Attachment 1

PAGE 20

CONSORT BUNKERS PTE LTD

CREW MANAGEMENT HR POLICY AND PROCEDURES MANUALVersion Date: 28 January 2011CONTENT

1. General1.1 Purpose

1.2 Scope and Applicability

1.3 Supplement/Revisions

2. employment

2.1 Vessel Crews Recruitment

2.2 Pre-Employment Medical Checkup

2.3 Working Permit for Non-Singapore Citizen /Permanent Resident

2.4 Determination of Employment

2.5 Probationary Period for New Employee

2.6 Renewal of Contract of Service

2.7 Annual Leave

2.8 Swap

2.9 Medical Leave

2.10 Resignation / Termination of Employment

2.11 Procedure for Voluntary Termination

2.12 Procedure for Involuntary Termination

2.13 Definition of Dismissal

2.14 Definition of Layoff

2.15 Placement Transfer / Reassignment

2.16 Definition of Transfer / Reassignment

2.17 Situations Where Transfer or Reassignment May Occur

2.18 Procedure for Transfer

2.19 Part-Time Additional Employment

2.20 Crews Working Pattern

2.21 Personal Records

3

PROFESSIONAL CONDUCT AND DISCIPLINE3.1

Code of Conduct

3.2

Definitions

3.3

Discipline

3.4

Disciplinary Procedure

3.5

Forms of Disciplines

3.6

Grievances

3.7

Purpose

3.8

Physical Security Practices

3.9

Information Security Practices

3.10

Safeguarding Official Information

3.11

Leaving Report / Checklist

3.12

Lost and Found

3.13

Declaration of Gifts

4

ETHICS POLICY

4.1

Our Commitment

4.2

Ethics Policy Committee

4.3

Roles & Responsibilities of Various Parties

4.4

Code of Ethics1.

GENERAL1.1

Purpose1.1.1This manual contains statement of Ship Crews Management policies and procedures. It is designed to be a working guide for respective Officer/Crew in the daytoday administration of the Ship Crews Matters policies. This manual is to be treated as "Confidential".

1.1.2These written policies should increase understanding, eliminate the need for personal decisions on matters of our Companywide policy, and help to assure uniformity throughout the organisation. It is the responsibility of each and every member of management to administer these policies in a consistent and impartial manner.

1.1.3Procedures and practices in the field of human resource management are subject to modification and further development. Each member of management can assist in keeping our human resource programme uptodate by notifying the Department whenever improvements can be made in the administration of our human resource policies.

1.1.4This Ship Crew Management policy manual is designed to serve as a source of information where staff can look with authority and completeness.

1.2

Scope and Applicability

The policies and procedures contained herein apply to all Officers/Crews onboard the respective ship appointed on the permanent establishment of the Company unless otherwise stated.

1.3

Supplement/Revisions

All Officers/Crews onboard will be governed by the terms and conditions specified herein and any amendments or changes as decided by the Management from time to time. You may refer to the Crew Manager for clarifications. 2.

EMPLOYMENT2.1

Vessel Crews Recruitment

2.1.1 A ferry ticket (one way) from Batam/Bintan or maximum of S$50 whichever lower shall be reimburse to the successful New Officer/Crew employed. A miscellaneous allowance of S$20 for current employed crew of assisting to send IPA (In-Principle Approved WP) as to gain entry for the new crew to Singapore.

2.1.2A flight ticket (one way) from Jakarta or maximum of S$230 whichever lower shall be reimburse to the successful New Officer/Crew employed.

2.1.3A transport allowance on arrival of S$30 or based on receipt issued from Chang International Airport or Tanah Merah Ferry Terminal to the Company s Doctor Clinic and the Management Office shall be reimburse to the successful new crew employed.2.1.4 In provision of work permit application for the new crew employed, the new crew shall be eligible or entitled for maximum S$60 per day and capped at 3 days only (maximum) being for his lodging, meal & etc without producing any receipt to stay in mainland, Singapore prior to board the respective vessel.2.2

PreEmployment Medical Checkup

2.2.1All non-Singapore citizen (excluding permanent resident) Officer/Crew hired on a permanent contract basis shall be required to attend a preemployment medical check-up.2.2.2The pre-employment medical check-up will be under Company expenses as part of employee/crew recruitment program. The medical check up serve to determine whether the employee/crew is fit for service.2.2.3The Offer of Employment shall be voided if the Officers/Crews do not pass the medical examination.

2.3Working Permit for NonSingapore Citizen/Permanent Resident

2.3.1For nonSingapore citizen/permanent resident, the Company will assist the Officer/Crew to obtain a valid working permit from the relevant authority:

a)Preparing a letter to support the working permit application.

b)Completing and endorsing the relevant working permit application form.

2.3.2The relevant authority will process and approve or reject the application. Depending on the nationality, qualifications, skills and experience of the applicant, the processing time may vary from one (1) to eight (8) weeks. The nonSingapore citizen/permanent resident is only allowed to commence work in the Company upon issuance of a valid working permit.

2.3.3The Offer of Employment shall be voided if the working permits for non citizens / permanent residents are not approved by the government authorities.

2.3.4The hiring of any NonSingapore citizen/permanent resident without a valid working permit is illegal.

2.3.5Commencement of Employment for NonSingapore Citizen/Permanent Resident where the Company will inform the Comptroller of Income Tax with regards to the commencement of work of the employee with the Company, which is a statutory requirement, lay down by the Inland Revenue Authority of Singapore.

2.4

Determination of Employment2.4.1

Contract of service

All Officers and Crews are hired by Consort Bunkers Pte Ltd on a contractual basis.

Direct contract staff are engaged directly by Consort Bunkers Pte Ltd and paid salary on a predetermined monthly rate based on Company's prescribed working pattern. They are on the Company's payroll.

2.4.2Length of Contract of Service

Duration of employment is based on mutual agreement between the Company and respective Officer/Crew and renewable upon mutual agreement by both parties.

2.5.

Probationary Period for New Employee

2.5.1All new Officer/Crew are required to serve a minimum Probationary Period of 6 months upon starting work with the Company. This is to allow the Management to determine the fit and performance of the new staff.

2.5.2Officer/Crew will be entitled to full Company's benefits on an earnedasyou-serve basis during the Probationary Period. The following benefits will be prorated according to their length of service fill the point of consumption:

i) Annual leave

ii) Medical/hospitalisation leave

2.6.

Renewal of Contract of Service2.6.1Depending on the contractual agreement, the Company may commence negotiations with the Officer/Crew regarding the renewal of his contract of service before the expiry of the contract of service.

2.7 Annual Leave

2.7.1Vessel Officers/Crews are eligible and entitle to 12 days annual leave, pro-rated for partial year contract. 2.7.2All Officer/Crews entitled annual leave application should be complete and submit to Company with a minimum of 14 days prior to the entitled annual leave date to be taken or before the mid month prior to next month leave applied. 2.7.3Any entitled annual leave application less than the minimum period of application period will be considered as urgent leave. Urgent leave application will be subject to Crews Managements approval, where Crews Executive or Port Captain should provide recommendation and Crews Manager will provide an approval (if permitted) to the urgent leave applied.2.7.4Vessel Master/Chief Officers entitled annual leave application form should only be sign & recommend by the Crews Executive or Port Captain and approved by Companys Manager.2.7.5Vessel Deck Crews entitled annual leave application form should only be sign & recommend by the respective vessels master/chief officer and approved by Crews Executive or Port Captain. 2.7.6Non-entitled annual leave application from the Deck Officers/Crews should submit to Crew Management with minimum of 21 days prior to the non-entitled annual leave date to be taken. 2.7.7A maximum of 2 days of non-entitled annual leave could be approved by the Crew Manager. If Crews need to apply more than 2 days of the non-entitlement annual leave, Crew Manager will need to provide recommendation and Management shall provide an approval (if permitted)

2.7.8

The Vessel Officer/Crews are NOT eligible for gazetted Public Holidays2.8Swap2.8.1Duty Swapping should only be allows between Officers/Crews of same caliber or qualification, in the same vessels. 2.8.2The swap should be mutually agreed between parties where the form should be submitted by the initiator before mid month prior to next month applied or minimum of 21 days prior the date of swapping. 2.8.3Duty swapping application will be subject to Crews Management approval, where Vessel Master (Crews application) or Crews Executive or Port Captain (Deck Officer application) should provide recommendation and Crews Manager will provide an approval (if permitted) to the duty swapping applied.

2.9Medical Leave2.9.1

The Officer/Crew are eligible for 14 days medical leave and 60 days hospitalisation leave, pro-rated for partial year contract. The Officer/Crews who are hospitalised for less than 46 days in any one year, his/her entitlement to paid sick leave for that year cannot exceed the aggregate of 14 days and the number of days on which he was hospitalised. 2.9.2

The Officer/Crew is to notify and to submit medical sick leave to the Company immediately in case of his absence from work due to illness after certification of sick leave by Companys doctor or Singapore Government doctor.2.9.3

Company will not recognize any foreign medical sick leave.2.10

Resignation / Termination of Employment

2.10.1The purpose of this section is to define the various possibilities of termination and to establish a systematic procedure applicable to all categories of Officers/Crews by which Officers/Crews are treated equitably upon termination and in compliance with all legal requirements or customary practice.

2.10.2

Definition of Termination

A termination is defined as either voluntary or involuntary. .

2.10.2.1

Voluntary Termination

This is a resignation initiated by the Officer/Crew. It could be the following:

1) A deliberate resignation requested by the Officer/Crew out of a personal desire to leave the Company, or

2) An induced resignation submitted by the Officer/Crew to avoid a dismissal.

2.10.2.2

Involuntary Termination

This is termination initiated by the Company because of unsatisfactory work performance, behaviour, misconduct, or layoff.

2.10.3

Termination notice period

1) Company shall be at liberty to terminate by giving the Officer/Crew one (1) month notice of termination in writing or by paying one (1) month salary in lieu of notice.2) Company reserves the right to terminate Officer/Crew service within 24 hours notice in the event that the Officer/Crew is found guilty of negligence or misconduct in which case the Company shall be the sole judge. Salaries shall be forfeited when Officer/Crew is terminated under such circumstance.3) Under the above circumstances (1) & (2), Company will no pay the transport and subsistence during repatriation to his own country of domicile.

4) The Officer/Crew can terminate their service (voluntarily) only after giving the Company two (2) months written notice . And apparently , if the Officer/Crew terminates the Agreement prior to the expiry of its Term , the Officer/Crew shall compensate the Company a sum equivalent to two (2) months of his salary .

2.11

Procedure for Voluntary Termination

2.11.1Termination notice as defined above, must be in writing and given to the Officer/Crews immediate supervisor. It will commence from the date the written notice is served. 2.11.2The procedure for resignation on own accord is as follows:

1) The Officer/Crew immediate supervisor should make an exhaustive attempt to find out the causes for the resignation.

2) The supervisor shall submit the letter of resignation to the Crew Manager.

3) The Crew Manager will inform the Management on the resignation.

4) The Crew Manager will send an email to the relevant Departments for their necessary action and a clearance form to the resigned Officer/Crew.

5) Any withdrawal must be recorded in the Officer/Crew's personal file.

6) Crew Manager will endorsed/acknowledge in acceptance of resignation letter.

7) The cessation payment shall be mailed to the resignee 14 days from the last day of service of the Officer/Crew. All obligations to the Company and government shall be deducted from the cessation pay.

8) The Officer/Crew shall return all Company's properties and submit the completed Clearance Form to the Management through Crew Manager, otherwise deduction, shall be mode from the cessation pay.

9) Officer/Crew who has tendered resignation is required to be present onboard till his last day of service (if necessary) to complete the clearance form.

10) Officer/Crew who has tendered resignation is required to fulfil their obligations in terms of compensation according to the employment contracts.2.12

Procedure for Involuntary Termination

2.12.1Supervisory Officer/Crew will recommend termination. The final decision will be made in consultation among the Crew Management and Senior Management.

2.12.2To recommend termination during the Initial Period, final recommendation to Senior Management must be made within 2 months from the date the Officer/Crews are recruited.2.12.3The letter of termination will be issued by the Crew Management.2.13

Definition of Dismissal

2.13.1A dismissal may be exercised for unsatisfactory work performance or behaviour, serious breach of any of the terms and conditions of employment or for gross misconduct like insubordination, theft, violence, moral turpitude, or other serious offences.

2.13.2Where a dismissal is carried out for gross misconduct, the dismissal could be immediate without prior warning depending on the nature of the offence.

2.13.3Officer/Crew dismissed by the Company will be issued a service termination notice by the Crew Management and all his accrued benefits will be forfeited.2.14

Definition of Layoff

2.14.1This refers to termination resulting from a reduction in manpower as a result of business downturn or reorganisation. Where layoff is necessary, the criteria of termination shall be based on skills and performance records. Only when all things are equal will seniority be considered.

2.15

Placement Transfer / Reassignment

2.15.1The main objective of this section is to provide consistency in treatment of transfers throughout the Companys vessel fleet, and to ensure that transfers are mode in the interests of both the Company and the Officer/Crew.

2.16

Definition of Transfer/Reassignment

2.16.1Transfer shall be defined as a lateral move from one job to another job of like value and importance within the same job grade. It could entail changes in job title, duties, supervision, work conditions, but not salary, job grade and seniority. A transfer exercise may come about either from the Officer/Crew's application or Crew Management's own initiative. The prerogative however rests with the Crew Management. A request for transfer from an unconfirmed employee will not be considered.

2.16.2'Loan' shall be defined as temporary transfer.

2.16.3'Reassignment' shall be defined as a change to a serving Officer/Crew's duties in the same line or section as presently assigned but of a different nature than that currently performed due to division of labour but one within the Officer/Crew's present job description. Such reassignment may be carried out without reference to the Senior Management but on authorisation of Crew Management.

2.17

Situations Where Transfer or Reassignment May Occur2.17.1

The situations where transfer or reassignment may occur are as follows:

1) Officers/Crews who are worthy, but who are obviously misassigned or whose jobs have been eliminated in the process of reorganisation will be retained and redeployed.

2) Officers/Crews may be requested to make business trips or to assist other vessel in their work due to exigencies or realignment of work requirements or schedules regardless of the physical location of such movement.

3) Officers/Crews may also be temporarily assigned to perform all or part of the duties of another Officer/Crew either of a lower, equivalent or higher level of appointment due to the absence (approved or otherwise) of such Officer/Crew. The terms of such temporary reassignment including the time period shall be stipulated in writing to the Officer/Crew if so requested. Otherwise, verbal communication by the Crew Management/ Vessel head shall suffice.

3)Officer/Crew may also request for a reassignment to another Vessel or another section within the same Vessel. Where the Officer/Crew satisfies the selection criteria of the receiving section (that is, the section to where the Officer/Crew has requested to be transferred) and whenever allowed by the work requirements and qualification criteria, his request for reassignment shall be obliged.

6)All transfers, loans or reassignments for business trips may be for a fixed duration or for an unspecified period of time, and shall be carried out in accordance with the Crew Management's Employment Procedure currently in force. No Officer/Crew shall have the right to refuse such a request unless an acceptable reason for so doing is given or where he is required to undergo a further or new period of probation or where he would suffer undue hardship as a result.

7)Any Officer/Crew aggrieved by any placement, transfer, reassignment, temporary or otherwise, may appeal to the Crew Management who shall grant the Officer/Crew an interview and make the necessary investigation before arriving at a decision in the best interest of the Company and the Officer/Crew.

8)Once transfer is confirmed, Crew Management will send an email or such information to the relevant parties for their necessary action.

2.18

Procedure for Transfer

2.18.1

The procedure for transfer is as follows:

1) Where Officer/Crew can be redeployed to another vessel, which is more suitable, his transfer must be subject to the mutual approval of the respective Vessel Master/Heads. The transfer may be initiated by the Officer/Crew himself or by the Crew Management.2) The Crew Management & Senior Management views should be sought to evaluate the possible effects of the transfer.

3) Crew Management will inform the receiving vessel of the Officer/crew's interest for transfer. Receiving vessel is to keep such information strictly confidential.

4) Receiving vessel will assess the suitability of the Officer/Crew and inform the Crew Management accordingly within two (2) weeks.

a) If the Officer/Crew were found suitable, the releasing vessel will have to indicate the timeframe he would like the transfer to be effected

b) The receiving Vessel Master should also consent to the transfer.

c) Crew Management will inform the Officer/crew if he is not found suitable.

5) Crew Management will inform the releasing Vessel of the Officer/crew's interest in a transfer and him being found suitable by the receiving Vessel. Approval from the releasing Vessel will be sought to release the Officer/Crew.

a) Crew Management will confirm the effective transfer date with the releasing vessel if it agrees to release the Officer/Crew. The effective transfer date must be within two (2) months.

b) Crew Management will inform the Officer/Crew and receiving Vessel if the releasing Vessel does not approve the release.

6) The receiving Vessel will provide the following information to Crew Management:

a) new job designation;

b) new approving manager; and

c) effective date of transfer.

7) The releasing vessel will have to forward to the Crew Management the performance plan of the Officer/crew with an assessment of his performance.

8) Crew Management will send email to inform all relevant parties of the transfer so that they can make the changes.

2.19

PartTime Additional Employment

Officers/Crews are expected to devote their whole time and attention to the Vessel and not to engage in parttime additional employment without the prior consent of the Management & Company. Those who wish to engage themselves in additional employment on a parttime basis may apply in writing to the Crew Management through the immediate supervisor.

2.20

Crews Working Pattern2.20.1

General

2.20.2This policy defines the official working pattern of the Company applicable to all employees Officers/Crews, except for the shore-based staff.

Working Pattern

i. Consorts barges 14 days onboard & 7 days off-board

ii. Pearls barges 3 months onboard & 1 month off-board

2.20.3All staff will be required to report to Jetty (either Marina South Pier or West Coast pier) by 10.00am on the changing duty day (via phone roll call) to board the chartered launch for change over duty.

2.20.4All staff will be required to observe any change of location schedule that the Crew Management or respective barge Master/Chief Officer may decide upon.2.20.5If duty personnel came after 10.30am on the changing duty day to the desire Jetty to report for duty, subject to Crew Management approval, where the cost for the launch may not bear by Company or he may be consider as AWOL.2.20.6Where any Officer/Crew are required to observe a different schedule due to unique work requirements, he shall be formally informed by the supervisor(s). These staff shall follow the timings & location as directed by the supervisor(s).

2.21

Personal Records

2.21.1

General

The purpose of this section is to establish the procedures for keeping an updated personal record.

2.21.2Crew Management will update the Officer /Crew records where changes occur.

2.21.3Officer/Crew is required to update the Crew Management, via email or written letter, if any of the following changes occur:

1) Changes in Address and/or Contact Number provide Crew Management with New Address/ Telephone Number and Effective Date of Change.

2) Changes in Marital Status submission of relevant document to Crew Management for their personal file and new address (if applicable).

3) Changes to details or person to contact during emergency.

4) Miscellaneous updates on the following:-

a) Professional or educational certifications achieved / attained.

b) Other awards received by staff.

Officer/Crew who are awarded additional certification, diploma or degree during their employment with Consort Bunkers will not automatically be eligible for any form of salary adjustment.

2.21.4

Authority of Access to Personal Files

Access to personal files of Officer/Crew is restricted. As a rule of thumb, only managers and above staff may request to view the personal files of staff who reports to him.

3

PROFESSIONAL CONDUCT AND DISCIPLINE

3.1

Code of Conduct

3.1.1

Purpose

3.1.1.1The purpose of this section is to provide a guideline for code of conduct to be observed by all employees.

3.1.1.2An employee is expected to behave himself at all times and discharge his duties to the Company for what he is paid.

3.1.1.3The Company may, after due inquiry, dismiss without notice an employee on the grounds of misconduct. Any violation of the Code of Conduct will lead to disciplinary action, including dismissal.

3.2Definitions

3.2.1Misconduct

Misconduct can be considered as failing into two general categories, based on the seriousness of the offence: Gross Misconduct and Lesser Offences.

3.2.2Gross misconduct are those offences which are so serious in nature that dismissal is appropriate without regard to the employee's past conduct record. Lesser offences are all instances of misconduct which cannot be considered as falling into the gross misconduct category. There is no hard and fast definition of all cases of gross misconduct or lesser offences as the circumstances in each case vary.

3.2.3The following acts or omissions serve as examples of misconduct for which an employee is liable to be disciplined. The list is not necessary exhaustive.

Gross misconduct

1)Assault on a member of supervision or fellow workers.

2)'Goslow' or instigation of a 'goslow' or work stoppage.

3)Sabotage.

4)Committing a nuisance on the Company's premises.

5)Wilful insubordination or disobedience of any lawful and reasonable order of a superior.

6)Theft within the Company or fraud or dishonesty in connection with the Company's business or property.

7)Demanding, offering or accepting bribes or any illegal gratification.

8)Serious falsifying of official records.

9)Participation in illegal strikes.

10)Engaging in work or trade which is in conflict with the Company's business.

11)Drunkenness: bringing alcoholic drinks into the Company; riotous, disorderly or indecent behaviour, threatening; intimidating, coercing other employees or interfering with the work of other employees: assault either provoked or otherwise.

12)Wilful or 'irresponsible action resulting in damage to any goods or property of the Company.

13)Disclosing to any person information with regards to processes, formulae or secrets of the Company.

14)Breach of Company's Information Security Policy and Procedures.

15)Gambling on the Company's premises.

16)Smoking on the Company's premises except in places where smoking is permitted.

17)Conviction by any Court of Law for any criminal offence.

18)Wilfully not reporting any defect or occurrence which an employee may notice, which might endanger himself or any other person or which might result in damage or danger to the Company's or any person's property.

19)Consumption or peddling of drugs within the factory premises or conviction under the Misuse of Drugs Act, 1973.

20)Distributing or exhibiting within the Company, handbills, pamphlets, posters, or whatever graphical writing without the sanction of the Management and against the interests of the Company.

3.2.4Lesser Offences

1)Absence without permission or adequate reasons i.e. unauthorised absence.

2)Obtaining or attempting to obtain leave of absence by false pretence.

3)Not observing hours of work or not being punctual.

4)Quarrelling with immediate supervisors, senior management or fellow colleagues.

5)Inefficiency i.e. failing to do the amount and quality of work expected of the employee, carelessness, negligence.

6)Refusing to accept job assignments or reasonable instructions in circumstances not constituting gross misconduct.

7)Sleeping while on duty.

3.3

Discipline

3.3.1Purpose

3.3.1.1In deciding disciplinary action to be taken, Management's representatives must understand that the purpose of discipline is aimed to obtain compliance with our established rules of conduct i.e. to correct improper conduct. It should not be punitive in nature with the purpose of punishing or "getting even" with the employee. This philosophy of corrective discipline applies only to the lesser offences which make up the bulk of disciplinary situations. Dismissal is a disciplinary action which is not "corrective" in nature and should be resorted to only where previous efforts to bring about correction have failed or for those major offences.

3.3.1.2There is no fixed pattern of penalties which can be given as representing proper application of corrective discipline for all situations. The progressive disciplinary procedure however includes the following:-

1) Verbal Warning;

2) Written Warning; and/or

3) Termination.

3.4Disciplinary Procedure

3.4.1Discipline must be exercised promptly if it is to be effective. A supervisor's silence over improper conduct is tantamount to condonation, and over a period of time, the incorrect standard becomes a norm which is difficult to overcome.

3.4.2Therefore the procedure is as follows:-

1)When an employee is found to have committed a misconduct in the course of employment, the immediate supervisor shall promptly conduct a thorough investigation for facts without delay. Clearly established facts allow disciplinary decision to be made in clear perspectives.

2)After investigation, the immediate supervisor shall immediately forward his report and recommend disciplinary action deemed necessary to the Corporate Matters Department, if the case is serious enough to warrant the senior management attention. In recommending the disciplinary action, the supervisor has to determine that there is a cause for it and that the disciplinary action is fair, because where disciplinary action is challenged, the burden is upon Senior Management to show cause for the action taken.

Verbal Advice

3)If it is only a minor offence, it is the discretion of the supervisor to serve a verbal advice without the involvement of the Corporate Matters Department. No written record need be given to the employee, but the verbal advice has to be noted in the employee's personal File. As the objective of the verbal advice is to condition and correct the work standard of conduct of the employee, improvement after the advice should be noticed and acknowledged.

Written Warning

4)If a written warning is to be served, the warning letter should be drafted by the Corporate Matters Department, if necessary, before it is issued to the employee. Where issued, such a warning will be issued by the General Manager. The written warning should include:-

a) A statement of the problem

b)Identification of any rule that has been violated

c)Consequences resulting from the infraction

d)Corrective action required of the employee

e)Proposed action by the Company failing corrective action

f)Reference to previous verbal advice or warning(s) and dates

g)Specific expiry dates of between one to six months, depending on misconduct so that if behaviour improves, they cease to apply.

The record however remains with the Company in the employee's personal file.

Termination

5)In the event that after verbal and written warning and there is no improvement, the Department head may decide to recommend dismissal. The approval of the dismissal is subject to the approval of the Senior Management. The employee shall be served the Termination or Dismissal letter by the Corporate Matters Department in the presence of his immediate supervisor. All technicalities in respect of termination or dismissal shall be handled by the Corporate Matters Department. The termination or dismissal letter shall be written and signed by the General Manager.

3.5Forms of Disciplines3.5.1Depending on the severity of the misconduct, the forms of disciplines shall include but not limited to the following:

1) Written/ Verbal warning

2) Suspension with/without pay

3) Dismissal

4) Termination with/without notice

5) Reduction in pay

6) Demotion

3.5.2Serious offences may also render the employee liable to prosecution under the jurisdiction of the courts of Singapore.

3.6

Grievances

3.6.1Purpose

3.6.1.1The purpose of this section is to:-

provide guidelines on the nature of disciplinary action to be taken for instances of misconduct so as to ensure uniform and fair discipline; and

to foster at all times, high morale that makes for selfdiscipline in every employee and group discipline within every work team.

3.6.1.2The Company recognises the value and benefit of mutual discussions. In situations when any employee feels aggrieved or in disagreement with the Companys practice, he is encouraged to discuss such matters with the Senior Management. Employees and/or immediate superiors are encouraged to make an attempt to settle differences or problems at the lowest level possible with reference to the following procedure. All correspondence will be dealt with the strictest confidence.

3.6.2Procedure for Grievances

3.6.2.1The procedure for grievances is as follows:

1)An employee with a grievance should raise the issue with his immediate supervisor, who will investigate and provide a solution or explanation to the employee within three working days after the grievance has been brought up.

2)If the immediate supervisor is the problem, then the employee should raise the issue in writing in confidence to the Corporate Matters Manager.

3)The Corporate Matters Manager shall investigate and provide a solution or explanation to the employee within three (3) working days after the grievance has been brought to his attention.

4)As a final resort, the employee shall have the opportunity to raise the grievance with Senior Management, who shall within a work week make all the necessary investigations and provide a decision. The decision of the Senior Management shall be final.

3.6.2.2Speedy handling of complaints and suggestions is vital to effective twoway communication. When a complaint or suggestion is presented, quick attention and action in getting the right answer, followed by prompt communication with the employee, will greatly enhance the success of the system and enhances good employee relations. All grievances must be properly documented.

3.6.2.3If for valid reasons, an employee feels that his grievance is too personal for discussion with his immediate superior, he may seek recourse through Corporate Matters Department. Alternatively, if the employee has a personal problem with his immediate superior, he could seek recourse to the Corporate Matters Department but it shall be done with the knowledge of his immediate superior.

3.7

Security Responsibilities

3.7.1Purpose

3.7.1.1The purpose of this section is to highlight the security responsibilities to be observed by all employees in the Company.

3.7.1.2The security roles and responsibilities of employees are governed by the Corporate Information Security Policy.

3.8Physical Security Practices

3.8.1Visitors / Guests

1)Employees, authorized visitors and guests are the only personnel allowed to enter Company's premises.

2)Employees who have visitors will have to meet their visitors at the Reception Counter and bring them to the meeting place and at the end of the meeting, escort them out to the Reception Counter. Under no circumstances are visitors allowed to wander about the office unescorted.

3.9Information Security Practices3.9.1The purpose sought to include and foster these is to ensure that official information is protected.

3.9.2Employees are not allowed to take any company documents home without prior approval from the immediate supervisor and upon such approval must return to the Company all materials, data and documents provided to them in the course of their work upon termination of service or upon request by the Company.

3.9.3The employee will use the information that he obtain by virtue of his employment in the Company, exclusively in performing his work. The employee will not disclose, in whole or in part, the information to any person without the prior written approval of the Company.

3.10Safeguarding Official Information

3.10.1All employees will be required to sign an undertaking to safeguard official information.

3.10.2All contract/temporary staff on project assignment with the Company will also have to undertake to safeguard official information to ensure that they do not release the Company's confidential information to the public.

3.10.3This condition shall apply both during and after the employment / engagement of the permanent/contract/temporary staff with the Company. Any breach or neglect of this undertaking is an offence, and may also render them liable to prosecution under the jurisdiction of the Courts of Singapore.

3.10.4Employees are to exercise discretion when surfing the Internet. The purpose is to prevent virus, spyware and malicious software from inadvertently breaching the Companys internal networks.

3.11Leaving Report / Checklist

3.11.1An employees who has terminated his services with the Company will be sent a Clearance Form and Exit Interview Form by the Corporate Matters Department.

3.11.2Corporate Matters Department will also inform the various Departments on the resignation of the staff for their appropriate action.

3.12

Lost and Found

If you find something that does not belong to you, please turn it in to the Administration Department. Alternatively, if you lose something, please also check with the Administration Department.

3.13

Declaration of Gifts

3.13.1All gifts received by an employee, which could be from a client, supplier, course provider, vendor or other business associate, are to be declared to the Corporate Matters Department if above the value of $100.

3.13.2As a general guideline, gifts that could be utilised in the office would be channelled back for office use. 4Ethics Policy

4.1Our Commitment

4.1.1In Consort Bunkers, we believe in uncompromising ethical standards in all our dealings with our customers, suppliers, governments, shareholders, public and with each other as the integrity of the Company rests on the integrity of our employees. It is our motto to conduct business lawfully and ethically in all countries, and each of us to practise diligent observance of the laws and regulations prevailing in each of these countries besides that of Singapore's.

4..1.2This Ethics Policy supplements but does not replace the Company's policies and procedures, and shall form a code of conduct we expect of all employees to upkeep our commitment towards ethical conduct. Adherence to the Ethics Policy is the responsibility of each employee and is a condition for continued employment, and shall be the subject of management attention, periodic internal audits and reviews.

4.2

Ethics Policy Committee

4.2.1An Ethics Policy Committee, comprising of the senior management team, shall be available for consultation on ethics issues or to answer any questions you may have about this Ethics Policy. In any instance where any employee requires guidance as to how to follow the Ethics Policy, he should seek advice from his supervisor, or any member of the Ethics Policy Committee. This does not relinquish the responsibilities that each employee has to comply with the Ethics Policy. Anyone violating this Ethics Policy, whether occurring through individual misconduct or a failure to exercise adequate supervision by a supervisor/manager, shall be subject to appropriate disciplinary action as recommended by the Ethics Policy Committee.

4.3

Roles & Responsibilities of Various Parties

4.3.1

Company

The Company will provide guidelines on matters of everyday business conduct. It will also ensure through established communication and training programs that all employees are aware of and understand the Ethics Policy. The Company will also enforce the compliance with the Ethics Policy, and guarantee that there will be no retribution for reporting an alleged violation of the Ethics Policy or the Company's policies and procedures.

4.3.2

Managers/Supervisors

We will ensure that all staff under our supervision, directly or indirectly, are given a copy of the Ethics Policy, share the Company's commitment to uphold the Ethics Policy, and understand their roles and responsibilities. As supervisors or managers, we will also conduct ourselves in accordance to the Ethics Policy, and demonstrate through our actions and words, our commitment to the standards. We will also maintain a workplace environment and culture that encourages frank and open communication, free of fear or anxiety of reprisal, concerning the upholding of the Ethics Policy. We will also report any knowledge of violation or possible violation directly to the Ethics Policy Committee for appropriate action, and treat each with the utmost confidentiality possible under the circumstances.

4.3.3

All Employees

We will review and refresh our knowledge and understanding of the Ethics Policy, and uphold the Ethics Policy and make it an active port of our everyday business life. We will practise due diligence and be sensitive to situations that could result in actions by any colleague that are illegal, unethical, violates the Ethics Policy or improper. We will also encourage our fellow colleagues to uphold the Ethics Policy, and report actual or perceived violation of the Ethics Policy or the Company's policies and procedures for appropriate action.

4.4

Code of Ethics

The following sets forth the general ethical standards that shall be met by all employees. However, the standards are not necessarily all of the obligations that apply to our conduct. In general, we must take care to avoid any conduct that could reasonably appear improper or might injure the Company's reputation for integrity in its activities. We will act in good faith, in the interest of the Company, without violation of the laws, Company's Ethics Policy and/or policies and procedures.

4.4.1

Conflict of Interest

No employee may have a personal, business or financial interest that is incompatible with the loyalty and responsibility owed to the Company. He will be required to disclose to the Company if he or any of his family members has or acquires, by gift, inheritance or otherwise, an interest in a supplier, customer, competitor or its business, or is performing services for such a firm as such relationship could have an appearance of potentially biasing his judgement or activities relating to our Company. He will declare on an annual basis, such interest. He will however not wait for the annual exercise to declare such interest, and undertakes to declare such interest as and when a potential conflict of interest is perceived.

4.4.2

Gratification

An employee or any member of his family shall not accept compensation, loan (other than personal loans from a recognised lending institution made in the ordinary course of business on usual and customary terms), or anything else of personal financial advantage from outside parties in connection with any transaction in which the Company might have an interest.

In occasions whereby it is not possible to turn down a gift regardless of value, such as a hamper delivered to the home/office of the employee, the employee shall declare and handover the gift to the Corporate Matters Manager, As such, employees are encouraged to inform vendors, customers or business partners, the Company's policy and decline any such known intention.

4.4.3

Discrimination

There will be no discrimination against an employee on the grounds of race, colour, religion, sex, age, disability or any other factor not pertinent to performance. This applies to all phases of employment including recruitment, promotion, transfer or compensation.

4.4.4

Proprietary information

The Company's trade secrets and proprietary data are parts of the Company's invaluable intellectual property. Protection of their confidentiality is vital. No employee shall use this information for personal benefit or for the benefit of anyone else. No employee shall also disclose such information without the authorisation of the General Manager, Consort Bunkers. All employees are therefore required to take reasonable precautions to protect such information from inadvertent disclosure. In the course of work, employees may also receive of have access to trade secrets or proprietary data of a government agency or other companies. The employees shall handle them in accordance with any agreements concerning their use or disclosure, and with the same care and under the same restrictions as if they were trade secrets or proprietary data owned by the Company. The employees will not disclose to other companies or use for the benefit of the Company the trade secrets and proprietary data of their former employers.

4.4.5

Gifts to Others

No gift (regardless of value) shall be given to an employee of a customer, vendor or other entity with the intent to influence corruptly that employee's conduct. While we cannot accept ourselves to be bribed or influenced corruptly, we will not conduct ourselves in any similar manner onto others, No employee shall also promise, offer or make any payments in money, products, or services, either directly or indirectly, to any government employee for in order to induce favourable business treatment or to affect governmental decisions.

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Crew Management- HR Policy & Procedures ManualPage 1

FOR INTERNAL CIRCULATION ONLY - NOT TO BE PUBLISHED OR DISTRIBUTED OUT OF CONSORT BUNKERS PTE LTDCrew Management - HR Policy & Procedures ManualPage 20

FOR INTERNAL CIRCULATION ONLY - NOT TO BE PUBLISHED OR DISTRIBUTED OUT OF CONSORT BUNKERS PTE LTD