Shipping is a fragmented, global industry operating in a culturally diverse environment. As a result of rising maritime accident rates and pollution incidents in the 1970s and 1980s, the International Maritime Organisation introduced two conventions that entered fully into force in 2002: the International Management Code for the Safe Operation of Ships and Pollution Prevention (ISM Code), and the 1995 revision of the 1978 Convention on Standards of Training, Certification and Watchkeeping for Seafarers (STCW Code). Introduction of the conventions served to focus the attention of the international maritime community on the need to raise industry-wide safety standards, but questions were raised about whether it was possible to develop a safety culture in a fragmented, global industry and what effects the diversity of cultures might have upon implementation of the ISM Code. This study explores those questions. Subsequent to a review of the literature, a model of the working of the ISM Code is developed and used to identify the constraints and pressures, particularly those that might be influenced by cultural values and attitudes, that impact upon the development and implementation of a Safety Management System in individual shipping organisations, which is the essence of the ISM Code. A comparative case study methodology is adopted for the empirical research and a number of investigative techniques are used to test the ISM Code model and obtain both qualitative and quantitative data to determine whether the impact of culturally influenced constraints and pressures would be best addressed by stricter enforcement of existing regulatory provisions or greater emphasis on education and training. From analysis of the data collected, the study concluded that: • Professional, vocational and safety training correctly utilised are effective in harmonising culturally influenced safety perspectives, thus improving safety performance; and • Culturally influenced constraints and pressures can be dealt with by the application of standard management techniques which, in a multi-cultural environment requires good cross-cultural management skills. The most common method of determining how effective a company has been in dealing with the various constraints and pressures affecting safety performance is to evaluate the efficacy of the organisation's Safety Management System by analysis of accident records, lost time incidents and hazardous occurrences (ACNSI, 1993). These data, reported under the provisions of Clause 9 of the ISM Code, are therefore analysed and compared with an industry sector benchmark. The study however, goes beyond such a purely quantitative approach and establishes the relative safety climate of the case study companies by means of perceptual audit of salient, safety-related factors. This qualitative technique draws together all the main research elements of the study and a Safety Climate Comparator is developed that provides a useful indicator of the relative status of those culturally influenced factors that ultimately affect a company's safety performance. By extension, the technique may be used to provide a Relative Safety Culture Maturity Model to measure the safety climate of other shipping companies relative to a benchmark standard.