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Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 14 of 17 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.3 PROTECTION OF THE ENVIRONMENT - Perform a full exchange of the water ballast, in oceanic or deep-water sea areas, before reach- ing their waters. - Log all ballasting, ballast exchange and deballasting operations. - Submit, before arrival, a special Ballast Water Reporting Form containing all relevant details. The Master must make an enquiry, in due time, about the existence of special rules, by asking the Agent at the destination ports, or the Company’s Chartering Department. All Company’s ships have on board a Ballast Water Management Plan which include Biofouling and Sediment Management Plan Appendix as per Mepc.207 (62) adopted on 15 July 2011, containing all necessary intructions on how to carry out the ballast water exchange in safe conditions, and all infor- mations on the procedures to be followed. The plan is in accordance with the IMO Resolution A.868(20) – Guidelines for the control and managemant of ship’s ballast water to minimize the transfer of harmful aquatic organisms and pathogens – Adopted on 27 November 1997. whose full text is therein contained. As for precautions to be taken when performing ballast water exchange at sea, as required by SOLAS 74/78 – V/22.4, see the BRIDGE MANAGEMENT MANUAL, I/2.4. 12.3.8 – ANTI-FOULING PAINTS - Regulation (EC) No.782/2003 (International Convention AFS 2001) Organotins (Tri-Butyl Tin = TNT) contained in traditional anti-fouling paints applied to ships’ hulls have proved to be extremely dangerous to the marine environment . Use of these harmful substances has been banned by the Company since several years, so that all its ships are now protected by TBT-free paints, in accordance with Regulation (EC) No.782/2003 of the European Parliament and of the Council of 14 April 2003 on the prohibition of organotin compounds on ships . Conformity of the vessel to the Regulation is certified by the International Anti-fouling Certificate (AFC) issued by RINA on behalf of the Administration, which must be carried by all ships (see Chapter 14, § 14.3). A set of records containing all details of the anti-fouling system originally applied to the hull and of the systems applied at each subsequent dry-docking is permanently attached to the certificate. 12.3.9 – DISCHARGES INCIDENTAL TO THE NORMAL OPERATION OF VESSELS - U.S.A. EPA VGP 18.12.2008 The Environmental Protection Agency (EPA) has developed requirements for discharges “incidental to the normal operation of vessels” into waters of the 3 miles territorial sea of the U.S.A. (e.g. deck runoff, graywater, chain locker effluent, cooling water, bilge oily water separator effluent, etc.). Following a special Notice of Intent (NOI) submitted by the owner/operator, the EPA authorizes such discharges under the coverage of the VESSEL GENERAL PERMIT, under particular conditions: - Meet the technology-based effluent limits and the related requirements contained in part 2 of the VGP. - Routine visual inspections of areas addressed, weekly or once per voyage, whichever is more frequent. - Quarterly sampling of effluents for any sign of visible pollutants. - Annual comprehensive vessel inspection. Above operations must be carried out and recorded in accordance with the VGP requirements. The Company submitted NOI for all ships of its fleet, and EPA activated the relevant VGP cover- ages. Each VGP is identified by a Tracking Number. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 15 of 17 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.3 PROTECTION OF THE ENVIRONMENT All ships are provided with: • one copy of the EPA letter confirming its coverage, together with relevant tracking number; • one copy of the VGP; • one Guidance Manual. The Company’s HSEQ Department takes care of the procedurs to obtain and maintain VGP cover- age and of all contacts with EPA. 12.3.10 – SPECIAL WASTE 12.3.10.1 – Medicines (Ministry of Health Circular Letter nr. 17 dated 20.07.1994) Expired or unnecessary medicines originating from the ship’s medical chest or belonging to crew members, are classified as special waste by Italian national regulations, and should be disposed-of as required (see Section 12.8 - § 12.8.4): - Discarded medicines should be kept in a leak-proof sealed container, identified in a special list drawn in triplicate. - The container should be stowed in the ship’s pharmacy, well segregated from other medicines and properly labelled. - Shore disposal shall be requested to the Port Health Office, and authorized by them. - The container should be handed over to a duly authorized firm, to be carried and delivered to the disposal plant. The delivery should be recorded in the SPECIAL WASTE RECORD BOOK, together with the relevant documentation. - Additionally, disposal of legal drugs should be entered in the MEDICAL DRUGS RECORD BOOK (See Chap- ter 14, § 14.4). 12.3.10.2 – Electrical/electronic appliances & materials [Company’s procedure] The following materials cannot be disposed of as garbage: ⇒ Exhausted and discarded general service, GMDSS and LSA batteries. ⇒ Exhausted and discarded batteries of any kind, powering portable and autonomous electrical and electronic equipment. ⇒ Neon tubes and lamps. ⇒ Electric/electronic components and parts (PCB, LED, etc.). ⇒ Discards/remnants of electrical cables. ⇒ Discarded domestic appliances (Refrigerators, washing/drying machines, boilers, radios, TV sets, DVD/CD players/recorders, Playstations, etc.). ⇒ Discarded electronic equipment (portable radios, portable meters, PC, printers, scanners, etc.). ⇒ Toner cartridges and writing ribbons of printers, recorders and loggers (Deck, Engine, office). These discarded materials should be sorted out and kept on board until they can be delivered to a suitable shore disposal facility. The delivery shall be recorded in the SPECIAL WASTE RECORD BOOK, to- gether with the relevant documentation. 12.3.10.3 – Coatings & Chemicals [Company’s procedure] Discards/remnants of the following materials must be disposed of in compliance with the Recom- mended Methods of Disposal detailed in their Material Safety Data Sheets (MSDS): ⇒ Marine paints (coatings, catalysts, hardeners, solvents, thinners, etc.). ⇒ Chemicals (Deck, Engine, domestic). ⇒ Fire-fighting foam-forming liquids (fixed system, portable applicators, portable and great capacity extinguishers). ⇒ Fire-fighting dry-chemical powders (portable extinguishers). These materials, together with their containers, should be sorted out and kept on board until they can be delivered to a suitable shore disposal facility. The delivery shall be recorded in the SPECIAL WASTE RECORD BOOK, together with the relevant documentation. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 16 of 17 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.3 PROTECTION OF THE ENVIRONMENT 12.3.10.4 – Cooking oil [Company’s procedure] Used cooking oil should never be dumped in the galley sink. The proper way to dispose of it is to put it in leak-proof sealed container, stowed in the galley ,properly labelled and delivered to a suitable shore disposal facility. The delivery shall be recorded in the GARBAGE RECORD BOOK ( code D) together with the relevant documentation. 12.3.11 – PROTECTION OF ENDANGERED SPECIES Wild fauna and flora are a irreplaceable part of life on our planet and must be protected in order to ensure its preservation. Many animal and vegetable species are threatened with estinction by the con- tinuous development of human activities, and are in need of special forms of protection. 12.3.11.1 – Passage planning: Areas to be avoided In order to safeguard various local forms of marine fauna and flora, protected areas (marine parks or reserves) and areas to be avoided by ships have been established by Coastal States in the waters subject to their control. The rules to be observed in voyage planning in order to avoid such areas are detailed in the Bridge Management Manual, Part II – § 1.7 (see Section 12.2.1). 12.3.11.2 – Convention CITES 73/79 The Convention on International Trade in Endangered Species of wild fauna and flora (CITES) was signed in Washington on March 3, 1973, and amended at Bonn on June 22, 1979. Its aim is the preser- vation of the delicate balance between the right ambitions of economic development of many Countries through the utilization of the various species of fauna and flora typical of their territory, and their protec- tion. The following is a short listing (not exhaustive) of goods whose trade is regulated or, in some cases, prohibited by the convention: - Ivory objects. - Elephant tusks and skins. - Coral (live or as jewels and ornaments). - Objects and shells of sea turtles. - Giant Clam shells. - Traditional oriental medicine products. - Orchids and cactus plants. - Leopard and other wild cats skins and coats. - Reptiles, alligator and crocodile skins and skin objects (shoes, belts, bags, etc.). - Live specimens of parrots, birds of prey, monkeys, scorpions and reptiles. - Shahtoosh and vicuña wool shawls. - Caviar. Possession of these goods by anybody on board, and their carriage on the Company’s ships are absolutely prohibited. 12.3.12 – COMPANY’S COMMITMENT 12.3.12.1 – Waste reduction The Company adopts the following methods to reduce the quantity of ship-generated waste: • Supply of materials and provisions to the ships:  Purchases in bulk.  Instructions to shipchandlers and suppliers to use packings and containers of the greatest available capacity. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 17 of 17 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.3 PROTECTION OF THE ENVIRONMENT The Company has the dedicated form “IP 02a – Form 02” for monitoring and evaluating the whole suppliers. Where choice is possible, the Company will purchase the goods to the environmentally friendly suppliers. • Fuels:  Ship’s Diesel generators use DMB or DMA (Distilled Dieseloil or Gasoil) instead of DMC or HFO (Blended Dieseloil or Heavy Fuel). Practically, no purification is needed and no sludges are generated. • Instructions to the ships:  Recycling of containers, vessels, packing materials.  Minimizing employing single-use objects and tools.  Regular use of non-disposable materials and equipment.  As far as practicable, avoid using plastic bags in collecting and selecting garbage. 12.3.12.2 – Energy conservation The correct operation and an accurate maintenance of ship’s Diesel engines and boilers ensure the most effective combustion, resulting in a lower fuel consumption per produced energy unit and a better exhaust quality. Company’s Technical Department regularly monitors ships’ main engines and Diesel generators performance and fuel consumptions, using a specially-designed software. At least every three years Technical Department arrange for a underwater survey and provide for propeller polishing as well as hull cleaning if necessary. In compliance with Italian L. 09.01.1999, No.10 - Rules for the Implementation of the National En- ergetic Plan, the Company appointed the Head of the Technical Department (UT) as its Energy Man- ager, in charge of providing for all notifications and fulfilments required by the law itself as to energy conservation. 12.3.12.3 – Surveillance and Measurement Plan The ISO – Quality/Environment (Q&E) Integrated Management System, in accordance with stand- ards UNI EN ISO 9001:2008 (Quality management) and UNI EN ISO 14000:2004 (Environmental man- agement) adopted by the Company (see Chapter 1, § 1.2) provides for a Surveillance and Measurement Plan (IP 11) for the regular monitoring of all ship-generated waste, as well of all substances (fueloils, luboils, chemicals, refrigerants, coatings, etc.) consumed on board the Company’s ships. 12.3.12.4 – New environmental technologies In order to keep its tecnichal staff abreast of the most recent developments in shipbuilding and ship- equipment industry and, particularly, in new environmental tecnologies, the Company: • Is partner to the most important national and international shipping organizations. • Keeps in touch with qualified research and superior learning centres. • Keeps in touch with classification societies, shipyards and manufacturers. • Regularly subscribes to the most important technical reviews and publications. • Encourages its staff to attend meetings, seminars and updating courses, and organizes their participation. New environmental technologies are examined and discussed during the periodical policy rewiew meetings. When appropriate or necessary, one or more of the following measures are decided: • Implementation of new procedures. • Fitting new equipment to the ships; • Updating new buildings plans and specifications. Such measures are subject to a management of change procedure (see Chapter 3, § 3.10). 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 12.4 CARGO OPERATIONS INDEX 12.4.1 GENERAL SAFETY RULES - 12.4.1.1 MSDS of cargo carried - 12.4.1.2 On-board smoking regulations - 12.4.1.3 Basic precautions - 12.4.1.4 Using on board mobile phones, pagers, automatic and digital cameras. - 12.4.1.5 Safe working practices 12.4.2 SAFETY RULES DURING CARGO OPERATIONS - 12.4.2.1 Use of radio electrical equipment - 12.4.2.2 Precautions to be observed 12.4.3 PORTABLE EQUIPMENT -- (i) Gas meters -- (ii) Cargo gauging and sampling equipment. -- (iii) Lack of operational gas meters 12.4.4 CARGO MEASUREMENT AND SAMPLING - TANKS INSPECTION 12.4.5 CARGO OPERATIONS - 12.4.5.1 Pre-arrival technical checks - 12.4.5.2 Mooring - 12.4.5.3 Informations exchange – Planning -- (i) Loading -- (ii) Discharging -- (iii) Planning of operations - 12.4.5.4 Carrying out cargo operations -- (i) Loading and discharging -- (ii) Trim, stability and stress conditions -- (iii) Crude oil Washing (COW) - 12.4.5.5 Inert Gas System (IGS) - 12.4.5.6 Entering pumproom - 12.4.5.7 Precautions against the risks posed by static electricity - 12.4.5.8 Inert Gas System breakdown - 12.4.5.9 Immediate stop of operations - 12.4.5.10 Ship-to ship (STS) operations 12.4.6 TANK WASHING GAS FREEING AND CLEANING - 12.4.6.1 Tank washing - 12.4.6.2 Gas Freeing - 12.4.6.3 Cleaning 12.4.7 BALLAST OPERATIONS 12.4.7.1 Segregated Ballast 12.4.7.2 Heavy weather ballast in oil cargo tanks 12.4.7.3 Ballast Water Exchange at Sea 12.4.8 WORKING IN THE CARGO PUMPROOM 12.4.9 CHECKS DURING PASSAGE 12.4.10 KEEPING CARGO SAMPLES ON BOARD 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 12.4 CARGO OPERATIONS 12.4.1 – GENERAL SAFETY RULES Basic information on safe performance of cargo operations on oil tankers are contained in the ICS/OCIMF publication International Safety Guide for Oil Tankers and Terminals - 5th Edition 2006 [ISGOTT/2006] (see Chapter 6 – Appendix - # 201). Activities concerning cargo operations are subject to the risk assessment process (see Chapter 12 - § 12.2, and the Risk Assessment File). 12.4.1.1 - MSDS of cargo carried [ISGOTT/2006 - 2.3.4] SOLAS 74/78 - VI/5-1 requires that all ships carrying oil in bulk as cargo to be provided with material safety data sheets (MSDS) for each cargo carried, in the IMO-recommended format as detailed in resolution MSC.286(86), to be delivered on board before beginning loading operations (see also Section 12.8 - § 12.8.7.2). The following procedure shall be followed at all loading ports:  arriving at the installation, the Master should request from the Shippers an MSDS in the IMO-recommended format for each grade of cargo to be loaded;  the MSDS(s) so obtained shall remain posted on board and used in the prescribed way throughout the voyage;  if an MSDS is not delivered on board before beginning loading operations, or it is not in the recommended format, the Master should tender a note a protest to the Shippers, copying it to the Chartering Department of the Company, and record the facts in the log book (Giornale Nautico - Libro II) to help avoid potential problems with PSC (and vetting inspectors);  used MSDS shall remain filed on board together with the relevant cargo documents. Risks for health caused by toxic gas contained in oil cargoes and fuels, particularly benzene, H2S and mercaptans, and relevant safety precautions to be observed are detailed in the ISGOTT/2006 - 2.3. 12.4.1.2 - On-board smoking regulations [ISGOTT/2006 - 4.2.2] As per Law no. 3 of 16 January 2003 Regulatory provisions on public administration art. 51 “Protecting the health of non-smokers” and as per WHO Framework Convention on Tobacco Control art. 8 entered into force on 27 February 2005 SMOKING ON BOARD IS NOT PERMITTED. SMOKING IS ALLOWED ONLY IN THE DESIGNATED ROOMS. The Master cannot fail to observe this rule by designating other rooms. Smoking rooms should be clearly identified by suitable notices. They should not have any opening to the outside and their internal entrance doors must be kept always closed. IT IS PROHIBITED TO CARRY CIGARETTES OR MATCHES OF ANY KIND. LIGHTERS ARE NOT ALLOWED ON BOARD; ONLY SAFETY MATCHES MUST BE USED. THE ELECTRONIC CIGARETTES ARE NOT CERTIFIED AS INTRINSICALLY SAFE AND THEIR USE MUST FOLLOW THE SAME RULE ISSUED FOR SMOKING REGULATIONS ON BOARD. Smoking permit may be revoked by the Master or by the terminal representative. It is prohibited both to smoke and to carry lighters or matches of any kind ashore, while transiting on jetty berths or through oil installations. 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 12.4 CARGO OPERATIONS 12.4.1.3 – Basic precautions [ISGOTT/2006 – 4.1].  All portable lamps and battery powered equipment used on board must be of an approved intrinsically safe type.  Accommodation and machinery space fire doors must be unimpeded and remain always shut by their automatic closing devices.  Self igniting lights attached to lifebuoys located on the main deck cargo tanks area must be of an approved intrinsically safe type.  Carrying out any kind of hot work on board is subjected to the procedure detailed in section 12.8 - § 12.8.10.3.2 (Hot Work Permit) 12.4.1.4 - Using on board mobile phones, pagers, automatic and digital cameras [ISGOTT/2006 – 4.8.6, 4.8.7]. Such battery-powered equipment cannot be used nor kept powered on the ship’s open decks and in any dangerous zone or compartment of the vessel and, in port, on docks and in terminal areas. Special safety signs are posted at all accommodation spaces exit doors. Use of mobile phones, pagers, tablets, PC’s or other electronic device that can promote the risk of distraction, must be avoided and kept switched off by all personnel during the watch on bridge nor in the CCR or in any place where they are keeping watch or duty. During commercial operation in port or at sea, the use of the above mentioned devices is permitted only and exclusively in cabins or recreations rooms. 12.4.1.5 - Safe working practices As for the safe performance of work on board, refer to the rules contained in Section 12.8 of this manual. Particularly:  Use of personal protective equipment. See § 12.8.1.5.  Use of cargo Material Safety Data Sheets (MSDS): See § 12.4.1.1.  Welding gases: See § 12.8.11.  Work permits: See § 12.8.12.3.  Enclosed spaces entry: See § 12.8.12.3.1. 12.4.2 – SAFETY RULES DURING CARGO OPERATIONS Detailed instructions on the procedures to be followed during oil loading, discharging and on-board transfer operations are contained in the publication Oil Transfer Procedures for Cargo Operations, provided to all tankers. Its availability and its use on board are compulsory whenever cargo operations are carried out in the territorial sea of the U.S.A., as requested by 33 CFR 155.720. It is an integral part of the Company’s policy of safety and protection of the environment in the waters of all Countries in the world. 12.4.2.1 - Use of radio electrical equipment [ISGOTT/2006 – 4.8] During cargo operations, use of radio-electrical equipment may pose some risks and their use should be limited or interrupted, as stated in the special placards posted on board:  GMDSS MF/HF SSB Transceiver: It cannot be used, it must be switched off before reaching the oil dock and its aerial must be grounded, as stated in the special notice posted on its console. 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 12.4 CARGO OPERATIONS  GMDSS and CCR VHF radio equipment: They can be used only with their power switch set to LOW. (Their power output should not exceed 1 W).  Portable UHF/VHF radio: Only intrinsically safe sets, belonging to the vessel’s equipment or supplied by the terminal, can be used. (Their power output does not exceed 1 W).  Automatic Identification System (AIS) on the navigation bridge: It cannot be used and must be switched off before the arrival at the oil dock, to be re-started only on departure. (Transmits in the VHF band with a power output of 12,5 W). In case local authorities require its operation in port for security or VTS reasons, notify the shore staff in advance.  Radar equipment: Radars must be switched off on arrival. Were it necessary to operate them while in berth, check the harbour and terminal safety regulations and apply to the shore staff in advance  Satellite Communications Equipment: They can be normally used. 12.4.2.2 - Precautions to be observed  A preliminary ship/shore safety meeting must be held before beginning cargo operations.  The Ship/Shore Safety Check List must be jointly completed and signed by the Chief Officer and the terminal representative. 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. [ISGOTT/2006 – 26.3]  In addition to the checklist, in all U.S.A. ports, a Declaration of Inspection must be jointly completed by the ship and the terminal or other ship/barge, in accordance with 33 CFR 156.150 requirements.  Machinery space must be fully manned (see Section 12.2.3, §12.2.3.4(iv).  Hot work of any kind is prohibited everywhere on board. Cold work may be authorised, once all necessary precautions have been taken and the special permit has been issued.  Welding gas bottles (oxygen and acetylene) must be closed and disconnected from their distribution lines.  Accommodation air conditioning should work on a partially-closed system (internal air partial recirculation). Air intakes must be kept not fully closed in order to maintain the inner spaces under positive pressure and avoid the ingress of external air through openings in unsafe areas (for instance when opening external access doors) [ISGOTT/20066 – 24.2].  A single external door should be used for working access to inner spaces, to be immediately closed after use.  All external doors must be kept closed. They should not be locked but, for security reasons, they shall be fitted on their outer side with breakable numbered seals.  Portable air pumps must be rigged on main deck aft, port and starboard, ready for use and connected to the slop tanks. They must be fastened to prevent any movement during operation and their bodies must be earthed.  Main deck scuppers must be effectively plugged.  Drip trays must be empty and dry, their closing systems in place.  Any rain water accumulation on deck or in the drip trays should be drained off.  Unused cargo manifolds and bunker connections must be closed, blanked and fully bolted.  Pressure gauges fitted to the offshore manifolds should be regularly checked during cargo operations for manifold valve leakage.  Sea chest and overboard discharge valves, both in the engine room and in the cargo pump room, when not in use, must be closed and fitted with numbered breakable seals (see Section 12.2.3 - § 12.2.3.5). Where fitted, sea chest blanks must be in place.  Forward lokers overboard line valves must be closed and sealed to prevent any accidental opening. 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 12.4 CARGO OPERATIONS  Impressed current cathodic protection: It is not necessary to switch the system off during cargo operations [ISGOTT/2006 – 17.5.2].  Tank washing lines may contain oil cargo. Valves must not be operated by unauthorised personnel. A special placard must be posted on board [ISGOTT/2006 – 11.5.10].  Fire fighting equipment should be correctly positioned and ready for immediate use. At least two fire-hoses, one forward and one aft of the cargo manifolds, must be connected to the fire main, which must be kept always under pressure. Two dry-powder or foam portable fire extinguishers must be conveniently placed near the manifolds. Foam monitors must be pointed toward the manifolds.  Emergency escape means, such as an off-side lifeboat, accommodation ladder or pilot ladder, should be kept promptly available. In case of an accident causing, or posing a threat of, pollution, activate procedures provided for by SOPEP and VRP (see Section 8.2). The Emergency and Special Conditions Checklists file (see. Section 8.3) is promptly available in the Cargo Control Room. 12.4.3 - PORTABLE EQUIPMENT The vessel is provided with the following portable equipment to be used in carrying out cargo operations: (i) Gas Meters [ISGOTT/2006 - 2.4 - 8.2] 1. - 2 - TANKSCOPES - Measurement of hydrocarbon vapours (%) in inert atmosphere. 2. - 2 - EXPLOSIMETERS - Measurement of LFL (%) in air. 3. - 2 - O2 METERS - Measurement of Oxygen concentration (0-21%). 4. - 2 - HAND PUMPS to be used in conjunction with specific gas tubes - Detection and measurement of toxic gas in ppm. 5. - 4 - PERSONAL GAS MONITORS (4 channels). It should be noted that the different gas testing functions can be incorporated into a multi-function measuring instrument. Gas measuring instruments 1, 2, 3 & 5 should be tested and calibrated in accordance with the manufacturer's instructions before the commencement of operations requiring their use. The gas that should be used for calibration and testing should be indicated on a label fixed to the instrument. Once a year they must be calibrated and re-certified ashore by an authorized (by the maker) Company or on board if the Ship is equipped with the certified calibration station. As for the Officers on-board training programme for portable gas meters use, test and calibration, see Chapter 5 - § 5.3.2.2(iv). (ii) Cargo gauging and sampling equipment [ISGOTT/2006 - 11.8] 1. - 3 - Tanksystem UTI (Ullage - Temperature - Interface) units. 2. - 1 - Tanksystem SAMPLER UTI units should be landed once a year to be factory-checked, calibrated and re-certified. As for the Officers on-board training programme for portable gauges use and checks, see Chapter 5 - § 5.3.2.2(v). 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 12.4 CARGO OPERATIONS (iii) Lack of operational gas meters In the case of a sudden lack on board of operational portable gas meters of the same type and function, due to unexpected circumstances, the following contingency plan should be followed:  The Master shall immediately inform the Company's Marine and Chartering Departments, copying the DPA.  The Company will arrange immediately for the renewal of the missing equipment, to be delivered on board on arriving at the first port of call.  Cargo operations will not commence until the new equipment has been received on board, checked and made operational.  Were an immediate supply not possible because of lack of time, unavailability, shipping or delivery problems and the like, the Company shall appoint a certified chemist, duly authorized by the Port State authority to carry out all necessary checks and measurements, remaining on board the ship throughout her stay. 12.4.4 – CARGO MEASUREMENT AND SAMPLING - TANKS INSPECTION [ISGOTT/2006 - 11.8 - 24.4] Cargo measuring and sampling and tanks gauging and dipping should always be carried out in closed conditions, using the specially fitted vapour locks and relevant equipment, and reduceing, if necessary, the IGS pressure. Opening of tank hatches and sighting & ullage ports (where fitted), as well as any other working or access openings (BTW, manholes), is not acceptable. Any request in the contrary by terminal personnel and/or surveyors must be rejected and both the Company’s Chartering Department and the DPA should be immediately notified by the Master. Ullage obtained by Fixed gauge system (radar) for Cargo Tanks must be compared with potable tape gauges (UTI) at least every two months, in the occasion of cargo gauging operation on completion of loading or before discharging. The results of check must be recorded in the Cargo Control Room Log Book Part II Technical Check – Section 2 f. Visual inspection of inerted cargo tanks is not acceptable. Inspection of gas-freed tanks is subject to the Enclosed Space Entry Permit procedure (see Section 12.8, § 12.8.10.3.1). Special precautions need to be taken when handling cargoes containing toxic substances, as per relevant MSDS (see § 12.4.1.1). Specifically, all persons assigned to measurement and sampling operations on deck must:  Wear a personal gas monitor.  Be equipped with an EEBD. 12.4.5 – CARGO OPERATIONS Cargo operations must be carried out under the responsibility of a duly certified Deck Officer, in accordance with STCW 95 (as a rule, the Chief Officer), being familiar with the ship’s cargo system. Cargo operations should be recorded in the Cargo Control Room Log-book - Part I – Record of Operations and in the Oil Record Book – Part II (see section 12.3 - § 12.3.2). 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 12.4 CARGO OPERATIONS 12.4.5.1 - Pre-arrival technical checks Before arriving at a loading or discharging terminal, Ch. Engineer and Ch. Officer should jointly carry out all preliminary tests and check as detailed in the Cargo Control Room Logbook - Part II – Technical Checks, where their results shall be logged. If, during discharge, a CO washing of cargo tanks has been planned, checks and tests should be carried out in accordance with the COW checklist contained in the approved ship’s COW Manual. 12.4.5.2 – Mooring 12.4.5.2.1 General Safety Mooring and unmooring operations, including the handling of tugs lines and anchoring, are potentially dangerous operations. Such operations must be carried out under the instructions of a responsible and experienced officer who has direct contact with the bridge. Proper precautions must be observed at all times so as to prevent accidents. The following are some simple but important notes of guidance: • Always use appropriate Personal Protective Equipment including safety helmets, safety shoes and gloves. Safety goggles are to be worn during anchoring. • Stand clear of all lines when under load. • Watch your feet. Do not step into a coil or loop. • Always ensure that a winch operator can see the person in charge. • Do not leave winches or windlasses running unattended. • Ensure all equipment is operational and well maintained. • Mooring areas are to be free from obstructions and litter and must be adequately illuminated at night. • Safety devices for mooring power supplies (such as spray shields for hydraulic equipment or electrical cut- offs for electric motors) are in place and operational. • When making synthetic fibre ropes fast to bitts, do not use a “figure of 8” alone to turn them up. Use two round turns (but no more) around the leading post of the bitts before “figure of eighting”. This method allows better control of the rope, is easy to use and is safer. It also prevents an effective reduction in SWL caused by the compressive forces imposed by figure of eighting. • The relevant publications are to be consulted for more comprehensive guidance on safe mooring. Risk Assessments are required to be carried out for all mooring operations to ensure that risk to personnel involved in mooring is reduced as far as practicable by taking into consideration equipment, arrangement and layout. These risk assessments are to be kept on file and can be re-used subject to review prior to the operation taking place. 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 12.4 CARGO OPERATIONS 12.4.5.2.2 Mooring Management Good ship mooring management requires a thorough knowledge of mooring principles as well as knowledge about the safe operation of the equipment on board. Particular attention must be given to the correct application of winch brakes as well as the maintenance of moorings, brakes and associated equipment. A key element in safe and successful mooring is planning. Planning must take into account not only the mooring layout of the vessel and the berth but also the prevailing and expected conditions of the weather, tide, currents and traffic movements. This information should be obtained by any means including radio information, nautical publications and advice from port authorities/traffic management centres. During mooring operations there must be sufficient personnel at each mooring station to carry out the operation safely and effectively. The safe mooring of a vessel also requires close co-operation between the ship and the shore. Mooring arrangements and planning are to be discussed with the pilot before coming alongside and the information relayed to the officers in charge of the mooring stations. When planning a mooring operation ensure that ropes and wires are not used on the same leads or bollards and that they do not cross in contact with each other. Wherever possible, mooring lines shall be of the same size and type. However where this is not possible, then all lines in the same service should be of the same material (e.g. spring lines all wire and breast lines all synthetic). Mooring equipment must be operated by competent persons and care must be taken to ensure that excessive loads do not arise on moorings. Personnel must never stand in rope bights and when moorings are under strain must not stand in “snap back zones”. Operators must be prepared to immediately slack back any line which comes under excessive strain and to this end care must be taken to ensure that lines do not become jammed. Inexperienced personnel must be carefully supervised. Before entering a port (if weather permits) and prior to sailing, a mooring systems survey is to be carried out. This survey is to be carried out by the Chief Officer and must include a full visual examination of the emergency towline (if fitted), the anchor releasing mechanism and the mooring lines. In addition, all winches are to be tested and where applicable oil levels checked. The overall mooring pattern naturally effects the load distribution to individual lines. Excessive loads in individual mooring ropes can lead to straining or even eventual parting of a mooring line and must be avoided. In general, the mooring pattern should be symmetrical with good, efficient leads so as to ensure a balanced load distribution among the lines for varying wind and current conditions. Mooring management is also important while the vessel is alongside, and it is essential that the vessels staff obtain the latest tidal, weather and traffic movements from relevant sources. Regular rounds are to be carried out and moorings tended as required. Moorings are to be tightened or slackened in such a way that ensures the ship does not move position or comes off the fenders or quayside. Adjustment must also ensure that severe loads are not placed on individual lines. Tides are to be calculated to determine both the height and times. Where a large tidal change is expected, additional crewmen are to be placed on duty in order to tend to the moorings, particularly when the ropes or wires are turned up on bitts. Failure to have sufficient hands on deck may result in the vessel coming off the quay and breaking away. In extreme tidal situations, consideration is to be given to stopping cargo so that personnel can concentrate on the mooring operation at the change of tide. 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 12.4 CARGO OPERATIONS Where there is a danger of losing control of moorings, cargo operations are to be halted, the Master advised and additional crew called to assist. The Master has the authority to call for tug assistance should he feel that the situation requires this. 12.4.5.3 - Information exchange - Planning In order to organze and plan cargo operations, a preliminary exchange of information should take place between the ship’s personnel and the terminal and Shippers/Receivers representatives. (i) Loading Shore – ship information: - Cargo specification and characteristics, nominated quantity, loading temperature; - delivery of MSDS of cargo to be loaded; - number and size of hoses/arms; - offered loading rate; - vapours venting method (mast-riser or VRS); - ship/shore communications; - required notice for final ship’s stop; - emergency stop signals; - any spacial data or requirement. Ship – shore information: - last cargoes carried, tanks cleaning, conditions of cargo tanks and lines; - slops on board, either to be landed or LOT; - required cargo quantity; - required rate of loading; - loading sequence (more than one parcel), cargo distribution on board; - loading stopped by shore or ship; - any spacial data or condition. (i) Discharging Shore – ship information: - Number and size of hoses/arms; - maximum rate of discharge and pressure at manifolds; - unloading sequence (more than one parcel); - ship/shore communications; - advanced notice of completion; - emergency stop signals; - any spacial data or requirement. Ship – shore information: - Quantity and temperature of cargo; - cargo distribution on board; - cargo tanks inert conditions; - planned rate of discharge; - COW performance; - time required to make the ship ready to sail after completion of discharge; - any spacial data or condition. (iii) - Planning of operations A detailed plan should be drawn up following the guidance given in the approved manuals Stability Information for the Master and Loading Manual for Longitudinal Strength (see Chapter 14, § 14.5), to be kept available in the cargo control room throughout the operations. The plan shall be worked out and completed 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 12.4 CARGO OPERATIONS by the Ch.Officer, verified by the Master, and signed by all Officers of Watch to indicate their understanding of it.Documentation on loading conditions are archieved and available on board. Loading conditions with minor deviations between actual and allowable loading (e.g. 1% variation by weight in cardo and ballast tanks and 2 cm on GM/KG) are subject to approve by Technical Department. The plan shall contain the following information: - Ship’s name, berth, date and time. - Name and signature of ship and terminal responsible persons. - List of personnel on duty. - Cargo quantity, grade(s) and parcels to be loaded/unloaded. - A plan of the distribution, lines and pumps to be used. - Opening or closing ullages. - Density, temperature and other relevant properties. - Shore lines to be used. - Loading/discharging rate. - Initial start-up rates and Notice of rate change. - Maximum allowed pressure. - Temperature limits. - Sequence of loading/discharging and simultaneous deballasting/ballasting and bunkering (if carried out simultaneously). - Drafts and Trims, stability and hull stress conditions at various stages of operations. - Vapours venting or recovery systems. - Critical stages of the operation. - Emergency stop procedures. - Emergency spill procedures and spill containment. - Hazards of the particular cargoes. - Precautions against static generation. - Control of cargo heating system. - Crude oil washing procedures. - Line clearing. - Under keel clearance limitations. - Bunkering. - Special precautions required for the particular operation. 12.4.5.4 - Carrying out cargo operations Operations should be carried out in accordance with provisions of Oil Transfer Procedures for Cargo Operations, as planned and agreed with the terminal. (i) Loading and discharging [ISGOTT/2006 – 11.1] Loading and discharging operations should always be carried out in closed conditions. 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 Section 12.3 - § 12.3.5.3 and Chapter 14 - § 14.5). Information on maximum permissible loading rate must be available and displayed in the cargo control room. Whenever, for whatever reason, cargo operations are stopped, ship’s manifold valves shall be closed and deck lines shall be drained by dropping them back into suitably low tanks. (ii) Trim, stability and hull stress conditions [ISGOTT/2006 – 11.2] Trim, stability and hull stress conditions of the vessel in the various stages of loading and discharging operations, previously calculated and included in the plan, should be regularly monitored by means of the cargo control room computer, connected on-line with the cargo and ballast continuous measuring systems. In 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 12.4 CARGO OPERATIONS case these systems become unavailable or disconnected, gauges shall be taken by portable equipment at hourly intervals, and shall be entered manually in the computer. Any limitation contained in the approved stability and loading manuals, as well as ship specific procedures for restoring stability in case of unstable conditions developing during cargo operations, must be posted in the Control Room. (iii) Crude Oil Washing (COW) [ISGOTT/2006 – 11.5] COW operations must be carried out following the instructions supplied by the ship's COW Manual. Particularly, all preliminary tests and checks must be carried out, using the special COW Checklist contained in the manual. As a rule, Charterparties for the carriage of crude oil require a complete COW of all cargo tanks, provided that the cargo carried is suitable for such operations. List and characteristics of non suitable cargo types are contained in the COW Manual. Apart from commercial requirements, the following criteria must be followed in choosing cargo tanks to be COWed on board SBT tankers before departure on a ballast voyage (IMO COW Systems - I/6.1; see Chapter 6, appendix - # 206): - Cargo tanks intended to carry heavy weather ballast must be completely washed. - In addition, approximately one quarter of all remaining tanks shall be washed for sludge control on a rotation basis. However, for sludge control purposes, no tank need to be washed more than once in every four months. 12.4.5.5 – Inert Gas System (IGS) [ISGOTT/2006 – 7.1, 7.2] Cargo tanks are protected from the risk of fire by a fixed Inert Gas System (IGS), designed and operated as to render and maintain their atmosphere non-flammable (inert), as per SOLAS 74/78 – II-2/4.5.5 requirements. - Inerting – Tanks should be inerted (O2< 5%) before using them to carry an oil cargo. - Maintaining inertization – Either by topping them up with gas whenever their inner pressure drops below a fixed limit or, while discharging, by deliverying inert gas to the tanks being emptied, so that the space left by the outgoing cargo will be occupied by the incoming gas. - Purging – When, after discharging, cargo tanks contain toxic gases (see § 12.3.5.3(b)), or flammable gas in such quantity to exceed the critical diluition line so to render them potentially dangerous, they should be expelled by purging the tanks with inert gas. - Venting – Vapours (gas mixtures) contained in the cargo tanks are vented to the atmosphere trough special fittings (individual HV valves, common mast riser). - Vapour Control System (VCS) – Some Port States do not allow a direct venting of vapours and provide special shore installations to receive and dispose of them. All Company’s ships are fitted with a Vapour Control System to be used to convey vapours to the shore installations through the IGS main connection (see § 12.3.5.3(a)). The main vapour collection line is fitted with a pressure sensing device. Its high and low pressure alarms should be set at the following values (see 46 CFR 39.20-13): - High pressure: Not more than 90% of the lowest pressure relief valve setting in the cargo tanks venting system. - Low pressure: Not less than four inches water gauge (100 mm/WG). Protection of cargo tanks structures against damages caused by pressure or vacuum is achieved in accordance with requirements of SOLAS 74/78 – II-2/11.6:  Primary means: Individual combined H/V vents and Vacrel valves are directly fitted to all cargo and slop tanks (Regulation 11.6.3.2).  Secondary means :individual pressure sensors, parts of the fixed tanks gauging system, are fitted to all cargo and slop tanks giving audible and visible alarm of abnormal pressure changes. 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 12.4 CARGO OPERATIONS Individual pressure sensors should be set at the following values: - High pressure: Not more than 10% greater than the normal actuating setting of the cargo tanks H/V relief valves. - Low pressure: Not less than zero (>0). . Additionally means: All cargo and slop tanks are connected by branch lines and valves to the IG main and to the common ship’s P/V Breaker and Mast Riser (Regulation 11.6.1.2) Insulation of tanks. Valves connecting tanks to the IG main must be provided with positive locking arrangements, the keys of which must be under the control of the Chief Officer. Correct operation of the IGS and VCS is detailed in the special manuals, available on board all ships (see Chapter 14 - § 14.5). Preliminary tests and checks of the IGS should be recorded in the Cargo Control Room Log-book – Part II. 12.4.5.6 - Entering pumproom [ISGOTT/2006 – 10.10) Because of their location, design and operation which require the space to be routinely entered by personnel, pumprooms necessitate special precautions. Best practice show a clear requirement for a document to control pumproom entry which may not be the usual Enclosed Spaces Entry Permit (OCIMF – Guidelines for Hot Work and Entry into Enclosed Spaces – 1 st Ed. 09/2008). Actually, some basic requirements of the entry permit cannot be met for obvious reasons in the case of an operational pumproom. Particularly: - The preliminary blanking off or isolation of all connecting pipelines, and the securing of valves on all pipelines serving the space cannot be carried out. - The indication of the maximum period of validity of the permit cannot be set in advance because the internal conditions of the space can suddenly change at any moment. The frequency of pumproom entry for routine inspection purposes during cargo operations should be critically reviewed with a view to minimising personnel exposure. The following procedure should be strictly followed (see also the special notice posted in the cargo control room): - In addition to the prescribed Emergency Escape Breathing Device (EEBD) permanently positioned on the pumps flat, a self contained air breathing apparatus must be located at entrance of the pumproom. - Tackle and stretcher for recovering an injured person must be rigged ready for use. - The ventilation system must be kept running. - The fixed hydrocarbon gas detection system must be working normally. - Before beginning cargo operations, a preliminary check of the pumproom atmosphere (O2, LFL, Toxic gas) must be carried out and its results must be recorded in the Cargo Control Room Logbook – Part I. - Entry must be ordered or authorized by a responsible Officer and must be recorded in the Cargo Control Room Logbook – Part I. - One person must be stationed at the entrance, connected by portable UHF radio with pumproom, cargo control room and/or bridge. - The person entering the pumproom must carry: Personal gas monitor (4 channels) Portable UHF radio Flashlight. - Notices and symbols ENTRY PROHIBITED TO UNAUTHORISED PERSONS must be displayed at the entrance. Additional checks of the pumproom atmosphere (O2, LFL, Toxic gas) should be regularly carried out during cargo operations and their results must be recorded in the Cargo Control Room Logbook – Part I. 12.4.5.7 - Precautions against the risks posed by static electricity 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 12.4 CARGO OPERATIONS Precautions and safety measures to be observed to prevent the risk caused by the generation of static electricity during loading and discharging operations are described in Chapter 3 of ISGOTT/2006. 12.4.5.8 - Inert Gas System breakdown In case of IGS breakdown during discharge, operations should be immediately stopped and shall not resume until the system operation has been restored or an alternative source of inert gas from shore installations has been provided (see Emergency Checklist No. 15 – Inert gas failure during discharge). On the extreme hazard of introducing atmospheric oxygen into inerted cargo tanks containing crude oil, continuing their discharge without a working IGS, because of the presence in them of Pyrophoric Iron Sulphide, see Chapter 2 - § 2.6 of ISGOTT/2006. 12.4.5.9 - Immediate stop of operations Cargo operations must be stopped immediately in the following cases (see also the special notice posted in the cargo control room): - Inert gas system failure or malfunction during discharge. - O2 content in inert gas deck main over 5% during discharge. - Presence of flammable gas in cargo pumproom during discharge. - Cargo tanks overfill (98%) alarm. - Toxic gas release to the atmosphere. - Unexpected list of the ship. - Leakage or risk of leakage from cargo system. - Abnormal strain on cargo hoses/arms. - Fire or risk of fire on board. - Fire or risk of fire ashore or on board other vessel/barge alongside or in proximity. - Thunderstorms with lightning. - Break of moorings. - Loss of communication with terminal during discharge. 12.4.5.10 - Ship-to-ship (STS) operations [ISGOTT/2006 - 11.9] Ship-to-ship cargo transfer operations (not from offshore installations, FPSO FSU and for bunkering) should be carried out in compliance with the ship's STS Operations Plan required by MARPOL 73/78 - I/8.41 (see Chapter 14 - § 14.5), containing all appropriate operational instructions and the checklists to be used as required. The Coastal State in whose waters STS operations will be carried out must be notified in advance by the Master or the local agent, as required by MARPOL 73/78 - I/8.42. The notification shall include:  name, flag, call sign, IMO number and estimated time of arrival of the oil tanker involved in the STS operation;  date, time and geographical location of the commencement of the planned operations;  whether operations are to be conducted at anchor or underway;  planned duration of the operations;  identification of the operations service provider or person in overall advisory control and contact information; and  confirmation that the oil tanker has on board an STS Operations Plan meeting the requirements of regulation I/8.41. Notification must be updated for any difference in the estimated time of arrival exceeding six hours. During STS operations, the ship must be ready to move at any time, with both Navigation Bridge and Engine Room permanently manned (see Section 12.2.3, § 12.2.3.4(iv). All details of the STS operations should be logged in the Navigation Logbook (GN/III), in the Engine Logbook and in the Master's General Logbook (GN/II), and should be recorded in the Oil Record Book – Part II and in the Cargo Control Room Logbook - Part I. Useful advice on STS operations is also contained in the ICS/OCIMF publication Ship to ship transfer guide (Petroleum) (see Chapter 6 – Appendix - # 209). FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 14 of 17 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.4 CARGO OPERATIONS 12.4.6 – TANK WASHING, GAS FREEING AND CLEANING [ISGOTT/2006 - 11.3, 11.4] Cargo tank washing, gas freeing and cleaning operation must be carefully planned. Potential hazards should identified, risk assessed and all appropriate preventive measures put in place (see Chapter 12 and the Risk Assessment Plan). The following portable measuring instruments must be checked, calibrated and kept ready for use: a) O2 meter; b) Tankscope c) Explosimeter d) Hand pump and tubes for toxic gas detection and measure. 12.4.6.1 - Tank washing The following precautions should be taken before commencing washing operations: - Tanks to be washed should be stripped dry, collecting all liquid oil remnants in the “dirty slop tank”. - Tanks inertization must be checked by portable O2 meter both at a point 1 metre below main deck and at its middle level. At neither of these locations should the oxygen content exceed 5% by volume. If necessary, the tanks should be “topped up” with IG until the above condition is reached. - Tanks to be washed must be at positive IGS pressure. - In case portable washing machines are being used, their water hoses must be checked for continuity. In no case should their electrical resistance exceed 6 ohm per metre length. During washing: - Measures must be taken to check that the atmosphere in the tanks remains non-flammable (O2 < 5% by volume) and at a positive pressure. - If the oxygen content in the tank exceeds 5% by volume, or its inner pressure is no longer positive, washing must be stopped until safety conditions are restored. - As a general rule, chemicals should not be used for tank washing. Were it necessary to use them, for commercial or special reasons, the master shall consult in advance the Company’s Technical Department (UT) and obtain all appropriate instructions. - Washing must be carried out in “closed circuit” conditions. Washings and oil residues must be collected and remain segregated in the slop tanks for further disposal in accordance with the requirements of MARPOL 73/78 – Annex I (see Section 12.3). Washing operations and disposal of waters and slops must be recorded in details in the Oil Record Book – Part II (see Section 12.3 - § 12.3.2). 12.4.6.2 - Gas freeing On completion of washing operations, cargo tanks contain a considerable amount of hydrocarbon vapours making their atmosphere higly flammmable, as well as toxic gas. a) Purging: - Tanks must first be purged with inert gas to reduce their hydrocarbon vapours content to 2% or less by volume, to ensure that, during the subsequent ventilation, no portion of the tank atmosphere is brought within the flammable range. - Tanks must be purged with inert gas also for taxic gas. - Venting of expelled vapours shall be through high-velocity (H/V) valves. Purging of tanks should be regularly monitored measuring their hydrocarbon vapours content by the tankscope b) Ventilation  Tanks ventilation may be started only when, inside them: FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 15 of 17 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.4 CARGO OPERATIONS - the hydrocarbon gas content, as measured by tankscope, is no more than 2% by volume, and - the quantity of any toxic gas, as measured by its special tubes, is below the Threshold Limit Value (TLV) as detailed in the MSDS of the last cargo carried (see previous § 12.4.1.1 and Section 12.8 - § 12.8.7.1).  Tanks to be gas freed must be isolated before starting their ventilation.  Venting of gas expelled must be through the special gas freeing covers.  Gas freeing progress must be regularly monitored at various levels by measuring the flammable gas concentration by the explosimeter.  A cargo tank may be regarded as completely gas free when: - its oxygen content is 21% by volume; - flammable gas concentration throughout it is less than 1% of the LFL; - there are no traces of toxic gas. Final measurements of these values must be carried out two times, with an interval of 10 minutes in between. 12.4.6.3 - Cleaning As for entering a gas free tank for cleaning and carrying out any works in its interior, see Section 12.8 – § 12.8.10.3 - Permits to work system. All cargo tanks washing, gasfreeing and cleaning operations must be recorded in the Cargo Control Room Logbook - Part I. Relevant preliminary technical checks must be recorded in the Cargo Control Room Logbook - Part II. 12.4.7 – BALLAST OPERATIONS [ISGOTT/2006 – 11.6) Safe entry procedures into the cargo pumproom are detailed in the previous § 12.4.5.6. 12.4.7.1 - Segregated Ballast As a rule, loading and discharging segregated water ballast is carried out simultaneously with the discharging and loading of cargo, and the operation is agreed in advance with the terminal and is planned together with cargo operations. This operation should be recorded, in conjunction with cargo operations, in the Cargo Control Room Logbook - Part I. Before commencing ballasting or deballasting at sea, it is necessary: (i) to check ballast tanks for flammable gas, using the fixed gas detection system and by portable explosimeter; (ii) to gauge the ballast tanks in order to check that the quantity of water ballast therein contained (loaded or umpumpable) remained unchanged; (iii) to carry out regular visual checks of the surface of the water contained or loaded in the ballast tanks, so to ascertain that it does not show any trace of oily materials. Such checks must be particularly accurate whenever the ballast tanks are adjacent to the fuel tanks or to the oil cargo tanks. While deballasting at sea, regular visual checks of the overboard water spout and of the surrounding sea surface must be carried out. 12.4.7.2 – Heavy weather ballast in oil cargo tanks When heavy weather conditions are expected, the Master shall consider the necessity to take on ballast water in the designated cargo tanks, in addition to the normal segregated ballast (see also Bridge Management Manual, Part I, § 2.1.1). The following procedure should be observed in taking on heavy weather ballast: ⇒ As a rule, the operation should be carried out alongside. In case the dock is not available the operation shall be carried out at a suitable nearby anchorage. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 16 of 17 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.4 CARGO OPERATIONS ⇒ During the previous discharge, tanks designated to contain water ballast should be full-cycle COW washed and thoroughly drained. ⇒ Lining-up of ballast transfer lines shall be carried out only after completion of all discharge, tanks check, hoses disconnection and manifolds closing operations. ⇒ Ballasting should be planned and carried out in accordance with instructions contained in the ship’s Procedure for Ballasting and De-ballasting Heavy Weather Ballast Tanks manual. ⇒ Taking on ballast water in cargo tanks may be started:  after Cargo Surveyors, having completed all tanks check, issued to the vessel the Dry Tank and ROB Certificates.  taking on segregated ballast water has been completed. ⇒ Gases contained in cargo tanks being ballasted must be vented through the IGS main and the Mast Riser. Cargo tanks not being filled shall be isolated from the IGS main. Subsequent discharge of heavy weather ballast from oil cargo tanks must be carried out in accordance with requirements contained in MARPOL 73/78 - I/34 (see Section 12.3 - § 12.3.2.2). Operations for loading and discharging heavy weather ballast water into/from the oil cargo tanks, both in port and at sea, must be recorded in the Oil Record Book - Part II and in the Cargo Control Room Logbook - Part I. 12.4.7.3 - Ballast Water Exchange at Sea Ballast water exchange at sea (see Section 12.3 - § 12.3.7) must be conducted in accordance with the ship's Ballast Water Management Plan. In compliance with current regulations, and in order to satisfy any Port State request, ballast water exchange must be recorded, besides in the Cargo Control Room Logbook - Part II, both in the Navigation Logbook (GN/III) and in the Master's General Logbook (GN/II). In case the exchange regards heavy weather water ballast carried in oil cargo tanks, such operation must also be recorded in the Oil Record Book - Part II. 12.4.8 – WORKING IN THE CARGO PUMPROOM [ISGOTT/2006 – 10.11) Safe entry procedures into the cargo pumproom are detailed in the previous § 12.4.5.6. All cleaning, maintenance and repair work are subject to risk assessment and must be carried out in accordance with Section 12.8 - § 12.8.10.3 - Permits to Work System. All entries in the pumproom as well as all operations therein performed must be recorded in the Cargo Control Room Logbook - Part I. 12.4.9 – CHECKS DURING PASSAGE The following checks and operations should be regularly carried out during passage: - Cargo tanks level – Ballast tanks level: Any variation should be promptly investigated and, if necessary, appropriate action shall be taken - Sounding of empty cargo and ballast tanks. Any abnormal condition should be promptly investigated. - Cargo temperature, when carrying a cargo which has to be heated or maintained to a given temperature, or any time that variations in cargo tanks levels are observed. - Cargo tanks inner pressure. IGS topping should be carried out whenever the pressures drops below 100 mm H2O. - Monitoring of ballast tanks and void spaces for flammable atmosphere. Empty or partially-filled ballast tanks, and void spaces adjacent to cargo tanks, should be checked for flammable gases (% LOL and innage) on a weekly basis. Results should be recorded in the Cargo Control Room Log Book - Part III – Ballast Tanks and Void Spaces. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 17 of 17 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.4 CARGO OPERATIONS - Detection and measurement of toxic gas in cargo tanks, as detailed in Section 12.3 - § 12.3.5.3(b). Results and details of any purging operation should be recorded in the Cargo Control Room Log Book - Part IV – Toxic Gases. 12.4.10 – KEEPING CARGO SAMPLES ON BOARD [ISGOTT72006 – 12.3] As a rule, sealed samples of all cargoes carried should be kept on board for a period of not less than 3 months from their discharge and delivery to the Receivers.  Samples should be kept in a locker or ship’s space in the cargo area, outside of accomodations and service spaces.  Consideration should be given to storing cargo samples in a location protected by a fixed fire-fighting system, such as a paint locker.  The space should be properly ventilated.  Expired samples should be disposed of in accordance with MARPOL 73/78 - Annex I (See Section 12.3). FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 1 of 6 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.5 SHIP IN PORT INDEX 12.5.1 Port Watch 12.5.1.1 – MOORING 12.5.1. 2 – SHIP ACCESS. 12.5.1.3 – USE OF PPE BY PEOPLE BOARDING THE VESSEL 12.5.1.4 – DUTIES OF THE OFFICER OF THE WATCH IN PORT 12.5.2 Communications 12.5.3 Crew Shore Leave 12.5.4 Loading Provisions and Stores 12.5.5 Ship Temporarily Immobilized FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 2 of 6 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.5 SHIP IN PORT 12.5.1 Port watch Watchkeeping arrangements in port should ensure: (a) safety of life, of the ship, of her cargo and of the port installations; (b) protection of the environment; (c) defence of security on board and ashore; (d) observance of international, national and local regulations; (e) maintaining the full efficiency of the ship. For safety reasons, the composition and workshifts of deck and engine watches during ship’s stays in port is the same as at sea. Performance of shipboard activities on normal day working hours, with a night watch for the remaining time, is allowed only when the ship is commercially idle, in safe conditions (as when the vessel is laid up in a shipyard for repairs and class survey). During port stays, the following rules must be always observed: (i) On arrival, the master shall ascertain any special requirement of the Port State as for the minimum number and the rank of persons to be kept on board. (ii) In any case, the master must arrange so that a sufficient number of crew members remain always on board in order to ensure the perfornmance of the following tasks: ◊ safety of shipboard activities and watch service, both on deck and in the engine room; ◊ emergency tasks. Specifically, the number of senior officers and crew available on board must be such that all necessary measures can be effectively taken in any emergency situation; ◊ performance of cargo operations; ◊ security of the vessel and shore installations; As for the safety rules to be observed during operational stays of oil tankers, see the previous Section 12.4. 12.5.1.1 - MOORING Before berthing, the terminal should provide the master, through the pilot or berthig master, with details of mooring plan. Berthing should be planned and agreed in advance. OCIMF publications Mooring Equipment Guidelines (MEG3), Effective Mooring and ISGOTT – Chapter 23 (see appendix to Chapter 6 of this manual) contain useful information about tankers mooring at oil-docks and SPMs. Special rules:  Do not use together, in the same service, lines of different material (mixed mooring).  As far as practicable, lines in the same service should lead parallel and be of the same length.  Wires should be operated with only one layer on the tension drum of the mooring winch (see MEG, fig. 7.1).  In making fast fibre ropes, one full turn should be taken on the leading post before starting to belay the bollard in figure of eight (see MEG, fig. 8.1).  Fibre tails and thair Mandal links can be damaged by chafing and contact with the shipside chocks, and should always be made tight overboard. When making fast by own lines to an FSU or for lightering operations, check that the fibre tails are shortened by belayng them around the bitts of the other ship (see MEG, fig. 3.14(a)).  Emergency towing-off wires (fire wires) rigged on the off-berth side of the ship, forward and aft, should be made fast to the bitts with at least 5 turns, and led directly to the shipside chock, with no slack on deck. They should remain suspended overboard and adjusted so to maintain their eyes 1 – 2 m. above the water (see MEG, fig. 3.15). FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 3 of 6 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.5 SHIP IN PORT  Some terminals require that ship’s anchors, when not in use, should be secured in the chain- compressors, to prevent their accidental release.This precaution should always be observed when moored at an SPM.  When shore moorings are used to supplement the ship’s moorings, their tending should be agreed in advance between ship and shore.  At SPM, an AB should be permanently stationed on the forecastle to watch and report mooring conditions and any leakage of oil. He should be equipped with portable UHF radio. Instructions on the action to be taken in case of break of moorings are contained in the Emergency checklist n.o 14 – Break away from jetty (see Chapter 8.7). 12.5.1.2 – SHIP ACCESS See Chapter 16 - § 16.4 of ISGOTT – 5th edition 2006. Particularly:  Whenever access means handrails (gangway or accomodation ladder) do not provide adequate protection, suitable safety nets must be rigged. This is the responsibility of the ship, regardless of whether the gangway is supplied by ship or shore.  Lifebuoys fitted with floating light and line must be be available in close proximity of access point. These floating lights must be of the intrinsically safe type.  A weather-proof container, duly marked by the appropriate IMO symbol, containing one copy of the ship’s Fire Plan and an updated crew-list must be loacted at the ship’s access point.  The following placard must be prominently displayed at the shore side of the access point, so as to be easily readable by incoming visitors. DANGEROUS CARGO ON HAND UNAUTHORISED PERSONS NOT ALLOWED VISITORS MUST SHOW IDENTIFICATION NO SMOKING – NO LIGHTERS OR MATCHES NO OPEN LIGHTS MOBILE PHONES MUST BE SWITCHED OFF  During darkness hours, means and points of access must be properly lighted.  As regards precautions to be taken and rules to be observed for supervising access to the ship and to identify and cheking-in visitors, see subsequent Section 12.7. Suitable installations (desk, shelter) shall be fitted in order to make easy the work of the personnel in charge of such duties. 12.5.1.3 USE OF PPE BY PEOPLE BOARDING THE VESSEL The vessel is always responsible for all accidents or dangerous situations which may happen on board, even if involving shore people, and it is the obligation of the Master and of the responsible Deck and Engineering Officers to ensure that all precautions and safe working practices are being followed by everybody. Visitors boarding the vessel through the terminal are generally screened in advance for safety at the entrance gate before being granted access to the installations. However, people belonging to barges, tugboats, etc., as well as people reaching the ship by launch, boarding from the offshore side, may find themselves in unsafe conditions because of lack of appropriate PPE. Appropriate precautions must be taken to prevent the occurrence of accidents on board, and the following procedure must always be observed:  All persons boarding the vessel, either through the shore gangway or from the offshore side by means of the accommodation- or pilot-ladder must be checked-in for safety and security FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 4 of 6 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.5 SHIP IN PORT in the usual way, and must be provided with the special identification badge sum-marizing on its back the basic ship’s safety information.  An adequate number of safety helmets, conspicuously marked VISITOR, must be kept ready at the check-in point. They shall be handed-over to all shore people boarding the vessel, not wearing their personal helmet, irrespective of their identity, position or function (agents, Company’s superintendents, surveyors, engineers, etc). The delivery must be recorded in the visitors record-book.  Crew members returning from shore leave must go directly to their accommodations using the shortest and safest way, well known to them, avoiding lingering on open decks or working areas.  Boarding of new crew members must be notified by portable radio to the Officer of the Watch. They must be escorted to their accommodations through the shortest and safest way, under the direction of their escorts. They shall be immediately briefed on the basic ship’s safety regulation and provided with their prescribed PPE before beginning any activity on board (see SMS manual – Chapter 5 - § 5.3.2.2(i)b.) 12.5.1.4 DUTIES OF THE OFFICER OF THE WATCH IN PORT Officer of the Watch shall co-operate with the Officer in charge of cargo and ballast operations. He must know their program, draft, trim and air-draft limitations (see Section 12.4), as well as tide and stream existing and scheduled conditions. Officer of the Watch must be aware of all bunkering and storing operations being carried out, as well as of the presence alongside the ship of any barges and transportation crafts. He shall identify all boarding people and have them escorted by one of the AB of watch, in case they need to contact the Master or other Officers, or to enter the accomodation area. Particularly, Officer of the Watch shall:  Make frequent checks of mooring conditions, particularly in ports where ample tide-level differences or strong streams exist, and whenever loading and discharging operations cause rapid changes in ship’s freeboard and trim conditions .  Ceck frequently the emergency towing wires (Fire Wires) rigged forward and aft: their eyes must be maintained at a distance of about 1 metre above the water.  Check working conditions of cargo hoses/arms; an AB equipped with a portable radio set shall be permanently stationed at the manifolds area.  Make sure that windlass and mooring winches are immediately available.  Be aware of any limitation to the immediate use of main engine and/or rudder.  Frequently check means of access to the ship (accomodation ladder, gangway), even if they have been supplied by the terminal.  Check traffic conditions in vicinity, particularly when the ship is moored alongside in rivers, canals or narrow passages.  Be aware of all activities being carried out on board and of the location of all personnel involved.  Make sure the compliance with all safety and pollution prevention rules.  Check scupper plug on deck.  Frequently check the water surface surrounding the ship for signs of pollution.  Check for smoke emissions. In case, notify immediately the Engineer of Watch or on Duty Service.  Between sunrise and sunset, make sure that national flag (at poop staff), courtesy flag (at the starboard end of mainmast yard) and signal flags are all correctly displayed.  During darkness hours, make sure of the good lighting of working areas on main deck and of the correct exhibition of all required light signals.  In case of unforeseen changes of weather conditions, or if storm warnings are received or notified on board, inform immediately the master. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 5 of 6 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.5 SHIP IN PORT 12.5.2 Communications On arrival. the master shall request all necessary informations to be able to contact the following shore organizations in case of need: ⇒ Harbour Master - COTP ⇒ Coast Guard ⇒ Teminal ⇒ Pilots – Tugboats ⇒ Agent. Information on all available communication means, together with instructions for their use, must be displayed on board as necessary. On board tankers, communications means agreed with the terminal, including telephone numbers and channels to be used, are part of the written exchange of information which must be carried out jointly by the ship and the terminal on arrival. (see Section 12.4). As for notifications to be made and contacts to be maintained with shore organizations in case of an accidents causing pollution or risk of pollution, see Section 8.2. 12.5.3 Crew Shore Leave During ship’s stays in port or at anchorages, personnel free from service (see § 12.5.1(ii)) may be authorized by the Master, through the CE or the CO, to go ashore on leave. Personnel shall hold the required Shore-pass issued by Port State authorities. Unauthorized people cannot leave the ship (Italian Working Agreement – Art. 11). A special notice board shall be posted at the gangway or accommodation ladder, stating ship’s next port of destination and the time to report back on board. All personnel on shore leave must return on board not later than the said time. For no reason the Master and the CO or the CE and the 2E are allowed to leave the ship together, as the availability of an experienced senior Officer, both on Deck and in the Engine Room, must always be assured. As for the consumption, both on board and ashore, and the introduction into the vessel of alcoholics and illegal drugs, see Section 12.8, § 12.8.6. 12.5.4 Loading Provisions and Stores The following procedure must be observed when receiving on board store and provisions, both in port and at an anchorage:  Consistently with the ship’s schedule and operational activities, the Master shall require all parts involved (Agents, Suppliers, Shipchandlers, etc.) to arrange the supply of any kind of stores and provisions to his vessel during daylight hours.  When alongside, storing operations must be approved in advance by the terminal.  A Deck Officer must be appointed by the Master as responsible person for storing operations, even when taking on Engine Department stores. He must be able to communicate clearly with the shore people and to supervise the activities both on board and on the shore/barge side.  Sufficient crew must be in place to effect safe storing, including a dedicated ship’s crane/hoist operator.  Cargo nets must be rigged overboard to prevent any fall of objects into the water or on the dock.  Suppliers to provide MSDS for any hazardous or potentially hazardous materials.  As for security checks of stores being supplied to the vessel, see Section 12.7. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 6 of 6 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.5 SHIP IN PORT  Any fall of stores overboard must be reported to the local Agent and, if appropriate, to the terminal, unless they have been immediately recovered by the crew or the shore/barge people, and no pollution whatsoever occurred.  Non-pollutants or harmless stores, once fallen overboard, must be considered as “garbage” and their recovery must be arranged immediately.  Loss or spill of pollutant or hazardous goods, like oils, chemicals, paints, etc. must be immediately notified in accordance with SOPEP and/or VRP, and relevant procedures must be activated.  As a basic rule, the Master must always notify by telephone all such accidents to the Company’s Shoreside Spill Co-ordinator (First Contact), or his substitute. 12.5.5 Ship Temporarily Immobilized Maintenance or repair works affecting main engine or the ship’s power generation capacity during an operational stay in port must be agreed in advance with the Technical Department (UT) of the Company and authorized by Port State authority, on condition that all required safety rules are strictly observed. A complete risk assessment must always be performed (see Chapter 12 and Risk Assessment Plan). Main precautions: ⇒ On final judgement of the Master, the whole crew must be kept on board. ⇒ The ship must be in good seaworthy trim (draft, trim, stability). ⇒ The ship must be safely moored. ⇒ Were it necessary to suspend cargo operations:  Cargo hoses/arms must be disconnected and their manifolds blanked.  Before stopping IGS plant, check inertization of all slop and cargo tanks, topping them off as necessary, and then isolate them singularly from gas main.  In case of lack of water supply to the deck-water-seal, gas main must be secured by locking in shut position the non-return valve and closing and padlocking the main isolation valve.  If in use, the vapour recovery sistem must be disconnected from the shore installations and its connection blanked. ⇒ Were ship’s fire-fighting fixed equipment out of service:  Connect the ship’s fire water main to the shore water system, using the international shore connection if necessary, and keep it permanently pressurized.  Keep ready for immediate use all fire-fighting mobile equipment, repositioned as necessary, particularly in areas interested by the repairs.  Organize and maintain an effective fire patrols service in all ship’s spaces. 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 SECTION 12.6 PREPARING FOR SAILING INDEX 12.6.1 Checking the crew on board 12.6.2 Security of the ship and the port 12.6.3 Documents – Clearance 12.6.4 Requesting port services 12.6.5 Checking weather and safety conditions at sea 12.6.6 Technical checks and tests 12.6.7 Fuel distance 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 SECTION 12.6 PREPARING FOR SAILING 12.6.1 Checking the crew on board All crew must report on board at the time specified by the Master, as shown on the special placard posted at the ship’s access point, as a rule, at least two hours before the estimated sailing time of the ship.. Before departure time, Chief Engineer and Chief Officer shall check that all personnel belonging to their respective Departments is present on board, and shall report that to the Master. Any case of unjustified absence from the ship, both in national and foreign ports, must be immediately notified to the competent authorities, both national (Harbour Master or Consulate) and of the Port State (Immigration Service) through the local ship’s Agent, and directly to the DPA, the Crewing Manager and the Manning Agent. The master must check that all crew members listed in the ship’s Minimum Manning Certificate are actually on board. Failing that, he must request the Crewing Manager for the prompt replacement of the missing persons, so to enable the ship to sail in safe conditions. 12.6.2 Security of the ship and the port As regards the precautions to be taken and the rules to be observed in order to assure the security of the ship and the port, particularly the inspections to be carried out on board before sailing, see the following Section 12.7. 12.6.3 Documents – Clearance Before sailing, the master must personally make sure to have on board: ⇒ All ship’s documents and papers, in regular course of validity. Particularly, he must ascertain that documents sent ashore for inward clearance or to be renewed/endorsed, have all been returned on board. ⇒ A complete set of documents pertaining to the cargo loaded addressed to the Consignees, as per Charterers instructions, plus a second one for ship’s use. ⇒ Passports and/or discharge books of all crew members. ⇒ Passports of any passengers or technicians on board ⇒ All statutory logbooks duly issued and endorsed by Flag State. According to Italian law in force, by applying for the outward clearance, the master declares, even by default, on his own responsibility “having fulfilled all safety, police, health, fiscal, customs and contractual obligations”. On receiving the outward clearance, deli-vered on board by the Agent, the master must check that it has been issued for the destination port he declared, and that all ships data therein contained are correct. 12.6.4 Requesting port services On arrival, the Master shall obtain from the local Agent all information on the procedure to be followed and the advanced notice to be given in requesting the port services (pilots, linemen, tugs) necessary for sailing. Port services shall be requested in accordance with instructions received. As soon as their availability has been confirmed and the time of sailing has been set, the Master shall inform both the CE and the CO (ready to move). 12.6.5 Checking weather and safety conditions at sea Availability of recent informations on the weather and safety conditions in the sea area the vessel will sail through after departure have a paramount importance for a safe sailing. 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 SECTION 12.6 PREPARING FOR SAILING GMDSS Officer is responsible to receive and collect all safety informations arriving on board during the ship’s stay in port (see Section 12.2, § 12.2.2.2): ⇒ NAVTEX:  Continuous automatic reception of local weather reports and warnings.  Continuous automatic reception of local navigational warnings. ⇒ INMARSAT-C EGC SafetyNET:  Continuous automatic reception of weather reports and warnings of METAREA.  Continuous automatic reception of navigational warnings of NAVAREA. ⇒ Meteofax – CHARTCO MetManager:  Scheduled reception of meteorological charts. The GMDSS Officer shall place at the disposal of the Officers of the Watch on the navigation bridge:  The latest weather reports;  the latest meteorological charts;  all gale/storm warnings in force;  all navigational warnings in force. During ship’s stay in port, the Master must always be immediately informed of the reception of any gale/storm warnings, or any particularly important navigational warnings (like new dangers to navigation, air or naval exercises, etc). 12.6.6 Technical tests and checks to be performed before sailing Tests and checks to be carried out within 12 hours before departure are required by the following national and international rules: ⇒ D.P.R. 8.11.91, n. 435 – Rules for the safety of navigation and human life at sea. – Regolamento per la sicurezza della navigazione e della vita umana in mare. – Articles 229 and 230. ⇒ SOLAS 74/78 – V/26. ⇒ 33 CFR 164.25. Tests and checks are listed on a special placard on the Navigation Bridge and in the Engine Control Room, and they are detailed in the ship’s Drills Log Book (operations 1.1 and 1.2) in which they shall be recorded, as well as in the Nautical Log – Book II and Book III, and in the Engine Log Book. The following checklists shall be used: • Navigation Bridge (see BRIDGE MANAGEMENT MANUAL, I/4):  Pre-departure Check List. • Machinery space (see Section 12.2.3, § 12.2.3.2):  Engine Room Pre-departure Check List  Steering Gear Check List. 12.6.7 – Fuel distance Before beginning a voyage the Master, with Chief Engineer’s advice, should make sure that the ship’s bunkers are enough to ensure a sailing range allowing: (a) to perform the planned voyage, with a minimum safety margin of 20%; (b) in case the voyage lasts for less than 10 days, the minimum safety margin must be 2 days of steaming. The Master should arrange the ship’s refuelling program in conjunction with the Company’s Chartering. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 1 of 6 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.7 SHIP SECURITY 12.7.1 FOREWORD Particular situations and events of a criminal nature represent a serious treat to the ship’s security, both in port and at sea. It is therefore imperative that suitable preventive measures are taken, also in co-operation with port and coastal States authorities. The most common of such situations are:  Stowaways  Drugs smuggling  Piracy  Terrorism. 12.7.2 INTERNATIONAL RULES Rules on the security measures to be adopted both on board ships and in ports are contained in the SOLAS 74/78 – Chapter XI-2 – Special measures to enhance maritime security and relevant International Ship & Port Facility Security (ISPS) Code. 12.7.2.1 – Company Security Officer (CSO) - (ISPS Code – A/11) The Company should designate a Security Officer (CSO), responsible for ensuring that a ship se- curity assessment is carried out; that a ship security plan is developed, approved by the Administration, and therefore implemented and maintained on board ships, and for liaison with the Ship Security Officer (SSO) and Port Facility Security Officers (PFSO). He should be trained in accordance with ISPS Code – A/13.1, and with the Maritime Security Programme devised by Flag State Italy Administration. The CSO is identified in Chapter 3 – Appendix, item f), of this manual. 12.7.2.2 – Ship Security Officer (SSO) - (ISPS Code – A/12) The Company should designate a Security Officer (SSO) on board ships, accountable to the Master, responsible for the security of the ship, including implementation and maintenance of the ship security plan, and for liaison with the CSO and PFSO. The SSO should be trained in accordance with ISPS Code – A/13.2, and with the Maritime Security Programme. 12.7.2.3 – Ship Security Plan - (ISPS Code – A/9) All ships should carry a plan developed to ensure the application of measures on board the ship designed to protect persons on board, ship’s stores or the ship itself from the risk of a security incident. The plan should be approved by the Flag State administration. The content of the plan is in accordance with ISPS Code – A/9.4. The plan should be protected from unauthorized access or disclosure. It is the responsibility of the SSO to keep the plan and the related documentation in a safe place on board, known and acces- sible only to the Master and to himself (ISPS Code – A/9.7). Ship security plans are not subject to inspection by officers duly authorized by a Contracting Gov- ernments to carry out controls on board (PSC). Permission to inspect the plan may be granted by the Flag State, through the CSO (ISPS Code – A/9.8, 9.8.1). 12.7.2.4 – Ship Security service documentation - (ISPS Code – A/10) The following records and files addressed in the ship security plan shall be kept on board:  Security Record Book.  Security equipment inventory.  Drills Logbook.  Visitors Record Book. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 2 of 6 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.7 SHIP SECURITY  Security checklists file.  Security messages file. The security documentation should be protected from unauthorized access or disclosure, kept by the SSO in the same way as the ship security plan (ISPS Code – A/10.4). 12.7.2.5 – Conformity to rules Conformity to the SOLAS 74/78 – XI-2 and to the ISPS Code are certified by the International Ship Security Certificate (ISSC) which should be carried by all ships. The complete file of all Continuous Synopsis Records (CSR) issued by the Flag State Administration in compliance with SOLAS 74/78 – XI-1/5, should also be carried on board (see Chapter 14 - § 14.2). 12.7.3 ADDITIONAL SECURITY PROCEDURES All ships are fitted with the the BIMCO publication The Ship’s Master Security Manual, to be used for reference and advice, particularly in cases or situations involving stowaways and drug smuggling (See Annex to chapter 6 - # 116). 12.7.3.1 – Keeping weapons on board Apart from placing the crew at a serious risk, weapons on board detract the Master and the Officers from their authority and jeopardize their capability to exert the rightful full control over the vessel. The Company strictly prohibits all crew members, as well as all people that for whatsoever reason are admitted or carried on the vessel (apart from local law-enforcing authorities and security protection forces provided by Italian D.L. 12.07.2011, n. 107 – art. 5) from bringing and keeping on board any fire-arms and edged weapons and any type of ammunitions. This exception of the aforesaid prohibition has been superseeded by “ the Italian Defence Minister decree dated 01.09.2011 which clearly identify the hight risk areas for the presence of piracy, followed by the agreement dated 11.10.2011 between the defence Minister and Italian Owners Association for the embarkation of the “ Governement military personnel “ on board the Italian flag vessels, as well as the imbarcation of “ Privately contracted armed security personnel ” by the issued of Italian decree dated 28.12.2012 n.266 and Home Affairs regulation. All procedures to enforce the said new regulations about the use of the weapons against any piracy attack has been included in the ship security plan. It is hereby stresseded that any authorization to carry arms (Shooting licence) issued by State Authorities to private citizens are not valid in foreign Countries and on board ships, and that keeping and carrying weapons, even in small quantity, on board ships, both national and foreign, calling at Italian ports or merely sailing through the Italian territorial sea, are subject to restrictions and declaration (D.L. 09.07.1999, n. 185). - In port, new crew members and people boarding the vessel should be checked for weapons as detailed in the Ship Security Plan. - At sea, in case the Master finds that a crew member or a person however on board, being not part of a security protection force, is in possession of a weapon, he shall immediately seize it, drawing up the relevant minutes together with two witnesses, and enter it in the Security Record Book and in the ship logbook. The finding should be notified to the CSO and to the PFSO of the next port of call. The seized weapon should be handed over to the Port State Authority, and a suitable statement shuld be delivered to the same, when in Italian ports, or to an Italian Consular Authority, when in a foreign port. On no account the weapon may be directly returned to its holder, even in case he leaves the ship. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 3 of 6 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.7 SHIP SECURITY 12.7.3.2 – Stowaways Stowaways on board pose a threat for crew and passengers phisical safety and health. If in a large number, given the small crews of modern ships, they represent an actual serious danger for the safety of the crew, of the vessel, of her cargo and of the environment. a) Preventing stowaways from boarding The following security measures should be enacted on board to avoid embarking stowaways during stays in ports or at anchorages: Strictly observe the rules contained in the Ship Security Plan on the care of the vessel during her stays at ports or anchorages. Particularly:  keep a continuous watch at the gangway or accomodation ladder, on main deck and near mooring lines and anchor cable;  by night, the ship and the surrounding sea and pier areas should be kept floodlighted;  strictly apply the procedure for admitting on board and checking-in visitors  carefully watch shore people operating on board, do not allow them to any ship zone where they have no reason to be;  do not fraternize with shore people on board, do not allow them into the accomodations;  cases as per previous item should be immediately investigated (it often happens that stowaways are helped on board by crew members);  be on the alert for unauthorised approaching craft or for swimmers coming close to the ship;  before sailing, search the vessel according to the procedure detailed in the following paragraph. b) Pre-departure search Before sailing, the vessel should be carefully searched by the crew, in order to ascertain that nobody has succeeded in stowing away, and that no parcels of illegal drugs have been slipped in and concealed on board (see following § 12.7.3.3): The search shall be performed only after all shore people attending the vessel during her stay in port has left. All ship’s spaces, even if not in use or locked, shall be searched. Chief Officer is responsible for searching the following parts of the vessel: - masts and open decks; - survival craft; - all ship’s compartments, spaces and equipment, forward of ER fore bulkhead; - all aft bridge-house spaces and rooms outside engine casing. Chief Engineer is responsible for searching the following parts of the vessel: - all ship’s compartments, spaces and equipment, aft of ER fore bulkhead and inside engine casing; - inner and top parts of the funnel; - steering gear compartment; - air conditioning space, emergency generator and fire pump rooms, IGS blowers room (when outside engine room). The serach should be carried out in co-operation between Chief Officer and Chief Engineer Outcome of search shall be personally notified by the responible Officers to the Master. The discovery of a stowaway should be immediately reported to the CSO and to the Port authority and. The stowaway sholud be handed over to the local Immigration Service before sailing. On no account may a stow-away be allowed to leave the ship unreported. The search and its results should be recorded in the Security Record Book and in the ship logbook. c) Finding stowaways at sea In case a stowaway or a stowaways party are discovered on board while at sea, the Master is responsible for: Lending them any assistance they may need; FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 4 of 6 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.7 SHIP SECURITY Taking care that their presence on board does not represent a danger for the safety of the crew, of the vessel, of her cargo, and of the environment; Notify the CSO and the PFSO of the next port of call and of the port where the stowaways boarded (if known); Provide the Company with all data wich can be useful for their prompt landing. The following procedure shall always be followed:  ascertain stowaways’ health conditions; if underfed and tired out, feed and accomodate them properly;  if they are sick, try to ascertain the nature of their illness, also by consulting the CIRM in Rome;  if they are suffering from infectuous deseases, take all suitable precautions or follow CIRM advice, and notify Health Office of the next port of call;  search the stowaways and their clothing, make sure that they do not carry weapons or drugs (often their only capital);  carefully search the space where the stowaways were hiding, looking for any document, personal belongings, concealed objects, etc.;  collect any available information about the stowaways’ identity and nationality, seize and keep any document in their possession;  find out in which port, when and how they boarded, and whether they have been helped by crew members or shore people;  collect and keep all stowaways’ properties and personal belongings and make up an inventory.  log the date, time, ship’s position and circumstances in which the stowaways were found, together with their names and personal data (if known) in the Security Record Book and in the ship logbook; During their stay on board, stowaways should be treated humanly. Nevertheless, for the good sake of ship’s safety, they have to be necessarily subjected to some restrictive measures:  stowaways cannot perform any work on board;  stowaways should be kept in detainment, under continuous surveillance. If more than one, they shall be kept secluded from each other, and it shall be avoided by all means that they communicate among themselves.  avoid by the most absolute way any fraternization or comradeship between crew members and stowaways, especially if they belong to the same racial, religious or national group;  stowaways shall be entered in the ship’s Muster List and properly trained for emergencies. The Chief Officer, in his capacity of SSO, is responsible for the custody of stowaways and for their safety in case of emergency. Daily, he reports to the Master on this matter. 12.7.3.3 – Drug smuggling Drug smuggling represents a serious danger, not only for the commercial management of the ship and of the Company, but for the personal safety of the crew itself, as this illegal activity is managed, on a world basis, by organized crime, using violence and criminals to protect their interests and to achieve their goals. Placing concealed parcels of drugs on board ships or using crewmembers to carry them are among the most common means used by illegal drugs traders. a) Prevention of smuggling Security measures to be observed in order to prevent drug smuggling are basically the same as those applied to prevent embarking stowaways. b) Company’s engagement Within the scope of its D&A policy (see Section 12.8, § 12.8.8.2.f)) the Company pledges itself to co-operate with all Countries’ authorities and, through BIMCO, has signed special agreements with some of them:  with the United States of America, the Sea Carrier Initiative Agreement (SCIA); FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 5 of 6 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.7 SHIP SECURITY  with most of the European Union Countries, and with Canada, various Memorandum of Under- standing (MOU). These agreements are intended to facilitate the Company in avoiding its ships being used by drug smugglers and bind it always to render its best co-operation to the contracting Countries’ customs authorities. Procedures to be followed and contact points to be used in the various Countries are contained in the BIMCO Ship Master’s Security Manual. 12.7.3.4 – Piracy In recent years, a dangerous revival of piracy has taken place. An ever increasing number of ships, in various parts of the oceans, both at sea or at anchor and in port, suffer pirate attacks every day. In order to collect all informations on piracy at world level and disseminate them to all interested parties, a Piracy Reporting Centre has been established by the International Maritime Bureau (IMB) in Kuala Lumpur (Malaysia) and as well NATO SHIPPING CENTRE LONDON. Piracy has reached dramatic proportions in the waters surrounding the Horn of Africa, where Somali- based pirates attack merchant ships not only in the Gulf of Aden, southern Red Sea and along the african mainland, but further offshore in the North Indian Ocean, up to the western coasts of the Indian Subcontinent. The pirates fire automatic weapons and Rocket Propelled Grenades (RPG) at merchant vessels in an attempt to board and hijack them. Once the attack is successful and the vessel hijacked, they would sail the vessel towards the Somali coast and thereafter demand a ransom for the release of the vessel and crew. This situation has led the international community to enact some forms of protection of shipping by deploying combined naval forces in the area and establishing procedures for ships sailing the dangerous zone, including registration, advanced notification and regular reporting. Publication BMP 4 - Best Management Practices to Deter Piracy off the Coast of Somalia and in the Arabian Sea Area (Version 4 – 2011) has been produced by the shipping Industry (ICS, IMB, ISF, OCIMF, INTERTANKO, IGP&I, among others) in consultation with the combined naval forces, the NATO Shipping Centre, EUNAVFOR, the UK Maritime Trade Operations (UKMTO), the US Navy Mari- time Liaison Office (MARLO), and INTERPOL. Its purpose is to assist ships to avoid, deter or delay piracy attacks in the High Risk Area (as declared by the combined naval forces). Experience and data collected by Naval/Military forces, shows that the application of the recommendations contained within BMP 4 can and will make a significant difference in preventing a ship becoming a victim of piracy. The publication is available on board all ships of the Company’s fleet (See Annex to chapter 6 - # 115). It contains detailed instructions, both to Shipmasters and SSOs on board and to CSOs ashore, particularly for:  Risk Assessment.  Passage planning.  Registration, notification and monitoring procedures.  Crew briefing and drills.  Ship protection measures.  Safe Muster-points – Citadels.  Action in case of pirate attack.  Action in case pirates take control.  Action in the event of military action.  Useful contact details.  Post-incident reporting. Ships sailing in the High Risk Area are continuously monitored by the CSO, in conjunction with the Italian Coast Guard MRCC in Rome. Though chiefly intended for the Arabian Sea area, BMP 4 contains useful advice and instructions on how to cope with pirate attacks in any part of the world. Therefore, its content should be well known FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 6 of 6 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.7 SHIP SECURITY by all Shipmasters and SSOs, and it shall be regularly used whenever a ship sails in areas where pirates activity is known or suspected to occur. Ships sailing into such areas must rergularly monitor the Daily Piracy Reports broadcast by Kuala Lumpur IMB Centre on the INMARSAT-C SafetyNET system, and must keep in touch with Port and/or Coastal States. Any pirate activity reported to the Italian Coast Guard MRCC in Rome is immediately notified to the CSOs of all Italian-managed ships, for further dissemination to the vessels they are responsible for. 12.7.3.5 – Terrorism Terrorism represents an extremely serious danger for the whole civil community, because of both the damages and victims it directly causes and the consequent serious conditions of international tension. Merchant ships are especially exposed to terroristic activity. Indeed:  they are weaponless and lack any own defense system;  technically, they are extremely vulnerable;  they can be used by terrorists as offensive weapons (damaging other ships or fixed installations, pollution, etc);  they can be used by terrorists to conceal and carry dangerous or destructive materials;  they can be hijacked and used, together with their passengers and crew, as means of blackmail;  they can be themselves the target to be hit by terrorists. Terrorist attacks against ships are similar to pirate attacks, with two basic differences:  Pirates act on gain and interest grounds, while terrorists act on political and ideological grounds.  Pirates can be savage and cruel, but they always care for their own personal safety, while terrorists are fanatics who, very often, do not care at all for their own lives. a) Preventive action - Defensive action Refer to the Ship Security Plan. The need to be on the alert and to act so as to protect the vessel and to avoid any risk for her safety and security cannot relieve the Master and the crew from fulfilling in any moment their moral and legal obligation of rescueing and assisting anybody being in danger at sea under any circumstances. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 1 of 28 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.8 SAFETY OF WORKING ENVIRONMENT AND HEALTH OF THE CREW INDEX 12.8.1 GENERAL RULES. 12.8.1.1 – Safety plan. 12.8.1.2 – Responsible person for on-board prevention and workers protection service (RESAL) – Person in charge of prevention and protection. 12.8.1.3 – Workers representative for the safety of working environment (RASAL) 12.8.1.4 – Company’s physician. 12.8.1.5 – Personal protection equipment (PPE). 12.8.1.6 – Personnel training. 12.8.1.7 – Periodical on-board prevention and protection meeting. 12.8.1.8 – Safety information to shore personnel operating on board. 12.8.1.9 – Labour accidents record book. 12.8.1.10 – Working environment safety management manual. 12.8.1.11 – Violation of working environment safety rules. 12.8.2 MEDICAL FITNESS OF THE CREW. 12.8.3 HOURS OF REST OF THE CREW. 12.8.3.1 – Fatigue Management. 12.8.4 ON - BOARD RECREATIONAL FACILITIES. 12.8.5 FOOD AND CATERING. 12.8.6 MEDICAL ASSISTANCE ON BOARD. 12.8.7 SHIP’S HYGIENE. 12.8.7.1 – Weekly Sanitary Inspections 12.8.7.2 – INTERNATIONAL CONVENTION (ILO) N. 68/1946 12.8.7.3 – Checks by the Company’s Physician 12.8.7.4 – Animals on board – Endangered Species 12.8.7.5 – Health awareness campaign 12.8.8 COMPANY’S DRUGS AND ALCOHOL (D&A) POLICY. 12.8.8.1 – Company’s commitment 12.8.8.2 – Basic rules 12.8.8.3 – Checks. 12.8.8.4 – Notice and information on Company’s D&A Policy. 12.8.8.5 – Records. 12.8.9 HEALTH HAZARDS CAUSED BY THE CARGO CARRIED AND BY PRODUCTS USED ON BOARD. 12.8.9.1 – Cargo and Fuel 12.8.9.2 – Products used on board. 12.8.10 RISKS IN RELATION WITH THE USE OF RESIDUAL HEAVY FUEL OIL. 12.8.11 WELDING GAS: PRECAUTIONS FOR CYLINDERS USE, HANDLING AND STORAGE. 12.8.12 PREVENTION OF LABOUR ACCIDENTS. 12.8.12.1 – Generals – Risk Assessment 12.8.12.2 – Use of Personal Protection Equipment (PPE). 12.8.12.3 – Permits system 12.8.12.3.1 – Enclosed Spaces Entry Permit – Enclosed Spaces Entry Log 12.8.12.3.2 – Hot Work Permit 12.8.12.3.3 – Work Permit 12.8.12.3.4 – Underwater Inspection and Work Permit FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 2 of 28 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.8 SAFETY OF WORKING ENVIRONMENT AND HEALTH OF THE CREW 12.8.12.3.5 – Work Permit for Lifting Operations. 12.8.12.3.6 – Cold Work Permit 12.8.12.3.7 – Lock Out – Tag Out Permit 12.8.12.3.8 – Safe Operation of Cranes & Lifting Appliances. 12.8.12.3.9 – Guarding of openings. 12.8.12.4 – Stop Work Authority Program 12.8.13 MANAGEMENT OF SHIP’S LIFTING TOOLS. 12.8.14 ADDITIONAL INFORMATION. 12.8.1 General rules On board Italian-flag ships the Decree 27 July 1999, n. 271 – Conformity of the rules for the safety and health of seafarers on board national merchant and fishing vessels to the law 31 december 1988, n. 485 is in force. This decree is included in the ship’s national rules file (see Chapter 6 - § 6.2(ii) and its Annex - # 406) . Purposes of the decree are (art. 1):  To ensure the protection of health and the prevention of labour accidents ond occupational illnesses;  To determine obligations and responsibilities of ship owners, seafarers and other concerned persons in relation to risk assessments on board ships.  To fix, the criteria relevant to the hygienic and living conditions of crew accommodations;  To define the criteria relevant to the on-board organization of the prevention, hygiene and working safety service and the use of the personal protection equipment (PPE).  To define the duration of the seafarers periods of work and rest;  To order safety measures in case of particularly risky conditions;  To ensure the information and training of the crew;  To establish the criteria for the issue of the training evidence and certification. This decree places several obligations on the Company, the shipmasters and the crew. 12.8.1.1 – Safety plan (art. 6 - § 1 and § 2): All ships must be fitted with a Safety Plan approved by the Administration. It contains:  a detailed plan of the vessel, showing all arrangements relevant to the working environment;  A technical description of the vessel, containing all necessary elements to assess the working hygienic and safety conditions existing on board;  A technical report of the risk assessment for the protection of seafarers health and safety in connection with the performance of work on board. A copy of the forwarding letter of the the safety plan sent by the Company to the Ministry of Transport is attached to the plan itself, and must be shown at any request by the Flag State authorities. 12.8.1.2 – Responsible person for on-board prevention and workers protection service (RESAL) – Person in charge of prevention and protection (art. 6 - § 5, a) and b)). On our ships, the function of responsible of the safety work environment (RSPP) go to two single persons. Hereby appointed by the Company for all vessels of its fleet:  Deck, Cabin and Catering Departments: Chief Officer (see chapter 4 - § 4.5.2.1);  Engine Department: Chief Engineer (see chapter 4 - § 4.5.3.1). On joining, they are informed in writing by the Master of their responsibility, and they will accept their duty signing the appropriate form. RESAL status is recorded in the ship’s Crew Roll (art. 12 - § 4). FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 3 of 28 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.8 SAFETY OF WORKING ENVIRONMENT AND HEALTH OF THE CREW 12.8.1.3 – Workers representative for the safety of working environment (RASAL) (art. 16). The Master shall arrange his election on board by the crew, in accordance with the procedure agreed with the seafarers unions. A copy of the relevant minutes shall be forwarded to the HSEQ Department. 12.8.1.4 – Company’s Physician (art. 6- § 5, c)). The Company appointed his Physician, with functions and tasks requested by art. 23. A copy of the appointment letter shall be kept on board, enclosed to the Safety Plan. 12.8.1.5 – Personal Protection Equipment (PPE) (art. 6 - § 5, g)) Company’s ships are fitted with the following personal protection equipment :  boiler suits  safety shoes  safety hard hats  soundproof ear protectors  safety harness  safety lines  safety goggles  leather gloves  oil- and chemical-proof gloves  visors  dust masks  flotation aids; and furthermore,  isolating gloves  electric welding personal equipment  heavy clothing for cool rooms entry  heavy clothing for cold climate  heavy caps for cold climate  rain gear (coat with hood and trausers)  neoprene rain boots  sunglasses. 12.8.1.6 – Personnel training (art. 6 - § 5, e), h), i), p) ). Personnel training as per paragraphs e), i) and p) should be given during the Crew Monthly Safety Meetings (see charter 5 - § 5.3.2.1(v)); training as per paragraph h), by means of the emergency drills required by R.S. and by SOLAS 74/78 (see chapter 8 - § 8.2). All ships are provided with a SAFETY OF WORKING ENVIRONMENT TRAINING MANUAL. It is completely written in the English language, and is dividend in the following parts:  Company’s Policy: - SMS Manual Section 12.8. - Work Permits. - Safety Placards.  Procedures and Practices.  Industry Advice (ICS, P&I, etc.);  Current Labour Regulations: - Italian Legislative Decree n.271/1999. - ILO Convention 180. - ILO Maritime Labour Convention 2006. The manuals has to be arranged on board in the following way: - one copy each in the Officers and Crew dayrooms (together with the SOLAS training manuals); - one copy entrusted to the Chief Officer, in his capacity of ship’s Safety Officer, for reference and crew training. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 4 of 28 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.8 SAFETY OF WORKING ENVIRONMENT AND HEALTH OF THE CREW 12.8.1.7 – On board periodical prevention and protection meeting (art. 14). The meeting must be held annually as required. Copy of the relevant minutes shall be forwarded to the Company’s HSEQ Department. 12.8.1.8 – Safety information to shore personnel operating on board (art. 10). Shore personnel operating on board during ship’s stays in port (authorities, superintendents and surveyors, agents, technicians, etc.) are normally trained in advance on safety rules to be observed and are fitted with suitable PPE by the organizations or firms to which they belong. Basic information on procedures and safety measures in force on board while the ship is in operational conditions are quoted on the personal badge assigned to all shore people in accordance with visitors identification and checking-in procedure (see section 12.7). 12.8.1.9 – Labour accidents record book (art. 25 - § 2) All labour accidents must be entered by the Master in his official Logbook and recorded in the special Labour accident record book approved by the Administration.(art. 25). Labour accidents must be notified to the Company as detailed in Chapter 10. 12.8.1.10 – Working environment safety management manual (art. 17) Company’s SMS Manual – Section 12.8: Safety of working environment and crew’s health. 12.8.1.11 – Violation of working environment safety rules. Full compliance with working environment safety rules is checked on board by Master and Deck and Engine departments RESAL Officers. The Company regards with particular concern any violation of the following safety rules which, besides being provided by its SMS, are clearly required by current Flag State laws: Use of personal protection equipment (PPE), in conformity with art. 8 D.Lgs. 27.07.1999 n. 271 (see Section 12.8, § 12.8.1). Prohibition to consume and possess alcoholics, in conformity with art. 15 Law 30.03.2001 n. 125, and art. 1120 Code of Navigation (see Section 12.8, § 12.8.6). Prohibition to take drugs and psychotropic substances, in conformity with art. 124 – 125 D.P.R. 09.10.1990 n. 309. Smoking regulations, in conformity with art. 227-1.a) DPR 08.11.1991 n. 435 (Safety Regulations) (see Section 12.4, § 12.4.1.1). - In case of violations of the above rules when on board, the Master, having consulted the Crewing Manager, shall apply the procedure provided for by art. 13 of current Italian Collective Bargaining Agreement, in compliance with Code of Navigation – Second Book – Title I: Infringements and disciplinary sanctions, that in such cases provide for the immediate dismissal of the seafarer. In all other circumstances, a Notification of a Reprimand shall be handed over to the seafarer. The notification will count as an initial warning. It shall be completed and signed by the Officer reporting the violation, as a rule the RESAL Officer, and by the Master. The concerned seaman shall sign it for receipt and acceptance. No immediate disciplinary action will follow a notification so accepted. It will remain filed on board for reference in case of further violations. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 5 of 28 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.8 SAFETY OF WORKING ENVIRONMENT AND HEALTH OF THE CREW In case the concerned seaman refuses to receive and sign the notification, it shall be signed by two witnesses, one of which will be the RESAL or the reporting Officer. The Master shall inform the Manning Agent, in case the seafarer is Indian, and the Crewing Manager, sending them a copy of the notification, for appropriate disciplinary action (as a rule, an immediate dismissal). Facts and procedure shall be recorded in the Master’s General Logbook (GiornaleNautico – Libro Secondo). 12.8.2 MEDICAL FITNESS OF THE CREW Medical fitness of all employed seafarers is ascertained in accordance with international standards in force (STCW/95, ILO 73, ITF). Italian seamen are subject to medical examinations required by the National Service for Medical Assistance to Seafarers (SASN) of the Italian Ministry of Health, in accordance with above standards. Medical fitness of seafarers engaged by the Manning Agent is ascertained by doctors approved by the Indian Government in accordance with Rule 4 of Merchant Shipping (Medical Examination) Rules 2000. Additional medical checks of Company’s seafarers, both italians and foreigners, required by art. 23 are carried out by the Company’s physician (see § 12.8.1.4). 12.8.3 HOURS OF REST OF THE CREW (art. 11) All ship’s personnel of Deck, Engine, Cabin and Catering departments, including the Master, must benefit by a number of hours of uninterrupted rest sufficient to assure that they can carry out safely their work. Limits of work and rest times are fixed by D.L. 27.07.1999, n. 271 - art. 11, in accordance with STCW and MLC 2006 Convention requirements. Times of daily work and watch shifts and times of rest, both at sea and in port, of each crewmember are detailed in the Table of Shipboard Working Arrangements displayed in various parts of the ship. Musters, firefighting and lifeboat drills, and drills described by National and international law and regulations ahall be conducted in a manner that minimize the disturbance of rest periods does not induge fatigue. Actual times of work and rest of all crew members (normal and overtime) must be recorded daily in the special Hours of Work Record Book. Times of interventions of the Duty Engineering Officer in the machinery space when the same is running in UMS conditions must also be recorded, as well as all crew training sessions held on board. Both the table and the record book are in conformity with Administration approved forms. Furthermore, all ships are equipped with a special software, produced by the International Shipping Federation (ISF), complying with international regulations, called the Watchkeeper 3.0. Its use on board makes easier the regular compilation of the statutory record-book and allows the automatic monitoring of the compliance with existing regulations. It is accepted by the majority of foreign Administrations and is recommended by the Majors, so that the results of PSC and vetting inspections will greatly improve. Hours of work performed daily by the entire crew, both on watch or on day shift, including Master and Chief Engineer, shall be entered in the statutory record-books of the Deck and Engine Departments. Work hours shall also be notified by the Heads of the ship’s Departments to the Officer in charge of the Watchkeeper 3.0 to be entered in the software. Data entered and resulting from the software shall be compared with the data of the record books to verify that they match. At the end of the month, every crew member will receive the second copy (coloured) of his page of the record-book, as provided by current regulations duly signed by the Master and seafarer for his acknowledge. An electronic copy of the software shall be sent to the Company’s Crewing Department for the required check and detection of any non-conformity. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 6 of 28 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.8 SAFETY OF WORKING ENVIRONMENT AND HEALTH OF THE CREW The Master should attach a Non-Conformity Report to the Watchkeeper software copy sent every month to the Crewing Department, containing all details (persons involved, circumstances, reasons, immediate action, suggestions and requests to the Company), for both Deck and Engine personnel. This Report must always be copied to the HSEQ Department. The Hours of Work Record-book shall remain filed together with the ship’s statutory log-books, as required. As per OPA 90, in U.S. waters all ship’s personnel may not be permitted to work more than 15 hours in any 24 hour period or more than 36 hours in any 72 hour period, except in an emergency or a drill. The Master and C/E must maintain a record of the hours worked whilst in U.S. waters. 12.8.3.1 FATIGUE MANAGEMENT A) Understanding Fatigue Fatigue is described in IMO’s MSC/Circ.813/MEPC/Circ.330, List of Human Element Common terms as: “A reduction in physical and/or mental capability as the result of physical, mental or emotional exertion which may impair nearly all physical abilities including: strength; speed; reaction time; coordination; decision making; or balance.” The most common causes of fatigue known to seafarers are lack of sleep, poor quality of rest, stress and excessive workload. There are many other contributors as well, and each will vary depending on the circumstance (i.e. operational, environmental). There are many ways to categorize the causes of fatigue. To ensure thoroughness and to provide good coverage of most causes, they have been categorized into 4 general factors.  Crew-specific Factors which are related to lifestyle behaviour, personal habits and individual attributes.  Management Factors (ashore and aboard ship) which are related to how ships are managed and operated. These factors can potentially cause stress and an increased workload, ultimately resulting in fatigue.  Ship-specific Factors which are related to ship specific factors that affect the crew’s ability to sleep, and others affect the level of physical stress on the crew (i.e. noise, vibration, accommodation spaces, etc.).  Environmental Factors which are related to exposure to excess levels of environmental factors, e.g. temperature, humidity, excessive noise levels. Alertness is the optimum state of the brain that enables us to make conscious decisions. When a person’s alertness is affected by fatigue, his or her performance on the job can be significantly impaired. Impairment will occur in every aspect of human performance (physically, emotionally, and mentally) such as in decision- making, response time, judgment, hand-eye coordination, and countless other skills. For example  Fatigued individuals become more susceptible to errors of attention and memory.  Chronically fatigued individuals will often select strategies that have a high degree of risk on the basis that they require less effort to execute. B) Causes of Fatigue Fatigue may be caused and/or made worse by one or a combination of things  Lack / poor quality of sleep FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 7 of 28 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.8 SAFETY OF WORKING ENVIRONMENT AND HEALTH OF THE CREW  Insufficient / poor quality of rest in interval between work periods  Stress  Boring or repetitive work  Noise or vibrations  Ship movements  Food at improper timings, frequency, content and quality  Medical conditions / illness  Ingesting (consuming) chemicals such as alcohol, caffeine  Jet lag  Excessive work load C) Recognizing Fatigue  The following list describes the various symptoms seen in fatigued persons: A. Physical  Inability to stay awake  Difficulty with hand-eye coordination skills  Speech difficulties (it may be slurred, slowed or garbled)  Heaviness in the arms and legs or sluggish feeling  Decreased ability to exert force while lifting, pushing or pulling  Increased frequency of dropping objects like tools or parts  Non-specific physical discomfort  Headaches  Giddiness  Heart palpitations / irregular heart beats  Rapid breathing  Loss of appetite  Insomnia ( not able to sleep)  Sudden sweating fits  Leg pains or cramps  Digestion problems  B. Emotional  Increased willingness to take risks  Increased intolerance and anti-social behaviour  Needless worry  Reduced motivation to work well  Increased mood changes (examples are irritability, tiredness and depression)  C. Mental  Poor judgement of distance, speed, time, etc.  Inaccurate interpretation of a situation (examples are focusing on a simple problem or failing to anticipate the gravity of the situation or failing to anticipate danger)  Slow or no response to normal, abnormal or emergency situations  Reduced attention span FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 8 of 28 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.8 SAFETY OF WORKING ENVIRONMENT AND HEALTH OF THE CREW  Difficulty concentrating and thinking clearly  Decreased ability to pay attention D) Fatigue Mitigation  General guidelines that can help you mange fatigue and maintain performances are as follows  Get sufficient sleep, especially before any period when you anticipate that you will not get adequate sleep.  When you sleep, make it a long period of sleep.  Take strategic naps. Reference: Assessment of risks and reduction of exposure to noise & vibration in all accommodation and recreational and catering facilities to be carried out by adopting measures in accordance with the guidance provided by the ‘ILO code of practice entitled Ambient factors in the workplace’, 2001, and any subsequent revisions, taking account of the difference between exposure in those areas and in the workplace. 12.8.4 ON-BOARD RECREATIONAL FACILITIES The vessels must comply with the Minimum Standards established by the MLC 2006, through the supply and maintenance of decent accommodation and recreational facilities for the use of seafarers working or living on ships, or both, consistent with promoting health and well-being of the seafarers. Mess rooms are equipped with adequate recreational facilities like TV, DVD player, Newspapers and magazine, in order to grant a pleasant post work activities. All crew is able to have email corresponded with families through the ship’s communication system. 12.8.5 FOOD AND CATERING. Its Company Policy to ensure that onboard managed vessels are observed following minimum standards: • food and drinking water supplies, having regard to the number of seafarers on board, their religion and cultural practices related to food, and the duration and nature of the voyage, shall be suitable in respect of quantity, nutritional value, quality and variety; • the organization and equipment of the catering department shall be such as to permit the provision to the seafarers of adequate, varied and nutritious meals prepared and served in hygienic conditions; • catering staff shall be properly trained or instructed for their positions; • Seafarers employed as ships' cooks with responsibility for food preparation must be trained and qualified for their position on board ship according Ship's Flag requirements; • Seafarers on board a ship shall be provided with food free of charge during the period of engagement according the National Collective Bargaining Agreement Labour (CCNL); • No seafarer under the age of 18 shall be employed or engaged as a ship's cook The hygienic control of the crew catering service on board is carried out by means of the SELF-CONTROL MANUAL according to the Hazard Analysis and Critical Control Point (HACCP) system required by CE 178/2002 and CE 852/2004 directives. The HACCP is a preventive food-control system that employees scheduled checks and measures in order to monitor the extent of controls on a certain hazard (microbial, chemical, physical, etc) in a production unit and then to check that the product complies with specific, normally microbiological criteria. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 9 of 28 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.8 SAFETY OF WORKING ENVIRONMENT AND HEALTH OF THE CREW The HACCP Manual includes the following topics: • Description of Operating Sectors • Purchasing and Receiving Raw Materials • Product Storage • Food Preparation • Sanitation Procedures • Personnel Hygiene • Check List and Records 12.8.6 MEDICAL ASSISTANCE ON BOARD (art. 24). Vessels should be fitted with medicines and materials required by the Italian Ministry of Health Decree dated 28.02.2012 (Table C – Tankers) (See annex to Chapter 6 – # 405.1). The Third Officer is in charge of the ship’s hospital. Specifically, he shall:  Ensure that all required regularly valid medicines, medical materials and tools are available in the ship’s pharmacy. To this purpose, he shall keep the special inventory up-to-date and notify the Master of the medicines to be supplied because of shortage or expiry date;  Keep the Medical Logbook and the Pharmaceutical Record-book required by D.M. 25.05.1988, n.279;  Draw up all necessary documents for shore medical assistance in port;  Collect and keep all expired or unnecessary medicines (special waste) for their appropriate final disposal (see Section 12.3, § 12.3.10.1);  Notify the Master of all medical condition of anybody on board;  Give the prescribed medicines under the Master’s supervision and responsibility;  Check regularly the conditions of ill or unfit-for-duty crewmembers (body temperature, pulse, bodily functions, diet) and keep the Master informed;  Check the good order of the ship’s hospital (medication room, sick-bay, isolation cabin) and its equipment;  Arrange for the most accurate cleaness of the ship’s hospital. The Master is responsible for medical assistance on board. Specifically, he shall:  Request the Marine Department (AR) to supply the ship with all necessary medicines and medical materials;  When necessary, request the Port Health authorities the renewal of the prescribed medical drugs outfit and the removal and disposal of expired or unnecessary drugs and medicines;  Keep in his office safe the prescribed medical drugs outfit and the Medical Drugs Record-book required by the Ministry of Health circular letter no.17 dated 20.07.1994 and by D.M. 28.02.2012.  Lend all possible medical assistance, as practicable on board . The WHO publication International medical guide for ships is available on board. It can be used by the master to obtain medical and nursing guidance (see annex to Chapter 6 - # 404.1 & 404.2). The Master shall never hesitate to ask for medical advice, even for apparently simple conditions, by calling the International Radio Medical Centre - CIRM in Rome, by fax, e-mail or telephone. Besides the required entries in the Giornale Nautico - Libro II and the Labour accidents record book, all cases of illness or personal injury, their treatment, the periods of absence from work shall be recorded in the Medical Logbook. All medical cases and labour accidents resulting in temporary unfitness must be immediately reported to the Crewing Manager and the DPA, and, for non-EU personnel, also to the Manning Agent. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 10 of 28 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.8 SAFETY OF WORKING ENVIRONMENT AND HEALTH OF THE CREW The Master shall never hesitate to divert his ship and to call the nearest port in order to obtain suitable medical assistance for an ill or injured crewmember or to land and hospitalize him. The Company ensure to all seafarers:  The right to be visited by a qualified medical doctor or dentist without delay in the ports of call, when practicable;  Medical care and health protection services, to the extend consistent with Company’s National law, either on board or ashore a foreign port, provided free of charge to seafarer. 12.8.7 SHIP’S HYGIENE Hygienic and living conditions on board italian flag ships established at Title 3 Reg. 3.1 of the Code (MLC 2006) are regulated by the DL 27.7.1999 n. 271. After an initial survey (art. 19), with the purpose of checking the implementation of the requirements of the D.L., ships are subjected to periodical surveys every two years (art. 20), in order to check that the above requirements are maintained. Surveys are carried out by the Committee having territorial jurisdiction (art. 31). N.B.: Pending the issue of the technical regulations required by art. 34, Law 16 June 1939, n. 1045 – Hygienic and living conditions of the crew on board national merchant ships – remains still in force. Besides other things, it requires the performance of a half-yearly technical-sanitary survey. When necessary, such survey must be requested directly by the Master to the Maritime Authority of the italian port of call (see Chapter 14, § 14.1e)). 12.8.7.1 – Weekly Sanitary Inspections In accordance with International Convention (ILO) N. 92 (Revised)/1949, weekly inspections shall be carried out in order to check the sanitary and good maintenance conditions of the following spaces and their fixtures and equipment:  Accommodations inspection: Carried out jointly by the Chief Officer and one of the Engineering Officers.  Ship’s Hospital Inspection: Carried out jointly by the 3rd Officer and one of the Engineering Officers. Minutes shall be completed for every inspection, duly signed by the inspecting Officers and by the Master. Inspection minutes shall remain filed on board for not less than three years. 12.8.7.2 – INTERNATIONAL CONVENTION (ILO) N. 68/1946 This convention, ratified by the Italian Government with its Law 2.8.1952 n.1305, requires that, on board all ships, the Master or an Officer appointed by him, together with the Cook responsible for the catering service on board, carry out a weekly inspection of the supply of food provisions and drinking water, and of the spaces and equipment used for their storage, preparation and service. Special minutes must be kept of the inspection, including any deficiency and relevant corrective action. The minutes shall be kept on board, in the Deck Department files. Every six months, copy of all the minutes shall be copied in a electronic form (CD) and sent through the Marine Department to the ship’s Home Port Authority. 12.8.7.3 - CHECKS BY THE COMPANY'S PHYSICIAN The Company requires that the two visits of the ship's working environment to be carried out every year by the Company's Physician in conformity with D.L. 27.07.1999, n. 271 - Art. 23.1.g) shall include also an hygienic check of the catering service, including drawing of swabs (working surfaces, chopping board, slicer) and drinking water samples. Results of relevant analysis carried out at shore qualified laboratories shall be notified to the HSEQ Department which, in turn, shall forward them to the vessel and circulate them among the Company's Departments for corrective action. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 11 of 28 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.8 SAFETY OF WORKING ENVIRONMENT AND HEALTH OF THE CREW 12.8.7.4 – Animals on Board - Endangered Species For the sake of protecting ship’s hygiene and crew safety, and to comply with national and international regulations on the matter, the Company provides that no animals of any kind, both personal pets or ship’s mascot may be kept on board the ships of its fleet. It should be remembered that, in several Countries, keeping on board and introducing animals is restricted or prohibited by special laws, and that the international convention CITES 73/79 prohibits the possession and carriage of some animals (and plants) belonging to endangered species, under heavy penalty (see Section 12.3, § 12.3.11.2). 12.8.7.5 – Health awareness campaign Health awareness campaign to be implemented by the Company Physician and implemented during the meeting on board DL 271 ex-art.14 (Diets, physical exercises). 12.8.8 COMPANY’S DRUGS AND ALCOHOL (D&A) POLICY 12.8.8.1 – Company’s commitment The Company is well aware that the use of drugs and the abuse of alcohol can seriously affect the ability of persons to carry out their duties and represent a serious risk for the correct and safe performance of whatever activity. The Company adopted therefore a drugs and alcohol (D&A) policy based on the OCIMF Guidelines for the Control of Drugs and Alcohol on Board Ships (see Chapter 6 – Appendix (part d)), in accordance with national and international regulations on this matter presently in force:  R.D. 30.03.1942 – Code of Navigation – article 1120.  Law 30.03.2001, n. 125 – article 15.  STCW/95 Code – Section B-VIII/2.5. 12.8.8.2 – Basic rules Company’s D&A policy is in force on board all ships of the Company’s fleet, both in port and at sea, for all ship personnel as well as for all shore or alien people finding themselves on board for whatever reason. Its basic rules are: A Absolute prohibition to use, to bring in, to possess, to give out and/or to sell any illegal drugs.  The Company assures its full co-operation to national and foreign public Authorities in the criminal prosecution of anyone using or possessing illegal drugs or drugs paraphernalia on board. B Absolute prohibition to use, to bring in, to possess, to give out and/or to sell any alcoholic beverage.  The BAC (Blood Alcohol Content) of all crewmembers, both at sea and in port, must always be 0 (zero). A grater value shows anyway an alcohol consumption.  The 0 (zero) limit is also valid for passengers and shore people temporarily on board while the ship is at sea.  The maximum limit of the BAC rendering a person incapable to carry out his tasks is 40 mg/100 o ml (0,4 /oo).  During port stays, the BAC of all people alien to the ship finding themselves temporarily on board, shall o in no case exceed the maximum value of 40 mg/100 ml. (0,4 /oo). All luggage, personal belongings, accommodation and ship’s spaces can be searched by order of the Master to ascertain the possession or existence of illegal drugs and alcohol. Crewmembers must observe all Company’s D&A policy rules even during their shore leave periods in port. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 12 of 28 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.8 SAFETY OF WORKING ENVIRONMENT AND HEALTH OF THE CREW Violation of these rules by anybody implies the immediate excuse from duty and discharging or turning away from the vessel, and in case of offence, a criminal report to the competent police and judicial authorities. Had the violation caused loss or damages to persons or property, the Company reserves for itself the right to protect its interests by appropriate legal means. Company’s D&A Policy – Instructions to Masters manual is available on all ships of the fleet. It contains full details of all its rules, directions and prevention and checking procedures. 12.8.8.3 – Checks (i) Pre-joining test: Pre-joining test for drugs of seamen being engaged for service on board ships of the Company’s fleet is carried out when ascertaining their medical fitness, in accordance with applicable rules presently in force (D.L.ve 09.04.2008, n.81 & 178/CSR 18.09.2008) (see previous § 12.8.2). Italian seamen are certified as FIT by the National Service for Medical Assistance to Seafarers (SASN) of the Italian Health Ministry only after passing the drug test. Seafarers engaged by the Manning Agent are checked for drugs by doctors approved by the Indian Government. Results of tests are recorded in the fitness certificate of every seaman. Additionally, on an occasional basis, preliminary tests for drugs of seafarers, particularly newly engaged ones, in accordance with OCIMF and ICS guidelines, are carried out by ALERE, which has been entrusted by the Company to carry out drugs and alcohol tests on board its ships. (ii) Personal agreement: On joining the ship, all crewmembers shall undersign their personal agreement with the Company, clearly accepting by this mean its D&A policy, undertaking to observe its rules and consenting to be subjected to all on-board tests and inspections. (iii) Test Coordinator (TC): The Company appoints its Test Coordinator (TC) who is responsible for ordering and organizing unannounced on-board tests, assessing the results of all tests notified by the Shipmaster, the appointed shore organization or by national or foreign Authorities, and to take all necessary measures. (iv) On-board BAC random testing: The Master shall establish a BAC monthly testing program for all crewmembers, taking into account various personal factors and special safety requirements. Special care in initial testing shall be given to newly- engaged or new-to-the-ship personnel. The program will be so arranged as to allow each crewmember to be tested at least once every three months. Occasional tests will also be carried out by the Master in accordance with instructions received from the TC on a time-by-time basis. The BAC test is performed using the special breath analyser available on board. On-board random testing procedures and immediate measures to be taken in case BAC values over the prescribed limits (see § 12.8.8.2-B) have been detected are detailed in the Company’s D&A Policy – Instructions to Masters manual. Additional drug test must be carried out on board to all European seafarers within 24 hours from their arrival on board. The test must be carried out according with Collection Procedure and should be recorded in the “Drugs test record form” both included in the Company’s D&A Policy – Instructions to Masters manual. The test record form must be sent to Marine Manager (at his personal e-mail) at the end of each month and they should be stored in the dedicated folder located in the Master’s cabin. In case of Positive drug test Master must advise, by phone, the Marine manager and then send immediately the test record form at his personal e-mail ([email protected]). FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 13 of 28 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.8 SAFETY OF WORKING ENVIRONMENT AND HEALTH OF THE CREW (v) Unannunced on-board alcohol and drugs testing: All ships of the fleet are party to a Drug and Alcohol Screening Programme. It provides for unannounced tests carried out on board by qualified ALERE personnel, to verify the the presence of alcohol or drugs in the organism of people being tested. The programme provides for an unannounced annual test of all crewmembers on board all ships and an additional unannounced test on board half (50%) of the ships of the Company's fleet, as ordered by the TC. Testing is performed by analysing personal urine samples collected with the tested person’s consent and sent to appointed shore laboratories through a special chain of custody ensuring their integrity and privacy. Checks are organized by the TC in accordance with the procedure detailed in the Company’s manual. Analysis results are notified personally to the TC, who shall arrange for their confidential processing and filing at the Company’s office. vi) Alcohol and drugs testing following serious marine incidents: The U.S. Coast Guard requires shipowners or operators to ensure that any person on board involved in a serious marine incident (SMI) must be tested for alcohol within two hours of the episode, and for drugs within 32 hours (46 CFR part 4, subpart 4.06). The Company has provided all its ships with an Emergency Testing Kit, supplied by ALERE, containing everything is needed to collect urine specimen of 10 people for alcohol and drug testing, to be used on board within 2 hours of the SMI. Detailed instructions for collecting and protecting the donors’ privacy are contained in the kit itself. The Company has established that, in case of any SMI involving one of its ships, this collecting procedure shall be carried out not only in the U.S.A. but everywere in the world. 12.8.8.4 Notice and Information on Company’s D&A Policy The following Italian/English placards, posted in various parts of the ship, notify and inform the crew and all persons being for whatever reason on board, of the rules, directions and procedures required by the Company’s policy: AVVISO SULL’USO DI DROGHE E ALCOOL WARNING - DRUGS AND ALCOHOL USE (Ed. CAIM – Genova) NIENTE ALCOOL A BORDO! NO ALCOHOL ON BOARD! (NOALCOHOL 02.2007) POLITICA AZIENDALE SU DROGHE E ALCOLICI COMPANY’S DRUGS AND ALCOHOL POLICY (TABPOLICY 01.2017) 12.8.8.5 Records Company’s D&A policy requires the following records on special forms: • PERSONAL AGREEMENT (ALCOPATT) File of personal agreements signed by crew. • DRUGS & ALCOHOL TESTS (ALCOTEST): Pre-joining test: date and place of the examination performed in order to ascertain the medical fitness of seafarers employed on board. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 14 of 28 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code SECTION 12.8 SAFETY OF WORKING ENVIRONMENT AND HEALTH OF THE CREW On board BAC random testing: rank and name of people tested, date, port or ship’s position, result. On board BAC random testing ordered by Company’s Test Coordinator: copy of TC’s order, rank and name of people tested, date, port or ship’s position, result and copy of the notification message to the Company. on board drugs testing for all European seafarers within 24 hours from their arrival on board Unannounced on board alcohol and drugs testing: Collection statement for urine samples and copies of personal cards of tested people issued by ALERE personnel. Alcohol and drugs testing after serious marine incidents : - list of tested people; - samples forwarding documents to ALERE (place and date, courier, AWB, etc.). 12.8.9 HEALTH HAZARDS CAUSED BY THE CARGO CARRIED AND BY PRODUCTS USED ON BOARD Cargo carried, as well as the various products used on board (fuels, chemicals, coatings, etc.) for ship and machinery’s operation and maintenance may pose health hazards to the crew. Therefore, they must be handled and used in the proper way, taking all necessary precautions and observing suitable procedures. To this purpose, shippers and makers must issue special Material Safety Data Sheets (MSDS) showing, for each cargo or product, the characteristics, danger, precautions to be taken in their use, action following an incident. For oil cargo in bulk and for oil used as fuel on board, this is a requirement of SOLAS 74/78 – VI/5-1. Responsible officers must have a good knowledge of the MSDS content and of their correct use on board, and take all appropriate precautions, checking their observance and giving all appropriate training to the crew. 12.8.9.1 Cargo and Fuel i) Cargo: Procedure to obtain MSDS at loading ports and their management is detailed in Section 12.4, § 12.4.1.1. MSDS of cargo carried must be posted in the A deck passageway leading to the cargo control room and there remain for the entire voyage and, after discharging, until the following loading of a different cargo or until all cargo tanks, as well as the whole ship, have been cleaned and gas-freed. ii) Fuel: Procedure to obtain MSDS from bunker suppliers, and their management, is detailed in Section 12.2.3 - § 12.2.3.9.2 . MSDS of fuel oil must be posted in the engine control room and there remain until that particular type of fuel has been completely consumed. 12.8.9.2 Products used on board The following products, normally used on board, may pose health hazards to the crew:  lubricants;  marine coatings;  chemicals used for the analysis and treatment of main engine circulating water and for the analysis and treatment of boilers feed water;  cleaning products (solvents, thinners, emulsifiers, etc.). MSDS of these products are supplied by their makers. They must be posted in their stores and, whenever possible, in the spaces where they are being used. The special locker in the machinery space used to store chemicals must contain the appropriate PPE (see subsequent § 12.8.10.2) and must be fitted with an emergency eyewash kit. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA