POLICY ON EMPLOYEE CONDUCT

Portavaga Ship Management Co., Inc. seeks to promote an environment that fosters and maintains a
high level of discipline among ALL crews. The company recognizes that the responsibility for meeting
high standards of performance and conduct on each crew.

The company expects each crew to observe high standards of conduct in the performance of his duties,
in his relationships with fellow crew and his dealings with the public and the community. For this
purpose, the Company establishes certain standards which are consistent with the Company’s
philosophy, objective, values, government policies and regulations which are necessary to enhance
harmonious and productive relationships among crew and with the public.

CLASSIFICATION OF PENALTIES

The following disciplinary actions shall be imposed as a result of infractions of company work rules and
regulations:

1. Written Reprimand (WR) – A written memorandum issued to the employee for an offense committed
warning against him that repetition of a similar offense shall be met with stiffer penalty.

2. Suspension (S) – A temporary physical detachment from service without salary. The suspended
employee shall not earn any benefit during the period of suspension such as vacation leave, sick leave,
etc.

3. Dismissal (D) – Dishonourable separation from the service. Discharge for just cause.

VIOLATIONS AND CORRESPONDING PENALTIES

The following are considered breaches of discipline which, when committed, shall have corresponding
penalties or sanctions as herein prescribed.

A violation committed by an employee shall be valid for a period of one (1) year from the time the
violation was committed.

Offenses or violations committed against the Company that are not included in the following, especially
violations of the country’s criminal laws will be subject to disciplinary action in accordance with the
circumstances of each case.

Legend for Penalties:

Written Reprimand - WR
Days of Suspension - DS
Dismissal - D
ABSENTEEISM Remedial Action Per Offense

1st 2nd 3rd 4th 5th

Reporting late to vessel ( less than 2 hours prior to vessel 3DS 10DS 30DS D
departure as determined by the Master or Company Office

Unauthorized Leave of Absence/ Absent Without WR 15DS D

Permission for one day

Unauthorized Leave of Absence/ Absent Without 10DS 30DS D

Permission for 3 consecutive days

Unauthorized absences from work without notice which D

exceeds 7 consecutive days shall constitute abandonment
of employment

Failure to report for work on the given period after 3DS 10DS 30DS D
expiration of approved leave

VIOLENCE OF COMPANY SAFETY RULES Remedial Action Per Offense

1st 2nd 3rd 4th 5th

Smoking within the vessel premises or in the place of work D

wherein such practice is prohibited

Failure to wear safety attire or uniform when prescribed 15DS 30DS D

within the vessel or company premises

Carrying of matches and lighters where such practice is D

forbidden within the vessel or company premises

Unauthorized use of life saving and fire fighting equipment 15DS 30DS D
for purposes other than the required use

Having open flames in prohibited areas within vessel D

premises/ property or place of work

Violation of ship/shore safety checklist or non- 15DS 30DS D

accomplishment of said checklist

Failure to report or attempting to cover up any reportable 15DS 30DS D

unsafe practices that may result to inquiry or damage to
property for which the company may be held liable
Failure to report immediately an accident or inquiry 15DS 30DS D
involving company personnel or any other person after
having access to information

Removing safety devices from machinery, equipment or any DS-D

other property without permission

Permitting unauthorized persons to operate company DS-D

machinery or equipment assigned to the offender

VIOLATION OF ENVIRONMENTAL SAFETY LAW Remedial Action Per Offense

1st 2nd 3rd 4th 5th

Unauthorized disposal of oily water from cargo tanks and D

engine room or pump room bilges

Negligence of crew on duty which resulted to oil spill on D

water

Littering or disposal of solid/domestic waster, bottles, D

plastic, etc

NEGLECT OF DUTY Remedial Action Per Offense

1st 2nd 3rd 4th 5th

Leaving work assignment or abandonment of post without S to D

permission and approval of the immediate superior

Simple negligence- Failure, disregard and neglect in WR to S D

discharging one’s responsibility resulting in minor loss,
damage to, or prejudice against the company.

Gross negligence resulting in serious loss or damage to the D

company

Sleeping while on duty DS-D

Failure and refusal to submit required reports to meet 7DS 15DS 30DS D
security requirements of the vessel

VIOLATION AGAINST HEALTH/ SAFETY/ SECURITY Remedial Action Per Offense

1st 2nd 3rd 4th 5th

Unauthorized carrying or possession of deadly weapons or D
explosives within Company premises

Allowing others to use one’s ID card or password to gain D

access to Company premises or to defraud the Company

Malicious mischief or any act aimed at causing alarm, panic, 30DS D

or confusion inside company premises

Deliberate and outright refusal to submit to security D

requirements.

Knowingly harboring a contagious disease which may 15DS 30DS D

endanger the health of fellow employees without notifying
the management

Acts creating or contributing to unsanitary conditions such 3DS 10DS 30DS D

as spitting, vomiting and littering

DISORDERLY CONDUCT AND MISBEHAVIOR Remedial Action Per Offense

1st 2nd 3rd 4th 5th

Gambling in any form or holding gambling operations, 15DS 30DS D

betting, lottery, or any game of chance within company
premises

Asking or accepting bribes in exchange for jobs, work DS - D

assignment or any favourable condition

Proven outright and deliberate discourtesy to client DS - D

Improper conduct or acts of gross discourtesy or rudeness DS - D

directed to clients, visitors as well as co-employees at any
time within company premises.

Intriguing or making false, defamatory or malicious WR 15DS 30DS D

statements against another employee so as to cast
dishonour, discredit or contempt on the latter.

Acts constituting threats, intimidating 30DS D

Assaulting a co-employee or any company official inside

company premises for any reason whatsoever.

Inflicting or attempting to inflict bodily harm or inquiry on 30DS D

any person
Provoking or instigating fight or fighting within company 30DS D
premises

Quarelling or using disrespectful, abusive, indecent or 30DS D

offensive language against another employee so as to cast
dishonour, discredit, or contempt on the latter.

Physical inquiry to others as caused by the offender’s D

outright deliberate action or negligence apart from paying
for moral or hospital obligations.

Drinking intoxicating beverages within the place of work D

Reporting to work or working under the influence of liquor/ S to D

alcohol or any intoxicating drink/substance

Bringing or attempting to bring prohibited hard drinks D

within the place of work

Possessing, using or causing to be used, pushing narcotic or D

prohibited drugs within company premises

Any untoward act/behaviour resulting from being under the D

influence of liquor or prohibited drugs which will prove
inimical or prejudicial to the company’s integrity and
credibility

Grossly indecent or immoral conduct within company D

premises, or acts violating moral principles, common
decency, and which proves damaging to the Company’s
credibility and integrity

Unwanted sexual advances such as kissing, embracing, or DS - S

caressing a fellow employee of the opposite or same sex

Raping or attempting to rape an employee D

Conviction of any crime with contempt D

Inducing, abetting, challenging co-employees to commit D

infractions against company policies, also includes juvenile
or playful acts of taunting others to disobey expressed
instruction

Posting on or removing from official business bulletin DS - S

boards any material without authority, also includes
vandalism
Using obscene or profane language WR 5DS 30DS D

Horse playing, Behaving loudly, making practical jokes, and WR 30DS D

pranks during working hours causing inquiry to another

Dishonesty Remedial Action Per Offense

1st 2nd 3rd 4th 5th

Forgery DS - D

Furnishing false or misleading information about the DS - D

company and/or oneself so as to possess authority in
dealing with third parties

Willful and authorized alteration, tampering or falsification DS - D

of vital company documents and records such as receipts,
vouchers, sales reports, etc. for any reason whatsoever,
particularly self gain

Unauthorized disclosure or selling of classified information, DS - D

articles, business secrets, manuals, softwares, printouts; or
permitting or assisting unauthorized persons to have access
to such classified information, or proprietary materials, to
the detriments of the Company

Conniving with another employee to defraud the company DS - D

or client

Submitting false medical or like certificates; D

misinterpretation of one’s credentials or furnishing false
information/documents to gain employment

Giving false testimony during company investigation; or D

willful concealment of evidence

Consenting to or covering up the misdeed of subordinates DS - D

or co-employees; including giving moral or technical
support to an erring employee or one charged of deviating
from company policies.

All other acts of dishonesty or deceit causing prejudice or D

damage to the company