Virono Maritime S.A. endeavours to earn the confidence of the shipowners, charterers, seafarers and the marine industry and other interested parties and be recognized as a high quality, trustworthy international ship manager. This can only be achieved by providing flawless services that satisfy all relevant requirements. The Company shall always provide professional ship management services to owners and charterers, protect their interests and assets under its care, and fulfil all their expectations.

The Company:

• Is committed to always comply with all applicable legal and other requirements that relate to the pertinent hazards and to continually improve the effectiveness of its CMS.
• Adopts a proactive approach concerning the needs of its clients and is responsive to their requests, suggestions or complaints, always trying to improve the value of its services.
• Encourages employee teamwork, personal improvement, cooperation, innovative thinking, initiative, leadership, decisiveness and focus on client’s needs and satisfaction.
• Sets measurable and meaningful objectives and targets and reviews them when appropriate.
• Addresses the needs of interested parties who receive its services or who may be impacted by them.

In order to objectively assess its performance, the Company:

• Establishes criteria for the quality of its services.
• Monitors, measures and analyses its objectives and targets for continual suitability to verify that processes are effectively implemented.
• Identifies and manages the risks and opportunities of its services.

The CMS defines the methods used to achieve Company’s Policies and the associated objectives and targets. Its implementation ensures that all applicable requirements related to managing ships will be satisfied, thus providing the necessary confidence between the Company and its customers.

The Company’s management considers its CMS as the basic tool for providing consistent and effective ship management service and improvement, provides sufficient resources and reviews it regularly to ensure its continuous suitability and effectiveness. The management commits itself in active implementation of the CMS and requires all involved personnel to do the same.

Every suggestion for improvement will be given full attention and will be brought to the highest level of the management.

All Company’s employees, ashore and at sea, are expected to comply with this policy and work towards achieving Company’s objectives. The success of the Company depends on the commitment and involvement of each individual employee.

This policy is continuously reviewed for its suitability and is available to the public and the Company’s customers, vendors and suppliers.

Virono Maritime S.A. holds health and hygiene as first priority in its operations, while its outmost concern is to always ensure that all employees execute their work under safe and hygienic conditions. In order to ensure high standards of health and hygiene, the Company:

• Complies with all applicable legislation and regulations, observes relevant guidelines, and applies responsible standards where laws and regulations do not exist.
• Seeks to identify and evaluate health and hygiene risks related to its operations that potentially affect employees, contractors or the public and establishes appropriate safeguards.
• Communicates knowledge about health and hygiene risks to individuals in potential risk or organizations and the scientific community.
• Determines at the time of employment and thereafter, as appropriate, the medical fitness of employees to perform their work without undue risk to themselves or others.
• Implements programs and appropriate protective measures to control such risks, including appropriate monitoring of employees in potential risk.
• Provides or arranges, as appropriate, for medical services necessary for the treatment of employee occupational illnesses or injuries and for the handling of medical emergencies.
• Provides voluntary health and hygiene promotion programs designed to enhance employees’ well-being and personal safety. These programs should supplement, but not interfere with, the responsibility of employees over their own health care.
• Undertakes appropriate reviews and evaluations of its operations to measure progress and to foster compliance with this Policy.

The Company’s goal is to achieve the highest standards of health and personal hygiene through continuous improvement.

Information about employees are confidential and should not be revealed to non-medical personnel except at the request of the employee concerned, or when required by law, when dictated by overriding public health considerations, or when necessitated by the Company’s Drug and Alcohol Policy.

This Policy has the full support of Top Management, is available to the public and applies to all Company’s employees.

Virono Maritime S.A. is committed to take all reasonable precautions and measures, during the operation of managed vessels, in order to ensure safety at sea, prevention of human injury or loss of life and avoidance of damage to property.

The Company’s goal is to achieve ZERO incidents through continuous improvement.

To fulfil these objectives, the management is committed to the following approach:

• Compliance with mandatory rules and regulations and taking into consideration the Codes, guidelines and standards recommended by the IMO, Flag Administrations, Class Societies and Industry organizations, applicable to operations of managed vessels.
•   Adherence to a Company’s Management System (CMS) by all Company’s employees, including managed vessels, which promotes the concept of HSSQEEn excellence, continuous improvement and enhancement of personnel skills.
• Assigning employees possessing sound skills and capabilities in required areas of responsibility, including adequate verification resources.
• Defining the organization, responsibility, authority and interfacing of the various management functions within the frame of the CMS.
• Providing for safe and environmentally sound practices in the operation of managed vessels.
• Assessing all identified risks to the ship, personnel and environment and establish appropriate safeguards.
• Providing and maintaining a safe working environment onboard to assist in preventing human injury and loss of life.
• Providing the necessary training to ensure that Company’s employees are capable of achieving safety and pollution prevention objectives in the work they perform.
• Providing facilities, systems/equipment and a maintenance system that is suited for the purpose of achieving objectives.
• Conducting management review meetings and management system audits.

This Policy has the full support of Top Management and applies to all Company’s employees.

Virono Maritime S.A. is committed through continuous efforts to improve its environmental performance in all areas required by the international regulations and laws and Company’s Management System and to ensure:

• Pollution prevention that emphasizes source reduction, including necessary funding and human resources, to effectively maintain the onboard systems, equipment and components.
• Minimizing the environmental impact of its operations.
• Continuous reduction of environmental risks.
• Sharing information on environmental performance with external stakeholders.

The Company’s goal is to achieve Zero spills or releases to the environment and reduction in permitted emissions through continuous improvement.
For achieving this goal, the Company:

• Complies with all applicable environmental laws, regulations and requirements and applies responsible standards where laws, regulations and requirements do not exist.
• Responds quickly and effectively to environmental incidents resulting from its operations, in co-operation with industry organizations and authorized government agencies.
• Assesses all identified risks to the environment and establishes appropriate safeguards.
• Shows concern and respect for the environment, emphasizes every employee's responsibility in environmental performance and fosters appropriate operating practices and training.
• Undertakes appropriate reviews and evaluations of its operations to measure progress and to foster compliance with this Policy.
• Conducts and supports research to improve understanding of the impact of its business on the environment, to improve methods of environmental protection and to enhance its capability to make operations compatible with the environment.
• Manages its business with the goal of preventing environmental incidents and of controlling emissions and wastes to below harmful levels.
• Designs, operates and maintains facilities to this end.
• Shares its experience with others to facilitate improvements in industry performance.

This Policy has the full support of Top Management, is available to the public and applies to all Company’s employees ashore and onboard.

It is Virono Maritime S.A. Policy that no seafarer, whatever rank, will navigate the vessel or will operate its equipment while impaired by drugs or alcohol or where there is any risk of such impairment.

In following this Policy, Virono Maritime S.A. :

• Has banned all alcoholic beverages from its managed vessels.
• Has banned any form of drug, with the exception of prescribed drugs, as well as the misuse of legitimate drugs. If a crewmember is found in possession of drugs then the Local Authorities will be contacted immediately.
• Has implemented random testing of all crew for banned substances and alcohol.
• Controls the use of all medical supplies on board the managed vessels.
• Will dismiss and impose penalty, as per National and International regulations, to anybody:
  • using alcohol or banned substances on board the vessel;
  • caught in possession of alcohol or banned substances;
  • found to have been instrumental in bringing alcohol or banned substances on board;
  • found to have a positive trace in any random testing sample, unless prior notice with authorisation for use, had been given to the Master.
• On no account shall a person under the influence of drugs or alcohol, be allowed to stand watch or perform any other duty, involving the safety of the vessel, her crew or cargo, and the public.
• Will take all disciplinary action, including dismissal, against anybody consuming alcohol, while ashore, for at least 4 hrs prior scheduled watchkeeping duties or work period.
• Any crewmember suspected for being under the influence of drugs or alcohol, while on duty, shall be immediately relieved from his duty and placed under observation until the influence of drugs or alcohol subsides.
• All crewmembers understand that it is their duty and benefit, to report immediately to the appropriate Officer or the Master, if they suspect or have evidence that one of their fellow crewmembers is intoxicated.
• The use of alcohol on the part of the pilot while performing his duties is strictly prohibited; if a pilot is noticed to be under the influence of substances resulting to the incapability of performing his duties will not be allowed to be part of the bridge team
• Requires all new recruits, prior their embarkation, to undergo a Drug and Alcohol test.

All employees must be adequately informed on the provisions of this Policy and must comply with their intent. This Policy has the full support of Top Management and applies to all employees.

Virono Maritime S.A. is committed to conducting all aspects of her business with honesty and integrity, and to providing a working environment where high standards of ethical, moral and legal business conduct are encouraged and safeguarded.

The Company is confident in the comprehensiveness and effectiveness of its Management System and its role in ensuring the safety of people and the environment, as well as in the effectiveness of its existing reporting channels.

Furthermore, the Company is committed to a workplace characterized by open communication regarding its business practices. As such, this Whistleblowing Policy has been developed to provide a means for employees and seafarers to raise concerns that cannot be, or have not been, adequately addressed via usual reporting channels without fear of retaliation or discrimination over such reports made in good faith.

The Whistleblowing Policy addresses concerns related to issues of public interest, including, but not limited to, the following:

• A criminal offence;
• Non-compliance with legislation and/or Company procedures, particularly in relation to health and safety at work or environmental protection;
• Dishonesty, either verbal or written (including intentionally maintaining official log books or records inaccurately);
• Malpractice or unethical conduct;
• Financial or non-financial misadministration or malpractice or impropriety or fraud;
• A safety and/or security risk or hazardous condition that may impact the life or health of individuals on board the vessel;
• Miscarriages of justice; and
• The deliberate concealment of any of the above.

If an employee has a legitimate concern in (and holds reasonable belief that the information he has relates to) one of the above areas and wishes to raise the concern in good faith, it should be raised with the Master, DPA or other Company’s representative who may be able to agree a way of resolving the concern quickly and effectively.

Although the Company’s Top Management maintains an open-door policy endeavouring to address individuals’ concerns internally, a concern can also be raised through relevant channels.

Reports can be made without fear of retaliation and be even anonymous. Upon receipt of a report, same will be assessed by the Company’s Top Management and an investigation may commence, if deemed necessary. Any victimization of a member of staff who “whistle-blows”, or any attempt to deter him from reporting, will be regarded as a serious disciplinary offense and will result in action under the Disciplinary Procedures.

Company operates in a socially responsible manner, ensuring the safety of people and the environment, through transparent and ethical behaviour, respecting the following principles:

• Accountability for the organization’s impacts on society and the environment;
• Transparency in the organization’s decisions and activities that have impact on society and the environment;
• Ethical behaviour at all times;
• Respect, consider and respond to the interests of the Company’s stakeholders and employees;
• Accept that respect for the rule of law is mandatory;
• Respect international norms of behaviour, while adhering to the principle of respect for the rule of law; and
• Respect human rights and recognize both their importance and their universality.

The Company addresses the following core subjects in order to identify the issues and priorities that are relevant for the organization: Organizational governance; Human rights; Labour practices; Environment.

Our commitment to this objective is underscored by the daily actions of our employees and their dedication to the numerous programs and practices we have implemented.

We aim to integrate sustainable thinking and corporate social responsibility into all our business processes and business relationships. Employee skills and competencies are developed by continually raising awareness and impartment of training.

We recognize that our operations have a global influence. With this in mind, we work diligently with our employees, local communities and internationally recognized bodies to ensure that social factors are integral to our business principles.

We promote continual improvement as a principal driver by knowledge-sharing practices and the timely review of our management systems while always meeting or exceeding all applicable legislative and regulatory requirements.

The Company, believes that although shipping is by far the most fuel-efficient mode of transport, nevertheless additional action has to be taken to further improve the energy efficiency of ship related operations. The increased energy efficiency eventually results in increased environmental protection by reducing air emissions.

Energy efficiency is controlled primarily through well-planned and properly managed ship operations and needs the personal commitment of everyone involved in the above tasks. To be successful, energy efficiency and conservation must become part of the day to day operation and living onboard.

In our efforts to enhance the energy efficiency on the shipboard operations, the Company is committed to:

Establishing and maintaining a Ship Energy Efficiency Management Plan (SEEMP) which is regularly reviewed by all concerned departments and approved by the management of the Company. This Plan, which applies to all fleet vessels, provides standard procedures and practices on best energy management under the various operational modes of the vessel

Implementing an Environmental Management System supported with several environmental programs with the objective of continually increasing energy efficiency and minimizing energy waste. A set of time-specific, measurable - whenever practicable - and achievable targets shall be established and maintained, which shall relate to a combination of design optimization, in-service performance monitoring and best-practice operational management processes

Promoting energy efficiency awareness through training to the shore and sea-going personnel and implementing energy related Campaigns and other personnel incentive/motivating programs

Monitoring and complying with all applicable legal requirements related to ship energy efficiency management

This Policy shall be periodically reviewed with the aim of being kept always updated so as to function as the “leading light” towards a continual energy efficiency improved performance.

This Virono Maritime S.A. policy outlines the necessary principles that users of social media shall observe, the conditions in which Internet activity will be monitored and actions to be taken upon violation of the established policy. The Company expects all individuals to comply with this policy at all times and to protect the Company’s reputation.

This policy deals with the use and misuse of social media platforms and other websites including but not limited to Social networking websites such as Facebook, CrewToo, MySpace, LinkedIn, Yahoo! Groups, QQ.com, VK.com. Micromedia / Microblogging websites such as Twitter. Multimedia websites such as YouTube and Instagram. Wikis such as Wikipedia. Blogs and News sites where content and comments can be posted. Any other website where user-generated content can be posted for wider sharing. This policy applies to all individuals working at all levels in the Company, either in the office or on board the vessels and covers the use of social media (as outlined above) during work and non-work hours, on personal and Company supplied equipment such as laptop computers and cellular / smart phones. The General Manager, the Heads of Departments and ships’ Masters are responsible for ensuring that the standards set forth by this policy are communicated to their teams and that their own conduct sets a good example in this respect. The Company recognizes the value of social media and expects all staff to use these tools responsibly.
The following basic principles should be observed:

• Be responsible. As an employee, any user-generated content could have an impact on the Company’s reputation, so give careful thought before sharing photographs or video of the Company assets, particularly our ships, facilities or people in uniform.
• Be accurate and honest. In any circumstance in which you are in doubt, or you are uncertain about how to respond to a post, contact the Company for guidance.
• Do not make posts or comments that may be considered defamatory, obscene, libellous, threatening, harassing or embarrassing to others.
• Never use someone else’s copyrights, copyrighted material, trademarks, service marks or other intellectual property. If you see comments relating to the Company that you think should be addressed, contact the Company for guidance.
• Do not use the Company’s logo (in any form) on any personal social media platform. Use of any Company logo must be approved by the Company.
• Respect others in any online social interaction. Do not use social media or any similar form of communication to attack or insult the Company.
• Do not disclose any confidential, proprietary or sensitive information about the Company as well as names of our employees, customers, vendors, contractors, suppliers, competitors or others.
• Do not comment on Company related legal matters, financial performance, competitors, strategy or rumours, unless you are specifically authorized to do so by the Company.
• If any member of the media (social or traditional) contacts you refer them to contact the Company.

Please be aware that violation of this policy may be grounds for disciplinary action up to and including termination of employment.

The purpose and objective of this Policy is to protect the company's information assets (note 1) from all threats, whether internal or external, deliberate or accidental, to ensure operations continuity, minimize damage and maximize return on investments and relevant industry opportunities.

To fulfil these objectives, the management is committed to the following approach:

1. It is the Policy of the Company to ensure that:
   1. Information and Systems identified as vulnerable to Cyber-attacks will be protected from a loss of confidentiality (note 2), integrity (note 3) and availability (note 4).
   2. Regulatory and legislative requirements are to be met.
   3. Cyber Security Contingency Plans have been produced for support.
   4. Cyber Security training will be available to all staff.
   5. All breaches of information security, actual or suspected, will be reported and investigated.
2. Guidance and procedures have been produced to support this policy. These include incident handling, information backup, system access, virus controls, passwords and encryption.
3. The role and responsibility of the Information Security Officer is to manage information security and to provide advice and guidance on implementation of the Cyber Security Policy.
4. All managers are directly responsible for implementing this Policy within their departments.
5. It is the responsibility of each employee/crew member to adhere to the Cyber Security Policy.

NOTES

1. Information takes many forms and includes data printed or written on paper, stored electronically, transmitted by post or using electronic means, stored on tape or video, spoken in conversation.
2. Confidentiality: ensuring that information is accessible only to authorized individuals.
3. Integrity: safeguarding the accuracy and completeness of information and processing methods.
4. Availability: ensuring that authorized users have access to relevant information when required.

The following values and principles have been established and implemented in this respect, shared among all shore based and shipboard employees at all levels:

• The Company shore staff and seagoing personnel shall not be involved in any kind of harassment, abuse or discrimination.
• The Company shore staff and seagoing personnel shall not conceal any identified unsafe act or event which affects or could affect human health and safety, the environment and the property.
• The Company shore staff and seagoing personnel shall carry out their duties in a professional and impartial manner. All Company employees shall act in honesty and good faith.
• All information regarding Company’s operations, projects, reports or any work carried out shall be treated as business confidential to the extent that such information does not conflict with Company’s policy for safety and environmental excellence and is not already disseminated or made generally available to third parties.
• Any kind of offer, gift or bribe in any form direct or indirect, including kickbacks is strongly prohibited in all Company’s operations and processes. Furthermore, the Company prohibits the use of other routes or channels for provision of improper benefits to, or receipt of improper benefits from agents, contractors, suppliers or employees of any such party or government officials.
• Procurements are conducted in a fair and transparent manner.