COMPANY’S POLICIES

Quality, safety & health policy

The Managing Director and Senior Managers are committed to provide Healthy and Safe working conditions, and to maintain a System for safe and pollution-free operating practices, complying with International regulations and requirements and conducting business within the law and the prevailing business ethics. The Company aims to continuously improve its services, and by so doing, its reputation and employment potential. The Managing Director and the Senior Managers expect their employees to comply with Quality Objectives, Safety and Pollution Prevention regulations & operating procedures always, to achieve the high-level goal of Zero Incidents and Zero Spills at Sea.

All employees are expected to take all necessary precautions to protect themselves, their colleagues, the ship, its cargo and the environment, and to maintain high standards of service. To further this aim, the company is being operated within the framework of this Management System. Responsibility for the Safety, Health, Quality, Environmental and Energy Efficiency Polices originates within the highest levels of Company Management.

The commitment of the Company, at all management levels, to Safety and Quality Procedures is maintained by its policy of providing the necessary resources and personnel for implementation, execution and monitoring of all aspects of Ship Management.

The Company’s principal objective is to:

• Eliminate injuries and illness to its employees and others who may be involved, and to prevent pollution of the environment by ensuring that safe practices and procedures are followed onboard, by Training, Review, and by Evaluation.
• Establish and maintain Quality Goals and Objectives for the supply of reliable services which meet and exceed the expectations of Charterers and Shipowners.

To achieve this objective, the Company’s Management System is provided for the purposes of operating each vessel in accordance with the stated Policy.

The official operating Management System is such that the Company:

• Has established safeguards against identified risks, unsafe or potentially unsafe conditions and practices. The Company is fully committed to the good health and safety of all crewmembers, contractors or the public, to their well-being and to the safe operation of its ships.
• Adheres to statutory rules and regulations, and considers applicable Codes, Guidelines and Standards recommended by the International Maritime Organization, Flag Administrations, Classification Societies and Maritime Industry Organizations. The Company provides its employees full information about these standards by means of clear communications, detailed instructions, adequate training and familiarization in all operational fields.
• Employs personnel that have the required skills and experience and provides continuous training, covering health, safety, environmental & energy performance matters.
• Promotes a continuous, organized control of Safety and Health, by constructive Safety Meetings between employees.
• Reviews and modifies the Company Policy, procedures & system by Masters’ and Management Reviews, to ensure its suitability and continuous improvement and uses it as a framework to establish Objectives and Targets.
• Has procedures in place to respond to Emergency Situations.
• Carries out Internal Audits and Inspections and takes appropriate Corrective Actions to any identified Non-conformance and ensures that all ISM-related tasks are performed in accordance with established procedures.
• Ensures that the maintenance of vessels’ hull and machinery is such as to keep them in good operating condition.
• Expects Contractors that it employs to follow the Company Quality, Safety, Health, Environmental Protection and Energy Efficiency standards, and monitors the said contractors as such.

Environmental protection & energy efficiency policy

The Managing Director and the Senior Officers are committed to establish, document, implement & maintain a Management System for safe & pollution-free operating practices, including Energy Efficiency & Energy use & consumption in compliance with National & International Regulations and applicable requirements and all relevant Legislation. The Company’s aim is to conserve and protect the environment from marine, atmospheric & other forms of pollution, including office-based waste, and to continuously improve its performance to achieve this aim. The Company operates a Policy of Zero Incidents and Zero Spills to the sea and land.

The Company has identified the following Environmental Aspects of its activities:

• Oil, and related products carried as cargo, fuel and oily waste as well as Chemicals, Liquefied Gases & other Noxious Liquid Substances carried as cargo in bulk and as residual waste.
• Dangerous Goods, including cargoes carried in bulk & in packaged form, as well as other packaged & containerized goods that may be hazardous to the environment, if spilled or lost.
• Garbage, including bio-degradable and non-biodegradable waste and Sewage.
• Ballast Water and the possibility of aquatic organisms or water-borne pathogens being transported in the ship’s water ballast.
• Antifouling Paints, and their effect on shellfish and other aquatic life.
• Cargo Vapour Emissions, and their toxic effect on health, climate and plant-life.
• Exhaust Emissions, including gases and un-burnt hydrocarbon particles and their contribution to smog, acid rain and the Greenhouse Effect.
• Ozone Depleting Substances, incl. CFCs and halon gases and their effect on global warming.
• Noise levels from machinery and the effect on ships’ crews as well as on local populations.
• Office generated waste, including wastepaper, special waste and other consumables.

The Company has integrated all the relevant Environmental Aspects in the Management System. By implementing the IMS procedures, the Company:

• Has identified the Environmental Aspects and has determined the Environmental Impacts related to its activities, products and services.
• Has developed the Energy Planning and has determined the Energy Performance Indicators related to its activities.
• Complies with Mandatory Rules and Regulations, also considering Codes, Guidelines and Standards from Maritime Organizations.
• Sets and reviews Environmental and Energy Efficiency Objectives & Targets, related to design optimization, purchase of energy efficient products & services and best practice operational management processes.
• Provides the Necessary Resources and assigns Responsibilities and Authority.
• Actively promotes Environmental and Energy Efficiency Awareness by training and educating its employees and by supporting and facilitating the distribution of such knowledge in this field.
• Operates its Office and Ships, taking into consideration the efficient use and conservation of Energy and Materials.
• Ensures that Residual Wastes are disposed-off in a safe and responsible manner.
• Expects all Contractors that it employs to follow the Company’s Environmental Management Policy and monitors the said contractors accordingly.
• Verifies compliance through Physical Inspection, Operational Tests and Document Analysis.
• Has established Emergency Procedures to respond to emergency situations and accidents that can have an impact on the environment and regularly tests these procedures.
• Keeps-up with Current Environmental Issues and topics and develops measures to minimize risk to the environment.

Drug & alcohol policy

Recognizing the negative effects of Drug and Alcohol abuse, the Company has adopted the following stringent measures and controls, not only meeting but surpassing ICS / OCIMF Industry standards:

No personnel engaged in Operations – ashore or afloat – will undertake any scheduled or unscheduled duty for the Company, while impaired by the effects of Drugs and Alcohol.

A Blood Alcohol Content (BAC) of 40mg/100 ml (0.04%) or greater is considered as alcohol impairment and is not tolerated.

• The Company has adopted a “No Alcohol/Dry-Ship Policy” and does not supply any Alcohol onboard. Additionally, the Company does not allow the acceptance of complementary offers and courtesy gifts by Suppliers onboard Company vessels.
• The possession, distribution and use of Alcohol onboard is strictly prohibited and will lead to immediate dismissal.
• The possession uses and trafficking of illegal Drugs onboard Company vessels is strictly prohibited and is considered as a very serious offence, which will lead to immediate dismissal and will render the person liable to legal proceedings.
• Any crew member who presents alcohol impairment above the acceptable BAC level will be immediately dismissed and will not be accepted for future employment with the Company.
• Drugs and Alcohol are not allowed onboard. A strict gangway watch is implemented and all crew who return from shore leave or join the vessel will be subject to a detailed search. Refusal to be subjected to a search will equal admission of guilt and the crew member will be dismissed.
• Watchkeeping personnel on shore leave, should abstain from alcohol consumption which would result in a BAC higher than the acceptable 40 mg/100ml (0.04%), if they have been scheduled for watch-keeping duties within the next four (4) hours.

The Officer of the Watch should not hand over the watch to a relieving Officer, if there is reason to believe that the latter is under alcohol impairment.

• Use of prescribed Drugs for strictly medical purposes is allowed, only under controlled conditions and following medical advice or recipe.
• Sedatives and other controlled / legal Drugs available in the Ship’s Medical Chest should be prescribed according to the regulations of the relevant Flag Administration and should be kept locked under the maste’s responsibility and control.
• All Shipboard personnel are subject to mandatory pre-employment Drug and Alcohol Tests.
• Before their employment, all Shipboard Personnel should sign the Drug and Alcohol Declaration. Adherence to the Company Drug and Alcohol Policy is a term of Employment.
• The Company arranges for strictly unannounced Drug and Alcohol tests, carried out by Shore Screening Companies on an annual basis.
• Watchkeeping personnel on shore leave, should abstain from alcohol consumption which would result in a BAC higher than the acceptable 40 mg/100ml (0.04%), if they have been scheduled for watch-keeping duties within the next four (4) hours.

Drug Tests are conducted as per EXXON MOBIL requirements. The Master is authorized to conduct Alcohol Tests, using type-approved equipment for alcohol testing which are calibrated and maintained as required.

Such tests are strictly unannounced and are carried out as per standard Company procedures for regular testing, for investigation purposes, or at master’s discretion.

• Any crew member refusing to be tested for Drugs & Alcohol, will be considered as an offender and will be dismissed.
• Any falsification of test results or unjustifiable positive test results directly imply immediate termination of employment.
• Compliance to the Company’s Drug and Alcohol Policy is mandatory for all Shipboard Personnel and for all Office Personnel who attend the vessels.

The Master is responsible to ensure full compliance with this Policy and to immediately report any violation.

Anti-harassment and anti-discrimination policy

The Company holds each employee responsible for maintaining acceptable standards of personal behavior in the business environment and for helping to ensure that all Company employees, as well as anyone invited into Company property/ships, are able to carry out their assigned duties in a business atmosphere that is free from harassment or discrimination.

The policy is simple: “Employees shall treat each other with respect, courtesy, consideration and professionalism. The Company does not tolerate any form of harassment or discrimination by any employee for any reason”. No one is exempt from this policy. The Company prohibits not only unlawful harassment, but also unprofessional and discourteous actions. Accordingly, any inappropriate slurs, jokes and/or remarks based upon an individual’s racial, ethnic, religious, or linguistic background or any other factors such as age, sex etc. will not be tolerated.

One example of unacceptable and offensive conduct is sexual harassment which includes unwelcome physical contact, sexually explicit language or gestures; uninvited or unwanted sexual advances, the use of vulgar language, the presence of sexually explicit photographs or other materials and the telling of sexual stories.

Other harassment includes any offensive, intimidating or hostile conduct that may interfere with the performance of an employee’s job or endanger the safety and wellbeing of anyone while on Company premises. Employees must always use mature judgment and maintain the highest standards of performance and personal conduct.

Some examples of prohibited conduct are:

• Verbal abuse, jokes, comments, nicknames or slurs that in any way relate to an individual’s race, color, sex, age, religion, national origin or disability.
• Joking or “kidding” that is considered unacceptable or offensive to another person.
• Threatening or profane language towards others.
• Fighting, assaulting or injuring another person.
• Pranks, practical jokes or other disorderly conduct.
• Creating a working environment that is intimidating, hostile or offensive or adversely affecting an employee’s work performance because of unwelcome or unwanted conversation, suggestions, comments, slurs, requests, demands, jokes, physical contacts or attentions.

Harassment can come from fellow employees, supervisors, managers or customers. Men as well as women can be victims of harassment. The Company cannot stress enough that it will not tolerate any form of harassment.