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•    Risk analysis and risk assessment are the main tools in the company taking decision concept, 
•    Having risk management consciousness will be ensured to all responsible management personnel in the office and on board,
•    Risk matricies are prepared accourding to company’s special health, safety, environment and finance subjects,
•    Degrees / conditions of taking risk and accepting risk of the company will be determined,

Risk Management
1-    Risk Assessment at Office
2-     Risk Assessment on board

Risk Assessment
1-    Termination of risk completely
2-    Toleration of risk
3-    Transfer of financial risk
4-    Treatment of risk

Requirements for Risk Treatment
1-    Control Activities in Risk Management
2-    Identify the work
3-    Set standards
4-    Measure
5-    Evaluate
6-    Support or Commend / Correct if necessary


•    Safety related issues shall be given priority in training activities,
•    Necessary measures shall be taken at the ports in order to secure physical safety of the ship,
•    The deliberate activities seriously threatening safety of the ship shall be considered a reason for termination of employment contract,
•    The safety element shall always be taken into consideration primarily for the activities aboard ships and no sacrifice shall be made in this aspect,
•    No activities threatening ship, life, property and environment safety will be allowed aboard the ship,
•    All the environment related subjects and activities shall always be taken into consideration primarily and strongly supported, no sacrifice shall be made in this aspect, 
•    Always to be alert for the environmental emergencies,   
•    To comply with entire national and international legal rules and regulations ensuring prevention of land, air and sea pollution,
•    All the environmental protection systems and equipment conditions and standards will be kept and  maintained on top condition,
•    Risk assessments will be done on each environmental management stages and proactive measures will be taken against all the risks,
•    To employ personnel having sufficient environmental competency, quality and ability aboard the ships and ashore,
•    The external/interested parties and other third parties’ environmental comments / recommendations shall be taken into consideration during environmental management system reviewing meeting(s). 


          The following criteria were defined in order to adapt the new officers to their tasks in the ships as soon as possible in order not to hinder the ship safety. 

•    The ship officers, during their handover tasks, will work together as long as possible. This joint working period will be:
- On-sign officer has the sufficient experience in same type ship; min 12 hours,
- On-sign officer does not have sufficient experience; min 24 hours,
•    As the company’s policy, the task change can not realize the Master and Chief Officer, or Chief Engineer and Second Engineer at the same time because they are the Key Personnels,
•    In specific situations that on-signed officer, who is not key personnel, and leaving officer cannot work together, the on-signed officer will be trained by a most experienced officer in ship for adaptation,
•    The Master and Chief Engineer, Chief Officer and Second Engineer cannot leave the ship altogether, if there is not an experienced officer, who knows the ship, for deck and engine-room in the ship,
•    In special cases, where majority of the ship officers and crew are changed, a long-term joint working or training will be taken into consideration.
•    During Loading and Discharge operations, the ‘key personnel’ change cannot be carried out. After the end of these operations, handover procedures are carried out.

 Procedures for Fastest and Correct Response to the Emergencies
1-    Emergency Response Procedure Aboard the Ship
2-    Emergency Response Procedure at the Company
3-    First Action Procedure In Case of Emergency 
Identified Potential Emergencies:
01     Main Engine Failure / Emergency Stop 
02    Steering System Failure 
03     Collision
04     Grounding                     
05     Collision with Submerged Items 
06    Fire
07    Fire on Deck 
08    Fire Accommodation
09     Fire in Engine Room 
10     Fire Galley
11    Fire in Pumproom 
12    Fire Cargo Area
13     Flooding                                     
14     Man overboard 
15     Oil Spill 
16     Pier / Shore Installation Damage 
17     Serious Injury / Dead 
18      Fire on Terminal / Breake Away from Jetty  
19     Piracy
20     Detention
21     Stowaway / Refugees 
22     Suspicious Items/Packages - Bomb Search 
23     Abondoning ship 
24     Search and Rescue (SAR) 
25     Helicopter Rescue
26     Rescue from Enclosed Space 
27     Gyro Compass Failure 
28     War Risk and Military Request
29     Dead Ship
30     Heavy Weather and Sea 
31     Salvage / ETA
32     Sabotage / Terrorist Attacks 
33     Bunker Spills 
34     Bridge Control System/Engine TelegraphFailure

Emergency Response Procedure at the Company:
An “Emergency Response Team (ERT)” has been established at the company to response the emergencies. 
The Emergency Response Team consists of the following personnel:
(1)    Operation Manager /DPA (Chief of ERT) 
(2)    Technical Manager (in the absence Opr. Mng., acts on behalf of Chief of ERT)
(3)    Human Resources Department Manager
(4)    Logistics Department Manager
(5)    Superintendents & Asst.Opr.Manager

All the emergency contact information for external organizations are filed in the ERT file and updated under DPA responsibility in every 3 month period in ‘quarterly performance evaluation meetings’ in the office.

ERT General Duties:


1.    Evaluate the accidents / near misses aboard ships and
if necessary get in touch with

- Opr. Mng./DPA
- Tech. Mng.
- Authorities,
 - Opr. Mng./DPA
- Asst.Opr. Mng
- Charterer and agencies,
- Opr. Mng./DPA
- Asst.Opr. Mng
- Insurance (P&I),
- Opr. Mng./DPA
- Asst.Opr. Mng
- Class, technical experts and consultants.
- Tech. Mng.
- Superint.

2.    Provide help and guidance to the ship management in order to mitigate the negative impact on the ship crated by the incident and to improve the personnel performance.
- Tech. Mng.
-Opr. Mng./DPA
- HR Mng.
- Superint.
- Asst.Opr. Mng

3.    Prepare and implement an urgent action plan in order to control the incident underway and establish most appropriate response method.
- Tech. Mng.
-Opr. Mng./DPA
- Superint.
- Asst.Opr.Mng.

4.    Criticize the current situation continuously and direct the ship management for following probable incidents by predicting them.
-Opr. Mng./DPA
-All ERT Members
-All ERT Members

5.    Get in touch with media if necessary
(seeChapter 15).

- Opr. Mng./DPA
- Tech. Mng.

Definition of Accident / Incident 
01    Classification of Incidents/Accidents
02    Accident/Incident Investigation Team

Accident / Incident Investigation and Analysis
1.    Benefits of Reporting Accidents or Potential Accidents in a Defined Method

Method of Corrective Measures
1.    Implementation and Follow-up of Corrective measures

Accident / Incident Investigation Procedures
1.    Follow-up and Control Procedure of  Accident/Incident and Near Miss Protective Measures
2.    Marine – Systematic Cause Analysis Technique (M-Scat)

Classification of Incident/Accident

Negligible:   Injury not requiring first aid,
                     No cosmetic vessel damage,
                     No environmental impact,
                     No missed voyages
Minor      :   Injury requiring first aid
                     Cosmetic vessel damage
                     No environmental impact
                     Additional work
                     Minor operational disruption
                     No missed voyages
Significant: Injury requiring more than first aid
                     Vessel damage
                                 Some environmental damage
                                 Longer operational disruption
                                 Financial loss
Critical          : Severe injury
                         Major vessel damage
                         Major environmental impact
                         Major operational disruption
                         Miss voyages (up to and including the entire season)
Catastrophic :Loss of life
                         Loss of vessel
                         Extreme environmental impact

•    Negligible, Minor and Significant accident/incidents are investigated by the Ship Investigation Team (Master, C/E, C/O).
•    Critical and Catastrophic accident/incidents are investigated by the Company Investigation Team (Technical Mng., Opr.Manager/DPA,  HRMng.).

Accident/Incident Investigation Team

Accident/Incident investigation teams divided into two groups, company accident/incident investigation team and vessel accident/incident investigation team. 

-    Company Accident/Incident Investigation Team:
They investigate all kinds of accident/incidents occured in the office and critical and catastrophic accident/incidents on ships.
Team formed from Opreation Manager / DPA(team leader), Technical Manager, Logistic Manager and HR Manager.
According to nature of the accident/incident, number of persons in investigation team can be increased.

-    Vessel Accident/Incident Investigation Team:
They investigate negligible, minor and significant type of accident/incidents accoured on ships.
Team formed from Master(team leader), Chief Officer and Chief Engineer.
According to nature of the accident/incident, number of persons in investigation team can be increased.
Investigation team should immediately act and investigate accident/incidents. Investigation should be completed as soon as possible and team should present their report to ERT in company.
Regardless the position of personnel, no one take place on investigation teams who connected with accident/incident. 

Shore-Based Management Meetings
1.      Weekly Coordination Meeting
2.    3 Monthly Performance Assessment Meeting
3.    Yearly Management Review Meeting

Company’s Emergency Response Team Meetings

Ship-Based Meetings
1.    Monthly Ship Safety, Security and Environment Protection Meeting
2.    Ship Performance Self Assessment Meeting


•    All precautions regarding the health and hygiene shall be measured as per national and international laws, rules and regulations,
•    It should be provided necessary environment for opinions or suggestions of staff about health, hygiene care and staff should be encouraged to participate,
•    Effectively information sharing, safety and regulations to prevent accidents and education are the most part of company health and hygiene policy,
•    In case insufficiency of the ship’s opportunities all chances for the health of all crew shall be sacrificed,
•    Periodic check up for all ship’s crew shall be maintained,
•    The crew who is not fit for duty on board shall ever and never be employed.

Work Permit System
1.    Hot work (Hot Work at Enclosed Spaces - Hot Work at Open Deck)
2.    Cold Work
3.    Entrance to Enclosed Spaces
4.    Work on Electrical Circuits
5.    Working Suspended and on the Mast
6.    Working in the Lifeboat
Hygiene / Health Aboard the Ship
1.    Rest Hours of Crew
2.    Health of Crew
3.    Health Services
4.    Implementations Associated with Drugs and Alcohol
5.    Control Methods of  Drugs and Alcohol Implementations
6.    Smoking Regulations
7.    Hygiene aboard the Ship
Sickbay and sickbay Equipment Aboard the Ships
Storage and Handling of Chemicals
Safety Campaigns and Encourage for the Safety, Health, Environmental
Activities and Reports


•    It’s strictly prohibited on board of all our ships to have, provided, distribute and sell all kinds of alcohol,
•    Permission on board of all our ships enable to have alcohol during port stays (when the crew is allowed to go shore with their shore passes) are restricted being % 0.04 (40mg/100 ml) of alcohol in the blood. Alcohol test of all crew when they are back on board from shore would be conducted by the officer on duty. The crew who will be on duty within forthcoming 4 hours shall stop to have alcohol,
•    The master or the officers having the master’s instruction of all our ships have the right and authority to conduct alcohol test, whenever they wish on the crew, of whom they want and suspect. Any personnel who deny the subject test their contract are immediately cancelled,
-    All Crew should be tested Chemical, Alcohol and Drugs before joining the  vessel by the Company which we have agreement with
-    Alcohol test should be done randomly on board every month.
-    Frequency of unannounced drug test on board is 12 months by shore responsible society.
-    Any failure to comply with alcohol policy of the company is considered as a major reason for cancellation of the contract.


•    The company will employ the staffs who are all experts and experienced in the fields where the company acts and all precautions to maintain this aim will be taken,
•    The criteria of recruitment, promotion and termination will be defined clearly and implemented without tolerants,
•    Career planning will be done for all duties,

For Company’s Employees
1.    Selection Criterian for Office Staff
2.    Recruitment Procedure 
3.    Training and Motivation
4.    Performance and Evaluation of Company Personnel
5.    Shore Based Management Handover Procedure
For  Seafarers
1.         Qualification Conditions/Criteria for the Master
SMS Training Before Joining To Ship
SMS Training In Ship
SMS Training In The Company
2.    Selection and Recruitment Criterion and Career Planning For Seafarers
3.    Selection Criterion
4.    Determination of English Level
5.    Career Planning / Promotion
6.    Physiological and Medical Convenience
7.    Recruitment
8.    Dismissing

For  Training and Evaluation of Seafarers
1.    Training Before Joining To Ship
2.    Training In Ship
3.    Training And Adaptation Programs For First Seaman Who Initiates To Work In Ship
4.    On-The-Job Training And Adaptation Programs In Ship
5.    Trainings In The Company

Company Award Regulations
Important Points of Our Selection Criteria
Main criterias for All Seafarers 
1-    To have a licence, a seaman book, passport, certificates of STCW and physical examination certificate for seafarers,
2-    Licence, seaman book, police visa, passport validity and STCW certificates should have appropriate validity,
3-    Professional knowledge and capability,
4-    Sense of responsibility,
5-    Leadership capability, personnel handling and manage personnel,
6-    Be aware of company policy and targets,
7-    Physical and psychological sufficiency,
8-    Be aware of safety structure and environmental protection,
9-    Be open to improve and orientate yourself,
10-    Acknowledge of ISM, ISPS, and ISO,
11-    Be aware of teamwork.

Main criterias for Senior & Junior Officers
1-    Graduated from Faculty or Instution Of Higher Education,
2-    Use computer skills at an upper intermediate level,
3-    To have an advanced marine language (English),
4-    To have a GOC license.(deck officers only),
5-    To have Ship Security Certificates range of the ISPS Code. (deck officers only),
6-    Reference evaluations from other companies should be appropriate,
7-    Be aware of RIGHT SHIP criterions,
8-    To have a capability to give training.

a.    Master
1-    Experience in the same duty at least 2 years at the bulk carriers and general cargo vessels,
2-    Before take a captain license, work at least 2 years, as a chief officer at the vessel that is in the structure of the company. Performance evaluations carry out by the office and as result sufficient candidate work as a captain,
3-    Not Passover 60 years of age,
4-    Have carry out a rightship vetting before,

b.    Chief Officer
1-    Experience in the same duty at least 1 year at the bulk carriers and general cargo vessels,
2-    Before take a chief officer license, work at least 2 years, as a second officer at the vessel that is in the structure of the company. Performance evaluations carry out by the office and as result sufficient candidate work as a chief officer,
3-    Not Passover 50 years of age,
4-    Have carry out a rightship vetting before.

c. Chief Engineer
5-    Experience in the same duty at least 2 years at the bulk carriers and general cargo vessels,
6-    Before take a captain license, work at least 2 years, as a second engineer at the vessel that is in the structure of the company. Performance evaluations carry out by the office and as result sufficient candidate work as a chief engineer,
7-    Not Passover 60 year age,
8-    Have carry out a rightship vetting before,

d. Second Engineer
1-    Experience in the same duty at least 1 year at the bulk carriers and general cargo vessels.
2-    Before take a second engineer license, work at least 2 years as a third engineer at the vessel that is in the structure of the company. A performance evaluation is carried out by the office and if he is found as a sufficient candidate to work as a second officer.
3-    Not Passover 50 years of age.

e.  Deck Officers & Engineers 
1-    At least 1 year period work as a deck officer/engineer at the bulk carriers and general cargo vessels.
2-    Before work as deck officer/engineer, have to trainee at the vessel that is in the structure of the company. A performance evaluation  is carried out by the office and as a result sufficient candidate work as a deck officer.
3-     Not Passover 35 years of age.


•    On board of the ships for all duties on duty trainings shall be planned and implemented,
•    Training levels of the personnel will regularly be tested and additional complementary trainings shall be provided for the personnel who are identified as unqualified,


In our company’s training center, there are detailed and current video training cassettes concerning our commercial activities and fleet structure. The ship officers gather periodically in the company’s head office (during long lasting maintenance, overhaul works and leaves, etc), and watch these video training cassettes after theoretical trainings to reinforce the trainings.

In this way, it is ensured all seafarers, who work in all our ships, to have high training standard, and to sustain it. Also The company encourages and supports appropriate interpersonal skills training and taking higher education courses.


•    Proactive measures shall be taken in maintenance and repair activities to be able to keep one step ahead of the incidents 
•    All the safety measures shall be taken before initiating maintenance and repair works and no sacrifice shall be made in this aspect.
•    Original or equivalent parts shall be preferred to supply spare parts. 
•    The engine room and deck equipments directly affecting ship safety (critical systems/equipments) shall be identified and kept in operational status at all times.

General Maintenance and Repair Principles
Critical and Stand-by Systems/Equipments
1.    Maintenance and Repair of Critical Equipment
2.    Stand-by Equipments and Systems

Shipboard Planned Maintenance and Control Systems

Routine Controls to be Carried-out by Ship Personnel and
Deficiency / Damage Follow-up system.
Routine Controls to be Carried-out by Company                
Deficiency reporting Follow-up System
Duty and Responsibility for Correction of Deficiencies
Preparation of Dry Docking / Repair Specifications
Workmanship Standards and Criteria for Repair and  Maintenance
Spare-parts Selection Criteria


Shore-BasedVessel Inspections/Controls

The aim of the inspections/controls and the procedures followed are mentioned below.

a. Operation Dept. Planned Vessel Controls
Inspections/Controls in every 6 months periodically by theshore-basedmanagement (Dept.Mngs. orSuperintendents)

The aims of this inspection are,
-    to check the vessel’s performance and condition according to Right Ship Check List and 
-    to establish by performance and the professional convenient of the staff at the vessel, 
-    also the education needs to be determined.

b.    Technical Dept. Planned Vessel Controls 

Inspections/Controls in every 6 months periodically by theshore-basedmanagement (Dept.Mngs. orSuperintendents)

The aims of this control are,
-    to check the vessel’s performance and condition according to Technical Dept. Inspection Check List and 
-    to establish by performance and the professional convenient of the staff at the vessel, 
-    also the education needs to be determined.

•    The aim of this policy is using and saving of the energy which is the greatest necessity of our age. Our goal is using it correctly, prevent unnecessary consumption, saving with simple ways and trained every employee.

•    There will be no concession on, safety and enviromental standards, when changing operation procedure, ship’s system/equipment and personel,
•    When making changes, risk assessment will be done and all necessary precautions will be taken in order to minimise operational risks,
•    Precautions, for solving/minimising the negative  formations due to management of changes will be included,
•    The effects of  management of change, will be looked at in the Management Review, at the end of each year.
To ensure that all proposals for changes to existing vessels and systems are investigated completed and documented in a professional and timely manner commensurate with the Company’s Management Systems and ISM Code requirements for a safe and proper Management.


Work arising from temporary and permanent changes to organization, personnel,  systems, process, procedures, equipment, products, materials or substances and laws and regulation cannot proceed unless management of change process is completed, where applicable, to include;

1. a risk assessment conducted by all impacted by the change, 
2. development of a work plan that clearly specifies the timescale for the change and any control measure to be implemented regarding;
a- equipment,facilities and process 
b- operations, maintenance, inspection procedures  
c- training, personnel and communication 
d- documentation
e- authorization of the work plan by the responsible person(s) through completion.

•    The market leader international companies within the sector will be followed closely,
•    We will be in close contact with education institutions/associations, in order to carry out joint studies at any opportunity,
•    Broadcasts and periodical publications, concerning the sector will be followed, in order to follow the new developments within the sector, which will be implemented to the company structure, if needed necessary,
•    Especially for incident and near-miss cases, with wide participated information transfer network, will be set and operated.

 Aim of Benchmarking Meeting is to improve company’s management standards via sharing information and experiences with the sector’s leading companies.

For this purpose;

1.    Benchmarking meetings should be done 6 months interval on companies’ main offices.
2.    Companies general managers, senior managers, department managers and/or equal ranked managers can participate to the meetings.
3.    Subjects existed in previous era and/or found necessary to discuss will be discussed during meetings. 

These will be (but not limited);
a.    Accident/Incidents and necessary actions to be taken,
b.    Right ship Vettings, Inspections and Controls (Rightship, Class, PSC),
c.    Present and new regulation applications,
d.    Seminar/conferences relating to sector; and
e.    Training requirements and joint solutions.  


•    When choosing a contractor, a contractor with ISO quality certificate will be our priority,
•    The operations of the contractors, specially the safety and environment safety aspects, are to be kept under control at all times, they will not be allowed to take any action, which is jeopardize our safety rules,
•    The performance of the contractors will be monitored and reviewed, which will be used for considered on their next employment,
•    The results of our reviews will be circulated to them, in order for them to improve themselves,
•    The National contractor companies, especially shipshandlers will be visited and inspected at their premises.