Benetech Shipping SA

Quality Policy

BENETECH SHIPPING S.A. endeavours to earn the confidence of the shipowners, charterers,
seafarers and the marine industry and be recognized as a high quality, trustworthy international
ship manager. This can only be achieved by providing flawless services that satisfy all relevant
requirements. The Company shall always provide professional ship management services to
owners and charterers, protect their interests and assets under its care, and fulfil all their
expectations.

The Company:
• Is committed to always comply with all applicable legal and other requirements that relate to
the pertinent hazards and to continually improve the effectiveness of its IMS.
• Adopts a proactive approach concerning the needs of its clients and is responsive to their
requests, suggestions or complaints, always trying to improve the value of its services.
• Encourages employee teamwork, personal improvement, cooperation, innovative thinking,
initiative, leadership, decisiveness and focus on client’s needs and satisfaction.
• Sets measurable and meaningful objectives and targets and reviews them when appropriate.
• Addresses the needs of interested parties who receive its services or who may be impacted
by them.

In order to objectively assess its performance, the Company:
• Establishes criteria for the quality of its services.
• Monitors, measures and analyses its objectives and targets for continual suitability to verify
that processes are effectively implemented.
• Identifies and manages the risks and opportunities of its services.
The IMS defines the methods used to achieve Company’s Policies and the associated objectives
and targets. Its implementation ensures that all applicable requirements related to managing
ships will be satisfied, thus providing the necessary confidence between the Company and its
customers.

The Company’s management considers its IMS as the basic tool for providing consistent and
effective ship management service and improvement, provides sufficient resources and reviews it
regularly to ensure its continuous suitability and effectiveness. The management commits itself in
active implementation of the IMS and requires all involved personnel to do the same.
Every suggestion for improvement will be given full attention and will be brought to the highest
level of the management.

All Company’s employees, ashore and at sea, are expected to comply with this policy and work
towards achieving Company’s objectives. The success of the Company depends on the
commitment and involvement of each individual employee.
This policy is continuously reviewed for its suitability and is available to the public and the
Company’s customers, vendors and suppliers.

Environmental Policy

BENETECH SHIPPING S.A. is committed through continuous efforts to improve environmental
performance in all areas required by the international regulations and laws and Company’s IMS
and EMS and to ensure:

▪ Pollution prevention that emphasizes source reduction, including necessary funding and
human resources, to effectively maintain the on board systems, equipment and components.
▪ Continuous reduction of environmental risks.
▪ Sharing information on environmental performance with external stakeholders.
▪ Minimizing the environmental impact of its operations
The Company’s goal is to achieve Zero spills or releases to the environment and reduction
in permitted emissions through continuous improvement.
For achieving this goal, the Company:
▪ Complies with all applicable environmental laws, regulations and requirements and applies
responsible standards where laws, regulations and requirements do not exist.
▪ Responds quickly and effectively to environmental incidents resulting from its operations, in
co-operation with industry organizations and authorized government agencies.
▪ Assesses all identified risks to the environment and establishes appropriate safeguards.
▪ Shows concern and respect for the environment, emphasizes every employee’s
responsibility in environmental performance and fosters appropriate operating practices and
training.
▪ Undertakes appropriate reviews and evaluations of its operations to measure progress and
to foster compliance with this Policy.
▪ Conducts and supports research to improve understanding of the impact of its business on
the environment, to improve methods of environmental protection and to enhance its
capability to make operations compatible with the environment.
▪ Manages its business with the goal of preventing environmental incidents and of controlling
emissions and wastes to below harmful levels.
▪ Designs, operates and maintains facilities to this end.
▪ Shares its experience with others to facilitate improvements in industry performance.
This Policy has the full support of Top Management, is available to the public and applies to all
Company’s employees ashore and onboard.

Health and Hygiene Policy

BENETECH SHIPPING S.A. holds health and hygiene as first priority in its operations, while its
outmost concern is to always ensure that all employees execute their work under safe and
hygienic conditions. In order to ensure high standards of health and hygiene, the Company:

▪ Complies with all applicable legislation and regulations, observes relevant guidelines, and
applies responsible standards where laws and regulations do not exist.
▪ Seeks to identify and evaluate health and hygiene risks related to its operations that
potentially affect employees, contractors or the public and establishes appropriate
safeguards.
▪ Communicates knowledge about health and hygiene risks to individuals in potential risk or
organizations and the scientific community.
▪ Determines at the time of employment and thereafter, as appropriate, the medical fitness of
employees to perform their work without undue risk to themselves or others.
▪ Implements programs and appropriate protective measures to control such risks, including
appropriate monitoring of employees in potential risk.
▪ Provides or arranges, as appropriate, for medical services necessary for the treatment of
employee occupational illnesses or injuries and for the handling of medical emergencies.
▪ Provides voluntary health and hygiene promotion programs designed to enhance employees’
well-being and personal safety. These programs should supplement, but not interfere with,
the responsibility of employees over their own health care.
▪ Undertakes appropriate reviews and evaluations of its operations to measure progress and
to foster compliance with this Policy.

The Company’s goal is to achieve the highest standards of health and personal hygiene
through continuous improvement.

Information about employees are confidential and should not be revealed to non-medical
personnel except at the request of the employee concerned, or when required by law, when
dictated by overriding public health considerations, or when necessitated by the Company’s Drug
and Alcohol Policy.

This Policy has the full support of Top Management, is available to the public and applies to all
Company’s employees.

Energy Efficiency Management Policy

BENETECH SHIPPING S.A, having established and implementing an Environmental
Management System in accordance with ISO 14001, believes that although shipping is by far the
most fuel-efficient mode of transport, nevertheless additional action has to be taken to further
improve the energy efficiency of ship related operations. The increased energy efficiency
eventually results in increased environmental protection by reducing air emissions.

Energy efficiency is controlled primarily through well-planned and properly managed ship
operations and needs the personal commitment of everyone involved in the above tasks. To be
successful, energy efficiency and conservation must become part of the day to day operation and
living onboard.

In our efforts to enhance the energy efficiency on the shipboard operations, the Company is
committed to:
▪ Establishing and maintaining a Ship Energy Efficiency Management Plan (SEEMP) which is
regularly reviewed by all concerned departments and approved by the management of the
Company. This Plan, which applies to all fleet vessels, provides standard procedures and
practices on best energy management under the various operational modes of the vessel.
▪ Implementing an Environmental Management System supported with several environmental
programs with the objective of continually increasing energy efficiency and minimizing
energy waste. A set of time-specific, measurable – whenever practicable – and achievable
targets shall be established and maintained, which shall relate to a combination of design
optimization, in-service performance monitoring and best-practice operational management
processes.
▪ Promoting energy efficiency awareness through training to the shore and sea-going
personnel and implementing energy related Campaigns and other personnel
incentive/motivating programs.
▪ Monitoring and complying with all applicable legal requirements related to ship energy
efficiency management.
This Policy shall be periodically reviewed with the aim of being kept always updated so as to
function as the “leading light” towards a continual energy efficiency improved performance.

Drug and Alcohol Policy

It is the Company’s Policy that NO seafarer, whatever rank, will navigate the vessel or will
operate its equipment while impaired by drugs or alcohol or where there is any risk of such
impairment.

In following this Policy, BENETECH SHIPPING S.A.:

▪ Has banned all alcoholic beverages from its managed vessels.
▪ Has banned any form of drug, with the exception of prescribed drugs, as well as the misuse
of legitimate drugs. If a crewmember is found in possession of drugs then the Local
Authorities will be contacted immediately.
▪ Has implemented random testing of all crew for banned substances and alcohol.
▪ Controls the use of all medical supplies on board the managed vessels.

▪ Will dismiss and impose penalty, as per National and International regulations, to anybody:

• using alcohol or banned substances on board the vessel;
• caught in possession of alcohol or banned substances;
• found to have been instrumental in bringing alcohol or banned substances on board;
• found to have a positive trace in any random testing sample, unless prior notice with
  authorisation for use, had been given to the Master.
• On no account shall a person under the influence of drugs or alcohol, be allowed to stand
  watch or perform any other duty, involving the safety of the vessel, her crew or cargo, and
  the public.
• Will take all disciplinary action, including dismissal, against anybody consuming alcohol,
  while ashore, for at least 4 hrs prior scheduled watchkeeping duties or work period.
• Any crewmember suspected for being under the influence of drugs or alcohol, while on duty,
  shall be immediately relieved from his duty and placed under observation until the influence
  of drugs or alcohol subsides.
• All crewmembers understand that it is their duty and benefit, to report immediately to the
  appropriate Officer or the Master, if they suspect or have evidence that one of their fellow
  crewmembers is intoxicated.
• The use of alcohol on the part of the pilot while performing his duties is strictly prohibited; if a
  pilot is noticed to be under the influence of substances resulting to the incapability of
  performing his duties will not be allowed to be part of the bridge team.
• Requires all new recruits, prior their embarkation, to undergo a Drug and Alcohol test.
  All employees must be adequately informed on the provisions of this Policy and must comply with
  their intent. This Policy has the full support of Top Management and applies to all employees.

Cyber Security Policy

BENETECH SHIPPING S.A. aims to:

▪ Protect information assets – including data printed or written on paper, stored electronically,
transmitted by post or electronic means, stored on tape or video, or spoken in conversation –
from all threats, whether internal or external, deliberate or accidental.
▪ Make sure operations continuity.

The Company’s management, to fulfill these objectives, is committed to ensure:

▪ Compliance with regulatory requirements
▪ Protection of information and systems identified as vulnerable to cyberattacks from loss of
confidentiality (information accessibility only to authorized individuals), integrity (safeguard
accuracy and completeness of information and processing methods), and availability (authorized
individuals have access to relevant information when required)
▪ Preparation of cybersecurity contingency plans
▪ Cybersecurity training to all staff
▪ Reporting and investigation of all security breaches, actual or suspected.

To support this Policy, there are procedures in place, including incident handling, information backup,
system access, antivirus controls, passwords, and encryption

Social Media Policy

This policy outlines the necessary principles that users of social media shall observe, the
conditions in which Internet activity will be monitored and actions to be taken upon violation of the
established policy. The Company, expects all individuals to comply with this policy at all times
and to protect the Company’s reputation.
This policy deals with the use and misuse of social media platforms and other websites including
but not limited to:
• Social networking websites such as Facebook, CrewToo, MySpace, LinkedIn, Yahoo!
Groups, QQ.com, VK.com .
• Micromedia / Microblogging websites such as Twitter.
• Multimedia websites such as YouTube and Instagram.
• Wikis such as Wikipedia.
• Blogs and
• News sites where content and comments can be posted.
• Any other website where user-generated content can be posted for wider sharing.
This policy applies to all individuals working at all levels in the Company, either in the office or on
board the vessels and covers the use of social media (as outlined above) during work and nonwork
hours, on personal and Company supplied equipment such as laptop computers and
cellular / smart phones.
The Managing Director, Heads of Departments and ships’ Masters are responsible for ensuring
that the standards set forth by this policy are communicated to their teams and that their own
conduct sets a good example in this respect.
The Company recognizes the value of social media and expects all staff to use these tools
responsibly.
The following basic principles should be observed:
• Be responsible. As an employee, any user-generated content could have an impact on the
Company’s reputation, so give careful thought before sharing photographs or video of the
Company assets, particularly our ships, facilities or people in uniform. For example, images
taken during an incident could potentially be detrimental to an investigation.
• Be accurate and honest. In any circumstance in which you are in doubt, or you are uncertain
about how to respond to a post, contact the Company for guidance.
• Do not make posts or comments that may be considered defamatory, obscene, libellous,
threatening, harassing or embarrassing to others.
• Before you post photographs of other people, get their permission first.
• Never use someone else’s copyrights, copyrighted material, trademarks, service marks or
other intellectual property.
• If you see comments relating to the Company that you think should be addressed, contact
the Company for guidance.
• Do not use the Company’s logo (in any form) on any personal social media platform. Use of
any Company logo must be approved by the Company.
• Respect others in any online social interaction. Do not use social media or any similar form
of communication to attack or insult the Company, fellow employees, customers, vendors,
contractors, suppliers, competitors or others.
• Do not disclose any confidential, proprietary or sensitive information about the Company as
well as names of our employees, customers, vendors, contractors, suppliers, competitors or
others. Employees are reminded of Company’s policy on public statements / media
response.