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the BG Institutions insist that according with Article 1, item 1, ( c) of Recruitment and Placement of Seafarers Convention 1996 (No.179), a company can carry out manning activities ONLY if they have signed a Agent Contract directly with a ship Owner. By "shipowner" they mean the actual owner of the vessels.
Kindly ask you for your competent commentary
Thanks in advance
George

And what exactly is to be commented? Where is the problem?

Additional:
The reason of my asking for a commentary is as the following:
We are a BG licensed manning company. In accordance with the requirements of the BG Government Institution, we are obliged to submit to them, each signed Agent Agreement for Seafarers Employment with a foreign company.
Connected with the above, we present to them a such Agent contract, which is signed between us and a UK company. The activities of this UK company are recruitment and placement of seafarers to different shipowner and shipmanagement’s companies.
The BG Institution refuse to record the Agent Agreement. The motive of the refusal is that the UK Company is not a Shipowner. The BG Institution seam that in the sense of Aricle 1, item 1, ( c ) of the Recruitment and Placement of Seafarers Convention 1996 ( No.179 ) the status of the UK Company is not in correspondence with this Convention.
I think that the Article 1, item 1, ( a, b, c and d ) are only as an explanation of the meaning of the used terms (competent authority, recruitment and placement service, shipowner and seafarers).

According to
Article 4


1. A Member shall, by means of national laws or applicable regulations:

(b) determine whether and under which conditions recruitment and placement services may place or recruit seafarers abroad;

As far as I can understand from your description of the problem the Bulgarian authorities would like to verify that the seafarers ultimately have employment with a particular shipowner. And according to the definition of a shipowner such can be an "agent" but one "who has assumed the responsibility for operation of the ship from the shipowner and who on assuming such responsibilities has agreed to take over all the attendant duties and responsibilities" (Art.1, p. c). This agent mentioned in p. (c) is different from the figure of the "recruitment and placement service agency" defined in Art. 1, p. b, in so far as the latter is the link between the seafarers and the employers but it is not the direct employer itself.

Therefore, I think, that in addition to the agency contract with the seafarers agency you should also provide proof that the job offers are not in the abstract but are at the stage of individual employment of the seafarers. Or maybe you could show contracts that the seafarers agency has with "shipowners" within the meaning of the Convention.

But, I would suggest that your documents be carefully examined by a lawyer who could advise you according to the specifics of your case.

Would you please suggest some lowyer who could advise me according to the specifics of our case?

vladimirovlaw.com