HSQE System Manual - 01 Sep 2015

System Policies & Procedures o Manufacturers maintenance instructions should be followed in all instances Appropriate dress for the work and climate o The company provides winter clothing inventory for each vessel o Officers should monitor expected weather conditions and ensure appropriate clothing is issued to crew required to work outside the accommodation area Avoidance of drugs other than medications for illness and injury o Use of illegal drugs is prohibited o Staff are tested for drug use prior to assignment onboard and periodically thereafter, through both announced and unannounced testing o Test results indicating illegal drug use will result in dismissal if confirmed o Use of prescription drugs must be declared to the Master Vaccinations/inoculations required are fully up to date o The company provides pre-assignment medical checks and verifications o Medications for prevention of illness (e.g. anti-malarial tablets etc.) should be taken when required Avoidance of heat stress o Staff should be aware that abnormal urine colour is an indication of heat stress o Officers should have awareness of symptoms of heat exhaustion and heat stroke, and ensure adequate cool down periods are providedControlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 008HEALTH MANAGEMENT Approval: WBF Page: 5 of 28

System Policies & Procedures o The skin is to be protected from strong sunlight and crew should be encouraged to drink plenty of liquids to replace the body fluids lost through perspiration o Consumption of electrolytes is encourage Avoidance of slips, trips and falls o Staff and crew should be aware and continuously utilize techniques to prevent slips, trips, and falls o PA announcements should be made when heavy weather precautions are in effect o Oily areas should be wiped up by any individual observing such hazards o Anti-slip footwear should be worn when-ever working o Three point climbing techniques should be understood by all staff and practiced in climbing situations where appropriate8.2 Food HandlingWhen handling food, crew-members must observe good personalhygiene and food preparation practices, including: Food is not to be left lying around in ambient temperature. To prevent growth of harmful bacteria it is essential to keep food either very hot (above 63 Deg. C) or very cold (below 5 Deg. C) Cooled food items (e.g. fresh fruits and vegetables, processed and cooked meat products and foods prepared for rapid use) should be kept covered and stored at between 0 Deg C and 7 Deg C depending on the product Cook food thoroughly, especially meat, poultry, eggs and seafood. Bring foods like soups and stews to boiling to make sure that they have reached 70°C . For meat and poultry, make sure that juices are clear, not pink. Ideally, use a thermometer. Reheat cooked food thoroughlyControlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 008HEALTH MANAGEMENT Approval: WBF Page: 6 of 28

System Policies & Procedures  Proper cooking kills almost all dangerous microorganisms. Studies have shown that cooking food to a temperature of 70°C can help ensure it is safe for consumption. Keep food at safe temperatures: o Do not leave cooked food at room temperature for more than 2 hours o Refrigerate promptly all cooked and perishable food (preferably below 5°C) o Keep cooked food piping hot (more than 60°C) prior to serving  Microorganisms can multiply very quickly if food is stored at room temperature. By holding at temperatures below 5°C or above 60°C, the growth of microorganisms is slowed down or stopped. Fruits and vegetables that are not in good condition (e.g. spoiled, rotten, molded, etc.) are to be discarded Frozen provision defrosting should be carried out in a cool clean area with the defrosting goods kept covered and separate from cooked foods Separate work surfaces must be used for the preparation of raw meat and if space is restricted, at least a separate chopping board provided. However if the same surface is used for preparation of raw and cooked meats then the area must be cleaned between preparations Food that has been served and left-over food is to have a maximum shelf-life of not more than 48 hours because of the possibility of contamination Raw/unprocessed food must be kept apart from cooked food and milk. Where raw/unprocessed and prepared food is kept in the same compartment (freezer), items are to be kept well separatedControlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 008HEALTH MANAGEMENT Approval: WBF Page: 7 of 28

System Policies & Procedures Refrigeration thermometers should be easily visible to persons working in passageways serving the refrigerated spaces or on the engineers control panel Refer door seals to be maintained in good order Freezer and cooler compartments are to have properly maintained and accurate thermometers for temperature control and monitoring Alarms must be in good working order in case of lock-in Ensure freezer and cooler compartments are clean before food orders are received Dry food stores should be dry, cool, well lit and ventilated Food and provisions must not be ‘outdated’. Careful checking of ‘best before’, ‘use by’ or ‘other’ markings is to be carried out to ensure no ‘outdated’ provisions are retained onboard Personnel who are sick or infected by contagious diseases are not to handle food or provisions The Master is to ensure food and provisions are handled and stored hygienically by carrying out weekly inspections and general observation The catering staff must be properly dressed when handling or preparing food: o No bare or open slippers o Clean aprons to be worn when preparing food o Hands are to be frequently washed with soap and hot water Food preparation and eating surfaces must be cleaned after each meal with a clean cloth, antibacterial soap and water Dishes are to be promptly washed in dish soap and hot water Galley ConditionControlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 008HEALTH MANAGEMENT Approval: WBF Page: 8 of 28

System Policies & Procedures o Hot plates to be switched off when the galley is unattended o Equipment such as ranges, waste disposal units, hot plates, etc., must be kept clean o Mechanical ventilation system should be used to keep odours and smoke clear o Ventilation hoods and grease filters are to be kept in good condition and cleaned weekly. o Exhaust ducts should be inspected for grease build-up on a quarterly basis, and thoroughly cleaned when build-up is evident or at least annually o Food waste to be separated from other garbage and kept in sturdy, tightly covered garbage cans o Galley staff are required to understand and adhere to MARPOL garbage disposal requirements o Cookware, crockery and utensils are to be thoroughly cleaned after each use and properly stored o Keep knives clean and sharp o If plates, pots, pans, cutlery, etc. are washed by hand then hot water should be used o Where possible all galley utensils not in use are to be hung or stored to avoid loss, damage or injury to seafarers when the ship rolls o Facilities are to be provided in or near the galley wash basin for cleaning hands (e.g. soap and disposable towels or other hygienic drying facilities) Galley Stores o Store provisions so counting can be done easily o Rotate stock first in – first outControlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 008HEALTH MANAGEMENT Approval: WBF Page: 9 of 28

System Policies & Procedures o Wrap food items in freezers to prevent “freezer burns” o Store at convenient and cost-effective ports o Do not over-order as this leads to waste o Check expiry of new stores when received o Report poor quality stores via the ShipNet database8.3 Healthy Eating GuidelinesThe company promotes healthy eating through provision sufficientstores to provide a balanced menu in accordance with establishedguidelines, where the following proportionate distribution should usedas an approximate basis for preparation and consumption:Figure 8.3-1 Food Guide Pyramid o 30% Fruits & Vegetables o 30% Bread, Pasta, Rice, & Potatoes o 15% Meat & FishControlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 008HEALTH MANAGEMENT Approval: WBF Page: 10 of 28

System Policies & Procedures o 15% Milk & Dairy Foods o 10% Fat & Sugary Foods  Menus are to be prepared on a monthly basis and approved by the Master8.4 Infestation ControlAll spaces, especially where food is handled, are to be carefullymonitored for any sign of vermin infestation. If evident, controlmeasures must be applied as soon as possible, but subject to thefollowing restrictions: Poisons may only be used with the concurrence and oversight of the Master and Safety Officer Poison must be properly labeled and all warnings adhered to Poison must never be stored in the same spaces as food or medicine If cockroaches, mice, rats, flies or other vermin are evident, the crew must bring this to the attention of the senior onboard management immediately so extermination can be accomplished before significant infestation occurs. Professional pest control services should be requested via the technical superintendent if infestations resist treatments and become chronic No uncovered or unsealed food to be left out in the galley or pantry No food to be brought to cabins8.5 Living ConditionsThe company has determined that to maintain good living conditionsonboard and to present a good impression to those inspecting the ship(e.g. Port State Control) the visual appearance, condition andControlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 008HEALTH MANAGEMENT Approval: WBF Page: 11 of 28

System Policies & Proceduresstandard of maintenance of the crew accommodation and workingspaces is to be given high priority. The accommodation and working space heating, ventilation systems, lighting systems, water closets, washing facilities and similar fittings must be well maintained and operational. Individual crew accommodation (cabins) must be maintained in clean, decent and habitable condition, and free of goods or stores that are not the personal property of the occupants. All crew cabins, sleeping rooms and mess rooms are to be kept ventilated. The system of ventilation must maintain a satisfactory ambient condition under all external conditions of weather and climate. The vessels air-conditioning system is to be cleaned, maintained and operated as per the manufacturers recommendations. The PMS system is be used for maintenance and record keeping. The ventilation may have to be controlled (e.g. re-circulation) when handling certain hazardous cargoes such as petroleum in bulk.8.6 Sanitary AccommodationToilets, change rooms, showers and wash rooms must be kept cleanand sanitary including: Floors in are to be kept clean and well drained Sufficient lighting, heating and ventilation is to be provided Both hot and cold fresh water is to be available in all wash rooms Floor tiles should not be broken or missing Water closets are to be maintained with ample flush water and available at all times All drains to be clear and free flowingControlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 008HEALTH MANAGEMENT Approval: WBF Page: 12 of 28

System Policies & Procedures Multiple water closets in one compartment are to be screened for privacy Toilets are to be kept clean and well stocked with amenities: o Toilet tissue x 2 Rolls o Hand Soap o Hand Towels o Deodorizer8.7 Laundry FacilitiesEach vessel is to be provided sufficient laundry facilities to allowregular washing crew clothes and bed linens Laundry areas are to be kept clean and well organized There must always be sufficient dryers or drying rooms to preclude hanging of laundry in the ships passageways It is prohibited to hang laundry on hand rails or rig clothes lines in passageways or machinery spaces8.8 Potable Drinking WaterPotable water provided for consumption onboard should be maintainedin a clean and safe manner Potable water should be bright, clear; virtually colorless and aerated (e.g. it should bubble when shaken). When loading potable water: o Dedicated clean hoses are to be used. o The hoses are to be flushed thoroughly before use o Hoses are to be drained and properly stored between useControlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 008HEALTH MANAGEMENT Approval: WBF Page: 13 of 28

System Policies & Procedures o Deck filling points must be protected and secured with covers Annually, samples of potable water stored in bulk onboard are to be tested to confirm suitability for human consumption in accordance with WHO guidelines o If the quality of stored potable water is in doubt for any reason, bottled water should used for drinking purposes until tests can be arranged o Any source of non-potable water available from access valves or taps should be labeled to prevent inadvertent consumption8.9 Cabin MaintenanceThe company intends to maintain clean, functioning, healthy, sanitaryand aesthetically pleasing living quarters for everyone onboard. All Crew members must be given sufficient time off, while at sea, to undertake a thorough cleaning of their personal cabins and the common living areas Effectiveness of cleaning sessions must be checked every week by a stringent inspection by Master and /or Chief Officer Results of this inspection and any defects found must be recorded in an Inspection Register and rectified on the spot when possible Requisitions or repair specifications resulting from weekly Cabin Inspections should be sent to the office promptly so that requirements are made known to the Superintendent Engineers. Technical Superintendents are required to place suitable emphasis and priority to living conditions and maintenance of a professional standard onboard Any important matter not rectified promptly or that adversely affects the health and well being of the crew should be brought to the notice of the Designated Person AshoreControlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 008HEALTH MANAGEMENT Approval: WBF Page: 14 of 28

System Policies & Procedures8.10 Medical ScreeningThe company maintains industry standard pre-employment medicalchecks. Medical screening of all staff is conducted by physical exam todetermine suitability for employment. Anyone inadvertently exposed to toxic materials in excess of safe limits will be subject to a structured medical screening process to monitor possible health adverse health affects. Screening will be based upon o The physical examination upon initial employment as base line o A Post chemical exposure physical examination o Periodic Physical Exams for continued sea service o Post exposure physical examinations should include a comprehensive blood analysis to check for indicators of the specific chemical exposure.The exact make-up of the physical examination is in accordance withMarine Personnel employment criteria in consultation with thecompany's established network of approved medical clinics and/orregional medical facilities.8.11 Medical FacilitiesThe Master is responsible for ensuring that the ship at all times carriesa supply of medicines and medical equipment in accordance withcompany, flag state regulations, and IMDG Code where applicable. The On-board minimum inventory is based upon international requirements. The Master may requisition any additional medicines or equipment he considers necessary. o The Master is to ensure that the ship’s medical supplies are checked professionally by an approved pharmacist at least once every 12 months and that a certificate in this respect is issuedControlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 008HEALTH MANAGEMENT Approval: WBF Page: 15 of 28

System Policies & Procedures o All medicines are to be labeled in English o The Second Officer will normally serve as the medical officer o Expired medicines are to be separated from valid medicines and marked for disposal o Medicine should be returned to the pharmacist whenever possible and a log entry made describing the inventory returned. Expired medicines should not be disposed at sea or incinerated. o The Master shall keep in his custody all the narcotics onboard. These are to be listed and to be declared at every port o Other medication apart from first aid is to be dispensed by the medical officer only after approval from the Master is obtained o Antibiotics issuance require extreme caution due to the possibility of a life threatening allergic reaction to Penicillin Ships Hospital o The hospital accommodation should not be used other than for medical purposes and is to be maintained clean and ready for receipt of sick and injured persons at any time. o The medical chest is to be kept fully stocked with any time expiring medicines replaced promptly o Hot Water must be available from the sink tap o Fixed Oxygen sets are to have operating instructions posted o Oxygen sets are to have operating instructions readily available o Pesticide may not be store in the HospitalControlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 008HEALTH MANAGEMENT Approval: WBF Page: 16 of 28

System Policies & Procedures Medical Treatment o The Master will supervise and confer with the Chief Mate on medical matters, especially regarding any treatment of a life threatening emergency. o Radio advice from medical personnel ashore should always be given prompt consideration. o In all cases, illness and injuries must be treated with prompt medical attention in strict compliance with the Ship Captain’s Medical Guide or equivalent, or by doctor’s advice. o It is a company requirement that all injuries, no matter how minor, are reported to the medical officer8.12 Winter ClothingA full set of winter clothing and rain gear is to be stored storeroomwhich under the control of the Chief Officer. The Chief Officer is to be responsible for the administration ordering and replenishment of stocks. Stocks should be replenished on a 4-6 monthly basis bearing in mind that all on-signing officers and crew receive an issue of certain items from Crewing Agents. Winter coats, rain gear, and other costly items must be signed for and returned before signing off Minimum stock levels are indicated on SSA Master List 012, which includes those items signed for and in use Boiler Suits, Waterproof and Winter Clothing shall be washed in HOT water or dry-cleaned prior to their re-issue. All items are returnable and property of SeaTeam Management Pte Ltd.Controlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 008HEALTH MANAGEMENT Approval: WBF Page: 17 of 28

System Policies & Procedures8.13 Dress and AttireIn port, officers are to wear uniform, company polo, or clean boilersuits with company logo and a badge of rank. Crew on duty will wear,clean boiler suits or company polo as may be suitable for the workbeing carried out. Catering Staff o Catering staff serving in the Officers' mess room or Lounge and crew's mess room are to be properly dressed, both in port and at sea, in clean white catering jacket, or clean company polo, and black or dark blue trousers. Catering jackets and black or dark blue trousers are supplied by the manning agents at the place of engagement. Attire in Mess-Rooms, Day-Rooms & Public Spaces o Proper attire is to be worn in mess rooms and day-rooms at all times. These are clean areas where shore staff and visitors may be entertained and under no circumstances are working clothes or boiler suits to be worn. o Personnel coming in from watch or other duties should wash and change clothes, if necessary, before seating themselves. They must be allowed the necessary time to wash and change. Whenever the work they are performing makes this difficult, they should use the duty mess room. o Personnel may wear off-duty clothes when they are in the day-rooms. o Flip flops are prohibited from use in any public area, including passageways, stairs, smoking rooms, TV rooms, and mess rooms, and may only to be worn in one’s own cabin o Sandals with straps or other sung fitting, clean leisure footwear may be worn in public spaces, when off duty.Controlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 008HEALTH MANAGEMENT Approval: WBF Page: 18 of 28

System Policies & Procedures8.14 Prevention of Drug & Alcohol AbuseSeaTeam is committed to prevention of drugs and alcohol abuse basiszero tolerance. This Policy is an integral part of the Company’s Health,Safety, Quality & Environmental Policy, in order to prevent incidentsand accidents by proper control of drug abuse and consumption ofalcohol on board Company vessels. In this respect Company must beable to demonstrate at all times that its employees and contractorsare free from the effects of drugs and alcohol.  Every seafarer must understand that he is under a moral and legal obligation to ensure that persons with “impaired” ability from drug or alcohol abuse are not allowed to endanger the safety of others onboard or cause damage to environment and property. Protection of Human Life and Environment are above all other considerations.  SeaTeam policy applies to all personnel employed on vessels Managed, by SeaTeam, and all persons contracted to perform duties on those vessels. It also applies to all Company personnel, supernumeraries or visitors to the vessel.8.15 Drug & Alcohol Policies  Drug Abuse Policy o The use and possession of any drug, unless medically prescribed by a doctor or issued by the ships medical officer, is strictly prohibited onboard any company vessel or when on company business. o The unlawful distribution of any drugs onboard any Company vessel or whilst engaged in Company business is strictly prohibited. o The use of any drug prescribed by a doctor must be declared to the Company prior employment and to the Master on joining the vessel. Personnel should be aware that use of prescribed drugs may impair a person’s mental and / or physical ability to safely perform his duties without endangering the safety of others onboard. The CompanyControlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 008HEALTH MANAGEMENT Approval: WBF Page: 19 of 28

System Policies & Procedures reserves the right to consult with its Doctors before employing such seafarers. o Any person found unlawfully in possession of, abusing the use of, or handling and distributing drugs, shall have their employment immediately terminated and reported to the appropriate authorities where they may face prosecution under applicable national law. o For purposes of employees the, unlawful drugs may be such drugs as, but not limited to, Marijuana, Opium and derivatives (Heroin), Cocaine, Lysergic Acid (LSD), Amphetamines and Phencyclidine (PCP). Alcohol Policy o The Company Policy for the fleet is a ‘Dry Ship’ Policy. No alcoholic beverages are permitted to be taken onboard any of the Company’s vessels by anyone or from any source whatsoever. While this does not preclude the consumption of alcohol while ashore, Company Policy requires that Ship’s personnel must not join or return to the vessel from shore leave with a detectable blood alcohol concentration above 0.04% (40mg/100ml). All personnel will be subject to periodic and unannounced breathalyzer tests for alcohol use. Drug & Alcohol Screening o Pre-employment blood and urine tests for drug use and or alcohol abuse is required o Staff are required to cooperate fully with the Company’s random screening program carried out by Company contracted doctors or professionals o Staff are required to submit to random tests, using alcohol testing devices placed onboard, to ensure that Company Drug and Alcohol Policy is being observed. o Staff will be tested following any accident. Such testing is mandatory in certain jurisdictionsControlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 008HEALTH MANAGEMENT Approval: WBF Page: 20 of 28

System Policies & Procedures o The seafarer must acknowledge that he has understood company drug and alcohol policies and consents to fully cooperate and abide by the policies. Any refusal to undergo tests or tampering with the samples will constitute gross misconduct and grounds for immediate dismissal. Policy Application o The Master and Management of SeaTeam have the power to terminate the employment of any person who has tested positive to any of the tests, including random tests, or whom is believed to be, through witnessed actions, impaired due to the use or abuse of drugs or alcohol. Seafarers Responsibilities o It is the duty of the every seafarer not to handover a watch or permits any person who appears to be under the influence of alcohol to carryout any shipboard duties. Such encounters are required to be reported to the Master, who shall take appropriate action in the best interest of safety of ships complement and protection of the environment. o Where any doubt exists as to the Master’s ability to perform his duties through impairment by alcohol, then the Chief Officer and Chief Engineer Officer must jointly assess the need for the Master to be breath tested, and if the test indicates use of alcohol, SeaTeam Management must be immediately advised and the Chief Officer should assume command in the interim. o Minimum Period of Abstinence  All crew shall observe a minimum period of at least 8 hours after consuming any alcohol prior to taking over a watch  Un-Announced Periodic Alcohol Testing On-Board o The Master is to ensure random alcohol tests are conducted at least once per month. The vessel will log results in an “Alcohol Testing Record” which will be maintained onboard all vessels.Controlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 008HEALTH MANAGEMENT Approval: WBF Page: 21 of 28

System Policies & Procedures o Tests are to be administered to all officers and ratings including the Master o All tests will be witnessed by at least two officers, not including the person being tested o All test results will be entered in an “Alcohol Test” log, to be maintained by the Master, and contain the following:  Name of Person tested  Date of Test  Time of Test  Test Reading  Readings 0.04% or less reported as negative  Readings above 0.04% will be reported to HSQE o The HSQE Department will review cases of \"positive\" readings (above 0.04%) and consult with Master o The Master or Chief Engineer, with Master's concurrence, shall carry out alcohol testing on personnel just prior to or during, a duty status period whenever there is significant evidence that the man is intoxicated to a point that he cannot safely discharge his duties. Un-Announced Periodic Drug Testing o The HSQE Department will advise the vessel when testing is scheduled; each position will be tested within a twelve month period. HSQE will advise the port and the date that the test is to be carried out; this information is kept confidential until the service provider is on route. Confidentiality o The Drug & Alcohol Testing program must be handled in a most discreet and confidential manner to protect the rights of all seamen involved. The absolute control and security ofControlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 008HEALTH MANAGEMENT Approval: WBF Page: 22 of 28

System Policies & Procedures samples and test data must be adhered to by the HSQE Department, the Qualified Collectors, and by the ship's officers administering onboard alcohol tests.  Alcohol Testing In Case Of Accidents o The Master must, as soon as possible, after an accident has occurred carry out alcohol testing of all personnel on duty or involved, including himself, and log the result.  Endorsement of Declaration on Drug and Alcohol Abuse o All Officers and Ratings are required to sign the Sea Team Form Crew 028 \"Pre-Employment Declaration\". If a copy is not available in the crew member’s sign-on documents, Master is to ensure that the form is endorsed and filed.  Positive Test Results o Any officer or crew member who fails to be within company required limits for drugs and alcohol when tested will not be employed or if already onboard then replaced. o Any crew, visitors or others who are determined to be under the influence of illegal drugs or controlled substances will be immediately reported to the appropriate authorities and transferred off the vessel.  Alcohol Test Equipment o Due to the relatively low cost of new equipment, alcohol test equipment should be replaced on an annual basis. All Masters are to verify the purchase or last calibration date of the supplied equipment and requisition new alcohol test equipment 12 months from the original supply or last calibration date.8.16 Shipboard WelfareTo cater for general shipboard welfare, the company has allocatedUSD $200 to be contributed each month, paid from the Master's cashControlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 008HEALTH MANAGEMENT Approval: WBF Page: 23 of 28

System Policies & Proceduresaccount, for reading materials, games, gymnasium equipment, videofilms, and other items as deemed appropriate by those onboard.  Masters are responsible for the overall health and well being of the crew and should endeavor to improve morale and maintain a hospitable environment onboard o Masters, or their delegate representatives, are to ensure welfare & morale issues are periodically discussed with the crew, and use their input in procurement of recreational materials as may best suit the needs of the majority of the crew8.17 Office Occupational Health and SafetyOffice Occupational health and safety guidelines are provided for officeworkers by the HSQE department where “Office-wise” proceduresdeveloped by the Australian Government, has been adopted by thecompany and provided to employees on the shared common drive.Employees are advised to take appropriate countermeasures forcommon office hazards, such as:  Mechanical hazards, such as filing cabinets that tend to tip when heavily laden top drawers are open.  Physical hazards, like glare or reflections from screens; hot components of photocopiers; poorly designed chairs that do not provide the user with adequate back support; or poorly designed jobs and tasks that demand prolonged work in a fixed posture.  Chemical hazards, such as vapors in the atmosphere – for example, paint, solvents or airborne particles like photocopier toner.  Psychological hazards, like the need to perform excessive workloads under pressure; being bullied by a co-worker or supervisor; lack of satisfaction from a job where there is inadequate recognition of work performed; or repetitive work and insufficient task variety.Controlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 008HEALTH MANAGEMENT Approval: WBF Page: 24 of 28

System Policies & Procedures  Electrical hazards such as damaged electrical cords; or overloaded power points that may lead to the risk of electric shock.Employees are required to maintain an awareness of office hazards,and to follow manufacturer’s instructions in the use of office productsand equipment. The DMR should be notified if hazard situation existsthat cannot be controlled by the employee.8.18 AsbestosWorking with asbestos can release small fibres into the air. Breathingthese fibres in can eventually lead to a number of fatal diseases.These include: o Asbestosis or fibrosis (scarring) of the lungs; o Lung cancer; and o Mesothelioma (cancer of the inner lining of the chest wall / abdominal cavity).Although the body will get rid of most of the larger fibres that canenter the nose and mouth, tiny fibres can pass into the lungs. Thebody naturally gets rid of any asbestos fibres taken in with food andwater. Asbestos fibres cannot be absorbed through the skin. Providedthe asbestos material is intact and in a position where it cannot easilybe damaged, it will not pose a risk to health by releasing fibres intothe air.There is no cure for asbestos-related diseases. There is usually a longdelay between first exposure to asbestos and the first symptoms ofdisease. This can vary between 15 and 60 years. It is possible thatrepeated low-level exposures may lead to asbestos-related diseases.Uses of AsbestosAsbestos was used for thermal insulation (lagging), brake (friction)linings, jointing and packing. In addition to solid sheets, it may occurin sprayed form, pre-formed mouldings and inside insulating boards.Use of the more dangerous “Brown” and “Blue” asbestos wasControlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 008HEALTH MANAGEMENT Approval: WBF Page: 25 of 28

System Policies & Proceduresdiscontinued many years ago, but “White” asbestos (which is notalways white) is still occasionally found in some applications.Complete Prohibition on Use of AsbestosSince 1st July 2002, the installation of materials that contain asbestoshad, under SOLAS Regulation II-1/3-5, been prohibited for all ships,except for some vanes, joints and insulation.From 1st January 2011, any new installation of materials that containasbestos is, under SOLAS Regulation II-1/3-5, completely prohibited,for all ships without any exceptions.Asbestos Free DeclarationFrom 1st July 2012, SOLAS regulation requires all suppliers of stores,spares and any equipment to issue an Asbestos Free Declarations tothe vessels whenever they supply anything. Similarly, all repairworkshops and shipyards are also required to issue an Asbestos FreeDeclarations to the vessel stating that no asbestos containing materialwas used while carrying out the repairs, servicing, overhauls orreconditioning. To this effect, TPMS has notified all its suppliers andworkshops to issue an Asbestos Free Declaration.Master and Chief Engineer are to ensure that they receive theAsbestos Free Declarations from all suppliers, workshops andshipyards as detailed below. In the event that such a declaration is notprovided to the vessel, then the Superintendent In-charge or FleetManager must be contacted immediately.An ‘Asbestos Free File’ should be maintained on board. This file shallbe in the custody of the Master and should include the following: o An Asbestos Free Declaration provided by the ship yard or repair yard to which a vessel has been post 1st July 2012. o An Asbestos Free Declaration provided by any workshop or subcontractor for any repair, servicing, overhaul or reconditioning, carried out post 1st July 2012.Controlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 008HEALTH MANAGEMENT Approval: WBF Page: 26 of 28

System Policies & Procedures o An Asbestos Free Declaration provided by the supplier of spares and stores that have been procured onboard post 1st July 2012. o An Asbestos Free Declaration from supplier of spare parts that are already existing onboard and have not been consumed but will be consumed post 1st July 2012.The above declarations will be verified by the attending classsurveyors at the 1st scheduled periodical survey after 1st July 2012.Handling of Asbestos on Older VesselsThe hazard from asbestos only exists where material is in dust orfibrous forms. The hazard increases with disturbance of the material.Certain types of jointing may still contain small quantities of whiteasbestos. Products, such as in Section 2 above, which havetraditionally been made from asbestos, should be assumed to containasbestos, unless positively labelled otherwise.Such products should be kept damp whilst working on them. Cuttingtools must be sharp and only hand-tools may be used. They mustNEVER be ground, machined or filed down. Waste must not be allowedto accumulate and any dust or spillage cleaned up using wet cloths.Use a respirator where there is any risk of dust.If lagging material containing (or suspected to contain) asbestos isdamaged, it should be sealed until an expert contractor can replace itunder controlled conditions. It should NOT normally be removed fromsite by vessel's staff. When inspecting and sealing damaged laggingwhich contains asbestos, personnel involved should wear: o Full sleeve disposable boiler suits. o Rubber gloves. o Suitable respirator incorporating complete nose and mouth cover.Care should be taken to minimise any disturbance of the material. Thearea must be kept well ventilated. Soiled clothing must be sealed indouble plastic bags and appropriately marked for disposal.Controlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 008HEALTH MANAGEMENT Approval: WBF Page: 27 of 28

System Policies & ProceduresIf it is absolutely necessary to disturb materials containing (orsuspected to contain) asbestos, a formal Dangerous Work Permitprocess must be followed, including a toolbox meeting (including riskassessment) and DPA approval obtained, prior to starting work. Thenumber of personnel involved should be minimised and considerationshould be given to the use of all-enclosing fireman’s suits andbreathing apparatus / smoke helmet.Any dust, broken or disturbed material containing, or suspected tocontain asbestos should be double-bagged (in plastic bags) and clearlymarked.Reference to be made to UK Health & Safety Executive Publication:INDG 289 & 187 when preparing work plan & risk assessment.  Documentation & Filing o Onboard Alcohol Test Record o External Drug & Alcohol Test Records o Winter Clothing Issuance Record  Distribution o All Offices o All Vessels  References o OHSAS 18001 o Ship Captains Medical Guide o Tanker Safety Guide (Chemicals) o MFAG, Supplement to IMDG Code o International Medical Guide for Ships (IMGS)Controlled Revision: 01 Jan 2015HSM Part A – SPP Doc No. 008HEALTH MANAGEMENT Approval: WBF Page: 28 of 28

System Policies & Procedures9.0 Environmental Management  Purpose o SeaTeam has established an Environmental Management System (EMS) in conformance with ISO 14001 as a means to implement environmental policies and objectives  Application o All Offices o All Vessels  Responsibility o Shore Management Team o Shipboard Management Team o Individual Staff & Crew 9.1 Scope The company HSQE System is designed to comply with the Safety Management requirements of the ISM Code, the health standards of OHSAS 18001 and the Quality Management requirements of ISO 9001 and TMSA requirements. The Environmental Management System (EMS), specified in this manual, incorporates the environmental management practices outlined by the International Standards Organisation in the ISO 14001 standard. • The environmental management practices and procedures established within this document are to be implemented throughout the organisation. A specific \"To Do\" implementation list, Form HSQE 023, will be provided to each office department and to each ship. • The “To Do” list is required to be completed by all vessels to facilitate system implementation and program awarenessControlled Revision: 01 Sep 2015HSM Part A - SPP Doc No. 009ENVIRONMENTAL MANAGEMENT Approval: WBF Page: 1 of 41

System Policies & Procedures9.2 Environmental PrincipalsIt is a company ambition to achieve environmental excellence in allaspects of business operations and continuously improve performanceby taking into account evolving scientific and practical knowledge withinthe shipping sector.• SeaTeam, as a reputable and responsible ship manager, has made a commitment to achieve a reduction in pollution, conserve and protect the environment and will ensure that the utmost care and all possible actions, with the available capabilities and resources, will be undertaken to prevent pollution through safe operation of managed vessels and efficient operations in the office.• The company will strive to, where possible, further reduce the environmental impact of operations by reducing consumption of materials, re-using, rather than discarding where practicable, and through promotion of recycling and the use of recycled materials• Emphasizes that ultimate responsibility for compliance with environmental procedures rests with each employee.• The company will encourage suppliers to continuously reduce the impact of their operations by giving preference to environmentally friendly products whenever it is economically feasible9.3 General ObjectivesThe objectives of the Environmental Management System are: • To implement, maintain, and improve environmental management practices throughout the company • To ensure conformance with the company environmental policy • To demonstrate conformance to others • To ensure the company's practices are in conformance with ISO 14001 and certified by an external organisationControlled Revision: 01 Sep 2015HSM Part A - SPP Doc No. 009ENVIRONMENTAL MANAGEMENT Approval: WBF Page: 2 of 41

System Policies & Procedures9.4 Identification & Evaluation of Environmental AspectsAn annual screening of company activities is to be conducted by HSQEDepartment. For this purpose, SeaTeam Master List 017 forIdentification and Evaluation of Environmental Aspects will be used. Allidentified aspects are listed and rated with regards to the potentialimpact on different areas of the environment and the significance ofspecific aspects. Current criteria for significance are:Assessing Environmental Aspects for SignificanceThe following criteria will be used to determine numerical values forassessing significance of Environmental Aspects Listed in SAM Master-List 017 Scale of Impact: o Toxicity (compositional characterization of materials and wastes) o Amounts (volumes and masses of emissions, waste, or releases) o Amounts (consumption of renewable and non-renewable resources) Severity /Scarcity o Frequency of episodes o Severity of actual or potential impacts Interested Parties o Legal Requirements o Community ConcernThe potential impact to the environment will be scored by the HSQEpersonnel for the level of impact of each listed aspect in relation to thefollowing six categories: Air WaterControlled Revision: 01 Sep 2015HSM Part A - SPP Doc No. 009ENVIRONMENTAL MANAGEMENT Approval: WBF Page: 3 of 41

System Policies & Procedures Land Natural Resources Flora FaunaImpact will be indicated through assignment of a numerical score from1-5, with 1 being the lowest and 5 being the highest. A sum above 12in any two areas or a total of more than 40 points in any analysis willindicate if the Aspect is to be considered Significant under ISO 14001and will be subject to environmental initiatives through controlmeasures specified in the company’s’ Health, Safety, Quality &Environmental Program as detailed on HSQE Form 010, 5 Year Plan.For each Significant Environmental Aspect, the organization willestablish an appropriate objective and target on HSQE Form 010.There are three primary types of objectives: Control or Maintain – is an appropriate objective for SEAs that are the subject of environmental regulations because the environmental policy states that we will comply with the law. In these cases, the objective will be to maintain conformance with operational controls, such as procedures and work instructions that apply to those significant aspects. The target will be ongoing. Improve – is appropriate for SEAs that our facility goals commit us to improving upon. For example, energy- or water-use reductions that are not required by law but fall within our commitment to pollution prevention. Improvement objectives also can be used for SEAs that have regulatory drivers and environmental improvement goals. Study or Investigate – is appropriate in cases where the HSQE thinks improvement will be feasible and beneficial, but study is needed to determine how much improvement can be achieved and timeframes that are feasible. The objective will be to study the alternatives by a target date in preparation for later setting an improvement objective (or dropping the objective if the study reveals that the changes are not financially, technologically, or logistically feasible).Controlled Revision: 01 Sep 2015HSM Part A - SPP Doc No. 009ENVIRONMENTAL MANAGEMENT Approval: WBF Page: 4 of 41

System Policies & Procedures The Health, Safety, Quality & Environmental Program specified on HSQE Form 010 will address the objectives through controls that provide:  Compliance Assurance  Materials Management  Pollution Prevention/Waste Minimization  Energy ManagementAt least annually, the identification and evaluation of environmentalaspects will be reviewed and updated, including the criteria forsignificance. The review will be indicated by the date on the form and willconsider any additional areas that need to be addressed, as evident from:  Observations, Suggestions & Best Practices  Business Needs 9.5 Identification of Legislation The HSQE Department will routinely screen legislation based upon applicable standards of the statutory regulations contained in applicable international conventions, national regulations affecting vessels in specific trading areas, and relevant industry guidelines and or recommended practices. • The applicability of various standards and pending new legislation will be considered and addressed in the company's quarterly management review. • The HSQE Manager will subscribe to classification society news and publications to compliance with applicable regulations and standards is continuously monitoredControlled Revision: 01 Sep 2015HSM Part A - SPP Doc No. 009ENVIRONMENTAL MANAGEMENT Approval: WBF Page: 5 of 41

System Policies & Procedures9.6 Environmental PlanningSeaTeam will plan services and operations for vessels under itsmanagement to meet all pertinent environmental regulations andendeavour to incorporate environmentally friendly practices.• Company procedures will be evaluated in conjunction with management reviews with the aim of reducing or eliminating potentially negative environmental impacts from managed vessels9.7 Setting of Environmental Objectives & TargetsTargets for progressive improvement are established in conjunctionwith management review meetings and applied to company operationsthrough release of a comprehensive 5 years HSQE Plan.• The 5 Years HSQE Plan provides a time based Environmental Program where objectives and targets are specified, based upon the identified significant aspects and over which the company may exert influence.• Current criteria for establishment of Objectives and Targets are: o Areas where waste can be minimised and efficiency increased o Must be measurable o Must be achievable o Initial Objectives and Targets were established and approved by the Managing Director in advance of vessel management.• Progress is reviewed in conjunction with the company’s quarterly management review.• The company Environmental Program may then be modified basis the results of the reviews.• The company environmental program will address those environmental issues affected by significant aspects, including: o Environmental Initiatives to achieve objectives and targets o ObjectivesControlled Revision: 01 Sep 2015HSM Part A - SPP Doc No. 009ENVIRONMENTAL MANAGEMENT Approval: WBF Page: 6 of 41

System Policies & Procedures o Annual Targets for Improvement o Responsibility for achieving Objectives and Targets9.8 Environmental ReadinessThe HSQE System provides detailed procedures for implementedprocedures for pollution prevention. Primarily these procedures arefound in the Tanker / Chemical Tanker or Bulk Carrier OperationsManuals, Shipboard Oil Pollution Emergency Plan or Shipboard MarinePollution Emergency Plan, Vessel Response Plans, Shipboard EnergyEfficiency Management Plan, US VGP Nation Pollution DischargeElimination System (NPDES) Logbook, as well as vessel specificprocedures for bunkering, cargo handling, bilge and ballasting, wastedisposal and emergency response.9.9 ResponsibilitiesKey responsibilities with regard to environmental protection areoutlined in this section.• Managing Director o Manage company resources efficiently and effectively in line with environmental targets and objectives o Ensure that the aims of the company environmental protection policy are achieved o Ensure adequate resources are dedicated to environmental management• Senior Manager HSQE o Establish and implement the EMS o Serve as the Management Representative o Ensure all policies and procedures comply with statutory requirements Ensure environmental targets and objectives are appropriateControlled Revision: 01 Sep 2015HSM Part A - SPP Doc No. 009ENVIRONMENTAL MANAGEMENT Approval: WBF Page: 7 of 41

System Policies & Procedureso Annually Review the EMS, update and monitor environmental risks and amend objectives and targets where neededo Approve all EMS procedures, objectives, and targetso Evaluate and coordinate the effectiveness of the EMS to deliver continuous improvement• Department Heads o Supervise EMS procedures in section where responsible o Ensure policies and procedures are followed by subordinate staff o Monitor environmental targets and objectives o Motivate staff in EMS use and improvement• Office Administration o Ensures new office staff receives a copy of the company environmental policy o Ensures office activities are carried out as efficiently as possible o Ensures office related targets and objectives are monitored and achieved o Ensures office supplies are purchased in line with the Environmental Program o Establishes and monitors adequate recycling areas in the office o Advises vendors that preference will be given to re-cycled or environmentally friendly products and services• Purchasers o Be aware of green purchasing strategies and endeavour to standardize procurement of environmentally friendly products when economically feasibleControlled Revision: 01 Sep 2015HSM Part A - SPP Doc No. 009ENVIRONMENTAL MANAGEMENT Approval: WBF Page: 8 of 41

System Policies & Procedures• HSQE Department o Develop EMS documentation o Serve as Internal Auditors for audits of the EMS o Identify non-conformances and required corrective action o Identify environmental aspects and develop objectives, targets and program o Maintain relevant legislation o Advising interested parties of EMS requirements o Provide EMS training as needed• Shipboard Management Team o Ensures HSQE Policy statement is posted o Ensures ship activities are carried out as efficiently as possible and operations are managed in accordance with the established polices and procedures o Ensures targets and objectives are monitored and achieved onboard ship o Ensures supplies are purchased in line with the Environmental Program o Establish and coordinate recycling on board o Provide EMS training to crew• Second Engineer o Environmental Officer with primary responsibility for EMS implementation aboard shipControlled Revision: 01 Sep 2015HSM Part A - SPP Doc No. 009ENVIRONMENTAL MANAGEMENT Approval: WBF Page: 9 of 41

System Policies & Procedures• Sea Staff and Employees o Sea staff and employees will be responsible for improving the environment in daily activities and wherever possible, reporting environmental hazards and participating in environmental initiatives9.10 Training, Awareness & CompetenceThe purpose of this procedure is to provide a system whereby companypersonnel are trained in EMS procedures, instructions, andassignments.While initial training is provided during induction, the Training Managerand Shipboard Management Teams are responsible for ensuring staffsare adequately trained in EMS requirements. Familiarisation re-trainingsessions are to be conducted as needed to facilitate EMSimplementation. For shipboard and office staff, training is to placeemphasis on specific roles key personnel. Re-training will be required ifand when lack of knowledge is detected during annual internal audits.• Training Agenda o HSQE Policy & Documentation o Roles and Responsibilities of Key personnel o Operational Practices o Environmental Impacts o Potential Consequences o The current Environmental Management Program o Targets and Objectives o Garbage Management / Re-cycling o SEEMP / Office Energy efficiency o Ballast Water ManagementControlled Revision: 01 Sep 2015HSM Part A - SPP Doc No. 009ENVIRONMENTAL MANAGEMENT Approval: WBF Page: 10 of 41

System Policies & ProceduresCompetence is ensured through the training provided as well as theprofessional licenses and educational background of staff and crew.• An “Environmental Management Training Power Point Presentation”, and related videos materials will be provided to each vessel to facilitate training9.11 CommunicationsThe purpose of this procedure is to provide a system whereby internaland external communications procedures regarding the EMS arespecified• Internal Communications o Internal communications and inter-relations are specified in the HSQE Administration Manual. The procedures detailed will be used for all internal communications related to the Environmental Management System and will include use of the ShipNet Marine Information Suite for information exchange and record keeping • External communications procedures are specified in the HSQE Administration Manual. The approved procedures will be used for External communications related to the Environmental Management System.Controlled Revision: 01 Sep 2015HSM Part A - SPP Doc No. 009ENVIRONMENTAL MANAGEMENT Approval: WBF Page: 11 of 41

System Policies & Procedures• Interested Parties o Notice is served to business associates, principals, that, out of concern for the environment, SeaTeam Management Pte Ltd has established an Environmental Management System in accordance with the standards of ISO 14001. It is company policy to promote good environmental practices as a part of our daily business. This means that we will give preference to products, services, and vendors that are environmental friendly. It is our policy to promote conservation, recycling, pollution prevention, and efficiency in all that we do. We therefore request interested parties to take note of our efforts to improve the environment and understand that we will reward those practicing or promoting environmentally friendly products and services with our business.”• Subcontractors and Suppliers o In order to communicate concern for the environmental impact of goods and services used, purchase orders and quotation requests must include a statement indicating a preference for environmentally friendly products and services or ISO 14001 certified vendors.9.12 Core Environmental Management DocumentationThe core elements of the Environmental Management System are:• HSM Part A - SPP Doc No. 009• Referenced sections in the HSQE System• Applicable company Forms• Environmental Records and logs• Contingency Plans• Garbage, SEEMP, and VOC Management PlansControlled Revision: 01 Sep 2015HSM Part A - SPP Doc No. 009ENVIRONMENTAL MANAGEMENT Approval: WBF Page: 12 of 41

System Policies & Procedures9.13 Operational ControlThe company has established specific procedures to control operationsand activities associated with significant environmental aspects.Procedures that cover situations where absence could lead to deviationsfrom environmental policy, objectives and targets are specified in:• HSQE Document 009 - Environmental Management• Referenced sections in HSQE System• Operating criteria is stipulated in HSQE Operations Manuals• Manufacturer’s Instructions9.14 Goods and ServicesFor the purpose of mitigating the impact of company procured goodsand services, all suppliers and vendors are notified of the companyEnvironmental Management System and preference is given to thosegoods and services that are environmentally friendly and have a lesserimpact of identified significant aspects.9.15 Environmental EmergenciesPurpose The purpose of this document is to identify and specifyprocedures for response to accidents and emergency situations and forpreventing or mitigating environmental impacts.• Contingency PlansProcedures for response to emergency situations and mitigation of anypotential environmental impact are covered in the company'semergency and contingency plans which include: o The Shipboard Oil Pollution Emergency Plan (SOPEP) o Shipboard Marine pollution Emergency Plan (SMPEP) o The OPA 90 Vessel Response Plan o U. S. State Vessel Response Plans (California/Alaska)Controlled Revision: 01 Sep 2015HSM Part A - SPP Doc No. 009ENVIRONMENTAL MANAGEMENT Approval: WBF Page: 13 of 41

System Policies & Procedures o HSQE System Emergency Contingency Plan o Office Building Emergency Plan• Review of Emergency Procedures o It is standard procedure to review emergency and contingency plan content following significant accidents and exercises. Post incident evaluations are used to determine if revision to procedures is necessary.• Drills and Exercises o Each contingency plan has specific periodic drills and exercise requirements that are consolidated under company HSQE System schedules.9.16 Compliance Monitoring & ControlThe company has established procedures to regularly monitor andmeasure key characteristics of operations and activities that can affectthe environment.Environmental protection onboard ships and in the office functions, iscontinually monitored and measured through inspections, audits andsuperintendent oversight to ensure conformance with theenvironmental management standards contained in this manual andISO 14001.Key shipboard and office operations are regularly monitored to checkand ensure areas which may have a significant impact of theenvironment are monitored via established procedures, including:• Assessment of environmental performance versus environmental objectives and targets during management reviews• Monitoring safety during critical and essential operations aboard ship by certified officers• Ensuring periodic calibration of environmentally critical measuring instruments:Controlled Revision: 01 Sep 2015HSM Part A - SPP Doc No. 009ENVIRONMENTAL MANAGEMENT Approval: WBF Page: 14 of 41

System Policies & Procedures o Oil Discharge Monitoring Equipment – Testing / Service during dry dockings o Bilge oily water separator – Testing / Service during dry dockings o Incinerator high temperature cut out - Per makers instructions onboard o Sewage Plant – During DockingsFurther Monitoring is accomplished via Periodic Inspection. Managedships are visited 2-3 times a year by a technical superintendent ormanager. During these visits, a technical survey is conducted inaccordance with an approved condition check-list. The findings areentered in the ShipNet Database after discussion with the Master andChief Engineer, who are charged with itemized follow-up.The HSQE department conducts internal audits on the ships and eachoffice department annually. A primary focus of the internal audit is toverify compliance with safety, environmental protection, security andoperational legislation and regulations. Approved audit check- listForms are used to ensure an adequate cross section of relevantoperations are examined onboard.• All reports from superintendents, in-house and external auditors, and classification or oil company inspectors are analyzed in the ShipNet System and dealt with in accordance with statutory and commercial requirements.• When periodical inspections reveal a non-conformance, a non- conformity note, as incorporated in the ShipNet database, is issued. The responsibility for closure, root cause investigation, and corrective and preventive actions are built into the ShipNet System.• The HSQE Departments are responsible for evaluating any possible environmental impact and ensuring corrective and preventive action is properly initiated, followed up and closed. The corrective and, or preventive actions should always be appropriate to the magnitude of the problem and commensurate with the environmental impact.Controlled Revision: 01 Sep 2015HSM Part A - SPP Doc No. 009ENVIRONMENTAL MANAGEMENT Approval: WBF Page: 15 of 41

System Policies & Procedures9.17 Environmental RecordsEnvironmental records are to be legible, identifiable, and traceable.Environmental records are to be stored and maintained in a way that iseasily retrievable and protected from damage and loss. For thispurpose, environmental management and training records are primarilymaintained in the ShipNet database or otherwise assigned file and formnumbers in accordance with the established filing index.• Records specifically related to environmental management are those listed in this document, when referred too in context with or for the primary purpose of environmental management or training.• The retention time of environmental records will be three years unless connected to a claim or accident, in which case records will be retained for a period of ten years.9.18 Environmental AuditsThe company HSQE System has a periodic audit process for verificationof conformity with ISM Code Safety Management Standards, ISO 9001Quality Management, and OHSAS 18001 Safety & Heath Standardswhich will be used for concurrent auditing of the EnvironmentalManagement System to ISO 14001 Standards. Audits will be conductedby the HSQE Department personnel who have completed appropriateinternal auditor training courses.• Company audit check-lists include requirements of ISO 14001 for both the company offices and vessels under technical management. Audits will be scheduled annually and will confirm: o Environmental Management implementation o The results of previous audits have been properly addressed o The results of the audits will be formally recorded in the ShipNet Database9.19 Environmental Management Practices ReviewPeriodic review of Environmental Management processes isincorporated in and recorded in conjunction with the quarterly HSQEmanagement system review. A more comprehensive report is preparedControlled Revision: 01 Sep 2015HSM Part A - SPP Doc No. 009ENVIRONMENTAL MANAGEMENT Approval: WBF Page: 16 of 41

System Policies & Proceduresannually basis information collected through audits, inspections,Master's reviews, and feedback from staff, crew, principals, andindustry organisations.The management review will address the possible need for changes topolicy, objectives, and other elements of the environmentalmanagement system based upon changing circumstances and thecompany commitment to continual improvement.9.19.1 Monthly Environmental ReportTo facilitate structured monitoring of shipboard effluent discharges, thecompany has included a monitoring record in HSQE Form 006 - MonthlyHSQE Report for Effluent Discharges in Current Month. To harmonizemonitoring strategies, the listed effluents correspond with those in theUS NPDES VGPQuantities are to be estimated in cubic meters (m³) basis followingmethods: A. Flow rate x Duration of discharge B. Cubic volume of area x Duration of discharge C. Total volume of blasting residue recovered - Volume of blasting grit used D. Average Monthly Anode Consumption Rates x No. of anodes E. Manual Removal F. Total m² of Surface Area x Estimated thickness G. Quantity Replaced H. Average daily production x MonthOnly those effluents known to have been discharged within the currentmonth should be included in the monthly report.Controlled Revision: 01 Sep 2015HSM Part A - SPP Doc No. 009ENVIRONMENTAL MANAGEMENT Approval: WBF Page: 17 of 41

System Policies & ProceduresMeasurement GuidanceEffluent Method Effluent MethodDeck Wash down and A Bilge-water / Oil Water ARunoff Separator EffluentDischarges of Ballast A Anti-Fouling Hull CWater CoatingsAqueous Film Forming B Boiler / Economizer AFoam (AFFF) Blow down ACathodic Protection D Chain Locker EffluentControllable Pitch G Distillation or Reverse APropeller Hydraulic Fluid Osmosis BrineElevator Pit Effluent E Fire Main Systems AFreshwater Lay up A Gray Water AEffluent produced from A Refrigeration and Air HInert gas Scrubbers Condensate DischargeRudder Bearing G Seawater Cooling ALubrication Discharge Overboard DischargeSeawater Piping A Small Boat Engine Wet ABiofouling Addictive ExhaustUnderwater Ship F Stern Tube Oily GHusbandry Discharges DischargeGray water mixed with A Exhaust Gas Scrubber ASewage from Vessels Washwater DischargeControlled Revision: 01 Sep 2015HSM Part A - SPP Doc No. 009ENVIRONMENTAL MANAGEMENT Approval: WBF Page: 18 of 41

System Policies & Procedures9.20 Prevention of PollutionThe company is committed to the prevention of pollution andincorporates by reference, the measures specified in the publications:International Safety Guide for Oil Tankers & Terminals (ISGOTT),Tanker Safety Guide (Chemicals), IBC / BCH Code, Tanker Clean SeasGuide, and Prevention of Oil Spill through Pump room Sea Valves.9.20.1 Bunkering OperationsBunkering is a critical operation that must be properly plannedmonitored and controlled.• The Chief Engineer should personally supervise all bunkering operations. Close cooperation and continuous communication should be maintained with terminal or bunker-barge during the transfer operations.• The Officer of the Watch on Deck should be advised before starting bunkering operations. This is to make sure that appropriate precautions are taken by the deck department. The OOW should be kept informed of the progress and completion of the bunker operations.• Transfer procedures shall be established, be permanently posted and contain all required information.• These should be posted in a place where they can be easily seen and used by members of the crew when engaged in bunkering operations.• Each ship is provided a generic set of “Transfer Procedures” but the Chief Engineer is responsible to render content specific for use onboard. The completed bunker procedures should be approved by the signed endorsement of the Chief Engineer.• Bunker samples shall be taken at the ships manifold from an approved sampling point• If the sample point cannot be agreed upon, the vessel should not sign for any samples offered by the supplier as this may later be interpreted as an acceptance and thereby prejudice any claim.Controlled Revision: 01 Sep 2015HSM Part A - SPP Doc No. 009ENVIRONMENTAL MANAGEMENT Approval: WBF Page: 19 of 41

System Policies & Procedures9.20.2 Bulk Liquid Cargo HandlingCargo or Bunkering operations involving the transfer of oil or othersimilar products have a high potential for pollution if not properlyplanned and carried out in accordance with ISGOTT, IBC Code / BCHCode, Tanker Safety Guide (Chemicals), and/or other ship specifictransfer procedures. The company has established strict controls fortransfers as detailed in the bulk carrier or tanker operation manual9.20.3 Piping SystemsPollution incidents have often been caused by leaking cargo line,dresser couplings, valve flanges, faulty pressure gauge connections andother parts of the main cargo piping system on deck. External orinternal pipe corrosion, in particular at the bottom of the cargo pipes,may not be easily detected.9.20.4 Funnel EmissionsThere strict regulations and fines for smokestack emissions of blacksmoke. Vessels should keep a strict check on their equipment and, asmuch as possible, limit the smoke from the boilers and engines.• Daily comparison of funnel emissions to a smoke density chart is required each noon so the OOW may alert engine staff well in advance of port call if dark smoke is detected• Fuel oil consumption will be used to calculate CO2 emissions, in accordance with the Shipboard Energy Efficiency Management Plan requirements and recorded on From HSQE 039 as the Energy Efficiency Operational Index9.20.5 Marine OrganismsMany countries in the world have experienced problems with marineorganisms being transferred in the ballast water of ships. In somecountries, this has resulted in harm to local marine life affectingfisheries due to depletion of resources. In general legislation requiresthe ship to change ballast when in deep sea prior to arrival. The vesselis provided with a Ballast Water Management Plan in accordance withinternational rules which must be followed during ballast exchanges.Controlled Revision: 01 Sep 2015HSM Part A - SPP Doc No. 009ENVIRONMENTAL MANAGEMENT Approval: WBF Page: 20 of 41

System Policies & Procedures• Masters should check with port agents or charterers as well as consult all relevant port information systems to ensure all such regional regulations are complied with as part of pre-arrival planning• Every vessel is provided with a Bio-fouling Management Plan (BIOMP) for inclusion as appendix to the Ballast Water Management Plan9.20.6 Contaminated BallastContaminated ballast may easily result in a pollution incident.Operations must always be monitored and due care taken o Those ballast tanks containing ballast are to be inspected for oil contamination at least weekly while at sea. o Inspection for oil contamination is to done by a visual check of the surface of the water in the ballast tanks if possible. Those tanks situated next to cargo oil or fuel oil tanks are to be identified for extra attention. o It is recommended that ballast pipes and sea-chests be flushed through so no discoloured water will be sighted on start up of de-ballast operations. o A permanently stencilled sign to be marked at the ballast pump/s control panel (or operating station) requiring that the ballast tank/s to be discharged be inspected for oil contamination prior to commencing de-ballasting. o At start of de-ballast operations and again during final stripping of a ballast tank the area of the ocean close by the overboard valve is to be constantly monitored for signs of oil pollution. o If any oil pollution is suspected then all operations are to cease and the vessels oil pollution emergency action plan is to be activated. o Masters and officers in charge of de-ballasting operations are reminded that sampling via the tanks sounding pipes may not be a good indicator of oil contamination due to the sounding pipe being solid. If manhole covers or tank vents heads areControlled Revision: 01 Sep 2015HSM Part A - SPP Doc No. 009ENVIRONMENTAL MANAGEMENT Approval: WBF Page: 21 of 41

System Policies & Procedures removed then these must be properly re-secured after inspection. If inspection is intended by overflowing tanks to confirm no oil on top great care must be exercised to ensure that the tanks are not over pressurised. o To assist in the detection of contamination of ballast water a stock of oil finding paste is to be carried onboard.9.20.7 SewageMARPOL Annex IV regulations shall be followed. No untreated sewageshall be discharged from the vessel. The sewage treatment plant shallbe properly used and maintained.9.20.8 GarbageAll garbage shall be sorted and handled strictly in accordance withMARPOL Annex V. No garbage shall be discharged / thrown overboardin port or at sea except for food waste, cargo residues, cleaningsolvents, and other limited items as allowed by the MARPOL conventionwhich must be consulted prior to discharge of any garbage overboard.• Garbage shall always be disposed of in accordance with Annex V of MARPOL 73 / 78.• The company has produced standard Garbage Management Plans to ensure the crew comply with International regulations and company policy. The Shipboard Management Team is responsible to ensure that plan is followed. o The Garbage Management Plan and Garbage Record Book are provided in Sections A & B of HSQE Booklet 009 o Poster STP 033 is to be prominently posted so that all staff are reminded that discharge of all forms of plastics into the sea is prohibited o Poster STP 034 is also provide for prominent posting to remind the crew “ DON’T THROW GARBAGE OVERBOARD”Controlled Revision: 01 Sep 2015HSM Part A - SPP Doc No. 009ENVIRONMENTAL MANAGEMENT Approval: WBF Page: 22 of 41

System Policies & Procedures• The company Garbage Record Book is pre-printed and includes MARPOL 73/78 regulations and the prescribed method of documentation. Entries are to be made for all operations specified in the instructions and always in compliance with the MARPOL Convention.• The Chief Officer is in charge of Garbage Management and completion of the Garbage Record Book. He is responsible to: o Arrange collection of the garbage from all the receptacles placed aboard the ship as and when necessary but generally weekly, however, galley waste is to be collected daily o Ensure the garbage is properly separated o Ensure all processed and unprocessed garbage is stowed in tight, securely covered containers o Ensure that there is no build up of gas from the waste in the storage area o Ensure Joining crew are given proper instruction concerning the Garbage Management Plan and procedures onboard to ensure that non compatible waste is stowed separate from each other. o To ensure the area is kept properly cleaned and disinfected to prevent infestation by flies, insects, etc. Crew members must assist in garbage management by properly separating and placing garbage in the relevant receptacles provided onboard. o To assist with separation, extra receptacles are to be placed in the following areas where feasible:  Galley & Pantries - 3 in total – 1 marked for Plastics & Plastics mixed with non- plastics, 1 marked for Food Waste and 1 marked for Other Garbage (Paper, rags, glass, metal, bottles, crockery, etc.)  Common rooms – Bridge, Engine Control room, Cargo Control Room, Mess and TV rooms - 2 in total – 1 marked for Plastics & Plastics mixed with non-plastics and 1 marked for Other Garbage (Paper, rags, glass, metal, bottles, crockery, etc.)Controlled Revision: 01 Sep 2015HSM Part A - SPP Doc No. 009ENVIRONMENTAL MANAGEMENT Approval: WBF Page: 23 of 41

System Policies & Procedures  Sufficient receptacles to be placed at all other places (cabins, etc).  All garbage containers within the accommodation and machinery spaces are to be constructed of non- combustible material. o The Waste Management Plan, shall be displayed in the galley and pantries, on the bridge, in the engine control room, in the accommodation near the mess rooms. o Wherever possible the ships garbage is to be discharged to proper port facilities in an effort to minimise the amount of garbage being discharged into the ocean. o Plastic is to be landed for shore disposal and not burned unless the incinerator is certified for such purposes. o Regional or state variation may further restrict what cannot be burnt / disposed of shall be stored onboard and disposed of in the appropriate shore facilities in a port. Following can only be discharge to the sea when the ship is proceeding on her voyage9.20.9 Special Care ItemsCertain wastes require special care to ensure environmental hazardsare appropriately controlled.• Any asbestos that has to be discarded is to be stored, sealed in plastic and the quantity advised to the company who will arrange disposal at a hazardous waste facility. o Removal, sealing and handling must be accomplished in accordance with the Code of Safe Working Practices and under the close supervision of the 2/E as Environmental Officer• Used batteries are to be stored in plastic containers and landed for shore disposal• Batteries are explosive and must never be burnedControlled Revision: 01 Sep 2015HSM Part A - SPP Doc No. 009ENVIRONMENTAL MANAGEMENT Approval: WBF Page: 24 of 41

System Policies & Procedures• Used and contaminated cleaning chemicals are to be stored in sealed drums for disposal to port facilities or preferable, returned to the manufacturer• Chemicals must never be mixed• Chemical Drums must be well marked• Used chemicals must never be burned.• Where there are rags or material contaminated with these chemicals: o Washed dry and recycle if possible o Burn if not recyclable o Store for disposal at port facilities if unsafe to burn• Paint should be used for the purpose purchased and wastage kept minimal• Items such as used aerosol cans, toner cartridges, etc are to be stored for disposal to port facilities.• Medicines shall not be disposed of into the ocean. Expired inventory must be returned to the pharmacy supplying the replacement inventory. o Narcotic drug disposal/return must be logged in the Official Deck Logbook.• Oil Impregnated Waste o Any oil impregnated must be stored carefully and only for short periods as the waste can be self heating and self igniting. o Oil impregnated waste (e.g. rags, lining, etc) capable of being burnt in the incinerator is to be burnt. o Pyrotechnics  Ideally pyrotechnics should be returned to suppliers in exchange when new pyrotechnics are supplied.Controlled Revision: 01 Sep 2015HSM Part A - SPP Doc No. 009ENVIRONMENTAL MANAGEMENT Approval: WBF Page: 25 of 41

System Policies & Procedures  If no alterative exists, safe stowage is paramount. Expired flares should be marked “Expired Pyrotechnic – DO NOT USE” and stowed away from other safety equipment in a secure store or weapons magazine, in a waterproof container, sealed and locked. Maintain continued safe stowage and wait until subsequent ports and continue to request disposal via local agents.9.21 Pollution Prevention and ResponseRegulations do not apply to emergency discharges for securing thesafety of the ship or saving life at sea or to discharges resulting fromdamage, provided that all reasonable precautions have been taken andthat the Owner or Master has not acted intentionally or recklessly.Tank overflows is one of the more common causes of oil pollution.• Monitor loading rates in all tanks to make sure levels are the same as those expected.• Maintain constant communication with shore terminal regarding transfer rates.• Regularly monitor the ullages of the tanks being loaded, especially when tanks are approaching the topping off stage.• Where fitted, high level (95%) alarms, and overfill (98%) level alarms should be maintained in good operating condition. However, these are only a back up and should not be the only means of monitoring during topping off of tanks. o In the case of accidental discharge or the possibility of such discharge, the Master must send a report giving all relevant details by the fastest possible means to the authorities of the nearest coastal state without delay as per the approved SOPEP. o Spill containment is a critical backup when oil has spilled on deck. Many pollution incidents could have been avoided by prompt action and careful preparation of containment beforehand. o Make sure that all scuppers are tightly pluggedControlled Revision: 01 Sep 2015HSM Part A - SPP Doc No. 009ENVIRONMENTAL MANAGEMENT Approval: WBF Page: 26 of 41