HSQE Policy (Health, Safety, Quality & Environment)

This policy is applicable to all directors, officers, employees, subcontractors, and third parties acting on behalf of CARGOWARD (“Covered Persons”) across Brazil and internationally.

1. HSQE commitments

CARGOWARD commits to:

1.1. Protect people: prevent injury and ill health through disciplined risk controls, training, competent supervision, and stop-work authority.

1.2. Protect the environment: prevent pollution, control residues and waste streams, and maintain environmental discipline aligned with port requirements and IMO/MARPOL expectations.

1.3. Deliver quality through control: execute services through defined workpacks, documented acceptance criteria, evidence-based reporting, and traceable close-out documentation.

1.4. Comply with applicable requirements: follow applicable laws, port/terminal rules, and vessel procedures, applying the more stringent requirement when standards differ.

1.5. Continually improve: treat incidents, near misses, deviations, and nonconformities as inputs to operational improvement and governance strengthening.

2. HSQE governance and accountability

2.1. Leadership accountability: CARGOWARD leadership is accountable for HSQE performance, resourcing, and governance.

2.2. Line responsibility: supervisors and operation leads are responsible for implementing HSQE controls at the worksite, ensuring permits, access readiness, and safe methods.

2.3. Individual responsibility: every Covered Person has the duty to work safely, follow procedures, report hazards, and refuse unsafe instructions.

2.4. Stop-work authority: any Covered Person may stop work where conditions are unsafe or non-compliant. Stop-work decisions are protected and must be escalated for review.

3. Standards, frameworks, and operational alignment

3.1. CARGOWARD’s HSQE management approach is aligned with commonly recognized HSQE frameworks and maritime expectations, including (where applicable to the operation):

• ISO 9001 (Quality Management principles),

• ISO 14001 (Environmental Management principles),

• ISO 45001 (Occupational Health & Safety Management principles),

• IMO conventions and operational expectations, including MARPOL and SOLAS,

• Vessel safety management practices aligned with the ISM Code,

• Port/terminal HSSE requirements and permit-to-work systems.

3.2. This policy does not constitute certification. It defines internal operating standards and governance expectations.

4. Risk management: planning, controls, and execution discipline

4.1. Each operation must be planned with risk discipline appropriate to scope and environment. Controls may include:

• pre-job planning and workpack definition;

• hazard identification and task-specific risk assessment;

• toolbox talks and shift briefings;

• permit-to-work interfaces (as applicable);

• isolation and lockout controls (as applicable);

• access and fall prevention;

• lifting plans and exclusion zones (as applicable);

• emergency readiness and escalation channels.

4.2. Where risk is elevated (confined space, hot work, high-pressure jetting, chemical handling, underwater/diving, work at height), enhanced controls must be applied.

5. Health and safety: minimum operating requirements

5.1. Competency and training: personnel engaged in specialized activities must be competent, trained, and supervised.

5.2. PPE and equipment integrity: appropriate PPE must be used and maintained; equipment must be inspected and suitable for the task and environment.

5.3. Fitness for work: personnel must be fit for duty and free from impairment that could introduce risk.

5.4. Incident reporting and learning: all incidents, near misses, and unsafe conditions must be reported promptly. Corrective actions must be tracked to closure.

6. Confined space, tank entry, and gas-free readiness (tank cleaning contexts)

6.1. Confined space entry and tank cleaning involve hazardous atmospheres and must follow strict controls, including:

• entry permits (PTW),

• isolation and ventilation readiness,

• gas testing/monitoring regimen,

• rescue preparedness and standby watch,

• continuous risk review and stop-work authority.

6.2. Any gas measurements or “gas-free” related deliverables are time- and location-specific and must be supported by records and operational context.

6.3. Unless expressly agreed otherwise in writing, CARGOWARD does not replace the Vessel/terminal authority responsible for PTW authorization and statutory safety management obligations.

7. High-pressure washing and hydro-jetting (cargo holds / tanks)

7.1. High-pressure washing and hydro-jetting require controls for:

• jetting pressure management and lance handling,

• exclusion zones and line-of-fire controls,

• PPE and face/eye protection,

• equipment inspection and hose integrity,

• safe access and stability on tank tops and structures.

7.2. Chemical usage, when required, must follow compatibility and handling controls, SDS review, and containment measures.

8. Cargo hold cleaning: quality control and verification methods

8.1. Cargo hold preparation is executed based on scope and the vessel’s structural realities (tank tops, bilges, frames, upper areas, hatch coamings/covers, ledges and corners).

8.2. Quality is supported through:

• defined cleaning sequences and hold-by-hold controls;

• bilge detailing and residue removal discipline;

• drying and ventilation control where applicable;

• verification steps (e.g., rag/glove checks) consistent with scope;

• documentation packs including photos, checklists, and close-out notes.

8.3. Third-party acceptance criteria (surveyors, charterers, terminals, receivers) may vary and are outside direct control; CARGOWARD’s quality posture is to execute traceable work and document evidence-based outcomes.

9. Environmental management: prevention, containment, and documentation

9.1. CARGOWARD maintains environmental discipline to prevent pollution and to manage residues and waste streams responsibly. Controls may include:

• containment and housekeeping;

• spill prevention and response readiness;

• segregation of residues and waste streams;

• coordination with licensed waste reception/disposal channels where applicable;

• maintenance of disposal documentation where available.

9.2. Environmental compliance is subject to port/terminal rules and authority direction; operations must follow local requirements and operational constraints.

10. Underwater operations: safety, controls, and limitations

10.1. Underwater work is constrained by sea state, currents, visibility, access limitations, and port authorizations. Safety controls include:

• dive planning and competence requirements (where applicable),

• risk assessment and job safety analysis,

• communication protocols and standby readiness,

• evidence integrity and limitation recording.

10.2. Underwater evidence and reporting must reflect actual conditions observed and recorded and must state limitations transparently.

11. Quality management: traceability, nonconformity, and continuous improvement

11.1. CARGOWARD operates with a “controlled execution” approach supported by documentation, defined workpacks, and evidence-based reporting.

11.2. Deviations and nonconformities must be recorded, investigated, and corrected. Preventive actions must be implemented where systemic risks are identified.

11.3. Client feedback, surveyor comments, incident learnings, and operational outcomes are inputs for continuous improvement.

12. Security, compliance, and authority interface

12.1. Port environments require disciplined interface with authorities and terminals. CARGOWARD maintains a compliance-first posture, including:

• lawful conduct;

• accurate submissions and records;

• controlled access management;

• escalation of irregular requests (including improper payment requests) in line with ABAC rules.

13. Communication, documentation integrity, and confidentiality

13.1. CARGOWARD documentation must be accurate, timely, and free from manipulation or misrepresentation.

13.2. Operational records and evidence packs may contain sensitive information and must be protected under confidentiality and data protection requirements.

14. Objectives and performance indicators

Depending on the operation profile, CARGOWARD may track HSQE indicators such as:

• incident frequency and severity;

• near-miss reporting rates;

• safety observation closure time;

• nonconformity rates and corrective action closure;

• environmental incidents/spill metrics;

• client and surveyor feedback trends;

• documentation completeness and traceability scores.

Indicators are used to drive improvement and operational governance.

15. Reporting and escalation

15.1. HSQE concerns, incidents, near misses, and compliance issues must be escalated promptly through operational leadership channels and may be reported to: contact@cargoward.com.

15.2. Retaliation against good-faith reporting is prohibited.

16. Policy review and updates

This HSQE Policy is reviewed periodically and may be updated to reflect changes in legal requirements, operational environments, and governance best practices. The “Last Updated” date indicates the current version.