COMPANY POLICY

The company policy established to achieve the purpose is;

-To establish management system having safety and environment excellence philosophy and to make continuous improvement (No accidents, No harm to people, No damage to the environment)

-The safety and environment related subjects shall always be taken into consideration primarily, and no sacrifice shall be made in this aspect.

-All the necessary sources will be used to establish/maintain healty/hygienic working conditions onboard.

-Risk assessments will be done on each management stages and proactive measurements will be taken against all the risks.

-Always to be alert for emergencies and all the necessary preventive actions will be taken.

-To establish safety and environment philosophy/idea for all the company personnel.

-To ensure continuous improvement of safety management abilities of shore-based and ship-based senior managements.

-To prepare training, drill and familiarization procedures and checklists to maintain a top level control.

-To ensure top quality maintenance and repair standard for company vessels.

-To employ personnel with sufficient competency, quality and ability aboard the ships and ashore.

  • SAFETY POLICY
  • Life and property safety always comes first aboard the ships.

    The safety rules defined by national and international rules and regulations shall be obeyed.

    The safety element shall always be taken into consideration primarily for the activities aboard ships and no sacrifice shall be made in this aspect.

    No activities threatening ship, life, property and environment safety will be allowed aboard the ship.

    Safety related issues shall be given priority in training activities.

    Entire personnel shall participate physically to the muster drills associated with safety.

    No smoking shall be allowed throughout the ship other than appointed smoking areas.

    The firefighting equipment, fixed and portable firefighting systems shall be kept operational and ready for emergency utilization at all times.

    Necessary measures shall be taken at the ports in order to secure physical safety of the ship.

    The deliberate activities seriously threatening safety of the ship shall be considered a reason for termination of employment contract.

  • ENVIRONMENTAL POLICY
  • To establish management system having environment excellence philosophy (No Spill and No Damage to the environment) and to make continuous improvement.

    All required/necessary measures (preventive and proactive actions) shall be taken in order to maximize the effect of environmental protection, to minimize the pollution (zero-spill), to control and prevent them at all times.

    All the environment related subjects and activities shall always be taken into consideration primarily and strongly supported no sacrifice shall be made in this aspect.

    To provide both ship and shore based resources necessary for the effective implementation of the environmental management system.

    Always to be alert for the environmental emergencies.

    To comply with entire national and international legal rules and regulations ensuring prevention of land, air and sea pollution.

    To ensure identification and implementation of duties and responsibilities of the entire company and ship personnel associated with environmental protection in accordance with current procedures.

    To keep and maintain the standards of trainings related to environment protection at the top level.

    To ensure improvement of knowledge and abilities of company and ship personnel associated with environmental protection, especially to cover emergency situations, fully in compliance with local and international rules.

    All the environmental protection systems and equipments conditions and standarts will be kept and maintained on top condition.

    Risk assessments will be done on each environmental management stages and proactive measures will be taken against all the risks.

    To employ personnel having sufficient environmental competency, quality and ability aboard the ships and ashore.

    The external interested parties and other third parties environmental comments/recommendations shall be taken into consideration during environmental management system reviewing meeting(s).

    Company environmental policy should be communicated to all persons working for or on behalf of the organization, contractors working at on organization's facility and external interested parties.

  • HEALTH AND HYGIENE POLICY AND OHSAS POLICY
  • All of the health and hygiene related measures defined by national and international codes, rules and regulations shall be taken.

    The ship sickbays shall be kept in top quality and maintained in this way.

    Periodical health controls of the ship personnel shall be made.

    The personnel not suitable to work at sea due to health reasons shall not be assigned to the ships.

    All kinds of measures shall be taken aboard the ships and ashore to have the personnel to work at a healthy and hygienic environment and necessary regulations shall be prepared.

    Entire ship personnel shall be trained on "First Aid" with applied additional classes.

    We guarantee that the number of accident, injuries and occupational illness will be always decreased.

  • DRUG AND ALCOHOL POLICY
  • The Company is committed to promoting a safe, healthy and productive working environment for all employees.

    The Company recognizes that drugs and alcohol abuse may impair the personnel's ability to perform their duties.

    This is particularly valid for those employees whose tasks entail safety and health risks for themselves and others. The company always provides and support necessary control in order to avoid evident reason that any error or accident they make may cause loss of lives, fire and environment pollution, or third part property damage is to be considered particularly exposed to these dangers by shipboard personnel. It must not be forgotten that a ship is a very complex system which always require efficient personnel ready for all eventualities.

    The Company deems it important therefore to establish that:

    - the possession, use, distribution or sale of drugs by employees is strictly prohibited and is grounds for immediate contract annulations.

    - the possession, use, distribution or sale of alcohol on the managed ships is subject to the Company's specific instructions on the matter. Violation of these instructions is grounds for disciplinary action.

    - being unfit for work because of drugs or alcohol is strictly prohibited and is grounds for immediate contract annulations.

    - Personnel used alcohol or drug shall not be permitted to perform duties which may be critical for the safety of the ship, health of the personnel and risk of pollution.

    - Pilots, office personnel, guests, contractors, vendors and any other person onboard shall be required to comply with the policy restrictions concerning use, possession, distribution and sale of alcohol and drugs and provisions regarding searches. Those who violate the policy shall be sent away from the vessel and may be denied future access..

    CONTROLS ON BOARD

    Deterring Measures:

    Measures aimed at deterring drug smugglers and excessive alcohol consumption by crew members have been adopted by the Company.

    Unannounced Drug And Alcohol Tests:

    Unannounced drug tests are also carried out on board by inviting a health team on a basis not to proceed 1 year. Especially, alcohol tests are performed more frequently by the vessel herself when Master decide necessary to make test(ex: before the duty officer's taking over or before cargo operations) This procedure is in Master's responsibility and it is his choice where, when and who will the involved to these tests. Master may decide to perform these tests under following situations:

    - When a strong suspicion exists of use of alcohol in violation of the Company's specific instructions.

    - after any accident involving the ship. (e.g.: collision, fire, grounding, pollution and any other serious accident on board)

    - When the tasks of the person involved may cause risks to others, to the ship or to the environment.

    A positive test result (over the limits as indicated in OCIMF) or refusal to submit to the drug and alcohol test causes immediate contract annulations.

    The test carried out in ashore's recognized laboratories are to be under the responsibility of a medical doctor.

    The office has to be reported about the result of the alcohol test carried out on board whatever the ratio shows.

    Security Measures

    The following security measures are also taken to avoid drugs being put on board when vessels are in port or at anchor:

    Security control at the gangway and/or on deck (in accordance to ISPS Code requirements.)

    Control that unauthorized vessels and/or divers do not approach the ship. In this respect, the Master shall immediately inform the Port Authority if divers or other suspicious movements of unauthorized people are noticed under the vessel.

    The Master or the Company may decide to conduct unannounced searches for drug and alcohol.

    Procedures And Instructions Company's instructions

    As a company policy, the necessary documentation like circulars and posters which are prepared for warning the personnel are regularly sent to the vessel.

    Flag state circulars regularly will send to the vessel by the Company and to be apply accordingly. These circulars to keep in file both the Company and the vessel.

    Instructions For Carrying Out The Alcohol Test On Board

    The on board test is to be carried out by using the Breath Analyzer

    For what concerns alcohol consumption, the following requirements are to be complied with:

    No seafarer should have at any time more than 0.00% Blood Alcohol Concentration (BAC) level

    The test for the Master shall be carried out by the Chief Officer.

    The tests which is requested at least once a month shall be carried out for related personnel before critical operations when decided for the necessity.

    Instructions For Carrying Out The Alcohol Test On Board

    Unless there is reason for blood testing, the test is carried out only by analysis of the personnel's urine.

    The test will be carried out in recognized ashore laboratories.

    Logging Procedures

    A log book is kept under the Master's responsibility, where the date, time, name of the seafarer, test readings and name and signature of the test responsible are recorded, every time an alcohol test is carried out:

    The drug tests results carried out by the recognized laboratories ashore are kept in a specific file in office and a copy is sent to the vessel.

    Posters

    Posters listing the effects of drug use and alcohol abuse are hung up at various points within the ship's living quarters;

    Posters containing the Company's policy in respect of drug and alcohol use and abuse are hung up at various points within the ship's living quarters.

    Company Controls

    The Company shall verify that the D&A policy is correctly implemented and that tests are regularly performed.

    Distribution and Consumption

    To use of any kind of alcohol strictly prohibited.

    The possession, use, distribution or sale of alcohols by employees is strictly prohibited and is grounds for immediate dismissal.

    Conduct of Alcohol Test

    During the practice of alcohol tests the following procedure must be followed:

    - The responsible person who will make test and the witness must be alone in a separate area from all other personnel with the person to be tested.

    - If the result of test is positive the test be must repeated under the supervision of a witness who must be an authorized officer.

    - The person to be tested has to right to choose his own witness.

  • MAINTENANCE POLICY
  • A "Planned Maintenance System" shall be developed and implemented for maintenance and repair of the engine room and deck equipments.

    The engine room and deck equipments directly affecting ship safety (critical systems/equipments) shall be identified and kept in operational status at all times.

    A critical bench stock level for spare parts shall be identified for ships and these levels shall be maintained.

    During maintenance activities lasting and long term solutions shall be taken instead of daily solutions.

    Proactive measures shall be taken in maintenance and repair activities to be able to keep one step ahead of the incidents

    All the safety measures shall be taken before initiating maintenance and repair works and no sacrifice shall be made in this aspect.

    Original or equivalent parts shall be preferred to supply spare parts.

  • PERSONNEL POLICY
  • Train and employ personnel capable of following and implementing technical developments, using initiative when necessary and bearing responsibility consciousness.

    Take short, medium and long term measures to increase the training standard of the personnel working for the Company to an adequate level defined by international regulations and rules.

    Employ expert and experienced personnel in Company's field of interest and have them to work for Company longer periods.

    In personnel employment give priority to the successful and experienced personnel worked for the Company previously.

    Establish and maintain "Team Work" concept within the Company.

    The criterias of recruitment, promotion and termination will be defined clearly and implemented without tolerants.

    Career planning will be done for all duties, both office and ship staft will be encouraged internal promotion.

  • TRAINING POLICY
  • The Company shall give priority for training activities both at sea and ashore based on the idea that the trained personnel is the greatest potential power in achieving of targets and objectives.

    Plans shall be made to prepare continuous and complementary training activities.

    The training activities in the sector shall be monitored closely and measures shall be taken to have the expert instructors in the field of interest to train the personnel when deemed necessary.

    Close relations shall be established with the education organizations within the sector and joint works shall be carried out.

    The job familiarization training shall be programmed aboard the ship associated with each duty and implemented accordingly.

    The education levels of the personnel shall be tested with regular intervals and additional training shall be provided for individuals found unsatisfactory.

  • QUALITY POLICY
  • Formation and continuity of "Service quality standards" will be performed according to the international commerce rules and regulations.

    Formation and continuity of "Management and Environment protection standards" will be performed according to the national and international maritime rules, laws and regulations.

    All units service quality will be increased to international standards level concerning the customer satisfaction.

    Perception of quality will be created and improved for all units at all levels in hierarchy of the organization.

    All national and international improvements in quality are to be monitored and the out comes will be shared through out the organization.

    All factors that may have a negative impact to service quality standards are to be determined and urgent corrective actions will be taken in order to level with international standards.

    Application of whether service or managerial quality principles will be monitored at all levels.

    There will be no compensation to established quality standards at all units and levels.

    Continuous improvement and continuity of quality standards will be obtained.

  • MANAGEMENT OF POLICY
  • There will be no concession on, safety and enviromental standards, when changing operation procedure, ship's system/equipment and personel.

    When making changes, risk assessment will be done and all necessary precautions will be taken in order to minimise operational risks.

    All changes will be according to both national and international rules and regulations.

    The changes will not be in contradiction with the valid company rules and standards.

    All management of changes will be approved by the required class societies.

    The updating of management of changes will be carried out and followed fastidiously.

    Precautions, for solving/minimising the negative formations due to management of changes will be included.

    According to the changes, the need for trainings will be identified, and will be carried out, where felt necessary.

    The results of the management of change, will be notified to the effected division, department, vessel together with assosiations and authoroties, where ever felt necessary.

    In order to explain the effects of the management of change, familirization trainings will be arranged.

    The effects of Major management changes, on the valid system, will be looked over in detail.

    The request for change coming from within/outside or assosiations/authoroties, will be welcomed. When these change requests are not met within the set time limit, alternative time limit will be arranged.

    The effects of management of change, will be looked at in the Management Review, at the end of each year.

  • BENCH-MARKING POLICY
  • We will be exchanging information with valuable national and international companies, within the sector.

    The market leader international companies within the sector will be followed closely.

    We will be in close contact with education institutions/associations, in order to carry out joint studies at any opportunity.

    Systems and practices, which are tested and successful, will be followed, and arrangements for adaptation within the company management will be our priority.

    Special attention will be given to prevent any private documents belonging to the company, being circulated.

    Always keep in mind that confidential documents should not be circulated, at any time.

    Broadcasts and periodical publications, concerning the sector will be followed, in order to follow the new developments within the sector, which will be implemented to the company structure, if needed necessary.

    Especially for incident and near-miss cases, with wide participated information transfer network, will be set and operated.

  • THIRD PARTY POLICY
  • When choosing a contractor, we must make sure that they suit our rules and regulations, if not these contractors will not be appointed.

    When choosing a contractor, a contractor with ISO quality certificate will be our priority.

    Contractors will undertake to obey our company's rules and regulations, at all stages of their contract.

    Before starting work, the contractor will be trained on companies safety, environment protection and incident prevention procedures, and they will be asked to obey these rules.

    The operations of the contractors, specially the safety and environment safety aspects, are to be kept under control at all times, they will not be allowed to take any action, which is jeopardize our safety rules.

    The performance of the contractors will be monitored and reviewed, which will be used for considered on their next employment.

    The results of our reviews will be circulated to them, in order for them to improve themselves.

    The National contractor companies, especially shipshandlers will be visited and inspected at their premises.

  • RISK MANAGEMENT POLICY
  • Risk analysis and risk assessment are the main factors in the company taking decision consept.

    Having risk management consciousness will be ensured to all responsible management personnel in the office and on board.

    "Company risk bank" is prepared from risk evaluations which are made related to all ports / terminals that take place in our commercial activities and emergency situations that are established whether in the office or on board.

    Risk matricies are prepared accourding to company's special health, safety, environment and finance subjects.

    Degrees / conditions of taking risk and accepting risk of the company will be determined.

  • SAFETY NAVIGATION POLICY
  • The company will safe, reliable and efficient marine transportation.

    Recommendations and guidelines detailed in the following publications to be followed by all vessels: Bridge Procedure Guide - International Chamber of Shipping Bridge Team Management - Nautical Institute. These publications will be available and understood by all personnel involved in navigation and bridge watchkeeping duties.

    It is the Company's responsibility to ensure that the tools required for safe navigation are readily available and that all personnel are properly trained for the tasks they are expected to perform.

    The Company will issue instructions describing the minimum navigational standards to be followed on board.

    The national and/or international regulations relating to navigation shall be strictly adhered to.

    Masters have to take the initiative to ensure that bridge watchkeeping practices and procedures are maintained in accordance with Company and best industry requirements. This is established through good communications, company procedures and Master's standing orders. The OOW is responsible, under the overall command of the Master, for the safe navigation operation of the ship.

    Prior to departure from any port, the Master shall ensure that the vessel is in all respects seaworthy for the voyage.

    The watch-keeping officer shall make effective use of all available navigational equipment including the helm, engines and signalling apparatus when circumstances so require.

    The Master is responsible for ensuring that a full berth-to-berth passage plan (all navigation equipments and systems, all relevant charts and publications with updated corrections) has been completed for the voyage in hand and that this has been checked for completeness and accuracy prior to commencement of the voyage, all bridge watchkeeping officers must sign the plan to confirm their understood.

  • PURCHASING POLICY
  • Third parties as spare part manufacturer-authorizated agent, trader, technical supplies and service provider company will be chosen priority according to having ISO quality certifications and apppointment criterions. Priority;

    1) To have a 14001 Quality certificate,

    2) To have a 9001 Quality certificate,

    3) To have a 9002 Quality certificate,

    4) To be member of IMPA and/or ISSA,

    5) Class society approved service company,

    6) To have a culture of Safety, Environment and Security and putting in practice the all relevant regulations.

    Spare part supplier criterions. Priority;

    1) Manifacturer,

    2) Authorized agent, and

    3) Trader.

    Creterions for spare part and technical equipment. Priority;

    1) To be genuine,

    2) Orginal Equipment Manufacturer,

    3) It will be given much attention and care for not to supply imitation spare part or technical equipment / tools, and

    4) Not to supply asbestos contain and/or toxic contain which can be harmed to the people and environment equipments.

    Company needs from the third parties in regard to company environment policy;

    1) To ask environment friendly material for the packages,

    2) In case of the plastic contain products, to supply high volume package and in order to minimize quantity,

    3) To encourage supplier for the quality certificates, and

    4) The safety, environmental and security precautions will be complied with strickly.

    5) To send company procedures to the makers, traders and service companies.

    Others;

    To receive as much as possible minimum three quotations for all the inquiries for local and outside of Turkey, in case of not obtaining three quotations, the Fleet Manager's confirmation shall be taken for the best/optimal (quality + cost + delivery time + payment term) choosing,

    Prior to supplies to send a information to the master and local agent for the supplies and services due to ISPS practices,

    After completion of supply; Master's "Third party Evaluation" forms to be recorded and these are followed up by the master,

    To ask from suppliers and service providers for a route cause analyze and corrective actions in case of any complain/s in the master's "Third party Evaluation" forms. Also to give feedback to the masters and if necessary to the fleet for the corrective actions received from the concern company,

    To make a feedback for the information received from the manufacturers or their agent or suppliers or service providers related to improvement of their products or new products or new environment friendly materials and packages and warnings as well as all kind of case studies,

    To perform and present the department's K.P.I.(Key Performance Indicators), Risk Assessments and Action Plans periodically properly,

    To perform knowledge share meeting with the manufacturer and their agent / suppliers / service providers annually in order to give new developments in the company and company environment policy, the problems past lived with complains of the vessels and their taken precautions and corrective actions,

    To cooperate with manufacturer and their agent / suppliers / service providers as well as with company departments with high respect, commercial ethic, and

    To follow "Purchasing Process" and "flow chart" according to "Purchasing Process" of the company management manual shall be complied with strictly.