Policies

Policies

A/S Dampskibsselskabet TORM (the Company) owns and operates a modern fleet of quality ships built using high construction standards and superior equipment. Our ships exceed international rules and regulations concerning requirements for double hull vessels and the use of hard light-coloured coatings.

It is Company policy to comply with statutory rules and regulations in order to ensure that all employees are able to execute their work under safe, healthy and proper working conditions.

The Company’s goal is to eliminate all known risks that may result in accidents/incidents, injuries, illness, damage to property or to the environment. The recognition of all potential risks is the backbone of our organisation, and concerted efforts are aimed at the prevention of errors, hazardous situations, and incidents at sea and ashore.

If such a situation should occur despite our efforts, every employee at sea and ashore is required to utilise our Safety and Improvement Reporting System, including the Accident/Incident, Near-Accident/Near-Miss, Non-Conformity and Suggestion for Improvement reporting programme. Employees must also participate in determining and eliminating potential causes of the incident in order to avoid re-occurrences.

Company Management believes that safety is best served through free and open dialogue and that this, together with our No Blame policy, helps prevent accidents.

The Company places the highest priority on its Safety Management System, strongly emphasising that each individual employee within the organisation must be totally committed to adhering to standards.

Management reviews the Safety Management System annually to verify its effectiveness and continually improve the system.

In order to achieve ultimate levels of safety and quality, Management has issued detailed policies that are an integral part of general Company policy. These include:

safety and quality management policy
security policy
environmental protection policy
purchasing policy
crew complement policy
vessel audit and inspection policy
personnel safety and health policy
work hour policy
drug and alcohol policy
media policy

These policies are implemented through processes described in the Company’s Safety & Quality Management System, which includes job descriptions, standing orders, instructions, forms, checklists, posters and via the distribution of relevant information.

The Designated Person has full authority to perform his/her duties as described in the ISM Code, is the link between the Company and the crew on board our vessels, and is guaranteed direct access to the Chief Executive Officer (CEO).

Ultimate responsibility in ensuring the implementation of and adherence to Company policies at all levels within the organisation remains solely with Management.

Company policy is required to be posted onboard all vessels in accordance with the Poster Location Matrix (Form ID 090-001).

Safety and Quality Management Policy
Safety and quality are fundamental principles of all industrial activities and the shipping business is no exception. The Company regards safety and quality with the utmost concern and seriousness.

Company policy stipulates that each employee at sea and ashore is instructed that his or her prime responsibility is to protect the Company, the employees ashore, the vessels and their crew, equipment and cargoes, in order to maintain and improve a strong safety and quality culture within the organisation.

Management shall participate in establishing proactive safety and quality campaigns, and support such activities.

The Company maintains its Zero Incident policy by monitoring and analysing all reported shipping incidents worldwide, and distributing lessons learned to all vessels and divisions in order to avoid re-occurrences of such incidents.

The Company is focusing on as low as possible Lost Time Accident Frequency, with zero being the optimal goal.

The Company arranges excellent safety and quality training at internationally recognised training facilities and holds frequent, realistic emergency drills with participation of internal and external sources. This is to ensure that safety and quality standards within the organisation are regularly monitored, analysed and maintained at a high level.

Management requires that Senior Officers and visiting shore management always lead by example in safety and quality related issues, and set a good example for vessel crew and others by wearing proper personal protection equipment (PPE) and complying with stated safety practices and procedures.

Security Policy
The Company is highly committed to security. Its vessel security plans establish that Masters have the overriding authority and responsibility to make decisions regarding vessel safety and security. In the event of a breach of security or loss by intentional destruction or theft, the Master may request the assistance of the Company or of any Contracting Government as may be deemed necessary.

Environmental Protection Policy
The protection of the environment is of the utmost concern to the Company. Management requires employees at sea and ashore to maintain a Zero Oil Spill at Sea policy.

Company policy requires the use of environment-friendly anti-fouling paints, the implementation of reuse, recycling and recovery of waste processes within the organisation, and work with suppliers and contractors to supply biodegradable packaging. This will assist in avoiding damage the global environment, people, wildlife and property.

In order to comply with statutory rules and regulations, detailed updated instructions and procedures are available onboard the Company’s vessels to ensure the proper treatment and handling of cargo, bunker and lubrication oils, paints, chemicals, solvents and other substances.

By assessing the risks of potential environmental impact by certain aspects of the shipping business, the Company has identified the following areas of primary concern:

oil and associated products
chemicals and solvents
nitrogen oxide (nox) substances
sulphur oxide (sox) substances
dangerous dry cargoes
shipboard and office-generated waste
ballast water handling
cargo vapors
halons, cfc’s and hcfc’s
tbt-based anti-fouling paint
co2 and partial emissions from vessels

The Company’s Safety Management System (QMS) is carefully addressing anti-pollution efforts and pollution caused by any of the above stated sources.

The Company’s Environmental Management System (QMS) focuses on continuous improvements to environmental performance and legislative compliance.

The scope of Company’s ISO-14001 system covers owned and partly-owned tankers under technical management by A/S Dampskibsselskabet TORM. All vessels in the fleet and all offices are required to follow environmental procedures and guidelines.

Purchasing Policy
Company policy ensures environmentally protective purchase and supply activities in support of waste reduction methods such as purchasing in bulk to reduce excessive packaging.

Management encourages recycling initiatives and the use of non-disposable equipment onboard its vessels.

The Company’s relations with its suppliers are characterised by mutual trust, understanding and honesty, and we prioritise the procurement of environmentally friendly products when available.

Suppliers receive comprehensive information regarding mandatory standards, price and quality, service and deliveries, including delivery irregularities.

Each vessel maintains an optimal spare part inventory, taking into consideration necessary stock of spare parts for critical equipment.

Crew Complement Policy
Company vessels operate in accordance and compliance with current internationally recognised rules and regulations. We employ fully licensed Danish and foreign officers and ratings who meet the requirements for service, age, medical fitness, training, qualifications and examinations.

The Company recognises and endorses STCW Convention requirements, and applies these requirements as a minimum for all employed officers and ratings.

The Company always employs officers and ratings with the best possible qualifications.

The Company provides career development for its junior officers, and aims to recruit senior officers within its own ranks whenever possible.

Officers and ratings must pass the required relevant training in order to obtain the appropriate certificates before being assigned to any given position on a vessel operated by the Company.

Personnel training and development is of the utmost importance. The Company encourages supplementary simulator-based training in engine and navigational safety, training in the handling of cargo equipment, courses in the handling of hazardous materials, and such like.

The Company maintains a schedule to ensure the monitoring and evaluation of employee competency, personal characteristics and dedication. The schedule calls for regularly conducting performance evaluations and reporting results that provide the basis for overall evaluation, promotions, call for supplementary training, warnings, dismissals, and such like.

English is the working language of the Company, and all crew members must be familiar with the English language, in particular with maritime terms and orders used onboard vessels.

Vessel Audit and Inspection Policy
The Company verifies that compulsory safety and quality standards are met by having Company representatives audit and inspect each vessel at requisite intervals.

Company representatives inspect the vessel, its equipment, crew and its operation, or audit the officers and crew according to the requirements of the SMS. Findings are reported to the vessel and the Company’s Safety & Quality Department in a written report.

Corrective actions of findings revealed during an audit or inspection are assigned to the relevant personnel within the organisation. Subsequent follow-up on the implementation of corrective action is verified by the Auditor or Superintendent.

Personnel Safety and Health Policy
In order to prevent accidents and work-related illness among its employees, the Company places the utmost importance on safe and healthy working conditions. Safety and the protection of health have the highest priority in the Company.

The Company has established procedures to protect its employees against exposure to dust, noise, cold, heat, chemicals and other dangerous materials, and clear instructions have been issued for the use of personal protection equipment onboard vessels.

It is required that Safety Meetings are held monthly, during visits by appropriate Company representatives, and in connection with extraordinary circumstances involving accidents, incidents, extreme temperatures and extreme working conditions.

The Company maintains a healthy catering policy, and supplies its vessels with high-quality fitness equipment. Employees are encouraged to use this equipment whenever possible.

If an employee becomes sick or injured onboard, the Radio Medical system is to be immediately contacted for advice. If the vessel is in or close to a port, local medical assistance will be requested.

Incidents must be reported to the Flag State Administration.

The rules and regulations issued by the national Danish Maritime Occupational Health Service covering safe and healthy work environments are part of this policy.

Work Hour Policy
Company vessels are operated according to and in compliance with current internationally recognised rules and regulations concerning with number the of work hours in a given time period.

The Company recognises and endorses the requirements of pertinent ILO-conventions and current agreements with associated labour unions and the STCW Convention.

The Company requires senior officers to organise and plan daily work operations and watch duties onboard, complying with relevant requirements.

Drug and Alcohol Policy
It is imperative that the operation of Company vessels are never subject to any consequences due to the abuse of drug and alcohol among employees.

The Company complies with the internationally recognised recommendations issued by OCIMF. The Company monitors its employees via regular examinations for drug and alcohol abuse. These examinations are being conducted by fully trained and authorised examiners.

In addition to a mandatory annual unannounced drug and alcohol test, the Company has arranged for an additional annual unannounced test to be conducted on 50% of its vessels, which are chosen at random.

In addition, the Company will at a randomly chosen time request Masters to perform an alcohol test and immediately report the result to Management.

Refusal to submit to a drug and alcohol test, a positive drug and alcohol test result, or violation of the drug and alcohol policy will lead to disciplinary action by Management, including immediate termination of employment.

Media Policy
No employee other than the Chief Executive Officer (CEO) or the Chief Financial Officer (CFO) may provide any information whatsoever to the media (news agencies, reporters, radio and television services), unless instructed to do so by the CEO or the CFO.

The Company has engaged Maritime Technical International Inc. (MTI Network) to provide media response management services and training. MTI Network may solicit any and all information from agents, correspondents and representatives concerning selected Company vessels.

_________________________
Klaus Kjærulff
Chief Executive Officer


9.6 Occupational Health
The Company has laid down a plan of action to improve occupational health onboard.

In close collaboration with the Danish Maritime Occupational Health Service and suppliers of material and equipment, key objectives are being defined and addressed, with the goal of making improvements. Substitutions of chemicals, paint and house-keeping products have been carried out, and new products are monitored continuously, as the improvement of occupational health is an ongoing process.Solutions for local exhausts or the proximity of equipment where the crew may be exposed to noxious gases have been installed, or will be installed when an effective solution has been found.

The Company is committed to the guidelines provided by the Danish Maritime Occupational Health Service, including Sector Specific Guidance referred as the Fall Arrest System.

The Company strongly encourages shipboard management to implement and utilise the tools provided, such as onboard safety initiation and risk assessment of work.

The Company’s newbuilding program requires the evaluation of specifications for vessel construction and equipment to ensure compliance with Company policy and flag state regulations.

A future Company task will be to focus on the psychological work environment by implementing a staff appraisal system to measure workplace satisfaction and uncover potential areas of improvement.