3.2.1 Purpose

(a) The purpose of this provision is to demonstrate the commitment of Company in complying with all applicable environmental regulations and establish a procedure for identifying and having access to legal and other requirements, which are directly applicable to the aspects of all activities. The procedure has been developed in accordance with the legal requirements consisting of state, federal and local regulations, code of practices and laws.

(b) The term “other requirements” refers to mandatory or voluntary codes of conduct and performance standards (either internally or externally created) that the company has committed to.

3.2.2 Scope

This procedure is applicable to all activities and services of Company and managed fleet vessels.

3.2.3 Procedure

(a) The following describes the procedures for identifying; obtaining and providing access to legal and other requirements associated with the operation of activities of the company. The Company has implemented a register and library system of current environmental legislation including regulations, standards and codes of practice relating to its work activities.

(b) In developing the Environmental Management Plans it is the responsibility of SMC to track, identify and evaluate the relevant environmental performance requirements, and any contractual requirements that may have reference to environment protection and then document how changes to environmental legislation are systematically followed up.

(c) Company has identified environmental regulatory requirements. The integrated EMS will provide company office facilities and company vessels with information regarding regulatory compliance requirements.

(d) Within Technical and Marine Groups share an overall responsibility for tracking and receiving applicable environmental laws and regulations and identifying those related to the operations of the Company. These are then informed to all relevant Groups and finally to SMC.

(e) This committee, under MD/ TD/DPA shall then record and evaluate the effect of these regulations on the overall environmental activities of the Company.

(f) Company employs a variety of techniques and information sources to regularly track, identify and evaluate applicable laws and regulations. These include, but are not limited to:

• Classification Society circulars
• Commercial services and databases;
• Regulatory agencies (federal, state and local)
• Trade groups and associations
• Internet
• Consultants and attorneys
• Newsletters and magazines
• Information made available and provided by trade associations and membership organizations;
• Communications with Federal, State and local regulatory agencies and authorities.

(g) Upon receiving the information from Technical and/or Marine Group the GM System Group / shall advise the SMC and the committee then deliberates to identify any legal and other requirements associated with the information and collect further information necessary to reduce environmental risk.

(h) The GM System Group shall compile and maintain updated copies of applicable environmental laws and regulations and enter them into the List of Legal Requirements and Regulations EMS-07E.

(i) Company technical group is assigned the responsibility to ensure compliance and validity of certifications and permits/ licenses related to such requirements that they oversee for the Company.

3.2.4 Legal Requirements

(a) Company’s list of legal and other requirements List of Legal Requirements and Regulations EMS-07E, and Regulatory Register is provided to each department within office and each Company Group vessel.

(b) Regulatory compliance within each group is the responsibility of the group manager. It is the responsibility of SMC to alert each Company group and vessel of its requirements under a particular regulation.

(c) Important regulations, guidelines and recommendations addressing the issue of pollution prevention and environmental protection from ships for different aspects are listed below. This list is not to be looked upon as complete by any means. It is underlined that the documents listed are under continuous development.

(d) Company shall comply with all environmental requirements established under applicable international, flag state, and port state law.

3.2.5 Compliance with Legal Requirements

(a) Periodical verification of legal requirements

(b) Technical Director, Marine, HSSEQ group shall be responsible for checking new legal requirements which are issued worldwide from all available resources which shall include but not limited to the following:

• IMO website
• Intertanko website, weekly Newsletters, Class website and technical information
• Newsletters from QI
• OCIMF website
• P&I and H&M underwriters websites and Newsletters
• Circulars from Time Charterers
• News alerts from local agents
• Flag State websites and Newsletters
• BIMCO website and weekly Newsletters
• Intermanager News alerts

3.2.5.2 Compliance of Legal Requirements

(a) Compliance on board vessels shall be verified in the following manner:

• Email confirmation from vessel of new regulation by system group.
• Verification of minutes of Safety meetings once a month for documenting the discussion on new regulation and compliance by each Marine/ Technical Superintendent
• Verification during onboard visits / audits by SI / auditor

3.2.6 Relevant Documents and Records

• EMS-07E List of Legal & Other Requirements and Regulations
• Regulatory Register (Running)