CASTOR SHIPS S.A. takes all reasonable precautions and measures during the operation of managed ships, to ensure safety at sea, prevention of human injury or loss of life, and avoid property damage.

The Company’s goal is to achieve ZERO incidents through continuous improvement.

The Company’s management, to support its policy, adheres to the following principles:

• Compliance with all applicable laws and mandatory rules and regulations and consideration of the applicable codes, guidelines and standards imposed or recommended by the IMO, Flag Administrations, Class Societies, and Industry organizations.
• Adherence to Castor Integrated Management System (CIMS) which promotes the concept of HSQE excellence, continuous improvement, and enhancement of personnel skills.
• Assignment of employees with sound skills and capabilities to the necessary areas of responsibility, including adequate verification resources.
• Definition of the organization, responsibility, authority, and interfacing of the various management functions within the CIMS
• Provision of safe and environmentally sound practices in the operation of the managed ships.
• Provision and maintenance of a safe working environment onboard and ashore.
• Identification of all hazards related to work and operations onboard and ashore, taking mitigating measures to minimize relevant risks.
• Provision of the necessary training to ensure that the Company’s employees can achieve safety and pollution prevention objectives in their scope of work.
• Establishment and Maintenance Safety culture across the organization.
• Achievement of Operational Excellence through zero incident & customer’s satisfaction.
• Provision of facilities, systems/equipment, and a maintenance system suitable to achieve the Company’s objectives.

CASTOR SHIPS S.A. commits to continually improve its environmental performance in all areas required by the international regulations and laws and to ensure:

• Pollution prevention that emphasizes on source reduction, including necessary funding and human resources, to effectively maintain the onboard systems, equipment, and components.
• Minimization of the environmental impact of its operations.
• Continuous reduction of environmental risks.

Our goal is to achieve

Zero spills or releases to the environment

and

reduction of the permitted emissions aiming to Zero.

To achieve this goal, CASTOR SHIPS S.A. adheres to the following :

• Complies with all applicable environmental laws, regulations, and requirements and applies responsible standards where laws, regulations, and requirements do not exist.
• Responds quickly and effectively to environmental incidents resulting from its operations.
• Minimizes any significant adverse environmental impact of new developments & minimizing the environmental impact of operations. This is done through the use of the environmental management procedures and planning, and through the assessment of

   environmental impacts, before starting a new activity or project;

• Assesses all identified risks for the environment and establishes appropriate safeguards.
• Shows concern and respect for the environment, emphasizes on every employee’s responsibility toward environmental performance and fosters appropriate operating practices and training.
• To educate, train and motivate employees to raise their awareness of the strategic importance of environmental management ,encourage concern and respect for the environment so as to enhance their skills so that they can conduct their activities in an
  environmentally responsible manner;
• Undertakes appropriate reviews and evaluations of its operations to measure progress and to foster compliance with this Policy.
• Raises awareness of the threat that climate change poses to environmental sustainability, health and wellbeing of communities and future generations.
• Shares its experience with others to facilitate improvements in the industry’s performance.
• Manages its business to prevent environmental incidents.
• Designs, operates, and maintains facilities to this end.

CASTOR SHIPS S.A. endeavors to earn the confidence of the shipowners, charterers, seafarers, and other interested parties and recognition as a high quality and trustworthy international ship manager. This is possible only through the provision of flawless services that satisfy all relevant requirements.

CASTOR SHIPS S.A. provides professional ship management services to owners and charterers, protects their interests and assets under its care, fulfills their expectations and:

• Always complies with all applicable legal and other requirements to continually improve the effectiveness of its CIMS.
• Adopts a proactive approach to its clients’ needs and is responsive to their requests, suggestions, or complaints, always trying to improve the value of its services.
• Encourages employee teamwork, personal improvement, cooperation, innovative thinking, initiative, leadership, decisiveness, and focus on the client’s needs and satisfaction.
• Sets measurable and meaningful objectives and targets and reviews them frequently.
• Addresses the needs of interested parties who receive the Company’s services or whom these services may impact.

To objectively assess its performance, the Company:

• Establishes criteria for the quality of its services.
• Monitors, measures, and analyses its objectives and targets for continual suitability to verify the effective implementation of the established processes.
• Identifies and manages the risks and opportunities of its services.

CASTOR SHIPS S.A. treats health, hygiene, and the crew’s welfare as the priority in its operations, while its utmost concern is always to ensure that all employees work under safe and hygienic conditions. To ensure high health and hygiene standards, CASTOR SHIPS S.A.:

• Complies with all applicable legislation and regulations, observes relevant guidelines, and applies responsible standards where laws and regulations do not exist.
• Seeks to identify and evaluate health and hygiene risks related to its operations that potentially affect employees, contractors, or the public and establishes appropriate safeguards.
• Communicates knowledge about relevant risks to individuals or organizations.
• Determines the medical fitness of employees’ work without undue risk to themselves or others.
• Implements programs and appropriate protective measures to control potential risks, including suitable monitoring of employees.
• Provides medical services necessary for the treatment of employees occupational illnesses or injuries and the handling of medical emergencies.
• Provides voluntary health and hygiene promotion programs to enhance employees’ well-being and personal safety.

Our goal is to achieve the highest standards of health and personal hygiene through continuous improvement.

Employee information is confidential. DO NOT reveal any employee information to non-medical personnel, except if requested by the employee concerned, or if required by law, dictated by overriding public health considerations, or required by our Drug and Alcohol Policy

CASTOR SHIPS S.A. believes that although shipping is by far the most fuel-efficient means of transport, nevertheless additional action is necessary to improve the energy efficiency of ships related operations further. Increased energy efficiency eventually results in increased environmental protection by reducing air emissions.

To enhance the energy efficiency of the shipboard operations, CASTOR SHIPS S.A. commits to:

• Establish and maintain a Ship Energy Efficiency Management Plan (SEEMP).
• Increase energy efficiency and minimize energy waste. A set of time-specific, measurable – whenever practicable – and achievable targets are established and maintained, which relate to a combination of design optimization, in-service performance monitoring, and best-practice operational management processes.
• Promote energy efficiency awareness through training to all employees.
• Apply practices and invest in clean-energy technology that contribute to a rational management and efficiency of the available resources
• Provide the framework for setting and reviewing energy objectives and targets and ensure the availability of information and of necessary resources for their achievement.
• Monitor and comply with all applicable legal requirements related to ship energy efficiency management.

This Policy deals with the use and misuse of social media platforms and other websites, including but not limited to:

• Social networking websites such as Facebook, Instagram, MySpace, etc.
• Micromedia/microblogging websites such as Twitter
• Multimedia websites such as YouTube and Instagram
• Wikis such as Wikipedia
• Blogs, news sites, and any other website where people post content and comments. 

CASTOR SHIPS S.A. recognizes the value of social media and expects all staff to use these tools responsibly.

Always observe the following basic principles:

• Be responsible. As an employee, any user-generated content may impact the Company’s reputation, so be extremely careful before sharing any photos or videos of the Company’s assets, particularly of our ships, facilities, or people in uniform.
• Be accurate and honest. If you are in doubt or uncertain about responding to a post, contact the Company for guidance.
• DO NOT post or comment on content that others may consider defamatory, obscene, libelous, threatening, harassing, or embarrassing. Respect others during any online social interaction.
• Before you post photos of other people, get their permission first.
• NEVER use someone else’s copyrights, trademarks, or other intellectual property.
• If you see any comments relating to the Company that you think require addressing, contact the Company for guidance.
• DO NOT use the Company’s logo (in any form) on any personal social media platform. The use of the Company’s logo requires the Company’s approval.
• DO NOT use social media or any similar form of communication to attack or insult the Company, fellow employees, customers, vendors, contractors, suppliers, competitors, or others.
• DO NOT disclose confidential, proprietary, or sensitive information about the Company and names of employees, customers, vendors, contractors, suppliers, competitors, or others.
• DO NOT comment on Company-related legal matters, financial performance, competitors, strategy, or rumors, unless you are expressly authorized to do so.

If any member of the Media (social or traditional) contacts you about your user-generated content (i.e., blog post, comment, video), a colleague’s or another party’s, DO NOT engage in any dialoge but ask them to contact the Company.

CASTOR SHIPS S.A. operates in a socially responsible manner, ensuring the safety of people and the environment and 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 an impact on society and the environment.
• Ethical behavior at all times.
• Respect, consideration, and responsiveness toward the Company’s stakeholders’ and employees’ interests.
• Respect for international norms of behavior, while adhering to the principle of respect for the rule of law.
• Respect for human rights and recognition of both their importance and universality.

CASTOR SHIPS S.A. addresses the following core subjects for identifying the issues and priorities relevant to the organization:

• Organizational governance
• Human rights
• Labor practices

We aim to integrate sustainable thinking and corporate social responsibility into all our business processes and business relationships.

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 by knowledge-sharing practices while always meeting or exceeding all applicable legislative and regulatory requirements.

CASTOR SHIPS S.A. guarantees its commitment to security matters and declares that all works conducted by its personnel have sufficient supervision to comply with the provisions of the ISPS Code.

Our Policy is to provide a secure working environment by establishing and maintaining the required security measures to prevent unlawful acts that endanger the safety and security of persons and property onboard the ship. CASTOR SHIPS S.A.’s objectives are to:

• Provide security procedures and practices for ships operations to protect the security of ports and the wider community and establish safeguards to reduce the risk to the crew, passengers, and port personnel onboard.
• Improve the security skills and awareness of all employees.

In a conflict between commercial interests and the aims of the Security Policy, the Master must prioritize this Policy and the objectives mentioned above. To achieve this, he must:

• Actively promote security awareness among all employees.
• Consider the decisions of the international shipping community.
• Schedule in advance, as far as possible, the voyage, the cargo handling, and all ship operations to foresee possible dangers and take the necessary precautions.

All employees must comply with the requirements of the SSP and be familiar with their security duties and the measures necessary to protect the ship from any unlawful act.

In the event of an attack on the ship or hijack attempt, preserving the lives of the ship’s personnel has priority over any other considerations.

CASTOR SHIPS S.A. is committed to safeguarding information, and its processing systems is of strategic importance for the Company in order to achieve its short and long term objectives and at the same time to ensure the confidentiality of the data of the customers receiving its services.

The Company, recognizing the criticality of information and information systems in the execution of its business operations, applies an Information Security and Cybersecurity Policy with the following Information Security objectives:

• Ensuring the confidentiality, integrity and availability of the information it manages.
• Ensuring the proper functioning of information systems.
• The timely response to incidents that may endanger the Company’s business operations.
• Meeting legislative and regulatory requirements.
• The continuous improvement of the level of Information Security and Cybersecurity.

For this purpose:

• The organizational structures necessary for monitoring issues related to Information Security and Cybersecurity are defined.
• Technical measures to control and restrict access to information and information systems shall be defined.
• The way in which information is graded according to its importance and value is defined.
• The necessary actions to protect information during the stages of its processing, storage and circulation are described.
• The ways of informing and training the Company’s employees, both ashore and onboard, and partners on Information Security and Cybersecurity issues are defined.
• Identify ways to respond to Information Security and Cybersecurity incidents.
• The protection of IT and OT systems identified as vulnerable to cyberattacks from loss of confidentiality (information accessibility only to authorized individuals), integrity (safeguard accuracy and completeness of information and processing methods), and availability (authorized individuals have access to relevant information when required) are defined.
• Describe the ways in which the safe continuity of the Company’s business operations is ensured in case of malfunction of information systems or in cases of disasters.

The Company carries out assessments of the risks related to Information Security at regular intervals and takes the necessary measures to address them. It implements a framework for evaluating the effectiveness of its Information Security processes, through which performance indicators are defined, the methodology for measuring them is described and periodic reports are produced and reviewed by the Top Management in order to continuously improve the system.

The CySCO is responsible for controlling and monitoring the policies and procedures related to Information Security and taking the necessary initiatives to eliminate all those factors that may compromise the availability, integrity and confidentiality of the Company’s information.

All employees of the Company and its partners with access to information and information systems of the Company are responsible for complying with the rules of the applicable Information Security Policy.

The Company is committed to the continuous monitoring and compliance with the regulatory and legislative framework and to the continuous implementation and improvement of the effectiveness of the Information Security Management System.

This Policy abides all personnel employed ashore and onboard, contractors, visitors, vendors, agents and any person using the Company’s IT and OT systems.

CASTOR SHIPS S.A. treats employees and crews’ mental health as a priority in its operations, while its utmost concern is always to ensure that all personnel work under conditions that reduce mental health risk factors. To ensure protection of mental health of all personnel, CASTOR SHIPS S.A.:

• Complies with all applicable legislation and regulations, observes relevant guidelines and applies standards where laws and regulations do not exist.
• Seeks to identify and evaluate mental health risks related to its operations that potentially affect employees, crews, contractors, or the public and establishes appropriate safeguards.
• Continuously strives to improve its working environment and culture by identifying, eliminating, or minimizing all harmful processes, procedures and behaviors that may cause psychological harm or illness to its personnel.
• Communicates knowledge about relevant risks to individuals or organizations.
• Determines the mental and psychological fitness of personnel’s work without undue risk to themselves or others.
• Implements programs and appropriate protective measures to control potential risks, including suitable monitoring of personnel.
• Provides mental health services necessary for the prevention, support and treatment of personnel mental health illnesses and the handling of relevant crisis and emergencies.
• Seeks to promote mental health awareness and reduce associated stigma.
• Provides mental health promotion programs to enhance personnel’s wellbeing.

Our goal is to achieve the highest standards of health and personal hygiene through continuous improvement.

CASTOR SHIPS S.A. is committed to a workplace characterized by open communication regarding its business practices. An Open Reporting policy has been adopted to:

1. i) encourage disclosure and investigation of improprieties before they can disrupt the business or operations of the Company or lead to serious loss and
2. ii) to provide an avenue for its employees to raise concerns without fear of retaliation for reports made in good faith.

Employees are encouraged to always take all appropriate action to stop any known misconduct by fellow Employees or other Company personnel and to address their concerns via an email with their immediate supervisor, manager or other appropriate point of contact within the organization or the Open Reporting Hotline. Then the Company’s representative will decide on a way of resolving the concern quickly and effectively. Upon receipt of a report, the Management Board assesses the report and an investigation immediately begins. Top Executives always maintain an ‘open door practice’ to address individuals’ complaints for resolution internally, whenever possible.

The Open Reporting policy addresses concerns related to issues of public interest, including, but not limited to, the following:

Criminal offense

• Non-compliance with legislation or Company’s procedures.
• Dishonesty, either verbal or written, including intentional inaccurate maintenance of official logbooks or records.
• Malpractice or unethical conduct.
• Financial or non-financial misadministration or malpractice or impropriety or fraud.
• Safety or security risk or hazardous condition that may impact the life or health of individuals .
• Miscarriages of justice.
• Deliberate concealment of any of the above.

The Company will not permit any negative or adverse actions to be taken against any Employee or other individual because that person has made a report in good faith about any of the policies, rules or regulations even if such report proves to be mistaken. More specifically, the Company will not discharge, demote, suspend, threaten, harass or in any manner discriminate against any Employee in the terms and conditions of employment because of any lawful act done by the Employee with respect to good faith reporting of complaint(s).

Retaliation in any form against an individual who has made a report in good faith will not be tolerated. Any act of alleged retaliation should be reported immediately and will be promptly investigated and resolved.

CASTOR SHIPS S.A. commits to providing and ensuring a working environment with respect for the dignity, personality, and well-being of all the employees, free from offensive, hostile, and/or intimidating influences that may affect job performance, safety, and/or mental and physical well-being, encouraging the elimination of harassment and bullying.

This Policy addresses concerns related to vindictive and/or humiliating and degrading behavior, including, but not limited to, the following:

Harassment:

• Display or circulation of offensive material
• Offensive language, mockery or sexist/racist/homophobic jokes or remarks, and rude gestures
• Comments about a person’s physical appearance or character that embarrass or distress
• Spreading malicious rumors or insulting someone or intrusive/persistent questioning (particularly about age, race, ethnic origin, marital status, sex, disability, sexual orientation, culture, religion or belief, personal life)
• Making or sending unwanted, sexually suggestive, hostile, or personally intrusive comments, telephone calls, text messages, emails, comments on social networks, faxes, or letters.

Bullying:

• Verbal or physical threats or abuse, such as shouting or swearing, in public or in private, including derogatory or stereotyped statements or remarks
• Personal insults
• Making threats or inappropriate comments about career prospects, job security, or performance appraisals
• Cyberbullying including inappropriate suggestive and unwanted remarks, graphics or threat-centered abusive emails, postings on social networks, and text messages.

CASTOR SHIPS S.A. actively encourages all employees to bring any incident, including those affecting others, to its attention immediately. Complaints can be made without fear of retaliation if they are not vexatious or malicious. The Company treats all harassment and bullying complaints seriously and in strict confidence.

Contact Senior Officers onboard and/or the Crew Manager / DPA / Head of HR ashore as the first point of reference if you want to make a complaint or report an incident.

CASTOR SHIPS S.A.is committed to the below provisions aiming to safeguard welfare and human rights:

1. Conduct its business consistently with the United Nations (UN) Guiding Principles on Business and Human Rights, the 10 principles of the UN Global Compact, the International Bill of Human Rights, ILO Declaration on Fundamentals Principles and Rights at Work, the regional applicable laws and MLC.
2. Provide a safe, physically and mentally healthy, psychologically safe and secure environment for all personnel.
3. Promote an inclusive working culture by facilitating teamwork, respect and fair treatment among all shore and seagoing personnel.
4. Promote equal opportunities and treat all personnel fairly, with care, respect, dignity, without discrimination based on any protected characteristic (like age, civil status, color, culture, descent, disability, gender, language, maternity/paternity, national or ethnic origin, political opinion, pregnancy, race, religion, sexual orientation, etc.).
5. Support open communications onshore and onboard and improve morale and working relationships for all.
6. Communicate guidelines and “Dos and Don’ts” aiming to facilitating optimal social personnel relations based on principles of fairness, diversity, respect and dignity.
7. Implement a “Zero Tolerance” Policy regarding discrimination, harassment, violence or retaliation both onshore and onboard.
8. Verify that seafarers are:
9. Not subject to fraud, substitution of contracts or retention of passports.
10. Not charged any costs that are prohibited by the MLC, such as repatriation costs, etc.
11. Free to join a workers’ union of their choice.
12. Informed about the confidential grievance channels that can be used to raise a complaint before, during and after employment even anonymous.
13. Encouraged to report suspected or actual occurrence(s) of illegal, unethical or inappropriate behaviors or practices. In case of reporting, they are not considered as ‘problematic’ or ‘complainer’.
14. Protected against retaliation, including no blacklisting for raising grievances.
15. Protect the rights of the seafarers during any criminal investigations following accidents, including their rights to avoid self-incrimination, to fair treatment, and to payment of wages, subsistence, accommodation and medical care.
16. Respect the human rights of communities that our business impacts.

All personnel and hired contractors are required to comply with this policy.

CASTOR SHIPS S.A., with the aim to protect its interests, controls and prohibits the contraband and smuggling of illegal material within its premises and onboard managed ships. Furthermore:

• Strictly prohibits the possession of firearms, weapons, explosives, ammunition or pornographic material on Company premises or onboard ships operated by either Company’s employees, sub-contractors, visitors or other persons.
• Controls the possession of contraband onboard the fleet ships by carrying out periodic inspections of personnel habitant spaces by the Master or his appointed representative. The results of these inspections are reported to the Company following their completion.
• Prohibits the contraband and smuggling of tobacco, cigarettes and alcohol.
• Will take disciplinary action, including termination of employment, against anybody onboard the ship who is proven to be in possession of any of the aforementioned controlled items.
• Requires all seagoing staff to sign a Declaration of Acceptance of this policy on joining the ship and prior to assuming duty.

Adherence to this Policy is considered as a term of employment.

CASTOR SHIPS S.A. Management considers the management of risk to be a continuous process and the cornerstone of all the HSQE elements. In this respect, CASTOR SHIPS S.A.:

• Regularly identifies the hazards and assesses all identified risk to its ships, personnel and the environment.
• Assesses potential hazards and risks to personnel, property, the public, customers and the environment for shipboard operations, and modifications.
• Ensures that:
• Assessed risks are addressed by levels of management appropriate to the nature and magnitude/level of the risk.
• Decisions are clearly documented and result into actions implemented through the Company’s procedures.
• Establishes appropriate safeguards to manage the risk by preventing or minimizing the impact of potential accidents, personal accidents, hazardous situations, cyber incidents, near misses, complaints.
• The ALARP (As Low As Reasonably Practicable) principle establishes the relationship between the cost benefit of implementing the risks control measures and the acceptability of risk in a hazardous activity.

Leaders ashore and onboard:

• Put into place and promote the use of Risk Assessment processes to identify hazards associated with the shipboard operations, personnel and the environment.
• Review Risk Assessments at regular specified intervals and as changes are planned.
• Identify existing controls.
• Assess all identified risks, including cyber risks.
• Implement controls of the hazards and manage the risks within tolerable levels.

All personnel are committed to demonstrate and embed cyber risk management into their business and daily activities as part of the Company wider risk management responsibilities imposed.

It is the Company’s Policy that no seafarer navigates the ship or operates its equipment while impaired by drugs or alcohol or where there is any risk of such impairment. Following this Policy, CASTOR SHIPS S.A.:

• Bans:
• All alcoholic beverages from its managed ships.
• Any form of drugs, excluding prescribed drugs, as well as the misuse of legitimate drugs.
• Implements random and unannounced testing of all crew for banned substances and alcohol in such a frequency as to act as an effective abuse deterrent.
• All officers and ratings shall be tested at least once a year through a combined program of unannounced testing and routine medical examinations.
• Controls the use of all medical supplies onboard the managed ships.
• Dismisses and imposes penalties, as per national and international regulations, to anybody who:
• Uses alcohol or banned substances onboard the ship.
• Possesses alcohol or banned substances.
• Participates in bringing alcohol or banned substances onboard.
• Has a positive trace in any random testing sample, unless the Master is informed in advance and provides authorization for use.
• Will take all disciplinary actions, including dismissal, against anybody consuming alcohol, while ashore, for at least 4 hours before returning to ship and scheduled watchkeeping duties or work period.
• Alcohol impairment is defined as a Blood Alcohol Content (BAC) of 40 mg/100ml and equivalent alcohol in breath or greater, which is considered to be a violation of the D&A policy.
• Requires all recruits to take a Drug and Alcohol test before their embarkation
• Implements Post-incident D&A testing of each involved individual.

All seafarers understand that it is their duty and benefit to report immediately to the appropriate Officer or the Master if they suspect or have evidence of a fellow seafarer’s intoxication.

CASTOR SHIPS S.A.:

• Ensures that personnel assigned to the various tasks connected with the provision of services offered by the Company are appropriately competent in those tasks.
• Identifies training needs by appropriate means (such as on-going appraisal of individual development and performance).
• Arranges appropriate training for individuals in line with the resources available and current operational demands.
• Encourages those more experienced in the Company’s business and operations to share their knowledge with less experienced personnel.
• Maintains adequate records of competency.
• Conducts periodic informal interviews with personnel where free interchange of opinion can take place to address both the needs of the individual and those of the Company.
• Adheres to National and International requirements for manning ships and ensures that the records of sea-staff are available for verification.
• Establishes and operates a robust Competency Management System for the continual improvement of personnel’s hard and soft skills.
• Establishes a Learning Organization.
• Invests on and provides with training over and above the minimum regulatory requirements.
• Supports effective and modern training methods that are interactive, empowering, simulate real-life examples, etc.
• Changes the mindset in respect to effective communication means by adopting reflective learning principles.

CASTOR SHIPS S.A. in order to promote commitment to career development has adopted the following Employment Policy and Principles:

• Provision of a safe and healthy working environment
• Establishment of a cadet program for providing with opportunities of increasing familiarization and knowledge with future duties and responsibilities
• Development of appraisal and promotion procedures for monitoring seafarers’ performance and providing with opportunity for proceeding to higher ranks
• Establishment of Service Employment Agreements in compliance with applicable Statutory and Administration Rules
• Provision of appropriate training throughout entire career for increasing each seafarer’s level of skills, knowledge and awareness
• Recruitment of personnel based on objectively set criteria and requirements
• Provision of health protection, medical care, welfare and social security protection in accordance with MLC 2006 and applicable regulations
• Establishment of a shore assignment scheme
• Construction of ships in accordance with latest applicable Rules and Regulations, along with adoption of innovative technologies
• Service within a Management System in compliance with safety9001/45001, and highest industry standards
• Fostering of a concept of just culture within the Company’s Organization
• None discrimination based upon race, color, sex, religion, political opinion, national extraction or social origin
• Encouragement of continual professional development of personnel
• Aiming at filling any vacant position from within the fleet.

CASTOR SHIPS S.A.  is committed to the below provisions aiming to minimize human error, optimize human performance and promote safe and efficient operations:

1. Enhances understanding of human factors (HFs) and how they are managed.
2. Recognizes the link between HFs and safety performance.
3. Considers error as normal and an opportunity to learn and improve.
4. Creates a safe, healthy, and sustainable work environment from a holistic perspective, understanding and providing for human needs.
5. Ensures personnel safety, health, and wellbeing in the optimization of work systems and operations as a top priority.
6. Designs and manages work systems and operations to ensure organizational and personnel alignment, minimize risk, continuous evaluation, learning and sustainability.
7. Accounts for individual differences and organizational contingencies in the design of work systems and operations.
8. Utilizes collective, trans-disciplinary knowledge and full participation of personnel for designing systems, detecting problems and creating solutions for human factor/element in work systems and operations.
9. Promotes non-blame culture and speaking up so that everyone feels empowered to highlight issues.
10. Encourages everyone to feel they can act to resolve safety issues.
11. Promotes, supports and communicates continuous proactive improvement.
12. Commits to two-way engagement with the personnel by:
13. Gathering opinions and feedback from frontline personnel.
14. Discussing company and leadership values, expectations, and standards.
15. Encouraging personnel to speak up about concerns.
16. Requiring from Leaders to make themselves available to the workforce through walkabouts and discussions, with the aim of understanding what makes work difficult.
17. Respecting and acting on concerns of more junior team members.
18. Engages specialists and train personnel to conducting technical, task, behavioral, cognitive and workload assessments and apply results, to minimize the risk that human performance requirements will not be met under all expected conditions.
19. Assesses the impact of Company’s culture, leadership, activities, tasks and processes on human situation awareness, motivation, workload, task performance, error, and physical well-being, and implements design changes to minimize negative impacts and improve outcomes.
20. Documents HFs plans, activities and results.

All personnel and hired contractors are required to comply with this policy.

CASTOR SHIPS S.A. is committed to:

• Provide and ensure a working environment and places free from discrimination, harassment, violence or retaliation of any kind.
• Monitor any relevant case and giving special attention to risky situations and placing special focus on minorities and vulnerable groups with protected characteristics.
• Initiate progressive disciplinary actions, including dismissal, to reprimand any person of any rank onboard or ashore who is involved with acts of discrimination, harassment, violence or retaliation.
• Enhance specific protection for women, when and where employed.
• Prohibit flawed, falsified or shammed logged work/rest hours.

The Company actively encourages all employees open communication to bring any incident, including those affecting others, to its attention immediately. Complaints can be made without fear of retaliation if they are not vexatious or malicious. The Company treats all such incidents seriously and in strict confidence.

Contact Senior Officers onboard and/or the Crew Manager / DPA / Head of HR ashore as the first point of reference if you want to make a complaint or report an incident.

Castor Ships S.A. is committed to compliance with all applicable international sanctions by conducting thorough due diligence, monitoring regulatory developments, and ensuring that the Company’s operations, partners, and cargoes adhere to the highest legal and ethical standards.

The Company is managing, either on a pure commercial, or also on a technical basis, vessels that are ultimately owned by corporations that are publicly listed in a US Stock Exchange (NASDAQ) makes the whole process of abiding with applicable sanctions of paramount importance for the company, as also evidenced by the below steps all the company’s departments are following:

• For each new partnership and/or cooperation that the Company is entering into with any third party for any reason whatsoever, the legal department is the one designated to address to all such parties the company’s standard questionnaire (“Know Your Customer”), which includes a detailed section of Sanction-related inquiries; Before the Company enters into any agreement and/or contact, the legal department collects and reviews the information provided before it grants the green light to all other departments to contractually engage or not;
• Moreover, all the contracts and/or the agreement the Company enters into of whatever nature (e. including but not limited to MoAs – Finance Documentation – TCPs – Commercial Agreements) are each specifically reviewed and commented on by the legal department in respect of the therein mentioned provisions and clauses relevant to the applicable sanctions, thus no such document is signed before the legal department signs off on the sanctions provisions; given the close relationship between the Company and the public listed entities, such documents are very often reviewed by external counsels confirming the validity of such clauses;

Furthermore, in case there is any request from any third party to proceed either commercially or operationally with an action or series of actions that could potential impact the adherence on behalf of the Company of the applicable sanctions laws, all departments of the company address such concerns to the legal department, which is designated to review such actions and if required reach out to sanctions-specialists before any decision is made;

Castor Ships S.A. was accredited for 2nd  year on April 2025 with ISO 9001 Quality Certification and ISO 14001 Environmental Certification by Bureau Veritas as a result of continuous efforts for high quality services and environmental compliance with international legislation.