HSQE System Manual - 01 Sep 2015

System Policies & Procedureso Maintain an efficient deck watch during all cargo or bunkering operations.o Establish procedures and communications so that oil transfer can be stopped immediately if there is an overflow or other emergency.o Any accumulated water should be drained regularly and scupper plugs replaced immediately after the water has been run off.o Check/repair scupper plugs during voyage before arriving at loading/discharging ports.o Keep inside of scupper drain pipes clean and free from rust or corrosion. This is to make sure that expandable scupper plugs are able to fit tightlyo Make sure that dump valves into slop tanks (if fitted) can be easily opened. Also that any of the ship's personnel in charge of operations could make a decision to open such valves in an oil spill emergency. (If these tanks are under I.G. pressure, it will be necessary to depressurize before opening the dump valves)o Dump valves from the manifold drip tray, if fitted, should be regularly checked to make sure that they can be easily opened to drain oil in an emergency.o A crew member should regularly check overboard during the cargo or bunkering operations to look for escaping oil.o Gutter bars (fishplates) should be regularly checked to make sure that they do not have holes or cracks in them.o Oil spill equipment should be readily available in quantities as required by Master-List 013 Ship Pollution Equipment including:  Portable pumps - Kept ready on standby, fully connected, earthed, and with all hoses ready for immediate operation during loading, discharging, bunkering or any other operation that requires pumping overflowing oil back to ships tanks  Absorbent pads - For the recovery of oil or other pollutant from deck and from in the waterControlled Revision: 01 Sep 2015HSM Part A - SPP Doc No. 009ENVIRONMENTAL MANAGEMENT Approval: WBF Page: 27 of 41

System Policies & Procedures  Sawdust - Can be used to absorb residual oil or other pollutant after which recovery by shovels is possible.  Non-sparking flat edged shovels - To assist with recovery of residual oil or other pollutant  Heavy duty plastic buckets - To assist with spill recovery  Brooms - To assist with recovery of residual oil or other pollutant  Non-sparking hand scoops - To assist with small spills recovery  Heavy duty plastic trash bags - For the retention of oil, oil soaked materials or any other pollutant until proper disposal can be arranged  Empty drums - For the retention of oil, oil soaked materials or any other pollutant especially any hard or solid objects until proper disposal can be arranged  Chemical Oil Spill Dispersant or Emulsifier - For breaking up oil spills Note: Must not be used over the side without prior approval or Port State Authorities.9.22 Machinery Space BilgesThe control, storage and disposal of the oil and water that accumulatein machinery space bilge’s is considered by the company to be an areawhere there is a high risk of pollution if standard procedures are notfollowed and crew are not properly instructed.• At all times the storage onboard and the disposal overboard must be in compliance with Annex 1 of MARPOL 73/78. The Chief Engineer is responsible to the Master to ensure the security of the bilge overboard valve, the proper operation of the oily water separator and the proper keeping of logs and records, including: o Daily Soundings to be recorded in the Engine Log Book o Ship Specific OWS Training Document to be produced, including:Controlled Revision: 01 Sep 2015HSM Part A - SPP Doc No. 009ENVIRONMENTAL MANAGEMENT Approval: WBF Page: 28 of 41

System Policies & Procedures • OWS alignment checklist per makers instruction • Minimum level of bilge holding tank to be established to ensure sediments and floating oil is not injected into the OWS suction line • Operational procedure for the OWS to be included in 2/E hand-over notes with a requirement for a specific discussion point during hand-over o Bilge Holding Tank inspection and cleaning to be recorded at 6 month intervals o Code I entries are to be made in the ORB anytime the OWS is turned on for inspection and testing (to identify the reason the data logger records the operation) o Bilge cross-over valves to be marked “do not open without C/E permission”• The engine room oily water separator overboard valve is to be locked o Master is to retain key to OWS overboard valve, with pre- requisite permission for use• Numbered security seals are to be fitted on all other MARPOL System connections to document system integrity. The seal numbers, date fitted, and reason for any change is to be recorded in the engine oil record book. o Master to retain numbered MARPOL Seals, with pre-requisite permission for change-out• Chief Engineers are to personally ensure that emergency bilge suctions, both anti-flooding and MARPOL valves, are not locked Storage of Machinery Space Residues• Any oil residues that can not be disposed of properly (e.g. incinerating onboard or discharge through the oily water separator) is to be retained onboard until disposal to a port reception facility can be arranged.Controlled Revision: 01 Sep 2015HSM Part A - SPP Doc No. 009ENVIRONMENTAL MANAGEMENT Approval: WBF Page: 29 of 41

System Policies & Procedures• Oil residues (sludge resulting from purifying fuel & lube oils and other residues resulting from drainage’s, leakage’s, exhausted oil) from the machinery spaces may only be stored in those tank nominated in the IOPP Certificate.• Oily bilge water may only be stored in those tanks nominated in the IOPP Certificate.• Storage of oil residues and oily bilge water in tanks other than those nominated in the IOPP certificate is illegal and the ship may be fined or detained for contravening the MARPOL 73/78 regulations. Disposal - Overboard Machinery space bilge water may be discharged overboard through the oily water separator with 15 ppm oil content alarm if the ship is not within the special areas listed in annex 1 of MARPOL 73/78• While not designated as a “Special Area” the Australian Great Barrier Reef allows no discharge of oil or effluent shoreward of a line running along the outer side of the reef.• All engine staffs are to note that bypassing the oily water separator is illegal and will not be tolerated on managed vessels.• The company does not allow disposal of bilge water overboard in the non-automatic discharge mode.• Only green label detergents are to be used when cleaning engine room bilges where wash water is discharged through the oily water separator.• Incineration o Where sludge and residual oil is to be processed (burned) onboard, this operation is to be carried in strict compliance with the incinerator Manufacturers Instructions. The instructions are to be readily available near the operating station of the incinerator and the ship crew operating the incinerator must be properly instructed and protected. o Care is to be taken to avoid dangerous situations that may result in injury to the crew or damage to the machinery (e.g. burning pressurized containers and aerosol cans, burning items that give off toxic gases).Controlled Revision: 01 Sep 2015HSM Part A - SPP Doc No. 009ENVIRONMENTAL MANAGEMENT Approval: WBF Page: 30 of 41

System Policies & Procedures o Residual clinker and ash is to be stored onboard for disposal at a convenient port facility. o No incineration is to take place while in port limits.• Engine Oil Record Book o An Oil Record Book Part 1 for machinery space bilge’s and draining and as prescribed by law shall be kept. o The oil record book must be kept readily available for inspection by Port State Control or other authorized persons for inspection at any time. o The entries into the oil record book shall be initialled by the withstander performing the operation. o The Chief Engineer is responsible to ensure that all required oil record book entries are correctly recorded and is to indicate his review of entries by signing each completed page adjacent to the Masters signature.9.23 Green PurchasingThe products and services procured by the company will beenvironmentally friendly when economically feasible.• Suppliers will be considered interested parties and as such will be notified of company EMS requirements.• When economically viable alternatives are available, preference will be given to recycled or otherwise environmentally friendly product, including: o Soaps o Cleaners o Pressurised spays o Refrigeration systems and gasesControlled Revision: 01 Sep 2015HSM Part A - SPP Doc No. 009ENVIRONMENTAL MANAGEMENT Approval: WBF Page: 31 of 41

System Policies & Procedureso Chemicalso Fire extinguishing mediao Computers and electronicso Machineryo Paper consumableso Printing Ink/Cartridgeso General stores9.24 Air PollutionThere are several gases, collectively called greenhouse gases that trapthe infrared radiation emitted from the Earth. Although these gasesmake up a small percentage of our atmosphere, they significantly affectthe amount of infrared light energy leaving the earth. Therefore, theydisrupt the heat budget and are a cause of global warming. Thecompany's environmental procedures will include steps to help mitigatethe well know and higher proportional marine generated air pollutants,including:• Nitrogen Oxides.• Sulphur Oxides• Solid Particles• Carbon Dioxide• Carbon monoxide• CFCs - Chlorofluorocarbons• Volatile Organic Compounds o Each vessel will undergo survey to obtain issuance of an International Air Pollution Prevention Certificate to confirmControlled Revision: 01 Sep 2015HSM Part A - SPP Doc No. 009ENVIRONMENTAL MANAGEMENT Approval: WBF Page: 32 of 41

System Policies & Procedures compliance with international standards for prevention of excess gases9.24.1 Minimizing Generation of Air PollutionShipboard incinerators also contribute significantly to air pollutiongenerated by vessels.• Under MARPOL Annex VI, substances prohibited from being incinerated include cargo residues from Annex I (oil), II (Chemicals) and III (packaged dangerous goods) or related contaminated packing materials: o Polychlorinated biphenyls (PCBs) as found in electrical transformer oil; o Garbage containing significant amounts of heavy metals; o Refined petroleum products containing halogen compounds. o Used paint or chemical containers o Batteries or other lead containing materials o A placard listing prohibited materials is to be posted in the incinerator room.• Fuel Oil - As SO2 emissions are directly related to the sulphur content of the fuel used, the first solution is, where possible, to use fuel with a lower Sulphur content as required for marine fuels MARPOL Annex VI and other regional regulations: Table 009-1 Restrictions on Sulphur in Marine FuelsType of Fuel / Type of Trade Area Sulphur Regulation Entry intoMachinery Content Force 4.5% m/m MARPOL Annex VI in forceany Marine Fuel worldwide 1.5% m/m EU Directive in force 2005/33Marine Diesel Oil (MDO: EU Waters 0.1% m/m EU Directive in forceDMB and DMC) 1999/32 1.5% m/m California Air in forceMarine Gas Oil (MGO: EU WatersDMX and DMA)Marine Gas Oil (MGO) within 24 nm of California ShoreControlled Revision: 01 Sep 2015HSM Part A - SPP Doc No. 009ENVIRONMENTAL MANAGEMENT Approval: WBF Page: 33 of 41

System Policies & Proceduresand Marine Diesel Oil Resource Board(MDO) California AirMain / Auxiliary Engines / within 24 nm of California Shore MGO (DMA) Resource Board in forceBoilers to be operated with MDO / MGO 1.5 % m/m only MDO (DMB) EU Directive in force 0.5 % m/m 2005/33 in forceany Marine Fuel at all EU Berths 0.1% m/m in force EU Directiveany Marine Fuel all EU Inland Waterways 0.1% m/m 2005/33 1 August 2011 (date effective 1any Marine Fuel SOx Emission Control Areas 1.0% m/m Revised MARPOL August 2012)any Marine Fuel (SECA): North Sea, Baltic Sea, Annex VI 1 January 2012 English Channel 1.0% m/m 1 August 2012 Revised MARPOL Nord American Emission Control 3.5% m/m Annex VI 1 January 2013 Area MGO (DMA) (date effective 1 1.0 % m/m MARPOL Annex VI January 2014)any Marine Fuel worldwide MDO (DMB) 1 January 2015 0.5 % m/m CARB Marine Note expectedMain / Auxiliary Engines / within 24 nm of California Shore 2-2011 (562 kB) 1 January 2020Boilers to be operated with MDO / MGO 1.0% m/m CARB Marine Note only 3-2011 (158 kB) 0.1% m/m CARB Marine Noteany Marine Fuel US Caribbean Sea Emission 4-2011 (142 kB)any Marine Fuel Control Area 0.5% m/m CARB Marine Noteany Marine Fuel (Puerto Rico, Virgin Islands) 5-2011 (28 kB) SOx Emission Control Areas IMO MEPC.62 (SECA) Summary worldwide Revised MARPOL Annex VI Revised MARPOL Annex VIo Guidance  Every bunker loading includes a sampling of the fuel oil for analysis by a certified laboratory or service, such as provided by Det Norske Veritas; the analysis will reveal the sulphur content  The technical superintendent will monitor bunker supplies for compliance  Vessels trading Special Areas must be aware of regional sulphur content restrictions and adjust operations well in advance to ensure LSFO meets the applicable standardControlled Revision: 01 Sep 2015HSM Part A - SPP Doc No. 009ENVIRONMENTAL MANAGEMENT Approval: WBF Page: 34 of 41

System Policies & Procedures  Switch over procedures, including designation of fuel tanks for LSFO stowage, must be prepared, and approved by the responsible superintendent. Change over must be logged in the engine log book, including time, date and places of starting change-over to document that only LSFO is burned upon entry to Sulphur Emission Control Areas (SECA ).  The company is responsible for ensuring that the owners and operators are made aware of LSFO requirements for planned voyages in order that fuel oil requirements may be arranged in advance of the voyage.• Smoke Stack Emissions - The type and colour of smoke from the ship's smoke stack should be monitored on a daily basis in order to ensure that engines and machinery are operated efficiently and thereby prevent excess pollutants from entering the atmosphere. To mitigate excess smoke, the following procedure is to be implemented: o When vessels noon position is taken, funnel smoke will be observed by the officer of the watch and compared to the smoke pollution comparison chart posted on the bridge. o Any constant observation, lasting longer than 30 Minutes, of level 5 or greater, will be reported to the Chief Engineer. o Noon smoke observations including the level observed and any actions taken, are to be logged in the ships log book o Smoke stack emissions in excess of level five are to be investigated by the engine department to determine if the air fuel ratio or other factors require adjustment. The engine department is to adjust machinery settings or induce procedures (such as a soot bomb) as needed to maintain an efficient burn.• Cargo Vapours o During loading of volatile or toxic cargoes, venting must take place through approved systems that expel vapour clear of the tank deck area in accordance with Chapter 16 of ISGOTT and the vessels approved Volatile Organic Compound (VOC) Plan .Controlled Revision: 01 Sep 2015HSM Part A - SPP Doc No. 009ENVIRONMENTAL MANAGEMENT Approval: WBF Page: 35 of 41

System Policies & Procedures U.S.C.G. vapour emission control system regulations shall be followed where and when applicable.• Refrigerants, Halon, and other CFCs - Ships should not emit CFCs into the atmosphere except where installed refrigerant or fire extinguishing system leakages occur. o Only approved gases are used when systems are pumped down and gases replaced. Crew members should be encouraged to discontinue use of products such as under arm deodorants and shaving foam which use CFC aerosol propellants o Form Tech 033 Ozone Depleting Substances Log is to be maintained to record the Mass KG of ozone depleting substances used onboard. The Second Engineer is responsible to ensure the record is kept up to date. o Any discharge to the atmosphere is to be reported to the company as an Air Pollution Incident and recorded in the ShipNet database9.25 Waste ReductionExcess waste not only contributes to environmental impacts, it alsogreatly affects the cost efficiency of the company. The companytherefore stands to gain double benefit from measures that minimisewaste9.25.1 Basic Measures• Recycle packaging for onboard use should always be considered (e.g. 20 litre paint drums for use as garbage bins or as buckets).• Order items in bulk rather than ordering individually packed items.• Stock reusable items instead of disposable items (e.g. cups, utensils, towels, etc.).• Cleaning used items for re-use (rags, etc.).• Waste copy paper onboard will be separated and re-used for printing of draft documents so that both sides are usedControlled Revision: 01 Sep 2015HSM Part A - SPP Doc No. 009ENVIRONMENTAL MANAGEMENT Approval: WBF Page: 36 of 41

System Policies & Procedures• Waste copy paper in the office is to be shredded and sent for recycling• Printing of non-essential e-mail will be discouraged.• Department Heads are to monitor paper consumption• Garbage should be segregated for recycling where practical and possible. Areas should be established, if adequate space if available, to allow recycling and/or proper disposal of the following items: o Scrap Aluminium (drink cans, lathe and press turnings) o Cardboard boxes o Broken or antiquated spare parts o Phone books / Nautical Publications o News Papers• Hazardous waste - for return to supplier or manufacturer (where / if possible) o Batteries o Toner Cartridges o Expired Medicine o Other hazardous items when storage becomes full, the quantity of material should be weighed or volume estimated and entered on the Garbage Log. The materials' destination, where disposed of, is to be recorded. o Recycling and waste minimisation measures are voluntary and subject to space available, availability of facilities, and trade considerations. Compliance with MARPOL requirements is compulsory in all instances.Controlled Revision: 01 Sep 2015HSM Part A - SPP Doc No. 009ENVIRONMENTAL MANAGEMENT Approval: WBF Page: 37 of 41

System Policies & Procedures9.25.2 The 4 R’sMore natural resources are needed to support the world’s growingpopulation. There is a need to conserve our natural resources to makethem last as long as possible. Conservation involves the intelligent useand care of these resources. SeaTeam is committed to help conservenatural resources by encouraging the 4 R- Approach in everyday workthroughout the organization.• Reduce o We can help to conserve by reducing our consumption of water, electricity, petrol and other fuels.• Re-use o Instead of throwing away old objects, we should try to think of ways to re-use them.• Recycle o Recycling involves subjecting something to processes that break it down in order to produce fresh materials. Glass, metal, some plastics and most kinds of paper can be recycled.• Recover o It may be possible for boilers or incineration plants to recover heat energy from burning of materials or refuse and use this heat energy for other purposes like generating steam to produce electricity. This will help to make the world’s fuel resources (which are non-renewable) to last longer!9.26 Energy ConservationEnergy Consumption Staff will be encouraged to reduce energyconsumption through practical means as detailed in the ShipboardEnergy Efficiency Management Plan (SEEMP) wherever possible. Thiswill include:• Turning off electrical appliances, computers, and lights when not if use.Controlled Revision: 01 Sep 2015HSM Part A - SPP Doc No. 009ENVIRONMENTAL MANAGEMENT Approval: WBF Page: 38 of 41

System Policies & Procedures• Procurement of new equipment that is Energy-Star, or other similar efficiency system, rated. Example: Replacement of a 1970s refrigerator with a new Energy-Star refrigerator can save over 2,000 kWh per year and several hundred dollars in electricity costs every year while reducing carbon dioxide emissions by over 2,000 pounds every year.• Increase Air Conditioner thermostats by 1-3 degrees, and no lower than 24 degrees Celsius for thermal comfort• Close curtains in day time or apply window tinting• A reduction in the number of light bulbs in use where possible. Replace the five most frequently used incandescent light bulbs with compact fluorescent bulbs.• On vessels, generators and other auxiliary machinery not necessary for normal at sea demands, should be taken off line whenever possible o Mid day reports should indicated the total number of generators being run• On vessels, pipes, fitting and duct work associated with heating and cooling systems should be well insulated and sealed To reduce the amount of waste generated.• The vessels Environmental Officer is required to: o Conduct Energy Conservation Audits on an annual basis using approved checklists and best practice guidance o Promote Energy Conservation in all instances of machinery operation9.27 Asbestos ManagementAll ships are required to maintain an inventory of Asbestos material onboard. The 2nd Engineer will be responsible for maintenance andmonitoring for Asbestos.Controlled Revision: 01 Sep 2015HSM Part A - SPP Doc No. 009ENVIRONMENTAL MANAGEMENT Approval: WBF Page: 39 of 41

System Policies & ProceduresVessels built on/after 1st July 2012 to have an Asbestos Freecertificates.Vessel built before 1st July 2012 to have an Asbestos Free Certificate orAsbestos Management Plan.The Asbestos Management plan will ensure compliance with SOLAS II-1/3-5, MSC.1/Circ.1374, & MSC.1/Circ.1045. The Vessel specific plan toinclude:• Inventory & Condition Assessment of asbestos-containing materials,• Maintenance & monitoring Programme,• Abatement actions ,• Procedures for planned repair and removal of asbestos-containing materials,• Surveillance Record of Asbestos – containing Material,• Guidance Notes for Maintenance Personnel,• Risk Assessment if ship staff is required for Urgent Repair work at sea.Vessel, Technical Supt and Purchasing officer shall ensure that anynewly installed materials on board shall not contain asbestos.Controlled Revision: 01 Sep 2015HSM Part A - SPP Doc No. 009ENVIRONMENTAL MANAGEMENT Approval: WBF Page: 40 of 41

System Policies & Procedures Documentation & Filing o SEEMP o VOC Plan (Tankers) o Form HSQE 010 HSQE Management Program o Garbage and (NPDES VGP) Logs o Smoke Comparison Chart o Oil Record Book/s o Environmental Records  ShipNet Database Distribution o All Offices o All Vessels References o ISO 14001Controlled Revision: 01 Sep 2015HSM Part A - SPP Doc No. 009ENVIRONMENTAL MANAGEMENT Approval: WBF Page: 41 of 41

System Policies & Procedures10.0 Quality Management  Purpose o SeaTeam has established a Quality Management System (QMS) in conformance with ISO 9001 as a means to implement quality policies and objectives  Application o All Offices o All Vessels  Responsibility o Office Managers o Shipboard Management Team o Individual Staff & Crew 10.1 Scope The various HSQE processes specified in this manual, incorporates the Quality Management practices outlined by the International Standards Organisation in the ISO 9001 standard. 10.2 Quality Principals The company maintains a commitment to quality in all activities and has established procedures to effectively ensure the quality of crew, vessel, equipment and cargo are maintained at highest standards. It is policy to attract, develop, motivate and retain loyal and dedicated employees who positively contribute to the company's quality objectives and HSQE Policy fulfilment. Our services shall be provided in conformance with the ISO 9001 and other stated requirements. The company will strive to maintain a reputation as a quality conscious, effective, reliable, cost consciousControlled Revision: 01 Sep 2010HSM Part A – SPP Doc No. 010QUALITY MANAGEMENT Approval: WBF Page: 1 of 6

System Policies & Proceduresand service minded company. We shall use principles of qualityassurance in evaluation, monitoring and management ofsubcontractors. We shall continuously evaluate our performance withthe aim to improve the quality of our services, our managementsystem and working procedures.The attention of the Managing Director and Senior Manager HSQE willbe drawn to all complaints and other cases where claims of poorquality are raised against the company. Such cases will beinvestigated and analyzed with the aim to improve any identified weakpoints and prevent recurrence.10.3 Main Quality ObjectivesSeaTeam's main quality objective is to deliver management servicesthat meet the requirements, needs and expectations of our clients, thepublic and other parties with interests in safe operation of vessels,protection of the environment, vessel, cargo and crew within theframework of the ISM Code, classification rules, statutory regulationsand applicable laws through efficient and cost effective execution.  In order to achieve the quality of services specified, specific measurable quality targets are established in conjunction with HSQE System Management Reviews.  Quality objectives included in the 5 year HSQE Plan which is communicated through meetings, seminars, visits on-board and by posting content on notice boards throughout the organization.  Targets and objectives listed are re-evaluated for continued relevance at least annually. Measurability of the objectives are taken into account as far as possible when these are set so that these become useful inputs in evaluation of the continuous improvement status of the Company’s HSQE Management System.10.4 Identification and Justification for ExclusionsThe Design and Development of a tangible product and Preservation ofProduct standards sections of ISO 9001 are specifically excluded dueControlled Revision: 01 Sep 2010HSM Part A – SPP Doc No. 010QUALITY MANAGEMENT Approval: WBF Page: 2 of 6

System Policies & Proceduresto the commercial nature of the organization. SeaTeam Managementis a service entity and will not be involved in tangible product designor production.10.5 Normative ReferenceDocumented procedures included in the HSQE Management Systemfor compliance with ISO 9001 are indicated in the NormativeReference included as an addendum to this manual10.6 Interaction between processesThe interaction between various processes is specified in the companyorganizational and shipboard organizational charts10.7 Customer Related Processes10.7.1 Identification of Customer RequirementsSeaTeam has established and included procedures in the HSQESystem for estimating and assessing customer requirements. Thisincludes:  Customer requirements which have to be met as part of the services provided SeaTeam  Customer differences in reporting intervals  Customer requirements with regard to the content of reports  Customer requirements with regard to the use and approval of vendors10.7.2 AgreementsAll engagements by SeaTeam for ship management and crewing aredefined in written agreements. The purpose of the agreement is toregulate the relationship between SeaTeam and the owner (customer)and to ensure that all work and services are performed with quality.Controlled Revision: 01 Sep 2010HSM Part A – SPP Doc No. 010QUALITY MANAGEMENT Approval: WBF Page: 3 of 6

System Policies & ProceduresNormally SeaTeam will propose to use its standard agreements(BIMCO). The agreements contain the following elements:  Commencement  General obligations  Special obligation  SeaTeam rights as manager  Accounting, book-keeping, reporting  Period/Termination of agreement  Remuneration  Disbursements/Payments  Responsibilities/Liability/Indemnity  Assignment  Governing laws and arbitration  NoticesThe standard agreement is to ensure SeaTeam's responsibilities andrights as manager is confined to the technical management andcrewing of the vessel, and does not include commercial operation ofthe vessel. The terms and conditions are based on generally acceptedpractice in the ship management industry. SeaTeam has adoptedBIMCO's \"Shipman\" Clause 18 as its indemnity clause as this has beenaccepted by the industry as a fair basis for Owners'/Managers'responsibilities rights and liabilities.10.7.3 ReviewAll potential management agreements will be reviewed by theManaging Director before signing to ensure that:  Obligation, requirement and responsibilities are adequately defined and documentedControlled Revision: 01 Sep 2010HSM Part A – SPP Doc No. 010QUALITY MANAGEMENT Approval: WBF Page: 4 of 6

System Policies & Procedures  Terms and conditions are as generally accepted in the ship management industryRecords of such reviews may be indicated by initialing in pen and inkon the office copy of the agreement.10.7.4 Assessment of Customer RequirementsCustomer (ship owner) requirements must be reviewed prior to entryinto any contractual obligation to provide services. SeaTeam willreview of customer requirements prior to accepting a potential client.The purpose of the review is to ascertain feasibility and compliancewith business objectives, particularly with respect to ship safety andprotection of the marine environment. The review will include andaddress client specific contracts or arrangements that may berequired, with the aim of enhancing customer satisfaction andincludes:  Supply Contracts  Service Contracts  Shipbuilding Contracts  Repair Contracts  Insurance Contracts  Crewing Contracts  Any requirement that deviates from the frequencies, schedules, guidelines and procedures contained in the HSQE System10.7.5 Customer CommunicationsSeaTeam has specific procedures regarding communications withowners and principals, which primarily restricts direct communicationsto management level for:  Customer Inquiries  Negative customer reactions to the quality of services providedControlled Revision: 01 Sep 2010HSM Part A – SPP Doc No. 010QUALITY MANAGEMENT Approval: WBF Page: 5 of 6

System Policies & Procedures10.7.6 Process ApproachThe Health, Safety, Quality and Environmental Management System(HSQE) is designed to promote a process approach for development,implementation, maintenance and improvement so that companyeffectiveness in meeting customer requirements can be progressivelyenhanced.  The process is dynamic and ever changing  The process places focus on customer satisfaction  The process produces measurable results so that improvement can be monitored  Documentation & Filing o HQSE Policy  Posted in all offices and on all vessels o Management Review  Masters Files o Normative Reference  HSM Master-List 001  Distribution o All Offices o All Vessels  References o ISO 14001 o TMSA 2Controlled Revision: 01 Sep 2010HSM Part A – SPP Doc No. 010QUALITY MANAGEMENT Approval: WBF Page: 6 of 6

HSQE System ReferencesTable 001 – Appendix 1: Correspondence between ISM Code, ISO 9001:2008 & ISO 14001:2004,OHSAS 18001:2007 and ABS Guide for Marine Health, Safety, Quality, Environmental and Energy Management ABS HSQEEn Guide, 2012 ISM Code ISO 9001: 2008 ISO 14001: OHSAS SeaTeam HSQE 2004 18001: 20071 General1.1 Scope and Application 1.3 1.2 1 1 SPP 1.21.2 Certification 13 3 SPP 1.31.3 Definitions 15 1.1 3 3 SPP 1.42 Policy2.1 General Requirements 2.2 4.1 4.1 4.1 SPP 002 1.2 5.1 5.32.2 Occupational Health, Safety, Environmental and Energy Policy 1.4 4.2 4.2 SPP 2.2 2.12.3 Quality Policy 5.3 SPP 2.33 Planning3.1 Environmental Aspects 4.3 SSA/MLC 0173.2 Energy Planning HSQE Form 0103.3 Hazard Identification, Risk Assessment, and Risk Control 4.3.1 SPP 0073.4 Legal and Other Requirements 1.2.3 4.3.2 4.3.2 SPP 2.3.15 5.2 4.5.2 4.5.2 ShipNet Alerts 7.2.13.8 Health, Safety, Environmental and Energy Objectives and Targets 1.2.2 5.4.1 4.3.3 4.3.3 HSQE Form 010 1.2.3 8.5.13.9 Quality Planning and Objectives 5.4.1 HSQE Form 010 7.1 SPP 10.3Controlled Revision: 01 Jan 2015HSM Part B – HSR Table 001NORMATIVE REFERENCE Approval: WBF Page: 1 of 4

HSQE System References ABS HSQEEn Guide, 2012 ISM Code ISO 9001: 2008 ISO 14001: OHSAS SeaTeam HSQE 2004 18001: 20073.10 Customer Focus 5.2 SPP 10.7 7.23.11 Management Programs 1.4.3 4.1 4.1 4.3.3 HSQE Form 010 3.2 5.5.1 4.3.3 11.3 5.1 4.4.13.12 Management System Documentation 1.4 4.2.1 4.4.4 4.4.4 SPP 2.3.11 3.2 4.2.2 4.4.5 4.4.5 11.34 Implementation and Operation 5.14.1 Resources, Roles, Responsibility, Accountability, and Authority 3.3 5.5.1 4.4.1 4.4.1 SPP 003 5.5.2 6.1 6.24.2 Infrastructure 6.3 SPP 1.1.14.3 Work Environment 6.44.4 Designated Person(s)/ Quality Management Representative(s)/ En- 3.3 5.5.2 4.4.1 4.4.1 SPP 3.1.6 vironmental Management Representative(s)/ Energy Management 4 Representative(s)/ OH&S Management Representative4.5 Master’s Responsibility and Authority 5.1 4.4.1 4.4.1 SPP 3.1.1 5.2 4.4.2 4.4.2 6.14.6 Shipboard Personnel 6.2 4.4.2 4.4.1 SPP 006 6.3 4.4.2 6.6 6.7Controlled Revision: 01 Jan 2015HSM Part B – HSR Table 001NORMATIVE REFERENCE Approval: WBF Page: 2 of 4

HSQE System References ABS HSQEEn Guide, 2012 ISM Code ISO 9001: 2008 ISO 14001: OHSAS SeaTeam HSQE 6.3 2004 18001: 20074.7 Competence, Training, and Awareness 6.4 6.2.1 4.4.2 CRM Part C 6.5 6.2.2 4.4.2 SSA 0044.8 Communication, Participation, and Consultation 4.4.3 SSA0024.9 Control of Documents 11 5.5.3 4.4.5 4.4.3 7.2.3 4.4.5 Induction Video 1.0 1.2.3 4.2.3 4.4.6 Induction Manual4.10 Operational Control 1.4.2 7.1 7 7.2 SPP 2.3.134.11 Purchasing 7.4 SEEMP4.12 Customer’s Property 10.1 7.5.1 SOPEP4.13 Preservation of Service 10.2 7.5.2 PCM4.14 Traceability 10.3 7.4 BOM 10.4 7.5.4 TOM 1.4.5 7.5.5 8.1 7.5.3 SSA 003 8.2 8.3 SPP 10 SPP 005 BDP 0104.15 Maintenance of the Ship and Equipment 7.6 4.4.6 4.4.6 SPP 2.3.94.16 Emergency Preparedness and Response 8.3 4.4.7 4.4.7 ECM4.17 Design 8.2.3 4.5 4.5 Excluded5 Measurement, Analysis, and Improvement 4.5.1 SPP 0055.1 Monitoring and Measurement SPP 5.1.35.2 Control of Nonconforming Materials, Equipment, or Cargo Spaces 8.3 4.5.1Controlled Revision: 01 Jan 2015HSM Part B – HSR Table 001NORMATIVE REFERENCE Approval: WBF Page: 3 of 4

HSQE System References ABS HSQEEn Guide, 2012 ISM Code ISO 9001: 2008 ISO 14001: OHSAS SeaTeam HSQE 2004 18001: 20075.3 Nonconformity, Corrective and Preventive Action 1.4 8.5.2 4.5.3 4.5.3 SPP 5.1.3 9.1 8.5.3 9.25.4 Control of Nonconforming Service 8.3 REQN Form 0075.5 Incident Investigation 4.5.3 SPP 6.115.6 Control of Records 3.1 4.5.4 4.5.4 10 4.2.4 13 12.15.7 Internal Audit 12.3 8.2.2 4.5.5 4.5.5 SPP 5.1.1 12.4 12.56 Management Review6.1 Development, Implementation and Procedures for Management 5.6.1 4.6 4.6 SPP 5.3 Review6.2 Review and Evaluation 12.2 SPP 5.3.16.3 Review Inputs 5.6.2 4.6 4.6 SPP 5.3.16.4 Review Outputs 5.6.3 4.6 4.6 OFFC 0016.5 Review Communication 12.5 5.5.3 4.6 4.6 ShipNet6.6 Corrective Actions Arising from Review 12.6 ShipNet Feedback6.7 Review Records 5.6.1 4.6 4.6 ShipNet AlertsControlled Revision: 01 Jan 2015HSM Part B – HSR Table 001NORMATIVE REFERENCE Approval: WBF Page: 4 of 4

HSQE System Manual1.0 Security PolicyThe company recognizes the need to provide a secure workingenvironment, by establishing and maintaining the required securitymeasures to prevent unlawful acts against ships, which endanger thesafety and security of persons and property on board Company ships. Itis policy of SeaTeam to ensure that managed vessels comply with theprovisions of the ISPS Code as well as Flag Authority and National/PortState Regulations regarding marine security matters.SeaTeam is committed to: • Provide security procedures and practices for ship operations to protect the security of the vessels, the ports they call at and the wider community; • Establish safeguards to reduce the risk to crew and personnel on- board Company Ships • lmprove the security skills and awareness of company personnel ashore and onboard ship; • Prepare contingency measures for emergencies relating to possible security incidents; • Developing a Ship Security Assessment and a Ship Security Plan specific to each individual ship; • Clearly identify the Company Security Officer and Ship Security Officer for each vessel and fully support the nominated Security Officers such that they can fulfill their duties in accordance with SOLAS, ISPS Code and Flag State Regulations. • Take all reasonable measures to protect the ship against acts of piracy and robbery. • Ensure protection of life is the top priority in all security activitiesControlled Revision: 01 Jun 2013HSM Part C – CSM Doc No. 001HSQE MANAGEMENT SYSTEM Approval: WBF Page: 1 of 28

HSQE System Manual1.1 Company ResponsibilitySeaTeam will ensure: • Each managed vessel has an approved Ship Security Plan (SSP) • Each managed vessel has a designated and alternate Ship Security Officer onboard • Each managed vessel has access to a Company Security Officer and alternates • Each managed vessel has has sufficient security measures in place onboard to safeguard the vessel from anticipated security threats in compliance with SOLAS Ch. XI-2 Regulations 4, 5, 7 & 8 and ISPS Code, Part A and relevant sections of Part B and the latest edition of Best Management Practices • The Company Security Officer, Master and Ship Security Officer are provided with the necessary support needed to fulfill their duties and responsibilities. • The CSO is responsible for notifying ‘points of contact’ in respective Contracting Governments, with concerns about other ships, movements or communications and will request advice or assistance. • Vessels are continuously updated with security instructions for transits the Gulf of Aden or the Somali Basin. Vessels are required to adhere to the latest best practices and updates provided, including reporting procedures and precautions to be taken on board the ship when transiting these areas. • Vessels utilize the naval convoy system when vessels are transiting the Gulf of Aden unless results of a specific risk assessment deem participation in the daily group transit to acceptable under prevailing conditions • Employees are safe when traveling. Our security officers continuously monitor and assess the situation in areas where there is potential unrest. Travel may be deferred or postponed in case of war, unrest, or other significant danger.Controlled Revision: 01 Jun 2013HSM Part C – CSM Doc No. 001HSQE MANAGEMENT SYSTEM Approval: WBF Page: 2 of 28

HSQE System Manual1.2 Entering Pirate Prone High Risk Areas1.2.1 Assessing RiskThe SSO is to carry out a ship and voyage specific risk assessment prioreach transit to develop controls to reduce risks and ensure the following istaken into account: • Crew Safety - when formulating measures to prevent illegal boarding and external access to the accommodation, ensure that crew members will not be trapped in case of fire or flooding • Freeboard - Pirates will likely try to board at the lowest point above the waterline • Speed – Full sea speed is to be maintained when transiting the High Risk Area unless otherwise adjusted for participation in a convoy • Sea State - It is more difficult for pirated to operate small craft effectively in sea state 3 and above • Review of the SSA and SSP • Crew’s Moral • Commercial implications • Availability of military protection • Engine reliability • Ballistic protection for crew on the bridge o The company provides Ballistic Window Film for Bridge Windows • Guidance will be provided by CSO with regard to the recommended route o Routing will based upon Risk Assessment, with avoidance of the High Risk Area being a fundamental objective when possibleControlled Revision: 01 Jun 2013HSM Part C – CSM Doc No. 001HSQE MANAGEMENT SYSTEM Approval: WBF Page: 3 of 28

HSQE System Manualo Typical preventive routing is illustrated in Figure 1-1Figure 1-1 Preventive Routing o Employment of Armed Guards is not considered an alternative to best management practices in regard to routing but is required by owners, when contractual requirements allow, as a supplement to other protective measuresControlled Revision: 01 Jun 2013HSM Part C – CSM Doc No. 001HSQE MANAGEMENT SYSTEM Approval: WBF Page: 4 of 28

HSQE System Manual1.2.2 Report, Monitor & Participate in Established SchemesRegister ship with MSCHOA website • Initiate and Maintain Reporting to Naval/Military forces o To the UK Maritime Trade Operations (UKMTO) whose reporting process is to incorporate:  Initial Report  Daily Reports  Final Report (upon departure from the high risk area or arrival in port). o To the Maritime Security Centre – Horn of Africa (MSCHOA) which is the planning and coordination centre for EU Naval forces (EUNAVFOR). • Keep AIS Turned on • Use Navigation lights only • Monitor and track of warnings and intelligence and adhere to recommendations • If transiting the Gulf of Aden, join naval convoy and follow the Internationally Recognized Transit Corridor (IRTC)1.2.3 Establish a Hardened / Stocked CitadelThere is a detailed criterion that any Naval/Military forces will apply beforeconsidering a boarding operation to release the crew from a Citadel whichis to be ensured in onboard planning: • 100% of the crew must be secured in the Citadel. o All persons except bridge and security personnel are to muster earlyControlled Revision: 01 Jun 2013HSM Part C – CSM Doc No. 001HSQE MANAGEMENT SYSTEM Approval: WBF Page: 5 of 28

HSQE System Manual o Exact route from bridge to Citadel is to be pre-planned and timed during drills so that bridge team can make into the citadel with sufficiently safe margin if boarded • The crew of the ship must have self contained, Independent reliable 2-way communications (sole reliance on VHF communications is not sufficient) o All vessels are to be fitted with a SevSat Communications System for emergency communications from the citadel • The pirates must be denied access to ship propulsion o Engines should be stopped and taken off bridge control1.2.4 Plan and Install Ship Protection MeasuresImplement adequate hardening measures before entering piracy proneareas. Masters are instructed to employ a structured and layereddefense to ensure the pirates cannot get access into the accommodation,engine room and bridge areas so that the strengths of the ship are usedas an effective tool in hardening the ship, Including: • Proper and efficient lookouts to get early warning of threat. • Increasing speed and maneuvering the vessels • Rigging of razor wires around the accessible parts of the ship e.g. stern, parallel body, companion ways and other vulnerable parts of the ship • Temporary extension on the width of the gunwale / fishplate by fastening empty drums as available. • Trailing mooring ropes / cargo nets which could foul approaching small boat propellers • Dunnage such as empty 200 ltr oil drums, wooden pallets to block ladders to prevent successful boarding.Controlled Revision: 01 Jun 2013HSM Part C – CSM Doc No. 001HSQE MANAGEMENT SYSTEM Approval: WBF Page: 6 of 28

HSQE System Manual• Locking down all access points into the accommodation, bridge and engine room.• Escape contingences in case of fire or flooding• Pre-positioning of critical tools such as the cutting torch• All vessels are to obtain the following chart and publication for planning and preparation prior entry to HIGH RISK areas. o BA Q6099 - Anti piracy planning chart o Best Management Practices - Latest version• Brief crew: Inform them to be vigilant and inform bridge / duty officer of anything suspicious / not normal; the attitude \"this will not happen to me\" should be strongly discouraged.• The best form of defense is to ensure that a threat of an attack is detected at an early stage - hence a proper all round look out using all available means is of vital importance.• Conduct drills, including Citadel Drills, and training sessions prior to entering a high risk area• Ensure all crew are fully aware of alarm procedures and muster stations• Master to adjust ship routines prior to entering high risk area to ensure well rested and additional crew on watch at all times• Ensure blind spots and dark areas are lit up (ensure lighting does not hamper safe navigation and lookout duties)• Ensure the deck watch work in pairs at all times as applicable.• Ensure rounds on deck are taken at irregular intervals as applicable.• Reporting from deck to bridge at regular intervals (if reporting not done it is the first indication that there is something wrong)• Be especially vigilant during watch change over times.Controlled Revision: 01 Jun 2013HSM Part C – CSM Doc No. 001HSQE MANAGEMENT SYSTEM Approval: WBF Page: 7 of 28

HSQE System Manual • Rig and pressurize fire hoses prior to entry into high risk areas • Engine room to be manned • Keep security / urgency messages ready to transmit while transiting high-risk areas • Keep important telephone numbers ready at hand especially those of UKMTO, CSO and contact details of Naval fleet in vicinity (broadcasted usually) with a spare set placed in the Citadel • Designated communications officer to handle emergency communications (this will ensure the master is able to concentrate and deal with the situation rather than being distracted by communication procedures) • Keep emergency checklists ready at hand • Test the SSAS • All incidents are to be reported to the UKMTO and the Company (actual, attempted & suspicious approach)1.2.5 Employment of Private Security Maritime Companies (PMSC)The decision for PMSC engagement will only be made after completion ofa Risk Assessment and with further discussion with the Owner, Charterer,Insurer Master, and subjective to the Flag Administration approval,including the Coastal States the Ship is calling. The decision to employan armed team will be determined by: • Owners Policy • Intelligence to review the piracy situation on the planned route to determine the risk • Whether all other alternatives and practical means of self-protection have been effectively considered, and the risk is determined to be unacceptableControlled Revision: 01 Jun 2013HSM Part C – CSM Doc No. 001HSQE MANAGEMENT SYSTEM Approval: WBF Page: 8 of 28

HSQE System Manual • The potential misuse of firearms resulting in bodily injury or death; • Liability issues; • The potential for escalation of the situation at hand; • Compliance with international and national law. • Residual Risk levels • Adequacy of onboard lifesaving appliances, medical supplies and cabin facilities and if exceeded, to obtain Flag & Classification Society dispensation prior NOTE - ANY DECISION TO EMPLOY PRIVATE ARMED GUARDS DOES NOT REPLACE BEST MANAGEMENT PRACTICE GUIDELINES, BUT SIMPLY PROVIDES AN ADDITIONAL LAYER OF PROTECTION1.2.6 Assessment of Private Marine Security Companies (PMSC)Prior to entering into an agreement with a PMSC, the company willundertake a documented due diligence assessment to validate the PMSC’sability to provide a safe, controlled, lawful and effective service. Coastalstate jurisdiction and any laws and regulations imposed by the flag Stateconcerning the use of PMSC and Privately Contracted Armed SecurityPersonnel (PCASP) must be complied with. Furthermore the use of PCASPshould not be considered as an alternative to Best Management Practices(BMP) and other protective measures. • The CSO or alternate is responsible for the selection, vetting, and assessment of PMSC to ensure the requirements of all stakeholders is considered prior to engagement onboard • To assess the capability of PMSC to carry out a proposed task, a thorough enquiry regarding the prospective PMSC should be undertaken, particularly in the absence of a robust certification scheme • The below following criteria will be used in vetting and evaluating a PMSC for serviceControlled Revision: 01 Jun 2013HSM Part C – CSM Doc No. 001HSQE MANAGEMENT SYSTEM Approval: WBF Page: 9 of 28

HSQE System Manualo Company has been vetted by owners and meets owners criteria as a preferred security vendoro Charterer acceptance of nominated PMSCo Company structure and place of registration;o company ownership;o financial position (e.g. annual accounts/bank references);o extent of insurance cover (in particular covering third-party risks);o senior management experience;o quality management indicators – e.g. ISO certification.o any information if the PMSC may have incident over its history of service to the industryo documentation in maritime (as opposed to land-based) experience;o written procedures on management including team-leading skills, chain of authority, change in command, responsibilities in life saving;o signatory to International Code of Conduct for Private Security Providerso numbers of transits safely completedo understanding of flag State, port State and coastal State requirements with respect to carriage and usage of firearms;o availability of written testimonials/references from previous clients in the maritime industry;o availability of documentary evidence that firearms are procured, stored, carried, used, transported, embarked and disembarked legally;Controlled Revision: 01 Jun 2013HSM Part C – CSM Doc No. 001HSQE MANAGEMENT SYSTEM Approval: WBF Page: 10 of 28

HSQE System Manualo understanding of the Somalia-based piracy threat including the military operations in the area, and the means to maintain current knowledge;o understanding of BMP and, in particular, ship protection measures; ando Access to competent maritime legal advice (e.g. in-house counsel/external legal advisers) on a 24/7 basis.o Proactive stance regarding preservation of lifeo PMSC should be able to provide documentary evidence which may include:  criminal background checks;  Minimum Number of Guards forming per Team  Nationality of Guards per Team  history of employment checks;  military and law enforcement background checks, where applicable;  records of medical, physical, and mental fitness of personnel (including regular drug and alcohol testing);  verifiable systems in place to ensure continued suitability for employment of their personnel;  documentary evidence of relevant experience and certification in the use and carriage of firearms to be deployed including Firearms Dealer License or End- User License, Export/Import License, Authorization Letter by Coastal States to embark/disembark Firearms;  systems for provision of security identity documentation, travel documents and visas.Controlled Revision: 01 Jun 2013HSM Part C – CSM Doc No. 001HSQE MANAGEMENT SYSTEM Approval: WBF Page: 11 of 28

HSQE System Manual  Maximum period/duration of Guard engagement onboard per Contract  Availability of In-house Blacklist Record for Guards  comprehensive and detailed records of training, both initial and refresher training, available for inspection;  that subject to any additional requirements of the flag State, PCASP have received, as a minimum, shipboard familiarization training, including communication protocols;  that personnel have been trained and qualified to documented company standards in the appropriate use of force following recognized principles/guidelines recognized by the flag State;  that personnel have been trained to operate the specific firearms and other security equipment that will be used on the ships on which they will be deployed;  that personnel have been given medical training to a recognized international standard; and  that personnel have been given appropriate training and/or briefing with specific reference to the ship type, where that ship will be operating, and the provisions of the International Ship and Port Facility Security (ISPS) Code, International Safety Management (ISM) Code and BMP.o PMSC must maintain insurance cover for themselves, their personnel and third-party liability cover (of at least USD 5 Million) and that the PMSC terms of engagement do not prejudice or potentially prejudice the ship-owner's insurance cover.  Public and employer's liability insurance cover to an appropriate level and as required by the ship-owner; and personal accident, medical expenses, hospitalization and repatriation insurance.  Firearms Insurance, if applicableControlled Revision: 01 Jun 2013HSM Part C – CSM Doc No. 001HSQE MANAGEMENT SYSTEM Approval: WBF Page: 12 of 28

HSQE System Manual o Firearms type equipped by PCASP o Minimum amount of Ammunitions per Firearm allocated for each Firearm o Types Security Equipment & Body Armor & Communication Device Team equipped o Ability to be conducted & compliance with GUARDCON or if otherwise Contract has been review & approved by Insurers, inclusion of Knock for Knock Clause in Contract o Capacity to embark Firearms abt 17N Red Sea by Patrol Craft o Patrol Craft if owned by Company o List of Main Ports of Embarkation/Disembarkation o Restriction for engagement for any Ports o Ability to be engaged for conduct Recovery of Hijacked Vessel1.2.7 Command & Control when PMSC Team is OnboardThe Master shall, at all times throughout the duration when PCASPonboard and the performance of the Security Services, have and retainultimate responsibility for the safe navigation and overall command of theVessel. Any decisions made by the Master shall be binding and undertakenby Security Personnel accordingly. • The most fundamental aspect of carrying armed civilian guards on board a merchant vessel is that under no circumstances should there be a derogation of the Master’s authority – he retains at all times full command of and responsibility for the vessel. • It is however acknowledged that the Master of a merchant vessel does not have the necessary expertise to command a team of armed guards in the use of firearms or necessarily to decide upon situations where a graduated response by the guards is appropriate.Controlled Revision: 01 Jun 2013HSM Part C – CSM Doc No. 001HSQE MANAGEMENT SYSTEM Approval: WBF Page: 13 of 28

HSQE System Manual • In the event of any actual, perceived or threatened act of piracy and/or violent robbery and/or capture/seizure by third parties, the PCASP Leader shall advise the Master or (in the Master’s absence) the Officer of the Watch that he intends to invoke the Rules for the Use of Force. • Each of the Security Personnel shall always have the sole responsibility for any decision taken in regard to targeting and weapon discharge in accordance with the Rules for the Use of Force and applicable national law. • Nothing shall be construed as a derogation of the Master’s authority under SOLAS. Accordingly, the Master retains the authority to order the Security Personnel to cease firing under all circumstances. o For the avoidance of doubt, nothing in this Clause shall compromise each of the Security Personnel’s right of self- defense in accordance with applicable national law.1.2.8 Principle Of Use Of Force( RUF) / Rule Of Engagement (ROE)The CSO when informing the Master of the engagement/embarkation ofPCASP will provide the Use of Force (RUF) or Rule Of Engagement (ROE)for Ship’s understanding. The general requirements for application of RUFare that it must be: • In accordance with Flag state law; • In accordance with regulations of any port and any Port and Coastal state laws which govern the storage and use by PCASP of their weapons and Security Equipment; • PCASP are trained and qualified to relevant documented PMSC standards in the appropriate use of force in accordance with Flag state law; • PCASP use force it is in a manner consistent with applicable law; • PCASP use force it does not exceed what is strictly necessary; • Use of force is proportionate and appropriate to the situationControlled Revision: 01 Jun 2013HSM Part C – CSM Doc No. 001HSQE MANAGEMENT SYSTEM Approval: WBF Page: 14 of 28

HSQE System Manual • Have clear and unambiguous instructions and training on when and how force may be used; and • Take all reasonable steps to avoid the use of lethal force.The RUF should reflect the following guidance on graduated andproportional use of force: • Principles o To enable the graduated approach and command and control of the situation defined above the o Force used must be necessary and proportional; o Respect for human dignity and the human rights of all persons should prevail; and o Attempts at non-violent means should be applied first. • Non-violent measures o Presence – being visible on the upper deck and bridge wings to potential attackers; o Visual – the use of flares or lasers initially aimed over a potential attackers head and then at them; o Sound – the use of long range acoustic signalling devices (LRAD) giving warnings or any other means such as loud hailers or even written banners; and o Show Intent – the use of passive measures such as hoses, releasing objects to hinder approaches of skiffs (nets, logs etc), showing PCASP weapons and raising them to indicate intent to use. • The RUF should consider “states of readiness” for the PCASP. It is suggested that there should be three states for consideration:Controlled Revision: 01 Jun 2013HSM Part C – CSM Doc No. 001HSQE MANAGEMENT SYSTEM Approval: WBF Page: 15 of 28

HSQE System Manual o Normal: Firearms are stowed and locked in the container/locker with PCASP maintaining normal watch- keeping. This condition is set when the vessel is not in high risk areas, territorial waters, or under imminent threat. Ammunition is to be stored in a separate locked container, and issued by the Team Leader with each round counted and signed for o Heightened: When vessel is in the high risk area and imminent threats are identified, on the instruction on the Team Leader, Firearms are taken out of the container/locker for immediate readiness. The weapons are loaded but made safe o Stand To: PCASP prepares stand to positions with weapons made ready with safety catches applied and under orders of the Team Leader (TL):  The TL assesses the precise level of risk and decides on action to be taken;  The TL obtains prior concurrence from the Master and issues fire control orders to the PCASP team clearly identifying the intended target/s and type of fire;  PCASP open fire as directed by the TL.  The Master retains full authority to instruct the PCASP team to cease fire at anytime, while respecting the PCASP’s right to self defense• Types of Fire: o The decision to open fire having been taken by the TL, the type of fire should be defined in the RUF taking into account the distance and behavior of the suspect craft. o First, warning shots should be: • fired into the air a safe distance above the skiff/over the pirates’ heads or, to the side of the skiff,Controlled Revision: 01 Jun 2013HSM Part C – CSM Doc No. 001HSQE MANAGEMENT SYSTEM Approval: WBF Page: 16 of 28

HSQE System Manual • fired with sole intention to display clearly the armed capability of the PCASP; • fired into the water ahead of the skiff for the same purpose; • Utilized to assess the accurate range, speed and angle of approach of the target skiff. o Second, disabling fire should be used against the skiff engine or hull in order to stop the attack but without intentionally using lethal force. o Third, deliberate direct fire should be used against the attackers when all other methods have failed.• Use of Lethal Force and Opening Fire at a Person: o Lethal force should be used only as a last resort and in accordance with the principles referred to above. The circumstances where lethal force in self-defense can be used will vary. Such circumstances may include an armed attack of an MV where the attackers are, for example: • Firing directly at the MV or persons on board in circumstances where the attackers have failed to heed warning shots or other deterrent measures (assuming there was sufficient time for such measures). • Preparing to fire or firing at the vessel whilst clearly demonstrating an intention to close with vessel in an attempt to board, by positioning very close or alongside and preparing climbing ladders for that purpose. • Aiming, launching, rocket propelled grenade or equivalent. o If a PCASP opens fire:  Aimed shots should be fired to stop the attack;Controlled Revision: 01 Jun 2013HSM Part C – CSM Doc No. 001HSQE MANAGEMENT SYSTEM Approval: WBF Page: 17 of 28

HSQE System Manual  No more rounds than are necessary should be fired in order to stop the attack; and  All precautions should be taken not to injure anyone other than the targeted person.  The time, number of shots fired, direction of each shot, and ship’s position is to be recorded in the ships logo Figure 1-2 provides a synopsis of application of graduated use of force that is printed as company poster STP 031 and kept on the bridge for ready referenceFigure 1-2 Graduated Use of ForceControlled Revision: 01 Jun 2013HSM Part C – CSM Doc No. 001HSQE MANAGEMENT SYSTEM Approval: WBF Page: 18 of 28

HSQE System Manual1.2.9 Review Prior Acceptance of PCASP TeamPrior to each engagement, the PMSC must provide their allocated PCASPTeam details to the Security Department/CSO for final screening andacceptance, which is to include: • PCASP Passport • PCASP CV • PCASP STCW Certifications • PCASP Criminal Screening Record which should not be more than 12 months old for company service but not more that 6 months old if employed onboard a vessel under charter to IMT • Medical/Health Screening Report of PCASP which should not be more than 1nos year • Firearm ListIn addition, the size, composition and equipment of the proposed PCASPteam should be carefully discussed and agreed as necessary by the ship-owner contracting with the PMSC in regard to: • Size of the PCASP team – this will be influenced by factors including: length of the estimated time of the ship transit, latest threat assessment, the agreed duties of the PCASP team (e.g. will they act as additional lookouts and assist with rigging self- protection measures?) and the size and type of ship, its speed and freeboard. The analysis should indicate the minimum number of persons that should form the security team, taking into account the need for continuity of protection in the event of injury or illness; • Ship safety certificate – the size of the PCASP team plus the crew should not exceed that specified in the ship's safety certificate. If the ship safety certificate requirements cannot be met due to added security personnel, then the flag Administration should be consulted; • Composition – it is important that there is an appropriate hierarchy, experience and skill mix within the on-board PCASP team. The team leader should be competent in ship vulnerability and riskControlled Revision: 01 Jun 2013HSM Part C – CSM Doc No. 001HSQE MANAGEMENT SYSTEM Approval: WBF Page: 19 of 28

HSQE System Manual assessments and be able to advise on ship protection measures. It is recommended that one of the PCASP personnel be qualified as the team medic (or equivalent); • Equipment requirements – this will be influenced by factors including: length of the estimated time of the ship transit, latest threat assessment, the agreed duties of the PCASP team (will they act as additional lookouts, utilize day- and night-vision equipment, assist with rigging self-protection measures?) and the size and type of ship. Enhanced medical equipment is recommended; and • Firearms – the appropriate firearms package to be employed in accordance with the applicable flag State national legislation pertaining to the type, carriage and use of firearms by PCASP, in order to provide an accurate and graduated level of deterrence, at a distance. • Training – Company specific training in anti-piracy operations onboard a merchant vessel including rules for the use of force with refresher provided at least every 2 years, and: o Detailed and documented training in the weapons system(s) which the PMSC personnel would be deployed with. o Team Leaders would have attended a documented PMSC specific Team Leader training course. o Minimum team size should be 4 persons.1.2.10 Flag State With Insurer’s Approval/No ObjectionPrior the embarkation of the PCASP, the approval or no objection inwriting by the Flag Administration with Insurer and/or other parties is tobe obtained by the CSO.1.2.11 PMSC Performance Appraisal SystemThe Master or SSO is to submit a performance evaluation report to theCSO and/or vessel superintendent for each PMSC deployment, in additionto any evaluation report that may be required by the Flag Administrationor Charterer.Controlled Revision: 01 Jun 2013HSM Part C – CSM Doc No. 001HSQE MANAGEMENT SYSTEM Approval: WBF Page: 20 of 28

HSQE System Manual • The performance evaluation report should cover following items such as: o Safety Awareness o Communications o Watch-keeping Skills o Drills & Training o Professionalism o Marine Security Awareness o Firearms Usage o Compliance with agreed procedures.1.2.12 Relationship Between PMSC And Ship’s CrewFigure 1-3 below, illustrates the communication flow & Commandstructure between PCASP & Ship’s Crews: • Guards should be signed onto the ships articles as supernumeraries • Guards are required to adhere to company PPE expectations • Guards are required to sign a company standard letter of indemnity upon boarding the vessel. • Guard use of drugs and alcohol is prohibited and may be subjected to unannounced testing if conduct or odor raises suspicion • Working language and communication will be in English • The presence of ARMED PMSC should be communicated during MSCHOA and UKMTO reports. • PMSC personnel are not permitted to use any ships communication equipment without prior permission of the MasterControlled Revision: 01 Jun 2013HSM Part C – CSM Doc No. 001HSQE MANAGEMENT SYSTEM Approval: WBF Page: 21 of 28

HSQE System Manual • Figure 1-3 Communication Flow & Command Structure Between PCASP & Ship’s Crews1.2.13 Management Of Arms & AmmunitionThe Master shall be responsible for the supervision and control of theweapons and the associated ammunition. • The weapons shall only be handled by professional and experienced trained personnel and only in accordance to the Master’s direct orders. o All applicable international and local laws, regulations and guidelines pertaining to the use and carriage of weapons are to be abided by.Controlled Revision: 01 Jun 2013HSM Part C – CSM Doc No. 001HSQE MANAGEMENT SYSTEM Approval: WBF Page: 22 of 28

HSQE System Manualo The weapons and ammunition shall be kept in a suitable secure Weapons Locker and locked up when there is no imminent threat and when the ship is in port.o The provision of a secure location for the storage of firearms at Sea, is the bridge of the ship or the locker within the Bridge to be used for this purpose, where the Firearms are locked into the firearms containers used by the guards to transport their weapons can be stored and continuously guarded at all times by the presence of PCASP.o The provision of a secure location for the storage of firearms in Port and Territorial Waters of Coastal States is the Bonded Store, where the Firearms are locked into the firearms containers used by the guards to transport their weapons can be stored with the Key placed to the safe keeping of the Master. If a Gun Safe is equipped onboard the Firearms can be stored into it but must be sealed by the Custom when entering a Port, if it is located outside the Bonded Store/Locker. The Company does not permit the permanent storage of Firearms onboard the Ship without the presence of PCASP.o The handling of Firearms is solely limited to the PCASP and at no times shall the Firearms be handled by the Crews, not even for photography. The Company considers handling of Firearms by Crews as a serious and unacceptable violation to the Company Policy and failure to comply with will result in the dismissal and under the circumstances reported to the concern Authorities.o PMSC shall determine the handing of Firearms by their PCASP under the provisions of the RUF or ROE and best combat practice, including the loading of Ammunition and removing the safety of the Firearm in the event of threat.o Prior to the embarkation of PCASP, the PMSC shall inform the CSO of the Firearm List which is allocated to the engagement and upon the embarkation of the PCASP, the Master shall request the PCASP Team Leader to tally the Firearms & Ammunition, with any other equipment provided to the engagement, while this Firearm Inventory List shall be signed by the PCASP Team Leader (Master may countersign as Witness) and reported to the PMSC & Company when theControlled Revision: 01 Jun 2013HSM Part C – CSM Doc No. 001HSQE MANAGEMENT SYSTEM Approval: WBF Page: 23 of 28

HSQE System Manual reporting shall be retained onboard by the Ship for safe keeping.o PCASP must carry proof of weapons authorization and at all times adhere to principals of safe weapons handling:  Treat every weapon as if it were loaded  Never point a weapon at anything that is not intended to shoot.  Keep the finger straight and off the trigger until ready to fire.  Keep the weapon on SAFE until ready to fire.  Move the head and the eyes with the muzzle as it moves.o Any discharge or bullets fired in the event of threat and when Master’s permission obtained for zeroing/test fire the Rifles for accuracy, shall be only made from the Bridge Wing, to the permitting circumstances with good practices and immediately reported to the Master. Security Team to as far as possible, collect the empty Shells when fired. Subsequently this shall be logged into the Deck Log Book and reported to both the CSO and PMSC. The Firearm Inventory List shall be updated accordingly by the PCASP and copy provided to the Master.o In the event the PCASP requires zeroing/test firing of the Rifles for accuracy, the Master must raise a Dangerous Work Permit HSQE Form 004 with following specific safety points checked:  No crew on deck  No other vessel within 5 NM  No internal cargo or fuel transfer ongoing  For tankers, vessel is headed into the wind and Portable gas alarm on the bridge wing indicates less than 1% LELControlled Revision: 01 Jun 2013HSM Part C – CSM Doc No. 001HSQE MANAGEMENT SYSTEM Approval: WBF Page: 24 of 28

HSQE System Manual  Vessel is not within the territorial waters of any nation • Coastal States & Authorities which are allowing Merchant Ships to call their Home Ports with Firearms on-board, are taking a very serious view in the requirement to promptly, accurately and timely declare the Firearms onboard, due to concerns over their National Security. o Violations for improper declarations on Firearms with Ammunition may result in serious consequences, detention and may lead to very serious Financial Penalty or even imprisonment. o Ship is to coordinate with CSO, PMSC, PCASP and Port Agents to promptly, accurately and timely declare the Firearms onboard with copies of Firearm Licenses, prior entry into Port. o In addition, to ensure that Custom Official to tally the amount of Firearms physically, and as far as possible request the Custom Officer to countersign in Declaration Form before allowing the Custom/Authority to Seal the Firearms Case or Gun Safe(if equipped) and Bonded Store. o In order to prevent problems, prior arriving Intermediate Ports, the Master or SSO are to again tally the Firearms & Ammunitions with the PCASP Team Leader before locking into Weapon Cases & into the Bonded Stores. o If any different, immediately resubmit Firearms Declaration to Agent & report to CSO with Security Firm.1.2.14 Duties & Safety Induction of Onboard PMSC TeamUpon the embarkation of the PCASP, the Master must hold a meeting withthe PCASP and the Crew. The following shall be explained & discussbetween the Crews & PCASP: • Introduction of the PCASP to the Crew o Safety Officer is to conduct Shipboard Safety & Security Familiarization for the PCASP using Form HSQE 025Controlled Revision: 01 Jun 2013HSM Part C – CSM Doc No. 001HSQE MANAGEMENT SYSTEM Approval: WBF Page: 25 of 28