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 PRINCIPLES

  1. As an International Sea Transport Company, we will actively seize opportunities that contribute to growth and development by meeting and responding to our customers’ needs.


  2. We will strive to maximize company value by always being creative, continually pursuing higher operating efficiency and promoting an open and visible management style that is guided by the highest ethical and social standards.


  3. We will promote and protect our environment by maintaining strict, safe operation and navigation standards.


 Ship Management

Our is to convey VM philosophy and actions on company responsibility including safe operation and environmental protection, which are the foundation of our business activities. This report covers the areas – “management includes safe operation”, the “environment”, and “finance”.

Management of the units of the fleet entirely owned or Bareboat chartered has been entrusted to Vestland Marine as technical manager of international repute, a corporation established and operated from Gdynia, Poland.

Within the framework of a permanent policy to guarantee our customers quality service, and in addition to the above, with the firm purpose of being able to be actively involved, with high economic efficiency, in the day by day more competitive environment of the maritime transport industry, efforts have been centered on acquiring great trustworthiness and safety in the daily operation of each of our vessels, at costs compatible with international levels.

Thus, within the ambit of standing international regulations on maritime modes of transport, the company have strictly fulfilled the regulations of the ISM Code (International Management Code for Safe Operation of Ships and Pollution Prevention) and, in an important effort to ensure the quality of ship management services, technical operation procedures have been ISM certified by DNV which represents a guarantee of excellent service to our customers. The above shows our permanent commitment regarding quality performance, privileging the safety of human life at sea and the protection of both the marine environment and of the goods entrusted in custody.

Also, it should be emphasized that all our vessels have been equipped with modern electronic data transfer systems (IT Systems), thus allowing management ashore to communicate directly with the vessels. The latter has led to more efficient technical and operational management of all human as well as material resources.

All the efforts described, together with the continuous and self-sacrificing daily work of our crew members on board, guarantee the good operational condition of every vessel’s systems and equipment, strengthening our commitment to provide an efficient service to the advantage of our clients.

 Safe Operation

Safe operation is the very foundation of VM business activities, and the basis of environmental protection. The entire Company works to ensure safety in every aspect of operation.

Company philosophy on safe operation

Our business depends on the ocean, which truly belongs to everyone. Protecting the ocean is a critical duty for everyone. For those of us in the shipping business, there is no margin for error when it comes to safety. We all have to recognize that vessel safety is the basic premise of our business.

Basic policies of VM safe operation

  1. Respect and follow laws and regulations


  2. Maintain safe operation


  3. Protect human life and the marine environment


  4. Improve personnel skills.


  5. Ensure reliable vessel maintenance and management.


Continuous improvement for safe operation

Vestland Marine and vessels Ship Management share the same philosophy on vessel safety, and have developed a comprehensive ship management system including land-based support sections. Our efforts focus on both “hardware” and “software” aspects such as proper maintenance and management of vessel hulls and equipment, establishment of ship operation skill standards, and education and training of seafarers.

These efforts are reflected in the unique VM Safety Management System.

Emergency response system

We have developed a marine accident response manual to ensure an immediate, appropriate remedy to any level of accident. In case of a major accident, we have an emergency task force headed by the Fleet Manager. Our emergency response system centered on the task force works to limit the spread of damage and ensure the safety of people and cargo. In addition, we conduct periodic table-top drills based on realistic accident scenarios.

Onboard assessments to improve vessel safety

Direct instruction and audits are important to monitor vessel status and develop more effective approaches to safety and environmental protection. For that purpose, regular vessel inspections are essential. VM vessel inspections are intended to confirm that ship management are performing up to standards and reflect our policies on vessel operation. When visiting a vessel, the inspector are using a newly developed “Pocket Check List” as well as a revised “Health, Safety and Quality Check List”, we focus on both hardware and software, inspecting the bridge, cargo holds and equipment, engine room, navigation instruments, and fire and safety protection equipment, and mooring, while reviewing operational methods, maintenance records, hydrographic chart updates, and spare parts inventory. Inspections also cover environmental aspects such as appropriate treatment and disposal of trash, waste oil, and bilge water.

Since 2005, we implemented inspections to promote company policies on safe operation and environmental protection.

  • Confirm environmental measures


  • Reinforce overall vessel security system ensuring compliance with ISPS Code.


  • Check Port State Control (PSC) inspection items


  • Prevent engine trouble


 ENVIRONMENTAL POLICY STATEMENT

As an International sea transport company, Vestland Marine is committed to protecting the health of our marine/global environment and therefore promotes and supports policies that:

  1. Protect all aspects of the marine/global environment and foster safe navigation;


  2. Comply with all environmental legislation and regulations that we are required to by law, and all relevant standards and other requirements that we subscribe to. And, whenever possible, further reduce the burden on the environment by setting and achieving even tougher voluntary standards;


  3. Periodically review and revise our environmental protection measures on the basis of our framework for setting and reviewing environmental objectives and targets;


  4. Conserve energy and materials through recycling and waste reduction programs;


  5. Purchase and use environmental safe goods and materials;


  6. Promote the development and use of environmental safe technology;


  7. Educate and encourage employees to increase their focus on protection of the environment through enhanced publicity efforts, and communicate our Environmental Policy to employees;


  8. Always strive to ensure that our business activities contribute to and adequately support worthy environmental protection activities

 Code of ethics

Vestland Marine will conduct its business honestly and ethically wherever we operate in the world. We will constantly improve the quality of our services, products and operations and will create a reputation for honesty, fairness, respect, responsibility, integrity, trust and sound business judgment. No illegal or unethical conduct on the part of officers, directors, managers, employees or affiliates is in the company’s best interest. Vestland Marine will not compromise its principles for short-term advantage. The ethical performance of this company is the sum of the ethics of the men and women who work here. Thus, we are all expected to adhere to high standards of personal integrity.

Officers, crew, directors, managers and employees of the company must never permit their personal interests to conflict, or appear to conflict, with the interests of the company, its clients or affiliates. Officers, crew, directors, managers and employees must be particularly careful to avoid representing Vestland Marine in any transaction with others with whom there is any outside business affiliation or relationship. Officers, crew, directors, managers and employees shall avoid using their company contacts to advance their private business or personal interests at the expense of the company, its clients or affiliates.

No bribes, kickbacks or other similar remuneration or consideration shall be given to any person or organization in order to attract or influence business activity. Officers, crew directors, managers and employees shall avoid gifts, gratuities, fees, bonuses or excessive entertainment, in order to attract or influence business activity.

Officers, crew, directors, managers and employees of Vestland Marine will often come into contact with, or have possession of, proprietary, confidential or business-sensitive information and must take appropriate steps to assure that such information is strictly safeguarded. This information – whether it is on behalf of our company or any of our clients or affiliates – could include strategic business plans, operating results, marketing strategies, customer lists, personnel records, upcoming acquisitions and dispossession, new investments, and operating costs, processes and methods. Proprietary, confidential and sensitive business information about this company, other companies, individuals and entities should be treated with sensitivity and discretion and only be disseminated on a need-to-know basis.

Misuse of material inside information in connection with trading in the company’s securities can expose an individual to civil liability and penalties under the company and civil ACT. Under this Act, directors, managers, Officers, crew and employees in possession of material information not available to the public are “insiders.” Spouses, friends, suppliers, brokers, and others outside the company who may have acquired the information directly or indirectly from a director, manager, officer, crew or employee are also “insiders.” The Act prohibits insiders from trading in, or recommending the sale or purchase of, the company’s securities, while such inside information is regarded as “material”, or if it is important enough to influence you or any other person in the purchase or sale of securities of any company with which we do business, which could be affected by the inside information. The following guidelines should be followed in dealing with inside information:

  • Until the material information has been publicly released by the company, an employee must not disclose it to anyone except those within the company whose positions require use of the information.


  • Employees must not buy or sell the company’s securities when they have knowledge of material information concerning the company until it has been disclosed to the public and the public has had sufficient time to absorb the information.


  • Employees shall not buy or sell securities of another corporation, the value of which is likely to be affected by an action by the company of which the employee is aware and which has not been publicly disclosed.
Officers, crew, directors, managers and employees will seek to report all information accurately and honestly, and as otherwise required by applicable reporting requirements.

Officers, crew, directors, managers and employees will refrain from gathering competitor intelligence by illegitimate means and refrain from acting on knowledge which has been gathered in such a manner. The Officers, crew, directors, managers and employees of Vestland Marine will seek to avoid exaggerating or disparaging comparisons of the services and competence of their competitors.

Officers, crew, directors, managers and employees will obey all Equal Employment Opportunity and act with respect and responsibility towards others in all of their dealings.

Officers, crew, directors, managers and employees will remain personally balanced so that their personal life will not interfere with their ability to deliver quality products or services to the company and its clients.

Officers, crew, directors, managers and employees agree to disclose unethical, dishonest, fraudulent and illegal behavior, or the violation of company policies and procedures, directly to management.

Violation of this Code of Ethics can result in discipline, including possible termination. The degree of discipline relates in part to whether there was a voluntary disclosure of any ethical violation and whether or not the violator cooperated in any subsequent investigation.

Remember that good ethics is good business.

 Drugs and Alcohol Policy

Terms

Drug and alcohol abuse contributes to billions of Euros of lost productivity and thousands of work place injuries every year. Our policy is to employ a work force free from alcohol abuse or the use of illegal drugs. This company takes drug and alcohol abuse as a serious matter and will not tolerate it. The company absolutely prohibits the use of alcohol or non-prescribed drugs at the work place/vessels or while on company premises. It also discourages non-work place drug and alcohol abuse. The use, sale or possession of alcohol or drugs while on the job or on company property will result in disciplinary action, up to and including termination, and may have legal consequences. Employees are expected and required to report to work on time and in appropriate mental and physical condition for work. It is our intent and obligation to provide an alcohol and drug-free, healthful and safe work environment. Vestland Marine reserves the right to demand a drug or alcohol test of any employee at any time or based upon reasonable suspicion. Reasonable suspicion includes, but is not limited to, physical evidence of use, involvement in an accident, or a substantial drop off in work performance. Failure to take a requested test may lead to discipline, including possible termination.

The company also cautions against use of prescribed or over-the-counter medication which can affect your work place performance. You may be suspended or discharged if the company concludes that you cannot perform your job properly or safely because of using over-the-counter or prescribed medication. Please inform your superior/supervisor prior to working under the influence of a prescribed or over-the-counter medication which may affect your performance.

Employees must report any conviction under a criminal drug statute for violations occurring on or off the Company's vessels/premises while conducting company business. A report of a conviction must be made within 1 day after the conviction. Vestland Marine will make every effort to assist its employees who wish to seek treatment or rehabilitation for drug or alcohol dependency. Conscientious efforts to seek such help will not jeopardize any employee's job and will not be noted in any personnel record. You may also be required to agree to random testing and a “one-strike” rule.

Employees who work on the company vessels are prohibited from drinking alcohol for eight (8) hours before their shift and during their shift period.

The monitoring of alcohol consumption and taking a stance against drugs is something that all reputable companies include in their manning policy. Vestland Marine, as a tanker operator, has even stricter guidelines imposed upon us by the major oil companies. Many oil/chemical terminals have a “zero” tolerance policy.

If you have a drug or alcohol problem, please ask for our help!

 Drugs and Alcohol Testing Policy

Employees Subject to Testing

Under Vestland Marine’s drug and alcohol testing policy, current and prospective employees, crew and shore based who work or would work in high-risk or safety-sensitive positions will be asked to submit to drug and alcohol testing. No prospective employee will be asked to submit to testing unless an offer of employment has been made. An offer of Vestland Marine, however, is conditioned on the prospective employee testing negative for drugs and alcohol.

Safeguards

Vestland Marine’s policy is intended to comply with all laws governing drug and alcohol testing and is designed to safeguard employee privacy rights to the fullest extent of the law.

Selection

All Vestland Marine’s employees will be asked to submit to drug and alcohol testing.

Tested Substances

Vestland Marine’s drug and alcohol testing program is limited to testing for e.g., blood alcohol, specific drugs and drug types. Any other substances that may be tested using the same method used to test for controlled substances will not be tested and, if found will not be reported.

Written Notice

Before being asked to submit to a drug and/or alcohol test, the employee will not receive any notice of the request or requirements.

Licensed Laboratories

Any drug and/or alcohol testing required or requested by Vestland Marine will be conducted by an approved laboratory. The employee may obtain the name and location of the laboratory that will analyze the employee's test sample.

Notice of Results

If the employee is asked to submit to a drug or alcohol test, Vestland Marine will notify the employee of the results within 24 hours after it receives them from the laboratory. To preserve the confidentiality Vestland Marine strives to maintain, the employee will be notified by writing whether the test was negative or confirmed positive and, if confirmed positive, what the next step is.

Positive Test Results

If the employee receives notice that the employee's test results were confirmed positive, the employee will be given the opportunity to explain the positive result following the employee's receipt of the test result. In addition, the employee may have the same sample retested at a laboratory of the employee's choice.

Adverse Employment Action

If there is reason to suspect that the employee is working while under the influence of an illegal drug or alcohol, the employee will be suspended without pay until the results of a drug and alcohol test are made available to Vestland Marine by the testing laboratory. Where drug or alcohol testing is part of a routine physical or random screening, there will be no adverse employment action taken until the test results are in.

Confidentiality

Vestland Marine will make every effort to keep the results of drug and alcohol tests confidential. Only persons with a need to know the results will have access to them. The employee will be asked for the employee's consent before test results are released to anyone else. Be advised, however, that test results may be used in arbitration, administrative hearings and court cases arising as a result of the employee's drug testing. Also, results will be sent to law agencies as required by law. If the employee is to be referred to a treatment facility for evaluation, the employee's test results will also be made available to the employee's counselor. The results of drug testing in the workplace will not be used against the employee in any criminal prosecution.

Costs

Vestland Marine will pay the cost of any drug and alcohol testing that it requires or requests employees submit to, including retesting of confirmed positive results. Any additional tests that the employee requests will be paid for by the employee.

Drug and Alcohol Use at Work Prohibited

Vestland Marine will not tolerate any use of non-prescribed drugs or alcohol during work hours. If the employee comes to work under the influence of drugs or alcohol or use drugs or alcohol during work time, the employee will be terminated.

 General Safety Policy

Safety - General Policy

Providing safe working conditions and maintaining continuity of employment is of continual concern. In this regard, it is important that adequate policies and procedures be developed and adhered to in order to ensure safe, efficient operating conditions, thereby safeguarding employees and facilities.

The Company will not knowingly permit unsafe conditions to exist, nor will it permit employees to indulge in unsafe acts. Violations of Company rules and regulations will result in disciplinary action.

The Company believes that the safety of employees and physical property can best be ensured by a meaningful program.

Employee

Since the employee on the job is frequently more aware of unsafe conditions than anyone else, employees are encouraged to make recommendations, suggestions, and criticisms of unsafe conditions to their immediate supervisor so that they may be corrected.

Supervisors

Supervisors are responsible for the working conditions within their department and the plant generally. A supervisor should remain alert at all times to dangerous and unsafe conditions, so that he/she may recommend corrective action, discipline employees who habitually create or indulge in unsafe practices, assess new or changed situations for inherent dangers, and follow up on employee suggestions for corrective action so that unsafe conditions are not instituted or permitted to exist.

Safety Committee Meetings

Company operates in accordance with ISM guidelines and as such encourages the employee’s involvement in company-wide safety committee meetings to be held monthly. The committee will specify procedures and actions to be taken in the event of safety, fires, security and other emergencies. Decisions and recommendations will be communicated via the departmental team meetings.

Injuries

All employees are required to immediately report all occupational illnesses or injuries to your supervisor, no matter how minor, and complete an occupational illness or injury form.

 Declaration on Quality and Safety Policy

To maintain the highest level of safety and quality within all our activities, Vestland Marine is committed to operate to at least those requirements which are laid out in the following standards and codes:

  • The ISM Code for safe ship operation and pollution prevention.


  • The ISPS Code, the International Ship and Port Security Code.


  • To ensure that these requirements are continually met or surpassed, Vestland Marine’s senior management will be responsible for ensuring that policies and procedures are clearly defined for all personnel.
However, all persons at all levels will have their own responsibility to ensure that they carry out all duties in line with the company policy and procedures so that a high standard is achieved in a safe, controlled and efficient manner.

In order to guarantee the required levels of safety and quality.

  • All personnel will be adequately trained and qualified to at least that level for which they are responsible.


  • The correct method for managing all activities will be based on the relevant standards and regulations.


  • These relevant standards and regulations will form the basis of Vestland Marine’s procedures and instructions.


  • All personnel will have a responsibility to perform their own duties correctly every time by following the Vestland Marine’s procedures and instructions.
Maintenance of the Vestland Marine’s safety and quality system depends upon clear definition of objectives so that it can be easily understood on all levels, with the Safety and Quality manual being the main reference document. A program of constant management, supervision and auditing will ensure that all personnel are safely achieving the required levels of quality with preventive and corrective action being implemented where identified.

The benefits of the Vestland Marine’s safety and quality system will be as follows :

  • Safe working environment on board ship through improved safety.


  • Avoidance of damage to the environment through greater controls and awareness.


  • High level of quality service towards our clients who appreciate the need for safe and efficient ship operations.
Although our systems already fulfill international requirements, all Vestland Marine’s personnel are encouraged to continually find ways of improving safety, quality and environmental protection so that we can maintain our position as a leading professional ship manager.

 Manning Policy

This document lays down the criteria and policy to be conformed with in all matters relating to marine manning. Any exception to this policy is to be communicated through the President for approval before being implemented.

The reference section of the company’s document library contains the current ILO maritime conventions and STCW 95 regulations and is to be used for reference purposes. The legal requirements of these instruments must be complied with at all times.

  1. Vestland Marine’s manning companies should be the first and preferred choice for supplying or controlling all maritime manpower. In the event this is not appropriate and an external agency is used then this agency is to comply fully with this policy document.


  2. Our manning policy will always support effective ways of protecting people, property and the environment through the selection and training of safety conscious marine personnel.


  3. It will be the duty of Vestland Marine in-house negotiator to advise the external manning company of these requirements and to ensure that a system is put in place to see that they are fully complied with and, to monitor such manning arrangements.


  4. This document and its policy criteria will be monitored by the Crewing Manager responsible for marine manning and it will be the manager’s duty to bring the Presidents attention any matters not complying with the policy or needing change.


  5. The vision statement will be achieved through the application of the mission statement, and in the absence of any other criteria bring about the correct multinational balance of the personnel appointed to each vessel.


  6. Vestland Marine should continue to actively support its manning offices for reasons of strategy, economy, and effectiveness. The maritime manpower development of all other geographic areas will be monitored to ensure any expansion opportunities that arise are taken at the correct time.


  7. It will be the responsibility of the in-house manning companies to ensure that the correct seafarers contracts are in place at all times, complying fully with all aspects of this document. These companies will be responsible for all training within their jurisdiction in line with approved annual budgets that will reflect internal needs and external legal requirements.


  8. Cadet training (if such program will be established) will be supported in all locations in order to ensure a supply of quality senior officers for the company’s future needs. Such levels as will be supported will reflect the company’s manning strategy for the future, being in line with the annual budget set and approved downwards through the manning companies from Vestland Marine’s President. Each year the Crewing Manager of Vestland Marine responsible for marine manning will submit a manning document reflecting Vestland Marine’s training program for the coming five years. This will include the expenditure anticipated for the coming year and be presented in time for the President’s approval at the time that the budgets are agreed.


  9. Vestland Marine’s policy document lists all ITF/Unions and Associations currently involved with our seafarers through our manning offices. They are to be involved in the approval of agreements for manning on maritime facilities when appropriate. This policy section is to be updated over time to reflect any changes in our policy, at the same time act as a central reference point for establishing which is the appropriate union/association in any given location


  10. A scorecard matrix will apply to each vessel that comes under this policy document. This is to assist Vestland Marine’s Senior Managers to see that its manning policy is being effective. The Vestland Marine Crewing Manager for marine manning will be responsible for producing the scorecard and the mechanism under which it will operate. The Manager will chair a committee in conjunction with appropriate managers whose responsibility will be to set up the criteria for producing such a scorecard. The day-to-day monitoring and publishing of the scorecard will be the responsibility of the appropriate manning agency. This scorecard will include but not be limited to such items as expenditure against budget, performance against expectations using appraisals reports, the percentage of timely planned relief’s that take place, and safety related incidents.


  11. The appropriate substantive manning level and multi-national mix will be determined by arrangement with Vestland Marine along with the specification and job description for each substantive rank to be deployed on the vessels covered under this policy.


VESTLAND MARINE Sp. z o.o.