Policies

It is Almi Tankers’s Policy to promote safety at sea. We are committed to continuous efforts to identify and eliminate or manage safety risks associated with our activities.

Almi Tankers’s goal is to conduct its business in a manner that protects the safety of employees, all persons involved in its operations, customers and the public as well as to prevent all accidents and injuries through the active participation of every employee.

Our goal is to achieve ZERO accidents and ZERO spills through continuous improvement.

To achieve this goal, we :

• Comply with all applicable laws and regulations and apply responsible standards where laws and regulations do not exist.
• Design and maintain facilities, 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 our operations, in co-operation with industry organisations and authorised government agencies.
• Stress to all employees, contractors and others working on our behalf their responsibility and accountability for safe performance whilst at work and safe behaviour outside of work.
• Undertake appropriate reviews and evaluations of our operations to measure progress and to foster compliance with this policy.
• Conduct and support research to extend knowledge about the safety effects of our operations and promptly apply significant findings and, as appropriate, share them with employees, contractors, government agencies and others who might be affected.

This policy has the full support of the top management and applies to all employees of Almi Tankers.

At Almi Tankers, we rank health and hygiene amongst the top priorities in our operations. Our outmost concern is to ensure that all work is conducted under conditions in accordance with our health and hygiene standards and continuous improvement is ensured. This applies to shore staff, seagoing personnel and third parties both aboard our vessels and in our office premises. In order to ensure high standards of health and personal hygiene, we:

• Comply with all applicable laws and regulations and apply responsible standards where laws and regulations do not exist.
• Seek to identify and evaluate health, ill health and hygiene standards and risks related to our
• operations that potentially affect employees, contractors or the public.
• Company employees and the safety technician, as their representative, are consulted accordingly when changes that affect workplace health and safety occur.
• Communicate knowledge about health and hygiene risks to potentially affected individuals or organisations and the scientific community.
• Determine at the time of employment and thereafter, as appropriate, the medical fitness of employees to do their work without undue risk to themselves or others.
• Implement health and safety objectives, programmes and appropriate protective measures to control such risks, including appropriate monitoring of potentially affected employees.
• Provide or arrange, as appropriate, 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 our operations to measure progress and to foster compliance with this Policy.
• Conduct and support research to extend knowledge about the health and hygiene effects of our operations.
• Provide voluntary health and hygiene promotion programmes and campaigns designed to enhance our employees’ well-being and personal safety. These programmes and campaigns should complement, but not interfere with, the employees responsibility for their own health care.
• Information about employees obtained through the implementation of health programmes and campaigns are considered confidential and are not to be revealed to non-medical personnel except at the request of the employee concerned, whenever requested by law enforcement authorities, when dictated by overriding public health considerations, or when necessary to implement the Drug and Alcohol Policy.

Management encourages active participation and consultation of all personnel in applying the IMS and will respond positively to recommendations that identify changes in Policy, practices or equipment necessary to improve standards.

This policy has the full support of the top management and applies to all employees of Almi Tankers.

Almi Tankers ensures that the quality of our operations, the safety and health of our employees and the protection of the environment are the predominant factors in all aspects of our operations. In this respect, our Integrated Management System (IMS) has been designed to continuously improve the quality of the services offered.

All our staff are familiar with our IMS, which is understood and adhered to at all times. Regular reviews are conducted in order to both ensure the maintenance of our quality standards and identify potential improvements with the aim of implementing them.

Almi Tankers is committed to conducting all its activities in a safe, reliable, efficient and environmentally sound manner that consistently meets and exceeds our customers’ expectations, while ensuring compliance with statutory and regulatory requirements. We are a customer satisfaction oriented company and all our activities are geared towards ensuring our operational integrity.

Through our contact with other industry participants, industry best practices are identified and adopted if considered to be positively contributing to the quality of our services. Open and ongoing dialogue will be maintained with all stakeholders to communicate their expectations and to discuss feedback on our performance.

In order to ensure that operational and quality service objectives can be achieved, the IMS addresses the continuous monitoring of all aspects of  our operations so that potential problems can be readily identified and appropriate corrective actions undertaken.

Our IMS is based on the belief that preventing problems from occurring is in the best interests of our customers and ourselves.

This policy has the full support of the top management and applies to all employees of Almi Tankers.

Almi Tankers S.A. commitment to energy efficiency is demonstrated by the Company’s Top Management decision that the Company and its managed vessels, be in compliance with the ISO 50001 Standard on Energy Management Systems.

We recognise that energy consumption on board our vessels is directly linked to fuel burning/ consumption, which has environmental impacts, such as “Consumption of Natural Resources” and “Emissions to Air”. With the aim to minimise such impacts, we commit to examine and implement Energy Management practices by:

– Consistently complying with all national / international environmental & energy rules and regulations associated with our activities in accordance with the ISO 50001 standard requirements,

– Providing each vessel with an Energy Efficiency Management Plan,

– Analysing all the energy efficiency potentials of our activities, in order to plan and implement energy efficiency measures,

– Maintaining, reviewing and revising our Energy Efficiency Management Procedures accordingly as well as the Company’s Energy objectives and targets as identified in the Company’s Energy Review Plan and Programme,

– Measuring the vessels bunkers’ consumption and evaluating their performance,

– Employing suitably competent and qualified personnel who can carry out operations in an energy efficient manner,

– Providing training for our personnel to enable them to effectively utilise the Company’s procedures and energy efficiency measures,

– Seeking to ensure that contractors and suppliers conform to the Company’s environmental and energy efficiency requirements. Aiming to the Company’s continual improvement in the field of Energy Efficiency Management,

– Adopting Fuel Management procedures (from purchasing to consumption and residual disposal) considering Energy Efficiency,

All Company employees are responsible for implementing the Company’s Energy Policy.

Our Company’s Energy Efficiency Management Policy is under constant review by the Top Management, aiming to always be up-to-date with the changing environment in which we operate and to function as a leader for continual improvement on Energy Efficiency.

The Senior Management of ALMI TANKERS S.A. has approved the Data Protection Policy and hereby demonstrates its full commitment to the effective implementation of the present policy, to the provision of sufficient resources, and to the continual improvement of the Data Protection Program. The Policy ensures that:

• Any personal data handled, including that of clients, employees, vessel crew or any other personal data processed or stored, is  protected against any physical, system or application level unauthorised access.
• Confidentiality, Integrity and Availability of personal data handled by ALMI TANKERS S.A., are guaranteed.
• ALMI TANKERS S.A. continually monitors and complies with the applicable Data Protection Legislative and Regulatory requirements.
• ALMI TANKERS S.A. does everything possible to facilitate the data subjects in exercising their rights, as derived by the Data Protection Legislative and Regulatory Frameworks.
• Data Protection Training and Awareness Programmes are performed formally for all employees.
• All confirmed or suspected Personal Data Breaches are reported as Incidents, and should be thoroughly investigated and effectively managed.
• All confirmed Personal Data Breaches, that are likely to result in a risk to the rights and freedoms of natural persons, are communicated to the Data Protection Supervisory Authority.
• All confirmed Personal Data Breaches, that are likely to result in a high risk to the rights and freedoms of natural persons are communicated without undue delay to the affected data subjects.
• All processes that are likely to result in a high risk to the rights and freedoms of natural persons undergo a Data Privacy Impact Assessment and all the necessary technical and organisational measures are taken in order to ensure that the risk is minimized. In case that a process results in a high risk, the Data Protection Supervisory Authority is consulted.
• ALMI TANKERS S.A. provides any information relating to processing to the data subject in a concise, transparent, intelligible and easily accessible form, using clear and plain language, in particular for information addressed specifically to a child, when this information is requested by the data subject.
• ALMI TANKERS S.A., taking into account the nature, scope, context and purposes of processing, as well as, the risks of varying likelihood and severity for the rights and freedoms of a natural person, implements appropriate technical and organisational measures to ensure and to be able to demonstrate that processing is performed in accordance with the applicable Data Protection Legislative and Regulatory Frameworks.
• Technical and Organisational measures are continuously monitored and evaluated via the risk assessment process and appropriate resources are provided in order to control the risks and minimise the impact on personal data.
• ALMI TANKERS S.A., both at the time of the determination of the means for processing and at the time of the processing itself, implements appropriate technical and organisational measures, which are designed to implement data-protection principles in an effective manner.
• ALMI TANKERS S.A. integrates the necessary safeguards into the processing in order to meet the requirements of the Data Protection Legislative and Regulatory Frameworks and protect the rights of the data subjects.
• ALMI TANKERS S.A. solely uses processors that provide sufficient guarantees on the implementation of appropriate technical and organisational measures in a way that processing meets the requirements of Data Protection Legislative and Regulatory Frameworks and ensures the protection of the rights of the data subject.
• ALMI TANKERS S.A. keeps an up-to-date record of processing activities for all processes that handle and store personal data.
• Appropriate procedures, standards, technical and organisational controls should be in place in order to support this Policy.
• All Managers are directly responsible for implementing the Data Protection Policy and ensuring staff compliance within their respective business areas.
• All employees, contractors and suppliers are formally required to comply with this Policy and carry out their responsibilities as defined.
• Any violations of the Policy, Standards and Procedures are subject to disciplinary action. The specific disciplinary action depends on the nature of the violation, the impact of the violation to the Group and possibly to the data subjects.
• ALMI TANKERS S.A. regularly ensures compliance with this Data Protection Policy through audits, reviews, tests, technical monitoring and should take appropriate actions for continual improvement.

Almi Tankers is committed to continuous efforts to improve environmental performance in all areas required by our Environmental Management System (EMS), part of our Integrated Management System (IMS) towards a cleaner environment.  Furthermore, we are committed:

• To pollution prevention through investing in human resources as well as effective maintenance of our vessels’ systems and equipment.
• To the continuous reduction of environmental risks.
• To sharing information on our environmental performance with external stakeholders.
• To resources management in a rational, sustainable and environmentally aware manner aboard and ashore.

Our long-term goal is to achieve ZERO spills, ZERO incidents and reduction in permitted emissions through continual improvement.

To achieve this goal, we:

• Comply with all applicable environmental laws, regulations and requirements and apply responsible standards where laws, regulations and requirements do not exist.
• Manage our business with the goal of preventing environmental incidents.
• We are prepared to respond quickly and effectively to environmental incidents resulting from our operations, in co-operation with industry organisations and authorised government agencies.
• Show concern and respect for the environment, emphasise every employee’s responsibility regarding our environmental performance and foster appropriate operating practices and training.
• Endeavour to continuously develop our employees’ environmental awareness and culture. We undertake appropriate reviews and evaluations of our operations to measure progress and to foster compliance with this policy.
• Conduct and support research to improve the understanding of our business’s impact on the environment, to improve methods of environmental protection and to enhance our capability to make our operations compatible with the environment.
• Manage and control to the best extent possible emissions, wastes and the consumption of natural resources in line with sustainable shipping principles. We design, operate and maintain facilities and procedures to this end to avoid to the best extend practicable pollution from Oil/associated products/ chemicals, Noxious Liquid Substances, Dangerous Goods, Sewage, Garbage, Ballast Water, Cargo Vapours, Engine Exhaust emissions, Halons, CFCs, Noise and Coatings.
• Share our experience with others to facilitate improvements in industry performance.

This policy has the full support of the Top Management and applies to all employees of Almi Tankers.

ZERO ALCOHOL – ZERO DRUGS – ZERO TOLERANCE

Almi Tankers’ Drug and Alcohol policy is in line with the principles laid out by the Oil Companies International Marine Forum (OCIMF) “Guidelines for the Control of Drugs and Alcohol aboard Ships”. The Policy applies to all seagoing personnel for the entire contracted period (aboard & ashore) as well as shore staff when aboard.

The possession, consumption, trafficking and sale of alcohol and/or drug substances aboard is prohibited.

The possession or consumption of any substance that may cause an individual to behave unusually in the course of performing his duties is prohibited.

The possession or consumption of alcoholic beverages and liquor, e.g. beer, brandy, vodka, whisky, wine, etc. aboard is prohibited.

Masters are to ensure that Officers and staff are not under the influence of alcohol when taking over their scheduled duties.

Boarding the vessel with any traces of alcohol in one’s blood is prohibited.

To enforce this, the Master is to carry out unannounced and random tests, in addition to other measures. Deck and Engine Officers may not hand over the watch if their replacements are under the influence of alcohol. The Master or the Chief Engineer must be informed immediately in this case. The accepted alcohol limit in blood / breath is 0.0%.

A pilot noticed to be under the influence of any substance that may limit his ability to perform his duties must not be allowed to be involved in the vessel’s operations and must be reported to the local authorities.

Before embarkation, all officers and ratings are tested during routine medical examinations for drug use and alcohol consumption by recognised and authorised laboratories ashore. In addition, at least once per year an unannounced external D&A test is carried out by authorised company on board each vessel. Furthermore, as a minimum, on a monthly basis, unannounced alcohol tests are carried out by vessel’s means and are generated by the Ship Master. Last but not least, unannounced alcohol tests are also generated by the Head Office at a frequency less than the shortest contract period on board.

Any crewmembers found to be in breach of this policy will be subject to disciplinary action, which may include immediate repatriation.

This policy has the full support of the Top Management and applies to all employees of Almi Tankers.

The aim of this policy is to encourage all Almi Tankers S.A. members to report any suspected or confirmed illegal events without fear of any consequences.

1. All members of Almi Tankers S.A. should immediately report to their supervisors any illegal acts (suspected or confirmed) regarding SAFETY, ENVIRONMENTAL or DRUG & ALCOHOL regulations.

2. If a person does not think that their supervisor’s response is full or correct, or does not want to report the incident to a certain superior (at any level – maybe because that individual was involved), then they may report to the level of authority above that person, or even higher if necessary.

3. Reports can be anonymous.

4. Although team members should ideally report illegal acts immediately, events may be reported later if required.

5. A whistleblower* will never be punished for making a report in good faith (i.e. not to damage another person or the Company).

6. If a person makes a false or malicious report to damage the Company or another individual, they will be subject to disciplinary action, which may include termination of employment or even legal procedures to protect the reputation of ALMI TANKERS S.A. and its members if required.

7. Anyone who retaliates against a whistleblower (who reported an event in good faith) will be subject to discipline, including termination of his employment if necessary.

8. Supervisors, officers, masters and managers who receive the reports must always act quickly to investigate and/or resolve any issue.

9. Supervisors and officers are obliged to pass all reports up to the next level.

10. The identity of a whistleblower must remain confidential, known only by managers that are:

a.) Higher in the chain of command than the level at which the incident was reported.

b.) Directly involved in the handling of whistleblower reports.

c.) A name may have to be shared with law enforcement agencies if required, although every effort will be made to protect the individual’s anonymity.

NOT reporting an illegal act may be considered the same as participating in it.

Examples of when it is right to follow the whistleblower procedure:

– Deliberate ignoring of essential safety procedures

– Deliberate illegal discharge of pollutants into the sea

– Breach of the Drug and Alcohol Policy, etc.

This policy must NOT be used for reporting general complaints such as salaries, work hours, breaches of service contracts etc.  (as defined by MLC/ILO relating to occupational matters) unless these issues fall under the definition of illegal actions.

In the unlikely event that it is impossible to report via the Master, the free e-mail provided to seafarers by the Company may be used to report illegal events to the Head Office at any time.
To ensure confidentiality, the following e-mail addresses should be used.  CEO@almitankers.gr and/or DPA@almitankers.gr

* A ‘whistleblower’ is someone who has the moral courage to stand against illegal practices by reporting any such act to the Head Office.

This policy has the full support of the Top Management and applies to all employees of Almi Tankers.

When we post something on social media, it moves from the private to the public domain. What you publish is widely accessible and it will be around for a long time – the internet never forgets, and your digital footprint can serve as a source for journalists. Therefore, whilst Almi Tankers S.A. recognises that social media increases opportunities for communication; it can also pose a threat to Company reputation.

This Social Media Policy is designed to provide helpful, practical advice for employees on the use of social media. Social media refers to websites and applications that enable users to create and share content or to participate in social networking (e.g. Facebook, Twitter, YouTube, Snapchat, Instagram etc.).

This Social Media Policy applies to all Almi Tankers S.A. employees who make use of social media, whether or not they are gaining access to it via Almi Tankers S.A. equipment/networks and whether or not they are using it during working hours. Please be aware that violation of this policy may be grounds for disciplinary action up to and including termination of employment.

• Think Before You Post Your views and actions online can impact Company reputation. Think twice before sharing images or videos of Almi Tankers S.A.’s assets, particularly ships, facilities or people in uniform. Avoid violating the privacy of fellow seafarers, co-workers or sharing confidential Almi Tankers information online.
• Get it Right Never share inaccurate information about the Company. If you are unsure of the accuracy of what you are about to share, check with the DPA and/or the Communications Department before posting.
• Be Respectful Always treat others in a respectful and positive manner. Never use social media as a platform to harm, insult, threaten, defame or embarrass others.
• Be Yourself If it’s clear who you work for, you should also make it clear your views are your own; use a disclaimer if necessary, for example, “The postings on this page are my own and do not necessarily represent the views of the company that employs me.”
• Follow Official Communication Channels During an incident, respect all official communication channels and do not post comments, photographs, videos or any other relevant content online.
• Adjust your Privacy Settings Be smart about protecting yourself, your privacy, and Almi Tankers S.A.’s confidential information. You should only allow access to those you really want to share information with.
• Report Potentially Harmful Material If you find defamatory commentary about the Company on social media forums please inform the DPA and/or the Communications Department, who can respond appropriately.

The Management of ALMI TANKERS S.A. approves the Information Security Policy and hereby declares its full commitment to the effective implementation of the policy hereunder, to the provision of sufficient resources, and to the continual improvement of the Information Security Management System (ISMS).

The Information Security Policy ensures that:

• The ALMI TANKERS S.A. information (including clients’ information) is protected against any unauthorised physical or digital access.

• Confidentiality, Integrity and Availability of ALMI TANKERS S.A. and Clients’ Information are guaranteed.

• ALMI TANKERS S.A. continually monitors and complies with Legislative and Regulatory requirements.

• Business Continuity Plans and Procedures, related to IT & Information Security Infrastructure, are implemented, maintained, tested and continuously improved.

• Information Security Training is performed consistently for all employees and Awareness Programmes are closely monitored.

• All confirmed or suspected Information Security Breaches are reported to the Information Security Officer, thoroughly investigated and effectively managed.

• Measurable Security Objectives are set and appropriate resources are provided in order to ensure their achievement.

• Threats, Vulnerabilities and Risks are continuously monitored and evaluated via the risk assessment process. Appropriate resources are provided, in order to control the risks and minimise the impact on the ALMI TANKERS S.A. information and digital assets.

• Appropriate procedures, standards, technical and organisational controls are in place in order to support the Policy.

• The Information Security Officer is responsible for maintaining the ISMS Policy and providing support and advice during its implementation.

• All Managers are directly responsible for implementing the ISMS Policy and ensuring staff compliance within their respective business areas.

• All ALMI TANKERS S.A. employees, contractors and suppliers are formally required to comply with this Policy and observe their security responsibilities as defined.

• Any and all violations of Security Policy, Standards and Procedures are subject to disciplinary action. The degree of disciplinary action depends upon the nature of the violation and its impact on ALMI TANKERS S.A.’s informational assets and related facilities.

• ALMI TANKERS S.A. regularly verifies compliance with this ISMS Policy through audits, reviews, information security drills and technical monitoring, and takes appropriate actions for continuous improvement.