DRUG AND ALCOHOL POLICY

It is the Company’s 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, DOLPHIN MARINE CO,.LTD:

• Has controlled 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 beyond company procedure;
• 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 authorization 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

ENERGY EFFICIENCY MANAGEMENT POLICY

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. 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
• A set of time-specific, measurable – whenever practicable – and attainable targets has been established and maintained, which 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. It has the full support of Top Management and applies to all Company’s employees.

ENVIRONMENTAL POLICY

DOLPHIN MARINE CO,.LTD Shipping is committed through continuous efforts to improve environmental performance in all areas required by the international regulations and laws and Company’s SMS towards a cleaner environment, and to ensure:

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

The Company’s goal is to achieve ZERO spills 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.
• 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.

HEALTH AND HYGIENE POLICY

DOLPHIN MARINE CO,.LTC 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.

NAVIGATIONAL POLICY

1. Always put navigation safety first.
2. Always follow on the International Regulations for Preventing Collisions at Sea 1972 (COLREGs 1972)
3. A minimum UKC should be maintained as follow:
4. For all vessels when underway: 10 percent of vessel’s navigational draft after allowing for squat.

Note: If the depth of sea bottom more than 200 % percent of vessel’s navigational draft after allowing for squat, no need to calculate UKC.

• For vessels in the channel or in port limit area: 10 percent of vessel’s navigational draft after allowing for squat.
• For vessels alongside a protected berth:
• 0.3m for ships with summer drafts of less than 10m
• 0.6m for ships with summer drafts in range 10m – 18m
• 0.9m for ships with summer drafts in excess of 18 m

Vessels moored to sea berths such as Conventional/Multi Buoy Mooring (CBM) and Single Point Mooring (SPM) must make an additional allowance to allow for sea-swell. This allowance will vary as detailed previously.

Should a charterer request a lesser minimum than stated above, or in ports where a lesser/greater is permitted or the accepted norm, the Master has to notify and consult the Company/ Operation Managers.

In case of navigation with ECDIS when determining UKC, the accuracy of charted depths within the ENCs required for the voyage should be taken into account (Refer Procedure for operation with ECDIS)

• In areas of charting CATZOC 6 (ZOC A1), the UKC should be 10% of calculated vessel draught.
• In areas of charting CATZOC 4-5 (ZOC A2, B), the UKC should be 15% of calculated vessel draught
• In areas of charting CATZOC 2-3 (ZOC C, D), the UKC should be 25% of calculated vessel draught.

Where charting CATZOC is Un-assessed by the ENC producer (ZOC U), reference should be made to other sources of accuracy data before determining the UKC.

QUALITY POLICY

DOLPHIN MARINE CO,.LTD endeavors to earn the confidence of the shipowners, charterers, seafarers and the marine industry 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 SMS.

The Company 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.

The Company encourages employee teamwork, personal improvement, cooperation, innovative thinking, initiative, leadership, decisiveness and focus on client’s needs and satisfaction.

The Company sets measurable and meaningful HSQE objectives and targets and reviews them when appropriate. 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

The SMS 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 it’s SMS 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 SMS 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.

SAFETY POLICY

The Management of DOLPHIN MARINE CO,.LTD 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 accidents 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 Safety Management System (SMS) by all Company’s employees, including managed vessels, which promotes the concept of safety and environmental 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 SMS.
• Providing for safe and environmentally sound practices in the operation of managed vessels
• 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.

CYBER SECURITY POLICY

DOLPHIN MARINE CO,.LTD in order to address cyber security items has published the following Cyber Security Policy. The purpose and objective of this Cyber Security Policy is to protect the company’s information assets 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.

1.Top Management has approved the Cyber Security Policy.

2. It is the Policy of the DOLPHIN MARINE CO,.LTD to ensure that:

• 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).
• Regulatory and legislative requirements are to be met.
• Cyber Security Contingency Plans have been produced for support (note 5). 
• Cyber Security training will be available to all staff.
• All breaches of information security, actual or suspected, will be reported to, and investigated by, the Information Security Manager.
• Cooperating Third Parties (service providers, producers etc) to be reviewed regarding their Cyber Security Policy and performance.

3. Guidance and procedures have been produced to support this policy. These include incident handling, information backup, system access, virus controls, passwords and encryption.

4. The role and responsibility of the designated Information Security Manager (note 6) is to manage information security and to provide advice and guidance on implementation of the Cyber Security Policy. 

5. The designated owner of the Cyber Security Policy has direct responsibility for maintaining and reviewing the Policy. 

6. All managers are directly responsible for implementing the Cyber Security Policy within their departments. 

7. 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 authorised individuals.
3. Integrity: safeguarding the accuracy and completeness of information and processing methods.
4. Availability: ensuring that authorised users have access to relevant information when required.
5. This will ensure that information and vital services are available to users whenever they need them.
6. Depending on the size and nature of the business this may be a part or full-time role for the nominated person.

GENERAL DATA PROTECTION POLICY

This policy is the guidance for GDPR compliance (EU 2016/679), applies to all staff and is supplementary to Company’s policy related to Cyber Security. Data Protection Officer, has overall responsibility for the dayto-day implementation of this policy.

1. Top Management has approved the General Data Protection Policy.
2. It is the Policy of the DOLPHIN MARINE CO,.LTD to ensure that:

• Fair and lawful processing is applied to items subject to regulation
• Regulatory and legislative requirements are to be met.
• Sensitive personal data is protected, secured and handled as per regulation.
• Personal data processed by Company is accurate, adequate, relevant and not excessive, given the purpose for which it was obtained.
• Processing of data is in accordance with the individual’s rights.
• Cooperating Third Parties (service providers, producers etc) to be reviewed regarding their General Data Protection Policy and performance
• All breaches or unauthorized process to be reported to Data Protection Authority within 72 hours.

3. Guidance and procedures have been produced to support this policy. These include incident handling, information backup, system access, virus controls, passwords and encryption.

4. The role and responsibility of the designated Data Protection Officer is to manage information security and to provide advice and guidance on implementation of the Cyber Security Policy.

5. The designated owner of the General data Protection Policy has direct responsibility for maintaining and reviewing the Policy. 

6. All managers are directly responsible for implementing this Policy within their departments

It is the responsibility of each employee/crew member to adhere to the General Data Protection Policy.

SECURITY POLICY

The Company’s Top Management is committed to providing a safe and secure ship working environment and supports its ships to detect and deter terrorist or criminal activities.

In order to enforce this Policy, the Company has developed a Security Management System that meets the following security requirements:

Development, implementation and updating of a Ship Security Plan individual to each Company vessel in accordance with the provisions of the ISPS Code Parts A & B and the US Coast
Guard MVIC 10-02.

Development, implementation and updating of a Cyber Security Plan individual to each Company vessel

• The detection of security threats and the taking of preventive measures against potential security incidents.
• The designation of appropriate senior staff, with overall responsibility for security, within the Company and individual ship.
• Cooperation with the responsible authorities and acting on advice from them. Promotion of security awareness among all employees.
• Establishing a reporting and recording system for security incidents. Establishing, implementing and verifying specific security measures on board.
• Establishing a Cyber security plan on board each vessel

The Company is also committed to providing the appropriate security guidance, advice, documentation and necessary resources in order to meet its security objectives and fully comply with the requirements of the ISPS Code and/or any additional requirements that may be stipulated by the relevant competent Contracting Government.

In addition, the Company is committed to ensuring that the Company Security Officer, the Master and the Ship Security Officer are given the necessary support to fulfil their duties and responsibilities in accordance with Chapter XI-2 of the ISPS Code

Company’s objectives are to

• Provide security procedures and practices for ship operations to protect the security of ports and the wider community and establish safeguards to reduce the risk to crew, passengers and port personnel onboard.
• Improve the security skills and awareness of Company personnel ashore and onboard
• In case there is a conflict between commercial interests and the aims of the Security Policy, the Master will give priority to this Policy and the above-mentioned objectives which will be achieved by: Comprehensive training for Company and ship personnel. The personnel undergo training both immediately upon hiring and continuously during their employment
• Actively promoting security awareness amongst Company and ship personnel
• Taking into account the decisions of the international shipping community.
• Regular documented reviews and internal audits of security procedures and plans in order to allow for constant update and improvement of the Plan.
• Scheduling in advance, as far as possible, the voyage, the cargo handling and all ship’s operations in order to foresee possible dangers and take the necessary precautions.

All employees and crewmembers are expected to comply with the requirements of the SSP and shall be familiar with their relevant security duties and the measures required to protect the ship from any unlawful act.

In the event of an attack on the ship or highjack attempt, the preservation of the lives of ship personnel is to be placed above all other considerations.

In the event of an attack on the ship or highjack attempt, the preservation of the lives of shippersonnel is to be placed above all other considerations.

The Company declares that the CSO and the SSO have adequate knowledge and/or have received training, shipboard personnel with specific security duties have sufficient knowledge and ability to perform their assigned duties and that all other shipboard personnel have sufficient knowledge of and are familiar with relevant provisions of the SSP. The Company ensures that the CSO, the Master and the SSO are given the necessary support to fulfil their duties and responsibilities in accordance with SOLAS and the ISPS code.

This Policy will be revised whenever necessary in order to ensure that the aims set are achieved and to monitor the correctness and effectiveness of the procedures and guidelines given.

Finally, in case of conflict between safety and security, Company hereby declares that safety will be always come first.

CODE OF ETHICS AND CODE OF CONDUCT

• The Company’s shore staff and seagoing personnel shall not be involved in any kind of harassment, abuse, discrimination or child pornography.
• The Company’s 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’s personnel shall carry out their duties in a professional and impartial manner. All Company’s employees shall act in honesty and good faith.
• All information regarding DOLPHIN MARINE COMPANY LIMITED 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. 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.

Responsibilities

Company’s Top Management provides evidence of commitment to the development and implementation of the ML&SMS and continually improving its effectiveness by:

• Establishing the Company’s policies;
• Communicating the importance of meeting the customer’s as well as the statutory and regulatory requirements;
• Ensuring that Company’s objectives are established; 
• Conducting management reviews.

The Company determines, provides and maintains the infrastructure needed to achieve the specified or implied requirements of its customers. Furthermore, the Company determines and manages the work environment, both on board the ships and in the office, as needed, to achieve conformity to the requirements of the provided services.

The Company’s Top Management has appointed a member of the management as the DPA who, irrespective of other responsibilities, has defined roles, responsibilities and authority to:

• Provide a link between the Company and those aboard;
• Liaise with external parties on matters concerning establishment, approval, and timely auditing of the ML&SMS to comply with applicable Codes, standards or industry guidelines;
• monitor the HSQE aspects of the operation of each ship and provide adequate support;
• verify that the ML&SMS is established, implemented and maintained, as appropriate;
• organise management reviews and report to the Top management on the performance of the ML&SMS, including recommendations for improvement;
• promote the Company’s HSQE culture
• provide awareness of meeting customers’ as well as statutory and regulatory requirements.

The DPA has direct access to the Senior Management regarding his responsibilities and support for the ML&SMS implementation. The Company provides adequate resources and support to enable the DPA to carry out his functions. The identity of the DPA is made available to all persons working under the Company’s control.

The Managers of the various departments are responsible for implementing the requirements of the ML&SMS and for ensuring that personnel at all levels of the organization understand the Company’s Policies. All Managers ensure that they have the necessary equipment, resources, personnel and capability to achieve the required safety standards and quality of service

The Master has total responsibility for the operation, seaworthiness and safety of the vessel at all times both at sea and in port. He is responsible for the economical and efficient operation of the vessel. He has the overriding authority and responsibility to act decisively and according to his best judgement, in order to prevent:

• Injury to Personnel or loss of life;
• Damage to the environment;
• Damage to property (including vessels, cargo and other third party property).

Furthermore, the Company ensures that each ship is manned with qualified, certificated and medically fit seafarers, in accordance with national and international requirements.

The Company has also established procedures to ensure that new personnel and personnel transferred to new assignments related to safety and protection of the environment are given proper familiarization with their duties. Ships’ personnel receive relevant information on the ML&SMS in a working language understood by them, and are able to communicate effectively in the execution of their duties.