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Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 15 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 12.8.10 HAZARDS IN CONNECTION WITH THE USE OF RESIDUAL HEAVY FUEL OIL Residual Heavy Fuel Oil (not distilled), when used on board, must always be considered potentially dangerous and capable of producing light hydrocarbons in the tanks headspace, such that their vapours could render them explosive or contain toxic gas (H2S). Precautions and safety measures to be observed in using such fuel oil are contained in the ICS/OCIMF/IAPH publication INTERNATIONAL SAFETY GUIDE FOR OIL TANKERS & TERMINALS (ISGOTT) – 5th edition 2006 – Chapter 2, § 2.7 (see Appendix to Chapter 6 - # 201). 12.8.11 WELDING GAS – PRECAUTIONS FOR CYLINDERS USE, HANDLING AND STORAGE Publication UNITOR Handbook for Maritime Welders detailing all precautions to be used for handling and using welding gas and relevant cylinders is available on board all ships. Oxygen and acetylene cylinders, both in-use and spare, should be stored apart in their special lockers, outside accommodations and machinery space, accessible from open decks, using the following precautions:  Lockers should be clearly identified with the name of the type of gas (oxygen or acetylene). They should not be used for storing other materials.  Lockers should well ventilated and away from any heat source.  Smoking and using necked flames is prohibited in the cylinder lockers. Relevant prohibition signs must be posted.  Loose gas cylinders should be lifted on board using a suitable cargo net; chains, slings or strops should never be used. They should be never handled by their valve or protection cap. A cylinder trolley or other appropriate device should be used when moving cylinders, even for short distances.  Cylinders must be kept upright and properly secured in their racks.  Spare cylinders should be closed by their protection caps.  Cylinder valves should be closed when not in use.  Flashback arrestors must be fitted at both ends of the gas lines, at the work station and in the storage lockers.  During loading, unloading, on-board transfer, tank washing, cleaning and gasfreeing, when any hot work is prohibited on board, all cylinders must be disconnected and closed by their protection caps.  Personnel in charge of handling cylinders and using welding gas should be qualify. The number of welding gas cylinders on board Company’s ships is set at 5 (3 oxygen + 2 acetylene). In special cases (large repairs, maintenance team on board, etc.) particularly authorized on a time-by-time basis by the Technical Department (UT), this quantity may be increased to a maximum of 18 (12 oxygen + 6 acetylene). The Chief Engineer is responsible to have the in-excess cylinders landed as soon as it is no more necessary to keep them on board. 12.8.12 PREVENTION OF ACCIDENTS 12.8.12.1 Generals – Risk assessment Chief Engineer and Chief Officer, as responsible persons in charge of on-board prevention and workers protection service (RESAL) (see § 12.8.1.2) shall organize the work of the personnel belonging to their Departments, in accordance with guidelines contained in the ship’s Safety plan. Planning of maintenance work must not be limited to the work itself. It must comprise all related ancillary activities, like moving and positioning spare parts and materials, rigging scaffoldings and suspension systems, handling and fitting dunnage, planking, rigging, etc. Risk assessment (see Chapter 12, § 12.1 and the Risk Assessment Plan) must result in the necessity of adopting the following preventive measures: FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 16 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  Reference to instruction manuals specific to the machinery and equipment being worked on and adherence to their directions.  Use of proper tools, as detailed in the instruction manuals.  Preliminary check of tools to be used.  Detail all suitable personal protection equipment (PPE) to be used (see § 12.8.10.2).  When applicable, use the permit to work system (see § 12.8.10.3).  Appointment of a responsible person. As far as practicable, a team leader in charge of supervising a work should not be directly involved in the work itself and his main task should be to make sure that all activities are being carried out correctly and in safe conditions.  Personnel in charge of specific activities, like operating lifting equipment, using hydraulic or pneumatic tools, starting machinery, must be familiar with their tasks and should be examined and checked in advance FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 17 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 12.8.12.2 Use of PPE Basic rules for using PPE on board are summarized in table 12.8.a. Table 12.8.a Use of PPE is compulsory for all ship’s personnel (art. 8 - § 1c)), no matter of his rank, seniority or task, under the direct responsibility of CE and CO. CE and CO should make sure that the PPE outfit of their Departments is always adequate, and should request their supply as necessary to the Marine Department (AR) (see § 12.8.1.5). FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 18 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 Permit to Work System There are many types of operations on board ships where the routine actions of one man may inadvertently endanger another or when a series of action steps need to be taken to ensure the safety of those engaged in a specific operation. It is always necessary, before beginning a work, to identify its hazards and then to ensure that they have been eliminated or effectively controlled. (see § 12.8.10.1). Work permits herein detailed are Existing Control Measures for the reduction of the severity of identified hazards. The permits system in use on board Company’s ships is based on instructions and checks clearly defined in special lists, requireing formal actions by those responsible for the work and their recording. It comprises: 1. Entry into Enclosed Spaces 2. Hot Work 3. Particular Works (aloft, ship-side, electric machinery, sea water systems) 4. Underwater Inspection & Work 5. Lifting Operations 6. Cold Work Permit 7. Lock Out – Tag Out Permit The system consists of special Permits forms, including a checklist, to be completed and signed by the responsible persons before beginning the work. Permits give a description of the operations to be carried out and, by means of the checklist, allow to make an assessment of working conditions and associated risks and to specify the precautions to be taken to avoid any danger to the people performing such operations. A permit to work does not represent in itself a guarantee of safety for its performance, as it cannot take into consideration all unusual or unforeseeable events which may however happen, but it represents an effective means of prevention for accidents if all persons in charge of enforcing it follow with awareness and cleaverness the required procedures. As a rule, the following guidelines should be observed:  assessment of working conditions and permits signature must be carried out by the Responsible Officer (R/O), i.e. the CE and the CO, in their capacity of responsible persons in charge of on-board prevention and workers protection service (RESAL) for their Departments (art. 6.5) (see § 12.8.1.2);  before signing a permit the R/O must personally check that all preventive measures have been taken, and give appropriate instructions to make sure that they will be maintained throughout the period of validity of the permit;.  the permit must be issued by the Master, in his capacity of responsible person for the prevention and seamen protection service on board (art. 6.5);  a permit must contain a clear indication of its period of validity;  permits must be integrally completed;  information contained in the permit must be detailed and clear;  a permit must be considered as a set of instruction to be followed and its procedures must be applied exactly, unless different written orders are given;  only the work described in the permit may be carried out;  the permit must be handed over to the Team leader responsible of the work (R/W) to be carried out who in turn must check that all required safety measures have been taken and sign the permit for acknowledgement;  as soon as the work has been completed, the R/W must notify the R/O, giving him back the permit, signed and entered with the time of completion;  when necessary, more than one permit should be issued for the same work (for instance, Enclosed Spaces Entry Permit and Hot Work Permit). FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 19 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 All permits must be kept on board in their Deck and Engine Departments files for at least 3 years. Detailed information on the Permit to Work system are contained in Chapter 9 – § 9.3. of the ISGOTT – 5th edition 2006 12.8.12.3.1 Enclosed Spaces Entry Permit - Enclosed Spaces Entry Log. An entry permit must always be issued whenever one or more persons have to enter a space where a factor of risk (low or high) for human life may exist. To assess the factor of risk of an enclosed space inner atmosphere, the following conditions must be accertained:  want or lack of oxygen;  presence of toxic or dangerous gases;  presence of sediments or substances which are likely to cause want of oxygen (like stagnant water, large rust formations, etc.) or to release toxic or dangerous gases.  ventilation;  conditions and contents of adjacent spaces;  isolation of adjacent spaces, pipings, systems or machinery interesting the space to be entered;  results of preliminary atmosphere test carried out by portable instruments must be:  Oxygen (O2 Meter) : - Volume equal to 20,8%.  Flammable gas (Explosimeter): - LEL less than 1%  Toxic gas (Gas detector tubes): - Totally absent. Compartments who contained or are normally used to contain petroleum (oil cargo, fuel oil) and adjacent spaces there to must always be considered as enclosed spaces having a HIGH FACTOR OF RISK. Careful consideration must be given to entering spaces which have remained closed for a period of time. Spaces such as Emergency Generator rooms, Inert Gas ventilators room, Enclosed life boats, Battery rooms and any spaces that may be deficient of oxygen. Ventilation must be in operation for at least ten minutes prior to entry into small places. Entry in such spaces is subject to the observance of the following additional safety rules:  repetitive atmosphere tests during operation must be carried out, carefully recorded in the permit itself;  in no case a high risk enclosed space may be entered in the absence of the R/O and of a specially- appointed liaising person supervising entry, standing at the entrance;  the person supervising the entry shall log all people entering the space by rank, name, time of entry and time of exit, checking that, at any time, the number of persons in the space does not exceed the maximum number of persons allowed there in;  all entries and exits must take place within the time frame specified both on the entry permit and on the entry log;  on completion of work, or of the working day, the log shall be closed by the responsible person with time and signature. Nobody shall enter any enclosed space for the purpose of helping a person in troubles unless he has first taken all appropriate precautions for his own safety; this in order both to avoid risking his own life and making worse the conditions of the person in troubles (see Section 8.3 – Emergency Checklist No. 20). In case of any difficulty space must be immediately cleared by everybody. Detailed information on enclosed spaces are contained in Chapter 10 of the ISGOTT – 5th edition 2006. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 20 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 12.8.12.3.2 Hot Work Permit A Hot Work Permit must be issued every time that works involving sources of ignition or temperatures sufficiently high to cause the ignition of a flammable gas mixture have to be carried out. This includes any work requiring the use of welding, burning or soldering equipment, blow torches, some power driven tools, portable electrical equipment which is not intrinsically safe or contained within an approved explosion-proof housing, and internal combustion engines (ISGOTT – Definitions, page xxviii). Procedures to issue a Hot Work Permit vary in accordance with its location. Detailed information on hot work are contained in Chapter 9 – § 9.4. & 9.8.13 of the ISGOTT – 5th edition 2006. 1) General precautions AA The only designated space on board where conditions are deemed safe for the performance of hot work is the engine room workshop (ISGOTT - § 9.4.2). BB Hot work to be carried out in any other part of the ship must be approved in advance by the Technical Department of the Company. In requiring such approval, the shipboard management must provide sufficient information for the Technical Department to make a considered judgement on the proposals and in particular to review, challenge and approve the risk assessment carried out by the ship. CC A Hot Work Permit must be issued for all works carried out both in the engine room workshop (7-day permit) and in any other locations on board (One job only permit). DD No hot work can be performed on board whenever loading, discharging, bunkering, tank purging, washing and gasfreeing operations are being carried out EE No Hot Work may be carried out on board while the ship, even if idle, lays alongside an oil dock. FF Hot work area must be checked by the explosimeter (LEL<1%). GG Adjacent spaces which may contain hydrocarbon vapours within 0.5 m from hot work must be tested and declared Safe for Hot Work. HH Adjacent spaces which may contain hydrocarbon vapours outside 0.5 m from hot work must be below 10% LEL. II Pipeline or equipment being worked must be free of liquid. JJ Pipeline or equipment being worked must have been gas freed. KK Hot work does not reduce vessel fire fighting capability. LL Adequate ventilation is provided. MM Objects on which work has to be done and surrounding area have been cleaned of all flammable material. NN A work planning meeting has been held and the risk assessment has been completed. 2) Specific precautions Workshop: - The permit has a duration of one week and is valid for all hot work being carried out during that period. The permit becomes invalid whenever the vessel is in the conditions as per previous points DD and EE. - Workshop housekeeping must be maintained. - Welding curtain must be in good conditions and properly set. - Ventilation must be suitable to the work to be done. - Engineer on watch/duty must be notified of beginning and completion of all hot work. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 21 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 Machinery space (Engine room & casing – Steering gear compartment): - The permit has a maximum duration of 24 hours and is valid for only one work. - Hot work has been authorized by Company’s Technical Department (authorization enclosed to permit). - Technical Department is being notified of beginning and completion of hot work. - Bilges below hot work area have been checked free of flammable materials and vapours. - Hot work will be shielded to contain sparks. - Hot work on pipes used to carry flammable liquids: Section has been dismantled. - Hot work on pipes sections extending beyond space: Section has been blanked. - Engineer on watch/duty is being notified of beginning and completion of all hot work. - A new permit will be issued if hot work is stopped for more than 6 hours. Poop Deck: - The permit has a maximum duration of 24 hours and is valid for only one work. - Hot work has been authorized by Company’s Technical Department (authorization enclosed to permit). - Technical Department is being notified of beginning and completion of hot work. - Hot work may be carried out only underway in the open sea. - The work will be carried out in suitable wind and weather conditions. - Hot work will be shielded to contain sparks. - Work will not continue if sparks drift towards bunker tanks air pipes or flammable material. - Fire pump is being kept running with fire hoses led out and connected. - A new permit will be issued if hot work is stopped for more than 6 hours. Open decks: - The permit has a maximum duration of 24 hours and is valid for only one work. - Hot work has been authorized by Company’s Technical Department (authorization enclosed to permit). - Technical Department is being notified of beginning and completion of hot work. - Hot work may be carried out only underway in the open sea. - Cargo and slop tanks within a radius of at least 30m. around the working area have been purged with - IG and their hydrocarbon vapour content reduced to <2% by volume - Hot work will be shielded to contain sparks. - Work will not continue if sparks drift towards flammable material. - Fire pump is being kept running with fire hoses led out and connected. - A new permit will be issued if hot work is stopped for more than 6 hours. All other ship's locations: - The permit has a maximum duration of 24 hours and is valid for only one work. - Hot work has been authorized by Company’s Technical Department (authorization enclosed to permit). - Technical Department is being notified of beginning and completion of hot work. - Appropriate fire-fighting equipment is laid out and ready at working area. - A new permit will be issued if hot work is stopped for more than 6 hours. 12.8.12.3.3 Work Permit A Work Permit must be issued every time that one or more of the following operations have to be performed on board:  working aloft on bosun’s chair or scaffolds (> 2 m.);  working on the ship side (suspended or on rafts);  working on electrical systems or equipment;  working on sea water systems. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 22 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 12.8.12.3.4 Underwater Inspection and Work Permit All hull works or inspections carried out by divers or scuba divers must always be authorized in advance by the Technical Department (UT) of the Company, unless a particular local emergency situation does not allow any delay. A special permit must be issued in the prescribed way before beginning any underwater activity, together with any applicable work permit. This permit is a Company’s safety procedure which must be always followed by all those concerned. It is additional to any safety measure or assistance requested by the diver or scuba diver, and should be signed for acknowledgement by all parts involved in the operation. 12.8.12.3.5 Work Permit for Lifting Operations A Work Permit must be issued every time that lifting operations are carried out on board using the equipment listed in the RECORD OF SHIP’S LIFTING APPLIANCES AND CARGO GEAR (ILO/152), like handling cargo/bunker hoses, rigging gangway, loading stores and provisions, moving pieces/weights, transferring people, performing machinery maintenance in engine and cargo pump rooms, etc. 12.8.12.3.6 Cold Work Permit A Cold Work Permit must be issued for any work carried out in a hazardous or dangerous area that will not involve generation of temperature conditions likely to be of sufficient intensity to cause ignition of combustible gases, vapours or liquids in or adjacent to area involved. 12.8.12.3.7 Lock Out – Tag Out Permit A Lock Out - Tag Out permit must be issued in order to prevent incident caused by the accidental starting of equipment during maintenance, a lock- out/tag-out procedure is to be adopted and used on energy isolating devices. 12.8.12.3.8 – Safe Operation of Cranes & Lifting Appliances.  A load greater than the Safe Working Load must never be lifted unless it is a test required by regulation and is performed by a competent person.  The weight to be lifted must always be know. If not, then every effort must be made to obtain this information.  Lifts of unknown weights considered close to the Safe Working Load of the lifting appliances must not be lifted until the weight is determined.  The Ch. Officer/Ch. Engineer must always be consulted if there is any doubt.  The Safe Working Load of any lifting appliance must be clearly posted on the appliance.  Only those personnel trained and competent to do so, and authorized to do so by a responsible Ship’s Officer, may operate any lifting appliance, except in the event of an emergency endangering health or safety.  Training shall consist of theoretical instruction and supervised practical experience, in order that the trainee appreciates the factors affecting the safe operation of the lifting appliance.  Preparation for use: (See Operational procedures and Manufactures instructions on board).  Switch on power for required lifting appliance. Check that all power settings are correct. Be sure that the 2 speed change valve is in load position before manoeuvring the crane and also after use the crane be FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 23 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 sure that the 2 speed change valve is in load position. Remove all lashings. Raise lifting appliance to ready use position.  All lifting appliances should be thoroughly inspected prior to use, this inspection must include, as a minimum, condition of all falls and wires, control levers (free and effective movement) power supplies (Hydraulic & Steam Leaks), Safe Working Load and condition of all fittings.  All operational modes must be used prior to any lift being made – any abnormalities, strange noises must be reported to the Master/Ch. Engineer and investigated/resolved prior to any lift being made.  Where the operator’s visibility is restricted a system of communication must be agreed to in advance, this may include radios, hand signals, or other effective systems. Standard hand signals must be displayed as appropriate and all crew are to be familiar with the signalling system.  Proper use must be made of tag lines to control loads and all lifting operations fully discussed with all involved prior to commencing a lift.  When the crane is in operation, all personnel (except the operator) must remain outside the area (arc) of operation. Movement within this area must only be made when connecting/disconnecting lifts to/from the hook.  Securing after use. Switch on power to required lifting appliance. Check that power settings are correct. Lower lifting appliance to securing position. Secure all lashings. Switch power off.  All maintenance must be carried out as per manufacturers instructions and the vessels Planned Maintenance System.  Note: Only one person is to be nominated as a signaller to the lifting appliance operator for each operation.  Full use must be made of the guidance given in the Code of Safe Working Practices in addition to the above requirements. This publication should also be used for training purposes. 12.8.12.3.9 - Guarding of openings Hatchways that are open for handling cargo or stores, through which persons may fall or on which they may trip, should be closed as soon as work stops, except during short interruptions or where they cannot be closed without prejudice to safety or mechanical efficiency because of the heel or trim of the ship. The guardrails or fencing should have no sharp edges and should be properly maintained. Where necessary, locking devices and suitable stops or toe-boards should be provided. Each course of rails should be kept substantially horizontal and taut throughout their length. Guardrails or fencing should consist of an upper rail al a height of 1 metre and an intermediate rail at a height of 0.5 metres. The rails may consist of taut wire or tau chain. Where the opening is a permanent access way, or where work is in progress which could not be carried out with the guards in place, guards do not have to be fitted during short interruptions in the work (e.g. for meals), although warning signs should be displayed where the opening is a risk to other persons and in order to avoid that people remain trapped inside. Above mentioned procedure should apply also to all the space provided of external locking device and not provided with an unlockable device from the inner side (eg. Bosun store, pumpman workshop, etc.). FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 24 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 12.8.12.4 STOP WORK AUTHORITY PROGRAM Introduction The Company’s employees (including shore personnel and vessels crew), contractors and visitors have the responsibility, authority and obligation to halt an operation if the situation appears unsafe or work is being performed in what appears to be an unsafe manner, or where concerns or questions regarding the control of health, safety, security and environmental risk exist. Each person entering any work site onboard and ashore, agrees to comply with the safety rules and procedures that have been conveyed to them as part of their job or safety induction and in accordance to the Company’s SMS. When an employee, contractor or visitor notifies a supervisor of an unsafe act or condition, it is the supervisor's responsibility to either correct the safety issue immediately or protect the crew from the safety hazard, and also to develop a plan to eliminate the hazard. No work will resume until all Stop Work issues and concerns have been adequately addressed. Any form of retribution or intimidation directed at any individual or company for exercising their authority as outlined in this program will not be tolerated. Key Responsibilities All Company’s employees (including shore personnel and vessels crew), and contractors are responsible to initiate a Stop Work intervention when warranted, support the intervention of others and properly report all Stop Work actions. The DPA and the vessel’s Masters are responsible for monitoring compliance with the requirements of this program; maintaining associated documents, records and training materials; identifying trends; sharing lessons learned and exchanging information within the Office and the fleet. The Company’s Managers, the heads of vessel’s departments (Chief Office and Chief Engineer) and the attending Superintendents (if present onboard) are responsible to create a culture, where SWA is exercised freely, honor request for Stop Work, work to resolve issues before operations resume, recognize proactive participation and verify that all Stop Work actions are properly reported with required follow-up completed. Procedure In general terms, the Stop Work Authority (SWA) process involves a stop, notify, correct, and resume approach for the resolution of a perceived unsafe work action or conditions. Most like likely to participate in such process is personnel that clearly understands how to initiate, receive and respond to a Stop Work intervention, similarly to the behavior-based safety processes. Some key indicators of safety and job task hazards that require an employee to Stop Work are (not limited to): 1. A change: A modification or alteration that deviates from the way the job task is normally performed or from the written procedural instructions may cause unsafe work actions or conditions. For example, using a different tool, altering a standard procedure to meet new job task requirements, making a change to the work plan, or observing parameters that are outside the standard procedures. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 25 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 2. An unscheduled event: An unplanned event that distracts employees from the job task being performed may cause unsafe work actions or conditions. For example, inclement weather, simultaneous work occurring nearby, or a community or property owner activity following an accident or spill. 3. An observation with safety impact: Whenever any person observes a condition or situation that has an impact on safety. For example, a hose lying across a walkway, a spill that has not been cleaned up, a loose handrail or a damaged tool. 4. An incomplete understanding: Whenever any person involved with an operation or a coworker does not completely understand instructions, procedures or ongoing activities. For example, making assumptions about job task steps, uncertainty over the order that job steps are performed, or differing opinions about how a job task is performed. 5. Relay information: Whenever a situation requires critical information to be relayed, an unsafe work action or condition may occur. For example, shift change or crew reassignment. 6. Observing new hazards: Whenever a person encounters risks that have not been addressed during previous job safety analysis or risk assessments. For example, new PPE requirements based on job task demands previously unidentified. 7. A need to ask for help: Whenever a job requires additional people, or the experience level of the person performing the job task requires support, an unsafe work action or condition may occur. For example, working to meet production demands and performing a two-person procedure alone, an inexperienced worker who does not ask for help, not asking for help with a heavy lift, or needing help with reading a drawing or sketch. The following steps should be the framework for all Stop Work interventions: Step Protocol Instruction 1. When a person identifies a perceived unsafe condition, act, error, omission, or lack of understanding, a Stop Work intervention shall be immediately initiated with the person(s) observing and/or those who are potentially at risk. 2. If the Person in Charge for the specific work is readily available and the affected person(s) are not in immediate risk, the Stop Work Action should be coordinated through the Person in Charge. If the Person in Charge is not readily available or the affected person(s) are in immediate risk, the Stop Work intervention should be initiated directly with those at risk. 3. Stop Work interventions should be initiated in a positive manner by briefly introducing the identifying person’s oneself and starting a conversation with the phrase, “I am using my Stop Work authority because.” Using this phrase will clarify the user’s intent and set expectations as detailed in this procedure. 4. All affected personnel and supervision should be notified of the Stop Work issue. If necessary, associated work activities should be stopped, person(s) removed from the area, the situation stabilized and the area made as safe as possible. 5. All parties involved in the specific operation shall discuss and gain agreement on the Stop Work issue. 6. If determined and agreed that the task or operation is safe to proceed as is (i.e., the Stop Work initiator was unaware of certain facts or procedures) the affected persons should thank the initiator for their concern and proceed with the work. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 26 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 7. Proceed with the job task safely:  Ensure that any recommendations in the applicable Risk Assessment (RA) or management of Change (MOC), as necessary, are implemented.  Develop temporary procedures or revise existing procedures to accurately, safely perform the job task.  Confirm that everyone understands the job task as it is about to be performed.  Confirm that proper tools, materials, spill prevention/remediation equipment or personnel, etc. are available.  Confirm that the appropriate and trained workforce is available.  Determine if there is enough time to perform the job task safely. Confirm that the communication is appropriate (spotters, hand signals, signage, language barriers, etc.). 8. If the Stop Work issue cannot be resolved immediately, work shall be suspended until proper resolution is achieved. When opinions differ regarding the validity of the Stop Work issue or adequacy of the resolution actions, the Person in Charge for the specific work/operation shall make the final determination. Details regarding differences of opinion and resolution actions should be included in the documented report. 9. All Stop Work interventions and associated detail shall be documented and reported to the heads of vessel’s departments (Chief Office and Chief Engineer) and the attending Superintendents (if present). Documentation and follow-up All Stop Work interventions exercised in accordance to the present procedures shall be documented as a Near Miss utilizing the Company’s controlled Near Miss Report. The Near Miss report shall refer specifically to the intervention by using the words “STOP WORK” at the beginning of the incident description in order to differentiate it from traditional Near Miss reports. Stop Work reports shall be reviewed by the vessels’ Masters (or by attending Company’s representatives during dry-dockings and new-building projects) in order to: 1. Measure participation. 2. Determine quality of interventions and follow-up. 3. Trend common issues and identify opportunities for improvement. 4. Facilitate sharing of lessons learned. 5. Support recognition programs. The DPA will also regularly circulate incident details regarding the number of Stop Work actions reported across the fleet and in other worksites of interest (such as during dry-dockings and new building sites), as well as details regarding common trends and lessons learned. Normally, it is the desired outcome of the Stop Work intervention that identified safety concerns are addressed to the satisfaction of all involved persons prior to the resumption of work. Although most issues can be adequately resolved in a timely fashion at the job site, occasionally additional investigation and corrective actions may be required to identify and address root causes. Stop Work interventions that required additional investigation or follow-up will be handled utilizing existing procedures and documentation requirements for Incident Investigation. In order to build and reinforce a culture in which Stop Work Authority (SWA) is freely exercised and accepted, positive feedback should be given to all affected personnel regarding resolution of the Stop Work issue and FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 27 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 under no circumstances should retribution be directed at any person(s) who exercise, in good faith, their Stop Work authority as detailed in this program. In this context the vessels’ Masters (or the attending Company’s representatives during dry-dockings and new-building projects) are encouraged to positively recognize crew and contractor participation in the program, as follows: 1. Informal recognition should be ensured a minimum, in the form of an expression of appreciation for a job well done, of individuals when they exercise their authority to Stop Work or demonstrate constructive participation in a Stop Work intervention. 2. Additionally, formal recognition of selected examples of Stop Work interventions and those responsible should be made during regularly scheduled safety meetings. Training Requirements Training regarding this Stop Work Authority (SWA) Program shall be conducted as part of all new crew and contractors’ familiarization, upon embarkation, with records maintained in the respective Familiarization Records. Additionally, a review of the SWA Policy shall be carried out as part of the MRM and regularly during the vessels’ safety meetings and the Masters System’s Review Reports. 12.8.13 MANAGEMENT OF SHIP’S LIFTING TOOLS A complete list of all lifting tools (chain-blocks, lifting beams, mucking winches, pad eyes, wire and band slings, etc.) existing on board, both in the engine room and on deck, not subject to ILO Convention 152 (see Register of Ship’s Cargo Gear Handling and Machinery Gear) must be kept both on board and in the Technical Department of the Company.  All tools must be clearly identified, certified and marked with their SWL and testing data.  Use of un-marked unidentifiable lifting tools is prohibited. If found on board, such tools must be immediately disposed of in the prescribed way.  Manufacturing, modifying or adjusting hoisting tools of any kind (wire and rope slings, buckets made out of used paint pails, extensions, welded or threaded parts, etc.) represent a serious violation of the existing safety laws.  Lifting tools must be stored on board in a tidy and orderly way, in their proper containers or in special lockers, with clear indications of their use.  Tools intended for specific operations or special work shall never be used for any other purpose.  All lifting tools must be visually inspected every six month. The inspection shall be carried out by the heads of the ship’s departments, CE for Engine and CO for Deck departments.  Lifting tools shall be landed for traction-testing and certification at every ship stay in a shipyard for drydocking.  Assorted small lifting tools, like slings or shackles not being part of special systems or devices, should be kept in a special container, and shall be renewed every five years.  Engine and Deck lifting tools and relevant inspection and testing operations are included in the ship’s planned maintenance system (PMS) AMOS. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER JANUARY 2017 0 28 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 12.8.14 ADDITIONAL INFORMATION Useful information on safety of working environmant on board are contained in the following pubblications (see Chapter 6 - Appendix):  MCA – Code of Safe Working Practice for Merchant Seamen  ICS – Safety in Tankers  ICS/OCIMF – International Safety Guide for Oil Tankers & Terminals (ISGOTT). FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 1 of 5 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER 13 COMMUNICATIONS 13.1 FOREWORD The Company is well aware that an effective communication system at all levels is of paramount importance for a safe management of the ships. This is true both for ship/shore and for onboard communications . 13.2 SHIPS COMMUNICATION SYSTEMS 13.2.1 – GMDSS All Company’s ships are fitted with a radio communication Global Maritime Distress and Safety System (GMDSS) for sea areas A1, A2 e A3 (SOLAS 74/78 – IV/7 & 10) consisting of: ⇒ n. 2 satellite INMARSAT Standard C systems: • Continuous automatic reception of EGC SafetyNET messages: ◊ distress, urgency and safety broadcast by the appropriate MRCC ; ◊ Maritime Safety Information (MSI): METAREA weather reports and warnings, NAVAREA navigational warnings. • Automatic transmission of distress messages to the appropriate MRCC. • Public correspondence (CP) telex via Coast Earth Stations (CES). • Transmitting, via CES, ships reporting system messages (ARES, AMVER, etc.). ⇒ n. 1 SSB MF/HF radio-telephone transceiver: • Continuous automatic reception of distress messages transmitted by other ships or coast stations on DSC frequencies. • Automatic transmission of distress messages on DSC frequencies. • Public correspondence (CP) via coast radio stations. ⇒ n. 2 VHF radio-telephone transceivers: • Continuous automatic reception of distress messages transmitted by other ships or coast stations on DSC channel 70. • Automatic transmission of distress messages on channel 70 (DSC). • Continuous watch on channel 16. • Port operations channels: Communications with VTS, pilot stations, port authorities. • Intership channels: Ship-to-ship [bridge-to-bridge in U.S.A.] communications. • Public correspondence (CP) via coast radio stations. ⇒ NAVTEX receiver: • Continuous automatic reception of local MSI (weather reports and warnings, navigational warnings) broadcast on MF by Navtex coast stations. ⇒ Emergency Position Indicating Radiobeacon (EPIRB): • Automatic transmission on 406 Mhz of the distress and location signal for the COSPAS-SARSAT satellite search and rescue system. ⇒ Long Range Identification and Tracking (LRIT): • Automatic transmission of ship’s identity and position, for safety, security and pollution prevention purposes, every 6 hours or following a polling command, to the Flag State Administration. (SOLAS 74/78 – V/19.1) Ship’s survival craft are fitted with the following radio-communications equipment (SOLAS 74/78 – III/6.2): ⇒ n. 3 VHF portable radio-telephone transceivers with DSC. ⇒ n. 2 Search and Rescue Radar Transponders (SART) operating on 9 GHz band. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 2 of 5 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER 13 COMMUNICATIONS 13.2.2 – Additional systems One or more of the following INMARSAT radio communication systems are fitted on board ships for their operational and commercial needs: ⇒ Standard B / FLEET77: • phone, fax, e-mail; ⇒ FLEET BB / VSAT C: • phone, fax, e-mail, data; ⇒ Mini M: • phone, fax. These systems are also used by the following ship’s equipment: • ChartCo: Reception and management of Weekly Notices to Mariners for the updating of UKHO charts and publications (ChartManager). – Reception of meteorological charts and weather reports (MetManager). • Telephone booth for crew private traffic with pre-paid cards. ⇒ VHF radio-telephone transceiver in cargo control room: • Direct communications with terminals during loading and discharging operations. • Direct communications with other ship/ barges during lightering/bunkering operations. 13.2.3 – Shore Based Maintenance Service The shore based maintenance service required by SOLAS 74/78 – IV/15 for GMDSS and all ships radio-communication equipment is assured by the appointed radio-electric services Companies TELEMAR or ITS (SIRM), of Rome. The relevant certificate is permanently posted on board near the GMDSS console. 13.2.4 – Responsibility ITU – Radio Regulations 1994 – Chapter XI - Article 54: § 1 – The service of a ship station is placed under the supreme authority of the master or of the person responsible for the ship or other vessel carrying the station. § 2 – The person holding this authority shall require that each operator comply with these Regulations and that the ship station for which the operator is responsible is used, at all times, in accordance with these Regulations. All incoming and outgoing communications handled by the officers in charge of GMDSS take place always and in every case under the authority and responsibility of the Master who must authorize all traffic, of any kind, originating from the ship. It is the duty of officers in charge of GMDSS and radio communications to submit to the master all incoming and outgoing messages, both commercial or private. 13.2.5 – Secrecy of communications ITU - Radio Regulations 1994 – Chapter XI - Article 54: § 3 – The master or the person responsible, as well as all persons who may have knowledge of the text or even the existence of a radio-telegram, or of any information whatever obtained by means of the radio-communication service, are placed under the obligation of observing and ensuring the secrecy of correspondence. Present location of the radio equipment on the navigation bridge does not always allow the possibility of ensuring the right privacy of all incoming and outgoing correspondence, both commercial or private. It is the duty of the GMDSS Responsible Officer and, in his absence, of the Officer of the Watch, to check that no person unconnected with the service, whatever his rank or position on FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 3 of 5 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER 13 COMMUNICATIONS board, may look over or learn about messages or information received or sent by means of the equipment located on the navigation bridge. They must keep the secrecy of all communications they may happen to learn about. 13.2.6 – On-board radio-communications On-board internal radio communications required by ship’s various activities (docking, anchoring, cargo operations, etc) must be made exclusively by the special intrinsically safe UHF portable radio transceivers available on board all ships. Their radiated power must be always less than 1W. 13.3 SHORE COMMUNICATION SYSTEMS Company’s head office is fitted with an e-mail and a telephone system assuring the reception and sending of all types of messages, so organized: • All departments are provided with their own e-mail address. Such address are not shared among different offices and messages sent to them cannot be read by other departments. • Individual e-mail address are assigned to all members of the Company’s shore staff. Such address are intended for Company’s internal use and for contacts with third parts, and should never be used for ship/shore/ship communications. • The system handles each e-mail address separately, so that a mail sent to a certain address can be worked (read, answered, resent, shared) only by its holder (office or person). • Phone numbers and e-mail address are detailed in the Annex to Chapter 3 of this manual, as well as in the special lists both ashore and on board (see Chapter 3, § 3.6). In order to assure a safe reception and a correct handling of all ships’ messages, the following rules must be followed:  All messages must be sent to the address of the department in charge of the subject. The attention of a particular person of the department staff may be called in the message, as appropriate  No message can be sent to the individual address of anybody of the shore staff, irrespective of his position, function or rank, for whatever reason.  The subject must always be entered atop all messages. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 4 of 5 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER 13 COMMUNICATIONS 13.4 ROUTINE MESSAGES Ships shall send to the Company the following messages: 1) Departure message – At Engine Full Away: - Departure port. - Date/local time/UTC. - Port of destination. - ETA: Date/local time. - Replenished: HSFO - LSFO - LSDO - MGO - Luboils - Fresh Water. - R.O.B.: HSFO - LSFO - LSDO - MGO - Luboils - Fresh Water. 2) Daily position message (SOLAS 74/78 – V/28.2) – At ship’s noon: - Voyage speed order (Full wording) - Date. - UTC. - Position. - True course & Average speed. - Wind and Sea: Direction/force. - Details of any external or internal conditions that are affecting the voyage or the normal safe operation of the ship. - ETA: Date/local time. - ETB: Date/local time (if known). - ETD: Date/local time (if known). - ME RPM. - ME consumption: HSFO - LSFO. - Gensets consumption: HSFO - LSFO - LSDO - MGO. - Boilers consumption: HSFO - LSFO - LSDO - MGO. - ME Cylinder oil consumption. - R.O.B. ME Cylinder oil: HS - LS. - Slip. - Fresh Water production. - Drinking Water consumption. - Distilled Water consumption. - R.O.B. Fresh Water. 3) Arrival message – At Stand-by Engine: - Arrival port. - Date/local time/UTC. - ETB: Date/local time (if known). - ETD: Date/local time (if known). - R.O.B.: HSFO - LSFO - LSDO - MGO - Luboils - Fresh Water. Messages shall be addressed to all Company’s Departments and Office. In conformity with SOLAS 74/78 – V/28.2 requirements, messages are monitored by the HSEQ Department which, in case of non- reception, shall contact the concerned ship to check her regular operational conditions, and shall retain them for the entire duration of the voyage at least. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 5 of 5 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER 13 COMMUNICATIONS 13.5 COMMUNICATIONS IN EMERGENCIES The following situations must be considered as emergencies: A a risk exists for the safety of human life on board and/or at sea; B a risk exists for the safety of the ship and/or the cargo; C a pollution happened, or there exist a risk of pollution; D a threat exists for the security of the ship and/or the port in which the ship lays. Emergency situations must be notified to the Company as detailed in Chapter 8.9 of this manual. 13.6 ON-BOARD COMMUNICATIONS Section 12.2.3, § 12.2.3.8 clearly states that the exchange of information necessary for the regular operation of the ship between the Master and the Chief Engineer must be in writing. As a rule, all other communications (instructions, inquiries, orders, etc.) are given verbally. However, in some special circumstances, a written exchange of communications may become necessary. Such circumstances may be: • when, because of urgent repair works to be carried out by the engineering department, it is necessary to reduce the ship’s speed or to stop the main engine; • in case of disagreement between the Master and the Chief Engineer (for instance, when the main engine power output requested by the Master is not supplied by the Chief Engineer); • when the Master or the Chief Engineer modify instructions or procedures stated in this manual or otherwise required by the Company; • in case of a repeated refusal by one of the ships Officers to obey an order given by the Master or the CE. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 1 of 8 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER SHIPS DOCUMENTS AND LOGBOOKS 14 STATUTORY MANUALS & DIRECTIONS 1.2 OBJECTIVES 1.2.3 The safety management system should ensure: 1) compliance with mandatory rules and regulations 2). that applicable codes, guidelines and standards recommended by the Organization, Administrations, classification societies and maritime industry organizations are taken into account 11. DOCUMENTATION 11.1 The Company should establish and maintain procedures to control all documents and data which are relevant to the SMS 14.1 Periodical check and renewal of certificates On board all ships, the Master must keep a list of the ships certificates and documents, continuously updated. On signing off, the Master shall hand over the updated list to his relief and shall enclose a copy of it to the Handing-over Report (see Chapter 5, § 5.3.3(v)). Ashore, the Technical Department maintains a computer-based list, updated with the dates of expiry, which can be accessed on-line by all Company’s offices, and a general file of copies of all ships’ documents and papers. Technical department is responsible for monitoring of “Condition-Of-Class” (CoC), or equivalent items. The CoC will be closed out as soon as possible. CoC and Recommendations are regularly monitored (at least monthly) by accessing to Class Website. Company police requires immediate close up. a) Documents subject to renewal and endorsement surveys: Surveys are organized by the Company’s Technical Department (UT): a) The Department organizes the surveys, taking into account the ship’s voyages and operational needs, and keeps in touch with the classification Society (RINA), the Flag State authorities (central, local, consular) and with the qualified organizations and firms whose intervention is due. b) The Department notifies the Master of the port and date of the surveys. c) The Master, assisted in case by one of the Company’s Technical Superintendents, co-operates with surveyors and Flag State officers in carrying out the surveys on board. d) On completion of surveys, the Master updates the ship’s documents list and sends a copy of it to the Technical Department (UT), together with copies of all documents issued to the ship or endorsed by Flag State and classification societies. e) The Technical Department updates the computer-based office list and inserts into the general file the copies of the renewed or endorsed documents. b) ISM Code – Safety Management Certificate (SMC): Organization of audits for issue, periodical endorsement and renewal of ship’s SMC is the responsibility of the Designated Person Ashore (DPA), through the HSEQ Department, as agreed with the General Manager and the heads of the Company’s departments. a) The DPA applies for the audit at a convenient port and date to the competent Flag State authority (COTP, consulate), with copy to the appointed auditing body (RINA). b) The DPA notifies the Master of the port and date of the audit. c) The internal Auditor appointed by the DPA boards the ship and attends the audit, carried out by the appointed body (RINA) and, in national ports, by the local maritime authority as well. d) Once the appropriate “Declaration (Dichiarazione ai fini)” issued by RINA has been obtained, the internal Auditor, in co-operation with the Master, arranges for the issue, endorsement or renewal of the SMC by the competent authority. e) The SMC, issued or endorsed by the authority, shall be delivered to the Master who will see for his filing on board, for updating the ship’s documents list and sending a copy of it to the Technical Department. f) The Technical Department sees for the updating of the shore computer-based list. g) Internal Auditor delivers a copy of the SMC to the Technical Department, for insertion into the shore general file, and another copy to the DPA for the HSEQ Department special file. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 2 of 8 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER SHIPS DOCUMENTS AND LOGBOOKS 14 STATUTORY MANUALS & DIRECTIONS c) ISPS Code – International Ship Security Certificate (ISSC): Organization of audits for issue, periodical endorsement and renewal of ISSC is the responsibility of the Company’s Security Officer (CSO), through the HSEQ Department, as agreed with the DPA and the General Manager a) The CSO applies to the Captain of the Port of Rome, competent for Company’s head office location, jointly agreeing the port and date. b) The Office notifies the Master of the port and date of the audit. c) CSO boards the ship and attends the audit, carried out by the Duly Authorized Officer (DAO) of the COTP of Rome. d) On a positive outcome of his audit, the DAO issues to the ship a new ISSC, or endorses the existing one. The Master sees for his keeping on board, for updating the ship’s documents list and sending a copy of it to the Technical Department. e) The Technical Department sees for the updating of the shore computer-based list. f) The CSO delivers a copy of the SMC to the Technical Department, for insertion into the shore general file and sees for keeping another copy in the special file of the HSEQ Department. d) Documents issued to the ship through the Company (C.L.C., P&I, ITOPF, etc.): As a rule, issue and forwarding to the ships of such documents are in the care of the Chartering/Insurance, Administration and Crewing Departments. a) Documents are sent to the ship by the responsible department, which shall see for the filing of a copy in their archives and in the general file. b) The Master shall immediately acknowledge receipt of the documents and see for their keeping on board. He shall update the ship’s documents list and send a copy of it to the Technical Department. c) The Technical Department sees for the updating of the shore computer-based list. e) Documents issued directly to the ship: The Master shall apply well in advance, through the Agent, for the issue or renewal of the following documents: • In Italian ports : - Crew Roll (Ruolo Equipaggio). - Health & Hygiene Inspection. - Safety Inspection. - Ship’s Pharmacy Certificate. - Drink Water Tanks Certificate. • In foreign ports: - Ship Sanitation Control Exemption Certificate (SSCE). - When necessary, the Crewing Department takes care of the issue of the Crew Roll in foreign ports (consulates), in cooperation with the Master. Local authorities may also carry out safety inspections on board, issuing the relevant certificates or reports, as: - PSC. - U.S.C.G. Certificate of Compliance (COC). a) The Master updates the ship’s list and sends a copy of it and of the new document to the Technical Department (only the title page of the Crew Roll). b) The Technical Department acknowledges receipt and arrange for the update of the shore computer based list and general file. c) Data of the Crew Roll (number/serial, authority, place and date of issue/renewal) shall also be notified to the Accounting and Crewing Departments. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 3 of 8 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER SHIPS DOCUMENTS AND LOGBOOKS 14 STATUTORY MANUALS & DIRECTIONS 14.2 Documents issued by the Flag State 14.2.1 – Safety certificates Safety certificates issued to the ship by the Flag State through their Local Maritime Authorities (COTP, consulates) can be endorsed or written only by the authority itself, even if they are subject to surveys or audits carried out by the Appointed Body (RINA). In particular, the “Declaration to the purpose of the periodical endorsement (Dichiarazione ai fini della vidimazione periodica)” issued by the RINA surveyor must be submitted to the local authority in order to have a certificate endorsed but it can in no way substitute the endorsement itself. 14.2.2 – Crew Roll (Ruolo Equipaggio) Although it looks like a record-book, the Crew Roll is one of the ship’s papers, not a logbook (Italian Code of Navigation – Art. 169). Normally the local Maritime Authority of an Italian port issues it to the ship but, if necessary, it may be issued by a Consulate in a foreign port, in agreement with the MIT. It is valid for three years. The Maritime Authority must make all entries and records in the Crew Roll. The Crew Roll contains the ship’s data and the name of the Owners and Managers/Operators. Engagements and discharge of all crewmembers, and arrival and departure endorsements must be entered therein. All certificates issued to the ship (safety, class, health, crew insurance, etc.) must be recorded in the roll. The last part of the Crew Roll is reserved to the Master for recording civil status certifications for any event occurred at sea (birth, death, loss at sea, wills). 14.3 List of ship’s certificates and documents All Ship Certificates listed in the Form HSEQ 02 must be kept on board under Master control with all others documents. Master has to be kept update the Ship Certificates folder and Form HSEQ 02. The Form HSEQ 02 must be send to All Company’s Depts monthly, copy should be attached to the Master Handover report. 14.4 List of ship’s official log books The following logbooks must be kept on board (Italian Code of Navigation - First Part - First Book - Title V - Chapter III), as required by current national and international regulations: 1. NAUTICAL LOG – FIRST BOOK (C.d.N. - Art. 173) Ship’s Inventory GIORNALE NAUTICO – LIBRO PRIMO Inventario di bordo 2. NAUTICAL LOG – SECOND BOOK (C.d.N. - Art. 173) General and Accounting Log GIORNALE NAUTICO – LIBRO SECONDO Giornale generale e di contabilità 3. NAUTICAL LOG – THIRD BOOK (C.d.N. - Art. 173) Navigation Log GIORNALE NAUTICO - LIBRO TERZO Giornale di navigazione 4. NAUTICAL LOG – FOURTH BOOK (C.d.N. - Art. 173) Cargo Log FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 4 of 8 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER SHIPS DOCUMENTS AND LOGBOOKS 14 STATUTORY MANUALS & DIRECTIONS GIORNALE NAUTICO - LIBRO QUARTO Giornale del carico 5. ENGINE LOG (C.d.N. - Art. 175) GIORNALE DI MACCHINA 6. GMDSS LOG (C.d.N. - Art. 175) 7. OIL RECORD BOOK – PART I (MARPOL 73/78 – I/17) - Machinery space operations 8. OIL RECORD BOOK – PART II (MARPOL 73/78 – I/36) - Cargo/ballast operations 9. GARBAGE RECORD BOOK (MARPOL 73/78 – V/10.3) 10. DRILLS RECORD BOOK (R.S./91 - Art. 232.10) REGISTRO DELLE ESERCITAZIONI 11. FIRE-FIGHTING SERVICE LOG (R.S./91 - Art. 246) GIORNALE DEL SERVIZIO ANTINCENDIO 12. FIRE-FIGHTING EQUIPMENT INVENTORY (R.S./91 - Art. 246) INVENTARIO DEI MEZZI ANTINCENDIO 13. PHARMACEUTICAL RECORD BOOK (Ministry of Health Decree 28.02.2012) REGISTRO DI CARICO E SCARICO DEI FARMACI 14. MEDICAL DRUGS RECORD (Ministry of Health Circular Letter no.17 – 20.07.1994 & BOOK Ministry of Health Decree 28.02.2012) REGISTRO DI CARICO E SCARICO DEGLI STUPEFACENTI 15. LABOUR ACCIDENTS RECORD BOOK (D.L. 27.07.1999, no. 271 – Art. 25.2) REGISTRO DEGLI INFORTUNI 14.4.1 – Management of official logbooks (D.P.R. 15.02.1952, no. 328 – Regulations for the navigation code) Issue and endorsement (art. 362) – Before being put into service official log-books must be numbered and stamped with the official seal at the top of each sheet by the captain of the port or the consular authority. In the first page of each book a declaration, signed by the captain of the port, must be entered, stating the number of its pages, the name, type, home port and official number of the ship, the name of the master and the date of issue. Compilation (art. 363) – Official logbooks must be written out in order of date, in succession, with no blank spaces and notes between the written lines or on margins. Scrapings are not allowed and, were any deletion necessary, it must be made in such a way that the delated words remain readable. Blank spaces must be filled with pen strokes. Submission (art. 364) – Official logbooks must be submitted as requested by the merchant marine or consular authorities, which have power to issue copies of abstracts of them. Withdrawal and custody (art. 365) – When a ship is cancelled from its register the merchant marine or consular authorities withdraw the official logbooks and forward them to the ship’s register office for custody. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 5 of 8 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER SHIPS DOCUMENTS AND LOGBOOKS 14 STATUTORY MANUALS & DIRECTIONS Completed logbooks are withdrawn by the local authority who, having issued new logbooks in accordance with provisions of art. 362, forwards the completed ones to the ship’s register office for custody. Completed logbooks which have not been withdrawn by the maritime or consular authorities must be kept on board under Master’s responsibility, for their further or final delivery to the ship’s register office. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 6 of 8 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER SHIPS DOCUMENTS AND LOGBOOKS 14 STATUTORY MANUALS & DIRECTIONS 14.5 Statutory manuals and directions The following manuals, documents and guidelines must be made available on board as applicable and required by current national and international regulations: (a) Manuals and documents - Approved: 1a. - SMS MANUAL - [ISM Code - 11.3] – RINA approved. 2a. - STABILITY INFORMATION FOR THE MASTER - [SOLAS 74/78 - II.1/22] – RINA approved. 3a. - LOADING MANUAL FOR LONGITUDINAL STRENGTH IN CALM WATERS. - [RINA Rules - Section B] – RINA approved. 4a. - DAMAGE CONTROL PLAN AND BOOKLET (*) - [SOLAS 74/78 - II-1/B-4, 19] – RINA approved. 5a. - SHIPBOARD OIL POLLUTION EMERGENCY PLAN (SOPEP) - [MARPOL 73/78 – I/37] – RINA approved. 6a. - SHIP SECURITY PLAN - [SOLAS 74/78 - XI-2 – ISPS Code - A/9] – Flag State approved. 7a. - VESSEL RESPONSE PLAN (VRP) - [USA OPA-90] – USCG approved. 8a. - WATER BALLAST MANAGEMENT PLAN - [IMO Resolution A.868(20)] – RINA approved 9a. - V.C.S. MANUAL - [46 CFR 39] – RINA approved. 10a. - C.O.W. MANUAL - [MARPOL 73/78 – I/13B(5)] – RINA approved. 11a. - SAFETY PLAN (Safe Working Practice) - [D.L. 27.07.1999 no.271 - art. 6.1] – Flag State approved. 12a. - VOC MANAGEMENT PLAN (Volatile Organic Compounds) - [MARPOL 73/78 - VI/15.6] – Flag State approved. 13a. - STS OPERATIONS PLAN (Ship-to-Ship) - [MARPOL 73/78 - I/8.41.1]– Flag State approved. (*) Only for ships the keel of which has been laid after 01 January 2009. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 7 of 8 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER SHIPS DOCUMENTS AND LOGBOOKS 14 STATUTORY MANUALS & DIRECTIONS - Not approved: 14a. - GARBAGE MANAGEMENT PLAN - [MARPOL 73/78 – V/10(2)] 15a. - I.G.S. MANUAL - [FSS Code – 15/2.4.4] 16a. - O.D.M.E. MANUAL - [MARPOL 73/78 – I/15(3)(c)] 17a. - OIL TRANSFER PROCEDURES - BUNKERING - [33 CFR 155.720-155.785] 18a. - OIL TRANSFER PROCEDURES - CARGO OPERATIONS - [33 CFR 155.720-155.785] 19a. - MANUAL FOR FOOD SELF-CHECKING IN ACCORDANCE WITH HACCP METHOD - [DL 25.05.1997 n.155] 20a. - LSA TRAINING MANUAL (+) - [SOLAS 74/78 – III/35] including: LSA MONTHLY INSPECTION CHECK-LIST - [SOLAS 74/78 – III/20.7] 21a. - ON-BOARD LSA MAINTENANCE INSTRUCTIONS (+) - [SOLAS 74/78 – III/36] 22a. - FIRE-FIGHTING TRAINING MANUAL (+) - [SOLAS 74/78 – II-2/15.2.3] 23a. - FIRE SAFETY OPERATIONAL BOOKLET (+) - [SOLAS 74/78 – II-2/16.2] 24a. SAFETY OF WORKING ENVIRONMENT TRAINING MANUAL (+) - - [D.L. 27.07.1999, n. 271 - art. 6, § 5 e) i) p)] 25a. - EMERGENCY TOWING BOOKLET - [SOLAS 74/78 - II-1/3-4] 26a. - RECOVERY OF PERSONS FROM THE WATER - [SOLAS 74/78 - III-17-4] 27a. SEEMP MANUAL - - [MARPOL 73/78 – Annex IV] (+) Available to crew in the mess- or day-rooms. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 8 of 8 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER SHIPS DOCUMENTS AND LOGBOOKS 14 STATUTORY MANUALS & DIRECTIONS (b) Placards and plans 1b. - MUSTER LIST - [SOLAS 74/78 – III/8 & 37 – R.S./art. 203 – D.M. 27.02.02, no. 93] N.B.: On Flag State approved form. 2b. - LSA OPERATION AND LAUNCHING INSTRUCTIONS - [SOLAS 74/78 – III/9] 3b. - LIFE SAVING SIGNALS - [SOLAS 74/78 – V/29] 4b. - FIRE PLAN - [SOLAS 74/78 – II-2/15.2.4] N.B.: RINA approved. 5b. - MAGNETIC COMPASS DEVIATION TABLE (#) - [SOLAS 74/78 – V/19.2.1.3] 6b. - EMERGENCY STEERING CHANGE-OVER PROCEDURES - [SOLAS 74/78 – V/26.3.1] 7b. - WHEELHOUSE POSTER - [SOLAS 74/78 – II-1/28.3 & IMO Resolution A.601(15)] 8b. - INTERNATIONAL CALL SIGN - MMSI - [SOLAS 74/78 – IV/6.2.5] 9b. - GARBAGE COLLECTION AND DISCHARGE PROVISIONS - [MARPOL 73/78 – V/10.1] 10b. - DISCHARGE OF OIL PROHIBITED - [33 CFR 155.450] 11b. - SHIPBOARD WORKING ARRANGEMENTS (ORGANIZZAZIONE DEL LAVORO A BORDO) - [D.L. 27.07.1999, no. 271 - art. 11.9] N.B.: On Flag State approved form. (#) Endorsed by Flag State - Posted in the wheelhouse. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 1 of 20 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended - ISM Code CHAPTER 15 SAFETY MANAGEMENT SYSTEM DOCUMENTATION 11. DOCUMENTATION 11.1 The Company should establish and maintain procedures to control all documents and data which are relevant to the SMS. 11.2 The Company should ensure that: 1. valid documents are available at all relevant locations; 2. changes to documents are reviewed and approved by authorized personnel, and 3. obsolete documents are promptly removed. 11.3 The documents used to describe and implement the SMS may be referred to as the \"Safety management manual\". Documentation sould be kept in a form that the Company considers more effective. Each ship should carry on board all documentation relevant to that ship. 15.1 FOREWORD Documentation of Company’s Safety Management System (SMS) comprises: ⇒ Ships statutory documents prescribed by current Flag State and international regulations, as detailed in the relevant parts of this manual: (i) Log Books (Chapter 14 - § 14.4). As for the management of statutory Log Books (issue, endorsement, compilation, submission, withdrawal and custody) see § 14.4.1. (ii) Manuals and documents (Chapter 14 - § 14.5(a)). (iii) Placards and plans (Chapter 14 - § 14.5(b)). ⇒ Company’s documents, additional to the statutory documents, both on board and ashore, as detailed in this chapter. 15.2 COMPANY’S DOCUMENTS (i) Company Manuals and Publications containing the prescribed procedures and the instructions given by the Company to its ships. (ii) Records of operations in which all operations, inspections, checks, meetings, works carried out, as well as all records prescribed by the SMS, both ashore and on board, must be entered. (iii) Information exchange: Correspondence and various communications beteween the ships and the shore office, as requested by the SMS. (iv) Company placards to be kept permanently posted on board ships, containing particularly important warnings or notices prescribed by the company’s SMS. (v) Company’s circular letters: Updates, directions and informations supplied by the Company to the ships. Company’s documents (ii) and (iii) must be kept for not less than three (3) years, both on board ships and in the shore offices. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 2 of 20 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended - ISM Code CHAPTER 15 SAFETY MANAGEMENT SYSTEM DOCUMENTATION 15.2.1 – Company Manuals and Publications GM = General Manager – AR = Marine Department – IT = Informatic Technology Office – PS = Crewing Department – UT = Technical Departmentt – HSEQ = HSEQ Department Reference Description SHORE OFFICES LOCATION ON BOARD 8.3.1.1 Emergency and Special Conditions Check-list file HSEQ Navigation bridge – ECR – CCR 8.5.2.2 Emergency Response Manual GM AR IT PS UT HSEQ 12.1.1 Risk Assessment Plan UT Ship’s office 12.2.1.1 Bridge Management Manual HSEQ Navigation bridge Watchkeeping & Duty Service Rules 12.2.3.3 UT HSEQ ECR and Chief Engineer’s Standing Orders 12.3.5.6 Annex VI Manual UT Master’s and Chief Engineer’s office 12.8.5.2.1 Self-control Manual (HACCP) UT HSEQ Master’s office 12.8.6 Company’s D&A Policy – Instructions to Masters HSEQ Master’s office FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 3 of 20 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended - ISM Code CHAPTER 15 SAFETY MANAGEMENT SYSTEM DOCUMENTATION 15.2.2 – Records of operations – Information exchange Their description and location, both in the shore offices and on board, are detailed in the subsequent combined table. Q&E = ISO - Quality / Environment Integrated Management System – OMNIA = Computerized Crew Management System – AMOS = Computerized planned maintenance system (PMS) GM = General Manager – AR = Marine Dept – IT = Informatic Technology Office – PS = Crewing Dept – UT = Technical Dept – HSEQ = HSEQ Dept D = Deck Dep.t – E = Engine Dep.t – ← ↔ → = Sender SMS Type of RECORD OF OPERATIONS INFORMATION EXCHANGE Reference document Description SHORE OFFICES O/BOARD SHORE OFFICES O/BOARD ↔ 3.6 CARD Shore personnel telephone directory GM AR IT PS UT D E HSEQ 4.4.1 Master’s SMS review HSEQ D FOLDER 4.4.2 Master’s reports on SMS non-conformities HSEQ ← D ← 4.5.3 FOLDER CE job assignements to Engineers. UT E Minutes of monthly shipboard safety team ← 4.8 FOLDER HSEQ meetings D 5.2.2 Q&I Shore personnel job description GM AR PS UT HSEQ 5.2.2 FILE Curricula of shore key persons GM 5.3.1 CARD Candidate Evaluation Report (IP 03 – Form 5) PS 5.3.1 OMNIA Seafarers personal data. PS (*) 5.3.1.7(b) CARD Briefing – De-briefing Checklist PS 5.3.1.8(a) FOLDER Crew documents and certificates file D (*) – Also in Manning Agent office. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 4 of 20 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended - ISM Code CHAPTER 15 SAFETY MANAGEMENT SYSTEM DOCUMENTATION SMS Type of RECORD OF OPERATIONS INFORMATION EXCHANGE Reference document Description SHORE OFFICES O/BOARD SHORE OFFICES O/BOARD → ← 5.3.1.8(b) FOLDER Crew changes documentation PS D Record of shore meetings with Masters and 5.3.2.1 FOLDER PS CEs 5.3.2.2 ISF R/BOOK ISF - Personal Training & Service Record Book D (*) E (*) 5.3.2.2(i)a. D (**) [8.2] SAFETY OFFICER TRAINING 5.3.2.2(i)b. CARD (**) [8.2] CREW FAMILIARIZATION D RECORD JOINING OFFICERS TRAINING ON COMPANY SMS D BOOK 5.3.2.2(ii) RECORD JOINING ENGINEERS TRAINING ON COMPANY SMS E BOOK RECORD ← 5.3.2.2(iii)a CREW MONTHLY SAFETY MEETING PS BOOK D 5.3.2.2(iii)b FILE RECORD OF DVD TRAINING D RECORD USE OF PORTABLE METERS - OFFICERS MONTHLY 5.3.2.2(iv) D BOOK DRILL 5.3.2.2(v) ISF R/BOOK TRAINING OF OFFICERS FOR HIGHER POSITIONS D (***) DECK CADETS ON-BOARD TRAINING MANUAL D (*) 5.3.2.2(vi) MIT R/BOOK ENGINEERING CADETS ON-BOARD TRAINING E (*) MANUAL (*) – Consigned to the interested persons. (**) – Filed in the SAFETY FAMILIARIZATION folder. (***) – In the ISF Personal Training & Service Record Book of the interested persons. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 5 of 20 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended - ISM Code CHAPTER 15 SAFETY MANAGEMENT SYSTEM DOCUMENTATION SMS Type of RECORD OF OPERATIONS INFORMATION EXCHANGE Reference document Description SHORE OFFICES O/BOARD SHORE OFFICES O/BOARD Deck Officers operationasl familiarization FOLDER checklist D 5.3.3(i) Engineering Officers operational familiarization FOLDER E checklist ← FOLDER Masters handing-over reports AR 5.3.3.1 D FOLDER CEs handing-over reports file UT ← E 5.3.4.1 FILE Seafarers’ Apprisal Reports PS (*) 5.3.4.2(i) FILE Master & CE on-board Apprisal Report PS Apprisal cards of Masters and CE after 5.3.4.2(ii) FILE PS completion of term 5.3.5 FILE Officers Development Checklists PS 5.3.6.3 OMNIA Officers Retention Rate PS ← ← 7.2.3.1 FOLDER Weekly maintenance management meetings AR UT D E RECORD STRUCTURES AND COMPARTMENTS INSPECTIONS 7.2.4 D BOOK RECORD BOOK Structures and compartments inspections ← FOLDER UT reports D 7.2.5 AMOS MAINTENANCE OF LIFE SAVING APPLIANCES D AMOS FIRE-FIGHTING EQUIPMENT MAINTENANCE E (*) – Copy to the interested persons and 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 6 of 20 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended - ISM Code CHAPTER 15 SAFETY MANAGEMENT SYSTEM DOCUMENTATION SMS Type of RECORD OF OPERATIONS INFORMATION EXCHANGE Reference document Description SHORE OFFICES O/BOARD SHORE OFFICES O/BOARD RECORD 7.2.6 DECK DEPT. – INSPECTIONS RECORD-BOOK D BOOK Monthly Tracking Form for ← ← 7.2.8 FOLDER AR UT Defects / Recommendations (form TEC 07) D E ← ← 7.3.2 FOLDER Repair list (form TEC 08) AR UT D E Repairs documentation (shipyard or during ← ← 7.3,5 FOLDER AR UT stays) Dry-Dock Book DD D E Matrix Index of Forms TEC (TEC 01) ← ← 7.3.5 FOLDER AR UT AR UT D E List of selected materials and services 7.4.1 AMOS AR UT suppliers Spare parts, materials and equipment → → ← ← 7.4.2 AMOS requisitions & supply AR UT D E Consummables and provisions → ← ← 7.4.3 AMOS requisitions & supply AR D E Documentation of technical assistance → → ← ← rendered on board AR UT D E 7.4.4 FILE Documentation of materials landed for repairs ← ← (TEC 11) AR UT D E ← ← 7.4.6 AMOS Inventory AR UT D E AR UT D E → ← Luboil analysis 7.5 FOLDER UT E Water analysis → ← UT E FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 7 of 20 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended - ISM Code CHAPTER 15 SAFETY MANAGEMENT SYSTEM DOCUMENTATION SMS Type of RECORD OF OPERATIONS INFORMATION EXCHANGE Reference document Description SHORE OFFICES O/BOARD SHORE OFFICES O/BOARD 8.2 – 8.3 [5.3.2.2(i)] FOLDER Safety Familiarization D 8.2.1.2 FOLDER Ship/shore anti-pollution drills (SOPEP – VRP) HSEQ D Minutes of the Emergency Team Ashore 8.5.2.5 FILE GM meetings ← 9.3 FILE Flag State Safety Surveys - PSC – USCG COC HSEQ D → ← 9.4 FOLDER Charterers & Underwriters vetting inspections GM D Company inspections reports – Corrective 9.6 FOLDER UT D actions ← 10.1 FOLDER Accidents, non-conformities, near miss reports HSEQ D ↔ 10.5.2 FOLDER SAFETY NOTICES GM IT AR PS UT D HSEQ RECORD 12.2.1 MASTER’S NIGHT ORDERS BOOK D BOOK FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 8 of 20 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended - ISM Code CHAPTER 15 SAFETY MANAGEMENT SYSTEM DOCUMENTATION SMS Type of RECORD OF OPERATIONS INFORMATION EXCHANGE Reference document Description SHORE OFFICES O/BOARD SHORE OFFICES O/BOARD - Passage Plans D - Pre-departure Checklist D - Pre-arrival Checklist D - Pilot Cards D FOLDER - Voyage Planning Checklist D Bridge Management - Pilotage/Harbour Steaming Plan – Information D Exchange Checklist Manual - Changing-over the Watch Checklist D - UKC Calculation forms D ← - Master’s Monthly Audit Checklist and Report AR D SOFTWARE Charts correction (ChartCo Chart Manager) D FOLDER Temporary and Preliminary (T&P) Notices D Navigational Warnings FOLDER D (NAVTEX & NAVAREA MSI) FOLDER Weather reports, warnings and chartlets D Bridge RASTER charts CDs (regional & corrections) D Management CD file Manual ENC CDs (regional & corrections) D RECORD BOOK NAVIGATION BRIDGE VHF COMMUNICATIONS LOG D SOFTWARE SAR reporting messages (ARES – AMVER) file D FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 9 of 20 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended - ISM Code CHAPTER 15 SAFETY MANAGEMENT SYSTEM DOCUMENTATION SMS Type of RECORD OF OPERATIONS INFORMATION EXCHANGE Reference document Description SHORE OFFICES O/BOARD SHORE OFFICES O/BOARD Engine Room Pre-departure Checklist E 12.2.3.2 FOLDER Engine Room Pre-arrival Checklist E Steering Gear Checklist E RECORD 12.2.3.3 (i) CH. ENGINEER ORDERS BOOK E BOOK RECORD 12.2.3.3(ix) COMPANY’S ENGINE LOGBOOK E BOOK 12.2.3.4(i) FOLDER UMS Checklist E Written Master - Ch.Engineer informations → ← 12.2.3.8 LOGGED exchange D E 12.2.3.9.2 FOLDER MSDS for Fuel Oil E 12.2.3.9.3 Bunkering Operations Planning file E FOLDER Bunkering Safety Checklist file E (*) 12.3.2.1 ENCLOSURES Documents of delivery of bilge water to shore E Documents (**) of delivery of washings and slops 12.3.2.2 ENCLOSURES D to shore 12.3.4 ENCLOSURES Documents (***) of delivery of garbage to shore D (*) – Enclosed to Oil Record Book – Part I; (**) – Enclosed to Oil Record Book – Part II; (***) – Enclosed to Garbage Record Book FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 10 of 20 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended - ISM Code CHAPTER 15 SAFETY MANAGEMENT SYSTEM DOCUMENTATION SMS Type of RECORD OF OPERATIONS INFORMATION EXCHANGE Reference document Description SHORE OFFICES O/BOARD SHORE OFFICES O/BOARD 12.3.5.3(b) RECORD CARGO CONTROL ROOM LOG BOOK – PART IV D 12.4.9 BOOK 12.3.5.5 FOLDER Bunker Delivery Notes file E RECORD Fuel Supply MARPOL Samples file E BOOK 12.3.7 FOLDER Ballast Water Reporting Forms file D 12.3.9 FILE U.S.A. VGP D RECORD D BOOK SPECIAL WASTE RECORD BOOK 12.3.10 ENCLOSURES Documents of delivery of special waste to shore D 12.3.12.2 FOLDER L. 9.11.1999, no.10 – National Energetic plan UT 12.3.12.3 Q&E Surveillance and Measurement Plan HSEQ 12.4.1.1 FOLDER MSDS of cargo carried D Preliminary ISGOTT Ship/Shore Safety 12.4.2.2 CFOLDER D Checklist file RECORD 12.4.5 CARGO CONTROL ROOM LOG BOOK – PART I D BOOK RECORD CARGO CONTROL ROOM LOG BOOK – PART II D BOOK 12.4.5.1 CFOLDER COW Checklist D FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 11 of 20 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended - ISM Code CHAPTER 15 SAFETY MANAGEMENT SYSTEM DOCUMENTATION SMS Type of RECORD OF OPERATIONS INFORMATION EXCHANGE Reference document Description SHORE OFFICES O/BOARD SHORE OFFICES O/BOARD 12.4.5.3 FOLDER Cargo operation plans file D RECORD 12.4.9 CARGO CONTROL ROOM LOG BOOK – PART III D BOOK RECORD (*) BOOK SECURITY RECORD BOOK D RECORD 12.7.2.1 SECURITY DRILLS RECORD BOOK D (*) BOOK RECORD (*) BOOK VISITORS RECORD BOOK D Security Checklist file D (*) FOLDER 12.7.2.1 Security messages file D (*) HSEQ FOLDER Ship/shore Security Drills (**) D (*) Minutes of on-board workers representative ← 12.8.1.3 FOLDER HSEQ (RASAL) elections D Letter of appointment of the Company’s 12.8.1.4 ENCLOSURE HSEQ D (*) Physician Yearly on-board prevention and protection ← 12.8.1.7 FOLDER HSEQ meeting D ← 12.8.1.11 FOLDER Notification of a Reprimand PS D Documentation of Company’s Physician 12.8.2 FOLDER PS examinations (*) – Confidential documents, kept under the SSO’s responsibility. (**) – confidential documents, kept under the CSO’s responsibility. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 12 of 20 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended - ISM Code CHAPTER 15 SAFETY MANAGEMENT SYSTEM DOCUMENTATION SMS Type of RECORD OF OPERATIONS INFORMATION EXCHANGE Reference document Description SHORE OFFICES O/BOARD SHORE OFFICES O/BOARD RECORD BOOK HOURS OF WORK RECORD BOOK D E 12.8.3 SOFTWARE ISF – Watchkeeper 3.0 PS ← D RECORD D BOOK MEDICAL LOGBOOK 12.8.4 FOLDER Medical assistance in port (SASN forms) D (**) Minutes of accommodations & ship hospital 12.8.5.1 FOLDER D inspections 12.8.5.2.1 FOLDER Documentation of HACCP self-control system D ILO Convention nr 68/1964 – Weekly 12.8.5.2.2 FOLDER D inspections 12.8.5.2.3 FOLDER Documentation of Company’s Physician checks HSEQ D (*) – Attached to the statutory publication Safety Plan (D.L.vo 271 = Safe Working Practices). (**) – Copied to the Company’s Administration Department (CT). FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 13 of 20 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended - ISM Code CHAPTER 15 SAFETY MANAGEMENT SYSTEM DOCUMENTATION SMS Type of RECORD OF OPERATIONS INFORMATION EXCHANGE Reference document Description SHORE OFFICES O/BOARD SHORE OFFICES O/BOARD FOLDER Pre-joining Test PS 12.8.6.3(i) FOLDER Statutory pre-joining examination PS D 12.8.6.3(ii) FOLDER Crew personal agreements D HSE 12.8.6.3(iv) On-board BAC random testing D Q (*) Unannunced on-board D&A testing D 12.8.6.3(v) HSE FILE Results of unannunced D&A testing Q (**) On-board D&A test after serious marine 12.8.6.3(vi) FOLDER HSE D incidents Q 12.8.7.2 FILE MSDSs for products used on board. AR UT D E Enclosed Spaces Entry Permits file D E 12.8.10.3.1 FOLDER Enclosed Spaces Entry Log file D E Hot Work Permits file E 12.8.10.3.2 FOLDER Hot work authorizations → ← UT E 12.8.10.3.3 FOLDER Work Permits file D E (*) – Only random tests ordered by the Coordinator. (**) – Confidential documents kept by the Test Coordinator. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 14 of 20 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended - ISM Code CHAPTER 15 SAFETY MANAGEMENT SYSTEM DOCUMENTATION SMS Type of RECORD OF OPERATIONS INFORMATION EXCHANGE Reference document Description SHORE OFFICES O/BOARD SHORE OFFICES O/BOARD 12.8.10.3.4 FOLDER Underwater Inspection and Work Permits file D 12.8.10.3.5 CFOLDER Work Permits for Lifting Operations file D M 12.8.11 FOLDER List of lifting tools UT D M HSEQ ← 13.4 SOFTWARE Routine messages (departure/position/arrival) GM IT AR PS UT (*) D 14.1 SOFTWARE List of ship’s certificates and documents GM AR PS UT HSEQ FILE List of ship’s certificates and documents D FOLDER RINA: ESP FILE UT D → RINA – Quarterly Survey Status D 14.1(a) FOLDER UT RINA – Surveys documentation UT D FOLDER LLR/ABS: Class certificates - Surveys UT D FOLDER Ships’ certificates and documents file D 14.3 FOLDER Ships’ certificates and documents copies file UT (*) – Monitored and filed by HSEQ Department (HSEQ) in compliance with SOLAS 74/78 – V/28.2. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 15 of 20 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended - ISM Code CHAPTER 15 SAFETY MANAGEMENT SYSTEM DOCUMENTATION SMS Type of RECORD OF OPERATIONS INFORMATION EXCHANGE Reference document Description SHORE OFFICES O/BOARD SHORE OFFICES O/BOARD ↔ ENCLOSURES Lists of Company circular letters in force GM AR IT PS UT D E HSEQ → FOLDER Circular letters DG AR (*) D GM → FOLDER Circular letters AR - RT - BK D AR (*) → FOLDER Circular letters IT AR (*) D IT 15.2.4 → FOLDER Circular letters PS AR (*) D PS → FOLDER Circular letters UT AR (*) D UT → FOLDER Circular letters POL - NAV AR (*) D HSEQ → FOLDER Circular letters HSEQ AR (*) D HSEQ Selected circular letters for CE (AR-BK-IT-PS- → FOLDER E UT- POL-HSEQ) HSEQ → ← FOLDER In-out correspondence with Marine Department AR D → ← FOLDER In-out correspondence with IT Office 15.2.5 IT D FOLDER In-out correspondence with Crewing Department → ← PS D In-out correspondence with Technical → ← FOLDER Department UT D (*) – Kept in the circular letters general archive in the Postal Office of the Marine Department (AR). FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 16 of 20 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended - ISM Code CHAPTER 15 SAFETY MANAGEMENT SYSTEM DOCUMENTATION SMS Type of RECORD OF OPERATIONS INFORMATION EXCHANGE Reference document Description SHORE OFFICES O/BOARD SHORE OFFICES O/BOARD In-out correspondence with HSEQ Department → ← 15.2.5 FOLDER HSEQ D → → → → → ← FOLDER In-out correspondence with the Company IT UT AR PS HSEQ E GM ← 15.3 FILE Voyage cargo documents (*) D Reports of internal audits of ships, including NC/OBS 16.1.1 FOLDER and relevant corrective actions. HSEQ D (**) Reports of internal audits of Company offices, FOLDER HSEQ including NC/OBS and relevant corrective actions. RINA – Declaration for the SMC, including NC/OBS 16.2 FOLDER and relevant corrective actions. HSEQ D (**) RINA – Declaration for the DOC, including NC/OBS FOLDER HSEQ and relevant corrective actions. 16.3 FOLDER Minutes of yearly policy revision meetings HSEQ (*) – Care of the Chartering Department. (**) – Single folder. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 17 of 20 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended - ISM Code CHAPTER 15 SAFETY MANAGEMENT SYSTEM DOCUMENTATION 15.2.3 – Company Placards Reference Description Form Number LOCATION BOARD Company Policy Statement PLACARDPOL 4 (1) Navigation Bridge – (1) Ship’s office or Master’s 05.2010 reception room – (2) Officers and crew messrooms. Personal Safety Cards 8.1.1 SAFETYCARD = Posted in all crew cabins. 01.2008 Bridge Team Organization WATCHCOND Bridge 07.2007 1 Navigation Bridge Management Guidance on Steering Gear Test Routines (ICS placard) BRISTG 1 Navigation Bridge Manual 07.2007 Part I Notice on the Correct Use of VHF Channels (ICS placard) BRIVHF 1 Navigation Bridge 08.2003 Prohibition to use MF/HF transceiver during cargo operations BRIMFHF 02.2001 1 Navigation Bridge, on the GMDSS console. Use of Radioelectrical Equipment During Cargo Operations RADIOELECTRIC 2 (1) Navigation Bridge – (1) CCR [12.4.2.1] and While the Ship is Berthed or in Vicinity of an Oil Dock. 07.2007 [12.6.3] Tests and checks before departure and arrival PROVETAB 2 (1) Navigation Bridge – (1) ECR 07.2008 BEFORE USING THE BILGE OIL WATER SEPARATOR (15ppm) BILGESEPNOTICE 2 (1) ECR – (1) Near bildge pump 02.2010 12.2.3.5 OVERBOARD DISCHARGE VALVE SEALED AGAINST ACCIDENTAL BILGEWARNING = TAG - To be applied to all sealed overboard OPENING - DO NOT OPEN 02.2010 discharge valves. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 18 of 20 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended - ISM Code CHAPTER 15 SAFETY MANAGEMENT SYSTEM DOCUMENTATION Reference Description Form Number LOCATION BOARD FIRE DETECTION AND ALARM SYSTEM FIREZONES 3 (1) Control panel on the Bridge – (1) Firefighting CR 03.2011 – (1) ECR 12.2.3.6c) FIREZONEWARNING1 THIS ZONE HAS BEEN ISOLATED = NOTICE - To be displayed in all isolated zones. 03.2011 FIRE ZONES No.__ HAVE BEEN ISOLATED FIREZONEWARNING2 1 NOTICE - To be displayed at the control panel on the 03.2011 navigation bridge. Food Waste Grinder 12.3.4.1 RUMENGRINDER 1 Galley 09.2012 Smoking Regulations (1) Navigation Bridge – (1) ECR – (1) CCR – (2) 12.4.1.1 SMOKING 10.2012 9 Officers and crew dayrooms – (4) Main & A Deck inner passageways, Port & Stbd. Warning about tank washing lines (ISGOTT/2006 – 11.5.10). (1) CCR – (2) A Deck internal passageway, Port & 12.4.2.2 COWLINES 3 Stbd. 07.2007 Cargo Pumproom Entry Procedure 12.4.5.6 PUMPROOM 1 CCR 07.2007 Stop all cargo operations at once STOPOPS 08.2008 12.4.5.9 1 CCR DRUG WARNING DRUGWARN (CAIM) 9 12.8.6 NO ALCOHOL ON BOARD! NOALCOHOL 9 (1) Navigation Bridge – (1) ECR – (1) CCR – (2) A Deck inner passageway, Port & Stbd.- (2) B & C Decks 02.2007 Company’s Drugs & Alcohol Policy TABPOLICY 9 inner passageways – (2) Main Deck inner 11.2010 passageway near the ER stairs door and the changing Use of Personal Protection Equipment (PPE) rooms. 12.8.10.2 TABLE 12.8.A 9 02.2013 FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 19 of 20 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended - ISM Code CHAPTER 15 SAFETY MANAGEMENT SYSTEM DOCUMENTATION 15.2.4 – Company’s circular letters file Circular letters are used by the various Company’s departments and offices to supply the ships Masters with informations and instructions. They are identified by a group of letters (sender’s initials/department or office) followed by its category and consecutive number in the year and the date (for instance an/AR – NAV 22/1995 dated 02.08.1995). Circular letters issued by the various departments and offices of the Company are grouped in the following categories: DG – Communications by the General Manager – Normally issued through the Chartering/Insurance Department. HSEQ – Health, safety, environment, security and quality – Issued by the HSEQ Department. NAV – Navigation and ports - Issued by the Marine Department and by the HSEQ Department. POL – Protection of the environment - Antipollution - Issued by the HSEQ Department. UT – Hull & machinery technical matters, spare parts, safety equipment, classification - Issued by the Technical Department. AR – Consummables, seamanship & life-saving equipment, coatings - Issued by the Marine Department. RT – Radio & navigation equipment and instruments, nautical charts & publications, comunications systems – Issued by the Marine Department. BK – Fuel and lubricants - Issued by the Marine Department and the Technical Department. PS – Crew - Issued by the Crewing Department. IT – Informatic Technology – Issued by the IT Office. Circular letters are kept in special files, both on board and ashore. Files comprise a List of circular letters in force continuously updated every time that a circular letter is being issued or cancelled. Canncelled circular letters must be removed from the files and destroyed. 15.2.5 – Correspondence with the Company Correspondence between the ships and the various departments of the Company, both in paper form and as e-mail, should be regularly recorded and shall be kept in special files, both on board and in the shore offices, for at least three years. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 20 of 20 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended - ISM Code CHAPTER 15 SAFETY MANAGEMENT SYSTEM DOCUMENTATION 15.3 REPORTS TO THE COMPANY At the end of each voyage, the Master shall send to the various departments of the Company the following documents:: • Document: ⇒ Sent to: - Crew change (for each port) - Crewing Department (PS) - Complete set of cargo documents - Chartering Department (NG). 15.4 – DOCUMENTS OF THE SHIP’S COMMERCIAL MANAGEMENT The ship is commercially managed jointly by the Master and by the Chartering/Insurance Department of the Company, in conformity with current national and international law rules. The Quality-Environmental (Q&E) Manual contains appropriate Commercial Guidelines (IP 01 OI 01) which include detailed instructions on 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 1 of 4 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER 16 AUDITS AND POLICY EVALUATION 2. SAFETY AND ENVIRONMENTAL POLICY 2.2 The Company should ensure that the policy is implemented and maintained at all levels of organization both ship-based and shore-based. 12. COMPANY VERIFICATION, REVIEW AND EVALUATION 12.1 The Company should carry out internal safety audits on board and ashore at intervals not exceeding twelve months to verify whether safety and pollution-prevention activities comply with the SMS. In exceptional circumstances, this interval may be exceeded by not more than three months.. 12.2 The Company should periodically evaluate the effectiveness of the SMS in accordance with the procedures established by the Company. 12.3 The audits and possible corrective actions should be carried out in accordance with procedures. 12.4 Personnel carrying out audits should be independent of the areas being audited unless this is impracticable due to the size and the nature of the Company. 12.5 The result of the audits and reviews should be brought to the attention of all personnel having responsibility in the area involved. 12.6 The management personnel responsible for the area involved should take timely corrective action on deficiencies found. 16.1 COMPANY’S INTERNAL AUDITS The Company, as part of its responsibility to regularly review the Management system and its performance, requires internal audits. A programme is established to plan, perform and document those internal audits which will enable management to verify compliance with the Management system. The objectives of the Internal Audits are: • To provide Management and customers with evidence that the Management system is in operation and responds to contractual requirements. • To determine knowledge of the SMS manual and commitment in observing its requirements • To check certificates and other ship’s documents • To determine the effectiveness of the system within the organisation. • To provide means for initiating corrective actions. (where the system is found to be ineffective or where non-compliances are observed) • To verify implementation of corrective actions. The Designated Person Ashore, in liaison with Line Management is responsible for the above programme and the internal audits and performed by using company dedicated forms. Internal Audits are performed at intervals not exceeding twelve months in accordance with the audit planning schedule established and held by the Designated Person Ashore and performed by DPA or trained personnel appointed by DPA who have no direct involvement in the department (for example, the Designated Person should not be allowed to audit himself or his department). Likewise, on board a vessel the ship’s crew should not be allowed to audit themselves on board. It is felt that this type of audit would not be effective as they are responsible for the vessel and it’s operation and could be protective of their position. In exceptional circumstance, this interval may be exceeded by not more than 3 months (ISM Code A 12.1) and a sufficient explanation for the delay shall be documented. 16.1.1 Conducting the Audit It will be the responsibility of the appointed assessor to carry out the audit and report the audit findings back to the Master and the DPA. They will normally use the company audit report/ checklist, although the issue of a company Non-Conformance form. The assessor should verify and report the status of any outstanding Action Items, NC, Accident Reports, etc. Any deficiencies noted during the audit should be recorded in the pro-forma audit report. These should be discussed on board with the Master, Chief Engineer and any other relevant staff at the end of the audit, when the proposed corrective action should be agreed, as appropriate. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 2 of 4 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER 16 AUDITS AND POLICY EVALUATION Where training is given in response to a deficiency, this should be recorded in the audit report. Where appropriate, a detailed onboard training notification should be forwarded to Crew Department, who will then update personal training records accordingly. In case additional shore training/refreshment is required, a notification will be addressed to Crew Department. 16.1.2 Reporting Assessors should send a copy of their report to the DPA, the original report remaining onboard the vessel. Where the line Management of the vessel concerned is based separately from the DPA, a copy of the report should be forwarded to the appropriate line Management. On receipt of the audit report in office, the printed report is circulated electronically to the appropriate parties for comment/action, and follow up. 16.1.3 Definition of Non conformity When objective evidence indicates non-fulfilment of a specific requirement stated by the safety management system, a situation of non-conformity is considered to have occurred. Non conformity would require corrective action to be taken by the ship’s management/company within 3 months. A major non-conformity is an extremely serious situation that poses a serious threat to the safety of personnel, the ship or the environment which requires immediate corrective action, or an essential requirement of the ISM-Code have not been implemented. If a major non-conformity has been raised, the company has to initiate corrective action during the audit and, if appropriate corrective action can be realized immediately, the major NC shall be downgraded to a NC. The NC requires a proposal for further corrective action. The Company DPA has to be notified of the major non-conformity and the corrective action immediately after carrying out the audit. 16.1.4 Reviewing Non-Conformances Once a non-conformance has been reported and the necessary action taken to correct the non- conformance, a review is undertaken to determine whether further investigation is required to identify the root cause and hence prevent a future re-occurrence of the non-conformance. A non-conformance which requires further investigation can be classed as any incident which has serious operational, safety and/or environmental protection implications, and which has the potential to reoccur if no further action were to be taken. 16.1.5 Implementation of Preventive Action In order to prevent re-occurrence, company has established a monitoring system of the non-conformance which require further investigation. Company Safety Management System will be implemented in accordance to the results and discussion of the monitoring results. Safety Notice could be issued in order to highlight the new implementations. 16.1.6 Follow Up Action items identified either in the audit report or from circulation of the report, which are vessel based or office based are followed up by the concerned Department. Both on board and in the Company’s offices, all internal audits reports shall be kept filed, care of the Master and of the HSEQ Department respectively. 16.2 AUDITS OF THE APPOINTED AUDITING BODY AND CERTIFYING AUTHORITY The appointed auditing body (RINA) has the responsibility to carry out periodical audits on behalf of the Italian Coast Guard (certifying Authority), in order to verify that the system has been put into operation and is correctly applied, and for the renewal of the documents prescribed by the ISM Code. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA

Issued by: Approved by: Date Issue Page HSEQ DEPARTMENT GENERAL MANAGER January 2017 0 3 of 4 SAFETY MANAGEMENT MANUAL According to IMO Resolution A.741(18), as amended – ISM Code CHAPTER 16 AUDITS AND POLICY EVALUATION Initial audits carried out on board new ships of the fleet (see Chapter 2, § 2.3) and renewal audits on board and in the shore offices, cover all areas of the safety management system (SMS), while a rule- selection criteria applies to the periodical ones. Periodical audits in the Company’s office are carried out annually, within a time frame of ± 3 months, the ones on board ships during the third out of the five years of validity of their Safety Management Certificates (SMC). Audits are attended by the Company’s DPA and/or internal Auditor. As a rule, ships audits in Italian ports and audits of the Company’s office are carried out jointly by RINA Auditors by Officers of the local Coast Guard (COTP). On completion of the audit, both on board and in the Company’s office, any discovered non- conformity or observation shall be examined and discussed with the responsible people (Master, senior Officers, DPA and internal Auditor on board, the DPA, Heads of Departments and internal Auditors ashore. 16.2.1 Audit Report RINA Auditor issues a Statement for the SMC or for the DOC (Dichiarazione ai fini del SMC or del DOC) with a number of reports attached, one for every discovered non-conformity and observation and for the proposed corrective actions. Reports shall be signed by the RINA Auditor and by the Master, and the Company’s DPA or Auditor on board, and by the DPA and the Heads of Departments ashore. On board, a copy of the Statement for the SMC and of the enclosed reports shall be handed over to the Master and a copy to the Company’s DPA or internal Auditor. In the offices, a copy of the Statement for the DOC and of the enclosed reports will be handed over to the HSEQ. 16.2.1.1 – Dealing with non-conformities Within fifteen (15) days, the DPA must submit to the RINA Auditor copies of the non-conformity reports, annotated with the proposed corrective action and date of fulfillment. Having examined them, RINA Auditor will return them duly endorsed for approval. The DPA will send the reports so endorsed to the Master of the ship or the heads of the shore departments involved. Corrective actions so approved by RINA Auditor must be completed within the agreed time limits. Their fulfilment shall be recorded in the relevant reports, both on board and ashore, and notified by the Master, or by the heads of the involved departments, to the DPA. 16.2.2 – Issue and endorsement of certificates The Statement for the SMC/DOC and the reports on the non-conformities/observations are handed over to the Flag State authority (COTP or consulate) of the port where the ship’s audit was carried out, or to the Flag State authority competent for the Company’s head office location which, on their turn, shall endorse the Safety Management Certificate (SMC) or the Document of Compliance (DOC) respectively, or shall issue new documents. Flag State authority reserves to itself the right to have the RINA audits outcomes verified by its Officers, before endorsing or renewing the documents. On the occasion of the following audits, both on board and in the Company’s office, the RINA Auditor inspects the copies of the statement and of the relevant reports of the previous audit, checks that all non-conformities and observations have been solved in the agreed way and time, as notified, and closes them out accordingly. Both on board and in the Company’s office, copies of all statements and reports issued by RINA Auditor must be kept filed by the Master and the HSEQ Department respectively, together with all documents related to the corrective actions. FRATELLI d’AMICO ARMATORI S.p.A. - ROMA