ISM COMPLIANCE MATRIX

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ISM COMPLIANCE MATRIX PROCEDURES COMPLIANCE WITH ISM No PROCEDURE ISM CP01 DOCUMENT CONTROL 11 CP02 CONTRACT REVIEW - CP03 MANAGEMENT OF CHANGE - CP04 COMMUNICATIONS 6.7 CP05 RECRUITMENT AND PLACEMENT 6.1/6.2/6.7 CP06 SEAFARERS TRAINING, APPRAISAL & FAMILIARISATION 6.3/6.4/6.5/6.6/6.7 CP07 SHORE BASED PERSONNEL RECRUITMENT, TRAINING & APPRAISAL 6.3/6.4/6.5 CP08 RISK ASSESSMENT 1.2.2 (.2) CP09 MOORING OPERATIONS 7 CP10 MAINTENANCE, INSPECTION & CONDITION MONITORING OF VESSEL 7/10 CP11 DRY-DOCKING & REPAIRS 10.1 CP12 EQUIPMENT CALIBRATION & TESTING 10.3 CP13 NAVIGATION 7 CP14 CARGO OPERATIONS 7 CP15 VESSEL PERFORMANCE REPORTING & MONITORING 7 CP16 PURCHASING & SUPPLIER ASSESSMENT - CP17 HEALTH, SAFETY MANAGEMENT & ENVIRONMENTAL PROTECTION 7/8 CP18 ACCIDENTS, SERIOUS ILLNESS & HAZARDOUS OCCURRENCE REPORTING & ANALYSIS 9 CP19 DRUGS AND ALCOHOL 6.2 CP20 FILING SYSTEM 6.6/11 CP21 NON-CONFORMANCE 9.1 CP22 CORRECTIVE & PREVENTIVE ACTION 9.2/12.3/12.6 CP23 MANAGEMENT ANALYSIS & REVIEW 12.2/12.5 CP24 INTERNAL AUDITS 12.1/12.3/12.4/12.5 Page 1 of 6

COMPLIANCE WITH ISM ISM MISSION STATEMENT - SCOPE & OF THE COMPANY MANAGEMENT SYSTEM 1 ORGANISATION STRUCTURE, RESPONSIBILITIES & ACCOUNTABILITIES 3.2/3.3/4/5 QUALITY - HEALTH, SAFETY & ENVIRONMENTAL PROTECTION 1.2.2 (.2)/ 1.4.1/ 2.1 SECURITY - EMERGENCY RESPONSE 8 NAVIGATION 7 CARGO OPERATIONS 7 VESSEL PERFORMANCE MONITORING 7 VESSEL MAINTENANCE INSPECTION 7/10 EQUIPMENT CALIBRATION 10.3 RECRUITMENT, TRAINING & APPRAISAL OF SEAFARERS 6.1/6.2/6.3/6.4/ 6.5/6.6/6.7 SHORE BASED PERSONNEL MANAGEMENT 6.3/6.4/6.5 DRUGS & ALCOHOL 6.2 PURCHASING - COMMUNICATIONS 6.7 CONTRACT REVIEW - DOCUMENT CONTROL 11 PLANNING OF PRODUCT REALIZATION 7 NON-CONFORMANCES, ACCIDENTS, HAZARDOUS OCCURRENCES & OCCUPATIONAL INJURIES AND DISEASES REPORTING, ANALYSIS AND CONTINUAL IMPROVEMENT 9/12.6 INTERNAL AUDIT 12.1/ 12.3/12.4/ 12.5 MANAGEMENT REVIEW 12.2 CUSTOMER FOCUS - BUSINESS ETHICS - COMPANY OBJECTIVES - SEQUENCE & MAPPING OF COMPANY PROCESSES - QUALITY RECORDS & FILING SYSTEM 11 Page 2 of 6

ESTORIL MANAGEMENT SYSTEM COMPLIANCE WITH LIBERIAN FLAG ADMINISTRATION S LIBERIAN ISM-001, Para. 5.2 ISM-001, Para. 5.2 ISM-001, Para. 5.3 ISM-001, Para. 5.5 ISM-001, Para. 5.6.1 ISM-001, Para. 5.6.2 5.6.3 5.7.2 5.7.3 5.8.1.1 5.8.1.3 5.8.1.4 5.9 Safety & Environmental Protection Policy must be signed by the Company s Chief Executive or other senior executive officer. Safety & Environmental Protection Policy should be reviewed at regular intervals. The Company who has assumed the responsibility for operation of a ship from the Ship owner should agree in writing to take over all the duties and responsibilities imposed by the Code. The owner, even if the entity responsible for the operation of a ship is other than the owner, must provide the Office of the Deputy Commissioner, Marine Safety Division, with the name, address telephone and fax numbers, and E-Mail address of the Company responsible for the operation of the vessel. The Company must designate a person or persons who will be responsible for monitoring and verifying proper operation of the CMS within the company and on each ship. The Company must provide Office of the Deputy Commissioner, Marine Safety Division, with the full name of the DPA and current information sufficient to enable direct and immediate contact at all times between the Administration and the DPA. The CMS should incorporate the elements of IMO Resolution A.443 (XI) Decisions of the Ship Master with regard to Maritime Safety and Marine Environment Protection Any system of operational control implemented by Company shore based management must allow for the Master s absolute authority and discretion to take whatever action considers to be in the best interest of passengers, crew, cargo, the vessel and the marine environment. The Company should provide the Master with documentation of the specific duties delegated to the officers under Master s command. The Company s Management System should ensure that joining crew members have proper seafarer s certification including licenses, special qualification certificates, seafarers identification and record books and training as required by international conventions, the Liberian Maritime Law, the Liberian Maritime Regulations and specifics of the publication Requirements for Merchant Marine Personnel Certification, RLM- 118. The shipboard CMS should include procedures for the transfer of command and documented hand-over notes. The shipboard CMS should include procedures for documented duties instructions, familiarization training in accordance with section A-I/6 of the STCW Code, 1978, as amended, for on-coming officers and crew, and on board documentation retention. A Master s Port Arrival / Departure Safety Check List should be included in the shipboard CMS incorporating pre-established Company policy guidelines for GO, NO GO situations and reporting requirements for the Master s compliance. The Ship s operations plans should include procedures to insure the required Liberian annual safety inspection is conducted on time and in accordance with the Maritime Regulations and Marine Notice INS-004. The ship s operations plans should incorporate the Maritime Regulations requirement for emergency drills and weekly training sessions. The Company s Management System must provide that statutory, Administration, or Company required emergency preparedness plans will be periodically reviewed and updated, and if necessary, reapproved by the Administration or an RO on its behalf. Page 3 of 6 Policy Manual, Sec. 05 CP17, par. 3.2./ CP23, Par.3.5 As per relevant notification As per completed RLM-297 Declaration of Company. Policy Manual, Sec. 03, CP17, Para. 3.2 and ERP, Appendix A As per completed RLM-297 Declaration of DPA. FIM, Chapter A, Para. 2.1 FIM, Chapter A, Para. 2.1 & ERP, Sec. 4.3 FIM, Chapter A, Para. 2&3 CP05, Par. 3.2.2 CP06, Para. 3.2.3, Forms: VC-03 CP06, Para. 3.2 & 3.3, CP20 (document retention) & Forms VC-01, VC-02, OC- 03, OC-07. CP13, Para. 3.3, Forms: VN-07, Preparation for sea and VN-13, Preparation for arrival in port CP10, Para. 3.2 & 3.3 CP17, Para. 3.3, FIM, Chapter B, Para. 5 and as per VS-10 CP17, Sec. 3.3.2 CP23, Sec. 3.5

LIBERIAN 5.10.1 5.10.2 5.10.3 5.10.4 5.11.1 5.11.2 5.11.3 5.12 5.13 The shipboard CMS procedures for reporting accidents and incidents should incorporate the provisions of Chapter IX of the Maritime Regulations (RLM-108) which require the immediate notice and reporting of incidents to the Administration and establishes duties and responsibilities for the Company, ship officers and crew. The CMS should also incorporate the provisions of Article IV and Article X of the Rules for Marine Investigations and Hearings (RLM- 260). The CMS should also incorporate the provisions of Maritime Regulation 10.296(7) on accident prevention and appointment of safety officer. The Company and shipboard CMS should contain procedures for immediately reporting Port State detentions to the Administration. The maintenance system established by the Company and documented in its CMS should include systematic plans and actions designed to address all those items and systems covered by class and statutory surveys and ensure that the vessel s condition is satisfactorily maintained at all times. As part of Company initiated ship safety inspections, the shipboard CMS should include reference to the Liberian annual safety inspections required by Maritime Regulation 7.191, as more fully described in Marine Notice INS-001, and use of Form No.338-1/00, the Operational/ Safety Checklist for SOLAS 74/78, or a similar Company developed form as addressed in Marine Notice INS-004. The CMS should also provide for the logging of actions or measures taken to rectify deficiencies and non-conformities noted during surveys and annual safety inspections and the giving of notification to the Administration and designated RO of the corrective actions taken. Documents should be easily identified, traceable, user friendly and not so voluminous as to hinder the effectiveness of the CMS. The Company must conduct internal audits shore and on each ship at least annually to determine whether the various elements of the CMS have been fully implemented and are effective in achieving the stated objectives of the Code. The internal audits are in addition to the annual, intermediate, and renewal audits carried out by the Liberian Auditor or an Recognized Organization CP18 and as per Forms: RLM-109, Report of Vessels casualty or accident and RLM-109-1, Report of personal injury or loss o life As above FIM, Chapter A, Para. 2.5 CP10 Para. 3.5 CP10 CP10 Paragraph 3.2 CP10 Paragraph 3.3.2 & Fire Fighting Equipment and Life Saving Appliances Maintenance Plans CP10, Sec3.2, Form: OS-07 CP01 CP24 Page 4 of 6

ESTORIL MANAGEMENT SYSTEM COMPLIANCE WITH BAHAMIAN FLAG ADMINISTRATION S BAHAMIAN BMA B66-12/04 BMA B21-12/01 Bulleting No. 72 rev.01 Bulleting No. 89 Bulletin No. 101, rev. 01 Bulletin No. 120 The vessel will be inspected by a Bahamas Maritime Authority (BMA) approved Nautical Inspector annually within three (3) months before or after the assigned anniversary date. A valid Bahamas Certificate of Inspection (COI) must be displayed at a prominent location either on the Navigation Bridge or within the accommodation. The Company shall ensure that all Bahamian ships carry copies of the latest merchant shipping legislation and the Officer s Guide. Enhancing Lifeboat Safety during Abandon Ship Drills: (a) The Master shall use his professional judgement to modify or postpone the drills that are required under SOLAS Ch. III Reg. 19.3. Full details of planned drills are to be entered onto the Official Log Book with reasons for the modification or postponement. (b) At ISM Audits, the following must be available on board: Manufacturer s instructions and recommendations The Company s procedures for maintenance and inspection Records of lifeboat drills Records of inspection and maintenance of equipment, including details of the competent persons undertaking the activity Failure to maintain any of these documents is considered to be ISM Non-Conformity and must be specially reported to the Bahamas Maritime Authority. The Company is responsible for assessing and selecting a suitable competent person emphasising on the training, development and motivation of the seagoing staff. Documentary evidence of personnel competence, e.g. records of training, study and assessment, must be available on board. Master shall include a Flag State file in his filing system. This file is to incorporate revised Bulletins and notices, together with a revised copy of the Bahamas National Requirements. The carriage of this document is to be verified during SMC audit. (BNR SOLAS Ch. IX Flag State File). Copies of these documents - in either hard copy or digital form are to be maintained for immediate reference onboard every vessel and in every shore office. The Company shall immediately notify the BMA, the Classification Society and/or Recognised Organisation issuing the affected certificate and the ISM issuing body, of any detention of a Bahamian registered vessel. In addition, the Company is required to invite the Classification Society and relevant Recognised Organisation on board to assist in clearing up the deficiencies. The initial report to the BMA must include: A full copy of the PSC report. Confirmation of notification to Classification Society and Recognised Organisations as appropriate. Advice of actions taken or planned to rectify all deficiencies at the earliest opportunity. Good communications are essential to enable prompt resolution of matters related to PSC detention. It is important that the BMA receive the initial report promptly so that an assessment of the detention can be made. The Company is required to perform a formal analysis of the root causes and take the appropriate corrective actions to prevent similar deficiencies arising in future. The report of this analysis and corrective actions (final report) is to cover all of the deficiencies raised at the detention and should also include comments from the Master or Chief Engineer on the deficiencies. The final report must be submitted to the BMA at the earliest opportunity, but not later than three weeks from the date of detention. Page 5 of 6 CP10, Para. 3.2 List of Publications FIM, Chapter B, Para. 5.2.1.1 Maintenance Plan for LSA FIM, Chapter A, Para. 1.4, 2.1 CP20 CP10 Para. 3.5

BAHAMIAN Bulletin No. 04 If the vessel is involved in an accident involving serious injury; loss of life; or damage to the ship, property or the environment the Company must report the accident to the Bahamas Maritime Authority. An Initial Report should be communicated to the BMA Casualty Investigation section within 4 hours of the Accident by telephone, fax or email. The Initial Report should give brief details of the casualty: Ship s Name, IMO Number Time of Accident Position Brief Description of the Accident In the case of serious marine casualty resulting in major damage, pollution, serious injury or loss of life outside office hours the Emergency Response Officer should be contacted. CP18 & Casualty Report Form (CRF-1) Page 6 of 6