XPF has made public commitments related to: fuel efficiency and reducing carbon emission; responsible ship recycling; reducing plastic use; biofouling management; whale collisions; employee wellbeing, diversity, equal opportunity and nondiscrimination, occupational health and safety, human rights and labor practices; training and development of staff; and compliance with laws relating to business conduct.

Eastaway has a safety management system (SMS) that meets the requirements of Singapore flag, IMO conventions, Maritime Labor Convention (MLC) and requires each Eastaway-managed vessel to undergo required inspections and obtain certifications as per respective flag state requirements. The SMS is being systematically implemented in the vessels managed by Eastaway. XPF’s E&S policies and Eastaway’s SMS will be applied to the project vessels as well. The Project Companies will, as agreed under ESAP # 1, incorporate compliance with IFC PSs and alignment with good international industry practice (GIIP) as reflected in the applicable and relevant parts of the WBG General EHS Guidelines and WBG EHS Guidelines for Shipping in each Project Vessel-level SMS; and develop and implement a stakeholder engagement plan.

Eastaway’s SMS has identified key E&S risks and impacts and put in place mitigation and management measures for the identified risks and impacts, including comprehensive emergency preparedness and response procedures covering: fire; abandon ship; collision; grounding; flooding; structural failure; heavy weather damage; deviation; helicopter; steering gear failure; power failure; main engine failure; personnel accident; rescue from hold; man over board; spillage of harmful substances; oil spills; shore based emergency; and ship-shore emergency coordination. Crew are trained in emergency response and periodic inspections and drills are conducted. However, some aspects in the project vessel level SMSs need to be further strengthened, particularly those relating to: the inclusion of E&S requirements in contractor and vendor selection; ship recycling; final waste disposal by subcontractors including during dry docking; crew safety during shore leave; community health and safety linked to crew shore leave; gender aspects; and biodiversity. Accordingly, the Project Companies will, as mentioned at ESAP # 2, incorporate in their respective SMSs additional procedures or upgrade existing procedures related to: contractor screening and oversight based on contractors’ E&S management and performance; duty of care verification to document how onshore waste management contractors treat or dispose of all waste streams using chain of custody forms to be signed / stamped at the final disposal / treatment facility including final waste disposal during dry dock  particularly in relation to the removed hull coating so as to obtain assurance that it meets IFC PS3.

Eastaway has four senior shore-based staff members whose responsibilities specifically include E&S responsibilities as well. Further, on each of the project vessels, three senior crew members (the Master, Chief Engineer and Chief Officer) and those in supervisory positions, have specific E&S responsibilities as part of their job responsibilities. Eastaway has competence & training requirements for crew members and a structured staff and crew training process in place.

Eastaway has a monitoring, documentation/record keeping and review program in place including periodic inspections and internal and third-party audit. Key Performance Indicators (KPIs) related to audit observations, occupational health and safety (OHS), fuel efficiency and greenhouse gas emissions are in place. Inspection findings, incident investigation and analysis and KPIs are discussed in monthly safety meetings and corrective actions developed. Comprehensive review of audit findings and E&S performance is undertaken in annual SMS reviews. The Project Companies will, as mentioned at ESAP # 3, put in place procedures to: develop a systematic approach and criteria for selection of E&S-related KPIs; and ensure that KPIs capture the management measures required in the SMS for significant E&S risk including KPIs for gender aspects, labour and working conditions aspects, and environmental aspects to ensure all risks and performances are captured, consistent with IFC’s PSs.

XPF has a set of HR policies and procedures aligned with the requirements of Singapore labor laws and employment laws in the country of employment. The HR Policies are generally aligned with IFC PSs.

Typically, each project vessel will have a manning of [15] persons and they are hired from various countries. XPF’s policies and Eastaway’s crew contracts will be applicable to the crew on the project vessels also. Each crew receives a written contract describing the terms of employment. The terms and conditions for crews meet the requirements of Maritime Labor Convention (MLC) and Singapore Maritime Union for vessels registered in Singapore flag. In the project vessels, crew will have a single-occupancy accommodation/cabins with attached bath.

Crew on several vessels are part of a union and the Singapore flag vessels have a collective bargaining agreement with Singapore Maritime Union and Singapore Organization of Seafarers. XPF and Eastaway adhere to Singapore labor laws and MLC (for vessel crew), which require prevention of child and forced labor. OHS is addressed through the safety management system described under PS1 above.

XPF has a whistleblowing policy in place which covers employees, agents, managers, crews, suppliers, workers (including independent contractors, agency workers), temporary employees, freelancers, non-executive directors, consultants, and customers. Also, the Company has a non-discrimination and sexual harassment prevention policy in place. There is a separate complaints mechanism for sexual harassment related issues and the investigation is undertaken by a panel from an independent third-party organization. [XPF has contractually required the third-party investigation agency to include at least one woman member as part of the panel.] Additionally, XPF has a grievance mechanism which is available to shore-based staff and Eastaway has a grievance mechanism that is available to vessel crew and third-party workers. XPF will, as agreed upon in ESAP # 4, upgrade procedures for prevention and redress of gender discrimination and gender based violence and harassment (GBVH) including: to prominently display commitment to equal opportunity employment in the recruitment advertisements; training and awareness building on prevention and redress of gender discrimination and GBVH of all company staff and vessel crew, particularly on vessels where women seafarers will be deployed;  specifying the time within which each step in the redress mechanism will be completed; ensuring availability of female hygiene products, hygienic and safe sanitation disposal facilities and welcoming social and recreational spaces on vessels where women seafarers are deployed; regular consultation with female employees about the suitability of the facilities and required improvements; and development, monitoring and reporting of KPI’s to track gender aspects. Further, as agreed upon in ESAP # 5, XPF will: update the employee grievance mechanism to include provisions for anonymous complaints; specify time within which each step will be completed in the grievance and whistleblower mechanisms; articulate a retrenchment policy; and articulate a policy on workers organization.

The project vessels will be Energy Efficiency Design Index (EEDI) Phase 3 compliant and will have approved Ship Energy Efficiency Management Plan (SEEMP) III detailing how the project vessels will achieve their carbon intensity (CII) targets. Eastaway maintains records of reductions in fuel and energy consumption and sludge disposal to shore facilities (instead of incineration) and is working with vendors on minimization of plastics and packaging.

The average fuel consumption of each of the project vessels is expected to be about 20575 tons HFO and 1380 tons of VLSFO, amounting to about 68367 tCO2e per vessel per annum. The average CO2 emission is expected to be 8.58 grams CO2 per tonne-nautical mile.

The project vessels will comply with relevant IMO requirements related to air emissions and will have International Air Pollution Prevention Certificate. These vessels have been designed to meet NOx tier III emission control area (ECA) requirements and will have open-loop SO2 scrubbers. The vessels will use 0.5% sulphur fuel during voyage and 0.1% sulphur fuel in emission control areas and in jurisdictions/areas where open loop scrubbers are not permitted. The project vessels will not have any halon fire extinguishers.

Eastaway’s vessels have in place procedures, equipment, facilities and record keeping/documentation that meet IMO requirements related to: IMDG cargo handling; ballast water management; garbage management; sewage treatment and disposal; sludge management; safe use of pesticides; prevention of pollution from oil and noxious liquids; hull and propeller cleaning; and anti-fouling system. Waste is segregated at source, hazardous waste is kept on board and disposed off ashore to licensed hazardous waste disposal facilities, and sewage is treated and effluent discharged at sea. Oil residues are disposed ashore to contractors. In relation to IMDG cargo, Eastaway requires a third-party inspection and certification of the cargo in the container. These equipment, facilities and procedures will be provided in the project vessels also.

The averaged quantity of oil sludge expected to be disposed ashore per project vessel is expected to be about 220 m3 per annum, and the total food waste disposed (into the sea) per vessel will be about 35 m3 per annum. Eastaway’s vessels dispose of [ballast water sediments], electronic waste, operational waste and plastic to onshore contractors. Plastic compactors are installed on longer route vessels. Food waste and treated sewage is disposed in high seas.

Eastaway’s SMS has a process in place for maintenance of inventory of hazardous materials (IHM). The project vessels are all new build vessel to be commissioned in 2023 and 2024, will have/maintain an IHM and are not expected to be sent for recycling soon. However, Eastaway is committed to ensure that if any of the project vessels are sent for recycling during the period of IFC’s loan, it will be sent to a shipyard that complies with the requirements of the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009.

Eastaway will, as agreed upon in ESAP # 6, develop and implement as part of the SMS for the project vessels: a code of conduct for crew shore leave specifying requirements to avoid any adverse impacts on local communities, including gender-related aspects; procedures to provide general advice and training on H&S risks including communicable diseases; and establish a systematic procedure to request information from port agents or other credible sources on potential E&S, health and safety risks to the crew during shore leave and potential community health and safety risks associated with shore leave.

A ship security plan is prepared as per ISPS code that describe the response to foreseeable situations including stowaways and refugees. The Project Companies will, as mentioned at ESAP # 7, develop and implement a systematic screening procedure for security contractors which documents evidence that ICOC policies and procedures are being followed and that guards are trained in the UN Basic Principles on the Use of Force and Firearms and UN Voluntary Principles on Security and Human Rights; and procedures on rescue and handling of refugees and migrants at sea.

The expected route of the project vessels passes through or near several Important Marine Mammal Areas (IMMA) in the Indian Ocean, coastal Sri Lanka and the Gulf of Aden. In order to manage risks to marine mammals, the project vessels will adhere to the relevant legal obligations and guidelines, which may include a combination of: permanent, seasonal and voluntary Areas to be Avoided (ATBA), Traffic Separation Schemes (TSS) or port approach routes; permanent, seasonal, or short term and dynamic routing measures implemented in response to observations of whale aggregations or Voluntary Dynamic Management Areas (DMAs), which are temporary protection zones triggered when three or more whales are sighted within 2-3 miles of each other outside of active Seasonal Management Areas and vessels are encouraged to avoid these areas or reduce speeds to 10 knots or less while transiting through them; and rapid reporting network of whale sightings or acoustic detections to alert vessels transiting an area.

Further, Eastaway has developed procedures for screening of biodiversity risks for international shipping routes and implementation of good practice measures to minimize potential impacts on marine mammals including reporting of whale collisions to the International Whaling Commission, optimizing routes to minimize impacts on sensitive areas like IMMAs, avoid/minimize discharge in such areas, monitor presence of whale species in the area, reduce speed to 10 knots or less if a whale species is identified within 3 nautical miles and gather data on threatened marine mammal species that occur in sensitive areas. As agreed upon in ESAP # 8, the Project Companies will update the biodiversity management procedure to include: training including annual refresher training of current and any new crew for monitoring and reporting sightings of marine mammals including preparation of specific materials to aid seafarers in the identification of marine mammals by members of professional marine mammal professional association; at least two trained crew members must be present on each voyage and present on the bridge; provision of infra-red and reticulated binoculars (to be used by staff trained to observe marine mammals); and development of a reporting system to share information with NGOs and other conservation organizations studying marine mammals for example Global Biodiversity Information Facility.