HSQE System Manual - 01 Sep 2015

HSQE System Manual Health Safety Quality& Environmental Management SystemHSQE SYSTEM MANUAL ISM Code ISO 9001:2008 ISO 14001:2004 OHSAS 18001:2007 TMSA MLC 2006Controlled Approval: WBFHSQE Doc No. COV Page: 1 of 1COVER PAGE

HSQE System ManualSection Record or Revisions TitleDoc 000ADoc 000B 01 Sep 2015 01 Sep 2015Part A System Policies & ProceduresDoc 001 1.0 01 Jun 2013Doc 002 2.0 01 Jan 2015Doc 003 3.0 01 Sep 2015Doc 004 4.0 01 Jun 2013Doc 005 5.0 01 Sep 2015Doc 006 6.0 01 Sep 2015Doc 007 7.0 01 Sep 2015Doc 008 8.0 01 Jan 2015Doc 009 9.0 01 Sep 2015Doc 010 10.0 01 Sep 2010Part B HSQE System ReferencesTable 001 01 Jan 2015Part C SecurityDoc 001 1.0 01 Jun 2013Doc 002 2.0 01 Sep 2015Controlled Revision: 01 Sep 2015HSM Doc No. 000ARECORD OF REVISION Approval: WBF Page: 1 of 1

HSQE System ManualSection Table of Contents TitleDoc 000ADoc 000B Record of Revisions Table of ContentsPart A System Policies & ProceduresDoc 001 1.0 Introduction 1.1 Company Profile 1.1.1 Company Organizational Structure 1.1.2 Shipboard Organization 1.2 Declaration and Scope 1.2.1 ISO Exclusions 1.3 Normative Reference 1.4 Terms, Definition and AbbreviationsDoc 002 2.0 HSQE Management System 2.1 Mission & Vision 2.2 Health, Safety, Quality, & Environmental Aspirations 2.3 HSQE Policy Statement 2.3.1 Values and Beliefs 2.3.2 Assessment of Risk 2.3.3 Management of Change 2.3.4 Audit and Review 2.3.5 Standard Operating Procedures 2.3.6 Training 2.3.7 Continual Improvement 2.3.8 Emergency Preparedness 2.3.9 Maintenance of Ship & Equipment 2.3.10 Incident Investigation & Reporting 2.3.11 HSQE System Documentation 2.3.12 Records 2.3.13 Document Control 2.3.14 Reference Documents 2.3.15 Compliance with Mandatory Rules 2.3.16 IT Policy 2.3.16.1 Social Media Policy 2.3.17 CommunicationControlled Revision: 01 Sep 2015HSM Doc No. 000BTABLE OF CONTENTS Approval: WBF Page: 1 of 7

Doc 003 HSQE System ManualDoc 004Doc 005 3.0 Company Responsibilities and Authority 3.1 Responsibilities & Authority 3.1.1 Master’s Responsibilities & Overriding Authority 3.1.2 Managing Director 3.1.3 Senior Managers 3.1.4 Managers 3.1.5 Staff 3.1.6 Designated Person Ashore / Designated Management Representative 3.1.7 Company Security Officer 3.1.8 Responsibility to Report to Flag Administration 3.2 Management Commitment 4.0 Resources and Personnel 4.1 Provision of Adequate Resources 4.2 Human Resources 4.3 Recruitment 4.3.1 Selection of Staff 4.3.2 Appraisal 4.3.3 Training 4.3.3.1 Induction 4.3.4 Sea Staff Administration 4.3.5 Shore Staff 4.3.6 Qualification of Personnel 5.0 Company Verification, Evaluation and Review 5.1 Verification 5.1.1 Periodic Audits & Inspections 5.1.2 Audit Planning 5.1.3 Identification and Control of Faults & Non- Conformance 5.1.4 Suggestions, Complaints & Grievance 5.2 Evaluation 5.2.1 Incidents, Accidents, and Hazardous Occurrences 5.2.2 Corrective & Preventive Action 5.2.3 Analysis of Incidents, Accidents, and Audits/Non-Conformities 5.3 Review 5.3.1 Management Review 5.3.2 Master’s Annual System Review 5.3.3 Legal ReviewControlled Revision: 01 Sep 2015HSM Doc No. 000BTABLE OF CONTENTS Approval: WBF Page: 2 of 7

Doc 006 HSQE System Manual 5.3.4 Performance Measurement, Analysis & Improvement 5.3.5 Benchmarking 5.3.6 Key Performance Indicators 5.3.7 Continuous Improvement 5.3.8 Environmental Aspects 6.0 Safety Management 6.1 Promotion of HSE 6.1.1 Hazard Communication 6.1.2 Department Head Supervision 6.2 Monitoring Safety Onboard 6.2.1 Safety Committee 6.2.2 Safety Officer 6.3 Safe Working Practices 6.3.1 Safety Stations 6.3.2 Time Out / Step Back 5X5 6.3.3 Tool Box Talks 6.3.4 CARE Card System 6.3.5 Personal Protective Equipment (PPE) 6.4 Dangerous Work 6.4.1 Hot Work 6.4.1.1 General Precautions 6.4.1.2 Precautions in Enclosed Spaces 6.4.1.3 Welding, Burning and Cutting Equipment 6.4.1.4 Concurrence 6.4.2 Enclosed Spaces 6.4.2.1 Entry 6.4.2.2 Atmospheric Tests 6.4.2.3 Ventilation 6.4.2.4 Pre-Entry Safety Meeting 6.4.2.5 Emergency Standby Equipment 6.4.2.6 Communication 6.4.2.7 Work on Pipelines and Valves 6.4.2.8 Spaces that are not Gas Free 6.4.2.9 Painting 6.4.2.10 Personal Gas Detectors 6.4.2.11 Marking of Entry or Access Hatches 6.5 Hydrogen Sulphide (H2S) 6.6 Winning with Safety Incentive Program 6.7 HSQE / Quality Safety Campaigns 6.7.1 Organizational Improvement Incentive 6.8 Safety SignageControlled Revision: 01 Sep 2015HSM Doc No. 000BTABLE OF CONTENTS Approval: WBF Page: 3 of 7

HSQE System Manual 6.9 House Keeping 6.10 Identification & Sharing of Best Practices 6.11 Incident Reporting, Investigation and Analysis 6.11.1 Classification of Incidents 6.12 6.11.2 Reporting 6.11.3 Investigation 6.13 6.11.4 Analysis 6.11.5 Close-out 6.11.6 Post Incident Drug & Alcohol Testing Emergency Drills and Training 6.12.1 Conduct & Recording 6.12.2 Types of Training and Drills 6.12.3 Planning 6.12.4 Life Boat Drills 6.12.4.1 Davit Launched Life Boats 6.12.5 Fire Drills LSA & FFA Maintenance 6.13.1 Lifeboat MaintenanceDoc 007 7.0 Risk ManagementDoc 008 7.1 Management of Change 7.1.1 Recurring Changes 7.1.2 Requesting Change 7.1.3 Communication of Change 7.2 Risk Assessment & Control 7.2.1 Hazard Identification 7.2.2 Risk Estimation 7.2.3 Risk Control 7.2.4 Close-Out Targets 7.2.5 Risk Monitoring 7.2.6 When to Conduct a Risk Assessment 8.0 Health & Hygiene 8.1 Individual Responsibilities 8.2 Food Handling 8.3 Healthy Eating Guidelines 8.4 Infestation Control 8.5 Living Conditions 8.6 Sanitary Accommodation 8.7 Laundry Facilities 8.8 Potable Drinking Water 8.9 Cabin Maintenance 8.10 Medical ScreeningControlled Revision: 01 Sep 2015HSM Doc No. 000BTABLE OF CONTENTS Approval: WBF Page: 4 of 7

HSQE System Manual 8.11 Medical Facilities 8.12 Winter Clothing 8.13 Dress and Attire 8.14 Prevention of Drug & Alcohol Abuse 8.15 Drug & Alcohol Policies 8.16 Shipboard Welfare 8.17 Office Occupational Health and Safety 8.18 AsbestosDoc 009 9.0 Environmental Management 9.1 Scope 9.2 Environmental Principals 9.3 General Objectives 9.4 Identification & Evaluation of Environmental 9.5 Aspects 9.6 Identification of Legislation 9.7 Environmental Planning 9.8 Setting of Environmental Objectives & Targets 9.9 Environmental Readiness 9.10 Responsibilities 9.11 Training, Awareness & Competence 9.12 Communications 9.13 Core Environmental Management Documentation 9.14 Operational Control 9.15 Goods and Services 9.16 Environmental Emergencies 9.17 Compliance Monitoring & Control 9.18 Environmental Records 9.19 Environmental Audits Environmental Management Practices Review 9.20 9.19.1 Monthly Environmental Report Prevention of Pollution 9.21 9.20.1 Bunkering Operations 9.22 9.20.2 Bulk Liquid Cargo Handling 9.20.3 Piping Systems 9.20.4 Funnel Emissions 9.20.5 Marine Organisms 9.20.6 Contaminated Ballast 9.20.7 Sewage 9.20.8 Garbage 9.20.9 Special Care Items Pollutant Prevention and Response Machinery Space BilgesControlled Revision: 01 Sep 2015HSM Doc No. 000BTABLE OF CONTENTS Approval: WBF Page: 5 of 7

HSQE System Manual 9.23 Green Purchasing 9.24 Air Pollution 9.24.1 Minimizing Generation of Air Pollution 9.25 Waste Reduction 9.25.1 Basic Measures 9.26 9.25.2 The 4 R’s 9.27 Energy Conservation Asbestos ManagementDoc 010 10.0 Quality Management 10.1 Scope 10.2 Quality Principals 10.3 Main Quality Objectives 10.4 Identification and Justification for Exclusions 10.5 Normative Reference 10.6 Interaction Between Processes 10.7 Customer Related Processes 10.7.1 Identification of Customer Requirements 10.7.2 Agreements 10.7.3 Review 10.7.4 Assessment of Customer Requirements 10.7.5 Customer Communications 10.7.6 Process ApproachPart B HSQE System References Table 001 ISM / ISO / OHSAS Normative ReferenceControlled Revision: 01 Sep 2015HSM Doc No. 000BTABLE OF CONTENTS Approval: WBF Page: 6 of 7

Part C HSQE System Manual Doc 001 Security Doc 002 1.0 Security Policy 1.1 Company Responsibility 1.2 Entering Pirate Prone High Risk Areas 1.2.1 Assessing Risk 1.2.2 Report, Monitor & Participate in Established Schemes 1.2.3 Establish a Hardened / Stocked Citadel 1.2.4 Plan and Install Ship Protection Measures 1.2.5 Employment of Private Security Maritime Companies (PMSC) 1.2.6 Assessment of Private Marine Security Companies (PMSC) 1.2.7 Command & Control when PMSC Team is Onboard 1.2.8 Principle of Use of Force (RUF) / Rule of Engagement (ROE) 1.2.9 Review Prior Acceptance of PCASP Team 1.2.10 Flag State with Insurer’s Approval / No Objection 1.2.11 PMSC Performance Appraisal System 1.2.12 Relationship Between PMSC and Ship’s Crew 1.2.13 Management of Arms & Ammunition 1.2.14 Duties & Safety Induction of Onboard PMSC Team 1.2.15 Pirate Attack 1.2.16 Incidence Action 2.0 Stowaway 2.1 Precautions whilst at Anchor 2.2 Precautions whilst alongside a Berth 2.3 Stowaway Search Prior Departure from a High Risk Port 2.4 Stowaway Detection after Vessel’s Departure from Port 2.5 Stowaway Focal Point (SFP)Controlled Revision: 01 Sep 2015HSM Doc No. 000BTABLE OF CONTENTS Approval: WBF Page: 7 of 7

System Policies & Procedures1.0 Introduction  Purpose o To introduce SeaTeam Management Pte Ltd as a commercial entity  Application o Stakeholders o Office Staff o Sea Staff  Responsibility o Senior Management Team 1.1 Company Profile SeaTeam Management Pte Ltd (SeaTeam) was established in Singapore in 2009 as a private limited company, to provide ship management services. The company is controlled by the Board of Directors. Daily management and oversight is provided by the Managing Director. The organisation is comprised experienced staff in the fields of technical ship management, accounting, purchasing, personnel management, and health, safety, quality, and environmental. The company intends to manage services the following vessel types: • Oil Tankers • Bulk Carriers • Product / Chemical TankersControlled Revision: 01 Jun 2013HSM Part A – SPP Doc No. 001INTRODUCTION Approval: WBF Page: 1 of 9

System Policies & ProceduresVessels managed are to be registered in several Flag States and areplaced under various Classification Societies.1.1.1 Company Organizational StructureThe SeaTeam organizational structure reflects the operationalobligation and condition for the company with lines of authority andresponsibility. The senior management of SeaTeam consists of: • Managing Director • Technical Director • Accounting Manager • Senior Manager, HSQE • CEO CrewingThis group oversee the overall management of the company withrespect to strategy, planning, policies, quality and operations. Themain departments are headed by senior managers, with the ManagingDirector heading Administration. • Technical DepartmentThe Technical Department responsible for daily technical managementof the fleet and may divided into Fleet Group Sections as needed sosuperintendents maintain an adequate span of control. The FleetGroup Sections consist of manager, usually a marine engineer, asuperintendent for each 3-5 vessels in the fleet group, a purchasingexecutive, and a secretary. • Health Safety Quality & Environmental (HSQE) DepartmentResponsible for regulatory compliance, Marine Operations, Vetting,Safety, Security Quality and Environmental Protection Matters • Accounts DepartmentControlled Revision: 01 Jun 2013HSM Part A – SPP Doc No. 001INTRODUCTION Approval: WBF Page: 2 of 9

System Policies & ProceduresResponsible for payments, invoicing, and financial regulatorycompliance Responsible for all financial matters, book keeping &accountability • AdministrationUnder the oversight of the Managing Director, provides recruitment,training and employment arrangements for office staff, medical andtravel arrangements and general office management • Crewing DepartmentBased in Chennai & Manila, provides recruitment, training andemployment arrangements for sea staff, medical and travelarrangements and complete management of manning servicesOwners will provide the necessary insurance cover required for thevessels managed and therefore no specific insurance department isestablished.Figure 1-1 Office OrganizationControlled Revision: 01 Jun 2013HSM Part A – SPP Doc No. 001INTRODUCTION Approval: WBF Page: 3 of 9

System Policies & Procedures1.1.2 Shipboard OrganizationThe Shipboard Management organizational structure is based on theindustry standard. The Master is in command with the Chief Engineerand Chief Officer acting as department heads.Figure 1-2 Shipboard OrganizationControlled Revision: 01 Jun 2013HSM Part A – SPP Doc No. 001INTRODUCTION Approval: WBF Page: 4 of 9

System Policies & Procedures1.2 Declaration & ScopeSeaTeam has established a comprehensive Health, Safety, and QualityEnvironmental Management System (HSQE), to allow the company tooperate in accordance with company policy and assess its ability tomeet customer, regulatory, and organizational requirements. TheHSQE documentation provides a systematic and transparentmanagement system designed to continually improve performancewhile addressing the needs of all interested parties.The Scope of the management system encompasses the healthstandards contained in OHSAS 18001, the Safety Standards mandatedby the ISM Code, the Quality Standards detailed in ISO 9001, theEnvironmental Standards specified in ISO 14001 and the MarineLabour requirements of MLC 2006; this integrated HSQE System isalso designed to comply with the OCIMF's TMSA Best PracticeGuidelines.1.2.1 ISO ExclusionsVessel management services do not include ISO 9001 coveredprocesses for the design or development of a tangible product orpreservation of product, these two topics are considered permissibleexclusions.1.3 Normative Reference • ISO 9001 - Quality Management Systems • ISM Code - The International Safety Management (ISM) Code for the Safe Operation of Ships and Pollution Prevention. • ISO 14001 - Specification for Environmental Management Systems. • OHSAS 18001 - Safety & Health Management Specification • MLC 2006Controlled Revision: 01 Jun 2013HSM Part A – SPP Doc No. 001INTRODUCTION Approval: WBF Page: 5 of 9

System Policies & Procedures• TMSA Guidelines - OCIMF Tanker Manager Self Assessment Best Practice Guidelines1.4 Terms, Definitions, and AbbreviationsFor the purposes of the HSQE Management System, the terms anddefinitions given below and in ISO 9001:2000 and ISO 14001 apply:• The Company o Means SeaTeam Management (Singapore) Pte Ltd who provide the total ship management services to the owners in accordance with the terms and conditions of the Management Agreement(s)• The Owner o Means the registered Owner or his appointed representative of each vessel under management of the Company. The Owner or his appointed representative is deemed to be the person or company (Principal) who has the authority to entrust the management of a vessel to the Company.• Managing Director o The Managing Director means the ultimate responsible person for the Company's Quality & Environmental Management System.• Quality o The totality of features and characteristics of a service or an activity, which bear on it's ability to satisfy a given need by conformity to the appropriate requirements. In short \"Fitness for Purpose\".• HSQE System Manual o An authorised document setting out the Quality & Environmental Policies of SeaTeam Management Pte. Ltd., including descriptions of how statutory and voluntary requirements are addressed. The manual refers to detailedControlled Revision: 01 Jun 2013HSM Part A – SPP Doc No. 001INTRODUCTION Approval: WBF Page: 6 of 9

System Policies & Procedures health, safety, quality & environmental system procedures and operating instructions.• Designated Management Representative (DMR) o The person who has combined responsibility for ensuring the requirements for both quality and environment are met• Designated Person Ashore (DPA) o The designated person ashore is responsible for ensuring that the requirements of the safety aspects of the Quality System are implemented to ensure the safe operation of each ship and providing the link between Senior Management and personnel on the ships• Major Non-Conformity o A substantial deviation from statutory requirement, a total breakdown of HSQE requirements, or a serious deficiency or defect of sufficient magnitude that it requires correction prior to sailing• Non-Conformance o The non-fulfilment of specified requirements• Verification o Confirmation by uninvolved persons that an activity or service is in accordance with the specified requirements• Administration o Is the Government of the State whose Flag a ship is registered• Customer o The party for whom services are directly provided by SeaTeam Management Pte. Ltd.Controlled Revision: 01 Jun 2013HSM Part A – SPP Doc No. 001INTRODUCTION Approval: WBF Page: 7 of 9

System Policies & Procedures• Complaint o A stated grievance concerning the company's activities.• Incident o An abnormal event or occurrence demanding attention.• Accident o An unintentional occurrence with consequential negative impact on personnel property or the environment.• Continual Improvement o The process of enhancing the HSQE to achieve improvements in the overall quality and environmental performance• Environmental aspects o Any element of the Company's activities that can have an interaction with the environment. A significant environmental aspect is an environmental aspect is one that can have a significant environmental impact.• Environmental Impact o Any change to the environment, whether adverse or beneficial, wholly or partly resulting from the Company's activities, or services.• Policy o A statement by the Company of its intentions and principles in relation to its overall HSQE performance, which provides a framework for action and for the setting of HSQE objectives and targets.• Interested Parties o Those with an interest in the environmental aspects of the Company's operational activities and services. These include employees, investors, insurers, local residents, customers,Controlled Revision: 01 Jun 2013HSM Part A – SPP Doc No. 001INTRODUCTION Approval: WBF Page: 8 of 9

System Policies & Procedures environmental groups, those exercising statutory environmental control over the Company, and the general public.• Safety & Environmental Excellence o Means consistent long term conformance with the company HSQE Policy Statement• Principal Vendor o A vendor with which the company has long term contractual relations, or provide continuous supply of goods or services for a period of 12 months or more Documentation & Filing o Nil Distribution o All Offices o All Vessels References o ISM Code o ISO 9001 o ISO 14001 o OHSAS 18001 o OCIMF TMSA o MLC 2006Controlled Revision: 01 Jun 2013HSM Part A – SPP Doc No. 001INTRODUCTION Approval: WBF Page: 9 of 9

System Policies & Procedures2.0 HSQE Management System  Purpose o To promote HSQE compliance  Application o All Offices o All Vessels  Responsibility o Office Management Team o Shipboard Management Team 2.1 Mission & Vision To provide quality, safe, efficient, and environmentally friendly ship management services that increase the net wealth of shareholders while providing secure and professionally fulfilling careers for our employees by maintaining the highest degree of integrity in all aspects of our operations. 2.2 Health, Safety, Quality, & Environmental Aspirations SeaTeam Management Pte Ltd aspires to be an industry leader in the safe and environmentally friendly management of its fleet of ships by eliminating harmful consequences from our operations, through:  Zero Injuries  Zero Pollution Incidents  Zero Property DamageControlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 002HSQE MANAGEMENT SYSTEM Approval: WBF Page: 1 of 21

System Policies & Procedures2.3 HSQE Policy Statement SeaTeam Management is a performance driven company that considers safety, health, quality and the protection of the environment one of our highest priorities and essential to the success and growth of our company. We believe:  Accidents are preventable  No Injury, property, or environmental damage is acceptable  No job is ever so urgent or so important that we can't take the time to do it safely and with due care for the environment To ensure these simple but powerful targets we shall foster an open, trusting and just culture where our employees are empowered to express themselves on HSQE issues. Everyone has stop work authority and is expected to use it to prevent or reduce the impact of an accident or environmental incident. Shore and shipboard management teams are charged to take a lead role in upholding HSQE expectations and shall be held accountable. We shall:  Evaluate our HSQE performance and continually improve delivery by identifying and adopting ever evolving best practices  Ensure our staff are well trained and that all senior officers possess appropriate experience for the vessel types on which they serve  Select out subcontractors based on their ability to provide services in compliance with our policies  Maintain a commitment to quality in all activities to effectively ensure the quality of crew, vessel, equipment and cargo are maintained at highest standards We will not engage in deceptive work practices, but will take responsibility and own up to problems if and when they occur. We shall be ready to respond professionally to any foreseeable emergency, just in case, despite our best efforts, something should go wrong. Through management commitment and with the support of our staff and crew, we shall be a leader in safety and environmental excellence.Controlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 002HSQE MANAGEMENT SYSTEM Approval: WBF Page: 2 of 21

System Policies & Procedures o A copy of the HSQE Policy Statement signed by the Managing Director is provided for public display throughout the organization and is required to be posted in a prominent place in all SeaTeam Offices and on all ships2.3.1 Values and Beliefs We are all accountable for ourselves and the safety of others in the workplace. Working safely is a condition of employment. People are our most important resource, and as such, safety is unequivocally our number one (#1) core value. The company's target is zero (0) HSQE incidents. We will provide requisite training to our employees to empower an incident prevention culture. Safety excellence requires proactive and demonstrated leadership. Managers and Shipboard Management Teams are to be responsible and held accountable. All employees and contractors are responsible for performing their daily activities in a manner consistent with our HSQE policy. When a serious injury or incident occurs, we will determine its cause and share the lessons learned with our industry partners and stakeholders worldwide. We will strive to prevent pollution and preserve the environment in which we operate by utilizing resources responsibly and operating in accordance with best practices. Our goal will be to reduce and eliminate waste from our operations at the source; however, where wastes are generated, they will be handled safely and responsibly. We will meet or exceed compliance with applicable laws and regulations. Our work with the public and regulatory authorities will be conducted in an atmosphere of trust, openness and cooperation.Controlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 002HSQE MANAGEMENT SYSTEM Approval: WBF Page: 3 of 21

System Policies & Procedures2.3.2 Assessment of RiskShore and Shipboard Management Teams shall evaluate risks to ourships in the environment in which we operate. Risk assessment willprovide the necessary tools to identify and mitigate the likelihood andconsequence of a negative impact from operations. We viewmanagement of risk as an on-going process that is critical toachieving an incident-free workplace.  Shore and Shipboard Management Teams will encourage Behavior Based Safety Management through adherence to Quality Safety Campaign initiatives, Job Safety Analysis, Tool Box Meetings or equivalent procedures.  Risk assessment will be used to identify and control potential hazards to personnel, property and the environment.  Shore and Shipboard Management Teams are to ensure identified risks are controlled documented and communicated to affected staff  Where appropriate, close out targets in way of date, time, or duration of effect, shall be indicated for controls or corrective actions2.3.3 Management of ChangeWhenever there is a change in approved plans, as built design, orstandard operational procedures, there is a risk that such changescould cause something to go wrong. Management of Change (MOC)requirements will encompass changes made to organization, systems,equipment, procedures, and personnel to ensure that risks aresufficiently managed in order to reduce and eliminate anyunacceptable risks to personnel, property, and equipment.  Shore and Shipboard Management Teams evaluate potential positive and negative consequences of proposed changes and seek the endorsement of management where appropriate.  Managers will monitor and evaluate the effectiveness of changes on their work force and the organization.Controlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 002HSQE MANAGEMENT SYSTEM Approval: WBF Page: 4 of 21

System Policies & Procedures  Nominated closeout dates for implementation of changes shall not be exceeded without approval from the Master and, if intolerable consequence is estimated, the DPA.  MOC records will be filed and retained by each vessel and the technical department to facilitate the maintenance of such records.  Whenever newly acquired vessels enter into the fleet ownership/management the familiarisation of superintendents and crew shall be specifically addressed in take-over procedures2.3.4 Audit and ReviewReview of the HSQE Management System will be performedperiodically by senior management and Masters. ManagementReview will include various industry feedback, internal suggestions,HSQE statistics, any customer complaints, and results from audit andinspections. Based on the findings of the review process, changes inthe HSQE System will be instituted to ensure continual improvement.  HSQE audits will be performed and reported at least annually on all vessels and at all offices  Any principal vendors not ISO 9001 compliant, will also be subject to annual quality audits or evaluations  The company will develop and provide to all units a 5 year HSQE plan for continual improvement.  Shore and Shipboard Management Teams will identify and report adverse workplace conditions or employee behaviors that may result in injury or HSQE exposure and need improvement  Findings of audits and inspections, statistical trends, suggestions complaints, and other relevant feedback will be utilized to amend the 5 year HSQE Plan to target identified weak points2.3.5 Standard Operating ProceduresOur objective is to ensure that all activities are conducted within thescope of established Standard Operating Procedures (SOPs)Controlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 002HSQE MANAGEMENT SYSTEM Approval: WBF Page: 5 of 21

System Policies & Procedures SOPs will be written and communicated for routine and/or hazardous operations Regular documented audits and inspections shall be conducted to ensure that company policies and procedures are being adhered too Forms and Checklists will be utilized as guidance for completion of recurring tasks so that safety precautions are continuously carried out in a standard manner Paperwork will be kept to an absolute minimum. The company strongly encourages the use of electronic recording systems to the maximum extent possible. Elimination of duplicate documentation or recording or the same activity shall be a primary goal of HSQE System management Logs shall be utilized to record completion of checks; paper files of completed checklists shall not be kept except for certain safety and environmental records where pen and ink completion is required.2.3.6 TrainingTraining will be a continual process to enhance the knowledge, skillsand attitudes of all employees. A training program for initial andrefresher training will be established. Shore and Shipboard Management Teams will assume the responsibility of ensuring that employees are provided the means to maintain their own competence. A training matrix will be established and maintained illustrating the training requirements for staff Training records for all staff will be maintained o Seagull CBT Administrator has a menu for recording of personnel participation in onboard training and drills (in lieu of a personal training record book). This is in addition to the various mandatory and recommended CBT modules forControlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 002HSQE MANAGEMENT SYSTEM Approval: WBF Page: 6 of 21

System Policies & Procedures various ranks and the ETOTS program which is a must for promotion criteria for tankers. Shore and Shipboard Management Teams will implement the training plans and provide on the job training and coaching to reinforce formal training and build competency for promotion Training Managers are responsible to monitor training needs and arrange appropriate training as needed to meet statutory and industry requirements, as well as company expectations Staff is encouraged to provide assistance in defining training requirements, designing training programs, and providing feedback on training effectiveness. The company will sponsor senior officer seminars at least once each year to promote, emphasize and enhance the HSQE System; all officers are encouraged to attend once every 2 years2.3.7 Continual ImprovementThe company's goal is to achieve employee participation incontinual improvement. Managers will endeavor to obtain theinvolvement and participation of employees (including contractoremployees) in HSQE Management. Employees will take responsibility for their own health, safety and environmental protection as well as that of others All employees shall be required to understand their roles and responsibilities in the HSQE management system and participate in HSQE programs All employees shall be made to understand that no work shall take place until all appropriate HSQE controls are in place All employees are empowered to identify and assess potential risks and communicate their concerns to managementControlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 002HSQE MANAGEMENT SYSTEM Approval: WBF Page: 7 of 21

System Policies & Procedures2.3.8 Emergency PreparednessEffective emergency preparedness systems provide identification,assessment and management of potential adverse situations. Thecompany has established and maintains written emergencyresponse plans for all foreseeable contingencies. To promote HSQE compliance The HSQE System Emergency Contingency Manual will serve as the foundation for emergency response actions. All other contingency plans will have the same basic organization incorporated into relevant sections, where shipboard and shore- based emergency actions are detailed Emergency plans shall be distributed to each vessel and company office The plans shall Identify emergency response personnel, contact points, resources, equipment, and training requirements as well as industry resources that have the ability to assist in response Emergency response plans shall provide guidance for all types of foreseeable emergencies (medical cases, spills, fires/explosion, hurricanes, etc.) Exercises and drills shall be periodically scheduled and cover all scenarios of high hazard potential2.3.9 Maintenance of Ship & EquipmentAn effective and thorough mechanical and operational integrityprogram is essential to the safe operation and reliability of allcritical equipment. It shall be directed toward providing andmaintaining mechanical integrity and ensuring the proper use of allequipment. Shore and Shipboard Management Teams will ensure a planned maintenance program is implemented on-board all vessels to ensure continuous integrity of systemsControlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 002HSQE MANAGEMENT SYSTEM Approval: WBF Page: 8 of 21

System Policies & Procedures PMS will primarily be computerized “ShipNet” systems but may be temporarily substituted by paper-based systems during implementation phase, during computer break-downs, or on certain vessels where sale or similar circumstance is pending. New, spare and replacement parts shall meet design requirements as indicated in manufacturer’s instructions. English language instruction manuals are to be available for all critical and essential equipment, LSA, FFA, Marpol Equipment, and any other system where failure could prove hazardous to personnel, property, or the environment. ISO 9001 certification will normally be the basis upon which supply vendors are accepted, although under extenuating circumstances, managers may authorize other suppliers if necessity dictates need and other quality controls, e.g. storing report, are utilized. Spares for critical equipment will be class certified, approved, or otherwise accepted as fit for service. Employees shall be trained and familiarized with operational procedures so that equipment will not be operated outside established limits. This will be verified by off-signing personnel during hand-over periods, prior to relief. Computerized Planned Maintenance Systems will be utilized to monitor maintenance due and close out of corrective actions resulting from incidents, inspections, audits, and assessments. o Extension of over-due items in ShipNet must be approved by the Superintendent with the reason stated Technical Superintendents are required to maintain an inspection plan that covers all vessels in the fleet, with at least two inspections per annum of each vessel o Technical Superintendent Inspection Reports as considered \"Work Lists\" o Superintendent Inspections “do not” require identification of root causes or recurrence preventionControlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 002HSQE MANAGEMENT SYSTEM Approval: WBF Page: 9 of 21

System Policies & Procedures o Technical incidents (equipment break-downs) require identification of root causes and development of preventative measures, which should be indicated in ShipNet Non-conformities are to be captured in the HSQE Module of ShipNet, where non-conformances are separately recorded and appropriate actions entered to correct and prevent recurrence2.3.10 Incident Investigation & ReportingTimely reporting in accordance with statutory requirements is acompulsory requirement. All senior officers and managers arerequired to know and abide by reporting requirements as mandatedby: The company Classification Society Flag Administration Port State ControlManagers will promote a culture that actively encouragesemployees to report all incidents and dangers. When any of the following incidents occur, an Incident Investigation Report and Root Cause Analysis will be required: o Fatality or Lost Time Injury o High Potential Near Miss o Fire or Explosion o Oil or Chemical Spill into the sea o Grounding, Collision, or Allision o Property Loss in Excess of $100KControlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 002HSQE MANAGEMENT SYSTEM Approval: WBF Page: 10 of 21

System Policies & Procedures2.3.11 HSQE System DocumentationStandard templates are used throughout the HSQE System to makeits contents user friendly and easy to understand. Each manual issegregated into sequentially numbered and coded sections for easyreference. Guiding Manuals o HSQE System Manual  Acronym – HSM  Part A – System Policies & Procedures  Part B – HSQE System References  Part C - Security o System Administration Manual  Acronym – SAM  Part A – Ship/Shore Administration Documents  Part B – Ship/Shore Administration Master Lists o Vessel Type Operations Manual  Acronym – (Vessel Type) Operations Manual  Part A – Bridge & Deck Documents  Part B – Bridge & Deck Checklists  Part C – Engine Operational Documents  Part D – Engine Operational ChecklistsControlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 002HSQE MANAGEMENT SYSTEM Approval: WBF Page: 11 of 21

System Policies & Procedureso Emergency Contingency Manual  Acronym – ECM  Part A – Emergency Contingency Documents  Part B – Emergency Response Matrixeso Crew Manual  Acronym – CMM  Part A – Marine Personnel Administration Documents  Part B – Marine Personnel Administration Matrixes  Part C – MLC 2006 Documentso SeaTeam Forms, Logs, & Printed Booklets  Numbered, Dated, & Assigned Departmental Abbreviations  Validity denoted on Master-Listo HSQE Posters  Numbered & Dated  Validity denoted on Master-Listo Directives & Alerts  Numbered & Dated  Distribution Subject to Department Head ApprovalControlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 002HSQE MANAGEMENT SYSTEM Approval: WBF Page: 12 of 21

System Policies & Procedures o SeaTeam Induction Manual  Acronym – SIM  Subordinate to and Supportive of Documents listed above  Individualized copies2.3.12 Records Duplication of record keeping or data recording, is counterproductive and therefore discouraged. In those circumstances where alternative arrangements (Forms, Logs, Electronic Methods) can provide equitable or better recording of data than records developed for purpose, alternative methods are acceptable as long as content of the records conforms to HSQE requirements and use is approved by the Master and reported to the HSQE Department.  Company offices and vessels must maintain accurate records. All records must be legible and identifiable to the vessel or operation involved. Officers and Managers are to ensure records are stored according to a filing index and that personnel are designated with responsibility for reviewing documents, safe- keeping, retention time, back-up, and disposal  The default retention time for any document not specifically stated is 3 years, however electronic copies may be retained indefinitely, at the discretion of the company  Records are considered proprietary and are not be released to any third party with the consent of a senior manager2.3.13 Document Control Document control is a process whereby the validity of HSQE System documentation is constantly maintained so that only the latest approved procedures and instructions are available for reference.  Documents are produced, numbered, verified, approved, registered, filed and distributed by date, with the current validControlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 002HSQE MANAGEMENT SYSTEM Approval: WBF Page: 13 of 21

System Policies & Procedures documentation maintained at all times in the ShipNet Database for ease of reference. Changes to documents are subject to change control. When changes to the HSQE System are made, the section affected will be reproduced with the date of the change and revision status marked in the footer of the page Changes to documents are verified and approved by the Senior Manage HSQE All content uploaded into the ShipNet database constitute the latest and most up-to-date controlled versions of HSQE Documentation. Once updated documents are uploaded, paper versions a directive is issued to highlight changes to the fleet Printed versions of the updated documents may take 2-3 months to reach vessels (depending upon trade) and lag time, though considered normal, must be kept in mind when referring to documentation after an update.2.3.14 Reference DocumentsReference documents refer to documents used but not produced bySeaTeam. This includes classification rules, ships plans anddrawings, statutory rules and regulations, standards, codes and laws,and instruction manuals. Inventory for ship’s library of publications is specified in HSQE Master-Lists Instruction manuals should be in the English language2.3.15 Compliance with Mandatory Rules SeaTeam operates its fleet in compliance with classification rules and statutory regulations.Controlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 002HSQE MANAGEMENT SYSTEM Approval: WBF Page: 14 of 21

System Policies & Procedures  Each vessel will also have onboard relevant documentation. The extent and content is provided on an Inventory Master List. Each Captain is required to verify the on board inventory when changing command.  The company keeps itself updated on all relevant and required rules, regulations and amendments. This is achieved by subscribing to, or by being members of international organizations such as the Intertanko, BIMCO, and by being in contact with the major classification societies and maritime administrations.  New rules, regulations and changes are monitored by department heads, the consequences evaluated and necessary actions taken to comply. The vessels and the office staff are informed through circulars, emails, and/or amendments to HSQE System2.3.16 IT Policy SeaTeam requires that computer systems, software, and related equipment be managed as follows:  The IT department is responsible for all computer hardware requirements and software packages used within the company. Maintenance of Servers, Computers, Printers, Networks, UPS and other hardware, is the responsibility of IT department. Maintenance covers the day to day upkeep of the hardware. If any problems related to this equipment arise, the IT department is to check and verify the condition of the system. If the equipment breaks down and is beyond the ability of the IT department to repair, then the IT department is to coordinate with an approved vendor for appropriate action. If the service charges or parts which are needed are beyond a reasonable cost, the IT department will then recommend a new one subject to approval from the approving manager. Any repair or replacement of equipment will be based on company’s best practices and not user personal preference. Renewal of equipment will be made from time to time according to company’s best practices.Controlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 002HSQE MANAGEMENT SYSTEM Approval: WBF Page: 15 of 21

System Policies & Procedures Any malfunctioning of the equipment providing IT facilities is deemed urgent and restorative action should be taken. The IT department is to notify all internal staff whenever repairs and/or maintenance is being carried out.Data security and software standardization It is SeaTeam’s objective that all software being used in the office and within the fleet is compatible with each other. All users of SeaTeam’s computer and E-mail systems are required to change their password periodically. Personal passwords are solely for privacy legislation and cannot be disclosed or made available to any other members without the express approval of Senior Management. Computer systems are owned and/or operated for the conduct of company business. Employees should not expect any rights to exclusively or privately use any Company property. PCs and notebooks are set up by IT department with the required software and access to systems. Users are not allowed to change any PC hardware, settings or software. Unlicensed software cannot be installed and will subject the company to copyright infringement. All software on company PCs and notebooks must be purchased and licensed or authorized by the company.Server application It is the responsibility of the IT department to maintain the data integrity of the system. Other software aside from the corporate standard may be approved for installation by a Senior Manager provided the IT department is consulted and notice is given by the Senior Manager.Office Back-Up The backing up of all files in the office network is done automatically, between 2200 and 2300, daily.Controlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 002HSQE MANAGEMENT SYSTEM Approval: WBF Page: 16 of 21

System Policies & ProceduresVessel data backup/data loss prevention Vessel backup is taken via External Hard disk with 1TB capacity. Backup software is to be installed on the server and the backup is scheduled for Weekly Anti-Virus software is to be installed on all the server and the update patch will be automatically downloaded to the server during HMC mail communication process. There are to be 2 hard disks with the server, with which data will replicate in parallel. If the operating system is corrupted, a repair CD is provided with the server. Server is configured with 2 Drives All the main data files are in the Data drive instead of the default C:\Bootable driveServer administration and anti-virus Standard read write rights for all the users are granted to log onto the network. The IT department is responsible for securing the data in the network. Anti-Virus software is installed and updated to automatically scan, detect and clean any harmful programs or files carrying viruses. The IT department is to exercise due diligence where new virus strains are concerned.Email Email is a corporate tool for communication, internal and external. It is not our intent to judge the merit of Email content. Users are responsible for their day to day Email usage. In order to maintain our company’s integrity and avoid destructive viruses, evasive action against the spread of viruses must be taken by all staff.Controlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 002HSQE MANAGEMENT SYSTEM Approval: WBF Page: 17 of 21

System Policies & ProceduresPurchasing IT equipment The IT department will endeavor to procure energy efficient components in line with the company policy for energy conservation.Shipboard Internet Access Internet Access aboard ship is restricted to the SEVSAT System in accordance with conditions approved by the company Fleet 77 may not be used for Internet connection or surfing Access to pornographic sites is strictly prohibited All crew member are to conform to SeaTeam Social Media Policy All crew member are to act in accordance to the Internet/IT declaration signed under SeaTeam Form No. Crew 028B IT and computer systems are company property. Due to recurring problems with unauthorized Internet Access, Virus Infection, and Copyright Infringement, the following is applicable: o Computers are not to be used on the Bridge by anyone on watch or forming part of the bridge team at any time o Mobile devices are not to be used on the Bridge by anyone on watch or forming part of the bridge team at any time with the exception of the Master communicating with the relevant parties during pilotage or transiting o Chartco laptop or PC is authorized for use on the bridge and is strictly only for the use of Chartco facilities o No means of Internet Access is to be connectible on the Bridge either via cable or wireless o SeaTeam will employ a firewall which will determine the sites to be allowed or blocked. The IT department maintain those categories in accordance to best business practices. Those popular categories like social media (eg. Facebook, Twitter)Controlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 002HSQE MANAGEMENT SYSTEM Approval: WBF Page: 18 of 21

System Policies & Procedures will not be blocked and will be allowed to be access within our network. Other requests made by ship staff are subjected to approval by the IT department. o If illegal download of any type of contents or other clear misuse of SEVSAT that results in the levy of a fine against the company, the amount of the fine will be deducted from the pay of the crew member involved o A Master List of user names and passwords along with any software installation disks are to be kept in the Master's safe, not divulged to juniors, and passed to each new Master, when there is a change in command, with specific remark entered in hand-over notes.2.3.16.1 Social Media Policy SeaTeam Management has established the following Social Media Policy to provide employees with a guidance on the use of social media. Social media must be used responsibly so as to avoid damage to SeaTeam’s image and/or individual employees on a personal level. Every Employee of SeaTeam Management is expected to comply with the following:  Never imply that he/she is representing SeaTeam Management  Avoid personal opinions that may be interpreted as speaking on behalf of SeaTeam Management.  Avoid using social media to comment on activities during an incident involving the company.  Be aware that emotional comments during a crisis may make the situation worse.  Comply with local laws and regulations and not to infringe any intellectual property or rights of others.  Be responsible for what he has posted.Controlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 002HSQE MANAGEMENT SYSTEM Approval: WBF Page: 19 of 21

System Policies & Procedures  To realize that a post may be seen by many and some viewers may misinterpret opinions posted.  Not post anything that offends accepted social standards of decency.  Not post any personal or confidential business information about SeaTeam Management or SeaTeam Management’s stakeholders  Not post any sensitive information that is not publicly available but learned in the course of the job.  Understand that information posted online may be impossible to delete at a later date.  Understand that anything posted can spread to other media platforms. SeaTeam Management’s official social media accounts SeaTeam has the following official social media accounts. Staff may approach the Systems Manager should they have anything they would like to see included on these sites. 1. Website – www.sea-team.com (Used for official incident comments/updates) 2. Facebook – www.facebook.com/SeaTeam.Management (For contributions of general interest, events, places, activities, best practices or encouraging words) Any post made by any employee of SeaTeam Management other than on the SeaTeam Management’s public accounts is not to be considered to be a public statement or endorsed view of SeaTeam Management.2.3.17 CommunicationAll crew are required to be able to communicate effectively andunderstand instructions in an emergency. 1. Working Language - The shipboard working language will be determined by the nationalities of the crew on board. Where multinational crews are employed, English will be the officialControlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 002HSQE MANAGEMENT SYSTEM Approval: WBF Page: 20 of 21

System Policies & Procedures working language. Where the entire crew is made up of a single nationality, the native language may be used as the working language. 2. Command Language - The command language, between ship and shore, will be English. All Masters, Chief Engineers and nautical officers are required to have conversational command of the English Documentation & Filing o HSQE Policy Statement  Prominently posted in all offices and on all vessels  Provided to all staff during Induction Distribution o All Offices o All Vessels References o ISM Code o ISO 9001 o ISO 14001 o OHSAS 18001 o OCIMF TMSA o Quality Safety Program o MLC 2006Controlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 002HSQE MANAGEMENT SYSTEM Approval: WBF Page: 21 of 21

System Policies & Procedures3.0 Company Responsibilities & Authority  Purpose o To clearly state the responsibilities and authorities of key staff  Application o Singapore Office o All Vessels  Responsibility o Office Managers o Shipboard Management Team3.1 Responsibilities & AuthorityThe responsibilities and authority connected to each management andfunction position onshore and on board are described in job descriptionsand authority charts. 3.1.1 Master’s Responsibilities & Overriding Authority The Master is Management’s representative on board. He has the authority to act as he deems necessary, in an emergency situation involving the safety of the crew, vessel and cargo, and for pollution prevention without prior approval from the company. The Master of the ship has overriding authority in matters regarding safety and pollution prevention. This authority allows the Master to make critical decisions with regard to measures which may be necessary to save the ship, including use of Lloyds Open Form, in situations where shore based personnel cannot be contacted or the immediate circumstances preclude all alternatives.Controlled Revision: 01 Sep 2015HSM Part A - SPP Doc No. 003TABLE OF CONTENTS Approval: WBF Page: 1 of 5

System Policies & Procedures3.1.2 Managing DirectorThe Managing Director is responsible for all activities within thecompany. He will manage the company in accordance with nationallaws and regulations, company polices, and the plans and budget asapproved by the Board. The Managing Director has the overallresponsibility for HSQE implementation and the quality of servicesprovided by the company.3.1.3 Senior ManagersThe Technical Director is responsible for the daily operation of the fleetmanaged. As head of department, he is responsible for theadministration and running of this department.The CEO Crewing is responsible for all crewing and marine personnelmatters related to the employment of sea staff for the fleet, and theday to day operation of the Crewing Department where locatedThe Senior Manager HSQE is responsible for the development,implementation and maintenance of the HSQE Management System.He will assess risks, initiate audits and follow up corrective actions. Heis also responsible for the implementation, and company adherence tothe HSQE Management System. He monitors performance, conductsmanagement reviews and proposes improvements where needed3.1.4 ManagersIt is the responsibility of each line manager to implement the HSQESystem in his or her unit. He or she should ensure that all employeesare familiar with their responsibilities, authority and interrelationships.Each manager has in turn responsibility the quality of all activitieswithin the organizational unit • The Marine Manager is designated responsible for maintaining navigational standards on board. He is charged to oversee navigational practices and guide Marine Superintendents and Port Captains in assisting in monitoring the implementation of navigational standards.Controlled Revision: 01 Sep 2015HSM Part A - SPP Doc No. 003TABLE OF CONTENTS Approval: WBF Page: 2 of 5

System Policies & Procedures3.1.5 StaffEach employee has the responsibility to know and adhere to HSQESystem policies and procedures. Each employee is required to have aclear understanding of their job descriptions and the operationalprocedures for equipment in their charge. Each employee isresponsible for his or her own safety and compliance with HSQEprocedures relevant to their work and jobs being carried out, as wellas the quality of work accomplished.Each employee is responsible to ensure that no job is ever consideredso urgent that it cannot be carried out safely and in anenvironmentally correct manner3.1.6 Designated Person Ashore/Designated ManagementRepresentativePerson designated by the Managing Director to serve as a link betweenthe staff and top management in health, safety, quality, andenvironmental. He has the responsibility to monitor the safety andpollution prevention measures on board, and to ensure the vesselshave adequate resources to carry out employment in accordance withthe standards mandated by the HSQE Management System, andarrange additional support when need be.The Designated Person/Management Representative is responsible toreceive complaints and feedback from the fleet when the normal chainof command breaks down regarding serious and or potentiallyhazardous conditions.• The Primary DPA is the Senior Manager HSQE• The Alternate DPA is the CEO Crewing (Manila & Chennai) o If the primary DPA is directly involved or id the subject of a particular problem, the Alternate DPA should be contacted for assistanceControlled Revision: 01 Sep 2015HSM Part A - SPP Doc No. 003TABLE OF CONTENTS Approval: WBF Page: 3 of 5

System Policies & ProceduresCompetency Profile• The IMO has issued a Marine Safety Circular (MSC-MEPC.7/Circ. 6, dated 19 October 2007) to clarify the minimum training requirements for DPA as required by the ISM Code, implemented on 1 July 1998. The guidance comprises eight elements of which the DPA shall be competent: o Knowledge and understanding of the ISM Code o Mandatory Rules and regulations o Applicable Codes, Guidelines and standards as appropriate o Assessment techniques of examining, questioning, evaluating and reporting o Technical or operational aspects of safety management o Appropriate knowledge of shipping and shipboard operations o Participation in at least one marine-related management system audit o Effective communications with shipboard staff and senior management3.1.7 Company Security OfficerThe Company Security Officer has been employed by the Company tooversee ship security. The CSO serve as a link between the vesselsand top management in security matters. The CSO has responsibilityto monitor security and ensure compliance with the ISPS Codeonboard.3.1.8 Responsibility to Report to Flag AdministrationThe HSQE Department will ensure that the documentation identifyingthe company as the entity responsible for the operation of the shipunder the ISM Code is prepared and submitted to the owner forControlled Revision: 01 Sep 2015HSM Part A - SPP Doc No. 003TABLE OF CONTENTS Approval: WBF Page: 4 of 5

System Policies & Procedures endorsement and forwarding to the flag administration. A copy of entity notifications will be maintained on board and in the office3.2 Management CommitmentSeaTeam communicates its management commitment to HSQEmanagement in its policy statement. A signed version is required to be: • Posted in every office and on every ship under management • Provided to every employee on recruitment • Discussed with each employee during inductionThe Managing Director maintains an \"Open Door\" policy with SeaTeamstaff. Although the Designated Person is primarily responsible to receivecomplaints and feedback from the fleet, any senior manager may becontacted when management involvement is needed to rectify a recurringproblem or when necessary resources are deemed to be inadequate.  Documentation & Filing o HSQE Policy Statement  Prominently posted in all offices and on all vessels  Provided to all staff during Induction o Lloyds Open Form  Master's E-File  Distribution o All Offices o All Vessels  References o ISM CodeControlled Revision: 01 Sep 2015HSM Part A - SPP Doc No. 003TABLE OF CONTENTS Approval: WBF Page: 5 of 5

System Policies & Procedures4.0 Resources & Personnel  Purpose o To detail company processes to provide and verify adequacy of resources and personnel  Application o All Offices o All Vessels  Responsibility o Shore Management Team o Shipboard Management Team4.1 Provision of Adequate Resources SeaTeam has established procedures to ensure vessels are provided with adequate resources to allow shipboard work and operations to be carried out in a safe and environmentally friendly manner. • Required inventories of essential materials are specified in minimum inventory lists • The adequacy of resources is confirmed through periodic audits and inspections, where any inadequacy in company standards may be reported as a non-conformance. • The Designated Person Ashore (DPA) is a vital communications link in ensuring daily budgetary considerations does not adversely affect the adequacy of resources. The Designated Person Ashore (DPA) should be contacted any time essential personnel, stores or services are not provided within normal and reasonable time limits. When repeated shortfalls are identified, the Designated Person Ashore (DPA) will communicate such concerns to the attention of the Managing Director for action as may be appropriate.Controlled Revision: 01 Jun 2013HSM Part A – SPP Doc No. 004TABLE OF CONTENTS Approval: WBF Page: 1 of 8

System Policies & Procedures4.2 Human Resources The proficiency and success of SeaTeam is closely linked to ability to recruit and maintain qualified staff. The company has established an HSQE Administration Manual with complete and detailed selection, training and motivation criteria.4.3 Recruitment Recruitment of Ship's crew is accomplished by SeaTeam India, or through other reputable manning agents. Recruitment of Shore staff is accomplished by SeaTeam Singapore.4.3.1 Selection of StaffThe total manning of the ship is specified according to vessel typeand trade and shall always be in compliance with statutoryrequirements and the minimum manning certificate. It is verifiedthat the ship is manned according to these requirements.• Vessels are individually screened to confirm adequate manpower is assigned on board.• The qualifications and experience required for each position on board is based on:o STCW convention of 1995o Type of vessel, cargo, size, trade• Recruitment verifies that each candidate has appropriatequalifications and experience and is medically fit. The processincludes checking of educational and competency certificate,personal identification and travel documents, neededendorsements, and required courses attended.• Staff and crew are required to declare medical history and have a standard medical check by an approved medical clinic.• All crew members are required to understand key instructions and have a basic command of the English languageControlled Revision: 01 Jun 2013HSM Part A – SPP Doc No. 004TABLE OF CONTENTS Approval: WBF Page: 2 of 8

System Policies & Procedures o Ship's officers are required to have a good command of both written and spoken English• The Master is required to be conversant with all policies and ensure HSQE procedures are emphasized to crew.• Masters and Chief Engineers are to be routed, as far as practical, via the Singapore office prior to joining a SeaTeam vessel for the first time. Such briefing is to be of no less than one full day in the office, and to include all relevant Safety, Health, Environmental, Operational, and Technical issues.• If the Master or the Chief Engineer for any reason is not able to visit the office prior to joining, a SeaTeam representative, will join the ship at the first convenient port to brief the Master or Chief Engineer on company procedures.• As a matter of routine, senior personnel are to be routed through the SeaTeam office at least once a year for briefing or debriefing as far as practicable.• In cases were a significant incident or occurrence has transpired, the involved senior officers will, whenever possible, be routed through the Singapore office for debriefing and explanation.• It is company policy to utilize certain select senior officers in the head office, for limited periods while ashore, for administrative and technical support as well as enhanced induction and team building.4.3.2 AppraisalThe company uses a form based appraisal system to periodicallymonitor and review the ability and conduct of staff and crew. Theevaluation form includes identification of desired and recommendedtraining and is discussed with the appraised individual tocommunicate expectations and values.Controlled Revision: 01 Jun 2013HSM Part A – SPP Doc No. 004TABLE OF CONTENTS Approval: WBF Page: 3 of 8

System Policies & Procedures4.3.3 TrainingIt is the intention of SeaTeam to provide a variable training programso staff may refresh and upgrade knowledge qualifications. Trainingprograms will be designed to assist to all staff in their own \"upwardmobility\" through additional certifications and qualifications forpromotion. The company intends to retain qualified personnel byproviding for their continued growth within the company.The company will provide all staff with a basic knowledge of thesafety, health and environmental issues that will make managedvessels safe for personnel, cargo carried and the environment. Suchknowledge will be assured through provision of:• Statutory courses where needed for the position employed• Pre-departure orientation and/or induction seminars• Personal copy of the Company Induction Manual• Company Quality Safety Campaign• Multi-Media Resources such as Computer Based and Video Training• Detailed familiarization and induction checklists for joining staff SeaTeam will provide company sponsored training in safety, operations and other matters through in-house sources and local maritime schools and institutions. 4.3.3.1 Induction The HSQE Induction course for SeaTeam staffs is to be arranged prior to the individual‘s start date or at the earliest possible opportunity thereafter. Induction is preferably presented during periodic seminars scheduled for this purpose, but alternately may be accomplished via review of on-line HSE Induction .ppt presentations. In all cases staff, are presented with a personal copy of the company induction manual.Controlled Revision: 01 Jun 2013HSM Part A – SPP Doc No. 004TABLE OF CONTENTS Approval: WBF Page: 4 of 8

System Policies & ProceduresVessel and Office specific induction, is conducted by the safetyofficer, HSQE staff, or the individual‘s supervisor using the pre-prepared program available on the server.Sea Staff• New joining Sea Staff are required to complete an escorted safety tour of the vessel with essential safety information to be provided prior to sailing, with the balance of familiarization conducted within 48 hours after leaving port. Company checklists are to be used to record conduct of this initial familiarization. Off-signers are responsible to demonstrate use of equipment that is required to do their jobs, with officers required to provide hand-over notes listing pending items and any known hazards or limitations pending.Office Staff• Office induction checklists are to be be completed whenever new staff joins the company. Managers are responsible to meet and provide orientation for new staff in accordance with the checklistVisitors• Any person visiting SeaTeam ships or officers is to be presented with an Office Safety Card or Visitors Badge with Safety Instructions. The employee greeting the visitor is responsible to advise the visitor to refer to the card for safety information.Contractor Staff• Contractors working aboard SeaTeam vessels are to be provided with copies of the company induction manual and advised that they must comply with company HSQE standards when working onboard. The Safety Officer is responsible to monitor contractor working practices and instruct the supervisor to stop work if unsafe acts or conditions are observed.• Personnel sailing onboard are required to sign company indemnity form and possess written assignment instructions detailing the scope of their employment while onboard.Controlled Revision: 01 Jun 2013HSM Part A – SPP Doc No. 004TABLE OF CONTENTS Approval: WBF Page: 5 of 8

System Policies & Procedures4.3.4 Sea Staff AdministrationSeateam's Crewing functions are primarily managed by localSeaTeam offices overseas which are dedicated to the employmentof Sea Staff. This includes:• Recruitment• Interviewing and selection of new staff• Maintaining records of all officers and crew• Maintain crew list and personal particulars of those onboard.• Ensure crew training requirements (including ShipNet) is provided.• SeaTeam crewing offices shall co-ordinate all the signing on/off and repatriation of crew members including liaising with Shore Management Team, agents, unions and national authorities. They will be the point of contact for all crewing matters such as wages and other employment conditions.4.3.5 Shore StaffThe personnel function for the office staff is administered by theAdministration Department., headed by the Managing Director.Company personnel guidelines cover all relevant personnelfunctions. Responsibilities and authority are outlined, jobdescriptions specified and recruitment and training proceduresimplemented.4.3.6 Qualification of PersonnelAll staff is required to hold appropriated qualification documents forthe position being filled. Detailed qualification requirements arespecified in qualification tables and matrixes in the Crewing Manualor Ship/Shore Administration Manual for shore staff.Controlled Revision: 01 Jun 2013HSM Part A – SPP Doc No. 004TABLE OF CONTENTS Approval: WBF Page: 6 of 8