Company Policies

The policy refers to the ships managed by DEDE DENİZCİLİK TAŞIMACILIK TİC.LTD.ŞTİ..hereinafter called the "Company". 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 emphasize its commitment to the following objectives, in order of priority:

Prevent physical injury and loss of life;

Protect the environment, the marine in particular;

Maintain the technical and operational efficiency of the vessels at the highest possible level;

Protect vessels and crew against illegal practices,harassment and bullying;

Operate the vessels and transport the cargo safely and efficiently.

The Company requires that whenever a conflict arises between commercial or economic motives and the above points, the Master shall always decide by giving priority to the latter in accordance with the above established order.

To achieve the above-mentioned objectives, the Company shall provide the necessary resources and qualified personnel, defining its organization, identifying specific tasks and responsibilities, establishing training requirements and coordinating all the tasks in order to:

Ensure the safe operation of the vessels and protection of the environment in compliance with the applicable national and international rules and regulations;

Establish safeguards against all identified risks;

Constantly improve the technical and operational training of the personnel both on board and ashore;

Maintain the highest maintenance standards on all managed vessels;

Always be ready, both ashore and on board, to deal with emergency situations;

Apply, whenever and as appropriate, industrial standards.

The Company shall inform all the personnel of their specific duties and shall require their commitment to achieve the above-mentioned objectives.

However, for what concerns the operation of the ships, 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 the ship and for the protection of the environment, whether these are in agreement or not with the procedures and instructions provided by the Company.(Master’s overriding authority)

The Master is also responsible for immediately reporting to the Company any accident or non-conformity which may affect the safety of the personnel or of the ship or which may pollute the environment. Adequate personnel and means of communication are provided for this purpose. The effective implementation of the Company's policy is regularly reviewed in order to ensure both that the objectives are achieved and that the procedures and instructions are suitable and effective.

DEDE DENİZCİLİK TAŞIMACILIK TİC.LTD.ŞTİ. (Hereinafter called the “Company”), conscious of its responsibilities in this field, pledges its commitment to environmental protection. Company, has already accepted its own responsibility to show all efforts for preventing the pollution of Air, Marines, Rivers and Water lakes. All Crew on board, should adapt to the rules of international and national conventions for Garbage Pollution and International Convetions for Shipboard Oil Pollution Prevention.

The company's environmental policy is to prevent the environment being damaged, in particular due to sea transportation. In this respect, we are committed to continual improvement in environmentally sound performance and pollution prevention. The Company is going to carry out the effective planning and crew trainings to ensure performing of Environment Pollution Prevention Applications and Activities effectively and by knowing the responsibilities. Company will positively evaluate and take into account, advising for revision of Prevention of Environment Pollution, procedures and the instructions by crew onboard.

The followings are committed in order to reach related goals:

Follow existing national and international legislation.

Environmentally orientated training for both ship-based and shore-based employees

To keep our employees on board and ashore currently updated regarding the environmental regulations considering sea transportation.

Never throwing anything overboard except for food waste.

Seek to use environmentally friendly anti-fouling.

Immediately informing the national authorities in case of accidents which may lead to pollution of the environment

Optimize the use of separate ballast tanks.

Ensuring that anti-pollution materials are always nearby bunkering and when loading-unloading (if necessary)

Seek to reuse, recycle and recover waste when possible.

Try to influence suppliers and contractors to operate within environmental standards that are not in conflict with our policies.

The Company shall inform all the personnel of their specific duties and shall require their commitment to achieve the above-mentioned objectives.

However, for what concerns the operation of the ships, 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 the ship and for the protection of the environment, whether these are in agreement or not with the procedures and instructions provided by the Company.(Master’s overriding authority)

Shipboard Oil Pllution Prevention Emergency Plan (SOPEP) for each ship, is developed to help crew onboard for stopping or reducing the pollution that comes unexpected situations

The company's safety policy is to prevent accidents and work-related illnesses among the company's employees. This aim is to be achieved by ensuring:

that working conditions are totally secure as regards health and safety.

that dangerous chemicals and materials are used only in accordance with procedures and methods that effectively protect employees against accidents and illness.

that all employees have received proper instruction in safety procedures.

that the established safe limits for exposure to, for example, noise, cold, dust and steam are followed.

that machines, tools and other technical aids are in good working order and used in a sensible manner as regards health and safety.

that safety shoes are always worn for work on deck.

that safety helmets are always worn outside accommodation and engine room.

that during loading-discharging procedures, personal safety equipment is always properly used on board.

that safety meetings are held regularly.

Drug and Alcohol Policy applies to all personnel who may sail on DEDE DENİZCİLİK TAŞIMACILIK TİC.LTD.ŞTİ.. (Hereinafter called the “Company”) vessels or work on Company Shore Departments.

DRUG

The misuse of legitimate drugs or the use, possession, distribution, or sale of illicit or non-prescribed controlled drugs on board ship or by crewmembers on shore leave is totally prohibited.

The Company will not authorize the employment of any persons who are users of or have a recent record of the use of illegal drugs or have abused the use of prescribed medications. Any crewmember found in contravention of the drug policy of the Company will be instantly dismissed and handed over to the appropriate authorities for prosecution. All are reminded that in certain countries, possession of illegal substances can result in the DEATH PENALTY. Any person found to be in possession of or trafficking in an illegal substance will be liable to immediate dismissal from the vessel. If the possession of the illegal substance is then proven, they will also be liable to dismissal from the Company and may also be liable to criminal proceedings and could be dealt with by any country in whose jurisdiction the offence has been committed. Drug trafficking is dealt severely by the courts of most countries and sentences may include capital punishment.

The company will also take measures on illegal drug use prevention.

ALCOHOL

Excessive consumption of alcohol can have serious adverse affects on an individual’s health and their ability to function effectively and therefore any person found to have an alcohol problem will not be employed by the Company.

The possession, distribution, sale and consumption of alcoholic beverages on board are prohibited. This prohibition applies to crew and visitors.

All mariners are warned that in the USA, a crewmember found aboard the vessel under the influence of alcohol can be heavily fined.

It is strictly prohibited to bring onboard and to consume alcohol on all vessels in the company.

This policy will be strictly enforced at all times, both ashore and on board.

CONTROLS ON BOARD

Deterring measures

The Company has adopted measures to deter drug smuggling and alcohol use on board.

For this purpose, all shipboard personnel (including Master) shall be requested to undergo blood and/or urine tests for traces of drugs and/or alcohol before hoining the vessel.

Unannounced drug and alcohol tests

For this purpose, all shipboard personnel (including Master) shall be requested to undergo blood and/or urine tests for traces of drugs and/or alcohol within their contract durations. This procedure is in General / Fleet Manager’s responsibility and it is his choice where, when and who will the involved to these tests.

Alcohol test on board can be sudden.This procedure is in Master’s responsibility and it is his choice where, when and who will the involved to these tests. Master may decide to perform these tests under following situations:

when a strong suspicion exists of use of alcohol in violation of the Company's specific instructions

after any accident involving the ship (e.g.: collision, fire, grounding, pollution and any other serious accident on board)

when the tasks of the person involved may cause risks to others, to the ship or to the environment

when so requested by any law

A positive test result or refusal to submit to the drug and alcohol test is grounds for disciplinary action including immediate dismissal.

If the Master is the one, who will be involved to these tests, Chief Officier becomes responsible for the performing of the tests.

The tests carried out in ashore's recognized laboratories are to be under the responsibility of a medical doctor.

Security measures

The following security measures are also taken to avoid drugs being put on board when vessels are in port or at anchor:

Security control at the gangway and/or on deck

Control that unauthorized vessels and/or divers do not approach the ship. In this respect, the Master shall immediately inform the Port Authority if divers or other suspicious movements of unauthorized people are noticed under the vessel.

Master or the Company may decide to conduct unannounced searches for drug and alcohol.

PROCEDURES AND INSTRUCTIONS

Company's instructions

As a company policy, the necessary documentation like circulars and posters which are prepared for warning the personnel are regularly sent to the vessel.

Instructions for carrying out the alcohol test on board

On board test is to be carried out by using the Breath Alcohol Analyzer

The following control criterion applies to alcohol testing; it does not permit the possession or consumption of alcohol on board.

Blood Alcohol Concentration (BAC) shall not exceed 0.04%. This control threshold does not imply permission to possess or consume alcoholic beverages on board.

Instructions for carrying out the drug test

Unless there is reason for blood testing, the test is carried out only by analysis of the personnel's urine.

The test will be carried out in recognized ashore laboratories.

Logging procedures

DEDES.27 is kept under the Master's responsibility, where the date, time, name of the seafarer, test readings and name and signature of the test responsible are recorded, every time an alcohol test is carried out

A specific file is kept ashore for filing the drug tests results carried out by the recognized laboratories.

Posters

Posters listing the effects of drug use and alcohol abuse are hung up at various points within accommodation house,

Posters containing the Company's policy in respect of drug and alcohol use and abuse are hung up at various points within accommodation house.

Company Controls

The Company shall verify that the Drug and Alcohol policy is correctly implemented and that tests are regularly performed.

Prohibition of Possession, Distribution and Consumption

On vessels operated by the Company, the possession, distribution, sale and consumption of alcoholic beverages are prohibited, whether on duty or off duty.

All personnel must be aware the rules especially as follows:

Personnel reporting for duty shall not be under the influence of alcohol. Any waiting period before duty must not be interpreted as permission to consume alcohol on board.

Rest periods and off-duty time do not remove the prohibition on possession or consumption of alcohol on board.

The stated 0.04% BAC control threshold is not an entitlement to consume alcohol. Hourly quantities or calculations of alcohol units do not permit alcohol consumption on board.

Conduct of Alcohol Test

During the practice of alcohol tests the following procedure must be followed:

The responsible person who will make test and the witness must be alone in a seperate area from all other personnel with the person to be tested,

If the result of test is positive the test be must repeated under the supervision of a witness who must be an authorized officer,

The person to be tested, has to right to choose his own witness,

If there is a evidence about the alcohol policy is not observed, the relevant procedure is given in DEDEC.06 of subject manual.

DEDE DENİZCİLİK TAŞIMACILIK TİC.LTD.ŞTİ. (Hereinafter called the “Company”) is committed to providing the Customers with a complete shipping service that meets their requirements at all times. In this respect, the intention is to be always recognized as offering a high quality service.

The company is involved with technical, manning, safety management, ship building, ship repair and dry-docking as well as chartering and cargo operations.

The structure of business term of the company is;

Shipping,

Chartering and Operation,

Technical Management,

Manning Management,

Ship Building, repair and dry-docking processes,

Shipping Agency,

Shipchandlering

The company Management Policy to ensure that Company services comply with statutory and other formally defined requirements that concern safety, protection of the environment and the needs of the customers . Company intention is to provide services of a consistent and controlled quality; and to ensure the high standards to be maintained at all times.

Company will achieve this by;

Company presents high quality service enabling to meet all customers expectations with the qualified staff who have experience for company services.

Training of all staff to ensure that they are capable of meeting the defined standards.

Evaluating the crews and vessels performance and developing the levels for better operations

For the Safe Operation of Ships and Pollution Prevention (ISM Code), Consistently operating the documented Safety Management System which fully complies with the requirements of the International Safety Management Code.

Consistently looking at ways to improve our services through operational efficiency, which includes health and safety at work and the needs of the environment.

To respond the today’s expectations with latest technology and highest standards of equipments.

An important element of this policy is: To ensure that it is properly communicated and understood throughout the company and all vessels under management as well as to ensure that every employee understands their contribution to our objectives.

Staff who having a defined involvement with the operation of the management system, will be informed of their responsibilities in the relevant procedures. Other staff will be made aware of the management’s philosophy by the display of this Policy Statement.

DEDE DENİZCİLİK TAŞIMACILIK TİC.LTD.ŞTİ. (Hereinafter called the “Company”) is specialised in the management of chemical and product tankers where highly trained staff is needed for the safe operation of the ships. The Company believes that both the ship and office personnel need to be trained in accordance with the regulations and continuosly developing technology.

The Company is well aware of the fact that having the required certificates and licenses does NOT necessarily mean that the person is suitable for the position mentioned in his license. Provided that the person has been found in compliance with the company manning policy, he is given a complete training prior to joining the vessel and then this training is supported by the basic and specific training given on board. The training at the office on the safety management system of the Company also forms a part of the specific training of the seaman.

The Company is very eager to follow the new regulations governing the dry / general cargo shipping business and provide training to its staff accordingly. It is a part of the Company’s policy that publications giving information regarding the developments in dry / general cargo shipping are received regularly by the office.

The Company encourages its office staff to visit the vessels and give refreshing training lectures. The Company even requires its office to staff and the Master of the vessel to give training programs beyond the minimum requirements should they deem necessary.

The Company believes that only highly trained personnel can be aware of the environmental safety. The Company strictly requires its personnel to follow the Company Environmental and Safety Policy.

In simple words the Company aims no accidents, no pollution and no injury by implementing this policy.

The effective implementation of the policy is regularly reviewed to make sure that the objectives are achieved and the procedures are effective and suitable.

As per DEDE DENİZCİLİK TAŞIMACILIK TİC.LTD.ŞTİ. (Hereinafter called the “Company”) quality policy the main basic point is, to reach the top quality level enabling to compete with other companies. Therefore, company updates its records and raises and maintains the services under ISM conditions. There are some items which shows the purpose of the company to achieve.

Customer Satisfaction

Researching and Developing

that planning and error prevention are important areas within the quality system.

Efficiency with operation, environment and company

that work is carried out continously to improve quality standards

that all emplyoees are familiar with their individual jobs quality requirments

that all emplyoees report all deviations in quality regardless of their cause.

That controls are carried out to ensure that our environmental protection policy is fulfiled.

To meet the above-mentioned objectives, it is essential that the company in particular the chartering department, is constantly informed of the customer’s needs and expectations.

Quality can be defined as the degree to which the customer’s expectations are fulfilled. The degree of need fulfilment can be drawn up as a bar chart illustrating the ratio of the need expressed to the need fulfilled.

The company will do its best to ensure that the customer receives the highest possible level of need fulfilment.

These goals are to be achieved through the company’s declared objectives;

Must be kind and polite plus rendering good service to everyone.

Vessels must be well maintained

Vessels’ cargo holds must be ready for the cargo.

Be conscious of the environment

Maintain the safe operation and vessel

The purchasing policy of DEDE DENİZCİLİK TAŞIMACILIK TİC.LTD.ŞTİ. (Hereinafter called the “Company”) is to ensure that when purchasing goods or services we employ suppliers who can always meet our needs and expectations.

Our relations with our suppliers must be characterized by mutual trust, understanding and honesty. Quality is the most important factor of any purchase, and is followed by the price to quality ratio. However, attention must always be paid to the delivery time.

The following rules must be applied to attain the above:

By Company;

Give our suppliers comprehensive information about Company standards.

Make it clear that quality is the major factor in Company relations.

Carry out evaluation of the suppliers' ability to deliver.

Make clear Company requirements regarding the product and the associated service.

Carry out spot checks on price and quality.

Give notification of approaching purchases as soon as possible.

Inform the supplier of delivery irregularities as soon as possible.

Stimulate the exchange of relevant experience through personal visits, etc.

Keep our side of all agreements.

By Suppliers;

Deliver on time the agreed quantities of goods which match with specifications.

Solve problems connected to delivery errors quickly and efficiently without involving the company in burdens on paperwork, custom formalities etc.

Solve problems quickly and efficiently.

Organise overseas deliveries without involving the company in burdens on paperwork, custom formalities etc.

Give notification of delivery irregularities in good time.

Show willingness to collaborate with us to ensure efficient order and delivery procedures.

Consider our partners as long-term partners and give good service.

DEDE DENİZCİLİK TAŞIMACILIK TİCARET LTD.ŞTİ. (herein after called the “Company”) is a continuously growing company specialised in the management of dry/general cargo vessels. The Company aims to keep its fleet consisting of new modern cargo vessels. In this respect the Company considers building new vessels at yards that have an established experience base in vessel building. The Company is well aware of the fact that building vessels with double hull is crucial for environmental protection. As a principle, the Company strictly complies with the regulations regarding new buildings and is very eager to use the latest technology for such buildings. As the Company already has a good level of knowledge of new buildings, it even searches and applies new techonologies to contribute to the environmental protection

The Company is very strict on building vessels that exactly fit to its very specific needs, therefore It usually modifies the yard design or in some cases It may accept a design without any modification. In both cases the Company shows utmost diligence for site supervision and for the approval of the plans. The Company may seek external assistance for the approval of the yard calculations.

It is the Company’s principle to have a total control during the building of the tanker at all times. The Company always maintains a sufficient number of technical personnel for this purpose. For work where specialist assistance is needed, the Company always employs specialists which are well known to the market. The Company is also well aware of the fact that specialist areas supervision requires more attention and diligence. The Company motivates its staff for such a work.

The Company employs ship staff well in advance for the new buildings. It employs ship’s senior officers about two months before the delivery of the vessel and the remaining personnel join the vessel 2–4 weeks before the delivery of the vessel. As the ship staff’s experience is very important for the safe and easy operation of the ships, the Company seeks information from the sea staff operating on Company fleet. The senior officers on board are also involved in the site supervision up to their capacity.

The Company works with the first class suppliers for the construction of the tankers and aims to have good relationships with such parties. Detailed records of previous correspondence are maintained for this. Opinions of the ship staff about the equipment which has direct effect on the operation of the vessels are always required at least verbally by the Company.

Documentation control is crucially important for new buildings. The Company makes every arrangement to make sure that all the documentation regarding a new building is received from the parties involved.

The effective implementation of theCompany’s policy is regularly reviewed in order to ensure that the objectives are achieved and the procedures and instructions are suitable and effective.

DEDE DENİZCİLİK TAŞIMACILIK TİCARET LTD.ŞTİ. (herein after called the “Company”) security policy is an active and practical security management policy based on the general security awareness of all personel and a range of measures, including plans, procedures and guidelines, in order to safeguard company crew, other employees, visitors, ships and cargoes from terrorist, piratical or other criminal acts.

Company, being fully aware of the requirements of the forthcoming ISPS Code, will:

Observe the international laws and regulations regarding maritime security and ensure that they are fully covered in Company Security Manual

Safeguard employees, visitors, customer cargo and ships

Appoint and empower a suitably senior company officer as the Company Security Officer (CSO) with overall responsibility for security on board all company controlled vessels and give him sufficient resources to fullfil his duties and responsibilities.

ensure that the security is risk assessed, taking into account the type of crew, cargo, ship, routes and destinations

Co-operate with the responsible authorities and act on their advice

Promote safety and security awareness among all employees

appoint an officer as the Ship Security Officer (SSO) on each ship and support their responsibilities and duties

Provide guidance and advice to Masters, SSOs and crew on the response to the threat and keep such guidance updated

Establish a security element to the crisis management structure including Media and Response Plans

Establish a reporting and recording system for incidents and pass that information to the authorities

recognise that additional security requirements may impose additional burdens on Masters and crew

Support Master in his authority to make independent security decisions and ask for assistance where necessary

Support the CSO, Master and SSO to fulfil their duties and responsibilities

DEDE DENİZCİLİK TAŞIMACILIK TİC.LTD.ŞTİ. (herein after called the “Company”) cyber security policy goal is safe and secure shipping. This policy is a policy that including procedures and guidelines, in order to safeguard company, crew, other employees, visitors, ships and cargoes from cyber criminal threatenings.

All employees and third parties who have temporary or permanent access to our systems and hardware must keep all DEDE DENİZCİLİK TAŞIMACILIK TİCARET LTD.ŞTİ. data strictly private and confidential. This applies during employment and after employment has ceased. Any unauthorised sharing or use of company data may be treated as a criminal offence and will be prosecuted.

Company, being fully aware of the requirements of the forthcoming cyber risk management, will:

Ensure that all company’s and ship datas are secured for cyber related risks.

Ensure that cyber risks are identified, analysed and on board systems are designed and secured for cyber risks.

Observe the international laws and regulations regarding cyber security and cyber crimes security and ensure that they are fully covered in Company Safety Management Manual

Safeguard employees, visitors, customer cargo and ships from cyber risks.

Ensure that providing an effective technical support to ships for cyber related risks.

Identifying of hardware and software systems on board and at company’s office.

Developing, monitoring and reviewing of a cyber security plan (CSP)

Promote cyber security awareness among all employees

appoint an officer as the Cyber Security Officer (CYSO) on each ship and support their responsibilities and duties.

Provide guidance and advice to Masters, SSO/CYSOs and crew on the response to the threat and keep such guidance updated

Support the CSO, Master and SSO/CYSO to fulfill their duties and responsibilities to provide cyber security.