HSEQ POLICY

Nippon India Ship Management(“NISM”), its Directors and Senior Management are fully committed to a ZERO TOLERANCE policy ensuring that the waters on which its ships operate are protected from pollution and continuously strive to identify and correct any conditions perceived to be unsafe and hazardous to the environment.

The objective of the Company is to prevent pollution of the environment from the following sources related to the aspects of its operations:

Oil, Noxious Liquid Substances, Sewage, Garbage, Dangerous Goods, Ballast Water, Cargo Vapour and Engine Emissions, Refrigerants, Halons and CFCs, Noise, Anti-Fouling Paints, Sludge, Bilge Water, Tank Cleaning Residue, Effluent Discharges.

To achieve these goals, the Company will:

• Comply with all applicable legislation and other requirements to which the Company subscribes, which relate to its environmental aspects and strive, where practicable, to exceed compliance requirements
• Assess on a continual basis the environmental risks associated with its operations, setting appropriate objectives and targets and implementing environmental programs to minimise the environmental impact of its operations by reducing waste, emissions and discharges, by minimising its impact on biodiversity and by using energy efficiently
• Promote environmental awareness through the training and education of its employees
• Respond quickly and effectively to pollution incidents resulting from its operations, in co-operation with industry organisations and authorised government agencies
• Engage with shipping industry organisations and relevant authorities and participate and support research initiatives with the aim of developing measures to minimise the shipping industry’s impact on the environment
• Communicate its Environmental Policy to the public

The Company places the health of its employees among its top priorities and seeks to ensure that all shore staff and seagoing personnel execute their work under healthy and hygienic conditions.

In order to ensure high standards of health and personal hygiene it is the Company’s Policy to:

• Comply with all applicable laws and regulations, and apply responsible standards where laws and regulations do not exist
• Identify, evaluate and minimise health and hygiene risks related to its operations that potentially affect its employees, contractors or the public
• Communicate knowledge about health and hygiene risks to its employees and where appropriate to maritime community
• Determine at the time of employment, and from time to time thereafter, the medical fitness of employees to do their work without undue risk to themselves or others
• Provide or arrange for medical services necessary for the treatment of employee occupational illnesses or injuries and for the handling of medical emergencies
• Undertake appropriate reviews and evaluations of its operations to measure progress and to foster compliance with this Policy
• Implement programs and appropriate protective measures to control health risks
• Work with government agencies and others to develop responsible laws, regulations and standards, based on sound science and consideration of risk
• Provide voluntary health and hygiene promotion programs designed to enhance employee wellbeing and personal safety. These programs should supplement, but not interfere with, the responsibility of employees for their own health care. Information about employees obtained through the implementation of these programs should be considered confidential and should not be revealed to non-medical personnel except at the request of the employee concerned, when required by law, when dictated by overriding public health considerations, or when necessary to implement the Company’s Drug and Alcohol Policy.

It is the Policy of the Company to conduct business in an honest, sincere lawful and ethical manner. Acts of bribery and corruption are condemned and the Company is committed to act professionally, fairly and with dignity and integrity in all business dealings and relationships. This is irrespective of the exact time and location of any operation. Effective systems such as the auditing of accounts are in place to counter bribery and corruption.

In addition to the above principle the Company will respect all laws (international laws and those local laws that have become known to us through the appointment of local Agents in foreign countries) in an effort to counter bribery and corruption. Bribery and corruption are punishable for individuals committing a relevant offence and the Company could face severe consequences that could include imprisonment, fines and damage of its reputation.

The Company employees should always act on a good faith basis, enter into commitments that are feasible to be met, fulfil the Company obligations, never mislead people, never participate in corrupt business practices, and treat people with merit and respect.

Sometimes ethical decisions involve dilemmas; in such cases it is necessary for the relevant issues to be brought to the attention of the Company management and employees should seek instructions within the framework of this policy.

This policy is applicable to both shore and shipboard employees at all levels.

Drug and Alcohol (D&A) abuse is one of the major social problems of today’s world. Within the shipping industry, Maritime Authorities and Organisations, having identified the negative effects on ships’ safety, have issued strict regulations and instructions to control D&A use, abuse and drug trafficking.

Nippon India Ship Management, recognising the importance of the issue, has adopted the following Policies:

• The possession, use, trafficking and sale of drugs aboard the Company’s vessels is prohibited and is viewed as a severe offence
• Any crew-member found involved in any drug related activity will be discharged at the first port of call and his future employment with the Company cancelled. Depending on the nature of involvement Authorities may be notified and/or legal prosecution may be initiated
• Use of prescribed drugs for medical treatment is allowed only under controlled conditions and following specific medical advice
• Drugs kept in medical chest must be locked under Master’s responsibility and control
• No spirits are allowed on board
• Alcoholic beverages and spirits are not allowed in crew quarters
• No consumption of alcohol is allowed when the ship is in port
• Consumption of alcohol (only beer) at sea is allowed with meals under controlled conditions
• Watch-keeping personnel must abstain from alcohol for at least 4 hours prior to taking over watch at sea
• Blood alcohol content of 40mg/100ml or greater is considered as alcohol impairment
• All officers and ratings are subject to pre-employment D&A test
• Unannounced drug and/or alcohol tests will be carried out as per Company’s instructions. Equipment for alcohol test is available aboard all Company ships

Compliance with this policy is mandatory for all Company’s shipboard personnel, as well as, for all persons boarding the ship under any capacity.

The Master is responsible to ensure compliance and enforce appropriate measures as per Company’s instructions.

This regulating policy applies to all Company personnel during their employment period whether onboard or ashore.

NISM – General Conditions of Purchase and Services-01.09.2021