Company Policy Statement

Fleet Announcement – Release 10

These Policy Statements are instructed by the senior management and are valid for Zeaborn Ship Management GmbH & Cie. KG and its subsidiaries (i.e. Zeaborn Crew Management GmbH & Cie. KG, Katharinen Schiffahrt GmbH & Cie. KG), further referred to as „company“ or Zeaborn Ship Management.

1. Human rights and human resource policy

The company and its management board are committed to support and to protect the International Bill of Human Rights within their sphere of influence and throughout their business activities. The company actively participates in the United Nations Global
Compact.

All employees both on board and ashore shall be treated in a fair, just and correct manner, based on relevant international and national rules and regulations and applicable working terms and conditions.

The company and its management board do neither permit nor tolerate but will prevent any kind of discrimination and harassment of their employees on board or ashore on the grounds of race or ethnic origin, gender, religion or belief, disability, age or sexual
orientation.

The company demands and expects from its employees that each individual shall carry out the work he or she is hired for in a responsible, professional and skilled manner and do their utmost to encourage and create a human, healthy, safe, and secure working
environment.

2. Quality policy

It is the declared corporate self-conception of the company to continuously improve the performance of its entire business activities as a ship managing company for dry cargo vessels. This shall promote the aim of the company to be valued by its external and internal stakeholders for an economical, ecological and social responsible and sustainable business conduct, for highest service quality and reliability as well as for highest safety and security standards.

The company wants to develop its human and technical resources and systems in order to continuously increase the quality of services, productivity, profitability and environment protection.

The employees working in the company are regarded as a resource of high value, helping to achieve the company’s goals. They shall be committed to quality, reliability and expertise.

The vessels shall be kept well maintained in a good and efficient condition, i.e. to comply with class and mandatory requirements. All resources necessary for this purpose will be ensured by the company.

The owners shall receive all necessary information regarding the fulfilment of the management contract and any deviations from agreed standards or budgets.

Each employee shall positively support these aims and perform his or her tasks and responsibilities in a most professional way and in accordance with all applicable national and international rules and regulations as well as with all voluntary regulations with regard to quality, safety and environmental protection to which the company has subscribed.

Each employee shall inform the company about any possibility or need for improvement of day-to-day business, service or organizational subjects.

3. Health, safety and environmental protection policy

The company will assess all identified risks to its own and third party’s personnel, vessels, cargoes, to any other own or third party’s property and to the environment and establish appropriate safeguards in order to ensure that no unacceptable or avoidable risks are taken.

The company is aiming for an accident free operation of all vessels which includes a zero pollution and a zero incident strategy. The company is committed to prevent injuries and ill health, furthermore to continuously improve the occupational health and safety management and performance.

To achieve these objectives the company issues instructions complying with mandatory rules and regulations. Applicable codes, guidelines and standards recommended by the IMO, administrations, classification societies and maritime industry organizations are taken into account as well. The instructions shall also ensure the correct handling of the vessels and their equipment as well as the correct treatment of the cargo carried, in particular dangerous cargo.

The company will employ qualified staff and continuously improve their skills and abilities, including preparing for emergencies, related to occupational health, safety and environmental protection.

Safe practices in all ship operations are laid down in the respective SMS procedures. Together with a safe working environment, where each employee takes the responsibility for his / her own and others safety, they are the safeguard against all identified risks. All staff shall conduct their duties in such a way, that these objectives are ensured. The company will provide all necessary resources to achieve afore mentioned objectives.

All staff is entitled and encouraged to report non-conformities related to the SMS and any applicable international or national law, rule or regulation and to make proposals for improvement of the system to the Designated Person.

All employees have the obligation to report to their superior or supervisor all conditions that might be hazardous to their safety or to the environment.

The company provides an internal designated Environmental Whistle-Blowing-Hotline to all employees. This Whistle-Blowing-Hotline is the last resort when all other possible means of reporting incompliances with environmental rules and regulations are already exhausted.

4. Energy Efficiency Policy

Zeaborn Ship Management and its management board are committed to make responsible and efficient use of energy on board of all vessels under management, with the purpose of preserving natural resources and reducing emissions of greenhouse gases into the atmosphere. This use of energy resources provided (on board) by third parties and by the company itself is part of a sustainable and future-oriented business strategy of Zeaborn Ship Management.

The management will lead and promote energy efficiency programs and will provide all necessary resources in order to ensure that the principles of this policy are met. Objectives and targets are established and continuously reviewed to measure and improve the energy efficiency performance of the company.

Zeaborn Ship Management actively participates in and promotes further development of technologies on board of the vessels as well as of the design of its vessels to meet afore mentioned energy performance targets.

The company holds and organizes regular training and education courses for its staff to raise the awareness for the necessity of an excellent energy efficiency performance within all areas of its core business activities. All employees are expected to support and promote this energy efficiency policy and to take over any of their individual responsibilities which may be derived from the respective objectives and targets.

The company further ensures compliance with all legal and other international and national requirements and regulations related to energy consumption and consequential impacts on the environment. All rules are constantly monitored by the company to ensure the timely adaption of any changes.

5. Drug and alcohol policy

To increase the safe operation of each ship Zeaborn implemented a drug and alcohol restriction policy.

Procedures related to the drug and alcohol policy are described in Fleet-Instruction “F05 Alcohol and Drug Procedure”.

Company's Policy Statement