Statement and QE Policy

COMPANY'S POLICY STATEMENT (SMS - Issue 10 - 31.05.2010)

This policy refers to Fratelli d'Amico Armatori S.p.A. of Rome, hereinafter called the Company, and toits managed ships.

The Company, conscious of its responsibilities in this field, pledges its commitment to safety and environmental protection.

The Company establishes that all operations carried out by its personnel, both ashore and on board, will always be performed with the utmost care, with the view of reaching the following goals, hereinafter listed in order of priority, by practicing an effective zero-incidents and zero-spillsto sea policy:

1. to prevent physical injury and loss of life;
2. to protect the environment, in particular the marine one;
3. to ensure ships' safety and to maintain their technical and operational efficiency at the highest level;
4. to protect ships and crew against illegal practices;
5. to operate the ships and to transport the cargo safely and efficiently.

The Company aims to reach these goals trough a process of self assessment and continuous improvement.

The Company establishes that, whenever a conflict arises between commercial or economic interests and the above-mentioned goals, its Managers and ship Masters shall always decide and act by giving priority to such goals.

To reach its goals, the Company shall provide the necessary material and personnel resources, and shall define its organisation by assigning specific tasks and responsibilities, establishing qualifications and training requirements, and co-ordinating all offices in order to:

6. assess all identified risks to its ships, personnel and the environment and establish appropriate safeguards;
7. ensure the safe operation of the vessels and the protection of the environment in compliance with the applicable national and international regulations;
8. constantly improve the technical and operational training of the personnel, both on board and ashore;
9. ensure the highest maintenance standards on board all managed vessels;
10. always be prepared, both ashore and on board, to deal with emergency situations;
11. apply, whenever and as appropriate, minimum industrial standards.

The Company shall instruct all personnel of their specific duties and shall demand their full commitment in achieving the above-mentioned goals.

However, as far as ship operations are concerned, it is understood that on board the Master has the overriding authority to act or give the necessary orders for the protection of human life, for the safety of his ship and for the protection of the environment, whether these are in agreement or not with the procedures and instructions provided by the Company.

The Master is also responsible for reporting immediately to the Company any accident or non-conformity which may affect the safety of the personnel and of the ship or which may pollute the environment. Adequate means of communication are provided to this purpose.

The actual implementation of the Company's policy is regularly reviewed in order to ensure both that the appointed goals are reached and that its procedures and instructions are suitable and effective.

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QUALITY / ENVIRONMENTAL POLICY (QE Manual rev. 0.3 – 15.06.2010)

In today's shipping industry, the provision of quality services, prevention of accidents and preservation of the environment are complex and pressing issues in constant evolution.

Fratelli d’Amico Armatori S.p.A. (the Company) provides a professional ship management service in a cost-effective manner, in order to meet the customers’ requirements as well as fulfil its responsibilities towards its employees and the environment.

In this context, the Company has chosen to adopt the principles of an effective quality-environmental integrated system in compliance with national and international regulations, with ISO 9001:2008 and ISO 14001:2004 standards and in accordance with the requirements of the Italian law decree 231/2001.

The main objectives are promoting safety, quality and environmental culture, preventing any accident, protecting the environment against any type of pollution, satisfying all partners’ requirements and protecting personnel rights according to our Ethical Code.

In order to pursue the above mentioned objectives, the Company has established the following principles:

• Providing adequate resources to implement effectively the quality and environmental integrated system;
• Complying with all national, international rules and regulations (mandatory and voluntary) governing the marine industry;
• Promoting safe practices and maintaining a healthy working environment in order to prevent injuries, pollutions and property damage or loss;
• Evaluating the environmental impacts and identifying risks incoming from ship’s operations and company activities;
• Improving skills and behaviour of crew and shore-based personnel by appropriate training and development program;
• Promoting a safety / environmental emergency preparedness by specific drills and training;
• Monitoring quality and environmental integrated system continuously by measurable objectives and performance indicators;
• Ensuring sustainable development of our environmental performance, considering implementation of the best available techniques, where appropriate and where economically viable, and fully take into account the cost-effectiveness of such techniques;
• Meeting customer requirements as defined in the contracts and monitoring his satisfaction and acting on the results;
• Supporting the improvement of suppliers through an effective communication and partnership;
• Implementing and improving Quality and Environmental Integrated System continuously by periodical review, in order to ensure that the Company’s objectives are reached and achieved;
• Promoting and sharing ethical values through all organizational levels by Company’s Ethical Code application.

Top management provides evidence of its commitment to the development and implementation of the quality management system and continually improving its effectiveness by the availability of resources and ensuring that the quality policy is communicated and understood within the organization.