Whistleblower Policy

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

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

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

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

• A criminal offence;

• Non-compliance with legislation and/or Company procedures, particularly in relation to health and safety at work or environmental protection;

• Dishonesty, either verbal or written (including intentionally maintaining official log books or records inaccurately);

• Malpractice or unethical conduct;

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

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

Navigation Policy

The safety of personnel, vessel, cargo, and the protection of the environment is the foremost objective in the navigation of managed vessels.

Navigational safety requires selection of courses and speeds that provide a margin of safety which takes into account all of the influences which could affect the vessel’s progress, and is dependent upon the prevailing conditions and location.

The Master is fully responsible for the safe navigation of the vessel. He should obtain all relevant navigational information and secure that all applicable International, National and local navigational Rules are followed, that all courses are planned in accordance with Company voyage planning requirements and that operating practices safeguard the vessel, its personnel and cargo.

The ultimate responsibility for safe navigation rests with the Master. However, this responsibility also extends to Officers and Crew, who must always be on the alert to prevent incidents. It is the duty of each crew member observing any situation which they feel may endanger the safety of personnel, the vessel, the environment, or the cargo or impact on flawless operations, to report their observations to the Officer of the Watch, or if circumstances dictate, to the Master. An investigation should be carried out immediately and action taken as necessary.

On each occasion and using all available means, the Master shall independently assess and verify the relevant information for all scheduled load and discharge ports/terminal/berths. Such verification shall include but not be limited to drafts and applicable under-keel clearances (UKC), in accordance with the requirements of SOLAS Chapter V, regarding Safety of Navigation and the Guidelines for Voyage Planning

• Safe progress of vessel shall be ensured by proper use of all navigational aids and equipment to frequently determine position of vessel when underway. The position fixing frequency should be such that the vessel cannot run into danger during the interval between fixes.

• Company’s vessels shall be navigated in:

o A prudent and safe manner at all times

o Strict compliance with COLREGS

o Compliance with applicable routing requirements

o Most efficient and economical (optimum) manner and seamanship practice

Regarding safe navigation the Company, has established procedures for sound and efficient Bridge Organisation, Passage Planning and Voyage Execution. The main objective of the procedures is to ensure all Company vessels passage planning and execution of voyages will be carried out, having the safety of the vessel, the crew, the cargo and the environment as the primary objectives. In order to achieve this objective:

• Navigation of the vessel shall be based on the Bridge Team Management concept, which is based on the elimination of “one person errors”.

• All Officers must be fully aware of the Company navigation procedures and COLREGS.

• All Officers must be familiar with their duties, the operation of all navigational equipment and the vessel’s maneuvering capabilities.

• charts, navigational publications and the relevant updates shall be regularly provided to all the vessels by sub contracted Chart Agents and updates shall be regularly carried out by the designated Officer onboard.

• Passage planning shall be prepared prior to voyage commencement and shall be approved by the Master. Execution of the voyage shall be based on the passage plan, with all necessary modifications which may be required, considering the weather, traffic and vessel conditions prevailing at any stage of the voyage

• ENCs are available and routinely updated

• All deck officers have undergone ECDIS generic training and completed the familiarization process (including type specific training to ECDIS installed on board), in accordance with IMO requirements

• All navigation watchkeeping officers must be competent in the control of safety parameters and alarm settings including alarm interrogation of ECDIS, prior to taking charge of a navigational watch.

• Maintain a strict implementation of the Company’s UKC Policy at all times

• Company expect Masters to give the Pilot every co-operation, but also point out that having a Pilot on board does not in any way diminish the Master’s responsibility for the safety of his ship

• Company fully supports the use of traffic separation schemes as a means of increasing safety margins for ships. In addition to IMO accepted schemes, Company also encourages compliance with the various voluntary schemes around the world

• Masters may enhance the Navigation Policy and Procedures set forth in this section through his standing orders, only by addition or expansion to ensure the vessel’s safe operation.

Company vessels shall provide safe, reliable and efficient marine transportation. The safety of Life and the Ship shall always take precedence over other considerations. Nothing in this policy or in any regulation issued by the Company should be construed as relieving any Master, Officer or Crew member of their responsibilities to exercise sound judgment at all times.

Occupational Health & Hygiene Policy

Company has determined that safety at sea, prevention of human injury or loss of life, and avoidance of damage to the environment, in particular to the marine environment, to property and impact to public shall always be given first priority.

Company is also committed to protecting the safety and occupational health of its employees and any person working (or providing services) for or on behalf of Company by making every effort to prevent work-related injuries, ill health and diseases, while managing associated risk aiming to achieve a zero incident working environment onboard the vessels and ashore.

Top Management supports Company's Policy via to:

• Comply with all applicable laws and regulations, and apply responsible standards where laws and regulations do not exist;
• Identify, evaluate and minimize occupational health and safety risks related to its operations that potentially affect its employees and any person working (or providing services) for or on behalf of Company or the public;
• Communicate Policy and knowledge about occupational health and safety risks to its employees and where appropriate to maritime community;
• Establish and maintain a workplace environment and culture that supports physical and mental healthy lifestyle choices and promote ‘care-for-people’ principles
• Respond quickly, effectively and with care to emergencies or incidents resulting from its operations, in co-operation with industry organizations and authorized government agencies;
• Undertake appropriate reviews and evaluations of its operations to measure progress and to foster compliance with this Policy, aiming at continual improvement of the management system;
• Work with government agencies and others to develop responsible laws, regulations, and standards based on sound science and consideration of risk;
• Implement programs and appropriate protective measures to control occupational health & safety risks;
• Work towards Achieving the objectives of the Zero Incident Industry.
• Promote a process approach and risk based thinking throughout the organization
• Comply with Stop Work Authority & Obligation procedures applied across the fleet without repercussion.
• Provide voluntary occupational health and safety promotion programs designed to enhance employees’ well-being and personal safety. These programs should supplement, but not interfere with, the responsibility of employees for their own health care.
• Lead by example & promote ‘working as a team’ principles.
• Foster, cultivate and preserve a culture of diversity and inclusion without tolerating any form of harassment or bullying
• Involve Company’s employees and any person working (or providing services) for or on behalf of Company in the decision-making process [participation], in accordance with the applicable procedure, and engage them in seeking advice before decision [consultation]

Information about employees obtained through the implementation of these programs should be considered confidential and should not be revealed to non-medical personnel except at the request of the employee concerned, when required by law, when dictated by overriding public health considerations, or when necessary to implement the Company’s Drug and Alcohol Policy.

Quality Policy

It is the Company’s Policy to earn the confidence of the shipowners, charterers, shippers and the marine industry in general by providing quality, professional ship management services, in a cost effective, safe and environmentally friendly manner, whilst being responsive to their needs.

In this respect, the Company has identified the safety at sea, prevention of human injury or loss of life, and avoidance of damage to the environment, to property and public as complimentary of quality. Company’s Safety Management System is designed to continuously improve also the quality of the services offered by the Company.

Top Management adheres next principles in support to this Policy:

• To provide safe, environmentally sound and cost effective services that meet or exceed the requirements of our customers, as agreed, protect their interests and fulfill their expectations; while ensuring effective and efficient compliance with prevailing statutory and regulatory requirements.
• To address within SMS the continuous monitoring of all aspects of the Company’s operation so that potential problems can be readily identified and appropriate corrective actions implemented
• To constantly learn industry best practices, and, where there is a clear benefit, such to be adopted by the Company.
• To develop and establish a mutually beneficial qualitative relationship between the Company and its suppliers in order to enhance the ability of both to create value;
• To manage all activities and related resources as a process in order to achieve more efficiently a desired result;
• To determine the inputs required and the outputs expected; the resources needed for these processes and ensure their availability;
• To determine the sequence and interaction of these processes and apply the criteria & methods needed to ensure the effective operation and control of these processes;
• To assign the responsibilities and authorities for these processes;
• To evaluate these processes and implement any changes needed to ensure that these processes achieve their intended results
• To establish and review objectives and targets with the aim of continually improving performance
• To make an analysis of data and information pertaining to Company’s Management System before taking any decision;
• To address the risks and opportunities that need to be addressed to give assurance that the Company’s management system can achieve its intended results; enhance desirable effects; prevent, or reduce undesired effects and achieve improvement;

The success of this policy is based on the management’s commitment to achieve employee engagement and continual improvement

Drug & Alcohol Policy

Recognizing that drugs and alcohol can impair ability to perform duties in a safe way, Company has adopted the policy that no seafarer, irrespectively of rank, will navigate the vessel, operate its equipment or perform assigned duty at any time while impaired by drugs or alcohol. Any seafarer found to be under influence of drugs or alcohol shall be immediately released from duty.

ALPHA GAS, recognizing the importance of the issue, has adopted the following Principles:

• The possession, use, trafficking and sale of drugs and any substance, which is defined as narcotic and is illegal, onboard the Company’s vessels is prohibited and is viewed as a severe offense.
• Use of prescribed drugs for medical treatment is allowed only under controlled conditions and following specific medical advice.
• Drugs kept in medical chest must be locked under Master’s responsibility and control.
• No spirits are allowed on board
• No crew personnel detected to be under the influence of alcohol or drugs is permitted to board a Company-managed vessel without being escorted
• Alcoholic beverages and spirits are not allowed in crew quarters.
• No consumption of alcohol is allowed when the ship is in port.
• Controlled consumption of beer only at sea is allowed as per Company’s Procedures, Flag Requirements and under Master’s responsibility
• Watchkeeping personnel must abstain from alcohol for at least 4 hours prior to taking over watch at sea.
• Blood alcohol content of 40mg/100ml or greater is considered as alcohol impairment.
• All officers and ratings are subject to pre-employment D&A test.
• Unannounced drug and/or alcohol tests will be carried out as per Company’s instructions.
• Equipment for alcohol test is available onboard all Company ships.

AG will take disciplinary action, including termination of employment, against anybody on board who is proven to:

• Have consumed banned substances at any time;
• Have consumed any quantity of alcohol during, or 4 hours prior to, the commencement of his scheduled duties;
• Be unfit for work due to the use of drugs or alcohol;
• Possess or be accessory in bringing aboard a managed vessel alcohol or any banned substance; or
• Have a positive trace in any drug random testing sample or a blood alcohol content equal to or greater than 40mg/100ml.

Any crewmember found involved in any drug or alcohol impairment related activity will be discharged at the first port of call and his/her future employment with the Company will be cancelled. Depending on the nature of involvement Authorities may be notified and/or legal prosecution may be initiated.

• Compliance with this policy is mandatory for all Company’s shipboard personnel, as well as, for all persons boarding the ship under any capacity.
• The Master is responsible to ensure compliance and enforce appropriate measures as per Company’s instructions.
• This regulating policy applies to all Company personnel during their employment period whether onboard or ashore.
• AG has also adopted the same ZERO TOLERANCE Policy for shore personnel, according to which Drug and Alcohol consumption, distribution and possession are strictly prohibited at Company’ s premises

Environmental Protection & Energy Efficiency Policy

Company is fully committed to conducting its activities in an environmentally responsible, energy efficient and sustainable manner and minimizing the environmental impact of its operations, through managing the environmental & energy matters as an integral part of its business.

Company’s top priority is the protection of environment and optimization of energy efficiency by aiming at achieving Zero Spills / Zero Releases to Environment, Reducing Permitted Emissions targets and Conserving Energy Efficiently. In order to achieve these objectives, the Company is committed to:

• Comply with all applicable legislation and other requirements to which the Company subscribes which relate to its environmental & energy aspects and strive, where practicable, to exceed compliance requirements.
• Establish an Environmental & Energy Management Plan, incorporated into its Safety Management System with the aim to continually improve Company’s environmental & energy performance
• Provide the framework for setting and reviewing environmental & energy objectives and targets and ensure the availability of information and of necessary resources for their achievement.
• To develop and provide our services in such a way as to minimize their environmental & energy impacts and improve their understanding at all stages by any of our customer and the international community, whilst ensuring they are safe for their intended use and efficient in their consumption of energy and natural resources
• Annually review Environmental Protection & Energy Efficiency Policy with the aim of being kept always updated
• Respond quickly and effectively to pollution incidents resulting from its operations, in cooperation with industry organizations and authorized government agencies.
• Engage with shipping industry organizations and relevant authorities and participate and support research initiatives with the aim of developing measures to minimize the shipping industry’s impact on the environment and facilitating energy efficient operations.
• Support and embrace industry initiatives towards reduction of greenhouse gas and sharing the strategy for shipping de-carbonization
• Communicate its Environmental & Energy Policy to the public and all persons who work for, or on behalf of this Company. Company shall not communicate externally any results about its energy performance, unless such is officially requested by an external third party and upon final approval by Top Management
• Support the purchase of energy efficient products and services and design for energy performance improvement;
• Document and communicate this policy to all persons who work for, or on behalf of this Company either ashore or on-board the managed / operated vessels and to make the same available to the public through its official website;
• Assess on a continual basis the environmental & energy risks associated with its operations, setting appropriate objectives and targets and implementing environmental programs to minimize the environmental impact of its operations by reducing waste, emissions and discharges, by minimizing its impact on biodiversity and by using energy efficiently.
• To be actively involved with, install and operate innovative environmentally friendly & energy efficient technology
• Promote environmental protection & energy efficiency awareness through the training and education of its employees.
• Transportation of clean energy

Anti-Bribery & Anti-Corruption Policy

It is the Policy of the Company to conduct business in an honest, sincere lawful and ethical manner. Acts of bribery and corruption are condemned and the Company is committed to act professionally, fairly and with dignity and integrity in all business dealings and relationships. This is irrespective of the exact time and location of any operation. Effective systems such as the auditing of accounts are in place to counter bribery and corruption.

In addition to the above principle the Company will respect the Law of the Country of Registry of the ships, the International Conventions related to the Law of the Sea and those local laws that have become known to us through the appointment of local Agents in foreign countries in an effort to counter bribery and corruption. Bribery and corruption are punishable for individuals committing a relevant offence and the Company could face severe consequences that could include imprisonment, fines and damage of its reputation.

The Company employees should always act on a good faith basis, enter into commitments that are feasible to be met, fulfill the Company obligations, never mislead people, never participate in corrupt business practices, and treat people with merit and respect. Sometimes ethical decisions involve dilemmas; in such cases it is necessary for the relevant issues to be brought to the attention of the Company management and employees should seek for instructions within the framework of this policy.

This policy is applicable to both shore and shipboard employees at all levels. The Company is seeking to prevent and face the challenges of bribery and facilitation payments by including in all time and voyage charters clauses based on the following model:

• Owners confirm that they / their Managers have a policy to prevent bribery and that this policy includes procedures which to the best of Owners’ knowledge and belief are adequate to prevent any such bribery by any member of their or their Managers’ organization or by any person providing services for them or on their behalf, including without limitation the Master and crew of the Vessel.
• Charterers confirm that they have a policy to prevent bribery and that this policy includes procedures which to the best of Charterers’ knowledge and belief are adequate to prevent any such bribery by any member of their organization or by any person providing services for them or on their behalf.
• For the purposes of this clause, a “facilitation payment” means a payment of money, goods or other thing of value to any governmental official or other individual in a similar position of authority or influence in any country for the purpose of expediting or securing the performance of a routine service or action. This definition applies even where the payment or other benefit is nominal in amount.
• Charterers confirm that their schedules allow time for Owners and/or the Master to test requests for facilitation payments which may be improper & to resist demands for improper facilitation payments.
• If the Master and/or crew are requested to pay any bribe or make any facilitation payment the Master shall have the right to issue a Protest. Any Protest issued in accordance with this sub-clause shall be copied to Charterers immediately.
• It is understood that where a bribe or facilitation payment has been requested and has been refused by or on behalf of the vessel, this may result in delay to the vessel and/or to cargo operations, and that those parties whose requests have been refused may raise false or irrelevant allegations against Owners and/or the vessel and/or Master and/or crew, and therefore it is agreed that if the Master shall have issued a protest in accordance with sub-clause (5), in the absence of clear evidence to the contrary it shall be deemed that any delay ensuing is the result of the refusal of a bribe or facilitation payment.
• (a) (to apply to voyage charters) All time lost as a result of a refusal by or on behalf of the vessel to pay any bribe or improper facilitation payment shall count as laytime or (if vessel already on demurrage) as time on demurrage.

  (b) (to apply to time charters) Delay as a result of a refusal by or on behalf of the vessel to pay any bribe or improper facilitation payment shall not be considered as time lost for the purpose of any off-hire provision.

Security Policy

It is the policy of the Company to provide a secure working environment by establishing and maintaining the required security measures to prevent unlawful acts covering all aspects of activities, which endanger the safety and security of persons, property, information systems, data and technology infrastructure across its organization.

Company has established procedures for identifying, mitigating and responding to security threats applicable to vessels, trading areas and shore based locations, while protecting information systems (hardware, software and associated infrastructure), their data and the services they provide, from unauthorized access, harm or misuse. Cyber Risk Management has both safety and security aspects with emphasis on managing the safety risks introduced by OT, IT and networks, as without appropriate technical and procedural risk protection and control measures, OT is vulnerable to disruption affecting the safe operation of a ship and protection of the environment.

Company shall provide the necessary support to the CSO, Master, SSO and I.T Security Officer, in order to fulfil their duties and responsibilities.

In support to this policy, Company is committed to:

• Provide security procedures and practices for ship’s & Company’s operations and to protect the security of the ship, ports, the wider community and Company’s & Vessel’s Information Systems;
• Establish safeguards to reduce the risk to visitors, crew and shore personnel on-board the Company’s ships;
• Actively promoting security awareness amongst Company’s personnel and improving security skills;
• Regular documented reviews and internal audits;
• Prepare contingency measures for emergencies relating to possible security incidents.
• Identify, assess and treat information security risks tailored to Company;
• Establish appropriate guidance and mitigation measures for security principles and threats;
• Protect the Company's & Vessel’s assets (incl. information) from all threats, whether internal or external, deliberate or accidental, to ensure operations continuity, minimize damage and maximize return on investments and relevant industry opportunities
• Manage cyber risks as part of the overall approach to safety management and protection of the environment

Social Responsibility Policy

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

• Accountability for the organization’s impacts on society and the environment;
• Transparency in the organization’s decisions and activities that have impact on society and the environment;
• Ethical behavior at all times;
• Respect, consider & respond to the interests of Company’s stakeholders & employees;
• Accept that respect for the rule of law is mandatory;
• Respect international norms of behaviour, while adhering to the principle of respect for the rule of law; and Respect human rights and recognize both their importance and their universality.
• Contribute to a better society by offering safer transportation & a cleaner environment
• Identify and promote its Values across the organization with the active involvement of its personnel (any person working (or providing services) for or on behalf of Company)
• Manage Human Behavior and Attitude and Utilize Risk Management Tools to address the Human Element
• Invest on Competency, Training and Professional Development of its people
• Promote Safety Culture across the organization investing on Credibility, Action-Orientation, Vision, Accountability, Communication, Collaboration, Feedback and Recognition
• Invest & maintain on a Learning Organization
• Promote a culture of supporting the health & wellbeing (physical & mental) issues of employees
• Seek for Stakeholders’ engagement

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

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

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

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

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