It is Varship Shipping Co. Ltd’s Policy to promote actions for the prevention of damage to the Environment and to carry out its operations in a safe and environmentally friendly manner.

We, the Varship Shipping Co. Ltd ’s top management and personnel, ensure that all our activities, regarding the ship operation, ashore and on board, will be systematically controlled against environmental criteria.

Constant Environmental Objectives for Varship Shipping Co. Ltd are:

• To provide for the prevention of pollution and for a safe working environment.
• To establish safeguards against all identified environmental risks.
• To minimise, if possible, the wastes, residues and emissions which are produced by its operations and to always manage them in the most environmental effective way.
• To continuously improve the Company’s environmental performance.
• To continuously cooperate with its suppliers and contractors for their environmental improvement.

We have developed and implemented an Environmental Management System according to ISO 14001:2004, in the terms of which we:

• Consistently follow all national and international rules and regulations governing the Marine Industry.
• Analyse all the environmental aspects of our activities, in order to plan and realize programs for continual environmental improvement.
• Control environmentally these parts of our operations which are carried out by our suppliers and co-operators.
• Employ suitably competent and qualified personnel who are capable of carrying out operations in a safe and environmentally friendly manner.
• Provide environmental training for our personnel to enable them to effectively utilize the Company’s procedures.
• Formulate corrective and preventive actions, from incident investigation and audit reports, to improve environmental management skills onboard ship and in the Company’s offices.
• Seek to ensure that contractors and suppliers conform to the Company’s safety and environmental requirements.

All company’s employees are responsible for implementing the Company’s Environmental Policy. The Company’s management is responsible for monitoring and reviewing the Environmental Policy at regular intervals in order to ensure that it remains relevant and effective.

Reviewed by the General Manager on 28/11/2006

Through its commitment to Quality - Safety and Protection of the Environment it is the policy of Varship Shipping Co. Ltd to ensure safety at sea, prevention of human injury or loss of life and avoidance of damage to the environment and to property. The Company aims to remain at the forefront in the established field of Ship Management by continuous improvement and innovation, providing all ship owners with ship management services which meet their needs and expectations consistently.

The Company is totally committed to achieving the Highest Safety Management standards throughout the managed fleet and help to protect the environment of the world wide trading areas. These High Standards of Quality and Safety will be achieved by operating a Quality System which meets the requirements of EN ISO 9002(1994) regarding Quality Assurance and the International Maritime Organisations ISM CODE Res.A.741 (18) (4I11/1993) which sets Safety Management Standards for operating ships.

In implementing this policy, the Company not only complies with relevant legislation, but also encourages other initiatives for protecting health and safety and environment of those affected by its activities through the following:

• Seeking to avoid harm to health, injury to personnel and damage to property from its operations and those of contractors acting upon its behalf.
• Recognising the importance of the involvement and commitment of Senior Management and the responsibility of each and every employee in the implementation of this policy. Managers, Superintendents and sea staff at all levels are held accountable for their health, safety and environmental protection.
• Acknowledging the principle that all accidents can be prevented actively promotes, among all those associated with its activities, the highest standards of safety awareness and performance.
• Maintaining contingency procedures for serious accidents and hazardous occurrences to minimise harm to people, property and the environment and works with relevant authorities and emergency services to develop and implement such procedures.
• Maintaining and providing an effective Safety Management System of communication on safety related matters.
• Compliance with mandatory rules, regulations, codes, guides and standards applicable to the Company's Safety Management System.
• Continuous improvement of safety awareness and safety management skills throughout the Company both ashore and on board each vessel.

The Quality - Safety Management System has the active support of the Company Senior Management. The General Manager has the overall responsibility and authority for the development and monitoring the implementation and effectiveness of the Quality - Safety Management System, ensuring the requirement by EN ISO 9002 (1994) and IMO's ISM CODE are maintained. Compliance with this Policy and the Quality - Safety Management System is mandatory and binding on all staff. Quality, Safety and Pollution Prevention is the responsibility of everyone in the Company. All shore and sea personnel are instructed to adhere to this policy, its requirements and Quality - Safety Management System procedures and instructions. Customer satisfaction and the good name of the Company are directly dependent upon this working philosophy.

Reviewed by the General Manager on 29/11/1996

This document applies to all subcontractors and suppliers who work on onboard Varship Shipping Co. Ltd vessels and at the company’s offices.

ENVIRONMENTAL POLICY
We recognise that our activities have an impact on the environment and in order to limit out effect on the environment as much as possible we implement an Environmental Management System (EMS) according to the ISO 14001.

We try to have an environmental control over all the activities carried out by us or for us, so we ask you to comply with the following rules when working on site. Varship Shipping Co. Ltd reserves the right to stop the activities of the subcontractor – supplier whenever there is a risk for the human safety and the environment.

The following parts contains generally applicable guidelines. Depending on the nature and duration of the activities, Varship Shipping Co. Ltd can extend these guidelines further, even after the activities have actually started.

ENVIRONMENTAL GUIDELINES

• No polluted water may be discharged into the sewage system or into the sea without the prior authorisation of the Varship Shipping Co. Ltd personnel.
• Hazardous products should always be in containers.
• Leaks should be cleaned up immediately using absorbent materials. The absorbent materials must be deposited in the proper refuse containers provided.
• Leaks should be reported immediately to our supervisor.
• The contractor must remove all waste caused by his activities or work, including packaging waste, unless otherwise agreed with the company.
• The wastes are collected separately to facilitate recycling and handling of dangerous wastes.
• All wastes and tools should be removed daily.
• Engines should be properly tuned and may not be left on unnecessarily.

SAFETY GUIDELINES

• Subcontractors are required to take the necessary precautions to ensure the safety of their staff and Varship Shipping Co. Ltd staff and to prevent all forms of pollution and damage to the company’s equipment.
• The contractor shall appoint a person to be responsible for the safety of his staff working onboard or at our offices and to act as the contact person for Varship Shipping Co. Ltd.
• The contractor is responsible for applying for the necessary permits required to carry out certain work.
• It is forbidden to consume alcoholic drinks on VARSHIP SHIPPING premises.
• The contractor provides his staff with personal protective equipment.

ORDER AND CLEANLINESS

• Keep the toilets, washrooms and rest facilities clean.
• Electrical cables, hoses, pipes, etc should be laid out so that people are not likely to trip over them and they do not hinder operational activities.
• Openings in floors, walls and grids must be sealed off immediately. If this is not possible because of the nature of the work, a fixed barrier is to be set up and appropriate warning signs posted/erected.
• The contractor is responsible to ensure that the working area is properly indicated and delimited. The manager of the department concerned must always be informed of the nature, time and place of the work.

ACCIDENTS AND EMERGENCY SITUATIONS
The subcontractor – supplier is obliged to report the following immediately:

• Environmental accidents (accidental emissions, spillage of hazardous products)
• Damage to Varship Shipping Co. Ltd property.
• Any injury or accident.
• Fire.

If it is necessary to evacuate, follow Varship Shipping Co. Ltd personnel. The person in charge on behalf of the contractor should ascertain whether all his staff have been able to evacuate and inform the Varship Shipping Co. Ltdperson in charge for the number of people left behind.

Throughout the period of the work, the fire fighting equipment and evacuation routes must always be kept clear.