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Issued by: Approved by: Date Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 1 of 1 SAFETY MANAGEMENT MANUAL According to: IMO Resolution A.741(18), as amended – ISM Code DISTRIBUTION LIST This distribution list is reprinted when necessary. It is not subject to Certifying Body (RINA) approval, and its change should not be recorded in the manual's revisions checklist. Copy no. Consigned to: Copy no. Consigned to: 1 General Manager 11 Master M/t MARE ORIENS 2 Head of HSEQ Department 12 Ch.Engineer M/t MARE ORIENS 3 Head of Technical Department 13 Master M/t MARE NOSTRUM 4 Head of Marine Department 14 Ch.Engineer M/t MARE NOSTRUM 5 Head of Crewing Department 15 Master M/t MARE DORICUM 6 Head of Chartering Department 16 Ch.Engineer M/t MARE DORICUM 7 Certifying Body (RINA) (electronic) 17 Master M/t MARE PICENUM 8 Manning Agent (electronic) 18 Ch.Engineer M/t MARE PICENUM 9 Master M/t MARE TIRRENUM 19 Master M/t MARE SICULUM 10 Ch.Engineer M/t MARE TIRRENUM 20 Ch.Engineer M/t MARE SICULUM

Issued by: Approved by: Date Issue Page st HSEQ DEPARTMENT GENERAL MANAGER 21 April 2017 2 1 of 1 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code REVISIONS CHECKLIST no. Issued Parts affected Note 0 26 January 2017 Version 1 - Revisione 0 - SMS Manual == Pollution or Risk of Pollution Contacts Details th 1 20 April 2017 Annex to Chapter 3, page 3 of 4 (Company’s First Contact and Alternate Contact) Annex to Chapter 3, page 3 of 4 and New Deputy CSO Contact 2 21 April 2017 st page 4 of 4 Details These pages should be updated and changed every time the manual is revised FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 1 of 4 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code INDEX = DISTRIBUTION LIST = REVISIONS CHECKLIST = INDEX = COMPANY POLICY STATEMENT Chapter 0 DEFINITIONS - ABBREVIATIONS AND ACRONYMS Chapter 1 SAFETY MANAGEMENT SYSTEMS – THE MANUALS - 1.1 Safety Management System (SMS) according to the ISM Code - 1.2 ISO - Quality/Environment (Q&E) Integrated Management System - 1.3 Tanker Management and Self Assessment (TMSA) Chapter 2 COMPANY’S FLEET AND SERVICES - 2.1 Type of ships - 2.2 Services - 2.3 New ships of the Company’s fleet - 2.4 Ships leaving the Company’s fleet Chapter 3 COMPANY’ S DESCRIPTION AND ORGANIZATION - 3.1 Company’s profile - 3.2 Working language - 3.3 Organization - 3.4 General Manager - 3.5 Departments: Organization, tasks and responsibilities - 3.6 Designated Person Ashore (DPA) - 3.7 Emergency Preparedness - 3.8 Protection of privacy - 3.9 Risk Assessment - 3.10 Management of change - Annex a) Address and telephone numbers b) General Manager c) Designated Person Ashore d) Heads of Departments e) Persons in charge of office f) Contacts for the operational management of emergencies g) Company’s Organization FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 2 of 4 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code INDEX Chapter 4 SHIPBOARD ORGANIZATION - 4.1 Resources and personnel - 4.2 Ranking on board - 4.3 Working language - 4.4 Master’s responsibility and authority with regard to the SMS - 4.5 Shipboard organization - 4.6 Watchkeeping and Duty service - 4.7 Master’s authority in employing ship’s personnel - 4.8 Shipboard Emergency Team Chapter 5 MANAGEMENT OF PERSONNEL - 5.1 Generals - 5.2 Shore personnel - 5.3 Seafarers Chapter 6 CONVENTIONS, REGULATIONS, CODES, GUIDELINES AND REQUIREMENTS - 6.1 Generals - 6.2 Conventions and rules to be observed - 6.3 Codes, guidelines and instructions - 6.4 Publications on board - Annex SMS Library Chapter 7 MAINTENANCE OF SHIP AND EQUIPMENT - 7.1 General rules - 7.2 On-board maintenance - 7.3 Repairs - 7.4 Supplies - 7.5 Analysis of water and lube oils - 7.6 Asbestos Chapter 8 EMERGENCY PREPAREDNESS - 8.1 Emergency situations - 8.2 Safety Familiarization of the Crew - 8.3 Collecting evidence - 8.4 Handling the media - 8.5 General Emergency - 8.6 Pollution And Risk Of Pollution - 8.7 Breakdowns and Shipboard Emergency Situations - 8.8 Assistance And Salvage - 8.9 Emergency Response Team (Ashore) FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 3 of 4 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code INDEX Chapter 9 SURVEYS AND INSPECTIONS - 9.1 Foreword - 9.2 Flag State and Class surveys - 9.3 Safety Inspections - 9.4 Inspections by Charterers (Vetting) - 9.5 Monitoring and Analysis - 9.6 Company’s inspections Chapter 10 INCIDENTS - NON CONFORMITIES - NEAR MISSES - REPORTS AND ANALYSIS - 10.1 Generals - 10.2 Incidents - 10.3 Non conformities - 10.4 Near misses - 10.5 Company’s investigation and analysis - 10.6 Documentation Chapter 11 DEVELOPMENT OF PLANS FOR SHIPBOARD OPERATIONS Chapter 12 OPERATIONAL PROCEDURES AND INSTRUCTIONS - 12.1 Risk Assessment - 12.2 Operational procedures and Instructions SECTION 12.1 Foreword - Implication of commercial decisions in terms of safety SECTION 12.2.1 Sailing - Navigation bridge SECTION 12.2.2 Sailing - GMDSS SECTION 12.2.3 Sailing - Engine Room SECTION 12.3 Protection of the environment SECTION 12.4 Cargo operations SECTION 12.5 Ship in port SECTION 12.6 Preparing for sailing SECTION 12.7 Ship’s security SECTION 12.8 Safety of working environment and health of the crew Chapter 13 COMMUNICATIONS - 13.1 Foreword - 13.2 Ship’s communication systems - 13.3 Shore communication systems - 13.4 Routines messages - 13.5 Communications in emergencies FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 4 of 4 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code INDEX - 13.6 On-board communications Chapter 14 SHIPS DOCUMENTS AND LOGBOOKS - STATUTORY MANUALS & DIRECTIONS - 14.1 Periodical check and renewal of certificates - 14.2 Documents issued by Flag State - 14.3 List of ship’s certificates and documents - 14.4 List of ship’s official log books - 14.5 Statutory manuals and directions Chapter 15 SAFETY MANAGEMENT SYSTEM DOCUMENTATION - 15.1 Foreword - 15.2 Company’s documents - 15.3 Reports to the Company - 15.4 Documents of the ship’s commercial management Chapter 16 AUDITS AND POLICY EVALUATION - 16.1 Company’s internal audits - 16.2 Audits of the appointed auditing body and certifying authority - 16.3 Policy evaluation and revision FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 1 of 2 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code COMPANY POLICY STATEMENT Vision Fratelli d’Amico Armatori S.p.A. (the Company) provides a professional ship management service efficiently in order to meet the interested parties’ requirements always in a safety manner and respecting the environment. Mission The Company has adopted the Safety Management System comprehensive of ISM Code in compliance with national and international regulations, of ISO 9001 and ISO 14001 standards in accordance with the requirements of the Italian law decree 231/2001, ISPS Code and MLC 2006. Objectives The main objectives are promoting safety, security, quality and environmental culture, preventing any accident, protecting the environment against any type of pollution, satisfying interested parties’ requirements and protecting personnel rights according to our Ethical Code. The Company establishes that all operations carried out by its personnel, both ashore and on board, will always be performed with the utmost care, with the view of reaching the following goals, hereinafter listed in order of priority, having the target of zero-incidents and zero-spills: - to prevent physical injury and loss of life; - to protect the environment, in particular the marine one; - to ensure ships safety and to maintain their technical and operational efficiency at the highest possible level; - to protect vessels and crew against illegal practices; - to operate the vessels and to transport the cargo safely and efficiently. The Company aims to reach these goals through a process of self-assessment and continuous improvement. Principles In order to pursue the above mentioned objectives, the Company has established the following principles: providing adequate resources to implement and improving effectively the Safety Management System continuously by periodical review, in order to ensure that the Company’s objectives are reached and achieved; ensure the safe operation of the vessels and protection of the environment in compliance with all national and international rules and regulations governing the marine industry; improving skills and behaviour of all personnel by appropriate training and development program; promoting a safety/security/environmental emergency preparedness by specific drills and training; meeting interested parties’ requirements as defined in the contracts and monitoring their satisfaction; promoting and sharing ethical values through all organizational levels by Company’s Ethical Code. The Company establishes that, whenever a conflict arises between commercial and/or economic interests and the above-mentioned goals, its Managers and Shipmasters shall always decide and act so as to give priority to such goals. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 2 of 2 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code COMPANY POLICY STATEMENT Top management provides evidence of its commitment to the development and implementation of the Safety Management System and continuously improving its effectiveness by the availability of resources and ensuring that the Company Policy is communicated and understood within the organization. The implementation of the Company's Policy is regularly reviewed in order to ensure that the appointed goals are reached and that its procedures and instructions are suitable and effective. GENERAL MANAGER Carlo Cameli FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 1 of 3 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended - ISM Code CHAPTER 0 DEFINITIONS – ABBREVIATIONS AND ACRONYMS a) ISM CODE = DEFINITIONS 1.1.1 ISM Code The International Management Code for the Safe Operation of Ships and for Pollution Prevention as adopted by the IMO by Resolution A.741(18), as amended. 1.1.2 Company The owner of the ship or any other organization or person, such as the manager or the bareboat charterer, who has assumed the responsibility for the operation of the ship and who, on assuming such responsibility, has agreed to take over all duties and responsibilities imposed by the ISM Code. 1.1.3 Administration The Government of the State whose flag the ship is entitled to fly. 1.1.4 Safety Management A structured and documented system enabling Company System (SMS) personnel to implement effectively the Company safety and environmental protection policy. 1.1.5 Document of Compliance A certificate issued to a Company which complies with the (DOC) requirements of the ISM Code, and indicates the ships’ types to which it applies. 1.1.6 Safety Management A certificate issued to a ship, which signifies that the Company Certificate (SMC) and its shipboard management operate in accordance with the approved safety management system (SMS). 1.1.7 Objective evidence Quantitative or qualitative information, records or statements of fact pertaining to safety or to the existence and implementation of a safety management system element, which is based on observation, measurement or test and which can be verified. 1.1.8 Observation A statement of fact made during a safety management audit and substantiated by objective evidence. 1.1.9 Non-conformity An observed situation where objective evidence indicates the non-fulfilment of a specific requirement. 1.1.10 Major non-conformity An identifiable deviation that poses a serious threat to the safety of personnel or the ship or a serious risk to the environment that requires immediate corrective action or the lack of effective and systematic implementation of a requirement of the ISM Code. 4 Designated Person The shore person, or persons, having direct access to the Ashore (DPA) highest level of the Company’s management, who has the responsibility and the authority to monitor all safety and pollution prevention aspects of the operation of each ship and to ensure that adequate resources and shore-based support are applied, as required. 12 .1 Audit A systematic examination to determine whether the SMS activities and related results comply with planned arrangements ant whether these arrangements are implemented effectively and are suitable to achieve the objectives. 12.4 Internal Auditor A Company’s person, qualified to perform verifications of compliance with the requirements of the ISM Code, independent of the areas being audited. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 2 of 3 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended - ISM Code CHAPTER 0 DEFINITIONS – ABBREVIATIONS AND ACRONYMS b) ABBREVIATIONS AND ACRONYMS - ORGANIZATIONS: ABS American Bureau of Shipping - Houston, TX BIMCO The Baltic International Maritime COuncil - Copenhagen BV Bureau Véritas - Courbevoi (Paris) CIRM Centro Internazionale Radio Medico - Roma CONFITARMA CONFederazione ITaliana ARMAtori - Roma ECSA European Community Shipowners’ Associations - Brussels EMSA European Maritime Safety Agency - Lisboa GL Germanischer Lloyd - Hamburg IACS International Association of Classification Societies - London IALA International Association of Lighthouse Authorities - Paris ICAO International Civil Aviation Organization - Montreal IAPH International Association of Ports and Harbours - Tokyo ICS International Chamber of Shipping - London IFSMA International Federation of Shipmasters’ Associations - London IHO International Hydrographic Organization - Monaco ILO International Labour Office - Genève IMO International Maritime Organization - London IMPA International Maritime Pilots’ Association - London INMARSAT INternational MARitime SATellite Organization - London INTERTANKO INTERnational TANKOwners Association - Oslo ISF International Shipping Federation - London ISO International Organization for Standardization - Genève ITOPF International Tanker Owners Pollution Federation Limited - London ITU International Telecommunication Union - Genève LR Lloyd’s Register - London MCA Maritime and Coastguard Agency - Southampton MIT Ministero delle Infrastrutture e dei Trasporti - Roma OCIMF Oil Companies International Maritime Forum - Bermuda RINA Registro Italiano NAvale - Genova UNI Ente Nazionale di UNIficazione - Milano USCG United States Coast Guard - Washington, DC USDA United States Department of Agriculture - Washington, DC USDHS United States Department of Homeland Security - Washington, DC WMO World Meteorological Organization - Genève WHO/OMS World Health Organization/Organization Mondiale de la Santé - Genève FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 3 of 3 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended - ISM Code CHAPTER 0 DEFINITIONS – ABBREVIATIONS AND ACRONYMS - ACTS AND CONVENTIONS: CFR Code of Federal Regulations - (USA) CdN Codice della Navigazione - (R.D. 30.03.1942, n. 327) CITES 73/79 Convention on International Trade in Endangered Species of Wild Flora and Fauna - 1973/1979 CLC 69/92 International Convention on Civil Liability for Oil Pollution Damage - 1969/1992 COLREG 72 International REGulations for Preventing COLlisions at Sea - 1972 FAL International Convention on FAcilitation of InternationaL Maritime Traffic - 1965 LL 66/88 International Convention on Load Lines - 1966/1988 MARPOL 73/78 International Convention for the Prevention of POLlution from Ships - 1973/1978 MLC 2006 ILO Maritime Labour Convention - 2006 OPA 90 Oil Pollution Act 1990 (USA) OPRC 90 International Convention on Oil Pollution Preparedness Response and Cooperation - 1990 RS/1991 Regolamento per la Sicurezza della Navigazione - (D.P.R. 08.11.1991, n. 435) SOLAS 74/78 International Convention for the Safety Of Life At Sea - 1974/1978 STCW International Convention on Standards of Training, Certification and Watch- keeping for Seafarers - 1978/2010 UNCLOS United Nations Convention on the Law of the Sea (Montego Bay Convention) - 1994 FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 1 of 2 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER 1 SAFETY MANAGEMENT SYSTEMS – THE MANUALS 1.1 SAFETY MANAGEMENT SYSTEM (SMS) ACCORDING TO THE ISM CODE Instructions and procedures adopted by the Company in order to conform itself to the international standards for the safe management and operations of ships and for the pollution prevention, in accordance with the requirements of the IMO Resolution A.741(18): International Management Code for the Safe Operation of Ships and for Pollution Prevention, as amended, (ISM Code - § 11.3), are contained in the Company’s Safety Management Manual (SMS Manual). 1.1.1 Safety Management Manual a) Purpose The purpose of the SMS Manual is:  to supply general introductive guidelines to the Safety Management Manual implemented by the Company;  to describe the Company’s policy regulating the safe and efficient operation of managed ships;  to describe how the Company acts in response to unexpected events; and  to supply a basic reference for the manuals regulating the daily activities of the Company’s personnel on board and ashore. The described policy should be observed both by the shore personnel and by the ships crews. The manual belongs, and its use is reserved, to the Company. It cannot be divulged or made known to third parties without a previous permission granted by the General Management. The SMS Manual shall be approved in advance by the Auditing body (RINA) on behalf of the Certifying body (for Italian flag ships the Ministry of Infrastructures and Transports – Coast Guard General Headquarters). b) Diffusion Each copy of the manual is numbered and consigned, in accordance with the Distribution List at the beginning of each volume, to: • General Manager • Head of HSEQ Department • Head of the Technical Department • Head of the Marine Department • Head of Crewing Department • Head of Chartering Department • Auditing body (RINA) • Manning Agent (abridged) • Masters and Chief Engineers of all ships of the Company’s fleet. The manual should be kept in such a way that it is promptly available to all shore and ship staff. On board, it will be kept on the navigation bridge and in the engine control room (or in the Engine Department Office) so that it may be promptly consulted by all the Deck and Engine Officers. c) Revisions The SMS Manual is regularly reviewed and updated by the HSEQ Department, in accordance with directions obtained by the Company’s Departments, as described in chapter 16 – paragraph 16.3. The updates shall be approved by the General Manager and shall be notified to all the manual’s consignees by Issues, progressively numbered and dated. Each issue should be approved in advance by the Auditing body (RINA). The manual’s updates are recorded on the Revisions checklist at the beginning of each volume. The list is reprinted every time that a new revision has been issued. The consignee, or the person appointed by him to carry out the update, shall record the date the manual was actually updated, and sign it. 1.2 QUALITY / ENVIRONMENTAL (Q&E) INTEGRATED MANAGEMENT SYSTEM Management systems following the ISO standards are elaborated so to help firms to identify their own process, to monitor their interactions, show the requisites applicable to them, in order to rationalize them with a consequent improvement of their effectiveness. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 2 of 2 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER 1 SAFETY MANAGEMENT SYSTEMS – THE MANUALS Such systems are certifiable, that is to say it is possible to obtain from a qualified organization a statement of conformity to standard requirements. Certification is not compulsory, yet it is the result of a voluntary choice by a firm deciding to adopt a management system going beyond the current statutory regulations, systematically involving managers, employees and suppliers towards the common objective of a continuous improvement. This is the reason why certifications cannot be considered a simple recognition but an important tool to communicate to customers the firm’s commitment and, as a consequence, its reliability. The Company adopted an integrated Quality/Environment management system certified by RINA S.p.A. of Genoa, for the following field of activity:  CARRIAGE OF CRUDE OIL AND ITS DERIVATES BY OWNED AND CHARTERED SHIPS in accordance with the following standards: • UNI EN ISO 9001:2008 – Quality management system, on the 7th August 2008; • UNI EN ISO 14001:2004 – Environmental management system, on the 28th August 2008. The Q&E integrated management system is organized according to levels of documentation differentiated in extension and degree of details in accordance with the complexity of the process, of the used methods and of the skill and training level of personnel. Documentation is integrated to the SMS. HSEQ Department is responsible for the management of the integrated system. 1.2.1 Quality-Environmental Integrated Manual The Quality-Environmental Integrated Manual describes, in accordance with the articles of the norms of reference, the aspects of the management system pertaining to SMS procedures and documents. Specific cross-references to them are also contained in the SMS Manual, as necessary. The manual is available in electronic form both on the internal net of all Company’s offices and on board all ships of the fleet. The manual is regularly reviewed and updated by the QEM. 1.3 TANKER MANAGEMENT AND SELF ASSESSMENT (TMSA) In order to monitor and improve its safety management systems, both ISM and ISO, the Company avails itself also of the OCIMF developed Tanker Management and Self Assessment (TMSA) programme. TMSA is a tool allowing ship operators to assess their safety management systems against listed key performance indicators (KPI) and indicates best practice, which can be used as a reference to develop improved processes and procedures. TMSA assessment can be conducted and regularly reviewed and updated by the Company online at its dedicated web site, which is also accessible to all Majors party to OCIMF. The TMSA programme provides for close contacts with the Charterers, with an exchange of information which may be also of commercial character. It is therefore directly managed by the HSEQ Department of the Company, in close collaboration with the Crewing, Marine and Technical Departments. Intertanko Benchmarking (LTIF Rating) is used to identify the improvements in the safety management system. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 1 of 2 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER 2 COMPANY’S FLEET AND SERVICES 1.2.2 OBJECTIVES OF THE SAFETY MANAGEMENT 1. Provide for safe practices in ship operation and a safe working environment; 2. Assess all identified risks to its ships, personnel and the environment and establish safeguards against; 3. Continuously improve safety management skills of personnel ashore and aboard ships, including preparing for emergencies related both to safety and environmental protection. 11. DOCUMENTATION 11.1 The Company should establish and maintain procedures to control all documents and data which are relevant to the SMS. Each ship should carry on board all documentation relevant to that ship. 2.1 – Type of ships This manual applies to the following types of ships Oil Tankers The Company (ISM Code – 1.1.2) delivers a special statement to the Ministry of Infrastructure and Transport – Italian Coast Guard Headquarters, 6 th Department - Safety of Navigation (Certifying Authority), containing its own data (Company’s full style, IMO number, address and telephone numbers of its head office), and the list of its ships, stating their names, type, home port and official and IMO numbers. The list of managed ships should also be submitted to the recognised auditing body (RINA). 2.2 - Services The following are the services rendered by the Company, which are subject to the requirements of the Safety Management System: ⇒ Technical management; ⇒ Crew management; ⇒ Operational management. The General Manager shall assess the implications of commercial decisions in the safe management of the ships and in the pollution prevention. 1 In any case, the Shipmaster shall always refuse to load a cargo whose carriage is not allowed by the ship’s certificates. 2.3 - New ships of the Company’s fleet On board ships entering the Company’s fleet (new build, purchase or new management), the Safety Management System (SMS) shall be implemented in the following way: (i) the Company’s Document of Compliance (DOC) is relevant to the ship concerned; (ii) the SMS provided by the Company for the ship concerned includes key elements of the ISM Code and has been assessed during the audit for the issuance of the DOC; (iii) the Company has planned the internal audit of the ship within three months; (iv) the master and officers are familiar with the SMS and the planned arrangements for its implementation; (v) instructions, which have been identified as being essentially are provided prior to sailing; and (vi) relevant information on the SMS has been given in a working language or languages understood by the ship's personnel. The Company shall then send in an application to the Harbour Master Office or to the Italian Consular Authority of the port where the ship is lying, either in Italy or abroad, copying it to the local RINA office, to obtain the issue of an Interim Safety Management Certificate (ISMC) to the ship, together with the prescribed Declaration of Company According to ISM Code. The certificate will be issued by the maritime or consular authority after an assessment survey has been carried out, with positive outcome, by the recognized auditing body (RINA). The interim certificate should be kept on board together with the photocopy of the Company's DOC. Its validity cannot exceed six months. 1 See chapter 12 – section 12.1 “Implications of commercial decisions in terms of safety” of this manual. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 2 of 2 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER 2 COMPANY’S FLEET AND SERVICES After the SMS has been practiced on board for a sufficient time, and after the required internal audit has been carried out, the Company shall apply again for the issue to the ship of a full term Safety Management Certificate (SMC), subject to the positive outcome of an audit carried out by the recognized auditing body (RINA). The Administration reserves to itself the right to visit the ship on its own discretion, in order to check the verification and auditing operations carried out by the recognized auditing body (RINA) surveyors. 2.4 - Ships leaving the Company’s fleet When a ship leaves the Company’s fleet, her Master should make sure that all documents pertaining to the Company’s SMS are removed and returned to the Company’s Office. Documents shall be kept in Company’s custody for not less than 3 years after the ship left its management. The Ministry of Infrastructure and Transport – Italian Coast Guard Headquarters and the recognized auditing body (RINA) shall be promptly notified whenever a ship leaves the Company’s management. The following ship’s documents shall always be delivered to the Company for their subsequent return to the certifying authority or organization, as appropriate, even if no change of flag occurred and therefore all other certificates remain on board until their expiry date (see Chapter 14 - §14.3): • Safety Management Certificate (SMC). • Copy of the Company’s Document of Compliance (DOC). • International Ship Security Certificate (ISSC). • Certificates of Financial Security in Respect of Civil Liability for oil Pollution Damage (CLC). • Crew Insurance Certificate (IPSEMA). • Insurance documents (HM/WR, P&I, ITOPF). Minutes of the delivery of all ship’s documents to the local maritime authority (Harbour Master Office or Consulate), to the Company and to the new owners/operators shell be kept and duly signed by the Master, the Company’s representative attending on board and the representatives of the new ship’s owners/operators. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 1 of 7 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER COMPANY’S DESCRIPTION AND ORGANIZATION 3 3. COMPANY RESPONSIBILITIES AND AUTHORITY 3.2 The Company should define and document the responsibility, authority and interrelation of all personel who manage, perform and verfy work relating to and affecting safety and pollution prevention. 3.3 The Company is responsible for ensuring that adequate resources and shore based support are provided to enable the Designated Person or Persons to carry out their functions. 3.1 COMPANY’S PROFILE Fratelli d’Amico Armatori S.p.A. is a Shipping Company active in the international carriage by sea of oil cargoes, worldwide, for both Italian and foreign charterers, by means of its own ships as well as managed ships. The Company, founded in 1946 by its present share holders, has reached a top position in the international shipping market thanks to the high technical standard of its ships, the competence and skill of its crews, a sound tradition of reliability and efficiency of its owners, managers and entire staff, and to a valuable experience, acquired over the course of many years, in all aspects and problems of shipping, safety at sea and protection of the environment. Generations of Officers and Shipmasters have been trained and have proudly served on board the many ships of its fleet. The Company’s head office is located in Rome, Via Liguria 36, in the fashionable Ludovisi neighbourhood. 3.1.1 Company Identification Number In accordante with SOLAS 74/78 - XI-1/3-1, the International Maritime Organization assigned the following Identification Number to the Company: IMO 0207191 3.2 WORKING LANGUAGE The Company's working and documentation language, both in the shore offices and on board ships, is the English language. Contacts with the Administration (Flag State) are made in Italian, as requested by current national regulations. Relevant documents may be kept in the Italian language, if so required. 3.3 ORGANIZATION Company’s organization is based on the following Departments and Offices: • Accounting • Insurance • Chartering • Technical • Marine • Crewing, • HSEQ (Health, Safety, Environment & Quality) directed by Heads of Departments; • IT Office under the direct control of the General Manager. 3.4 GENERAL MANAGER (GM) The General Manager is empowered by the Board of Directors for the operational and commercial management of the Company. He appoints in writing the Heads of Departments, the Designated Person Ashore (DPA), the Company Security Officer (CSO) and the Quality & Environment Manager (QEM). He is the person responsible for the Safety Management System (SMS) and has specific authority to: (a) ensure that a system in accordance with ISM code is enforced, applied and maintained; (b) identify the needs and provide suitable resources for the safety management activities, both on board the ships and in the Company’s offices; FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 2 of 7 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER COMPANY’S DESCRIPTION AND ORGANIZATION 3 (c) verify the proper enforcement of the system on board the ships and in the Company’s offices by means of audits carried out by the directly managed HSEQ Department. Responsible persons identity and the Company’s structure and organization are detailed in the Annex to this chapter. 3.5 DEPARTMENTS: ORGANIZATION, TASKS AND RESPONSIBILITIES 3.5.1 – Accounting Department (a) Company’s economical management (budgets, checking economical results). (b) Operational accounting (invoicing, adjustements, bookkeeping, etc.). (c) Financial (currency operations, cash keeping, etc.). (d) Employee accounting (shore and seagoing personnel wages and social contributions). 3.5.2 – Chartering/Insurance Department (NG) (a) Chartering ships (spot and time-charter). (b) Checking ships operativity (port expenses, etc.). (c) Supply of fueloils. (d) Selecting company’s agents and keeping in touch with them. (e) Relations with Italian and foreign industrial organizations (CONFITARMA, INTERTANKO, BIMCO, etc.). (f) Requesting and organizing Charterers’ ship vetting inspections. (g) Insurance matters (HM/WR, P&I, ITOPF). Although the Chartering Department is not directly involved in the Safety Management System (SMS), due attention should be given to the implication that commercial decisions may have in terms of safety, ship operation and pollution prevetion (See Section 12.1 – Implication of commercial decisions in terms of safety). 3.5.3 – Technical Department (UT) (a) Classification of ships and planning of maintenance and repairs. (b) Spare parts supply, choosing suppliers, checks and documentation. (c) Ships’ technical supervision. (d) Safety equipment (e) Monitoring and assessment of the technical output of machinery and ships. (f) Technical management and check of the supply of fuel and lube oils to the ships. (g) Developments of preliminary plans and technical specifications for new buildings or major refittings. The Head of the Technical Department and the Superintendents are responsible for the technical supervision of the ships. For particularly complex technical problems the Company may avail itself of external advisers, specifically experienced on the matter. 3.5.4 – Marine Department (AR) (a) Fitting and maintenance of navigational and communications equipment and Safety Radio. (b) Nautical charts and publications. (c) Statutory logbooks; Company’s record books, publications and SMS library. (d) Seamanship and life saving equipment. (e) Supply of lube oils. (f) Supply of consumable materials and stores to the ships’ deck and engine departments, choosing suppliers, checks and documentation. (g) Supply of coatings and checking their application. (h) Checking the victualling management on board and relations with the catering firm. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 3 of 7 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER COMPANY’S DESCRIPTION AND ORGANIZATION 3 (i) General affairs, head office logistics. (j) Postal office. (k) Checking and approving any sludge and garbage disposal ashore (l) Dealing with the Company’s MD in charge (m) OCIMF – Drug & Alcohol Policy (see Section 12.8 this manual). 3.5.5 – Crewing Department (PS) (a) Providing and enrolling seamen, medically fit, holding all necessary licenses and certificates, properly skilled, having a good knowledge of the English language, in order to crew the company’s ships in accordance with national and international regulations, availing itself also of a qualified Manning Agent (see chapter 5). (b) Supervision of crews and relevant expenses. (c) Carrying out audits in the Manning Agent offices. (d) Travel office of Company’s personnel. 3.5.6 – HSEQ Department (HSEQ) (a) SMS - ISM Code:  Designated Person Ashore (DPA) (see following § 3.6); - Internal Auditor (see Chapter 16 of this manual). - Supervision and coordination of the Company’s SMS, both in the shore and ship departments, and relevant internal audits (see Chapter 16 of this manual). - Revision and updating of the SMS Manual and of manuals, publications and operational records required by the SMS. - Dealing with the Flag State and the Auditing body (RINA) and organizing audits for the issue and periodical endorsement of documents to the Company (DOC) and to the ships (SMC), in accordance with ISM Code. (b) Security - ISPS Code:  Company Security Officer (CSO) (see Section 12.7 of this manual). - Tasks requested by ISPS Code. - Dealing with the Flag State and the Security Consultant for the issue and revision of safety plans. - Organizing the required CSO/SSO training courses. - Organizing the yearly ship/shore drills. - Dealing with the Flag State and organizing audits for the issue and periodical endorsement of the requested documentation (ISPS Certificate, Continuous Synopsis Record). (c) MARPOL 73/78 - I/37 – U.S.A. OPA-90:  SOPEP – VRP: Company’s first contact - Shoreside Spill Response Coordinator (see Section 8.2 of this manual). - Requested drills organization. (d) Decree 27.07.1999, n.o 271 – Safety and hygiene of working environment (see Section 12.8 of this manual). - HACCP. (f) Decree 30.06.2003, n.o 196 – Protection of privacy (see following § 3.8):  Responsible person for the management of personal data, directly appointed by the board of Directors. (g) Quality / Environment Integrated Management System in accordance with UNI EN ISO 9001:2008 and UNI EN ISO 14001:2004 standards (see Chapter 1 of this manual). (h) TMSA - Management of the system. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 4 of 7 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER COMPANY’S DESCRIPTION AND ORGANIZATION 3 3.5.7 – Informatic Technology Office (IT) Directly managed by the General Manager (a) Fitting, management and maintenance of informatics technology and softwares in main office and on board ships. (b) Technical management of informatics systems privacy. (c) Purchasing and supply hardware, software and consumables. (d) Fleet and Office communications. (e) Outsourching and consultancy coordinations. 3.5.8 – KEY SHORE STAFF HAND OVER PROCEDURE Key Personnel who have planned to go for a shore leave more than five days should hand over to their Deputies all relevant pending jobs/activities in order to ensure proper monitoring during their absence. Following list of Personnel are involved in that procedure: OUTGOING VERSUS INCOMING (DEPUTY) CHARTERING/OPERATIONS GENERAL MANAGER MANAGER DPA DEPUTY DPA CSO DEPUTY CSO TECHNICAL MANAGER TECHNICAL SUPERINTENDENT MARINE MANAGER MARINE SUPERINTENDENT CHARTERING/OPERATIONS COMMERCIAL OPERATOR MANAGER CREW MANAGER CREW OPERATOR IT MANAGER IT OFFICER Both outgoing and coming staff should sign for acknowledge and acceptance what it is stated in the report. The form to be used is MNG 05 Key Shore Staff Hand Over Report; HSEQ Dept. shoud be advised about any shore leave in order to keep proper evidence and maintain the related record. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 5 of 7 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER COMPANY’S DESCRIPTION AND ORGANIZATION 3 4. DESIGNATED PERSON(S) To ensure the safe operation of each ship and to provide a link between the Company and those on board, every Company, as appropriate, should designate a person or persons ashore having direct access to the highest level of management. The responsibility and authority of the designated person or persons should include monitoring the safety and pollution prevention aspects of the operation of each ship and ensuring that adequate resources and shore- based support are applied, as required. 3.6 DESIGNATED PERSON ASHORE (DPA) The Designated Person Ashore (DPA) is the link between the Company and its ships. He has direct access to the higest level of management. The DPA has the responsibility to:  Monitor in every moment all aspects of the ships’ management concerning safety and pollution prevention.  Ensure that suitable resources and assistance from shore to the ships are always available, in order to carry out and actually implement the principles outlined in this Manual.  Ascertain that any corrective action is promptly carried out. The DPA is the Company’s First Contact for any emergency in Safety and Environmental. The DPA is appointed by the General Manager by written statement. He shall notify the General Manager of any deficiency or non conformity detected during an internal inspection or audit, or reported from the ship. He shall make sure that all decision taken by the General Manager with the purpose of maintaining the highest level of safety and environmental protection are actually being carried out. Any time the DPA considers that additional resources are necessary to fulfil his tasks, he shall request them in writing to the General Manager who, in turn, will assess the situation and decide as soon as possible on the most appropriate action to maintain the highest level of effectivness of the SMS. The DPA shall keep a file of such correspondence. Company’s DPA and his deputy, together with the telephone numbers to contact them, are listed in the Annex to this chapter. Furthermore, the Company supplies its ships with a continuously updated telephone directory, containing the home and mobile phone numbers of the DPA and his deputy, and of all the office people that could be called AOH by the ships’ staff. In order to protect the privacy of personal data, the directory is intended only for ship's personnel in charge of their management, i.e.: • The Master: • the Chief Engineer; • the Officer responsible for GMDSS. A complete list of the home address and telephone numbers of all the Company’s shore personnel is also available in the offices. The Master must notify the DPA of any occurrence or incident affecting the safety of human life, the health and well being of the crew, the normal management of the ship and of cargo operations, her safety and the protection of the environment, particularly when assistance from the Company (both technical and human resources) is needed. Such notifications must be recorded by the Master in his statutory Logbook (Giornale Nautico - Libro Secondo). Initial contact with the DPA for urgent matters or emergency situations must always be established by phone, to be followed as soon as possible by written messages detailing the nature of the problem and supplying all relevant information. Were it not possible, in case of need, to contact the DPA, his deputy or persons of any Department shall be called. Any person so called by a Shipmaster shall inform the DPA as soon as possible. For immediate response, see Chapter 8, § 8.9.2 of this manual. In case of a serious and imminent danger for the human life, the vessel, the environment and the ship security, the Master shall carry out the procedures and act in accordance with instructions contained in Chapter 8 and Section 12.7 of this manual. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 6 of 7 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER COMPANY’S DESCRIPTION AND ORGANIZATION 3 3.7 EMERGENCY PREPARADNESS See Chapter 8 – § 8.9. 3.8 PROTECTION OF PRIVACY In order to protect the privacy of persons and subjects having whatever connection with its activities, the Company carries out the management of their personal and sensible data in accordance with the requirements of Decree 30 June 2003, n.o 196 – Code on the protection of personal data, and its subsequent amendments. 3.9 RISK ASSESSMENT See Chapter 12 – § 12.1. 3.10 MANAGEMENT OF CHANGE The Company established procedures for evaluating and managing changes to operations, procedures, drawings, ship's equipment or personnel to ensure that safety and environmental standards are not compromised (See Table 3.a):  The Procedure OP 02 is used to carry out and document the process of change using Company’s Form MOC HSEQ 15;  Risk assessment (see Chapter 12 - § 12.1.1) is a part of the procedure, for both temporary and permanent changes;  The procedure ensures that potential consequences of a change are identified together with any required risk-reduction measures.  The procedure ensures that any change is approved by senior shore/ships' management and not by the person directly involved in the change.  Both shore and ships' staff are subject to a documented familiarization programme;  A documented handing over system exists for both shore and ships' staff;  The procedure routinely identifies any training needs arising from changes in equipment or procedures;  The procedure include provisions for familiarization of superintendents and crew with newly acquired ships entering the managed fleet.  The procedure ensures that all applicable drawings, procedures, publications and other technical documents are updated following any change or modification;  The procedure ensures that any temporary changes do not exceed the initial authorisation for scope or time without review and reapproval by appropriate management;  The procedure ensures that changes not carried out within the proposed time scale are reviewed and revalidated  Records of the procedures are kept for verification purposes. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 7 of 7 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER COMPANY’S DESCRIPTION AND ORGANIZATION 3 CATEGORY Change subject: Initial Review / risk Re-evaluation Parties affected evaluation by: Final Approval by the change: by: Commercial Trading Area Operation Manager / GM Vessel / Company DPA Documents IMS Revisions - New Managers / DPA GM Company / Vessel Procedures Documents Company’s policies DPA GM Company / Vessel Technical Drawings, plans, Technical Manager / GM Vessel manuals DPA Technical Deck/Cargo Technical Manager / GM Vessel Equipment or DPA Components Technical E/R Equipment or Technical Manager / GM Vessel Components DPA Technical Safety Equipment or Technical Manager / GM Vessel Components DPA Technical Change of or new Relevant Managers GM Company / Vessel software/ hardware Technical Major Repairs – Technical Manager / GM Vessel Modification DPA Personnel Shipboard personnel – Crew Manager / DPA GM Company / Vessel Manning levels Personnel Shipboard Personnel Crew Manager / DPA GM Company / Vessel – New Nationality Personnel Shore Personnel - Managers /Personnel GM Company Position Change Manager /DPA Personnel Company’s Managers /Personnel GM Company organisation, Manager /DPA restructuring, reporting relationships Commercial New Subcontractor Managers / DPA GM Company / Vessel Operational / Changes on types of Operation Manager / GM Company / Vessel Commercial cargo DPA Operational New vessel type in the Managers / DPA GM Company / Vessel fleet Commercial Change of vessel’s DPA GM Company / Vessel name or Flag or Class, etc. Commercial New acquisition Managers / DPA GM Company / Vessel Temporary Temporary changes of Managers / DPA DPA Company / Vessel medium or low risk Emergency Emergency changes Master / Managers / DPA Company / Vessel of medium or low risk DPA Emergency Temporary or Managers / DPA GM Company / Vessel Temporary Emergency changes of high risk Table 3.a FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Page st HSEQ DEPARTMENT GENERAL MANAGER 21 April 2017 1 of 4 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code COMPANY’S DESCRIPTION AND ORGANIZATION ANNEX TO CHAPTER 3 This annex is reprinted when necessary. It is not subject to Certifying Body (RINA) approval and its change should not be recorded in the manual's revisions checklist. a) ADDRESS AND TELEPHONE NUMBERS Fratelli d’Amico Armatori S.p.A. Via Liguria, 36 – 00187 ROMA, Italy HEAD OFFICE Tel.: +39 06 46711 (switchboard) Fax: +39 06 482 8145 b) GENERAL MANAGER Carlo CAMELI Office: +39 06 46711 (switchboard) Mobile: +39 335 368 288 [email protected] c) DESIGNATED PERSON ASHORE Massimo DE DOMENICO Designated Person Office: +39 06 4671 3183 (direct) Ashore (DPA) Mobile: +39 335 649 5123 [email protected] Carlo INCORONATO Office: +39 06 4671 3110 (direct) Deputy DPA Mobile: +39 335 875 6658 [email protected] FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Page st HSEQ DEPARTMENT GENERAL MANAGER 21 April 2017 2 of 4 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code COMPANY’S DESCRIPTION AND ORGANIZATION ANNEX TO CHAPTER 3 This annex is reprinted when necessary. It is not subject to Certifying Body (RINA) approval and its change should not be recorded in the manual's revisions checklist. d) HEADS OF DEPARTMENTS Technical Manager Massimo DE DOMENICO Technical Department (UT) Office: +39 06 4671 3183 (direct) Mobile: +39 335 649 5123 [email protected] Marine Department Manager Carlo INCORONATO Marine Department (AR) Office: +39 06 4671 3110 (direct) Mobile: +39 335 875 6658 damarm @damicofratelli.it Crewing Manager Ms. Valeria POGGI Crewing Department (PS) Office: +39 06 4671 3129 (direct) Mobile: +39 334 600 1564 [email protected] DPA/QEM Massimo DE DOMENICO HSEQ Department (HSEQ) Office: +39 06 4671 3183 (direct) Mobile: +39 335 649 5123 [email protected] [email protected] e) PERSONS IN CHARGE OF OFFICES Person in charge Massimo SCALA Informatic Technology (IT) Office +39 06 4671 3114 (direct) Office Mobile: +39 335 784 0654 [email protected] FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Page st HSEQ DEPARTMENT GENERAL MANAGER 21 April 2017 3 of 4 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code COMPANY’S DESCRIPTION AND ORGANIZATION ANNEX TO CHAPTER 3 This annex is reprinted when necessary. It is not subject to Certifying Body (RINA) approval and its change should not be recorded in the manual's revisions checklist. f) CONTACTS FOR THE OPERATIONAL MANAGEMENT OF EMERGENCIES Dedicated telephone number (24h - 7/7) to be used only to notify the Company of an emergency situation +39 06 4671 3555 POLLUTION OR RISK OF POLLUTION Company’s first Contact Massimo DE DOMENICO for SOPEP and VRP - Office: +39 06 4671 3183 (direct) Shoreside Spill Response Mobile: +39 335 649 5123 Co-ordinator [email protected] Carlo INCORONATO Office: +39 06 4671 3110 (direct) Alternate Contact Mobile: +39 335 875 6658 [email protected] SECURITY INCIDENTS Franco MITRANO Company Security Officer Office: +39 06 4671 3173 (direct) (CSO) Mobile: +39 329 564 3920 [email protected] Anita Izabela ZWOLINSKA Office: +39 06 4671 3143 (direct) Deputy CSO Mobile: +39 342 349 5469 [email protected] The initial contact to notify the Company of an emergency situation should be established by using the appropriate mobile telephone number or the special phone number. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Page st HSEQ DEPARTMENT GENERAL MANAGER 21 April 2017 4 of 4 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code COMPANY’S DESCRIPTION AND ORGANIZATION ANNEX TO CHAPTER 3 This annex is reprinted when necessary. It is not subject to Certifying Body (RINA) approval and its change should not be recorded in the manual's revisions checklist. g) COMPANY’S ORGANIZATION BOARD OF DIRECTORS MANAGER Carlo GALDO CHAIRMAN ACCOUNTING GENERAL MANAGER DEPARTMENT Carlo CAMELI Romano MANCINI INFORMATIC DPA TECHNOLOGY OFFICE Massimo DE DOMENICO Massimo SCALA HSEQ CHARTERING TECHNICAL MARINE CREWING DEPARTMENT DEPARTMENT DEPARTMENT DEPARTMENT DEPARTMENT Massimo Federico Massimo Carlo Valeria DE DOMENICO BALDINI DE DOMENICO INCORONATO POGGI QEM Carlo INCORONATO Deputy DPA Franco MITRANO CSO Anita Izabela ZWOLINSKA Deputy CSO VESSELS FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 1 of 8 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741 (18), as amended – ISM Code CHAPTER 4 SHIPBOARD ORGANIZATION 6 RESOURCES AND PERSONNEL 6.2 The Company should ensure that each ship is manned with qualified, certificated and medically fit seafarers in accordance with national and international requirements 4.1 RESOURCES AND PERSONNEL Number and qualifications of the crew members of a ship should meet national and international regulations requirements and be detailed in the Minimum Manning Certificate issued by the Flag State, taking into account also all operations the ship could be involved in, the ship’s tonnage, type and technical characteristics, her service and navigation limits. Generally, the total number of crew on board the Company’s ships is higher than the number stated in the certificate. In consideration of particular voyages, cargo types and maintenance needs, the Company may provide Additional crewmembers. However, the maximum number of persons on board can never be in excess of the maximum number allowed by the Cargo Ship Safety Equipment (SAFEQ) Certificate (see Chapter 14 - § 14.2 of this manual). In order to reduce to the minimum any issue related to communication and particularly to the social aspects of communication, the Company has set as 4 the maximum number of nationalities on board its vessels. Officers, Petty Officers and crew should hold the necessary certification and have attended all qualification and training courses required by national and international regulations. 4.2 RANKING ON BOARD Ranking on board Italian-flag ships is so set by Article 321 of Navigation Code (Italian Merchant Shipping Act): Order Rank (STCW/Italian) 1 Master / Comandante 2 Chief Engineer (CE) / Direttore di Macchina Chief Officer (CO) / 1° Ufficiale di Coperta (1UC) 3 2 nd Engineer (2E) / 1° Ufficiale di Macchina (1UM) 2 nd Officer (2O) / 2° Ufficiale di Coperta (2UC) 4 3 Engineer (3E) / 2° Ufficiale di Macchina (2UM) rd 5 Other Deck and Engineering Officers 6 Boatswain / Nostromo 7 Others Deck and Engine Petty Officers 8 Ratings 4.3 WORKING LANGUAGE Working and documentation language on board Company’s ships is the English language. In order to keep the statutory documents and to carry out all appropriate contacts with the Administration (Flag State), EU citizens employed as Masters on board Company’s ships must have a good knowledge of the Italian language, in conformity with current national regulations. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 2 of 8 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741 (18), as amended – ISM Code CHAPTER 4 SHIPBOARD ORGANIZATION 5. MASTER'S RESPONSIBILITY AND AUTHORITY 5.1 The Company should clearly define and document the master's responsibility with regard to: 1. implementing the safety and environmental-protection policy of the Company; 2. motivating the crew in the observation of that policy; 3. issuing appropriate orders and instructions in a clear and simple manner; 4. verifying that specified requirements are observed; and 5. periodically reviewing the SMS and reporting its deficiencies to the shore based management. 5.2 The Company should ensure that the SMS operating on board the ship contains a clear statement emphasizing the master's authority. The Company should establish in the SMS that the master has the overriding authority and the responsibility to make decisions with respect to safety and pollution prevention and to request the Company's assistance as may be necessary. 4.4 MASTER’S RESPONSIBILITY AND AUTHORITY WITH REGARD TO THE SMS While the general responsibilities and authority of the master are set in the following paragraph 4.5.1, his responsibilities and authority with regard to the provisions of the Safety Management System (SMS) are hereinafter detailed: 1. Carrying into effect the Company’s policy in regard of safety and pollution prevention. To this purpose, he shall make sure that:  the crew has a good knowledge of the SMS, checking that the manual and other Company’s publications have been read and understood by responsible people, and its content is well known by all crew members;  proper working practices and operational and safety procedures are followed;  ship personnel is regularly trained;  safety and anti-pollution drills are carried out; he shall also check the effectiveness and good co-operation of the teams taking part in the drills;  operations are regularly recorded, as requested by this manual. To this purpose, he should check ship’s operations, discuss them with his Officers, check the relevant documentation, request periodical reports from responsible persons. 2. motivating the crew in putting into effect such policy. 3. continuous revision of safety and pollution prevention procedures and instructions, notifying the Company any comment or suggestion to the purpose, so to improve its policy. 4. issue suitable orders and instructions to the crew in a simple and clear way, so to reach its goals. 5. checking actual compliance on board to the SMS requirements with regard to safety and pollution prevention The Master shall make sure that new crew members, as soon as possible after joining, are properly informed, either directly by him or by Officers who have already been suitably trained on SMS, and that they are encouraged in observing the Company established policy (see Chapter 5 – § 5.3.2.2(ii)). The name of the new crew member, his joining date and the name of the training Officer shall be entered in the special record book. It is Master’s responsibility to inform the DPA of any occurrence that, in his opinion, may affect the safe management of the ship or result in a risk of pollution and that requires the Company’s assistance in corrective action. Important and urgent notifications to the DPA should be made in writing, and must be recorded by the Master in his statutory Logbook (Giornale Nautico - Libro Secondo) (see Chapter 3 – § 3.6). 4.4.1 – Master’s review of the SMS Every contract, the Master shall review and check the fulfilment of the SMS on board the ship, using a Company’s Form Master Review of the SMS, which shall be handed over to the auditor or DPA attending the vessel for the yearly audit. Copy of the checklist, endorsed by the auditor or the DPA, shall be kept filed on board. 4.4.2 – Reporting SMS non-conformities The Master shall notify to HSEQ Dept. any non-conformity of the system or of its enforcement noticed on board, such as a disagreement with current legislation (R.S., SOLAS 74/78, MARPOL 73/78, STCW, MLC 2006, etc.), operational procedures not in accordance with industry requirements (OCIMF, ICS, INTERTANKO, etc.), impracticable operations and procedures, any kind of shortcomings or mistakes. The HSEQ Dept. together with the General Manager and the involved persons, shall assess the Master’s report and decide on any action to be taken or any change to be made, as the case may be. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 3 of 8 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741 (18), as amended – ISM Code CHAPTER 4 SHIPBOARD ORGANIZATION 4.4.3 – Master's Overriding Power Although the Company gives detailed operational and emergency instructions and procedures, it is clearly established that, on board, the Master has full and complete overriding authority and responsibility to take any decision he can deem appropriate for the safety of human life and of his ship and to protect the environment. Master can request Company's assistance, in case he reckons it necessary. 4.5 SHIPBOARD ORGANIZATION Tasks and responsibilities: 4.5.1 – Master ⇒ Highest authority on board (Italian Code of Navigation - Part I - Book II - Title III - Chapter IV). ⇒ Responsible for the safety of the ship, of her crew, of the cargo and for pollution prevention. He may take any decision he deems necessary for the safety of life at sea and of the ship, for the protection of the environment, and for the defence of public and ship’s security. ⇒ Responsible for keeping ship documents and crewmembers’ discharge books, documents and passports. ⇒ He represents the Owners before the crew, national and foreign Authorities, Charterers, Shippers, Consignees, etc. ⇒ Responsible for the correct loading of the cargo, its keeping, transportation and redelivery, in accordance with relevant charter parties. ⇒ Responsible for voyages planning. ⇒ Sole responsible for navigating and manoeuvring the ship, to be carried out personally by him on entering or sailing ports, canals, rivers, and in any circumstance when navigation is particularly difficult (C.N.- Art. 298). He remains responsible also when a duly certified Officer carries out the watch on the navigation bridge and when employing a pilot. ⇒ Responsible for making the ship ready and giving all necessary assistance for statutory surveys and classification surveys and works. 4.5.2 – Deck, Cabin and Catering Departments 4.5.2.1 – CHIEF OFFICER ⇒ Watch keeping on the navigation bridge (see Section 12.2.1). ⇒ Safety Officer (Italian Safety Regulations 1991 – art. 202.5). Responsible person for crew training and emergency drills, and relevant records. ⇒ Responsible person for the mobile fire-fighting equipment (except those to be employed in the engine room), of the communication means and of fire-fighting service (S.R./91 - art. 214.2). Chief of the Fire Party (S.R./91 - art. 253). ⇒ Responsible person for LSA. In charge of ensuring that all LSA are in good order and promptly ready for use (S.R./91 - art. 203.5). ⇒ Responsible person (RESAL) in charge of safe working practices for deck, cabin and catering department labour, as per relevant safety plan (DL 27.7.1999 n.271- art. 6.5 – see Section 12.8). ⇒ Responsible person for entries in the Oil Record Book, Part II - Ballast/cargo Operations, and in the Garbage Record Book (see Section 12.3). ⇒ Checks and inspections of hull structures and compartments, as per PMS (AMOS). ⇒ Cargo and ballast loading, unloading, keeping and transfer. Washing and cleaning cargo tanks (see Section 12.4). ⇒ Management and direction of deck, cabin ⇒ Management of catering personnel. ⇒ Maintenance of structures and compartments, main and open decks, accommodations, and relevant inspections and records, as per PMS (AMOS). ⇒ Responsible person for deck, cabin and catering inventories. ⇒ Requisitions for deck, cabin and catering materials. ⇒ Stationed on the navigation bridge, the forecastle or the poop on arrivals, departures and while sailing rivers or canals, as ordered by the Master. ⇒ Responsible person for the ship in absence of the Master or in case the Master can no longer maintain her command. 4.5.2.2 – SECOND OFFICER ⇒ Watchkeeping on the navigation bridge (see Section 12.2.1). ⇒ Navigating Officer (See Bridge Management Manual – Party I, § 3). FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 4 of 8 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741 (18), as amended – ISM Code CHAPTER SHIPBOARD ORGANIZATION 4  Ship Security Officer (in case 2/O has not got the SSO Certificate, the tasks will be carried out by the Chief Officer)  Maintenance of navigation equipment and instruments (see Bridge Management Manual – Party I, § 8.1).  Ship’s cash and crew accounting (this task is taken on by the GMDSS-dedicated Officer, when carried).  Stationed on the navigation bridge, the forecastle or the poop on arrivals, departures and while sailing rivers or canals, as ordered by the Master.  Assisting cargo and ballast loading, unloading, keeping and transfer. Washing and cleaning cargo tanks (see Section 12.4).  Responsible person for hygienic inspections on board and check required by HACCP manual (see Section 12.8). 4.5.2.3 – THIRD OFFICER  Watchkeeping on the navigation bridge. (see Section 12.2.1).  In charge of checks and maintenance of all mobile fire-fighting equipment, and of the updating of the relevant inventory, and of all LSA, under Chief Officer’s and Chief Engineer’s supervision.  Responsible person for ship’s pharmacy and for entries in the medical log-book (see Section 12.8).  Preparing documents for inbound/outbound clearance, port business, crew-members medical assistance (these tasks are taken on by the GMDSS-dedicated Officer, when carried).  Assisting cargo and ballast loading, unloading, keeping and transfer. Washing and cleaning cargo tanks (see Section 12.4).  Stationed on the navigation bridge, the forecastle or the poop on arrivals, departures and while sailing rivers or canals, as ordered by the Master. 4.5.2.4 – DECK CADET  Assisting Deck Officers. 4.5.2.5 – GMDSS-DEDICATED OFFICER  Management of telecommunications (see Section 12.2.2).  Equipment ordinary maintenance.  Equipment spare parts inventory.  Telecommunications accounting.  Collecting and filing weather reports received by means of the GMDSS equipment.  Receiving and filing meteorological chartlets.  Receiving and filing MSI received by means of GMDSS equipment.  Obtaining ship’s chronometer absolute and daily rate. When there is no GMDSS-dedicated Officer on board, his tasks are carried out by the three Deck Officers, holding a GOC, whose presence on board is requested in such a case. One of them shall be appointed by the Master as GMDSS Responsible Officer with a special entry in the radio logbook. 4.5.2.6 – PETTY OFFICERS AND RATINGS  BOATSWAIN: At station forward for anchoring, mooring, unmooring. – Organizes checks and carries out seamanship and ordinary maintenance works of the ship and her equipment. – Keeping and checking consumables and stores.  TANKMAN: – Assists the Chief Officer in cargo operations. – Operates and maintains the vessels pump room/pumps and cargo handling equipment. Carrying out repair and maintenance duties both on deck and in the engine spaces as instructed by Chief Officer and Chief Engineer.  ABLE-BODIED SEAMEN (AB): Watchkeeping on the navigation bridge (helmsman and lookout). – Watchkeeping on deck and at ship’s access in port. – At station forward or aft for anchoring, mooring and unmooring. – Seamanship and ordinary maintenance works.  ORDINARY SEAMEN (OS): At station forward or aft for anchoring, mooring and unmooring. – Seaman-ship and ordinary maintenance works. – Tidying and cleaning storerooms and accommodations.  DECK BOYS: At station forward or aft for anchoring, mooring and unmooring. – Seamanship and ordinary maintenance works. – Tidying and cleaning crew quarters including the galley. - Assisting Cook.  COOK: Stores management (fresh, dry and frozen provisions). – Keeping and checking galley tools and equipment. – Bread making. – Preparation and distribution of meals. Requisition of stores.  STEWARD: Officers’ cabins service. – Officers messroom service. – Tidying and cleaning officers’ quarters. – Management of tableware and linen. – Laundry service. – Assisting Cook.  GALLEY BOY: Assists the Cook. – Tidying and cleaning storerooms, galley and pantries. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 5 of 8 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741 (18), as amended – ISM Code CHAPTER 4 SHIPBOARD ORGANIZATION 4.5.3 – Engine Department 4.5.3.1 – CHIEF ENGINEER ⇒ Responsible person for the good working order, maintenance and operation of main engine and all ships machinery ⇒ Responsible person for the fixed fire-fighting installations and for the mobile fire-fighting equipment to be employed in the engine room. In charge of ensuring that all fire-fighting equipment is in good order and promptly ready for use ⇒ Responsible person for Critical Equipment operation, Maintenance, Repair and amending parameters such us changing alarm set – point. ⇒ Responsible person in charge of safe working practices for engine department, as for relevant safety plan ⇒ Responsible person for entries in the Oil Record Book, Part I- Machinery spaces operations ⇒ Responsible person for the replenishment, sampling and correct management of ship's fuel and lube-oils ⇒ Responsible person for safety technical checks ⇒ Responsible person for maintenance and repairs works and operations ⇒ Responsible person for training engine department personnel on their task and on the Safety Management System SMS ⇒ Responsible for training of engine personnel ⇒ Responsible for the efficiency of all apparatus connected with \"Solas\" and \"Marpol\" certification. ⇒ Responsible for the engine stores and the PMS system ⇒ Checking fresh water production and supply ⇒ Responsible for the proper fill-in the PMS system Work Order and SMS Documents ⇒ Responsible for the evaluations of Engine Officers and the characteristic note for all engine personnel ⇒ Responsible for all documentation on board and proper filing. 4.5.3.2 – SECOND ENGINEER ⇒ Duty service or watchkeeping 04˚˚/08˚˚ and 16˚˚/20˚˚ in engine room ⇒ Responsible person for the engine department in absence of the Chief Engineer or in case the Chief Engineer can no longer maintain its management ⇒ Responsible person for Critical Equipment operation, Maintenance, Repair. ⇒ Organizing maintenance and repair work in accordance with Chief Engineer's instructions ⇒ Management of engine department personnel ⇒ Preparing stores and consumable provisions requisitions to be submitted to the Chief Engineer for approval ⇒ Responsible for keeping the inventories assigned ⇒ In charge of fixed fire-fighting equipment operation (R.S./91 - art. 211). TASKS ⇒ Responsible for maintenance of Main engine/Shaft line/Stern tube seal ⇒ Responsible for maintenance of emergency Diesel Generator ⇒ Responsible for maintenance for Turbo pumps and Cargo Line ⇒ Provision fridge and accommodation A/C plant maintenance ⇒ Steering gear daily check ⇒ Responsible for weekly / monthly test assigned ⇒ Responsible of inert gas system and oxygen analyser MONTHLY DOCUMENTATIONS ⇒ Main Engine running hours ⇒ Dpa/E-gics ⇒ Main engine Axials vibrations ⇒ Main Engine Marpol Annex VI Nox report ⇒ Main Engine scavenging inspection ⇒ Main Engine crankshaft deflections report ⇒ Main Engine crankshaft Inspections ⇒ Main Engine bearing inspections and clearances report ⇒ Maintenance and calibrations pistons and liner report ⇒ Main Engine exhaust valve maintenance report ⇒ Main Engine exhaust valve sealing test ⇒ Steering gear inspection report FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 6 of 8 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741 (18), as amended – ISM Code CHAPTER 4 SHIPBOARD ORGANIZATION ⇒ Cargo pumps performance data ⇒ Stern tube monitoring record 4.5.3.3 – THIRD ENGINEER ⇒ Duty service or watchkeeping 00˚˚/04˚˚ and 12˚˚/16˚˚ in engine room ⇒ Boiler water, cooling water and S.W. analysis ⇒ Bunkering operations ⇒ Liaising and conferring with 1st Assistant Engineer about overhauling all apparatus ⇒ Responsible for keeping the inventories inherent what above TASKS ⇒ Responsible for Bunker & transfer Oil/HFO in accordance with Chief Engineer's instructions ⇒ Main Engine fuel valves maintenance ⇒ Auxiliary Engines maintenance ⇒ Responsible of Auxiliary boilers and economizer maintenance and water analysis ⇒ Responsible of bilge and sludge system ⇒ Test and check of all apparatus connected with \"Solas\" and \"Marpol\" certification ⇒ Responsible of life boats maintenance ⇒ Responsible for keeping the inventories assigned. MONTHLY DOCUMENTATIONS ⇒ Running hours Diesel generator ⇒ DPA & auxiliary performance data report ⇒ Auxiliary engine marpol Annex IV Nox Report ⇒ Crankshaft Deflections report ⇒ Auxiliary engine bearings inspection & clearances ⇒ Auxiliary engine Piston & liner maintenance report ⇒ Auxiliary engine turbocharger maintenance ⇒ Main engine fuel valve maintenance report ⇒ Auxiliary Boilers performance data report ⇒ Auxiliary Boiler System water analysis ⇒ ME&Auxiliary Machinery cooling water analysis 4.5.3.4 – FOURTH ENGINEER ⇒ Duty service or watchkeeping 08˚˚/12˚˚ and 20˚˚/24˚˚ in engine room ⇒ Testing and checking of all apparatus connected with \"Solas\" and \"Marpol\" certification ⇒ Liaising and conferring with 1st Assistant Engineer to overhauling all apparatus ⇒ Responsible for keeping the inventories assigned TASKS ⇒ Responsible for Purifiers maintenance and fuel oil booster system for ME/DDGG ⇒ Responsible for the air compressor maintenance and all system ⇒ Responsible for the cooling system at Sea/fresh water and ballast line maintenance ⇒ Main Engine turbochargers daily wash ⇒ Lubricating oil analysis. ⇒ Oil and chemical inventory in accordance with Chief Engineer's instructions ⇒ Sewage plant maintenance ⇒ Responsible for the Fresh water system and FW generator ⇒ Responsible for SW chlorine system ⇒ Responsible for maintenance and to grease all deck machinery MONTHLY DOCUMENTATIONS ⇒ Main Engine stuffing box & F:O pumps leakages measuring reports ⇒ Running hours purifiers ⇒ Air compressor running hours ⇒ Fresh Water generator performance report FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 7 of 8 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741 (18), as amended – ISM Code CHAPTER 4 SHIPBOARD ORGANIZATION ⇒ MGPS Performances & chlorine analysis ⇒ Sewage system analysis ⇒ Viscosity on board analysis ⇒ Lubricating oils & greases monthly ROB ⇒ Lubricating oils & greases consumptions ⇒ Lubricating & greasing rounds ⇒ Chemical monthly ROB & consumptions ⇒ Chain block inventory record ⇒ Inventory of shackles, chains, rings, turnbuckles etc. 4.5.3.5 – ENGINE CADET ⇒ Assists Engineering Officers. 4.5.3.6 – PETTY OFFICERS AND RATINGS • FITTER: Mechanical and ordinary maintenance works of the ship and her machinery. – Gas and electrical welding and operation of machine tools. – Keeping and checking workshop consumables and stores. • ELECTRICIAN: Ordinary maintenance works of ship’s electric machinery and equipment. – Keeping and checking electric workshop consumables and stores. RESPONSABILITIES ⇒ Ordinary maintenance works of ship's electric machinery and equipment, keeping and checking electric workshop consumables and stores TASKS ⇒ Daily round for general check of Electric Motor, Electrical Panel and burned lamp replacement ⇒ Daily check of Cathodic Protection (CAPAC) ⇒ Daily check of Marine Grow Preventing System (MGPS) ⇒ Weekly check for all Battery: load test, voltage and density check ⇒ Weekly check of life boats lighting, engine starting and steering movement ⇒ Weekly Emergency Generator starting and running for 15 min. Check for instrument panel functioning PRE ARRIVAL CHECK ⇒ Check Low insulation of 440V and 220V on Emergency Switchboard and Main Switchboard ⇒ Check for emergency escape lighting. Replace burned lamp ⇒ Check for all electrical sockets closed with cover. ⇒ Check for all Deck lighting. Replace burned lamp DOCUMENTATION ⇒ Battery log ⇒ CAPAC System ⇒ MGPS System ⇒ Low Insulation measurement log • ENGINE HAND: Ordinary maintenance work. – Tidying and cleaning machinery spaces. 4.6 WATCHKEEPING AND DUTY SERVICE Watchkeeping service on the navigation bridge is described in Chapter 12 – Sections 12.2.1 and 12.2.2. Duty and Watchkeeping service in the engine room is described in Chapter 12 – Section 12.2.3. On board all ships the Table of shipboard working arrangements (Annex A to D.L. 27.05.2005, n. 108), detailing Watchkeeping, duty service and working hours of the crew, should be posted on the navigation bridge, in the engine control room and in crew accommodations, as required by STCW/95 and D.L. 27.07.1999, no. 271. 4.7 MASTER'S AUTHORITY IN EMPLOYING SHIP'S PERSONNEL In the interest of safety of navigation, the Master has the authority to employ temporarily his crewmembers for a service which is different from the service for which they had been engaged, assuming that such service is adequate both to their certificates of competency and to their position on board. In case of need, for the safety of life and of the ship, and FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 8 of 8 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741 (18), as amended – ISM Code CHAPTER 4 SHIPBOARD ORGANIZATION for the protection of the environment, seamen may be employed in any service (Italian National Working Agreement - Chapter V - Article 24.2 – NUSI CBA Article 7.4 – MUI-CBA – OFFICERS: Article 9.5) 4.8 SHIPBOARD EMERGENCY TEAM A Shipboard Emergency Team is formed on board all ships, with the purpose of:  attending to all matters relevant to safety, security, pollution prevention, including crew training programs, operational procedures, prevention of accidents, use of personal protection equipment (PPE), ship’s hygiene, etc.;  analysing any serious incident, any accident, non-conformity or near-miss in order to identify their causes and enact an appropriate preventive action (see Chapter 10);  considering the various emergency situations which may happen on board and decide which response action may be necessary (see Chapter 8);  apprising SMS effectiveness on board and expressing any suggestion to improve it;  apprising crew training level and identifying any further need (additional training sessions and drills, refreshment courses, etc.). As a rule, the shipboard emergency team is composed by: - Master (responsible person) - Chief Engineer - Chief Officer - Second Engineer - Second Officer The emergency team meets whenever the Master deems it necessary, at least once every month as a rule. Safety Committee Meeting form of all meetings shall be kept and remain filed on board. A copy shall be sent to the Company’s HSEQ Department. The Master may extend the emergency team meeting to other crew members, or to all the crew, whenever the subject being examined requires so. The HSEQ Dept., the DPA and all other concerned people will assess the minutes and decide about any requirement or proposal from the ship. If necessary, the highest management levels shall be involved. In case the Company deems a requirement or a proposal to be groundless and do not need any action, an explanatory note shall be entered in the minutes either by the DPA or the Head of competent Department, before filing it. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 1 of 21 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER 5 MANAGEMENT OF PERSONNEL INDEX 5.1 GENERALS - 5.1.1 Company’s Policy - 5.1.2 Working language 5.2 SHORE PERSONNEL - 5.2.1 Engagement - 5.2.2 Qualification & Job Description - 5.2.3 Training - 5.2.4 Monitoring and merit rating - 5.2.5 Management of Change 5.3 SEAFARERS - 5.3.1 Engagement - 5.3.1.1 Minimum Age - 5.3.1.2 Certificates of competency and training - 5.3.1.3 Seafarer’s Employment Agreements - 5.3.1.4 Number of Crew - - - - (a) Minimum Manning Certificate - - - - (b) Aggregated experience - 5.3.1.5 Medical fitness - 5.3.1.6 Terms of Service on board - 5.3.1.7 Probation period - 5.3.1.8 Crew changes - 5.3.1.9 Masters and Senior Officers - - - - (a) Rotation - - - - (b) Briefing and De-briefing 5.3.1.10 Documentation - - - - (a) Crew - - - - (b) Crew changes - 5.3.2 Training - 5.3.2.1 Shore training - 5.3.2.2 On-board training - - - - (i) Training on safety tasks and emergencies - - - - (ii) Training on Company’s Safety Management System (SMS) - - - - (iii) Training of the crew - - - - (iv) Training of Officers on the use and checks of portable instruments - - - - (v) Training of Officers for higher positions - - - - (vi) Instruction and training of Deck and Engine Officers - 5.3.3 Officers operational familiarization - 5.3.3.1 Masters and Chief Engineers – Handing-over Reports - 5.3.3.2 Officers and Engineers - Handing-over Reports - 5.3.4 Monitoring and merit rating - 5.3.4.1 Officers and Crew - 5.3.4.2 Masters and Chief Engineers - 5.3.5 Qualification for advancement - 5.3.6 Motivation - Incentives - Crew retention - 5.3.6.1 Motivation - 5.3.6.2 Incentives FRATELLI d’AMICO ARMATORI S.p:A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 2 of 21 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER 5 MANAGEMENT OF PERSONNEL - 5.3.6.3 Crew Retention - 5.3.7 On Board Compliant Procedure. - 5.3.8 Payment of Wages - 5.3.9 Seafarer Repatriation. - 5.3.9.1 General - 5.3.9.2 Entitlements - 5.3.9.3 Shipowner Costs - 5.3.9.4 Additional Provisions - 5.3.9.5 Loss of Right of Repatriation 5.1 GENERALS 5.1.1 – Company’s policy The recruitment of the Italian and European seafarers is directly managed by the Company crew department. Procedures have been established by the Company in order to make sure that its personnel are properly qualified to perform their safety-related tasks. Particularly, the Company has adopted special procedures to make sure that its managers, Masters and Chief Engineers of its ships are fully conversant with the Safety Management System (SMS). Special attention is payed to the training of new engaged people and of personnel assigned to new tasks, and to the training necessary to maintain their required qualification and skills. Before reaching their ships, Masters and Chief Engineers should be briefed on the latest updates and changes of the SMS, so as to be able to apply it out on board and to train the ships personnel. Suitable procedures exist to make sure that Officers and crew members joining the ships are duly trained on board in order to familiarize themselves with the ship and her machineries and with their appointed their tasks (ISO IP 03 OI 01). Management of personnel consists of four main activities: 1. Engagement 2. Training 3. Monitoring and merit rating 4. Motivation. For the engagement of non-EU ship personnel, the Crewing Department cooperates with Messrs. BERNHARD SCHULTE SHIPMANAGEMENT (HONG KONG) LIMITED PARTNERSHIP as Manning Agent. Employment of such personnel is in full compliance with all national and international (ITF) regulations in force. The Company audits yearly the Manning agency, checks that the above-mentioned agency operates in accordance with the Company policy, of which it has a copy, and the following amendments, and according to the MLC 2006 requisitions described in standard A1.4. During the audit, the Company shall check also that the shipping agency audits, at regular intervals, its sub-agents who operate in territories that have ratified or not ratified the convention, giving evidence of their own authorizations and certifications. Particularly, the shipping agency shall give evidence that its sub-agents who operates in countries that have not ratified the convention, operate according to the MLC 2006 requisitions. 5.1.2 – Working language. The Company's personnel working language, both in the shore offices and on board ships, is the English language. 5.2 SHORE PERSONNEL 5.2.1 – Engagement The decision to engage new personnel for the shore staff is taken by the management, considering the operational requirements of the Company. Search for personnel is normally done by: FRATELLI d’AMICO ARMATORI S.p:A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 3 of 21 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER 5 MANAGEMENT OF PERSONNEL • Advertising on specialized media. • Search through external recruitment organizations. • Assessment of employment applications. • People already in possession of special qualification and experiences making themselves available on the job market. The management, and Heads of concerned Departments, assess candidates, taking into account:  Personal data  Qualification  Experience  Result of special interviews. Particular consideration is given to the inclusion in the shore staff of senior Deck and Engine Officers having served for an extended period of time on board ships of the fleet, with above-the-average results. Newly recruited persons are subject to a trial period in which their work is closely monitored by senior staff. A formal engagement will follow if such a trial period ends positively. 5.2.2 – Qualification & Job Description Key Shore staff must be qualified according to the minimum standards established by the Company: GENERAL MANAGER Minimum 5 years’ experience as Manager in Shipping Companies with commercial, insurance, technical Company Requirement and human resources experience; specific knowledge of global Shipping Market realities. Similar experience may be accepted upon evaluation of the CV.  Supervision and coordination of all shipping activities; Job Description  Building up forward strategies, their direction and implementation. In the Company Organization, he has direct access to the Board. CHIEF FINANCIAL OFFICER University degree in Economics. Experience in administration and financial matters. Minimum 5 years’ Company experience in all economic matters. Requirement Similar experience may be accepted upon evaluation of the CV. Directing and supervising all financial, corporate and administrative matters including:  Financial Statement;  Treasury;  Bookkeeping; Job Description  Administration and legal matters;  Budget control;  Notarization Document. Use of methods, tools and techniques for a correct survey of the managerial matters. In the Company Organization, he has direct access to the Board. DESIGNATED PERSON ASHORE (DPA) Degree in Naval Architecture and Engineering or Certified Master for ships > 3000 GRT (STCW-II/2) with at least 5 years’ experience. Company Requirement A minimum of 5 years of supervisory experience in ISM Management System, Internal Auditor and HSE Management activities. Similar experience may be accepted upon evaluation of the CV  Having direct access to the highest level of management to ensure the safe operation on board and monitoring if adequate resources and shore-based support are provided;  Coordination of safety and pollution prevention activities on board, according to ISM Code, SOLAS, MARPOL and other mandatory Survey on board;  Follow up the implementation of the Safety Management System;  Cooperation with Chartering Dept. about Vetting activities; Job Description  Provides for SMS Internal Audit on board and in the Company Office, according to Audit Program;  Keep contact with Classification Society and Marine Administration for DOC / SMC;  Report to the Administration the corrective action taken to close any SMS Non Conformities;  Follow-up the implementation and verification of corrective/preventive actions process related to Incident Investigation inclusive their effectiveness. In the Company Organization, he reports directly to the General Manager. FRATELLI d’AMICO ARMATORI S.p:A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 4 of 21 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER 5 MANAGEMENT OF PERSONNEL DEPUTY DPA Degree in Naval Architecture and Engineering or Certified Master for ships > 3000 GRT (STCW-II/2) with Company at least 3 years’ experience. Requirement A minimum of 1 years of supervisory experience in ISM Management System Similar experience may be accepted upon evaluation of the CV  Co-operate with DPA for the implementation of the Safety activities on board and in the Company Office; Job Description  Provides for SMS Internal Audit on board and in the Company Office, according to the Audit Program, or carries out extra audit according to Flag Administration, Company or other directions. In the Company Organization, he reports directly to the General Manager when DPA is unavailable. COMPANY SECURITY OFFICER (CSO) Naval Architect/Mechanical Engineer with at least two (2) years’ experience in Marine industry or Marine Company Requirement Deck Officer with at least three (3) years sea going experience  Coordination of Security activities on board, according to ISPS Code;  Follow up the implementation of the Ship Security Plan of each vessels and relative assessment; Job Description  Keep contact with Flag Administration and International Mandatory for ISPS activity;  Carries out planned ISPS Internal Audits on board, according to the Audit Program, or carries out extra audit according to Flag Administration, Company or other directions.  Report to the Administration the corrective action taken to close any ISPS Non Conformities. In the Company Organization, he reports directly to the General Manager. DEPUTY CSO Naval Architect/Mechanical Engineer with at least one (1) year experience in Marine industry or Company Requirement Marine Deck Officer with at least one (1) year seagoing experience or at least one year as employee in the Maritime Security industry. Similar experience may be accepted upon evaluation of the CV.  Co-operate with CSO for the implementation of the Security activities on board and in the Company Office; Job Description  Provides for ISPS Internal Audit on board and in the Company Office, according to the Audit Program, or carries out extra audit according to Flag Administration, Company or other directions. In the Company Organization, he reports directly to the General Manager when CSO is unavailable. Q&E MANAGER Degree in naval architecture or Certified Master or Chief Mate for ships > 3000 GRT (STCW-II/2). Minimum of 2 years of supervisory experience operating under QE Management Systems and HSE Company Requirement Management activities. Similar experience may be accepted upon evaluation of the CV.  Managing of Q&E Manual (QEM), Integrated Procedures and relative documents, granting their availability and filing on board and in the Company Office;  Managing revisions and updates of QEM , Integrated Procedures and relative documents;  Managing of ISO corrective and preventive actions, verifying efficiency and closing;  Co-operate with DPA for harmonized continuously the SMS Manual and QEM and all other ship’s matters;  Management of Environmental activities in the Company Office;  Monitoring Environmental activities on board in cooperation with DPA; Job Description  Provides for ISO Internal Audit on board and in the Company Office, according to the Audit Program, or carries out extra audit according to Flag Administration, Company or other directions;  Promote and cooperate with Technical Dpt. about Environmental projects on board the ships;  Organize Management Reviews and keep its records;  Training of personnel relative to Q&E issues.  Tracking and analysing shipboard navigational and technical audits reports and addressing the findings to the Heads of Marine and Technical Dept.  In the Company Organization, he reports directly to the General Manager. FRATELLI d’AMICO ARMATORI S.p:A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 5 of 21 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER 5 MANAGEMENT OF PERSONNEL CHARTERING & OPERATION MANAGER Minimum 5 years’ experience in shipping companies with commercial, insurance, technical experience. Company Requirement Knowledge of global shipping market realities. Fluent in written and spoken English.  Coordination and performance of operational matters related to voyage management of fleet; Job Description  Spot chartering of Company fleet. In the Company Organization, he reports directly to the General Manager. TECHNICAL MANAGER Naval Architect/Mechanical Engineer with at least five (5) years’ experience in Marine industry or Marine Company Requirement Engineer (License Chief Engineer) with at least five (5) years sea going experience at Oil Tankers.  Responsible for overall Technical Maintenance of ships.  Assure the most efficient and economical operation of the Fleet maintenance,  Supervises all activities required to preparing, verifying and reporting information about ordinary maintenance as well as out of ordinary events (i.e. dry-docking, conversions, modifications, warranties, damages, etc).  Provides all documentation relevant to technical updates and related legislation to On-board and Shore Management. Job Description  Participate to the Company Incident Response Plan as a team member.  Supervises and co-ordinates daily activities of Purchasing Personnel in procurement of spares and issuing of purchase orders .  Enforces procedures in compliance with Company's rules, regulations and policies  Immediate referent for ship’s manager in case of urgent requisitions follow up, expediting of service orders and, generically, all requested updates.  Responsible for suppliers evaluation, outsourcing and approval In the Company Organization, he reports directly to the General Manager. FRATELLI d’AMICO ARMATORI S.p:A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 6 of 21 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER 5 MANAGEMENT OF PERSONNEL TECHNICAL SUPERINTENDENT Naval Architect/Mechanical Engineer with at least three (3) years’ experience in Marine industry, or Marine Engineer (License Chief Engineer) with at least five (5) years sea going experience at Oil Tankers Company Requirement or Marine Deck Officer with at least three (3) years sea going experience at Oil Tankers. Similar experience may be accepted upon evaluation of the CV.  Supervision and control through Amos of maintenance of all ship equipment on board;  Planning and execution or Dry Dock;  Evaluation of specifics received by shipyards concerning both new buildings and planned d/d;  Extensive follow up with shipyards on new buildings;  Supervising and monitoring all technical aspects of the vessel including, safety and environmental protection and ensure that these are carried out in compliance with the Company’s requirements, maritime rules, regulations and Industry Standards,  Making recommendations for rectification of deficiencies or improvements to the existing situation;  Attending Vetting and third party inspections;  The promotion of the SMS Policy and culture on board vessels;  Ensuring that the working conditions on-board are safe;  Motivating vessels’ personnel for continuous improvement and encourage enhancement of performance;  Performing technical audits; Job Description  Assisting in the investigation and analysis of accidents, incidents and serious near misses.  Suggesting to the DPA possible improvements/modifications of the SMS;  Participating in the Emergency Response Team:  Keeping abreast with the Statutory and Class regulations and standards;  Conducting inspections in accordance with the SMS requirements;  Assisting the shipboard personnel to eliminate problems and/or malfunctions;  Attending and sailing with vessels to solve operational problems aboard, as deemed necessary;  Planning vessels’ equipment maintenance as allowed by the vessel’s itinerary and schedule and in accordance with the SMS procedures.  Attending delivery of new acquisitions;  Monitoring and evaluating the performance of the seagoing personnel and reporting accordingly to the Crew Manager;  Participating in the briefing and de-briefing of Masters, Chief Engineers, etc. before and after appointment, as per the SMS relevant procedure;  Conducting on board training on technical matters; In the Company Organization, he reports directly to the Technical Manager. MARINE MANAGER Degree in Naval Architecture and Engineering or Certified Master for ships > 3000 GRT (STCW-II/2) with at least 5 years’ experience as Master or CO on Company Requirement board Company's ships. Similar experience may be accepted upon evaluation of the CV.  Supervises and co-ordinates daily activities of Purchasing Personnel in procurement of  spares, consumable and issuing of purchase orders.  Enforces procedures in compliance with Company's rules, regulations and policies.  Immediate referent for ship’s manager in case of urgent requisitions follow up, expediting of service orders and, generically, all requested updates. Responsible for suppliers’ evaluation, outsourcing and approval.  Resolves major conflicts and disagreements with Suppliers, assuring that the Company's Job Description  procedure are observed and enforced.  Checks the victualling management on board and relations with the catering firm.  General affairs, head office logistics.  Responsible of Postal office.  Checks and approves any sludge and garbage disposal ashore.  Deals with the Company’s MD in charge.  Responsible for fitting and maintaining navigational and communications equipment including the Safety Radio. In the Company Organization, he reports directly to the General Manager. FRATELLI d’AMICO ARMATORI S.p:A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 7 of 21 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER 5 MANAGEMENT OF PERSONNEL MARINE SUPERINTENDENT Company Requirement Marine Deck Officer with at least five (5) years sea going experience at Oil Tankers.  Maintaining nautical standards on-board vessels and implementing suitable controls by adopting improved navigation practices, equipment, training and procedures;  Inspecting managed vessels in port and en-route and providing specific instructions to the Officers for issues pertaining to the SMS;  Monitoring of the Flag State and PSC requirements and following-up of third party inspections’ results;  Monitoring the inventories of mooring equipment, safety equipment, life-saving, fire-fighting equipment and portable instruments in support to Marine Manager  Attending Vetting and third party inspections;  The promotion of the SMS Policy and culture on board vessels;  Motivating vessels’ personnel for continuous improvement and encourage enhancement of performance; Job Description  Performing internal audits;  Assisting in the investigation and analysis of accidents, incidents and serious near misses.  Reviewing all reports of non-conformities, incidents or near misses received by the vessels assigned to him and following-up the implementation and verification of corrective/preventive actions process inclusive their effectiveness;  Suggesting to the DPA possible improvements/modifications of the SMS;  Participating in the Emergency Response Team;  Keeping abreast with the Statutory and Class regulations and standards;  Attending delivery of new acquisitions;  Identifying the need for crew training;  Conducting on board training. In the Company Organization, he reports directly to the HSEQ Manager and/or Technical Manager or Marine Manager. CREW MANAGER Certified Master for ships > 3000 GRT (STCW-II/2) with at least 5 years’ experience as Master and CO Company Requirement on board Company's ships, or a minimum of 5 years’ service in the Company's Crewing Department. Similar experience may be accepted upon evaluation of the CV.  Maritime human resource Management;  Interview, preliminary selection and enrolment of ships personnel – Contact with manning agencies;  Evaluation of professional profile as regard to qualification and certification; Job Description  Evaluation of outgoing performance of shipboard personnel and achievement of the Company;  Management – Selection for the Company Roster;  Personnel signing On/Off, joining and repatriation formalities (Agreement, visas, Ticketing, etc.) including all Medical matters (medical pre-employment examinations, assistance, etc. );  Co-operate with DPA for continuously implementation of the SMS on board the vessels and in the office. In the Company Organization, he reports directly to the General Manager. IT OFFICE IT Engineer or equivalent degree with Extensive experience in Information Technologies & Company Requirement Communication System management or minimum of 5 years’ experience in IT managing.  Head Office’s Computerized System Administrator;  Electronics Supplier and Contractor Coordinator; Job Description  Hardware / Software training coordinator  Purchase Responsible for: Software / hardware – mobile/fixed line telephony – Electronics Equipment - Other Communication Systems – Computer consumable spares (ashore & on board). In the Company Organization, he reports directly to the General Manager. FRATELLI d’AMICO ARMATORI S.p:A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 8 of 21 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER 5 MANAGEMENT OF PERSONNEL 5.2.3 – Training All the positions in our Company have role specific training requirements. The relevant “List of Basic Training Matrix for Shore Personnel” include training requirements per position. The training process cycle includes: • Identification of training needs • Approval of training • Participation in training seminars • Personnel training records update • Evaluation of the training The DPA and the Company’s Managers are responsible for ensuring that all shore staff receive adequate training for the duties they are expected to perform. The DPA, the CSO and their Deputy must be trained in Incident Investigation and Risk Assessment. Every five years, an Incident Investigation refresher training must be taken. The Company arranges anyhow for all concerned people to be trained in order to be acquainted with: • Company’s policy in respect to safety and protection of the environment (SMS); • technical and management problems; • coming into force of new regulations (acts, conventions, classification Societies’ rules, etc.) affecting the management and operation of ships (see chapter 6 - § 6.1); • implementation of new technologies on board. Training may consist of:  Instructions on specific subjects given either by experts (external or from the Company) or by means of publications and audio visual systems.  Attending courses, seminaries, lectures and meetings.  Temporary transfers to offices where a better knowledge of specific subjects can be acquired.  Visits on board ships of the fleet. Persons appointed to a new function shall receive clear instructions on their tasks and responsibilities and shall be followed in their work and receive a suitable support by senior personnel and the Head of Department. FRATELLI d’AMICO ARMATORI S.p:A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 9 of 21 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER 5 MANAGEMENT OF PERSONNEL 5.2.4 – Monitoring and merit rating The Company monitors the activities of its personnel. Monitoring may be resumed in the following points:  Heads of Departments appraise the work and skill of their staff during special meetings; furthermore,  every Head of Department makes a report to the General Manager or the behaviour and activities of every newly recruited person on completion of his trial period;  the General Manager assesses the work and skill of the Heads of Departments during special meetings covering their activity and SMS. Whenever a deficiency arises through the monitoring and merit rating process, the Company will provide as appropriate (training, updating, etc.). 5.2.5 – Management of Change Engagement, promotion, substitution or assignment to other tasks of key personnel of the shore staff are subject to a process of management of change, including a procedure of risk assessment (see Chapter 3, § 3.10). 5.3 SEAFARERS 5.3.1 – Engagement Engagement of all EU seafarers is carried out by the Crewing Department, while for non-EU seafarers by the Manning Agent, under the supervision of the Crewing Manager (ISO IP 03 OI 01). Seamen wishing to ship on board Company’s vessels should fill an application accompanied by their CV and copies of all their certificates and training documentation, to be examined by Crewing Manager. Data of non-EU personnel available for engagement through the Manning Agent shall be recorded in a personal file, to be also submitted to the Crewing Manager for examination. All officers, both senior and junior, are examined in accordance with the Candidate Evaluation Report (IP 03 – form 5). Data of all seafarers, both EU and non-EU, considered to be suitable for employment are inserted in the Company’s crew management database before their joining. New CO and 2Es, coming from other Companies, may be engaged only if they have gained at least a 12 months experience in that rank, with references and CV suitable for the particular type of vessel. Their joining is subject to the results of an interview by DPA, Marine Manager, Technical Manager and Crewing Manager, and to the final approval by the General Manager. Officers engaged through the Manning Agent, may be interviewed by videoconference. As a rule, Masters and CEs are chosen among the Company’s senior CO and 2Es (see § 5.3.5). If appropriate, Masters and CEs coming from other Companies can be engaged, having at least two years of experience in that rank, with suitable references and CV. Promotion or engagement of Masters and CEs are subject to the results of a series of interviews with the Heads of Company’s Crewing, Marine and Technical Departments, with the DPA and, as for Masters, with the Head of Chartering Department, to a process of management of changes (see Chapter 3, § 3.10) and to the final approval by the General Manager. Masters and CEs coming from other Companies shall attend a familiarization seminar in the shore offices before commencing their service on board. CEs engaged through the Manning Agent, may be interviewed by videoconference. In conformity with Flag State requirements (Code of Navigation – Article 292-bis), EU citizens employed as Masters on board Italian-flagged ships must have a good knowledge of the Italian language and of the current Italian maritime legislation. 5.3.1.1 - Minimum age No seafarer below 18 years old will be engaged by the Company. The master shall ensure, through the check of passports, seaman books or equivalent document, that none of the crew on board is under the age established by the Company. The date of the birth of each seafarer shall be noted down next to his name on the Crew List. If the Master identifies a seafarer under the age established by the Company, shall notify it immediately to the Crewing Dept. for his immediate signing-off. FRATELLI d’AMICO ARMATORI S.p:A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 10 of 21 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER 5 MANAGEMENT OF PERSONNEL 5.3.1.2 - Certificates of competency and training Recruited seafarers must hold the certificates of competency and special training requested for their position on board by current legislation (See Table 5.a). The Company recruits only qualified and certified personnel to carry out their duties on board according to national and international requirements (STCW). All seafarers shall not be allowed to work on a ship unless they have successfully completed training for personal safety on board ship. The Company checks for all the seafarers: a) the authenticity of their certificates; b) the validity of their certificates; c) the completeness of their certificates. The Manning Agent initially checks the originals of Indian crew certificates, a copy of them is sent to the Company on their enrolment. Copies of all certificates of seafarers are electronically filed and constantly up-to-dated by the Crewing Department. Each seafarer shall sign on board Company vessels holding all his own certification that he will handle to the master as soon as on board. The master checks the certificates of all on-signers, ensuring that they are all in course of validity and informs the Company in case of an overlooked anomaly or a missing certificate. In case a certificate is issued by a foreign Administration, the Italian Administration must issue an endorsement attesting the recognition of that certificate. Seafarers are allowed to serve on board for a period not exceeding 3 months, provided that a documentary proof of an application for an endorsement is readily available. It is the Manning Agent, under the Crewing Manager supervision, that carries out all relevant procedures at the competent Italian Consulate in order to get such an endorsement. The Company prior to the enrolment must verify that the ship’s cooks are trained, qualified and competent for the rank they cover in accordance with national regulation. In case a fully qualified cook is not present on board because of a signing off on emergency grounds, the Company must ensure that seafarers who prepare food in the galley have been trained about food and personal hygiene, as well as the handling and storage of food on board. All Seafarers shall pass a basic maritime English test. Company Crewing Department will take charge of planning English tests for EU Seafarers newly employed, while Manning Agency will take charge of testing non-EU crew. EU seafarers newly employed to serve on board the Company’s ships in particular will undergo the Basic Marlin Test. If an Officer’s Certificate of Compliance (COC) examination is undertaken in English, the basic English Language test will not be required. Certificates of competency (*) STCW P.O. Galley Special training Class Regulation Master CE CO 2E OOW EOW GMDSS Ratings Crew Others Master > 3,000 grt 1 II/2 X Chief Officer > 3,000 grt 1 II/2 X Officer of Watch > 500 grt 2 II/1 X G.O.C. IV/2 X(i) X(i) X IMO Course ECDIS - Generic X X X Model 1.27 ISM Code ECDIS - Ship specific (ii) X X X 6.3 & 6.5 Chief Engineer > 3,000 kW 1 III/2 X Second Engineer > 3,000 kW 1 III/2 X Engineer of Watch > 750 kW 2 III/1 X Rating of Watch – Deck II/5 X Rating of Watch – Engine III/5 Medical care VI/4-2 X X Advanced fire fighting (iii) VI/3 X X X X X X X X Tanker basic (paragraph1) (iv) V/1-1-1 X X X X X X X X Tanker advanced (paragraph 2) V/1-1-2 X X X X X X X(v) MARPOL Crude Oil Washing (COW) X X X X X(vi) X(vi) I/13B ISPS Code Ship Security Officer (SSO) X X X(vii) B/13 ISPS Code Training course for security awareness X for seafarers FRATELLI d’AMICO ARMATORI S.p:A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 11 of 21 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER 5 MANAGEMENT OF PERSONNEL ISPS Code Certificate of proficiency for seafarers X X X X X X X with designated security duties (*) As per OCIMF Officers matrix requirements.. (i) All three Deck Officers of the Watch when a dedicated GMDSS Officer is not carried. (ii) On-board trickle down training (i.e. one officer training another) is not acceptable. (iii) Only personnel designated to control fire-fighting operations. (iv) All personnel assigned specific duties and responsibilities related to cargo or cargo equipment. (v) Only if immediately responsible for loading, discharging, care in transit or handling of cargo. (vi) Only if taking part in COW operations. (vii) Only for 2 nd Mates if such task is not assigned to C/O. Table 5.a Additional training is requested by the Oil Majors for Masters and Deck Officers on various particular aspects of their activity on board (See table 5.b). Reference Special training OCIMF VIQ-6 Master Chief Officer Deck Officers Bridge Team Management (BTM) 3.5 X X X Ship-handling (present ship) 3.6 X(i) X (i) - A master with less than three years sea time in rank, or who has practical experience of less than thirty port entry/departures as master, must have attended a ship handling course or have sufficient practical experience. Practical experience may include training in chief officer rank under a master’s supervision, provided this is properly documented (see § 5.3.2.2(vi)). In the event that the master has in excess of ten years’ experience, this question should be answered NA. Table 5.b All navigating Officers including Master must attend refresher course on BTM / BRM every 5 years. Masters & Chief Officers must attend refresher course on Ship Handling training every 2 years. 5.3.1.3 Seafarer’s employment agreements The Company recruits its own personnel through an employment agreement as per applicable collective bargaining agreements. The Master shall ensure that each new joiner is delivered original seafarers' employment agreement (SEA) signed by both the seafarer and the ship-owner or a representative of the ship-owner that grants good working and living conditions on board the ship as required by MLC 2006; A copy of each collective bargaining agreement applied on Company’s vessels shall be available on board in order to allow the seafarers easy access to information contained in it and keep it available on competent authorities’ request. One original copy of the contract will be filed in the crewing department. The seafarers' employment agreement and any applicable collective bargaining agreement shall also be available on board in English. Master shall check and keep in custody all individual seafarers' employment agreements in the original and immediately inform the Company in case of anomaly. The seafarer's employment agreement is in compliance with National requirements and includes the following minimum information: a) seafarer's full name, date of birth or age, and birth place; b) ship-owner's name and address; c) place and date when the seafarers' employment agreement was signed; d) the rank in which the seafarer is employed; e) the amount of the seafarer's wage or, where applicable, the formula used for calculating it; f) the amount of paid annual leave or, where applicable, the formula used for calculating it; g) the termination of the agreement and the conditions thereof, including: • if the agreement is permanent, the conditions entitling both parties to terminate it, the required notice which shall be the same for the ship-owner and the seafarer; • if the agreement is a fixed term one, the expiring date; • if the agreement is for one voyage, the port of destination and the time within the agreement is to expire after the arrival in port; h) the health and social security protection benefits to be provided to the seafarer by the ship-owner; i) the seafarer's entitlement to repatriation; j) reference to the collective bargaining agreement, if applicable; k) any other particular the national law may require. At the end of contract each seafarer shall receive by Master a document / declaration containing a record of his employment on board the ship. (i e.: Seaman's Book or Certificate of Discharge). Such document shall not contain declarations in relation to quality of their work or wage. FRATELLI d’AMICO ARMATORI S.p:A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 12 of 21 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER 5 MANAGEMENT OF PERSONNEL 5.3.1.4 Number of crew (a) - Minimum Manning Certificate All Company's managed vessels are manned in accordance with the \"Minimum Safe Manning Certificate\", issued by the National Authority, under the provision of regulation V/14.2 of the International Convention for the Safety of the Life at Sea, as amended, taking into account the ship's size, service and automation degree and the Circular n. OO1 issued on 20/10/2010 in accordance with the IMO Resolution A.890 (21). Italian Administration establishes that the vessels are manned in compliance with the Law n.30/98 - Art. 2 Sub. 1 - Letter C and national requirements shall be those as provided by the above mentioned law and by Art. 318 of Italian Navigation Code. The \"Minimum Safe Manning\" of all managed ships is to be such that all crewmembers have sufficient hours of rest without a break to allow them to perform their duties safely (The hours of rest without a break are also to be in accordance with the contracts of employment and, after 1 February 1997, with STCW requirements). Before departure, the Master must personally ensure that the ship is well manned and equipped. ( Art. 297 of Italian Navigation Code); (b) - Aggregated experience In order to ensure a safe ship and cargo operations management in accordance with its SMS rules, the Company has established for its Masters and Officers minimum aggregated periods of experience, in accordance with Oil Majors' requirements (See table 5.c). Master / Chief Officer 2nd Officer / 3rd Officer Aggregated experience Chief Engineer / 2nd Engineer Junior Engineers Years with Company (calendar) 2 1 Years in rank (service) 3 1 Yeras on oil tankers (service) 6 N/A Yeras on all types of tankers (service) N/A 1.5 Note: The three types of tankers considered by OCIMF’s SIRE VPQ-6 are: Oil Tankers – Chemical Tankers – Gas Tankers. Table 5.c Were the Officers serving on board in accordance with the Minimum Manning Certificate not suited to fulfill the above conditions, as for instance, in case of promotions or new engagements, the Crewing Department shall send an additional Officer/Engineer on board, so to be able to meet the above minimum requirements. 5.3.1.5 Medical fitness All seafarers embarked on board the Company vessels must be fit to perform the duties they are employed for. In order to meet such requirement, each seafarer shall submit to medical checkup every two years as well as to pre-joining medical visit not beyond 3 days before his signing-on, 10 days for EU seafarers in case of signing on in a country different from Italy, according to the Circular issued by Foreign Ministry on 06/10/2015. Therefore, before joining, each seafarer shall have a valid two-year medical certificate, issued according to Code 1/9 of STCW ’78, ILO 147 & Regulation 1.2 of MLC 2006 as amended, and a pre-joining medical certificate according to the Navigation Code art. 323, Law 244 22/01/1934, Law 1602 28/10/1962, dal D. Lgs. 108/2005. Both medical checks are carried out by a duly qualified medical practitioner inside the facilities of Seafarers Health Care Services. The crewing department of the Company, before the signing-on of each seafarer, checks the expiring date of his two-year medical examination certificate and receive confirmation of fitness at the end of pre-joining medical visit. If the two-year medical examination certificate expires before the end of the contract of enrollment, the seafarer can obtain its renewal by a qualified medical practitioner in any port of call where she/he is available and to be valid the new certificate issued must be ratified by the Italian Consulate. Copies of all biennial medical certificates are electronically filed in the crewing dept. of the Company, while the originals of both biennial and pre-joining medical certificates are available on board. Seafarers engaged by the Manning Agent are pre-examined by doctors approved by the Flag State in accordance with Rule 4 of Merchant Shipping (Medical Examination) Rules 2000. As for screening of seafarers for drugs and alcohol, see Section 12.8 - §12.8.8.3(i). 5.3.1.6 Terms of service on board Duration of service terms on board is regulated by the national or ITF crew agreements in force. Any request for relief must be given to the Master in accordance with the above agreements and shall be immediately forwarded to the Manning Agent and to the Crewing Department. FRATELLI d’AMICO ARMATORI S.p:A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 13 of 21 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER 5 MANAGEMENT OF PERSONNEL 5.3.1.7 Probation period Newly engaged seamen are subject to the probation period stipulated by the current collective working agreements. The same rule applies to newly promoted COs and 2Es. 5.3.1.8 Crew changes Turnover of ship’s personnel is planned by the Crewing Department. Crew changes shall be organized taking into account the ship’s planned voyages. Before signing off a crew member, whose position on board is made compulsory by the minimum manning certificate, the Master must check that his relief holds all requested certificates of competency and special training. Were this not the case, the Master shall keep on board the signing off crew member and notify it immediately to the Crewing Manager and the DPA. In case of unexpected singing off of a crewmember (for instance because of bad health conditions), whose position on board is made compulsory by the minimum manning certificate, the Master shall notify it immediately to the Crewing Department and shall defer the sailing until a relief has joined the vessel. In case of absolute necessity and if the passage length and conditions allow it, the Crewing Department shall apply to the Flag State (local authority or consulate) for an exemption to the minimum manning certificate allowing the ship to sail in full safety conditions to her next port, short of a crewmember. 5.3.1.9 Masters and Senior Officers (a) - Rotation Rotation on board of Masters, CEs, COs and 2Es is planned by the Crewing Manager, taking into account Company’s demands and, as far as possible, in agreement with concerned people, always in accordance with applicable crew agreements. (b) - Briefing and De-briefing Before reaching their ships, Masters and CEs, as well as COs and 2Es, serving for the first time in such positions, shall visit the Company’s head office in order to meet the heads of Marine, Technical and Crewing Departments and the DPA. Masters shall also meet the Head of the Chartering Department and the General Manager. After leaving the ship, Masters and CEs shall be called to the Company’s head office to give a report on their period on board. Meetings shall be carried out in accordance with a special Briefing/De-briefing Checklist. 5.3.1.10 Documentation a) - Crew The following documents of all crewmembers should be kept on board in the care of the Master: • seaman discharge book; • passport (if required); • certificate of competency (endorsed for foreign seamen); • training certificates; • medical fitness certificates; • international vaccination certificate. b) - Crew changes The Crewing Dept. will keep filed, of every crew change, the following documents: • shore communication of planned changes; • ship/shore communications for any request for request, changes in program, unexpected situations; • “Crew change” form sent by the ship to confirm the change; • On-signers working agreements shall remain filed both on board and in the Company’s Crewing Department office. The following document, apart from being delivered to the crewmember, shall remain filed only on board: FRATELLI d’AMICO ARMATORI S.p:A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 14 of 21 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER 5 MANAGEMENT OF PERSONNEL • copy of discharge letters for Italian seamen signed off in foreign ports where no national consular authority exists. 5.3.2 – Training Crew training is considered to be of fundamental importance for the safety of the ship and of life at sea and for pollution prevention. An appropriate training is organized by the Company in order to inform its ship personnel and to keep them updated about: • Company’s policy in respect of safety and protection of the environment (SMS); • entry into force of new rules (laws, conventions, Class Societies standards, etc.) affecting the management and operation of ships (see chapter 6 - § 6.1). • new technologies being introduced on board. Training is carried out both ashore, by attending courses, seminaries and meetings with experts of the Company and external organizations, and on board, in accordance with the ISO IP 03 OI 01 Chapt. 3.. 5.3.2.1 Shore training Periodical training and refresher meetings between Company’s managers and staff and Masters, CEs and senior COs and 2Es are arranged in the offices. Meetings and subjects dealt with are duly recorded. Additionally, Masters and CEs take limited turns of service in the Company's offices, both for training and for standardizing to the utmost the technical management of ships. The Company selects qualified Italian training centres, entrusting them with the task of taking care of all its ships’ and shore personnel training requirements, including tailoring specific training sessions for senior Officers and key persons in view of future deliveries of new buildings with new equipment on board. Similarly, the Manning Agent provides for the shore training of the non-EU seafarers at its own training centre in Mumbai (India). In addition to the above, the Company conducts seminars for all its Officers. A formal tracking system is in place in order to proper monitor that all Officers attend Company-run seminars at least once every 2 years. In order to achieve the above requirement at least two Company-run seminars will be organized per year in Company’s premises and in Manning Agent’s premises. 5.3.2.2 On-board training The Master, the Safety Officer, the SSO and the Senior Officers shall train the personnel on the rules to be observed and the procedures to be followed for the ship’s safety and the protection of the environment. Furthermore, Senior Officers shall teach Junior Officers all necessary tasks in order to enable them to take over a higher position on board, in case of need. All crew members subject to the on-board training programme are provided by the Company with the special ISF Personal Training & Service Record Book in which all given training shall be recorded by the trainers. Basically, on-board training consists of:  direct practice on the working place;  drills;  training sessions. FRATELLI d’AMICO ARMATORI S.p:A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 15 of 21 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER 5 MANAGEMENT OF PERSONNEL (i) TRAINING ON SAFETY TASKS AND EMERGENCIES (see subsequent chapter 8). a. Safety Officer training On joining his ship, the Safety Officer, as a rule the CO (see Chapter 4 – § 4.5.2.1), shall be acquainted with her technical peculiarities and with the procedures to be followed in carrying out his task, using a special checklist. b. Crew familiarization Every new crew member shall be supplied with all his personal safety equipment and shall be familiarized as soon as possible with the basic ship’s emergency arrangements and procedures, using a special checklist. Checklists for items a. and b. of all crewmembers on board shall be kept in the Safety Familiarization file. c. Crew emergency preparedness It is assured by means of a program of drills and training sessions carried out in accordance with SOLAS 74/78 and R.S./1999 requirements, and any time it is deemed necessary by the Master. This training must be also recorded in both the statutory Drills Log Book and Fire-fighting Service Log Book (see Chapter 14 - § 14.4, items 11 & 12). (ii) TRAINING ON COMPANY’S SAFETY MANAGEMENT SYSTEM (SMS) Masters and CEs must take care of training new Officers on the rules, instructions and procedures related to their tasks and activities on board, as required by the Company’s SMS for safety and protection of the environment. As a rule, this training should be completed within 15 days from the date the new Officer joined the ship, and should be recorded in the special Joining Officers Training on Company’s SMS record book of the Deck and Engine Departments. (iii) TRAINING OF THE CREW. a. Monthly Safety Meetings A safety meeting shall be held every month by the Safety Officer, dealing with: ⇒ safety of life at sea, safety of the ship and her cargo; ⇒ protection of the environment; ⇒ correct operational procedures; ⇒ safety of working environment (see section 12.8 – § 12.8.1.6). The meetings shall be recorded in the special Monthly Safety Meeting of the Crew record book. Copy of the records shall be sent to the Crewing Department and HSEQ Department. b. VIDEOTEL programme On board ships fitted with the VIDEOTEL DVD library the relevant training programme shall be followed and properly recorded.(IV) TRAINING OF OFFICERS ON THE USE AND CHECKS OF PORTABLE INSTRUMENTS. Every month, all Deck Officers and Cadets and, on rotation, the Engine Officers and Cadets, shall practise the operation, calibration and checks of such instruments, under the direction of the CO. The training must be recorded in the special record book Use of Portable Meters – Officers Monthly Drill. (v) TRAINING OF OFFICERS FOR HIGHER POSITIONS In order to cope with unexpected situations and also to increase Officer's retention, the Master and Senior Officers shall train their subordinate Officers and teach them the basic tasks they need to know to be able to take over a higher position on board, both in case of need or in subsequent turns of service. • The Master shall train the CO in:  Ship’s handling.  Conning the vessel in special conditions (arrivals, departures, harbor steaming, rivers/canals, master-pilot relationship, etc.). • Senior Officers shall train junior Officers in:  Planning cargo operations.  On-deck cargo sampling and gauging.  Cargo calculations.  Tank washing and cleaning. The training shall be recorded in the trainee ISF Personal Training & Service Record Book (see § 5.3.5). FRATELLI d’AMICO ARMATORI S.p:A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 16 of 21 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER 5 MANAGEMENT OF PERSONNEL (vi) INSTRUCTION AND TRAINING OF DECK AND ENGINE CADETS. It is the duty of the Master and of Deck and Engine Officers to take care of the professional instruction and training of the cadets, to be recorded in their personal Flag State approved Training Record Book, as required. 5.3.3 – Officers operational familiarization The Company is well aware of the importance of employing on board its ships Officers having a good knowledge of the vessel, and it has established a familiarization program for new personnel in order to give them adequate information on the operation of all ship’s machineries and equipment. To this purpose, the following criteria should be used: (i) Every Deck and Engine Officer, of any rank, joining a ship for the first time or returning on the same ship after more than 12 months shall be provided with a Familiarization Checklist of the most important operations he must learn to carry out as soon as possible. The familiarization process shall be completed within two weeks and shall be supervised by a Senior Officer. Its final check is the responsibility of the Master or the CE. Familiarization check-list should be kept in the Deck and Engine files for at least 1 year. (ii) Whenever possible, an overlap period with the outgoing Master/CE shall be observed:  one day, in case the new Master/CE already holds an experience with that type of ship or with our Company.  two days, in case the new Master/CE has no experience with the Company and is not familiar with that type of ship. If no overlap period is possible, C/O and 2/E shall have been embarked at least one month before the joining of new Master/CE. (iii) Whenever possible, an overlap period with the signing off C/O/2/E shall be observed:  one day, in case the joining C/O/2/E already holds an experience with that type of ship and with Company SMS.  In case the joining C/O/2/E is new and has no experience with the Company SMS or is not familiar with that type of ship, the overlap period shall include a full cargo operation. If no overlap period is possible, the Master or CE shall take care of a prompt familiarization of the new C/O/2/E with his basic tasks, and shall support him during his first turn of watch or for a reasonable period of time as deemed necessary. (iv) An extended overlap period will be considered in special cases (for instance, in case of a total change of crew with personnel unfamiliar with that ship). (v) The simultaneous signing off of the Master and the CO or the CE and the 2E is not allowed as the availability of an experienced Senior Officer, both on Deck and in the Engine Room, must always be assured. (vi) The simultaneous signing off of the 2 nd Mate and the 3 Mate or the 3 Engineer and 4 Engineer is no allowed as rd th rd the availability of an experienced Junior Officer, both on Deck and in the Engine Room, must always be assured. 5.3.3.1 Masters and Chief Engineers - Handing-over Reports On leaving the ship, the Master and the CE, together with their joining colleagues, shall complete the prescribed Handing-over Report. This document has several purposes: - Firstly, to inform the relieving Master or CE of the current conditions of the ship and her equipment and machinery, as well as of the situation of his various managerial tasks, in order to familiarize him with his new assignment; - to document the acknowledgement by the new Master or CE of the vessel’s current conditions, and his acceptance of the appointment; - to supply basic elements for the Masters’ and CEs’ general appraisal process (see § 5.3.4.2(ii)); - to supply the Company, when reviewed ashore by the concerned Departments, with a short and concise report on the ship’s conditions which can be of good use in assessing her current needs and planning appropriate action. The report will be completed in two originals and jointly signed by the handing over Master or CE and his relief. One original, together with all its relevant enclosures, shall be forwarded to the appropriate Company’s Department (Marine for Masters, Technical for CEs), while the other one shall remain filed on board. The report shall be examined and discussed on the occasion of the concerned Master or CE de-briefing (see § 5.3.1.7(b)). FRATELLI d’AMICO ARMATORI S.p:A. - ROMA