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Annex 1

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SHIP MANAGEMENT MANUAL

(ENGLISH VERSION)

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SHIP MANAGEMENT MANUAL


FIRST EDITION

Notes:
This manual is valid from the issue date.
This manual is not to be altered or marked in any way.
Any review or alteration to this manual is to be carried out as per the system procedures.
Any revisions of this manual will be recorded on the Revision sheet.

Issued by: Approved By:

PT Jala Nusantara Mardika

Head of Ship Management Team

This publication is the property of PT Jala Nusantara Mardika. No part of this publication is to
be reproduced, stored in a retrieval system, or transmitted in any form or by any means without
the prior permission of PT Jala Nusantara Mardika.

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RECORD OF REVISION

Record of all the previous revisions are maintained in office with Company Management System
team.

Chapter Page Rev. No. Date

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TABLE OF CONTENTS

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ABBREVIATION / ACRONYMS
CDTR Controlled Document Transmittal Record

DOC Document of Compliance

DPA Designated Person Ashore

FAC First Aid Case

HR Division Human Resource Division

HSM Health & Safety Manual

ISM Code International Safety Management Code

ISO International Organization for Standardization

ISPS International Ship and Port Facility Security

IT Division Information Technology Division

HSMT Head of ship management team

IT Information Technology department

LTI Lost Time Injury

LWC Lost Workday Case

MR Management Representative

MTC Medical Treatment Case

NC Non-Conformity

OHSAS Occupational Health and Safety Management System

PMS Planned Maintenance System

PPD Permanent Partial Disability

PTD Permanent Total Disability

QHSE Quality, Health, Safety and Environmental

RWC Restricted Work Case

SMC Safety Management Certificate

SOLAS International Convention for Safety of Life at Sea

SOPEP Shipboard Oil Pollution Emergency Plan

STCW International Convention on Standards of Training, Certification and Watch


keeping for Seafarers.

SUPT Superintendent

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TRC Total Recordable Case

AOH After Office Hours

CBA Collective Bargaining Agreement

DCR Document Change Request

DOT Department of Transportation

DWT Deadweight

IACS International Association of Classification Society

IAPH International Association for Ports & Harbors

ICS International Chamber of Shipping

ILO International Labor Organization

IMDG International Maritime Dangerous Goods

IMO International Maritime Organization

ISF International Shipping Federation

ISGOTT International Safety Guide for Oil Tankers and Terminals

ITU International Telecommunication Union

LOF Lloyd’s Open Form

OCIMF Oil Companies International Marine Forum

SMM Ship Management Manual

SMPEP Shipboard Marine Pollution Emergency Plan

SMS Safety Management System

UMS Unmanned Machinery Space

VRP Vessel Response Plan

WHO World Health Organization

CMS Common Marine Services

CTS Common Technical Services

SMT Ship Management Team

CMPT Competency Management Team

FSC Flag State Control

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IGF International gas fuel (gases or other low-flashpoint fuels)

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DEFINITION
Accidents
Accident is an uncontrolled or unplanned event or consequence of events that results in an injury or
harm to people, damage to environment, damage to property or loss in profitability.

Administration
The Government of the State whose flag the vessel is entitled to fly.

Company
The Owner of the ship or any other organization or person such as the manager, or the bareboat
charterer, who has assumed the responsibility for operation for the ship from the ship owner and
who, on assuming such responsibility, has agreed to take over all the duties and responsibility
imposed by the Code.

The Company, with respect to the managed vessel is acting as the Owner’s representative. Contact
details can be found in Ch. 4.

Company/Office
Is the PT Jala Nusantara Mardika

Controlled Document
Any document issued which has been uniquely identified as a “Controlled Document”, is valid and
relevant to a specific operation and is traceable for recall. Only “Controlled Documents” shall be
used for work affecting safety and pollution prevention. Any document, which has not been uniquely
identified as a “Controlled Document”, is a Non-Controlled Document.

Corrective Action
The action that is taken to remove the cause of an occurred non- conformance and to prevent
recurrence.

Designated Person
The person designated by the Company to provide the link between the Company and those
onboard. The Designated Person has access to the highest level of management and has the
responsibility and authority to monitor the safety and pollution-prevention aspects of the operation
of the vessel and to ensure that adequate resources and shore-based support are applied, as
required.

Fatality
A death directly resulting from a work injury regardless of the length of time between the injury and
death.

Note: fatalities are included in the Lost Time Injury count.

First Aid Case (FAC)


This is one-time treatment and subsequent observation or minor injuries such as bruises, scratches,
cuts, burns, splinters, etc. The first aid may or may not be administered by a physician or registered
professional.

Incident
An incident is an accident, near miss or dangerous occurrence.

Lost Time Injuries (LTIs)

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Lost Time Injuries are sum of Fatalities, Permanent Total Disabilities, Permanent Partial Disabilities,
and Lost Workday Cases.

(LTIs = Fatalities + PTD + PPD + LWC)

Lost Workday Case (LWC)


This is an injury which results in an individual being unable to carry out any of his duties or to return
to work on a scheduled work shift on the day following the injury unless caused by delays in getting
medical treatment ashore.

Note: An injury is classified as an LWC if the individual is discharged from the ship for medical
treatment.

Major Non- Conformity


Major Non-Conformity means an identifiable deviation that poses a serious threat to the safety of
personnel or the ship or a serious risk to the environment that requires immediate corrective action
and includes the lack of effective and systematic implementation of a requirement of this Code.

Medical Treatment Case (MTC’s).


This is any work-related loss of consciousness (unless due to ill health), injury or illness required
more than first aid treatment by some physician, dentist, surgeon, or registered medical personnel,

e.g. nurse or paramedic under the specific order of a physician or if at sea with no physician onboard
could be considered as being in the province of a physician

MTCs Include:

Injuries which result in loss of consciousness, even if the individual resumes work after regaining
consciousness (N.B. this does not cover loss of consciousness due to ill):

Sutures for non-cosmetic purposes Use of casts, splints, or other means of immobilization

Any surgical treatment


Removal of embedded objects from eye by surgical means Use of other than non-perspective drugs
or medications Use of series of compresses for treatments of bruises, sprains, or strains

MTC’s exclude the following


First aid, LWCs and RWCs

Hospitalization for observation without treatment

A one-off tetanus injection

Consultative visit to, or examination by, a physician or registered processional for the purpose of a
confirmatory check.

Near Miss
Any uncontrolled or unplanned event that under slightly different circumstances could have led to a
loss in the form of personal injury, environmental damage, or property damage.

Non-conformity
Means an observed situation where objective evidence indicates the non-fulfilment of a specified
requirement.

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Objective Evidence
Quantitative or Qualitative information, records, or statements of fact pertaining to the existence
and implementation of a Safety Management System element, which is based on observation,
measurement, or test and which can be verified.

Observation
A statement of fact made during a Safety Management Audit and substantiated by objective
evidence.

Permanent Partial Disability (PPD)


Permanent Partial Disability is any work injury which results in the complete loss, or of use, of any
member or part of the body, or any impairment of function of parts of the body, regardless of any
pre- existing disability of the injured member or impaired body function, that partially restricts or
limits an employee’s basis to work on permanent basis at sea. Such an individual could be employed
ashore but not at sea in line with Industry Guidelines.

Permanent Total Disability (PTD)


Permanent Total Disability at any work injury which incapacitates an employee permanently and
results in termination of employment on medical grounds (e.g. Loss of limb(S) permanent brain
damage, loss of sight) and precludes the individual from working either at sea or ashore.

Preventive Action
Action that is taken to remove the cause of a potential non- conformity.

Restricted Work Case (RWC)


This is an injury which results in an individual being unable to perform all normally assigned to
another job on a temporary or permanent basis on the day following the injury.

Note:
The following come into the category of “less than normal assigned work functions”
Performing all duties or normal assigned work functions but at less than full time schedule;
Performing limited duties at normally assigned job at fulltime schedule; and,
Transfer to other duties.
Safety Records
Documented evidence of actions taken to achieve the standards required as lay out in the Safety
Management System procedures and to demonstrate the effectiveness of the Safety Management
System. Safety records shall include pertinent sub-contractor records.

Senior Officers
In vessels - Master, Chief Officer, Chief Engineer, and Second Engineer.

Total Recordable Cases (TRC)


The sum of all work-related fatalities, los time injuries, restricted work injuries and medical
treatment injuries: TRCs = LTIs + RWCs + MTCs

Work Injury
This is any sign or symptom of physical damage or impairment to any part of the body directly
resulting from an accident regardless of the length of time between the incident and the appearance
of the injury.

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1 INTRODUCTION

1.1 THE COMPANY


Synergy Maritime Private Limited (SMPL) is a ship management company which was
established in 2006. SMPL head office is located at the following address:
PT Jala Nusantara Mardika
Patra Kuningan – Sout Jakarta
Telp: +62-
Email: ops.jnm@sarana-global.com

Types of vessels operated by the company on behalf the owners are:


 Cable Ship
 Cable Barge

1.1.1 COMPANY RESPONSIBILITY FOR VESSEL OPERATIONS


Assignment of responsibility for the operation of the vessel will be communicated by the
Owner of the vessel to the respective Flag Administration before taking over the vessel.
The Ship Management team (SMT) shall maintain copies of such correspondence from the
owner to the Administration. A copy of the same shall be available with the Master of the
vessel.

1.1.2 CONTEXT OF THE ORGANISATION


Synergy Group through its ship management companies located across the globe provides
technical management services to its esteemed customers in compliance to the
International and Local legislations.
Technical management services, shall include but not limited to:
Developing, Implementing, Monitoring, and Reviewing the Policies and Procedures to
operate the vessels in safe and effective manner, in compliance to the applicable
regulations and to high standards recommended in the industry (Hereinafter called -
QHSSE management System – Quality, Occupational Health, Safety, Security, and
Environmental Management system – or Integrated Management System).
Maintain the assets to the highest standards in the industry and to entire satisfaction of the
customer.
Company identifies, analyses, monitors and reviews factors that may affect our ability to
satisfy our customers and stakeholders, as well as; factors that may
adversely affect the stability of our process, or our management system’s integrity.
To ensure that our Integrated Management System is aligned with our strategy, whilst
taking account of relevant internal and external factors; we initially collate and analyses
pertinent information in order to determine potential impact on our context and subsequent
business strategy.
Company then monitors and reviews this information to ensure that a continual

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understanding of each group’s requirements is derived and maintained. To facilitate the


understanding of our context, we regularly consider issues that influence our context
during management review meetings and are conveyed via minutes and other periodical
reports.
The output from this activity is evident as an input to the consideration of risks and
opportunities, and the actions that we take to address them.
Although we acknowledge that ISO 9001:2015 does not require our organizational context
to be maintained as documented information, we maintain and retain; in addition to this
document, the following documented information to describe our organizational context:
Analysis of future plan, strategies, and statutory and regulatory commitments pertaining to
safety and environmental protection;
Analysis of Industry performance related to QHSSE;
Safety and security reports from Industry;
Technical reports from technical experts and consultants from Industry;
Minutes of meetings (Management and review minutes), process maps and reports, etc.

1.1.3 INTERNAL ISSUES


The following are the identified Internal issues with regards to the context of the
organization:
Identifying and employing suitable qualified individuals
Identifying and providing appropriate training to ship and shore staff
Ensuring that the ship and shore staff are adequately motivated
Challenges in complying with the stringent Local/National/International regulations.
Ensuring effective communication across all levels of the organization, both on shore and
on vessels
Identifying and readying up to the challenges of Market demands
Identifying and working with Subcontractors to enhance the system improvement.
Ensuring harmony across the group keeping different cultural backgrounds in mind
Ensuring the processes are appropriate and does not result in another risk.
Ensuring adequate financial resources are available to effectively implement the
management system.

1.1.4 EXTERNAL ISSUES


The following are the identified External issues with regards to the context of the
organization:
Stringent requirements and regulations from the following:
Authorities – Port States, Flag States, and other government authorities boarding the
vessels
Charterers and their agents
Terminals and Ports

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Industry regulatory bodies such as IMO, Classification Societies


Industry requirements (SIRE / TMSA)
Legal issues – arising out of claims
War and other acts that are beyond the control of organization
Not understanding changing customer and market needs
Not understanding the trends that is having an impact on the objectives
Economic backdrop and changing Technology
Cultural and Social

1.1.5 RELEVANT INTERESTED PARTIES


Company recognizes that we have a unique set of interested parties whose needs and
expectations change and develop over time, and furthermore; that only a limited set of
their respective needs and expectations are applicable to our operations or to our quality
management system. Such needs and expectations broadly include those below.
Ship Owners and their customers
Charterers
Bareboat Charterers
Sub Charterers
Ship Agents
Ship Owners - Not to exceed the budget that is agreed between the Ship Owner and the
Company. For the Charterers / agents - To ensure safety of cargo and Environment;
Regulators and their appointee
Flag State
Port State
Classification Society’s
To comply with their rules and requirements;
Ship and Shore Staff:
Employment, motivation, career progression, safe working requirements and improving
self;
Insurers:
To ensure the safety of people, assets, environment are adequately insured; Cargo
Interested Parties
 Ports
 Terminals
 Shippers
 Charterers
 Safety of the port and terminals.
Sub-Contractors:
Relationship to be beneficial for both the parties

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Owners / Shareholders:
Growth and profitability of the company
To ensure that our Services and processes continue to meet all relevant requirements, we
identify and assess the potential impact of any relevant needs and expectations that may be
elicited from the interested parties.
Where appropriate, to ensure that our processes are aligned to deliver the requirements of
our interested parties; we convert relevant needs and expectations into requirements which
become inputs to our Integrated Management Services and to our services.

1.1.6 STRATEGIC DIRECTION


To ensure compliance with the company’s vision, mission and values the strategic
direction is set as below:
Work towards achieving as a globally trusted and preferred shipping company providing
holistic and comprehensive solutions in ship management;
Establish a working culture prioritizing Occupational Health, Safety, Security and
prosperity of people, assets, and environment;
Continuously strive to make this world a safer and better place for all stakeholders by
working towards zero injuries, damages, and environmental pollution;
Leverage the global understanding and domain expertise to cater to dynamic customer
needs;
Innovate continuously and exploit the possibilities of latest technologies to keep ahead of
rapidly changing industry trends;
Build long standing partnerships based on integrity, shared values, and mutual benefits;
Expand our team by employing right talents and providing them with vibrant, conducive,
and progressive work culture;
Contribute to the wellbeing and progress of community by promoting and upholding our
commitment towards society through CSR initiatives
Identify, Analyze, and Review the requirements of the interested parties periodically.

1.1.7 VISION, MISSION AND VALUES


We are a young and dynamic team steered by our core values and strong domain expertise.
Every phase of our evolution and growth is driven by integrity, profound conviction in
human values and deep-rooted concern for environment. Our Vision, Mission and Values
reflect the unique DNA of our organization and define the code of conduct that will guide
every employee and associate through our growth and success.
1.1.7.1 OUR VISION
Our roadmap starts with our vision, that is – “To be a globally trusted and preferred
shipping company providing holistic and comprehensive solutions in ship management.
Safety, security, and care for our people, assets, and environment remain our priority. We
continually strive to make this world a safer and better place for all stakeholders by
working towards zero injuries, damages and pollution and continuously work towards
reduction in permitted emissions.
1.1.7.2 OUR MISSION
Our mission serves as the framework for our roadmap and guides every aspect of our

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business by describing what we need to accomplish in order to achieve our vision. We


shall:
Leverage our global understanding and domain expertise to cater to dynamic customer
needs;
Innovate continuously and exploit the possibilities of latest technologies to keep ahead of
rapidly changing industry trends;
Build long standing partnerships based on integrity, shared values and mutual benefits;
Expand our team by employing right talents and providing them with vibrant, conducive
and progressive work culture;
Contribute to the wellbeing and progress of community by promoting and upholding our
commitment towards society through CSR initiatives.
1.1.7.3 OUR CORE VALUES - I -STEER SYNERGY
Our core values are the deeply held beliefs and are the seeds of our organizational culture.
They serve as a compass for our actions and describe how we behave both individually
and collectively. Our anagram for the core values- i-STEER Synergy, helps embedding of
the core values into each individual in our organization.

1.1.8 MAIN PROCESSES


The main functional processes of the company are as below.

1.1.9 INTEGRATED MANAGEMENT SYSTEM


1.1.9.1 SCOPE AND PURPOSE
Based on the analysis of the issues and requirements Company has established the scope of
our Integrated Management System in order to implement our objectives and our policies
that are relevant to our context, Services and any interested parties. Company commits to
work towards the Health, Safety, and Environmental
Excellence, which means to work towards more than “mere compliance”.
To achieve this, an integrated management system has been developed comprising the
requirements of
 Company’s Management Principles,
 International Safety Management (ISM) Code, as amended,
 ISO 9001: 2015 Quality Management System Standard, as amended
 ISO 14001:2015 Environment Management System Standard, as amended, and
 ISO45001: 2018 Occupational Health and Safety Management System
Specifications, as amended.
 Industry Recommendations such as TMSA.
This integrated management system shall provide measures to identify and promote best
Practices from the industry and across the fleet. Company shall initiate a “QHSE
excellence campaign” to reach the aspiring goal of Zero injuries; Zero damages; Zero
pollutions in shipboard operations.
Ship Management Manual (also called Integrated Management System Manual) provides
the framework and guidelines for the management system.

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OBLIGATION
Company employees are required to be aware of these policies and through regular
reference to the Integrated Management System, understand the relevant safe working
practices and procedures contained within the management system appropriate to their
role.
OVERVIEW
The Management System established to achieve the objectives set out on the Company
Policies consists of manuals, circulars, forms, and checklists are structured as follows:

Figure 1- Level of Document

Level 1 – Ship Management Manual


This manual provides the policies, management commitment and objectives for the
implementation of Integrated Management system on board the ships and in office.
Level 2 – Operating manuals, procedures for office and ships
This level includes all other manuals which are applicable to both the ships & the office,
specific to the office and specific to the ships. Company procedures in this level are
indicated in the table given in the next page. In addition to the company manuals
mentioned in the table including ship specific manual such as Ballast Water Management
Plan, Garbage Management Plan, Shipboard Oil Pollution Emergency Plan, Vessel
Response Plan, ECA Manual, VOC Manual (for tankers only), STS (for tankers only), Bio
Fouling Management Plan, Ship Security Plan, Emergency Towing Arrangement Manual,
Solas Training Manual are also included in level 2.
Level 3 – Forms & Checklists
Forms and checklists are prepared based on the procedures and are used by the operators
as an aid to memory. It ensures completeness and consistency while carrying out
operations.
Level 4 – Circulars / Bulletins
This level includes Company circulars/bulletins, manager’s/owner’s instructions, flag

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circulars and Industry bulletins sent from the office to the vessels.
These circulars and manager’s instructions, form part of the company’s management
system and are used to supplement the manuals with additional information which may be
later included in the Level 1 & 2 documents. Security circulars will be sent separately as
and when necessary.
The level 4 documents may be retained in soft copy or in hard copy which shall be
accessible to all the personnel on board and in the office, unless specifically mentioned.
LOCOATION
S. No. LEVEL TITLE OF MANUAL OFFICE SHIPS
ON SHIP

1. LEVEL 1 Ship Management Manual Yes Yes Ships Office


2. Office Procedure Manual
3. Criteria and Guidelines for Manning Yes No

4. Health& Safety Manual Yes Yes Ships Office


5. Contingency Manual Yes Yes Wheel house
6. Navigation Manual Yes Yes Wheel house
LEVEL 2
7. Technical Manual Yes Yes ECR
8. EMS Manual Yes Yes Ships Office
Yes
Cargo Operations manual
(specific to
(Oil Tanker / Non-Tanker Gas Ships Office / CCR
9. Yes (all) vessel
manual/chemical manual)
type)
10. Office forms and checklists Yes No
LEVEL 3
11. Shipboard forms and checklists Yes Yes Ships Office
12. Circulars/ Bulletins Yes Yes Ships Office
13. Manager’s / Owner’s Instruction Yes Yes Ships Office
LEVEL 4
14. Flag Circulars Yes Yes Ships Office
15. Industry Bulletins Yes Yes Ships Office

Company provides one hard copy of applicable manuals. In addition, controlled,


noneditable version of company manuals is stored in computerized PMS system and
accessible in many locations including ECR & Ship’s office.

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2 THE POLICIES

2.1 QUALITY, OCCUPATIONAL HEALTH, SAFETY AND


ENVIRONMENTAL PROTECTION POLICY
Occupational Health and Safety shall be our priority.
We recognize that in the operation of our ships, there is a risk to the health and safety of
personnel on-board, to third parties and to the environment. We seek and commit to
minimizing such risks at all levels.
Environment Protection shall be one of our highest priorities and shall undertake to
implement all possible, reasonable, and practicable actions to prevent any type of
pollution.
To achieve these, we shall
 Provide safe operation of ships and safe working environment to the staff.
 Provide a safe and healthy working environment free from unauthorized use of
drugs and alcohol.
 Examine Company working practices to identify risks and establish safeguards
against such risks.
 Ensure that all vessels comply with all applicable mandatory rules and regulations.
 Ensure adequate resources and shore-based support provided to the vessels.
 Employ competent and qualified personnel.
 Provide training for employees to enable them to achieve company objectives and
targets.
 Continuously improve skills of employees.
 Monitor performance of company, ships, and the employees.
 Formulate corrective actions, from incident investigation and audit reports on-
board ship and in the Company office.
 Identify and develop appropriate preventive action to proactively prevent injuries
and accidents
 Disseminate the safety and environmental related information to the vessels.
 Develop, maintain and exercise Contingency / Emergency response plans.
 Proactively approach and manage customer relationship.
 Identify and address customer complaints, requirements, and expectations in the
pursuit of customer satisfaction
 Regularly review towards continual improvement of the management system
 Zero Tolerance towards any non-compliance or breach of environmental
regulations.
 Encourage open reporting in a transparent manner without fear of repercussions.
 Use IT technology effectively and develop solutions to breakdown the complexity
of Ship management into easily manageable tasks for both ship & shore staff.

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Apart from the above policies, company will contribute to the wellbeing and progress of
local community through CSR initiatives.

2.2 MANAGEMENT COMMITMENT AND RESPONSIBILITY


Company’s leadership is also responsible for implementing the Integrated Management
System, which includes the development and deployment of the quality policy, the quality
objectives, and specific plans that are customer focused.
Top management provides the leadership and governance to all activities related to the
lifecycle processes including defining the strategic direction, responsibility, authority, and
communication to assure the safe and effective performance.
Company’s governance structure provides necessary support for creating and establishing
appropriate processes that are important for maintaining and achieving our quality
objectives and policies. In addition, governance activities include systematic verification
of the effectiveness of our QMS by undertaking internal audits and analyzing performance
data.
Regular management reviews ensure that our quality management system is adequate and
effective, and that any necessary adjustments are made thus.
Top management is committed to implementing and developing the integrated
management system and this commitment is defined by our corporate policies and
objectives. Company ensures that our policies are understood, implemented, and
maintained throughout at all levels of the Organization through printed distribution of our
policy statements and through periodic management review of the policy statements and
objectives. Company communicates our mission, vision, strategy, policies, and processes
to all employees in order to:
 Create and sustain shared values of fairness and ethical behavior;
 Establish a culture of trust and integrity;
 Encourage commitment to quality;
 Provide people with the required resources, training, and authority to act with
accountability;
 Inspire, encourage, and recognize people’s contribution.
We believe that proper and effective management of a vessel is achieved by the co-
operative effort of an integrated network comprising the vessel, the management office,
the manning offices, the port agents, classification societies, statutory bodies, and other
institutions. Good communication and exchange of information are key elements in this
relationship and is the tool for ensuring that all involved parties are working in accordance
with the objectives.
The management, senior executives and employees of the Company recognize the fact that
in order to provide high quality ship management services, implementation and
functioning of the policies and the management system are of vital importance.
The responsibility for establishing and maintaining the policies is of the senior
management of the company (in office and ship). The responsibility for understanding and
executing the defined Company procedures in meeting the requirements of the policies
resides with all employees on-board and ashore.
The Master has the responsibility for implementing this policy on-board the ship under his
command. Further, he has complete authority over all activity and all personnel on-board
and is responsible for safe navigation of the vessel. In matters relating to safety and
pollution prevention, the Master has the overriding authority and discretion to take

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whatever action he considers to be in the best interest of the crew, ship, company, cargo,
and marine environment.
The Master and Chief Engineer on board the ships shall be directly responsible for
undertaking all measures necessary to prevent pollution of the environment.

2.3 CUSTOMER APPROACH


Company strives to identify current and future customer needs, to meet their requirements
and to exceed their expectations. Top management ensures that the focus on improving
customer satisfaction is maintained by setting and reviewing objectives related to customer
satisfaction at management review meetings.
Top management also ensures that customer requirements are understood and met.
Customer requirements are understood, converted into internal requirements, and
communicated to appropriate personnel within the Organization.
The company identifies that its primary quality objective is to provide a safe,
thorough and cost effective “Total” ship management services to the principals.
Prior to committing to a customer, the company shall carefully study and analyses
Specific requirements of the principals,
Requirements that are not stated by the customer but necessary for the ship management
services,
Relevant statutory and mandatory regulations and requirements related the company,
Relevant statutory and mandatory regulations and requirements related to
the vessel’s flag,
Any additional requirement that may be determined by the company and
Budgetary requirements and restrictions.
Industry Recommendations such as TMSA.
Basis above the company shall commit its intention. The contract shall be prepared
appropriately and communicated to all concerned.
The company shall ensure that
The requirements are clearly defined
Any differences are resolved and
It is well equipped to meet the above requirements
The company shall review the requirements at regular intervals to ensure the requirements
are met.
The company shall arrange to ensure regular meeting of its senior management at suitable
occasions with the Principals in relation to
Service information provided,
Identify any additional specific requirements and
Feedback.
The feedback received from the principals shall be analysed, investigated and, appropriate
action taken as deemed necessary. Any complaint received from the Principals shall be
carefully investigated, root cause identified, corrective actions taken and communicated to
the Principals. Such Requirement, Feedback and Complains shall be discussed in the

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management review for continual improvement of the management system or the


necessary amendment to the contract.

2.4 BUSINESS ETHICS POLICY

2.4.1 PROFESSIONAL DILIGENCE


2.4.1.1 Information Sharing:
Synergy will abide by all applicable legal requirements protecting the privacy of a
customer’s or employee’s personal information. All customer and employee personal
information is confidential and may not be disclosed except as permitted by law and
applicable regulations. Synergy will share information relating to its performance,
customers, outcomes of meetings and discussions with employees at various levels on a
‘need to know’ basis.
In other words, information will be shared depending on the need for a person to use this
information to do his / her job. Before disseminating any information to colleagues /
outsiders every employee is expected to apply the same judgment on whether they ‘need to
know’.
Where authorization for disclosure of information to a third-party has been given, the
employee involved must ensure that an appropriate confidentiality or non- disclosure
agreement has been executed.
2.4.1.2 Social Networking:
Employees are not to publish, post or release any information that is considered
confidential or not public on social media. If there are questions about what is considered
confidential, employees should check with their supervisor.
Social media use shouldn't interfere with employee’s responsibilities or any area of duty.
Use of personal social media for business purposes is strictly prohibited. Inappropriate use
of social media, either in an official or personal capacity, may be cause for disciplinary
action. If unsure whether a communication is appropriate or not, employees should consult
with their supervisor and refer to the Synergy policies before posting on social media.
2.4.1.3 Adherence to processes:
All employees are expected to strictly adhere to standard processes & quality standards.
2.4.1.4 Conflict of Interest:
A Conflict of Interest could be defined as a “situation that arises when a decision making
authority is seen to have a personal stake in the outcome of the decision itself”.
Employees of Synergy may find themselves in situations that are of the nature of creating
a Conflict of Interest. If in doubt, it is always best to consult the Immediate supervisor /
Manager concerned before taking any decisions in such cases. A few such situations are
listed below:
2.4.1.5 Participating in Outside Activities:
Synergy recognizes and respects the right of employees to take part in activities that
promote their special talents and abilities outside their jobs. However, these activities must
be lawful and free of conflicts with their responsibilities as employees of Synergy.
Employees pursuing such activities should ensure that:
The purpose should be to give expression to talent and stay in touch with
one’s hobbies and not for the motive of making money.
Employees should not solicit opportunities from customers using their relationships.

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This should not be done during Company time or should not interfere with work.
Prior permission must always be obtained in writing prior to participating in such
activities.
2.4.1.6 Relationships with Partners, Business Affiliates and Companies:
Employees are prohibited from entering into any kind of personal business contracts with
Synergy’s partners, business affiliates and companies.
Employees are likely to be offered cash or gifts in the course of their dealings with
business partners. The following guidelines will apply here:
 Accepting cash, whatever the amount, is totally prohibited. Please keep your
supervisor informed in case you are offered something of this nature.
 Small value gifts in the nature of mementos and flowers on festive occasions is
acceptable but high value gifts – those in excess of Rs 500/- – should not be
accepted and should be politely turned down. This also needs to be reported to the
Division Head.
2.4.1.7 Non-Compete Undertaking:
While in employment with Synergy, employees will not engage in any activities in any
capacity including free consultations or advises during or after office hours, which is in
competition to the business of the company or in related business or which results in
employing other serving employees of the company.
Employees are not permitted to set up part-time businesses or take up part-time
employment in any area as these will hinder their performance and clearly place them in a
conflict-of-interest situation. Teaching assignments can be taken up with the permission of
the Director provided they do not affect work in the Company.
2.4.1.8 Accepting Honoraria:
Employees may be invited to speak / contribute at various professional forums. Any
honoraria offered in such forums may be accepted if the knowledge shared there is based
on the employee’s professional capability and is subject to prior approval from the
Director.
Personal Integrity in the use and handling of company property and funds
2.4.1.9 Company Property and Company goods:
Employment at Synergy will provide you with access to the Company’s resources in the
form of workplace automation facilities, communication equipments, stationery and
vehicles, cash and stocks.
Employees are expected to display utmost personal integrity in the use of these resources
for discharging official responsibilities.
Should you need any of the above resources given by Synergy for your personal use, you
are required to obtain the prior approval of your Division Head.
Employees should restrict their personal usage of the company’s Internet and
e-mail facilities as well as automation facilities available to them.
2.4.1.10 Company funds:
As employees of Synergy you may be required to handle Company funds.
The funds of the company must be spent for official purposes only and not for any other
reasons.
Employees using funds for official purposes must produce proper support documents such
as bills, invoices and receipts as proof for the amount spent by them for official purpose.

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Employees are required to settle their travel expense claims as per travel policy norms.
Entertainment expenses, wherever and whenever possible needs to be approved prior to
their being incurred as per Company policy.
Synergy will view very seriously any attempts to falsify expense claims of any nature
including conveyance, travel and entertainment.
2.4.1.11 Representing the Company:
Employees are prohibited from speaking to the press on any subject, unless authorized to
do so. All questions or requests for information from the press should be directed to the
Director.
In the event of government officials visiting the Company premises, employees are
expected to engage with such officials in a polite and courteous manner and to inform
them that most information with relation to the operations of the Company are available
with Senior Managers of the Company and any such requests regarding the operations of
the company should be immediately put forward to the Human Resources Department.
Employees may be invited to speak in professional forums or participate in conferences,
seminars, and on-line chats or write in professional magazines. Under all such
circumstances, employees must ensure that participation is with prior written approval
from the Director of the Company.
2.4.1.12 Adherence to Security Protocol
Security and adherence to Security protocol is critical in Synergy. Employees are
requested to cooperate with the security personnel to help them discharge their duties. This
will include the following:
Having visitors to record their entry and exit in the Visitor’s Register.
Meeting visitors at the reception, lobby or designated place and not have them move
around in restricted areas.
Complying with guidelines relating to movement of products that may be introduced from
time to time.
This list is not exhaustive; you may have to comply with any other guidelines that may be
introduced from time to time.
2.4.1.13 Anti-Corruption and Anti-Bribery:
Acceptance of any kind of gift or payment from the service providers and third parties is
forbidden. Also receiving hospitality service from the third party, except in case when they
are appointed for that facilitation; is strictly prohibited.
Nobody shall offer or pay the personal payment, gift or favour in return for favourable
treatment or to gain a business advantage.
Any sort of activities mention above shall not be designated to anybody else to do so on
your behalf.
Facilitation payments are discouraged. In case of any request for facilitation payments,
immediate line manager must be contacted.
Business transactions on behalf of ‘Synergy’ should not involve acquiring, using or
holding monetary profit/ property achieved from criminal proceedings.
Everybody has the responsibility to report corrupt behavior. Turning a blind eye to
suspicions of bribery, corruption or money laundering can result in liability for Synergy
and for individuals.

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2.4.2 COMMITMENT TO OUR EMPLOYEES


2.4.2.1 Equal Opportunity & Diversity:
a) We have equal opportunity policy for everyone. This helps us to ensure
availability of best possible resources and adequate quantity of competent pool.
b) Sometimes people can breach equal opportunity policies without even realizing it
– for example, if they are unconsciously biased towards recruiting people like
themselves.
c) Therefore, employment related decisions must be based on objectives &
geographic legislations and should not be taken under the influence of personal
feelings, prejudices and preferences of the employer.
d) Employment decisions which includes hiring, evaluation, promotion, training,
development, discipline, compensation and termination must be based solely on
objective factors, including merit, qualifications, performance and business
considerations.
e) Diversity has its own value and advantages. However, discrimination based on
race, color, religion, age, gender, sexual orientation, gender identity, marital status,
disability, ethnic origin or nationality is intolerable.

2.4.3 HARASSMENT
2.4.3.1 Bullying and Harassment:
Synergy is committed to providing a workplace that is free from harassment and bullying.
All Ship staff have a right to work in an environment free from harassment and bullying,
and to be treated with dignity and respect. Even unintentional harassment or bullying is
unacceptable. Synergy will treat all complaints of harassment and bullying seriously and in
strict confidence.
Synergy considers any complaint of cyber bullying to be a serious issue. Cyber bullying is
the use of modern communication technologies to harass, embarrass, humiliate, threaten,
or intimidate an individual to gain power and control over them.
The use of the company’s communication equipment for such purposes will be treated as a
serious breach of the company code of conduct and result in disciplinary action against
perpetrators.
All managers and directors are responsible for actively intervening to prevent and stop any
bullying behavior that is occurring in their workplaces, whether or not a complaint is
received.
Synergy provides these procedures by which all staff can have any complaint of
harassment and bullying addressed.
All ship staff have a right to use the procedures in this policy if they believe they have
experienced harassment or bullying that can be dealt with under these procedures.
2.4.3.2 Sexual Harassment:
Sexual Harassment refers to:
Any gesture, expression, language or act that is caused by an employee of the other gender
that deliberately or purposely violates his/ her dignity, privacy, mental or physical well-
being.
Sexual Harassment may include:
Use of offensive / obscene language

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Making obscene calls or sending / forwarding obscene mails


Making passes / advances / comments on dressing of co-Employee’s physical appearance
in the office.
Physical contact like touching or patting customers or co-Workers.
Misuse of one’s position / authority in office to ask or demand for
sexual favors.
Display of obscene pictures and posters at the workplace
Showing signs of over-friendliness with the other gender if it is unwelcome.

2.4.4 HUMAN RIGHTS


2.4.4.1 Human Rights Violator Regime:
Our established policies and standards help us create fair labour practices and a positive
work environment. We should develop environment where our staff work with contractors
and suppliers who contribute to sustainable development and are economically,
environmentally & socially responsible.
Following measures shall be adopted to identify contractors & service provider who are
associated with human right violation:
Verifying the service provider background during initial evaluation prior employing and
then during periodic audits.
Continuous monitoring of services and behaviors on each engagement. Service provider
found involved in any human right violation directly or indirectly must be barred from
future services.

2.4.5 BUSINESS CONDUCT VIOLATION


2.4.5.1 Business Conduct Violation refers to acts:
 Which go against the standards of discipline, or
 That is detrimental to the interests of the Company, or
 That is a violation from established standards of behavior expected at the
workplace.
 An employee guilty of misconduct may be:
 Censured or,
 Warned in writing or,
 Suspended by an order in writing by the Business Head / Director for a period not
exceeding one month or,
 Penalized by stoppage of annual increment or,
 Penalized by reduction in rank or,
 Discharged or,
 Dismissed without notice or compensation.
In awarding punishment, the Management shall take into account the gravity of the
misconduct, the previous record of the employee and any other extenuating or aggravating
circumstances that may exist.

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2.4.5.2 Dealing with Business Conduct Violations:


Synergy is charged with the responsibility of taking appropriate corrective action in the
event of Business Conduct Violation.
As a responsible employer the Company will:
 Thoroughly investigate the nature and gravity of the violation to establish the facts
of the case, and;
 Give a reasonable opportunity to secure the explanation of the concerned
employee.
 Based on these inputs the Company will take action, as it considers appropriate.

2.4.6 AMENDMENTS TO THESE RULES:


Any or all of the above provisions may be amended by the Company at its sole discretion.

2.4.7 REFERENCE: Appendix 1 Synergy Code of Conduct.

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3 OBJECTIVES

3.1 OBJECTIVE GUIDELINES


The company’s prime objective is to provide safe and thorough “Total Ship Management
Solutions” to the principals effectively.
Detailed and Specific objectives shall be prepared, monitored, and reviewed periodically.
Management programs shall be formulated to achieve the specific objectives of
Occupational Health, Safety, and Environment. These programs shall be established with
responsibilities and targets defined for applicable functions & levels in office & vessel.
These shall be communicated to all concerned.
Objectives and programs shall be reviewed at company management review. Listed below
are the guidelines in preparing the specific objectives and programs.

3.1.1 Quality
1) No delays to the vessel with respect to up keeping of vessel’s statutory certification
and Classification society requirement.
2) Spares pertaining to Main and Auxiliary Engines connected to the vessel shall be of
original manufacturers supply. However, in case unable to obtain from original
manufacturer a suitable spare shall be provided
3) As far as practicable stores other than for routine consumables, shall be purchased
from approved ship suppliers. However, in case of new suppliers, purchase procedure
to be strictly complied with.
4) No modifications shall be permitted to the original equipment or machinery involved
in safety and performance output of the vessel unless it is approved by flag state or
Classification Society or the original manufacturers.
5) Vessel’s performance shall be carefully monitored to avoid any delay or detention or
low performance. In cases any abnormal deviation, the same shall be analyzed and
corrective actions taken. The ship-owners shall be appraised of the same.
6) Vessel’s expenses shall be maintained within the operational budget. In case of
exceeding abnormally, ship-owners express permission shall be obtained.
7) No detentions related to vessel at any port by authorities under any circumstances.
8) Feedback shall be collected from the customers every quarter and analyzed.

3.1.2 Occupational Health and Safety Objectives


1) All officers and crew to be made aware of Occupational Health and Safety awareness
2) All ships to be maintained in clean and hygienic condition.
3) Not to allow any outbreak of infectious diseases (Viz, Cholera, SARS, etc.)
4) No accident due to poisonous gas inhalation or asphyxia.
5) Minimize direct safety related deficiencies in port state or flag state inspections.
6) No injury of any type
7) To be ready always for emergencies on-board and ashore.
8) To operate ships in full compliance with applicable international and national

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legislation.
9) To investigate incidents, deficiencies and non-conformities and implement corrective
actions.
10) Think proactively and provide Preventive actions to avoid accidents on-board.
11) To assist the seafarers to upgrade their safety conscious (ness) by disseminating safety
related information.
12) To review the Risk Assessment for various activities, its suitability and to identify
additional hazards, if any, and update control measures as necessary.
13) To identify potential Superintendents among the senior sailing officer and encourage
the Senior Officers when on leave, to actively engage in key activities such as Shore
based drills, Management Reviews, Dry Docking, Training etc.
14) Develop IT systems to effectively manage Ships and simplify Ship’s crew and Shore
staff efforts.

3.1.3 Environmental Objectives


Raise General Environmental Awareness and convey company’s policy on Zero Tolerance
towards any non-compliance or breach of environmental regulations, to all shore and ship
staff
Provide training to all personnel on the compliance of environmental policy and
procedures.
Identify and review related regulations.
Ensure all pollution prevention equipment on board fully operational.
Assess and review environmental hazards and derive necessary control measures.
No spill of any type that may cause marine pollution, violating legislation.
No damage to environment due to ballast water
Reduction in permitted Emissions
Use of Eco-friendly Refrigerants for Domestic Fridge, A/C.
Reduction in use of papers and paper wastage.
Use of bio-degradable chemicals
Measure SOX / NOX and CO2 emissions by Calculation and work towards emission
control.
Establish means for improving and monitoring the energy efficiency of ship operations.
Promote environmental awareness in community / Schools.
No air pollution incidents
To encourage open reporting in a transparent manner.

3.1.4 CSR Objectives


To identify economically backward community and provide support for their wellbeing
and progress.

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3.2 INTERNAL AND EXTERNAL RESOURCES REQUIRED TO MEET


THE OBJECTIVES

3.2.1 Quality Objectives


1) Survey and Certification department
2) Technical team to procure and supply original spares, routine consumables
3) Ship Management team - Close monitoring of vessels maintenance, operation, and
budgetary requirements by Technical and Marine Superintendents
4) Audit team - for Periodic audits and Vessel Inspection aimed towards ensuring safe
operation and preventing detention

3.2.2 Occupational Health and Safety Objectives


1) Training Division – to improve crew awareness on Health and Safety matters
2) Common Technical Services - Providing adequate supplies of medicines to prevent
outbreak of any disease on-board
3) Common Marine Services – For periodic review of procedures to prevent accidents,
incidents, injury, detention, emergency preparedness, major investigations,
disseminating safety related information, review of Risk assessments

3.2.3 Environmental Objectives


Environmental Management Cell - to monitor the adherence to environmental policy and
procedures

3.3 INFRASTRUCTURE AND WORK ENVIRONMENT


The company shall determine, provide, and maintain necessary infrastructure to ensure the
objectives are met.
The company shall ensure suitable buildings, workspaces, computers (desk top and
laptops); telephone, fax, mobile telephones, computer software, transport etc. are available.
The company shall provide adequate resources (technical and human) to effectively
implement the integrated management system

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4 ORGANIZATION STRUCTURES

4.1 ORGANIZATIONAL STRUCTURE – OFFICE


Organizational structure of Synergy Group and Synergy Maritime Private Limited is
shown below;

4.1.1 SHIP MANAGEMENT TEAM


Each vessel shall be assigned a Fleet Manager, Marine Manager, Technical
Superintendent, Marine Superintendent, and executives.
Marine Managers are assigned fleet, based on the type of vessel, and may serve as DPA to
those vessels. Where the fleet is vast, the fleet manager may also be designated as the
DPA. Marine manager is over all in charge for the operational and safety
performance and implementation of company’s QHSE policy across his fleet.
Technical Superintendent and Marine Superintendent are identified as in-charge for each
vessel and the vessel shall report to them for all issues concerning performance of the
vessel.
The contact details of the in-charge Technical & Marine Superintendents will be updated
and sent to vessels periodically.
For Manning, the in-charge should be contacted.
For all correspondences, Technical Superintendent and Marine Superintendent are to be
copied.

4.1.2 DESIGNATED PERSON ASHORE


In order to ensure the safe operation of each ship and to provide a link between the
Company and those on board, company shall appoint a “Designated Person Ashore”
having direct access to the highest level of management.
One of the senior officials in the top management shall be nominated as the
“Designated Person ashore” for every ship managed by the company
He shall be reporting to the Head of the Ship Management Team of the company in
functions pertaining to the DPA.
The Head of the Ship Management Team shall be responsible for providing adequate
personnel resources, material resources; support in terms of training and authority to the
DPA for him to perform effectively.

4.1.3 RESPONSIBILITIES OF DPA


The responsibility of the Designated Person Ashore shall be as follows
Verify and monitor all safety and pollution prevention activities in the operation of each
ship.
This monitoring should include,
Communication and implementation of the safety and environmental protection policy;
Evaluation and review of effectiveness of safety management system;
Reporting and analysis of non-conformities, accidents, and hazardous occurrences;

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Organizing and monitoring of internal audits;


Appropriate revisions to the SMS; and
Ensuring that adequate resources and shore based support are provided While verifying
and monitoring the Safety and pollution prevention activities, if it becomes apparent that
the same is of concern, DPA shall liaise with the vessel and
shore support to ensure that all safety and environmental protection standards are fully
met.
If the Master or any crewmembers on-board feel that the safety of life, the environment or
property is compromised due to any particular circumstances, the DPA should be
contacted.

4.2 DELEGATION
In the absence of DPA, alternate DPA shall have the necessary authority and responsibility
to carry out DPA’s functions.
DESIGNATED PERSON CONTACT DETAILS
Office Tel: +91 44 4321 5555
Office Fax: +91 44 4321 5500
Email: vg “VESSEL NAME”@synergyship.com

Alternate Designated person contact details


Office Tel: +91 44 4321 5555
Office Fax: +91 44 4321 5500
Email: vg “VESSEL NAME”@synergyship.com

The name contacts numbers and after office hours’ number of the DPA and Alternate DPA
shall be communicated to the vessels as per company posters and also included in safety
familiarization booklet.

4.3 MANAGEMENT REPRESENTATIVE


As required under the ISO 9001, ISO 14001 standards and ISO 45001 specifications, the
organization shall appoint a top management representative who, irrespective of other
responsibilities, shall have responsibility and authority that includes,
Ensuring that processes needed for the Quality, Occupational Health, Safety,
Environmental management system are established, implemented, and maintained.
reporting to top management on the performance of the QHSE management system and
any need for improvement, and
Ensuring the promotion of awareness of customer requirements throughout the
organization.
The company delegates the “Head of CMS team” as the Management representative to
effectively carryout these functions.
The detailed responsibilities are mentioned in the Office procedures Manual.

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4.4 CONTACT DETAILS OF MANAGEMENT REPRESENTATIVE


Head of CMS Team
Office Tel:
Office Fax:
Email:

4.5 ORGANIZATIONAL STRUCTURE – SHIP Ref: Safety familiarization


booklet - SF10

4.6 INTERNAL COMMUNICATION


Company communicates information internally regarding our Integrated Management
System and its effectiveness, through documented training, internal audit reports and
continual improvement processes. Company divisions both vessel and ashore are
responsible for establishing regular formal and informal communications as needed to
convey to their employees / crew the relevance and importance of their activities;
typically, this information is conveyed through meetings.
Communications regarding how employees contribute to the achievement of objectives are
also conveyed and reinforced during employee / crew performance reviews. Issues
pertaining to our Integrated Management System that may be communicated internally
include:
Day-to-day operations and general awareness;
Quality policy;
Information on achieving objectives and targets;
Risk and opportunities.
Top management and their Managers / Vessel Masters are responsible for communicating
the company policies as well as the importance of meeting customer, statutory and
regulatory requirements to employees / crew within their respective departments. They
ensure the quality policy is understood and applied to the daily work of the organization
/vessel through the establishment of measurable goals and objectives. Internal
communication occurs on an on-going basis and is achieved through various mechanisms
as appropriate:
Regular meetings and briefings;
Training sessions and training material;
Display boards, memorandums, bulletins;
Website and internal e-mails;
Process performance data analysis and audit results;
Targets, objectives, KPIs, management system manual and procedures;
Corrective action from Management Review, Incident investigation, and non-
conformance reports, corrective actions on recurring defects arising from VIR and external
inspections;
Minutes of ad-hoc and scheduled meetings.

4.7 EXTERNAL COMMUNICATION


Company determines the need to communicate information externally to our interested

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parties, regarding the effectives of our Integrated Management System. In most instances,
external interested parties (such as customers, Industry, etc.) are the main driving force for
our organisation to implement our Integrated management system.
There are various processes or means of external communication such as:
Periodical Reports for Budget and safety performance
Notifications of incidents vide Email
Regular direct meeting with the interested parties at their location
Interested parties meeting us for Review and audits
Customer Relationship Managers established for seamless communication with the clients
Company ensures that appropriate level of hierarchy makes all external Communications.
Where required, advice appropriate to the context of the communication may be sought
concerning the content and dissemination of certain external communications. Responses
to external communications are recorded if they are transmitted by email are archived
electronically in cloud.

4.8 CUSTOMER COMMUNICATION


Feedbacks analyzed in MR and inputs goes back to the SMS
Feedback/ complaints if any is obtained form Terminal / Receivers / Charterers via e-
mails, Feedback forms and meetings

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5 MASTER RESPONSIBILITIES & AUTHORITIES

5.1 RESPONSIBILITIES:
The Master is responsible for:
1) The safety of the crew, the ship, and any cargo that the vessel may be carrying
2) Implementing the Company’s health, quality, safety and environment policies aboard
the vessel and for motivating all crew members to observe the intended and implied
requirements (this may be achieved by clearly explaining to crewmembers the content
of the policies and procedures as well as why they have been implemented, crew
motivation can be encouraged by involving crewmembers in operations, asking for
comment and recommendations for improvement, by using basic risk assessment and
by providing practical and interesting training sessions).
3) Issuing orders and instructions to the crew in a clear and simple manner (this may be
achieved by the Master providing written Standing Instructions which clearly explain
what is required of all personnel and which are publicly exhibited).
4) Verifying that the requirements of the safety management system are observed (this
may be achieved by regular inspections of all areas of the vessel, by witnessing key
operations and by reviews at management meetings).
5) Periodically reviewing the safety management system and reporting any deficiencies
in the system to the shore-based management.

5.2 AUTHORITY
The Master is ultimately responsible for the safe operation of the vessel, safety of crew and
for preventing pollution from the vessel. The Master is empowered in all situations with
Overriding Authority to act decisively according to his best judgment to:
 prevent injury to crewmembers and other persons;
 protect the vessel and other vessels and/or property from damage;
 Prevent pollution from the vessel.

It is the Master’s duty to depart from the requirements of the SMS and to assume
that overriding control when he feels the situation warrants such action.
The Master should request any assistance that he may require from any appropriate person
ashore, at any time, to assist in fulfilling these responsibilities.
In the event of an accident, the Master has the overriding authority to engage any
assistance necessary to protect the vessel, crew, cargo, and / or the environment. In
situations of danger, where immediate assistance is required, such help should be obtained,
where possible, by agreement to Lloyd’s Standard Form of Salvage
Agreement (Lloyd’s Open Form). if outside parties are ready to render assistance but are
unwilling to accept LOF, the Master has the authority to agree any alternate means of
ensuring assistance necessary to avert immediate danger. If time and circumstances permit,
the Company must be notified to make the necessary arrangements without endangering
the vessel.
Please refer to Chapter 18 of this manual for more detailed description.

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6 RESOURCES AND PERSONNEL

6.1 INTRODUCTION
This chapter describes the company procedures for employment and welfare of ship and
shore staff. This chapter covers the requirement of Maritime Labour convention 2006.
The Maritime Labour Convention (MLC 2006) was unanimously adopted by International
Labour Organization (ILO) on 23rd February 2006. The Convention seeks to protect the
fundamental rights of seafarers to safe and secure work place, fair terms of employment
and decent working and living conditions on board ship.

6.1.1 Definitions
Seafarer: means any person who is employed or engaged or works in any capacity on
board a ship to which this Convention applies.
Seafarers’ employment agreement includes both a contract of employment and articles of
agreement.
Seafarer recruitment and placement service means any person, company, institution,
agency, or other organization, in the public or the private sector, which is engaged in
recruiting seafarers on behalf of ship-owners or placing seafarers with ship-owners
Ship: means a ship other than one which navigates exclusively in inland waters or waters
within, or closely adjacent to, sheltered waters or areas where port regulations apply.
Ship-owner: means the owner of the ship or another organization or person, such as the
manager, agent, or bareboat charterer, who has assumed the responsibility for the
operation of the ship from the owner and who, on assuming such responsibility, has agreed
to take over the duties and responsibilities imposed on ship-owners in accordance with this
Convention, regardless of whether any other organization or persons fulfil certain of the
duties or responsibilities on behalf of the ship-owner.

6.1.2 Abbreviations
MLC 2006: Maritime Labor Convention, 2006
MLC: Maritime labor certificate
SOC: Statement of compliance
DMLC: Declaration of maritime labor compliance – composed of part I and part II Part I:
List of national legal provisions for implementing requirements of the convention – drawn
up by the competent authority of flag state.
Part II: The measures and plans adopted to ensure ongoing compliance with national
requirement as prescribed in part I – drawn up by the ship-owner and reviewed and
certified by the flag administration or RO recognized by the flag state.
RO: Recognized Organization

6.1.3 Certification process


A current valid maritime labor certificate and declaration of maritime labor/ compliance,
accompanied by an English-language translation where it is not in English, shall be carried
on the ship and a copy shall be posted in a conspicuous place on board where it is available
to the seafarers.

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Sections 6.2 to 6.10 are applicable to shipboard personnel. Procedures for shore staff
employment is provided in section 6.11.

6.2 SELECTION, RECRUITMENT, AND PLACEMENT PROCEDURES


For the purpose of recruitment of shipboard personnel, the company shall liaise with
principals for direct manning or liaising with manning agents.
Company ensures that where Seafarer recruitment agencies are based in and licensed by
State Parties to the MLC 2006, they are recognized by the flag state. Company may
engage any of the Flag approved Recognized Organizations or through the company’s
internal audit mechanism to ensure that when using seafarer recruitment and placement
services located in countries not party to the MLC 2006, such services are, as far as
practicable, consistent with the requirements of the MLC 2006. Company may engage
seafarer recruitment and placement service already audited by any of the flag approved
Recognized Organizations. Company shall ensure that such services are consistent with the
requirements of the MLC 2006.
Company’s recruitment policy, selection process and procedures are detailed in the Guide
to Manning agents. Recruitment and placement services shall be operated in an orderly
manner that protects and promotes seafarer’s employment rights as provided in MLC
2006.

6.3 RECRUITMENT POLICY


The company recognizes that the quality of crew on board ship and their effective
performance are the key to success.
Company commits to providing the principals, crew with high
level of safety awareness, adequate qualification, well-motivated and appropriately trained.
Company shall ensure that the vessel is:
Manned with qualified, certificated, and medically fit seafarers in accordance with
National and International requirements.
Appropriately manned in order to encompass all aspects of maintaining safe operations on
board.
Company ensures compliance with the Minimum Safe Manning Document issued by the
Flag state.
Company shall not levy any fee or other charges to seafarers for providing employment to
seafarers directly or indirectly, in whole or in part for the purpose of recruitment
Company shall work on the feedback from the principal and strive for continual
improvement.
The Company employs seafarers on behalf of ship owners, as per requirements of the
principal. The company is an equal opportunity employer and it does not discriminate on
basis of Nationality, religion, caste, or sex.
The Company shall avoid employing more than three nationalities on board a vessel. All
personnel of similar cultural and lingual origin, e.g. people of Indian subcontinent (India,
Pakistan, Bangladesh, and Sri Lanka) are considered one nationality. Where specialized
professional qualification is required for a ship board operation, the limitation of
nationality shall be waived.
The personal data of the seafarer shall be used only for processing, recruitment, and
placement on-board ships. This data shall remain confidential and shall not be released to a
third party. The Company shall not use any mechanism/ or list intended to prevent seafarer

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from gaining employment elsewhere.


The Company shall make arrangement for maintenance and repatriation of a stranded
seafarer.
The Company shall make arrangements for transportation of mortal remains of an expired
seafarer as per the agreement with the principal of the vessel. The company shall take all
possible efforts to inform the death or permanent disability of the seafarer to the
employment office (if employed through a crewing agent) and to the next of kin of the sea
farer within forty-eight hours of such death or disability.
However, when conveying the death or disability to the next of kin, it shall be done in
most suitable and appropriate manner.
The Company shall ensure that ships, on which seafarers are recruited & placed, are
covered by P&I Insurance.
The Company shall record complaints made by seafarer against recruitment / placement
procedure. Company shall take appropriate action to redress the grievance. Any
unresolved complaint may be addressed to the relevant regulatory authority / unions.
The company shall make every endeavour to place on board vessel a seafarer, who has
signed a contract of employment with the company.
Company shall ensure that seafarers only above age 18 years are employed or engaged to
work on a ship managed by the Company. This shall be verified by the company /
manning office from the seafarers’ s discharge book and or passport.

6.4 QUALIFICATION
Note: Below guidelines are the minimum required qualifications and may differ to a higher
requirement as per the Owners and Matrix (For Tankers) requirements.
ANY OFFICER JOINING A VESSEL SHALL HAVE:
A valid certificate of competency issued by the relevant approved authority and approved
by the flag administration of the vessel for at least the rank of appointment and valid for
the duration of his contract + 1 month.
Hold the mandatory STCW course certificates.
hold the appropriate dangerous cargo endorsements (as applicable)
Valid seaman’s discharge book
Valid medical fitness certificate as per STCW guidelines.

6.4.1 ANY SENIOR OFFICER JOINING THE VESSEL:


Senior officers shall have at least 6 months sailing experience on the particular type and
size of vessel.
They shall undergo the necessary in-house training as given in Training matrix.
If due to any urgent requirement, the above condition is not met, Senior
Management’s approval is required.
SENIOR OFFICER (MASTER OR C/E) JOINING THE VESSEL:
All Masters joining the vessels shall have undergone either simulator training or at least 6
months’ experience in the particular type of and size of vessel.
New promotion Masters shall have undergone additional in-house simulator training in the
particular type and size of vessel.

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Newly promoted master / CE shall be provided with an overlap period of 1 week with the
signing off master / CE, after taking over
If due to any urgent requirement, the above condition is not met, Senior
Management’s approval is required.
The company shall ensure that masters and all senior officers are fully conversant
with the company’s Safety Management System prior joining.
CREW/RATING JOINING A VESSEL SHALL HAVE:
Relevant watch keeping certificate if applicable. (For watch keepers)
Hold the mandatory STCW course certificates.
hold the appropriate dangerous cargo endorsements (as applicable).
Valid seaman’s discharge book
Valid medical fitness certificate as per STCW guidelines.
Cooks are trained, qualified and found competent as per flag requirements and MLC 2006
requirements. For each vessel please refer to DMLC II for individual flag requirements.

6.4.2 ANY DECK CADET JOINING A VESSEL SHALL HAVE


Passed the secondary education examination.
Completed the pre-sea training.
Hold the mandatory STCW course certificates.
Valid seaman’s discharge book
Valid medical fitness certificate as per STCW guidelines.

6.4.3 ANY ENGINE / ELECTRICAL CADET JOINING A VESSEL SHALL


HAVE
Be a graduate or a diploma in respective engineering
Have undergone approved pre-sea/workshop training
Hold the mandatory STCW course certificates.
Valid seaman’s discharge book
Valid medical fitness certificate as per STCW guidelines.
Detailed requirement about the certification is provided in Fleet personnel recruitment
manual Ch. 3 or guidelines to respective manning agents as applicable.
It shall be the responsibility of the manning office to verify that the above qualification
requirements are met before being appointed.

6.5 MEDICALS FOR SEAFARERS


Company ensures that, prior to beginning work on a ship; any seafarer employed holds a
valid medical fitness certificate attesting that the seafarer is medically fit to perform the
duties they are to carry out on board the ship. The nature of the medical examination and
Certification shall be in accordance with the ILO 73 or STCW 2010 or MLC
2006Conventions and fulfilling any specific flag state requirements. This shall be verified
by the manning team or the manning agency prior signing the employment agreement.
The company accepts valid medical fitness certificate issued only by the following:

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 A medical practitioner recognized by a MLC State Party and familiar with


guidelines for conducting pre-sea and periodical medical fitness examinations for
seafarers published by IMO, ILO, or WHO; or
 A medical practitioner recognized by a STCW State Party on the “STCW White
List”; or
 A registered medical practitioner recognized by flag state and familiar with
guidelines for conducting pre-sea and periodical medical fitness examinations for
seafarers published by IMO, ILO or WHO.
Medical certificate shall be in English and maximum validity for medical fitness certificate
is two years. Color Vision shall be tested for deck Officers, deck ratings, electricians, and
any other seafarer expected to carryout Navigation duties.
Maximum validity for color vision is for six years. In any case Medical certificate shall be
valid for the intended contract period + 3 months.
In urgent cases, prior joining, where a seafarer does not possess a valid medical certificate
and cannot get this prior vessel sailing out of port, company shall obtain permission from
the Flag State for the seafarer to sail until the next port of call where medical examination
can be carried out and certificate obtained from a qualified medical practitioner provided
that:
the period of such permission does not exceed three months; and
the seafarer concerned is in possession of a medical certificate which has not been expired
for longer than 1 Month.
If the period of validity of a certificate expires during a voyage, the Master informs the
company and makes arrangements to send the seafarer for a medical examination at the
next port of call provided that the period shall not exceed three months.
Seafarer who have been refused a certificate or have a limitation imposed on their ability
to work will be given an opportunity to have further examination by another independent
medical practitioner.
Seafarers upon signing off from chemical tankers/ Vessels carrying ammonia or after
exposed to chemicals must undergo blood chemical accumulation test.
Masters to refer to the OP-CHEM-47 form “Seafarers Blood Accumulation Test”
which must be completed for each seafarer on his sign-off.
For crew signing off from Chemical and Oil/Chemical Vessels (carrying chemicals):
Medical examination as per company form OP-CHEM-47 shall be conducted within 14
days of sign-off to check for any toxicological constituents

The medical examination after signing off shall only be required, if the cargo carried
during the crew member’s tenure were noted to be toxic in nature.
Each crew member shall be availed with the cargo list by the vessel master on sign off.
However, the test as form OP-CHEM-47 is mandatory for crew members prior joining
chemical tankers.
The medical examination test report shall be reviewed by the company doctor and
maintained with office for future reference and records
Seafarer’s medical report must be treated as confidential on-board.
Master shall ensure Validity of Medical Certificate at the time of Joining Vessel. Company

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shall inform master of any pre-existing diseases for the seafarers at the time of joining
(Form M-09).

6.6 EMPLOYMENT OF SHIP’S PERSONNEL

6.6.1 SEAFARER’S EMPLOYMENT AGREEMENT


The terms and conditions for employment of a seafarer shall be in English and set out in a
clearly written legally enforceable contract of employment.
Prior to joining vessel, all ship staffs are required to sign the employment contract, which
shall state the terms and conditions of employment on board.
All seafarers shall have the opportunity to examine and seek advice on the terms and
conditions in their seafarers’ employment agreement, including any Collective bargaining
agreement (CBA) that forms part of the employment agreement before signing. This is to
ensure that they have freely entered an agreement with a sufficient understanding of their
rights and responsibilities.
The contract of employment is made in two originals and duly signed by the seafarer and
the ship owner / representative of ship owner. One original will be handed over to the
seafarer, the other original will be placed on board and a copy of the same shall be retained
at office.
The term and agreement of the CBA applicable to the ship shall apply to
administration of seafarer’s employment on board vessels. The collective bargaining
agreements are available on board and accessible to Flag State inspectors, duly approved
Recognized Organizations (RO) and authorized officers in ports visited by the vessels.
Contract duration will be mentioned in the employment contract based on the relevant
CBA which shall not exceed 11 months.

6.7 GUIDANCE ON CONTRACT DURATION FOR SAILING VESSEL


SHIPS CONTRACT DURATION – MONTHS

Master & Chief All other officers All ratings Cadets


Bulk Carrier Engineer
Container
Tanker
4–8 6 - 10 9 - 10 9 -10

Contract duration shall be agreed between the seafarer and the company.
The Contract of Employment is deemed to commence on the date the ship staff departs
from their closest declared international airport to join their assigned vessel.
Each crewmember must be assigned a company ID number for ease of all correspondences
with the office. Company shall maintain an up to date register of all seafarers recruited or
placed through them.
The vessel’s Master reviews the certificates of all crew joining and confirms that they have
complied with relevant requirements, prior to signing them aboard the vessel. Only
original certificates are acceptable. Master shall sign off a crew member only after
ascertaining that the reliever possesses all necessary documents and certificates including
flag requirements. Master to ensure that clear information on the conditions of
employment, including a copy of Collective Bargaining Agreement and/or Collective

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Agreement (where applicable), are easily obtainable on board by seafarers, and accessible
for review by officers of a competent authority, including those in ports to be visited.
Master must ensure that all seafarers have a “Seaman’s Discharge Book”, and that this
document shall contain a record of their employment on ship and shall not contain any
information on the quality of the seafarer’s work or their wages.

6.8 WAGES, OVERTIME, ALLOTMENTS BALANCE OF WAGES &


HOLIDAYS
The wages shall be paid to the seafarer as agreed on the employment agreement. The
account of wages shall be in US dollar, in accordance with employer or its agent’s
instruction on exchange rates. The account of wages shall be handed over to the seafarer
every month. The account shall contain the minimum information fields that are required
by national law.
For the purpose of wage calculation, a calendar month shall be regarded as having 30 days.
The seafarer shall be entitled to a home allotment, payable at the end of each month to
transmit all or part of their earnings to their families or dependents or legal beneficiaries.
The home allotment, once a month to the seafarers nominated bank account shall be free of
any service charge.
Where more than one account has been designated by the seafarer, allotments to any
subsequently designated account(s) shall be provided at a reasonable charge.
The rate of currency exchange shall, in accordance with national laws or regulations, be at
the prevailing market rate or the official published rate and favourable to the seafarer.
As far as possible, company will settle the balance of wages in US dollars prior to the
seafarers signing off the vessel. However, in event of currency restriction prevailing in that
port, company employer shall pay the seafarer in local currency, if so desired.
If in exceptional circumstances, funds are not available on board or with agents, company
will settle the balance of wages within a maximum of 30 days or as per the applicable flag
state requirements by remitting it into the nominated bank account or by mailing a US
dollar cheque to the permanent address or address given to the master prior signing off.
Normal work hours shall be as per the respective CBA. The rates of overtime shall be as
agreed in the employment contract. The guaranteed overtime hours and allowance shall be
as stated and agreed in the employment contract.
Overtime shall be recorded individually and in duplicate by the master or the head of the
department. Such copy shall be approved by the seafarer and both the copies must be
signed by the master and /or the head of the department. One copy shall be given to
seafarer.
Any additional hours worked during an emergency directly affecting the immediate safety
of the ship and its passengers, crew, or cargo of which the master shall be the sole judge,
or for the work required to give assistance to other ships or persons in immediate peril
shall not be deemed as overtime hours.
Seafarer shall be paid extra work allowance as per the CBA applicable to the vessel.
Seafarer shall be entitled to holidays as per CBA applicable to the vessel.
For work and rest hour requirement, please refer to HSM manual.
When the ship enters in an area where war like operations take place, the seafarer will be
entitled to the benefits as per relevant terms and conditions in the CBA of officers and
ratings that are in force.
Where a seafarer is held captive on or off the ship as a result of acts of piracy or armed

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robbery against ships, wages and other entitlements under the seafarers’ employment
agreement, relevant collective bargaining agreement or applicable national laws, including
the remittance of any allotments and shall continue to be paid during the entire period of
captivity and until the seafarer is released and duly repatriated as per the agreement or,
where the seafarer dies while in captivity, until the date of death as determined in
accordance with applicable national laws or regulations.
The terms piracy and armed robbery against ships shall have the same meaning as in MLC
2006 (as amended). The entitlement to repatriation shall remain valid for the seafarer in
case of captivity on or off the ship as a result of piracy or armed robbery, even if they are
not claimed within reasonable time as defined by national laws or regulations or Collective
Agreements.
The seafarer will be responsible for all personal taxation whether of an income or capital
in nature in relation to the income from the employment. In the event that the employer or
its agent pays such taxes on seafarer’s behalf, the seafarer shall indemnify the employer
and its agent against all such payments it may make in respect thereof. It will be the
seafarer’s responsibility to ensure, if required by any government of recognized authority
to remit any portion of the earning to the state/ authority in question.
The following deductions from seafarer’s wages are permitted and may be applicable in
agreement with the concerned crew but may not be limited to Deductions permitted in
relevant national laws, or agreed to in a CBA, on-board purchases, telecommunication
calls and internet access, cash advances, allotments, contributions by the seafarer in
relation to any pension fund, charity, and in respect of membership of a body to any trade
union and friendly society.
In any case, no deductions can be made from a seafarer’s wage in respect of obtaining or
retaining employment. Monetary fines against seafarers other than those authorised in a
CBA are prohibited.

6.9 ENTITLEMENT TO LEAVE / REJOINING


Every seafarer is entitled for leave based on the duration of service on board as per the
employment contracts or respective CBA.
Those unable to re-join on completion of their entitled leave, shall notify the Office at least
6 weeks in advance with valid reasons.
Seafarers will be considered for early re-joining provided all their training and certification
requirements have been met and they can avail balance of leave during the calendar year.
In no case will a seafarer be considered for re-joining unless they have completed a
minimum of 2.5 days of leave per month of service on their previous ship.
Justified absence from work to attend approved maritime vocational training courses
required by the company and on account of injury or illness, is not counted as part of
annual leave.
The Company will not entertain requests from any seafarer to forego the annual leave.
The Master shall, where practicable, grant shore leaves to seafarers after ensuring that the
operational requirements of the ship can be met at all times. To handle any emergencies,
the Master must ensure that at least 50% of each Deck and Engine Department crew
remains on-board whilst the vessel is in port or at anchorage. One Senior Deck Officer
(Master or Chief Officer) and one Senior Engineer (Chief Engineer or Second Engineer)
will remain on board at all times. It is the responsibility of the crew members to return to
the vessel prior the shore leave expires. Appropriate shore leaves expiry notices as decided
by the Master to be put up. Nevertheless, it is the responsibility of the crew member to find
out the Shore leave expiry time from their respective HOD prior leaving the vessel. The

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Master shall exercise his discretion to retain more than 50% of the crew, should the
vessel's circumstances so requires.
RELIEF REQUEST
Masters to communicate to the company / manning agencies giving details of required
crew change for the next one month. Manning team / Manning agents in consultation with
company will plan the sign off of the seafarers and inform the Master about the crew
change and the tentative dates and port. The relief plan will consider request received from
seafarers for early relief.

Relieving of crew is carefully programmed in order to ensure safety levels of on- board
management system are maintained at all times.

While planning relief, the following requirements shall be met:


Following ranks shall not be relieved at same time:
Master & C/E; Master & C/O; C/E & 2/E - Interval between the relief of these ranks shall
be at least 14 days.
Any two key personnel from same department, which will hamper the safe and smooth
operation of the vessel.
Not more than one freshly promoted officer to be signed on at the same time within one
department.
Relief of more than 50% of complement at one port shall be avoided. Details on minimum
overlap period and pre-joining familiarization are provided in Company’s Guidelines to
manning agencies.
Any deviation from this guideline for relief / overlap period / pre-joining familiarization
shall be in consultation and approval of Head of Ship Management team.
Master to update manning company regarding ETD and request them to reschedule crew
departure if required.
In all cases, the company has the option of relieving the seafarer within 30 days either side
of completion of contract date, subject to operational convenience, convenient port, relief
position etc.
The Master will advise the company when:
Any crew change conducted on board vessel.
Any supernumeraries (Surveyor, Technicians, Office representatives) embarking the vessel
for the purpose of sailing with the vessel.
Any supernumeraries disembarking the vessel after sailing on board.
REPATRIATION

The company complies with requirements of flag state and seafarers’ national
requirements for provision of financial security to ensure that seafarers can be repatriated
in accordance with the MLC 2006 requirements.

Except in cases of indiscipline, misconduct, or gross negligence of the seafarer to comply


with company instructions and/or mandatory rules and regulations, the company will

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repatriate the seafarer at their expense in accordance with the Employment Contract.
The Master may discharge a seafarer for justifiable cause, including any of the following
grounds however in compliance with procedures mentioned in flag requirements and in
seafarer’s national employment agreement:
Unjustified failure to report on board at such times and dates as may be specified by the
Master;
Theft, embezzlement, or wilful destruction of any part of the vessel, its cargo, or stores;
Serious insubordination or wilful disobedience or wilful refusal to perform assigned
duties;
Mutiny or desertion;
Habitual intoxication, quarrelling or fighting;
Possession of dangerous weapons, narcotics, or contraband articles;
Intentional concealment from the ship owner or Master at or prior to engagement under the
Shipping Articles of a condition which resulted in sickness or injury;
Assistance to stowaways; and
Wilful violation of the laws of the administration or applicable local criminal laws.
The Company will provide on-board every ship a copy of the national provisions regarding
repatriation in a language read by the seafarers.
Company ensures that the minimum notice period for early termination is not less than 7
days, or payment-in-lieu for shorter notice.
SPECIAL REQUESTS
It is Company's policy to discourage requests for extensions of contract for all ranks.
However, these may be considered in the following special cases:
Extra sea time required for examination purposes;
Mutual agreement between staff on back-to-back rotation.
Extension request should be given at least one-month prior completion of contract in a
duly signed written application to the master who will then forward the same along with
the weekly manning report. All requests should carry the Master / Chief Engineer’s
recommendation and have valid reasons. Fleet personnel department in consultation with
the fleet manager shall either approve or reject these requests.
The person seeking extension of contract should be willing to stay up to one month beyond
the ‘new’ contract completion date. This should be mentioned and acknowledged in the
extension request letter. If extension is granted then cancellation of extension will be
treated at par with early relief request, and deductions will apply accordingly.
The management may approve requests where, due to examination or marriage purposes,
officers wish to join the vessel for a period less than the stipulated contract. The Manning
team must be notified of this in writing, prior their joining the vessel. Seafarer may also
request for early relief for Justifiable reason by submitting signed early relief letter, 30
days’ prior the expected date of relief, specifically indicating whether person is willing to
bear the repatriation expense or not.
Only emergencies involving the crewmember’s wife, child, mother, or father shall qualify
for sign off on compassionate grounds. At the sole discretion of the management,
deductions may be waived for staff relieved to meet an emergency requirement at home.
RESIGNATION

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Resignations shall be submitted to the Master in writing. The Master shall investigate the
matter in detail before reporting to the office. The Office will endeavour to relieve the
individual as per the conditions given in the employment agreement.
SEAFARER’S COMPENSATION FOR SHIP’S LOSS OR FOUNDERING
The Company shall do its utmost to prevent seafarers from being rendered unemployed
due to loss of any of its ship.
In case the Company is unable to place a seafarer on board within 30 days of disembarking
from such a ship, the company will compensate the seafarer in accordance with national
laws of the flag state or applicable collective bargaining agreement.
DEATH AND DISABILITY COMPENSATION
Death and disability compensation will be made as per the terms and conditions of the
employment contract and the flag regulations of the vessel on which the individual served
at the time of the incident.
Master of the vessel shall take measures for safeguarding property left on board by sick,
injured, or deceased seafarers and for returning it to them or to their next of kin.
Company shall be liable to pay the cost of burial expenses in the case of death occurring
on-board or ashore during the period of engagement.
MANNING LEVELS
Each ship carries a Minimum Safe Manning Certificate issued by the Flag State, a copy of
which is maintained in the company and manning offices.
The number of seafarers on each ship is decided by the company based on nature of the
vessel and her trading pattern so as to ensure that the ship can be operated safely,
efficiently and with due regard to security under all conditions and thereby prevent fatigue.
Guidance and relevant Flag State dispensation is provided to the Master in cases where a
seafarer position suddenly falls vacant due to exigencies and replacement cannot be placed
on board in reasonable time, and the ship is required to sail short.
The company shall provide additional deck and/or engine watch keeping officer beyond
the safe manning levels to ensure that fatigue is effectively managed, and operations are
carried out safely.
The vessels ship management team shall identify the requirement of additional watch
keepers based on the nature and frequency of the voyage and operations and approval shall
be done by the Fleet manager.
If a ship has changes like but not limited to construction, machinery or equipment,
operation and / or method of maintenance, or seafarers persistently fail to comply with rest
hour’s requirement, a risk assessment should be carried out and the safe manning
document should be reviewed in consultation with the company, Flag state shall be
notified as necessary.
Master and senior officers should assess seafarer fatigue and provide feedback to company
so that appropriate corrective actions can be implemented.
DISCIPLINARY PROCEDURE
All seafarers shall ensure strict discipline at all times. When non-compliance by a seafarer
occurs, Master shall investigate particulars and causes, prepare a report in writing, and
submit it to the company. Statements written and signed by the person himself and his
superior shall be attached to the report.
The company shall investigate the contents of non-compliance, promptly determine

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disposition and report to the Master.


For determining disposition, all information on non-compliance shall be notified to the
manning company and decision should be reached through consultations. Notice of
disposition shall be accompanied by a statement of agreement signed by the responsible
personnel of the manning company.
Records of all such non-compliances shall be maintained by the company and used for
further counselling / training.
The company strongly believes that for staff involved in operational incidents, re-
education, and further training, both on the job and while ashore, is to be provided as a
means for raising their skills and job knowledge. Refer to SMM Chapter 17 (On board
Discipline) for further details.
ACCOMMODATION AND CATERING
CREW WELFARE AND MESS COMMITTEE:
The objective of forming a crew welfare and mess committee is to look after crew welfare
and maintain a satisfactory standard of catering on board. Committees members shall be
elected internally and normally hold the position for a period determined by the Master. It
is recommended that staff be provided an opportunity in rotation every 2 months. The
Mess committee is responsible for taking care of the crew welfare and catering
requirements of the staff on board. The names of the committee members shall be posted
in the mess rooms. The committee will be presided by the Master.
The committee would normally consist of not less than five members including:
Master
Chief Engineer
Cook
One Deck rating + Deck Officer
One Engine rating + Engine Officer
Mess Committee shall meet at least once every month to discuss the following:
Quality and quantity of food served
Quantities remaining on board
Any discrepancies in quality / quantity of provisions
Menu
Crew complaints regarding food
Procurement plan / victualling budget
Wastage of food
Inspection of the provision stores and galley
Hygiene
Garbage management
Entertainment
Crew communications
Suggestions by crew members regarding the management of the welfare and mess shall be
made, in writing. A suggestions book will be provided for crew to address their complaints

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/ suggestions. These suggestions shall be discussed and closed during mess committee
meetings. Alternately complaints / suggestions may be brought up verbally at a committee
meeting which should be suitably recorded in the minutes of the meeting. Any complaint
related to food / welfare on board shall be brought to the attention of the committee or
department head using the on- board complaint form AD-11. The committee should
investigate the complaint and make all efforts to resolve the complaint amicably and as far
as practicable. A complaint that cannot be resolved by the welfare / mess committee shall
be brought to the attention of the superintendent for the vessel.
Mess meetings may as far as possible be attended by all members of the Mess not on
essential duty. This may be done to discuss important matters which requiring early
attention. The minutes of the mess committee meeting shall be recorded. The welfare /
mess committee must appreciate the limitations of the Cook and do whatever is necessary
to help to manage the provisions on board. Daily menu shall be maintained and displayed.
ACCOMMODATION AND RECREATIONAL FACILITIES
The Company ensures that accommodation and living conditions on board are to standards
specified by the Flag Administration.
MLC 2006 Crew Accommodation Certificate is held on board ships constructed after
coming into force of MLC 2006. Ships constructed prior to coming into force of MLC
2006 carry a Crew Accommodation Certificate or Crew Accommodation Exemption
certificate in accordance with ILO 92 or ILO 133, as required by the Flag State.
Recreational facilities are provided on all ships that can be used by seafarers free of cost to
them. These facilities and services should be reviewed frequently to ensure that they are
appropriate in the light of changes, in the needs of seafarers resulting from technical,
operational and other developments in shipping industry.
As a minimum each ship is provided with the following towards crew welfare:
Televisions, personal computers, radios, music systems and DVD players for use at
designated spaces
Sufficient rotating / replenishing stock of books, magazines, and music & video discs
Sufficient indoor games
Exercise equipment
Where possible, facility for swimming
Facilities for recreational handicrafts
It is the responsibility of each crew member to assist in maintaining the equipment’s. In
case the recreational equipment gets damaged inadvertently or in the course of normal use
(wear and tear), Master should inform the company and raise requisition. The crew welfare
and mess committee should consider the general upkeep of the recreational equipment.
Smoking is permitted in designated smoking areas. Restrictions on E- Cigarette should be
the same as for the Normal cigarette.
Provisions have been established to allow visitation of seafarers while in port and to allow
partners to be carried on board for part or all of a voyage provided compliance with
necessary security clearances and SOLAS regulations. The seafarer is responsible for
insurance coverage of the partner; the company facilitates the process for the seafarer to
obtain this insurance. Seafarer shall provide a letter of indemnity for such visitors in the
company prescribed form. Seafarers shall be granted shore leave to benefit their health and
well-being and with the due regard to operational requirements of their positions.
Email facility is provided to seafarers free of charge and ship-to-shore telephone is

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provided at reasonable cost.


Internet and Social Networking
On ships provided with internet facility, crews are given this facility for the following
reasons:
Communication with family and friends made easier and much competitive, by
applications such as IM Chat and other social networking websites;
Useful for self-study purposes (skill diversification);
Can be used to provide e-learning tools leading towards higher competency;
Online banking (especially important for a seafarer who looks after his own financial
affairs);
The ability to keep up to date with world events, both on a regional & global scale;
Raises the crew’s computer literacy through usage, hence enabling better
interaction with automated systems.
However, there are possible misuse by the crew which can be detrimental to the company
and the vessel. In order to safeguard against possible misuse by the crew following rules to
be adhered to:
Officers and crew are not to use the internet during their work hours unless it is for official
purposes.
Internet should not be accessed on Bridge / CCR / ECR for private browsing by duty
watch keepers.
Internet usage should not affect the rest hours, i.e. Increase in fatigue levels (prolonged use
of the internet resulting in less rest time).
Maximum usage of internet for private browsing should not be more than 2 hours in a day.
Master and Chief Engineer shall monitor the crew, to check if anyone is distracted from
work and has a continual want to use the internet.
No photographs of any shipboard operation are to be uploaded in any social networking
site or sent to any external party.
Guidelines on use of Social Networking Site / Web Site by vessels officers and crew:
In order to use the Social Networking Sites and Web Sites responsibly, following
guidelines are to be adhered to by the vessel’s officers and Crew:
Contents on Social Networking Sites/Webs are exposed to the eyes of countless people all
over the world. Some of your casual posting may cause significant serious legal actions by
the person who reads your post and may cause negative damages to the company. You
should use your common sense as not only a responsible employee of the company, but
also as a responsible member of the society, when you are posting.
When posting your personal account on SNS/Webs, the person who reads your posting
may sometimes (especially if it is work related) confuse your personal opinions/ responses
with those of the company. Please specify that your posting contents are not formal
opinions and responses by the company and clarify that your contents do not represent the
company.
You should never post any illegal contents and / or those items which may prejudice /
infringe the rights of any third party. The company especially prohibits the following
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Those which may infringe copyrights, trademark rights, portrait rights of any third party,
Those which may prejudice privacy of any third party
Those which may harm reputation of any third party
Those which may harm trust/honour/dignity of any third party
Those which may harm reputation/ trust/ honour/ dignity of the company
Those which may be legally regarded as pornographic expressions
Those which may cause/ support hacking/ unauthorized electrical access
Those which may be legally regarded as discrimination
Those which are untrue / incorrect/ false/ fraudulent
Any confidential information of the company and / or personal information which the
company holds as secret, such as but not limited to those regarding customers, suppliers,
maritime casualties.
Those which may threaten public order and morals, and / or which are
against the company’s compliance policies/ rules/ regulations/ guidelines.
FOOD & CATERING
Master to ensure that the provision of food and drinking water are of appropriate quality,
nutritional value, quantity, and variety taking into account the number of seafarers on
board, their religious requirements, and cultural practices as they pertain to food, and the
duration and nature of the ship’s voyage. A menu shall be prepared on daily basis to
ensure above criteria is met. The menu shall be displayed in the mess room and the record
of menu shall be maintained for a period of one year.
Master to ensure that the organization and equipment of the catering department permits
the provision to the seafarers of adequate, varied and nutritious meals prepared and served
in hygienic conditions.
Seafarers on board are provided with food and drinking water free of charge during the
period of engagement. All catering staff to be trained and instructed in food and personal
hygiene and handling and storage of food.
Cooks on board should be trained, qualified and found competent for the position in
accordance with Flag requirements. For each vessel please refer to DMLC II for individual
flag requirements.
In circumstances of exceptional necessity, the competent authority may issue a
dispensation permitting a non-fully qualified cook to serve in a specified ship for a
specified limited period, until the next convenient port of call or for a period not exceeding
one month, provided that the person to whom the dispensation is issued is trained or
instructed in areas including food and personal hygiene as well as handling and storage of
food on board ship.
An inventory of ship properties including the recreational items and galley equipment
(cabin / space wise inventory) shall be maintained by the master and condition of same
shall be verified during periodical inspection of accommodation.
To ensure that seafarer accommodation is clean, decently habitable and maintained in a
good state of repair, Master to carry out crew accommodation and hygiene inspection at
intervals not exceeding 7 days. This inspection shall cover recreational areas, food and
drinking water, all spaces and equipment used for the storage and handling of food and
drinking water; and galley and other equipment for the preparation and service of meals.

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Records of such inspections are made in official log-book. Record shall be maintained for
the inspections carried out using the Master’s accommodation Inspection Checklist.
HEALTH PROTECTION, MEDICAL CARE, AND WELFARE
Company’s Quality, Occupational Health, Safety, and Environment (QHSE) Policy, is
documented in SMM Ch. 2 and various procedures for health protection and safety and
environmental compliance is given in HSM manual. It is the duty of the Master to
implement the policy / procedures and it is the duty of every seafarer to follow the policy /
procedures.
MEDICAL CARE
The Company is responsible for providing medical treatment and facilities for all
personnel on board, as per the employment contract. Seafarers have the right to visit a
doctor or dentist without delay in ports of call, where practicable.
The Company shall make payments for emergency dental treatments such as extraction or
repair due to injury. Costs for cosmetic dental treatment, such as cavity fillings, polishing
etc. will be borne by the individual crewmember.
Hospital accommodation is to be used solely for Medical purposes. Medicines and
equipment on-board are to be maintained in accordance with WHO requirements.
Controlled drugs are stored in a secure locker in Master’s custody. On vessels where the
ships dispensary forms a part of the hospital all medicines in the dispensary should be kept
under lock and key.
Expired medicines and used medical supplies to be stored in a designated locker (Under
lock) with an updated inventory. Disposal of expired medicines to be carried out in
accordance with the Ship specific Garbage management and in compliance with any local
rules/regulations.
Refer to HSM manual for guidelines for health promotion on board the vessels. Master to
ensure crew are made aware of the health bulletins which are regularly sent to the vessel
and motivate the crew to participate in the health program
The Master should use his discretion when requesting medical treatment ashore for any
crewmember of the vessel. Shipboard medication is to be used for the treatment of minor
illnesses or injuries.
The sickness Report form shall be filled in for every crewmember visiting a doctor. One
copy of the report with the doctor’s comments shall be retained on board and one copy
shall be forwarded to the office. A record of all medical treatment provided on board and
ashore during the tenure of the seafarer is maintained. Flag specific report forms if any, to
be complied with.
The Office should be immediately informed of any illness or injury for which a crew
member needs to be sent to a shore doctor for medical assistance and/or if the crew
member needs to be taken of work for one full day.
All seafarers are provided with medical / essential dental care and are entitled to visit a
medical practitioner ashore for this purpose. All medical care provided is comparable with
the medical care available to workers ashore. Each Seafarer’s medical report must be
treated as confidential on-board.
Company shall bear the expense of medical care, including medical treatment and the
supply of the necessary medicines and therapeutic appliances, and board and lodging away
from home until the sick or injured seafarer has recovered, or until the sickness or
incapacity has been declared of a permanent character.
Emergency medical advice is available to all ships at sea by radio, satellite communication

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24 hours a day. Master should not hesitate to avail the above facility in case of medical
emergencies.
In case required Master to seek medical guidance at sea from:
Ship Captain’s Medical Guide (Publication available in Regs4Ships Software)
International Medical Guide (Publication available in Regs4Ships Software)
C.I.R.M (Centro International Radio Medico)
Tel No: +39 0659290263 (24hours number) E-Mail: telesoccorso@cirm.it
Web site: www.cirm.it
Balaji Medicals (In case CIRM not responding)
Tel No: +91 44 24364651; +91 44 24364652; +91 44 24364653
Email Id: info@balajimedicalcentre.com; dr@balajimedicalcentre.com Web site:
www.balajimedicalcentre.com
HEALTH, SAFETY PROTECTION & ACCIDENT PREVENTION
Detailed procedures for health and safety protection and accident prevention are given in
SMM and HSM manuals. Reference as follows:
.Permit to work systems – HSM Ch. 02
Safety meetings – HSM Ch. 05
Chemical handling and storage – HSM Ch. 11
Risk Management – HSM Ch. 10
Fatigue management – HSM Ch. 12
Food and hygiene – HSM Ch. 13
Accident reporting and investigation – SMM Ch. 9
Health Surveillance – HSM Ch. 14
Occupational Hazards and Diseases – HSM Ch. 15
A risk assessment shall be carried out, in order to reduce and prevent risk of exposure to
harmful levels of ambient factors such as noise and vibration as well the risk of injury or
disease that may arise from the use of equipment and machinery on board ship.
COMPLAINT PROCEDURE
This procedure is provided to establish formal complaint procedures, as prescribed by the
Flag state, for the fair, effective and expeditious handling of seafarer complaints alleging
breaches of MLC 2006.
Company ensures that all seafarers working on board any ship have a copy of the on-
board complaint procedures, as prescribed by the flag state. The manning department shall
handover below documents to the seafarer at the time of joining along with the Seafarers
Employment Agreement:
On-board complaint procedure, form SF-10
Complaint form AD-11
Contact details of company authority/DPA, form SF-10
Contact details of Flag state competent authority for addressing complaints, form SF-10
Contact details of competent authority in seafarer’s country of residence, form SF-10

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All on board complaints should be addressed to the respective head of departments or to a


superior officer. Complaints should be resolved quickly and effective, at the lowest level
possible.
All complaints and decision outcomes should be recorded in the prescribed form and a
copy of it provided to the seafarer concerned.
The complainant maybe accompanied and represented by another seafarer of choice on
board the ship.
Complaints regarding health and safety matters should also be reported to the safety
officer.
All complaints must be addressed as far as possible within 48 hours of receipt but in no
case later than the time as prescribed by the respective flag.
The Master should personally handle all complaints that are not satisfactorily resolved to
the satisfaction of the complainant by the head of the department or superior officer.
The Management strictly prohibits victimization of any sorts towards the seafarer filing the
complaint.
The vessel shall keep on board a record for complaints, where all of these as well as the
decisions made related to the same, should be recorded. Also, a copy of this shall be
provided to the seafarer; if a complaint cannot be resolved on board, the matter should be
referred ashore to the company, who will then resolve the matter in the time frame as
prescribed by the respective flag which in any case shall not exceed a period of eight (8)
days.
This shall be done in consultation with the concerned seafarer or any person they may
appoint as their representative; and in all cases, seafarers have a right to file their
complaints directly with the master, office and where necessary, to any appropriate
competent external authority (as declared by respective flag) such as, but not limited to:
Flag Administration Nautical Inspector;
Flag Administration Recognized Organization Inspector;
Port State control official;
Local seafarer labour organization representative; or
Other seafarer welfare assistance service.
If within the period of eight (8) days, the complaint on board has not been resolved, then
the period shall be extended for twenty-two (22) more additional days or such time as
prescribed by the respective flag state, with the sole purpose to find a favourable solution,
which shall be recorded on the registries of the ship and be available to the competent
authorities.
The complainant may contact the Master, Chief Engineer, Chief Officer or 2nd Engineer
to provide impartial advice regarding his complaint on a confidential basis.
Refer to below flow diagram:
COMPLAINT
UNRESOLVED
COMPLAINT
UNRESOLVED
Ster

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Complaint refer to the Company


Complaint refer to the competent external authority
COMPLAINT
RESOLVED
COMPLAINT
RESOLVED
COMPLAINT RESOLVED
Complaint is resolved and decision recorded in prescribed form
Complaint is resolved and decision recorded in prescribed form
Complaint is resolved and decision recorded in prescribed form
TRAINING
It is the company’s policy to ensure that all personnel receive training in the methods and
techniques required to undertake their duties and responsibilities. All personnel whose
work may create significant impact on the environment shall receive appropriate training
to ensure QHSE awareness.
Master is responsible for identifying the training needs of the ship staff whilst on board
ship and for conducting training through drills, safety meetings and other trainings as
identified. Training conducted on board shall be recorded in the Training Record form and
informed to office.
Office is responsible for identifying and arranging the training needs of the ship staff
whilst they are ashore and for maintaining the training records of all ship staff in database
Master in consultation with the Heads of Department shall identify the training needs of
the staff on-board. Staff appraisals help in identifying the training needs. This shall be
reported, and the entry shall also be made in the database. Master will arrange on-board
training as required.
PRE-JOINING FAMILIARIZATION:
The vessel has documented procedures to ensure that new personnel and personnel whose
assignment aboard is changed are familiarised with their duties prior to assuming their
responsibilities. Refer to HSM manual Ch. 1 Sec 1.7 for more details.
IN-HOUSE TRAINING
In house training courses are provided at the company and at the manning offices and the
training material is developed based on the IMO model course and industry best practices.
Training will be carried out by designated trainers, which will be documented in the
training programme. In house training modules include guidance on Risk management,
Incident reporting and investigation, Safety officer course etc. to achieve health and safety
protection and accident prevention. More details are given in Office Procedure Manual and
Guidelines to Manning Agencies.
COMPUTER BASED TRAINING
In addition to in-house training programme, company also provides computer based
training. Office is provided with the CBT module which the Staff may use to train when
they are on leave or during pre-joining formalities. The CBT modules are also reviewed
and modified as per requirements identified.
ON BOARD TRAINING

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Training will be also carried out by trainers when they board the vessel for inspections. If
time permits, the trainers will sail with the vessel for on board training. The training
curriculum will be designed based on vessel requirements.
In addition to training carried out by trainers from company, training shall be carried out to
all staff on Code of Safe working practices and HSM. While every effort should be made
to make the training sessions as practical as possible, even a simple interpretation of the
relevant sections, albeit clearly delivered, will have some benefit. This training shall be
recorded in the minutes of Safety Committee meeting.
All staff will be grouped as given in the below table for this training and the training will
be given by the mentors.
TEAM TEAM MENTOR CHAPTERS MONTH
MEMBERS
AB Junior Deck Master (Team COSWP-1,2,5,8 & 9 Jan /July
officers (Team A) HSM Ch08& Ch. 10, SMM Ch16
A) COSWP-3,7,11,13&23 Feb /Aug
Chief Officer HSM- Ch. 3
Deck Crew (Team B) COSWP 4,6,12,21&25 Mar / Sep
and Cadet HSM – Ch. 02
(Team B) COSWP – 14,15,17,20&24 Apr / Oct
HSM Ch12 & Ch13
COSWP –10,16,18,19 &22 May / Nov
HSM Ch. 09 & Ch. 07
COSWP – 25,33,28/29 Jun
(as e /
De
applicable)
c
C Jun Chi COSWP-1,2,5,8 & 9 Jan
ior ef /Jul
HSM Ch08& Ch. 10,
D En En y
SMM Ch16
gin gin
eer eer COSWP-3,7,11,13&23 Fe
s (Te b /
HSM- Ch. 3
(Te am Au
am C) g
C)
COSWP 4,6,12,21&25 Ma
Sec r /
HSM – Ch. 02
En ond Se
gin En p
e gin COSWP – Ap
Cre eer 14,15,17,20&24 r /
w (Te Oct
and am HSM Ch12 & Ch13
Ca D) COSWP –10,16,18,19 Ma
det &22 y /
(Te No
am HSM Ch. 09 & Ch. 07
v
D)
COSWP – 25,33,28/29 Jun
(as e /

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applicable) De
c
E Gal Sec COSWP-1,2,5,8 & 9 Jan
ley ond /Jul
HSM Ch08& Ch. 10,
Cre Off y
SMM Ch16
w icer
COSWP-3,7,11,13&23 Fe
b /
HSM- Ch. 3
Au
g
COSWP 4,6,12,21&25 Ma
r /
HSM – Ch. 02
Se
p
COSWP – Ap
14,15,17,20&24 r /
Oct
HSM Ch12 & Ch13
COSWP –10,16,18,19 Ma
&22 y /
No
HSM Ch. 09 & Ch. 07
v
COSWP – 25,33,28/29 Jun
(as e /
De
applicable)
c
PROMOTION ORIENTATION PROGRAMME
Promotion orientation programme is to enable an objective assessment of the aspiring
officer, identify any training needs required and check his suitability for promotion to
senior ranks on board.
Command orientation programme is designed to assist the Chief Officers to learn the
required skills prior to considering them for promotion. This will be initiated from the
office.
On-board training programme is available for other senior officers (2nd officer to Chief
Officer, 2nd Engineer to Chief engineer and 3rd engineer to 2nd Engineer). This
programme is used to help officer grow as an able and professional senior officer.
OF-MA-003 (Second Engineer Orientation) and OF-MA-004 (Chief Officer Orientation
Program) forms to be used for promotion program.
Master’s and Chief Engineers to play the Mentor role and encourage the aspiring officers
to voluntarily take up this orientation programme.
Junior Officers to be trained in cargo operations including planning by the Chief officer.
This is to be done as part of promotion orientation program and /or involving then in cargo
planning and execution. This is to Prepare the juniors for the next role. Junior Engineers
(3rd and 4th) to be trained on Bunkering. Second Engineer promotion orientation program
to include Effective bunker handling.
Any training need identified during this programme shall be fulfilled prior promotion.
Evidence of this training shall be maintained with the Manning team. (See records for

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applicable forms).
SEMINAR
Seminars will be organized once in a year by company and the schedule will be planned to
accommodate as many senior officer as possible.
Seminars will be used to promote company safety management system and safe culture.
To promote and encourage commitment for safety and environmental excellence, awards
will be given to vessels. Category of awards and final decision of awardees will rest with
the management.
Agenda for the Seminar to Include the Below,
Company culture, ethics and values.
Environmental management.
New legislation.
Safety, human element and security issues.
Specific shipboard procedures, e.g. the role of the Safety Officer, enclosed space
entry, safe mooring and engine room waste management.
Career development.
Lesson learned from Incidences and Near Misses.
EXTERNAL TRAINING
As per the annual training plan, external training will be conducted using recognized
training institutes.
All records related to training carried out shall be maintained by the office.
DRILLS AND SAFETY VIDEOS
Potential emergency drills, likely to be involved with the ship, shall be practiced for which
the Master of each vessel shall be responsible to impart necessary training to the staff.
Such records shall also be maintained by the Master.
Safety video shall be periodically demonstrated to all the staff on board, record of which
shall be maintained by the Master.
The training / drill matrix shall be followed as a minimum for conducting the drills /
training.
TRAINING OF CADETS
Training officer for Deck cadets is the chief officer and for Engine cadets is the 2nd Eng.
Other officers/Ratings may participate in training of cadets, however dedicated training
officer remains overall responsible.
Deck and Engine cadets shall be engaged for training purposes only. They shall not
perform any duties without qualified supervision. Under no circumstances the cadets are to
be engaged in duties not serving the purpose of their future vocational development as
defined in STCW 2010.
To ensure above, it is essential that the shipboard training is carried out strictly in
accordance with their Structured Shipboard Training Program.
Instead of allotting repetitive (Especially menial/laborious/secretarial) Tasks, which
restrict new learning, cadets should be given tasks as per CRB/TAR books.
Their records/project books should be inspected and signed at regular intervals correctly,

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since officer signing record books may be called by Flag state for verification.
At least 4 hours of Bridge/Engine room or cargo watch keeping time must be allotted
everyday/occasion, since this most imperative skill cannot be imparted ashore.
Training shall be carried out within normal working hours (Morning 0800 hrs to evening
1700 hrs) except for times where cadets may be required to get involved in watches or
critical operations at night time.
2 days in a week (Preferably Wednesday and Saturday) shall be kept for theoretical studies
etc. This schedule may be deviated for exceptional training purposes, such as, watch at
port or sea.
It is the responsibility of the training officer to monitor the work & rest hours of cadet
closely and he shall take all measures to avoid having non-conformance in rest hours for
cadets.
APPRAISAL
The form Ship Staff Appraisal Report is to be used for Officers, Cadets, and Ratings.
This form is referred to as the “appraisal form” throughout this section.
GENERAL GUIDELINES
The Company attaches the utmost importance to the appraisal of seagoing personnel,
including the prompt despatch of the completed and signed reports in accordance with
these instructions.
The Appraisal process is NOT confidential. The objective of an appraisal is two-fold:
to report the performance of sea-going personnel to the Company, and
to apprise the individuals of their progress, highlighting both their strengths and
weaknesses.
Hence it is important that the contents of a report are discussed with the individual
concerned and his feedback, if any on the appraisal is noted.
When conducting an appraisal, the following guidelines should be observed:
Sufficient time should be allowed for preparing the appraisal report and for discussion of
the contents. For this purpose, a suitable time and venue should be selected, with adequate
notice given to the officer, cadet or rating concerned. The appraisal interview should not
be conducted in a public place or at a time when interruptions can be expected.
The appraisal report should contain no “surprises”. Personnel should be continuously
aware of their performance as part of day-to-day contact with their superior and should,
therefore, be already aware of their progress. For example, it would be incorrect to give a
“poor” grading for conduct if no prior warnings of misconduct have been recorded.
The utmost caution should be exercised when discussing a person’s
‘promotion potential’ and it should be stressed that any recommendation made relates to
that specific reporting period only. The Master will, in general, be unaware of a person’s
previous employment history, which will be an important factor when assessing a person’s
employment status.
Hasty judgments regarding promotion may be damaging to the individual concerned and
may, in the future, compromise the safety of a vessel. If during an appraisal interview the
Master indicates that a person is ready for promotion, he should make it clear that this is
only a recommendation and in no way guarantees that a promotion will immediately
follow.

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The appraisal form should be filled out with care and fairness, and in the interests of both
the person reported on and the Company. An honest judgment should be made of the
qualities of the person based on the entire period and not an isolated incident alone.
Performance must be measured against the requirement of the position and in this respect
the designated
reporting officer (see below) should be thoroughly familiar with the person’s
duties or job description.
When signing the report, the Master should indicate whether he concurs with the
comments of the appraising officers and should check the compatibility or grading given
and the comments made.
Submission of inaccurate or inconsistent reports will reflect adversely on the reporting
officer and the Master. The Master should check in particular that the report has been
signed, as appropriate to the case.
Master shall ensure that all appraisal reports are discussed with the
individual concerned and the person’s signature and feedback if any are
obtained on the appraisal form.
When identifying any areas of weakness, the reporting officer may also make suggestions
in that section of the report, concerning any training that might assist the career
development of the individual.
These remarks should be reflected on the appraisal report.
Adverse appraisals of personnel who have completed 2 successful contracts with good
evaluation reports will be scrutinized by the management before a final decision is taken.
THE APPRAISING OFFICER

RANK APPRAISING
OFFICER
Deck Officers Master & Chief
Officer
Engine Room Staff Chief Engineer
Deck Ratings Chief Officer
Catering Staff Master

There may be circumstances where the Master may feel that an appraising officer
designated above is not the most suitable person to carry out the task. In such
circumstances, he may complete the report himself or delegate the task to an alternative
officer. In both cases, the reasons for doing so must be stated in the master’s Comments
Section.
When Master wants to recommend a termination of employment due to poor performance,
inadequate discipline, or non-compliance with code of conduct on board, he shall send a
confidential report by email to office. Such adverse appraisals of personnel who have
completed 2 successful contracts with good evaluation reports will be scrutinized by the
management before a final decision is taken.
Superintendents will submit a report on vessel’s personnel, following a visit to a

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vessel.
FREQUENCY OF REPORTING
Performance appraisals shall be conducted for all personnel as follows:
Upon sign off of an individual
At midterm of the individual
Prior Master/Chief Engineer sign off (Provided they have completed at least 40 days on
board)
Or
Special condition (request from office)
Master’s and Chief Engineer’s appraisals shall be conducted by office.
DISTRIBUTION OF REPORTS
The Original reports to be forwarded to the Synergy office in a sealed envelope, unless
requested otherwise by the Company.
The Master shall forward copies of the reports to the appropriate manning agency offices.
COPIES OF REPORTS NEED NOT BE RETAINED ONBOARD.
CADETS AND TRAINEES
The information required by the Company during the early stages of an officer’s
career varies from that once competency has been achieved.
The comments of the reporting officer under all circumstances to be shown to the cadet or
trainee.
The reports to be distributed as in 6.9.4 above.
GUIDELINES TO MANNING AGENCIES
In case of manning through agents, the company shall assess the ability of the manning
agents with respect to the requirement of the company. The manning agent shall be
reliable and should have good reputation in manning business through many years of
experience, own training system and adequate qualified crew candidates.
A detailed guideline shall be developed by the company for respective manning agents and
that shall include following minimum requirement:
Ensure that Synergy policies and guidelines for recruitment, medical examination, training
and placement are fully understood.
provide qualified seafarers for ships assigned to the crewing agency for manning as per
company requirement
Ensure that seafarers only above age 18 years are employed or engaged to work on a ship
managed by the Company. This shall be verified from the seaman’s discharge book and or
passport
The manning agent shall have in place procedures to prevent exploitation of the seafarers
by their staff for personal gains, financial or otherwise.
Shall not levy any fee or other charges to seafarers for providing employment to seafarers
directly or indirectly in whole or in part for the purpose of recruitment.
Recruitment and placement services shall be operated in an orderly manner that protects
and promotes seafarer’s employment rights as provided in MLC 2006.

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Ensure that assigned vessels are manned as per minimum safe manning certification.
Inform Synergy if MSM is not complied and arranged for dispensation from flag state.
Verify that certificates of competency are valid and assess the authenticity of the
certificate of competency with the issuing authority.
ensure that seafarers employed on board are qualified as per STCW regulations, as
amended, have certificates that is endorsed by Flag state and comply with selection criteria
specified by Synergy.
Interview prospective candidates to review experience and qualifications, review the
adequacy of experience and competency to serve on assigned vessel.
Carry out reference checks for experience stated by the seafarer.
Forward to Synergy, bio-data of candidates shortlisted to join vessel, for review and
approval.
Communicate crew relief plans to company for approval.
Ensure all seafarers employed in assigned vessel qualify / medical examinations as agreed
with Synergy.
Be familiarized with company’s QHSE policy and Safety Management System.
Impart training courses specified for each rank as required by Synergy.
Provide quarterly report of seafarers employed on board Synergy vessels.
Have an appraisal system that determines crew performance and sets criteria for
promotions.
Have a grievances redress system to resolve seafarer complaints. Complaints pertaining to
shipboard SMS shall be forwarded to Synergy.
Have procedures to provide medical assistance to seafarers, who are signed off from
Synergy vessels due illness / enquiry.
Continuously monitor and provide information and recommendations to the Controlling
office relating to local conditions with respect to availability of crew, forthcoming
employment terms and wage reviews, potential difficulties relevant activities and training
facilities and developments.
Be audited by Synergy once a year.
Provide the Seafarers with policies, contact details of key personnel of Synergy, DPA &
CSO for vessel.
EMPLOYMENT OF OFFICE STAFF
Office will recruit experienced, qualified, and competent personnel in the office, either
through recruitment or transfer or promotion from within, to support the management and
operation of the vessel(s), consistent with the quality, health, safety, and environmental
protection policies of the Company.
Detail of recruitment of office staff is provided in the Office procedure manual. Head of
Ship Management team is responsible for identifying and arranging for the training needs
of the shore staff. Training needs of the office staff shall be identified in the Management
Review and appropriate training shall be arranged. Records of shore-based training of
office staff shall be maintained by the CMS team. Shore based personnel upon his/her
joining is guided by his/her immediate senior and also trained by the senior executives for
proper functioning. The Office procedure manuals serve as a basis for their initial
guidance.

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Shore based personnel are encouraged to attend seminars conducted by the in matters
pertaining to various aspects of the marine field, for which the Head of Ship Management
team will nominate the person to attend same. Such records are separately maintained.
Appraisal of the office staff will be done at least annually. The Head of various teams will
apprise the members of the office staff. The appraisal interview offers you an opportunity
for useful discussion with your supervisor.
If the appraiser identifies a training need then there is the opportunity to arrange to meet
that need.
The opportunity to have a discussion with your appraiser gives you a chance to ask about
his perception of your performance.
There may be several different things, which you feel are preventing you from doing your
job better. These may be lack of training, poorly defined job objectives, insufficient help
from colleagues, or the way you are managed. Sometimes your manager will agree with
you and sometimes he will not; but the more clearly each of you can convey your views to
the other, the more likely you are to agree to what needs to be changed and the more likely
are actions to result which will enable you to become more effective. In particular, good
decisions about training are more likely to be made if you have done some thinking about
them.
If your manager indicates some weakness or inadequacy in your approach to your job, it
may be that the principal effort in improving performance may have to come from you.
Considerable investments are made in the training and development of staff and the
Performance Appraisal process is an ideal opportunity for you to highlight any training
needs that you consider will develop your strengths or overcome any perceived
weaknesses. The success of an assessment interview depends both on you and your
Manager.
Records:
Employment Contract – Form M11
Contract Extension Request Letter – Form M 34 Training Record – SF-17
Ship Staff Appraisal Report (Appraisal form) – AD 12 On Board Complaint form - AD 11
Safety Familiarization Booklet - SF-10
Pre-Joining Briefing – OF-MA-010, OF-MA-011, OF-MA-012 OF-MA -003 -Second
Engineers Orientation Programme OF-MA-004- Chief officers orientation programme
OF-MA-006-Command Orientation Programme
OF-MA-007-Chiefengineers orientation programme.

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7 DEVELOPMENT OF PLANS FOR VESSEL


OPERATIONS

7.1 DEVELOPMENT OF PLANS FOR VESSEL OPERATIONS


Key operations of the vessel that have an impact on safety and pollution prevention are
identified from the vessel operations and from guidance from relevant authorities within
the industry. Other operations may be identified by audits, reviews, and/or inspections.

7.2 DEFINITIONS
"Special Shipboard Operations" are defined as those operations where errors may become
apparent only after they have created hazardous situations and when accidents have
occurred. These include, but are not limited to:
 Securing watertight integrity,
 Checking for navigational safety,
 Periodical checking for reliability of machinery and equipment,
 Maintenance operations,
 Condition of stability, overloading and overstressing,
 Checking and control for spare parts and important articles,
 Lashing of cargoes
 Safety patrol
 Preventative actions against piracy, terrorism, and stowaway,
 Smoking restriction
“Critical shipboard operations” are defined as those operations where an error may
immediately cause an accident or a hazardous situation for the crew, the ship, or the
environment.
These include, but not be limited to:
No Description of work Control measures in addition to procedures

Navigation during reduced visibility, Checklist & Level 1 Risk Assessment


Navigation in high density traffic areas Checklist & Level 1 Risk Assessment
Navigation in confined waters, Checklist & Level 1 Risk Assessment
Navigation in heavy weather condition, Checklist & Level 1 Risk Assessment
Navigation in vicinity of ice Checklist & Level 1/2 Risk Assessment
Bunkering operations, Checklist & Level 2 Risk Assessment
Enclosed space entry Checklist & Level 2 Risk Assessment
Hot Work Checklist & Level 2 Risk Assessment
Working aloft / outbound Checklist & Level 2 Risk Assessment
Electrical work including work in elevator Checklist & Level 2 Risk Assessment
11 Diving operations Checklist & Level 2 Risk Assessment
12 Mooring Level 2 Risk Assessment & Tool Box Meeting

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13 Heavy lift Tool Box Meeting


14 Helicopter Operations Checklist and Level 2 Risk Assessment
15 Topping off on tankers Level 1 Risk Assessment
16 Crude Oil Washing and Tank Checklist &Level 1 Risk Assessment
cleaning operations on tanker
17 Nitrogen Padding on chemical Checklist &Level 2 Risk Assessment
tankers
18 Hose connection and disconnection on all tankers Level 1 Risk Assessment
19 STS operation on all tankers Checklist and Level 2 Risk Assessment
20 Comingling of LPG cargoes on m,Gas Carriers Level 2 Risk Assessment
Following operations in heavy weather Checklist & Level 2 Risk Assessment
Working on deck
Operating crane Checklist & Level 2 Risk Assessment
Entering holds/tanks Checklist & Level 2 Risk Assessment
Monitoring reefer temperatures Checklist & Level 2 Risk Assessment Checklist &
Anchoring operation Level 2 Risk Assessment
Checking of log lashing Level 2 Risk Assessment

Procedures addressing these Special and Critical operations are prepared and are included
in the:
Navigation Manual;
Health and Safety Manual
Cargo operations manual
Technical Manual
Forms and checklists are prepared based on the procedures and are available for ready
reference.
These procedures shall:
Comply with local, international regulations and company policies.
Provide tools for planning and monitoring operations by means of instructions and
checklists. Risk assessment and permit to work systems are good planning tools in
controlling the critical activities.
Provide contingency planning for critical operations.
Suggest ways to prevent or reduce health hazards due to work place hazards or substances.
The shipboard personnel and suggestions continually review these procedures to improve
the operations are conveyed to office via various systems like Shipboard Management
reviews, Monthly Safety meetings and monthly review of manuals on board.
A planned maintenance system is implemented on board to ensure reliability of
machinery and equipment. All critical equipment’s are identified and marked on the
planned maintenance systems.
Sufficient resources shall be made available on board to perform safe and efficient
operations and thorough maintenance. Minimum required spares and stores for safe
operation, maintenance and contingency shall be maintained on board.

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7.3 RISKS AND OPPORTUNITIES


The overall aim of risk and opportunity management within Company is to ensure that
organizational capabilities and resources are employed in an efficient and effective manner
to take advantage of opportunities and to mitigate risks.
Senior management are responsible for incorporating risk-based thinking in to our
organization’s culture. This includes the establishment of risk management policies and
targets to ensure effective implementation of risk and opportunity management principles
and activities by:
Providing sufficient resources to carry out risk and opportunity management activities;
Assigning responsibilities and authorities for risk and opportunity management activities;
Reviewing information and results from audits and risk and opportunity management
activities;
Innovate continuously and exploit the possibilities of latest technologies to keep ahead of
rapidly changing industry trends to reduce or eliminate the occupational health and safety
hazards'.
The scope of Company’s Risk and opportunity management process includes the
assessment of the internal and external issues identified in Chapter 1, and the assessment
of the needs and expectations of any interested parties identified in Chapter 1. Risk and
opportunity management is undertaken as part of company’s day-to-day operations and is
captured at the following hierarchy:
Strategic level;
Programme level;
Department level;
Process level;
Establishing such a hierarchy for capturing risk and opportunity ensures that each is
managed at the most appropriate level within our Organization. Typically, the following
categories are assigned to each level in the hierarchy as shown in the table opposite.
Business Hierarchy Risk / Opportunities
Strategic Level Budgets and Profitability; New Ship owners and vessels
under the management
Programme Level Performance and Efficiency; Achieving objectives and KPI’s
Department Level Resource and Targets; Trained and competent crew on board
and experienced shore staff
Process Level Evaluation and Assurance; Management Review, Appraisals,
Internal Audits, External Audits, feedback from interested
parties.
Company has classified its ‘risk appetite’ as the amount of risk that we are willing to
accept in pursuit of an opportunity or the avoidance of risk where each pertains to system
conformity, and which reflect the following considerations:
Risk management philosophy per process;
Capacity to take on or mitigate risk;
Our objectives, business plans and respective stakeholder demands;
Evolving industry and market conditions;
Tolerance for failures.

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Company uses Risk assessments register to help record, assess, respond, review, report,
monitor and plan for the risks and opportunities that we perceive to be relevant. The
registers allow our Organization to methodically assess each risk and to study each
opportunity associated with our Organizational context, and the needs and expectations of
our interested parties. The register records the controls and treatments of risks and
opportunities and preserves this knowledge as documented information as part of the
company risk assessment register.

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8 GENERAL
Procedures have been established, pertinent to the vessel, for identifying, describing, and
responding to potential emergency situations. Additional potential emergency situations
may be identified during drills, by a change of voyage, or by non-conformities or
accidents.

8.1 EMERGENCY DRILLS


The Company has established a program of emergency drills that are conducted aboard the
vessels and onshore. It is the Master’s responsibility on board and the Designated Person’s
responsibility ashore to ensure that the program of drills is carried out. Refer to
Contingency Manual for more details.

8.2 EMERGENCY RESPONSE


The Company maintains emergency response plans for the effective response, by vessel
and shore-based personnel, to hazards, incidents, and emergency situations. These are in
compliance with national and international regulations.

8.3 REFERENCE
Contingency Manual SOPEP/SMPEP
Ship Security Plan
Chemical Tanker Manual (Applicable for Chemical Tankers)

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9 VESSEL GENERAL REPORTING


Refer to SMM Chapter 19 Communication for routine reporting. As guidance to Masters
for easy reference following matrix gives an overview of the communication that a Master
is required to perform with the office. For the better understanding the process of office
communication is also provided against every process by the Master. It must be noted that
a Risk assessment must be carried out for every Condition of class and dispensation and
must be approved by the vessels SMT.

9.1.1 Reporting Matrix


MASTER OFFICE
ACTIVITIES COMMUNICATION COMMUNICATION
RESPONSIBILITY RESPONSIBILITY

9.2 OTHER IMPORTANT REPORTING:

9.2.1 REGULATORY REPORTING OF VESSEL DAMAGE, DEATH, INJURY,


SERIOUS ILLNESS OF PERSONNEL, CASUALTIES
All regulatory reports including flag state, on vessel damages, death, injury, the vessel
shall report serious illness, in consultation with office. Detailed reporting procedures are
available in contingency Manual.

9.2.2 DEFICIENCIES POINTED OUT BY PSC / FSC AND SIMILAR OTHER


AUTHORITIES.
Deficiencies notified to vessel by authorities such as Classification Society surveyors, Port
State Control inspectors, vetting inspectors, Flag State authority, charterers, Terminal
inspectors etc. shall be notified to the company. A corrective action plan shall be agreed
upon with the company. The vessel superintendent shall monitor such deficiency and close
out as agreed. The company shall communicate to the authority that have raised the
deficiency and ensure close out.
Requirements for reporting to flag state:
All PSC/FSC inspection results shall be reported immediately to relevant division of flag
state. Masters shall send the inspection report to office and Ops & Tech Team will send
the report to flag state.
The action taken to correct the deficiency identified by PSC shall be sent to flag state as
soon as possible by SMT (in the format required by flag state).
The action taken to correct the deficiency identified during flag state annual safety
inspections shall be sent to flag state within 30 days of the inspection date. Report shall be
sent by SMT in the format required by flag state.
Any failure of equipment that may affect safe navigation and further closure of the defect
shall be reported to the concerned flag state.
Occurrences of occupational accidents, injuries and diseases on board ships shall be
reported promptly. Additional reporting shall be done if the accident, injury, or disease
renders the crew unfit for work for more than 3 consecutive days or hospitalized for at

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least 24 hours.

9.2.3 URGENT NOTIFICATION TO THE FLEET


Head of CMS team shall ensure that the fleet is rapidly notified of the following through
bulletins:
Urgent safety related information
Urgent Security related information
The Company must make arrangements to receive and review security related information
and disseminate appropriate data to vessels and other parties. Up-to-date security
information relating to a trading area should be passed to the vessel in good time prior to
her entering or transiting the area. Security information may be obtained by the Company
using the following sources:
International and national agencies
Military authorities
Local agent
Specialist consultants
Industry bodies
Any violation of regulations
Any major incident
Any near miss of high potential.
Other important information on safe / unsafe practices, near misses from the fleet as well
as from the industry and information on new regulations will be notified to the fleet
through quarterly brochures.

9.3 INCIDENT REPORTING & INVESTIGATION PROCEDURE


9.3.1 PURPOSE
The purpose of this procedure is to ensure that a formalized system exists for reporting of
the incidents (includes near misses), investigation of incidents, for carrying out an analysis
of the incidents, for implementing corrective actions and for sharing the lessons learnt
from the incident / near miss with all concerned by sending broadcasts.
Incident investigation has the primary purpose of preventing further incidents by
identifying the causes and lessons learnt to allow safeguards to be put in place to prevent
recurrence.

9.3.2 SCOPE
This procedure applies to
Any casualty, accident or serious incident involving a vessel managed by Synergy.
All incidents involving any person on articles of agreement on Synergy managed vessel
whether on-board, ashore or accessing the vessel
Incident involving any contractor including shipyard workers, visitor, or Office personnel
while on board or accessing the vessel.
Near Miss reporting is an integral part of an incident reporting system. Not all near misses
will require full investigation and thus a system for capturing these unsafe acts and

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conditions should be available.

9.3.3 RESPONSIBILITY
The Master is responsible for the timely reporting of all incidents and near misses to the
office and for the on-board investigation of the incident.
Master shall also submit a root cause analysis for the incident or near miss report as
applicable.
The respective Marine Manager or his designate shall analyse the severity and nature of
the incident reported by the vessel and reviews the corrective measures arising out of the
incident. He shall review the root cause and the corrective action plan submitted by master
and update/amend same if required. The incident/near miss shall only be closed out after
master’s final confirmation of the implementation of corrective action plan. He shall
determine if immediate information needs to be sent to the fleet.
Marine Superintendent will be responsible for collection of information and preparation of
the incident report bulletin.
If evidence shows that the incident has either occurred due to or resulted in a breach of
regulatory requirements, the DPA is required to report it to the appropriate authorities.
The respective Marine Manager or his designate is responsible for monitoring the effective
disposition of the non-conformance as a consequence of the incident or near miss.

9.3.4 DEFINITIONS
Please see the Acronyms / Abbreviations and Definitions listed in the starting of the
manual.

9.3.5 FORMS FOR REPORTING


All incidents shall be reported to the office in the appropriate manner. The report shall be
completed and sent thru the ship palm or using the prescribed format if ship palm is not
available.
Near Miss report – shall be used for reporting Near misses
Accident / Damage report - shall be used for reporting accidents on-board.
Injury report - shall be used for reporting injuries

9.3.6 CLASSIFICATION OF INCIDENTS


In deciding the category of an incident, the “Potential” as well as the “Actual”
consequence must be taken into account. Personal injury should be the first consequence to
be evaluated and this will take precedence over the other types of loss or damage.
In order to be able to address each incident with the correct level and speed of response the
decision on the category must be made within 24 hours of the incident.
The following table details the consequences and categories against which the potential of
an incident should be measured are defined. (Also refer Consequence table on Chapter 08,
Risk Assessment for understanding of category)

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Incident Personal Property Damage Environmental Release Near Miss


Category Injury

Catastrophic Fatality, PTD, Loss of vessel or Major Spill >=10 Bbls into sea or
(Extremely total loss uncontrolled gas release >10
Harmful) amounting over tonnes or volumetric equivalent
1,000,000 USD

Critical (Severe Ill health Major damage, Oil spill into sea < 10 barrel Oil spill Catastrophic
Harm) leading to Yard repair contained on deck > 10bbls Potential – Near
permanent required. Regional environmental impact, Miss
disability, (Damages loss likely to receive citation / fine and
PPD, amounting to could jeopardize the reputation of
500,000 USD the company
and over but less
than 1,000,000
USD)

Marginal LWC, RWC, Vessel disabled or Oil spill contained on deck Critical Potential
(Moderate MTC, expenses > 1barrel < 10 barrel – Near Miss
Harm) amounting to USD
10,000 but
less than USD
500,000.
Minor First Aid Case Minor Damage, Oil Spill contained on deck Marginal
Repairable on < 1 Bbl. or Potential – Near
board Any failure of primary Miss
containment (contained spill on
board in various area of
operation).
Environmental impact not
existent.
As per the area of concern, incidents may be further categorized as below.

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Environmental Fire Injurie s Naviga Mooring FAILURE Technical Cargo Cargo System Critical safety Critical Structural FAILURE
incidents tion Incidents handling FAILURE equipment FAILURE Navigation
inciden t incident (critical system equipment
includes FAILURE
following)
Oil spill Overboard Fire of any All sort of Navigat Mooring line failure Loss of Cargo Cargo tank Quick closing valves BNWAS Failure of Hull,
magnitud e injury ion - Power contamina level gauging plating, framings and
Allision tion system supports

Chemical spill Mediva c Navigat Anchor & equipment Hose handling Bilge Alarm Radars Failure of hull fittings
overboard ion - damage or crane (Including piping,)
Collisio fouling
n
Breach of Primary Mooring machinery Cargo Crane Emergency GeneratorECDIS Failure of
containment - Cargo damage that has superstructures
immediate impact on
safety of
vessel

Breach of Primary Cargo pumps Emergency battery SSAS


containment -
Bunker
Breach of Primary Inert gas plant Oil mist detectors Steering
containment - failure
Hydraulic Oil

The incident categories are available in the company’s incident reporting software (Shippalm). Incidents classified in above table shall be reported
in “Incident -accident & damage/injury” category in Shippalm.
Correct Category must be selected when reporting.

9.3.7

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9.3.8 INITIAL REPORTING


The initial response to an accident or near miss should be made by the appropriate means
depending upon the category of the incident. In all cases, an initial notification by email or
phone should be made to the Superintendent.
This should be done as soon as practicable after the occurrence of the incident or near miss
and should contain as much information as is available through a preliminary
investigation, with the added comment that a report will follow after carrying out a
thorough investigation.
For initial reporting of defects related to hull, machinery and equipment, defect report
must be raised in the ship palm. Where shippalm is not available HMX reports must be
raised. For HMX reports of category Substantial and Intolerable, in addition damage
reports would have to be raised in consultation with Technical Superintendent.
At any case, the Master shall complete and send appropriate Incident Report to office in no
later than72 hours after the incident. If the Master is unable to complete the incident report
within the time limit, he shall request extension from the respective Marine Manager.
The Marine Manager or DPA shall assess the incident for the need of statutory or legal
requirements to the authorities. He shall provide necessary direction and guidelines to the
superintendent and / or vessel for reporting the incident to the appropriate authorities
within the required deadline.

9.3.9 INCIDENT INVESTIGATION TRAINING AND TEAM


9.3.9.1 Investigation Training for Office Staff
Investigation shall always be headed only by suitably qualified investigator.
At office, as far as possible, the staff that form part of the investigation team shall be duly
trained in Incident Investigation methodology. At least one senior staff should be trained
by the External agency who developed the incident investigation model or by a suitable
Classification Society. He in turn, may, train the other superintendents and the vessel staff.
Trained superintendents should be given opportunity to participate in the investigation if
relevant to the skill before expected to lead an investigation.
The Incident Investigation training shall be refreshed at a period not more than 5 years.
9.3.9.2 Investigation Training for Ship Staff
Training shall be provided to the senior officers on-board on incident investigation
methods.
This may be done in shore-based seminars, specific training by office or on-board training
session.
Pre joining briefing may also be effectively utilized to carry out incident investigation
course for seafarers
Company shall ensure that at any time, at least two seafarers on-board should have been
trained in Incident Investigation.
Refresher course for Incident investigation shall be provided for the team at a period not
more than 5 years.
9.3.9.3 Incident Investigation Team Office and Shore:
Incident investigation team on-board shall consist of Master, Chief Officer (Safety
Officer), Chief Engineer and Second Engineer. Master shall lead the on-board

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investigation team and if the Master is directly connected with the incident, the Chief
Engineer or Safety Officer shall lead the team.
Marine Manager shall head the investigation team ashore, except for minor category.
Constitution of the office team for the category shall be as follows.
 “Catastrophic” – Head of Ship Management Team, Head of CMS, Head of
Technical Team, Marine Manager, DPA & All superintendents as required.
External consultants / experts and representations from owners as required.
 “Critical”- Head of CMS &Head of Technical Team, Marine Manager, DPA and
one Superintendent.
 “Marginal” – Marine Manager, DPA, One Marine Superintendent and one
Technical superintendent.
 Minor – Marine Superintendent and / or Technical Superintendent.
Marine Manager/DPA in consultation with head of CMS shall assign the lead investigator
and ensure that the person leading the investigation is not connected with the incident.
The senior most team member in investigation team or Head of Ship Management as
constituted by the above categorization will be the one who approves the investigation
report.

9.3.10 STAGES OF INCIDENT INVESTIGATION


The first stage in investigation involves establishing factual information. This requires
recording and observation of all activities at the time and scene of the incident.
Once the incident is under control, the Master and on-board investigation team shall carry
out a methodical investigation of the incident to determine the causes and the appropriate
corrective measures to prevent recurrence.
The investigation will require the observation and collection of all relevant information,
which may include but is not limited to:
 Photographs
 Sketches
 Statements from persons involved in the incident and any witnesses
 Operational records
 Logbooks
 Checklists
 Permits
 Maintenance records
 Test records
 Certificates
 Data printouts
 Record of rest hours
 Saved Data Records (e.g. VDR, ECDIS Back up)
 D&A Tests

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 CCTV
 Evidence from VTS
The second stage is to analyse the facts and make a judgment on the direct, indirect and
root causes.
Incident investigation process shall primarily follow Loss causation model (identifying
direct causes, indirect causes, and root causes) with the help of events and Conditional
factor charting or events and causal factor charting, human factor analysis and barrier
analysis. Taproot model may alternatively be used in cases that indicate long pre- existing
conditions with a potential to evolve as a causal factor.
However, depending on incident the head of investigation team in consultation with the
Head of CMS shall decide on the various tools to be adopted as relevant to the incident
and investigation process.
The gathered evidence and the facts of the incident should lead to the determination of
direct, indirect and root causes and thereafter, to the derivation of corrective measures to
prevent recurrence.
If necessary, an Event and Causal Charting should be done to depict the events in logical
sequence and to analyse the event by identifying various unsafe conditions and unsafe acts
that existed / contributed to the event.
The identification of causes follows a process of asking a series of "why did it happen"
questions.
The first ‘why’ or on occasion, 'how' question will provide the direct cause(s). The direct
causes may be an “unsafe act” or a normal act carried out an “unsafe condition” or the
combination of both.
The second 'why' question seeks to understand why the direct cause(s) happened. The
answers will provide the indirect cause(s). Usually these are the job and personal factors
that exist.
In the final stage, questioning why the indirect cause(s) occurred will lead to the root
cause(s), which are always non-compliances with procedures / rules / regulations / industry
best practice / proper design standards or at times, lack of a procedure / regulation /
knowledge / training etc.
A near miss of serious nature will be managed similar to an accident in the identification
of causes and corrective measures.
The third stage is to recommend actions to ensure, as far as possible, that the incident will
not or is less likely to happen again. Each of the identified root causes should now be used
to develop an appropriate corrective measure that will address the lapse and prevent its
recurrence.
All incidents involving the ship / shore interface shall, whenever possible be investigated
by both parties involved. Whenever this is considered impracticable, the minimum action
required subject to the draft copy of completed investigation report shall be made available
to the other party.

9.3.11 INCIDENT INVESTIGATION REPORT


The investigation report should be completed as soon as possible with all the facts and
relevant information. Statements from participants and witnesses should be used to
establish the facts. Drug & Alcohol testing for the personnel involved is to be done within
2 hours of the incident.

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Every possible effort shall be taken to ensure the report is full of facts as this report assists
to identify the root causes and thereby efficient corrective action. Ops and Tech team will
review the report sent by the Master and the investigation team. The time duration allowed
for the completion of the investigation shall be reviewed until all issues are addressed and
resolved. The final report is completed as soon as practicable. However, the report shall be
completed within 90 days from the date of the accident unless a different time scale has
been decided by the investigation team. The Incident Investigation report should include
the time scale & the person responsible for closing out the proposed Corrective/Preventive
Action.
The investigation report is to state the following at the bottom of the report:
Report should not be written with litigation in mind and, shall be inadmissible in any
judicial proceedings whose purpose, or one of whose purposes is to attribute or apportion
liability or blame.
Master will be responsible for implementing the corrective action on-board. The DPA
shall approve all extension.

9.3.12 REVIEW
The report sent by the vessel shall be reviewed by the office investigation team to confirm
that the incident has been adequately investigated, analysed, categorized and sound
recommendations made. The office team shall ensure that the investigation has fully
explored the possible causes and identified appropriate actions to prevent recurrence. The
office analysis of the incident report shall be recorded in the “Analysis of the incident
reporting by office”.
It is important that suggested corrective action, should be such that, it does not generate a
new hazard in the system. Hence, if necessary, a risk assessment shall be carried out prior
implementing the suggested corrective action.
The findings and the conclusions from the investigation shall be circulated to the fleet and
appropriate shore personals. Masters shall discuss the bulletins with all crew so that similar
incidents are prevented.
Where appropriate, Head of Ship Management Team shall share the investigation results
and the lessons learnt with other authorities such as class, oil major vetting departments,
charterers, industry groups, equipment manufacturers, and various customers to avoid
similar incidents on other vessels.

9.3.13 ACTION PLAN AND FOLLOW UP


The Ops & Tech team is responsible for ensuring the corrective actions are documented,
tracked, and closed out. Incident report shall be uploaded in to Shippalm along with PIC
and target dates for closeouts assigned and closeouts verified.
The findings and the conclusions from the investigation shall be circulated to the fleet and
appropriate shore personals.
Master’s shall discuss the bulletins with all crew so that similar incidents are prevented.

9.3.14 TREND ANALYSIS


The incidents shall be reviewed in the management review to identify the suitable action
plan shall be derived to avoid / minimize the losses in future.
While conducting risk evaluation in relation to management of occupational safety and
health shall refer to appropriate statistical information from the ships and from general

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statistics provided by the Flag state.


Trend analysis must also be carried out for defective navigation equipment.

9.3.15 NEAR MISS:


While the Near Miss reporting is an integral part of Incident reporting system, not all near
misses will require full investigation.
The near misses which have high potential for learning or for loss control shall be
investigated. The near misses which record just the unsafe acts or conditions need not be
investigated but they shall be captured in the system for trend analysis. Marine Manager
will decide whether a full investigation is necessary or not.
Near Miss report may e completed anonymously by the vessel.
Near miss reports shall be reviewed for the presence of potential danger and the lessons to
learn.
The review of Incident analysis shall be sent to the vessels as lesson learnt.

9.3.16 UNSAFE ACTS / UNSAFE CONDITIONS (LARP REPORTING)


LARP Card system is used for reporting all unsafe acts and unsafe conditions observed on
board. Refer to HSM Ch. 01 for more details.

9.3.17 NON-CONFORMITY
Nonconformity occurs whenever
The documented safety management system fails to provide the necessary control to
prevent the occurrence of an adverse incident
The documented safety management system is not implemented., i.e. actual practice does
not conform to the documented system
The safety management system fails to address a situation that result in an adverse event
A situation is identified that represents a potential hazard.
A series of related deficiencies identified by company personnel or external organisation.
REPORTING OF NON-CONFORMITIES
Non conformities are reported to the office with a view towards improving Occupational
Health, safety, and protection of environment.
A non-conformity may be reported or deemed to have received through the following:
 Internal audit report
 External audit report
 Condition of Class
 Master’s review of SMS
 Deficiencies noted during PSC / FSC / SIRE inspections
 Minutes of safety meeting
 Defects noted in vessels inspection report
 Minutes of management meeting

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 Document change requests


 Incident reports (Near Miss, Damages & Injuries)
 Maintenance reports
Form, Letter, or e-mail addressing the non-conformance
Master shall raise a Non-conformity using the Non-conformity report form SF-02.
Subsequently a defect report shall be raised in the ship-palm relating to the Non-
conformity and followed up as required.

9.3.18 ANALYSIS OF NON-CONFORMITIES


Every Non-conformance that has been identified (as reported various sources, refer 9.4.1)
shall be analysed by the vessel to identify the immediate cause, root cause and corrective
actions. The description of the non-conformity along with cause analysis and corrective
action plan shall be forwarded to the office using Corrective Action Report. For non-
conformities raised through internal audits shall be recorded and followed up through Non-
Conformity Report, instead of Corrective Action Report
The superintendent of the vessel shall, in conjunction with the other divisions, review the
cause analysis and corrective / preventive action plan prepared by the vessel and approve
or amend the plan as required, in agreement with master. He shall in liaison with the
Marine Manager, analyse and propose the long-term preventive measure to avoid re-
occurrence of similar Non conformity.
Where appropriate, risk assessment is carried out for implementation of corrective / long
term preventive measures to ensure that no new hazards are generated in the process of
implementation.
The closure of the non-conformity is reported to the office. Office shall verify the
corrective action and close the non-conformity report. Evidence of the corrective action is
documented along with the non-conformity report.
The effectiveness of the corrective / preventive action shall be monitored by the Master
and verified by the superintendent or auditor during the next visit to the vessel.
Long term preventive measures are implemented through the most appropriate method.
The Long-term preventive measures may include changes to strategy, Polices, update
PMS, bring in Changes to Manuals, or provide new procedures as necessary.
Record the same as necessary for continual improvement
In the event the vessel requires more time to implement the corrective action, the reason
for extension is reported to the respective superintendent. An approval from the DPA/
Marine Manager is required to extend the due date.
The company shall review all the non-conformities during the management review to
identify the trends and learning points. The review of Non conformities shall form an input
for the management review
9.3.18.1 Major Non-Conformities:
If Major Non conformities are identified during internal or External Audits, they are
significant events and require immediate corrective actions to be implemented. If
identified on board, unless mitigated immediately by on-the- spot corrective actions, a
major non-conformity can result in a vessel’s Safety Management Certificate becoming
invalid in the short term.
It is essential to work closely with and be guided by the auditor to develop an action plan

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with immediate and effective corrective actions that will satisfy the auditor and enable the
major non-conformity to be downgraded to non-conformity.
Note: A major non-conformity raised on a ship must be downgraded to non- conformity
before the ship is allowed to sail.
9.3.18.2 Failure of or Non-operational Critical Equipment:
If the failure of any Critical equipment is observed during any Audit/Inspection, the
corrective action has to be immediately initiated and company informed accordingly in
accordance with Section
of Technical manual. All practical efforts have to be initiated to get the critical equipment
repaired/rectified prior to vessels departure from port, Failing which, a detailed Risk
assessment should be submitted to office, all due notifications to company/class/Flag state,
as applicable, to be carried out and waivers obtained to sail out .

9.3.19 CORRECTIVE ACTION PROCESS


 Origin – Need for corrective action identified by Non conformities / Accident
Reports / Incident Reports / Audits / Inspections / Reviews / Others
 Entered / Communicated / Recorded
 Agree immediate actions with Responsible Persons
 Assign a responsible person and agree action time
 If major incident or near miss of high potential, communicate alert to other vessels
in the fleet.
 Discuss causes in consultation with all involved and derive appropriate corrective
action. The corrective action should include measures to prevent recurrences.
 Review corrective action through risk assessment process prior implementation
and suitable for the magnitude of the problems.
 Approve and Implement Corrective Action
 Analysis trends and learning points
 Provide to Management Review
 Communicate to the respective parties
 Plan for changes to strategy, Polices, update PMS, bring in Changes to Manuals,
or provide new procedures as necessary. Record the same as necessary for
continual improvement.

9.3.20 PREVENTIVE ACTION PROCEDURES


Preventive action is the action taken to eliminate the cause of a potential non- conformity
or other potentially undesirable situation.
The company shall undertake proactive measures to identify all potential non-
conformities that can affect the Integrated Management System.
Determination of potential non-conformity
A potential non-conformity can be determined by:
 Performance Monitoring of the vessel

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 Vessel Inspection
 Internal Audits
 Adhering to change management procedures
All identified potential non-conformities shall be evaluated for action required to prevent
their occurrence. Any such action shall be reviewed through risk assessment process prior
to implementation as deemed necessary.
The proposed preventive action shall be appropriate to the magnitude of the potential non-
conformity.
The technical superintendent of the vessel and the Master on-board shall be responsible for
implementing the confirmed
These preventive actions shall be recorded and reviewed in the management review.

9.3.21 REFERENCES
 H&S Manual
 Contingency Manual
 Marine injury reports
 guidelines by OCIMF SMM Ch. 19
 Company bulletin
 Technical Manual

9.3.22 RECORDS
 Index of Forms – AD-00
 Mailing List – AD-01
 Near miss report –SF-04
 Damage report – SF-05
 Injury report - SF-06
 Analysis of the incident reporting by office OF-MA-021
 HMX Report Form TE-20
 Third party damage report – OP-03
 Non-Conformity Report Form - SF-02
 Corrective action report Form- SF-2A

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10 PLANNED MAINTENANCE
Planned Maintenance System is to be followed on board to ensure that the vessel is
maintained in compliance with Flag, Classification Society, and any additional
requirements to ensure continued safe and pollution free operation.

10.1 RESPONSIBILITY
Designated on-board departmental heads are responsible for ensuring that scheduled
maintenance and repairs are carried out according to the planned maintenance programme
provided to the vessel. Procedures for implementing vessel and equipment-planned
maintenance are documented in the Technical Manual.

10.2 ROUTINE INSPECTIONS


Routine inspections are scheduled in the planned maintenance programme. These
schedules are to be followed and any deviation is to be brought to the attention of the
technical superintendent.

10.3 CRITICAL EQUIPMENT & SYSTEMS


The Master and Chief Engineer shall identify critical equipment and technical systems, the
sudden operational failure of which may result in a hazardous situation (critical
equipment). The Fleet Manager must approve the above Critical Equipment and Systems
list. Specific measures shall be taken to promote the reliability of such equipment and
technical systems by including them into a programme of planned maintenance and, where
appropriate, regular operational testing of standby arrangements.
“Critical Equipment” will be highlighted in the planned maintenance system to
ensure regular check, test, and inspection.

10.4 BREAKDOWN OF VESSEL’S EQUIPMENT


Breakdown of the vessel’s critical equipment shall be reported immediately to the
Vessel’s Superintendent. Breakdown of equipment may result in changes to the vessel’s
preventive maintenance system in order to avoid recurrence.
In the event of the breakdown of an item of equipment or a system, the Master may, in
liaison with the Technical Superintendent amend the maintenance and inspection
requirements of the planned maintenance system pertaining to that equipment or system, in
order to prevent a recurrence of that breakdown.
Refer to the Technical Manual for more details.

10.5 RECORDS
Planned maintenance and repairs carried out on the vessel’s equipment are
recorded in the planned maintenance programme.
Breakdowns of vessel’s equipment and associated repairs are recorded in the
planned maintenance records for reference and analytical purposes.

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11 DOCUMENT CONTROL
The hierarchical structure of the management system documentation and the manuals in
each level is described in Chapter 1 of this manual.

11.1 DOCUMENT MANAGEMENT


To ensure that all documentation relating to company’s Integrated Management
System is properly reviewed and controlled, the CMS team shall ensure that:
Documentation is reviewed for adequacy prior to issue.
Documentation is approved by the Head of CMS team prior to issue.
Documentation is reviewed, updated and re-approved as necessary in an orderly manner
Documentation is uniquely identified.
Initial issues and revisions to documentation are issued to assigned document holders.
Relevant versions of applicable documents are available at place of use.
Prevent the unintended use of obsolete documents, and to apply suitable identification
when they are retained for any purpose.
Issue controlled documents by a transmittal process that requires the recipient to
acknowledge upon receipt and updating of the relevant procedure or drawing.
The Integrated Management system documents are issued in controlled form to the persons
detailed in the approved distribution list. The distribution list will be maintained by the
CMS team.
It is the responsibility of respective controlled copy holder to ensure that
Obsolete documents are removed from points of use when replaced or deleted from the
system.
Up to date documentation is available at locations where it is required and used.
Revisions to documents are subject to the same approval and review procedure as the
original version. Review and approval of revised documents is performed by the same
persons or functions as the original document. Bulletins, Manager’s Instruction &
Circulars are reviewed once in a year and where applicable, contents of the circulars shall
be included in the affected procedures after which those Bulletins, Manager’s Instruction
& circulars will be withdrawn.

11.2 CHANGE MANAGEMENT OF COMPANY DOCUMENTATION


Changes to controlled documents shall be carried out through the Document Change
Request procedure as explained below:
 A request for a change is made either through mail to CMS team or filling the
relevant section in Monthly Review of Manuals & ISM/ISPS review. Master,
Chief Engineer, or Office Superintendents may raise a document change request
by mail. It is necessary to describe the change required and the reason why it is
required. The CMS team and the head of the related division in the office as
deemed necessary shall review the request. If the change is acceptable, it is
recorded in the company data base for further action. If the request is to be
rejected it has to be done with the approval from Head of CMS team,

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communication shall be sent to the person making the request with a reason for the
rejection. The reason for rejecting the request shall be entered in the data base.
 For any proposed policy changes affecting the seafarer, a risk assessment shall be
carried out by the CMS team. Consultation shall be carried out with the seafarers
attending pre-joining briefing, during Seminars, and their feedback to be
considered while developing the policy change.
If the request is accepted, the person making the request shall be notified. Amendments to
the document shall be carried out by the person who raised the document change request
or by a Superintendent in the relevant department. The documents will undergo the same
review procedure as the original document prior to making the required amendments to it.
The amended document will be reviewed by the CMS team and other interested parties
within the Company office to ensure compliance with applicable safety and quality
requirements, applicable codes, and regulations. For major changes in the operating
procedures, a risk assessment shall be carried out to confirm that the changes are in
compliance with the regulations and does not create a new hazard. Superintendent will
decide whether a risk assessment is necessary or not.
After the document is reviewed and approved by the Head of relevant team, it will be sent
to the Head of Ship Management Team for final approval. If the amended document is
approved by the Head of Ship Management Team, it will be handed over to the CMS team
for further process.
If the changes proposed and agreed require the entire manual to be rewritten, then the
edition number of the manual will be changed. If the changes proposed and agreed affects
some sections of the procedures, then the revision number of the procedures affected will
be changed.
Amendments to documents will be highlighted by red font and by including a vertical line
in the left margin adjacent to the amended text. The highlighting of the amended text will
remain until it is superseded by another amendment to the document.
If the entire manual is rewritten, then there is no need of highlighting the changes. CMS
team will provide the appropriate edition & revision number, format and print the new or
amended versions of the documents and take the signature from Head of Ship
Management Team. After obtaining the CMS Team’s signatures, controlled copies will be
sent to all recipients (vessels, manning offices) identified in the distribution list.
Whenever new or amended controlled documents are issued, they are accompanied by a
Controlled Document Transmittal Record (CDTR) that contains instructions on how the
document is to be included in the manuals.
On receipt of the controlled documents, the recipient shall update the affected documents
into the manuals and discard the superseded copies. Changes in procedures should be
highlighted to all employees. Acknowledgement of receipt and updating of documents
listed in the CDTR should be sent back by the recipient to the Company. Master shall be
guided with below process flow chart whenever new or amended controls documents are
received on board.

Table 1- process

Electronic documents and data shall be controlled to ensure only the most relevant issues
are used. They are updated from the Company office as required.

11.3 CHANGE MANAGEMENT OF THIRD-PARTY DOCUMENTATION


Amendments to third party documents such as Vessel’s plans, technical drawings and

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technical manuals originated by or approved by third party shall be carried out through the
Document Change Request procedure as explained below:A request for a change is made
by sending mail to CMS team. Master, Chief Engineer, or Superintendent may raise a
change request. It is necessary to describe the originator of the document (third party),
approving authority of the document (E.g.: Classification society), the change required and
the reason why it is required. The SMT Team and the head of the related division in the
office as deemed necessary shall review the request. If the change is acceptable, it is
recorded in the company data base by CMS team for further action. If the request is to be
rejected, after approval from Head of CMS, a mail shall be sent to the person making the
request with a reason for the rejection. The reason for rejecting the request shall be entered
in the data base.
Changes may also arise through a Management of change process that requires permanent
changes to documents such as the below but not limited to,
Certification.
Manuals.
Plans and drawings.
Operational procedures.
Records checklists and forms.
Planned maintenance including spare parts inventories.
If the request is accepted, the person making the request shall be notified. Amendments to
the document shall be carried out by the person who raised the document change request
or by a Superintendent in the relevant department. The amended document will be
reviewed by the CMS team and other interested parties within the office to ensure
compliance with applicable safety and quality requirements, applicable codes, and
regulations. For major changes in the third- party documents, a risk assessment shall be
carried out to confirm that the changes are in compliance with the regulations and does not
create a new hazard.
Superintendent will decide whether a risk assessment is necessary or not.
After the document is reviewed, it will be sent to the third party who approved it initially.
If the amended document is approved by the authority, it will be sent back to the vessel
and one copy retained in the office.
Whenever new or amended third party documents are issued, they are accompanied by a
Controlled Document Transmittal Record (CDTR). On receipt of the CDTR, the recipient
shall update the amended document, and discard the superseded copies. If feasible,
Changes in the documents should be highlighted to all employees affected by the changes.
Acknowledgement of receipt and updating of third party documents listed in the CDTR
should be sent back by the recipient to the Company.

11.4 RETENTION OF OBSOLETE MANUALS AND DOCUMENTS.


Copies of obsolete manuals and documents are to be identified and one copy retained as
records separately by the CMS team.
All other copies of obsolete documents are to be destroyed in order to preclude accidental
use. This applies both in office as well as onboard vessels.

11.5 RECORD CONTROL


Records are completed documents that contain objective evidence showing how well
activities are being performed or what kind of results are being achieved. They lend

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themselves to analysis for determination of methods to continually improve the


management system. Also, besides providing objective evidence, they also promote
accountability.
All QHSE records should be maintained for a minimum period in order to provide
evidence of conformity to requirements and the effective implementation of the QHSE
management system.
Records for office use and vessel use are identified in the Office forms and checklists file
and Vessel forms and checklists file. Records can be maintained either electronically or in
paper form. When the records are stored electronically, it should have a back-up system or
other suitable measures to prevent the loss of records.
Records shall be stored and protected in such a way that they could be retrieved suitably.
The records shall be destroyed by shredding or erasing electronically at the end of the
retention period. Copies of obsolete documents are to be destroyed in order to preclude
accidental use.
Index of forms in office and vessel shall mention the retention period of the documents.
All other system records are retained on board for the managed life of the ship unless
instructed otherwise by the office.

11.6

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11.7 RECORDS
Monthly Review of Manuals: SF-03 ISM review: SF-03A
Annual ISPS Review: ISPS-12
Common data base maintained in the office

Figure 2 - flow chart

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12 AUDITS
A planned schedule of internal and external audits is to be designed and maintained, to
verify the compliance of implemented safety and pollution prevention activities with the
documented requirements. The plan shall include both shipboard audits and office
departmental audits.

12.1 RESPONSIBILITY
The Head of CMS team is responsible for preparing the audit plan for vessels & office, for
assigning auditors to carry out the audits and for reviewing the final audit report.
The assigned auditors are responsible for conducting the audit of the vessels / office
divisions and for preparation of audit report.
The CMS team is responsible for scheduling, coordinating the audits and for maintaining
the records.
The responsibility for making a timely response to audit findings is that of the Master
/ Marine Superintendent / Technical Superintendent with support of other Office
departments as required.

12.2 PERIOD OF AUDITS


The schedule of internal shipboard and office audits and their frequency are dependent
upon:
impact on the safety and pollution prevention aspects of operations
The number of problems being experienced with each ship / office division
Results of previous audits
In all cases, the internal audit of ships and office shall be carried out at an interval not
exceeding 12 months. In exceptional cases, this interval may be exceeded by not more than
3 months (additionally for ships, flag state requirements should be adhered to).
Whenever such extensions are required for internal audit of ships, company will approve
them on case to case basis, after complying with company procedures and flag
requirements. An extension of internal audit can be granted under the following criteria,
but not be limited to;
If the vessel is on long voyage, where the passage of the vessel makes it difficult to
arrange the audit within the scheduled time frame;
If the auditor is unable to reach the ship due to unforeseen circumstances, and that an
alternate auditor could not be arranged within the remaining time frame to carry out the
audit; or
If the present port of call is such that it is not possible to arrange the audit, due to access
control measures, weather condition, civil unrest, or some such condition.
In case an extension is to be granted for Internal Audit, then, an interim audit has to be
carried out by Master and Ch Engineer complying with the company’s internal audit and
the report submitted to office. Same shall be cited as completed in order to grant an
extension.
Extension of internal audit and communication with flag if any needs to be filled in and to
be sent to the Master.

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External audits shall be carried out as per the frequency determined by the auditing
authority.

12.3 AUDIT PLAN


The Head of CMS team will make an internal audit plan for the vessels and office
divisions at the end of each year for the following year. The plan will be amended when
changes to the organization takes place or when new vessels are acquired or sold.
Whenever the audit plan is amended, the amended plan shall be circulated to the affected
vessels / office divisions.

12.4 AUDIT REPORT SUBMISSION


For all company and the vessel internal audits, the Auditor shall prepare and submit the
audit report as soon as practicable however always within 14 days of the audit to Head of
CMS team. Head of CMS team shall review the audit report, comment on the
categorization of the findings as NCs and observations and then shall forward the report to
the respective vessel and office division.

12.5 VESSEL INTERNAL AUDITS


A qualified auditor will be assigned to carry out vessel internal audits. He will usually be a
superintendent (technical/marine) from the office.
The master shall be informed of the audit plan at least 2 weeks in advance. During the
internal audit of the vessel, the following activities shall be carried out:
Opening meeting, in which the auditor and the head of department / Master shall:
Review and agree on the audit scope
Define tour & interview schedule (if applicable)
Identify interviewees, documents & processes to be audited As far as possible, all senior
officers shall attend the opening meeting.
Conduct of the audit
Audit will be carried out in accordance with the agreed audit scope
The vessel audit will also include a walk-about inspection of the vessel.
The auditor should not allow the audit process to disrupt critical workflow of the vessel. At
the same time, the Master shall endeavour to make the auditees available for the audit
without delay.
The auditor shall keep a record of personnel interviewed.
The auditor may also seek and keep copies of records for evidence.
The auditor shall verify implemented system through observation, interviews, and scrutiny
of the documentation.
Closing meeting
The auditor shall discuss the audit findings with the Master.
Review the findings and determine a schedule for disposition.
Discuss ideas for improvement and determine a schedule for implementation.
A preliminary report shall be given to the Master. However, if due to insufficient time the
report cannot be prepared, then the findings shall be discussed verbally and agreed.

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Auditor prepares and submits the audit report within 14 days of the audit to Head of CMS
team. (Through Shippalm reporting format) Head of CMS team reviews the audit report,
comments on the categorization of the findings as NCs and observations and then
circulates for comments amongst (through Shippalm):
The vessel’s technical and marine superintendents
Operations and Technical team
CMS team
DPA
The Head of Ship Management team
The final report shall be forwarded to the vessel and office divisions.
Report is maintained on board in the Shippalm software A printed copy to be maintained
on board for third party verification. Follow up verification of the corrective action is done
by the visiting superintendent and entered in the report.
For all Non-conformities, Corrective / preventive actions are initiated by the shipboard
management team and implemented, by responsible persons designated for the task, within
a set timescale, but up to a maximum of three months.
Observations indicate potential risks to the management system, but the vessel need not
respond to the office. These observations should be reviewed by the Master and
department heads and sent to the office for closure verification. Records shall be available
for this.
The shipboard management team shall forward to the office the corrective action plan of
the NC’s within 30 days of the completion of the audit. This can be sent by mail and does
not necessitate scanning and sending the NC form.
The shipboard management team shall follow up corrective actions and when such
corrective actions are seen to be effective, the Master shall inform the office and close out
the audit finding.
If the person responsible for the corrective action is shore based, the Master will close the
finding when he is satisfied that the corrective action is complete and effective.
The audit process shall be reviewed on a quarterly basis that shall include the qualification
of auditors, training need of auditors, number of audits carried out by each auditor,
compliance to audit plan, compliance to audit report completion time scale and the
unresolved non-conformances.
The above audit processes are mapped to Shippalm Internal audit module. ( OPM 3.2.6)

12.6 VESSEL NAVIGATIONAL AUDITS


Marine Superintendent from the office or a suitably qualified person will conduct
navigational audits on-board the vessel at least once a year. This may be combined with
the internal audit.
Dynamic Navigation Audit are to be conducted for all vessels while on a passage by a
Marine Superintendent or a suitably qualified person.
Dynamic navigation audit should include navigation in Open sea/Coastal waters, Under
pilotage, during Berthing-unberthing and during anchoring.
It is carried out as part of the Internal Audit annually for tankers and bi-annually for other
vessels. However, if the same is not possible an additional Dynamic navigation audit will
be carried out within three months of the internal audit.

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Where a planned sailing Dynamic navigational audit has not been possible or where no
other option for conducting a sailing audit is immediately available, the Superintendent
utilizes VDR downloads to conduct an unannounced remote navigation audit, in order to
assess navigational practices on board. The process should be over a fixed time span and
involve a critical passage such as a Straits transit, port approach or pilotage situation.
After every change of command, the incoming Master shall carry out a navigational audit
as per the appropriate form sent by the company. Interval between two Navigation audits
by Master shall not exceed 3 months. Additional navigational audits may also be carried
out by the Master if advised by the company.

12.7 VESSEL MOORING AND CARGO AUDITS


At least 02 cargo and mooring audits shall be conducted in every 6 months period in tanker
fleet and every 12 months period in Dry vessels fleet. These audits may be carried out
during vessel’s internal audit or during vessel inspections by superintendents and shall
require witnessing of cargo and mooring operations.

12.8 VESSEL EXTERNAL AUDITS


The Certification Body in compliance with ISM Code requirements carries out external
audits. It is the responsibility of the Master to request the Vessels superintendent arrange
for vessel external audits. The Vessels superintendent shall arrange for external audits.
The original audit report is retained on the vessel and a copy is sent to the Vessels
superintendent.
Corrective and preventive actions are initiated by the shipboard management team and
implemented, by responsible persons, designated for the task, within a set timescale.
The shipboard management team follows up corrective actions and when such corrective
actions are seen to be effective the Master closes out the audit finding, or as required by
the audit body.
If the person responsible for the corrective action is shore based, the Master will close the
finding when he is satisfied that the corrective action is complete and effective.
When all the findings for an audit are closed then copies of the closed-out findings, duly
signed by the Master, will be passed to the Vessels superintendent who must submit them
to the Certification Body for approval. When the approval is given one approved copy is to
be retained by the SMT team and one copy is to be sent to the vessel and filed there.
These records will be examined by internal and external auditors and must be retained for
the whole period that the SMS is valid on the vessel.

12.9 INTERNAL AUDITS OF THE COMPANY OFFICE


Office internal audits shall be carried out at an interval not exceeding 12 months by a
qualified auditor who is as far as possible independent of the areas being audited.
This interval may at exceptional circumstances, be exceeded by not more than 3 months.
The Head of CMS team will plan the office audit schedule and will appoint an independent
auditor to carry out the audit.
CMS executive will notify the respective Division at least 2 days prior to carrying out the
audit. The auditor will prepare the scope / elements to be audited, in consultation with the
Head of CMS team for special areas requiring attention, and by reviewing past audit
results.
The results to be recorded on the Office Internal Audit report form.

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12.10 EXTERNAL AUDITS OF THE COMPANY OFFICE


Such audits are carried out by the Certification Body to a program that complies with ISM
Code requirements. It is the responsibility of the CMS team to request such audits in a
timely fashion.
Any findings resulting from any of the above types of audit will be analysed by the CMS
team and included in the Company review. A copy of the review will be forwarded to the
ships and retained in the office. If any trends become apparent through analysis of findings
the ships will be notified as soon as a trend becomes obvious.

12.11 REVIEW OF AUDIT RESULTS


The results of all internal / external audits of the vessels and the office, including all
identified non-conformities will be reported using the audit report forms as early as
possible. The results are provided to responsible persons in the area where the non-
conformity is discovered and to the Head of CMS team. Timely and appropriate corrective
action is taken in response to non-conformities, the maximum period being three months.
In cases where serious non-conformities are found, a follow up audit may be necessary.
This shall be at the discretion of the Head of CMS team & Head of Ship Management
team. The purpose of this follow up audit is to ensure that corrective action has been taken
and that it is effective. A record shall be made of the decision whether to have a follow up
audit.
Should a follow up audit be deemed necessary, the audit procedure explained in this
chapter will be repeated.
Master / office should maintain records to demonstrate that all actionable items have been
closed out as soon as is reasonably practicable.
Corrective actions taken are followed up, to be certain that they have been implemented
within the agreed timescale and that they have been effective. Audit results should drive
continuous improvement of the management system
Formal analysis of the audit results will be carried out by the CMS team and the findings
of the analysis will be included in the subsequent Management review. If any trends
become apparent through analysis of findings, the ships / the office division will be
notified as soon as a trend becomes obvious. A copy of the analysis report will be
forwarded to the ships and retained in the office.

12.12 VERIFICATION
Apart from the verification processes carried out by third parties, the Master and Senior
Officers designated by him will verify that vessel procedures are being followed by
examining and countersigning log books, checklists etc. from time to time.

12.13 VESSEL INSPECTION


Vessel inspection shall be conducted by a Superintendent (Technical).

12.14 FREQUENCY
Vessel inspections shall be conducted at least twice in a year. One inspection should be
made after sailing with the vessel.

12.15 CONDUCT
The inspection is aimed to ensure that the vessel is maintained and operated in a safe and

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efficient manner. The inspection shall be detailed and include:


Status of vessel certification
Implementation of Company Management System
Review of vessel documentation
Status of surveys
Condition of Hull, machinery, and equipment
Status of stores and spares supply and pending requisitions
Operational status of Critical equipment
Readiness of LSA, FFA and Pollution Prevention equipment
Crew Performance
Crew Motivation and morale
Vessel performance against the charter party requirements
Vessel consumptions
Standard of vessel cleanliness and hygiene
Follow up of last inspection report and effectiveness of the corrective actions taken

12.16 DEFICIENCIES
Any deficiency noted during the inspection shall be brought to the attention of the
concerned staff and a corrective action plan made. All VIR Reports to be signed off by the
vessel manager.

12.17 RECORD
The inspector shall produce a detailed report including photographs depicting the status
and deficiencies. On completion of inspection, the technical superintendent shall give
preliminary report (draft report) to the master and chief engineer. Defect list/Observations
lists to be discussed and corrective actions should be agreed. At this time the target dates
shall be assigned. The vessels shall receive VIR defect report in ShipPalm within 3 weeks
from the day of completion of inspection.
The report shall include the deficiencies noted and corrective action plan. The report shall
be circulated for comments amongst:
The shipboard management teams
The vessel’s technical superintendent
Ship Management Team (SMT)
CMS team
Admin & HR team
IT team
DPA
The Head of Ship Management team
The report shall be sent to the vessel, as early as possible, for further follow up actions.
The report shall be maintained by the SMT.
Timely and appropriate corrective action is taken by ship / office in response to

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deficiencies, the maximum period being three months. Deficiencies which require action
in dry dock must be separated and included in dry dock defect list.
Master / office should maintain records to demonstrate that all actionable items have been
closed out as soon as is reasonably practicable.
Corrective actions taken are followed up, to be certain that they have been implemented
within the agreed timescale and that they have been effective. Inspection results should
drive continuous improvement of the management system.

12.18 REVIEW OF INSPECTION RESULTS


Master / office should maintain records to demonstrate that all actionable items have been
closed out as soon as is reasonably practicable.
Corrective actions taken are followed up, to be certain that they have been implemented
within the agreed timescale and that they have been effective. Inspection results should
drive continuous improvement of the management system
Formal analysis of the inspection results will be carried out by the SMT / CMS team and
the findings of the analysis will be included in the subsequent Management review.
Analysis shall include comparison of data with third party inspections and comparisons
between vessels within the fleet with sister vessels. If any trends become apparent through
analysis of findings, the ships / the office department will be notified as soon as a trend
becomes obvious. A copy of the analysis report will be forwarded to the ships and retained
in the office.

12.19 AUDITS OF ASSOCIATE ENTITIES


The company (DOC holder) may delegate part of the work (for example, supply of ship
stores & spares, manning, etc.) to another entity, however the company remains
responsible for the operation of the ship(s), even if some of the tasks are delegated to other
entities or given back to the owner. In such cases the company shall provide clear
standards for delegating specific tasks and establish the levels of authority and lines of
communication between the departments, branches, and delegated entity. The company
shall monitor and carry out periodic verification of the delegated task to ensure compliance
with the relevant ISM Code requirements.

12.20 SENIOR MANAGEMENT VISITS


Senior Management from the office will visit the vessel for the purpose of for having a
visible and felt leadership as well as for sharing the following with our seafaring
colleagues;
Company’s commitment towards safety and environmental protection.
Company’s vision and Commitments.
Addressing high risk exposure as determined from incidents in the fleet and industry.
LFI and focus campaigns as shared by SHELL or other such entities from the industry.

These visits shall be planned, such as to include different type of vessels and owners.
During these visits effort must be made to interact with maximum number of sailing staff.
Information regarding the on-board visits and the details of topics covered should be
conveyed to the CMS team so that same can be recorded and conveyed to various third
parties as required.
These visits as a minimum should be as follows:

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At least one of the personnel from senior Management (Above Manager Level) shall visit
1 Vessel per Quarter.
At least one of the personnel from Manager Level shall visit 2 Vessels per quarter.

12.21 RECORDS
Vessel inspection reports
Audit reports
Audit Plan
Form OF-MA 027

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13 DOCUMENT OF COMPLIANCE (DOC)


The Company shall maintain a Document of Compliance (DOC) in accordance with
the requirements of the ISM Code. The DOC shall be held at the Company’s office.
A copy of the DOC shall be placed on-board the vessel to allow the Master to demonstrate,
to interested parties, that the Company is capable of complying with the requirements of
the Code.

13.1 VERIFICATION OF THE DOC


The Company recognizes its responsibility to request annual verification of the DOC by
the issuing authority. The Company recognizes that failure to request annual verification
or evidence of major non-conformities with the Code could result in the DOC being
withdrawn.
The Company also recognises that if the DOC is withdrawn then any associated Safety
Management Certificates would also be withdrawn.

13.2 SAFETY MANAGEMENT CERTIFICATE (SMC)


A Safety Management Certificate (SMC) shall be maintained aboard the vessel in
accordance with the requirements of the ISM Code. A copy of this certificate shall be held
at the Company’s office.

13.3 VERIFICATION OF THE SMC


The Company recognizes its responsibility to request timely verifications by the issuing
authority. The Company recognizes that failure to request such verifications or evidence of
major non-conformities with the Code could result in the SMC being withdrawn.

13.4 INTERIM DOC


The Company recognizes that when new ship types are to be added to the existing DOC
then an interim DOC should be issued as in paragraph 14.1 of the ISM Code. It is also
recognized that if the Company takes management of a ship with a flag that is new to the
Company then it will be necessary to have the DOC accredited by that flag.

13.5 INTERIM SMC


The Company recognizes that when new ships come into Company management or when
a ship changes flag, an interim SMC should be issued for each of such ships as in
paragraphs 14.2 & 14.4 of the ISM Code.
For an interim DOC to be granted the following conditions should be met:
An ISM compliant Safety Management System (SMS) should be documented and in place.
Key management personnel should be trained in the SMS procedures.
Personnel engaged in the management of the ships should be familiar with the procedures.
The Company should have established a Safety & Environmental Protection policy. The
policy should be authorised and signed by the Head of Ship Management team.
The policy should be displayed in the office.
There should be a person designated as the link between the ships and senior management,

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i.e. the Designated Person Ashore (DPA).


There should be a plan in place for the implementation and auditing of the SMS during the
six-month validity period of the interim DOC.
For an Interim SMC the following conditions should be met:
A valid copy of the Company DOC is to be available on-board.
ISM Code 3.1; Owner to Administration notification regarding responsibility for the
operation of the ship is valid and on-board.
Safety Management System manuals are on board.
The Master and Senior Officers should be familiar with the SMS.
The Master and Senior Officers should be aware of the planned arrangements for the
implementation of the SMS within the validity period of the interim SMC.
Instructions that have been identified as essential, prior to sailing, have been given, for e.g.
lifeboat stations, fire stations, emergency communications procedures, safety requirements
from the SOLAS training manual.
Plan for the internal audit of the SMS within 3 months is available on board.
Valid Class and Statutory certificates status.
A copy of the Certificate of Registry (or provisional certificate of registry) issued by the
Flag State authorities is to be on board.

13.6 VERIFICATION
Apart from the verification processes carried out by third parties, the Master and Senior
Officers designated by him will verify that vessel procedures are being followed by
examining and countersigning log books, checklists etc. from time to time.

13.7 SCHEDULE OF TRAINING AND AUDITING FOR THE SIX-


MONTH VALIDITY PERIOD

Figure 3- training schedules

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14 MANAGEMENT REVIEW
Management reviews of the Safety Management System are to be carried out both on-
board the ship and, in the office, at least twice a year. The objective of management review
shall be to evaluate the effectiveness of the system in attaining the objectives set in the
company policy.

14.1 MANAGEMENT REVIEW – OFFICE


Quarterly Reviews shall be conducted on Divisional basis that shall include review of
various processes within the division (e.g., Internal Audit, Vessel inspections,
Management of change and Incident Management, Defect Reporting, Surveys etc.) to
verify the effectiveness of the processes and to manage the resources. As far as possible all
superintendents in the division shall attend the meeting that will be coordinated by the
divisional head.
Company Management review shall be conducted once in Six months, i.e., beginning of
January and July of the calendar year.
Input of Management reviews in office shall include
Follow up actions from previous management reviews
Review of mission statements and high-level policies
Master’s management review reports (ISM & ISPS Reviews)
Internal audits,
External audits,
Condition of Class,
Vessel Inspection Reports,
Reports and trends of inspections by third parties including (PSC, FSC, Vetting, etc.)
Any reported non-conformities,
Fleet incidents and accidents, comparison between total numbers of LARP Cards, Near
Miss against number of “Lost Time Injuries” (LTI), Incident free days, best practises etc
Incident analysis and trends shall be done to provide an overview of where risk lies in the
company’s work activities
Incidents on-board pertaining to shipyard workers & other contractors which shall include
their exposure hours.
Pending items of vessel deficiency
Operational performance
Audit Plan Process
Incident Investigation process
Status of Corrective actions
New Regulations due and other proposed changes to the management system
Management of Change
Risk Assessments received and Suggested Changes to the Management system
Review of Key Performance Indicators and action plan to achieve the target

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Trend analysis of QHSE Incidents including Near Miss, Non-Conformances including the
ones from audits / inspections and Principals [Comparison between numbers of near
misses against the number of the lost time injured (LTI)] and of defective navigational
equipment.
Analysis of Letter of protests issued and received
Analysis of vessels KPI including needs for training for vessels not meeting the KPI. This
should also include a review of the training of such vessels based on gaps identified from
leading and lagging indicators.
Feedback received as described in Chapter 20 (Feedback)
Trend analysis of breakdowns in critical equipment.
Trend analysis of the irregularities in “lube oil analysis”
Fleet maintenance activity
Trend analysis of crew change activity with focus on timely relief of seafarers
Trend analysis of D&A violation cases across the fleet
Additionally, the following input shall be done on an annual basis (at the end of the year)
Review of Policies, Objectives and Targets under OHSAS and EMS
Performance of Personnel
Employee satisfaction survey
Training needs
Customer Complaints – Including complaints from Principals, Charterers and/or clients,
Visitors
Services provided by various vendors
Compliance with Division / Company Budgets
Resource needs especially office resource levels with respect to the number of vessels
managed.
Review of verification of entities undertaking delegated tasks such supplying stores,
spares, and manning, etc., to the company are acting in conformity as per company’s
procedures.
Monitor and review the requirements of the interested parties.
Changes to Significant Environment aspect and their impact.
Quality, health and safety related internal and external issues.
The output of the company management review shall include decisions and action related
to:
Improvement of the effectiveness of Integrated Management System and its processes
including the need for changes to its QHSE policy, objectives, and procedures. This shall
include measurements of the below but not limited to;
Near miss reports.
Behaviour-based safety system observations.
Incident free days.
Best practices identified.

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Hazards identified.
Unsafe acts identified.
Safety suggestions.
Improvement of services related to Principal’s requirement.
Resource needs especially office resource levels with respect to the number of vessels
managed
Include trends in defect of Navigation equipment.
Include trends in breakdown of critical equipment
Include trends in irregularities in lube oil analysis
Overview of fleet maintenance activity
Analysis of vessels KPI and targeted vessel trainings based on gaps identified from leading
and lagging indicators.
The related information from the output of management review shall be communicated to
all divisions, the vessels, and other concerned parties, as necessary.

14.1.1 AGENDA
An agenda of the meeting shall be circulated along with pertinent reports by the head of
the division at least one week in advance of the meeting.

14.1.2 PARTICIPANTS
The Head of Ship Management Team shall attend company review, DPA and heads of all
divisions.

14.1.3 RECORDS
Records of minutes of Company Management reviews shall be made and circulated to all
divisions and the fleet. The CMS team shall maintain records. The Management Review
Report shall be circulated to all vessels for the staff’s benefit by end of February and
August of the calendar year.

14.2 MASTER’S MANAGEMENT REVIEW


The Master shall carry out review of the implementation of management system on- board
with inputs from the shipboard management team twice a year, i.e., by end of June and
December of the calendar year. For a vessel newly taken over into the management, the
ISM review to be completed within three months of take over.
This requires the master to write a short review report
In practice, it is advisable for the Master and the on-board management team to read
through the entire chapter and review the system each month and assemble the report over
the length of a voyage. This will help to identify any errors that are static & untouched for
a considerable period of time for the review to be more effective, across the fleet; selected
sections of a particular manual are reviewed by all vessels and reported to company.
Following table shows the Schedule for Masters Review of company management system:

Month Chapter / Manual

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January SMM Ch. 1 to 10


February SMM Ch. 11 to 20 & annexes (1 to 3)
March HSM Ch. 1 to 6
April HSM Ch. 6 to 12
May HSM Ch. 13 to 17 and Annex (1 to 2)
June Navigation manual Ch. 1 to 5, Appendix (1 to 4),
Technical manual
Ch 1 to 3 Annex (1 to 3)
July Navigation manual Ch. 6 to 11, Appendix (5 to 8),
Technical
manual Ch 4 to 6 Annex (4, 5) appendix 1
August Cargo operations manual first half (Specific to vessel)
September Cargo operations manual second half (Specific to vessel)
October Contingency manual 1 to 3, EMS Ch. 1 to 7 Annex (1 &
3)
November Contingency manual rest of the chapters. Annex (1 to 5)
and ISMS
Manual
Forms and checklists, Circulars, and Manager’s
instructions,
December
SOPEP, Garbage Management Plan, Ballast Water
Management plan, MSMP and LMP

In addition to above schedule, Masters are free to review any other section as applicable.
Feed backs from monthly review shall be sent to office through monthly review of
manuals.
In every June and December review, the Master should go through feedbacks from
previous six months and voice his opinions on how the system has run and any positive or
negative aspects of operating the SMS. He should use the points listed below as general
headings. These items are a part of the Management Review Agenda.
Review the on-board management system for relevance and effectiveness.
Review any third-party audit / inspection reports and make any comments that are
appropriate.
Review safety meetings to assess their value to the SMS and, if appropriate, make
suggestions for improvement.
Comment on safety and vessel operations generally as influenced by the SMS.
Comment on defects and deficiencies and progress on corrective actions.
Comment on accidents and incidents.
Crew performance and motivation.
These items are part of the monthly safety meetings and review reports can be made up

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from the minutes of these meetings where the points are discussed. Refer to HSM for more
details.
A copy of the Master’s review is to be sent to the Office / Marine Superintendent.

14.2.1 RECORDS
Monthly Review of Manuals: SF-03 ISM review: SF-03A
Annual ISPS Review (Every December): Form ISPS 12

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15 HOURS OF WORK AND REST


It is the Company’s policy to conform to the requirements of STCW 2010, Statutory
Instruments, ILO Guidelines, MLC Convention, OPA 90 and any other pertinent
regulations concerning hours of work and rest for personnel aboard Company operated
vessels.

15.1 PURPOSE
To implement the Company’s policy on work and rest periods and to demonstrate
compliance with relevant rules and regulations.

15.2 SCOPE
All Company sea staff while sailing on-board a Company operated vessel.

15.3 PROCEDURE
A schedule to be posted of required hours of work, at sea and in port, for each rank and
position on-board every vessel. The number and pattern of working hours required shall
conform to the regulations listed above.
A record of actual hours worked, and rest periods taken shall be maintained for each
seafarer. Such records shall be maintained aboard ship for a period of one year.
Records to be sent electronically to the Company office and be retained for five years.
For vessels fitted with ISF watch keeper-Planning tool shall be used effectively to plan for
a forthcoming event. Substitutes to be identified in case any operation extends longer than
anticipated and likelihood of breach of Minimum Rest hours. Consider giving additional
rest one day prior to port call where hectic operations are expected.
Refer to HSM for more details regarding ways to mitigate fatigue on board and regarding
maintaining records for the hours of work and rest hours.

15.4 RECORDS
Work Hours and Rest Hours record SF-16
For vessels fitted with ISF watch keeper - The ISF electronic recording system.

15.5 RESPONSIBILITY
Each crewmember is responsible for maintaining their work/rest periods record.

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16 MANAGEMENT OF CHANGES

16.1 CHANGE MANAGEMENT POLICY


We believe “Change is continuous”. While many changes are envisaged and procedures
formulated in advance and presented in this management system manuals, some of the
changes can be unexpected. Company shall strive to mitigate the risks and guard against
unforeseen hazard that could arise from not managing the change correctly.

16.2 RESPONSIBILITY
The overall responsibility for managing the changes affecting various activities in office
and Vessels lie with the Head of Ship Management team.
The Head of CMS team is responsible for monitoring the changes affecting the office.
The Master is responsible for monitoring the changes affecting the vessel.
each employee of the company has the responsibility to become aware of the Management
of change process.

16.3 DEFINITION
Change:
Change means a temporary or permanent substitution, alteration, replacement (not in
kind), modification by addition or deletion of organization, personnel, critical equipment,
applicable codes, operating limits, procedures, emergency response equipment from the
present configuration whether they are planned or out of emergency.
Management of change:
Changes affecting the ships and offices can introduce new hazards, which if not identified
and managed in time, could result in incidents. A well-defined process for approving the
changes, prior to their implementation is called Management of change.

16.4 TYPE OF CHANGE


Change can be classified as Organizational change, Engineering change and Operational /
Document change.
The following activities come under the scope of Management of change (or change
management) process. The below list is given for guidance only and is not exhaustive.

16.4.1 Organizational changes:


Addition of New vessels in the fleet
Handing over vessels to other managers
New post created or eliminated in office
Opening of new branch office
Recruitment of new manning agent
Changes in office organization structure
Change of key personnel in office (Exchange of MR/DPA)
Riding crew in ships for major repairs

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Promotion of key personnel (Ex - C/O to Master)


Change in vessels trading area (e.g. First time port for Vessel/company, First US call for
vessel, Calling Alaska, First time voyage though particular areas like Northern sea route
etc.)

16.4.2 Engineering changes:


Installation of new equipment in ships (Ex -Installation of a new compressor)
Major Modification to existing ships or original design of equipment
Introducing new system or program (Ex – New PMS system),
Changes to software of a critical equipment (Ex – changes to approved loadicator
software)
Replacement of equipment / material - not of same kind
Use of different materials
Using a new instrument setting (e.g.: outside normal operating limits) for equipment
Changes and/or upgrades to software.

16.4.3 Operational / Document changes:


Operational change means any change to or from documented operating procedures and
principles as outlined in the company management system or Manufacturers
recommendation.
New procedure to be introduced
Changes to controlled documents
Changes to third party manuals
Changes from the operating procedures

16.4.4 Temporary changes:


This is the change process required for any changes that are not permanent in nature.
That means changes are initiated with intentions to restore back the system in its original
state after pre-defined time interval.
Examples for temporary changes include, but are not limited to:
Defects or failure of any equipment associated with Statutory Certificates for which
dispensation is required.
Items listed in SEQ Form E
Items listed in SRR Form R
IOPP Form A / B
Supplement to IAPP Certificate
Not meeting Safety Manning Certificate
Example: GMDSS Equipment defective, LSA Equipment Defective, FFA Equipment
Defective, SSAS malfunction, MLC/ Crew Accommodation, etc
Any temporary change in machinery or critical fixture
Vessel fell short of critical spares.

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Temporary change in routing


Vessel short of required navigation charts or ENC
Deviation from existing procedures
Visiting new Port
Temporary de-activation of security features for carrying out maintenance or operation.
Deviation from manufacturers recommendations

16.5 PROCESS (REFER TO THE FLOW CHART IN APP 1)


The process explained in this section is not applicable to changes that are adequately
covered by existing procedures such as:
Changes to company-controlled documents and third-party documents (Addressed in
SMM Ch. 11)
Change of Master & Chief Engineer (Addressed in this procedure section 16.6.1)
Change of Superintendents in office (Addressed in Office procedure manual)
Temporary operational changes from documented procedures (Addressed in this procedure
section 16.7)
Changes to alarm settings / Isolation of alarms (Addressed in this procedure section 16.8)

16.6 INITIATION:
All staff in ships or in office is responsible for identifying a need for change. Ship staff
shall inform either Master about the need for a change. Similarly, office staff shall inform
any Superintendent about the change identified. Whenever there is a change is identified,
the change initiator (Master / Marine & Tech Superintendent) shall fill up the relevant
section of the Change request form, including the reason & the source for the change
requirement; justification for the change and send to change coordinator for endorsement
(Organizational and Operational changes – to Marine Superintendent / Engineering
changes to Technical Supt) If there are any supporting documents that can also be attached
with the filled-up form.
The initiator shall provide sufficient details to enable the objectives of the proposal is fully
understood.
The filled-up Change Request form shall be submitted to Change Coordinator. One of the
Marine or Technical Superintendent will be the change coordinator. The Change Initiator
could also be Change Coordinator.

16.7 ENDORSEMENT
The Change Coordinator shall receive the Change request form and analyse the change
request based on the justification, other options, and budget requirements. If he considers
that the change proposed is likely to be implemented, then only he will endorse the change
proposal for further review. He will fill in the relevant sections of the Change request
form, informs the Master and will coordinate for registration of the change.
Any proposed change is approved at an appropriate level and not by the person directly
involved in the change. (Ref 16.5.5)

16.8 REGISTRATION AND TRACKING


The Change Administrator (designated CMS executive) receives the Change request form,

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registers the request in Change Register and issues a unique number for the change
proposed.
Once the change is registered and given number, the Change Administrator shall fill in the
relevant section of the Change request form and inform the Change Coordinator and the
Master. He will start collecting all the records associated with the change proposed like
risk assessment, meeting minutes etc., till the change is closed out. Even if the change
proposal is rejected or not progressed, details must be collected and documented as to why
the change proposal is rejected.
He / She will maintain the status of all change requests in the data base whether they are
open or closed. The records (like the signed change request forms or risk assessments) will
also be stored in the data base for each change requested.

16.9 ASSESSMENT OF IMPACTS


Change coordinator shall form a team for assessing the impact of the change proposed on
QHSE aspects. The team shall have at least the following members:
Tech Superintendent
Marine Superintendent - SMT
Marine Superintendent - CMS
Master / Ch. Eng. (for changes made in the ship)
The hazards identified should be eliminated or mitigated to bring down the consequences
to minimum acceptable level. The proposed change should be thoroughly assessed for
various points including the following:
Is it necessary at first point?
Is it feasible / cost beneficial?
Availability of resources
Impact on Quality issues
Impact on Safety issues
Impact on Health issues
Impact on Environmental issues
Impact on business
Impact on security issues
Impact on the organization
Impact on other activities and interfaces
How the consequences of the changes are eliminated, substituted, or mitigated?
Does it confirm to mandatory regulations?
Does it meet contractual obligations?
Does it require certification?
Does it meet original design?
Does it affect the goals and targets set by the company?
Does it involve service providers?
Training requirements

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Time frame for temporary change


Requirement for new procedures or modification to existing procedures
Modification to drawings, manuals
Modification required to emergency response process or equipment
Requirement for additional maintenance / spares
Effective risk reduction measures shall be identified for potential consequences of all
identified hazards. Basis the outcome of the assessments, the change shall be classified
based on risk, priority, and the cost estimate. Once the risk assessment is completed,
relevant section of the Change Request Form is filled in and sent to approving authority
along with the records of all risk assessments carried out and additional documents such as
sketches / drawings marked with proposed changes.
MOC Process to state clearly on identification of stake holders and methods of
communication to the stake holders. Ref TE 19

16.10 APPROVAL
The approving authority may:
approve the change plan
alter or send it back for revision, if he determines that certain aspects of the change
proposal are unacceptable or need more work
Reject it if the plan is not suitable.
If the change is approved under some conditions, then these conditions shall be clearly
described in the Change Request form. While approving temporary change, duration for
approval shall be highlighted. For permanent changes, proposed time scale for
implementation shall be highlighted.
After the change is approved, it may be implemented. Change coordinator shall send the
approved change request form along with other records such as risk assessments etc. to
change administrator for maintaining records.
Approving authority for changes are mentioned in the below table:
SL NO CHANGE CLASSIFICATION APPROVING AUTHORITY
VERY HIGH & HIGH BASED ON RISK ASSESSMENT Head of Ship Management
1 HIGH BASED ON COST (Above 100,000 USD) / Head of Technical / Head of
CMS
MEDIUM BASED ON RISK ASSESSMENT Marine Manager / CMS
2 MEDIUM BASED ON COST (50,000 ~ 100,000 USD) Manager / Technical
Manager
LOW & VERY LOW BASED ON RISK ASSESSMENT Marine Manager / CMS
3 LOW BASED ON COST (Below 50,000 USD) Manager / Technical
Manager

The approver’s review must ensure that:


Progress is monitored against time.
Objectives are being met and risks managed.
Any deviations are identified and addressed.

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Any identified improvements to the plan are recorded.


Temporary changes do not exceed the initial authorisation for scope or time
without review and re-approval by the appropriate level of management.

16.11 IMPLEMENTATION
Once the change proposal is approved, a step-by-step implementation plan shall be
developed to ensure that the implementation of change is carried out:
All identified hazards are mitigated or controlled by the identified risk reduction measures
With minimum interference to other routine activities
By maximizing the use of available resources
After the training is provided to relevant personnel
Complying with all relevant permit to work system
Within the planned time line
Change Coordinator is responsible forming a change implementation team and for
planning the implementation of the change in consultation with Master and other personnel
as required. Once the implementation plan is developed, it shall be circulated to all
concerned personnel including the Change Administrator for record keeping.
The implementation plan should describe how the change would be tested prior to
implementation, where it is possible. This will greatly reduce unwanted surprises and
delays.
The required material, equipment and contracted services shall be arranged as necessary.
All the implementation work should be in compliance with the Permit to Work system.
Regular updates on the progress of the change implementation should be reported to
office.
If the change cannot be implemented within the proposed time line, the change shall be
reviewed once again and revalidated.

16.12 COMMUNICATION
Successful change requires the engagement and participation of the people involved.
Communication before, during and after the change is one of the most important aspect of
the change management process.
The Change Coordinator has to ensure that all the end users of the changes are informed of
the change.
To achieve support of all personnel in a change management, proper communication shall
be established to ensure that:
Sufficient advance notice is given before implementing any change, especially if a
response is expected.
Affected staff knows to whom they should respond to, if they have comments or concerns.
The impacts, hazards associated with change and mitigation requirements are well
communicated across the organization
All employees are informed when the change is implemented

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16.13 DOCUMENTATION
The change should be fully incorporated into the management system. The procedures
affected by the change should be amended by following the required document change
procedure as explained in Ch. 11 of this manual.
The changes to designs should be reflected in drawings and copies of design changes shall
be made available to operating personnel as well as to maintenance personnel.
Documents that may be affected may be as below, but not limited to;
Certification.
Manuals.
Plans and drawings.
Operational procedures.
Records checklists and forms.
Planned maintenance including spare parts inventories.

16.14 COMPLETION REVIEW AND CLOSE OUT


After the implementation of the changes, a review should be carried out to verify whether
the change has produced the desired result.
A review of the change involving the appropriate personnel from the office or the ship
must take place upon completion of the change implementation to ensure the following:
That the scope of the approved Change Request has been implemented
All actions on the implementation plan have been completed
That affected documentation and databases are updated
Personnel of the affected area are informed of the changes
Where any discrepancies are identified, they shall be corrected or resubmitted into the
relevant Change Management process for review, approval and sign off.
If the review result is satisfactory, the change can be closed out.
Lessons learnt / Improvements after the completion of MOC shall be used to better similar
changes in the future.
Completion of temporary change:
Whenever Temporary MOC approaches its maximum specified duration, the MOC team
shall decide to progress the MOC using one of the following Temporary Assurance
Options:
Restore the temporary change to its previous state. Risk assessment of temporary MOC to
be revalidated to checkout for effective closure.
Extend the Temporary MOC – Any requirement to extend the duration of temporary
change will require a revalidation of the risk assessment and approval from DPA.
Convert the Temporary MOC to a Permanent Technical MOC – Requires a new risk
assessment and new MOC. Temporary MOC shall not be closed until the permanent MOC
has been approved.
Below flow chart explains the process for temporary changes:

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16.15 ASSIGNED STAFF FOR MANAGING CHANGE PROCESS

Designation Organizational Engineering changes


changes
V Office Vess Office
es el
se
l
Initiator M Marin Mast Tech Supt
as e Supt er
te
r
Coordinator Marine Supt Tech Supt
Administrator CMS Executive CMS Executive

Review Team M Marin Mast Fleet


leader as e er Manager
te
Mana
r
ger
Approving As per table in section 16.5.5
authority
Implementati Marine Supt Tech Supt
on
team leader
PROCEDURE FOR CHANGE OF PEOPLE
Whenever a new staff joins the office, he / she undergo a familiarization program. The
staff will be assigned to function under the care of a senior until sufficiently familiarized.

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In case of travel of a superintendent, other superintendent will take over the


responsibilities and will be briefed by the outgoing Superintendent.
When a staff leaves the office, the responsibilities handled will be transferred to the other
staff as assigned by the team Head until such time a replacement is announced.
For change of people on-board, procedures on induction briefing, briefing of a specific
vessel, handing over procedures is provided in H&S Manual and Fleet Personnel
Recruitment Manual.
For change of people in office, procedures on induction briefing, briefing of specific
division and handing over procedures is provided in Office procedure Manual and Fleet
Personnel Recruitment Manual.

16.16 HAND OVER (MASTER AND CHIEF ENGINEER)


When a Master hands over to his relief he must use the Master’s hand over record form as
the basis for his hand over notes. The form must be completed and hand over notes should
be written to include, as a minimum, the items mentioned in the hand over record form.
Where possible, this hand over notes shall be sent to the joining Master in advance by
mail. The incoming master shall carry out the Navigational audit as per the company
guidance.
When a Chief Engineer hands over to his relief he must use the Chief Engineers hand over
form as the basis for his hand over notes. The form must be completed and hand over notes
should be written. Where possible, this hand over notes shall be sent to the joining Chief
Engineer in advance by mail.

Masters and Chief Engineers, after joining a ship and taking over, should issue their own
set of standing orders, and have the pertinent officers sign them. After successful take
over, both Master and Chief Engineer should carry out a thorough inspection of their
respective departments, as per the takeover audit checklist, and forward the completed
report to the office within 14 days of takeover.
HAND OVER (OTHERS)
The Master must ensure that in advance of a crew change, all relevant hand-over notes
(including inventories) are prepared by each member of the shipboard management team
and other crewmembers as appropriate.
These notes should be concise while covering all key areas of activity. The members of the
shipboard management team are responsible for preparation. A copy should be retained on
board for the verification of the Superintendent (if required). The Chief Officer and the
2nd Engineer additionally complete the takeover audit checklist according to their
respective positions, and the report should be sent to office within 14 days of takeover.
The hand-over period for senior staff will be determined by the Technical Superintendent
in-charge of the concerned vessel.
HANDING OVER CALL
When the change of top four ranks on board is planned, the technical/marine
superintendent shall:
Obtain the handing over notes of outgoing officer one week before the planned sign off.
Go through the handing over notes and verify that outstanding defects on board are
mentioned and updated in ship-palm defect reporting module.
Conduct a telephonic ‘handing over call’ with the outgoing and the incoming officer as per

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the handing over notes and discuss the outstanding defects on board.
Outline the corrective action plan for defects with the incoming officer.
The call shall be recorded in the respective handing over form in ‘additional information
section’.
OPERATIONAL CHANGES FROM DOCUMENTED PROCEDURES
All operational changes from the documented procedures shall be of temporary nature with
a definite time limit.
Should it become necessary to deviate from the documented procedures, the Master or the
office staff involved in the process shall send the required deviation from the procedure
along with the justification for the change and risk assessment done showing the impacts
of the changes proposed to the Marine Manager. The Marine Manager will coordinate for
a HSE and technical review of the proposed deviation from the procedure by relevant
department personnel. Based on the review result, the Head of Ship Management will
approve the temporary change from operating procedure.
TEMPORARY CHANGES TO ALARM SETTINGS / DEACTIVATION OF ALARMS
Temporary changes in settings of any equipment from the maker’s or statutory
recommendations and temporary deactivation of any critical system safety alarms shall be
carried out in accordance with the procedure explained in this section.
Any permanent changes to alarm settings shall go through the process explained in section
16.5 of this procedure.
Critical and safety systems include but not limited to:
Fire Alarms, Fire Pumps & Emergency fire pumps, Fixed Fire Fighting Systems, Overfill
Prevention or Warning Systems, Thermal/Pressure Relief Valves, ME alarms, UMS
alarms, AE alarms
Critical systems / equipment is reflected in the vessel specific computer-based PMS.
Temporary changes on critical system safety alarms / controls must be controlled
and authorized using the form “Temporary changes to critical system safety alarms”
Prior to planned deactivation of alarms or changing any settings of any safety alarms
/ controllers, the Chief Engineer or Chief Officer shall complete the Form. Steps will
involve identifying the risk involved, the action planned to mitigate the risks and the
personnel who will be informed of the intended changes. Master will confirm the steps and
send the form to Technical Superintendent for approval.
Technical Superintendent will go through the request, discuss with the Fleet Manager if
necessary.
He will send a mail to the vessel approving the changes and duration of approval if the
changes planned are safe. Master will attach the email copy with the form and send it to
the Chief engineer or Chief Officer who will carry out the changes to settings or the
deactivation of alarms. Upon completion of the job planned or after the expiry of the
approval duration, the alarm system shall be reinstated to original position and the
technical superintendent shall be informed.
If the job is not completed, for any extension, the process has to be repeated.

16.17 TEMPORARY CHANGES


Temporary MOCs are not a recommended approach for changes that will be in place for
significant periods of time. Therefore, use of Temporary MOCs should be minimized and

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carefully managed to ensure restoring of system within time frame. Duration of temporary
MOC should be based on the expected time frame as well as any increase in risk.
The maximum life of a Temporary MOC shall be 60 days from the date of approval.
However, to evaluate the risk during change, risk assessments shall be validated every 15
days.
In addition, the management of change procedures for temporary changes shall ensure that
the equipment and procedures are returned to their original or designed conditions at the
end of the time limit for the temporary change. If any extension is required for a temporary
change, it should go through the complete management of change process again.

16.18 EMERGENCY CHANGE REQUESTS


All change requests which need to be implemented within 24 hours of raising change
request is classified as Emergency Change.
In some cases, events are critical enough that they must be rushed into effect thereby
creating an unscheduled change. During those events, where practical, the review should
include as much of the normal process as possible. An appropriate risk assessment shall be
conducted prior to proceeding with the approval process.
Master shall discuss with key office personnel as required and request to speed up the
approval process.
All emergency changes shall require the approval of the approving authority, acting on
advice and guidance from Ship Management Team and CMS personnel.
The complete change process, including validation of the risk assessment, shall then be
followed as soon as practicable.

16.19 Records:
Engineering and Organization Change Request Form: TE-19
“Temporary changes to critical system safety alarms” (Form No TE 28)
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17 CODE OF CONDUCT
The most effective form of discipline is self-discipline. This can be achieved by having a
responsible attitude to the job, concern for the efficient operation and safety of the vessel
and for the comfort and convenience of other crewmembers. Breaches of self-discipline
that occur have to be dealt with by setting a framework of discipline or Code of Conduct.
Orders must be given and obeyed if a ship is to operate safely and efficiently. Co-
operation will be gained if it is obvious to the crewmember that orders given are
reasonable. If orders appear unreasonable then the crewmember is entitled to request an
explanation. At the same time wilful or repeated refusal to comply with reasonable orders
or other anti-social behaviour must be expected to have certain consequences.
An important factor in gaining co-operation is good communication. This applies both to
communication between the Company and the vessel and to communications between
personnel on-board the ship. If all concerned with the running of the vessel are kept as
fully informed as possible about the Company’s policies and objectives and are made
aware of the importance of their own contribution to the voyage, co-operation and morale
will be much improved.
Disciplinary procedures are designed to emphasise and encourage improvement in an
individual’s conduct and performance as well as to ensure the safe and efficient operation
of the vessel.
Violations of any magnitude in compliance of policy will result in disciplinary action as
per the just culture and may result in dismissal from organization and/or legal action
against the convicted party.
DEALING WITH MISCONDUCT OR UNDER PERFORMANCE
A crewmember who is alleged to have committed an act of misconduct or deemed to be
under performing will be seen in the first instance by the Chief Officer or Chief Engineer
(as appropriate). If the head of department is satisfied that no further action is required, or
that an act of misconduct did occur, and call for no more than an informal warning, then he
should proceed accordingly. In the case of under- performance, it may be that additional
training will provide the most effective solution.
If the offence is of a more serious nature (see below) or is a repetition of similar minor
offences, then the case must be referred to the Master. In dealing with such an offence the
Master should observe the following general guidelines:
Cases referred to the Master should be handled with the minimum of delay.
A hearing should be convened by the Master and a thorough investigation carried out. This
will include, where necessary, the calling of any witnesses and the recording of their
statements.
The head of department should be present at a disciplinary hearing and the crewmember
has the right to be accompanied by a colleague who may advise him and speak on his
behalf.
After careful and thorough investigation and having considered all the evidence, the
Master shall verbally inform the crewmember whether he finds that he has committed the
offence(s) in question.
Depending on the findings of the Master he may dismiss the case, issue a Formal Warning,
or dismiss the crewmember from the ship.
Details of the offence(s) and the action taken shall be recorded in the Official Log.

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The crew member shall be given a copy of all entries made in the logbook relating to the
offence(s) for which he is subject to disciplinary action and should acknowledge receipt.
If the crew member declines to acknowledge receipt, then a subsequent entry shall be
made which must be witnessed by another senior officer and, if possible, by other seafarers
of the same nationality as the crew member being disciplined.
In the event the allegation of misconduct involves the Master, the DPA will conduct the
initial hearing and any subsequent appeals will be referred to the Head of Ship
Management.
Record shall be maintained in the vessel as well in the office.
Appeal Procedure:
The company recognizes the inalienable right of a Seafarer to appeal against a disciplinary
action imposed on him. The seafarer may exercise his right to appeal in the event of
following disciplinary actions-
Final warning
Dismissal from employment
Demotion
Deduction from wages to compensate for expenses incurred by company. Whenever a
disciplinary action is imposed, the Seafarer shall be informed of his right to appeal to a
higher authority in the company within 14 days. The higher authority may be the vessel’s
DPA or vessel’s superintendent or Fleet Personnel superintendent at the crew recruitment
office. The Seafarer shall inform of his decision to appeal preferably in writing, through
the master or directly to the person in the company.
The DPA or the Fleet Personnel Superintendent shall resolve the appeal with 14 days of
receipt of the appeal. If the seafarer has signed off from the vessel, he may be called to the
office for appeal resolution.
The seafarer may be accompanied by a fellow crew member from the vessel or a bona fide
member of the Crew union in which the seafarer is a member.
The outcome of the appeal and the reasons for the decision shall be informed to the
seafarer in writing within a time frame decided at the time of appeal resolution.
The seafarer has the right to escalate the dispute to senior management in Synergy if he is
not satisfied with the outcome of the appeal.
The Seafarer’s right to approach Flag state administration or appropriate authority in their
country of domicile remains indefeasible.

17.1 SERIOUS MISCONDUCT


The Company considers the following to be serious acts of misconduct to have been
committed, that may lead to dismissal from the ship if proved, to the reasonable
satisfaction of the Master:
Assault
Wilful damage to the ship or any property on board, or unauthorised disposal
of Ship’s property for personal gain.
Theft or possession of stolen property.
Unauthorised possession of weapons or explosives.
Persistent or wilful failure to perform duty.

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Conspiring with others at sea to impede the progress of the voyage or navigation of the
ship.
To be asleep on duty or failure to remain on duty if such conduct would prejudice the
safety of the ship or any person on board.
Unlawful possession, consumption, and/or distribution of drugs/Alcohol.
To be under the influence of alcohol or drugs whilst on duty, or off duty to the extent that
safety of the ship or any person on board is prejudiced.
While dealing with cases of serious misconduct, the relevant CBAs. Other related union
agreements and flag state requirements shall be duly consulted and complied.
Intimidation, coercion, and/or interference with the work of other employees.
Behaviour that seriously detracts from the safe and/or efficient working of the ship.
Misconduct of a sexual nature, or other misconduct based on sex, affecting the dignity of
women or men at work that is unwanted, unreasonable, and offensive to the recipient.
Causing or permitting unauthorised persons to be on board the ship whilst at sea.
Repeated acts of misconduct of a lesser degree after one or more warnings have been
issued.
Abetting or conniving with others to smuggle or mis-declaration of, or failure to declare
articles leading to seizure and/or fine to the vessel.
Desertion or assisting others to desert.
Being left behind by the vessel.
POLICY ON HARASSMENT AND BULLYING
PURPOSE:
The purpose of this policy is to ensure that all staff are treated and treat others with dignity
and respect, free from harassment and bullying. All staff should take the time to ensure
they understand what types of behaviour are unacceptable under this policy .
This policy covers harassment or bullying which occurs both in and out of the vessel, such
as on shore leave or at events on board for social functions. It covers harassment and
bullying by ship staff, office staff and also by third parties such as suppliers or visitors on
board vessels.
INTRODUCTION:
Harassment:
Harassment is a form of discrimination which has the purpose or effect of violating the
dignity of a person and of creating an intimidating, hostile, degrading, humiliating or
offensive environment.
The following may be found to be examples of harassment:
Displaying or circulating offensive or suggestive material;
Innuendo, mockery, lewd or sexist/racist/homophobic jokes or remarks;
Use of offensive language in describing or making fun of someone with a disability;
Comments about a person’s physical appearance or character which cause embarrassment
or distress;
Unwelcome attention such as spying, stalking, pestering, overly familiar behaviour or
unwelcome verbal or physical attention;

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Making or sending unwanted, sexually suggestive, hostile or personally intrusive


telephone calls, text messages, emails, comments on social networks, faxes or letters;
Unwarranted, intrusive or persistent questioning about a person’s age, marital status,
personal life, sexual interests or orientation, or similar questions about a person’s racial or
ethnic origin, including their culture or religion;
Unwelcome sexual advances or repeated requests for dates or threats;
Suggestions that sexual favors may further a person’s career, or that not offering
them may adversely affect their career;
Leering, rude gestures, touching, grabbing, patting or other unnecessary bodily contact
such as brushing up against others;
and Spreading malicious rumours, or insulting someone (particularly regarding age, race,
marriage, civil partnership, pregnancy and maternity, sex, disability, sexual orientation,
religion or belief, and gender reassignment).
Bullying:
Bullying is a form of harassment that includes hostile or vindictive behaviour, which can
cause the recipient to feel threatened or intimidated. It results in a work environment in
which a group of people or an individual may become threatened or intimidated because of
the negative or hostile behaviour of another group of people or individual. Bullying may
involve a misuse of power or position and is often persistent and unpredictable. It may be
vindictive, cruel or malicious. However, it can also arise when a person is unaware of the
effect that their behaviour is having on other persons or does not have any intention to
bully.
The following may be found to be examples of bullying:
Verbal or physical threats or abuse, such as shouting or swearing at colleagues, either in
public or in private, including derogatory or stereotyped statements or remarks;
Personal insults
Belittling or ridiculing a person, or his/her abilities, either in private or in front of others;
Sudden rages or displays of temper against an individual or group, often for
trivial reasons;
Subjecting someone to unnecessary excessive or oppressive supervision, monitoring
everything, they do or being excessively critical of minor things;
Persistent or unjustified criticism;
Making unreasonable demands of staff or colleagues;
Setting menial or demeaning tasks that are inappropriate to the job or taking away areas of
responsibility from an individual for no justifiable reason;
Ignoring or excluding an individual from social events, team meetings, discussions and
collective decisions or planning;
Making threats or inappropriate comments about career prospects, job security or
performance appraisal reports;
Spreading malicious rumours, or insulting someone (particularly regarding age, race,
marriage, civil partnership, pregnancy and maternity, sex, disability, sexual orientation,
religion or belief, and gender reassignment). Shunning people at work and rebuffing their
efforts to integrate with others if they are believed to ‘not fit in’;

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Cyber bullying including inappropriate:


Suggestive and unwanted remarks;
Graphics or threat-centred, abusive emails;
Postings on social networks; and
Text messages.
There are sometimes situations when excuses are made to, define or refer to behaviour or
situations between people at work which may involve ‘hidden’ bullying:
Strong or robust management styles;
A working relationship that is described as a ‘personality clash’;
Someone being described as ‘over-sensitive’ or ‘unable to take a joke’;
Describing someone as having an ‘attitude problem’;
A manager who ‘has a low tolerance for non-safety critical mistakes which are made
unintentionally;
Making fun of someone who has made a minor mistake at work.
POLICY:
Synergy is committed to providing a workplace that is free from harassment and bullying.
All Ship staff have a right to work in an environment free from harassment and bullying,
and to be treated with dignity and respect. Even unintentional harassment or bullying is
unacceptable. Synergy will treat all complaints of harassment and bullying seriously and in
strict confidence.
Synergy considers any complaint of cyber bullying to be a serious issue. Cyber bullying is
the use of modern communication technologies to harass, embarrass, humiliate, threaten,
or intimidate an individual to gain power and control over them. The use of the company’s
communication equipment for such purposes will be treated as a serious breach of the
company code of conduct and result in disciplinary action against perpetrators. All
managers and directors are responsible for actively intervening to prevent and stop any
bullying behavior that is occurring in their workplaces, whether or not a complaint is
received.
Synergy provides these procedures by which all staff can have any complaint of
harassment and bullying addressed.
All ship staff have a right to use the procedures in this policy if they believe they have
experienced harassment or bullying that can be dealt with under these procedures.
REPORTING:
Any ship staff who feels that he is being harassed, has the right to report the incident to his
superiors or to the office. It may be through informal process or formal process depending
on the situation.
All ship staff are encouraged to report any incidents related to harassment or bullying,
including those that affect others.
If you do not feel comfortable raising a complaint yourself, you may ask a friend or
colleague to do so on your behalf. You will not be penalized by the company for making a
complaint, provided it is not vexatious or made maliciously. Remember, it is the victim’s
perception of any actions that counts. If YOU feel you have suffered harassment or
bullying, the company will investigate the issue raised.

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Any reporting related harassment or bullying will be dealt with utmost confidentiality as
practicable. There won’t be any victimization against the complainant or alleged
perpetrator and the incident will be processed through fair investigation.
DESIGNATED CONTACT PERSON(DCP):
If a complaint cannot be resolved informally by the vessel staff or Vessel PIC’s ashore
then a Formal complaint for harassment and bullying to be sent to
complaint@synergyship.com.
Capt. Ramadass V. has been designated as the contact person in respect of this policy. If
any ship staff has any question or query about the operation of this policy or requires any
clarification about it, they may approach DCP for advice on the above-mentioned E-mail,
which will be given with strict confidentiality.
COMPLAINT PROCEDURES: Informal process:
If the ship staff believes they are being harassed, they should tell the person responsible
that they find their behaviour inappropriate and ask them to stop. Sometimes people are
not aware that their behaviour is unwelcome and causing distress If the harassment
continues.
Ship staff should normally raise a claim of harassment or bullying with their immediate
supervisor and attempt to resolve such claims locally and informally. Where the attempt to
informally resolve the matter fails or is not appropriate, staff should discuss the matter
with the Head of department or master.
If the complaint still withstands and remains unsolved then same to be discussed with the
vessel PIC (Superintendents) or the DPA.
The complainant may also approach the designated contact person for a discussion. An
informal discussion can often lead to greater understanding and an agreement for the
behaviour to cease.
Formal Process:
In case the matter is not solved on board same to be reported to the Designated contact
person through official complaint procedures as laid out in SMM CH 6.7.
Form AD-11 to be used to raise the complaint. For complaints related to harassment and
bullying the name and designation of the person alleged to be mentioned. A meeting will
be arranged where both the complainant and the alleged perpetrator may be accompanied
by another seafarer.
Following the formal complaint, an investigation will be initiated, and both the parties will
be given a fair chance to prove their point.
If the investigation shows that the alleged perpetrator is at fault, then the person will be
dealt with appropriate disciplinary action, which may include termination of employment.
Where the complaint is about someone other than an employee (such as a contractor,
supplier, or visitor), company will consider what action may be appropriate to protect the
complainant and anyone involved pending the outcome of the investigation. Where
appropriate, company will attempt to discuss the matter with the third party.
Confidentiality:
All complaints received pursuant to this policy will be considered confidential to the
extent possible. The identities of the complainant and the defendant and any witnesses will
be kept as confidential as possible, except where disclosure is necessary to aid in the
investigation, to take disciplinary action. The parties of the complaint are always also
expected to maintain confidentiality.

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A complaint of sexual harassment shall be investigated by an individual of the same


gender as the person raising the complaint.
Hearings, including any resulting disciplinary hearing, will be kept confidential. Company
shall provide with impartial advice to both parties and otherwise assist them in following
the complaints procedure.
Fair treatment shall be applicable to complainant and respondent. Both the parties will be
allowed to call for witnesses. A written record shall be maintained for all the discussions.
RESOLUTION OF CASE/ACTION
Upon resolution, if the complaint is upheld, the company shall ensure that appropriate
action is taken with regard to handling the perpetrator of the harassment and all necessary
support will be provided to the victim. The incident
may be shared with the seafarers’ organizations (such as ITF, Unions, and other crew
related organizations)
GRIEVANCES
Refer to SMM Chapter 6 – Compliant procedure
17.6 REFERENCE: Appendix 1- Synergy Code of Conduct

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18 MASTER'S RESPONSIBILITY
By International Law, the Master has the ultimate authority on board. His decisions and
actions are binding on the Owner, Charterer, and Manager. He should, therefore, carry out
his responsibilities with this in mind, using his best judgment at all times.
The management system provided by the Company does not in any way relieve him of his
duties to issue orders and instructions, and he can, and indeed must, deviate from the
system provided, if particular circumstance so require. All such deviations from the system
must be reported in writing to the company, explaining the deviation and the reason for it.
With regard to safety, quality and environment protection, the Master has the
responsibility on board the ship for:
Implementing the company’s Quality, Health, Safety, and Environmental Policy.
Motivating the crew in the execution of that policy.
Verifying that the System is functioning and that specified objectives are achieved. Issuing
appropriate orders and instructions to all crew members in a clear and simple manner.
Ensuring safe work practices on-board through use of proper personal protective
equipment.
Reviewing the Synergy Safety Management System and report any modifications that are
considered necessary.
Implementing regular Safety Committee meetings to plan and review all progress
regarding quality and safety on-board. The Master shall nominate members of the Safety
Committee but shall at least include heads of the different departments and representatives
from the crew. Report of such meetings must be maintained and copy to be forwarded to
the Marine Superintendent in charge.
Implementing on a regular basis, management meetings other than those above, in order to
plan and review areas such as the Planned Maintenance System, Budget, Dry Docking, and
other ship operational issues relevant to the operation of the vessel.
Reporting any incidents and situations that may lead to incidents and affect the safe
operation of the ship, present a risk to human life or risk of pollution. Any reporting
requirements from the Flag State must also be adhered to.
Ensuring that all aspects of the management of the vessel are planned and that operations
liable to involve risk to personnel, environment or property are properly assessed (Risk
Management).
He must ensure that under no circumstances operational safety systems are bypassed or
ignored unless measures are taken to maintain a safe operation. All such deviations from a
safety system must be recorded in the appropriate Logbook and reported to the company
explaining the background for the deviation.
Ensuring that all safety and lifesaving equipment is maintained and kept in a proper place
and is ready for use at all times.
Ensure that all communication and navigational equipment are maintained in proper
working condition. Any breakdown of communication and navigational equipment shall
be immediately reported to the superintendent in charge of the vessel.
Ensuring that the day-to-day operation and seaworthiness of the vessel is in accordance
with national and inter-national rules and regulations and company requirements
The Master is responsible for safe navigation at all times, crew relations, catering and

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welfare, good discipline, evaluation of crew performance training, familiarization and


working morale.
The Master is responsible for the vessel's funds, custody transfer, recording/reporting, slop
chest/delegation of slop chest duties, provision, control of purchasing, budget planning and
follow-up and for ensuring that the vessel's certificates (statutory/class) are at all times
valid. Any discrepancies must be reported in accordance with established reporting
procedures.
Electronic certificates: Various flags and class have started issuing electronic certificates
in accordance with FAL.5//Circ.39 (Guidelines for the use of electronic certificates). The
authenticity and validity of electronic certificates can be checked through an authentication
services by the issuing authority using a UTN (Unique tracking number). Where vessel is
set up with online account to Class website, the Master should download a copy of the
vessel certificates when these are published and save a copy of onboard.
The Master has the authority to take corrective action in the best interest of the Vessel with
regard to safety, quality, and environmental protection.
In the Master's absence the Chief Officer shall take command.
The Master or a person appointed by the Master holding a valid GMDSS License shall
maintain the GMDSS procedures. After taking over command, master should carry out
emergency communication drill through 24hrs emergency contact number and fax within
10 days of taking over.
Master shall be the designated medical officer on board. He shall be responsible for
ensuring the health and well-being of all seafarers on board. Master is responsible for
obtaining timely “Radio medical advice” from Company’s appointed medical advisor or
other recognized medical authorities, in times of serious medical illness or injury. He shall
assign duties to 2nd officer or other certified officer using his discretion, to assist him in
carrying out the medical duties on board.
CHIEF OFFICER’S RESPONSIBILITIES AND DUTIES
The Chief Officer is the head of the Deck Department and in addition is the vessel's Safety
Officer, Training Officer and responsible for carrying out the vessel’s Garbage
Management Plan. He will be the Officer in Charge in the absence of the Master.
Unless ordered otherwise by the Master, the Chief Officer is responsible for the 0400-0800
and 1600-2000 watch at sea. Where the ship is manned with an additional officer, every
Chief Officer has to stand watch for at least 4 watches in a week.
The Chief Officer is responsible to the Master for the following:
Doubling up the bridge team for navigating in Coastal Waters or Traffic Separation Zones,
at times defined by the Master and for assisting the Master during manoeuvring.
Cargo operations with regard to:
Loading, discharging, ballasting, de-ballasting, gas freeing, inerting, purging, cooling
down, gassing up etc.
Vessel's trim, draft, stability, and stress
Keeping all reports and records associated with the cargo/ballast operations
The condition of the vessel's deck and deck equipment operation and maintenance
according to classification societies, flag state, national and international requirements,
rules, and regulations. Regarding technical matters, the Chief Officer will co-operate with
the Chief Engineer, who has the overall responsibility for the vessel's technical equipment.
Follow up and continuous updating of the Planned Maintenance System, including the

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spare parts system, as far as Deck Department is concerned. This includes re-ordering used
spare parts. The officer should make the individual entries responsible for the task(s) in
question. All entries must be verified by full signature.
Be responsible for the safety of all personnel on-board, including risk assessment of the
work environment.
Also, to ensure that the maintenance and testing of all life-saving, fire- fighting, and
pollution prevention and personnel safety equipment is carried out satisfactorily by the
Deputy Safety Officer or other persons designated to do such tasks.
Administration of the deck crew, ensuring efficient and safe work practice, including
preparation of necessary work checklists and training for particular tasks.
Ensuring he receives training for next level in rank, as well as ensuring lower ranks receive
sufficient training for their next level.
General health and personnel hygiene.
Ensuring that all relevant drills and exercises such as, but not limited to, lifeboat drills and
fire exercises, emergency steering drills, oil pollution prevention drills, are carried out as
required by the law.
Attending all management and safety meetings.
Informing the Deck Officers and crew about all matters relevant to this department and the
duties to be performed to ensure a safe and efficient operation.
Ensure that all staff including him is properly alert and rested at all times. It is of vital
importance that requirements as laid down in STCW 2010 are met even during periods of
increased workloads such as during loading, discharging or any other operation of the
vessel. The above does not apply if the safety of personnel, environment and property is in
jeopardy.
Ensure that all documentation related to his duties is properly maintained.
Chief Officer is responsible for operating BWTS which includes maintaining enough
consumables and stores for smooth operation for at least 03 months.
The Chief Officer shall be responsible for the upkeep of plans and manufacturers’
instructions relevant to all deck machinery and equipment.
Ensure that all his responsibilities with a view to SOLAS, (Safety Officer), STCW 2010,
(Training Officer), and MARPOL, (cargo operation, garbage management plan, VOC
management plan on tankers) are adhered to. Be in charge of the vessel’s fire- fighting
teams if the fire is related to the deck area outside of engine/engine casing and follow the
orders from the Master who is ultimately in charge of and coordinating the operation.
Be in charge of the oil spill prevention and/or oil spill reduction operations in accordance
with orders given by the Master.
Be in charge of one of the lifeboats in an abandon ship operation, in accordance with the
orders from the Master.
Chief Officer along with the 2nd Eng. is the designated Ship’s Safety Officer unless
decided otherwise by the Master. His functions as a Safety Officer are defined in HSM
chapter 5.
Chief Officer is in-charge of ensuring accommodation spaces are cleaned regularly as per
a defined schedule and maintained in hygienic condition.

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18.1 2ND OFFICER’S RESPONSIBILITIES AND DUTIES


Unless ordered otherwise by the Master, the 2nd Officer is responsible for the 0000- 0400
and 1200-1600 watch at sea and during cargo operation or whenever necessary for the safe
operation of the vessel.
The 2nd Officer is responsible to the Master during his watch on the bridge and all related
matters and to the Chief Officer during cargo operation. The 2nd Officer shall also
perform the duties as Navigating Officer.
The 2nd Officer is responsible for the following:
The safe navigation during his watch.
The day to day monitoring of the vessel's performance.
Inspecting and maintaining all navigational aids and equipment relating to the navigation
of the vessel.
Preparing and maintaining all relevant reports and logs including, but not limited to,
position reports, AMVER reports, voyage reports, noon report, and
chronometer/radar/compass/ RDF logs.
Preparation of voyage plans.
Performing all relevant tests and checks relating to the navigation and manoeuvring of the
vessel.
Maintaining all logs, reports and checklists relevant to his duties and updating the Planned
Maintenance System, regarding tasks that he is responsible for. All entries must be verified
by full signature.
He should familiarize himself with all procedures and checklists relevant to the duties
carried out regarding special and critical operations, in order to maintain the highest
possible level of safety (esp. Permit to work system).
During cargo operations, the 2nd Officer shall perform his duties as outlined in the
Standing Orders – Cargo operations.
As necessary, assist Chief Officer in on-board safety familiarization. Attend mooring
station as assigned by master.
At all times to keep charts and nautical publications, also including List of Radio Signals,
updated and corrected, according to the information and material provided. Assist master
in paperwork related to provision and bond. This responsibility will be given to either 2nd
officer or 3rd officer as decided by master.
The Second Officer shall be responsible for assisting the master in carrying out medical
duties, as assigned, including:
Maintenance and upkeep of the medical locker and maintaining a Medical Log for
medicines dispensed and rendering of medical/ first aid assistance to injured and sick crew.
Assisting the Master in dispensing medicines, providing first aid on board and for
maintaining the medical log.
Encouraging seafarers to report any known or new medical condition or illness, which may
adversely affect the ability of the seafarer to safely perform assigned duties, or which may
be detrimental to the health and welfare of others on board.
With Master’s approval, obtaining information from all seafarers on board regarding any
medications they are using, including over-the-counter medicines, prescription medicines,
vitamins, herbal supplements, etc.

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Assist the Master to ensure ship staff has appropriate pre-employment medical
examination are completed satisfactorily and check that no limitations are highlighted in
the pre-joining medical reports.
In order to get familiarized with Chief mate’s duties, 2nd officers should spend at least 4
hours a week assisting chief officer in shipboard maintenance. This will be finalized by
Master based on vessel schedule and the seniority of the second officer.
Note: Any deficiencies and irregularities to be reported to the Master and/or Chief Officer.

18.2 3RD OFFICER’S RESPONSIBILITIES AND DUTIES


Unless ordered otherwise by the Master, the 3rd Officer is responsible for the 0800- 1200
and 2000-2400 watch at sea and during cargo operation or whenever necessary for the safe
operation of the vessel.
The 3rd Officer shall perform the duties as Deputy Safety Officer, and he is directly
responsible to the Chief Officer regarding all safety-related matters. He shall assist Chief
Officer in On-board safety familiarization.
The 3rd Officer is responsible to the Master during his watch on the bridge and all related
matters and to the Chief Officer during cargo operations and maintenance of safety,
firefighting and pollution prevention equipment.
Third officer to understudy second officer’s role.
The 3rd Officer is responsible for the following:
The safe navigation during his watch.
The maintenance and operation of all firefighting, lifesaving, pollution prevention and
personnel safety equipment as directed by the Chief Officer. (See Note) 4E will be
responsible for all LSA / FFA items in Engine room. Maintenance of LSA / FFA items in
Engine room (Example: Inspection of all LSA/FFA items in ER, recharging of
extinguishers, pressure testing of fire hoses and recording same in the SOLAS / FFA
Checklist).
Attending Safety Meetings and to join the Safety Review Team.
Keeping updated all safety and lifesaving related information posted within the vessel such
as, but not limited to, muster lists, equipment related information, escape/exit marking.
During cargo operations, the 3rd Officer shall perform his duties as outlined in the
Company’s Standing Orders – Cargo Operations. Attend mooring station as assigned by
master.
He should familiarize himself with all procedures and checklists relevant to the duties
carried out regarding special and critical operations, in order to maintain the highest
possible level of safety (esp. Permit to work system).
Maintaining all logs, reports and checklists relevant to his duties and updating the Planned
Maintenance System, regarding tasks that he is responsible for. All entries must be verified
by full signature.
His duties include inspecting, operating, and ensuring timely maintenance of all
VHF/MF/HF transceivers (GMDSS) and handheld VHF/UHF radios, and keeping relevant
logs and records. (See note)
Maintaining flag/signal equipment. (See Note)
Maintaining all logs, reports and checklists relevant to his duties and updating the Planned
Maintenance System, regarding tasks that he is responsible for. All entries must be verified

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by full signature.
Assist master in paper work related to provision and bond. This responsibility will be
given to either 2nd officer or 3rd officer as decided by master.
Assist master in all paper work related to port formalities.
Note: Any deficiencies and irregularities to be reported to the Master and/or Chief Officer.
Where junior third officers are employed on board vessels, they shall
discharge their duties and responsibilities in line with that of Third officer’s
responsibilities and duties as outlined in SMM Chapter 18, section 18.4.

18.3 ADDITIONAL NAVIGATING OFFICER


Below are only guidelines and this can be modified by Master based on the experience of
all deck officers on board at that time.
Job responsibilities of additional navigating officer would include but not limited to:
He will be responsible for the 0800-1200 and 2000-2400 watches at sea and during cargo
operation.
The Additional navigating officer is responsible to the Master during his watch on the
bridge and all cargo / port related matters to the Chief Officer during cargo operation.

18.4 Other Responsibilities:


GMDSS Officer in charge of all GMDSS equipment and Log keeping
Assisting Master with all routine position reports, maintaining certificate status,
allotments, port papers, paperwork related to Provision and Bond
Flag and Signal Equipment's
Assist third officer in LSA / FFA items as and when necessary. However, third officer will
remain responsible to Chief Officer for maintenance of LSA / FFA items.
Attend Mooring stations as assigned by Master
Report deficiency and irregularities to Master and or chief officer.
Above job allocation to be done after the officers has a settling time on-board for at
least two weeks where new officer will understudy his senior’s officers.
Chief Officer will be relieved of his normal navigation watch keeping duties but will
continue to be responsible to the Master for the following:
Assist Master during Arrival/Departure ports so that he'll get familiar with the
manoeuvring characteristics of vessel.
Doubling up the bridge team for navigating in Coastal Waters or Traffic Separation Zones,
and at times defined by the Master
Assisting the Master during manoeuvring.

18.5 BOSUN’S DUTIES


The Bosun shall report directly to the Chief Officer regarding all matters relevant to the
Deck Department.
His duties are (but not limited to):
Ensuring that the work plans issued by the Chief Officer are being followed. Ensuring the

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deck hands are efficiently employed during the working hours, at all times keeping in
mind the safety of the crew.
Familiarize himself with all checklists relevant to the duties carried out on deck regarding
special and critical operations, in order to maintain the highest possible level of safety
(esp. Permit to work system).
Familiarize himself with all equipment relevant to the performance of his duties, also
including safety and emergency equipment and procedures.
Familiarize himself with all kinds of products such as, but not limited to, paint thinner,
cleaning chemicals, oil and grease regarding safety and health hazards. Assist in Inventory
management of deck stores, ropes, paints as required by Chief Officer.
Check that all work related to deck machinery/cranes is carried out in a controlled
condition and by qualified personnel.
During cargo operations, the Bosun is assigned as mooring watch, in addition to his duties
as Bosun.
Note: Any deficiencies and/or irregularities regarding equipment and procedures to be
reported to the Chief Officer.

18.6 DUTIES OF ABLE AND ORDINARY SEAMEN


He shall report to the deck officers and Bosun to carry out watch keeping and maintenance
tasks as designated by the Chief Officer.
He should familiarize himself with all checklists relevant to the duties carried out on deck
regarding special and critical operations, in order to maintain the highest possible level of
safety (esp. Permit to work system).
He should familiarize himself with all equipment relevant to the performance of his duties,
also including safety and emergency equipment and procedures.
He should familiarize himself with all kinds of products such as, but not limited to, paint
thinner, cleaning chemicals, oil and grease regarding safety and health hazards. Be certain
that all work related to deck machinery/cranes that he does is carried out in a safe and
proper fashion.
Duties include:
Watch keeping during navigation, at anchorage and during port stay.
Report to the Bridge OOW for steering and lookout duties.
Attend to mooring stations under instructions from the supervising officer.
During port watch, attend to cargo operations as directed by the duty officer; tend
moorings, cargo hoses and the gangway.
Perform maintenance tasks, under instruction from the Bosun.
Assist in receiving and stowing stores and spares.
Perform security and anti-piracy watches, whenever required.

18.7 CHIEF COOK’S DUTIES


The Chief Cook reports directly to the Master regarding all matters relevant to the Catering
Department. His responsibilities and duties are, but not limited to:
Ensuring that the work plans issued by the Master are being followed.

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Ensuring that the Catering Staff is efficiently employed during the working hours, at all
times keeping in mind the safety of the staff.
Familiarizing himself with all equipment relevant to the performance of his duties. The
general cleanliness and hygiene of all living quarters, mess rooms, provision rooms and
galley.
Preparation and serving of all meals.
Assisting the Master in preparation of provision and stores requisitions, the department's
Budget Planning and follow-up.
Ensuring that the provisions are utilized in the best possible way.
Ensuring that the MARPOL 73/78 regarding garbage disposal is complied with by himself
and his department.
Chief Cook is in-charge of ensuring that that galley, pantry, provision rooms, fridge rooms
and all food handling spaces are cleaned regularly as per a defined schedule and
maintained in hygienic condition.

18.8 STEWARD’S DUTIES


The steward is responsible to the Chief Cook for carrying out his duties in a safe and
proper fashion.
He is to assist the Chief cook in the preparation and serving of meals and in inventory
management of provision and cabin stores.
He is to familiarize himself with all equipment relevant to the performance of his duties.
He is to assist the Chief Cook in maintaining a high level of cleanliness and hygiene in all
living and working spaces in the accommodation.
Depending upon the nature of ship’s operations, he may be required to assist the
ship’s crew in carrying out the master’s and Chief Engineer’s orders. This will include, but
not be restricted to, handling of stores, assisting in mooring operations, and standing anti-
piracy watches.

18.9 CHIEF ENGINEER’S RESPONSIBILITIES AND DUTIES


The Chief Engineer is the head of the Engine Department. His duties include: Technical
advice to the Master.
Operation and Maintenance of all machinery in engine room and on deck according to
Classification Societies requirements, flag state requirements, national and international
rules, and regulations.
Control and update of Class Surveys, certificates, records, files, drawings, etc. Verification
of recording in engine log book by signature once every day.

18.10 Administration and training of engineers and crew. Safety in the engine
room.
In the case of fire in the Engine Room or other areas covered by any fixed Fire
extinguishing systems, subject to the Master's authorization, the Chief Engineer will be
responsible for effective operation of the system.
Requiring sufficient bunkers and consumption control of fuel oil and bunkers as stated in
the Charter Party.
The Chief Engineer is in charge of the bunkering operation. If unavailable, the Master

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shall appoint another senior officer for the duty of the bunkering. (Refer: Technical
manual- Bunkering Procedures).
It is the responsibility of the Chief Engineer to ensure that there is sufficient lubrication oil
on-board at the beginning of each passage to meet the anticipated consumption, together
with one full charge for all different systems.
Chief Engineer in-charge of maintenance of fixed firefighting system. All deck machinery
Windlass, Winches, Cranes etc.
Request for repairs and service when required from shore. Prepare, maintain and follow-up
dry-docking lists.
Reporting to Technical Division on machinery related matters, such as maintenance report
and general condition report for each voyage. The Chief Engineer is expected to revert to
the office by phone, fax or E-mail if he suspects that the Management does not realize the
urgency of the matter.
Ensure that all matters related to the technical situation of the vessel deviating from the
planned operation as set down in charter parties, own or other plans and procedures are
reported immediately to technical division. He must ensure that under no circumstances
operational safety systems are bypassed or ignored unless measures are taken to maintain a
safe operation. All such deviations from a safety system must be reported to the company
explaining the background for the deviation.
Overall follow up and overall continuous updating of the Planned Maintenance System,
including the spare parts system. The individual entries should be made by the officer
responsible for the task(s) in question. All entries must be verified.
He is the Environmental Compliance officer on-board. His is to ensure implementation of
EMS. He is responsible for the maintenance of MARPOL equipment’s on-board.
Ensure that proper watch keeping and log entries are made for engine room and cargo
control room. Controls, monitors and records discharge of bilges, effluents, and CFC
consumption.
Chief Engineer is in-charge of ensuring that engine room and machinery spaces are
cleaned regularly as per a defined schedule and maintained in safe and environmentally
friendly condition.
CE is responsible for maintenance of BWTS system and maintaining stock of minimum
spare parts to keep the system in readiness.

18.11 2ND ENGINEER (1ST A/E) 'S RESPONSIBILITIES AND DUTIES


Unless ordered otherwise, the 2nd Engineer is normally responsible for safe operation of
0400-0800 and 1600-2000 watch.
This includes, but is not limited to:
Being in charge of the daily tasks in the engine room, such as maintenance planning,
including the general cleanliness of the engine room and all adjacent compartments, and
distributing the maintenance work to the crew at work start in the morning.
Ensuring that all maintenance work is done in a proper and safe way in engine room or in
other areas.
Ensuring that all engine staff understand the company requirements regarding permit to
work system and risk assessment and comply with the requirements. Proper operation and
maintenance of all automatic control equipment and systems in engine room.
Is in charge of maintenance of the following equipment:

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Inert Gas system (Tankers only) to be assisted by Electrician. Main Engine


Oily water separator
AUS &vacuum pump motors (Tankers only) to be assisted by Electrician. ODMCS
(Tankers only) to be assisted by Chief Officer.
Cargo oil pumps & ballast pumps
Ensuring that all safety equipment in the engine room and all other machinery areas are
taken care of by the Safety Officer.
Follow up and continuous updating of the Planned Maintenance System, including the
spare parts system, as far as Engine Department is concerned. This includes re- ordering
used spare parts. The individual entries should be made by the officer responsible for the
task(s) in question. All entries must be verified.
Any abnormality to be reported to the Chief Engineer, as well as the general condition of
the machinery.
He shall be called upon standby and/or at any time as circumstances may require. 2nd Eng.
along with the chief officer, is the designated Ship’s Safety Officer unless decided
otherwise by the Master. He shall liaise closely with the Chief Officer regarding all safety
related matters.
His functions as a Safety Officer are defined in HSM chapter 5

18.12 3RD ENGINEER (2ND A/E)'S RESPONSIBILITIES AND DUTIES


Unless ordered otherwise, 3rd Engineer is normally responsible for safe operation of the
0000-0400 and 1200-1600 watch.
This includes, but is not limited to:
Auxiliary engine running and maintenance as required by Chief Engineer. Boilers,
fresh water generator
Maintenance and weekly check and test running of the lifeboat motors.

Maintaining all logs, reports and checklists relevant to his duties and updating the Planned
Maintenance System, regarding tasks that he is responsible for. All entries must be verified
by full signature.
He should familiarize himself with all procedures and checklists relevant to the duties
carried out regarding special and critical operations, in order to maintain the highest
possible level of safety (esp. Permit to work system).
Any abnormality to be reported to the Chief Engineer or to the 2nd Engineer.
The 3rd Engineer may be called upon standby and/or at any time as circumstances may
require.

18.13 4TH EGINEER (3RD A/E)'S RESPONSIBILITIES AND DUTIES


Unless ordered otherwise, 4th Engineer is responsible for safe operation of the 0800-1200
and 2000-2400 watch.
This includes, but is not limited to:
Proper maintenance of lube oil purifiers, air compressors and related equipment.
Recording of logs to above systems.

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Recording of stern tube lube oil consumption and lube oil temperature. Monthly check of
water contents in lube oil.
Assisting Chief Engineer in bunkering operations, soundings & completion bunker plan &
checklist.
Recording of oil consumption in cargo, ballast, and fuel oil hydraulic systems.
Maintenance and weekly check and test running of one of the lifeboat motors and
emergency fire pump.
Maintaining all logs, reports and checklists relevant to his duties and updating the Planned
Maintenance System, regarding tasks that he is responsible for. All entries must be verified
by full signature.
He should familiarize himself with all procedures and checklists relevant to the duties
carried out regarding special and critical operations, in order to maintain the highest
possible level of safety (esp. Permit to work system).
Any abnormality to be reported to the Chief Engineer or to the 2nd Engineer.
The 4th Engineer may be called upon standby and/or at any time as circumstances may
require.
The 4thEngineer (See Note) will be responsible for the maintenance of all LSA / FFA /
Pollution prevention and personnel safety equipment located in Engine Room and
Machinery Spaces. (see note) In coordination with safety officer 4E shall ensure that all
above equipment are kept in operational readiness at all times.
Example as follows, but is not limited to:
Inspection of all LSA/FFA items in ER, recharging of extinguishers, pressure testing of
fire hoses and record maintaining in the SOLAS / FFA Checklist.
Note: Any deficiencies and/or irregularities regarding equipment and procedures to be
reported to the Chief Officer.
Note: Where Junior 4th engineers are employed on board vessels they shall discharge their
duties and responsibilities in line with that of 4th engineer’s responsibilities and duties as
outlined in SMM Chapter 18, section 18.13.
Where 4th Engineers are not employed on board as per the safe manning requirements, the
duties for the maintenance of all LSA / FFA / Pollution prevention and personnel safety
equipment located in Engine Room and Machinery Spaces, shall be assigned to 3rd
Engineer.

18.14 GAS ENGINEERS RESPONSIBILITIES AND DUTIES


(APPLICABLE FOR GAS TANKERS ONLY)
The Gas Engineer (or the Third Engineer) shall carry out the following and shall be
responsible to the Chief Officer for a) and b) and to the Chief Engineer for c) to e)
Control of temperature and pressure of tanks.
Control of cargo.
Pre-arrival checks.
Loading, Discharging and Cargo change operations.
Attending at manifold at the time of ship – shore alignment.
Manifold connection / disconnection and change of any cargo line section.
Report to Chief Engineer for maintenance of following-

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Management of operation and maintenance of Gas plant related machinery and equipment
in general.
Operational management of machinery and equipment when they are in transient stages at
the start and completion of cargo work.
Management of the alarm of Gas Plant related machinery and equipment.
Fixed Gas detector and ESD system.
Carry out maintenance and repair task, when required in engine room as assigned by Chief
Engineer.
Strict Observance of Safety Management System
The Gas Engineer (or the Third Engineer) shall familiarize himself with the Safety
Management System. He shall carefully read the SMS Manual and observe the contents
thereof.

18.14.1 Navigation
Watch keeping at Sea
As a rule, the Gas Engineer (or the Third Engineer) shall not engage in any watch duties at
sea or in normal UMS operation duties.

18.14.2 Maintenance and Management of Operation


Maintenance Planning
The Gas Engineer (or the Third Engineer) draw up maintenance plans and work plans for
the machinery and equipment in his charge and submit them to the Chief Engineer.

18.14.3 Maintenance Work


The Gas Engineer (or the Third Engineer) is responsible for carrying out the maintenance
work on the machinery and equipment in his charge in accordance with the Chief
Engineer's orders.
Preparation of Maintenance Records
The Gas Engineer (or the Third Engineer) shall prepare maintenance and measurement
records, and other documents pertaining to the machinery and equipment in his charge and
submit them to the Chief Engineer.
Equipment and Machinery under Charge of Gas Engineer (or Third Engineer) The
equipment and machinery under the Gas Engineer's (or the Third Engineer's) charge shall
be as follows:
Control of Gas Plant and management of overall maintenance and operation of Gas related
machinery; various machines and equipment in the CCR; IGG and related equipment; N2
generator; cargo spray pump; gas compressors and heat exchangers for cargo;
instrumentation for Gas related equipment; automatic control system for equipment under
his charge; fixed gas detecting system; compressor room, motor room fans; control of
related parts and spares; documents and clerical work.
Operation Control of Machinery and Equipment and LPG Plant
The Gas Engineer (or the Third Engineer) shall maintain the machinery and equipment
under his charge in good order. He shall also carry out control of temperature and pressure
of cargo tanks and control of cargo in accordance with the Chief Officer's orders.
Familiarity with Machinery and Equipment and LPG Plant

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The Gas Engineer (or the Third Engineer) shall investigate, study and be thoroughly
familiar with the Gas plant and especially with the construction, operating principle, piping
system, running conditions and other factors of the machinery and equipment under his
charge. Also, after joining the ship, he shall promptly familiarize himself with the normal
operating methods and regular duties pertaining to the machinery and equipment coming
under his charge.

18.14.4 Parts Control


The Gas Engineer (or the Third Engineer) shall control the parts of the machinery and
equipment in his charge and submit to the Chief Engineer by the specified time any parts
that need requisitioning.

18.14.5 Control of Ship's Stores


The Gas Engineer (or the Third Engineer) shall control documents and prepare requisitions
for the ship's stores pertaining to the cargo machinery, and submit them to the Chief
Engineer.

18.14.6 Others
He shall carry out other matters as instructed to him by the Chief Engineer or the Chief
Officer.

18.15 ELECTRICIAN'S/ETO’S RESPONSIBILITIES AND DUTIES


In case of vessel with designated electricians;
Unless ordered otherwise, the Electrician is normally responsible for safe operation of all
electrical equipment.
This includes, but is not limited to:
Maintenance and proper running of all electrical equipment such as motors, switchboards,
automation, navigation, radio equipment (when called for), cabling, light fixtures, and
cargo equipment in co-operation with the Chief Engineer, 2nd Engineer and Reefer
Engineer.
Test running and checking of auxiliary and emergency diesel generator weekly.
Maintenance and check of all emergency batteries.
To be present in the engine control room during manoeuvring e.g.: pilotage, arrival
departure port berthing, unberthing, anchoring etc. and as per Chief Engineer discretion.
For tankers only – To be present during starting, stopping of cargo operations and IG plant
until operations stabilized and as required by Chief Engineer.
Follow up and see that the Planned Maintenance System, including spare parts system, is
continuously updated, and used spare parts are re-ordered.
Any abnormality to be reported to the Chief Engineer or 2nd Engineer.
The Electrician shall be called upon standby in port and/or at any time as circumstances
may require.
He should familiarize himself with all procedures and checklists relevant to the duties
carried out regarding special and critical operations, in order to maintain the highest
possible level of safety (esp. Permit to work system).
The Electrician reports to Chief Engineer and 2nd Engineer. He carries out his day- to-day
work as directed by Chief Engineer and 2nd Engineer.

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The Electrician is also responsible for the maintenance of all FFA (electrical part) in the
accommodation, engine room and machinery spaces. (see note) In coordination with safety
officer the electrician shall ensure that all detectors, fire alarm call points etc. are kept in
operational readiness at all times.
Example as follows, but is not limited to:
Inspection and testing of all fire detectors, smoke detectors, fire alarm call points,
emergency batteries etc. and record maintaining in the SOLAS / FFA Checklist.
Note: Any deficiencies and/or irregularities regarding equipment and procedures to be
reported to the Chief Officer.
Note: Where Junior electricians are employed on board vessels they shall discharge their
duties and responsibilities in line with that of electrician’s responsibilities and duties as
outlined in SMM Chapter 18, section 18.14.
In the absence of Electrician in the vessel Chief Engineer shall nominate these
responsibilities to other engineers.
REEFER ENGINEER’S RESPONSIBILITIES AND DUTIES
Unless ordered otherwise, the Reefer Engineer is responsible for safe operation o fthe
cargo systems according to the makers’ instruction manuals. This includes, but is not
limited to:
Meeting Charterers' requirements as indicated in the Charter Parties.
Maintenance, checking and testing of all main, auxiliary and emergency systems and units
related to the cargo systems.
The Reefer Engineer must assist as required during cargo operations.
He should familiarize himself with all procedures and checklists relevant to the duties
carried out regarding special and critical operations, in order to maintain the highest
possible level of safety (esp. Permit to work system).
The Reefer Engineer is responsible for preparation of the cargo systems prior to
loading/discharging and other cargo operations during voyage.
For loading/discharge and other related operations the Reefer Engineer answers to the
Chief Officer and collaborates with the deck officer who is on cargo watch.
The Reefer Engineer is expected to inform the Chief Engineer regarding the maintenance
program, technical matters, or malfunctions.
Follow up and see that the Planned Maintenance System, including spare parts system, is
continuously updated and used spare parts are re-ordered. Sign records with full name.

18.16 DUTIES OF A MOTORMAN (OILER)


Reporting to the Engineer officers to carry out watch keeping and maintenance tasks as
designated by the 2nd engineer.
He should familiarize himself with all checklists relevant to the duties carried out in the
engine department regarding special and critical operations, in order to maintain the
highest possible level of safety (esp. Permit to work system).
He should familiarize himself with all equipment relevant to the performance of his duties,
also including safety and emergency equipment and procedures.
He should familiarize himself with all kinds of products such as, but not limited to, paint
thinner, cleaning chemicals, oil and grease regarding safety and health hazards.

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Be certain that all work that he does is carried out in a safe and proper fashion.
Depending upon the nature of ship’s operations, he may be required to assist the ship’s
crew in carrying out the Master’s and Chief Engineer’s orders. This will include, but not
be restricted to, handling of stores, assisting in mooring operations, and standing anti-
piracy watches. He should take part in cleaning common spaces like mess rooms, smoke
rooms or any space in accommodation as decided by the senior management on board.

18.17 DUTIES OF PUMP MAN (ONBOARD TANKERS)


Reporting to Chief Officer. He should obtain his work schedules and instructions from
Chief Officer unless delegated under Second Engineer for specific work to be carried out.
He should familiarize himself with cargo operations, pumps, and other machinery he will
be assigned to operate. He should carry out the work with safe and efficient manner. He
should familiarize himself with all checklists relevant to the duties carried out by him
regarding special and critical operations, in order to maintain the highest possible level of
safety (esp. Permit to work system).

18.17.1 Primary functions:


To assist Chief Officer in all cargo / ballast transfer and associated operations.
To maintain and carry out effective repairs on the Cargo, ballast systems including:
IGS, Tank cleaning, COW, valve hydraulics
Gauging systems, Heating coils and
Equipment associated with cargo / ballast pumping and piping system (excludes E/R
Machinery and equipment).
All repairs and Maintenance should be carried with consultation of Chief Officer and
Chief engineer.
To be present for critical cargo and ballast operations like topping up, initial lining up,
hose connection / disconnection, stripping, COW, Tank cleaning, gas freeing / inerting
operations.
Pump man should carry out the following duties:

18.17.2 In Port
Line up in pump room for discharging, stripping or ballasting
Prepare manifold to accept discharging arms.
Gauging and sampling of cargo tanks
Monitor cargo, ballast and stripping pumps
Assist in monitoring the cargo operations as required by Chief officer
Monitor COW machines and vac strip system

18.17.3 At Sea
Maintenance of the cargo hydraulic valve system under the supervision of Chief Engineer
Chief Officer:
Condition of hydraulic boxes and pilot valves
Hydraulic pumps and accumulator

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Hydraulic line leaks


Emergency hydraulic hand pump
Actuators of hydraulic valves in the cargo tanks, pump room and on deck
Replacement of defective seat rings of valves in the cargo tanks, pump room and on deck.
COW system
Maintenance of COW machines
Maintenance of portable tank cleaning machines
Repair and overhaul of line valves Gauging system
Repair and maintenance of fixed system
Care and maintenance of UTI tapes and samplers Cargo pumping system
Maintenance and repair of cargo, ballast and stripping pumps
Deck equipment Maintenance and repair of:
P/V valves, IG valves, deck seal, P/V breaker
Gas freeing equipment and demucking winches
Tank dome and manhole packing
Pressure gauges and thermometers Cargo heating system
Valve repairs
Cleaning steam traps
Starting and stopping of cargo heating
Testing of heating coils Pump Room
Cleanliness
Maintenance of all pressure gauges and pneumatic lines
Greasing / lubrication Miscellaneous
Daily atmosphere and sounding check of ballast tanks and void spaces
Maintain an inventory of cargo system related spares and stores.
Depending upon the nature of ship’s operations, he may be required to assist the
ship’s crew in carrying out the Master’s and Chief Engineer’s orders. This will include, but
not be restricted to, handling of stores, assisting in mooring operations, and standing anti-
piracy watches.

18.18 WIPER
Reports to: 2nd Engineer
Primary function:
Assist in maintenance and housekeeping in the Engine Room.
Main tasks and responsibilities:
Report to the 2nd Engineer and take instructions for maintenance and housekeeping in the
machinery spaces.
Assist in receiving and stowing stores and spares.

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Attend to bunkering operations, taking instructions from the duty engineer.


Perform security and anti-piracy watches, whenever required.
Familiarize himself with the duties of a Motorman, to enable flexibility in operations.
Depending upon the nature of ship’s operations, he may be required to assist the
ship’s crew in carrying out the Master’s and Chief Engineer’s orders. This will include, but
not be restricted to, handling of stores, assisting in mooring operations, and standing anti-
piracy watches.

18.19 FITTER
Responsibility and Authority:
The Fitter reports to the 2nd Engineer and shall consider his orders both effective and
binding, as though emanating from the Chief Engineer.
He will be responsible for the clean and tidy condition of his workshop and store and will
maintain his stock of spare gear and general stores in good order and condition. He will
pay special attention to the upkeep of the electric and gas welding / cutting equipment and
associated consumables.
He should have thorough understanding of company permit to work system especially
company hot work procedures.
He will also be responsible for the compilation of spare gear and stores requirements
pertaining to his scope of work.
The Fitter shall assist the Chief Engineer in discharging his responsibilities towards the
maintenance of both deck and engine room machinery as well as the repair of Company
property.
Since the nature of his job will often involve carrying out Hot Work, the Fitter is
authorized to stop work and bring to the notice of the Chief Engineer, his misgivings
regarding the safety conditions at and around the work site.

18.19.1 Duties upon joining a company vessel:


Immediately upon joining a vessel and subsequent to meeting the Master, the Fitter will
report to the Chief Engineer. He will be familiarized as per the company Familiarization
procedures and shall try to obtain pertinent information from the outgoing Fitter. At the
earliest opportunity, he shall take stock of the equipment and spare gear under his charge,
and report to the 2nd Engineer regarding their condition. Later, he shall familiarize himself
with the general lay out of the vessel, enabling him to work independently and respond
quickly to emergencies.

18.19.2 Maintenance:
On day-to-day matters, involving the maintenance and upkeep of equipment and property,
he will be directly responsible to the 2nd Engineer, considering his orders as being those
issued by the Chief Engineer.
At those times when he may be required to work under the daily supervision of the Chief
Officer, he will still report to the 2nd Engineer and be answerable to the Chief Engineer.
He will inspect the condition of spare gear and report any unserviceable item to the 2nd
Engineer. He should satisfy himself that there is a sufficiency of gas and electric welding
consumables as well as other essential stores on-board to meet immediate and reserve
requirements.

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He will be responsible for mobilizing the necessary equipment at his work site, working
independently as far as practicable. On completion of the job, he will ensure that the work
site is squared up, associated equipment is returned to their designated locations and
properly stowed.
Depending upon the nature of ship’s operations, he may be required to assist the
ship’s crew in carrying out the Master’s and Chief Engineer’s orders. This will include, but
not be restricted to, preparing of location for hot work, handling of stores, assisting during
bunkering operations, assisting in mooring operations, standing anti- piracy watches, and
preparing for vessel inspections.

18.20 DECK CADET


Deck Cadets are responsible to the Master through Chief Officer for the performance of
their duties and the timely completion of their training program.
Cadets will be assigned tasks commensurate with their training requirements, and always
under the supervision of a deck officer.
The cadets will be responsible for the timely completion of tasks and projects detailed in
their training record books (either provided by training institute or by company) and for
having their performance appraised by the relevant officers.
The cadets will be responsible to the Master, through the Chief Officer, for the
performance of their tasks in a safe and environmentally responsible manner. To this end,
the cadets shall familiarize themselves with applicable international, national regulations
and Company policies and procedures.

18.21 ENGINE CADET / JUNIOR ENGINEER


Engine cadets / Junior Engineers are responsible to the Chief Engineer through
2ndEngineer for the performance of their duties and the timely completion of their training
program.
The Engine Cadet or Junior Engineer reports to the 2nd Engineer and shall consider his
orders as both effective and binding.
He is an engineer officer under training and as such shall assist the senior engineers in
carrying out their responsibilities towards repair and maintenance of engine room
machinery and equipment. Cadets will be assigned tasks commensurate with their training
requirements, and always under the supervision of Engineers.
The Engine cadets / Trainee engineers will be responsible for the timely completion of
tasks and projects detailed in their training record books (if provided by training institute
or by company) and for having their performance appraised by the relevant engineers.
Engine cadets / junior engineers shall be responsible to the Chief Engineer, through the
2nd Engineer, for the conduct of Engine Room operations in compliance with applicable
international and national regulations and Company policies and procedures.
Junior Engineers may be allowed to keep independent Engine watch as they have Class IV
competency. However, the independent watchkeeping by J/E to be decided by Chief
engineer after due diligence.

18.22 TRAINEES
Where a trainee is engaged, he shall perform the duties as per the rank specific duties as
mentioned about under the guidance of his seniors. For example, a trainee seafarer will
perform the duties of a Seafarer under the guidance of his seniors.

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Restrictions in work practices for trainees:


A seafarer under the age of 18 or with less than 12 months of sea service should not work
aloft or overside.
A seafarer under the age of 18 or with less than 3 months of sea service should not be
allocated work in an enclosed space. Trainees over the age of 18 and with more than 3
months of experience may enter enclosed spaces if accompanied by an experienced
person.
As far as possible, trainees may not be assigned standby duties for enclosed space entry or
aloft / overside tasks.
A trainee shall operate machinery under the direct supervision of experienced ship staff.

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19 COMMUNICATION
Company believes that effective communication is vital for efficient management of
vessels which may be formal or informal.
The Head of Ship Management Team shall ensure that necessary communication
processes are established within the organization and that communication takes place
regarding the effectiveness of the QHSE Management System.
Synergy uses the following means of internal communication: -
Telephone
Email
Fax
Circulars
Letters/ Memo
Reports
In addition to the periodical meetings and reviews, company encourages informal meetings
at office and on-board the vessels as frequent as possible.
Company shall allocate individual, group and general e mail identity for the staff
responsible for managing the vessel. Company shall provide e mail facility to the vessels.
The Master shall be responsible for all correspondence and communications related to the
business of the vessel. He may delegate his job to other officers as necessary.
When required, the master must ensure the confidentiality of the messages and documents
that he receives or sends. It is however stressed that the company
operates on “open” system of Management and Master should not be unnecessarily
secretive with regards to “non-confidential” documents.
Master may use appropriate communication equipment (Telex, Telefax, Telephone or
Email) according to the requirement.
It is recommended that for urgent communication that needs an immediate attention,
telephone shall be used followed by detailed email and or fax.
Contact numbers of the company with direct line and AOH shall be provided and updated
in circulars.

19.1 GENERAL COMMUNICATION


All communication shall be addressed to or copied to company’s common email ID.
All messages from the vessel that are sent to statutory bodies, the charterers, Operator,
navigation agents and port agents and other parties, except private email shall be copied to
company.
All statutory communications shall be sent directly by the master in close liaison with
office. All communication which requires immediate attention from office shall be marked
as "Non routine" in the message subject. Mentioning as "Non routine" will help the group
managers/management to focus on the major issues, and provide appropriate attention
where required.
Following are few examples for Non-routine messages. In case of doubt, please mark the

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message as "Non routine".


All HMX Reports
All Accidents
Major breakdown / defects - Black out / ME stoppage / Defects in steering gear / other
major breakdown of machinery / damage to vessel / malfunctioning of key equipment
Injury to personnel (any category including First aid)
PSC / FSC / Flag inspection / External audit / Class / Other 3rd party inspection reports /
Any COC issued
Urgent manning issues - including disciplinary issues, emergency sign on sign off and
issues with crew certificates
Any delay / expected delay in vessel operations in port
Sudden change in ETA / ETD affecting other arrangements
Any urgent requirement needing Management / Manager's immediate attention
Overhaul of Marpol equipment/renewal of Coalescer or emulsifier/Incinerator refractory
patch up etc.
Violation of D&A policy (reports with blood alcohol content exceeding company
requirement)
Certificates / Surveys expected to become overdue (due to port calls, delays, etc.)
Following messages should be under routine message.
Noon reports sent to charterers
Month end reports
ETA reports
Voyage orders
SMMS exports
Requisitions

19.2 DAILY AND OTHER PERIODICAL REPORTS


Vessel’s daily reports such as noon, arrival and departure reports should be made
through either of the following options in the mentioned order of priority:
Data entry in ShipPalm WinApp software where installed, and auto synchronization with
shore side application via Amos Connect communication system or manual
synchronization with shore side application via other communication systems as
applicable.
In the unforeseen event of failure of the above methods the afore mentioned reports should
be sent using the Event report (excel sheet) attached to an email addressed ONLY to
Shipreportsgroup@synergyship.com

19.3 FORMS & CHECKLISTS


Company form referred under the forms and manual shall be prepared and sent by the
master in electronic / paper form as appropriate. Refer Forms & Checklists Manual.
There is no need to replicate the hard copy, if the same is sent in electronic form. When the
company forms are sent by courier, the details shall be communicated to the office to

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enable track the consignment.

19.4 COMMUNICATION WITH THE MEDIA


No seafarers employed on-board the ship shall discuss any company business with Media
representative or other third party unless the prior consent of the Head of Ship
Management Team.
If the media approaches any crew member, they should refer the person to the Master.

19.5 DOCUMENT CONTROL OF MESSAGES


All routine, non-routine, urgent, and other operational messages addressed from and to the
vessel shall be numbered for traceability. Record shall be maintained for all such messages
in the appropriate form (either electronically or paper form).
It is recommended that messages of least importance and meant for intention of
instantaneous use can be deleted for efficient record keeping.

19.6 LANGUAGE
English is the working language of the vessel and personnel aboard the vessel shall have
knowledge of the English language appropriate to their position. The vessel’s personnel
should be able to communicate effectively in English.
All personnel should be able to understand key instructions relevant to operations as well
as emergency instructions in English.
Officers comply with STCW 2010 requirements for knowledge of English.The
crewmembers receive relevant information on the SMS in English.

19.7 PERSONAL EMAIL ONBOARD SHIP


We aim to provide easy and continuous access to private email for our seafarers. The
Master should not be burdened with the additional task of having to forward personal
emails on behalf of crew. The computer in common areas like the smoke
room / ship’s office may have been configured with an email account on outlook for each
crew member (password protected). Crew can send personal emails from their individual
email accounts that get routed through the communications computer on the bridge, if the
computers on board are connected through LAN.
Alternately vessels fitted with Amos- Crew connect or similar software may already be
using this facility. Ships that do not have computers connected through LAN / Wi-
Fi or do not have the Amos Crew Connect / similar software should contact the
vessel’s superintendent for assistance.
Personal E mail will be permitted for the crew of the vessel provided following are
complied with.

Attachments to the private E mail are not permitted.


E mail messages shall be in textual content only and limited to 10K in size (approximately
3 pages of A4).
No abusive words or potentially defamatory statement is included.

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19.8 SHIPPALM (COMPANY INHOUSE SOFTWARE)


Company uses in house software “Shippalm” to report record and monitor its
various ship management activities and processes. At present Shippalm process modules
comprises of:
Document Management System
Incidents
Internal Audits
SIRE Inspections
VIR
SCMM
Navigation Audits
Superintendent Inspection
External Audits
PSC Inspections
Terminal/Charterers/Owners inspections.
Defects
PMS
Purchase
Crewing
Certification
COC
Dispensation
Daily Reporting
Voyage performance
Other processes that are paper/email based are in development stage for conversion to
software.
All content uploaded into the Shippalm database constitute the latest and most up to date,
controlled versions on the SMS documentation
Crew and officers are trained / briefed on applicable Shippalm process modules.
“Shippalm” may be temporarily substituted by paper-based systems during
implementation phase, during computer break downs or on vessels where sale or similar
circumstances is pending.

20 ROLE OF FEEDBACK IN POLICYMAKING


As a part of the HSSE excellence initiative, feedback is considered essential for continual
improvement of processes. Involvement of key personnel in policy making in way of
feedback is critical.

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20.1 SOURCES OF FEEDBACK


Feedback is received from the below sources but not limited to:
From Seafarers during attendance of courses in training centre.
From Seafarers during attendance of Pre-Joining familiarization.
From senior officers during office briefing.
From officers during Seminars.
From vessels safety committee meetings
From Masters ISM review.
From Senior management visits to vessels.
From safety meetings conducted during vessel superintendent visits.
From third party contractors that may address their concerns to Master onboard.
From vendors, agents, contactors.
From Customers.
Circulating industry and fleet incidents.
Industry alert bulletins.
Feedback from group companies.
Open reporting programmes.
From shore staff
DCR resulting from the above

20.2 FORM OF THE FEEDBACK


Feedback may be collected in the following ways;
In way of Feedback Form, no OF-MA-025 collected during interaction with seafarers in
training centre, PJF and office briefing.
Informal comments received during interactions with senior managers and vessel
superintendents
Comments documented in SCMM and Master ISM review.
Through in-house electronic media available to both shore and sea staff.

20.3 EFFECTIVE FEEDBACK


For feedback to be effective it must be:
SPECIFIC and address a particular area, where weakness in policy is felt or an
improvement is imperative for safe operations.
May be supported with examples.

20.4 REVIEW OF FEEDBACK


All feedback collected or received is directed to the CMS department, where it is analysed
and reviewed on a six-monthly basis in the management review. A DCR is raised for
effecting changes in the policy.

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ANNEX I
STANDARD PUBLICATIONS

Please refer QHSE Circular “STANDARD LIST OF PUBLICATIONS” for latest publications list.

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ANNEX II
STATEMENT OF CONTEXT – RELATED TO EXTERNAL AND
INTERNAL ISSUES

STATEMENT OF CONTEXT - RELATED TO EXTERNAL AND


INTERNAL ISSUES
Organization: Synergy Maritime Private Limited
Address: Synergy Maritime Private Limited., 4th floor
AKDR Tower, # 3/381, Rajiv Gandhi Salai
(OMR), Mettukuppam, Chennai 600
097, India.
Purpose: To monitor and review information about the
external and internal issues those are relevant
with established Integrated Management
System Policy.
Objectives: To define the external and internal factors that
the
organizations must consider when they manage
risks.
External Context:

Legal Stringent requirements and regulations from


the following:
Authorities – Port States, Flag States, and other
government authorities boarding the vessels
Charterers and their agents
Terminals and Ports
Industry regulatory bodies such as IMO,
Classification Societies
Industry requirements (SIRE / TMSA) Legal
issues – arising out of claims
Technological Economic backdrop and changing Technology.
Not upgrading technology to the latest is a
threat (maximize errors).
Competitive Not understanding changing customer and
market needs
Market Not understanding the trends that is having an
impact on the
objectives. War and other acts that are beyond
the control of organization

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Cultural / Social Majority of the work force are from Indian


subcontinent and majorly Southern part of
India. With the opening of new branch offices
for manning, western and northern Indian crew
are joining the organization. Food habits and
language are an identified issue; however, they
are mitigated with having English as the
official language on board the vessel and in the
office.

STATEMENT OF CONTEXT - RELATED TO EXTERNAL AND


INTERNAL ISSUES
There are vessels with mixed crew, Food and
language are the
major concerns when having mixed nationality
on board.
Economic Volatility of currency i.e. Rs. Vs. USD.
Others Upcoming requirements of international
conventions like IMO Requirements, SOLAS,
MARPOL Convention etc.
1. Internal Context:
Values Planning of individual developments through
training, preparing them for higher level of
responsibilities and professional competences.

Ensuring harmony across the group keeping


different cultural backgrounds in mind.
Culture Ensuring harmony across the group keeping
different cultural backgrounds in mind.
Ensuring that the ship and shore staff are
adequately
motivated.
Knowledge Identifying and employing suitable qualified
individuals. Identifying and providing
appropriate training to ship and shore staff
Ensuring the processes are appropriate and does
not result in another risk
Performance Challenges in complying with the stringent
Local/ National/ International regulations.
Ensuring effective communication across all
levels of the organization, both on shore and on
vessels

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Identifying and readying up to the challenges of


Market demands
Identifying and working with Subcontractors to
enhance the
system improvement.
EHS To ensure environment, health and safety of
work force specially in case of their
dissatisfaction level after occurrence
of incident, if any.
Finance Ensuring adequate financial resources are
available to
effectively implement the management system.
2. Interested Parties:
Interested Parties Requirements / Needs Expectations
of of Interested
Interested Parties Parties

STATEMENT OF CONTEXT - RELATED TO EXTERNAL AND


INTERNAL ISSUES
Ship Owners and To provide technical Ship
their customers management services Owners -
Not to
Charterers
exceed the
Bareboat To enhance growth budget that
Charterers and profitability of the is agreed
company between
Sub Charterers
the Ship
Ship Agents Owner and
To implement the
Occupational Health Company.
and Safety standards Maintain
(IMO/ILO regulations, the assets
national and local to the
regulations, and highest
company standards) standards
in the
industry
To implement and to
Environmental entire
Management standards satisfactio
(IMO regulations, n of the
national and local customer
regulations, and
company standards)
For the

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Charterers
/ agents -
To ensure
safety of
cargo and
Environme
nt;
Maintain
the assets
to the
highest
standards
in the
industry
and to
entire
satisfactio
n of the
customers.
Charterers
- To
ensure safe
and secure
transportat
ions of
goods.
For all
above
parties:
Maintain
ships in
clean and
hygienic
condition.
No
accidents/i
njury of
any type.
No
outbreak
of any
infectious
diseases.
Zero
MARPOL/
Ballast
water
related
violations.

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Reduction
in
emissions.
Promote
eco-
friendly
activities.

STATEMENT OF CONTEXT - RELATED TO EXTERNAL AND


INTERNAL ISSUES
Agents/Service Generation of regular Long
Provider business and fulfil the term
required specified by relations
/ Sub contractor
the organization. hip,
regular
business,
Implementation of prompt
Occupational Health exchange
and Safety standards of
(IMO/ILO regulations, informati
national and on and
local regulations, and timely
company standards payment
of
service
rendered.
Ships to
be
maintain
ed in
clean and
hygienic
condition
. No
accidents
/Injury of
any type.
No
outbreak
of any
infectiou
s
diseases.
Insurers Premiums to be paid in To
time ensure
the
and insurance to be
safety of
maintained at all times.

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people,
assets,
and
environm
ent.
Regulators and Comply with To
their appointee IMO/ILO regulations, operate
national and in
Flag State
complian
local regulations,
Port State ce to
company’s, and
Classification internatio
Classification
Society nal,
Society’s requirements
national,
Certification with respect to QHSE
and local
agencies/authorit standards
regulatio
ies n with
valid
certificati
ons.

Timely
inspectio
n/survey/
audit
regimes
on
vessels
and
shore
establish
ments.

Effective
communi
cation
exchange
,
submissi
on of
documen
ts/reports
etc.

Ships
should
always
be
seaworth
y and

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maintain
ed.

No
accidents
/Injury of
any type.

No
outbreak
of any
infectiou
s
diseases.

Zero
MARPO
L/Ballast
water
related
violation
s.

STATEMENT OF CONTEXT - RELATED TO EXTERNAL AND INTERNAL


ISSUES
Reduction in emissions.
Ship and Continuous Motivation, career
Shore Staff Employment progression and self-
improvement.

To provide safe and


healthy work Adequate office support
environment to maintain workplace
safety and health, and to
comply with applicable
To provide adequate environmental
guidelines and regulations.
resources to meet
environmental
regulations/standards
Labour Worker’s right as To ensure compliance of
Union defined under different worker’s related
rules and regulations regulations and
agreements.

Adequate office support

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to maintain workplace
safety and health.
Promote crew welfare
and mental health.
Cargo Safety and security of Effective communication
Interests the cargo, port, and the and co-operation for safe
terminals. and secure operations.
Ports
Terminals
Implementation of Ships to be maintained in
Shippers
Occupational Health clean and hygienic
Charterers and Safety standards condition.
(IMO/ILO regulations,
national and local
regulations, and No accidents/Injury of
company standards) any type.

Implementation of No outbreak of any


Environmental infectious diseases.
Management standards
(IMO regulations,
national and local Zero MARPOL/Ballast
regulations, and water related violations.
company standards) Reduction in emissions.
Owners / Growth and
Shareholder profitability of
s
the company

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ANNEX III
MONTHEND REPORTS IN SHIPPALM
All vessels are submitting month end reports via email. To facilitate easy access to the month end
reports, we have created a module in the ship palm for submitting month end reports.

We request all vessels to submit the month end reports henceforth via ship palm Module 3 Forms
and Checklists.

Please find below Ship Palm Vessel Version 1.10.0.0 Module 3 “Forms and Checklists”
Shippalm being used as a system for internal audit tracking and close-out. For further
clarification, please contact shippalmsupport@synergyship.com

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ANNEX IV
ISO REFRENCE TABLE

ISO ISO 14001:2015 ISO Reference


9001:20 45001:2018 Manuals
15
Context of Organization
4.1 4.1 4.1 SMM Ch.
Organiza Organization Organization 1.1
tion Context Context
Context
4.2 4.2 Relevant 4.2 Relevant SMM Ch.
Relevant Interested Interested 1.3
Intereste
Parties Parties
d
Parties
4.3 4.3 4.3 SM E S
Manage Management Management M MS M
ment System Scope System Ch. M
Ch.
System Scope 1.2 C
Scope 1.8 h.
1.
8
4.4 QMS 4.4 EMS 4.4 OH&S SMM Ch.
Processe Processes Management 1.7
s
System
Leadersh
ip
5.1 5.1 Leadership 5.1 SMM Ch.
Leadersh and Leadership 2.2
ip and and
Commitment
Commit Commitment
ment
SM E S
M MS M
5.2 5.2 5.2 OH&S
Ch. M
Quality Environment Policy Ch.
1.3 C
Policy Policy
2.1 h.
2.
1
5.3 5.3 Roles, 5.3 Roles, OPM Ch.
Roles, Responsibilities Responsibilit 1.3 - Shore
Responsi /Authoriti ies/Authoriti SMM Ch. 18

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bilities/A es es - Ship
uthoritie
s
5.4 HSM Ch. 5,
Consultation 5.4.3, OF-
& MA-056
Participation
Planning

6.1 6.1.1 Address 6.1.1 SMM Ch.


Address Risks & Address 7.3
Risks Risks &
Opportunities
and
Opportunitie
Opportu s
nities
SM E
M MS
6.2.1 6.1.2 6.1.2 Hazard H
Ch.
Quality Environmental Identification Ch. S
2,
Objectiv Aspects M
3.1
es An C
nex h.
1 10
6.2.2 6.1.3 6.1.3 Legal SM E S
Planning Compliance & Other M MS M
to M
Obligations Requirement Ch. Ch
achieve
s 3 1 C
objective h.
s 2
6.3 6.1.4 Planning 6.1.4 SM SM S
Planning Action Planning M M M
for Action M
Ch Ch.
change
11 2 C
h.
2
6.2.1
Environmental
6.2.1 OH&S SMM Ch. 3
Objectives
Objectives
6.2.2 Planning 6.2.2
to Achieve Planning to
SMM Ch. 3
Objectives Achieve
Objectives
Support

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7.1.1 7.1 7.1 SMM Ch. 6,


Resources - Resources Resources OPM CH
General
1.4, CH 5
7.1.2 People 7.2 7.2 SMM Ch. 6,
Competen Competen OPM CH
ce ce
1.4, CH 6

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APPENDIX I
COMPANY CODE OF CONDUCT

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TABLE OF CONTENT
Section 1
1. Synergy Personal Responsibility
2. Manager Responsibility
3. Health, Safety and Environment
4. Labor Standards
5. Equal Opportunity
6. Engagement of third parties
7. Anti-corruption policy
8. Interaction with government officials
9. Harassment and Bullying
10. Protection of assets
11. Use of IT and electronic communication.
12. Information management
13. Disclosure and business communications
14. Personal data privacy
15. Conflict of interest
16. Reporting and recording
17. Visual Branding

Section 2
1. Professional conduct at workplace
2. Individual conduct at workplace

Section 3
1. Conduct while at sea
2. Serious misconduct

Section 4
1. Violation of code

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PURPOSE
Code of Conduct is to help Synergy Group members to make the right decisions and
remain true to our core values.
This publication guides to refresh individual knowledge and provide sound advice to come
out clean from the situations.
These core values are the base of the company and thus they are non-negotiable.
Personal commitment to these codes & compliance ensure our performance and earning of
reputation in highly competitive ship management environment.
Everyone shall not allow complacency to put yourself at risk of breaking the rules or
creating unacceptable risk for you, your colleagues and to the management.

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APPLICATION

This Code applies to Synergy personnel


Ship personal sailing under the management of Synergy Group.
Office staff who are employed by Synergy Group.
Contractors and consultants who are agents of, or working on behalf of, or in the name of a
Synergy Group.

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CORE VALUES

Our core values are the deeply held beliefs and are the seeds of our organizational culture.
They serve as a compass for our actions and describe how we behave both individually
and collectively. Our anagram for the core values- i-STEER Synergy, helps embedding of
the core values into each individual in our organization. By living these values,
“SYNERGY” aspires to set a high standard of excellence worldwide.
Integrity is the core value that will define our organization and the way we do our business
at all times – during period of success as well as during challenging times. As an
organization, we will not associate or be a party in any unethical or corrupt dealing or
practice.
Safety is our business as well as our commitment and future. It is paramount in everything
we do. We continuously work towards setting new industry standards in safety of people
and environment.
We believe in being proactive, direct, and honest in our communications with all
stakeholders. We consider transparency a critical factor in building lasting relationships.
People are our biggest assets. Empathizing helps in understanding the individual as well as
the environment that he is in. Empathy, as a part of the just culture enhances the safety
culture.
We believe in empowering people with courage, freedom and confidence to take right
decisions. We encourage them to be accountable for their actions even when they commit
mistakes. We believe that constructive learning from mistakes is the best way of
improving and empowering oneself and the organization.
We believe that respect is the foundation of a good organization. At Synergy, all our
actions are driven by respect towards self, others and environment. As a company working
in diverse geographies, we respect the diversity of culture and ideas. We also respect and
comply with laws and regulations in different regions.

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JNM MOTTO

We believe that “The whole is greater than the sum of its parts”. Synergy based on mutual
trust and confidence is our key strength – and we constantly strive to align our individual
abilities to achieve organizational goals and shared vision.
By living these values, “SYNERGY” aspires to set a high standard of excellence
worldwide.

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SECTION 1 - RESPONSIBILITY
This Section is applicable to:

 Ship personnel
 Office staff
 Contractor and consultants

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.1 JNM PERSONNEL RESPONSIBILITY


Read and comply with this Code of Integrity.
Understand the risks in your role and how to manage them.
Seek advice when things are not clear.
Make sure that any third-party contractors, agents or consultants you work with are aware
that we are bound by our Code and that they should act accordingly.
Speak up. It is our duty to report any suspected violations of the Code.
In any dilemma follow this self-exercise

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.2 MANAGER RESPONSIBILITY
Manager – Vessel Senior Management and Office Key Staff
 Managers must display visible compliance in following code.
 Maintain environment on board where people are complying to company values &
ethics.
 Create the atmosphere where people always strive opting the right approach to
achieve their objectives and feel confident about speaking up.
 Understand the main Code violation risks and the procedures to mitigate them.
 Forbid yourself from any action through which vessel can get the tacit acceptance
to take deviation from the core values & ethics.
 Be alert to any violations of the Code and encourage your team members to speak
up if they know or suspect a violation.
 Support team members who make good faith reports and ensure there is no
retaliation for escalating potential wrong doings.
 Ensure your staff understand the procedures they should follow to avoid violating
the Code, including recording gifts and hospitality and potential conflicts of
interest in the Code of Conduct.
 Briefing on requirement of code to new member of organization and advising
them for the support they have in meeting the conduct.

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.3 HEALTH, SAFETY AND ENVIRONMENT (HSE)


Our aim is to Zero Injury, Zero Damages and Zero Pollution.
3.1 Organizational Requirement
 Each group company is expected to set suitable targets for HSE improvement.
 Appraise themselves with the progress and report performance levels.
 Strive for continuous improvement to make work environment safer.
 Incessant effort in reducing the environment emission.
 Integration of technology in work system to simplify the life of seafarer.
3.2 Individual Requirement
 Comply with set rules, standards, and procedures.
 Adherence to Safety, Security and Drug & alcohol policy.
 Raise the voice in unsafe or non-compliant situation.
 Report accidents and injuries.
 Take actions to identify hazards.
 Established mitigating measures to minimize the effect of hazards.
 Set up the action plan to restore normalcy in any difficult scenarios.
 Analyse the incidents to identify the root cause and learn from them.
 Always remain prepared for extreme conditions.
 Improve the skills of co-workers.

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.4 LABOUR STANDARDS
Our established policies and standards help us create fair labour practices and a positive
work environment.
Prohibition of child labour: Involvement of individuals under the age of 18 for Synergy
business is strictly prohibited. We must adhere to legal minimum age requirement of any
nation where we operate.
Prohibition of forced labour: Any use of forced labour, slavery, servitude, or trafficking in
human beings is strictly prohibited. All Synergy personnel are entitled to accept or leave
their employment freely. Our company will not require Synergy Personnel to work to
repay a debt owed to them or to a third party.
Employment against payment: Employment must be offered to competent deserving
candidates based on merit. In order to obtain employment, we will not do any of the
following :
Withholding identity papers or work permits,
Requiring workers to deposit bond, money or any items of monetary value,
or use of any other constraint is strictly prohibited.
Prohibition of illegal, clandestine, and undeclared employment: We shall comply with all
applicable regulations to prevent illegal, clandestine, and undeclared employment.
Freedom of association: Our company respects and recognizes the right of workers to
negotiate collectively and to create or join labour organizations of their choice without any
sanction, discrimination, or harassment.

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.5 EQUAL OPPORTUNITY
We have equal opportunity policy for everyone. This helps us to ensure availability of best
possible resources and adequate quantity of competent pool.
Sometimes people can breach equal opportunity policies without even realising it – for
example, if they are unconsciously biased towards recruiting people similar to themselves.
Therefore, employment related decisions must be based on objectives & geographic
legislations and should not be taken under the influence of personal feelings, prejudices
and preferences of the employer.
Employment decisions which includes hiring, evaluation, promotion, training,
development, discipline, compensation and termination will t be based solely on objective
factors, including merit, qualifications, performance and business considerations.
Diversity has its own value and advantages. Discrimination based on race, colour, religion,
age, gender, sexual orientation, gender identity, marital status, disability, ethnic origin or
nationality is intolerable.

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.6 ENGAGEMENT OF THIRD PARTIES


Our company respects international human rights standards & frameworks and works to
ensure that we do not infringe on fundamental human rights through our operations,
services, or business relationships. We believe every synergy personnel should be treated
with trust, respect, and courtesy. Our company is committed to foster a work environment
that is fair and safe, where the rights of all are respected and everyone can achieve their
full potential.
Also, Synergy staff will collaborate with contractors and suppliers who are economically,
environmentally & socially responsible. Service provider found involved in any human
right violation directly or indirectly must be barred from future services.
Contractors and suppliers will be collaborated based on initial background & security
screening according to company standard. This initial check will be followed by periodic
audits for assurance.
Engagement will have a signed written contract explaining the service being provided for
legitimate business.

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.7 ANTI-CORRUPTION POLICY
7.1 Policy Statement
Synergy personnel shall not involve in any form of corruption or bribery either directly or
indirectly. Synergy personnel must decline any opportunity which would place our ethical
principles and reputation at risk even if it may result in the Company losing business or
otherwise suffering a disadvantage.
Everybody has the responsibility to report corrupt behaviour. Turning a blind eye to
suspicions of bribery, corruption or money laundering can result in liability for Synergy
and for individuals.
This policy is applicable for all business activities and collaboration with government
authorities, independent organization, commercial enterprise, or any private service
providers.
7.2 Policy Understanding & Compliance
7.2.1 Corruption
Dishonest behavior by those in positions of power for business or personal gain. It can
include giving or accepting bribes or inappropriate gifts, double-dealing, under- the-table
transactions, manipulating elections, diverting funds and laundering money.
7.2.2 Bribery
A bribe is an illegal or unethical gift or lobbying effort bestowed to influence the
recipient's conduct. Bribery is performed through giving, offering, soliciting, or receiving
(or attempting to give, offer, solicit, or receive) any item of value to influence the actions
or behaviour for the purpose to obtain commercial advantage. Bribery can take a variety of
forms and may include common business practices or social activities, such as providing
gifts, entertainment, travel, and hospitality which can fall under category of bribery in
certain circumstances.

Prohibited for JNM Personnel


 Giving or receiving cash or cash equivalent (such as gift certificates/cards),
stock and personal property to support synergy business.
 Forgiveness of a debt without proper authorization
 Charitable contributions—if made to a charity at the direct request of a
government official or private business partner, it could be considered an
indirect bribe made in order to obtain or retain business or to secure other
improper business advantage.
 Job offers or internship awards—offers to Government Officials (or their
relatives) can present a risk of violating anti-bribery or anticorruption laws and
regulations. Compliance must be consulted prior to making such offers

7.2.3 Gifts
Means items of value or benefits of any kind given to someone as a sign of appreciation or
friendship without expectation of receiving anything in return.
7.2.4 Hospitality & Entertainment
Facilitation of services for individual or team recreation.
Expectation from JNM Personnel
 Acceptance of gifts, hospitality, or any form of entertainment facilitation from

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service providers or third parties is prohibited except acceptance of small


promotional corporate gifts and hospitality.
 Providing gifts, hospitality & entertainment to third parties or within
organization must be proportionate to the occasion.
 All Gifts, Hospitality, Travel and Entertainment must be given openly and
transparently and must be properly documented.
 Director permission is necessary for such facilitation.

7.2.5 Facilitation Payment


Facilitating payments are payments made to public, organization or government officials
with the intention of expediting an administrative process and to benefit party making the
payment.
7.2.6 Extortion
Practice of obtaining something, especially money, through force or threats. This is
generally practiced in form of threatening to penalize for noncompliance of local
regulation

7.2.7 Double-Dealing
Practice of pretending to act in a manner when intention is to act contrary. This is
dishonest behaviour for the purpose of deceiving the partner.
7.2.8 Money laundering
Money laundering is the illegal process of making legal any money generated by a
criminal activity, such as drug trafficking or terrorist funding, corruption etc. This can also
be explained as business involvement that has financial ties to organised crime.

7.2.9 Diverting funds


Means Misutilization of Funds for a purpose for which loan was not sanctioned. As
employees of Synergy you may be required to handle Company funds.

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.8 INTERACTING WITH GOVERNMENT


OFFICIALS
Government Official: Person acting in an official capacity or on behalf of government
entity, political office and representation of public international organization
Synergy promote transparent and lawful interaction with government officials. To
encourage such lawful interactions Synergy personnel must:
Ensure that they know the rules of the country in which they are operating and act in
compliance with local rules. This includes tender negotiations as well as entering into a
contract with them.
Never accept, give or promise anything that could be interpreted as intending to
improperly influence a governmental decision.
Synergy personnel must not use third parties, for example agents, consultants, or brokers,
to do what is not permitted to do ourselves.

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.9 HARASSMENT & BULLYING


Every Synergy person is expected to treat others with respect and avoid situations that may
be perceived as inappropriate.
Feedback, criticism and challenge must always be delivered in an appropriate and
respectful manner.
Power must not be misused for making intrusion into employee personal life.
In particular, be aware of cultural sensitivities – what is acceptable in one culture may not
be in another. It is important to be aware of and understand these differences.
It is the responsibility of each individual to challenge someone if his/her behaviour is
hostile, intimidating, humiliating or disrespectful.
Below mention are the understanding of the behaviours that falls under category of
Harassment and Bullying
9.1 Harrassment
Harassment in any form such as action, conduct or behaviour which is humiliating,
intimidating or hostile will not be tolerated. Following are strictly prohibited.
Making inappropriate jokes or comments.
Displaying offensive or inappropriate material.
Physically or verbally intimidate or humiliate others.
Sharing objectionable material through emails, text or social media.
Discriminatory remarks on the basis of sex, hierarchy, religion, physical disability,
nationality, or age.
- Unwelcome attention such as spying, stalking, pestering, overly familiar behaviour or
unwelcome verbal or physical attention.
9.2 Sexual Harassment
Sexual Harassment refers to any unwelcome sexual advances, requests for sexual favors,
and other verbal or physical conduct of a sexual nature when:
Submission to such conduct is made either explicitly or implicitly a term or condition of an
individual's employment, or Submission to or rejection of such conduct by an individual is
used as a basis for employment decisions affecting such individual, or Such conduct has
the purpose or effect of unreasonably interfering with an individual's work performance or
creating an intimidating, hostile, or offensive working environment.
Unwelcome Behavior is the critical word. Unwelcome does not mean "involuntary." A
victim may consent or agree to certain conduct and actively participate in it even though it
is offensive and objectionable. Therefore, sexual conduct is unwelcome whenever the
person subjected to it considers it unwelcome. Whether the person in fact welcomed a
request for a date, sex-oriented comment, or joke depends on all the circumstances.
Sexual harassment may include following. Such deeds are considered strictly unacceptable
and they will not be tolerated.
Use of offensive / obscene language.
Making obscene calls or sending / forwarding obscene mails.
Making passes / advances / comments on dressing of co-Employee’s physical appearance
in the office.

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Physical contact like touching or patting customers or co-Workers.


Misuse of one’s position / authority in office to ask or demand for sexual favours.
Display of obscene pictures and posters at the workplace.
Showing signs of over-friendliness with the other gender if it is unwelcome.
9.3 Bullying
Bullying is a form of harassment that includes hostile or vindictive behaviour, which can
cause the recipient to feel threatened or intimidated. Bullying may involve a misuse of
power or position and is often persistent and unpredictable.
Personal insult through following may be considered as examples of bullying:
Belittling or ridiculing a person, or his/her abilities, either in private or in front of others.
Sudden rages or displays of temper against an individual or group, often for trivial reasons.
Subjecting someone to unnecessary excessive or oppressive supervision, monitoring
everything, they do or being excessively critical of minor things.
Persistent or unjustified criticism.
- Setting menial or demeaning tasks that are inappropriate to the job or taking away areas
of responsibility from an individual for no justifiable reason.
Making threats or inappropriate comments about career prospects, job security or
performance appraisal reports.
Cyber bullying including inappropriate:
Suggestive and unwanted remarks.
Graphics or threat-centred, abusive emails.
Postings on social networks; and
Text messages.

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.10 PROTECTION OF ASSETS


Everyone is personally responsible for safeguarding and using company assets
appropriately. Employees are expected to take all preventive measures to avoid waste,
loss, damage, abuse, fraud, theft, misappropriation, infringements and other forms of
misuse of assets.
Be complete and accurate when reporting assets, liabilities, revenues and expenses.
Employee shall protect company assets given to them. Also, they must play their role in
protecting shared assets against misuse, lost or theft.
Report if someone is putting company assets at risk or using them inappropriately.
Respect assets of other employees.

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.11 USE OF IT AND ELECTRONIC


COMMUNICATIONS
Use of personal electronic equipment such as mobile or music system which can distract
the individual from carrying out his duties effectively, are prohibited in workplace.
Use of electronic equipment is barred in the work area where they present serious safety
risk.
For cyber security all official IT equipment must be maintained as ISMS manual.
In case of any threat to cyber security, ‘company information security officer’ of the
company has to be contacted immediately.
Personal use of company supplied IT equipment must be kept limited, occasional and
brief.
Synergy name or brand shall not be used in personal emails.
Employees should restrict their personal usage of the company’s Internet and e-mail
facilities as well as automation facilities available to them.
Sharing of IT equipment and company software login details is not permitted to
unauthorized users.
Unapproved modification or disabling of security setting / configuration of IT equipment
which result in deviation from company IT procedure, is not permitted.
Company IT equipment must not be used for access, store, send or post pornography,
indecent and offensive materials.
Online gambling and conduct of unlawful activities are forbidden on company IT
equipment.
You must only use approved internet-based services to store, process or share business
information.

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.12 INFORMATION MANAGEMENT


Employee shall assess the risks associated with any information handling so that they can
protect the distribution of information to unauthorized personnel.
When anybody create or receive information, they must assign it a confidentiality
classification and only share it with those who are entitled and permitted to receive it.
While working with third parties, employee must consider his authorization to share
information with others.
Employees are not to publish, post or release any information that is considered
confidential or not public on social media. If there are questions about what is considered
confidential, employees should check with their supervisor.
Employees may be invited to speak in professional forums or participate in conferences,
seminars, and on-line chats or write in professional magazines. Under all such
circumstances, employees must ensure that participation is with prior written approval
from the Director of the Company.
Social media use shouldn't interfere with employee’s responsibilities or any area of
duty.
Use of personal social media for business purposes is strictly prohibited.
Employee must not engage with the media on behalf of Synergy without disclosure
clearance from Media relation team.
All communications made directly to public either by print media or social media on
behalf of Synergy must be cleared by highest management authority in consultation with
media co-ordinator and legal team.
Every communication to the public on behalf of Synergy must be accurate in all material
respects, complete, relevant, balanced and in compliance with all applicable laws and
regulations.
Appropriate disclaimers must be used, especially when the communication contains
forward-looking information.

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.13 DISCLOSURE AND BUSINESS


COMMUNICATIONS
Synergy will share information relating to its performance, customers, outcomes of
meetings and discussions with employees at various levels on a ‘need to know’ basis.
In other words, information will be shared depending on the need for a person to use this
information to do his / her job. Before disseminating any information to colleagues /
outsiders every employee is expected to apply the same judgment on whether they ‘need to
know’.
Employee must not disclose information about business activities unless they are
professionally capable and authorised to do so.
Employee must not engage in casual conversation on sensitive or confidential matters with
individuals who are not a part of that project.
Employees are prohibited from entering into any kind of personal business contracts with
Synergy partners, business affiliates and companies.
They shall not send communications containing confidential information of any project
outside their working group for that project.
Only Synergy-approved social media channels are to be used for official business provided
user is approved and have received the required training.
Use of personal social media accounts for disclosing confidential business information or
other business program is strictly forbidden.
Individual using personal account on social media to discuss company matters shall use
disclaimer that content shared by him/her is totally based on personal ideology and
understanding.

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.14 CONFLICT OF INTEREST


A Conflict of Interest could be defined as a “situation that arises when a decision-making
authority is seen to have a personal stake in the outcome of the decision itself”.
Employees may find themselves in situations that are of the nature of creating a Conflict of
Interest. If in doubt, it is best to consult the Immediate supervisor / Manager concerned
before taking any decisions in such cases.
Participating in outside activities for enhancing talents and abilities outside jobs should be
lawful and free of conflicts with their responsibilities as employees of Synergy.
Employees are not permitted to set up part-time businesses or take up part-time
employment in any area as these will hinder their performance and clearly place them in a
conflict-of-interest situation. Only exception is teaching assignment with director
permission.
Employees pursuing such activities should ensure that:
The purpose should be to give expression to talent and stay in touch with
one’s hobbies and not for the motive of making money.
Employees should not solicit opportunities from customers using their relationships.
This should not be done during Company time or should not interfere with work.
Prior permission must always be obtained in writing prior to participating in such
activities.

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.15 PERSONAL DATA PRIVACY


Personal data is broadly defined as any information relating to an identified or identifiable
individual such as name and contact details. More private information, such as race or
ethnic origin, health data, sexual orientation, criminal behaviour etc is sensitive personal
data and subject to more stringent requirements.
Data shall be protected from inappropriate access or misuse. When it is to be transferred to
third parties, it must be appropriately safeguarded. If we do not comply with these
requirements, we risk causing harm to individuals and could face fines or litigation.
All customer and employee personal information is confidential and may not be disclosed
except as permitted by law and applicable regulations.
Identify the privacy risks before collecting, using, retaining or disclosing personal data for
any official purpose.
Limit the processing of personal data for specific, defined, legitimate purposes only.
When you process or share individual’s personal data within organization or to third party,
you must always inform them.
Personal data in possession has to kept up to date and disposed of when no longer
required.

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.16 REPORTING AND RECORDING


Truthful Reporting
Report issues, and actions to address them, transparently and accurately and in accordance
with applicable Company policies and standards.
Employee shall not falsify or delay information gathering during an investigation or
enquiry.
Never misstate the truth or conceal information, whether on behalf of the company or for
personal gain.
Records Management
Write clearly, professionally and accurately in all documents (e.g., emails, texts, memos,
reports and financial statements).
Take responsibility for the integrity of records you create and manage. Retain them in
compliance with records retention schedules and our policy.
Employee must not unlawfully conceal, alter or destroy documents.
Do not destroy or alter any records that are covered by a “legal hold” initiated by the Legal
Division.

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.17 VISUAL BRANDING


Synergy staff must use brand logo and trademarks appropriately.
Any alteration in colour, aspect of the logo or tag lines is not allowed.
Template of the official background shall strictly follow the visual style guidelines of the
company.
Superimposing of brandmark over photocopy is not allowed.
Any content with the brandmark has legal implications, so their use shall be limited to
official purposes only.

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SECTION - 2
This Section is applicable to
 Office staff
 Consultant and contractors

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.1 PROFESSIONAL CONDUCT AT WORKPLACE


Following will be considered serious misconduct at workplace and will result in
disciplinary actions:
Absence from work without informing your supervisor in charge.
Habitual absence without applying for or securing sanctioned leave or absence without
leave for more than ten consecutive days or overstaying the sanctioned leave without
sufficient grounds or satisfactory explanation.
Wilful slowing down of work in performance of work or abetment or instigation thereof.
Theft, fraud, or dishonesty in connection with company’s property or business.
Refusal or failure to comply with Company’s instruction to work in shifts and/ or in other
sections or divisions or any other place of business of the Company when so transferred or
required to do so.
Changing working place without orders or wandering away from assigned place of duty
during working hours.
Sleeping while on duty.
Wilful insubordination (including refusal or failure to perform work assigned) or
disobedience, whether in combination with another or any lawful or reasonable orders of a
supervisor
Refusal to accept a charge sheet, warning, memorandum, or any other communication
issued by the management.

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.2 INDIVIDUAL CONDUCT AT WORKPLACE


Below mention conducts are intolerable at workplaces:
Assaulting colleagues at or away from workplace.
Any act of violence at workplace.
Unauthorized possession of any lethal weapon in the Company premises.
Fighting or attempting bodily injury to another employee of the Company
Use of profane or abusive language to a supervisor or a fellow employee.
Exhibiting intimate relationship with colleague within work premises
A close personal relationship is defined as a relationship between individuals who have or
have had a continuing relationship of a romantic or intimate nature.
Discouragement of close personal relationships: Our company discourages close personal
relationships in the workplace or with partners and beneficiaries of our programs.

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SECTION - 3
This Section is applicable to
 Ship personnel
 Contractor and consultants

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.1 Conduct While at Sea


(For Seafarers, contractors, and company representatives)
1.1 Punctuality
is very important both for the efficient operation of the ship and to avoid putting extra
work on others. This is true of joining the vessel at the time appointed, returning from
shore leave, reporting for watch-keeping duty and all other work. Absence at the time of
sailing, in particular, may seriously delay the ship or even prevent her sailing until a
replacement is found.
1.2 Duties.
Every seafarer should carry out their duties efficiently to the best of their ability. Seafarers
have a right to be told clearly what their duties are and to whom they are responsible for
carrying them out; if in doubt, they should ask. Seafarers must also obey reasonable
commands and instructions.
1.3 Treatment of accommodation.
The ship is both a seafarer’s place of work and home. Therefore, both personal and shared
facilities and accommodation should be used appropriately with consideration for others.
1.4 Behaviour towards others
A person’s anti-social behaviour can be a nuisance to others on board. In extreme
circumstances, it can also place the ship and the crew at risk of danger. Such behaviour
includes but is not limited to excessive noise, abusive language, harassment, bullying,
aggressive attitudes and offensive personal habits. Seafarers should also be considerate
towards those who need to sleep whilst others are awake.
1.5 Conduct in emergencies.
In any emergency or other situation in which the safety of the ship or of any person on
board or the marine environment is at stake, the Master, Officers and Petty Officers are
entitled to look for immediate and unquestioning obedience of orders. There can be no
exceptions to this rule. Failure to comply will be treated as among the most serious of
breaches of discipline.

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.2 SERIOUS MISCONDUCT
The Company considers the following to be serious acts of misconduct to have been
committed, that may lead to dismissal from the ship if proved, to the reasonable
satisfaction of the Master:
 Assault
 Wilful damage to the ship or any property on board, or unauthorised disposal of
 Ship’s property for personal gain.
 Theft or possession of stolen property.
 Unauthorized possession of stolen property.
 Persistent or willful failure to perform duty.
 Conspiring with others at sea to impede the progress of the voyage or Navigation
of the ship.
 To be asleep on duty or failure to remain on duty if such conduct would prejudice
the safety of the ship or any person on board.
 Failure to report to work without satisfactory reason or absence from place of duty
or from the ship without leave.
 Breach of company rules and procedures relating to alcohol, drugs or smoking.
 While dealing with cases of serious misconduct, the relevant CBAs. Other related
union agreements and flag state requirements shall be duly consulted and
complied.
 Intimidation, coercion, and/or interference with the work of other employees.
 Behaviour that seriously detracts from the safe and/or efficient working of the
ship.
 Misconduct of a sexual nature, or other misconduct based on sex, affecting the
dignity of women or men at work that is unwanted, unreasonable, and offensive to
the recipient.
 Causing or permitting unauthorised persons to be on board the ship whilst at sea.
 Repeated acts of misconduct of a lesser degree after one or more warnings have
been issued.
 Abetting or conniving with others to smuggle or mis-declaration of, or failure. to
declare articles leading to seizure and/or fine to the vessel.
 Desertion or assisting others to desert.
 Being left behind by the vessel.

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JNM - SHIP MANAGEMENT MANUAL
(This section is specific to PT Jala Nusantara Mardika)
Rev No: 0.0
APPENDIX I Rev Date: 25 April 2023
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SECTION - 4
This Section is applicable to
 Ship personnel
 Office Staff
 Contractor and consultants

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JNM - SHIP MANAGEMENT MANUAL
(This section is specific to PT Jala Nusantara Mardika)
Rev No: 0.0
APPENDIX I Rev Date: 25 April 2023
Page: 1 0f 1

.1 VIOLATION OF CODE
Crew members are reiterated on their obligation to report any violation of company policy.
As much as possible, the confidentiality of anyone reporting a violation of any company
policy will be maintained. However, identity may have to be disclosed to conduct a
thorough investigation, to comply with the law, and to provide accused individuals their
legal rights of defense. Synergy will not retaliate against anyone who makes a good faith
report of a possible violation.
Reporting to be carried out to Director.
Name: XXXXX Contact Details: XXXX
Violations of any magnitude in compliance of policy will result in disciplinary action as
per the just culture and may result in dismissal from organization or legal action against
the convicted party.

Uncontrolled Document When Printed

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