Safety and Quality Policy

The Senior Management of the Company is committed to delivering the highest quality services to the shipping industry with absolute regard for safety and the environment.

Company policy requires all staff to carry out their duties in a professional, efficient, and safe manner in compliance with all applicable laws, rules and regulations. Staff must not knowingly participate in any unsafe or illegal activity. Compliance includes taking into account codes, guidelines, flag state requirements and standards issued by the various maritime organisations.

The Company is committed to identifying all risks associated with its operations. Controls and safeguards must be put in place to minimise these risks in order to provide safe working conditions for all employees and third parties.

Company policy requires a safe, healthy, and productive workplace for all employees. The workplace, whether at sea or ashore, must be kept in a condition which will ensure that good standards of health and hygiene are maintained at all times.

Alcohol and/or drug abuse, including drug trafficking, will not be tolerated and the Company operates strict control measures which must be complied with. Both impair ability to perform properly and will have serious adverse effects on the safety, efficiency, and productivity of other employees and the Company as a whole. Any employee found in breach of this policy will be subject to disciplinary procedures. These policies apply equally to visitors which include pilots, office personnel, guests, and contractors. Certain clients insist on a zero alcohol policy.

The Company issues, maintains, and continually improves its various policies and Safety Management System (SMS). This provides for safe practices in ship operation and a safe working environment ashore and afloat. Compliance is a condition of employment, and all employees are required to strictly adhere to the policies and follow the procedures contained in the SMS.

The SMS meets as a minimum standard the requirements of the ISM Code and the ISO 9001 standards.

The Company is committed to the on-going and continual improvement of its safety management system. Quality and safety objectives are to be established and reviewed regularly. Through this and the development of safety management skills of its staff, ashore and afloat, the Company pursues the long-term goals of zero injuries to persons working onboard its managed fleet. All office and shipboard personnel are required to support and contribute to the effective implementation of the Company policies.

Date: 15-April-2023                                        Managing Director

ENVIRONMENTAL AND CONSERVATION OF ENERGY POLICY

The Senior Management of the Company is committed to delivering the highest quality services to the shipping industry with absolute regard for safety and the environment.

Company policy requires that all risks to the environment associated with the global operation of the Company offices and vessels are identified and controls put in place in order to ensure that the adverse effects of all emissions and discharges are minimised.

The Company operates a zero-tolerance policy for deliberate discharges in breach of MARPOL. Misuse of the Oily Water Separator (OWS) by any form of tampering and/or the use of by-pass pipes (‘magic pipes’) is strictly forbidden.

All logbooks, environmental records and working record books must be carefully and accurately maintained and be in agreement where applicable. This includes (but is not limited to) Deck and Engine Room logbooks, oil record books, garbage record books, ballast management records, seal records and sounding books.

Energy conservation is an essential part of environmental protection, and all vessels are to be provided with the Company’s Ship’s Energy Efficiency Management Plan (SEEMP). It is policy that the requirements of this plan are complied with in order to reduce the damaging emissions from burning of fossil fuels. Pollutants such as the oxides of Carbon, Nitrogen and Sulphur emitted to the atmosphere contribute to the effects of greenhouse gases and acid rain. Records of energy conservation are to be maintained and periodically reviewed. Any non-conformities relating to energy conservation shall be identified and corrected.

Through commitment to continual improvement in energy performance and development of environmental management skills of its staff, the Company pursues the goal of zero spills to the sea and minimal emissions to the environment. The Company recognizes that operational efficiencies make an invaluable contribution to reducing global carbon emissions and is committed to improving the energy efficiency throughout its operation.

Company Policy Requires:

• Compliance with mandatory rules and regulations, taking into account codes, guidelines and standards from maritime organisations;
• Actively promoting environmental and energy awareness through training and education;
• Operation of its offices and ships as efficiently as possible adopting the principles of re-use and recycling;
• Focussing on minimising pollutants at source through effective maintenance and supply of spares;
• Ensuring that residual wastes are disposed of in a safe and responsible manner, paying special attention to hazardous waste generated on board;
• Suppliers and contractors working under its direct control and affiliated companies to apply environmental standards consistent with its own;
• Wherever possible, suppliers provide the most energy efficient product or service in line with our Procedures;
• Benchmarking environmental performance;
• Verification of compliance by undertaking regular inspections and audits and rectifying non-compliance;
• Environmental or Energy objectives and targets are to be set and processes implemented to achieve them;
• Audits are required to ensure that the policy is complied with and that the environmental management system remains appropriate and is capable of adapting to changing circumstances.

Date: 15-April-2023                                        Managing Director

Security Policy

The Company is committed to providing a secure and safe working environment. Company policy requires security measures to be established and maintained with the aim of preventing illegal activity or hostile acts which endanger the safety and security of persons onboard and are a threat to property and the environment.

The Company complies with the International Ship and Port Facility Security (ISPS) Code and policy is to:

• Encourage a strong security culture based on international requirements to guard against those who deliberately seek to harm;
• Have in place security procedures, practices and guidance for ship operations to protect the security of the ship, ports and the wider community;
• Having safeguards in place to reduce the risk to passengers, crew and port personnel;
• Encourage the security skills and awareness of Company personnel ashore and onboard ship through training and other means;
• Contingency measures for emergencies relating to possible security incidents;

All personnel must comply with the Company’s security requirements and Ship Security Plans (SSP) and ensure that they are familiar with their duties in relation to pro-active on-board ship security.

In piracy areas it is policy that ‘best practice’ procedures prepared by industry groups must be followed and complied with. Company specific guidelines are to be prepared to augment and clarify company requirements.

The Company shall ensure that the Company Security Officers, Ship Security Officers and Masters are given the necessary support to fulfil their duties and responsibilities in accordance with SOLAS Chapter XI-2.

It is Company policy that there must be no unauthorised guns or ammunition onboard. Authorised weapons are limited to those carried by government officers, law enforcement officers, specialist security officers and other port officials who are expected to carry firearms as part of their normal security requirements or weapons / ammunition carried as part of the ship’s manifested cargo. Possession of unauthorized firearms, ammunition or other offensive weapons onboard is strictly prohibited and will result in disciplinary action and / or removal from the vessel.

Date: 15-April-2023                                        Managing Director

Social Media Policy

The Company recognizes the importance of social media as a forum for employees to post their own views and ideas. The Company policy requires rules to be followed when posting an article or picture concerning our company or any vessel managed by us. Material posted online can severely impact the Company and clients’ reputations and inaccurate or harmful material must not be posted. Staff must make it clear that views are their own and not as a Company representative.

Date: 15-April-2023                                        Managing Director

Declaration of Compliance

When this document has been read and understood, the declaration at the foot of this page is to be signed confirming understanding and compliance.
It is essential to note and understand the following key policy points.

• Compliance is a condition of employment.
• Personal drug and/or alcohol abuse will not be tolerated.
• The Company is committed in every way possible to stopping the carriage of drugs and prohibits the unlawful possession and handling of drugs on any vessel, on Company premises, or when conducting Company business.
• Staff must not knowingly participate in any unsafe or illegal activity and must comply at all times with all mandatory rules and regulations.
• I am aware of and will comply with our business ethics policy.
• The Company operates a zero-tolerance policy for deliberate discharges in breach of MARPOL. Misuse of the Oily Water Separator (OWS) by any form of tampering and/or the use of by-pass pipes (‘magic pipes’) is strictly forbidden.
• All logbooks, environmental records and working record books must be carefully and accurately maintained and be in agreement where applicable. This includes (but is not limited to) Deck and Engine Room logbooks, oil record books, garbage record books, ballast management records, seal records and sounding books.
• Failure to follow SMS procedures relating to the protection of the environment is a dismissible offence.
• If any violation is observed, this must be made known to the Master immediately.

Authorities now impose severe penalties both on the Owners and on individuals found guilty of causing pollution and this may include personal fines and imprisonment. In addition, any crewmember, after appropriate disciplinary procedures have been completed, found to have knowingly violated any of the above listed items will be considered guilty of “Serious Misconduct” and as such may be instantly dismissed from the vessel.

DECLARATION

I confirm that:

a) I have read, understood and will comply with the Safety & Quality Policy, Environmental and Conservation of Energy Policy, Drug and Alcohol Policy, and confirm my compliance.

b) I understand the warning given above and that I fully understand the penalties relating to this subject.

c) Employment is offered to and accepted by me on the understanding that I will comply with the Company procedures (SMS) while serving on board the vessel.

d) If I believe that undocumented procedures, unsafe and/or illegal practices are being followed or are taking place I shall bring this to the notice of the Master, the DPA or other Company representative without delay.

e) I will not delay reporting in order to notify a third party prior to notifying the Company.

To assist me in my understanding of the above, I also confirm that:

a) I have received and understood training in the SMS.

b) I have seen and understood the Environmental Compliance Procedures and I understand their content and implications.

c) I have no history of drug or alcohol abuse or smuggling of illegal substances and confirm I have not been convicted of any criminal offence, drug related or otherwise.

                                                                                                                                 Name    ________________

                                                                                                                                 Signature    ________________ Date    ________________

                                                                                                                                 Rank    ________________ Vessel    ________________

Human Resources – General

Senior Management recognises that people are the most important asset of the Company and the effective planning and management of human resources is an essential part of providing quality service. No person is to be discriminated against on the grounds of age, gender, sexual orientation, disability, marital status, family status, religion, colour, race, ethnic or national origin. All employees are to be treated with respect, dignity and courtesy. Local employment legislation must be adhered to at all times It is essential that all personnel understand that their performance contributes to the success of the organisation and appreciate the importance of effective teamwork, commitment and loyalty.

Human Resources – Shore Employees

The Company ensures its HR strategies are aligned with business strategy, and that its HR policies and procedures respond to the personal needs of employees and support operating efficiency.

Company policy requires:

• Office-based employees to be qualified in relation to their specific job tasks and responsibilities. All positions must have a detailed job description with the minimum education standards and experience level clearly specified. Appointments are made only on the basis of qualifications, skill, experience and aptitude;
• Senior management are responsible for ensuring that all personnel are aware of the aims of the Company and are properly trained and motivated to achieve its business goals and objectives and have access to the Company employment handbook and relevant local sections;
• The maintenance of accurate employee records and effective application of the Company performance appraisal system;
• The provision of a training and development programme in order for office personnel to improve their knowledge and experience;
• A structured employee development system and succession plan to ensure that the future management needs of the Company are met;
• Leaders and managers to adopt good people management skills.

Conditions of employment for office-based employees are set out in the Company's contracts of employment. Reward and incentive are linked to individual performance.

Human Resources – Seafarers

The Company is committed to the employment of competent and motivated seafarers recognising that this is vital in order to provide the standards of service required by our clients.

Company Policy requires:

• Ensuring that vessels are manned with qualified, experienced, medically fit and competent officers and crew.
• Operating an effective Shipboard Familiarization process, which ensures all are conversant with the Company Safety & Quality and Environmental & Conservation of Energy.
• Compliance with the crew selection and engagement procedure contained in the SMS;
• Encouraging individuals to improve and update their knowledge of modern shipboard procedures and to upgrade their certificates;
• Operating a programme for the training of deck and engine cadets;

This policy outlines the Company’s commitment to seafarers and their basic rights including health, welfare and working conditions.

Date: 15-April-2023                                        Managing Director

Social Media Policy

The Company recognises the importance of Social media as a forum for employees to post their own views and ideas. Shore and Sea-staff are required to follow certain rules when posting an article or picture concerning the Company or any vessel managed by us. Material posted online can severely impact the company and clients’ reputations.

• Never publish inaccurate information regarding the Company online.
• If you are unsure of the accuracy of your comments, do not publish them. If in doubt, check with your line Manager.
• Always ensure that if you are talking about your workplace online that you have made it clear any statements are your own and do not represent the views or values of the Company.
• Avoid violating the privacy of your co-workers, clients, and competitors etc.
• Only post online what you would be comfortable saying to people in person or in public. Would you be happy for your children, your parents, or your boss to read your comments?
• Never use social media as a platform to harm, intimidate, insult, threaten, defame or embarrass others.
• If you find hurtful or defamatory commentary about the Company on social media forums, help us combat such negativity by informing your immediate manager.

The Company monitors social media outlets as part of its overall media monitoring process.

Date: 15-April-2023                                        Managing Director

Drug and Alcohol Policy

The Company is fully committed to ensuring that all its employees, contractors, and facilities are free from Drug & Alcohol abuse in all its business activities wherever it operates.

To achieve the above, the company shall:

• Comply with applicable national, local, and international laws, rules and regulations, and industry code of practices.
• Ensure all its workplaces are FREE FROM DRUG & ALCOHOL by prohibiting the illicit use, possession, distribution, sale, storage, procurement or manufacture of the same.
• Require all its employees and contractors to undergo drug and alcohol testing in accordance with company’s procedures.
• Encourage employees who are drug and alcohol dependent to voluntarily seek professional counselling and rehabilitation.
• Take proactive steps to promote awareness among employees on the hazards and ill effects of drug and alcohol abuse.
• Require all employees and contractors to strictly adhere to the “ZERO DRUG AND ALCOHOL” policy.
• Any employee found to be in breach of this policy shall be summarily dismissed.

Date: 15-April-2023                                        Managing Director