OUR POLICIES

It is the Company’s Policy to promote Safety at sea. In order to comply with this Policy, the Company is committed to continuous efforts to identify, eliminate or manage safety risks associated with its activities.

The Company’s goal is to conduct its business in a manner that protects the safety of employees, all persons involved in its operations, customers and the public as well as to prevent accidents, injuries and occupational illnesses through the active participation of every employee.

The Company goal is to achieve ZERO accidents and ZERO spills through continuous improvement.

To achieve this goal, the Company:

• Complies with all applicable legislation and regulations and applies responsible standards where laws and regulations do not exist.

• Designs and maintains facilities, establishes management systems, provides training and conducts operations in a manner that safeguards people and property.

• Assesses all identified risks to its ships and personnel and establishes appropriate safeguards.

• Responds quickly, effectively and with care to emergencies or accidents resulting from its operations, in co-operation with industry organizations and authorized government agencies.

• Stresses to all employees, contractors and others working on its behalf, their responsibility and accountability for safe performance whilst at work and safe behavior outside of work.

• Undertakes appropriate reviews and evaluations of its operations to measure progress and to foster compliance with this Policy.

• Conducts and supports research to extend knowledge about the safety effects of its operations and promptly applies significant findings and, where appropriate, shares them with employees, contractors, government agencies and others who might be affected.

This Policy has the full support of Top Management and applies to all employees of the Company.

Company policy is to promote environmental awareness and to protect the environment in all its forms. The Company is committed, through continuous efforts, to improve environmental performance in all areas required by international regulations and improve Company’s standards towards a cleaner environment, to reduce oil waste or other pollutant production, control emissions and wastes to below harmful levels and eliminate spills and environmental incidents.

The Company long-term goals are to achieve ZERO incidents and ZERO spills through continuous improvement.

In order to achieve these goals, the Company:

• Assesses all identified risks to the environment and establishes appropriate safeguards to ensure continuous reduction of environmental risks.

• Is committed to pollution prevention, in particular through source reduction, including necessary funding and human resources to effectively maintain the onboard systems and equipment.

• Maintains an environmental management system which is continuously improving, provides training to all persons involved in our operations and which supports operating in a manner that safeguards the environment and prevent pollution.

• Designs, operates and maintains facilities to this end.

• Complies with all applicable environmental laws, regulations and legal requirements and applies responsible standards where laws, regulations and legal requirements do not exist.

• Ensures employees are well trained to respond quickly, effectively and with care to any environmental incident that may occur from our operations, in co-operation with industry organizations and authorized governmental agencies.

• Shows concern and respect for the environment, emphasizes every employee’s responsibility to environmental performance and fosters appropriate operating practices and training.

• Provides funds and human resources as necessary in order to effectively maintain and repair the systems, equipment and components in the machinery spaces.

• Undertake appropriate reviews and evaluations of our operations to measure progress and to foster compliance with this Policy.

• Stress to all employees, contractors and others working on our behalf that they are responsible and accountable for respecting and protecting the environment whilst involved in our operations.

The Company adopts all the duties and responsibilities imposed by ISO 14001:2004 to provide adequate resources (e.g. technical, financial, and human resources) to ensure that the management’s environmental objectives are achieved.

The Company is against any incentive or bonus programs based on minimizing operational costs associated with the operation, maintenance, and repair of machinery space systems, equipment and components without ensuring that efficiency and performance are maintained. Employees shall not avoid such costs and thereby sacrifice environmental compliance.

All personnel and Senior Officers, whether ashore supporting our ships or at sea working onboard, will actively work to prevent unsafe acts and damage to the environment and they should lead by example in complying with environmental practices and procedures. Furthermore, they shall NOT retaliate against or in any way treat adversely any subordinate, co-worker, employee or crew member for their reporting of any environmental, integrity or other violation. Company’s personnel ashore and onboard who fail to comply with this Policy shall subject to disciplinary action up to and including termination of services.

This policy shall be displayed in the Company’s offices. The vessel shall display this policy on the Bridge, in the Engine Control Room, and in Officers’ and crew mess rooms. The Environmental Policy is communicated to all employees ashore and onboard.

The Company reviews this Policy periodically to ensure its suitability and continuous improvement and uses it as a framework to establish Environmental Objectives and Targets.

Potential consequences of deviating from specified operating policies/procedures, include possible termination of employment; and liability for criminal/civil/administrative penalties as a result of noncompliance. Failure to notify regarding any violation of the EMS, or other maritime environmental protection requirements is grounds for discipline or dismissal, subject to applicable labor laws.

The Company, being involved in the operation and management of vessels providing worldwide transportation of cargoes, recognizes the need to apply standards of security on the managed vessels and within the office environment.

The Company guarantees its commitment to matters of security and declares that all works conducted by its personnel, either ashore or onboard, will be effectively supervised in order to comply with the provisions of the ISPS Code.

The Company’s objectives are to:

• Provide security procedures and practices for ship operations to protect the security of ports and the wider community and establish, implement and verify specific safeguards and security measures on board, to reduce the risk to crew, passengers and port personnel onboard against identified risk.

• Maintain global security situation awareness, improve the security skills and promote security awareness amongst all Company’s employees ashore and onboard.

• Conduct assessments of possible security threats to vessels and shore establishments and take preventive measures against potential security incidents.

• Take into account the decisions of the international shipping community and comply with all applicable security laws, regulations.

• Scheduling in advance, as far as possible, the voyage, the cargo handling and all ship’s operations in order to foresee possible dangers and take the necessary precautions.

• All employees and crewmembers are expected to comply with the requirements of the SSP and shall be familiar with their relevant security duties and the measures required to protect the ship from any unlawful act.

In the event of an attack on the ship or highjack attempt, the preservation of the lives of ship personnel is to be placed above all other considerations.

• In case there is a conflict between commercial interests and the aims of the Security Policy, the Master will give priority to this Policy:

In case of conflict between Safety & Security SAFETY PREVAILS OVER SECURITY

Company Commitment

The Company is committed to:

• Develop, implement and maintain a Ship Security Plan for each vessel, with established reporting & recording procedures for incidents in accordance with the requirements of the SOLAS – ISPS code, providing the appropriate security guidance, advice, documentation and necessary resources and the directives in order to meet its security objectives and fully comply with the requirements of the ISPS code and any additional requirements that may be stipulated by the relevant competent Contracting Governments.

• Receive and evaluate security briefs at high risk ports and in high risk areas, cooperate with the responsible Authorities and relevant enforcement agencies to act on advice from them.

• The Company declares that the CSO and the SSO have adequate knowledge and/or have received training. Shipboard personnel with specific security duties have sufficient knowledge and ability to perform their assigned duties and that all other shipboard and Company personnel have sufficient knowledge of and are familiar with relevant provisions of the SSP

• The personnel undergo training both immediately upon hiring and continuously during their employment.

• The Company ensures that the CSO, the Master / SSO are given the necessary support to fulfill their duties and responsibilities in accordance with SOLAS and the ISPS code.

• This Policy will be revised whenever necessary in order to ensure that the aims set are achieved and to monitor the correctness and effectiveness of the procedures and guidelines given. Regular documented reviews and internal audits of security procedures and plans in order to allow for constant update and improvement of the Plan.

• All of the Company’s shore-based and shipboard personnel are strictly required to adhere to this policy by fully complying with relevant security procedures and measures as well as all applicable national and international regulations.