LAUGFS Maritime Services (Pvt) Ltd. and its Senior Management are fully committed to a ZERO TOLERANCE and ZERO SPILLS policy ensuring that the environment (air, water) in which its ships operate are protected from pollution and continuously strive to identify and correct any conditions perceived to be unsafe and hazardous to the environment. Pollution of the environment by a ship can be caused in a number of ways both as a result of system failure and/ or of human error. LMS is committed to preventing both sources of error through a Planned Maintenance System and a program of education and training of staff and through implementation of a set of procedures in accordance with its GMS System. The objective of the Company is to prevent pollution of the environment from the following sources related to the aspects of its operations: LAUGFS Maritime Services (Pvt) Ltd. shall achieve this objective by maintaining, implementing, and monitoring relevant GMS procedures and instructions

• Oil
• Noxious Liquid Substances
• Cargo Vapour and Engine Emissions
• Sewage
• Garbage
• Dangerous Goods
• Ballast Water
• Halons and CFCs
• Noise
• Anti-Fouling Paints
• Other Sources linked to the operation of the Company’s vessels

It is the Policy of LAUGFS Maritime Services (Pvt) Ltd. to provide quality and professional ship management services to its owned vessels and Charterers, in order to gain the confidence of its customers, seafarers and the marine industry in general, and to be recognized as a trustworthy and dependable ship management Company. The company adhere to mandatory industry rules, regulations and applicable conventions, codes, guidelines and standards set out by the International Maritime Organization, International Labour Organization, Maritime Administration of Sri Lanka, Classification societies, industry standards and terminals. The Company adopts a proactive approach concerning the needs of its clients and is responsive to their comments, requests, suggestions or complaints, trying always to improve the value and quality of its services. The Company sets measurable and meaningful quality objectives and follows and reviews them for ensuring continuous improvement. It is required from all Company employees to know and understand this Policy

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 onboard 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 unlicensed rating, regardless of whether the vessel is underway or in port whether watch standers or not.

The Company shall performed 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.
• Reasonable cause test: performed when there is reasonable belief that violation of this policy has taken place.
• Post-accident test: performed after an accident

Details of the tests are entered in the relevant logbook.

If the alcohol content of any seafarer (including the Master) after properly tested is found to exceed the company set limit (0,20 mg/l breath or 0,4 mg/ml in blood), 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 which 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.

The Company shall perform the following drug tests:

• Pre joining testing.
• Unannounced drug tests by a qualified external contractor.
• Monitoring of supply and distribution of controlled pharmaceuticals.
• Post-accident test: performed after an accident, if deemed necessary.

Details of the tests are entered in the bridge logbook.

If the result of drug test is positive, the crew member will be dismissed without compensation. Immediately the Master must report his name and rank to the DPA and crew Manager ashore, as well as to the authorities. The seafarer is subject to disciplinary action up to dismissal.

LAUGFS Maritime Services (Pvt) Ltd. , having established and implementing an Environmental Management System, believes that despite shipping is by far the most fuel efficient mode of transport, actions have 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. Energy efficiency and conservation must become part of the day to day operation and living onboard for successful results. In order to enhance the energy efficiency on the shipboard operations, the Company is committed to:

• establish and maintain a Ship Energy Efficiency Management Plan (SEEMP) which is regularly reviewed by all concerned departments. 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 attainable targets is established and maintained, which relate to a combination of design optimization, in-service performance monitoring and best-practice operational management processes.
• Promote 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.

The SECURITY POLICY of the Company is aimed at providing a safe work environment on ship, by establishing and maintaining the safety measures needed to prevent unlawful actions that threaten the safety and security of personnel and properties onboard the ships. The objectives of the Company are to:

• Implement the security procedures in operation of the ship to safeguard the security of port facilities and relevant wide range regional communities
• Establish the protection measures to mitigate the risks against the passengers and crew onboard and the personnel of port facilities
• Enhance the ability and consciousness of ship and shore personnel of the Company relating to the security
• Provide an emergency response measures for the potential security incidents.

The foregoing objectives shall be accomplished by:

• Ship security assessment and ship security plan (SSP) for each individual ship,
• Comprehensive training for all personnel of the Company restated to security,
• Positive enhancement of security consciousness by all personnel related to security,
• Periodic review of security procedures and security plans, and internal audit, that should enable a continuous improvement and updating of the security plans.

Every personnel of the Company are required to observe the procedural requirements specified in the ship security plan (SSP), and familiarize themselves with the security related duties and necessary measures to safeguard the ship from all unlawful acts.

The Company shall ensure to give necessary support to the ship to encourage company security officer (CSO), and ship security officer (SSO) to fulfill their duties and responsibilities in accordance with the requirements of chapter Xl-2 of SOLAS 1974 as amended and Part A of the Code (lSPS code A/6.2)

LAUGFS Maritime Services (Pvt) Ltd. is fully committed to ensuring the health and safety of all crew members and staff on board its vessels and in its offices, contracted personnel and any other persons who are directly or indirectly linked with its business and operations. LAUGFS Maritime Services (Pvt) Ltd. is committed to conducting its business with integrity and in accordance with all international, national and local laws and industry standards to which its business activities are subject. LAUGFS Maritime Services (Pvt) Ltd. will ensure that the concept of safe operations is conveyed and understood by all employees and that safe working practices are fully implemented on board all its ships. LAUGFS Maritime Services (Pvt) Ltd. aims to achieve the following objectives, through implementation of our Health and Safety Protection Policy:

• Safety at sea
• Injury and human loss prevention
• Prevention of damage to property (vessel and cargo)
• Assess all identified risks to its ships, personnel and the environment and establish appropriate safeguards