Microsoft Word - - 01 - Distribution List - VII - 27.06.2016.docx

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 17 of 18 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER 8 EMERGENCY PREPAREDNESS systems some drills should be organisedoutside normal office hours. A person should be nominated to develop the scenario and setthe objectives of the drill. Objectives should include but not be limited to the following: • Notification • Staff mobilisation • Ability to operate within this procedure • Media response • Communications • Documentation 8.9.7 –EVALUATION AND REVIEW The aim of emergency drills and exercises is not just to provide training in the use of emergency equipment but also to assess the efficiency of the Company’s Emergency Preparedness. Results of onboard drills, ship-shore drills/exercises and shore drills are documented and analysed to identify lessons learnt. The effectiveness of the drills shall be formally reviewed at the onboard monthly Safety meetings. Any suggested improvements arising from these reviews shall be forwarded, as soon as possible, to the DPA for approval. The DPA should assess the results of each drill/exercise, review its effectiveness and decide on the possible identification of training needs and amendments to procedures or instructions. A thorough assessment of all these results should take place at the Management Review Committee meetings. 8.9.8 –TRAINING The DPA is responsible for ensuring that all ERT members (including deputies) are appropriately trained in handling an emergency response. In house training will be performed by DPA to all ERT members once a year. Media training shall be given to key staff in order to provide good control and consistency during a crisis. Records shall be maintained listing names of staff that have been trained or have taken part in drills. SMS REFERENCES § 8.4 Handling the media § 8.9.2 Emergency Team Ashore § 12.1 Risk Assessment Plan § 14.5 Shipboard Oil Pollution Emergency Plan (SOPEP) Vessel Response Plans (VRP) – (OPA-90 and States) Ship Security Plan SMS RECORD OF OPERATIONS § 8.9.2.4 Minutes of the Emergency Team Ashore Meetings. SMS MANUALS Annex to Chapter 6 ICS/OCIMF – Perils at Sea and Salvage – A Guide for Masters. # 112 - # 114 # 115 - #116 - # 301 - IMO – Standard Marine Communication Phrases. # 302 - # 303 ICS/OCIMF/INTERTANKO – BMP-4 BIMCO – The ShipMaster’s Security Manual. P&I Club – Rules & Correspondents (Current Year Edition). FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 18 of 18 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER 8 EMERGENCY PREPAREDNESS I.R. Salter – Business and Law for the Mariner. NI – The Mariner’s Role in Collecting Evidence. SMS CORRESPONDENCE FORMS === None SMS RULES § 6.2 RD 16.03.1942, n. 262 –Civil Code – Codice civile. RD 30.3.1942, n. 327 – Navigation Code - Codice della Navigazione. Legge 31.12.1982, n. 979 – Provision for the protection of the sea – Disposizioni per la difesa del mare. DPR 8.11.91, n. 435 – Rules for safety of navigation and human life at sea – Regolamento per la sicurezza della navigazione e della vita umana in mare. D.L.vo. 27.7.1999, n. 271 – Rules for safe working practices and health of maritime workers on board national merchant and fishing ships– Adeguamento della normativa sulla sicurezza e salute dei lavoratori marittimi a bordo delle navi mercantili [e] da pesca nazionali. SOLAS 74/78 - International Convention for the Safety of Life at Sea. MARPOL 73/78 - International Convention for the Prevention of Pollution from Ships. Annex to Chapter 6 USCG # 515 – Volume 1 – 33 CFR - Navigation and Navigable Waters. # 109 – Volume 2 – 46 CFR - Shipping. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

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 ERT PERSONNEL - Annex to Chapter 8 This annex is reprinted as necessary. It is not subject to Certifying Body (RINA) approval and its change should not be recorded in the manual's revisions checklist. CONTACT DETAILS OF ERT PERSONNEL ERT MEMBERS SUBSTITUTES / STAND-INS O.H. / A.O.H. O.H. / A.O.H. NAME POSITION TELEPHONE NUMBERS NAME POSITION TELEPHONE NUMBERS O.H. No. A.O.H. No. O.H. No. A.O.H. No. Chartering/Operations Cameli Carlo General Manager +390646713130 +39335368288 Baldini Federico +390646713141 +393346852026 Manager De Domenico Massimo DPA +390646713183 +393356495123 Incoronato Carlo Deputy DPA +390646713110 +393358756658 Chartering/Operations Valenti Anna Baldini Federico +390646713141 +393346852026 Commercial Operator +390646713132 Manager Rita Incoronato Carlo Marine Manager +390646713110 +393358756658 Mitrano Franco Marine Sup/dent +390646713173 +393295643920 De Domenico Massimo Technical Manager +390646713183 +393356495123 Di Cecca Antonio Technical Sup/dent +390646713174 +393295643523 Poggi Valeria Crew Manager +390646713129 +393346001564 Gaudino Maria Crew Operator +390646713122 +393409538002 Scala Massimo IT Manager +390646713114 +393357840654 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 9 SURVEYS AND INSPECTIONS 4. DESIGNATED PERSON(S) The responsibility and authority of the Designated Person or Persons Ashore should include monitoring the safety and pollution-prevention aspects of the operation of each ship. 9.1 FOREWORD National and international legislation and classification societies regulations require periodical and occasional surveys to be carried out on board in order to ascertain that the operational conditions of the ships are in compliance with regulations in force Further inspections are required by charterers and commercial partners, with the purpose of assessing the suitability of the ship to a specific service, her conditions of maintenance, the certification and training of the crew and the Company’s management standard. The Company too has set up its own program of inspections, in order to check the general conditions of its ships and, as far as the crew is concerned, their familiarization with assigned tasks, their operational and safety training, the compliance with the procedures detailed in the Company’s manuals. 9.2 FLAG STATE AND CLASS SURVEYS Surveys required by Flag State legislation and classification Societies regulations must be carried out in due time, so that the relevant certificates are always in regular course of validity. As far as keeping and updating the certificates lists, both on board and ashore, their expiry dates, the relevant obligations from the ships and the Company and the organization of surveys, see subsequent Chapter 14. 9.3 SAFETY INSPECTIONS 9.3.1 – Flag State Safety Survey (Visita dei servizi di bordo) Italian-flagged ships are subjected to an annual ship’s safety survey (visita dei servizi di bordo), in accordance with art. 30 of Decree 8.11.1991, no.435 – Safety Regulations. The survey is carried by the maritime authorities of any Italian port of call of the ship. In any case, the time interval between two surveys cannot exceed 15 months. On completion of the survey the maritime authority issues to the Master the relevant minutes, listing pointed-out deficiencies with conditions and times allowed for their correction, and containing a final judgement. 9.3.1(a) - Procedure to be followed The following procedure should be observed when a ship is subjected to a Flag State safety survey (visita dei servizi di bordo) in an Italian port: • The Master must:  Notify immediately the DPA that the vessel is undergoing a Flag State safety survey, even if Company's representatives (officials, superintendents, etc.) are already present on board;  as soon as received, send to the DPA a copy of the survey's minutes;  in case of deficiencies provide for their correction within the allowed time limits. In case that they represent non conformities to specific rules (SOLAS 74/78, MARPOL 73/78, STCW/95, R.S./1991, DL 271/1999), forward as soon as possible to the DPA a Non Conformity Report (see Chapter 10 - § 10.3);  insert the survey's minutes in the ship's documents file and send a copy to the Technical Department, together with an updated list of documents, to be filed ashore (see Chapter 14 - § 14.1(e)). • The DPA must:  ensure that the Master receives all necessary assistance from the concerned Company's Departments, both during survey operations and for any deficiency corrections. 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 9 SURVEYS AND INSPECTIONS  check that all deficiencies have been corrected and eliminated as required.  examine and assess jointly with the Heads of Department the non conformity report and ensure that appropriate action is taken also on board all ships of the Company's fleet, as necessary. In case the ship does not call an Italian port for a period exceeding 14 months, the safety survey shall be carried out by a committee comprising the Master, the Ch. Engineer, the Safety Officer and a crewmember, using the special questionnaire and drawing up two copies of the minutes, which shall be endorsed by an Italian consular authority. One copy shall be kept in the ship’s documents file, and the other one shall be sent to the Company’s HSEQ Department that, in turn, shall forward it to the authority of the ship’s port of registry (article 30.5 of the Regulations). Copy of the minutes shall also be sent to the Technical Department, together with an updated list of documents, to be filed ashore (see Chapter 14 - § 14.1(e)). 9.3.2 – Port State Controls (PSC) - Memorandum of Paris (PMoU) In foreign ports ships may be surveyed by the Port State authorities (Port State Controls - PSC), in order to check their safety conditions, as provided by SOLAS 74/78 - I/19 e XI/4. With a view to regulating and standardizing such surveys the maritime Countries belonging to the European Union signed the Memorandum of Understanding on Port State Control – Paris, 26.01.1982. Presently, in addition to the 22 maritime Member States of the E.U., Canada, Croatia, Iceland, Norway and the Russian Federation have joined the MOU 1982. Similar international agreements have been drawn up in various parts of the world such as, for instance, in the far East (Tokyo MoU), South America (Viña del Mar Agreement), etc. As a rule, each member State inspects the 25% of the average number of foreign ships which entered its ports during the three last calendar years for which statistics are available. On completion of the survey, the PSO Officer hands over to the Master a written report stating its outcome and listing any deficiency and the conditions and times allowed for their corrective action, in accordance with the following code: DEFICIENCY ACTION CODE: 10 deficiency rectified 18 rectify deficiency within 3 months 15 rectify deficiency at next port 30 ship detained 16 rectify deficiency within 14 days 99 other (specify in clear text). 17 rectify deficiency before departure 9.3.2(a) – Paris MoU – New Inspection Regime (NIR) On the 1 January 2011 the PMoU, in cooperation with the European Union (Directive 2009/16/EC), st introduced the New Inspection Regime (NIR) aiming at changing its target of inspecting 25% of individual ships calling at each member state to a share commitment for full coverage of inspecting all ships visiting ports and anchorages in the PMoU region as a whole. Inspection reports will be recorded on an information system Thetis hosted and managed by EMSA in Lisbon, Portugal, available for search and daily updating by PMoU member States. Ships are assigned a Ship Risk Profile (SRP) based on various criteria (type, age, flag, class, company, number of deficiencies, number of detentions): ⇒ Low Risk Ships (LRS). Assuming that all other criteria are met, this SRP is largely based on the Flag State being included in the “white list” and complying with the Voluntary IMO Member State Audit Scheme (VIMSAS). - Inspections time window: between 24-36 months after the last inspection in the PMoU region. - Subject to a 24 hours pre-arrival message (ETA24). ⇒ Standard Risk Ships (SRS). Eligible for initial and more detailed inspections. - Inspection time window: between 10-12 months after the last inspection in the PMoU region. 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 9 SURVEYS AND INSPECTIONS - Subject to a 24 hours pre-arrival message (ETA24). ⇒ High Risk Ships (HRS). Eligible for an expanded inspection. - Inspection time window: between 5-6 months after the last inspection in the PMoU region. - Subject to a 72 hours pre-arrival message (ETA72) and a 24 hours pre-arrival message (ETA24). Ship-owners have the obligation to identify the Ship Risk Profile (SRP), in order to allow their vessels to send the appropriate pre-arrival messages. The present situation of the Company’s fleet, taking into consideration all available assessment parameters, is: • 1 Aframax oil tankers class MES/Tamano: Being more than 12 years old, they are High Risk Ships (HRS). • 2 Aframax oil tankers class MES/Chiba: Being less than 12 years old, they are Standard Risk Ships (SRS). • 3 Suezmax oil tankers class SHI/Geoje: Being less than 12 years old, they are Standard Risk Ships (SRS). Pre-arrival messages (ETA72 and/or ETA24) shall be sent to the Port State authorities through the local Agents. The SRP assessment is a continuous process, as it is linked to variable factors, some of them out of the Company’s control, like Flag State and class society performance. As for the Company’s performance, it depends above all on the outcome of its ships’ PSCs, as the poor results of a single ship can affect it and, consequently, the SRP of the entire fleet. Therefore, the DPA and the HSEQ Department, will closely monitor the situation, using the appropriate tools supplied by the PMoU itself, and any variation in SRP will be immediately notified to the concerned ship(s) as well as to the top Management. 9.3.2(b) - Procedure to be followed in case of PSC The following procedure should be observed every time that a ship is subjected to a PSC in a foreign port: • The Master must:  notify immediately the DPA that the ship is undergoing a PSC, even if Company's representatives (officials, superintendents, etc.) are already present on board;  send to the DPA the report, as soon as received;  in case of the ship being detained, notify immediately the DPA and request assistance from the local office of the Classification Society (RINA);  in case of deficiencies provide for their correction within the allowed time limits. In case that hey represent non conformities to specific rules (SOLAS 74/78, MARPOL 73/78, STCW/95, IMO, EU, CFR rules, etc.) forward as soon as possible to the DPA a Non Conformity Report (see Chapter 10 - § 10.3);  insert the report in the ship's documents file and send a copy to the Technical Department, together with an updated list of documents, to be filed ashore (see Chapter 14 - § 14.1(e)). • The DPA must:  ensure that the Master receives all necessary assistance from the concerned Company's Departments, both during PSC operations and for any deficiency corrections;  in case of the ship being detained inform immediately the Administration;  check that all deficiencies have been corrected and eliminated.  assess jointly with the Heads of Department the non-conformity report and ensure that appropriate action is taken also on board all ships of the Company's fleet, as necessary.  forward by fax or e-mail to the Administration copy of all PSC reports pointing out deficiencies, even if they did not result in the ship being detained (MARICOGECAP letter 23005 dated 16.03.2009): 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 9 SURVEYS AND INSPECTIONS The following are the Administration's offices in charge of the management of PSC on board Italian- flagged ships: Headquarters of the Italian Coast Guard Comando Generale del Corpo delle Capitanerie di Porto – Guardia Costiera Department VI - Safety of Navigation / Reparto VI - Sicurezza della Navigazione Viale dell'Arte, 16 00144 ROMA Phone: +39 06 454 8921 - Fax: +39 06 965 19919 e-mail: [email protected] On the basis of the information received, the Coast Guard Headquarters may order the performance of additional audits, both on board the involved ship and all Company’s ships, and in the Company’s office. 9.3.3 - USCG Inspection (COC) Foreign flag oil tankers intending to call a port of the U.S.A. are subject to a preliminary safety inspection by the USCG, for the issuance of a special Certificate of Compliance (COC) - previously called a Tank Vessel Examination Letter (TVE). The validity of the COC is of two years, with an annual check examination. The master of a tanker bound for an U.S.A. port with no valid COC on board must notify the Officer in Charge, Marine Inspection, of the port of destination, via his local Agent, at least 7 days before arrival. This notification is in addition to any other pre-arrival notice to the USCG required by other regulations (46 CFR 153.809). PSC and ISPS inspections may also be carried out by the USCG in the occasion of a COC inspection. The information exchange procedure between the ship and the DPA in case of a COC inspection, even if announced, is the same as for the PSC inspections, as detailed in previous § 9.3.2(b). 9.4 INSPECTIONS BY CHARTERERS (VETTING) Oil Majors members of the Oil Companies International Marine Forum (OCIMF) have established a program of careful inspections for vetting the oil tankers to be used for the carriage of their cargoes, called SIRE (Ship Inspection Report Programme), linked to a data base located at the OCIMF main Office in London accessible to all participating Majors. Inspections are carried out by qualified inspectors, belonging either to the Oil Major itself or to external organizations, according to a Uniform Vessel Inspection Procedure drawn up by OCIMF, in conformity with a special Vessel Inspection Questionnaire (VIQ). In order to ascertain the ship’s operational suitability at its best, inspections are normally carried out during stays in ports of discharge. Ships chartering is subject to the approval by the various Majors. Because of the approvals limited validity, vetting inspections must be carefully planned, requesting them from the Majors well in advance. Whenever possible, the Master is assisted by a Company’s representative during vetting inspections. Because of their relevant commercial importance, planning and organizing vetting inspections is cared by the Chartering Department, in agreement with Marine, Technical and Crewing Departments and with the HSEQ Department. On completion of the vetting inspection the inspector hands over to the master a preliminary report containing his observations. The master shall send a copy of the report to the Chartering Department as soon as possible. The outcome of the inspection is notified by the Major to the Company's Chartering Department, which is granted a 14-day time limit to answer, sending its comments and informing about all measures taken to deal with any observation. Once the above time has passed, the vetting outcome, whether amended or not, will be entered in the SIRE data base. 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 9 SURVEYS AND INSPECTIONS with any observation. Once the above time has passed, the vetting outcome, whether amended or not, will be entered in the SIRE data base. Results of all vetting inspections, relevant corrective actions, communications and comments sent to the Majors, and the updated situation of approvals of the Company’s ships are regularly examined and assessed by the General Manager, the DPA and the Heads of the various Departments. The Master and the Chief Engineer shall take in due consideration the results of Vetting and Underwriters inspections in planning maintenance works and requesting spares and materials. Any deficiencies found on board during inspections shall be corrected as soon as possible. Particularly:  In case of observations pointing out non conformities to specific rules (OCIMF, SOLAS 74/78, MARPOL 73/78, STCW/95, IMO, EU, CFR rules, etc.), the Master shall forward as soon as possible to the DPA a Non Conformity Report (see Chapter 10 - § 10.3);  Any observation or technical request from the inspectors involving changes to the ship's installations and equipment, or amendments to procedures and rules prescribed by the Company's SMS, must be submitted to the Chartering Department that, jointly with the DPA and the Heads of concerned departments, will examine it and, if appropriate, will take corrective action on board all ships of the fleet, by managing the relevant change in the proper way (see Chapter 3 - § 3.10). Unauthorized changes are not allowed. 9.5 MONITORING AND ANALYSIS Monitoring and analysing results of safety and vetting inspections is carried out by means of a special procedure (IP 11) provided for by the Quality - Environmental Integrated Manual (see Chapter 1 - § 1.2). 9.6 COMPANY’S INSPECTIONS & AUDITS 9.6.1 – Foreword Within the sphere of its process of self-assessment and continuous improvement, the Company gives the utmost importance to a programme of regular inspections/audits on board the fleet vessels in order to verify technical, safety, operational and navigational conditions. Inspections should be carried out in accordance with a defined programme by Technical and Marine Superintendents holding adequate qualification and experience. Inspections and Audits outcomes (observations/non-conformities/recommendations) will be handed over and shall be discussed by the Superintend with the ship’s Master and Chief engineer. Vessel shall inform in writing the Company about the results of the corrective actions taken, using dedicated Form. Copy of the above mentioned report together with the results and the subsequent notice of corrective actions implemented on board will be maintained by the Master in the related folder. Moreover, when practicable, during navigation, Superintendents will carry out an on-board Safety Meeting; the result of the Meeting will be provided through the Form SAF 19 Safety Committee Meeting Minutes attached to the inspection/audit 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 7 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER 9 SURVEYS AND INSPECTIONS 9.6.2 - Ship & Safety Inspections (Technical Department) Ship & Safety Inspections should address following items: ⇒ HULL & SUPERSTRUCTURES ⇒ E/R MACHINERY ⇒ CARGO RELATED EQUIPMENT ⇒ DECK/MOORING/ANCHORING EQUIPMENT ⇒ FIRE FIGHTING EQUIPMENT ⇒ SAFETY EQUIPMENT ⇒ POLLUTION PREVENTION ⇒ NAVIGATION&COMMUNICATION ⇒ SECURITY ISSUES ⇒ PMS / DOCUMENTATION SYSTEM Ship & Safety Inspections (TEC 101 Vessel Inspection Report) should be carried out every 6 months ± 1 month and at least one every 12 months to be carried out during a short sail of the attending Technical Superintendents with the Vessel. These short sails are a good opportunity to observe the shipboard equipment in operation and also to promote a strong safety culture across the fleet. 9.6.3 – Navigational Audits 9.6.3.1 - Company Navigational Audits (Marine Superintendent) In order to ensure proper execution of the Navigational Procedures, check the Bridge System and the competency of the Bridge Team, the Company carry out annual real-time Navigational Audits across the fleet. The reference checklist for the above mentioned audits is HSEQ 06 Company Navigational Audit Checklist. 9.6.3.2 - Master’s Navigational Audits The Master must conducts a Navigational Audit (HSEQ 04 Master Navigational Audit) not later than one month after change over the command and one within the end of his contract to ensure that the Navigating Officers and all Officers in charge of a Navigational Watch are complying with applicable Navigational Regulations and Company’s Procedures. Master may use, at his discretion, OCIMF VIQ Ch. 4 (Navigation) for his reference. 9.6.3.3 - Third Party Navigational Audits rd For the proper execution of the SMS navigational procedures, the Company may implement 3 Party real-time Navigational Audits. 9.6.4 – Programme Inspections/Audits should be carried out:  Ship & Safety Inspections in port: every six months +/- 1 month  Ship & Safety Inspections @ sea: at least 1 every 12 months  Company Navigational Audits: at least 1 every 12 months 9.6.5 Assessing Inspections Outcome Inspections outcome and measures taken to control and eliminate any shortcomings found on board are jointly examined and discussed by the DPA and the Department Heads. If necessary, additional resources shall be assigned, existing procedures and rules shall be suitably modified and updated, and new ones shall be established as well. Relevant documentation shall be properly filed by involved Departments. 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 9 SURVEYS AND INSPECTIONS 9.7 Relevant Forms Ship & Safety Inspection TEC 101 Vessel Inspection Report Company Navigational Audit HSEQ 06 Company Navigational Audit Checklist Master Navigational Audit HSEQ 04 Master Navigational Audit Safety Meeting held on board by Company Superintendent SAF 19 Safety Committee Meeting Minutes Master Navigational Audit HSEQ 04 Master Navigational Audit HSEQ 05 ECDIS Checks for Navigational Audits 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 INCIDENTS – NON CONFORMITIES – NEAR MISSES 10 REPORTS AND ANALYSIS 9. REPORTS AND ANALYSIS OF NON-CONFORMITIES, INCIDENTS AND HAZARDOUS OCCURENCES 9.1 The SMS should include procedures ensuring that non-conformities, incidents and hazardous situations are reported to the Company, investigated and analysed with the objective of improving safety and pollution prevention. 9.2 The Company should establish procedures for the implementation of corrective action, including measures to prevent recurrence. 10.1 Generals Providing for the safe management of the vessel and of the working environment and implementing suitable protection systems against all identifiable risks are two of the main objectives of the SMS. Analysing incidents, non conformities and near misses, whether occurred on board or in any way related to the ship, may help in identifying risks, including those not immediately evident, and so improving awareness of safety and environmental protection. Every time that one of such circumstances arise, the Master shall supply as soon as possible the DPA with a report of the occurrence, using the special forms Report of Incident - Non conformity - Near miss. It is the duty of the Company to carry out an accurate analysis of the events and of all circumstances, in order to ascertain the causes and so to be able to implement corrective action and to give suitable instructions to the ship’s staff, in order to prevent the recurrence of such situations. A similar analysis shall be carried out on board, during one or more of the periodical or occasional meetings of the ship’s emergency team (see Chapter 4, § 4.8) having the event as its subject. A copy of the report shall be kept on board, in a special file, under the Master’s responsibility. 10.2 Incident The immediate notification of any incident representing one of the EMERGENCIES as defined in Chapter 8, or a THREAT TO SECURITY as defined in Chapter 12 - Section 12.7, must be carried out by the Master in accordance with the procedures detailed in the said chapters and section of this manual. • DEFINITION: An unexpected and undesirable event resulting in damage or harm to people, to environment or to property • EXAMPLES OF INCIDENT: - Collision, fire, stranding, labour incident, damage or loss of fittings and equipment, damages of cargo, pollution. As soon as possible the Master, assisted according to circumstances by the Chief Engineer, the Chief Officer and other Officers and Engineers, shall carry out an incident investigation. He shall send a report to the DPA using FORM HSEQ 03, containing a description of the events, of all relevant circumstances, the investigation results, immediate actions carried out in order to minimize damages, and all particulars that can lead to the ascertainment of the causes and to their analysis. Any pertaining document in possession of the ship shall be enclosed to the report (Logbook copies/abstracts, appraisals, survey reports, protests issued or received, repair work reports, etc.). All labour incidents, irrespective of their seriousness and outcome, shall be notified as soon as possible both to the DPA and to the Crewing Manager and the Manning Agent. Reports shall be accompanied by the required documentation, as per D.L. 271/1999 (see Section 12.8, § 12.8.1.9). A basic performance indicator of labor incidents, in accordance with OCIMF guidelines, is kept by the HSEQ (QEM), using FORM HSEQ 48 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 INCIDENTS – NON CONFORMITIES – NEAR MISSES 10 REPORTS AND ANALYSIS 10.3 Non conformity • DEFINITION: An observed situation where objective evidence indicates the non-fulfilment of a specific requirement. • EXAMPLES OF NON CONFORMITY: - Deficiencies found on board by authorities (PSC, Flag State safety and hygienic inspections, etc.) (see previous Chapter 9, § 9.3). - Infringement or non-observation of statutory and SMS rules ascertained on board by the Master. The report shall contain a description of the non conformity, of the circumstances and by whom it was found, of any immediate corrective action carried out, and of its ascertained or supposed causes. Reports of non conformities found by third parts must include all relevant documentation. 10.4 Near miss • DEFINITION: An event or circumstance which has the potential to cause personal or property damage, but did not actualize due to chance, corrective action and/or timely intervention. The report shall contain a description of the circumstances which led to the dangerous situation and those which prevented the occurrence of the incident, as well as any judgement or suggestion on how to prevent the repetition of such situations. 10.5 Company’s investigation and analysis It is essential that clear and detailed reports are received from ships whenever a hazardous occurrence happens. Master is responsible for reporting, without delay, to the DPA (or his alternate) any incident that occurs on the ship under his command. Initial notification of the incident must be forwarded to the office as soon as possible but not later than 24 hours from it occurrence if medium risk, while high risk incidents within 12 hours. The full incident report must be completed and forwarded to office within 10 days from the occurrence, or before if company require. The incident investigation will broadly in accordance to the Incident Investigation Procedures OP 01 Priority is to be given to the safety of the injured and of those assisting them and to make the immediate area as safe as possible. Record as many of the details of the incident scene including, personnel details, position of the injured, details and condition of any PPE, tools etc. likely to have been used, photos and sketches of the area should be made and any damaged equipment relevant to the incident should be retained. Once any injured personnel are removed a more detailed survey of the area may be carried out. Witnesses should be interviewed as soon as possible after the incident and statements should be prepared for signing. Prepare and compile the incident report and forward to the company including photographs, sketches and witness statements. In the case of serious incident, the DPA (or his alternate) will activate the Emergency Response Team as Capt. 8.9.2 Where appropriate a representative from the office will be sent to the vessel to conduct the investigation. The completed incident report will be reviewed and analysed by the investigation team and any corrective actions will be returned to the vessel for action and filing using Form HSEQ 03 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 INCIDENTS – NON CONFORMITIES – NEAR MISSES 10 REPORTS AND ANALYSIS On receipt of the completed form, the investigation team will then carry out a further analysis and hold a review meeting to identify root causes and recommend any relevant action. The ship will get a copy of the review meeting minutes which are to be actioned as required and filed along with a copy of the original form. 10.5.1 – Preventive measures In accordance with the results of investigation, the Head of the concerned Department shall decide about the measures to be taken to avoid the repetition of the event. Such measures may consist in supplying the ships with new spares or equipment, issuing new instructions to the ship’s or shore personnel, establishing new operational procedures or modifying the existing ones. During internal audits, the Company’s auditor shall check that all preventive measures have been actually enacted, both ashore and on board, that they are carried out by responsible personnel. 10.5.2 – Safety Notices Experience gained and lessons learnt from particularly remarkable events occurred on board ships and notified by the masters must be shared with all responsible persons of the Company’s organization, both on board and ashore. This is indeed the best way of improving people’s awareness of the various unexpected difficult situations which may arise in our activity, and so avoid the recurrence of unfortunate events. Therefore the Company’s management shall inform all its masters and ship’s officers, as well as key persons ashore, of the results and conclusions of its investigations. To this purpose, whenever deemed appropriate, a special information note, called a Safety Notice (FORM HSEQ 18), shall be issued by the Company’s HSEQ Department and sent to the masters of all ships and to the heads of the shore departments. Safety Notices are numbered in sequence, beginning each year. They are sent via e-mail as soon as issued, and shall be acknowledged by the same mean. The purpose of a Safety Notice is to disseminate useful information among the officers of the Company’s fleet and the shore personnel, in order to avoid and to prevent the occurrence and the repetition of incidents and dangerous situations. It does not intend to represent any criticism, judgement or blame for any person, however involved. Investigations of unfortunate events are carried out by the Company having in mind the superior interests and well-being of its ships and their crew and the protection of the environment, on the basis of a sound no-blame policy. On board ships, Safety Notices shall be read and discussed by the masters and their deck and engineering officers, being also the main subject of the monthly meetings of the Ship’s Emergency Team (see Chapter 4 – § 4.7), and shall be regularly used for on-board training process. They shall be kept under the control of the master in a special file. Because of their confidential nature, they must be considered as internal documents and, as a rule, shall not be exhibited to persons from outside the ship and the Company, including Flag and Port State authorities 10.6 Documentation Original reports, together with the whole documentation of the investigation and analysis process, its results, copy of any Safety Report issued, the description of adopted measures and lesson learnt, shall be filed by the HSEQ Department and, when appropriate, will be share with industry groups including professional institute and oil majors departments. The “Incident Investigation” report must be published on the OCIMF website at “Incident Area” section. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 1 of 1 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER 11 DEVELOPMENT OF PLANS FOR SHIPBOARD OPERATIONS 7. DEVELOPMENT OF PLANS FOR SHIPBOARD OPERATIONS The Company should establish procedures, plans and instructions, including checklists as appropriate, for key shipboard operations concerning the safety of the personnel, ship and protection of the environment. The various tasks should be defined and assigned to qualified personnel. 8. EMERGENCY PREPARDNESS 8.1 The Company should identify potential shipboard situations and establish procedures to respond to them. The following procedure shall be adopted for the preparation of plans for key shipboard operations (procedures, rules, directions) concerning the safety of the ship and the protection of the environment. The ship’s specific plans and procedures are not to be approved by the Flag or by the Class, but will be checked as a part of the Ship Equipment survey and are to be considered as a part of the emergency preparedness plan required by the International Safety Management (ISM) Code Part A paragraph 8 and introduced by MSC Res. 338(91). (i) The Departments Heads, when deem it necessary on the basis of: ◊ new national and international rules and regulations; ◊ news obtained from industrial organizations and specialized media; ◊ results of internal audits and inspections; ◊ results of external surveys, audits and inspections; ◊ minutes of the ship emergency team monthly meetings; ◊ analysis of accidents, non conformities and near miss reported by shipmasters; ◊ suggestions and requests of masters, chief engineers, superintendents and other qualified persons; ◊ safety of the personnel; shall develop plans for the shipboard operations for which they are in charge, and arrange for their drafting; (ii) The General manager shall evaluate and approve the new plans and appoint the relevant tasks and responsibilities to qualified persons, in accordance with the provisions of Company’s policy. (iii) New plans shall be sent to the ships in the most convenient way (circular letters, service orders, insertion in Company’s manuals). (iv) The Master shall confirm to the DPA the reception of the new plans and their implementation on board. (v) The careful correct application of the new plans on board shall be ascertained on the occasion of the subsequent internal audits and inspections. The SMS manual shall be modified accordingly, updating it as detailed in Chapter 1, § 1.3. 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 12 OPERATIONAL PROCEDURES AND INSTRUCTIONS 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 appropriate safeguards, and 3. Continuously improve safety management skills of personnel ashore and aboard ships, including preparing for emergencies related both to safety and environmental protection. 7. DEVELOPMENT OF PLANS FOR SHIPBOARD OPERATIONS The Company should establish procedures, plans and instructions, including checklists as appropriate, for key shipboard operations concerning the safety of the personnel, ship and protection of the environment. The various tasks should be defined and assigned to qualified personnel. 8. EMERGENCY PREPARDNESS 8.1 The Company should identify potential emergency shipboard situations, and establish procedures to respond to them. 12.1 - Risk Assessment and Hazard Identification A Risk Assessment system has been developed for the Company's type of ships and has been integrated with the assessment for fittings and specific activities according to the ISM Code, as amended by Resolution MSC 273(85) and to Italian Coast Guard Headquarters circular letter No. 83 dated 21.05.2010. The risk assessment system and identification of hazards guarantees the conformity of the operational procedures and instructions defined in this manual (see following § 12.2) with the ISM Code and the Administration's rules. It has been defined a “standard procedure” to permit, when required, an assessment on board for an operation/activity not considered. The risk assessment for the safety of working environment has been defined following the rules contained in the D. Lve 27.07.1999, no. 271 and its subsequent integrations. The definition of the risk-value has been obtained using the experience and analysing data of incidents included in the best practice investigations. Procedures take into account (but not limited to) • Routine and non- routine activities (ref. Chap 7.1.2) • Health & Hygiene risk where appropriate • Anticipated mooring arrangement and equipment to ensure Safety of personnel • Activities of all personnel having access to workplace (including contractors and visitors) • Human behaviour, capabilities and other factors, • Identified hazards originating outside vessel, capable of affecting the health and safety of persons onboard as well as onboard work activities which may create hazards in the vicinity of the vessel.(these may include environmental aspects) • Facilities at the workplace, whether provided by the company or others. • All other operational hazards covering safety, environmental, security impacts. The Risk Assessment system must be verified on board every 12 months to check the conformity of safety and pollution prevention procedures with the Safety Management System (SMS). The risks have been defined for: • the health and safety of all people who are directly or indirectly involved in the activity, or who may be otherwise affected; • the ship; • the environment. The Risk Assessment system has been planned in the following way: • Identification of all existing hazards; • Identification of all causes bringing hazard during the operation/activity analysed; 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 12 OPERATIONAL PROCEDURES AND INSTRUCTIONS • Identification of all prevention and control measures; • Description of all consequences for people, ships and environment, considering the mitigated measures; • Assessment of the occurrence probability, considering the mitigating measures; • Assessment of the hazard severity, considering the mitigating measures; • Assessment of the risk level as a function of occurrence probability and hazard severity. 12.1.1 - The Risk Assessment Plan. A Risk Assessment Plan, both in paper and electronic form, is available both on board and in the Company's shore offices. It should be used in the following way (as per enclosed instructions): 1) Risk Assessment templates are provided for the majority of work activities carried out onboard as stated in the index. 2) Choose the relevant template from DECK and ENGINE sheets, fill in and achieved on board. 3) Review each of the hazards and fill the relevant \"Existing Control Measures\" cells if such measures are already implemented on the vessel. Work permits provided by the Permit to work system (see Section 12.8 - § 12.8.12.3) are themselves existing control measures. 4) Additional control measures, if identified for the given hazard, can be added at the bottom of the \"Existing Control Measures\" cells of the relevant hazard. 5) Fill the \"Probability (P)\" and \"Hazard Severity (S)\" box taking into account the existing control measures. 6) Additional hazards, if identified, can be added at the bottom of the HAZARD ANALYSIS OF THE INTENDED ACTIVITY form. 7) If the risk level assessed is HIGH, VERY HIGH or EXTREMELY HIGH, mitigation is necessary, as per corresponding \"Action\" rating, and additional control measures must be implemented. Such measures shall be recorded in the cells of the relevant hazards. 8) If the risk level is MEDIUM, monitoring is required to insure control is maintained, and additional checks may be anyhow carried out, in order to ascertain if the risk level can be further reduced at reasonable cost and with little effort. Appropriate references to the Risk Assessment Plan are contained in this manual, as necessary. 12.2 - Operational Procedures and Instructions. In this chapter, the Company supplies its shore personnel and the masters, officers and crew of its ships with appropriate instructions and procedures to be followed in order to enable them to carry out their tasks in an effective way and in safe conditions. The chapter is subdivided in the following sections: 12.1 Foreword – Implications of commercial decisions in terms of safety 12.2.1 Sailing – Navigation bridge 12.2.2 Sailing – GMDSS 12.2.3 Sailing – Engine room 12.3 Protection of the environment 12.4 Cargo operations 12.5 Ship in port 12.6 Preparing for sailing 12.7 Ship’s Security 12.8 Safety of working environment and health of the crew. Procedures and instructions frequently refer to regulations, conventions, IMO resolutions, rules issued by classification societies and maritime and oil industry organizations, available in the ships and offices SMS library or in other locations as detailed in this manual, for instruction, technical support and prompt reference for all personnel. 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 Section OPERATIONAL PROCEDURES AND INSTRUCTIONS 12.1 FOREWORD – IMPLICATION OF COMMERCIAL DECISIONS IN TERMS OF SAFETY 7. DEVELOPMENT OF PLANS FOR SHIPBOARD OPERATIONS The Company should establish procedures, plans and instructions, including checklists as appropriate, for key shipboard operationsconcerning the safety of the personnel, ship and protection of the environment. The various tasks should be defined and assigned to qualified personnel. Procedures and operational instructions contained in Chapter 12 – Sections 12.2 ÷ 12.8 – are given as guidance only and do not intend to cover all shipboard situations and activities. They are based on national and international codes of practice, guidelines and publications, and are supplemented both by mandatory pubblications and manuals required by laws (see Chapters 6 & 14) and by those provided by the Company’s SMS (see Chapter 15, § 15.2). These procedures and instructions point out those aspects of the operation of the ships that the Company deems necessary to bring to the attention of the crew. This choice is not to be considered as an underestimate of other operational aspects of the ship that the Company assumes are well known to the crew. Their contents do not restrict in any way the Master's authority to take such steps and issue such orders, whether or not they are in accordance with the contents of the above-mentioned procedures and instructions, considered necessary for the preservation of life, the safety of the ship and the protection of the environment. In particular, emergency procedures are recommended only if applicable and feasible. 12.1.1 Implication of commercial decisions in terms of safety Due consideration must always be given to the implications that commercial decisions may have in terms of safety, ship’s operation and pollution prevention. Particularly, unless commercially managed by a Pool or employed on time-charter, the Chartering Department must always ascertain that ships charterparties clearly state that: ◊ the intended voyage(s) must be along the normal traffic routes, within the navigation limits requested by underwriters (Institute Warranty Clauses); ◊ the Master has the maximum liberty in planning and carrying-out the passages; ◊ ports and berths must be clearly declared as safe and reacheable by the ship always afloat; ◊ the ship must be able to carry the stipulated cargo in safe conditions, on a draft never exceeding her maximum load line for the most restrictive of the seasonal areas she will sail through, in accordance with Convention LL 66/88; ◊ the cargo must be such that it can be loaded and stowed on board so that the ship always respects the hull stress and stability conditions requested by her loading manuals approved by the Administration or the classification Societies; ◊ cargoes to be loaded must be lawful; ◊ the Shippers shall supply the Master and/or the Company’s Chartering Department with the appropriate cargo informations, on the time and in the ways provided by SOLAS 74/78 – VI/2 & 5.1. In case of special demands (cargo, ship’s performances, operational area, etc.), before supplying the Master with the voyage orders, the Chartering Department shall consult the Technical, Marine and Insurance Departments, and the HSEQ Departments. 12.1.2 Reviewing Voyage Instructions The Chartering and Operation Manager is responsible to ensure that voyage orders and requirements for specific voyage have been communicated and understood by the Master and it is also followed step by step throughout the voyage except when vessel in Commercial Management Pool in which case he will have a role of control over these very same obligations that are delegated to the Pool Voyage Manager. The Chartering and Operation Manager upon receiving Charterer’s Voyage Orders will check them to ensure that they comply with C/P requirements where applicable and with Company’s and vessel’s procedure as per the Company’s Management System’s 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 Section OPERATIONAL PROCEDURES AND INSTRUCTIONS 12.1 FOREWORD – IMPLICATION OF COMMERCIAL DECISIONS IN TERMS OF SAFETY The Chartering and Operations Manager will promptly forward the Voyage Orders and his eventual variations/observations to the Technical, Marine and HSEQ Managers for their review who will communicate in writing their agreement or their observations. In case of arising issues for further consideration, a special meeting may be organized in order to address and resolve them. Upon completion of the above process, the voyage orders are forwarded to the General Manager, for his final review and approval, before being communicated to the vessel. The Voyage Orders Review will be forwarded to the Master by the Chartering and Operations Manager complemented with additional guidance to the Master, when this is considered appropriate. The Master will be alerted and his eventual feedback required, if necessary, in matters of, but not limited to, routing, under keel clearance, cargo tank preparation, cargo tank vapour management, emergency notification and exchange of information related to port terminal specific environmental requirements The Master will confirm safe receipt and full understanding. In case of Voyage Orders being received also by the vessel from the Time Charterers or the Commercial Operators, the Master will wait for the final approval as above. In case of any arising difficulty to comply, or in case of further clarifications are needed, the Master is instructed to contact immediately the Chartering and Operation Manager for further instructions and guidance. The Master is also expected to consider the voyage orders from his end; in case of any notified discrepancy between the orders and the established Company’s procedures, or in case of existence of physical restrictions to comply, he should immediately notify the Chartering and Operations department for further instructions. It is worth mentioning that the Master is not authorized to ignore or to deviate from the voyage orders by own initiative (except in case of emergency), but he should always communicate his comments to the Office, in order the Operations department to revert with feasible guidance. Same as above practice of reviewing is carried out each time voyage order updates are received. As per the Company’s established practices, the General Manager and the Technical, Marine and HSEQ Managers are always reachable by e-mail and phone during nights, weekends and holidays. Local orders SHOULD NOT be followed unless prior approval by the Chartering and Operations Manager, the Commercial Operator or the Time Charter Operator is obtained. The voyage orders are the definitive instructions. In case of information or instructions given from anyone (even if it appears to be from the Charterers directly) that contradicts these orders, the Chartering and Operations Manager should be always contacted your for verification. The Master shall never accept to load a cargo whose carriage is not allowed by the ship’s certificates. 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 SECTION 12.2.1 SAILING – NAVIGATION BRIDGE 12.2.1.1 GENERAL RULES Rules governing sailing and bridge team organization on board the ships of the Company’s fleet are contained in the publication BRIDGE MANAGEMENT MANUAL (BMM) drawn up and published in accordance with the requirements of STCW Code – Section B-VIII/2 – Part 3.1 and of 33 CFR 157.415. 12.2.1.2 CONTENT OF THE MANUAL P PART I – BRIDGE TEAM & SERVICE ORGANIZATION - 1 – MASTER’S NAVIGATIONAL RESPONSIBILITIES 1 -- 1.1 – Instruction 1 -- 1.2 – Bridge Organization 1 -- 1.3 – Monitoring Navigational Practices 1 -- 1.4 – Attendance On The Bridge 2 -- 1.5 – Navigational Briefings 2 -- 1.6 – The Navigational Watch 3 -- 1.7 – Re-assessment Of Manning Levels 6 -- 1.8 – Company manning requirements during manoeuvring 6 -- 1.9 – Compliance with COLREGS 6 -- 1.10 – Watch Shifts 6 -- 1.11 – Sole Lookout 7 -- 1.12 – New Personnel and Familiarization 7 -- 1.13 – Fire / Safety Rounds 7 -- 1.14 – Relieving the Watch 7 -- 1.15 – Look out during the watch 8 -- 1.16 – The Officer leaving the bridge 9 -- 1.17 – Recording Watch Condition 9 -- 1.18 – Identifying the Conning Officer 9 -- 1.19 – Distractions on the Bridge 9 -- 1.20 – Use of Mobile Phones on Bridge 9 - 2 – SAILING IN SPECIAL CONDITIONS 10 -- 2.1 – Heavy weather 10 -- 2.1.1 – Heavy-weather ballast in oil cargo tanks 10 -- 2.2 – Navigation in Restricted visibility 11 -- 2.3 – Freezing temperatures – Ice 11 -- 2.3.1 – Ice accumulation on ships 11 -- 2.3.2 – Ice Reports – Safety Messages 12 -- 2.3.3 – Ice navigation 12 -- 2.4 – Ballast Water Exchange at Sea 12 - 3 – NAVIGATING OFFICER 12 - 4 – TESTS AND CHECKS BEFORE DEPARTURE AND ARRIVAL 12 - 5 – MASTER/PILOT INFORMATIONS EXCHANGE 13 -- 6 – WRITTEN ORDERS TO THE OFFICER OF THE WATCH 13 -- 6.1 – Standing orders 13 -- 6.1.1 – Company’s standing orders 13 -- 6.1.2 – Master’s standing orders 13 -- 6.1.3 – Daily orders 13 - - 7 – SUPPLY OF ENCS AND PUBBLICATIONS 13 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 SECTION 12.2.1 SAILING – NAVIGATION BRIDGE -- 7.1 – Updating publications 13 -- 7.1.1 – Admiralty Information Overlay (AIO) 14 -- 7.1.2 – Electronic charts 14 -- 8 – BRIDGE EQUIPMENT 14 -- 8.1 – Nautical equipment and instruments 14 -- 8.1.1 – Compass 14 -- 8.1.2 – Course Recorder 15 -- 8.1.3 – Echosounder 15 -- 8.1.4 – Radar 15 -- 8.1.4.1 – ARPA 16 -- 8.1.5 – ECDIS 16 -- 8.1.5(i) – Training requirements 16 -- 8.1.5(ii) – Ships equipped with a double ECDIS 17 -- 8.1.5(iii) – Sailing by ECDIS 17 -- 8.1.6 – GPS 17 -- 8.1.7 – AIS 17 -- 8.1.7.1 – Use of AIS in collision avoidance situations 18 -- 8.1.8 – LRIT 18 -- 8.1.9 – BNWAS 18 -- 8.1.10 – VDR 18 -- 8.1.11 – Use of Electronic Navigation Aids 19 -- 8.2 – Operation of steering gear 19 -- 8.3 – GMDSS 19 -- 8.3.1 – Secrecy of communications 19 -- 8.4 – Oil Tankers - Use of bridge equipment in port 19 -- 8.5 – Bridge equipment breakdown 20 - 9 – KEEPING NAVIGATION LOGBOOK 20 - 10 – PLACARDS 21 - 11 – EMERGENCY PREPAREDNESS 21 -- 11.1 – General Emergency 21 -- 11.2 – Pollution and Risk of Pollution 21 -- 11.3 – Breakdowns and Shipboard Emergency Situations 22 -- 11.4 – Assistance and Salvage 22 - 12 – REFERENCE PUBLICATIONS 23 PART II – VOYAGE PLANNING 24 - 1 – PLANNING 24 -- 1.1 – Responsibilities 25 -- 1.2 – Notes on Passage Planning 25 -- 1.3 – Appraisal 25 -- 1.4 – Charts and Publications 25 -- 1.5 – Passage Plan using ECDIS 25 -- 1.6 – Passage Planning in Open Waters 27 -- 1.7 – Passage Planning in Coastal / Restricted Waters 28 -- 1.8 – Monitoring the route plan 28 -- 1.9 – Visual Monitoring Techniques 28 -- 1.10 – Radar Monitoring Techniques 29 -- 1.11 – Distance Off 29 -- 1.12 – Minimum Under Keel Clearance (UKC) 29 -- 1.13 – Deep contour 30 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 SECTION 12.2.1 SAILING – NAVIGATION BRIDGE -- 1.14 – Safety contour 30 -- 1.15 – Shallow depth / Shallow contour 30 -- 1.16 – Safety depth 30 -- 1.17 – Safety height 31 -- 1.18 – LOOK – AHEAD FUNCTION 31 -- 1.19 – Safety channel width ( XTD Corridor) 32 -- 1.20 – Minimum Safety Setting 32 -- 1.21 – Airdraft – Overhead Clearance (OC) 32 -- 1.22 – Employing a Pilot 33 -- 1.23 – Traffic Separation Schemes (TSS) 33 -- 1.24 – SAR Reporting Systems 33 -- 1.25 – Vessel Traffic Services(VTS) 33 -- 1.26 – Protection of the marine environment 33 -- 1.27 – Fuel distance 34 -- 1.28 – Pilotage 34 PART III – WATCHKEEPING RULES 40 - 1 – GENERAL RULES 41 -- 1.2 – Safe Speed 41 -- 1.3 – Deviation from or leaving the passage plan 41 -- 1.4 – Position Fixing 41 - 2 – DUTIES AND TASKS OF THE OFFICER OF THE WATCH 43 -- 2.1 – Underway 43 -- 2.1.1 – Using automatic steering systems 44 -- 2.1.2 – Radio communications 44 -- 2.1.3 – Sailing in UMS conditions 45 -- 2.2 – Sailing with a pilot on board 45 -- 2.3 – Ship at anchor 45 - 3 – CALLING THE MASTER 46 PART IV – ANCHORING PROCEDURES 47 - 1 – PRIOR TO ANCHORING 47 - 2 – DEPARTURE FROM ANCHORAGE 47 - 3 – DRIFTING 48 OFFICERS CHECKLIST 49-53 Appendix A STCW 2011 – STCW Code: Chapter VIII - Standards regarding watch-keeping – Sections A-VIII/1 - A-VIII/2 & B-VIII/1 - B-VIII/2 [abridged]. Appendix B MCA – MGN 379 (M+F) – Navigation: Use of Electronic Navigation Aids. Appendix C UKHO – AVCS User Guide. Appendix D IMO Resolution A.893(21) – Guidelines for voyage Planning. Appendix E Squat & UKC Appendix F OCIMF - ICS - INTERTANKO – Internatonal Best Practices for Maritime Pilotage. Appendix G Company’s placards related to the bridge team & service organization and performance, posted on the navigation bridge. Appendix H Company’s Check-lists and Forms in use on the navigation bridge. 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 SECTION 12.2.1 SAILING – NAVIGATION BRIDGE 12.2.1.3 UPDATING THE MANUAL The manual is updated as necessary by means of subsequent amendments, numbered in sequence, sent on board in attachment to special HSE circular letters. They are applied by the well known system of pasting a correction slip on the affected page, and a numbered recording tag, with date and signature, inside the front cover. Important and/or extensive changes are applied by publishing a new edition of the manual. SMS PROCEDURES § 12.2.1.1 BRIDGE MANAGEMENT MANUAL (BMM). BMM - I/1 Placard – Bridge Team Organization. BMM - I/4 Placard – Tests and Checks Before Departure and Arrival. BMM - I/6.2 Master’s Orders Book. BMM - I/8.2 Placard – Guidance on Steering Gear Test Routines (ICS). BMM - I/8.3 Placard – Notice on the correct Use of VHF Channels (ICS). BMM - I/8.4 Placard – Use of radioelectrical equipment during cargo operations and while the ship is berthed or in vicinity of an oil dock. § 14.5(b) Wheelhouse Poster. Table of Emergency Steering Change-over Procedures. Life Saving Signals Placard. § 12.1 Risk Assessment Plan. SMS ENCs AND PUBLICATIONS § 6.4.1 ENC and Publications for trading area. RASTER Navigational Charts (RNC): – UKHO Admiralty Raster Charts Service (ARCS). Electronic Navigational Charts (ENCs): – UKHO Admiralty Vectorial Charts Service (AVCS). IMO - International Regulations for Preventing Collisions at Sea (COLREG 72). IMO – Ship’s Routeing. IMO – International Code of Signals. IMO/ICAO – International Aeronautical and Maritime Search & Rescue Manual (IAMSAR) – Volume III. M.I.T. – ARES Manual. ICS/OCIMF – Bridge Procedures Guide. Annex to Chapter 6 NI – Bridge Team Management. # 111.B - # 114 IMO – Standard Marine Communications Phrases (SMCP). 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 SECTION 12.2.1 SAILING – NAVIGATION BRIDGE SMS RECORD OF OPERATIONS § 14.4 General and Accounting Logbook – Giornale Nautico - Libro II. Navigation Logbook – Giornale Nautico - Libro III. Drills Record Book – Giornale delle Esercitazioni. § 6.4.1 Compass Record Book. Chronometer Rate Book. AIO Notices file. Pilot cards and navigation bridge checklist file. Passage plans file. SafetyNET and NAVTEX MSI files. Weather reports and meteorological chartlets file. BMM - III/2.1 Radar Logbook. BMM - III/2.1.2 Bridge VHF Logbook. SMS CORRESPONDENCE § 13.4 Departure message. Position message. Arrival message. § 15.3 COPY – General and Accounting Logbook – Giornale Nautico - Libro II. ABSTRACT – Navigation Logbook – Giornale Nautico - Libro III. SMS RULES § 6.2 DPR 8.11.91, n. 435 – Rules for safety of navigation and human life at sea – Regolamento per la sicurezza della navigazione e della vita umana in mare. D.L.vo. 27.7.1999, n. 271 – Rules for safe working practices and health of maritime workers on board national merchant and fishing ships – Adegua- mento della normativa sulla sicurezza e salute dei lavoratori marittimi a bordo delle navi mercantili [e] da pesca nazionali. SOLAS 74/78 - International Convention for the Safety of Life at Sea – as amended. STCW – International Convention on Standards of Training, Certification and Watchkeeping for Seafarers, 1978/2011. Annex to Chapter 6 USCG # 515 = Volume 1-2 – 33 CFR - Navigation and Navigable Waters. # 109 # 109A 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 SECTION 12.2.1 SAILING – NAVIGATION BRIDGE 12.2.1.4 GENERAL RULES FOR ECDIS Rules governing ECDIS navigation information system on board the ships of the Com- pany’s fleet are contained in the ECDIS PROCEDURES MANUAL drawn up and pub- lished in accordance with the following requirements: • SOLAS Chapter V • IMO MSC.1/Circ.1503 “ECDIS – Guidance for Good Practice” • IMO Circ.207 'Differences between RCDS and ECDIS' • IMO Circ.255 'Additional guidance on chart datum and accuracy of position on charts' • IMO Circ.276 'Transitioning from paper chart to ECDIS' • IMO Circular SN 255 “Additional guidance on chart datums and the accuracy of po- sitions on charts” • IMO Circular SN.1/Circ.266 \"Maintenance of ECDIS software\" • IMO Resolution A.285 (VIII) - Recommendation on Basic Principles and Opera- tional Guidance Relating to Navigational Watchkeeping • IMO Resolution A.817 (19) 'Performance standards for ECDIS' as amended by MSC 64(67) & MSC 86(70) • IMO Resolution A.893 (21) 'Guidelines For Voyage Planning', • IMO Resolution MSC. 232 (82) 'Performance standards for ECDIS' • IMO Resolution MSC. 282 (86) 'Adoption of Amendments to SOLAS – ECDIS' • International Chamber of Shipping (2007), Bridge Procedures Guide UKHO (2011), NP 231 Admiralty Guide to the Practical Use of ENCs • Latest IHO’s and IEC’s Standards • STCW Code (2010), Part A, Chapter VIII - Watchkeeping (Part 4.1 Principles to be Observed in Keeping a Navigational Watch) 12.2.1.5 CONTENT OF THE MANUAL LIST OF CONTENTS 1 PART I - Introduction 2 PART II - Objectives 2 PART III - Approval 2 SECTION 1 THE OPERATION OF ELECTRONIC CHARTS 3 -- 1.1 - Types of Electronic Charts 3 -- 1.2 - Limitation of ECDIS 8 -- 1.3 - Alarms and indications 12 -- 1.4 - Symbols & information display 17 -- 1.5 - Back-up 19 -- 1.6 - Main components of ECDIS 19 -- 1.7 - Standard ECDIS functions 21 -- 1.8 - Operating ECDIS 21 -- 1.9 - ECDIS safety 22 -- 1.10 - ECDIS failure 22 -- 1.11 - Emergency procedures 26 -- 1.12 - Using ECDIS with other instruments 27 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 SECTION 12.2.1 SAILING – NAVIGATION BRIDGE -- 1.13 - Possible problems. 29 -- 1.14 - Passage planning 31 -- 1.15 - Precautions against Virus 38 -- 1.16 - Training of Navigating Officers 38 -- 1.17 - Licensing 42 -- 1.18 - Electronic Chart correction 43 -- 1.19 - PMS 46 Officers Checklist = As soon as a Deck Officer joins the vessel, he must look over this publication and carefully read its parts I, II, III and section 1 then sign the checklist, with date, rank and name. Appendix 1 = Implementation schedule of IMO ECDIS requirements. Appendix 2 = Facts about Electronic Charts and carriage requirements. Appendix 3 = Flag State ECDIS requirements. Appendix 4 = Ship Specific Equipment manufacturer User Manual. Appendix 5 = ECDIS on board training record; Onboard familiariation checklist. Appendix 6 = IHO ENC / ECDIS Data presentation test. Appendix 7 = Legislation, Standards and IMO Resolutions. Appendix 8 = ECDIS Contingency Plan. 12.2.1.6 Access to the VDR information The ship owner will have access in any circumstances and any time to the VDR and its information. The Master or any other crew shall not disclose any information of VDR to any other party other than the owner.The Company has introduced random unannounced analysis of VDR data to assess bridge navigation standards across the fleet and to identify weak areas and training needs. 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 SECTION 12.2.2 SAILING – GMDSS 12.2.2.1 General rules GMDSS service is regulated by: ◊ SOLAS 74/78 – Chapter IV; ◊ ITU – Manual for use by the Maritime Mobile and Maritime Mobile-Satellite Services (available at ship’s GMDSS station). ◊ STCW IV/2 ◊ D.L. 27.07.1999, no.271. See also Chapter 13 – Communications. The following information must be clearly and permanently displayed at the radio installation (GMDSS console): • Vessel’s international Call Sign, MMSI and INMARSAT C ship-station identity. • Instructions for operating the digital selective calling (DSC) and satellite communications equipment in an emergency. 12.2.2.2 GMDSS-responsible Officer The duty of GMDSS-responsible Officer is normally carried out by a dedicated Officer holding a General Operator Certificate (GOC). When a dedicated Officer is not carried, the radio communications service is performed by the three Deck Officer of the Watch holding a GOC whose presence on board is compulsory in such a case. One of them, so appointed by the Master in writing, is entrusted with the duty of GMDSS-responsible Officer. As for communications necessary to the normal operational and commercial management of the ship, see following Chapter 13. All operations pertaining to the service should be recorded in the GMDSS Logbook. For the purposes of safety, the GMDSS-responsible Officer must personally take care of the follow- ing tasks: a) Handling distress communications Handling all distress, urgency and safety communications and radio traffic under the orders of the Master. b) Operations to be carried out on arrival, on sailing and during passage: (i) On arriving in port: ◊ send the arrival message to the Company; ◊ make sure that the equipment necessary for the automatic reception of navigational warnings and weather reports (NAVTEX, EGC SafetyNET) are properly set for their regular operation during the forseen stay of the ship; ◊ switch off the RTF SSB MF/HF transmitter, which shall be restarted only after sailing (see Section 12.4, § 12.4.2.1). (ii) Before sailing: ◊ make sure that all GMDSS equipment are in good working order and that batteries are properly charged; ◊ collect, record and make available to the Officer of the Watch the latest weather reports and naviga- tional warnings for the sea areas the ship will sail, received during her stay in port. Gale or dangerous condition warnings must be handed over personally to the Master. 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 SECTION 12.2.2 SAILING – GMDSS (iii) On sailing from a port: ◊ start the DSC MF/HF and VHF receivers and set all GMDSS equipments for their proper working at sea; ◊ send the required ARES/INI message; ◊ send any sailing messages required by other traffic control systems (AMVER, SISTRAM, etc.), ac- cording to Master’s instructions; ◊ send the sailing message to the Company. (iv) At sea: ◊ check regularly the good working conditions of the GMDSS equipment; ◊ check that the GMDSS service is regularly carried out when performed by the Deck Officers of the Watch; ◊ hand over to the Officer of the Watch, as soon as received, all weather reports and navigational warnings for the sea area the ship is sailing; ◊ notify immediately the Master of any distress, urgence and safety message received; ◊ send the required ARES/INT or ARES/MOD messages; ◊ send any position or deviation messages required by other traffic control systems (AMVER, SISTRAM, etc.); ◊ send the position messages to the Company; c) Additional tasks. (i) On joining the ship, or when appointed as responsible Officer by the Master: ◊ he should make sure of the availability of all publications, technical manuals, spare parts, tools and measuring instruments for the radio equipment, as listed in the special inventory; ◊ he should complete, together with the outgoing GMDSS-responsible Officer, the handing-over record, as requested by the Radio Company, on which he shall enter any deficiency or difference. The record shall be signed by the Master for acknowledgement; ◊ he should ask the Master for the next voyage details. (ii) Periodical tests and checks: ◊ Both at sea and in port, the Officer should carry out and record the technical tests and checks as detailed in the GMDSS Logbook. (iii) Maintenance: (a) The GMDSS-responsible Officer shall regularly check the good working order of all equipment. (b) The ship’s Electrician is in charge of the maintenance of GMDSS batteries, at CE’s orders. The Electrician must regularly check their conditions of charge as per PMS. (c) The GMDSS-responsible Officer shall notify immediately the Master of any abnormal condition of the radio communications equipment. (d) Technical assistance shall be requested well in advance through the Marine Department. The fol- lowing shall be recorded: ◊ place and date the assistance has been rendered; ◊ repaired or calibrated equipment; ◊ spare parts used. Assistance reports shall be filed on board; a copy shall be sent to the Marine Department as soon as possible (see Chapter 7, § 7.4.4 and 7.4.5). FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

sued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 1 of 10 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18) as amended – ISM Code SECTION 12.2.3 SAILING – ENGINE ROOM 12.2.3.1 GENERAL RULES Watch and duty service in the machinery space are regulated by: ◊ STCW 95 – A-VIII/1 and A-VIII/2 - Part 3-2; ◊ D.L. 27.07.1999, no. 271. Activities in the machinery space (engine room, steering gear compartment, workshops) are subject to the risk assessment process (see Chapter 12 and the Risk Assessment Plan). 12.2.3.2 TESTS AND CHECKS TO BE CARRIED OUT BEFORE DEPARTURE AND ARRIVAL Tests and checks to be carried out within 12 hours before departure and arrival, as required by RS/1991 - art. 229-230, SOLAS 74/78 - V/26 and 33 CFR 164,25, are listed in the placard posted in the engine control room and on the navigation bridge. They shall be recorded in the Engine Log. In carrying out the preliminary tests and checks, the following checklists should be used: • Engine Room Pre-departure Check-list • Engine Room Pre arrival Check-list • Steering Gear Check-list to remain filed on board in suitable folders. 12.2.3.3 TASKS OF THE ENGINEERING OFFICER DURING THE WATCH The following paragraphs lay down the rules to be followed by the Engineers of the Watch in the circumstances to be normally espected during sailing. (i) - Chief Engineer’s written orders Appropriate orders are issued in writing by the Chief Engineer so that, in his absence, the Engineer of the Watch, or on duty, has no doubts on his responsabilities and how to act:  Standing orders should be entered in the proper space at the end of the Company’s publication Watchkeeping & Duty Service Rules and Chief Engineer’s Standing Orders, always available in the Engine Control Room. On joining the ship, new Engineers shall read them carefully and sign their special checklist for acknowledgement.  Night orders, issued daily by the Chief Engineer both for the night time and for his periods of absence from the engine room shall be entered, with date, time and signature, in the engine room daily log. On taking over the watch, or duty service, every Engineer shall read the night orders and acknowledge them by his signature. (ii) - Watch shifts Watch shifts are based on the “four and eight” criteria (four hours of service and eight hours of rest): 1. – Second Engineer: 04.00/08.00 – 16.00/20.00 2. – Third Engineer: 00.00/04.00 – 12.00/16.00 3. – Fourth Engineer: 08.00/12.00 – 20.00/24.00. (iii) - General tasks 1. The Engineer of the Watch acts on behalf and under the authority of the Chief Engineer. He is fully responsible for the operation of the propulsion system and of all machineries affecting the safety of the vessel. He must ensure that orders from the navigation bridge relevant to changes of propeller’s RPM and rotation way are immediately executed. 2. The Engineer of the Watch shall arrange for regular tours of inspection of the engine room and the steering gear compartment, in order to check and report any machinery malfunction or abnormal condition. 3. The Engineer of the Watch remains responsible for all operations in the engine room even in the presence of the Chief Engineer, unless officialy notified by him that he is personally taking such responsibility for himself. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

sued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 2 of 10 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18) as amended – ISM Code SECTION 12.2.3 SAILING – ENGINE ROOM (iv) - Taking over the watch 1. The incoming Engineer should make sure that his watch personnel are all fully fit for their tasks. 2. The outgoing Engineer shall not hand over the watch to the incoming Engineer if he has any reason to believe that the latter is not able to perform effectively his tasks. In such a case he shall immediately notify the Chief Engineer. The outgoing Engineer should advise his incoming collegue of: ◊ Chief Engineer’s orders and special instructions about the machinery and ship’s systems operation (See previous point (i)). ◊ repairs being carried out of machinery and systems, and their potentials risks. (v) - Informations to the navigation bridge The Engineeer of the Watch must immediately notify the navigation bridge of any abnormal condition or failure which could cause a reduction of the ship’s speed, a loss of steering or the stopping of the main engine, and of any problem in power generation or any other similar threat to the ship’s safety . Whenever possible, such informations should be given before the situation deteriorates, so to allow the navigation bridge as much time as possible to be able to implement an appropriate action for the prevention of a potential accident. vi) - Sailing in restricted visibility or other difficult conditions The Engineer of the Watch shall start a standing-by power generator and connect it to the main switchboard, so that an adequate power reserve is always available in case of a failure of one of the in- service generators. He shall make sure that enough pressure to the ship’s whistle is always available. He must keep himself ready to execute immediately whatever orders received from the navigation bridge. (vii) - Calling the Chief Engineer 1. The Engineer of the watch shall act immediately for the safety of the ship, of the machinery and of the crew, and to protect the marine environment, whenever circumstances so require. While in charge of a watch, no Engineer may be assigned to, neither may he begin, any other task or activity which could interfere with his responsibility of supervising the operation of ship’s machinery. 2. The Engineer of the watch must immediately notify the Chief Engineer in the following cases: ◊ the occurrance of any malfunction or failure of the machinery in the engine room and the steering gear compartment; ◊ in case of an emergency on board; ◊ for any doubt on how to act. (viii) - Machinery and equipment maintenance during the watch The Engineer of the watch shall collaborate with others Engineers in charge of maintenance or repair works, having always in mind what has been said under the previous point (vii). This may include, but not necessarily be limited, to : ◊ isolate and by-pass the part being worked on, and adjust the system so that it remains safely and properly in working conditions during the maintenance period; ◊ testing and restarting, if necessary, the repaired part or machinery. (ix) - Records Machinery working data and all operations pertaining to the machinery space service should be recorded in: - ENGINE LOG (GIORNALE DI MACCHINA) statutory logbook (See Chapter 14, § 14.3). - Company’s ENGINE LOGBOOK. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

sued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 3 of 10 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18) as amended – ISM Code SECTION 12.2.3 SAILING – ENGINE ROOM 12.2.3.4 SAILING IN UNMANNED MACHINERY SPACE (UMS) CONDITIONS Times of beginning and ending of UMS conditions should be recorded in the Engine Log and notified to the navigation bridge, in order to enter them in the Navigation Log. (i) - Duty Engineer The Chief Engineer shall establish inspection shifts, to be assigned to Officers duly certified to be in charge of an engineering watch and as duty engineers in an UMS. Duty Engineer shall be provided an appropriate uninterrupted period of rest. (ii) - Before leaving the machinery space unattended 1. The Duty Engineer shall carry out an accurate check of all machinery and of the whole engine room, using the special UMS Check-list, to be kept filed on board in a suitable folder. 2. The Duty Engineer shall check that the Dead Man safety system is set to a maximum working interval of no more than 15 minutes. 3 The identity of the Duty Engineer shall be notified to the Officer of the Watch on the navigation bridge. (iii) - While the machinery space remains unattended 1. In case of an alarm, the Duty Engineer shall ascertain its causes and take proper action, while resettting the signal as soon as possible. 2. Unless he is escorted, the Duty Engineer shall activate the Dead Man system as soon as he enters the engine room. In case its safety confirmation signal is not received on the navigation bridge at regular intervals of no more than 15 minutes, the Officer of the Watch shall immediately inform the Master. 3. In case it risults to be impossible to contact the Duty Engineer, persisting an alarm on the navigation bridge, the Officer of the Watch shall immediately inform the Master. 4. Duty Engineer shall immediately notify the Chief Engineer of any abnormal condition. (iv) - Sailing in situations demanding special caution – Special operations UMS condition is not allowed and the engine room shall be permanently attended by regular shifts of watch when sailing in situations demanding special caution. Particularly when:  Manoveuring for departure, arrival, shifting, mooring and unmooring;  Sailing rivers and canals;  Sailing Safety Fairways established by a Coastal State;  Sailing among or in vicinity of offshore installations (oil/gas rigs, platforms, pipelines, etc.);  Sailing in ice or heavy weather;  Sailing in narrow channels and fairways (COLREGS/9);  Sailing in or near areas of restricted visibility (COLREGS/19);  When the ship is restricted in her ability to manoeuvre (COLREGS/27) or is constrained by her draft (COLREGS/28);  When the ship is adrift;  Whenever so deemed necessary by the Master in order to ensure the safety of navigation. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

sued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 4 of 10 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18) as amended – ISM Code SECTION 12.2.3 SAILING – ENGINE ROOM The Master shall notify the Chief Engineer of the above situations as much in advance as possible. Furthermore, the machinery space shall be manned whenever the following operations are being performed:  Oil cargo-related operations (discharging, on-board transfer, tank washing, gasfreeing, inerting, etc), alongside, at sea berth, SPM, FSU terminals, and at anchor or underway (See Section 12.4, § 12.4.5 & 12.4.6);  Oil cargo-related operations (loading), at sea berth, SPM, FSU terminals, and at anchor or underway (See Section 12.4, § 12.4.5 & 12.4.6);  STS cargo transfer, both at anchor and underway (See Section 12.4, § 12.4.5.10);  Ballast operations (exchanging ballast at sea, loading heavy weather ballast) both at anchor or underway (See Section 12.4, § 12.4.7);  Bunkering, both alongside and at anchor by barge (See § 12.2.3.9.3). 12.2.3.5 OPERATION OF BILGE WATER SEPARATOR - OVERBOARD DISCHARGE VALVES Before starting the separator:  The alarm and automatic stopping device must be preliminary tested for good working conditions.  The Officer of the Watch on the navigation bridge must be notified, as per the special notice permanently posted both in the Engine Control Room and near the separator.  The above facts must be duly recorded in the statutory Engine Log (Giornale di Macchina). Whenever the Bilge Water Separator cannot be used (e.g. in port):  The overboard discharge valve must be closed. Positive evidence against any unauthorized or accidental opening must be provided by a numbered seal, the number of which can be verified in the statutory Engine Log (Giornale di Macchina) and in the Oil Record Book – Part I (Code I) where it must be recorded (see IMO MEPC.1/Circ.736 dated 08.11.2010 – Examples # 26-27). Such a method of sealing must be easily breakable to allow the valve to be opened in an emergency. Chains and padlocks are absolutely not admitted (see IMO MSC- MEPC.4/Circ.3 dated 19.12.2008).  Additionally, all overboard sealed discharge valves must be provided with a notice warning against unauthorized or accidental opening, stating that they may be opened only in an emergency by specific order of the Chief Engineer.  Any other valve (suction or discharge) of the bilge pumping and draining system the Chief Engineer deems appropriate or necessary to be kept closed must equally be sealed against accidental or unauthorized opening. 12.2.3.6 SAFETY PROCEDURES IN MACHINERY SPACE a) Maintenance works of the main engine while at anchor Maintenance works of the main engine while the ship is at anchor must be carried out in perfectly safe conditions, and shall always be athorized by the Port or Coastal State authorities. The following procedure applies: 1. The Chief Engineer should request Master’s authorization to carry out the work, giving its reasons. 2. The Master shall notify the Company’s Technical Department and obtain their assent; 3. The Master shall request the authorization to carry out the maintenance work from the local Authorities, following the required general rules. 4. Once obtained the authorization, the Master shall give his approval to the maintenance work, on the basis of a risk-assessment which shall take in due consideration particularly : ◊ settled good weather conditions for the time necessary to perform the work; ◊ availability of reliable weather reports; ◊ anchorage position: open waters or protected roadstead; ◊ suitable holding ground (depth of water and sea-bottom nature); FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

sued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 5 of 10 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18) as amended – ISM Code SECTION 12.2.3 SAILING – ENGINE ROOM ◊ prompt availability of the second anchor and of both windlasses; 5. The duration of work shall not exceed the time interval between two subsequent weather reports unless, in case of necessity, the work can be interrupted and the main engine brought back in operation in less than 30 minutes. b) Restarting critical equipment Written procedures, specific to the particular ship, are redily available in the engine room, supplying guidance on how to restart critical equipment. Particularly:  Regain power from the emergency to the main switchboard.  Charge the air receivers for the main diesel generators. Restart main diesel generators in order to provide electrical power to auxiliaries.  Restart all auxiliaries.  Restart the main engine and boiler. c) Isolation of Fire Zones Whenever, for technical reasons, it becomes necessary to isolate (deactivate) one or more of the “Fire Zones” of the fixed fire detection and alarm system, both in the machinery space and elsewhere on board, the following procedure must be observed:  Fire zones may be isolated from the navigation bridge control unit only upon request of the Chief Engineer, in his capacity of responsible Officer for all fixed fire-fighting equipment, and shall be authorized by the Master.  Isolation must be recorded in the Company’s Engine Logbook (Brogliaccio di Macchina), identifying the affected zones and detailing the times of beginning and completion. All entries must be signed by the Chief Engineer.  Personnel involved must be made aware of the duration and reasons of the isolation.  Isolated zones must be covered by regular fire patrols.  Special warnings must be posted at the system control panel on the navigation bridge and in the isolated zone(s) (tags FIREZONEWARNING1 and FIREZONEWARNING2).  The machinery space should not be operated unmanned with any zone in the space isolated. It must be borne in mind that, even if a single fire zone in the machinery space becomes accidentally or voluntarily inactive, the IAQ/UMS notation on the ship’s Certificate of Class becomes invalid and a full Engineering Watch must be kept. In this case, an appropriate entry must be made both in the statutory Engine Log and in the Master’s Log (GN/2).  Special placards FIRE DETECTION AND ALARM SYSTEM detailing the above procedure are permanently posted at the system control panel on the navigation bridge, in the ship’s fire station and in the Engine Control Room. d) Emergency preparedness In case of an accident causing, or posing a threat of, pollution, procedures provided for by SOPEP and VRP must be activated (see Chapter 8.6). The Emergency and Special Conditions Checklists file (see Chapter 8.7) is available in the Engine Control Room. 12.2.3.7 SAFETY CONDITIONS IN MACHINERY SPACE As for the safety of the working environment in the machinery space, particularly for: - precautions in the storage and use of chemicals, - precautions in using and handling welding gas, - personal protective equipment (PPE), - prevention of labour accidents, - work permits system, see Section 12.8 of this manual. Some basic precautions to be observed: FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

sued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 6 of 10 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18) as amended – ISM Code SECTION 12.2.3 SAILING – ENGINE ROOM  Escape routes must be marked by the special IMO symbols (green).  Machinery moving parts must be properly shielded.  Isolating footboards or floors must be placed in way of electrical switchboards and panels.  Cocks of glass-tube level indicators must be kept shut.  Double bottom tanks sounding pipes must be kept closed by means of their weighted covers.  Materials and spares must be kept in their special racks and properly secured.  Bilges must be clean and dry.  No leaks or traces of oily or greasy materials.  No oily rags or waste. 12.2.3.8 PROCEDURE TO AVOID SPARK FROM THE FUNNEL The danger arising from particles of incandescent soot being discharged from the funnel can be minimised by operation of the soot blowers on a routine basis at sea and also by operating the soot blowers as close before entering port as permissible. Soot blowing should preferably be carried out when there is sufficient load on the boiler to ensure a good uptake gas flow, in order to carry the deposits clear of the funnel. To avoid sparks from the funnel especially in port, ensure that carbon particles and un-burnt fuel particles are minimized in the pipe stacks. Dry soot has a high ignition temperature, and hence rarely catches fire. Once soot becomes wet, its ignition temperature drops significantly, and it burns very easily. This is why one can see sparks from funnel after Exhaust Gas Boiler has been water-washed, or after heavy rains during port stay. The sparks are caused by burning of wet soot particles. - Soot blow to be carried out once a day for Aux. Boiler and twice a day for the Exhaust Gas Boiler. Note: excessive soot blowing by means of steam might cause erosion damage on the generating bank. - Ensure that the funnel sparks arrest are regularly inspected and maintained always in good condition. - Aux. Boiler burners to be maintained in good condition to ensure good combustion and smoke sides of Aux. Boilers and Exhaust Gas Boilers to be maintained clean by regular water washings or air/steam cleaning as instructed by the boiler maker. - Avoid washing of the Exhaust Gas Boiler In port. lf this cannot be avoided ensure that a very thorough cleaning using copious amounts of water and ensuring that the Exhaust Gas Boiler is thoroughly cleaned before being put into use. After washing, run the boiler water circulating pump. This will cause a lot of soot to fall into the casing bottom, which must be cleaned before departure. - Ensure proper soot blowing of the Exhaust Gas Boiler and Aux. Boiler, before entering port. - Water washing using HP must be avoid. - Before to proceed with water washing make sure that the drain is not clogged - Maintain the Aux. Boiler on continuous firing mode if possible. - Maintain all internal combustion engines in good condition and carry out regular performance check on the engines to ensure optimum combustion. - Avoid unnecessary starting of the Auxiliary engines. - On every occasion before soot blowing, the bridge should be informed so that a watch can be kept on possible funnel sparking which has been the cause of several incidents of fire on the aft poop deck. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

sued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 7 of 10 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18) as amended – ISM Code SECTION 12.2.3 SAILING – ENGINE ROOM 12.2.3.9 INFORMATIONS EXCHANGE BETWEEN MASTER AND CHIEF EGINEER The exchange of the following informations, detailed in Table 12.2.3.a, being necessary for the correct operation of the ship, should be made in writing. When Master → Chief Engineer Chief Engineer → Master End of departure ◊ Local time at stand-by engine (SBE) ◊ Fuel ROB at EFA. manoeuvre (Engine ◊ Local time and UTC at EFA. ◊ Fresh Water ROB at EFA. Full Away = EFA). Beginning of Sea ◊ Departure manoeuvre: Miles run and time ◊ Fuel lifted in port. used. Passage (BSP). ◊ Fresh Water supplied in port. ◊ Voyage mileage and ETA at destination port. At sea, every day at ◊ UTC time. ◊ Average RPM from previous noon or from 12:00 hrs. local time ◊ Position. EFA. (Noon). ◊ Miles run from previous noon or from EFA, ◊ Slip. time used and avarage speed. ◊ Fuel consumptions from previous noon or ◊ Total miles run, time used and general speed. from EFA. ◊ Sea and weather conditions during previous ◊ Fuel ROB at noon. day. ◊ Fresh Water ROB at noon. ◊ Remaining mileage and updated ETA to destination port. End of Sea Passage ◊ Local time and UTC at SBE. ◊ Average RPM from previous noon. (ESP). ◊ Miles run from previous noon, time used and ◊ Slip. Beginning arrival avarage speed. ◊ Fuel consumptions from previous noon. manoeuvre (Stand by ◊ Voyage total miles run, time used and general Engine = SBE). ◊ Fuel ROB at SBE. speed. ◊ Sea and weather conditions from previous noon. Table 12.2.3.a See also Chapter 13, paragraph 13.4 – Routine messages. 12.2.3.10 FUEL OIL 12.2.3.10.1 Air pollution prevention As for the restrictions on the use of fuel oils required by current international regulations in order to reduce the release into the athmosphere of pollutants contained in the ships' exhaust gas, see Section 12.3 - § 12.3.5.2. 12.2.3.10.2 MSDS for Fuel Oil SOLAS 74/78 - VI/5-1 requires that all ships shall be provided with a material safety data sheet (MSDS) for oil used as fuel, in the IMO-recommended format as detailed in resolution MSC.286(86), prior to the loading of such fuel oil on board (see also Section 12.8 - § 12.8.9.1). The following procedure shall be followed every time that the ship is supplied with fuel oil:  the Chief Engineer should request from the bunkering installation (terminal or barge) an MSDS in the IMO-recommended format issued by the Supplier for each grade of fuel oil to be taken, prior to commence refuelling operations;  the MSDS(s) so obtained should be filed together with the relevant BDN and should be used on board in the prescribed way as long as the relevant fuel oil has not been completely consumed;  if an MSDS is not provided, or it is not in the recommended format, the Chief Engineer should immediately inform the Master who, in turn, should note a protest, either directly or through the Chartering Department of the Company or the brokers, and record the facts in the log book (Giornale Nautico - Libro II) to help avoid potential problems with PSC. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

sued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 8 of 10 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18) as amended – ISM Code SECTION 12.2.3 SAILING – ENGINE ROOM As regards the requirements of MARPOL 73/78 – Annex VI - Regulations 14 and 18, as to the quality of the replenished fuel, its sampling and the keeping on board of all relevant documentation and samples, see Section 12.3 – § 12.3.5.5. 12.2.3.10 (2a) Hazards in connection with the use of residual heavy fuel oil Residual Heavy Fuel Oil (not distilled), when replenished and used on board, must always be considered potentially dangerous and capable of producing light hydrocarbons in the tanks headspace, such that their vapours could render them explosive or contain toxic gas (H2S). Precautions and safety measures to be observed in using such fuel oil are contained in the OCIMF publication ISGOTT – 5th edition 2006 – Chapter 2, § 2.7 12.2.3.10.3 Bunkering procedures Bunkering of fuel or bulk lubricating oil proce-dures are detailed in the Company’s publication Oil Transfer Procedures (Bunkering). Useful information on bunkering operations are contained in Chapter 25 of OCIMF publication ISGOTT – 5th edition 2006 (see Chapter 6 – Appendix). Planning of bunkering operations should include the following: - Determining that there is adequate space for the volume of bunker to be loaded. - Unused bunker connections are blanked and fully bolted. - Extablishing maximum loading volume for all tanks. - Controls for the setting of bunker system valves. - Determining loading rates for the start of loading, bulk loading and topping-off. - Arrangements of bunker tank ventilation. - Internal tank overflow arrangements. - Verification of gauging system operation and accuracy. - Alarm setting on overfill alarm units. - Communication with the terminal/barge to establish when bunkering can be undertaken. - Method of determining the temperature of the bunker during loading. - Communication procedure for the operation, including emergency stop. - Manning requirements to execute the operation safely. - Monitoring of the bunkering operation and checking it conforms to the agreed procedure. - Changing over tanks during loading. - Containment arrangements and clean-up equipment to be available. - Continuous sampling kit has been correctly fitted to the connection in use. - Thermometers are fitted to the connection in use and temperature of bunker will be checked at regular intervals. - Testing procedures for determining the presence of hydrocarbon or H2S vapours. - Methods of managing the handling of bunkers which have or may have hydrogen sulphide (H2S) content. Specifically, all persons assigned to operations must, in this case:  Wear a personal gas monitor.  Be equipped with an EEBD. The following forms shall be used in planning bunkering operations and carrying out the preliminary safety checks [see ISGOTT/2006 – 25.4]: ⇒ Bunkering Operations Planning: It should be completed and signed by the Chief Engineer before starting operations, entering all the required data. When bunkering takes place simultaneously with cargo operations, its data shall also be included and reckoned in the cargo operations plan ⇒ Bunkering Safety Checklist : It should be completed in all its parts and signed by the Chief Engineer before starting operations. Items coded R (Re-check) must be regularly re-checked at appropriate intervals, as agreed between both parties. Repetitive checks shall be recorded in the checklist itself. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

sued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 9 of 10 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18) as amended – ISM Code SECTION 12.2.3 SAILING – ENGINE ROOM It should be borne in mind that, in all U.S.A. ports, in accordance with 33 CFR 156.150 requirements, a special Declaration of Inspection must be jointly completed by the ship and the barge or terminal in addition to the ISGOTT checklist. The above documents should remain conspicuously posted on board throughout bunkering operations, to be eventually filed by the Chief Engineer in the bunkering file. The Declaration of Inspection must be kept filed on board at U.S.C.G. disposal, for at least three months. Bunkering of fuel and bulk lubricating oils must be recorded in the Oil Record Book – Part I: Machinery space operations, as required by MARPOL 73/78 – Annex I – Regulation 17 and in the Engine Room Log Book. 12.2.3.11 TRANSFERRING BILGE WATERS AND OILY RESIDUES TO THE CARGO SLOP TANKS All ships are fitted with a special piping system for transferring bilge water and oily residues from the engine room to the cargo slop tanks. The system is approved and is recorded in the Form B attached to the IOPP certificate. The content of the bilge and sludge tanks may be transferred to the dirty slop tank whenever it contains waters and oily residues resulting from cargo tanks washing operations, or when such operations have been planned. The following procedures must be always observed:  Transfer operations must be agreed in advance between the Chief Engineer and the Chief Officer, with Master approval;  water and residues to be transferred must not contain any kind of chemicals, par-ticularly emulsifying agents;  Chief Engineer and Chief Officer shall jointly collect samples of waters and residues to be transferred. Such samples, duly sealed and counter-signed, must be kept on board in the care of the Chief Engineer for at least three months;  The Chief Engineer shall enter the transfer operation in the Oil Record Book – Part I.  The Chief Officer shall enter the transfer operation in the Oil Record Book – Part II.  The subsequent disposal of bilge water and oily residues transferred from the engine room shall be entered by the Chief Officer in the Oil Record Book – Part II. Disposal of bilge water and oily residues must be carried out in full compliance with all applicable national and international rules in force (see Section 12.3 - § 12.3.2). 12.2.3.12 POTABLE WATER 12.2.3.12.1 Freshwater loading and supply arrangements  Freshwater from low pressure evaporator or reverse osmosis should in general only be produced when the vessel is at least 20 miles from land or remote from any risk of estuarial pollution which in some sea areas can extend well in excess of 20 miles from land. The sea water suction to evaporators or reverse osmosis plants should be separate from other sea suctions e.g. machinery cooling water inlets, fire pump suctions, etc., and sited forward and on the opposite side of the ship from sanitary or bilge discharges.  Freshwater obtained from shore mains supply or water barge should be transferred by a hose exclusively used for that purpose.  Freshwater tanks should be coated internally with anti-corrosive materials which have been specially developed for fresh water tanks and will not contaminate the water. When modern epoxy coating systems are used, it is essential that the coatings are applied and allowed to cure strictly in accordance with the manufacturer's instructions. The manufacturer's advice on filling, flushing and emptying freshwater tanks before these are connected to the distribution system should also be strictly adhered to.  All potable water taken from shore should be chlorinated on loading to a sufficient concentration to ensure a residual free chlorine content of at least 0.2 ppm (0.2 mg/l). This concentration may be achieved by dosing in accordance with the guidelines contained in the International Medical Guide for Ships (See Chapter 6 – Appendix - # 201). Water produced on FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

sued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 10 of 10 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18) as amended – ISM Code SECTION 12.2.3 SAILING – ENGINE ROOM board should be treated by automatic chlorination or electrolytic silver ion release systems. Chlorine systems must provide a residual free chlorine content between 0.2 ppm and 0.5 ppm (0.2-0.5 mg/l). Silver ion concentration should be between 0.1 ppm and 0.8 ppm silver.  Freshwater tanks should be opened up, emptied, ventilated and inspected at intervals not exceeding 6 months and be thoroughly cleaned, re-coated as necessary, aired and refilled with clean disinfected freshwater. This operation should be recorded in the ship's logbook. Anyone entering any potable or washing water tank should wear clean clothing and footwear, and should not be suffering from skin infections, diarrhoea or any communicable disease.  In compliance with Law 16.06.1939, no.1045, Italian-flagged ships should carry a Freshwater Tanks Certificate issued by Port Health Authorities upon an inspection to be carried out every 6 months (See following Chapter 14, § 14.3, item 30). This certificate can be obtained only in Italian ports.  Potable water should be checked in accordante with the ship’s HACCP System requirements (See Section 12.8, § 12.8.5.2.1).  Flag State and local regulations covering the testing of domestic water by a competent laboratory should be complied with.  If the water is found to be contaminated, the storage tank should be filled to capacity and chlorine solution added to give a 50 ppm chlorine concentration (50 mg/l). The water should be allowed to stand for 4 hours and then the entire contents of the tank should be dumped.The tank may then be re-filled with disinfected water.  Test kits are available for on-board testing, both for residual chlorine and silver ion concentrations. Test must be carried out every 6 months (PMS) and report to be sent to Marine Department. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 1 of 17 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.3 PROTECTION OF THE ENVIRONMENT INDEX 12.3.1 Identification of pollutants and applicable rules 12.3.2 Oil - MARPOL 73/78 - Annex I - 12.3.2.1 Machinery space: Oil residues and bilge waters - 12.3.2.2 Cargo zone on tankers: Oil residues and oily mixtures – Heavy weather ballast - 12.3.2.3 Special Areas -- 12.3.2.4(a) Bunker and oil cargo transfer -- 12.3.2.4(b) Ship-to ship (STS) operations -- 12.3.2.4(c) Ballast transfer -- 12.3.2.5 Special requirements for the use or carriage of oils in the Antarctic special area 12.3.3 Sewage - MARPOL 73/78 - Annex IV 12.3.4 Garbage - MARPOL 73/78 - Annex V - 12.3.4.1 Definitions - 12.3.4.2 General prohibition on discharge of garbage into the sea - 12.3.4.3 Exceptions - 12.3.4.4 Placards, garbage management plan and garbage record-keeping - 12.3.4.5 Discharge provisions - 12.3.4.6 Ship’s garbage receptacles (IMO – USDA) 12.3.5 Air pollution - MARPOL 73/78 - Annex VI - 12.3.5.1 Ozone depleting substances - 12.3.5.2 Exhaust gas -- 12.3.5.2(a) Nitrogen oxides -- 12.3.5.2(b) Sulphur oxides -- 12.3.5.2(c) Changing fuel grade - 12.3.5.3 Gas from oil tankers cargo tanks -- 12.3.5.3(a) Volatile organic compounds (VOC) -- 12.3.5.3(b) Toxic gas - 12.3.5.4 Shipboard incinerators - 12.3.5.5 Fuel oil quality - 12.3.5.6 Annex VI Company’s manual 12.3.6 Disposal of ship-generated waste and cargo residues in the EU waters - Directive 2000/59/EC - 12.3.6.1 Procedure 12.3.7 Ballast water control and management - IMO Resolution A.868(20) 12.3.8 Anti-fouling paints - Regulation (EC) No.782/2003 12.3.9 Discharges incidental to the normal operation of vessels - U.S.A. EPA VGP 18.12.2008 12.3.10 Special waste - 12.3.10.1 Medicines - 12.3.10.2 Electrical/electronic appliances & materials - 12.3.10.3 Coatings & Chemicals - 12.3.10.4 Cooking oil 12.3.11 Protection of endangered species - 12.3.11.1 Passage planning: Areas to be avoided - 12.3.11.2 Convention CITES 73/79 12.3.12 Company’s commitment - 12.3.12.1 Waste reduction - 12.3.12.2 Energy conservation - 12.3.12.3 Surveillance and Measurement Plan - 12.3.12.4 New environmental technologies FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 2 of 17 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.3 PROTECTION OF THE ENVIRONMENT 12.3.1 – IDENTIFICATION OF POLLUTANTS AND APPLICABLE RULES POLLUTANTS RULES Oils:  MARPOL 73/78 – Annex I. - Oil residues and bilge waters from the en-  Law. 31.12.1982, n. 979 – Provision for the protec- gine room. tion of the sea – Disposizioni per la difesa del - Oil residues and oily mixtures from the mare. cargo zone.  D.L. 6.11.07, n. 202 - Accomplishment of directive - Heavy ballast water from cargo tanks. 2005/35/CE relevant to pollution by ships and con- sequent sanctions – Attuazione della direttiva 2005/35/CE relativa all’inquinamento provocato dalle navi e conseguenti sanzioni..  Directive 2000/59/EC. Sewage  MARPOL 73/78 – Annex IV.  Directive 2000/59/EC. Garbage  MARPOL 73/78 – Annex V.  Directive 2000/59/EC. Air pollutants:  MARPOL 73/78 – Annex VI. - Ozone depleting substances.  Directive 2005/33/EC. - Exhaust gas  California Air Resource Board (CARB) Marine - Gas from oil tankers cargo tanks. Notice 2009-2. - Gas from shipboard incinerators. Biological pollutants:  IMO Resolution A.868(20). - Aquatic micro-organisms in ballast water. Anti-fouling paints:  Regulation (CE) No.782/2003 (International Con- - Organotin (TNT) compounds. vention AFS 2001) Operational discharges  U.S.A. ECA VGP 18.12.2008 - Discharges incidental to the normal opera- tion of vessels Special waste: - Expired medicines  Ministry of Health Circular n.17 dated 20.07.1994. - Discarded/expired electrical/electronic  Company’s procedure. appliances & materials. - Coatings & Chemicals. - Cooking oil. Table 12.3.a Special rules and restrictions may be imposed by Port and Coastal States (including the European Union) to all ships staying in, or sailing through, waters subject to their control. It is the responsibility of the master to collect all necessary informations on such rules. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 3 of 17 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.3 PROTECTION OF THE ENVIRONMENT 12.3.2 – OIL - MARPOL 74/78 - ANNEX I Conformity of the vessel to the rules of the Convention are certified by the International Oil Pollu- tion Prevention Certificate (IOPP) issued by RINA on behalf of the Administration, which must be carried by all ships (see Chapter 14 - 14.3). All ships (oil tankers >150 DWT and all vessels >400 DWT) must carry an Oil Record Book - Part I – Machinery spaces operations (see Chapter 14 - §14.4) on which all operations involving oil resi- dues, polluted waters or waters liable to be polluted by fuels and lubricants used on board must be recorded as detailed in MEPC.1/Circ.736/Rev.2 dated 6 October 2011, available on board. Useful advices on the correct compilation of the record book are also contained in the INTERTANKO publication A guide for the correct entries in the Oil Record Book – Part I, available on board all ships (see Annex to chapter 6 - # 105). All entries must be signed by the responsible Officers and countersigned by the CE. Every completed page must be finally endorsed by the Master. All oil tankers (>150 DWT) must carry an Oil Record Book - Part II – Cargo/ballast operations (see Chapter 14, § 14.4) on which all operations involving cargo and polluted waters or waters liable to be polluted by the cargo (i.e. loading, internal transfer and discharging oil cargo; loading and discharging heavy weather ballast into cargo tanks; washing of cargo tanks, including COW; discharging water from slop tanks; disposal of oil residues; conditions of ODME; accidental discharges of oil) must be recorded. All entries must be made and signed by the Chief Officer, as responsible person for cargo operations. Every completed page must be finally endorsed by the Master. The Master must notify the DPA in due time of any necessity of discharging oil residues or oily waters to shore reception facilities. 12.3.2.1 – Machinery space: Oil residues and bilge waters (Regulation 15) Outside Special Areas, oil residues and oily mixtures from the machinery space may be dis- charged at sea only if the ship is en route and the oil content of the effluent does not exceed 15 ppm., through a filtering system satisfying the requirements of regulation 14, as defined in IOPP Certificate – Supplement B, item 2. Inside Special Areas, oil residues and oily mixtures from the machinery space may be discharged at sea only if the ship is en route and the oil content of the effluent does not exceed 15 ppm., through a filtering system fitted with an alarm system and an automatic stopping device satisfying the require- ments of regulation 14.7, as defined in IOPP Certificate – Supplement B, item 2.2.2. Lacking such char- acteristics, any discharge into the sea is prohibited and oil residues and oily mixtures must be retained on board, to be delivered to shore reception facilities. As for the incineration of oil residues (SLUDGE) see the subseguent paragraph 12.3.5.4. 12.3.2.2 – Cargo zone on tankers: Oil residues and oily mixtures - Heavy weather ballast (Regulation 34) Outside Special Areas, oil residues and oily mixtures from the cargo zone on oil tankers (cargo and slop tanks, pump-room) and heavy weather water ballast loaded into cargo tanks may be dis- charged at sea through an approved ODME, only if the ship is en route at a distance of not less than 50 sea miles from the nearest land, if the instantaneous rate of discharge of oil content does not exceed 30 litres per sea mile, and if the total quantity of oil discharged at sea is less than 1/30,000 of the total quantity of the particular cargo of which the residue formed a part. Inside Special Areas, any discharge into the sea is prohibited. Oily mixtures from cargo zone must be collected on board, to be delivered to the shore reception facilities. 12.3.2.3 – Special Areas (Regulation 1.11) Special Areas in which discharge at sea of oil residues or oily mixtures is regulated or prohibited, are: • The Mediterranean Sea. • The Baltic Sea, including the Skagerrak and the gulfs of Bothnia and Finland. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 4 of 17 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.3 PROTECTION OF THE ENVIRONMENT • The Black Sea. • The Red Sea, including the gulfs of Suez and Aqaba. • The Gulfs Area (Gulf of Oman and Arabian/Persian Gulf). • The Gulf of Aden. • The Antarctic area, South of 60°S. • The North-West European Waters. • The Southern South African Waters. 12.3.2.4(a) – Bunker and oil cargo transfer [Company’s procedures] See Section 12.2.3, § 12.2.3.9.3 and Section 12.4, § 12.4.5.4. 12.3.2.4(b) – Ship-to-ship (STS) Operations (Regulation 8.41) See following Section 12.4, § 12.4.5.10 12.3.2.4(c) – Ballast transfer [Company’s procedures] See following Section 12.4, § 12.4.7. 12.3.2.5 – Special requirements for the use or carriage of oils in the Antarctic Special Area (Regulation 9.43) 1 With the exception of vessels engaged in securing the safety of ships or in a search and rescue operation, the carriage in bulk as cargo or carriage and use as fuel of the following grades: .1 - crude oils having a density at 15°C higher than 900 kg/m3; .2 - oils, other than crude oils, having a density at 15°C higher than 900 kg/m3 or a kinematic viscosity at 50°C higher than 180 mm2/s; or .3 - bitumen, tar and their emulsions, shall be prohibited in the Antarctic area, as defined in Annex I, regulation 1.11.7. 2 When prior operations have included the carriage or use of oils listed in paragraphs 1.1 to 1.3 of this regulation, the cleaning or flushing of tanks or pipelines is not required. As for the disposal of cargo residues and oily waters in the sea areas of the European Union, see the subseguent paragraph 12.3.6. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 5 of 17 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.3 PROTECTION OF THE ENVIRONMENT 12.3.3 – SEWAGE - MARPOL 74/78 - ANNEX IV All ships should carry a Statement of Compliance for International Sewage Pollution Preven- tion (ISPP) issued by RINA on behalf of the administration under the provisions of MARPOL 73/78 (see Chapter 14 - § 14.3). Discharge of sewage into the sea must be carried out in accordance with the provisions of Regula- tion 11 af annex IV, summarized in the following table: Distance Minimum Rate of Sewage from land speed discharge Comminuted and disinfected sewage using a system ap- > 3 en route at not less proved by the Administration sea miles than 3 knots restrictions > 12 en route at not Sewage which is not comminuted nor disinfected. sea miles less than 4 knots No As above, that have been stored in holding tanks, Approved by the or originating from spaces containing living animals. As above Administration The ship has in operation an approved sewage No restrictions treatement plant certified by the Administration. Table 12.3.b As for the disposal of sewage in the sea areas of the European Union, see the subseguent paragraph 12.3.6. 12.3.4 – GARBAGE - MARPOL 74/78 - ANNEX V (Amended by Resolution MEPC.201(62)) 12.3.4.1 – Definitions (Regulation 1) For the purposes of this Annex, as implemented on board all oil-tankers of the Company: 1 - Animal carcasses means the bodies of any animals that are carried on board as cargo and that die or are euthanized during the voyage. 2 - Cargo residues means the remnants of any cargo which are not covered by other Annexes to the present Convention and which remain on the deck or in holds following loading or unloading. This item does not apply to oil tankers, as their cargo is covered by Annex I (Oil). 3 - Cooking oil means any type of edible oil or animal fat used or intended to be used for the preparation or cooking of food, but does not include the food itself that is prepared using these oils. 4 - Domestic wastes means all types of wastes not covered by other Annexes that are generated in the accommodation spaces on board the ship. Domestic wastes does not include grey water. 5 - En route means that the ship is underway at sea on a course or courses, including deviation from the shortest direct route, which as far as practicable for navigational purposes, will cause any discharge to be spread over as great an area of the sea as is reasonable and practicable. The en route require- ment prevents from discharging any grabage at sea while the ship is at anchor or drifting. 6 - Fishing gear means any physical device or part thereof or combination of items that may be placed on or in the water or on the sea-bed with the intended purpose of capturing marine or fresh water or- ganisms. 7 - Fixed or floating platforms means fixed or floating structures located at sea which are engaged in the exploration, exploitation or associated offshore processing of sea-bed mineral resources. 8 - Food wastes means any spoiled or unspoiled food substances and includes fruits, vegetables, dairy products, poultry, meat products and food scraps generated aboard ship. 9 - Garbage means all kinds of food wastes, domestic wastes and operational wastes, all plastics, cooking oil, generated during the normal operation of the ship and liable to be disposed of continuously or periodically except those substances which are defined or listed in other Annexes to the present Convention. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 6 of 17 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.3 PROTECTION OF THE ENVIRONMENT 10 - Incinerator ashes means ash and clinkers resulting from shipboard incinerators used for the incin- eration of garbage. 11 - Nearest land. The term \"from the nearest land\" means from the baseline from which the territorial sea of the territory in question is established in accordance with international law. A special baseline has been established off the north-eastern coast of Australia, as detailed in MARPOL 73/78 – V/1.11. 12 - Operational wastes means all solid wastes (including slurries) not covered by other Annexes that are collected on board during normal maintenance or operations of a ship, or used for cargo stowage and handling. Operational wastes does not include grey water, bilge water, or other similar discharges essential to the operation of a ship, taking into account the guidelines developed by the Organization. 13 - Plastic means a solid material which contains as an essential ingredient one or more high molecular mass polymers and which is formed (shaped) during either manufacture of the polymer or the fabrication into a finished product by heat and/or pressure. Plastics have material properties ranging from hard and brittle to soft and elastic. For the purposes of this annex, \"all plastics\" means all garbage that consists of or includes plastic in any form, including synthetic ropes, synthetic fishing nets, plastic garbage bags and incinerator ashes from plastic products. 14 - Special area means a sea area where for recognized technical reasons in relation to its oceano- graphic and ecological condition and to the particular character of its traffic the adoption of special man- datory methods for the prevention of sea pollution by garbage is required. For the purposes of this Annex the special areas are the Mediterranean Sea area, the Baltic Sea area, the Black Sea area, the Red Sea area, the Gulfs area, the North Sea area, the Antarctic area and the Wider Caribbean Region, as detailed in MARPOL 73/78 - V/1.14. 12.3.4.2 – General prohibition on discharge of garbage into the sea (Regulation 3) 1 - Discharge of all garbage into the sea is prohibited, except as provided otherwise in regulations 4, 5, 6 and 7 of this Annex. 2 - Except as provided in regulation 7 of this Annex, discharge into the sea of all plastics, including but not limited to synthetic ropes, synthetic fishing nets, plastic garbage bags and incinerator ashes from plastic products is prohibited. 3 - Except as provided in regulation 7 of this Annex, the discharge into the sea of cooking oil is prohibited (see subsequent § 12.3.10.4). 12.3.4.3 – Exceptions (Regulation 7) 1 - Regulations 3, 4, 5 and 6 of this Annex shall not apply to: 1.1 - The discharge of garbage from a ship necessary for the purpose of securing the safety of a ship and those on board or saving life at sea; or 1.2 - The accidental loss of garbage resulting from damage to a ship or its equipment, provided that all reasonable precautions have been taken before and after the occurrence of the damage, to prevent or minimize the accidental loss. 2 - Exception of en route: 2.1 - The en route requirements of regulations 4 and 6 shall not apply to the discharge of food wastes where it is clear that the retention on board of these food wastes presents an imminent health risk to the people on board. 12.3.4.4 – Placards, garbage management plans and garbage record-keeping (Regulation 10) 1 .1 - Every ship of 12 m or more in length overall and fixed or floating platforms shall display placards which notify the crew and passengers of the discharge requirements of regulations 3, 4, 5 and 6 of this Annex, as applicable; .2 - The placards shall be written in the working language of the ship's crew. 2 - Every ship of 100 gross tonnage and above, and every ship which is certified to carry 15 or more persons, and fixed or floating platforms shall carry a Garbage Management Plan (GMP) which the crew shall follow. This plan shall provide written procedures for minimizing, collecting, storing, processing and disposing of garbage, including the use of the equipment on board. It shall also designate the person or FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 7 of 17 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.3 PROTECTION OF THE ENVIRONMENT persons in charge of carrying out the plan. Such a plan shall be written in the working language of the crew. 3 - Every ship of 400 gross tonnage and above and every ship which is certified to carry15 or more persons engaged in voyages to ports or offshore terminals under the jurisdiction of another Party to the Convention and every fixed or floating platform shall be provided with a Garbage Record Book (GRB). The Garbage Record Book, whether as a part of the ship's official log-book or otherwise, shall be in the form specified in the appendix to this Annex. 3.1 - Each discharge into the sea or to a reception facility, or a completed incineration, shall be promptly recorded in the Garbage Record Book and signed for on the date of the discharge or incineration by the officer in charge. Each completed page of the Garbage Record Book shall be signed by the master of the ship. The entries in the Garbage Record Book shall be in English. 3.2 - The entry for each discharge or incineration shall include date and time, position of the ship, category of the garbage and the estimated amount discharged or incinerated; 3.3 - The Garbage Record Book shall be kept on board the ship or the fixed or floating platform, and in such a place as to be readily available for inspection at all reasonable times. This document shall be preserved for a period of at least two years from the date of the last entry made in it; 3.4 - In the event of any discharge or accidental loss referred to in regulation 7 of this Annex an entry shall be made in the Garbage Record Book, of the location, circumstances of, and the reasons for the discharge or loss, details of the items discharged or lost, and the reasonable precautions taken to prevent or minimize such discharge or accidental loss. 12.3.4.5 – Discharge provisions (Regulations 3, 4, 5 and 6) Discharge of garbage must be carried out in accordance with the procedures detailed in the Gar- bage Management Plan, summarized in the following Table 12.3.c. Offshore platform (>12 nm from land) Category Ships outside Ships within and all ships within (GRB) Type of garbage Special Areas Special Areas 500 m of such platforms Food waste comminuted or Discharge permitted Discharge permitted ground (1) ≥ 3 nm from the nearest ≥ 12 nm from the near- B Discharge permitted land en route and as far est land en route and as as praticable. far as praticable. Food waste not comminuted or Discharge permitted ground ≥ 12 nm from the near- B Discharge prohibited Discharge prohibited est land en route and as far as praticable. Cargo residues not contained Not applicable to oil Not applicable to oil Not applicable to oil n/a in wash waters tankers tankers tankers Cargo residues contained in Not applicable to oil Not applicable to oil Not applicable to oil n/a wash waters tankers tankers tankers Cleaning agents and addi- F tives (2) in deck and external Discharge permitted Discharge permitted Discharge prohibited surfaces wash water Carcasses of animals carried n/a on board as cargo and which Not applicable to oil Not applicable to oil Not applicable to oil died during the voyage tankers tankers tankers All other garbage, including plastics, synthetic ropes, plas- tic garbage bags, incinerator A C D ashes, clinkers, cooking oil, Discharge prohibited Discharge prohibited Discharge prohibited E F floating dunnage, lining and packing materials, paper, rags, glass, metal, bottles, crockery and similar refuse. Mixed garbage When garbage is mixed with or contaminated by other substances prohibited from discharge or having different discharge requirements, the more stringent requirements shall apply. (1) So to be capable of passing through a screen with openings no greater than 25 mm. (2) These substances must not be harmful to the marine environment. Table 12.3.c FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 8 of 17 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.3 PROTECTION OF THE ENVIRONMENT 12.3.4.6 – Ship’s garbage receptacles (IMO – USDA) Garbage receptacles should be suitably marked. They should be constructed of non-combustible materials with no openings in the sides or bottom [SOLAS 74/78 – II-2/4.4.2], with the possible exception of the receptacles located in the galley and pantries [IMO MSC/Circ.1120 – 02.06.04]. All receptacles should be covered, leak proof and the ones located on open decks should be kept inside the railing [7 CFR 330.400(g)(1) & 9 CFR 94.5 (f)(1)]. As for the disposal of garbage in the waters and ports of the European Union, see the sub- seguent paragraph 12.3.6. 12.3.5 – AIR POLLUTION - MARPOL 74/78 - ANNEX VI Conformity of the vessel to the rules of the Convention is certified by the International Air Pollution Prevention Certificate (IAPP) issued by RINA on behalf of the administration, which must be carried by all ships (see Chapter 14, § 14.3). 12.3.5.1 – Ozone depleting substances (Regulation 12) Emissions of such substances, as defined in Regulation 2 – item (6), are prohibited because they cause serious damages to the ozone layer in the stratosphere surrounding the Earth and shielding it from the harmful ultraviolet (UV) solar rays. When removed from ships, such substances, as well as the equipment containing them, must be delivered to shore reception facilities. No machinery or equipment using ozone depleting substances exist on board the ships of the Com- pany’s fleet, and the use of such substances is formally prohibited. 12.3.5.2 – Exhaust gas 12.3.5.2(a) – Nitrogen Oxides (Regulation 13) Regulation 13 limits the content of Nitrogen Oxides (NOx) in the exhaust gases of diesel engines fitted on board the ships. Limits vary in accordance with the engine rated speed (rpm). As an information, they are comprised between 17.0 g/kWh for slow engines (<130 rpm), and 9.8 g/kWh for fast engines (>2000 rpm). Such limits are in force for all diesel engines with a power output of more than 130 kW, installed on ships constructed (keel laid) after 01.01.2000. The regulation does not apply to emergency gensets, motors fitted to survival craft and, as a general rule, to all engines intended to be used solely in case of emergency. The content of Nitrogen Oxides in the diesel engines exhaust gases depends on their technical characteristics. Each engine must be provided with the following documentation: • Engine International Air Pollution Prevention Certificate (EIAPP), issued by the Classification Society upon completion of the required assessments, together with the relevant technical file. • Record of settings and replacements of engine components. 12.3.5.2(b) – Sulphur Oxides Limits to the Sulphur content (% by mass) in the various types of fuel oil used on board have been extablished in order to reduce the release into the atmosphere of Sulphur Oxides (SOx) contained in the exhaust gases from diesel engines and boilers. Various sets of rules are presently in force on the subject, the most restrictive of which must always be observed: - Global (MARPOL/VI – Regulation 14) FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 9 of 17 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.3 PROTECTION OF THE ENVIRONMENT Limits of sulphur content prescribed for all types of fuel: • Outside SECA/ECAs: 3.5%; • Inside SECA/ECAs: 0.1%. The sea area presently designated as emission control areas are: ⇒ SECA’s (SOx Emission Control Areas): - The Baltic Sea area, as defined in Annex I - regulation 1.11.2. - The North Sea area, as defined in Annex V - regulation 5(1)(f). ⇒ ECA (Emission Control Areas): - The North American area, as described by the coordinates provided in appendix VII to Annex VI. - EU (Directive 2012/33/EC) The maximum allowable sulphur content of fuel oil used by ships at beth in EU ports, other than those in the outermost regions (French Oversea Departments, the Azores, Madeira and the Canary Islands) will be 0.1% by mass (m/m). This covers all grades of fuel oil and all types of combustion machinery, including main and auxiliary boilers. At berth covers ships at anchor, on buoys or alongside, whether or not they are working cargo. Ships are not required to comply with the 0.1% m/m limit while manoeuvring. However, they must comply as soon as possible after arrival in port, and must continue to comply until as late as possible before departure. - California (CARB Marine Notice 2009-2) The following fuel requirements apply to ocean-going vessels main propulsion diesel engines, aux- iliary diesel engines and auxiliary boilers, when operating within the Emission Control Area (ECA) 24 nautical miles regulatory zone off the California coastline: • Marine Gas Oil (DMA) at or below 0.1% m/m sulphur content. • Marine Diesel Oil (DMB) at or below 0.1% m/m sulphur content. 12.3.5.2(c) - Changing fuel grade Ship-specific written procedures to control the change of fuel grade in use in order to comply with the above regulations are available on board. 12.3.5.3 – Gas from oil tankers cargo tanks 12.3.5.3(a) – Volatile organic compounds (VOC) (Regulation 15) In order to prevent or minimize as much as possible the release to the atmosphere of volatile organic compounds, directions contained in the ship's VOC Management Plan, requested by MARPOL 73/78 - VI/14.6 for tankers carrying crude oil, must be carefully followed (see Chapter 14 - § 14.5). Tankers operating at ports and terminals of Countries where VOC emissions are regulated, in ac- cordance with Protocol 1997, must be fitted with a vapour control system (VCS) approved by the Ad- ministration in accordance with the standards developed by IMO. 12.3.5.3(b) – Toxic gas [Company’s procedure] Some types of crude oils contain toxic substances, particularly: ◊ H2S – Hydrogen Sulphide ◊ C2H4O2S – Mercaptans (Mercaptoacetic acid). These substances may also be contained in other oil cargos, such as condensates, natural gaso- line, fuel oils. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 10 of 17 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.3 PROTECTION OF THE ENVIRONMENT Useful informations on toxicity of petroleum and associated substances may be found in ISGOTT – Chapter 2 - § 2.3. As a rule, the presence of such substances is indicated in the Material Safety Data Sheet (MSDS) that the Shippers should deliver to the vessel before the beginning of loading operations (see Section 12.4 - § 12.4.1.1). At the end of discharge of these types of cargo, the inert gas/hydrocarbon gas mixture contained in the cargo tanks results rich in toxic gases released by such substances. Unless properly eliminated in the open sea, the toxic gas mixture would be vented into the atmosphere in the next loading port, caus- ing its pollution. Venting of such gases could happen even during discharge, when an excessive pres- sure of the inert gas delivered to the cargo tanks could cause their individual HV pressure-relief valves to open. Normally, the maximum allowed limit for toxic gases contained in the tanks intended to receive an oil cargo should not exceed their Long Term Permissibile Exposure Limit (PEL): ◊ H2S – Hydrosulphuric Acid = 5ppm (in volume) ◊ C2H4O2S – Mercaptans = 0,5 ppm (in volume). To avoid any pollution of the atmosphere in coastal areas, the following procedures must be ob- served on board: ⇒ LOADED PASSAGE AND FOLLOWING DISCHARGE OPERATIONS - If the cargo loaded has been declared by Shippers as containing toxic gases (MSDS), the ullage of all cargo tanks must be tested by gas-measuring tubes every two days, beginning on the first day after sailing from the loading port (every day in case the voyage lasts 5 days or less), in order to ascertain their quantity (in ppm). A final test shall be carried out on the last day before arrival at the discharging port. - First and final tests must be carried out in any case, even if the cargo loaded had been declared to be free from toxic gases. In case any such tests give a positive result, the cargo must be considered as containing toxic gases and all appropriate cautions and safety procedures must be observed and carried out. - Before arrival at the discharge port, IG pressure shall be reduced so to be able to safely gauge tanks and sample cargo through the specially fitted vapour locks, without any escape of gas to the atmosphere (ISGOTT - 11.8.3). - During discharge, IGS plant shall be properly set, and gas main and cargo tanks internal pressure shall be carefully watched to avoid exceeding the pressure-relief valves opening values.- COW, final stripping of cargo tanks and lines and their pumping ashore shall be particularly accurate, so to minimize the quantity of sediments, clingage and cargo residues remaining on board. ⇒ BALLAST PASSAGE - On the first day after sailing from a port where a cargo containing toxic gases has been discharged, the atmosphere of all cargo tanks shall be tested in order to ascertain the quantity of such gases (in ppm) still contained in them. - If the quantity of toxic gas exceeds its allowed limits, cargo tanks shall be purged by inert gas. Purging will be started immediately and its progress will be checked by frequent tests of the tanks atmosphere by means of gas-measuring tubes. - Once the measurements show that the quantity of toxic gas contained in the cargo tanks has fallen below its allowed limits, purging will be stopped. After which, all cargo tanks shall be tested for toxic gases every two days (every day in case the remaining passage time is 5 days or less). A final test shall be carried out on the last day before arrival at the following loading port. - First and final tests must be carried out in any case, even if the cargo carried had been declared, or resulted to be, free from toxic gases. In case any such tests give a positive result, the cargo should be considered as containing toxic gas, all appropriate cautions shall be observed and all safety procedures, including purging, shall be carried out. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 11 of 17 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.3 PROTECTION OF THE ENVIRONMENT - If an abnormally high quantity of sediments or residues remaining on board render impossible to re- duce the quantity of toxic gas in the cargo tanks within their allowed limits, the Master will notify the DPA and request his authorization to wash the tanks and to dispose of the resulting oily waters in the proper way. Results of all tests carried out while at sea, together with details of any purging operation, shall be recorded in the Cargo Control Room Log Book - Part IV - Toxic Gases and shell be notified to the Chartering Department (NG) of the Company. All relevant messages and documentation shall be filed on board for not less then 3 years. 12.3.5.4 – Shipboard incineration (Regulation 16) Incinerators installed on board must be approved by the Administration in accordance with the standards developed by the IMO, as detailed in Appendix IV to this annex. Shipboard incineration of the following substances shall be prohibited: a) Cargo residues of substances listed in Annex I. b) PCB plastics. c) Garbage, as defined in Annex V, containing more than traces of heavy metals. d) Refined petroleum products containing halogen compounds. Shipboard incineration of sewage sludge and sludge oil generated during the normal operation of a ship may also take place in the main or auxiliary power plant or boilers, but in such cases, it shall not take place inside ports, harbours or estuaries. All ships with incinerators subject to this regulation shall possess a manufacturer’s operating man- ual which shall specify how to operate the incinerator within the limits described in paragraph (2) of Appendix IV. Personnel responsible for operation of any incinerator shall be trained and capable of implementing the guidance provided in the manufacturer’s operating manual. For the discharge or disposal of ashes generated by the incinerator, see the previous paragraph 12.3.4.1. Incineration of any kind of ship-generated waste is prohibited in the territorial seas of all Baltic Sea Coastal States (Helsinki Convention 1992). 12.3.5.5 – Fuel oil quality (Regulation 18) Fuel oil for combustion purposes delivered to and used on board the ships shall meet the require- ments defined in Regulation 18(1) and (2). Details of fuel oil delivered on board shall be recorded by means of a Bunker Delivery Note (BDN), issued by the Supplier, which shall contain at least the following informations, as listed in Appendix V to Annex VI: Name and IMO number of receiving ship. Port. Date of commencement of delivery. Name, address and telephone number of marine fuel supplier. Product name(s). Quantity (metric tons). 3 Density at 15°C (kg/m ) [ISO 3675]. Sulphur content (% m/m) [ISO 8754]. A declaration signed and certified by the fuel oil supplier’s representative that the fuel oil supplied is in conformity with Regulations 14(1) or (4)(a) and 18(1) of Annex VI. The BDN shall be kept on board the ship, readily accessible for inspection. It shall be retained for a period of at least three years since the fuel oil has been delivered on board. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 12 of 17 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.3 PROTECTION OF THE ENVIRONMENT Each BDN shall be accompanied by a representative sample of the fuel oil delivered, drawn during supply (MARPOL sample). The sample is to be sealed and signed by the Supplier’s representative and by the Master or the Officer in charge once completed the bunkering operations. It shall be retained under the ship’s control until the fuel oil is substantially consumed, but in any case for a period of at least 12 months from delivery.The samples to be stored in the dedicated cabinet in the chemical locker / Steering gear.  Checking fuel oil [Company’s procedure] In order to check the quality of the fuel oils purchased and supplied to its vessels, the Company has contracted a qualify Company as per Circular letter UT, for performing in its own laboratories all appro- priate analysis of fuel oil samples drawn on board during supply. Results are notified to the Company, to be examined and forwarded to the vessels. Publication FUEL QUALITY TESTING INSTRUCTIONS MANUAL, available on all vessels, con- tains detailed instructions on the procedures for fuel oil sampling and for samples management, and on interpretation of analyses’ results. The Chief Engineer is responsible for the good care of fuel samples on board. Samples should be labelled and recorded in the Fuel Supply Samples Record Book, and should be kept stored in the special cabinet fitted to all ships. 12.3.5.6 – Annex VI Company’s manual All ships carry a special manual, prepeared by the Technical Department of the Company, contain- ing: 1 – Regulation 12 – Guidelines. Technical documents relevant to: • Fire fighting system. • Air conditioning plants. • Cold provisions plant. 2 – Regulation 13 – Guidelines. Documents: • EIAPP (Statement of compliance) for all ship’s engines, issued by RINA. • Technical files of all ship’s engines, issued by the manufacturers and endorsed by RINA. 3 – Regulation 14 – Guidelines. 4 – Regulation 15 – Guidelines. Documents: • Compliance of VCS, issued by RINA. • VCS manual, endorsed by RINA. 5 – Regulation 16 – Guidelines. 6 – Regulation 18 – Guidelines. Publications: • MARPOL 73/78 Annex VI - Regulations for the Prevention of Air Pollution from Ships - Technical and operational Implications. • Fuel Quality Testing - Instruction Manual. 12.3.6 – DISPOSAL OF SHIP-GENERATED WASTE AND CARGO RESIDUES IN THE EUROPEAN UNION WATERS - Directive 2000/59/EC Directive 2000/59/EC, requests all ships calling at, or operating within, ports in the European Union to deliver all ship-generated waste and cargo residues to port reception facilities, and forbids their dis- charge into the sea. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 13 of 17 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.3 PROTECTION OF THE ENVIRONMENT These rules apply to all substances falling under the scope of Annexes I, IV and V to MARPOL 73/78, taking into account that: • Bilge oily waters from the machinery space may be discharged at sea, both outside and inside special areas, only if the oil content in the effluent does not exceed 15 ppm., through an approved filtering equipment fitted with an alarm system and an automatic stopping device, strictly in con- formity with MARPOL 73/78 – Annex I, Regulation 15 (See § 12.3.2.1). • Garbage and sludge incineration may be carried out in conformity with MARPOL 73/78 – Annex VI, Regulation 16, everywhere except in the territorial seas of all Baltic Sea Coastal States (including non EU States). (See § 12.3.5.4). 12.3.6.1 – Procedure (a) Notification At least 24 hours prior to arrival, the master shall notify the following information to the port authority, using the special Notification form:  Ship’s name, call sign, IMO number, flag.  Estimated time of arrival (ETA) and sailing (ETD).  Previous and next ports.  Last delivery of waste: Port and date.  Intention to: deliver all waste, - deliver some waste, - retain on board all waste;  For every tipe of waste and cargo residues: - amount to be delivered; - maximum dedicated storage capacity; - amount retained on board on sailing; - next intended delivery port; - estimated amount to be generated between notification and next port of call. A copy of Notification form must be sent to Marine Dept. and Charter Dept. (b) Delivery Before sailing, the ship shall deliver all ship-generated waste and cargo residues to the port recep- tion facilitiies. The ship may proceed to her next port of call without delivering the waste if it results from the information given before arrival that there is on board sufficient dedicated storage capacity for all waste and cargo residues that has been accumulated and will be accumulated during the intended voyage to the port of delivery. If there are good reasons to believe that adequate facilities are not available at the intended port of delivery, or if the ship’s destination port is unknown, the authority will force the ship to deliver its waste and cargo residues before departure from the port. 12.3.7 – BALLAST WATER CONTROL AND MANAGEMENT - IMO Resolution A.868(20) Studies carried out in various Countries have shown that many species of bacteria, plants and animals can survive in a viable form in the ballast water and sediments carried in ships, even after journeys of several month’s duration. Subsequent discharge of ballast water into port waters may result in the establishment of alien harmful acquatic organisms and pathogens which may pose threats to indigenous human, animal and plant life, and the marine environment. In order to prevent or minimize this form of biological pollution, several States, (among them Aus- tralia, Canada, Russia, U.S.A.) have issued special rules, to be observed by all ships calling their ports with water ballast on board. Practically, they should: FRATELLI d’AMICO ARMATORI S.p.A. - ROMA