HSE Policy

1

HSE Commitment

We commit to:

Putting HSE as a primary priority: no operation has priority over HSE;
Providing and maintaining workplaces, equipment, tools, processes and means so far as is reasonably practicable that they are safe and without risk to health;
Empowering every individual to stop unsafe work activities immediately if a situation presents an imminent risk;
Complying with all applicable legal, regulatory and other requirements relating to occupational health and safety and environmental protection;

Continually improving our HSE performance, taking corrective actions, learning from incidents and near-misses and improving our systems, procedures and behaviors;
Minimizing environmental impacts from our operations (waste, emissions, resource use), and applying good practice for ship-yard environments (e.g., spill prevention, emissions control, responsible waste management);
Ensuring that HSE roles and responsibilities are clearly defined, including leadership accountability and line-management responsibility to integrate HSE in planning, execution and review of activities.

2

Roles & Responsibilities

HSE Department/Team:

Provide guidance, monitor compliance, audit, investigate incidents/near-misses, support management in risk control, lead training and awareness campaigns.

3

Risk Management & Safe Work Systems

All work must be planned and risk-assessed before execution. This includes identification of hazards (e.g., working at height, hot work, lifting operations, confined space entry, electrical hazards, chemical exposure, marine/coastal environment risks).
Permit-to-Work (PTW) systems and safe-work-authorisation procedures will be used for high-risk tasks;
Specific controls will be in place for: Hot work (welding, cutting), Work at height / scaffolding / ladders, Lifting operations and crane/hoist safety, Electrical and mechanical hazards, Chemical/paint/solvent handling and storage.
Sub-contractors will be required to demonstrate HSE competence, comply with our standards and integrate into our HSE system;
Regular inspections, audits and reviews of HSE performance will be conducted; non-conformities will be corrected promptly;
Emergency preparedness and response. We maintain and test procedures for fire, spill, explosion, major injury, environmental release, evacuation, and other relevant scenarios.

4

Permit-to-Work (PTW)

All high-risk activities including hot work, confined space entry, work at height, lifting operations, and electrical or mechanical isolation shall only be carried out under a valid Permit-to-Work (PTW) system.

The PTW ensures that hazards are identified, safety precautions are taken, and authorized personnel approve and monitor the work before it begins.

5

Personal Protective Equipment

All employees working on site shall wear appropriate personal protective equipment.

Head protection
Eye protection
Hand protection

6

Fire Prevention Policy

We commit to maintaining a fire-safe workplace by:

Identifying fire hazards and implementing strict hot-work controls (welding, cutting, grinding, etc.).
Ensuring Permit-to-Work (PTW) systems are applied for all hot work in docks, workshops, and onboard vessels.
Keeping work areas free from combustible materials, oil residues, waste rags, and flammable vapors.
Ensuring all flammable liquids, paints, and gases are stored in certified fireproof containers or designated storage rooms with adequate ventilation.
Providing automatic fire detection and alarm systems where appropriate.
Installing and maintaining fire extinguishers, hydrants, hoses, and fixed suppression systems as per international shipyard fire-safety standards.
Conducting regular fire risk assessments and reviewing them after changes in operations or layout.

Firefighting Equipment

Fire extinguishers, fire hoses, hydrants, and fixed firefighting systems (e.g., CO₂ or foam systems) shall be inspected and maintained regularly.
All extinguishers shall be properly labeled, easily accessible, and inspected monthly by competent personnel.
Equipment maintenance and inspection records will be documented and stored by the HSE Department.

Emergency Response Plan

The company maintains a comprehensive Fire and Emergency Response Plan, covering alarm systems, evacuation routes, assembly points, firefighting procedures, and communication protocols.
Clear evacuation maps and signage must be posted in all areas.
Emergency contact numbers and assembly points must be visible and regularly updated.
Coordination with local fire departments and port authorities is required for integrated emergency response.

Training and Drills

All employees and contractors must complete basic fire-safety and emergency-response training during induction.
Fire wardens and emergency team members receive additional training in firefighting equipment use, evacuation coordination, and emergency communications.
Fire drills shall be conducted at least twice per year for all operational areas, including workshops, dry docks, and vessel areas.
Lessons learned from drills and actual incidents will be used to improve procedures and readiness.
Visitors and short-term contractors receive site-specific fire safety briefings upon arrival.

7

Training, Competence & Culture

All personnel (employees, contractors, visitors) will undergo HSE induction, and periodic refresher training appropriate to their role and risk exposure;
Supervisors and HSE staff will receive additional training in risk assessment, incident investigation, behaviour-based safety, leadership in safety;
We foster a positive HSE culture: every person is encouraged and entitled to raise HSE concerns, stop unsafe work, and propose improvement;
Regular toolbox talks, job-safety analyses before tasks, behavioral safety observations and communication campaigns will be used to reinforce safe behavior;

8

Environment

We commit to preventing pollution, reducing waste, minimizing resource consumption (energy, water, raw materials), engaging in responsible disposal or recycling of waste, and using best-available techniques/operations to avoid environmental harm.
Operations will strive to reduce harmful emissions, solvent/paint waste, uncontrolled discharges, and will manage environmental aspects through defined objectives and targets (e.g., reducing CO₂, emissions, spill incidents) as part of our environmental management system.
We will comply with applicable environmental legislation and permits, and regularly audit our environmental performance.

9

Performance Monitoring, Review & Continuous Improvement

Key performance indicators (KPIs) will be set for HSE (e.g., lost time injury frequency rate (LTIFR), near-miss reporting, number of unsafe work stoppages, number of environmental incidents, spill volume, waste recycled, energy consumption reduction).
The HSE Policy and system will be reviewed at least annually by top management to ensure continuing suitability, adequacy and effectiveness.
Incidents and near misses will be investigated promptly, root-causes identified, lessons learned communicated and action plans implemented.

HSE management system will follow the Plan-Do-Check-Act (PDCA) cycle:

Plan: Establish context, identify issues, set objectives.
Do: Implement controls, operational activities, emergency procedures.
Check: Conduct internal audits, compliance evaluations, management reviews.
Act: Implement corrective/preventive actions, improve system and performance.

10

Drug & Alcohol Policy

As per our commitment to health and safety, any employee, contractor or visitor under the influence of alcohol or drugs or in possession/distribution of such substances on our site constitutes a serious breach.

No working while under the influence of alcohol, drugs or un-prescribed substances.
Any detection of such influence or possession will lead to disciplinary action (up to termination) as per company procedures.
Those on prescribed medication affecting their ability to work safely must report to the site medical facility.

11

Responsibilities of Visitors & Third-Parties

Visitors and third-parties onsite must comply with our HSE rules, attend site safety briefings, wear required PPE, obey signage and escort requirements.
Any breach of HSE rules by visitors or contractors may result in removal from the site.

12

Scope of Review

This Policy covers all operations at our ship-building/repair facility, including but not limited to fabrication, assembly, painting, slashing, inspection, launching, heavy lifting, dock operations, subcontractor work and site support services.
It is applicable to all personnel including full-time employees, subcontractors, visitors, suppliers and other stakeholders when on site.

Health, Safety & Environment