SRTI Disclosures

No

2012

<25%

If SPO is seeking to recycle a ship it will only tender to (or via Cash buyers warranting to use) Ship Recycling Facilities (“SRF”) that are currently (and expected to be for the duration of the dismantling) fully certified by a reputable, independent, competent third party as having valid and verified accreditation against the Hong Kong International Convention (“HKC”) for the Safe and Environmentally Sound Recycling of Ships (whether or not yet formally adopted), and additionally if it is an EU Flagged ship, or departing on final voyage from an EU port, the SRF must by EU law be on “the white list” under the EU Ship Recycling Regulations (“SSR”) 1257/2013; The reputable, independent, competent third parties referred to in (2) above include (only) the following class societies: ClassNK, LR and DNV. This list will be reviewed periodically by SPO’s recycling representative (“RecRep”), generally the GM – Sustainable Development (“GM - SD”).

2012

When a ship is offered for sale at the end of its economic life to SPO: a. If the residual value is greater than 40% above the highest current scrap value then there need be no additional contractual provisions concerning sustainable recycling of the ship; b. If the residual value is between 25% and 40% above the highest current scrap value then there shall be included in the sale contract a contractual provision that the buyer must warrant to trade the ship for the subsequent 2 calendar years or, if the absence of this, to sustainably recycle the ship according to the SPO Sustainable Recycling Policy (and by extension, this SOP); c. In all other cases (viz. the residual value is below 25% above the highest current scrap value) then there shall be included in the sale contract a contractual provision that the buyer must warrant the ship will be sustainably recycled according to the SPO Sustainable Recycling Policy (and by extension, this SOP).

As per previous answer and then as required within the Agreed Bill of Sale

We have always maintained management control of vessels owned through j/vs. Should the vessel reach the end of its economic life, its management would be determined by SPO in accordance with the above.

Our own in house Sale contract has included this requirement in the very rare (3 in 45 years) occurrences when an owned vessel has reached the end of its economic life and been sent for sustainable recycling. We envisage that in the future we would deliver the vessel to the recycling facility specified in the contract, as we are doing in our sister company.

2 If SPO is seeking to recycle a ship it will only tender to (or via Cash buyers warranting to use) Ship Recycling Facilities (“SRF”) that are currently (and expected to be for the duration of the dismantling) fully certified by a reputable, independent, competent third party as having valid and verified accreditation against the Hong Kong International Convention (“HKC”) for the Safe and Environmentally Sound Recycling of Ships (whether or not yet formally adopted), and additionally if it is an EU Flagged ship, or departing on final voyage from an EU port, the SRF must by EU law be on “the white list” under the EU Ship Recycling Regulations (“SSR”) 1257/2013; 3 The reputable, independent, competent third parties referred to in (2) above include (only) the following class societies: ClassNK, LR and DNV. This list will be reviewed periodically by SPO’s recycling representative (“RecRep”), generally the GM – Sustainable Development (“GM - SD”)

4 SPO’s RecRep will undertake an on-site audit against the Sustainable Shipping Initiative Responsible Ship Recycling Standard (“SSI RSRS”) [see L4 document SSI RSRS] of any/all successfully tendering SRF, accompanied by a reputable, independent, competent third party, and this must have minimal NCRs on completion, as a subject to final confirmation of award of the sale for recycling; 5 The award of the sale for recycling of a SPO vessel at the end of its economic life to a cash buyer and/or the SRF itself directly shall include as a minimum, but not limited to, the following clauses: a. SPO will provide, at its sole cost and responsibility, both an HKC Compliance Monitoring Team (“CMT”) consisting of personnel such as at Master level, 2/E level and Bosun level, together with an auditor from a reputable, independent, competent third party, to work with the SRF management to close the gaps between the Ship Recycling Management Plan of the SRF (“SRFP”) and reality, and establish best SRF practice building on, and exceeding where feasible, the HKC; b. The CMT and 3rd Party Auditor will be employed by SPO HOF through contracts with relevant 3rd parties. These personnel will act as Technical Advisers to the SRF Management, and will expressly have no authority to instruct any SRF personnel to start, continue, or stop any work practices, except as explicitly provided below; c. It will be agreed between the SRF and SPO that all the personnel of SPO, including the CMT, RecRep and contracted auditor, will have the authority and responsibility to order all work to be stopped immediately on the recycling operation should they become aware of any work practices or omissions that have the potential to cause imminent or immediate harm to a) the health and safety of the workers, b) the environment. The stop work order will remain in place until the cause has been identified and remedied or rectified to the satisfaction of SPO; d. It will be agreed between the SRF and SPO that all the personnel of SPO, including the RecRep, CMT and any contracted auditor, will have the authority and responsibility to request a meeting with the SRF Management should they become aware of any work practices or omissions that, whilst they may not have the potential to cause immediate harm to people of the environment, but they are in contravention to the Ship Recycling Plan for the specific vessel in question (“SSRP”) or SRFP or the HKC. The meeting with management will occur as soon as possible and recommend systems, procedures and/or practices such as will remedy or rectify the compliance shortfall to the satisfaction of SPO; e. The SRF (and CMT) will provide a weekly sustainable recycling progress report to the GM – SD, from the time of beaching to the time of obtaining a Certificate of Completion of Recycling from the appropriate regulatory body; This report will be submitted by e-mail prior to opening business Singapore each week and will include as a minimum i. Executive Summary; ii. Man-hours worked and full HS&E statistics (FAT, PTD, PPD, LTI (and LTIFR), RWC, MTC, FAC (and TRCFR), AD, NMR, RTA, Environmental Spills, Compliance notices and any fines or penalties issued); iii. Stop work orders – reason and time to rectify; iv. Training undertaken, for whom, by whom and against which standard; v. Work permits issued (e.g. Hot work, enclosed space, work at height or over water); vi. Dismantling progress made over previous week – text and photographs describing key activities, measured against SRP, and a forecast ETC; vii. Details of internal and external audits of both SRF equipment, and processes measured against the requirements of the HKC; viii. Details of all recycled products and Hazardous Material disposed of, and to which certified, competent facility, over the preceding period; ix. Suggestions for improvement. f. Both the SPO RecRep and the contracted reputable, independent, competent third party auditor will visit the SRF during the dismantling, both announced and unannounced. The frequency will be as agreed between SPO GM SD and the 3rd Party Auditor, but is likely to be around monthly. The Audit During Recycling (“ADR”) will be undertaken on site involving the SPO GM SD, 3rd Party Auditor, CMT and SRF Senior Management. Each ADR will be shared with the CMT and SRF to enable them to build capacity and competence further;

N/A