2017.12.29 TMSA 3 Submission

Tanker Management and Self Assessment 3
A BEST-PRACTICE GUIDE FOR SHIP OPERATORS
Report name AIWK-7513-6571-3948

Date published 29 Dec 2017
Operator account 20639
Operator name Borealis Denizcilik AS
DOC number
IMO number 5925485
Address Sahrayicedid Mah. Halk Sok. No:52/8, Siddiklar Is
Merkezi, istanbul,
County/State kadikoy
Post code 34734
Country Turkey
© Copyright OCIMF 2017 TMSA Report ID AIWK-7513-6571-3948 1/56

Management, Leadership and Accountability
Stage 1
1.1.1 Management commitment is clearly defined in documentation that includes Yes
mission statements, policies and procedures.
Company Policies and SMS define the Company’s philosophy aiming to continuous upgrading the
standards of vessels’ operations and clearly state the high-level and long-term goals and
aspirations. Policy statements are signed by the Managing Director, acknowledged by all shore and
shipboard staff and posted in all vessels and in the office. Policies define core responsibilities which
aim to ensure that the Company’s principles are followed in all aspects of its business.
Management commitment and personal accountability for continuous improvement is clearly
defined and demonstrated through active and visible participation. (SMS Chapter 2.1 Mission
Statement, 2.2 Vision Statement and 2.3 Company's Policy Concept)
1.1.2 Senior management demonstrates a clear commitment to implementing the Yes

SMS.
The SMS requires management leadership and commitment visible to the organization and
accountability at all levels. The Top Management establishes and continuously reviews mission
statements, policies, targets and KPIs, provides perspective, sets expectations and provides the
resources for successful operations. The Company by implementing the SMS aims to accomplish
the stated policies and objectives for maintaining and upgrading the operational integrity of the
fleet. Managers are responsible for continuous improvement activities; they visibly participate in
relevant activities and lead by example. (SMS Chapter 2.6 Management Commitment)
1.1.3 HSSE excellence is fully understood and supported by vessel and shore-based Yes
management teams.
Through various communications links, such as ship/office visits, meetings, training seminars,
Campaigns, etc. the Company promotes the concept of HSSE excellence and sharing of information
at all levels within the organisation. Lessons learnt and best practices are captured, recorded,
shared and improvement plans are prioritised and monitored. The Company strives to ensure that
HSSE excellence is fully understood and supported by all vessel and shore-based management
teams. Managers track the recommendations to ensure that they are closed out and that all
necessary changes have been made. (SMS Form OPR 031 / 031A List of Best Practices , SMS
Chapter 3.4.3.2 Safety and Environmental Commitee, SMS Chapter 6.1.15.2 In house training, SMS
Chapter 12 Verification, Review and Evaluation, Objectives and Targets "Campaigns")

Stage 2
1.2.1 All company personnel can describe what HSSE excellence means in practice. Yes
Ship and shore management teams actively promote through leadership and sound management
practices the concept of HSSE excellence. Procedures are in place for measurement of staff
understanding and commitment through ship/office visits, meetings, audits, appraisals, seminars,
interviews etc. Senior Management provides direction through strong, effective and visible
leadership and clearly defines responsibilities and accountabilities. Continuous improvement
considerations form a part of everyday business. The workforce is actively participating in achieving
the Company’s objectives and targets. (Company Objectives and Targets, SMS Form CREW 009
Office Staff Appraisal Form, SMS Chapter 3 Company and Shipboard Responsibilities and
Authorities, Company Meeting Minutes, Company Run Seminars, various CBT trainings)
1.2.2 Management strives to improve safety and environmental performance at all Yes
levels.
Effective communication procedures between shore management and the fleet are fully
implemented and used to capture and share best practices, lessons learnt and trends.
Management strives to improve performance in the areas of HSSE performance at all levels
throughout the Company and establishes documented plans that contain specific actions to
achieve long-term goals and aspirations. (Company Objectives and Targets, KPIs, Management
Review Meeting Minutes). Management measures and identifies trends by maintaining statistical
records of all near misses, non- conformances and incidents and evaluates performance against the
action plan. Necessary resources are allocated to resolve problems, realign trends, etc.
1.2.3 Vessel and shore-based management teams promote HSSE excellence. Yes
Vessel and shore-based management teams promote HSSE excellence through strong and effective
leadership demonstrated through empowering personnel to intervene to prevent hazardous
situations developing, safety inspections, ship visits by senior Managers which include informal
meetings with all available vessel personnel as well as through recognition and rewarding of
outstanding HSSE performance. They also communicate SMS policies, principles and goals to all
employees through open forums, and workshops and include SMS considerations in ongoing
business strategies, decisions, planning and execution. (SMS Form OPR 012 Top Management Visit
Form, SMS Form OPR 006 Inspection Report Company Managers, Safety Campaigns (such as Stop
Work Authority), SMS Form 302009 Environmental, Health and Safety Inspection Form, SMS Form
302007 SMS Meeting Form (also with superintendents))

Stage 3
1.3.1 Shore management establishes targets related to HSSE performance and Yes
conducts measurements to assess and verify their implementation.
Management sets standards, objectives consistent with SMS expectations and KPIs and actively
participates in internal and external assessments to monitor their effectiveness. A comprehensive
KPI measurement and assessment system is being implemented. Performance is evaluated, the
degree to which expectations are met is assessed and the results are stewarded to management.
Measurable KPIs are reviewed during the Management Review meetings. (SMS Form OPR 001
Management Review Meeting Form, SMS Form OPR 013 KPI List)
1.3.2 The steps required to HSSE excellence at each level of the action plan are clearly Yes
defined by management.
Procedures for monitoring of targets and KPIs, as well as actions for achieving them are fully
implemented. Following every Management Review meeting, an action plan is drawn up, a clear
time frame is set, targets and objectives are established for each step of the plan in order to
achieve the long- term goals and their progress is monitored. Targets are defined for each
department head.(Company Management Review Meeting Minutes)
Stage 4
1.4.1 HSSE targets and objectives are discussed, at least quarterly, at management Yes
meetings onboard and ashore.
Progress towards HSSE objectives, targets and KPIs is discussed both onboard at Safety meetings
and ashore at Management Reviews. Where progress is less than planned Management intervene
to re-align performance by allocating all necessary resources and time frames. Where performance
exceeds expectations, management may consider reassessing and revising targets and objectives.
(Company Objectives and Targets, Company Management Review Meetings, On board Safety
Commitee Meetings)
1.4.2 HSSE performance targets are continually monitored against KPIs. No
1.4.3 All vessel and shore-based personnel demonstrate their commitment to HSSE No
excellence.
1.4.4 A strategic plan ensures continual improvements in HSSE performance are No

achieved.

Developing and Maintaining a SMS
Stage 1
1A.1.1 Management ensures that company policy and the supporting procedures and Yes
instructions cover all the activities undertaken.
The Company has established Policies, procedures and instructions which cover all the activities
undertaken. Top Management is involved in the process of approval, continuous review and
following up the implementation of all policies. Company’s policies are signed by the Top
Management, accepted by all employees and posted on all managed vessels and in the Head
Office. (SMS Chapter 2 Company's Policies and Management Commitment)
1A.1.2 Policy and procedures are formally reviewed at regular intervals to ensure Yes
robustness and effectiveness.
Procedures exist to encourage and evaluate suggestions for SMS improvements from all levels
within the organization. The Company regularly reviews regularly all its policies to ensure
robustness and effectiveness through shipboard safety meetings, Masters’ reviews, Management
reviews, Officer forums and other meetings.
1A.1.3 Procedures and instructions are written in plain language and contain sufficient Yes
detail to ensure that tasks can be completed correctly and consistently.
Management activities that require instructions and procedures are systematically identified and
they are suited to the purpose and easy to understand and follow. Instructions and procedures are
presented in a clear format and written in simple/plain language in order to be “well-digested”
from the readers and simple to use. Person(s) involved in the drafting of procedures are fully
aware, qualified and experienced in their specific topic. Procedures are drafted in a sequential way
and in a way that makes it easy to identify each step.
1A.1.4 Procedures and instructions are easily accessible to personnel and available at Yes
appropriate locations.
The SMS procedures and instructions are in alignment with the stated policies and each Company’s
Policy is materialized through established procedures. Sufficient electronic and/or hard copies of
the SMS are easily accessible to all personnel including contractors and Manning Agents. The SMS
is established, communicated, and supported at every level in the organization and is available at
all appropriate locations. (PMS-Document Management Module)
1A.1.5 A formal document control system is in place to ensure that the current SMS Yes
documentation is available.
All Managers are responsible for the evaluation and implementation of all revisions relevant to
their department. The level of authority for the final approval of the SMS documentation changes
is defined. Procedures also define the distribution and use of current controlled documents. The
document control system ensures that only the documentation in force is in use. Disposal of
obsolete documents and management of uncontrolled documents is properly implemented. (SMS
Chapter 11 Document/Data Control)

Stage 2
1A.2.1 Periodic meetings that review or amend current procedures, or propose new Yes
ones, take place at defined intervals and are formally recorded.
Advice on proposed SMS revisions is included within the agenda of the Management Review
meetings, Masters’ reviews and the Shipboard Safety meetings. Formal records include the
meeting minutes, details of procedures and instructions that have been updated as a result of
meetings, etc. Recommendations following incident investigations, Master’s SMS review, results of
RAs, recommendations from industry bodies, suggestions for continual improvement, new and
upcoming legislation etc. are always considered. (SMS Form 033003 Revision Demand Form)
1A.2.2 Managers’ roles, responsibilities and accountabilities for achieving objectives Yes
are defined within the SMS.
Roles and individual responsibilities and accountabilities are clearly established, assigned,
understood and documented for all employees and Managers. Management is accountable for
ensuring that the SMS is dynamic and is maintained to implement policy and deliver HSSE
excellence. The Management Review monitors relevant improvements and statistics. The SMS
contains provisions for reassigning responsibilities during periods of absence of key personnel as
well as hand over process for key positions which ensure the effective transfer of responsibilities
and critical knowledge. Managers are clearly held accountable for achieving the objectives
established for them. (SMS Chapter 3 Company and Shipboard Organization, Responsibilities and
Authorities, SMS Form OPR 013)
1A.2.3 Relevant reference documents are provided as a supplement to the SMS both Yes
onboard and ashore.
A controlled Company’s Library with regulatory publications and industry guidelines is available
ashore and onboard as per the established document control procedure. Each department is
responsible, based on their area of responsibility, to maintain the most updated editions in
coordination with the DPA. Relevant publications and industry guidelines are provided as a
supplement to SMS both onboard and ashore.(SMS Chapter 11 Appendix 1 Technical Library, SMS
Form 205001 Publication List Form, Contract with official publication supplier)
Stage 3
1A.3.1 Open dialogue between vessel personnel and shore-based personnel to No
improve the SMS is encouraged.
1A.3.2 Instructions and procedures covering shore and vessel operations are No
developed in consultation with those who will have to implement them.

Stage 4
1A.4.1 Benchmarking is used to identify further improvements to the SMS. No
1A.4.2 The company is innovative in improving the content, format and delivery of the No
SMS.
1A.4.3 Senior managers have an assurance programme in place to verify the No

effectiveness of the SMS.

Recruitment and Management of Shore-based Personnel
Stage 1
2.1.1 A pre-recruitment process is in place that ensures candidates for key shore- Yes
based positions have the appropriate qualifications, experience and
competence.
The Company has defined in its SMS Chapter 3 "Company and Shipboard Responsibilities and
Authorities" the minimum experience, qualifications and competence requirements for each key
shore position. Procedures are in place to ensure that these requirements are met prior to
employment. The responsibility for verifying competency is clearly defined. Fitness for duty is part
of the minimum qualifications, especially for those boarding the vessels.
2.1.2 The company has a documented recruitment process for key personnel. Yes
The recruitment procedure ensures that information supplied by recruits indicates that they have
the appropriate skills to fill the position and includes interview and checks that applicants have the
appropriate qualifications and experience. During the recruitment process, each candidate’s
credentials are checked to ensure that these are genuine and to verify their experience.
Background security checks and medical fitness are verified and training needs are identified
during interviews conducted to assess competence; relevant checks are evidenced in SMS form
CREW 017.
2.1.3 A formal familiarisation process is in place for newly recruited key shore-based Yes
personnel.
Each employee receives job specific familiarization to undertake his responsibilities as per
Company’s procedures. The familiarization process for newly recruited shore staff covers all
policies, including business ethics, cultural awareness, etc. Furthermore, the Company provides
initial, ongoing, and periodic refresher training for its employees to meet job and legal
requirements and to ensure understanding of the proper protective measures to mitigate potential
risks. Familiarization forms "SMS Form OPR 003 Familiarization and Training of Office Personnel"
are valid for the key shore staff and position specific trainings are identified in SMS Form OPR 027
Training Matrix.
2.1.4 There is a documented handover procedure for shore-based personnel. Yes

The Company implements documented temporary and permanent handover procedures for shore-
based staff. Position specific shore personnel handover forms (SMS Forms CREW 024 to 032) are
maintained. The scope and depth of the handover process is determined by the responsibilities of
the personnel involved.
2.1.5 Up-to-date records of qualifications, experience and training courses attended Yes
for all key shore-based staff are maintained.
Up-to-date records and experience of shore personnel as well as training courses attended are kept
in each employee’s personal file. Furthermore, the Company follows the established Training Plan
in accordance with SMS Chapter 6.2.8 Training Procedure (shore). In house and external training
seminars take place for all employees. Course information is kept detailing the various types/topics
of training. Records of qualification and appraisals are kept in employee personal file.

Stage 2
2.2.1 A formal personnel appraisal system ensures that key personnel undergo a Yes
performance assessment at least annually.
The appraisal system includes annual reviews of staff abilities, mid-year performance reviews,
individual target setting and identifies any development requirements, including additional training
needs. For all issues highlighted in the appraisals, follow up is performed in order to prioritise them
for resolution. The Management is effectively reviewing and track individual progress and career
development requirements through SMS forms CREW 009 Office Staff Appraisal Form and CREW
016 Personel Performance Contracts.
2.2.2 Retention rates for key personnel over a two-year period are calculated. No
Even though the company retention rates are satisfactory since the formation of the company, as
the Company has not completed a 2 year period, the requirement is not met.

Stage 3
2.3.1 Key personnel retain core technical skills through training, refresher training Yes
and participation in industry forums, seminars and conferences.
The Company understands the importance of continuous/refresher training as well as training
covering new subjects and industry initiatives. The key shore staff is qualified and trained as they
attend courses in training centers as well as various industry forums, seminars and conferences.
The Company has compiled a list of basic training seminars per position with defined refresher
periods, in order to cover all relevant regulatory aspects together with all additional Company’s
requirements. This plan, along with any individual training needs, are discussed and addressed
during the Management Review Meetings. Evaluation methodologies, such as examinations/tests,
appraisals, course critiques, etc., are used to assess the effectiveness of training. A training
evaluation procedure and form (SMS Form CREW 014 Training Assessment Form and CREW 015
Company Training Evaluation Form) is established and properly implemented. (PMS Training
Module)
2.3.2 Sufficient shore-based personnel are provided to implement the SMS Yes
effectively.
The number, experience and skills of personnel are sufficient to maintain operational integrity
under different operational conditions. The Top Management is committed to provide adequate
resources and sufficient people to implement efficiently the SMS and to provide full supervision of
all vessels in the fleet. The needs for shore based personnel are continuously foreseen to
effectively meet the anticipated workload and/or employee shortages due to age profiling,
promotions, increased fleet size, new ship types, new building programs and technological /
regulatory changes; relevant procedure has been established in Chapter 6.2.1 "General" of SMS
and regularly monitored during Management Review meetings.
2.3.3 Targets for retention rates are formally reviewed and documented. Yes
It is the Company’s policy to retain key staff and to promote continuity. This KPI is considered of
great importance and it is monitored in each Management Review. Retention rates are formally
reviewed, documented, compared and analyzed against specified targets. A procedure and an exit
interview form are established for shore staff leaving the Company in order feedback to be
obtained regarding working conditions, complaints (if any), etc. The company seeks to promote
personnel continuity, particularly of key personnel, and to develop career opportunities for all
personnel. Results from Exit Interviews are discussed during MRMs, any trend are identified and
required actions decided; relevant procedure are established in Chapter 6.2.3. "Resources", 6.2.5
"Nomination" and 6.2.14 "Exit Interview" of SMS.
Stage 4
2.4.1 Continual professional development of personnel is encouraged and supported. No
2.4.2 The company aims to fill relevant shore-based positions from within the fleet No
wherever possible.
2.4.3 The company promotes appropriate interpersonal skills training. No

Recruitment and Management of Vessel Personnel

Stage 1
3.1.1 Management has procedures for the selection, recruitment and promotion of Yes
all vessel personnel.
The candidates’ credentials e.g. certificates, training, experience, competence, working language
level, background security checks etc. are verified by suitably qualified personnel. In addition, the
authenticity of new recruits’ qualifications is verified with the issuing authorities. Issue dates for
certificates and endorsements correlate to previous experience and vessel type. Where manning
agencies are used, the company is responsible for oversight of the recruitment process. Minimum
requirements for seagoing personnel are implemented and the established selection, recruitment
and promotion procedure ensures that information supplied by recruits indicates that they have
the appropriate skills to fill the position. Cross-cultural values and attitudes are taken into
consideration in order smooth cooperation of seafarers onboard vessels to be ensured; relevant
checks are evidenced in the SMS form CREW 004 Application Form for Seafarers.
3.1.2 All vessel personnel have valid medical certificates in compliance with Flag State Yes
and/or relevant authority requirements.
All seagoing personnel meet the medical standards required by the Flag Administration and
Company’s requirements. Medical checks are conducted as a part of the selection and recruitment
process by Company’s selected doctors or contracted Medical Centers. D&A abuse and blood
accumulations are also checked prior employment. The frequency of medical checks is over and
above the Flag requirements and is defined in the SMS. Programs to identify and assess potential
safety and health hazards in the workplace that include provisions for notification and monitoring
of affected personnel, timely and proper correction of the deficiencies, and compliance with
applicable rules and regulations, are also described in the SMS Chapter 6.1.1 "General" and 6.1.8
"Selection and Appointment of Seagoing Personnel" and evaluated in Risk Assessments.
3.1.3 Procedures are in place to identify and manage mandatory training, including Yes
refresher training, for all vessel personnel.
The Company carefully monitors training needs and refresher requirements and training is
undertaken within a specific time frame. A Training Matrix (SMS Form CREW 034 Training Matrix
for Seagoing Personnel) is in place, including mandatory training per rank. Scheduling of crew
replacements is planned with the most efficient satisfaction of relevant requirements.
3.1.4 Formal familiarisation procedures are in place for vessel personnel, including Yes
contractors.
Familiarization procedures and forms for seafarers include onboard HSSE requirements, the SMS,
vessel specific operations and equipment and roles/responsibilities. Familiarization of 3rd Party
Personnel Form (SMS Form 301001 Supernumeraries, Contractors, Technicians' Familiarization
Form) includes a separate list of items for contractors, prior commencement of any work.
3.1.5 Documented handover procedures for key vessel personnel are in place. Yes
Company implements documented handover procedures for key vessel personnel and rank specific
handover forms are properly maintained. The scope and depth of the handover process is
determined by the responsibilities of the personnel involved. (SMS Chapter 6.1.12.1 Familiarization
and Handover Procedure)

Stage 2
3.2.1 Appraisal procedures are in place for all vessel personnel. Yes
All seafarers are appraised during the Master’s and Chief Engineer’s hand-over as well as at the end
of their contract. All appraisals are reviewed and followed up by the Company through SMS Forms
CREW 001 Evaluation Form For Master, CREW 002 Evaluation Form For Chief Engineer, 007004
Evaluation Report for Crew, 007005 Evaluation Form for Junior Officers and Senior Officers, 007011
Evaluation Form for Cooks which has direct involvement in the appraisal process. The appraisals
forms cover several items e.g. technical skills, soft skills, etc. Appraisals are filed so that shore
management can effectively track an individual’s progress. (SMS Chapter 6.1.16 Appraisals)
3.2.2 Procedures are in place to provide company specific additional training for all Yes
ranks.
The Company provides the best available initial and refresher training for all ranks as laid out in
Company’s rank specific Training Matrix (SMS Form CREW 034 Training Matrix for Seagoing
Personnel). The Company also provides to the seafarers the opportunity to request further career
development. The relevant procedures include the type of training, the frequency of refresher
training, etc. and relevant records are maintained. (SMS Chapter 6.1.3 Resources and 6.1.19
Promotion)
3.2.3 The company verifies that vessel personnel quality requirements are Yes
consistently met.
The Company is responsible to check the qualification levels, certification/experience, training
records, appraisals and compliance with manning procedures and legislative requirements of
recruited seafarers. The Crew Department is always looking for ways to further improve both the
quality of crew serving onboard and the working conditions under which they serve. Company
specific recruitment and promotion requirements are established and properly followed up. (SMS
Chapter 6.1.11 Verification of Qualifications and Certificates, PMS Crewing Module, PMS Training
Module, SMS Forms CREW 001 Evaluation Form For Master, CREW 002 Evaluation Form For Chief
Engineer, 007004 Evaluation Report for Crew, 007005 Evaluation Form for Junior Officers and
Senior Officers, 007011 Evaluation Form for Cooks )
3.2.4 Procedures to identify additional training requirements for individual personnel Yes
are in place.
SMS procedures include monitoring of new legislation, and review of appraisal
records/drills/exercises as sources of identifying additional training needs. Improvements realized
from additional individual training are recorded on subsequent appraisals and personal training
records. SMS Chapter 6.1.15.5 Training Needs Identification and Follow up also includes the
assessment of competence in rank or in preparation for promotion, correlation of non-
conformances, incidents and near misses and review of vessel performance and audit/inspection
trends as sources of identifying additional training needs.

3.2.5 There is an enhanced recruitment procedure for Senior Officers. Yes
The Company strives to fill Senior Officers’ positions from within the Company. Company’s
expectations and Senior Officers’ responsibilities are defined and specific procedures and checklists
have been established for the recruitment of Masters and Senior Officers. Interviews are
conducted by the head office, to ensure that the applicants have the required skills and
capabilities, to assess the candidate's personality and to determine his possible behaviour under
certain circumstances. Approval authorities for Masters and Senior Officers are defined and
familiarisation and training periods in the Office have been also established. All Company
personnel involved in the briefing process strive to continuously improve the recruitment/
interview process, ensuring expanded coverage of all topics relevant to Company’s goals for
continuous improvement. Briefing procedure for Senior Officers prior sign-on is established, as well
as a probationary period and relevant appraisal at the end of this period (SMS Chapter 6.1.8.1
Application and selection, 6.1.8.2 Briefing and 6.1.19 Promotion)
3.2.6 The company monitors and records training results and effectiveness. Yes
The training evaluation procedure, except from the feedback from trainees (SMS form CREW 014
Training Assessment Form), also includes company representation at training courses, review of
appraisal records, review of vessels’ performance and audit/inspection trends, correlation of near
misses, non-conformities and incidents. The effectiveness of training is periodically reviewed and
improvement actions are taken in the MRM.
3.2.7 There is a documented promotion procedure. Yes

Company’s procedures for promotion are clearly defined in the SMS Chapter 6.1.19 "Promotion"
and include identification of potential candidates, requirements on previous experience and
performance, training requirements, competency assessment, ability to communicate in a common
language, qualifications, etc. Relevant responsibilities are clearly defined along with placement
criteria to ensure that the necessary levels of individual and collective knowledge and experience
are maintained. Promotion procedures make optimal use of all information gleaned from
appropriate forms and parallel appraisals by Company’s Managers, Superintendents and auditors.
Promotion checklists per rank, including on-the-job training have been established. In addition,
promotion procedure includes simulator training, computer-based training and competency
assessment. The company aims to develop long-term career prospects for personnel and fill senior
officer positions from within the company.

Stage 3
3.3.1 There are enhanced appraisal procedures for Senior Officers. Yes
The performance of Senior Officers, regarding leadership skills, personnel management, safety
performance, open reporting, communication skills, shipboard operational performance and
technical skills, is monitored during their service period and formal evaluations by the Company’s
Managers and Superintendents are carried out (SMS Chapter 6.1.16 Appraisals). The aim is to
record positive achievements but also areas for improvement. Any identified training needs and
development requirements are satisfied before next employment.
3.3.2 The company provides career development for Junior Officers and aims to Yes
promote Senior Officers from within the company, where possible.
Procedures are in place to ensure proper guidance and encouragement for advancement of Junior
Officers. It is also Company’s aim, Senior Officers to be recruited from within the Company. Career
development guidance is documented and clearly sets out the requirements necessary for
promotion. (SMS Chapter 6.1.19 Promotion and 6.1.15.4 Training On board)
3.3.3 Training for vessel personnel exceeds the minimum requirements of the No
International Convention on STCW or of the relevant authority for vessel trade.
3.3.4 Personnel selection and recruitment is reviewed annually to ensure it complies No

with company policies and procedures.
Stage 4
3.4.1 Procedures to assess crew members for job competency are in place. No
3.4.2 A documented planning procedure is in place to ensures future manning needs No

can be met.
3.4.3 Cross-cultural interpersonal skills are promoted. No

Wellbeing of Vessel Personnel
Stage 1
3A.1.1 Procedures ensure that each vessel is appropriately manned in order to Yes
maintain safe operation onboard.
Each vessel is adequately manned in order to encompass all aspects of maintaining safe operations
on board, taking also into account the Flag State and National requirements, vessels’ types and
trading patterns, additional security and operational requirements, etc. Relevant manning level
assessments are kept and reviewed during MRMs
3A.1.2 Shore management provides adequate resources to ensure the wellbeing of Yes
vessel personnel.
All vessels are provided with recreation rooms for Officers and ratings, free wifi access to internet
via Vsat, TV sets (including auto-tracking SAT TV), DVD players, radio receivers, table games,
periodical magazines and library with various books. Through inspections by vessel personnel,
internal audits and ships’ visits, the Company ensures that adequate resources are available to care
for the welfare of the ships’ crew and to ensure their wellbeing. Well-being covers diverse aspects
of the crew’s quality of life including quality of food, accommodation, rest and recreation facilities,
hygiene, air conditioning, access to ship and shore medical facilities, eligibility for compassionate
leave, etc.
3A.1.3 Procedures ensure that working and rest hours of all personnel are in line with Yes
the STCW, applicable Flag State requirements or any relevant authority
guidelines for the vessel trade and are being accurately recorded and
monitored.
Rest hours are recorded using software and the records are monitored at least once in every month
by superintendents to confirm compliance (SMS Chapter 7.11.8 "Rest Hours"). Fatigue awareness
and preventive measures onboard is not underestimated. Vessels are manned adequately for their
type and trade and manning always exceeds the minimum required safe manning, especially where
voyages are short and workloads are high. Procedures in SMS Chapter 7.11 "Fatigue" address
potential fatigue issues such as adequate rest for joining personnel and sufficient time for effective
handovers upon personnel change. Procedures are in place for identification of non-compliances
and implementation of corrective actions.
3A.1.4 A formal D&A policy is implemented and a system is in place to monitor it on a Yes
regular basis.
The Company places maximum emphasis on strict compliance with established policies and
procedures which comply with Flag State legislation and OCIMF guidelines. Thus, a D&A policy is
implemented and a system is in place to monitor it on a regular basis. Procedures for random
unannounced D&A tests by external contractors and Alcohol tests by the Master and the Company
are in place and clearly described in the SMS. (SMS Chapter 7.07 D&A Procedure and 2.3.4 D&A
Policy).

Stage 2
3A.2.1 A defined complaints procedure is in place. Yes
Company’s complaint procedure (SMS Chapter 6.1.23 Complaint Procedure) complies with
applicable Flag and National requirements and is part of the familiarization process. All seafarers
have a copy of the complaint form and procedure and all complaints are recorded and dealt
accordingly.
3A.2.2 A documented disciplinary procedure is in place. Yes

A progressive disciplinary process, complying with Flag and contractual requirements, has been
established in SMS Chapter 6.1.17 Discipline and is properly followed. All vessel and relevant shore-
based personnel are familiar with the procedure.
3A.2.3 Documented procedures are in place to ensure high standards of hygiene are Yes
maintained.
The Company actively promotes high standard of housekeeping and hygiene, particularly in food
storage and preparation, laundry facilities and the hospital. Health and hygiene programs are in
place to assess potential safety and health hazards in the workplace. Moreover, the Safety Officer
as well as the Company’s personnel visiting the vessels, regularly inspect on board the food storage
and food preparation areas. Their findings are reviewed as part of our continuing effort to further
improve hygiene awareness on board.
3A.2.4 Retention rates for Senior Officers over a two-year period are calculated. No

Stage 3
3A.3.1 Seminars are held for senior officers that promote, emphasise and enhance the Yes
company’s SMS.
Our Company conducts Senior Officers seminars, at appropriate intervals, to promote, emphasize
and enhance the SMS, giving special attention to Company’s policies, culture, ethics and values,
Environmental management, New legislation, Safety issues, human element and security issues
(refer. SMS Chapter 6.1.15 "Training" ). Attendance is monitored to ensure that all Senior Officers
attend these shore-based seminars. Seminars are also recorded and circulated to fleet vessels and
added to training program to ensure that all senior officers absent in the seminars also watch and
comment on same.
3A.3.2 An enhanced documented disciplinary procedure is in place. Yes

Disciplinary procedure includes levels of violations, levels of authority, required actions, appeals, re
-education and additional training, particularly for those that have been involved in operational
incidents. Investigations are conducted for severe breached of discipline. The Company’s discipline
philosophy is based upon the concept of “Just culture”. The discipline procedure is also applied to
the contractors. (refer. SMS Chapter 6.1.17 "Discipline").
3A.3.3 Health awareness campaigns are implemented. Yes

The Company is committed to provide the fleet with bulletins/circulars/campaigns on various
important issues, including health awareness. Relevant procedures and health awareness
campaigns to identify and assess potential safety and health hazards in the workplace have been
established and implemented. (refer. Company Objectives and Targets "Campaigns").
3A.3.4 Retention rates for all officers over a two-year period are calculated. No
Stage 4
3A.4.1 Seminars are held for all officers to promote, emphasise and enhance the No
company’s SMS.
3A.4.2 A documented procedure to conduct vessel health-risk assessments is in place. No
3A.4.3 The company provides career development opportunities by arranging shore- No

based assignments for vessel personnel.

Vessel Reliability and Maintenance
Stage 1
4.1.1 Each vessel in the fleet is covered by a planned maintenance system and spare Yes
parts inventory which reflects the company’s maintenance strategy.
The PMS and spare parts inventory implemented on all vessels in the fleet covers all shipboard
equipment and machinery and includes a schedule of planned maintenance tasks and a record of
completed planned and unplanned maintenance .
Training is provided to ship personnel for the proper handling of the PMS ( PMS Training Module/
PMS familiarization training).
4.1.2 A defect reporting system is in place for each vessel within the fleet. Yes
The PMS integrates the defect reporting and all type of unplanned tasks (PMS Deficiency Module),
such as:
• Conditions of Class and Class memos which should be corrected without delay.
• All types of observations and remarks raised by any 3rd party inspectors
• Observations and job orders, issued by the superintendents during shipboard
attendances, as well as reported equipment failures or breakdowns.
The system enables tracking of defects from failure to repair on the basis of their due dates. The
defect reporting system also includes guidance as to the nature of defects that are recorded and
reported.
4.1.3 Company management regularly reviews the status of fleet maintenance. Yes
Maintenance reports are submitted to Office for review, as soon as they are issued, and
maintenance system monitoring is carried out as per (Chapter 10.1.1 ). The review process includes
status of defects, the number and nature of any outstanding maintenance tasks, the reason for
tasks being outstanding and the identification of any assistance required, such as spare parts or
shore technicians. In the unlikely case of outstandings, procedures are in place for formal
postponement to be granted by the Technical Department, based on assessment, including
consideration of manufacturers recommendations and completion within a specified time frame.
Emphasis is placed that leaving overdue tasks related to critical equipment is not tolerable.
4.1.4 The company monitors outstanding planned maintenance tasks. Yes

PMS outstandings are constantly kept below 6% per vessel and per month, in all over the fleet and
less than 3% per vessel averaged over the last 12 calendar months, in accordance to the Company’s
current KPIs for PMS performance. Moreover, PMS outstanding for critical equipment jobs is
always kept to zero level. Every effort is placed for the target rate of outstandings to be reduced
and stricter KPI to be endeavored.

Stage 2
4.2.1 A procedure is in place to ensure the validity and accuracy of statutory and/or Yes
Classification certificates.
Verification process (SMS Form No:001001A/B and E-PMS certificate module ) of vessels
certificates is performed both onboard and ashore by dedicated office personnel as per SMS
Chapter 10.9 "Statutory and Class Surveys And Certification. The procedure addresses Class status
reports, planning for surveys, extensions, dispensations and exemptions.
4.2.2 Cargo, void and ballast spaces are inspected to ensure their integrity is Yes
maintained.
Periodic tank and void spaces inspection is undertaken as per (SMS Chaapter 10.4.2 Inspection of
tanks and void spaces, SMS Form No: 106006 Cargo Tank Inspection Report , SMS Form No:106007
Ballast Tank Inspection Report) in line with Company’s policy and industry standards. Standardized
templates are available for comprehensive reporting of tank inspection, supported by sketches and
photographic records and inspections are monitored via the PMS. Guidance is provided to the
Company’s inspectors for objective inspections, by using Class and Industry publications, as well as
material incorporated in the SMS.
4.2.3 Superintendents verify maintenance and defect records during ship visits. Yes
Vessel visits are performed on a regular basis, minimum two annually for each vessel (often
exceeded), as per (SMS Chapter 10.4.4 Vessel Technical Inspections by Shore Staff , 10.4.5 Vessel
Internal Inspections by Shore Staff ). Annual extensive inspections during actual sails of the
superintendents are also carried out. Ship inspections examine thoroughly the vessel at least as per
VIQ standards, including evaluation of E/R operation, spares, PMS and defect reporting system
following-up. During the visits, technical superintendents verify that reported maintenance has
been carried out through a pre-defined checklist which identifies the items that are mandatory to
be verified and for the rest by random cross checks of records and machinery, observe engineering
practices, E/R management standards and whole vessel's housekeeping.
4.2.4 The company has a formal system to develop dry-dock specifications, which Yes
involves collaboration between the vessel and shore management.
Procedures and guidance for shore and vessel personnel for D/D repairs are in place (SMS Chapter
10.5.7 Major Repairs and Drydocking), including selection of shipyard, safeguards during the
vessel’s stay and proper monitoring and verification of repairs. The generation of the shipyard
repair list is conducted via the defect monitoring system, which identifies the items considered
unsuitable for in-service repairs. The system also includes procedures on health and safety
responsibilities, generic dry-docking tasks, manufacturer’s recommendations, statutory and
regulatory requirements, and actions for entering the dry dock and refloating. Items may be added
to this list by ship or shore responsible personnel.

Stage 3
4.3.1 A common computer-based maintenance system onboard each vessel records Yes
all maintenance tasks and incorporates the defect reporting system.
A computer-based maintenance system is used on board and in the office, integrating the planned
and unplanned maintenance reporting and monitoring tasks. The computer-based system is also
used to analyze defect reports in order the planned maintenance tasks and the minimum spare
parts required to be amended as appropriate. The maintenance and defect reporting system
includes manufacturer’s recommendations, work instructions and associated risk assessments,
equipment and machinery history, synchronization capability between ship and shore database,
etc. Defect reports are analyzed and planned maintenance tasks are amended as appropriate,
including a review of the minimum spare parts required. (E-PMS Maintenance, Deficiency and
Stock modules) .
4.3.2 The company policy is to maintain an optimum spare parts inventory or system No
redundancy for all vessels.
4.3.3 Performance indicators have been developed to monitor fleet reliability. The No
performance indicators are measured for individual vessels and fleet wide.
4.3.4 The frequency and extent of structural inspections of the vessel’s cargo ballast No
and void spaces is determined based upon risk criteria.
Stage 4
4.4.1 The maintenance and defect reporting system integrates the spare parts No
inventory management and procurement systems.
4.4.2 The maintenance and defect reporting system tracks all deferred repair items No
for inclusion in the dry-dock specification.
4.4.3 The maintenance and defect reporting systems provide management with a real No
time status of fleet maintenance.
4.4.4 The planned maintenance system includes the use of condition-based No

monitoring in order to ensure optimal equipment performance.
4.4.5 Comprehensive engineering audits are completed by a suitably qualified and No

experienced company representative. The audit includes observation of
engineering practices while on passage.

Vessel Reliability and Maintenance (Critical Equipment)
Stage 1
4A.1.1 Critical equipment and systems are identified and listed within the SMS and the Yes
vessel’s planned maintenance system.
Critical equipment and systems are clearly identified (in SMS 10.2.5 Maintenance of Critical
Equipment and 10.2.6 Planned and Unscheduled Critical Equipment Maintenance:
Deactivation/Reactivation Reporting) via a Risk Analysis process. Also, Critical Equipment is easily
identifiable in the Company’s PMS.
4A.1.2 A procedure is in place to manage the planned maintenance of critical Yes

equipment and systems.
Procedures are available in SMS Chapter 10.2.6 Planned and Unscheduled Critical Equipment
Maintenance: Deactivation/Reactivation Reporting, for informing the Company in case of
disarmament of any critical equipment for planned maintenance, as well as when it returns to
service. Also, procedures are available for the case of being impossible to complete PMS tasks of
critical equipment in time, including deferral standards, addressing the risks via a risk assessment
and Technical Manager’s approval. However, normally, leaving overdue critical equipment PMS jobs
is never tolerable and maintenance shall be carried out as soon as practicable.
4A.1.3 A procedure is in place which requires shore management to be informed when Yes
critical equipment or systems become defective or require unplanned
maintenance.
Procedures are available in SMS Chapter 10.2.6 Planned and Unscheduled Critical Equipment
Maintenance: Deactivation/Reactivation Reporting and SMS Form No: 425004
Deactivation/Reactivation Report, for informing the Company in case of disarmament of any critical
equipment due to failure / defect or requiring unplanned maintenance.
4A.1.4 Procedures are in place to record the testing of critical equipment and systems Yes
that are not in continuous use.
Routines for regular, functional testing of all critical equipment and systems (incl. those not in
continuous use) are incorporated in the PMS. Testing is performed in accordance with mandatory
requirements and manufacturers’ recommendations. (PMS Maintenance Module /Critical
Equipment Section)

Stage 2
4A.2.1 Maintenance on critical equipment and systems requiring them to be taken out Yes
of service is subject to risk assessment and management approval.
Planned and unplanned maintenance of critical equipment and systems, involving disarmament, is
authorized by the shore management on the basis of a risk assessment submitted by the vessel
(SMS Chapter 10.2.6 Planned and Unscheduled Critical Equipment Maintenance:
Deactivation/Reactivation Reporting) and for a specified period of time. Any extension required for
critical equipment maintenance, in excess to that initially authorized, has again to be approved by
shore management, on the basis of a new risk assessment and specified extended shut-down
duration.
4A.2.2 Work instructions are available in the planned maintenance system for critical Yes
All PMS routines for critical equipment maintenance are supported by proper work instructions,
including reference to spare parts, as applicable. Also, all entries of critical equipment, as they
appear in the PMS Maintenance module have a reference that in case of any disarmament for
maintenance, a risk assessment for authorization should be sent to the Company. Planned
maintenance of critical equipment is always carried out according to the work instructions and is
verified during superintendent visits.
Stage 3
4A.3.1 Designated personnel are responsible for the maintenance and repair of critical Yes
Competency standards for the maintenance and inspection of critical equipment and system have
been identified and set (SMS Chapter 10.2.5 Table competancy Standard for Operation, testing,
maintenance and amending parameters of critical equipment and alarms). When it is necessary to
employ 3rd party contractors, relevant arrangements are made by the office to ensure their
competencies. The subcontractors, as well as all persons involved with the critical equipment
maintenance, should acknowledge the risk assessment dealing with the relevant disarmament
risks.
4A.3.2 A procedure is in place to test and record performance data for all critical No
Stage 4
4A.4.1 The reliability and performance of critical equipment or systems and associated No
alarms is monitored and analysed.

Navigational Safety
Stage 1
5.1.1 The company designates appropriate shore-based personnel responsible for Yes
navigational standards.
The Fleet Manager, supported by a qualified and experienced team, is Company’s responsible
person for the maintenance of the navigational standards as described in SMS Chapter 3 "Company
and Shipboard Responsibilities and Authorities". The controls being at his disposal for effectively
maintaining the navigational standards and carrying out his assigned role are also clearly described.
5.1.2 Comprehensive procedures to ensure safe navigation are in place. Yes

Best industry standards are maintained with the Bridge procedures covering all aspects for safe
navigation. The procedures are constantly under review to accommodate any industry changes or
those resulting from the review of Company’s navigational standards (SMS Chapter 7.02
"Navigation")
5.1.3 Procedures to ensure effective bridge resource management are in place. Yes
Detailed procedures for effective Bridge Resource Management are included in SMS Chapter 7.02
"Navigation"
5.1.4 The company has procedures that ensure all navigational equipment is Yes
maintained as operational.
Under the supervision of the Technical department’s staff, all navigational equipment is kept fully
operational. All appropriate actions for planned and unplanned maintenance are carried out by
properly trained personnel, monitored and followed up via the PMS. Manufacturer's service
technicians are used for maintenance, when deemed necessary. (SMS Chapter 7.2.8 "Maintenance
Checks and Tests" and 10.3.15.2 "Repair of Navigation and Communication Equipment")

Stage 2
5.2.1 A procedure is in place requiring the Master to conduct a navigational audit to Yes
ensure compliance with navigational regulations and company procedures.
Masters carry out navigational audits on quarterly basis, starting from the beginning of their
assignment. Audit reports are sent to the Office for evaluation, analysis and follow-up in co-
ordination with the Master and the responsible Superintendent, as necessary. Additionally, audits’
findings are used for the identification of trends and the maintenance of the navigational
standards. (SMS Chapter 12.3 "Navigational Audits")
5.2.2 A procedure is in place for appropriate shore-based personnel to conduct Yes

navigational verification assessments.
Navigational verification assessments are carried out onboard every vessel on annual basis by
suitably qualified and experienced Superintendent or DPA, using Company’s checklist. Any findings
are followed up by the identification of the appropriate corrective actions which are assigned to
relevant Company’s personnel, verified and closed out in a specified time period. (SMS Chapter
12.3 "Navigational Audits")
5.2.3 The person(s) responsible for navigational standards ensures that navigational Yes
procedures are regularly reviewed and updated.
The DPA, supported by a qualified and experienced team, analysing the results of the audits,
assessments and external inspections and following the industry’s development on navigational
safety, constantly updates and verifies the effectiveness of Company’s navigational procedures
5.2.4 The company has a procedure to identify recurring defects in navigational Yes
equipment across the fleet.
The Technical department monitors Bridge equipment defects in order to identify recurrence which
will lead to a more active treatment or replacement and ensures that every effort has been placed
for their effective operation (SMS Chapter 7.2.8.2 "Maintenance/Checks and Tests -
Responsibilities")

Stage 3
5.3.1 Provision of charts, publications and electronic licenses is managed under Yes
contract by a recognised chart agent.
The Company has a contract with a recognized Chart agent for the automated supply of charts,
publications, corrections, electronic charts (SMS Chapter 7.2.19.3 "Books and Publications /
Nautical Charts). The vessel always has fully updated charts and publications for the voyage and
obtains charts and publications at short notice. Chart and publications outfits are monitored
onboard with discrepancies reported to the Company.
5.3.2 A formal programme ensures that Senior Officers receive appropriate ship- Yes
handling training before promotion to Master or assignment to a new vessel
type.
Promotion to Master is achieved by practice under supervision onboard similar vessels.
Additionally, senior Officers before their promotion to Master receive ship-handling simulator
training. Ship-handling simulator training is also a Company’s requirement in case of Masters’
assignment to a different type vessel. (SMS Chapter 6.1.19.1 "For promotion to the rank of Master"
and SMS Form CREW 034 Training Matrix for Seagoing Personnel)
5.3.3 Comprehensive navigational audits are conducted while on passage by a No

suitably qualified and experienced company representative.
Stage 4
5.4.1 Comprehensive navigational audits are conducted while on passage by a No
suitably qualified and experienced person.
5.4.2 All navigational assessment and audit reports from the fleet are analysed, No
trends identified and improvement plans are developed.
5.4.3 Competency assessment programmes ensure that Masters and navigation No

officers maintain core and specialist skills.
5.4.4 Navigation officers undertake periodic refresher bridge resource management No

simulator training at a national or industry accredited shore establishment.

Cargo, Ballast, Tank Cleaning and Bunkering Operations
Stage 1
6.1.1 Procedures for cargo, ballast, tank cleaning and bunkering operations are in Yes
place for all vessel types within the fleet.
Comprehensive procedures for cargo, ballast, tank cleaning and bunkering operations are available
for Oil Cargo and Chemical Tankers. These procedures (SMS Chapter 7.5 "Cargo and Ballast
Operations" and 7.4.13 "Handling of Fuel Oils - Bunkering Operations") also establish that the Chief
Officer / Chief Engineer is the person authorized by the Master for supervising the Cargo and
Ballast handling and bunkering operations, supported by specified deck and engine crew.
6.1.2 Procedures for pre-operational tests and checks of cargo and bunkering Yes
equipment are in place for all vessel types within the fleet.
Procedures in place (SMS Chapter 7.5 "Cargo and Ballast Operations" and 7.4.13 "Handling of Fuel
Oils - Bunkering Operations") establish test and checks of cargo and bunkering equipment prior and
whilst the operations in progress. Moreover, thorough accuracy verification and monitoring of test,
inspection, maintenance and certification of equipment is carried out via the PMS.
6.1.3 Management ensures that cargo, ballast and bunkering operations are Yes
conducted in accordance with company procedures.
The scope of superintendents’ attendances includes checking and verification of cargo and
bunkering operations during ship visits (SMS Chapter 12 "Verification"). Also, occasional distant
assessments are carried out by the Company, to review records not forwarded to the Office but,
normally, retained onboard. Analysis of third party inspections remarks and terminal feedback is
used to improve cargo operational standards.
6.1.4 The company has procedures that address cargo specific hazards for all vessel Yes
types within the fleet.
Procedures with specific instructions for addressing hazards due to nature of cargo are available in
SMS Chapter 7.5 "Cargo and Ballast Operations" including aromatic hydrocarbons, toxic cargoes,
incompatible cargoes, high vapour pressure cargoes and cargoes containing Benzene, mercaptans
and/or H2S, reactive and self-reactive cargoes, inhibited, static accumulator, corrosive, high density
cargoes, blended/biofuels, heated cargoes.

Stage 2
6.2.1 A comprehensive procedure for planning cargo, ballast and bunkering Yes
operations is in place for all types of vessel within the fleet.
Detailed cargo and ballast operation plans are prepared by the Chief Officer, approved by the
Master and acknowledged by all the Officers, involved in the operation.
Also, these plans are sent to the Office for review, prior to the commencement of the operation.
Procedures for drafting bunkering plans are also available in SMS Chapter 7.5 "Cargo and Ballast
Operations".
6.2.2 Comprehensive procedures cover all aspects of cargo transfer operations for Yes
each type of vessel within the fleet.
Procedures and, when applicable, recording templates are available in SMS Chapter 7.5 "Cargo and
Ballast Operations" for the following topics:
• Specified instructions for oil and chemical carriers.
• Pre-arrival checks and preparations.
• Ship-shore interface, meetings and checklists.
• Cargo survey and sampling.
• Double physical line-up setting.
• Static electricity precautions.
• Cargo operation progress monitoring.
• Topping off/stripping.
• Draining / disconnection of lines
• Cargo care during transit
6.2.3 Comprehensive procedures cover all aspects of ballast handling operations. Yes
Comprehensive ballasting procedures are available in SMS Chapter 7.5 "Cargo and Ballast
Operations" including ballast exchanges, use of Ballast Water Management Plan, guidance for
heavy weather ballasting, etc.
6.2.4 Comprehensive procedures cover all aspects of tank cleaning operations for Yes
each vessel type within the fleet.
Procedures for tank cleaning operations are described in SMS Chapter 7.5 "Cargo and Ballast
Operations". Tank cleaning is carried out on the basis of a written plan, discussed onboard during a
safety meeting and communicated to the Office for review.
6.2.5 Comprehensive procedures cover all aspects of bunkering operations for each Yes
vessel type within the fleet.
Comprehensive procedures for bunkering operations are available in SMS Chapter 7.4.13 "Handling
of Fuel Oils - Bunkering Operations". They include references to safety stocks, planning, operational
checks, sampling and analysis and precautions for toxic substances that might be contained in
bunkers.

Stage 3
6.3.1 Standardised templates are used for planning and operational record keeping. Yes
Controlled forms are always used for planning and operational record keeping for cargo, ballast,
tank cleaning and bunkering operations. (SMS Chapter 7.5.22 "Relevant Cargo Forms and
Document-Oil" and 7.5.30 "Relevant Cargo Forms and Document-Chemical"
6.3.2 Procedures for each vessel type within the fleet ensure tank atmospheres are Yes
maintained within defined limits for each cargo type being carried throughout
the voyage cycle.
Procedures are available, establishing that the IGS is used appropriately at all stages of the voyage
(SMS Chapter 7.5.13 "Inert Gas Operations-Chemical" and 7.5.14 "Inert Gas Operations-Oil"),
including conditions and risk assessment for the carriage of specific cargoes without the use of
inert gas, where this is required due to cargo characteristics. Moreover, procedures are available
for actions in case of IGS failure.
6.3.3 The SMS includes procedures for non-routine or specialised cargo and ballast No
operations undertaken in the fleet.
6.3.4 The SMS requires Junior Officers/relevant personnel to be actively involved in No

planning, line setting and execution of the cargo, ballast, tank cleaning and
bunkering operations as part of their continuing personal development plan.
Stage 4
6.4.1 Officers attend shore-based simulator courses covering routine and emergency No
cargo operations.
6.4.2 Comprehensive audits are completed by a suitably qualified and experienced No

company representative. The audit includes observation of cargo, ballast, tank
cleaning and bunker handling operations.

Mooring and Anchoring Operations
Stage 1
6A.1.1 Procedures for mooring and anchoring operations are in place for all vessel Yes
types within the fleet.
Guidance for mooring and anchoring operations, incl. safety precautions for involved personnel in
accordance with statutory regulations, OCIMF guidelines and industry best practices, is available in
SMS Chapter 7.3 "Deck Operations in Port"
6A.1.2 Maintenance, testing and routine inspections of mooring and anchoring Yes
equipment is included in the planned maintenance system.
The Company’s PMS and SMS Chapter 7.3.6 "Mooring" and 7.3.7 "Anchoring" includes the required
maintenance, testing and routine inspections of all mooring and anchoring equipment. (PMS
Maintenance Module)
6A.1.3 The company has procedures to manage the condition of mooring ropes, wires, Yes
mooring tails and joining shackles for all fleet vessels.
Instructions for care and stowage of mooring gear are included in SMS Chapter 7.3.6. "Mooring".
Additionally, inspection for the condition of mooring gear is conducted on quarterly basis and the
results are forwarded to the Office. (SMS Form 106005 Mooring Ropes Checklist in PMS Online ISM
module)
6A.1.4 The company has procedures that address the use of tugs. Yes
Guidance for working with tugs is included in SMS Chapter 7.2.15 "Working with Tugs and Line
Handling Boats". Procedures include the safe handling of ships’ lines or tug lines when making fast
or letting go, identification and use of suitable strong points for making tugs fast and designated
tug push points.

Stage 2
6A.2.1 Detailed procedures address each different type of mooring operation likely to Yes
be undertaken by fleet vessels.
Procedures for mooring at conventional berths/ terminals, STS, SBM, SPM. F(S)PO and double-
banking at berths are included in SMS Chapter 7.3.6 "Mooring". These procedures derive from the
relevant Risk Assessments which have been taken into consideration the risks that can be faced
during these operations.
6A.2.2 Procedures address all aspects of anchoring operations likely to be undertaken Yes
by fleet vessels.
Procedures for safe anchoring operations, including emergency anchoring, are included in SMS
Chapter 7.3.7 "Anchoring". These procedures derive from the relevant Risk Assessments which
have taken into consideration the risks that can be faced during these operations.
6A.2.3 Procedures ensure that vessels remain safely moored at all times. Yes
Mooring procedures address requirement for regular monitoring of mooring lines’ condition,
weather conditions and passing traffic to ensure the timely securing of the vessel in changing
conditions and avoid the vessel breaking out from its berth, as per SMS Chapter 7.3.6 "Mooring".
Additionally, guidance is also provided for actions that have to be taken in case that the vessel’s
safe mooring is jeopardized.
6A.2.4 Procedures are in place for the inspection, maintenance and replacement of Yes
wires, ropes, tails and ancillary equipment.
Each vessel has onboard certificates of all available mooring wires / ropes, which are properly
marked and the Company retains copies, annotated with dates and the specific winches to which
they are fitted (SMS Chapter 7.3.6 "Mooring"). The Company has a system in place to follow-up
inspection/replacement dates for all supplied mooring gear, including instructions for conditional
inspection and for retirement / discarding criteria, in SMS Form 106005 Mooring Ropes Checklist in
PMS Online ISM module. Procedures and records are in place for routine inspections and while
spares reflect vessels’ trading areas.

Stage 3
6A.3.1 Procedures identify requirements for personnel involved in mooring operations. Yes
Guidance for personnel requirements during mooring operations and Company’s requirement for
pre-mooring meetings and de-briefing after each mooring operation is included in SMS Chapter
7.3.6 "Mooring".
6A.3.2 Measures are taken to optimise onboard mooring arrangements to ensure the Yes
safety of vessel personnel.
Company takes every measure to optimise onboard mooring arrangements and ensure the safety
of personnel during mooring operations as per SMS Chapter 7.3.6 "Mooring".
6A.3.3 Procedures address the use of all ancillary craft used in mooring and towage No
operations.
6A.3.4 A process ensures that all mooring equipment and fittings comply with the No
latest industry guidance.
Stage 4
6A.4.1 The company actively seeks involvement of manufacturers, to enhance the No
management of mooring equipment including ropes and wires.
6A.4.2 All available means are used to ensure that vessels can safely moor at terminals No
being visited for the first time.
6A.4.3 Comprehensive audits are completed by a suitably qualified and experienced No

company representative. The audit uses observation of mooring operations.
6A.4.4 The company actively seeks out available or innovative technology to enhance No
safe mooring operations.

Management of Change
Stage 1
7.1.1 There is a documented procedure for management of change. Yes
A structured Management of Change process has been established within SMS Chapter 13
"Management of Change", through which, the Company ensures that proposed/forthcoming
changes are fully evaluated and managed to ensure that arising safety, quality, health, security,
environmental and energy management risks are identified and addressed. Procedures for
acceptance and implementation of permanent and temporary changes have also been established.
7.1.2 A procedure is in place to ensure that the impact of any proposed change is Yes
assessed.
The Company is using the Risk Assessment methodology to evaluate the impact of any proposed
change. Potential consequences are being taken into account as well as the needed risk reduction
measures and any additional resources required for proper implementation of the change. (SMS
Form 033001 Management of Change Form)
7.1.3 The management of change procedure clearly defines the levels of authority Yes
required for the approval of any changes.
The levels of authority for review and approval of changes are defined based on the results of the
risk assessment carried out. Any proposed change is approved at an appropriate level and not by
the person directly involved in the change. Clear responsibilities are included in SMS Chapter 13
"Management of Change".
7.1.4 Procedures identify emerging requirements. Yes

The Company has identified the required sources that provide emerging requirements, either
legislative or industry recommended best practices. HSSQEEn and Operational implications,
including navigation, engineering, maintenance, cargo, mooring, are being taken into account on a
case by case basis.
Stage 2
7.2.1 The management of change process ensures all proposed temporary and Yes
permanent changes to onboard procedures and equipment are subject to risk
assessment.
All proposed changes require evaluation of the potential consequences and their likelihood of
occurrence during the planning process for ensuring that risks are identified and control measures
for their effective mitigation are put in place. The choice and prioritisation of measures is based on
the risk impact and their manageability in order to ensure their effectiveness. Effected changes aim
to reduce these risks. RAs are re-examined within specified period of time to assess corrective
actions taken for the mitigation of risks involved. (SMS Form 033001 Management of Change
Form).

7.2.2 Management of change identifies all personnel that may be affected by the Yes
change and ensures that they understand the extent and likely impact of any
planned change.
Procedures for the update of important controlled documentation following any change have been
also established and implemented. Certificates, manuals, plans and drawings, technical documents,
operational procedures and their respective records/forms are always checked for possible
amendments due to a change. This mechanism links with and ties into the Company’s document
control system, so that important controlled documentation remains up-to-date. ………
7.2.3 Management of change procedures ensure that training needs arising from any Yes
proposed changes are identified and documented.
Training needs arising from any proposed changes are identified, documented and addressed
within a defined period. When the change directly affects the vessel, steps are taken to familiarise
the responsible Superintendents and the crew as required. Training and familiarization
requirements are identified and checklists of key steps to be taken are prepared. (SMS Form
033001 Management of Change Form)
7.2.4 Management of change identifies all documentation and records that may be Yes
affected by the change.
Procedures for the update of important controlled documentation following any change have been
also established and implemented. Certificates, manuals, plans and drawings, technical documents,
operational procedures and their respective records/forms are always checked for possible
amendments due to a change. This mechanism links with and ties into the Company’s document
control system, so that important controlled documentation remains up-to-date. (SMS Chapter 13
"Management of Change").
7.2.5 Regular reviews are conducted of management of change plans being Yes
implemented.Any changes not carried out within the proposed timescale are
reviewed, revalidated and approved.
If a proposed change is not completed within the set time frame then it must be reviewed and the
initial hazard/risk assessment be revisited and re-approved. A log of all changes is maintained to
identify the purpose, scope, time limitations and progress is monitored against time to ensure that
objectives are being met and risks managed. Any deviations are identified and addressed and any
identified improvements to the plan are recorded. Temporary changes shall not exceed the initial
authorisation for scope or time without review and re-approval by the appropriate level of
management. (SMS Form 033001 Management of Change Form).

Stage 3
7.3.1 A management of change procedure is applied when the company acquires Yes
additional vessels.
Specific procedures and relevant duties and responsibilities for Company’s personnel concerning
the acquisition of new tonnage either 2nd hand or new builds under Company’s management are
included in the SMS. Procedures are also in place to ensure that after vessel’s construction or
acquisition all records shall be maintained to indicate any change, the status of equipment etc. The
procedures apply to both new builds and existing tonnage and include supervision of new builds,
pre-purchase inspection and survey of existing vessels, including priority maintenance
requirements, familiarisation and training requirements both onboard and ashore, a period of
sailing or standby for key vessel personnel prior to delivery, etc. (SMS Chapter 15 "New
Acquisitions", SMS Form OPR 008 Pre-takeover Ship Inspection Report, OPR 026 Vessel Takeover
Checklist)
7.3.2 There is a periodic review of the outcome of all changes to ensure objectives Yes
have been met.
Procedures are in place to ensure that the outcome of all changes is reviewed during the
Management Review Committee meetings in which verification of achieved objectives takes place.
During those meetings any identified issues that need to be resolved are thoroughly discussed and
action plans for meeting objectives are being drafted. (Management of Change Log, MRM Agenda
and Minutes)
7.3.3 A software management procedure covers all shipboard and shore systems. No
Stage 4
7.4.1 For major changes to the shore organisation, management of change No
procedures ensure that manning, competency and experience levels are
maintained so that there is no deterioration in supervision and the
management of key processes.
7.4.2 The company actively seeks out improvements for new build design No
specifications.

Incident Reporting, Investigation and Analysis
Stage 1
8.1.1 Procedures ensure prompt reporting and investigation of incidents and Yes
significant near misses.
The established procedures and forms, regarding prompt reporting and investigation of all
incidents, accidents and near misses, persons/departments responsible for investigation as well as
description of the investigation process are included in the SMS. Investigation reports include
timeframe for close out of corrective actions. Management reviews the deadline till issues are
resolved. This is verified during Management review meetings. (SMS Chapter 9 "Reporting, Route
Cause Analysis and Investigation of Non-Conformities and Near misses")
8.1.2 The reporting and investigation procedures ensure that all mandatory Yes
notifications are carried out within the required time frame.
The SMS includes procedures for the mandatory notification of the incidents to the interested
parties within specified time frames, depending on the incident risk potential. (SMS Chapter 8.3
"Reporting Procedures")
8.1.3 Procedures ensure the fleet is rapidly notified of urgent information related to Yes
incidents and near misses.
The established procedures supported by specific forms ensure rapid notification, consistent
reporting, effective investigation analysis, documentation of incidents, accidents and near misses
and follow up methods to learn and avoid recurrence. The SMS procedures ensure the fleet is
rapidly notified of urgent information related to incidents and near misses. (PMS Deficiency
Module, SMS Chapter 9 "Reporting, Route Cause Analysis and Investigation of Non-Conformities
and Near misses")
8.1.4 Procedures ensure that incidents are investigated and analysed.Corrective and Yes
preventative actions are identified and implemented.
The Company uses industry recognised Incident analysis and Root Cause methodologies to
accurately establish the root cause of incidents. Investigation reports include references to possible
breaches of Company’s and legislative requirements as well as needed actions to prevent
reoccurrences. Relevant procedure is described with the SMS Chapter 9 "Reporting, Route Cause
Analysis and Investigation of Non-Conformities and Near misses". (ABS RCA methodology).
8.1.5 Procedures ensure that the appointed incident investigation team are Yes
appropriately trained and qualified to conduct the investigation and analysis.
The Company provides arrangements for managerial personnel to attend in qualified training
centers or Class Societies courses on how to conduct an incident investigation and root cause
analysis. Moreover, the in-house seminars include incident-investigation training. At least two
Senior Officers onboard each vessel are also certified. The investigating team may comprise shore
personnel, vessel personnel and/or third-party contractors. (SMS Chapter 9 "Reporting, Route
Cause Analysis and Investigation of Non-Conformities and Near misses", SMS Forms CREW 034
Training Matrix for Seagoing Personnel and OPR 027 Training Matrix for Office Personnel)

Stage 2
8.2.1 The incident-investigation procedure ensures that the root causes and factors Yes
contributing to an incident or significant near miss are accurately identified.
Procedures instruct the investigators to decide what information should be collected and evidence
that needs to be obtained. Every endeavour to collect sufficient information from logbook extracts,
D&A tests, Witness statements, VDR and ECDIS data, etc. to understand as much of what has
happened as possible, is been made. Once the causal factors are identified, the root causes of the
incident are identified through an adopted systematic methodology. (ABS RCA Methodology, SMS
Form 022005 Incident Investigation Document Checklist)
8.2.2 The composition of the investigation team is established according to the Yes
severity and type of the incident.
According to the Company’s procedures, the trained person appointed to lead the investigation
shall not be connected with the incident. Resources and personnel that can assist in investigation
include independent contractors. Furthermore, Office key personnel and at least two Officers
onboard each vessel have received Incident investigation training. Appointment of investigators is
based on the risk severity and type of the incident. (SMS Chapter 9 "Reporting, Route Cause
Analysis and Investigation of Non-Conformities and Near misses)
8.2.3 External training in incident investigation and analysis is given to at least one Yes
member of the shore-based management teams.
The Company provides arrangements for managerial personnel to attend training courses on how
to conduct an incident investigation and root cause analysis. Class Societies and other contracting
companies are utilized to provide relevant courses. This information is then handed over to other
relevant shore and ship personnel. (SMS Chapter 9 "Reporting, Route Cause Analysis and
Investigation of Non-Conformities and Near misses", OPR 027 Training Matrix for Office Personnel,
Incident Investigation Training Certificates of Shore Staff)
8.2.4 The safety culture encourages reporting of all near misses and incidents. Yes
The Company, through its established procedures, ensures a simple and user-friendly reporting
system and encourages vessel personnel to report any identified incidents and near misses. Each
received report is being analysed and investigated as appropriate to identify root causes and derive
lessons learnt which are promulgated to the fleet and reviewed at shipboard safety meetings. (PMS
Deficiency Module, SMS Form 302007 SMS Meeting Report in PMS Online ISM Module)
8.2.5 Lessons learnt from incidents are used to prevent any recurrence. Yes
The incident management procedures ensure that the lessons learnt from an incident investigation
are shared across the Fleet and the Office and used to avoid reoccurrence. (Message Log)

Stage 3
8.3.1 Lessons learnt from incidents and near misses and safety performance statistics Yes
are promulgated across the fleet periodically.
All reports received from vessels are monitored. A database of incidents and near misses is
maintained and regularly reviewed and distributed through safety bulletins or circulars to all
vessels and at Company’s seminars. The lessons learnt are used to facilitate improvements in
Company’s HSSE performance. (Message Log, MRM agenda and minutes, KPIs)
8.3.2 Analysis of company incidents and significant near misses is conducted at Yes
periodic intervals.
Quarterly safety performance statistics are produced, reviewed during the Management Review
meetings and disseminated to the fleet. Furthermore, the Management Review Committee
develops programs to address trends and ensure that actions are completed. (Quarterly and
Annual Management Review Meeting minutes, KPIs)
8.3.3 Incidents and subsequent investigations are reported to oil major vetting Yes
departments.
The established procedures provide for reporting of incidents and subsequent investigations and
lessons learnt to Oil Majors’ vetting departments. (SMS Chapter 9 "Reporting, Route Cause
Analysis and Investigation of Non-Conformities and Near misses")
8.3.4 Procedures ensure that incident investigation and analysis refresher training No
takes place after an appropriate period.
Stage 4
8.4.1 Incident analysis data is shared with industry groups. No
8.4.2 Procedures ensure that, where possible, all trained personnel are given the No
opportunity to participate in incident investigation and analysis.

Safety Management – Shore-Based Monitoring
Stage 1
9.1.1 Safety standards are monitored across the fleet during shore-based Yes
management visits to vessels.
It is the Company’s procedure to visit the vessels at frequent intervals in order to monitor their
condition and maintenance. The scheduled S/Ts visits are supplemented by additional visits by the
Company’s Managers which are also properly recorded. All Company’s Superintendents and
Managers fully understand that the promotion of a strong safety culture across the fleet is one of
their most important duties. For this purpose, Seminars, meetings and lectures are held by visiting
shore personnel. (SMS Form 302007 On board Safety Meeting (with superintendents), OPR 012 Top
Management Visit Form)
9.1.2 During vessel visits, every opportunity is taken to promote a strong safety Yes
culture across the fleet.
When Managers or Superintendents visit the vessels, it is required to organize and participate in
Safety Meetings, in order to promote a strong HSSE culture across the fleet. Relevant minutes are
maintained and issues covered are subject to follow-up in the office thereafter. The feedback from
the safety meetings are evaluated and used to improve the company’s safety procedures. (SMS
Form 302007 On board Safety Meeting (with superintendents), OPR 012 Top Management Visit
Form)
9.1.3 Procedures include a documented risk assessment system. Yes

The SMS aims to develop a proactive approach to safety management, both on board and ashore,
that includes identification of hazards and the implementation of preventive and mitigation
measures. The Company’s Risk Assessment program systematically identifies potential hazards and
manages operational risks fleet-wide. The relevant procedures also describe the additional
measures that should be taken to promote an effective safety culture and motivate staff to ensure
that they understand and embrace the requirements of the SMS. Finally, the Company has
established and maintains procedures to engage in a Risk Assessment program designed to identify
potential hazards and exposures, and manage operational risks, including those relating to health
and hygiene. (SMS Chapter 14 "Risk Assessment and Risk Management")
9.1.4 A documented permit to work system is in place. Yes

Comprehensive work permit system, combined with relevant risk assessments, is dealt with in
relevant procedures, including hot work and enclosed space entry. Special procedures establish
that Office approval is a pre-requisite for carrying out a hot work in identified hazardous areas.
(SMS Chapter 7.9.2 "Work Permits")

Stage 2
9.2.1 Risk assessments for routine tasks are used to develop safe working procedures. Yes
The Risk Assessment procedure is used to identify hazards during work planning. The Company’s
guidelines and relevant industry publications provide all the necessary information. Hazards and
risks are systematically identified and assessed to ensure that risk exposure is effectively managed
and considered at appropriate levels of management. Risk assessments are reviewed and updated,
all risk mitigation measures to address identified hazards are incorporated into the SMS
procedures, as required, and records are maintained (SMS Chapter 14 "Risk Assessment and Risk
Management" and SMS Chapter 7.9.2 "Work Permits")
9.2.2 The risk assessment process includes provision for assessing new, non-routine Yes
and unplanned tasks.
The Risk Assessment process includes provision for assessing new, non-routine and unplanned
tasks as well as response and mitigation elements to limit the impact of any unplanned
occurrences and provide for formulation of contingency plans to facilitate safe management and
recovery of the situation. Where no safe working procedure exists, a risk assessment is carried out,
reviewed and approved at an appropriate level. Alternative methods of work are considered and
documented in case the residual risk has been determined to be unacceptable. No new procedure
or equipment that could pose significant threat to safety, health or the environment is introduced
until full consideration of the potential risks has taken place. (Chapter 14 "Risk Assessment and Risk
Management" Table 5)
9.2.3 Risk assessments for new, non-routine and unplanned tasks are available to all Yes
relevant personnel.
All recognized potential hazards or otherwise undesirable operations in the risk-assessment
program are documented and used to improve SMS procedures and create a safe working
environment onboard all vessels. Risk assessments for new, non-routine and unplanned tasks are
available to all relevant personnel which should be familiarised with their contents. (PMS
Document Management Module - Risk Assessment Library)
9.2.4 Procedures ensure that all identified mitigation measures are completed prior Yes
to commencing work.
Prior to any work commencement, procedures are available to ensure that all identified mitigation
measures are completed. In this context, carrying out a risk assessment is a pre-requisite prior to
the issuance of any work permit.
9.2.5 Procedures manage the safety of contractors onboard. Yes

Procedures are available for contractors, riding teams and afloat repairs’ in SMS Chapter 7.9.1.7 "
3rd / Unauthorized Persons". These include guidance about reporting standards, familiarization of
the contractors with the Company’s safe working practices, use of PPE and permit issuance system,
evaluation of their performed works and clear duties and responsibilities between contractors and
vessel’s staff for ensuring compliance with Company HSSE Policies

Stage 3
9.3.1 A formal process is in place for shore management to review all risk Yes
assessments periodically.
The intervals for reviewing the Risk Assessments are defined in the SMS. After this review relevant
documents are reissued in part, or as a whole, if required. The Officers and crew are encouraged to
give their views regarding the level of success in mitigation of risk through improvements to
existing procedures. (Chapter 14.1.6.4 "Approval and Reassessment of RAS")
9.3.2 Proprietary safety tools are used to encourage hazard identification and to Yes
improve safety awareness throughout the organisation.
The Top Management has established and supports various safety tools to encourage hazard
identification and to improve safety awareness safety culture throughout the organisation.
Furthermore, near-miss reporting Campaigns are implemented and promoted, as they help to
reduce operational risks. (Safety Campaigns)
9.3.3 The company selects and maintains a list of approved contractors. No
Stage 4
9.4.1 Management collates all risk assessments for best practice sharing, in order to No
improve the company safety culture.
9.4.2 Periodic (at least quarterly) safety related publication(s) are issued. No
9.4.3 A formal contractor HSSE management system is in place. No

Safety Management – Fleet Monitoring
Stage 1
9A.1.1 Procedures require that safety inspections are conducted at scheduled intervals Yes
by a designated Safety Officer.
The Company has established and implements procedures that meet all regulatory requirements.
The appointed Safety Officers onboard the managed vessels conduct safety inspections at
scheduled intervals and the results are properly recorded, reviewed and maintained. Safety
inspections identify hazards and potential hazards to health, safety and the environment, include
all accessible areas of the vessel and recorded and reviewed at the monthly onboard safety
meetings. (SMS Form 302004 Hygiene Inspection Report, 302007 Safety Meetings On board,
302009 Environment, Health, Safety Inspections)
9A.1.2 The company safety culture encourages all personnel to identify, report and Yes
where applicable address hazards.
The Company’s safety culture encourages all personnel to identify, report and where applicable
address hazards. Hazards that cannot be rectified onboard are immediately reported to
management. The relevant Company’s procedures require a full assessment of the situation to be
undertaken by both shore and ship’s management before the operation can continue. (SMS
Chapter 7.9.1 Proceduresfor Safe Work Performance")
9A.1.3 Onboard safety meetings are held at least monthly. In addition, extraordinary Yes
meetings are held as soon as practicable after any serious incident onboard or
within the fleet.
Safety Meetings are carried out at least monthly and as soon as possible after any serious incident
or accident within the Company. The Company provides guidance as to the format, content and
conduct of ships safety meetings. All records are maintained on board and the Company reviews
and responds to these meeting, as appropriate. (SMS Form 302007 SMS Meeting Form in PMS
Online ISM Module - SMS Chapter 3.4.3.2 "Safety and Environmental Commitee")
9A.1.4 Procedures require daily work planning meetings to take place. Yes
In order to address anticipated risks during shipboard work planning, including implementation of
safe working practices, risk assessment and handling cross-departmental compatibility issues, daily
work planning meetings, formally minuted, are conducted. These meetings identify personnel,
tools and equipment required, establish appropriate PPE requirements and ensure compliance
with work and rest hours. (SMS Chapter 7.9.1.23.4. " Management Team Meeting / Toolbox
Meeting", Logbook 17 Daily Meetings)

Stage 2
9A.2.1 Intervention to prevent unsafe acts and unsafe conditions occurring is actively Yes
encouraged.
Procedures are available which aim to encourage intervention to prevent unsafe acts and unsafe
conditions occurring. These include, but not limited to tool-box pre-work meetings, stop work
authority program, etc. as well as monitoring during the monthly safety meetings. (SMS Chapter
7.9.2.18 Stop Work Authority Program - SMS Chapter 7.9.1.23.4. " Management Team Meeting /
Toolbox Meeting")
9A.2.2 Appropriate training in hazard identification and risk assessment is provided to Yes
vessel personnel.
RA training as well as hazard identification and reporting are included in the Company’s Training
Plan. The Company has established ways to identify and limit hazards to a manageable level by
using the RA process. Periodic RAs are performed by personnel trained in hazard identification and
RA, including expertise from outside the immediate unit, as appropriate. The RA program is
regularly reviewed and higher risk areas reassessed. The crew receives advice on assessing unsafe
acts and conditions, reporting findings and near misses and taking appropriate corrective action.
(SMS Form CREW 034 Training Matrix for Seagoing Personnel)
Stage 3
9A.3.1 Procedures encourage the reporting of safety best practices. Yes
The Company encourages safety best practices identification and reporting and ensures that best
practices identified on individual ships are transferred to the fleet. The Company uses safety
Bulletins and Management Reviews to coordinate best practices; where appropriate the best
practices are incorporated into the SMS.
9A.3.2 Procedures measure and compare the strength of the safety culture across the No
fleet to identify areas for improvement and to provide motivation to vessel
personnel.
9A.3.3 Management identifies opportunities to strengthen their safety culture through No

interaction with fleet personnel.
Stage 4
9A.4.1 Leading and lagging indicators of safety performance are analysed, both across No
the fleet and on an individual vessel basis, in order to identify areas where the
safety culture can be improved.
9A.4.2 Fleet safety trainers sail with the vessel to conduct training and promote the No
company values and safety culture.

Environmental and Energy Management
Stage 1
10.1.1 An environmental protection policy and management plan is in place. Yes
The Environmental Policy (SMS Chapter 2.3.2. "Environmental Management Policy")
includes the Company’s commitment to minimize the environmental impact of our operations; all
company’s personnel and 3rd party contractors are aware and familiar with this policy.
Responsibilities are clearly assigned for each environmental issue ashore and onboard. (SMS
Chapter 7.6 Environmental procedures ANNEX B Office Personnel EMS Responsibilities, ANNEX C
Shipboard Personnel EMS Responsibilities) The Company also maintains procedures for energy and
waste management. Training and familiarization records are maintained.
10.1.2 All sources of marine and atmospheric emissions attributable to company and Yes
vessel activities have been systematically identified.
The Company maintains a proactive approach to environmental management that includes
identification of all sources of pollution attributable to company and vessel activities and measures
for the reduction of potential impacts onboard and ashore (SMS Chapter 7.6 Environmental
procedures)
10.1.3 Procedures minimise marine and atmospheric emissions and ensure that they Yes
are always within permitted levels.
Procedures ensure that all applicable legal and other requirements to which the Company
subscribes are taken into account in establishing, implementing and maintaining its SMS.
Procedures describing methods of monitoring & minimising emissions, disposal methods, etc. are
maintained. (SMS Chapter 7.6 Environmental procedures)

Stage 2
10.2.1 The environmental management plan includes energy efficiency and fuel Yes
management.
The Company’s SMS and the vessels’ SEEMP include all the required procedures for energy
efficiency and fuel management. All voyage data is collected on a voyage by voyage basis, including
time spent alongside and at anchor and reports are submitted to the Office. (EEOI form/KPI)
10.2.2 The environmental management plan addresses efficient use of energy and Yes
includes actions to improve environmental performance.
During Management review meetings the fleet’s energy efficiency and performance is reviewed
and decisions are made regarding further actions for improvement. The Company has established
baseline criteria and relevant targets which are continuously monitored. Regular performance
reviews for machineries are conducted as per PMS. Hull condition and propeller fouling are
monitored as part of SEEMP. (NM per ton KPI)
10.2.3 The company seeks to optimise vessel energy efficiency. Yes

The energy efficiency measures included in the SEEMP provide an overview of the actions that are
already implemented or are under consideration for adoption; the latter are assessed during the
Management Review Meetings and relevant decisions are taken.
10.2.4 The environmental management plan includes procedures for fuel management Yes
in order to ensure regulatory compliance, energy efficiency and reduced
emissions.
The SMS includes procedures for fuel management to ensure regulatory compliance, energy
efficiency and reduced emissions. Fuel sampling and analysis is conducted at every bunkering.
Onboard fuel segregation and minimum stock levels are defined; consideration is also given to
issues that include fuel compatibility in order to minimize sludge production and keep the plant in
optimum operational condition. (SMS Chapter 7.4.13 "Handling of Fuel Oils and Bunkering
Operations")

Stage 3
10.3.1 The potential environmental impact of all company and vessel activities is Yes
subjected to evaluation.
The Management Review Meetings assess and evaluate the measures for the minimization of
emissions and environmental impacts, analyze the results and consider further actions (SMS
Chapter 7.6.1.14.4 "Hull Antifouling Systems", Company Objectives and Targets)
10.3.2 Specific emissions reduction targets are set in the environmental management Yes
plan.
The Company sets quantified pollutant reduction targets and maintains Environmental Programs
containing actions for minimising all the environmental impacts. These targets are under
continuous monitoring and review (Company objectives and targets)
10.3.3 A long-term environmental plan is maintained. No
10.3.4 Environmentally sound ship recycling practices are employed/adhered to. No
10.3.5 Environmental performance improvements are incorporated during the new No

build process.
Stage 4
10.4.1 Available technology is used to enhance energy efficiency. No
10.4.2 The company explores new ideas and engages in technology partnerships No
related to environmental performance.
10.4.3 Fleet environmental performance and energy efficiency is benchmarked. No

Emergency Preparedness and Contingency Planning
Stage 1
11.1.1 Detailed vessel emergency response plans include initial notification procedures Yes
and cover all credible emergency scenarios.
The SMS provides for review of the emergency response procedures based on feedback from drills
results and actual incidents. Masters’ reviews incorporate the results of SMS, SMPEP, etc., review.
The DPA regularly reviews all the emergency plans in consultation with the ships’ crews. (SMS
Chapter 8 "Emergency Preparedness")
11.1.2 A detailed shore-based emergency response plan covers all credible emergency Yes
scenarios.
Contact details are contained in the ERM. The Emergency response team can be contacted 24h per
day. The ERM ensures that there is 24-hour cover that takes account of holidays and work-related
travel arrangements (SMS Chapter 8 "Emergency Preparedness" - Company hotline - SMS Form
OPR 032 All Contact Details)
11.1.3 The shore-based emergency response plan has clearly defined roles, Yes
responsibilities and record keeping procedures.
The SMS describes the shore-based and shipboard emergency teams, and defines the roles and
duties of the team members as well as their contact details. Communications and logistics
personnel are included in the Emergency Response Team. Record keeping procedures are also
incorporated (SMS Chapter 8 "Emergency Preparedness" - SMS Form OPR 027 Training Matrix for
Shore Personnel)

Stage 2
11.2.1 The company provides suitable emergency response facilities. Yes
A suitable dedicated crisis room and other facilities i.e. dedicated phone connection, computer
network points, a whiteboard, TV and video facilities, emergency cabinet with plans/manuals,
Third party emergency contacts, etc., are available in Company’s premises. These facilities are
regularly reviewed to take account of new technology. (SMS Chapter 8 "Emergency Preparedness").
11.2.2 The scope and frequency of drills and exercises is determined by the number Yes
and type of vessels within the fleet and their trading pattern(s).
An onboard drill matrix (SMS Form 302001 Emergency Drill Plan) covers all required drills to be
conducted within a year time. This assists the Masters in planning the monthly drills. Drills are duly
followed up via PMS-Online ISM Module. Additional plan is maintained by the Company for the
annual major ship-shore exercises.
11.2.3 The plan includes procedures and resources to interact with media. Yes
External media response training is provided to key management staff (SMS Form OPR 027 Training
Matrix for Office Personnel) and vessels’ Masters (SMS Form CREW 034 Training Matrix for
Seagoing Personnel). Other individuals, both ashore and aboard, receive training for emergency
situations, as required. An agreement with a Media Handling Company is also in place, to provide
assistance when deemed necessary (MTI agreement).
11.2.4 Lessons learnt from exercises and actual incidents are incorporated into the Yes
emergency response plans.
Lessons learnt are always taken into account when updating emergency response plans. The Drill
program includes critiques to identify and correct deficiencies. Improvement suggestions are
documented and formally discussed (SMS Form OPR 014 Ship Shore Combined Drill Form and
Annual MRM minutes)

Stage 3
11.3.1 Records are kept of participants who have been involved in emergency drills Yes
and exercises.
Qualified stand-ins replacing regular members of the ERT have been included as participants in
Table Top Emergency Drills. Records of participants who have been involved in emergency drills
and exercises are properly maintained.
11.3.2 Arrangements are in place to use external resources in an emergency. Yes

Necessary arrangements to use external resources in emergency situations have been established.
The contact details of the various parties involved in emergencies, including the emergency
response damage stability contractor are detailed in each vessel’s SMPEP. Contact details for
salvage, towing, media consultants and technical departments of classification societies, flag states
and local authorities are also readily available (SMS Form OPR 032 All Contact Details)
11.3.3 Drills and exercises test the effectiveness of arrangements to call on external No
consultants and resources.
11.3.4 Business continuity, in the event of potential disruption to the main place of No
business, has been addressed.
11.3.5 Procedures address recovery following an incident. No
Stage 4
11.4.1 There is a formal business continuity plan identifying and addressing events No
that may result in serious disruption to the business.
11.4.2 The company participates in major emergency exercises involving external No

agencies.
11.4.3 Means to support a protracted emergency response have been identified. No
11.4.4 Additional resources to support crisis management have been identified. No

Measurement, Analysis and Improvement – Inspections
Stage 1
12.1.1 A company specific format is used for conducting and reporting vessel Yes
inspections.
Procedures and standardized format for reporting covering all areas of the vessel and its
equipment are available for vessel inspections by Company’s superintendents. (SMS Form OPR 016
Technical Inspection Report, 004001 Internal Inspection Report)
12.1.2 An inspection plan covers all vessels in the fleet, with at least two inspections of Yes
each vessel a year.
The Company has a policy for minimum two inspections per vessel annually annually (SMS Chapter
10.4.5 "Internal Inspection"). A vessel inspection plan (SMS Form 025003 Internal Inspection and
Audit Program) is drawn every beginning of the year and compliance is continuously monitored.
This plan includes anticipated visit dates against the actual dates (as done), in order to feed
material for discussion in the MRM and address points for improvement. The attendance plan also
indicates with specific identification (colour coding) the attendances which included sailing with
the vessel.
Stage 2
12.2.1 The inspection format is of a standard that is at least equivalent to the vessel Yes
inspection reports issued by industry bodies such as OCIMF, CDI or EBIS.
Company’s inspections guidelines and condition monitoring checklist are used as appropriate,
being both in VIQ-equivalent standards. The checklist in addition incorporates Company specific
items, areas identified from lessons learnt, Company and industry best practices and, where
applicable, vessel type specific items. SMS Form 004001 Internal Inspection Report)
12.2.2 A system records any deficiencies identified by the inspections and tracks them Yes
through to close out.
Internal inspection findings and job orders are fed for monitoring and follow-up in the PMS on the
basis of a due date. Checks are made on the status of open items (open deficiencies or defects not
corrected to the satisfaction of company management) in the quarterly MRM

Stage 3
12.3.1 To improve vessel standards, the company analyses its inspection results and Yes
makes comparisons within the fleet.
Each ship inspection report is used for measuring the level of compliance of the inspected vessel
against the Company’s procedures and the regulatory requirements.
By making comparisons within the fleet and among the findings, weaknesses or anomalies are
identified and corrective action is taken to ensure continual improvement.
12.3.2 In order to improve the inspection process, analysis of inspection results is No

compared with data from third party inspections.
12.3.3 The inspection process identifies weaknesses in personnel familiarity with No

equipment and operations.
Stage 4
12.4.1 Information from detailed analysis of inspections is fed into a continual- No
improvement process.
12.4.2 Information technology is used to enhance the inspection process. No

Measurement, Analysis and Improvement – Audits
Stage 1
12A.1.1 The company has documented audit procedures and standard audit formats. Yes
Controlled checklists for performing and recording all types of internal audits are included in the
SMS. These checklists contain all necessary items for ISM, ISPS Code, MLC (SMS Chapter 12
"Verification, Review and Evaluation", SMS Form 025002 Internal Audit Checklist)
12A.1.2 Company auditors are appropriately trained and qualified. Yes

Assessments/Audits are conducted by properly trained individuals with recognized
credibility, experience and expertise relevant to the operations being assessed . The company
maintains training records of individual auditors and a record of audits conducted by them (SMS
Form OPR 027 Training Matrix for Office Personnel, Shore staff training certificates)
12A.1.3 An audit plan covers all vessels and company offices. Yes
The annual audit plan (SMS Form 025003 Internal Audit and Inspection Program), which is always
kept up to date, covers all Company’s departments/activities and all managed vessels. The audit
system provides a review of the entire organization and the fleet on an annual basis.
Stage 2
12A.2.1 Audit results are reported to management within a specified time frame. Yes
A performance standard for the time taken from completing the audit to distributing the
report has been set. Spot checks are conducted to ensure that this standard is being met. Where it
is not being met, Managers intervene to improve performance (SMS Chapter 12.6 "Reporting and
Follow up")
12A.2.2 Audits are performed in line with the audit plan. Yes
Management reviews number of audits performed against number of audits planned during the
Management Review meetings. Where significant slippage has occurred, Management assign
resources to bring performance back into line with the plan. (Weekly Management Meetings and
quarterly and annual MRM minutes).
Stage 3
12A.3.1 All audit non-conformities are closed out within the prescribed time frame. Yes
The Company’s procedures, records and checks ensure resolutions of findings. The relevant reports
are sent to the DPA as soon as possible and an action plan on how findings will be resolved is
prepared. Actions not resolved after three months are passed to Top Management for resolution.
Records are maintained to demonstrate the status of the recorded deficiencies through to close
out and that all actionable items have been closed out as soon as is reasonably practicable.
Quarterly checks are made on the status of open actions and a summary is provided during
Management Reviews.

Stage 4
12A.4.1 Formal analysis of audit results is performed at least annually and this drives No
continual improvement of the SMS.
12A.4.2 Information technology is used to enhance the audit. No
12A.4.3 A contractor management system which includes periodic auditing is in place. No

Maritime Security
Stage 1
13.1.1 Documented security plans are in place. Yes
The company has documented security plans that cover all aspects of its activities including shore-
based locations, vessels and personnel (Office Security Plan, Ship Security Plan). The company has
identified the personnel responsible for security related matters both ashore and onboard.
13.1.2 The company has documented procedures in place to identify security threats Yes
applicable to vessels trading areas and shore-based locations.
The company has established documented procedures to identify security threats applicable to
shore-based locations (Office Security Plan). Furthermore, the SSP of the company’s vessels include
documented procedures to identify security threats applicable to vessels trading areas. These
procedures include a process for reviewing, when required, the identified threats and measures
against them, in order to keep them update.
13.1.3 Measures have been developed to mitigate and respond to all identified threats Yes
to vessels and shore-based locations.
The company has established measures mitigating and responding to all identified threats to shore-
based locations (Office Security Plan) and to vessels (SSPs). These measures include Access control,
Physical security measures, Drills and training, Security patrols and Searches. Contingency plans
have been developed to respond to any potential breaches of security.
13.1.4 Procedures are in place to obtain, manage and review current security related Yes
information.
The Company has developed procedures for obtaining, managing and reviewing current security
related information for vessels (SSPs) and shore-based locations (Office Security Plan). Also, the
responsible persons ashore and onboard for the review have been identified. The list of sources
from where security information is obtained has been defined.
13.1.5 Procedures include the reporting of potential security threats and actual Yes
security incidents.
The company has established procedures for reporting potential security threats and actual
security incidents that include internal ship reporting, vessel to the company, vessel to external
authorities and Company to external authorities. (Office Security Plan, Ship Security Plan).

Stage 2
13.2.1 Formal risk assessments of company activities are undertaken to identify and Yes
mitigate potential security threats.
The company has developed procedure for formal risk assessments of its activities identifying and
mitigating potential security threats. Ship specific hardening measures have been developed,
documented and implemented. Consideration has been given to the provision of appropriate ship
protection materials/equipment, which have been recorded in a vessel specific ship protection
measures/ hardening plan. (SSPs). The risk assessments are regularly reviewed, updated and the
company procedures are amended, as necessary.
13.2.2 The personnel responsible for security receive training appropriate to their role Yes
and the company’s activities.
The company has established procedure for training of personnel responsible for security,
appropriate to their role and Company’s activities. The procedure also includes identification and
training of alternate personnel for key security roles. The familiarisation process includes security
briefing to all personnel.
13.2.3 Policy and procedures include cyber security and provide appropriate guidance Yes
and mitigation measures.
The company has developed a policy and procedure regarding cyber security, including mitigation
measures and cyber security incident response plan have been established, where also systems
vulnerable to external threats or inappropriate use, with direct or indirect communication links,
have been identified onboard and ashore.
13.2.4 The company actively promotes cyber security awareness. Yes

The company has a documented process for training on cyber security of shore-based personnel,
vessel personnel and contractors. The topics of training include but they are not limited to locking
of unattended work stations, safeguarding of passwords, no use of unauthorised software,
responsible use of social media and control/prevention of misuse of portable storage and memory
sticks.
Stage 3
13.3.1 A travel policy is in place to minimise security threats to personnel. No
13.3.2 Security procedures are updated taking into account current guidance. No
13.3.3 The security policy and related procedures are included in the internal audit No
programme.

Stage 4
13.4.1 Assessments are undertaken of the company’s security measures and No
preparedness.
13.4.2 Independent specialist support is used to mitigate identified security threats. No
13.4.3 Vessels are provided with enhanced security and monitoring equipment. No
13.4.4 Security enhancements are considered for inclusion in refit specifications and No
new-build design.
13.4.5 The company is involved in the testing and implementation of innovative No

security technology and systems.

2017.12.29 TMSA 3 Submission

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Tanker Management and Self Assessment 3

A BEST-PRACTICE GUIDE FOR SHIP OPERATORS

Report name AIWK-7513-6571-3948

© Copyright OCIMF 2017 TMSA Report ID AIWK-7513-6571-3948 1/56

1.1.2 Senior management demonstrates a clear commitment to implementing the Yes

© Copyright OCIMF 2017 TMSA Report ID AIWK-7513-6571-3948 2/56

© Copyright OCIMF 2017 TMSA Report ID AIWK-7513-6571-3948 3/56

1.4.2 HSSE performance targets are continually monitored against KPIs. No

1.4.4 A strategic plan ensures continual improvements in HSSE performance are No

© Copyright OCIMF 2017 TMSA Report ID AIWK-7513-6571-3948 4/56

© Copyright OCIMF 2017 TMSA Report ID AIWK-7513-6571-3948 5/56

© Copyright OCIMF 2017 TMSA Report ID AIWK-7513-6571-3948 6/56

1A.4.3 Senior managers have an assurance programme in place to verify the No

© Copyright OCIMF 2017 TMSA Report ID AIWK-7513-6571-3948 7/56

2.1.4 There is a documented handover procedure for shore-based personnel. Yes

© Copyright OCIMF 2017 TMSA Report ID AIWK-7513-6571-3948 8/56

© Copyright OCIMF 2017 TMSA Report ID AIWK-7513-6571-3948 9/56

2.4.3 The company promotes appropriate interpersonal skills training. No

© Copyright OCIMF 2017 TMSA Report ID AIWK-7513-6571-3948 10/56

© Copyright OCIMF 2017 TMSA Report ID AIWK-7513-6571-3948 11/56

© Copyright OCIMF 2017 TMSA Report ID AIWK-7513-6571-3948 12/56

© Copyright OCIMF 2017 TMSA Report ID AIWK-7513-6571-3948 13/56

3.2.7 There is a documented promotion procedure. Yes

© Copyright OCIMF 2017 TMSA Report ID AIWK-7513-6571-3948 14/56

3.3.4 Personnel selection and recruitment is reviewed annually to ensure it complies No

3.4.2 A documented planning procedure is in place to ensures future manning needs No

3.4.3 Cross-cultural interpersonal skills are promoted. No

© Copyright OCIMF 2017 TMSA Report ID AIWK-7513-6571-3948 15/56

© Copyright OCIMF 2017 TMSA Report ID AIWK-7513-6571-3948 16/56

3A.2.2 A documented disciplinary procedure is in place. Yes

© Copyright OCIMF 2017 TMSA Report ID AIWK-7513-6571-3948 17/56

3A.3.2 An enhanced documented disciplinary procedure is in place. Yes

3A.3.3 Health awareness campaigns are implemented. Yes

3A.4.2 A documented procedure to conduct vessel health-risk assessments is in place. No

3A.4.3 The company provides career development opportunities by arranging shore- No

© Copyright OCIMF 2017 TMSA Report ID AIWK-7513-6571-3948 18/56

4.1.4 The company monitors outstanding planned maintenance tasks. Yes

© Copyright OCIMF 2017 TMSA Report ID AIWK-7513-6571-3948 19/56

© Copyright OCIMF 2017 TMSA Report ID AIWK-7513-6571-3948 20/56

4.4.4 The planned maintenance system includes the use of condition-based No

4.4.5 Comprehensive engineering audits are completed by a suitably qualified and No

© Copyright OCIMF 2017 TMSA Report ID AIWK-7513-6571-3948 21/56

4A.1.2 A procedure is in place to manage the planned maintenance of critical Yes

© Copyright OCIMF 2017 TMSA Report ID AIWK-7513-6571-3948 22/56

© Copyright OCIMF 2017 TMSA Report ID AIWK-7513-6571-3948 23/56

5.1.2 Comprehensive procedures to ensure safe navigation are in place. Yes

© Copyright OCIMF 2017 TMSA Report ID AIWK-7513-6571-3948 24/56

5.2.2 A procedure is in place for appropriate shore-based personnel to conduct Yes

© Copyright OCIMF 2017 TMSA Report ID AIWK-7513-6571-3948 25/56

5.3.3 Comprehensive navigational audits are conducted while on passage by a No

5.4.3 Competency assessment programmes ensure that Masters and navigation No

5.4.4 Navigation officers undertake periodic refresher bridge resource management No

© Copyright OCIMF 2017 TMSA Report ID AIWK-7513-6571-3948 26/56

© Copyright OCIMF 2017 TMSA Report ID AIWK-7513-6571-3948 27/56

© Copyright OCIMF 2017 TMSA Report ID AIWK-7513-6571-3948 28/56

6.3.4 The SMS requires Junior Officers/relevant personnel to be actively involved in No

6.4.2 Comprehensive audits are completed by a suitably qualified and experienced No

© Copyright OCIMF 2017 TMSA Report ID AIWK-7513-6571-3948 29/56

© Copyright OCIMF 2017 TMSA Report ID AIWK-7513-6571-3948 30/56

© Copyright OCIMF 2017 TMSA Report ID AIWK-7513-6571-3948 31/56

6A.4.3 Comprehensive audits are completed by a suitably qualified and experienced No

© Copyright OCIMF 2017 TMSA Report ID AIWK-7513-6571-3948 32/56

7.1.4 Procedures identify emerging requirements. Yes