It is the standard practice of the company not to employ any crew below the age of 18 onboard the vessels under the company’s management. Compliance is verified during employment process by the appointed and duly registered recruitment and placement service under the supervision of the DPA. Additionally, this is verified during internal inspections and audits by authorized company personnel.

Any non-conformities will be reported, investigated and followed up in accordance with the relevant management system procedures.

No seafarer shall be employed without a valid Medical Certificate, which was issued by a licensed medical practitioner authorized to conduct medical fitness examinations for seafarers in the country of examination (provided the authorization is accepted by the Flag State).

Certificates must conform to the standards described by STCW and issued following the procedures set out in the ILO/WHO Guidelines. Certificates issued by countries that are signatories to the STCW Convention are accepted. If the medical certificate expires in the course of a voyage, the certificate remain in force until the next port of call where the seafarer can obtain a new medical certificate from a qualified medical practitioner, provided that the period shall not exceed 3 (three) months.

The medical certificate must be provided in the English Language in addition to any other language.

Compliance is verified during employment process by the appointed and duly registered recruitment and placement service. The Master verifies the medical fitness certificate during the sign-on process.

Compliance with DMLC Part I is additionally verified during internal inspections and audits by authorized company personnel. Any non-conformities will be reported, investigated and followed up in accordance with the relevant management system procedures.

All seafarers are qualified and trained as per STCW'95 (as amended) and applicable Flag State requirements. All seafarers hold all documents as required by the Flag State. Cooks shall be trained and

certified by a training facility approved/authorized by the national authority or shall have other adequate training records. The appointed and duly registered recruitment and placement service will select and employ only those who meet the above requirements.

Prior to commencement of duties, all seafarers will be familiarized with their duties onboard, in accordance with relevant existing management procedures.

Compliance is verified during the employment process by the appointed and duly registered recruitment and placement service. The Master shall crosscheck all required documents and certificates during each crew change. Compliance with DMLC Part I is additionally verified during internal inspections and audits performed by authorized company personnel. Any non-conformities will be reported, investigated and followed up in accordance with the relevant management system procedures.

All seafarers will be given sufficient time to verify the content of the Seafarers Employment Agreement (SEA) and to seek advice - if needed - before signing it.

The SEA, with electronic signature, will be provided to each seafarer via email. The discharge book must be properly filled; when signing off no remarks about wages nor the quality of work will be made. Termination notice: as per Terms and Condition of Employment. All documents of the contract are available on board for the Master and Flag State inspector.

Compliance is verified during employment process by the appointed and duly registered recruitment and placement service under the supervision of the DPA. The Master will verify the existence of a valid SEA during the sign-on process.

Compliance with DMLC Part I is additionally verified during internal inspections and audits, by authorized company personnel. Any non-conformities will be reported, investigated and followed up in accordance with the relevant management system procedures .

This MLC Shipowner monitors all crewing activities. Seafarers may be employed directly or through the appointed and duly registered recruitment and placement service.

The responsibilities between the Owner and appointed and duly registered recruitment and placement service are clearly documented in a letter of engagement. These are available on board and accessible to each crewmember on board.

The DPA will ensure that the Master is provided with up-to-date evidence that all recruitment and placement services are in compliance with MLC 1.4.

Compliance with DMLC Part I is additionally verified during internal inspections and audits by authorized company personnel. Any non-conformities will be reported, investigated and followed up in accordance with the relevant management system procedures.

The Master is responsible to draft and post a table of shipboard working arrangements in the ILO/ IMO format.

Each seafarer shall have a minimum of 10 hours rest in any 24 hours period, and 77 hours in any seven-day period. The 10 (ten) hours of rest may be broken into no more than two periods, one of which shall consist of at least 6 (six) consecutive hours off duty. The interval between consecutive periods of rest shall not exceed 14 (fourteen) hours.

The Master shall ensure that the minimum rest hours are provided to each seafarer. Adequate compensation for call outs must be provided. Records to be kept on board; the seafarer will be provided with a copy. Drills and Exercises will be conducted in such manner so as to minimize the disturbance of rest periods and not to induce fatigue. The Master has the "overriding authority" for emergency situations to suspend the rest hours. Afterwards, the Master will provide adequate rest periods to all relevant seafarers. The Master verifies and ensures compliance to hours of rest or work requirements on board.

Additionally, compliance is verified by authorized company personnel on a monthly basis (during receipt of rest hours records) and during internal inspections and audits. Any non-conformities will be reported, investigated and followed up in accordance with the relevant management system procedures.

M-0303 Record of Rest Hours

M-0304 Table of Shipboard Working Arrangement

The Managing Director of the MLC Shipowner will set the manning level in accordance with the Minimum Safe Manning certificate issued by the Flag State and with a sufficient number of properly qualified and certified seafarers to avoid fatigue of seafarers.

The Master shall crosscheck at each crew change that these requirements are met i.e. that the required original certificates are available on board.

Compliance is verified during employment process by the appointed and duly registered recruitment and placement service under the supervision of the DPA. Authorized company personnel will additionally verify compliance to this regulation during internal inspections and audits. Any non-conformities will be reported, investigated and followed up in accordance with the relevant management system procedures.

The vessel was surveyed and certificated by a Recognized Organization as fully compliant with ILO 92/ 133. Separate sleeping rooms for men and women are provided. The A/C provides adequate ventilation, temperature and humidity in all sleeping and mess rooms. Sufficient lighting is available to

read a standard newspaper. Laundry is available to each seafarer. Recreational facilities are free of charge. The Master shall inspect the vessel as follows: every 4 weeks from top-to-bottom, the galley and provision stores and crew cabins every week. Results of inspections and its follow up must be recorded in the deck log book and records kept for at least three (3) years. Appropriate counter measures shall be initiated as directed by the Master, with the support of the vessel’s superintendent if and as required.

Authorized company personnel additionally verify compliance to this regulation during internal inspections and audits. Any non-conformities will be reported, investigated and followed up in accordance with the relevant management system procedures.

M-0401 Monthly Condition Report

The following facilities are available on board:

• Gym equipment
• TV/DVD Player
• Satellite dish/receiver
• internet

During the inspection performed every 4 weeks by the Master, he shall ensure that recreational facilities are in good working order.

The Master will ensure that any deficiencies will be rectified without unreasonable delay with the support of the vessel’s superintendent if/as required.

Authorized company personnel additionally verify compliance to this regulation during internal inspections and audits. Any non-conformities will be reported, investigated and followed up in accordance with the relevant management system procedures.

The MLC Shipowner provides adequate food and drinking water to all seafarers free of charge. The Master shall assure that only appropriate provisions will be received on board. Menus and meal plans will assist the Master and cook to assure adequate food of appropriate quality, nutritional value and quantity.

The appointed and duly registered recruitment and placement service and the Master ensure that every on-signing cook has the necessary training certificate(s), references and experience.

The Master and the vessel’s Superintendent ensure that the galley is properly equipped with the necessary tools and supplies for cooking and serving meals

The cook shall monitor the temperature of the cold stores. The log sheet shall be posted somewhere close to the stores. The drinking water (potable water) shall be analyzed every 12 months (max.). The certificate shall be filed on board for at least 3 years.

Galley and provision rooms will be inspected by the Master every week and the results recorded in the vessel’s logbook. The records must be kept for at least 3 years.

Authorized company personnel additionally verify compliance to this regulation during internal inspections and audits. Any non-conformities will be reported, investigated and followed up in accordance with the relevant management system procedures.

M-0704 Provision Stores Temp Log

The Master has the overall responsibility and overriding authority to implement the company’s HSEQ policy and procedures with full support of all relevant departments ashore.

Risk assessment procedures are documented and implemented. Regular safety training is held on board (as per Training Program/Plan). Any additional occupational health and safety training needs will be verified and identified by the Master, and recorded in the evaluation forms and submitted to the crewing department/ appointed and duly authorized recruitment and placement service, for further action.

A shipboard safety committee under the chairmanship of the Master has been established in accordance with ILO guidelines and meets monthly to discuss all open health and safety matters. The Master also ensures that all safety committee members receive appropriate training.

Accidents and Near Miss reports will be analyzed in accordance with established management system procedures.

Authorized company personnel additionally verify compliance to this regulation during internal inspections and audits. Any non-conformities will be reported, investigated and followed up in accordance with the relevant management system procedures.

Health and Safety Policy

Risk Assessments

SO-0200 Safety Officers Log Book

SO-0201 Training-/Exercise-/Drill Plan

M-1010 Crew Evaluation Report

SO-0203 Pre-Briefing Booklet

Reporting Procedure

Other supporting documents:

ILO safety guide

IMO MSC-MEPC.2/Circ.3

The superintendent and the Master are responsible that the vessel is equipped with a medical chest in accordance with Flag State requirements. The medical chest shall be inspected and certificated annually by a qualified ship pharmacist. The Master or an appointed officer with medical care certificate under his supervision will ensure full compliance between the external inspections.

Seafarers are promptly provided with free of charge medical care on board and ashore as well. The Master is trained, equipped and authorized to seek radio medical advice at his discretion.

Authorized company personnel additionally verify compliance to this regulation during internal inspections and audits. Any non-conformities will be reported, investigated and followed up in accordance with the relevant management system procedure.

2M-06 Medical Care

M-1001 Medical Report Form

Other relevant documents (PIC 2nd Mate):

• International Medical Guide for Ships (WHO)
• MFAG
• MSDS for dangerous good not listed in the IMDG code
• ITU Publications
• List of Radio Stations
• MEDICO contacts

The on-board complaint procedure has been made available to each seafarer inside the Seafarer Employment Agreement (SEA) and Pre-boarding booklet, and a hardcopy will be made available inside the MLC folder (in the mess rooms and/or recreation rooms if available). During the on-board familiarization process, the seafarer will be informed about the procedure. A hardcopy of the MLC 2006 is available to each seafarer in the MLC folder, contact details for complaints to the Flag and the country of residence are provided in Seafarer Employment Agreement and Pre-Boarding Booklet. This way, each seafarer has permanent access to the procedure.

Following complaint procedures are implemented on board by MLC Shipowner:

a) Complaints are addressed to the head of the department in which the seafarer works or to his superior officer,

b) Resolution is attempted by the head of department or the senior officer within 24 hours whenever practicable,

c) When resolution by the head of department or the superior officer is not successful the seafarer can take the matter to the Master who shall deal with it within a stated period which should be not less than 3 days,

d) Any seafarer making a complaint is allowed to be accompanied and to be represented by another seafarer of their choice on board the ship,

e) All complaints and the decisions made are recorded and a copy of the record is made available to the seafarer concerned, and

f) When a complaint cannot be resolved on board it is referred to the MLC Shipowner or his representative ashore who shall resolve the matter within one month.

The Master verifies and ensures that the entire crew has access to the compliant facilities on-board. Authorized company personnel additionally verify compliance to this regulation during internal inspections and audits. Any non-conformities will be reported, investigated and followed up in accordance with the relevant management system procedures.

SO-0203 Pre-Boarding Briefing Booklet

M-1025 Crew Complaint Report

This way, each seafarer has permanent access to the procedure.

On behalf of the MLC Shipowner, the appointed and duly registered recruitment and placement service will pay the monthly wages to the seafarer’s bank account. No bank transfer charges will be deducted. All records concerning the payment of wages will be made available on board such as monthly wages account, payrolls, and allotment orders, final wages account. All such records are held by the Master and kept confidential. Payment slips will be sent by the appointed and duly registered recruitment and placement service to Master and it will be provided to individual seafarer.

The MLC Shipowner will verify and ensure proper and timely payment of wages for the crew.

Authorized company personnel will verify compliance to this regulation during internal inspections and audits. Any non-conformities will be reported, investigated and followed up in accordance with the relevant management system procedures.

The registered owner of the vessel maintains at all times third party liability insurance covering any default in meeting the owner’s repatriation obligations. Such proof will be annually provided to the Office of the Deputy Commissioner. The certificate or any other documentary evidence of financial security in English issued by a financial security provider is posted on board in a conspicuous place.

The financial security ensures the seafarers repatriation in the event of their abandonment and provides direct access, sufficient coverage and expedited financial assistance.

The Master verifies and ensures that a copy of the ‘Financial Security Certificate’ is available on-board. Authorized company personnel additionally verify compliance to this regulation during internal inspections and audits

The DPA will ensure that the Master and crew receive prior notification if the ship owner’s financial security is to be cancelled or terminated, e,g. in course of a change of the financial security provider. Any non-conformities will be reported, investigated and followed up in accordance with the relevant management system procedures

The registered owner of the vessel maintains at all times third party liability insurance covering any default in meeting the owner’s repatriation obligations. Such proof will be annually provided to the Office of the Deputy Commissioner. The certificate or any other documentary evidence of financial security in English issued by a financial security provider is posted on board in a conspicuous place.

The financial security ensures the seafarers repatriation in the event of their abandonment and provides direct access, sufficient coverage and expedited financial assistance.

The Master verifies and ensures that a copy of the ‘Financial Security Certificate’ is available on-board. Authorized company personnel additionally verify compliance to this regulation during internal inspections and audits.

The DPA will ensure that the Master and crew receive prior notification if the ship owner’s financial security is to be cancelled or terminated, e,g. in course of a change of the financial security provider. Any non-conformities will be reported, investigated and followed up in accordance with the relevant management system procedures.