Policies

The Management of SUN ENTERPRISES LTD. is committed to take all reasonable precautions and measures, during the operation of managed vessels, in order to ensure safety at sea, prevention of human injury or loss of life and avoidance of damage to property.

The Company’s goal is to achieve ZERO incidents through continuous improvement.

To fulfil these objectives, the management is committed to the following approach:

• Comply with mandatory rules and regulations and take into consideration the Codes, guidelines and standards recommended by the IMO, Flag Administrations, Class Societies and Industry organizations, applicable to operations of managed vessels.
• Adhere to an Integrated Management System (IMS) by all Company’s employees, including managed vessels, which promotes the concept of HSQEEn excellence, continuous improvement and enhancement of personnel skills.
• Assign employees possessing sound skills and capabilities in required areas of responsibility, including the adequate verification of resources.
• Define the organization, responsibility, authority and interface of the various management functions within the frame of the IMS.
• Providing for safe and environmentally sound practices in the operation of managed vessels.
• Provide and maintain a safe working environment onboard to assist in preventing human injury and loss of life.
• Provide the necessary training to ensure that Company’s employees are capable of achieving safety and pollution prevention objectives in the work they perform.
• Provide facilities, systems/equipment and a maintenance system that is suited for the purpose of achieving objectives.
• Conduct management review meetings and management system audits.

This Policy has the full support of Top Management and applies to all Company’s employees.

SUN ENTERPRISES LTD. endeavours to earn the confidence of the shipowners, charterers, seafarers and the marine industry and other interested parties and be recognized as a high quality, trustworthy international ship manager. This can only be achieved by providing flawless services that satisfy all relevant requirements. The Company shall always provide professional ship management services to owners and charterers, protect their interests and assets under its care, and fulfil all their expectations.

The Company:

• Is committed to always comply with all applicable legal and other requirements that relate to the pertinent hazards and to continually improve the effectiveness of its IMS.
• Adopts a proactive approach concerning the needs of its clients and is responsive to their requests, suggestions or complaints, always trying to improve the value of its services.
• Encourages employee teamwork, personal improvement, cooperation, innovative thinking, initiative, leadership, decisiveness and focus on client’s needs and satisfaction.
• Sets measurable and meaningful objectives and targets and reviews them when appropriate.
• Addresses the needs of interested parties who receive its services or who may be impacted by them.

In order to objectively assess its performance, the Company:

• Establishes criteria for the quality of its services.
• Monitors, measures and analyses its objectives and targets for continual suitability to verify that processes are effectively implemented.
• Identifies and manages the risks and opportunities of its services.

The IMS defines the methods used to achieve Company’s Policies and the associated objectives and targets. Its implementation ensures that all applicable requirements related to managing ships will be satisfied, thus providing the necessary confidence between the Company and its customers.

The Company’s management considers its IMS as the basic tool for providing consistent and effective ship management service and improvement, provides sufficient resources and reviews it regularly to ensure its continuous suitability and effectiveness. The management commits itself in active implementation of the IMS and requires all involved personnel to do the same.

Every suggestion for improvement will be given full attention and will be brought to the highest level of the management.

All Company’s employees, ashore and at sea, are expected to comply with this policy and work towards achieving Company’s objectives. The success of the Company depends on the commitment and involvement of each individual employee.

This policy is continuously reviewed for its suitability and is available to the public and the Company’s customers, vendors and suppliers.

SUN ENTERPRISES LTD, maintains a ZERO TOLERANCE standard where spills or release to the environment are concerned. In this regard, the Company is committed through continuous efforts to improve its environmental performance in all areas required by the international regulations and laws and Company’s IMS and EMS and to ensure:

• Pollution prevention that emphasizes source reduction, including necessary funding and human resources, to effectively maintain the onboard systems, equipment and components.
• Minimizing the environmental impact of its operations, focused in using energy and natural resources in an efficient manner, including re-use and recycle whenever possible.
• Continuous reduction of environmental risks.
• Sharing information on environmental performance with external stakeholders.
• Fulfils its compliance obligations with ISO 14001 standards.
• Continual improvement of the EMS to enhance environmental performance.
• Correcting nonconformities.

The Company’s goal is to achieve Zero spills or releases to the environment and reduction in permitted emissions through continuous improvement.

For achieving this goal, the Company:

• Complies with all applicable environmental laws, regulations and requirements and applies responsible standards where laws, regulations and requirements do not exist.
• Responds quickly and effectively to environmental incidents resulting from its operations, in co-operation with industry organizations and authorized government agencies.
• Assesses all identified risks to the environment and establishes appropriate safeguards.
• Shows concern and respect for the environment, emphasizes every employee’s responsibility in environmental performance and fosters appropriate operating practices and training.
• Undertakes appropriate reviews and evaluations of its operations to measure progress and to foster compliance with this Policy.
• Conducts and supports research to improve understanding of the impact of its business on the environment, to improve methods of environmental protection and to enhance its capability to make operations compatible with the environment.
• Manages its business with the goal of preventing environmental incidents and of controlling emissions and wastes to below harmful levels.
• Minimize environmental impact, waste (Garbage, Sewage) to the water and emissions (Cargo vapor, engine exhausts, CFCs) to the air.
• Control the Ballast Water discharge as per applicable national and international regulations.
• Control the noise and protect the water environment from toxic antifouling paints.
• Shares its experience with others to facilitate improvements in industry performance.
• Implements Decarbonization Strategies as adopted by IMO and other international bodies

This Policy has the full support of Top Management, is available to the public and applies to all Company’s employees ashore and onboard

SUN ENTERPRISES LTD. holds health, hygiene and crew welfare as first priority in its operations, while its outmost concern is to always ensure that all employees execute their work under safe and hygienic conditions. In order to ensure high standards of health and hygiene, the Company:

• Complies with all applicable legislation and regulations, observes relevant guidelines, and applies responsible standards where laws and regulations do not exist.
• Seeks to identify and evaluate health and hygiene risks related to its operations that potentially affect employees, contractors, the public or other interested parties and establishes appropriate safeguards.
• Communicates knowledge about health and hygiene risks to individuals in potential risk or organizations and the scientific community.
• Determines at the time of employment and thereafter, as appropriate, the medical fitness of employees to perform their work without undue risk to themselves or others.
• Implements programs and appropriate protective measures to control such risks, including appropriate monitoring of employees in potential risk.
• Provides or arranges, as appropriate, for medical services necessary for the treatment of employee occupational illnesses or injuries and for the handling of medical emergencies.
• Provides voluntary health and hygiene promotion programs designed to enhance employees’ well-being and personal safety. These programs should supplement, but not interfere with, the responsibility of employees over their own health care.
• Undertakes appropriate reviews and evaluations of its operations to measure progress and to foster compliance with this Policy.

The Company’s goal is to achieve the highest standards of health and personal hygiene through continuous improvement.

Employees’ health data are confidential and should not be revealed to non-medical personnel except at the request of the employee concerned, or when required by law, when dictated by overriding public health considerations, or when necessitated by the Company’s Drug and Alcohol Policy.

This Policy has the full support of Top Management, is available to the public and applies to all Company’s employees

SUN ENTERPRISES LTD, maintains a ZERO TOLERANCE standard where the use of drugs and consumption of alcohol by seagoing personnel is concerned.

It is the Company’s Policy that no seafarer, whatever rank, will navigate the vessel or will operate its equipment while impaired by drugs or alcohol or where there is any risk of such impairment.

In following this Policy, SUN ENTERPRISES LTD.:

• Has banned all alcoholic beverages from its managed vessels.
• Has banned any form of drug, with the exception of prescribed drugs, as well as the misuse of legitimate drugs. If a crewmember is found in possession of drugs, then the Local Authorities will be contacted immediately.
• Has implemented random testing of all crew for banned substances and alcohol.
• To ensure compliance with this ZERO TOLERANCE policy, the Company has adopted a program of testing and screening, including random and unannounced drug/alcohol testing, in addition to routine pre-employment medical examinations.
• Controls the use of all medical supplies on board the managed vessels.
• Will dismiss and impose penalty, as per National and International regulations, to anybody:
• using alcohol or banned substances on board the vessel;
• caught in possession of alcohol or banned substances;
• found to have been instrumental in bringing alcohol or banned substances on board;
• found to have a positive trace in any random testing sample, unless prior notice with authorization for use, had been given to the Master.
• On no account shall a person under the influence of drugs or alcohol, be allowed to stand watch or perform any other duty, involving the safety of the vessel, her crew or cargo, and the public.
• Will take all disciplinary action, including dismissal, against anybody consuming alcohol, while ashore, for at least 4 hrs prior scheduled watchkeeping duties or work period.
• Any crewmember suspected for being under the influence of drugs or alcohol, while on duty, shall be immediately relieved from his duty and placed under observation until the influence of drugs or alcohol subsides.
• All crewmembers understand that it is their duty and benefit, to report immediately to the appropriate Officer or the Master, if they suspect or have evidence that one of their fellow crewmembers is intoxicated.
• The use of alcohol on the part of the pilot while performing his duties is strictly prohibited; if a pilot is noticed to be under the influence of substances resulting to the incapability of performing his duties will not be allowed to be part of the bridge team
• Requires all new recruits, prior their embarkation, to undergo a Drug and Alcohol test.

All employees must be adequately informed on the provisions of this Policy and must comply with their intent. This Policy has the full support of Top Management and applies to all employees.

SUN ENTERPRISES LTD., believes that although shipping is by far the most fuel-efficient mode of transport, nevertheless additional action has to be taken to further improve the energy efficiency of ship related operations. The increased energy efficiency eventually results in increased environmental protection by reducing air emissions.

Energy efficiency is controlled primarily through well-planned and properly managed ship operations and needs the personal commitment of everyone involved in the above tasks. To be successful, energy efficiency and conservation must become part of the day to day operation and living onboard.

In our efforts to enhance the energy efficiency on the shipboard operations, the Company is committed to:

• Establishing and maintaining a Ship Energy Efficiency Management Plan (SEEMP) which is regularly reviewed by all concerned departments and approved by the management of the Company. This Plan, which applies to all fleet vessels, provides standard procedures and practices on best energy management under the various operational modes of the vessel.
• Implementing an IMS supported with several environmental programs with the objective of continually increasing energy efficiency and minimizing energy waste. A set of time-specific, measurable – whenever practicable – and achievable targets shall be established and maintained, which shall relate to a combination of design optimization, in-service performance monitoring and best-practice operational management processes.
• Promoting energy efficiency awareness through training to the shore and sea-going personnel and implementing energy related Campaigns and other personnel incentive/motivating programs
• Monitoring and complying with all applicable legal requirements related to ship energy efficiency management

This Policy shall be periodically reviewed with the aim of being kept always updated so as to function as the “leading light” towards a continual energy efficiency improved performance.

This policy applies to all individuals working at all levels in the Company, either in the office or on board the vessels and covers the use of social media (as outlined above) during work and non-work hours, on personal and Company supplied equipment such as laptop computers and cellular / smart phones.

This policy deals with the use and misuse of social media platforms and other websites including but not limited to:

• Social networking websites such as Facebook, Instagram, MySpace, etc.
• Micromedia / Microblogging websites such as Twitter.
• Multimedia websites such as YouTube and Instagram.
• Wikis such as Wikipedia.
• Blogs and News sites where content and comments can be posted.
• Any other website where user-generated content can be posted for wider sharing.

The Company recognizes the value of social media and expects all staff to use these tools responsibly. The following basic principles should be observed:

• Be responsible. As an employee, any user-generated content could have an impact on the Company’s reputation, so give careful thought before sharing photographs or video of the Company assets, particularly our ships, facilities or people in uniform.
• Be accurate and honest. In any circumstances in which you are in doubt, or you are uncertain about how to respond to a post, contact the Company for guidance.
• Do not make posts or comments that may be considered defamatory, obscene, libelous, threatening, harassing or embarrassing to others.
• Before you post photographs of other people, get their permission first.
• Never use someone else’s copyrights, copyrighted material, trademarks, service marks or other intellectual property.
• If you see comments relating to the Company that you think should be addressed, contact the Company for guidance.
• Do not use the Company’s logo (in any form) on any personal social media platform. Use of any Company logo must be approved by the Company.
• Respect others in any online social interaction. Do not use social media or any similar form of communication to attack or insult the Company, fellow employees, customers, vendors, contractors, suppliers, competitors or others.
• Do not disclose any confidential, proprietary or sensitive information about the Company as well as names of our employees, customers, vendors, contractors, suppliers, competitors or others. Employees are reminded of Company’s policy on public statements / media response.
• Do not comment on Company related legal matters, financial performance, competitors, strategy or rumors, unless you are specifically authorized to do so.
• If any member of the media (social or traditional) contacts you about your user-generated content (i.e., blog post, comment, video), a colleague’s or another party’s, do not engage in a dialogue, but refer them to contact the Company.

The Company guarantees its commitment on matters of security and declares that all works conducted by its personnel, either ashore or onboard, will be effectively supervised in order to comply with the provisions of the ISPS Code. It is the policy of the Company to provide a secure working environment by establishing and maintaining the required security measures to prevent unlawful acts which endanger the safety and security of persons and property onboard the ship. Company objectives are to:

• Provide security procedures and practices for ship operations to protect the security of ports and the wider community and establish safeguards to reduce the risk to crew, passengers and port personnel onboard.
• Improve the security skills and awareness of Company personnel ashore and onboard.

In case there is a conflict between commercial interests and the aims of the Security Policy, the Master will give priority to this Policy and the above mentioned objectives which will be achieved by:

• Comprehensive training for Company and ship personnel. The personnel undergo training both immediately upon hiring and continuously during their employment.
• Actively promoting security awareness amongst Company and ship personnel.
• Taking into account the decisions of the international shipping community.
• Regular documented reviews and internal audits of security procedures and plans in order to allow for constant update and improvement of the Plan.
• Scheduling in advance, as far as possible, the voyage, the cargo handling and all ship’s operations in order to foresee possible dangers and take the necessary precautions.

All employees and crewmembers are expected to comply with the requirements of the SSP and shall be familiar with their relevant security duties and the measures required to protect the ship from any unlawful act.

In the event of an attack on the ship or highjack attempt, the preservation of the lives of ship personnel is to be placed above all other considerations.

The Company declares that the CSO, the Master and the SSO have adequate knowledge and/or have received training, that shipboard personnel with specific security duties have sufficient knowledge and ability to perform their assigned duties and that all other shipboard personnel have sufficient knowledge of and are familiar with relevant provisions of the SSP. The Company ensures that the CSO and SSO are given the necessary support to fulfill their duties and responsibilities in accordance with SOLAS and the ISPS Code.

This Policy will be revised whenever necessary in order to ensure that the aims set are achieved and to monitor the correctness and effectiveness of the procedures and guidelines given.

The purpose and objective of this Policy is to protect Company’s information assets from all threats. Maritime companies as well as ships are vital elements of global trade and economy. Cyber-attacks on information or control systems could negatively affect company employees, damage equipment, expose the environment to harmful pollutants or lead to extensive economic damage.

Sun Enterprises Ltd, in order to ensure continuity of operations, mitigate damage as well as ensure the protection of all of the above in general, is committed to the following:

• Information and Systems either onboard or ashore identified as vulnerable to Cyber-attacks should be protected from a breach of confidentiality, integrity and availability;
• Regulatory and legislative requirements should be met;
• Cyber security awareness and training of our employees/crew members should be enhanced;
• All breaches of information security should be reported and investigated;
• Cyber risk management should be applied in order to identify and assess Cyber vulnerabilities;

Adequate resources required to achieve the above commitments, such as guidance and procedures should be provided to our employees/crew members. Among others, these include incident handling, information backup, system access, virus controls, passwords and encryption.

SUN ENTERPRISES LTD. operates in a socially responsible manner, ensuring the safety of people and the environment, through transparent and ethical behavior, respecting the following principles:

• Accountability for the organization’s impacts on society and the environment;
• Transparency in the organization’s decisions and activities that have impact on society and the environment;
• Ethical behavior at all times;
• Respect, consider and respond to the interests of the Company’s stakeholders and employees;
• Accept that respect for the rule of law is mandatory;
• Respect international norms of behavior, while adhering to the principle of respect for the rule of law; and
• Respect human rights and recognize both their importance and their universality.

The Company addresses the following core subjects in order to identify the issues and priorities that are relevant for the organization: Organizational governance; Human rights; Labor practices; Environment.

Our commitment to this objective is underscored by the daily actions of our employees and their dedication to the numerous programs and practices we have implemented.

We aim to integrate sustainable thinking and corporate social responsibility into all our business processes and business relationships. Employee skills and competencies are developed by continually raising awareness and impartment of training.

We recognize that our operations have a global influence. With this in mind, we work diligently with our employees, local communities and internationally recognized bodies to ensure that social factors are integral to our business principles.

We promote continual improvement as a principal driver by knowledge-sharing practices and the timely review of our management systems while always meeting or exceeding all applicable legislative and regulatory requirements.

SUN ENTERPRISES LTD. is committed to conducting all aspects of her business with honesty and integrity, and to providing a working environment where high standards of ethical, moral and legal business conduct are encouraged and safeguarded. The Company is confident in the comprehensiveness and effectiveness of its Management System and its role in ensuring the safety of people and the environment, as well as in the effectiveness of its existing reporting channels.

Furthermore, the Company is committed to a workplace characterized by open communication regarding its business practices. As such, this Whistleblowing Policy has been developed to provide a means for employees and seafarers to raise concerns that cannot be, or have not been, adequately addressed via usual reporting channels without fear of retaliation or discrimination over such reports made in good faith.

The Whistleblowing Policy addresses concerns related to issues of public interest, including, but not limited to, the following:

• A criminal offence;
• Non-compliance with legislation and/or Company procedures, particularly in relation to health and safety at work or environmental protection;
• Dishonesty, either verbal or written (including intentionally maintaining official log books or records inaccurately);
• Malpractice or unethical conduct;
• Financial or non-financial misadministration or malpractice or impropriety or fraud;
• A safety and/or security risk or hazardous condition that may impact the life or health of individuals on board the vessel;
• Miscarriages of justice; and
• The deliberate concealment of any of the above.

If an employee has a legitimate concern in (and holds reasonable belief that the information he has relates to) one of the above areas and wishes to raise the concern in good faith, it should be raised with the Master, DPA or other Company’s representative who may be able to agree a way of resolving the concern quickly and effectively.

Although the Company’s Top Management maintains an open-door policy endeavoring to address individuals’ concerns internally, a concern can also be raised through the following channels:

E-mail: safety@sunenterprises.gr

Tel.: +30 213 010 3596 (Whistleblowing Hotline)

Reports can be made without fear of retaliation and be even anonymous. Upon receipt of a report, same will be assessed by the Company’s Top Management and an investigation may commence, if deemed necessary. Any victimization of a member of staff who “whistle-blows”, or any attempt to deter him from reporting, will be regarded as a serious disciplinary offense and will result in action under the Disciplinary Procedures.

SUN ENTERPRISES LTD. puts sustainability at the center of its business strategy through our industry leadership role, our operations and the services we provide.

Our sustainability principles:

1. A society for our future: Inspiring the next generation, developing sustainability competencies, and creating a healthy & safe workplace;
2. An environment with a future: Respecting the environment by exercising efficiency in the use of resources, preventing pollution, and protecting ecosystems and taking steps towards low carbon economy;
3. A responsible business for the future: Promoting sustainable economic growth with integrity, strong governance, and ethos, while recognizing the responsibility of providing to the society.

We do this by:

1. Adjusting our expectations and requirements in relation to the UN Sustainable Development Goals and by understanding how Global Megatrends will affect our business globally and locally;
2. Implementing controls to ensure compliance with relevant legislation and following up legislation changes;
3. Improving efficiency, including in the use of resources, water, energy and raw materials;
4. Understanding climate change and by assessing/addressing relevant risks;
5. Valuing diverse skills and contributions by improving diversity and equality and by developing strategies beneficial to human health and wellbeing;
6. Improving and assessing our environmental performance effectively and by ensuring the suitability of our suppliers and evaluating their performance;
7. Monitoring our sustainability performance against objectives and targets and by adhering to the Company’s Policies.

All employees, crews and contractors working on our behalf must share these commitments.

Everyone is empowered to ensure that our commitments are met.

The Code of Ethics and Code of Conduct (referred to hereafter also as the Codes) is based on Company’s beliefs and values establishing its commitment to honesty and integrity. The main function of the Codes is to make the fundamental values and principles, which guide the activities of the Company, known within the Organization and its managed vessels and to all agents, contractors, suppliers and other third parties, the Company cooperates with. The Codes apply to the whole Company and managed vessels.

The aim of the Codes is to ensure that the Company is united by strong and clear values and the highest standards of behaviour and to orient individual conduct with the purpose of confirming the image of correctness, prestige and the good reputation which have always been the assets of our Company. The Company expects from all personnel behaviour in line with the established principles, laws, rules and standards in order to protect its image, reputation and the quality of the services provided. All employees are responsible to comply with the Codes and actively support their principles. The Managers are responsible to ensure implementation and management of the Codes in their area of interest.

• The Company’s shore staff and seagoing personnel shall not be involved in any kind of harassment, abuse, discrimination or child pornography.
• The Company’s personnel shall not conceal any identified unsafe act or event which affects or could affect human health and safety, the environment and the property.
• The Company’s personnel shall carry out their duties in a professional and impartial manner. All Company’s employees shall act in honesty and good faith.
• All information regarding SUN ENTERPRISES LTD. operations, projects, reports or any work carried out shall be treated as business confidential to the extent that such information does not conflict with Company’s policy for HSSQEEn excellence and is not already disseminated or made generally available to third parties.
• Any kind of offer, gift or bribe in any form direct or indirect, including kickbacks is strongly prohibited in all Company’s operations. Furthermore, the Company prohibits the use of other routes or channels for provision of improper benefits to, or receipt of improper benefits from agents, contractors, suppliers or employees of any such party or government officials.
• Procurements are conducted in a fair and transparent manner.