POLICIES

It is the Policy of PTM to conduct business in an honest, sincere lawful and ethical manner. Acts of bribery and corruption are condemned and the Company is committed to act professionally, fairly and with dignity and integrity in all business dealings and relationships. This is irrespective of the exact time and location of any operation. Effective systems such as the auditing of accounts are in place to counter bribery and corruption.

In addition to the above principle PTM will respect the Law of the Country of Registry of the ships, the International Conventions related to the Law of the Sea and those local laws that have become known to us through the appointment of local Agents in foreign countries in an effort to counter bribery and corruption. Bribery and corruption are punishable for individuals committing a relevant offence and the Company could face severe consequences that could include imprisonment, fines and damage of its reputation.

PTM employees should always act on a good faith basis, enter into commitments that are feasible to be met, fulfil the Company obligations, never mislead people, never participate in corrupt business practices, and treat people with merit and respect.

Sometimes ethical decisions involve dilemmas; in such cases it is necessary for the relevant issues to be brought to the attention of the Company management and employees should seek for instructions within the framework of this policy.

This policy is applicable to both shore and shipboard employees at all levels.

Drug and Alcohol (D&A) abuse is one of the major social problems of today’s world. Within the shipping industry, Maritime Authorities and Organizations, having identified the negative effects on ships’ safety, have issued strict regulations and instructions to control D&A use, abuse and drug trafficking.  

PANTHEON TANKERS MANAGEMENT LTD., recognizing the importance of the issue, has adopted the following Policies:

§  Consumption of alcohol is not allowed on board Company’s vessels. ALCOHOL FREE VESSELS

§  The possession, use, trafficking and sale of drugs onboard the Company’s vessels is prohibited and is viewed as a severe offense.

§  Any crewmember found involved in any drug related activity will be discharged at the first port of call and his future employment with the Company cancelled.  Depending on the nature of involvement Authorities may be notified and/or legal prosecution may be initiated.

§  Use of prescribed drugs for medical treatment is allowed only under controlled conditions and following specific medical advice.

§  Drugs kept in medical chest must be locked under Master’s responsibility and control.

§  Company has adopted the policy that no seafarer, irrespectively of rank, will navigate the vessel, operate its equipment or perform assigned duty at any time while impaired by drugs or alcohol. Any seafarer found to be under influence of drugs or alcohol shall be immediately released from duty.

§  No spirits are allowed to bring on board.

§  Alcoholic beverages and spirits are not allowed in crew quarters.

§  Blood alcohol content of 40mg/100ml or greater is considered as alcohol impairment.

§  Breath test content of 25mg/100ml or greater is considered as alcohol impairment.

§  All officers and ratings are subject to pre-employment D&A test. Above disciplinary actions apply in case of violation.

§  Unannounced drug and/or alcohol tests will be carried out as per Company’s instructions.

§  Equipment for alcohol test is available onboard all Company ships.

Company will take disciplinary action, including crewmember discharge at the first port of call and his/her future employment with the Company will be cancelled, termination of employment, against anybody on board who is proven to:

§  Have consumed banned substances at any time.

§  Have consumed any quantity of alcohol.

§  Be unfit for work due to the use of drugs or alcohol.

§  Possess or be accessory in bringing aboard a managed vessel alcohol or any banned substance.

Compliance with this policy is mandatory for all Company’s shipboard personnel, as well as, for all persons boarding the ship under any capacity.

The Master is responsible to ensure compliance and enforce appropriate measures as per Company’s instructions.

Pantheon Tankers Management Ltd. is a leading provider of Crude Oil and Dirt Petroleum Products transportation services, utilizing its oil tankers fleet.

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 a way of life than just a mere compliance with rules and regulations so as to achieve Continual Improvement.

• With the aim of enhancing the energy efficiency of the ship operations, the Company is committed to:
• Implementing an Energy Management Program for continually increasing energy efficiency and minimizing energy waste. A set of time-specific, measurable -whenever practicable and possible- and attainable targets are established and maintained, which relate to a combination of design optimization, in-service performance monitoring and best-practice operational management processes.
• Ensuring availability of information and the necessary resources to achieve its objectives and targets.
• Supporting the purchase of energy-efficient products and services as well as to supporting design options that improve energy performance.
• Establishing and maintaining an Energy Efficiency Management Plan, which is regularly reviewed by senior management. This Plan, which applies to all fleet vessels, provides standard procedures and practice on best energy management under the various operational modes of the vessel.
• Ensure availability of information and necessary resources to achieve objectives and targets
• Promoting energy efficiency awareness through training to the shore and sea-going personnel and implementing energy related campaigns and other relevant personnel incentive/motivating programs.
• Promoting co-operation within the shipping industry for facilitating energy efficient operations.
• Monitoring and complying with all applicable legal requirements related to ship energy management.

The Company’s Energy Efficiency Management Policy is periodically reviewed with the aim of being kept always updated so as to function as the driver for a continual energy/ efficiency improved performance.

PANTHEON TANKERS MANAGEMENT LTD. is fully committed to conducting its activities in an environmentally responsible and sustainable manner with the ultimate goals of preventing damage to the environment, achieving ZERO INCIDENTS, ZERO SPILLS or releases to environment and reduction in permitted emissions targets and ensuring the continual improvement of its environmental performance.

Furthermore, the Company is committed to:

• Comply with all applicable legislation and other requirements to which the Company subscribes which relate to its environmental aspects and strive, where practicable, to exceed compliance requirements.
• Assess on a continual basis the environmental risks associated with its operations, setting appropriate objectives and targets and implementing environmental programs to minimize the environmental impact of its operations by reducing waste, emissions and discharges, by minimizing its impact on biodiversity and by using energy efficiently.
• Pollution prevention that emphasizes source reduction, including funding and human resources, necessary to effectively maintain and repair the onboard systems, equipment and components such as but not limited to:
  - Oil, associated products/chemicals, LNG & LPG
  - Noxious Liquid Substances
  - Sewage
  - Dangerous Goods
  - Garbage
  - Ballast water (including the transfer of micro-organisms)
  - Cargo Vapour and Engine Exhaust Emissions
  - Halons and CFCs
  - Noise
  - Anti-Fouling Paints
• Promote environmental awareness through the training and education of its employees.
• Respond quickly and effectively to pollution incidents resulting from its operations, in co-operation with industry organizations and authorized government agencies.
• Engage with shipping industry organizations and relevant authorities and participate and support research initiatives with the aim of developing measures to minimize the shipping industry’s impact on the environment.
• Communicate its Environmental Policy to the public.

The safety of personnel, vessel, cargo, and the protection of the environment is the foremost objective in the navigation of managed vessels. Speed and economy, while important, are secondary to safety and environmental considerations.

Navigational safety requires selection of courses and speeds that provide a margin of safety which takes into account all of the influences which could affect the vessel’s progress, and is dependent upon the prevailing conditions and location.

The Master is fully responsible for the safe navigation of the vessel. He should obtain all relevant navigational information and secure that all applicable International, National and local navigational Rules are followed, that all courses are planned in accordance with Company voyage planning requirements and that operating practices safeguard the vessel, its personnel and cargo.

The ultimate responsibility for safe navigation rests with the Master. However, this responsibility also extends to Officers and Crew, who must always be on the alert to prevent incidents. It is the duty of each crew member observing any situation which they feel may endanger the safety of personnel, the vessel, the environment, or the cargo or impact on flawless operations, to report their observations to the Officer of the Watch, or if circumstances dictate, to the Master. An investigation should be carried out immediately and action taken as necessary.

Regarding safe navigation the Company, has established procedures for sound and efficient Bridge Organisation, Passage Planning and Voyage Execution. The main objective of the procedures is to ensure all Company vessels passage planning and execution of voyages will be carried out, having the safety of the vessel, the crew, the cargo and the environment as the primary objectives. In order to achieve this objective:

• Navigation of the vessel shall be based on the Bridge Team Management concept, which is based on the elimination of “one person errors”.
• All Officers must be fully aware of the Company navigation procedures and COLREGS.
• All Officers must be familiar with their duties, the operation of all navigational equipment and the vessel’s manoeuvring capabilities.
• Navigational publications and the relevant updates shall be regularly provided to all the vessels by sub contracted Chart Agents and updates shall be regularly carried out by the designated Officer onboard.
• ENCs are available and routinely updated;
• All deck officers have undergone ECDIS generic training and completed the
• Familiarization process (including type specific training to ECDIS installed on board), in accordance to IMO requirements.
• All navigation watchkeeping officers must be competent in the control of safety parameters and alarm settings including alarm interrogation of ECDIS, prior to taking charge of a navigational watch.
• Especially for paperless bridge operation, two (2) legally compliant and Class certified ECDIS should be available with updated ENCs.
• Passage planning shall be prepared prior to voyage commencement and shall be approved by the Master. Execution of the voyage shall be based on the passage plan, with all necessary modifications which may be required, considering the weather, traffic and vessel conditions prevailing at any stage of the voyage

Company vessels shall provide safe, reliable and efficient marine transportation. The safety of Life and the Ship shall always take precedence over other considerations. Nothing in this policy or in any regulation issued by the Company should be construed as relieving any Master, Officer or Crew member of their responsibilities to exercise sound judgment at all times.

The Company is committed to placing the health of its employees among its top priorities and seeks to ensure that all shore staff and seagoing personnel execute their work under healthy and hygienic conditions.

In order to ensure high standards of health and personal hygiene it is the Company's Policy, authorized by the top Management to:

• Comply with all applicable laws and regulations, and apply responsible standards where laws and regulations do not exist, as to preventing injuries and illnesses of personnel
• Identify, evaluate and minimize health and hygiene risks from hazards related to its operations that potentially affect its employees, contractors or the public
• Communicate Policy and knowledge about health and hygiene risks to its employees and where appropriate to interested parties within the maritime community
• Determine at the time of employment, and from time to time thereafter, the medical fitness of employees to do their work without undue risk to themselves or others
• Provide or arrange for medical services necessary for the treatment of employee occupational illnesses or injuries and for the handling of medical emergencies
• Undertake appropriate reviews and evaluations of its documented operations procedures to measure progress and to foster compliance with this Policy, aiming at continual improvement of the management system
• Implement programs and appropriate protective measures to control health risks
• Work with government agencies and others to develop responsible laws, regulations, and standards based on sound science and consideration of risk
• Provide 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 for their own health care.

Information about employees obtained through the implementation of these programs should be considered confidential and should not be revealed to non-medical personnel except at the request of the employee concerned, when required by law, when dictated by overriding public health considerations, or when necessary to implement the Company’s Drug and Alcohol Policy.

Company 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.
• Contribute to a better society by offering safer transportation & a cleaner environment
• Identify and promote its Values across the organization with the active involvement of its personnel (any person working (or providing services) for or on behalf of Company)
• Manage Human Behavior and Attitude and Utilize Risk Management Tools to address the Human Element
• Invest on Competency, Training and Professional Development of its people
• Promote Safety Culture across the organization investing on Credibility, Action-Orientation, Vision, Accountability, Communication, Collaboration, Feedback and Recognition
• Invest & maintain on a Learning Organization
• Promote a culture of supporting the health & wellbeing (physical & mental) issues of employees
• Seek for Stakeholders’ engagement

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 and 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.

It is the Company’s Policy that the quality of its operations, the safety and health of its employees and the protection of the environment remain the predominant factors in all aspects of its operations.

In this respect, the Company has established and maintains a Safety Management System, or SMS, that is designed to continuously improve the quality of the services offered by the Company. The SMS is based on the belief that preventing problems from occurring is in the best interests of the Company, its employees and its customers.

The Company recognizes the importance of customer satisfaction and will work to provide services to its customers which meet or exceed their requirements and are in accordance with the standards of the Company. Open and ongoing dialog will be maintained with customers, and all stakeholders, to provide a channel for communicating expectations and discussing feedback on performance.

In order to ensure that operations and quality service objectives can be achieved, the SMS addresses the continuous monitoring of all aspects of the Company’s operation so that potential problems can be readily identified and appropriate corrective actions implemented. The Company seeks to constantly learn industry best practices, and, where there is a clear benefit, these will be adopted by the Company.

The Company is committed to conducting all its activities in a safe, efficient and environmentally sound manner, while ensuring effective and efficient compliance with prevailing statutory and regulatory requirements.

This Quality Policy has the full support of Senior Management. It is mandatory that the Quality Policy and SMS are known, understood, and adhered to by Company employees.

It is the Company’s Policy to promote Safety at sea and in the workplace and to avoid damage to the environment. In order to comply with this Policy, the Company is committed to constantly striving to identify and eliminate, or manage, safety risks associated with its activities and yet ensuring continual improvement of the management system.

The Company’s objective is to conduct its business in a manner that protects the safety of employees, others involved in its operations, customers, and the public as well as to prevent all accidents, injuries, and occupational illnesses through the active participation of every employee in the Company’s Safety Programs.

In order to achieve these objectives, the Company will:

• Comply with all applicable laws and regulations, and apply responsible standards where laws and regulations do not exist.
• Establish management systems, provide training and conduct operations in a manner that safeguards people and property.
• Respond quickly, effectively and with care to emergencies or accidents resulting from its operations, in co-operation with industry organizations and authorized government agencies.
• Stress to all employees, contractors, and others working on its behalf their responsibility and accountability for safe performance whilst at work and encourage safe behavior outside of work.
• Undertake appropriate reviews and evaluations of its documented operations procedures to measure progress and to foster compliance with this Policy.
• Work with government agencies and others to develop responsible laws, regulations, and standards based on sound science and consideration of risk.
• Company is committed to promote workers participation in safety committee meetings and consulation through suggestions.
• Comply with Stop Work Obligation procedures applied across the fleet.
  
• Work towards achieving the objectives of the Zero Incident Industry.
  
• To promote a process approach and risk based thinking throughout the organization.
  
• To lead by example.
  
• To establish and maintain Safety Culture across the organization.
  
• To achieve Operational Excellence through zero incidents.
  

It is Company’s policy that Smoking (including e-cigarettes and vaping devices)

by ship personnel or visitors onboard company vessels is strictly forbidden outside designated smoking places.

Smoking is only permitted in designated smoking areas, as directed by the Master, which are, while at sea:

1. Master’s and C/E’s Office.
2. Officer’s and Crew’s Smoking Rooms.
3. Engine Control Room (ECR).
4. Cargo Control Room (CCR).
5. Conference Room / Ship’s Office.
6. Wheelhouse*.

• Smoking in cabins is absolutely prohibited.
• In port/terminal, smoking is only permitted in the smoking rooms subject to port/terminal regulations/restrictions. The designated smoking areas should be agreed in writing between the ships Responsible Officer and the Terminal Representative before operations start.
• Designated smoking areas should be prominently marked at the entrances and inside.

*When at sea, smoking in the wheelhouse is prohibited during cargo operations including purging, gas freeing and tank cleaning.

Doors of the designated smoking places shall be closed at all times.

Smoking Regulations:

• Use of all mechanical lighters and portable lighters with electrical ignition sources is prohibited onboard.
• Only safety matches shall be used onboard, only in designated smoking areas.
• Use of matches outside the accommodation is strictly prohibited.

The Company recognizes the value of social media and expects all staff to use these tools responsibly. This policy outlines the necessary principles that users of social media shall observe.

This policy applies to all shore-based and shipboard employees during work and non-work hours, on personal and Company supplied equipment.

The Managing Director, Heads of Departments and ships’ Masters are responsible for ensuring that the standards set forth by this policy are communicated to their teams and that their own conduct sets a good example in this respect.

The following basic principles should be observed at all times:

• Be responsible. Any user-generated content could have an adverse impact on Company’s reputation. In that respect, careful consideration should be given before sharing photographs or video of the Company assets, particularly ships, facilities or people in uniform.
• Do not make posts or comments that may be considered defamatory, obscene, libellous, threatening, harassing or embarrassing to others.
• Do not use the Company’s logo (in any form) on any personal social media platform without prior approval of the Company.
• Do not disclose any confidential, proprietary or sensitive Company information as well as personal information of our employees, customers, vendors, contractors, suppliers, competitors or others. Employees are reminded of Company’s policy on public statements / media response.
• In the case that a vessel is involved in an incident, no unauthorized information may be disclosed by any crew member by private means of communication.
• Do not comment on Company related legal matters, financial performance, competitors, strategy or rumors, unless you are specifically authorized to do so by the Company.

Please be aware that violation of this policy may be grounds for disciplinary action up to and including termination of employment.

COMPANY 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.

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.

No harassment and bullying: Harassment includes any inappropriate and unwelcome conduct which, whether intentionally or not, creates feelings of unease, humiliation, embarrassment or discomfort for the recipient, where sexual harassment is unwelcome sexual advances, requests for sexual favours and other verbal or physical conduct of a sexual nature.

Bullying is a form of harassment that includes hostile or vindictive behaviour and results in a work environment in which a group of people or an individual may become threatened or intimidated because of the negative or hostile behaviour of another group of people or individual. Bulling, including cyber bulling, may involve a misuse of power or position and is often persistent and unpredictable.

Harassment and bullying are examples of conduct that is unwanted and causes detrimental effects, which may include, stress, lack of motivation, reduced work performance, absence from duties and resignations.

All seafarers have the right to work without suffering harassment and bullying. It is a matter of good employment practice to foster a working environment in which seafarers can work free of harassment and bullying. For the dignity and well-being of all seafarers, the Company is committed to the elimination of harassment and bullying from vessels and to ensuring a working environment in which everyone is respected.

In order to tackle harassment and bullying, the Company actively encourages its seafarers to bring incidents, including those that affect others, to its attention without delay, adopting reporting procedures, conducted in absolute confidentiality, in which all seafarers should have confidence.

In every managed vessel, a person or persons are designated to act as the first point of reference for each seafarer that wishes to make a complaint, either a member of the crew, or a company employee based ashore, or a person designated by the Company to act on its behalf. The victim of harassment or bullying is also provided with the option, at his discretion, of resolving the complaint informally. This could involve the victim explaining the effects of the alleged perpetrator’s actions in the presence of another Company person, trained in the resolution of complaints. The alleged perpetrator may then be offered an opportunity to apologize for his actions and undertake not to repeat them.

Violation of the harassment and bullying policy should be subject to investigation.

Pantheon Tankers Management Ltd has developed a cyber security policy that sets the company’s guidelines and provisions for preserving the security of our data and technology infrastructure.

“Cyber Security” refers to the protection of information systems (hardware, software and associated infrastructure), their data and the services they provide, from unauthorized access, harm or misuse.

The Cyber Security Policy applies to all employees ashore and onboard, contractors, volunteers and anyone who has permanent or temporary access to Company’s and Vessels’ systems and hardware.
This policy is aligned with existing policies, rules, regulations and laws that Pantheon Tankers is subject to.

Cyber Security Policy Strategic Goals:

• Protect the health and the safety of the systems, personnel and cargo.
• Protect the ability of the ship to operate safely and not to endanger other ships, maritime structures or the environment.
• Prevent loss of sensitive information, including commercially sensitive or personal data.
• Ensure the smooth day-to-day operation of maritime information technology (IT), operational technology (OT), and communications systems.

Cyber Security Policy Objectives:

• Provide security procedures and processes so that operators know how to identify a potential cyber security threat.
• Identify and harden systems and networks.
• Establish safeguards to reduce the risk to visitors, crew and port personnel on board Pantheon Tankers ships.
• Improve the security skills and awareness of Pantheon Tankers personnel ashore and onboard ship, regarding cyber risks.
• Prepare contingency measures for possible cyber security incidents.
• Understanding and countering cyber threats, increasing operational resilience.
• Improve Cyber Security Awareness and management.
• Reduce system’s vulnerability to cyber threats.

MISSION

Be the preferred choice of the major charterers by setting the industry standards for safe and sustainable ocean transportation of crude oil & products with technically advanced, highly performing eco ships, crewed and operated by motivated, responsible, professional and properly qualified shipboard and shore based personnel.

The Company aims to achieve through continuous improvement:

ZERO incidents

ZERO harm to the environment

ZERO loss to process

ZERO lapses in security

Continuous REDUCTION in permitted emissions

VISION

Be recognized as a world leader in global energy ocean transportation safeguarding safety, security and sustainability.