HSQE Policy (Health, Safety, Quality & Environment)

SEACHIOS CRANE NAVAL E SERVICOS MARITIMOS LTDA., a company duly organized under the laws of the Federative Republic of Brazil, enrolled with CNPJ/Tax ID 09.258.299/0001-53, operating commercially under the brand Seachios® Marine Services (“Seachios”, “Company”, “we”, “us” or “our”).

HSQE Contact: hsqe@seachiosbrazil.com
Corporate Contact: contact@seachiosbrazil.com

Corporate HSQE Authority Statement and Topical Scope Anchor

This HSQE Policy is a binding corporate governance instrument defining Seachios’ minimum standards for Health, Safety, Quality and Environment (HSQE) across maritime and port operations performed, coordinated, supervised, interfaced, documented, contracted, or arranged by Seachios. It applies to Seachios personnel and all third parties acting with or on behalf of Seachios across Brazilian ports, terminals, anchorages and shipboard environments, including operational scopes such as cargo hold cleaning and hold preparation for dry bulk carriers, tank cleaning and residue handling interfaces, underwater inspection and underwater services (including hull cleaning, propeller polishing and rudder/appendage works), ship repair and marine engineering, terminal and industrial cleaning, port operational interfacing, and multi-port mobilization and riding-crew logistics. This Policy establishes non-negotiable requirements for permit-to-work discipline, confined space control, working at height, lifting and rigging, atmospheric testing governance where applicable, marine pollution prevention, spill readiness, waste and residue governance, evidence-based reporting, and Stop Work Authority. Seachios maintains operational alignment with applicable international maritime conventions and recognized safety-management principles, including SOLAS, MARPOL, and safety-management principles consistent with the ISM Code, and adopts structured risk and control practices consistent with commonly accepted maritime and industrial HSQE expectations.

HSQE Declaration

Seachios hereby issues this HSQE Declaration as a public, governance-grade statement of our standards and commitments.

1. Protection of life and prevention of harm are paramount. No commercial objective, schedule pressure, or operational convenience may override safe-work prerequisites and safe systems of work.

2. Environmental protection and marine pollution prevention are fundamental duties. Pollution prevention controls, waste and residue governance, spill readiness, and prohibition of uncontrolled discharge are mandatory.

3. Quality is defined by control and evidence. Seachios delivers services under defined acceptance criteria, controlled methods, traceable records, and verifiable documentation suitable for audit and stakeholder scrutiny.

4. Stop Work Authority applies to all participants. Any person may and must stop work when controls are missing or ineffective, without retaliation.

5. Integrity in HSQE decisions is mandatory. HSQE outcomes shall not be compromised by improper influence, concealment of hazards, unethical shortcuts, or misrepresentation of records.

6. Contractor and supplier HSQE governance is a condition precedent to engagement. Third parties must demonstrate competence, readiness, and acceptance of Seachios’ operational controls.

1. Policy Status and Governance Hierarchy

This Policy establishes Seachios’ minimum HSQE baseline. Where any client instruction, third-party practice, local custom, or production pressure conflicts with the minimum controls stated herein, Seachios will apply this Policy as its baseline standard and may escalate, suspend, or refuse work until adequate controls are restored.

Where multiple standards apply (client, vessel, terminal, or regulatory), Seachios may apply the strictest practical requirement as a risk control measure.

2. Definitions

• SWA (Stop Work Authority): The right and duty to stop work when conditions are unsafe or controls are missing or ineffective.

• HIPO (High-Potential Incident): Any incident or near-miss with credible potential for fatality, serious injury, major pollution, or major damage.

• JSA / TRA: Job Safety Analysis / Task Risk Assessment.

• PTW: Permit-to-Work system, including confined space entry, hot work, working at height, lifting operations, and hazardous energy isolation.

• Nonconformity: Deviation from scope, acceptance criteria, procedure, or required documentation/evidence.

• Evidence Integrity: Authenticity, traceability, custody and controlled issuance of records including photo/video evidence where applicable.

• Hierarchy of Controls: Elimination, substitution, engineering controls, administrative controls, PPE.

3. Scope of Application

This Policy applies to:

• Seachios directors, officers, managers, employees, trainees, and representatives;

• Contractors, subcontractors, labor providers, consultants, suppliers, intermediaries, and partners engaged by Seachios;

• Any operational activity where Seachios coordinates, supervises, represents, interfaces, mobilizes, documents, or exercises operational control.

Third-party engagement and continued access to site/vessel/terminal work is conditioned to HSQE readiness, competence, and acceptance of Seachios’ operational controls, including SWA and reporting obligations.

4. HSQE Non-Negotiables

Seachios’ minimum HSQE requirements include, without limitation:

1. Safe systems of work verified before start;

2. Stop Work Authority and non-retaliation;

3. Marine pollution prevention, spill readiness, and waste/residue governance;

4. Quality through acceptance criteria, inspection points, and evidence integrity;

5. Integrity in HSQE decisions (no improper influence, no concealment, no record manipulation);

6. Contractor and supplier HSQE governance as a condition of work continuation;

7. Immediate reporting and escalation of hazards, near-misses, incidents, environmental events, and material nonconformities;

8. Corrective and preventive actions tracked to closure and verified for effectiveness.

5. Governance, Roles, Accountability and Delegation

5.1 Executive Leadership

Executive leadership retains ultimate accountability for HSQE governance, resourcing, enforcement, and decisions to suspend operations or remove contractors where required.

5.2 HSQE Management Function

The HSQE function is accountable for policy maintenance, operational standards, audit programs, inspection routines, incident investigation governance, corrective action tracking, and evidence integrity requirements.

5.3 Operational Leadership

Operational leadership is accountable for readiness planning, risk assessment quality, PTW discipline, competence verification, supervision proportional to risk, and completion of HSQE and quality records.

5.4 Individual Accountability

Every person engaged in work under Seachios must comply with safe systems of work, use PPE correctly, report hazards and events, and exercise SWA where required.

6. Stop Work Authority, Non-Retaliation and Resumption Controls

6.1 Mandatory Stop-Work Triggers

Work shall be stopped immediately if any of the following conditions exist:

• Required permits are missing, invalid, incomplete, not communicated, or not understood;

• Confined space conditions exist without credible entry controls and rescue readiness;

• Atmospheric testing governance is absent or unreliable where required by exposure conditions;

• Fall protection is missing or unsuitable for height exposure;

• Lifting operations lack competent rigging, exclusion zones, or equipment suitability;

• Chemical hazards cannot be controlled or SDS information is unavailable;

• Environmental containment is absent, has failed, or uncontrolled discharge risk exists;

• Competence or supervision is inadequate for task criticality;

• Any credible HIPO condition exists.

6.2 Non-Retaliation

No retaliation, penalty, discrimination, or adverse treatment shall apply to any individual who stops work or raises HSQE concerns in good faith.

6.3 Resumption Governance

Work may resume only when hazards are controlled and verified, permits and requirements are valid and understood, supervision and readiness are restored, and environmental controls and documentation governance are confirmed.

7. End-to-End HSQE Risk Management Controls

7.1 Pre-Mobilization Governance

Prior to mobilization, Seachios implements, as applicable:

• Scope definition, exclusions, deliverables and acceptance criteria;

• Interfaces mapping and accountability allocation (vessel/terminal/client/contractors);

• Risk classification (routine / non-routine / critical);

• Resource plan, supervision plan and competence verification;

• Tools, equipment and PPE readiness confirmation;

• Site induction planning and access readiness;

• Emergency readiness alignment and communication plan;

• Environmental controls planning for residues, waste and containment;

• Evidence plan where evidence is a deliverable.

7.2 Task Risk Assessment (JSA/TRA)

Each task must have a risk assessment identifying hazards, defining controls using the hierarchy of controls, establishing hold points, setting stop-work triggers, and confirming workforce understanding.

7.3 Permit-to-Work (PTW) Discipline

Where PTW systems are required by site rules, vessel rules, or exposure, Seachios requires PTW compliance and will not proceed without it, including as applicable: confined space entry, hot work, working at height, lifting/rigging, and hazardous energy isolation.

8. Competence, Training, Fitness for Duty and Human Factors

Seachios requires competence proportionate to exposure. Specialized work requires role authorization and competent supervision. Fitness-for-duty considerations include fatigue governance, heat stress controls where applicable, prohibition of impairment, and communication clarity appropriate to operational teams.

9. Tools, Equipment and PPE Governance

Seachios enforces:

• Fitness-for-use verification and inspection discipline;

• Immediate withdrawal of defective tools/equipment;

• Suitability for maritime conditions;

• Minimum PPE baseline plus task-specific PPE;

• PPE discipline as a condition of work.

10. Environmental Protection, Marine Pollution Prevention and Waste/Residue Governance

Seachios commits to:

• Spill prevention planning and containment readiness;

• Waste/residue segregation, containment, traceability and controlled transfer;

• Controls for wash water, slops, residues, paint debris, rust scale and contaminated consumables as applicable;

• Prohibition of uncontrolled discharge to sea or shore;

• Environmental stop-work triggers where containment fails or uncontrolled release risk exists.

11. Quality Governance: Acceptance Criteria, Inspection Points and Evidence Integrity

Seachios defines quality as conformance + control + evidence.

Each job must define acceptance criteria, inspection points and sign-off method. Where reports or certificates are delivered, evidence integrity is mandatory: controlled issuance, version control, and prohibition of misrepresentation, concealment, manipulation, or omission intended to mislead.

12. Incident, Near-Miss and Nonconformity Management

Seachios requires immediate reporting of injuries, near-misses, unsafe conditions, environmental incidents, and quality nonconformities.

Investigation governance includes proportionate investigation, root-cause methodology, corrective and preventive actions tracked to closure, and effectiveness verification. High-potential events trigger escalation and re-validation of controls prior to resumption.

13. Emergency Preparedness and Response

Seachios maintains emergency readiness proportionate to exposure, including communications and escalation plans, alignment with vessel/terminal emergency arrangements, first-aid readiness, spill response readiness where relevant, and rescue readiness for confined space exposure where applicable.

14. Contractor, Supplier and Third-Party HSQE Governance

Third parties must demonstrate competence and readiness, provide fit-for-use equipment, comply with PTW systems and Seachios controls, accept SWA enforcement, report incidents, and cooperate with investigations. Noncompliance may result in suspension, removal, disqualification, and termination.

15. Assurance, Audits, KPIs and Management Review

Seachios applies field verification, inspections, audits, KPI monitoring (leading and lagging indicators), and management review to ensure governance effectiveness and continuous improvement.

16. Records Control, Confidentiality and Data Protection (HSQE Context)

HSQE records and operational documentation are controlled corporate assets. Seachios applies version control, retention discipline, controlled access to sensitive records, and appropriate confidentiality for client, vessel and personnel information processed in HSQE workflows.

17. Enforcement and Operational Refusal

This Policy is enforceable through stop-work and operational suspension authority, contractor removal and disqualification, disciplinary measures for willful noncompliance, and mandatory corrective action procedures. Seachios may refuse to proceed where minimum HSQE prerequisites are not met.

18. Updates

Seachios may revise this Policy and annexes to reflect regulatory evolution, operational learning, and governance improvements. Revisions take effect upon formal issuance by the Company.

Operational Annexes (Standards, Control Matrices and Checklists)

Annex A — Universal HSQE Operational Control Matrix (All Operations)

A1. Governance and Planning

• Defined scope, exclusions, deliverables and acceptance criteria

• Interfaces map with accountability (vessel/terminal/client/contractors)

• Named supervisor/coordinator with authority to enforce controls

• Risk classification (routine / non-routine / critical)

• Pre-job briefing record and verification of understanding

• Stop-work triggers communicated and acknowledged

A2. Risk Assessment (JSA/TRA)

• Risk assessment completed prior to start

• Critical steps and hold points identified

• Control verification before commencement

• Re-assessment triggers defined (weather, manpower, method, interruption, incident, abnormal condition)

A3. PTW Discipline (Where Applicable)

• Confined space entry controls and authorization

• Hot work permits, fire watch and post-work monitoring

• Working at height permits and fall protection controls

• Lifting and rigging plans and exclusion zones

• Hazardous energy isolation verification and control

A4. Competence and Fitness for Duty

• Competence verified for roles and exposures

• Fatigue and travel risk considered in planning

• Heat stress measures where applicable

• Prohibition of impairment enforced

A5. Tools, Equipment and PPE

• Fitness-for-use inspection and condition checks

• Defect reporting and withdrawal from service

• Minimum PPE baseline and task-specific PPE enforced

A6. Environmental Controls

• Waste and residue segregation and containment plan

• Transfer route and controlled disposal governance where applicable

• Spill prevention and containment readiness

• Prohibition of uncontrolled discharge

A7. Quality Controls and Evidence Integrity

• Acceptance criteria and inspection points defined

• Documentation package defined and controlled

• Evidence integrity requirements defined and enforced

• Nonconformity governance and corrective action triggers

A8. Incident Escalation

• Mandatory reporting culture for hazards and events

• Escalation ladder and contact points verified

• Corrective actions tracked to closure with effectiveness verification

Annex B — Cargo Hold Cleaning and Hold Preparation (Dry Bulk)

B1. HSQE Objective
To execute cargo hold cleaning and hold preparation under controlled governance suitable for bulk carriers and terminal environments, preventing injury and pollution while achieving readiness under defined acceptance criteria for dry bulk cargoes.

B2. Minimum Mandatory Controls

• Controlled access, lighting and ventilation planning

• Confined space governance where applicable (authorization, accountability, rescue readiness, communications)

• Working at height governance (engineered access where available, fall protection where required, exclusion zones)

• Water/pressure governance (hose discipline, secure connections, slip control and housekeeping)

• Chemical management (SDS availability, controlled dilution, labeling, storage, PPE discipline)

• Residue and waste governance (segregation, containment, transfer route discipline, prohibition of uncontrolled discharge)

• Quality governance (acceptance criteria, inspection points, evidence protocol, nonconformity and corrective action triggers)

Annex C — Tank Cleaning, Residue Handling and Gas-Free Interfaces

C1. HSQE Objective
To ensure tank cleaning and residue handling interfaces are governed by PTW discipline, atmospheric testing governance where required, ignition source control, and environmental containment suitable for high-consequence environments.

C2. Minimum Mandatory Controls

• PTW discipline where applicable

• Atmospheric testing governance where required (baseline, frequency, re-test triggers, competence)

• Ventilation planning and verification where required

• Ignition source control and hazardous energy discipline as applicable

• Residue/slops containment and traceability where applicable

• Spill readiness and rescue/emergency readiness proportionate to exposure

Annex D — Underwater Services (Inspection, Cleaning, Propeller Polishing)

D1. HSQE Objective
To execute underwater operations under movement restriction governance, exclusion zone control, environmental protection and evidence integrity suitable for port and anchorage contexts.

D2. Minimum Mandatory Controls

• Method statement and operational limits

• Propulsion/movement restriction confirmation and communications protocol

• Exclusion zones and area control discipline

• Competence and equipment readiness governance

• Environmental controls proportionate to scope and site requirements

• Evidence mapping and limitations statement for inspections; controlled issuance of deliverables

Annex E — Ship Repair and Marine Engineering

E1. Minimum Mandatory Controls

• PTW discipline for hot work, hazardous energy isolation and confined space where applicable

• Fire watch and post-work monitoring where applicable

• Fume/dust exposure controls and PPE discipline

• Lifting/rigging governance where applicable

• Acceptance criteria, inspection points and sign-off records

• Nonconformity and corrective action governance

Annex F — Terminal / Industrial Cleaning (Structures and Equipment)

F1. Minimum Mandatory Controls

• Hazardous energy isolation verification

• Height work plan and fall protection controls

• Exclusion zones under elevated work

• Dust/noise exposure controls and PPE

• Residue and wash water containment and controlled disposal governance where applicable

Annex G — Port Operational Interfacing (Agency / Clearance-Adjacent Governance)

G1. Minimum Governance Requirements

• Interface responsibility matrix (PTW control, supervision, emergency readiness, escalation)

• Verification of third-party HSQE readiness prior to mobilization

• Access and documentation control discipline

• Escalation and stop-work triggers

• Prohibition of representing compliance where prerequisites are absent

Annex H — Multi-Port Operations, Riding Crews and Logistics

H1. Minimum Mandatory Controls

• Mobilization plan and HSQE continuity governance

• Fatigue and travel risk considerations

• Site induction confirmations per location

• Equipment transport integrity checks

• Handover notes and closeout governance

Annex I — Evidence Integrity and Limitations Standard

1. Reports and certificates reflect conditions as observed and recorded at the time and within operational limits of access, lighting, visibility, safety constraints and environmental conditions.

2. No statement is made regarding hidden, internal, obstructed or non-observable conditions unless explicitly within scope and supported by credible evidence.

3. Evidence (photo/video, logs, checklists, sign-offs) is controlled under custody and version discipline.

4. Deliverables are operational outputs and do not constitute class surveys or statutory certification unless explicitly stated and agreed in writing.

5. Limitations affecting evidence completeness are stated clearly and without ambiguity.

HSQE FAQ (Governance and Operational Controls)

1) Does Seachios apply Stop Work Authority (SWA)?

Yes. Stop Work Authority is a universal governance control. Any person involved in Seachios operations may and must stop work when HSQE controls are missing or ineffective, without retaliation.

2) How does Seachios manage confined space risk in cargo holds and similar spaces?

Seachios applies controlled entry governance where confined space conditions exist, including authorization, accountability, communications readiness, and rescue readiness proportionate to exposure, in alignment with vessel/terminal permit-to-work discipline where applicable.

3) How does Seachios govern permit-to-work (PTW) requirements?

Where PTW is required by site rules, vessel rules, or exposure, Seachios requires PTW compliance for critical work such as confined space entry, hot work, work at height, lifting/rigging, and hazardous energy isolation.

4) How does Seachios prevent marine pollution during operations?

Seachios applies pollution prevention planning, spill readiness, residue segregation and containment, controlled transfer and disposal governance where applicable, and a prohibition of uncontrolled discharge.

5) How does Seachios control residues, wash water, and contaminated consumables?

Seachios plans and enforces waste and residue governance appropriate to the scope, including segregation, containment, traceability where applicable, and controlled transfer through approved channels.

6) How does Seachios assure quality in cargo hold cleaning and hold preparation?

Quality is governed through defined acceptance criteria, inspection points, controlled execution methods, and traceable records. Where evidence is part of the deliverable, evidence integrity and controlled issuance are mandatory.

7) How does Seachios manage risk in underwater inspection and underwater services?

Underwater operations are governed through method statements, operational limits, vessel movement restriction controls, exclusion zones, competence verification, equipment readiness, environmental controls proportionate to scope, and evidence mapping with clear limitations statements for inspections.

8) How does Seachios govern hot work and ship repair activities?

Where applicable, Seachios requires PTW discipline, fire watch readiness, hazardous energy isolation governance, exposure controls for fumes and dust, and quality acceptance controls with inspection points and records.

9) How does Seachios manage contractor and supplier HSQE readiness?

Third-party engagement is conditioned to competence, fit-for-use equipment, acceptance of SWA, PTW compliance where applicable, incident reporting discipline, and cooperation with investigations and corrective actions.

10) How does Seachios ensure HSQE decisions remain independent and integrity-driven?

HSQE decisions are treated as governance decisions. Seachios prohibits improper influence, concealment of hazards, unethical shortcuts, and any form of record manipulation or misrepresentation.

HSQE Contact

HSQE Governance and Reporting: hsqe@seachiosbrazil.com
Corporate Contact: contact@seachiosbrazil.com