It is the Company’s Policy to promote Safety at sea and in the workplace and to avoid damage to the environment. In order to comply with this Policy, the Company is committed to constantly striving to identify and eliminate, or manage, safety risks associated with its activities and yet ensuring the continual improvement of the management system.

The Company’s objective is to conduct its business in a manner that protects the safety of employees, others involved in its operations, customers, and the public as well as to prevent all accidents, injuries, and occupational illnesses through the active participation of every employee in the Company’s Safety Programs.

In order to achieve these objectives, the Company will:

• Comply with all applicable laws and regulations, and apply responsible standards where laws and regulations do not exist.
• Establish management systems, provide training, and conduct operations in a manner that safeguards people and property.
• Respond quickly, effectively, and with care to emergencies or accidents resulting from its operations, in co-operation with industry organizations and authorized government agencies.
• Stress to all employees, contractors, and others working on its behalf their responsibility and accountability for safe performance whilst at work and encourage safe behavior outside of work.
• Undertake appropriate reviews and evaluations of its documented operations procedures to measure progress and to foster compliance with this Policy.
• Work with government agencies and others to develop responsible laws, regulations, and standards-based on sound science and consideration of risk.
• The company is committed to promoting workers’ participation in safety committee meetings and consultation through suggestions.
• Comply with Stop Work Obligation procedures applied across the fleet.
• Work towards achieving the objectives of the Zero Incident Industry.
• To promote a process approach and risk-based thinking throughout the organization.
• To lead by example.
• To establish and maintain Safety Culture across the organization.
• To achieve Operational Excellence through zero incidents.

Bahr Shipping Company has developed a cyber security policy that sets the company’s guidelines and provisions for preserving the security of our data and technology infrastructure.

“Cyber Security” refers to the protection of information systems (hardware, software, and associated infrastructure), their data, and the services they provide, from unauthorized access, harm, or misuse.

The Cyber Security Policy applies to all employees ashore and onboard, contractors, volunteers, and anyone who has permanent or temporary access to Company’s and Vessels’ systems and hardware.
This policy is aligned with existing policies, rules, regulations, and laws that Pantheon Tankers is subject to.

Cyber Security Policy Strategic Goals:

• Protect the health and the safety of the systems, personnel, and cargo.
• Protect the ability of the ship to operate safely and not to endanger other ships, maritime structures, or the environment.
• Prevent the loss of sensitive information, including commercially sensitive or personal data.
• Ensure the smooth day-to-day operation of maritime information technology (IT), operational technology (OT), and communications systems.

Cyber Security Policy Objectives:

• Provide security procedures and processes so that operators know how to identify a potential cyber security threat.
• Identify and harden systems and networks.
• Establish safeguards to reduce the risk to visitors, crew, and port personnel on board Pantheon Tankers ships.
• Improve the security skills and awareness of Pantheon Tankers personnel ashore and onboard ships, regarding cyber risks.
• Prepare contingency measures for possible cyber security incidents.
• Understanding and countering cyber threats, increasing operational resilience.
• Improve Cyber Security Awareness and management.
• Reduce the system’s vulnerability to cyber threats.

The company’s environmental policy is to prevent the environment from being damaged, in particular, due to our Ship management and operation of ships trading worldwide.

The Company objectives are:

To run a flawless operation with zero spills and to continuously improve environmentally sound performance and pollution prevention from the following sources:

• Zero Spills of Oil, associated products/chemicals
• Zero Spills of Noxious Liquid Substances
• Sewage discharge to be in strict accordance with Marpol Annex IV criteria.
• Zero discharge of Dangerous goods to the environment
• Garbage discharge to be in strict accordance with Marpol Annex V criteria.
• Ballast water to be in strict accordance with the ballast water management plan.
• Zero Discharge of Ozone Depleting Substances (ODS)
• As per MLC 2006, noise and vibration levels shall be maintained and monitored in accordance with the ship’s build criteria and any deviation to be reported to the company.
• Zero application of Anti Fouling paints

To establish and maintain procedures to limit the impact of our operations on the environment

These objectives will be achieved by:

• The systematic identification and assessment of sources of marine and atmospheric pollution;
• Minimizing adverse environmental impacts and waste generation;
• Ensuring the safe and responsible disposal of residual wastes;
• Developing contingency plans for dealing with potential pollution incidents;
• Developing reporting arrangements for all pollution incidents or near-miss occurrences that could have resulted in pollution;
• Promoting the use of equipment and practices that minimize waste generation;
• Establishing reduction targets to minimize discharge pollutants;
• Comply with national and international regulations such as but not limited to MARPOL and meet the requirements of ISO 14001, EU and US regulations;
• Environmentally orientated training for both ship-based and shore-based employees.

Bahr Shipping Company is fully committed to ensuring the health and safety of all crew members and staff onboard its managed vessels and in its offices, contracted personnel, and any other persons who are directly or indirectly linked with its business and operations. The Company has a zero accidents and incidents policy.

The company’s health and safety policy is to prevent accidents and work-related illnesses among the company’s employees, contractors, and visitors. Bahr Shipping is committed to achieving Health and Safety Excellence.

Bahr Shipping will ensure that the concept of safe and healthy operations is conveyed and understood by all employees and that safe working practices are fully implemented ashore and onboard all its ships.

The Company objectives are:

• To provide safe and healthy practices in ship operations.
• To provide a healthy and safe working environment.
• To establish safeguards against all identified risks.
• To continuously improve the competence of personnel ashore and onboard the vessels.
• To be prepared to respond to emergencies related both to safety and environmental protection.

These objectives will be achieved by:

• Undertaking all necessary steps to achieve safety in accordance with the requirements of the IMO Convention of the Safety of Life at Sea, the International Safety Management Code, and other international, national, and classification rules.
• Continuously reviewing and updating the Quality and Safety Management System both in the office and onboard the vessels and designating a shore-based person (DPA) to control and secure implementation of the Safety Policy, to ensure any necessary changes have been reviewed, considered, and reapproved.
• Employing qualified seafarers, experienced with the ship’s type and trade;
• Onboard familiarization and refresher training on the use of the safety equipment, the application of safe working practices, and on risks involved in the type, trade, and operation of the vessel;
• Identifying training needs and providing relevant training onboard and ashore;
• Maintaining safety equipment to remain in good working condition;
• Regular on-board safety- and health inspections by Superintendents;
• Setting up an efficient ship-shore reporting system for safety and health matters;
• Promoting employee participation in measures aimed to achieve the company’s commitment to health and safe working excellence;
• Ensuring that experiences gained with respect to safety and health are shared throughout the Company;
• Free flow of information throughout the vessel including, in particular, the senior officers and BMT to avoid “the one-man error”

All employees on board and ashore shall comply with this policy at all times. This policy is to be displayed in prominent locations onboard the ships and in Bahr Shipping’s offices.

This policy is available to any interested party upon request.

It is the Policy of Bahr Shipping to provide high-quality and professional ship management services that will meet her clients’ needs, requirements, and expectations.

In this respect, the Company has established and maintains an HSESQ Management System, that is designed to continuously improve the quality of the services offered by the Company. The HSESQ is based on the belief that preventing problems from occurring is in the best interests of the Company, its employees, and its customers.

The Company objectives are:

• To gain the confidence of its clients, seafarers, and the maritime industry in general.
• To be recognized as a trustworthy and dependable ship management Company.
• To carry out ship management services in a professional, efficient and safe manner and to meet the requirements of ISM, ISO 9001, ISO 14001, applicable laws, rules and regulations, Flag State requirements, and Industry guidelines such as OCIMF TMSA.

These objectives will be achieved by:

• Setting measurable and meaningful Quality Objectives.
• Recognizing and adapting the Continuous Improvement Cycle
  • Plan: Developing plans that include effective strategies and provide clarity in company policies, purpose, processes, roles, and responsibilities
  • Act: Work to achieve the organization’s objectives by consistent implementation of plans.
  • Measure: Check, evaluate and feedback information on results achieved.
  • Improve: Define targets and focus efforts on areas where maximum benefit and improvement can be obtained
• Defining KPIs (Key Performance Indicators) that will help to drive the Company’s continuous improvement program.
• Adopting a pro-active approach concerning the needs of its clients and being responsive to their comments, requests, suggestions, and complaints, trying always to improve the value of its service and have customers satisfaction.
• Training all personnel, onboard and ashore, in the use of the Quality and Safety Management System, in order to have it fully understood implemented, and maintained at all levels.
• Encouraging all personnel to participate actively in the continuous improvement cycle by preventing, detecting, and reporting non-conformities in order to learn lessons and to prevent a recurrence. Any necessary changes have been reviewed, considered, and reapproved.

With the ultimate objective of protecting Human Life and the Environment and of assuring the highest standards of safety at sea, the Company has established a “Zero Tolerance Policy” with respect to consumption and possession of drugs & alcohol on board the vessels.

This Policy and the implementation details that are described below guarantee that:

• no seafarer will navigate a ship or operate its onboard equipment while impaired by substances;
• all seafarers must be able to respond at any time in an emergency situation using their best capabilities and unobstructed judgment.

The Master is responsible for the implementation of the drug & alcohol policy on board his ship.

The company shall provide him with the equipment and the necessary guidance to administer alcohol tests for all employees, officers, and ratings, as well as all the necessary support to implement the disciplinary action.

These regulating policies apply to all Company personnel during their employment period whether onboard or ashore.

ALCOHOL REGULATING POLICY:

Zero Tolerance” applies to all alcoholic beverages, including beer. This means that drinks containing alcohol are not permitted on board Company vessels and may not be consumed by any officer or rating, regardless of whether the vessel is underway or in port whether watchkeepers or not.

The Company shall perform the following alcohol tests:

• Pre-Joining: performed by the Company or by its Crewing Offices depending on the seafarer’s location.
• On-Board Random testing: performed randomly and unannounced on board by the Master and Safety Officer to Master’s discretion but all crewmembers including the Master must be tested at least once (1) per month.
• Reasonable cause test: performed when there is a reasonable belief that violation of this Policy has taken place.
• Post-accident test: performed after an accident on those who were directly involved.

Details on frequency and procedure for the above tests are presented in the relevant Procedures of the Company SMS.

Details of the tests are entered in the logbook.

If the test reveals that any seafarer (including the Master) is under influence of alcohol, he will be dismissed without compensation and his name and rank must be immediately reported to the DPA and Crew Manager ashore.

DRUG REGULATING POLICY

Zero Tolerance” means that the Use, Possession, Distribution or Sale of Drugs & Substances, is Prohibited

Any use of a prescribed controlled drug that causes, or contributes to unacceptable job performance or unusual behavior should require the seafarer to be excused from duty until such times as he is repatriated, or treatment and its after-effects ceased.

Attention: Officers and crew when embarking must declare to the master any kind of prescribed pharmaceutical drug that they are using and/or are carrying with them.

Company shall perform the following drug tests:

• Pre joining testing.
• Unannounced drug tests by a qualified external contractor following chain procedures, at least once (1) per year;
• Monitoring of supply and distribution of controlled pharmaceuticals.

If the result of the drug test is positive the Crewmember will be dismissed without compensation. Immediately Master must report his name and rank to the DPA and Crew Manager ashore.

Drug & Alcohol Test Procedure

Unannounced Drug & Alcohol tests are performed by a qualified external contractor following chain procedures, at least once per year (1). Details on frequency and procedure for the above tests are presented in the relevant Procedures of the Company Safety & Quality Management System. Analysis results are forwarded to the Company for evaluation and record keeping.

All employees on board and ashore shall comply with this policy at all times. This policy is to be displayed in prominent locations onboard the ships. This policy is available to any interested party upon request.