Company Policies

The mission of Miklagard S Gemi İşletmeciliği ve Ticaret A.Ş., and its Senior Management is to ensure that Quality, Health, Safety, Security and Environmental considerations remain top priority for the Company’s management and employees. Prevention of accidental risks and losses due to process failure are recognized as an integral part of our continuous improvement culture.

Company will strive for a long-term ZERO TOLERANCE culture aiming to have:

• No accidents, 
• No health-related incidents,
• No marine and atmospheric pollution,
• No oil spills, 
• No loss of process capability, 
• No lapses in security.

MIKLAGARD S and its Senior Management are fully committed to a ZERO TOLERANCE policy ensuring that the waters on which its ships operate are protected from pollution and continuously strive to identify and correct any conditions perceived to be unsafe and hazardous to the environment.

MIKLAGARD S is committed to conducting its business with integrity and in accordance with all international, national and local laws and other requirements to which its business activities are subject.

Company defines the term of ‘Pollution’ as ; The violation of international and domestic environmental rules and regulations limitations

Pollution of the environment by a ship can be caused in a number of ways both as a result of system failure and of human error. MIKLAGARD S is committed to preventing both sources of error through a planned maintenance program and a program of education and training of staff, and through implementation of a set of procedures in accordance with its Safety Management System.

The objective of the Company is to prevent pollution of the environment from the following sources related to the aspects of its operations:

• Oil
• Noxious Liquid Substances
• Sewage 
• Garbage
• Dangerous Goods
• Ballast Water
• Cargo Vapour and Engine Emissions 
• Halons and CFCs 
• Noise
• Anti-Fouling Paints. 

MIKLAGARD S shall achieve this objective by maintaining, implementing, and monitoring relevant SMS procedures and operational instructions.

With the ultimate objective of protecting Human Life and the Environment and of assuring the highest standards of Safety at sea, the Company has established a “Zero Tolerance Policy” with respect to Consumption, Possession, Distribution or Sale of Drugs & Alcohol on board the vessels.

This Policy and the implementation details that are described below guaranty that:

• No seafarer will navigate a ship or operate its onboard equipment while impaired by substances
• All seafarers must be able to respond at any time in an emergency situation using their best capabilities and unobstructed judgment.

The Master is responsible for the implementation of the Zero Tolerance Drug & Alcohol Policy onboard his/her ship. The company shall provide him/her with the equipment and the necessary guidance to administer alcohol tests for all employees, officers and ratings, as well as all the necessary support to implement the disciplinary action. These regulating policies apply to all Company personnel during their employment period whether onboard or ashore. Pilots, office personnel, guests, contractors, vendors and any other person onboard shall be required to comply with the policy concerning use, possession, distribution and sale of alcohol and drugs and provisions.

Those who violate the policy shall be sent away from the vessel and may be denied future access.

Miklagard S Gemi İşletmeciliği ve Ticaret A.Ş. is determined to attract the best available seafarers and to ensure they receive all the necessary training in order to do their jobs in the most professional manner.

The HSE department is responsible for providing training to all seafarers serving onboard the Company’s vessels and office staff.

Miklagard S Gemi İşletmeciliği ve Ticaret A.Ş.  has committed to all seafarers and office staff that they receive the proper training, have their work performance reviewed in a consistent manner, and promoted when and if they are ready to assume greater responsibilities.

Future training requirements are determined by shore-side training course grades, onboard assessments by senior officers and attending superintendents, vocational training courses and sea service courses.

Miklagard S Gemi İşletmeciliği ve Ticaret A.Ş.  believes that training beyond STCW certification is necessary in order to have a best class sea and office staff.

Miklagard S Gemi İşletmeciliği ve Ticaret A.Ş.’s training program takes into account consistency in the   Company training policy, the selection and order of courses, course syllabus, training centers, standardized assessments and the selection of seafarers and office staff attending each course as practicable.

Pre-joining Training

Prior to employment, office staffs and seafarers attend an in-house Safety, Quality and Environmental familiarization course that introduces them to the Company’s policies and procedures, operating principles and guidelines, the importance of safety and Company business practices.

Onboard Training

All seafarers joining Miklagard S Gemi İşletmeciliği ve Ticaret A.Ş. vessels are required to undergo ship-specific familiarization. Elements of the familiarization process must be performed:

• Prior to ship’s sailing;
• Prior to undertaking his shipboard duties;

In addition to ship-specific familiarization, there is a continuous onboard training process that includes:

• Vocational training;
• Safety training drills and safety meetings;
• Onboard training performed by Master, Senior Officers and Shore-Based Company’s staffs.

MİKLAGARD S GEMİ İŞLETMECİLİĞİ VE TİCARET A.Ş. is continuously reviewing the selection criteria and contents of all courses available. The Company is committed to offering trainings related to new technologies as deemed favorable its onboard seafarers and office staff.

MİKLAGARD S GEMİ İŞLETMECİLİĞİ VE TİCARET A.Ş.

Health and Safety Protection Policy

MIKLAGARD S, its Directors and Senior Management are fully committed to ensuring the health and safety of all crew members and staff on board its vessels and in its offices, contracted personnel and any other persons who are directly or indirectly linked with its business and operations.

MIKLAGARD S is committed to conducting its business with integrity and in accordance with all international, national and local laws and other requirements to which its business activities are subject.

MIKLAGARD S will ensure that the concept of safe operations is conveyed and understood by all employees and that safe working practices are fully implemented on board all its ships.

The Company System complies with the requirements of OHSAS18001 ‘Occupational Health and Safety Management System’

MIKLAGARD S aims to achieve the following objectives, through implementation of our Health and Safety Protection Policy in line with our OHSAS 18001 Certification:

• Safety at sea 
•  Injury, occupational diseases and human loss prevention 
•  Prevention of damage to property (vessel and cargo) 

Relevant procedures and operational instructions are included in the Safety Management System (SMS) that MIKLAGARD S implements, maintains and monitors.

This policy; provides a good practise guidance for employee use of social media and other sites and services. The
Social Media Policy fully complies with the ISO 9001:2008, ISO 14001:2004, OHSAS 18001:2007, ISM Code and
MLC 2006 standards and Company’s; Health & Safety, Environmental Protection, Security and Quality Policies.
Definition of Social Media For the purposes of this policy, “social media is a type of interactive online media that allows parties to communicate instantly with each other or to share data in a public or internal forum.” This includes (but is not
l imited to):

• Online social forums such as Twitter, Facebook and LinkedIn;
• Blogs, video and image-sharing websites such as Instagram, YouTube and Flickr;
• Instant messaging technologies such as Skype, Whatsapp and Lync.

There are many more examples of social media than can be listed here since this is a constantly changing area.
These guidelines should be followed in relation to any social media used.

Scope of the Policy
Social Media Policy covers all ship and shore based staffs who are employed by the Company and it applies to both professional use of social media on behalf of the Company and personal use of social media when referencing the Company.

Purpose of the Policy
The purposes of this policy are;

• To promote good practise
• To promote effective use of social media as a part of the Company’s offical activities
• To protect the Company and its staff
• To clarify where and how existing Company policies and procedures apply to social media

Use of Social Media
The following principles apply to both professional use of social media on behalf of the Company and personal
use of social media when referencing the Company.

• Employees must know and adhere to the Company’s other policies when using social media in reference to the Company.
• Employees should be aware of the effect their actions may have on their images, as well as the Company’s image. The information that employees post or publish may be public information for a long time.
• Employees should be aware that the Company may observe content and information made available by employees through social media. Employees should use their best judgment in posting material that is neither inappropriate nor harmful to the Company, its employees, customers or rivals.
• Although not an exclusive list, some specific examples of social media sharing are prohibited include posting commentary, content, image or videos that are defamatory, pornographic, proprietary, harassing, libellous, or that can create a hostile work environment.
• Employees are not to publish post or release any information that is considered confidential or not public. If there are questions about what is considered confidential, employees must check with the Human

Resources Department

• Employees are not to publish confidential information about an individual (such as a colleague) or organisation (such as a customer) or discussing the Company’s internal workings (such as future business plans that have not been shared).
• Employees are not to publish offensive, derogatory or discriminatory comments or other contents relating to sex, race (including nationality), disability, religion and belief or posting any content that are discriminatory and offensive.
• Employees are not to publish any information that could cause a security vulnerability to the fleet vessels (position of the vessel, cargo type, ETA, ETS, ETB, port informations, number of personnel, crew change informations, etc.) according to Company Security Policy which is prepared in comply with the ISPS Code.

Information Sharing Through Social Media
HR Department publishes informations regarding to; official Company activities, courses, in-house/external trainings, seminars, forums, and any other required announcements through the Company’s web site.

Social Media Use in Emergency Situation
Since according to Company’s Emergency Procedures, all media (TV, Radio, Web, Newspaper, etc.) communications are to be managed by the Emergency Response Team in any emergency situation, vessel or office staffs are strictly prohibited to share any information through social media (or any similar platform) regarding to the emergency situation which is not confirmed officially by the Company. The Company shares all required official informations through its own web site in case of any needs.

Disciplinary Action over Inappropriate Social Media Use
All ship and shore staff are required to adhere to this policy. Employees should note that any violation of this policy may lead to disciplinary action as per the Company’s disciplinary procedures.