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SEKUR HOLDINGS INC. SQ&E Management System ManualDate of Issuance : JUNE 2003 Issued by : SQMRevision No. : 1/FEB/09 Approved by : Managing DirectorChapter No. : 7 Ch.7Form No. G 5

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COMPANY DRUG AND ALCOHOL POLICY(POSTED IN THE OFFICERS/CREWS MESS AND ON THE BRIDGE)

Your Owners and Operators are committed to a safe, healthy and productive work environment for allemployees. The Company recognizes that alcohol or drug abuse by employees will impair their ability toperform properly and will have serious adverse effects on the safety, efficiency and productivity of otheremployees and the Company as a whole. Therefore:

Onboard their vessels, alcohol are prohibited. The vessels are DRY VESSELS. Nevertheless insome special cases small quantities of alcohol might be permitted by the Company. Whenpermission for alcohol is granted then vessels must be act as follows:

1. Neither the crew not anyone else visiting or otherwise onboard must be intoxicated at any time.The limit of alcohol impairment is:Blood alcohol content at any time while person is onboard, shall not exceed 0.04 percent GM/Decilitreof blood, or 40 MG/100 Ml or greater.

(For information on relation between blood alcohol content and alcohol consumption see SMSMChapter 7).

2. Consumption of alcohol onboard shall only be permitted for crew members above 18 years of agemaximum one beer (330 Ml) per meal maximum four beers per week to be served open and to beconsumed at the table. The entitlement shall not be transferable to another person.

3. Alcohol must not be consumed-period of abstinence from alcohol:Officers and crew scheduled for watch-keeping duty shall not consume any alcohol at least one hourprior to the start and during watch-keeping duty. Within last 24 hours prior to arrival at a countrysterritorial waters and until you have left the territorial waters, alcohol consumption must be suspendedand onboard alcohol beverages to be properly secured.

4. The purchase of private alcohol is not permitted for all onboard.5. The sale of alcohol to crew members is prohibited.

6. The ships alcohol stock onboard must be reasonable in quantity sufficient for legal use only, and underthe control of the Master.DRUGS (NARCOTICS AND SIMILAR SUBSTANCES)Owners do not accept that members of the crew and/or other persons onboard the vessel consumeunauthorized drugs or that any kind of drugs are brought or exist onboard their vessels (outside of the vesselshospital).

CONTROL AND MONITORING1. Master, Officers and crew prior to employment must undergo a drug and alcohol testing as arranged by

the recruiting office.2. The Master to carry out unannounced alcohol test onboard every month or when he finds it

appropriate using the alcohol test equipment provided onboard by the Owners. Results must be sent toCompanys office.

3. The Owners shall arrange for a shore contractor to carry out a drug and alcohol test. Master is to makethe appropriate log entries and he will be advised when the results are known.

VIOLATION OF THE ABOVE OWNERS RULES ABOUT DRUGS AND ALCOHOL WILLLEAD TO IMMEDIATE DISMISSAL.

We thank you for your understanding and co-operation.SEKUR HOLDINGS INC..