. Employees are (or should be) the embodiment of the company culture and value. They are accessible to anyone who knows how to use technology, thus we must recognise that they are the brand ‘ambassadors.’

Research suggests that most crises occur when companies fail to identify contentious issues at an earlier stage and/or do not put into action a plan to manage the issue before it spirals out of control.

Senior management is often preoccupied with external factors such as ‘who is saying what?’, ‘on what platform’ and they forget their internal stakeholders who can calm a crisis (informed employees) or worsen the situation (rogue employees). Effective crisis communications management depends on both internal and

external players and it’s usually wise to prioritise the internal. There is nothing more powerful than an informed team to protect a reputation.

How to engage employees:

• Define the organisation’s vision and ensure you have employee buy-in.

• Nurture your employees. Ensure you provide them with the support to grow.

• Encourage employees to have a voice in the business.

• Treat employees as the most important stakeholders.

• Communicate with employees on a regular basis to keep them abreast of developments (especially in a crisis).

Informed, engaged employees are the ultimate secret weapon; and I say secret, because all too many senior managers overlook their significance.

“Our company’s greatest asset goes down the elevator every night.” - David Ogilvy, known as the father of advertising, founder of Ogilvy & Mather advertising and public relations agency.

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Your employees are your secret weapon

James Woods, Crisis Response Manager Navigate Response

Crises come in many forms, from simple human error (such as the recent Oscar Best Picture mix up) to a complex oil spill creating major environmental concern. But, from a crisis communications perspective, there are two features that make something a crisis, impact on stakeholders and media scrutiny.

We live in the most connected, technologically advanced period in human-history, an era of social media, which has been instrumental in expanding our sources of information. The average person in Europe spends 80 minutes a day consuming and sharing “news” on social media, and this includes the employees of companies in our sector. This new media engagement creates competition for traditional journalists, but it also creates a goldmine of insider information.

Journalists won’t hesitate to make contact via social media and make your employees’ casual comments global news.

In most cases employees are on the front lines of any crisis and their online presence from LinkedIn to Facebook makes them easily identifiable and easily accessible. Give it a try some time – start with employee profiles on LinkedIn for one of your competitors, then search these same people on Facebook and try to find a picture from a “private” company event. In most cases, it’s shockingly easy.

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major player in the global bunker market. It also has extensive port operations.

This company recently set up a news unit, staffed by 20 journalists, aimed at providing news and information for the markets they serve – on the spot news, prices and analysis of the bunker markets.

The new operation is in direct competition with the media in which the company appears so regularly.

The digitalised nature of information technology has made it possible to run a plausible, popular news website from a back bedroom or a local Starbucks. This, added to the fact that journalists tend to be a younger, low paid bunch in general, makes it an attractive proposition for corporates looking to by-pass traditional media and get their corporate messages out to specific audiences.

We can see this trend increasing within shipping and oil and gas, sectors which traditionally have had few friends in the mainstream media.

But creating content is a new skill for most companies in maritime, so it requires new capabilities and expertise. Building a ‘brand newsroom’ gives the industry control over its messaging and content — and the ability to create and distribute content quickly.

The staffing will vary depending on the kind of shipping company, but one key role is essential: Someone in charge. It can be a “chief content officer” or a “managing editor” or a head of communications, but there has to be someone with a strong understanding of three related but very different things:

• The company’s goals, messages and potential audiences.

• The art of storytelling, whether from experience in journalism or communications.

• The technology, tools and partners needed to produce and distribute content effectively.

Depending on the goals, that person might hire professional journalists — either on staff or freelance — to research, report, write and publish content.

There are enough shipping and maritime journalists out there who will be content producers if asked. Indeed, we see a continuing trend within the maritime press of the ‘Hybrid’: one day the Hybrid is an independent journalist, the next day s/he puts his/her corporate communications hat on.

Shipping has for too long been an industry closed to the outside world. At its most noble, the aims of the ‘brand newsroom’ should be to make a closed company more open.

It should aim to make a company nervous about publicity more comfortable with it and to help it cope with a regulatory environment better than it thought possible before. To try new things, it should use new technology and break bad old habits of secrecy and opaqueness.

So the brand newsroom needs to be connected to the top level of the organisation. Perhaps it should be part of the office of the CEO. This would be a major culture change for most, but it is an important one – and it’s one the shipping industry will see more of in future.

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Building a “brand newsroom” in a shipping company

The traditional media’s relationship with the public, and in particular the business community, is changing rapidly.

While President Trump has gained publicity from labelling the US media “The Enemy”, there are other more subtle changes taking place in how communities and businesses view their relationship with journalists.

Today, many companies, in particular those engaged in the production and transport of oil, view the traditional media with deep suspicion. In the past this suspicion was played out by CEOs who took the view: “Say nothing” and “Don’t give them anything, they will go away”. But that attitude is changing fast with the dawning recognition that traditional media, so often seen as hostile, can be bypassed. Such is the power that the new digital media brings.

The revolution in digital news has spawned a new generation of media outlets owned by corporations and set up specifically to by-pass old media in an effort to get a corporate message across to a specific audience. The age of the ‘brand newsroom’ is here.

We have seen this most recently here in Asia with the setup of a newswire by a company long known as a news maker. It is a listed entity operating a fleet of vessels as well as being a

By Ed Ion, Director Navigate Response Singapore

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Page 12: The Navigate Response newsletter · 2017-03-19 · Cyber-crime Verifiable cyber-attacks against ships have been even more remote. A survey published last year by IHS Fairplay (in

Crisis communications for shippingNavigate Response is the strongest global crisis communications network specialising in the international shipping, port and offshore industries; headquartered in London and Singapore, we operate a global network of 34 offices in 24 countries around the world.

Engaging Navigate Response ensures that you are prepared for the worst and allows you to focus on dealing with the operational side of an incident without being distracted by the pressures of the 24/7 media.

Navigate Response is recommended by P&I Clubs in the International Group.

Contact

24/7 incident line: +44 (0)20 7283 9915 www.navigateresponse.com

United Kingdom

[email protected] +44 (0)20 3326 8451

Singapore

[email protected] +65 6222 6375

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