The policy refers to the ships managed by SCINICARIELLO SHIP MANAGEMENT S.r.l. hereinafter called the “Company”.

The Company seeks to conduct its operations so as to ensure safety at sea, prevention of human injury or loss of life. Further the Company does every effort to avoid damage to the environment and property seeking in particular :

– To protect the marine environment from oil, garbage, sewage and unwanted aquatic organisms by planning the maintenance of systems and equipments, developing manuals and instructions for that purpose, also applying antifouling paints not affecting sea life.

– To avoid air pollution using low sulphur fuels and where feasible using last generation of refrigerating gases and engines with low NO emission.

The Company seeks and develops, implements and maintains the standards of safety and environmental protection in line with the principles to achieve continuous improvement with zero spills and zero incidents.

The Company establishes that all operations carried out by its personnel, both ashore and on board, will emphasise its commitment to the following specific objectives in order to :

1. Provide for safe practice in ship operation

2. Provide a safe working environment

3. Establish safeguards against all identified risks

4. Constant improve the safety management skills of shipboard and shore based personnel including preparing for emergency related to safety and environment protection

The Company requires that whenever a conflict arises between commercial or economic reasons and the above points, the Master shall always decide by giving priority to points 1, 2 and 3.

To achieve the above mentioned objectives, the Company will provide the necessary resources and qualified personnel, defining its organisation, identifying specific tasks and responsibilities, establishing training requirements and co-ordinating all the tasks in order to maintain its ship and equipment in conformity with the applicable rules and regulations.

In order to achieve the above objectives the company establishes and adopts a safety management system that ensures the :

– Compliance with relevant mandatory rules and regulations

– The applicable codes, guidelines and standards recommended by IMO, relevant flag states, classification societies and maritime industry organisation are also taken into account

The Company has included the following functional elements in the development, implementation and maintenance of the safety management system :

– A Safety and Environmental protection Policy

– Instruction and procedures to ensure safe operation of ships and protection of the environment in compliance with relevant international and flag state legislation

– Defined levels of authority and lines of communication between and among shore and shipboard personnel

– Procedure for reporting accidents and non conformities within the provision of the ISM code

– Procedures to prepare guidelines and respond to emergency situation

– Procedures for internal audits and management reviews

WHILE A SET OF OPERATIONAL AND EMERGENCY PROCEDURES AND INSTRUCTIONS ARE PROVIDED FOR THE SHIPBOARD PERSONNEL, IT IS UNDERSTOOD THAT ON BOARD SHIP IT IS THE MASTER WHO HAS THE OVERRIDING RESPONSIBILITY AND AUTHORITY FOR THE SAFE OPERATION OF THE SHIP AND FOR POLLUTION PREVENTION.

The Master is also responsible for immediately reporting to the Company any accident or non-conformity which may affect the safety of the personnel or of the ship or which may cause pollution to the environment. Adequate personnel and means of communication are provided for this purpose.

It is of paramount importance for the Company to maintain a high level image towards the users of its services and all the parties involved in its operations, this will also be achieved by keeping the highest maintenance standards on all managed vessels.

In order to meet the objectives in safety and environment protection the Company requires total commitment from all personnel who are directly involved in the company’s operations. This includes shore-based managers and staff, vessel masters, officers and crews.

The following functions are taken into consideration :

Overall Responsibility

The Managing Director accepts overall responsibility for all matters related to safety and environmental protection.

Management Responsibility

Company management and vessel’s master are responsible for ensuring that the safety and environmental protection policy is implemented within their area of responsibility and on board vessel.

Individual Responsibility

All individuals who are involved in the Company’s operations are responsible for ensuring their own safety, the safety of other and for the protection of the environment.

Definition

Safety Management System is a structured and documented system that enable the company personnel to effectively implement the company safety and environmental protection policy.

The effective implementation of the Company’s Policy is regularly reviewed in order to ensure that the objectives of the Company are achieved and suitability and effectiveness of the procedures and instructions are established.