CMM	Crew Management Manual (CMM) Third Party Manning Agencies	Doc No.: CMM-6.4 Revision: 01 Date: 15 Oct 2024 Issued by: DPA Approved by: MD

THIRD PARTY MANNING AGENCIES (Recruitment and Placement Services)

This procedure applies to the supply to vessels under technical and crew management contracts.

It is the Company requirement that any Third Party Manning Agency (TPA) utilised for seafarer Recruitment and Placement Services (RPS) must comply and conform to the standards set out in MLC 2006 Code as applicable.

Seafarers shall have access to an efficient, adequate and accountable system of recruitment and placement services (TPA) for finding employment on board ship without charge to the seafarer.

6.4.1 General

The MD shall liaise with the FLP Manager prior to making a decision on the source of seafarer supply for individual vessels. This decision shall be recorded on the A-16.

6.4.2 FLP Department

Seafarers are normally obtained through the network of TPA. These TPA shall be subject to audit undertaken annually by QHSSE Department. Records of audits shall be sent to FLP Manager and MD.

FLP department must comply with the requirements of the MLC 2006 Regulation 1.4 for Recruitment and Placement Services and all other MLC regulations as applicable.

For vessels scheduled to enter the Company management, the A-16 is completed under the responsibility of the FLP Manager.

The basic services supplied by the FLP Department are supported by their documented procedures, are:

• Recruitment
• Crew Selection
• Crew documentation including documentation verification
• Visa procurement
• Medical checks
• Career development
• Training

For each fleet of vessels, the MD in liaison with the FLP manager shall agree, the level of service and support that shall be. These shall be clearly detailed on the A-16 form.

Such services include:

• Travel arrangements to the vessel and associated communications;
• Travel arrangements from the vessel and associated communications;
• Crew rotation planning (always approved by the Crew Manager);
• Authority for seafarer approval by the MD or FLP Manager;
• Direct contact with client;
• Procurement for Flag licenses;
• Direct communication with vessels associated with crew changes and crew support;
• Seafarer appraisals;
• Crew administration function.

6.4.3 Third Party Manning Agencies (TPAs)

Only internally approved TPAs shall be used by the FLP Department. The list of approved TPAs is maintained by the FLP Manager and available on Crew Server.

The need to negotiate a manning agreement with a TPA may be identified by an MD. TPAs are internally categorised as either:

1. Crew Supply & Mobilisation TPA; where the TPA is responsible for recruitment and mobilisation procedures as per IMS requirements.
2. Crew Supply TPA; where the contracting the Company office is responsible for recruitment and mobilisation procedures as per IMS requirements.

The following factors shall be considered by the FLP Manager when evaluating the need to use a TPA:

• The impact that a change in recruitment and mobilisation controls has on vessel’s operational risk;
• Availability of ex-crew in FLP Department;
• Loss of revenue;
• Client requirements;
• Manning fees;
• Previous experience and references with the proposed TPAs;
• Proposed TPAs MLC and Quality accreditation. All TPAs must comply with the requirements of the MLC 2006 Regulation 1.4 for Recruitment and Placement Services and all other MLC regulations as applicable.

The proposal, considering the above factors, shall be forwarded to the MD who will carry out an evaluation together with the originating MD before a decision is made on whether to negotiate a manning agreement with a TPA.

After approval by the MD, a manning agreement may be negotiated and agreed FLP MANAGER where the TPA will be used by more than one of the Company offices. Seafarers shall not be supplied to the Company vessels via a TPA until a manning agreement has been agreed.

a) Control of Crew Supply & Mobilisation TPAs

A high level of control shall be exercised by the Company office when utilising the services of Crew Supply & Mobilisation TPA. Before seafarers are mobilised onboard the Company managed vessels, the Crew Supply & Mobilisation TPA shall receive a full induction into the Company crewing policies and procedures. The Company contracting party is responsible for this induction process. The Induction process shall include as a minimum:

1. Access to IMS crewing procedures
2. Training in IMS crewing procedures
3. Access to Company specific posters and documentation
4. Access to seafarer Training material including Training Matrices via the Company Training Officer

The Company contracting party shall ensure that the Company Training Officer is advised of the details of the Crew Supply & Mobilisation TPA. The Company Training Officer is responsible for ensuring that measures are in place to undertake effective seafarer training as per the Training Matrix. The facilities or resources of the most appropriate the Company Training Manager can be utilised. The Company contracting party is responsible for monitoring the training capability and reporting to the Company Training Officer.

The Head of QHSSE is responsible for coordinating Crew Supply & Mobilisation TPA systems audits. These will be undertaken annually with the first audit undertaken within six months of signing the manning agreement. The TPA systems shall be audited against IMS crewing procedures as well as national and international requirements including MLC 2006. The Compliance Manager shall ensure that the follow up to audits is effective. Records of audits will be available on Crewing Server.

b) Control of Crew Supply TPAs

All recruitment and mobilisation processes for seafarers sourced through a Crew Supply TPA, will be the responsibility of the Company Crew Manager who has requested the TPA to source a seafarer and will be undertaken in the Company office.

Company Crew Manager should send Crew request to all Approved TPA at same time.

Crew Supply TPAs must comply with the requirements of the MLC 2006 Regulation 1.4 for Recruitment and Placement Services and the quality of their service delivery will be monitored. However, further controls are not required as the responsibility is retained internally within the Company.

6.4.4 FLP Department and TPA Audit Review

Audit results of FLP Department and TPA audit results will be posted on Crew Server by QHSSE. Audit findings shall be followed-up by the QHSSE Department to ensure necessary corrective action is taken.

Every six months the Head of QHSSE Department shall review the Audit reports, in order to ensure that the audit programme and corrective action are effective, that trends are identified, and that internal stakeholders have been notified.