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Bernhard Schulte
Shipmanagement


Bernhard Schulte Shipmanagement
QHSE Manual - Title Page
Document No. 5870

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QHSE Manual

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Bernhard Schulte Shipmanagement
Table of Contents
Document No. 5871

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TABLE OF CONTENTS

SECTION 1 SCOPE AND FIELD OF APPLICATION
1.01 Definitions
SECTION 2
2.01
2.02
2.03
2.04
2.05
2.06

COMPANY POLICIES
Mission and Vision Statement
Business Policy (Financial / Ethics)
Shipboard & Shore-side Occupational Health, Safety and Environmental Policy
Quality Policy
Shipboard Drug & Alcohol Policy
Speaking Up Policy

SECTION 3
3.01
3.02
3.03

QHSE MANAGEMENT SYSTEM
QHSE System Processes

Interaction and Application of the Processes
Management System Documentation
3.03.01
Control of Documents
3.03.02
Control of Records

SECTION 4
4.01
4.02
4.03
4.04

PLANNING
Business Plan
Quality, Health, Safety and Environmental Objectives and Targets
Management Commitment
Environmental Aspects
4.04.01
Resource Conservation
4.04.02
Pollution by liquid substances
4.04.03
Sewage
4.04.04
Carriage of dangerous goods in bulk or packaged form
4.04.05
Garbage
4.04.06
Ballast water (including transfer of micro-organisms)

4.04.07
Emissions to atmosphere
4.04.07.01
Cargo Vapours
4.04.07.02
Engine Exhaust Emissions
4.04.07.03
Halons & CFCs
4.04.07.04
Noise Pollution
4.04.08
Anti-fouling paint
Hazard Identification, Risk Assessment and Risk Control
4.05.01
Management of Change
Legal and Other Requirements
Customer Focus and Customer related process
4.07.01
General
4.07.02
Determination and review of the Requirements Related to Management of
Ships
4.07.03
Customer’s Records
4.07.04
Customer Communication

4.05
4.06
4.07

Bernhard Schulte Shipmanagement
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SECTION 5 RESPONSIBILITY, AUTHORITY AND COMMUNICATION
5.01 Designated Person(s) Ashore/Quality Management Representative/ Environmental
Management Representative(s)/OH&S Management Representative
5.02 Master’s Responsibility and Authority
5.03 Organizational Control
5.04 BSM Group – Shore Organization Chart
SECTION 6 RESOUCES, PERSONNEL, MAINTENANCE AND EMERGENCY

MANGEMENT
6.01 Resource Management
6.01.01
Infrastructure
6.01.02
Personnel
6.01.02.01
Shore based staff
6.01.02.01.01 Selection, recruitment and promotion
6.01.02.02
Ship’s Staff
6.01.02.02.01 Selection, recruitment & promotion
6.01.02.02.02 Ship Masters
6.01.02.02.03 Crew Welfare
6.02 Competence, Training and Awareness
6.02.01
General
6.02.02
Shore Seminars
6.02.03
Management System Awareness Training
6.02.03.01
Appraisals and Continual Professional Development
6.02.03.01.01 Ship Staff
6.02.03.01.02 Shore staff
6.02.04
Safety and Familiarization Training
6.03 Communication
6.04 Operational Control
6.04.01

Operational Control
6.05 Purchasing
6.05.01
Evaluation of Suppliers
6.05.02
Purchasing Information
6.05.03
Verification of Purchased Materials or Service
6.06 Customer’s Property
6.07 Preservation of Product (Service)
6.08 Identification and Traceability
6.09 Maintenance of the Ship and Equipment
6.09.01
Planned Maintenance Systems
6.09.02
Critical Equipment & Technical Systems
6.09.03
Drydocking and afloat repairs
6.10 Emergency Preparedness and Response
6.10.01
General
6.10.02
Contingency Plans
6.10.03
Drills and Exercises
6.11 Control of Monitoring and Measuring Devices (MMDs)
6.11.01
Control of Monitoring and Measuring for Shipmanagement Services

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SECTION 7 MONITORING AND MEASUREMENT
7.01 Monitoring and Measurement
7.01.01
Customer Satisfaction
7.01.02
Monitoring and Measurement of Service Characteristics
7.01.03
Monitoring and Measurement of Process
7.01.04

Inspection and Test Records
7.02 Nonconformity, Corrective Action and Preventive Action
7.02.01
Non-conformance / Control of Non-conforming Product /Service
7.02.02
Accident and Incident Reporting & Investigation (Root Cause Analysis)
7.02.02.01
Reporting of Incidents & Accidents
7.02.02.02
Investigating Incidents & Accidents
7.02.02.03
Training of Investigators
7.02.02.04
Sharing lessons learned
7.03 Analysis of Measurements and Improvement
7.03.01
Analysis of Audit Reports
7.03.02
Analysis of Vessel Inspection Results
7.04 Internal Audit
SECTION 8
8.01
8.02
8.03
8.04
8.05
8.06
8.07

MANAGEMENT REVIEW

General
Monthly Review Meetings
Quarterly Review Meetings
Yearly Review Meetings
Input to Meetings
Outputs and Actions
Distribution of Minutes

APPENDICES
Manual References to the codes (ISM) / standards (ISO 9001-2008, ISO 14001-2004 and
OHSAS 18001-2007) / TMSA


Bernhard Schulte Shipmanagement
Section 1 - Scope and Field of Application / Definitions
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Scope and Field of Application

“Bernhard Schulte Shipmanagement” a member of Bernhard Schulte Group consists of a Team of
highly skilled and experienced managers, technicians, engineers and ship’s officers as well as
specialists in the fields of Safety Management systems, Commercial Management, Ship Finance,
Personnel Management and Insurance.
This QHSE Manual covers all the activities of all our Offices involved in Shipmanagement, as well as
the operations onboard such managed vessels, excluding those vessels under crew management
contracts. The Management systems of the Company are based on the requirements of:
•
•
−
−
−
−

Mandatory Regulations (National, International, Flag State & Port State)
Applicable Codes, Guidelines, Industry Standards to which the Company subscribes
such as:
The ISM Code
ISO9001:2008a
ISO14001:2004
OHSAS: 18001b

With the following exception, all other requirements of the above standards have been addressed in
the system:1
Notes:
a. Exclusions:
i)

ISO9001:2008, Clause 7.3 Design and Development

Bernhard Schulte Shipmanagement does not currently perform true design activities as it is service
oriented as such, considers that the Design and Development clauses of ISO 9001:2008 do not
apply.
ii) ISO 9001:2008, Clause 7.5.2 validation of processes for production & service provision.
There are no special processes where the resulting output cannot be verified by subsequent
monitoring and thus considers this clause not applicable.
b. OHSAS 18001 – Compliance to this code is part and is under active consideration for future full
implementation and certification.

1

ISO 9001:2008 4.2.2.a


Bernhard Schulte Shipmanagement
Section 1 - Scope and Field of Application / Definitions
Document No. 5872

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Definitions

The definitions listed below taken, or adapted from the ISM Code, ISO 9001:2008, ISO 14001:2004
and OHSAS 18001:2007 are used in the system Manuals of the Company.
Accident – An incident with unexpected or undesirable consequences. The consequences may be
related to personnel injury or fatality, property loss, environmental impact, business loss, etc., or a
combination of these.
Administration – means the Government of the State whose flag the ship is entitled to fly.
Company – For the purposes of this Manual the Company is the Bernhard Schulte Shipmanagement
(Service Delivery Centre) who has assumed the responsibility for operation of the ship from the ship
owner and who, on assuming such responsibility, has agreed to take over all duties and
responsibilities imposed by the ISM Code. {Company = Organization (ISO 9001:2008)}.
Continual improvement – recurring process of enhancing the management system in order to
achieve improvements in overall performance consistent with the Company’s stated policies for safety,
quality and pollution prevention, as applicable.

Corrective Action – action to eliminate the cause of detected nonconformity
CSC – Crew Service Centre - refers to Bernhard Schulte Group Company which provides Ship
manning Services.
Customer – organization or person that receives a product or service.
Customer satisfaction – perception of the degree to which the Customer’s requirements have been
fulfilled.
DOC – Document of Compliance certificate issued to the Shore Office towards compliance with the
relevant provisions of the ISM Code.
Environment – surroundings in which the Company and its ships operate, including air, water, land,
natural resources, flora, fauna, humans, and their interrelation.
Environmental aspect – element of a Company’s or organization’s activities or products or services
that can interact with the environment.
Environmental impact – any change to the environment, whether adverse or beneficial, wholly or
partially resulting from the Company’s environmental aspects.
Environmental objective – overall environmental goal, consistent with the environmental policy, that
the Company sets itself to achieve, and which is quantifiable where practicable.
Environmental management system – part of the Company’s management system used to develop
and implement its environmental policy and manage its environmental aspects


Bernhard Schulte Shipmanagement
Section 1 - Scope and Field of Application / Definitions
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Environmental performance – measurable results of the Company’s management of its
environmental aspects.
Environmental Target – detailed performance requirement, quantified where practicable, applicable
to the Company or its ships, that arises from the environmental objectives and that needs to be set and
met in order to achieve those objectives.
GMD – Group Managing Directors for specific type of ships.
Hazard – source or situation with a potential for harm, in term of injury or ill-health, damage to
property, damage to workplace environment or a combination of these.
Hazardous Occurrence: An incident with no consequences, but could have reasonably resulted in
consequences under different conditions. (Hazardous Occurrences are sometimes referred to as Near
Misses.)
Incident - An unplanned sequence of events and/or conditions that results, or could have reasonably
resulted, in a loss event.
Infrastructure – system of facilities, equipment and services needed for the operation of the
Company.
Internal audit – systematic, independent and documented process for obtaining audit evidence and
evaluating it objectively to determine the extent to which the management system audit criteria set by
the Company are fulfilled
Interested Parties – person or group concerned with or affected by the performance of the Company.

International Safety Management (ISM) Code – means the International Management Code for the
Safe Operation of Ships and for Pollution Prevention.
Major non-conformity – means the identifiable deviation that poses a serious threat to the safety of
personnel or the ship or a serious risk to the environment that requires immediate corrective action and
includes the lack of effective and systematic implementation of the requirement of the Code.
Near Miss: (Same as Hazardous Occurrence)
Non-conformity – means an observed situation where objective evidence indicates the non-fulfillment
of a specified requirement.
Objective evidence – means quantitative or qualitative information, records or statements of fact
pertaining to safety or to the existence and implementation of a safety management system element,
which is based on observation, measurement or testing that can be verified.


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Section 1 - Scope and Field of Application / Definitions
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Observation – means a statement of fact made during a management audit and substantiated by
objective evidence.
Occupational health and safety (OH & S) – conditions and factors that affect the well-being of
employees, temporary workers, contractor personnel, visitors and any other person in the workplace.
Policy – overall intentions and direction of an organization related to its performance as formally
expressed by the top management.
Preventive action – action to eliminate the cause of a potential non-conformity.
Prevention of pollution – use of processes, practices, techniques, materials, products, services or
energy to avoid, reduce or control (separately or in combination) the creation, emission or discharge of
any type of pollutant or waste in order to reduce adverse environmental impacts.
Procedure – specified way to carry out an activity or process.
Quality – Degree to which a set of inherent characteristics fulfils the requirements.
Unless specifically stated otherwise within the application in this manual, includes the requirements for
all matters concerning health, safety and protection of the environment.
Quality Objective – Something sought, or aimed for, relating to quality.
Record – document stating results achieved or providing evidence of activities performed.
Requirement – a need or expectation generally stated, generally implied or obligatory.
Risk - It is the chance of something going wrong. It consists of two elements:
A) The likelihood that a hazard may occur.
B) The consequence (Including severity) of the hazardous event.
Risk assessment – overall process of estimating the magnitude of risk and deciding whether or not
the risk is tolerable.
Safety aspect – element of a Company’s or organization’s activities or services that represents an
actual or potential risk to safety or personnel, or the ship.
SDC – Service Delivery Centre - Refers to a Bernhard Schulte Group Company which is directly
involved in the provision of Shipmanagement services.

Severity – In the context of Risk Assessment, this means the possible degree of harm associated
with the hazard.


Bernhard Schulte Shipmanagement
Section 1 - Scope and Field of Application / Definitions
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SMC – Safety Management Certificate - A document issued to a ship which signifies that the
Company and its shipboard management operate in accordance with the approved safety
management system.
Supplier – organization or person that supplies a product or service.
System – set of interrelated or interacting elements required to direct and control a Company.

Top management – person(s) who directs or controls the Company.
Work environment – set of conditions under which the work is performed.


Bernhard Schulte Shipmanagement
Section 2 Company Policies
Document No. 5815

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Company Policies

The top management of the Company has adopted a Policy of operating its “Ship Management

Service” business under the provision of a comprehensive Quality, Health, Safety and Environmental
Management System, implemented and operated to the requirements of ISO 9001:2008,
ISO14001:2004, OHSAS 18001:2007* and the ISM Code. It is company policy to continuously operate
to these requirements, as would apply to it and where required (both as mandatory and value addition)
have the systems certified by Accredited Certification bodies.
The Top Management has ensured that it’s Policies:
•
•
•
•
•

are appropriate to the purpose, nature and scale of its business.
covers all activities undertaken by the Company.
includes commitments to comply with applicable requirements
has provisions to continually improve the effectiveness of its Management Systems.
provides for a framework for setting and reviewing its objectives.

The management ensures that all its policies are communicated, understood, implemented and
maintained at all levels of the shore-based and shipboard organization, and to all persons working for
or on behalf of the Company1, and that they are reviewed at Management Review meetings for their
continued suitability.2
Each of the company’s policies is implemented in practice through the application of formal procedures
and instructions3 and reviewed through processes described therein.
The policies are duly signed by top management.

* Compliance to this code is part and is under active consideration for future full implementation and
certification.
1

ISO 9001:2008 sec 4.2.1a/5.2 : ISO 14001:2004 sec 4.1, OHSAS 18001:2007 sect 4.1
TMSA 1A 1.1
3
ISO 9001:2008 5.3a/b/c
4
ISM Code Sect 2.2
5
ISO9001:2008 5.3d/e, ISM 2.2
6
TMSA 1 A 1.2
2


Bernhard Schulte Shipmanagement
Section 2.1 Mission & Vision Statement
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Mission and Vision Statement1

Vision
To be the leader in quality Shipmanagement.

Mission
To assist responsible and demanding customers achieve their business objectives through our
professionalism, dedication, enthusiasm and responsiveness.

Our Goals
Safety:

our first priority is the safe operation of the vessels we manage, with no
injuries, loss of life, and damage to property or the environment.

Human resources:

to be the employer of choice for competent seafarers and office staff.

Customer satisfaction:

to meet and exceed the expectations of our customers.

Service coverage:

to provide excellent value added services globally for all our customers’
needs.

Financial:

to continuously improve our results in a sustainable manner.

Our Values
We value:

our people, by respecting the individual, treating them fairly and providing opportunities for continuous
learning and development.
our business partners and adhere to the highest ethical standards.
our independence as a family owned company with long term focus and commitment to third party
shipmanagement.
the good reputation of Bernhard Schulte.
an entrepreneurial approach coupled with rigorous risk management.
service orientation and reliability through focusing on excellent service to our customers.

1

TMSA 1.1 a


Bernhard Schulte Shipmanagement
Section 2.1 Mission & Vision Statement
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Our Principles
We:

•
•
•
•
•
•
•
•
•
•

systematically manage risks.
continuously define, monitor and improve performance.
reward results.
are cost conscious.
meet our commitments.
encourage initiative and innovation.
promote team work and streamlined business processes.
take pride in cultural diversity and benefit from our global structure.
provide a modern and stable working environment so that all employees can contribute to the
best of their abilities.
are socially responsible.


Bernhard Schulte Shipmanagement
Section 2.2 Business Policy (Financial & Ethics)
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2.02 Business Policy (Financial / Ethics)
The Company recognises and acknowledges that the purpose of a contract for full and/or crew
management of a ship, is to provide a beneficial and profitable relationship for the Company and the
Client.
The Company shall not tender for, or secure any contract, if the resources of the Company are known,
or expected to be insufficient to comply with the requirements of the contract, or to meet existing and
expected regulatory requirements.
The Company shall not knowingly participate in any illegal activities of the client, his agents and/or his
representatives. Neither shall the Company enter into agreements or contracts that would involve the
Company, its agents and/or representatives, in unsafe acts or practices.
The Company shall allocate its resources to provide “satisfaction of service” to each client.
The Company shall advise the client of any possible conflict of mutual or third party interest that may
arise as a result of the terms and conditions expressed within the proposed or enacted contract.
The Company shall always respect and protect the confidentiality of each client’s business, subject to
legal, recognised, and accepted standards of industry. In doing so, the person appointed by the
management, as documented in the procedures, will detail and promulgate the individual client
requirements to responsible staff.
The Company will always adhere to sound and proper accounting principles in the management of
cash or funds made available by the client as a result of, or in addition to, the terms and conditions of
the contract.


Bernhard Schulte Shipmanagement
Section 2.3 Shipboard & Shoreside Occupational Health
, Safety & Environmental Policy
Document No. 5818

2.03

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Shipboard & Shore-side Occupational Health, Safety and Environmental Policy1

The Company recognises that occupational health, safety and environmental (OHSE) management is
essential in order to achieve the Company’s operating objectives. We are committed to prevention of
injury and ill health and continual improvement in OHSE performance.2
Our Occupational Health, Safety and Environmental Policy provides the framework for setting and
reviewing OHSE objectives and targets.3 It is based on the requirements of:
• The ISM Code
• ISO14001:2004
• OHSAS18001:2007

Our objectives are:
• To achieve zero spills, zero accidents and zero incidents4
• To establish safeguards against all identified risks5
• To continuously improve safety management skills of personnel ashore and aboard
ships, including preparing for emergencies related both to safety and environmental
protection.6
• To develop a sense of personal responsibility in all personnel towards health, safety
and environmental protection.
Implementation:7

The prime responsibility for implementing this Policy lies with line management (supervisory positions).
To achieve this, the commitment and involvement of all Company personnel is required. Onboard ship,
Senior Officers and visiting shore management must lead by example and comply with all safety
practices and procedures including at all times wearing the correct PPE.8
The Company will comply with all relevant national and international OHSE legislation, and
regulations, and take into account all industry guides and codes of practice9.
When considering new business or work methods, full account will be taken of all relevant health,
safety and environmental aspects to ensure that the standards required by this Policy are maintained.
All work will be properly supervised with safety and environment protection forming an integral part of
all planning and procedures. Necessary information, instruction and training will be given as necessary
to ensure the health and safety at work of all employees.
The Company is committed to improving health and safety performance and will respond positively to
recommendations, from both shore and sea staff, that identifies changes in policy, practices or
equipment necessary to improve standards.
All incidents of a serious or potentially serious nature will be investigated and recommendations
communicated through line management where appropriate.
1

ISM Code sect 1.2, 2.1, 1.4 ISO9001:2008 sect 5.1, 5.3, 8.5.1; ISO14001:2004 sect 4.1, OHSAS 18001:2007 sect 4.2
OHSAS 1800:2007 1 4.2.b, ISO14001:2004 4.2.b

3
ISO14001:2004 4.2.d
4
ISM Code 1.2.1, 1.2.2.1
5
ISM Code 1.2.2.2
6
ISM Code 1.2.2.3,
7
ISM Code 2.1
8
TMSA 9A 3.2
9
ISM Code 1.2.3, OHSAS 18001:2007 4.2.c, ISO14001:2004 4.2.c
2


Bernhard Schulte Shipmanagement
Section 2.3 Shipboard & Shoreside Occupational Health
, Safety & Environmental Policy
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Management will strive to ensure that purchase and supply activities are continuously improved with
respect to environmental protection. This includes waste reduction methods such as: 10
•
•
•

Bulk purchasing to reduce packaging
Recycling initiatives
Using non-disposable equipment

Management will use its best endeavours to ensure that contractors working on their behalf apply
standards compatible with this Policy.
This Policy will be communicated to all employees and contractors11, in order to ensure they are aware
of their OHSE obligations12; it will also be made available to the public13. It will be reviewed on a
regular basis to be updated or revalidated as appropriate.14

(signature)R. Bajpaee
Chief Operating Officer
Bernhard Schulte Shipmanagement
Date:

10

TMSA 10A 2.3
TMSA 10 1.1 ISO14001:2004 4.2.f ISM Code 2.2
12
OHSAS18001:2007 4.2.e
13
OHSAS 18001:2007 4.2.f, ISO14001:4.2.g
14
OHSAS 18001:2007 4.2.g
11


Bernhard Schulte Shipmanagement
Section 2.4 Quality Policy
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2.04 Quality Policy 1
Bernhard Schulte Shipmanagement is engaged in the business of Shipmanagement, and this Policy
applies throughout the organisation.
The implementation of this Policy is underpinned by the full support of the senior management
executives.
Our Quality System is based on the requirements of ISO9001:2008, and includes a framework for
establishing and reviewing quality objectives.2
To implement this Policy we shall focus on the needs of our business with particular reference to
consistently meeting and exceeding our customer’s requirements and our statutory obligations.3
Our quality management system will provide mechanisms for detecting system shortfalls and for
stimulating process improvements. 4
Bernhard Schulte Shipmanagement will:
• adopt procedures and disciplines to ensure that the system is effectively implemented and in
line with our organisational goals and expectations;
• undertake relevant skills training and conduct appropriate quality awareness training;5
• establish responsibilities for quality and communicate these responsibilities clearly to all
employees;
• check the effectiveness and ongoing relevance of the policies and procedures by initiating
regular reviews 6 and;
• regularly review the needs and expectations of our customers and initiate continuous
improvement activities to meet these expectations.

(signature)
R. Bajpaee
Chief Operating Officer
Bernhard Schulte Shipmanagement

Date:

1

ISO9001:2008 sect 5.1;5.3, 8.5.1, ISO14001:2004 sect 4.2; OHSAS 18001:2007 sect 4.2
ISO9001:2008 5.3.c
3
ISO9001:2008 5.3.b
4
ISO9001:2008 5.3.b
5
ISO9001:2008 5.3.d
6
ISO9001:2008 5.3.e
2


Bernhard Schulte Shipmanagement
Section 2.5 Shipboard Drug & Alcohol Policy
Document No. 5820

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2.05 Shipboard Drug & Alcohol Policy
The Company’s Shipboard Drug and Alcohol Policy comply with the recommendations contained in
OCIMF’s ‘Guidelines for the Control of Drugs and Alcohol On Board Ship’.1
With regard to Alcohol, this Policy is based on the following:
•
•
•
•
•

Consumption of alcohol limited to beer, wine and similar alcoholic beverages with an alcohol
content of less than 17%.
1 hour of abstinence for each unit of alcohol consumed.
Total abstinence from alcohol for 4 hours prior to a period of scheduled responsibility, i.e.
watchkeeping duties, port arrival/departure etc.
Flag, Port or Coastal State requirements, or Policies of Owners, Charterers, or other interested
parties which exceed the requirements of this Policy shall be adhered to as if included in this
Policy.
It is accepted that many of the company’s vessels will in fact be ‘dry’, with respect to alcohol
consumption, due to policies of owners or charterers.

In addition, the Company maintains a system based on breathalysers and random testing to monitor

the effectiveness of this Policy.
Any form of drug, with the exception of over-the-counter medicines and prescribed drugs, are totally
banned from Company managed vessels. Personnel on prescribed drugs must declare this fact to the
Master upon joining the vessel, or upon prescription if prescribed during the period of service onboard.
The Master if on prescribed drugs must declare this fact to the company prior joining the vessel, or
upon prescription if prescribed during the period of service onboard.
This Policy is monitored on board all vessels by the Master. In addition, Officers and Ratings undergo
screening carried out during routine medical examinations.
Officers and Ratings are subject to unannounced random tests conducted by qualified personnel to
Port State and Owners’ requirements.

(signature)R. Bajpaee
Chief Operating Officer
Bernhard Schulte Shipmanagement
Date:

1

TMSA 3 1.4


Bernhard Schulte Shipmanagement
Section 2.6 Speaking Up Policy
Document No. 6091

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Speaking Up Policy
The following policy is addressed to all Bernhard Schulte Shipmanagement employees and all other relevant
people.
The Top Management of Bernhard Schulte Shipmanagement is committed to a free and open culture in dealings
between its management, employees, customers, suppliers and all people with whom the Group engages in
business relations.
The Board recognises that effective and honest communication is essential to maintain our business values and
to ensure that instances of business malpractice are detected and dealt with.

Purpose
The purpose of this policy is to encourage everyone, whether they are employees, agency staff, agents,
contractors, suppliers of customer of the Group, to report any business misconduct without risk to themselves.

Policy
This policy will apply in cases where you genuinely and in good faith believe that business misconduct is
occurring, has occurred or may occur within the Bernhard Schulte Shipmanagement Group.
Below are some examples of business misconduct:
•

•
•
•
•
•
•
•
•
•

A criminal offence
A person not complying with any legal obligation
The use of deception to obtain an unjust or illegal financial advantage for the business unit or personally
A miscarriage of justice
Danger to the health and safety of an individual
Damage to the environment
A fundamental breach of internal control
Intentional misrepresentation directly or indirectly affecting financial statements
Serious non-professional or non-ethical behaviour including harassment and bullying,
Deliberate concealment of information relating to any of the above.

This policy is separate from the grievance procedure as detailed in the documented management system.

Procedure
You should, in the first instance, raise the matter with your immediate superior, Master or Department Head, or if
you do not feel this is appropriate, your management representative / DPA.
All instances of speaking up will be forwarded to the Group LPSQ Director, who will advise the respective GMD
and the COO.
Should you feel unable to talk to your immediate superior, Master or Department Head, or management
representative / DPA, then you should contact the Group LPSQ Director who will treat the matter in confidence:

Group LPSQ Director:
Captain Bill Lunn : Mob: +357 99662566
e-mail:
P.O.Box 50127, CY3601
Limassol, Cyprus


Bernhard Schulte Shipmanagement
Section 2.6 Speaking Up Policy
Document No. 6091

Approved by

LPSQ Director

Effective Date

03-JUL-2009

Revision

0

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Investigation
Once an allegation of business malpractice is made the Group LPSQ Director will agree an appropriate

investigation plan with the SDC Head and respective GMD, and will endeavour to respond to you within 10
working days setting out what further investigation, if any, is planned.
Once the investigation is complete it will be reviewed by the Group LPSQ Director and the COO and you will be
advised of the results of the investigation as well as any corrective actions which are being taken.
The Group is committed to running its operations without misconduct and expects its employees and other
stakeholders to share this objective. However the group also recognises that speaking up can be a potentially
sensitive issue. If you believe that you are being penalised in any way for speaking up, or if you do not have a
satisfactory response to your disclosure you should write to the Group LPSQ Director setting out the facts.

Safeguards
If requested we will take all reasonable steps to protect your anonymity. However you should be aware that
action taken as a result of your disclosure may lead to your identity needing to be revealed.
Any employee speaking up is protected against adverse employment actions (i.e. dismissal, demotion,
suspension, harassment or other forms of discrimination) for raising allegations of business misconduct. An
employee speaking up is also protected even if the allegations prove to be incorrect or unsubstantiated, provided
the disclosure is made in good faith and where it is believed the information and any allegation in it are true.

Disciplinary Action
If any allegation of business malpractice is substantiated, appropriate disciplinary action will be taken against the
responsible individual(s), up to and including termination of employment.
Furthermore, acts of retaliation or victimisation against an employee for speaking up will result in disciplinary
action being taken against the perpetrator, up to and including termination of employment,
The malicious use of the Speaking Up policy will result in disciplinary action up to and including termination of
employment


Bernhard Schulte Shipmanagement
Section 3 QHSE Management System
Document No. 5821

Approved by

LPSQ Director

Effective Date

16-JUL-2009

Revision

1

Page 1 of 7
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ALL

QHSE Management System

Bernhard Schulte Shipmanagement has established documented, implemented and maintains a
Quality, Health Safety and Environmental Management (QHSE) System and continually improves its
effectiveness in accordance with the requirements of:
•
•
•
•

The ISM Code1

ISO9001:20082
ISO14001:2004
OHSAS18001: 2007 (partly complying as mentioned in Sect 1 & 2 of this Manual)

Bernhard Schulte Shipmanagement has identified the processes required for the QHSE Management
System and determined how they apply throughout the organization. The sequence and interaction of
the processes are shown in this QHSE Manual.3
Refer Sec 3.02

The Company has determined the methods and criteria required to make sure that the operation and
control of these processes are effective (refer QHSE Procedures), and ensure that the resources and
information needed to operate and monitor them are available.4
The Company monitors, measures and analyses these processes as appropriate and takes actions
needed to achieve the planned results and continually improve.5
Refer Sec. 7.1

The processes are managed by Bernhard Schulte Shipmanagement in accordance with the
requirements of the relevant Standards, Codes, IMO, National, Flag State and International
Regulations. Where the company may choose to outsource any processes that can affect the
conformity of the service requirements, it ensures that such processes are controlled. Any such
processes and their controls are identified in the QHSE management system.6
All documentation pertaining to the management system, including policies are written in the English
language, being the common language understood by all shore and shipboard personnel.7 Instructions
and procedures are clear and simple to use. Actions are arranged in sequential order and in a way that
makes it easy to identify each step. 8
3.01 QHSE System Processes

The top level processes identified by Bernhard Schulte Shipmanagement as being necessary for the
QHSE management system are:
1. Running and Maintaining the Ship (A.1)

2. Managing Personnel (A.2)
3. Arranging Insurances (A.3)
4. Purchasing activities (A.4)
5. Monitoring and managing costs (A.5)
1

ISM 7.0
ISO 9001:2008 sect 4.1
3
ISO 9001:2008 sect 4.1. a&b
4
ISO 9001:2008 sect 4.1 c&d
5
ISO 9001:2008 sect 4.1 e&f
6
ISO9001:2008 sect 4.1
7
ISM 6.6 & Flag requirement (Cyprus)
8
TMSA 1A 2.1
2


Bernhard Schulte Shipmanagement
Section 3 QHSE Management System
Document No. 5821

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LPSQ Director

Effective Date

16-JUL-2009

Revision

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6. Monitoring, Analysis and Review (of processes and service delivery) (A.6)
Ref Sect 3.02
These processes satisfy the ISO9001:2008 requirement for process in that they include management
activities, provision of resources, product realization and measurement.9

3.02 Interaction and Application of the Processes
The Company has mapped out the interaction and application of the processes using the “Integration
Definition for Function Modelling” (IDEFO) language. This describes the main activity of Running and
Maintenance of the Ship of Ship Management Services with Inputs, Outputs, Controls. Mechanism,
Costs connected to it flowing in or out as appropriate. This permits the construction of models
comprising system functions (activities, actions, processes, operations), functional relationships, and
data (information and objects).
The top level processes of the management system can be depicted using this technique:

Each of above sub-processes (A.2, A.3, A.4, A.5, A.6 are further explained in the QHSE Shore Procedures by
use of RACI Charts. Further sub-sub-processes as applicable /appropriate are also detailed therein.

9

ISO9001:2008 sect 4.1


Bernhard Schulte Shipmanagement
Section 3 QHSE Management System
Document No. 5821

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LPSQ Director

Effective Date

16-JUL-2009

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3.03 Management System Documentation

The management system documentation:
•

defines the responsibility, authority and interrelation of all personnel who manage, perform and
verify work relating to and affecting safe operation, prevention of pollution and quality, as
appropriate10

•

includes documents, including records, determined by the company to be necessary to ensure
the effective planning, operation and control all its processes.

•

is maintained on a web based portal (called QMAN), with CD copies supplied to vessels, and
all paper versions being considered uncontrolled. This is the form that the Company considers
most effective.11

Instructions and procedures covering shore-based and ship-based operations are developed in
consultation with those who will have to implement them.12
The following three levels of documentation have been established, implemented and maintained to
the Company’s requirements towards Compliance with provisions of ISO9001:2008 13’,
ISO14001:2004, OHSAS 18001:2007 and the ISM Code:14 This arrangement provides for to
continually improve the effectiveness of its Management systems.

Level 1
Policies and QHSE Manual

Level 2
QHSE Procedures
based & Shipboard)
QHSE(Shore

Procedures

Level 3
Work Instructions,
Shipboard
Manuals
andRecords,
Plans, Company
Forms , Records
Operations
and Other
Manuals,
Forms,
Work Instructions
etc.

10

ISM sect 3.2
ISM sect 11.3
12
TMSA 1A 3.2
13
ISO9001:2008 4.1
14
ISM sect 11.1
11


Bernhard Schulte Shipmanagement

Section 3 QHSE Management System
Document No. 5821

Approved by

LPSQ Director

Effective Date

16-JUL-2009

Revision

1

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System Manual structure overview is as below:
USMS Tier Structure
QHSE Manual

L
L
Leeevvveeelll111

L
L

Leeevvveeelll222

L
L
Leeevvveeelll333

Shipboard Procedure

SHE Manual

Marine Operation

Technical

Manual

Operation Manual

Cargo Operations

EMS Manual

Manual

QHSE Shore Procedure

Contingency

Filing Forms &

Personnel Selection

Instruction to

Manual

Documentation

& Recruitment

CSC Manual

Manual

Manual

Risk Assessment &
Management of Change

Tanker Safety

Tanker

(General)

(Specific)

Bulk Carriers

Ship

Container

Shore

Other Cargo
(Ship Type)

-

Gas

-

Oil

-

Chemical

Level 1:

Quality Policy – a statement of the Company’s commitment to Quality and an enunciation of its
Quality objectives.15 This is issued by the COO and is reviewed annually. In addition to the Quality
Policy, following Policies has also issued by the Senior Management (COO), Shipboard & Shore-side
Occupational Health, Safety and Environmental Policy, and a Shipboard Drug and Alcohol Policy.
Unless specified otherwise, the Quality Policy is understood to embrace all aspects of these other
Policies.
Note:
Other Policies include “Business Policy” (Financial / Ethics), “Speaking up Policy” etc. as described in

Sect. 2.2 & 2.6.
QHSE Manual16 – outlines what we will do to meet the requirements of the elements of ISM,
ISO9001:2008, ISO14001:2004, OHSAS 18001:2007 codes, and the objectives set out there in the
various policies.
15
16

ISO9001:2008 4.2.1.a
ISO9001:2008 4.2.1.b


Bernhard Schulte Shipmanagement
Section 3 QHSE Management System
Document No. 5821

Approved by

LPSQ Director

Effective Date

16-JUL-2009

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The QHSE Manual contains references to various procedures called QHSE Procedures established for
the QHSE management system.17
Level 2:

QHSE Procedures18 – describes how we will satisfy each element of the various codes and standards
and how we control other critical processes in order to meet the commitments outlined in the Policies.
The complexity of the work and the skill level of personnel involved in performing the work and the
work environment governs the degree of control provided within the management system procedures.
Level 3:

Operations & Other Manuals: Contain instructions and procedures for Cargo Operations (ship type
specific), Safety Health
Environment, Technical, Environment Management System (EMS), Risk
Assessment, Management of Change (MOC), Personnel etc, to ensure Safe operation of ships and
protection of the environment all in compliance with relevant International and flag state legislation,19
(as applicable).
Contingency Response Plan Manual – This manual covers in detail Company’s set up and plans to
deal with Contingencies on board.
Forms, Filing & Documentation Manual20 – Forms used to complement QHSE Procedures and/or
Work Instructions. Once completed they constitute records. Also covers Company’s Document Control
Procedures and Filing Instructions.
Records21 – Records are established and maintained by the company to provide evidence of
conformity to requirements and of the effective operation of the Quality Management System.
Work Instructions – Supplements the company’s procedures by giving detailed instructions on how to
carry out the specified activities, controls, inspections or tests, or how to process documents.22 They
are used where the absence of such instructions would adversely affect service quality. These are
normally more specific to each SDC and mostly deal with Local level information.
3.03.01 Control of Documents23

The Company has established and maintains procedures to ensure that:
• All documents are identified, distributed and controlled, including data that relate to the
requirements of the Management System24. This includes where practical, documents of
external origin determined to be necessary for the planning and operation of the Management
System25. This covers all documents and data in any format, including hardcopy and electronic
media.

17

ISO9001:2008 4.2.2.b
ISO9001:2008 4.2.1.c
19
ISM 1.4.2
20
ISO 9001:2008 4.2.1.d
21
ISO 9001:2008 4.2.1.d
22
ISO 9001:2008 4.2.1.d
23
ISM Code sect 11; ISO9001:2008 sect 4.2.3; ISO14001:2004 sect 4.4.5; OHSAS 18001:2007 sect 4.4.5
24
ISM Code sect 11.1
25
ISO 9001:2008 4.2.3.f
18