Environmental Management System EMS 04-03 Communication	Doc No.: EMS-04-03 Revision: 01 Date: 15 Oct 2024 Issued by: DPA Approved by: MD

4.3.1 Purpose

(a) The purpose of this procedure is to establish requirements for internal EMS communication between various levels in the Company, and to enumerate the mechanism that exists for information to flow from the top down, and from the bottom up.

(b) Company has also established procedures for external communication with various interested parties in order to update and receive vital information pertaining to improvement and effective implementation of EMS.

4.3.2 Scope

This provision is applied to the communication-taking place among the various levels and functions within office and onboard ships and for the customers and external interested parties. Issues that may be communicated are suggestions and complaints, audit finding, spills, waste generation and disposal, accident information, risk assessment and control information, etc.

4.3.3 Responsibility and authority

• (c) The MTSI respective groups has the responsibility and authority for the internal and external communication between various groups and with fleet vessels.
• (d) The TD has the responsibility for communication with customers and suppliers concerning environmental matters of transportation of cargo.
• (e) The MD has responsibilities for the internal and external communication from consultants, contractors regarding the environmental aspects.

4.3.4 Procedures for internal communication

(f) Company has established levels of internal and external communication in accordance with the environmental policy. Company procedure describes:

• Methods adopted for communicating within Company to all levels and functions.
• Effectively communicating with other departments within Company.
• Means to communicate Company significant aspects to all organization personnel, contractors, and consultants, and for receiving and addressing their concerns.
• Procedure for communications with public authorities and the media during the management of emergencies.

4.3.4.1 Collection of information

(a) Managers / SI / PIC (as applicable) of marine and technical group shall collect and identify the following information and report them to the relevant GM for evaluation:

• (i) Information of new environmental aspects
• (ii) Achievement of the company environmental objective and target for assessment during Management review.
• (iii) Results of the internal and/or external audit
• (iv) Information of revision and issuance to the legal and other requirements.
• (v) Report of emergency accident and response: ECP

(b) The results of evaluation shall be discussed during Top Management Review and SMC to formulate a plan for follow-up as required.

4.3.4.2 Methods for collection of information

(a) Managers and Masters should collect internal information regarding the EMS by the following methods:

• (i) E-mail exchange
• (ii) Meetings within the Groups
• (iii) Shipboard Safety, Health & Environmental Committee (SHEC)
• (iv) Questionnaires (company and vessel)
• (v) Suggestion box: For improvements
• (vi) Complaint letter: For reporting non-compliance or infringements.

(b) On board crew shall provide suggestions concerning improvement of EMS during SHEC meetings. Alternately, crew is encouraged to make suggestions or register any complaints of non-compliance by using EMS-13 Record of complaints in the ‘suggestion box’ provided on board. This box shall be locked, and the key shall be under Master’s custody.

(c) These suggestions shall be discussed and debated in the presence of all and shall form part of the minutes of Safety Meeting.

(d) HSSEQ Group shall maintain a record of relevant internal communication.

4.3.5 Procedures for external communication

4.3.5.1 Collection of information

(a) When receiving the following external information regarding Environmental matters, Master shall enter such information along with other matters as required by HSSEQ with evaluation in Deficiency Reporting System and should report them to the PIC / GM of Marine and Technical groups.

• (i) Requirements and/or complaints from the berth / terminal
• (ii) Requirements and/or complaints from the Consignors and/or Ship Charterers
• (iii) Recommendations by PSC, port authorities and classification related to environment

(b) The PIC / GM of Marine and Technical groups shall verify such environment protection related information and report it to DP/MR, who shall then convey such information to the MD/TD and Top Management.

4.3.5.2 Collection of and response to the information from customers

(c) Manager of Business group shall monitor information relating to customer perception as to whether the company has met customer requirements pertaining to environmental protection and should obtain the information by ways of the following:

• (i) Questionnaire to the customer
• (ii) Periodical communication with customer
• (iii) Customer information as received from the relevant managers and Masters

4.3.5.3 Communication and Reporting

GM System Group shall maintain a record of communication with all external parties.

4.3.5.4 Communication with Media

ECP-14-00 New Media Handling Policy shall be referred to and complied with.

4.3.6 Communication through Normal Management Channels

4.3.6.1 Management Channels

The traditional flow of information from one management level to the next is appropriate and will be used to communicate environmental information. Periodic or routine staff meetings with open dialogue are encouraged.

4.3.6.2 Communication through Internal Newsletters

Certain environmental communications will be made through internal newsletters. Programs that promote environmental excellence and considered for release to managed vessels should be communicated to GM System Group for further action.

4.3.6.3 Communication through Videos

Videos may be used to relay environmental information to managed vessels.

4.3.6.4 Communication through e-mail and Special Memos

Announcements concerning environmental improvement programs, upcoming internal audits and/ or inspections, etc. will be disseminated through e-mail to Company staff and managed vessels.

4.3.6.5 Communication through Suggestion Boxes

Suggestion boxes will be made readily available on all managed vessels. Communication in this form coming directly from shipboard crew is a valuable source of information about potential environmental impacts. Suggestions will be evaluated concerning environmental improvements. Rewards will be considered for suggestions that are implemented.

4.3.6.6 Communication through Placards

Important instructions and guidance on Oil Pollution Prevention is communicated to shipboard staff with the help of various Oil Pollution Placards placed in engine room CCR & Common spaces.

4.3.6.7 Relevant documents and records

• EMS-13 Record of complaints and TMR meeting minutes.

Ref:
ECP-14-00 New Media Handling Policy