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Policies

1.Business Ethics
The Company in pursuit of its business objectives is committed to a course of the highest integrity, which avoids even the appearance of impropriety in the conduct of its affairs. The Company’s relationships with clients and suppliers are based on sound  commercial criteria that are not influenced by other factors such as gifts or entertainment. In this way the Company is able to sustain constructive ongoing relationships with those organizations, companies and individuals doing business or seeking to do business with it. The Company will render equitable and faithful performance to each of its customers and will respect the confidentiality of its customer’s business and activities.

The Company will not consciously participate in activities or practices which are known to be unsafe or illegal and will not commit itself to carry out business for a customer when the service to be provided may be used for illegal activities.

 Accordingly the receiving or giving of gifts, meals, travel, entertainment or other favors between employees and business contacts should be moderate, infrequent, appropriate to the occasion and only within genuine business purposes.

The giving of or receiving cash gifts are strictly prohibited.

Any infractions of this code of ethics will not be tolerated and the Company will act quickly in correcting the issue if the ethical code is broken.

Any employee found to have violated this policy may be subject to disciplinary action, up to and including termination of employment. All Policies are communicated to newly employed shore personnel and ship’s Officers and crew during familiarization process.
2.Safety Policy

The Management of ENESEL S.A. is committed to take all reasonable precautions and measures, during the operation of managed vessels, in order to ensure safety at sea, prevention of human injury or loss of life and avoidance of damage to property.

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

To fulfil these objectives, the management is committed to the following approach:

  • Compliance with mandatory rules and regulations and taking into consideration the Codes, guidelines and standards recommended by the IMO, Flag Administrations, Class Societies and Industry organizations, applicable to operations of managed vessels.
  • Adherence to an Integrated Management System (IMS) by all Company’s employees, including managed vessels, which promotes the concept of safety and environmental excellence, continuous improvement and enhancement of personnel skills.
  • Assigning employees possessing sound skills and capabilities in required areas of responsibility, including adequate verification resources.
  • Defining the organization, responsibility, authority and interfacing of the various management functions within the frame of the IMS.
  • Providing for safe and environmentally sound practices in the operation of managed vessels. Providing and maintaining a safe working environment onboard to assist in preventing human injury and loss of life.
  • Providing the necessary training to ensure that Company’s employees are capable of achieving safety and pollution prevention objectives in the work they perform.
  • Providing facilities, systems/equipment and a maintenance system that is suited for the purpose of achieving objectives.
  • Conducting management review meetings and management system audits.
This Policy has the full support of Top Management and applies to all Company’s employees.
3.Health & Hygiene Policy


ENESEL S.A. holds health and hygiene as first priority in its operations, while its outmost concern is to always ensure that all employees execute their work under safe and hygienic conditions. In order to ensure high standards of health and hygiene, the Company:

  • 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 health and hygiene risks to individuals in potential risk or organizations and the scientific community.
  • Determines at the time of employment and thereafter, as appropriate, the medical fitness of employees to perform their work without undue risk to themselves or others.
  • Implements programs and appropriate protective measures to control such risks, including appropriate monitoring of employees in potential risk.
  • Provides or arranges, as appropriate, for medical services necessary for the treatment of employee occupational illnesses or injuries and for the handling of medical emergencies.
  • Provides voluntary health and hygiene promotion programs designed to enhance employees’ wellbeing and personal safety. These programs should supplement, but not interfere with, the responsibility of employees over their own health care.
  • Undertakes appropriate reviews and evaluations of its operations to measure progress and to foster compliance with this Policy.
The Company’s goal is to achieve the highest standards of health and personal hygiene through continuous improvement.

Information about employees are confidential and shall not be revealed to non-medical personnel except at the request of the employee concerned, or when required by law, when dictated by overriding public health considerations, or when necessitated by the Company’s Drug and Alcohol Policy.

This Policy has the full support of the Company’s Management, is available to the public and applies to all Company’s employees
4.Quality Policy

ENESEL S.A. is fully committed to providing a Quality service, which consistently and continuously meets and exceeds the requirements of its Customers, in accordance with national and international laws, rules and regulations, whilst protecting assets under its care, its employees and the environment in general. This is achieved by establishing and discharging managerial and operational processes, which have emerged from a combination of sound managerial principles and long experience in the Shipping Industry. The implementation of this Policy is underpinned by the full support of the Top Management. The Company aims to maintain the quality of service it provides by:

  • Meeting and exceeding customer requirements and expectations as defined in the relevant Ship Management Agreements and Charter Parties with the aim of enhancing customer satisfaction.
  • Developing and implementing controlled processes,
  • Continual improvements in operational responsiveness,
  • Monitoring the effectiveness and ongoing relevance of the policies and procedures by initiating regular reviews,
  • Reviewing the needs and expectations of our customers and initiate continuous improvement activities to meet these expectations,
  • Complying with the ISM Code as well as continuously improving its Management System, always in line with ISO 9001 and ISO 14001,
  • Establishing and communicating measurable and consistent objectives and performance targets to Company employees,
  • Complying with applicable statutory requirements, international legislation and classification society requirements related to the services provided
  • Operating Vessels without accident(s) or incident(s) that could endanger the Company’s employees, the environment and/ or assets under the Company’s care,
  • Complying with current Health and Safety legislation and,
  • Developing employee skills and increasing their contribution through effective training
In order to meet the above objectives the company has developed and implements a Management System, which as a minimum shall meet the requirements of ISO 9001, ISO 14001, ISM & ISPS Code and MLC 2006 Convention.

All Company employees are responsible for implementing the Company's Quality Policy.

The Company's Management is responsible for monitoring and reviewing the Quality Policy at regular intervals in order to ensure that it remains relevant and effective.

Moreover, the Company’s Management shall ensure that its Quality Policy and its related procedures and controls are understood, implemented and maintained at all levels of its organization.

All Policies are communicated to newly employed shore personnel and ship’s Officers and crew during the familiarization process.
5. Environmental Policy

The Company is committed through continuous efforts to improve environmental performance in all areas required by the international regulations and laws and Company’s IMS and EMS towards a cleaner environment, and to ensure:

  • Pollution prevention that emphasizes source reduction, including necessary funding and human resources, to effectively maintain the onboard systems, equipment and components.
  • Continuous reduction of environmental risks.
  • Sharing information on environmental performance with external stakeholders.

The Company’s goal is to achieve ZERO pollution at sea, air and at land through continuous improvement. For achieving this goal, the Company:
  • 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, in co-operation with industry organizations and authorized government agencies.
  • Assesses all identified risks to the environment and establishes appropriate safeguards.
  • Shows concern and respect for the environment, emphasizes every employee's responsibility in environmental performance and fosters appropriate operating practices and training.
  • Undertakes appropriate reviews and evaluations of its operations to measure progress and to foster compliance with this Policy.
  • Manages its business with the goal of preventing environmental incidents and of controlling emissions and wastes to below harmful levels.
  • Designs, operates and maintains facilities to this end.
  • Shares its experience with others to facilitate improvements in industry performance.
This Policy has the full support of Top Management, is available to the public and applies to all Company’s employees.
6. Drugs & Alcohol Policy

It is the Company’s Policy that no seafarer employed shall navigate the Vessel, operate machinery or carry out his duties whilst he is impaired by drugs or alcohol or suspected to be under the impairment of alcohol or drugs

As a condition of continued employment all shipboard personnel are required to submit to drug and alcohol testing. Refusal to consent to the testing, falsification of a test or positive test results will result in the termination of employment.

All shore based and shipboard personnel of the Company are strictly required to adhere to this policy full complying with the Company’s procedures and all applicable national and international regulations.

The Company has defined as alcohol impairment a breath alcohol content of 0.20 mg/lt or more or 0.04% blood alcohol level (BAC).

In order to enforce this policy:

1) The Company implements very strict rules and procedures in alcohol distribution and consumption

2) The possession, use, trafficking of any kind of illegal drugs and for any reason on board the ship is prohibited

3) The Company implements procedures in alcohol distribution and consumption, which meet or exceed the relevant Flag State legislation and/or ICS/OCIMF guidelines and enforces a strict blood/breath and/or urine test schedule involving:

  • mandatory pre-joining tests for all seafarers
  • Periodical random testing/screening on board Vessels. Each Officer is to be tested at least once annually.
  • Regular breathalyzer tests on board, either as a control procedure, or during the case of an investigative process.
Seafarers found to be in violation of this Policy shall be immediately released from duty and dismissal / disciplinary action will be taken.

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

All Policies are communicated to newly employed shore personnel and ship’s Officers and crew during the induction & familiarization process.
7. Anti-Bribery & Anti-Corruption Policy



Enesel S.A. will not countenance bribery or corruption in any form. For further information regarding our internal policy on bribery and corruption please contact Ms. Anna Karatsivi, her contact details as follows: +30.210. 7260 501 or at anna.karatsivi@eneselsa.com

8. Data Protection and Privacy Policy



DATA PROTECTION AND PRIVACY POLICY

We at ENESEL SA (the "Company") respect your privacy and are aware that we expected to handle all personal data responsibly. We have, therefore, developed this Policy to clearly describe what types of information we gather, how this information is used, with whom it is shared and why, and to ensure that the Company complies fully with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (the "General Data Protection Regulation" or "GDPR").

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED?
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY

1. IMPORTANT INFORMATION AND WHO WE ARE

1.1 Purpose of this Privacy Notice

This privacy notice aims to give you information on how ENESEL SA collects and processes your personal data, whether through this website or through our exchanges with you.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

1.2 Controller

ENESEL SA is a data controller and responsible for your personal data (referred to as the Company, "we", "us" or "our" in this privacy notice).

We have appointed a data privacy team who is responsible for overseeing question in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy team using the details set out below:

Our full details are:

  1. Full name of legal entity: Enesel S.A.
  2. Data privacy team/email address:privacy@eneselsa.com
  3. Postal address: Kolonaki International Center, 23A Vasilissis Sofias Avenue, Athens 106-74, Greece
1.3 Changes to the Privacy Notice and Your Duty to Inform us of Changes

This version came into effect in May 2018. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

1.4 Third Party Links


This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU


Personal data or personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
  1. Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  2. Contact Data includes email address and telephone numbers.
  3. Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

We may also collect, use and share Aggregated Data such as statistical data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We may also collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) but, if we do, we will ensure that you are served with an explicit privacy notice telling you how we will deal with such information.

We will not collect any information about criminal convictions and offences, unless we have obtained your express consent.

2.1 If You Fail to Provide Personal Data


Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?


We use different methods to collect data from and about you including through:
  1. Direct interactions. You may give us your Identity, Contact and financial data by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  2. apply for a position in our Company;
  3. offer your or your company's business services to the Company;
  4. where you work for one of the Company's clients, business partners, consultants, advisors or other third parties the Company interacts with in a business context;
  5. otherwise interact with us for your and our business purposes, including marketing to us (whether by email or in person) or meeting us or any of our representatives in business context.
  6. Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, [server logs] and other similar technologies. We do not process this information.

4. HOW WE USE YOUR PERSONAL DATA


We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
  1. Where we need to perform the contract we are about to enter into or have entered into with you or your employer.
  2. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  3. Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data.

4.1 Purposes For Which We Will Use Your Personal Data


We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data on the basis of more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

 

 Type of data

 

 Lawful basis for processing including basis of legitimate interest

 

To register job applications for positions in our Company

(a) Identity

(b) Contact

Performance of a prospective contract with you.

To consider, evaluate and respond to marketing and/or business proposals from third parties

 

 

(a) Identity

(b) Contact

 

Necessary for our legitimate interests (to keep our records updated and assess services available to us).

 

To maintain and develop business relationships with clients, business partners, consultants, advisors or other third parties

(a) Identity

(b) Contact

 

Necessary for our legitimate interests (to keep our records updated and assess services available to us and to develop our business relationships with prospective clients and to grow our business).

 

To maintain and develop business contact with existing, former or potential future clients, partners or third parties whether by telephone, email or in person

 

(a) Identity

(b) Contact

 

Necessary for our legitimate interests (to keep our records updated and to develop our business relationships and to grow our business).

 

 

4.2 Change Of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA


We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
  1. Internal Third Parties as set out in the [Glossary].
  2. External Third Parties as set out in the [Glossary].
  3. Specific third parties such as third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS


We may share your personal data within our Group of companies. This may involve transferring your data outside the European Economic Area (EEA). All companies within our Group have adopted suitable policies giving effect to the GDPR and the data protection regime applicable with the EEA.

Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. DATA SECURITY


We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. DATA RETENTION


How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by Contacting us.

In some circumstances you can ask us to delete your data: see [Request erasure] below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS


Under certain circumstances, you have rights under data protection laws in relation to your personal data, such as the right to:-
  1. Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  3. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  4. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  5. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  6. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  7. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please Contact us.

9.1 No Fee Usually Required


You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.


9.2 What We May Need From You


We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

9.3 Time Limit To Respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. GLOSSARY

  • Legitimate Interest means the interest of our business in conducting and managing our business. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us.
  • Performance of Contract means processing your data where it is necessary for the performance of a contract to which you or your employer is a party and processing your personal data is necessary for such performance (e.g. where your email identifies you in person or where we are given access to your mobile or home telephone numbers) or to take steps at your request before entering into a contract with you.
  • Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
  • Third Parties means Internal Third Parties and External Third Parties.
  • Internal Third Parties Other companies in our Group acting as processors and who are based in the United Kingdom and provide insurance, chartering and commercial services to us.
  • External Third Parties
    • Service providers acting as processors based in Greece and Cyprus who provide IT and system administration services.
    • Professional advisers including lawyers, bankers, auditors and insurers based in and/or out EEA who provide consultancy, banking, legal, insurance and accounting services.
    • Ergani/other public bodies