1. OCCUPATIONAL HEALTH AND SAFETY
It is the Company’s Policy to provide a safe and healthy workplace environment for shore based and shipboard personnel and the Company is committed to:
- Prevent loss of life, work-related injury or illness by promoting safe and healthy practices and proper planning and execution of operations.
- Comply with applicable requirements that relate to Occupational Health and Safety (OH&S).
- Establish its own standards and guidelines where existing laws and regulations are not adequate to assure protection to human health and safety.
- Establish clear OH&S objectives and targets towards minimizing risk potentials and protect all staff working on board ships by the use of appropriate technology and operating procedures.
- Encourage all individuals to identify potentially unsafe conditions or unlawful practices and to undertake corrective measures.
- Provide all its employees with information, equipment and training necessary for them to carry out their work safely.
- Ensure that regular safety and contingency drills are conducted by the Master and at times supervised by the shore based personnel for ensuring that relevant personnel are fully conversant with their duties so as to maintain a confident and proficient team on board to deal with all contingencies and emergencies.
- Ensure that Safety is uppermost in mind in all Company instructions.
- Continuous improvement in OH&S management and OH&S performance.
2. ETHICS AND NON-RETALIATION
It is the Company’s Policy to ensure that all shore based and ship based personnel carry out their duties in an ethical and honest manner ensuring that they exhibit the highest standards of integrity and righteousness at all times. The Company is committed to:
- Ensure that no shore based employee or personnel onboard ships under Management, participates in any incentive or bonus programs based on minimizing operational costs associated with the operation, maintenance, and repair of machinery space systems, equipment, and components without ensuring that efficiency and performance are maintained. The intent of this is to ensure that staff do not avoid such costs and thereby sacrifice required level of compliance.
- Take appropriate action, up to and including dismissal, against any shore based employee or personnel onboard ships under Management who obstruct, hinder or present false information, or make false statements during any inspection; monitoring or audit carried out by any authority whatsoever.
- Ensure that NO shore based employee or personnel onboard ships under Management are punished, discriminated against or otherwise suffers negative consequences for reporting violations of QHSE laws, regulations, or policies.
- Take disciplinary action up to and including dismissal against any shore based employee or personnel onboard ships under Management who depart from specified operating policies and procedures.
Shore based employees and personnel onboard ships under Management may also be personally liable for criminal, civil or administrative penalties as a result of non-compliance.
3. HARASSMENT IN THE WORKPLACE POLICY
Company is committed to providing a work environment which is free from harassment. It is the Company policy to prohibit any form of harassment in any workplace whether in the office or onboard company managed ships.
Harassment covers a range of behaviours, including subtle and not-so-subtle, verbal and non-verbal behaviour. It can be engaged in or experienced by both males and females. The Company will not tolerate any form of harassment at any level. Harassment includes:
- Telling jokes or making verbal or physical innuendoes which are unwelcome and explicitly or implicitly belittle an individual’s sex, race, colour, religion, sexual orientation, gender identity, national origin, ancestry, disability, or age.
- Engaging in verbal or physical conduct of a sexual nature, including (for example) conduct that expressly or implicitly constitutes an unwelcome sexual advance or a request for sexual acts or favours
- Making an unwelcome verbal request of a sexual nature, e.g. suggestions that sexual cooperation will affect an employment decision or is a condition of an individuals continued employment
- Taking or failing to take a personnel action (e.g. firing, demoting, failing to promote) in reprisal for an employee’s rejecting or reporting an inappropriate conduct of a sexual nature
- Failing to take appropriate action in response to an employee’s reporting a harassing conduct (e.g. failing to investigate charges)
- Creating an intimidating, hostile, humiliating, or offensive work environment by means of verbal or physical conduct of a harassing nature
- Subjecting others to obscenity or offensive language (which might include displaying offensive or sexually suggestive photographs, objects, pictures, cartoons, graffiti, etc., using offensive language in situations where others are certain to hear it, and similar conduct);
- Graphic commentary about an individual’s body, sexual prowess or sexual deficiencies, or
- Leering, whistling, touching, pinching, assault.
This kind of behaviour is unacceptable both in offices and in any work-related setting outside our offices such as during business trips, on office outings, at parties, business-related social events and on board company managed ships.
The Company will follow local laws and regulations in terms of procedure in jurisdictions where a certain procedure is mandated.
4. DRUG AND ALCOHOL
The Company is committed to maintain a safe and healthy working environment, free from the unauthorised use of drugs and alcohol, for all employees.
The Company recognizes that alcohol, drug, or other substance abuse by employees may impair their ability to perform properly and will have serious adverse effects on the safety, efficiency and productivity of other employees and the Company as a whole. The misuse of legitimate drugs, or the use, possession, distribution or sale of illicit or un-prescribed drugs on company business or Company ships, is strictly prohibited and is grounds for termination. Being unfit for work because of use of alcohol or drugs is strictly prohibited and is grounds for termination of employment.
The Company may conduct unannounced searches for alcohol and/or drugs on Company ships. Unannounced periodic or random testing will be conducted when an employee meets any one of the following conditions:
- either the Individual has had a substance abuse problem
- or is working in a designated position identified by the Company
- or in a position where testing is required by law
A confirmed positive test result or refusal to submit to an alcohol or drug test is grounds for disciplinary action, including termination.
Reasons for such testing may include:
- for cause
- reasonable suspicion
- random types of testing
Contractors sailing as ship’s complement are subject to the provisions of the Company’s Drug & Alcohol Policy and Procedures. Visitors, contractors and vendor’s personnel will be subject to the same standards for search and inspection as the ship’s complement in regard to alcohol, drugs and controlled or illegal substances while on Company ships. Failure to comply with this Policy in this regard may result in removal from the ship and denial of future access.
It is the Company’s Policy to work towards a cleaner marine environment and the Company is committed to:
- Firmly support the International Convention for the Prevention of Pollution from Ships (MARPOL) and other environmental requirements and believing that the first line of defence against pollution must be to avoid accidents occurring.
- Comply with applicable marine environmental protection requirements established under International, Flag State, Port State and Coastal State Laws including but not limited to the International Convention for the Prevention of Pollution from Ships (MARPOL), concerning the use of Oily Water Separators, Oil Content Meters, Incinerators and other Pollution Prevention Equipment.
Company is committed to achieve Zero spill with continuous improvements through:
- Continuous improvement in environmental performance, including those areas in the Environmental Management System.
- Pollution prevention with an emphasis on source reduction, including the funding and human resources necessary to effectively maintain and repair the systems, equipment, and components found in machinery spaces of vessels.
- Continuous reduction of environmental risks.
- Sharing information with external stakeholders on environmental performance.
- Undertake steps in energy conservation to help address the problem of depleting natural resources and its impact on the environment.
Company has a Zero Tolerance approach to any non-compliance/violation of above policy and will extend fill cooperation to authorities in brining offenders to books.
The Company recognises that safety, environment protection, pollution prevention and efficiency are an integral part of good ship management which can only be a result of a combination of right skills, knowledge and experience ashore and onboard vessels.
In order to accomplish the desired objectives as well as provide and maintain the highest standards of ship management, the company is committed to:
- Employ staff having adequate qualifications, skills, knowledge and experience to serve in the rank or position they have been selected for.
- Employ only those seafarers who are mentally and physically sound and medically fit to effectively execute the set objectives of the Company.
- Inculcate a sense of loyalty and dedication and to encourage a sense of belonging to become long serving employees of the Company.
- Provide staff ashore and afloat with information and training necessary for them to fully understand the Company’s QHSE System.
- Ensure that compliance with the QHSE standards is a key ingredient in the identification of training needs and performance reviews of shore and shipboard personnel.
It is the Company’s policy to:
- Provide a secure working environment, by establishing and maintaining the required security measures to prevent unlawful acts against ships which endanger the safety and security of persons/property on board and the environment.
- Ensure that the Master, Company Security Officer and the Ship Security Officer are given necessary support to fulfil their duties and responsibilities in accordance with IMO’s draft amendments to SOLAS Chapter XI-2 and the ISPS Code.
The Master has the overriding authority and responsibility to make decisions regarding the security of the ship and to request the assistance of the Company or of any Contracting Government as may be necessary.
All Company employees, ashore and on board ships, are expected to comply with the required procedures within the Ship Security Plan and should be familiar with the relevant security duties required of them and the measures required to protect the ship from any unlawful act.
Complying with and maintaining ship security is a continuous process and as new potential threats are uncovered, additional security procedures and measures shall be devised and implemented.
8. SOCIAL MEDIA POLICY
It is the Company’s policy to ensure that that all shore based and ship based personnel use the internet in a responsible manner. All are personally responsible for the content they publish on-line, whether in a blog, social computing site or any other form of user-generated media. Be mindful that what you publish will be public for a long time.
- They should be careful about what information and images they make available to others on the Internet about the Company and Company’s managed vessels.
- Do not act in an inappropriate manner, intentionally or otherwise, and do not communicate any confidential information or other sensitive matters online and to third parties.
- Do not publish content that might allow inferences to be drawn which could damage Company’s reputation or any relationship with the Company.
- Do not use ethnic slurs, discriminatory remarks, personal insults, obscenity, or engage in any similar conduct.
- Show proper consideration for others’ privacy.
All Company employees, ashore and on board ships, are expected to comply with the required procedures within the Safety Management System pertaining to Social Media and appropriate use of internet.