Company HSEQ Policy

Company policies for Health, Safety, Environment and Quality (HSEQ) shall ensure that the HSEQ Objectives are achieved. The Policy shall be implemented and maintained at all levels of the organization, both ship based and shore based.

POLICIES ON HSEQ MANAGEMENT CERTIFICATION

• The Company shall implement and continuously improve an integrated HSEQ Management system, which satisfies the requirements of the ISM Code and the ISO 9001:2000 International Standard. The system shall be applied to all vessels operated by the Company, and for all operations and projects in which the Company is the responsible contract partner or for the Company’s participation in projects where another company is the responsible contract partner
• The HSEQ Management System shall be reviewed by an external certifying organization in accordance with a predefined time schedule, in order to uphold a continuously valid certificate

POLICIES ON HEALTH, SAFETY AND ENCIRONMENTAL PROTECTION

• Potential risks to personnel, vessel and equipment in ordinary shipboard operations and associated with projects and other maritime operations shall be identified and actions shall be taken to prevent unwanted incidents
• All accidents, near accidents and nonconformities shall be reported and followed up, and shall lead to the implementation of corrective and preventive actions and to revisions of procedures and other HSEQ documentation if called for to prevent reoccurrence of the incident
• The shore based and shipboard management shall be committed to work for the best possible working environment for their staff, both with regard to physical/material conditions and social matters.
• All non-conformities related to the HSEQ documentation shall be reported and followed up, and shall lead to revisions of the documents if called for.
• All personnel onboard the vessels and onshore shall at all times be well qualified for the tasks given to them, and the need for additional education and training shall be continuously evaluated and implemented.
• All personnel shall be familiar with the HSEQ Management system, and the Company management shall on a regular basis communicate to the Company staff its commitment and attitude relating to HSEQ issues.
• All units within the Company shall have implemented plans and procedures to prevent spills or discharge of any polluting or hazardous substance, or if discharges has occurred, to be able to reduce the consequences as much as possible.
• The management organisation and the Company’s manned vessels shall all have implemented procedures which shall aim at preventing or minimizing the consequences of any emergency situation

POLICIES ESPECIALLY RELATED TO QUALITY

• The Company shall be committed to satisfy customer's requirements, as stated in mutually agreed contract documents, and the Management shall communicate the commitment to all employees.
• Procedures shall be implemented to ensure that customer requirements are A defined and understood and that the Company’s ability to satisfy the requirements is confirmed.
• Communication with customers and potential customers shall be managed in a professional way.
• Subcontractors and suppliers shall be approved before acceptance, and received services and goods shall be verified by the Company to further assure quality.
• The Company’s strategies regarding services to be offered shall be based on a continuous monitoring of the development of selected areas, and shall include plans for the development of necessary corporate and individual competence.
• All operations shall be monitored, and each step, including tests and all changes or deviations from original plans shall be documented. Relevant corrective actions shall be initiated and followed up.
• A debriefing shall be held after all projects, and the experience and lessons learned shall be communicated to Company staff

POLICIES TO ACHIEVE THE HSEQ MANAGEMENT SYSTEM OBJECTIVES

• The HSEQ Management System documentation applies the Symfoni Document Manager and the Symfoni Quality Assurance module to manage all documentation related to manuals, procedures, onshore deviations, project administration and general document management.
• Distribution of the documentation and the reporting of unwanted incidents for the fleet are managed by application of the Document and the Event Module of the Star Information System.
• The system shall include updated lists of all codes, guidelines, standards and mandatory rules that shall be adhered to, and that shall be available onboard and on shore.
• All system documents shall be verified and approved prior to issue
• Reviews and audits shall be performed regularly, and corrections imposed to continuously improve the system

Trondheim, Norway April 1st 2006

Ole T. Bjørnevik

General Manager