Welfare Policy

Welfate Policy

Harassment, Bullying, Sexual Harassment and Sexual Assault
MYBULK SHIPMANAGEMENT INC. commits to providing and ensuring a workplace
respectful to the dignity, personality and well-being of all employees, free from offensive,
hostile and intimidating behaviors that may affect job performance, safety or mental and
physical well-being, encouraging the elimination of harassment, bullying, sexual assault and
sexual harassment.
Harassment means:

  • 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
  • Malicious rumors, insults or intrusive questioning (about age, race, ethnic origin, marital
    status, sex, disability, sexual orientation, culture, religion, belief or personal life)
  • Making or sending unwanted, sexually suggestive, hostile or personally intrusive
    comments, phone calls, text messages, emails, comments on social networks or letters.
    Bullying means:
  •  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.
    Sexual assault means sexual contact or behavior that occurs without explicit consent of the
    victim and may include:
  •  Rape or attempted rape
  •  Sexual contact occurring without the other person’s consent
  •  Threats
  •  Nonconsensual touching of one person for the sexual gratification of another.
    Sexual harassment means unwelcome sexual advances, requests for sexual favors, and
    other verbal or physical conduct of a sexual nature when:
  •  Submission to such conduct is made either explicitly or implicitly a term or condition of an
    individual’s employment; or
  •  Submission to or rejection of such conduct by an individual is used as a basis for
    employment decisions affecting such individual; or
  •  Such conduct has the purpose or effect of unreasonably interfering with an individual’s
    work performance or creating an intimidating, hostile, or offensive working environment.
    Consent means a voluntary, informed, enthusiastic, specific and ongoing expression of a
    person’s willingness to engage in an action.
    No such behavior is allowed within MYBULK SHIPMANAGEMENT INC. premises or
    managed vessels. MYBULK SHIPMANAGEMENT INC. strictly prohibits its employees, crew
    members, agents and contractors, as well as any other person entering its premises or
    managed vessels to engage in such behaviors.
    Diversity, Equity & Inclusion
    We are committed to promoting a welcoming and diverse workplace, both onboard and on
    our premises and to treat all personnel fairly, with care, respect and dignity, without

SAFETY MANAGEMENT SYSTEM

MANUAL Issue No.:
Issue Date:
Rev. No.:
Rev. Date:
Page:
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15/07/2025
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00/00/0000
2 of 3

Chapter 2

COMPANY’S POLICIES AND
MANAGEMENT
COMMITMENT
APPENDIX XII

discrimination based on any protected characteristic (like age, civil status, race, culture,
descent, disability, gender, language, maternity/paternity, national or ethnic origin, political
opinion, pregnancy, race, religion, sexual orientation, etc.). We are also committed to:

  •  Encourage Diversity, Equity & Inclusion through relevant action plans.
  •  Promote an inclusive working culture by facilitating teamwork, transparency, trust, respect
    and fair treatment among all shore and seagoing personnel.
  •  Provide equal opportunities to candidates and employees and oppose and avoid all forms
    of unlawful discrimination in all its activities, including:
    o Pay and benefits
    o Terms and conditions of employment
    o Dealing with grievances and discipline
    o Dismissal or redundancy
    o Parental leave
    o Requests for flexible working hours
    o Selection for employment, promotion, training or other development opportunities.
  •  Monitor our personnel’s demographics (such as age, sex, ethnic background, sexual
    orientation, religion or belief and disability) to track progress and ensure accountability
    and improvement.
  •  Review employment practices and procedures, when necessary, to ensure fairness, and
    also update them and this policy to take account of changes in the law.
  •  Not draw any inferences regarding the conduct or performance of an employee (including
    the use of drugs and alcohol by this employee) based on the employee’s protected
    characteristics.
  •  Communicate guidelines and “Dos and Don’ts” aiming to facilitate optimal social
    personnel relations based on fairness, equality, diversity, respect and dignity.
  • Encourage feedback from employees on Diversity, Equity and Inclusion initiatives and
    regularly evaluate the effectiveness of our relevant actions to constantly upgrade them.
  • Enhance specific protection for women, when and where employed.

Zero Tolerance
MYBULK SHIPMANAGEMENT INC. encourages all employees, crew members, agents,
contractors and any other person entering its premises or managed vessels to bring to its
attention immediately any incident of the above, including those affecting others, that may
take place within the Company’s premises or managed vessels or that may involve the
Company’s employees or crew members, through our Open Reporting Policy. Complaints
can be made without fear of retaliation if they are not vexatious or malicious. We treat all
such incidents seriously and in strict confidence and we are committed to:

  •  Monitor any case and give special attention to risky situations and place 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,
    sexual harassment, sexual assault, violence or retaliation.
    Contact Senior Officers onboard and/or the Crew Manager / DPA / HR Manager ashore as
    the first point of reference if you want to make a complaint or report an incident.
    All personnel and contractors are required to comply with this policy.

Date: 15
th July,2025