HSQE System Manual - 01 Sep 2015

System Policies & Procedures Documentation & Filing o HSQE Master Lists  HSQE Administration Manualo DPA Contact  SOPEP Company Contactso Company Induction Manual  Personal copy provided to each employeeo SeaTeam Form OFFC 002- Office Induction Program  Personnel Fileso SeaTeam Form CREW 025 - Safety Security Tour & Familiarization Checklist  Safety Officer Files Distribution o All Offices o All Vessels References o ISM Code o STCW 95 o OCIMF TMSAControlled Revision: 01 Jun 2013HSM Part A – SPP Doc No. 004TABLE OF CONTENTS Approval: WBF Page: 7 of 8

System Policies & Procedureso HSQE Administration Manualo MLC 2006Controlled Revision: 01 Jun 2013HSM Part A – SPP Doc No. 004TABLE OF CONTENTS Approval: WBF Page: 8 of 8

System Policies & Procedures5.0 Company Verification, Evaluation and Review  Purpose o To detail company processes to verify the functionality of the HSQE System and for review and evaluation of it's content and implementation  Application o All Offices o All Vessels  Responsibility o Office Managers o Shipboard Management Team 5.1 Verification The objective of verification is to confirm that an activity, a service or a product is in accordance with specified requirements. • Verification is a line manager responsibility, and is carried out on jobs and processes indicated in the HSQE Management System Manuals. • Routines and intervals are specified in controlled Master lists, Forms, and/or in the ShipNet database. • Verification is performed by qualified personnel independent of those performing the activity. The verification process allows for an independent review and check of selected parts, records and systems. • Verification also confirms HSQE implementation throughout he organization and is documented in established processes, including an annual internal audit of each office and ship.Controlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 005TABLE OF CONTENTS Approval: WBF Page: 1 of 17

System Policies & Procedures5.1.1 Periodic Audits & InspectionsThe HSQE Department is responsible to ensure verification audits areplanned & implemented to comply with applicable certificationstandards. Internal auditors are to have been trained at an IRCAapproved/accredited training institution, and will periodically chargedundertake audits to verify conformance with HSQE, statutoryrequirements and industry guidelines. Audits are conducted throughinterviews, spot checks of practices and checking of records and identifythe existence of any non-conformance or deficiency so that correctiveactions can be developed and instituted to prevent recurrence.• The ShipNet database is used to report, record, and monitor audit findings• During vessel audits, applicable items listed in the OCIMF Vessel Inspection Questionnaire are to be checked and verified, and results recorded in the audit report in ShipNet o Tanker Management Teams are required to complete the VIQ checklist prior to the audit, for subsequent verification by the auditor• Additional Navigational Audits are to be completed by Masters, at least once per contract. Marine Superintendents will likewise complete navigational audits, periodically when sailing on-board o The company arranges independent 3rd party auditors for random navigational reviews across the fleet, at a target interval of every 24 months, subject to safe port, short voyage, and no conflict with other inspections (e.g. SIRE).• At least twice yearly, Technical Superintendents &/or Managers are to review and audit progress of action plans for correction of maintenance and defects during ship visits. Items reports are recorded under “Technical Inspections” in the ShipNet Database• Audit checklists prepared by the company covering HSQE requirements and industry standards will be used to guide audits. Checklists are provided as a reference for the auditor and not considered part of the audit record.Controlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 005TABLE OF CONTENTS Approval: WBF Page: 2 of 17

System Policies & Procedures • Audit reports are required to be submitted via ShipNet within 5 working days of completion • During the annual internal HSQE Audits, a copy of the previous annual audit is to be used to verify close-out of the audit trail. The following audit minimum criteria is to be verified: o Knowledge and compliance with company policy o Validity of controlled HSQE documentation o Validity of statutory certificates o HSQE procedural compliance o Compliance with drill and exercise schedules o Close out of findings from previous audit and incident reports o Vessel specific systems where possible o OCIMF VIQ Compliance o Progress of corrective action plans for maintenance and defects5.1.2 Audit Planning The HSQE department will monitor and arrange annual audits of all offices and vessels. HSQE Department will provide notification to the department or vessel being audited with details of audit to be conducted. Audits may not be undertaken by any person with direct responsibility for the area being audited • Internal Audits o Due on 12 month Interval. o Planned due dates are based upon the previous audit o Non-conformities may be captured in the HSQE Module as line items included in an audit findings but identified as an NCControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 005TABLE OF CONTENTS Approval: WBF Page: 3 of 17

System Policies & Procedures o Observations may be recorded for concerns identified that are not clear non-conformances, or for items if left unattended may become a non-conformance in the future o In all cases, the audited vessel or department must be informed of the findings on completion of an audit; written acknowledgment is confirmed through replication of the audit report via ShipNet, normally within 5 working days. The default due date for all findings, NCs & Observations is 90 days. o The scope of internal audits is to be indicated in ShipNet and should include HSQE, ISM, ISO 9K&14K, OHSAS 18K, MLC, & ISPS o Auditors are responsible to ensure required corrective and preventive actions are understood, and properly entered in ShipNet. o Auditors are responsible to monitor each audit performed and ensure close-out is effected within due dates. o Auditors are responsible to use the company audit checklist as a guide, and record all findings in ShipNet, with coding as per the audit checklist or statutory element o Security audits are confidential; only the Company Security Officer (CSO), Ship Security Officer (SSO) or authorized Recognized Organization (RO) may have access without prior consent of the Company Security Officer (CSO) or Maritime Authority• External Audits o Certification audits will be carried out in accordance with requirements of the ISM Code, ISPS Code, ISO 9001, ISO 14001, and OHSAS 18001 by a Recognized Organization acting on behalf of the flag and accredited certification entity o Audits will be requested to be conducted concurrently wherever possibleControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 005TABLE OF CONTENTS Approval: WBF Page: 4 of 17

System Policies & Procedures o Commercial Audits are conducted by major oil companies to measure conformity with the Tanker Managers Self Assessment ratings lodged the OCIMF, and on board compliance with the requirements listed in the OCIMF VIQ o The HSQE Department is responsible for requesting and scheduling external audits• In general audits should include: o Opening meetings to introduce the audit team, summarize conduct of the audit, confirm all agreed persons/records are available, confirm time & date for the closing meeting and clarify any relevant details to the audit o A review of the “audit trail” from previous audit findings to verify close-out o That no condition exists that would jeopardize the safety and watertight integrity of the ship o A closing meeting prior to preparing the audit report & to present the results, observations, findings & where required any immediate corrective actions to be taken. o The closing meeting is also the time to diplomatically resolve any disagreement in findings. Items that are not agreed, should be indicated by the Master or Manager when endorsing the audit report or inspection record• Vendor AuditsVendor audits are conducted annually on significant suppliers ofproducts and services that do not have ISO 9001 QualityCertification. Audits may be conducted via completion of selfassessment questionnaires as may be deemed necessary toconserve economic resources.• ShipNet DatabaseControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 005TABLE OF CONTENTS Approval: WBF Page: 5 of 17

System Policies & Procedureso Audits, Incidents & Near Miss Reports, inspections, feedback, and management of change, complaints, suggestions, directives and alerts (and other similar reports as indicated in the provided menus) are normally populated in the ShipNet Database where content is replicated between ship and shore.o All data fields to be completed by the originator. If not applicable, the field should be marked N/A. If a document is attached, this should be indicated and the field. No data field should be left blank.o The monitoring of follow-up, completion and close-out is the responsibility of the department head and ultimately the Master, who should concur with content prior to forwarding the report to the office.o The Technical Superintendent is responsible to ensure all pending reports are closed within the due date.o The PMS Superintendent responsible for monitoring overdue items and alerting the DPA if any item is open more than 90 days.o Complete Coding of each ShipNet report is essential for effective analysis of data and is the responsibility of the originator.o Any extension of over-due items must be approved by the Superintendent (for PMS / Technical Reports) or the DPA (for HSQE items), as appropriate and reason stated in the reporto Technical superintendent inspection reports are considered \"Work-Lists\", which when entered in ShipNet do not require identification of root causes or recurrence prevention (the fields may be marked N/A). Monitoring completion of assigned work-list items is the responsibility of the Technical Superintendent, who may close out items basis input received, at his discretiono Non-conformities may be captured in the HSQE Module of ShipNet separately, or as line items included in an audit.Controlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 005TABLE OF CONTENTS Approval: WBF Page: 6 of 17

System Policies & Procedures5.1.3 Identification and Control of Faults & Non-Conformance A non-conformity report [NCR] may be issued when a non- fulfillment of a requirement of the HSQE System or statutory regulation is identified. NCRs may result from audits, inspections, or as a part of day to day business where needed to effect corrective action. The ShipNet computerized Non-Conformity Reporting System will be the primary tool with which NCRs are issued, monitored and recorded. • Permanent corrective actions are normally required within 90 days of the NCR date of issue; however this may be substantially shorter where prompt rectification is required. o The Designated Person Ashore (DPA) at times may however extend the due date where extenuating circumstances exist. o Status and completion is monitored and verified by the HSQE Department via ShipNet. On review of an NCR the HSQE Department may amend an NCR to correct mistakes. • The process of identification, controlling and reporting faults and NCRs is depicted in Figure 5-1 • Significant safety deficiencies that cannot be rectified by vessel staff are immediately reported to the Superintendent & DPA • Closure of audit findings are verified during the subsequent HSQE Internal Audit 5.1.4 Suggestions, Complaints & Grievance Suggestions, complaints, and grievances may be submitted to the company in ShipNet. The assigned technical superintendent has primary responsibility for monitoring problems, and ensuring actions are taken, monitoring completion and recording close-out. • ShipNet entries are to be coded according to the importance and satisfaction levels associated with the issue raised negative trends may be monitored; Anonymous Reports may be submitted to the DPA by via private email: [email protected] Revision: 01 Sep 2015HSM Part A – SPP Doc No. 005TABLE OF CONTENTS Approval: WBF Page: 7 of 17

System Policies & ProceduresFigure 5-1 Identification & Control of Faults & Non-ConformitiesIS IT CRITICAL EQUIPMENT OR IS THE CONDITIONEQUIPMENT OR PROCEDURAL FAILURE IS A MAJOR NC, AFFECTING MAJOR NC OCCURS SEAWORTHINESS, SUBMIT NON- OR PRESENT CONFORMANCE SIGNIFICANT FIRE, REPORT FLOODING, LSA OR IS PSC ENTER SPECIFIC FFA, AUXILLIARYNOTIFICATION REFERENCE TO POWER, OR VOLUME, CHAPTER, MARPOL REQUIRED? AND PARAGRAPH EQUIPMENT OF APPLICABLE IS THERE A YES REQUIREMENT LIMITATIONS OR FAILURE TO HAZARDS? COMPLY WITH A FOR MINOR NC DUE DATE NO CONDUCT RISK SPECIFIC MORE THAN 90 ASSESSMENT ANDREQUIREMENT OF EFFECT INTERIMTHE HSQE SYSTEM TAKE CORRECTIVE REPAIRS OR APPLY ACTION AND OR STATUTORY CLOSE NCR ADDITIONAL REQUIREMENT? REPORT HAZARD CONTROLSOTHER DEFECT, INITIATE CLASSDEFICIENCY, OR NOTIFICATION VIA OBSERVATION SUPERINTENDENTADD TO FORWARD EXTENSION DECLARE MAINTENANCE POSSIBLE VIA DPA CONDITION TO PSC PLAN OR ENTER UNDER AUTHORITIES ITEM IN SHIPNET EXTENUATING PRIOR ARRIVAL SYSTEM AS A CIRCUMSTANCES NEXT PORT “OR” CORRECT PRIOR TO BREAKDOWN OR HSQE EVENT SAILINGControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 005TABLE OF CONTENTS Approval: WBF Page: 8 of 17

System Policies & Procedures SeaTeam operates under an International Safety Management (ISM Code) Document of Compliance (DOC) valid for all the types of ships and flags managed by the company. • The DOC is issued by the relevant flag administration to certify the company's HSQE SYSTEM is approved and has fulfilled the safety management requirements of the ISM Code. • Every ship operated is issued a Safety Management Certificate (SMC) in verification that required safety management procedures have been implemented on-board in accordance with ISM Code requirements. • The company's HSQE System has been developed to be compliant with ISO 9001 Quality Management, ISO 14001 Environmental Management, and OHSAS 18001 Safety & Heath Standards. Certification is accomplished via external audit process by an accredited certification society. • The company operates it's vessels in compliance with the International Ship & Port Facility Security Code (ISPS Code). Every ship is issued an International Ship Security Certificate (ISSC) to certify that all required security measures have been effectively implemented on-board in accordance with the ISPS Code requirements5.2 Evaluation 5.2.1 Incidents, Accidents and Hazardous Occurrences The company utilizes the ShipNet database to analyze and evaluate incidents and hazardous (\"near miss\") occurrences for causation and trend modeling. The company investigation report form is replicated via ShipNet and coded in accordance with the approved evaluation hierarchy. o The Master is responsible for the accuracy of required entities and gathering associated evidence and documentation o The Safety Officer is to assist the Master in on board investigation and initial report production.Controlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 005TABLE OF CONTENTS Approval: WBF Page: 9 of 17

System Policies & Procedureso The HSQE Department is responsible for evaluating, accepting or correcting and analyzing investigation reportso Lessons learned are to be shared throughout the organization and industry partners as appropriate5.2.2 Corrective & Preventive Action• Corrective and Recurrence Preventive measures are evaluated for effectiveness and for implementation: o Immediately for emergency or safety related items; if immediate rectification cannot be effected, a risk assessment is to be completed to establish equivalent temporary controls o Within the stipulated closure date, unless specifically extended by the DPA due to mitigating circumstances o Reviewed as a standard agenda item Management Team Meetings o Distributed throughout the organization in conjunction with non-conformity report (NCR) summaries on a quarterly basis o Significant events are to be flashed to the fleet within 48 hours of occurrence to highlight preliminary findings and preclude speculation5.2.3 Analysis of Incidents, Accidents, and Audits/Non-ConformitiesThe HSQE Department will lead the process of analysis of Incidents,Accidents, and Audits/Non-Conformance's to identify any neededsystem improvements to prevent recurrence. The object ofanalysis will be to determine:• Root Causes (HSQE System Failures), Basic Causes (contributing factors) and Immediate Causes (Exact Failures) as appropriate and applicable to specific reports• Methods to prevent recurrenceControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 005TABLE OF CONTENTS Approval: WBF Page: 10 of 17

System Policies & Procedures • Need for amendment or improvement to the HSQE system • Adequacy of Immediate, short term, and long term corrective and preventative actions • Trends that may indicate systemic breakdowns o The ShipNet Database to be the primary tool utilized for analysis of reports though manual analysis is also acceptable5.3 ReviewEvery quarter, top management critically reviews the company's Health,Safety, Quality and Environmental Management System with respect tofulfillment of ISM Code, ISPS Code, TMSA, ISO 9001, ISO 14001 andOHSAS 18001 stipulations. 5.3.1 Management Review The review focuses on monitoring achievement of objectives and targets, customer satisfaction, occupational health, safety and environmental protection. The management will consider in conjunction with the review: • Suggestions, feedback, comments, and complaints • The content of Masters' annual System Reviews • Summary of Incidents and Non-Conformities • Vessel Maintenance and PMS System status • Achievement of improvement objectives and targets • Health, Safety, Quality, Security and Environmental aspects • The status of pending action items • Status of measures decided in the previous Management review • Status of HSQE documentation and policiesControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 005TABLE OF CONTENTS Approval: WBF Page: 11 of 17

System Policies & Procedures• Pending legal issues, statutory rules and regulations• Performance against Industry bench-marks• Impact of Changes approved through Management of Change processes to confirm objectives have been met• Crew selection and recruitment processes in regard to compliance with company policy and procedures and future needs• Review Master-List 024 Critical Equipment Risk Assessment for continued relevance and applicability (annually)A consolidated Management Review Report will be prepared by theHSQE Department for the Managing Directors approval. Onceaccepted, the Management Review Report will be transmitted to eachoffice and ship. A more comprehensive report, including acompilation of the important points input via Master's annual systemreviews, company policies, and a crewing systems review, will beprepared during the first quarter of each new-year. Any prevailingissues or and other significant points will be identified and addressedat that time. The 5 year HSQE Plan will be examined to monitorprogress towards listed objectives and targets. Weak points will beidentified, and targets, objectives, and strategies amended whereappropriate.5.3.2 Master’s Annual System ReviewMasters are required to review and report on the effectiveness of theHSQE System and make suggestions for improvement whereappropriate. The content of the Masters reviews will be used toimprove the content of the HSQE System where appropriate. • Master's System Reviews are due at least once per year, with the initial review due prior to the vessels initial SMC audit. o Masters may review hand-over notes for the previous year and include any issues or suggestions highlighted for improvementControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 005TABLE OF CONTENTS Approval: WBF Page: 12 of 17

System Policies & Procedureso Masters reviews are to be entered in the ShipNet database in the Feedback Module.  Each comment must have a separate finding created and codedo Masters Review Form 001 may be used by vessels without ShipNet installedo Annually, the Masters review should cover:  HSQE System Documentation  Documentation other the HSQE System  If Officers are conversant with the HSQE System?  If crew is adequately aware of the HSQE System?  Status of vessel’s trading certificates  Any recommendations by classification society, flag state or port states, which are not yet settled?  If non-conformities, accidents, serious incidents, hazardous occurrences, near misses and deficiencies been reported to the company and within targets?  If any corrective actions resulting from audits or deficiency reports pending?  Status of PMDS / maintenance plan?  Status of training plan HSQE 021?  Status of onboard familiarization  If there are any suggestions for improvement of the HSQE System?  Focal points to improve the implementation of the HSQE System?Controlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 005TABLE OF CONTENTS Approval: WBF Page: 13 of 17

System Policies & Procedures  If the Environmental Management System is implemented?  If the crew properly qualified and trained?  General condition of the vessel?  Implementation of the HSQE System and effectiveness of the procedures therein?5.3.3 Legal ReviewManagement will continuously review and identify legislation andstatutory rules that apply to its operations. To this end, thecompany will maintain an up to date library of relevant rules andregulation in its offices and on-board each ship.• Company managers are to review legal issues in conjunction with the management review to ensure company operations comply with the latest rules and to highlight any change to existing regulations,5.3.4 Performance Measurement, Analysis & ImprovementThe company's performance is evaluated through bench-markingcertain key performance indicators to industry averages andcompany established targets. Company performance evaluation willbe conducted concurrently and within the management reviewprocess. The company's ability to meet established goals andtargets is the primary indicator upon which overall performance willbe judged.5.3.5 BenchmarkingThe following sources will be used as performance comparativebenchmarks across the fleet and against the oil/marine industry as awhole: • INTERTANKO TMSA Industry AverageControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 005TABLE OF CONTENTS Approval: WBF Page: 14 of 17

System Policies & Procedures • Intertanko LTIF/TRCF & Crew Retention Averages • Informal Tanker Safety Forum Statistics5.3.6 Key Performance IndicatorsKey Performance Indicators (KPIs) are comprised of certain industrystandard performance statistics generally used by ship managementcompanies to benchmark performance so that management maytarget remedial actions as necessary. Generally, the followingcategories are monitored during quarterly management reviews: • Incident and accident ratios • Lost Time Injury Frequency • Near Miss Reporting • Staff Retention • Medical Repatriations • Overdue Planned Maintenance • Vetting Inspections • Negative Media • Port State Control Inspections/detentions • Unscheduled technical off-hire • Budget performanceKey Performance Indicators (KPIs) are tabulated quarterly anddistributed to senior management in conjunction with themanagement review report. Amendment to company operationalstrategies may be made based upon significant trends identified asKPIs are charted against previous periods.Controlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 005TABLE OF CONTENTS Approval: WBF Page: 15 of 17

System Policies & Procedures 5.3.7 Continuous Improvement Improvement is achieved by comparing statistics and amending objectives, targets and strategies as needed to achieve improved results in the areas specified in the company 5 year HSQE Improvement Plan. The senior management team will also actively monitor, review and act upon significant suggestions, trends, improvement opportunities, complaints, and other relevant feedback • The 5 Year HSQE Improvement Plan will address HSQE Aspects the senior management has determined to be significant as well as other identified areas where progress is achievable 5.3.8 Environmental Aspects SeaTeam evaluates Environmental Aspects based upon their Significance where activities ashore and on board company vessels are considered. Environmental aspects are evaluated by senior management annually in conjunction with the management review to determine any potential or actual significant impact on the environment and continued validity of company objectives and targets for the current year. • Aspects to be included in the 5 year HSQE Improvement Plan are those which the Company can be reasonably expected to influence within the scope of the HSQE Management processes. Documentation & Filing o Quarterly Management Review & Associated Documentation  HSQE File  Notice Board for current quarter o Certifications  HSQE Files  Prominently Posted or electronicControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 005TABLE OF CONTENTS Approval: WBF Page: 16 of 17

System Policies & Procedures Distribution o All Offices o All Vessels References o ISM Code o ISO 9001 o OCIMF TMSA o ISO 14001 o OHSAS 18001 o MLC 2006Controlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 005TABLE OF CONTENTS Approval: WBF Page: 17 of 17

System Policies & Procedures6.0 Safety Management  Purpose o To detail standard operating procedures to ensure safety concerns are correctly and properly managed throughout the organization  Application o All Offices o All Vessels  Responsibility o Shore Management Team o Shipboard Management Team o Individual Staff & Crew6.1 Promotion of HSE The company recognizes that safety and health is a prime responsibility of senior management. Department heads and Masters have responsibility to make safety and health top priority. Managers, in conjunction with the shipboard management team, must encourage development of a proactive safety culture. It is the responsibility of each employee to support safety and health objectives, policies and procedures though responsible actions and thereby prevent injury to themselves, their colleagues, property and the environment. • The company provides a variety of methods, including training, best practice sharing and awards, to encourage and promote HSE. Staff are expected to participate to the maximum benefit of the team. • Suggestions are encouraged and may be submitted via the ShipNet Marine Information System installed onboardControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 1 of 60

System Policies & Procedures6.1.1 Hazard CommunicationThe goal of hazard communication is to be sure employees know whathazards exist in the shipboard environment and what they must do toprotect themselves.• Hazardous Materials o Whenever dangerous cargo is carried, printed Material Safety Data Sheets (MSDS) Sheets must be prominently posted on a central notice board that that all persons on board may easily refer too the standard safety guidance provided. o Manufacturers MSDS Sheets should be available for all bunkers, paints, solvents, and chemical stores. A supplier file should be located in each location where the materials are used. MSDS pages should be protected by plastic lamination or other suitable means to prevent page degradation and contamination from handling. MSDS Sheets should normally be provided by suppliers, but if not available, an inventory of most common MSDS Sheets is provided to each ship on the HSQE System CD ROM. Should a needed MSDS Sheet not be included, the HSQE department should be contacted to assist. o Asbestos, if identified onboard, should be handled in accordance with procedures in the Code of Safe Working Practices 27.4, and made known by signage in areas where found. Company DPA should be notified if any leakage observed, and the Second Engineer assume responsibility to ensure any damaged areas are promptly sealed• Physical Hazards o Hazards should be communicated by prominent signage, markings and notices. Common hazards to be marked including:  Gangway Notice: Warning – no smoking, no open lights, no visitors; use of mobile telephones or cameras is prohibited; Dangerous Chemicals, if applicable.  No Smoking Signs at the Battery Room, Paint Locker, Oxygen & Acetylene StoreControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 2 of 60

System Policies & Procedures  Tiger striping of pinch points, trip hazards, slip hazards, and low overhead obstructions  High voltage warnings at main electrical panels and other high voltage areas  Posted warnings when dangerous work is being carried out (e.g. men aloft, divers down, electrical isolation, lock-out tag-out notice)  Posted signage indicating required personal protective gear work-shops, pump-rooms, engine spaces  Mark Safety Helmets with issue date so 3 year service life can be monitored• Biological Hazards o Biological hazards, such as Malaria or Swine Flu, are communicated to the crew by transmission of safety alerts as may be needed to control contamination in a given area of trade. o Kitchen and garbage areas bacterial hazards are communicated by signage, cooking and storage instructions, and/or training of ships crew regarding infection prevention o The ship's hospital is to have a sealed waste bin designated for disposal of biological waste generated in the course of rendering medical treatment. The designated bin is to be clearly marked for Biological Waste.• Safety Information Board o Every vessel should establish a vessel specific safety information board where important safety information may be displayed for visitors and crew. A safety information board should include:  MSDS Sheets for dangerous cargo if carried  On board Smoking Regulations  A description of Fire & General AlarmsControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 3 of 60

System Policies & Procedures  Identification of emergency muster points for visitors  An indication of current Security Level• Departmental Morning Meetings o A brief morning meeting is required of each department to review work to be done that day, communicate hazards to be encountered, and methods required to adequately control the hazards. The morning meeting is the time to, if required, conduct or review an applicable Risk Assessment and/or Job Safety Analysis, if dangerous work is scheduled to ensure all personnel are aware of hazards and the controls required o Ideally the morning meeting should include all hands so that deck and engine personnel are jointly aware of the maintenance activities carried out by the other departments. When not possible, the Chief Officer and Chief Engineer are to review activities jointly and advise their staff of any potential hazards to be avoided. o No minutes of morning meetings are required.6.1.2 Department Head SupervisionThe Department head is responsible to ensure each job is adequatelysupervised to confirm safe working practices are followed. Wheneverwork requires Lock Out Tag Out of systems, the department head ispersonally responsible to confirm that controls are properlyestablished prior to commencement of work.• The Department head is responsible to ensure each individual worker has access to and uses required PPE.• The Department head is responsible to call stop unsafe acts, and call for Time Out and Step Back 5X5 until conditions or practices are corrected.• The Department Head is responsible to ensure that all equipment to be used during the day is operated as per design and within safe operation limits and loads.Controlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 4 of 60

System Policies & Procedures6.2 Monitoring Safety Onboard Safety on board is monitored by the Shipboard Management Team, the nominated Safety Committee and the assigned Safety Officer. Office monitoring is the responsibility of the HSQE Department who will arrange regular on-board visits to audit safety and training standards and communicate with the ship on safety matters. HSQE monitoring will include confirmation, concurrence, and/or corrective action and close-out of HSQE issues, including: • Hot Work • Any Risk categorized as “Intolerable” in a Risk Assessment • Monthly Safety Reports • Audits and Inspections • Incidents • The Technical Superintendent is responsible monitor recommendations made during shipboard visits and highlight any need for improvement to senior management, track progress, and close reports when complete • Formal safety meetings are to be conducted by visiting managers and superintendents as a standard conclusion to each visit • All onboard inspections are to be recorded in the ShipNet database for monitoring and tracking 6.2.1 Safety Committee The vessel shall have an established Safety Committee that will meet on a monthly basis to review, discuss, report, analyze and evaluate hazards. The Safety Committee is to be made up of: • Master – As Chairman • Chief Mate (Safety Officer) • 3rd MateControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 5 of 60

System Policies & Procedures• 2nd Engineer• Bosun• Chief Cook• At least one senior rating from deck department• At least one senior rating from engine department• Any other members needed to comply with flag requirements o The committee will meet monthly to discuss and record actions related to:  Any reported incidents or unsafe conditions that have occurred, the results of investigations and recurrence prevention  On board procedures regarding health, safety & environmental matters that require attention  Accident, incident & pollution prevention procedures  Safe working practices  Correct use of safety and personnel protective equipment  Safety suggestions or concerns from crew  Any new safety related information received from the company  Safety training exercises held during the month and plans for the upcoming month  Status of safety equipment maintenance and records are updatedA meeting of safety committee should be held as soon a practicableafter any lost time accident or serious incident. The Minutes ofmonthly Safety Committee Meetings are to be recorded. An electroniccopy of each monthly report is to be forwarded to the HSQEDepartmentControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 6 of 60

System Policies & Procedures• The Master is responsible for: o Calling the meeting to order o Ensuring all members attend o Designating one officer to act as meeting secretary o Ensuring minutes are recorded o Transmission of minutes to the HSQE Department with cc to the assigned Technical Superintendent6.2.2 Safety OfficerThe Chief Officer is assigned the collateral duty of Ship Safety Officer,although some responsibilities such as equipment maintenance, isnormally delegated to the Third Officer. The Safety Officersresponsibilities include:• Inspection, testing, maintenance and readiness of the safety, lifesaving, emergency and fire fighting equipment, including oversight of personnel assigned to carry out such maintenance• Ensuring all crew and any riding crew, supernumeraries, etc. receive the following instructions: o Their duties in emergency situations o The vessels alarms signals o The location of muster points o The use of equipment required during an emergency (e.g. life jackets, fire extinguishers, life boats, life rafts, etc.) o Reporting hazards immediately for the attention of the Master, senior onboard management and the company o Assisting with the planning and coordination of drills, musters, training etc.Controlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 7 of 60

System Policies & Procedures• Duties o The Safety Officer has a duty to stop any work which he reasonably believes may cause a serious accident, and immediately to inform the master who is responsible for deciding when work can safely be resumed. o The safety officer’s role should be a positive one, seeking to initiate or develop safety measures before an incident occurs rather than afterwards. o He should be on the lookout for any potential hazards and means of preventing incidents. o Try to develop and sustain a high level of safety consciousness among the crew so that individuals work and react instinctively in a safe manner and have full regard to the safety not only of themselves but also of others. o The objective is to become the ship’s adviser on safety to whom the master, officers and all personnel will naturally turn for advice or help on safe working procedures. As such the Safety Officer, must always lead by setting a good example! o Where unsafe practice is observed, approach the individual or responsible officer concerned to suggest improvements in his method of working or use the safety committee to discuss examples of dangerous or unsafe practices in a particular area. o Where possible, ensure new staffs are assigned to work with a crew member who is himself adequately familiar with safe working practices and is safety conscious. o Greet experienced seamen joining the ship for the first time to stress the importance of a high level of safety consciousness and of setting a good example to less experienced personnel.• The safety officer should also promote safety on board, subject to the agreement of the master, by o Arranging the distribution of booklets, leaflets and other advisory material on safety mattersControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 8 of 60

System Policies & Procedures o Supervising the display of posters and notices, replacing and renewing them regularly. o Arranging for the showing of films of safety publicity and, where appropriate, organise subsequent discussions on the subjects depicted. o Encouraging members of the crew to submit ideas and suggestions for improving safety and enlist their support for any proposed safety measures which may affect them o Effective communication of new requirements or advice in relevant shipping legislation, Marine Notices and Company and ship’s rules and instructions relating to safety at work about the ship.• Investigation of accidents and dangerous occurrences o The safety officer has a duty to investigate notifiable accidents or dangerous occurrences affecting persons on board ship or during access, as well as potential hazards to health and safety and any reasonable complaints made by any personnel, and to make recommendations to the master. All investigations are to be documented in company standard format, the extent of which is governed by the seriousness of the incident.• Quarterly Safety Inspections o The safety officer is required to carry out health and safety inspections of each accessible part of the ship at least once every three months, or more frequently if there have been substantial changes in the conditions of work. “Accessible” should be taken as meaning all those parts of the ship to which any member of the crew has access without prior authority. Deciding whether “substantial changes in the conditions of work” have taken place is a matter of judgment. Changes are not limited to physical matters such as new machinery but can also include changes in working practices or the presence of possible new hazards. A record should be kept of all inspections. o It is not necessary to complete an inspection of the whole ship at one time, as long as each accessible part of the ship is inspected every 3 months. It may be easier to get quick and effective action on recommendations arising out of an inspection, if one section is dealt with at a time. WhenControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 9 of 60

System Policies & Procedures inspecting a section the safety officer should be accompanied by the officer or petty officer responsible for it. o Before beginning any inspection, previous reports of inspections of the particular section should be read, together with the recommendations made and the subsequent action taken. The control measures identified in any relevant risk assessment should also be read, and compliance with them checked during the inspection. Any recurring problems should be noted and, in particular, recommendations for action which have not been put into place. It is important, however, not to allow the findings of previous inspections to prejudice any new recommendations. • Quarterly Safety Officer Check Points o Every three months, the Safety Officer is to personally inspect the ship to identify and eliminate hazards utilizing the UK Code of Safe Working Practices, Annex 3.1 - Checklist for Safety Officer Inspection, as a Guide o Defects and Non-Conformities are to be reported and recorded in the ShipNet Database or by reporting forms if ShipNet is not functionally replicating6.3 Safe Working Practices The company adopts the UK MCA Code of Safe Working Practices for Merchant Seamen for establishment of safe working practices onboard • All working practices listed are incorporated by reference except for those areas where the HSQE System provides specific alternative guidance • Shipboard Management Teams are required to know and understand the Code of Safe Working Practices and ensure on board working practices are conducted in accordance with the code6.3.1 Safety Stations The company requires safety stations to be strategically located throughout the ship to ensure ready availability when neededControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 10 of 60

System Policies & Procedures o Eye Wash Stations are to be placed at each location where paints, chemicals, or batteries are stored or stationed o Chemical Protective Clothing, including gloves, goggles, and aprons is to be stationed at each location where batteries or chemicals are stored or stationed o Lock-Out/Tag-Out Stations, including locks and tags, are to be prominently stationed in both deck and engine department work areas o Decontamination showers and complete set of safety station for Chemical Tankers as per approved plans6.3.2 Time Out / Step Back 5 X 5Each individual has a role to play in ensuring that activities are carriedout in such a way as to avoid harm to persons, property or theenvironment. A call for Time Out is method of accident preventionthat is basic safety expectation of all staff.• A Time Out is an individual’s right and obligation to “Stop the Job” whenever they see imminent and pressing danger. A Time Out requires the courage to speak-up even when senior personnel are present.• Once a time out is called, all persons involved in the job should “step back for five minutes”, more commonly referred too in oil industry as “Step Back 5 X 5”. This 5 minute break is to allow evaluation of the danger observed so that hazard controls can be put in place before the job is resumed.6.3.3 Tool Box TalksTool box talks should be conducted every morning by both deck andengine departments. Tool box talks are to be used to distribute theday’s work assignments and discuss required precautions. These talksare informal and need not be recorded unless new or dangerous workis involved and a Job Hazard Analysis or Risk Assessment is neededfor the job.• A library of Tool Box Topics is provided for a variety of safety concerns. Tool Box Topics may be used in conjunction with toolControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 11 of 60

System Policies & Proceduresbox talks, as corrective action for related incidents, or for postingon bulletin boards for general awareness as deemed appropriate bythe safety officer.6.3.4 CARE Card Systemo In order to facilitate awarding individual effort, a CARE Card Reporting System has been established and to promote greater near miss reportingo CARE is an acronym that provides a means of correcting unsafe behaviors in a positive manner. CARE means to: C = Control - Control safety by observing fellow crew members A = Act - Take action if unsafe behavior or conditionsare observed R = Restore - Restore safe behavior or conditions E = Express - Express concern for the well being of the individualo CARE Cards have been printed in tear-off tablet form and are distributed together with the Safety Winner incentive cards. CARE Cards provide a simple and straightforward reporting system that focuses on the correction of unsafe acts or conditions on the spot. The CARE Card system gives credit to the crew member, regardless of rank or position, who reports a danger or an accident intervention. The person, who submits the report, is the person whose name is on the card, and the person who is to be credited for having taken action.o CARE cards are to be collected by the Safety Officer in a public \"suggestion box\" type receptacle. The Safety Officer is responsible to monitor onboard use of CARE Cards and ensure all hands are aware of the process and the company's expectation to participate. At the end of each month, the contents of the box are reviewed and closed-out by the safety committee each month by reviewing contents and highlighting corrective or preventive actions during all hands meeting. Brief details of the content the CARE Card are to be entered in ShipNet as a Near Miss. All minor Near Miss occurrences are toControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 12 of 60

System Policies & Procedures be \"Closed-Out\" in ShipNet by the Master and moved to the \"Closed\" Folder.• A CARE Card should be issued to document the reason any time-out is taken for safety reasons6.3.5 Personal Protective Equipment (PPE)All persons embarking company vessels are required to strictly adhereto personal protective equipment requirements where and whenconditions warrant.• Figure 6.3-1 Provides basic guidance for conditions and situations where PPE is required• The cost of this PPE shall be borne by the company. The following items are to be issued to each crew member: o Safety Helmet with chin strap o Safety Shoes o Chipping Goggles o Boiler Suits x 2 for each man o Hearing Protection (ear defenders or ear plugs) o Gloves• Any damaged safety equipment or protective clothing is to be reported to the Chief Officer for assessment• All PPE that has been discarded due to poor condition is to be destroyed or removed from the vessel o Only PPE that is of a good quality, correct for the purpose it is to be used for and properly fitting is to be ordered and suppliedControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 13 of 60

System Policies & ProceduresFigure 6.3-1 Personal Protective Equipment Requirements Boiler Suit Safety Shoes Helmet Ear Defenders Harness Goggles Leather Gloves Chemical Suit Chemical Gloves Visor Safety Line Floatation Aid Dust MaskOn DeckMachinery SpaceMooring OperationsAnchoring OperationsCargo OperationsCrane OperationsWire HandlingLifeboats / Rescue BoatShip SideHeight > 1.8MDe-scalingPaintingCleaning EquipmentChemicalsWeldingPower ToolsElectricalHydraulicPressureSteam Mandatory As Required• SAM Master List 012 - Ship Protective Clothing, provides the minimum inventory of PPE to be maintained onboard• The Department Head is responsible for issuance of individual PPE, monitoring it’s use and condition, and retirement for service when conditions dictate• Personnel are required to wear flotation whenever embarking from sea-side by boats or when working over the side, or rigging the gangway outboard of the maindeckControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 14 of 60

System Policies & Procedures6.4 Dangerous WorkAll jobs listed below require the issuance of a Permit to Work. Permitsensure that workers are briefed on dangers or hazardous work andprovide checks to ensure that energy sources are locked out, controlsare marked to identify and isolate hazards (Lock Out - Tag Out),and/or flammable ignition sources.• A permit to work is required for the following: o Working aloft with elevated height greater than 1.8 meters o Work with Asbestos o High Pressure Systems, Steam, Hydraulics or Compressed Air o Electrical Work o Diver and Underwater Operations o Confined Space Entry o Hot Work o Other Cold Work on Tankers o Grit Blasting o Elevator Maintenance• Dangerous Work Permit Form HSQE 004 is provided as a general work permit for hazardous work• Enclosed Space Entry Permit Form HSQE 007 is provided for use during confined space entry• Hot Work Form HSQE 008 is provided for use for all hot work outside the designated workshop• In case of electrical work, a signed and dated Electrical Isolation Tag is specifically required.• For Helicopter Operations, the checklist in the ICS Guide to Ship / Helicopter Operations is to be usedControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 15 of 60

System Policies & Procedures • For tankers, the company adopts the safe practices for management of dangerous work as specified in the International Safety Guide for Tankers and Terminals (ISGOTT) o The company requires all hot work, confined space entry, and tanker safety procedures to be carried out strictly in accordance with ISGOTT Guidelines which is incorporated by reference o Shipboard Management Teams are required to know and understand the requirements of ISGOTT and ensure on board practices are conducted in accordance with the guidance contained therein6.4.1 Hot WorkHot work is defined as any work requiring use of welding, burning,soldering equipment, blow torches, or work with power driven tools orportable electrical equipment that is not intrinsically safe, and internalcombustion engines. Any work involving sources of ignition that mightcause ignition of flammable gas mixtures.• Hot work may only be carried out outside the designated and approved work shop, if a Hot Work Permit has been issued and no other viable means of repair exists. Alternatives to be considered include cold work or removal of the piece for repair in the main machinery space work-shop. o For any hot work outside designated and approved welding and cutting work shop , the Master is to submit to the HSQE Department a written request with full details of the work proposed and a risk assessment detailing the expected hazards and controls to be established. HSQE concurrence is required prior to commencement of planned works and before the Hot Work Permit may be approved. • On tankers that carry petroleum or chemical cargoes all enclosed spaces including the cargo and ballast tanks, void spaces, duct keels and pipelines must always be considered to contain residual pockets of hydrocarbon or other explosive or flammable gases • On bulk carriers the dust from cargoes of coal, wheat, etc. may have an explosive mixControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 16 of 60

System Policies & Procedures• All ships present risks in the vicinity of fuel tanks, hydrogen emission from catholically protected ballast tanks, ignition of flammable materials or vapours (e.g. paint), and the use of welding and burning equipment may cause the conduction of heat through steel from safe to unsafe areas. The Master is responsible for ensuring hot work is conducted safely and is to ensure that the correct hot work procedures are planned, understood and will be followed, after which a hot work permit may be issued.• Hot work shall always be treated with extreme cautions especially when it is to be performed outside the designated workshop. Following requirement shall be met prior commencing hot work• A Hot Work Permit is required to be completed for any hot work outside the designated Machinery Space Workshop,• Risk Assessment to be completed and concurrence from HSQE Department necessary before job commences• Within Machinery Space Workshop, Permit is not necessary - this is a designated area for hot work.• Prior to starting any hot work: o Designate the person in charge of the hot work o A safety meeting is to be held with all those involved in the hot work. Briefing on the hot work procedures, communications procedures and any related safety precautions and contingency plans must be given o The Chief Officer will assess the hot work area and carry out the necessary checks and tests after which a written hot work permit with a duration that does not exceed 12 hours may be issued by the Master for each intended task o In the case of the engine room and engine room workshops the Chief Engineer may assess the hot work area• The procedures and precautions with all incorporated checks and tests are to be carried out: o After a permit time has expired and before continuing with hot workControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 17 of 60

System Policies & Procedures o After hot work has been suspended, and prior to starting hot work again6.4.1.1 General PrecautionsThe following precautions must be observed on every occasion whenhot work is intended: • On board tankers ISGOTT / Tanker Safety Manual (Chemical) procedures are to be strictly followed at all times. • All operations involving the cargo or ballast system including tank cleaning, gas freeing, purging or inerting are to be stopped before and throughout the duration of the work • Suitable and adequate firefighting equipment is to be made ready for immediate use. Where hot work is to be carried out at a compartment boundary then firefighting equipment is to be readied on both sides of the boundary. • A fire watchmen with radio contact to the bridge is to be posted and fully briefed • The hot work area is to be cleared of all combustible material including any combustible material on the adjacent side of any boundary. Adjacent tanks, holds, pipelines, etc. must be confirmed free of any dangers posed by hot work.• The work area is to be adequately ventilated. The frequency of atmosphere monitoring is to be established and recorded in \"Hot Work Permit\". Atmospheres should be re-tested after each break in work periods and at regular intervals as defined in the Form. The results of these checks are also to be recorded on the Form. Checks are to be made continuously to ensure there is no ingress of flammable vapours or liquids, toxic gases or inert gas from adjacent or connected spaces.• Hydrocarbon gas is generally heavier than air and may be present in pockets in compartments that have been ventilated for some time. However, methane gas which may be emitted from coal cargoes is lighter than air and therefore hatch covers must be tested. It is therefore most important that tests should be made throughout any compartment and at different levels.Controlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 18 of 60

System Policies & Procedures • Hot work on pipelines and valves is permitted when the item has been detached from the system by cold work and the remaining system blanked off. The item to be worked on should be cleaned and gas freed to be safe for hot work regardless of whether or not it is removed from the hazardous cargo area. • Check the work area and adjacent compartments and tanks are gas free with properly calibrated instruments6.4.1.2 Precautions in Enclosed Spaces Where hot work is to be carried out within an enclosed space, all Enclosed Space Entry Procedure procedures detailed in this document must be completed, and the following precautions taken: • The compartment is to be cleaned and ventilated until tests of the atmosphere indicate 21% oxygen content by volume and not more than 1% LEL • Arrange for continuous ventilation during hot work • Adjacent cargo tanks, including diagonally positioned cargo tanks, should either be: o Cleaned and gas freed, with hydrocarbon vapour content reduced to not more than 1% LFL and maintained at that level; or o Emptied, purged and the hydrocarbon vapour content reduced to less than 2% by volume and inerted; or o Completely filled with water o All other cargo tanks should be inerted and their deck openings closed. o Slops are to be placed in a tank as far away as possible (at least 30 metres) from the hot work area and that tank kept closed o All interconnecting pipelines to other compartments should be flushed through with water, drained, vented and isolated from the compartment where hot work will take placeControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 19 of 60

System Policies & Procedures o All sludge, scale, sediment or other material likely to give off flammable vapour is to be removed from an area of at least 10 meters around the area of hot work. Special attention must be given to the reverse sides of frames and bulkheads. Other areas that may be affected by the hot work, such as areas immediately below are to be cleaned.• For Bunker Tanks o Fuel oil bunker tank may be considered safe if tests using a combustible gas indicator give a reading of not more than 1% LEL in the ullage space of the bunker tank however, no heat transfer through the bulkhead of the bunker tank is to be caused by any hot work o No hot work should be carried out on bulkheads of bunker tanks containing bunkers or within 0.5 meter of such bulkheads6.4.1.3 Welding, Burning and Cutting EquipmentCompany Poster STP 011 is to be posted to provide instruction for thesafe working practices and the safe operation of all welding, burningand cutting equipment to be used. This sign would normally be postedin the engine room workshop adjacent to the equipment and at thestorage site of any oxygen and acetylene bottles.• The Chief Engineer has the responsibility of assessing and designating those onboard who may operate the ships welding, burning and cutting equipment to Adequate ventilation must be provided in all spaces where welding is undertaken to eliminate the gases, fumes and dust caused by the welding operation.• Noxious and toxic fumes may be produced during welding or burning operations and the burning process may result in depletion of oxygen therefore adequate ventilation must be arranged and respiratory protective masks provided if necessary.• Welding and burning equipment is to be carefully inspected before use to ensure it is in good condition and operating normally. Special attention must be paid when using electric-arc equipment ensuring:Controlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 20 of 60

System Policies & Procedures o That electrical supply connections are made in a gas free areas and the cable route to the work site is the safest possible and passing over gas free or inerted spaces o Cable connectors are to be insulated and designed that live terminals are not exposed on disconnection and electrode holders should be fully insulated so that no live part of the holder is exposed to touch o That existing supply wiring is adequate to carry the electrical current demanded without overloading and causing heating. Therefore, the cables should be inspected before use; if the insulation is impaired or conductivity is reduced, they should not be used o The insulation of flexible electric cables laid across the deck is in good condition o The earth connection is made adjacent to the work site and the earth return cable leads directly back to the welding machine o Compressed gas cylinders are to be handled with care, properly secured and kept upright with valves up and have valve covers in place during transport o Flash Back suppressors are fitted at the inlet to the cutting torch and at the Oxygen & Acetylene tank outlets• Operator’s of welding and burning equipment are to: o Be protected by clothing, leather gloves, non-conductive safety footwear and a welding helmet or suitable alternate (e.g. Eye goggles or a hand-held shield) Eye injuries are serious and may lead to permanent loss or impairment of vision o Have an assistant in attendance ready to assist in case of accidental electric shock or other injury o Be protected from contact with the ships structure by the provision of dry insulating mats or boards o Take extra care when welding operations are undertaken in hot or humid conditions when body sweat and damp clothing increase the risk of electric shockControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 21 of 60

System Policies & Procedures o Under no circumstances to work while standing in water or with any part of his body immersed o Have completed training in welding competencies6.4.1.4 ConcurrenceIt is Master's Responsibility to obtain concurrence for the HSQEDepartment that the controls described in the Risk Assessment areadequate. Each request must be made in writing and submitted 48hours prior to the commencement of the planned hotwork. Eachrequest should:• Be specific as to the exact location• Provide the Work Scope and Detail of all action• Describe the Reason as to why it is critical to conduct this hot work at this particular time• Detail the Planned Safety Precautions including preparations such as line flushing and water plugs (where deemed appropriate)• Be sent to the technical superintendent responsible for the vessel with a copy (cc) to the HSQE email address - vetting@sea- team.com• Technical Superintendents duty upon receipt o It is the responsibility of the dedicated Technical Superintendent to view the initial request and ascertain if this hot work is justified and in line with his own plans for the vessel. In turn he will add his own comments and recommendations to the request documentation (as received from the vessel). o The superintendent will then forward comments to HSQE Department for final review, from a safety perspective.• HSQE duty upon receipt o Upon receipt from the HSQE Department they will add their comments. It would be the responsibility of HSQE to review the Hot Work Concurrence request in its entirety and ensure allControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 22 of 60

System Policies & Procedures safety aspects have been identified both in the initial part of the request from the vessel and technical departments' suggestion. Upon the completion of review, he should be satisfied all safety measures are in place, if not he should supply details of any additional measures to be considered. The Concurrence request is then transmitted back to the vessel detailing agreement or restricting conduct of the hot work. • Close out notes on Hot Work o Upon receipt of the Hot Work concurrence from the Head Office, the usual practice for the ship to carry out the Hot Work on board will be to have a Tag-in and Tag-out notes. This will ensure that all equipment used on board for Hot Work are properly checked and cleared from the Hot Work area at the end of the Hot Work. By doing so will ensure nothing is left about in the tanks or at the work place. All future Hot Work completion messages must contain the phrase \"Hot Work completed and properly closed-out\" to indicate that all equipment used for the hot work are cleared item by item in a tag-in tag-out fashion • Close-out of Request o It is the responsibility of every Master to ensure proper close-out of all hot work operations. When you notify the office of the completion of the hot work, the work area is deemed to be safe, area cleared and vessel returned to normal safe operation (such as cargo tanks re-inerted).6.4.2 Enclosed Spaces Often a question on board will be what constitutes an enclosed space? The IMO defines an enclosed space as being one which has any of the following characteristics: • Limited openings for entry and exit; • Inadequate ventilation; and • Is not designed for continuous worker occupancy The definition includes, but is not limited to, the following compartments: Cargo spaces , Double bottoms, Fuel tanks , Ballast tanks, Cargo pump-rooms, Cargo compressor rooms, Cofferdams ,Controlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 23 of 60

System Policies & ProceduresChain lockers, Void spaces, Duct keels, Inter-barrier spaces, Boilers ,Engine crankcases, Engine scavenge air receivers, Sewage tanks . • The Safety Officer is to conduct and keep records of a Risk Assessment to identify ALL Enclosed Spaces onboard, as well as related hazards and controls needed to ensure safe entry. A master-list of confined spaces should be signed by the Master and kept in the cargo office for easy reference, together with confined space entry permits • The Safety Officer is to ensure confined space rescue drills are being carried out at least once every six months (as required by HSQE 021 - Record of Drills, Trainings & LSA Maintenance). • The Safety Officer is to ensure training in the use of the gas instruments carried onboard has been carried out and recorded in HSQE 021 when scheduled; training should include: o Identification of the hazards likely to be faced during entry into enclosed spaces; o Recognition of the signs of adverse health effects caused by exposure to hazards during entry; and o Knowledge of personal protective equipment required for entry• Entrances to enclosed spaces should be secured at all times when entry is not required.• When opened, an attendant should be posted at the entrance, or a suitable mechanical barrier should be placed across the opening together with a warning sign to prevent accidental entry. • All gas and oxygen detectors used are to be function tested and if necessary calibrated. Only personnel familiar with the gas and oxygen testing equipment are to carry out testing of the enclosed space atmosphere• In some cases it may be difficult to test the atmosphere throughout the enclosed space without entering the space (e.g., the bottom landing of a stairway) and this should be taken into account when assessing the risk to personnel entering the space. The use of flexible hoses or fixed sampling lines which reach remote areas within the enclosed space, may allow for safe testing without having to enter the space.Controlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 24 of 60

System Policies & Procedures• Steady readings of \"not more than 50% of the Occupational Exposure Limit (OEL) of any toxic vapours and gases\" should be obtained prior to entry along with a remark that \"It should be noted that the term Occupation Exposure Limit (OEL) includes the Permissible Exposure Limit (PEL). Maximum Admissible Concentration (MAC) and Threshold Limit Value (TLV) or any other internationally recognised terms.• It should be emphasized that the internal structure of the space, cargo, cargo residues and tank coatings may also present situations where oxygen-deficient areas may exist, and should always be suspected, even when an enclosed space has been satisfactorily tested as being suitable for entry, this is particularly the case for spaces where the path of the supply and outlet ventilation is obstructed by structural members or cargo.• If it is unclear whether or not a particular compartment is an enclosed space, a risk assessment should be carried out in accordance with IMO recommendations to overcome any doubts. The process of carrying out a risk assessment to identify enclosed spaces should be repeated at regular intervals as circumstances may change.6.4.2.1 EntryEntry into enclosed spaces is only permitted when:• A Risk Assessment has been completed or reviewed• Entry requirements specified on SeaTeam Form No. HSQE 007- Enclosed Space Entry Permit have been verified and the results recorded on the permit by hand in pen and ink o Enclosed Space Entry Permits are valid during the normal working day, and not to exceed 12 hours• A pre-entry safety meeting has been conducted to review the Risk Assessment and Entry Permit to reiterate hazards and required controls • The Permit has been signed by the personnel entering the space, the safety \"Attendant\", and it has approved by signature of the Master or Safety Officer.Controlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 25 of 60

System Policies & Procedures • The atmosphere is continuously monitored with portable gas monitors with audible alarm where applicable if personnel leave the space for more than 30 minutes, the atmosphere must be re- tested at the lowest point• Simultaneous tank entry. o Where simultaneous entry is required in different locations, separate permits must be issued. When issuing more than one permit, due consideration must be given to having sufficient resources available for emergency including personnel and safety equipment. o A detailed risk assessment is to be carried out, detailing safety precautions to be put in place to minimize risks posed by simultaneous entries. Except for periods when the vessel is gas free (e.g. during dry docking), copy of the risk assessment is to be forwarded to the HSQE/Marine Superintendent for review and concurrence prior to commencement of simultaneous entry of multiple spaces.6.4.2.2 Atmospheric TestsPrior to entry into a confined space, atmospheric testing must beconducted at least three levels, including the lowest point, withproperly calibrated gas detection instruments for the space to beconsidered safe for entry. Testing is to be conducted based uponknown hazards associated with specific types of enclosed spaces: • Cargo holds, ballast tanks, and voids o Oxygen content must be 21% by volume • Cargo, fuel tanks and other enclosed spaces on tank deck area o Oxygen Content must be 21% by volume o Hydrocarbons must be less than 1% LEL o Toxicity - Is measured to be less than the Threshold Limit Value (TLV) for all known or suspected toxins. The previous cargo and bunkers provides an indicator of toxins that should be suspectedControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 26 of 60

System Policies & ProceduresLack of OxygenLack of oxygen is to be suspected in any enclosed space. Thefollowing situations require risk evaluation of oxygen levels:• Tanks and other compartments that have been closed for a period of time particularly if they have contained water, have been subjected to damp or humid conditions or have signs of heavy corrosion• Oxidation of cargoes. Logs, sawn lumber, iron ore, coal, grain, vegetable oils and tapioca are among the numerous cargos known to consume oxygen in the atmosphere or to displace it by the evolution of other gases (such as Carbon Monoxide)• If an adjacent space has been inertedFlammable or Toxic GasesFlammable or toxic gases should be suspected in all of the following:• In the cargo tanks, pump-rooms, pipe-ducts, sewage tanks, bilge tanks, slops tanks, paint storage rooms, and other adjacent spaces in oil and chemical tankers• If sludge, scale and cargo residue is disturbed or subjected to a rise in temperature then gas free spaces or tanks may evolve or produce dangerous concentrations of flammable or toxic gasCarbon MonoxideCarbon Monoxide is a colorless odorless and tasteless gas that can befatal in high concentrations, Atmospheric testing and use of portablealarms is required when conditions for production exist• Ships Discharging Vegetable Oils o Prior to entry into cargo tanks with vegetable oil or vegetable oil residues,Controlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 27 of 60

System Policies & Procedures• Combustion Driven Engines o Whenever combustion driven equipment such as pumps or tractors, are operated in a confined space, hold or pump-room6.4.2.3 VentilationShould any atmospheric test reveal an unsafe atmosphere, the spaceshould be continuously ventilated with portable power ventilation fansuntil the space is safe for entry. To avoid short circuiting, whereventilated air exits the space without reaching the lowest points,extendable air ducts should be fitted to fans and lowered to the lowestpoint, as far diagonally opposite the tank hatch as possible.• Ventilation should be maintained continuously throughout entry• For vapours heavier than air (most clean products) the fan should take suction through the duct from the low point and exhaust vapours from the tank while bringing in fresh air from the hatch• For vapours lighter than air, the fan should blow air through the duct at the low point and force vapours from the tank through the hatch6.4.2.4 Pre-Entry Safety MeetingThe crew entering and those on standby outside the space are to bebriefed on:• Work instructions, expected duration of entry and the dangers and hazards that may be encountered• Working and safety equipment requirements• Use of personal oxygen or gas alarms• Contingency and emergency plans• Additionally, those on standby outside the space are to receive instruction on: o Raising the alarm by radioing the duty officer should agreed signals failControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 28 of 60

System Policies & Procedures o The duty officer will use the General Alarm to alert the crew of any emergency o Enclosed space atmosphere re-testing requirements o Rescue procedures. In relation to this, experienced personnel should be used6.4.2.5 Emergency Standby EquipmentThe following equipment must ready for use and put on standbyoutside the enclosed space:• 2 SCBA -Self Contained Breathing Apparatus• EEBD - Emergency Escape Breathing Device• Tripod with block and tackle, lifelines and rescue harness• Remote gas detection instruments with hoses long enough for deepest space• UHF two-way RadioThe list of standby equipment is for guidance and is not exhaustive.Ship's crew may add whatever extra equipment is deemed necessaryfor safe entry. Where practical a trolley cart should be used toconsolidate standby equipment and to transport the items around thedeck area, which is especially helpful when more than one enclosedspace is to be entered.6.4.2.6 CommunicationThe Duty Officer is to be advised of each enclosed space entry andmust understand the system of communication between thoseentering the enclosed space and those on standby outside the space.Suggested forms of communication include: Verbal via UHF Radio • Are you ok / I'm okControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 29 of 60

System Policies & Procedures Clicking of Torch Light beam • Two clicks - are you ok / three clicks - I'm ok Tapping with a Hammer • Two taps - are you ok / three taps - I'm ok6.4.2.7 Work on Pipelines and ValvesParticular care should be exhibited when working on pipelines andvalves within the space. If conditions change during the work,increased frequency of testing of the atmosphere should beperformed. Changing conditions that may occur include increasingambient temperatures, the use of oxygen-fuel torches, mobile plant,work activities in the enclosed space that could evolve vapours, workbreaks, or if the ship is ballasted or trimmed during the work\", andthat \"In the event of an emergency, under no circumstances shouldthe attending crew member enter the space before help has arrivedand the situation has been evaluated to ensure the safety of thoseentering the space to undertake rescue operations. Only properlytrained and equipped personnel should perform rescue operations inenclosed spaces.\" Where equipment, valves or pipelines are to beopened within an enclosed space and there is a risk that a flammableand or toxic liquid or vapour may be released:• the equipment, valves or pipelines are to be thoroughly flushed through with water and properly ventilated prior to opening• Breathing apparatus are to be available at the work site• Continuous gas monitoring is to be conducted while opening up the equipment, valves or pipelines6.4.2.8 Spaces that are not Gas FreeSpaces that have not been tested should be considered unsafe forpersons to enter\", and that \"Persons entering enclosed spaces shouldbe provided with calibrated and tested multi-gas detectors thatmonitor the levels of oxygen, carbon monoxide and other gases asappropriate\". Entry into a space that is not gas free or does notcontain 21% oxygen is only to be permitted on emergency basis whenControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 30 of 60

System Policies & Proceduresthere is absolutely no other alternative. The following restrictionsapply:• Prior to entry, the Marine Department must be advised of the reasons for the restricted entry• All crew involved are to be fully briefed on the hazards and extra safety procedures to be followed• The number of persons entering is to be kept to a minimum however; no less than two persons are to enter the space• Those entering are to wear either a compressed air breathing apparatus or an airline mask with an external air supply connected to the belt• An emergency rescue team fully equipped with breathing apparatus and rescue equipment to be on stand by• Completion of the 'Restricted Entry Addendum' to the enclosed Space Entry Permit (SeaTeam Form No. HSQE 007) where all conditions must be satisfactorily met• Where needed, selection of Chemical Protective Clothing (suits, boots and gloves) is to be made, based on the knowledge of the process for determining chemical resistance and personal exposure limits• Personnel (Master or Chief Officer) deciding upon a restricted entry must have been trained on the following topics: o How to determine the permissible exposure limits as expressed by a specific chemical's TLV-TWA, TLV-STEL and TLV-C o Location and understanding of Material Safety Data Sheets o How to operate and calibrate a toxic gas detector and determine results on a direct reading detector tube o How to use the \"Quick Selection Guide to Chemical Protective Clothing\" to properly determine chemical resistance requirementsControlled Revision: 01 Sep 2015HSM Part A – SPP Doc No. 006SAFETY MANAGEMENT Approval: WBF Page: 31 of 60