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 framework.
• 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. 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 management, 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. 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. believes that although shipping is by far the most fuel-efficient means of transport, 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.

CASTOR SHIPS S.A. aims to:

• Protect information and operation technology assets from all threats, whether internal or external, deliberate or accidental, ensuring their integrity and operational governance.
• Ensure operations continuity.

The Company’s management, to fulfill these objectives, is committed to minimize the impact of cyber incidents and to ensure:

• Compliance with regulatory requirements
• 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)
• Allocation of specific and clear responsibilities and tasks ensuring effective cyber risk management
• Preparation of cybersecurity procedures and protection measures based on identified vulnerabilities and Risk Assessments
• Establishment of contingency and recovery plans
• Cybersecurity training and readiness of all staff
• Reporting and investigation of all security breaches, actual or suspected, along with detailed investigation.
• Prepare contingency plans for emergencies relating to cyber security incidents;

To support this Policy, there are procedures in place, including incident handling, information backup, system access, antivirus controls, passwords, and encryption.

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. has a strong commitment to promoting honest conduct and ethical business conduct by all Employees and compliance with the laws that govern the conduct of our business worldwide. We believe that a commitment to honesty, ethical conduct and integrity is a valuable asset that builds trust with our customers, suppliers, employees, and the communities in which we operate.

To implement our commitment, we have developed this Code to deter wrongdoing and to promote honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships and avoidance of conflicts of interest. The Code establishes rules and standards regarding behavior and performance and constitutes a part of the terms and conditions of employment. Violation of the rules and standards embodied in the Code is not tolerated and will subject those responsible to disciplinary action.

This Code applies to the Company and all of its employees, directors and officers, including its Chief Executive Officer, Chief Financial Officer, its agents and persons performing similar functions as well as to all of its subsidiaries and other business entities controlled by it worldwide. All Employees are required to read and understand the Code. We encourage all Employees to ask questions regarding the application of the Code. Employees may direct such questions to their manager (in the absence of an actual or potential conflict of interest), or to a member of Management Board. Employees individually are ultimately responsible for their compliance with the Code. Every manager will also be responsible for administering the Code as it applies to Employees and operations within each manager’s area of supervision.

The Company’s policy is to distribute the Code to affiliated companies and urge that they have in force similar policies and procedures to secure compliance with the principles of business integrity and ethics set forth in this Code.

Duty To Report: Employees shall take all appropriate action to stop any known misconduct by fellow Employees that violate this Code. Employees who observe or become aware of a situation that they believe to be a violation of the Code have an obligation to notify their manager or the Management Board Chairman unless the Code directs otherwise. Violations involving a manager should be reported directly to the Management Board Chairman. When a manager receives a report of a violation, it will be the manager’s responsibility to handle the matter in consultation with the Management Board Chairman. If an Employee reporting a violation wishes to remain anonymous, all reasonable steps will be taken to keep their identity confidential. All communications will be taken seriously and, if warranted, any reports of violations will be investigated.

Violations of Law: A variety of laws apply to the Company and its operations, and some carry criminal penalties. These laws include banking regulations, securities laws, and state laws relating to duties owed by corporate directors and officers, as well as data protection regulations. Examples of criminal violations of the law include: stealing; embezzling; misapplying corporate or bank funds; using threats, physical force or other unauthorized means to collect money; making a payment for an expressed purpose on the Company’s behalf to an individual who intends to use it for a different purpose; making payments, whether corporate or personal, of cash or other items of value that are intended to influence the judgment or actions of political candidates, government officials or businesses in connection with any of the Company’s activities; The Company must and will report all suspected criminal violations to the appropriate authorities for possible prosecution, and will investigate, address and report, as appropriate, non-criminal violations.

Conflicts of Interest: A conflict of interest can occur or appear to occur in a wide variety of situations. A conflict of interest occurs when an employee’s or an employee’s immediate family’s personal interest interferes with, has the potential to interfere with, or appears to interfere with the interests or business of the Company. For example, a conflict of interest could arise that makes it difficult for an employee to perform corporate duties objectively and effectively where he/she is involved in a competing interest. Another such conflict may occur where an employee or a family member receives a gift, a unique advantage, or an improper personal benefit because of the employee’s position at the Company. Because a conflict of interest can occur in a variety of situations, you must keep the foregoing general principle in mind in evaluating both your conduct and that of others.

Employees under no circumstances are permitted to compete with the Company or take for themselves or their family members business opportunities that belong to the Company that are discovered or made available by virtue of their positions at the Company. Employees are encouraged to participate in civic, charitable or political activities so long as such participation does not encroach on the time and attention they are expected to devote to their company-related duties. Such activities are to be conducted in a manner that does not involve the Company or its assets or facilities, and does not create an appearance of Company involvement or endorsement. The Company will not make loans or extend credit guarantees to or for the personal benefit of officers, except as permitted by law. Loans or guarantees may be extended to other Employees only with Company’s approval.

Confidentiality and Privacy: It is of paramount importance that all Employees protect the confidentiality of Company information. Employees may have access to proprietary and confidential information concerning the Company’s business, clients and suppliers. Confidential information includes such items as non-public information concerning the Company’s business, financial results and prospects and potential corporate and commercial transactions. Employees are required to keep such information confidential during employment as well as thereafter, and not to use, disclose, or communicate that confidential information other than in the course of employment. The consequences to the Company and the Employee concerned can be severe where there is unauthorized disclosure of any non-public, privileged or proprietary information.

Honest and Fair Dealing: Employees must endeavor to deal honestly, ethically and fairly with the Company’s customers, suppliers, competitors and employees. Honest conduct is considered to be conduct that is free from fraud or deception. Ethical conduct is considered to be conduct conforming to accepted professional standards of conduct. Unfair conduct is considered to be conduct where one tries to take unfair advantage of another through manipulation or misrepresentation of material facts, abuse of privileged information or any other unfair-dealing practice.

Protection and Proper Use of Company Assets: The Company’s assets are only to be used for legitimate business purposes and only by authorized Employees or their authorized designees. This applies to tangible assets (such as office equipment, telephone, copy machines, etc.) and intangible assets (such as trade secrets and confidential information). Employees have a responsibility to protect the Company’s assets from theft and loss and to ensure their efficient use. Employees may not make improper payments in violation of law or Company policy. Theft, carelessness and waste have a direct impact on the Company’s profitability. If an Employee becomes aware of theft, waste or misuse of the Company’s assets such Employee should report this to his or her manager or the Management Board. Employees should not make use of the corporate facilities, supplies and equipment for personal purposes without the company’s approval.

Compliance with Laws, Rules and Regulations: All Employees are responsible for complying with the various laws, rules and regulations of the countries and regulatory authorities that apply to the Company’s business and location. Any Employee who is unsure whether a situation violates any applicable law, rule, regulation or Company policy should contact their manager or the Management Board.

Castor Ships S.A. was accredited on April 2024 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.