POLICY FOR SAFETY, PROTECTION, ENVIRONMENTAL MANAGEMENT AND HEALTH IN THE WORKPLACE

ISM Code Parag. 2. – Safety and Environmental Management Policy)

(ISPS Code – International Ship and Port Facilities Security)

(ISO 14001:2004 – Environmental Management)

(ISO 45001:2018 – Occupational Health and Safety Management Systems)

NAVEMAR S.A. (hereafter The Company), a company that carries out fluvial and maritime transportation activities, as well as loading and related activities; a Maritime, Representation, Broker, and Charter Agency; a Ship Operator for all sorts of Dry, Liquid or Container Cargo; establishes as a fundamental policy a profound respect for the safety and protection of human life, in all of its aspects, as well as environmental protection.

In order to fulfill this policy, the Company has established a Safety, Protection, Environmental Management and Health in the Workplace System, which complies with all of the ISM Code and ISPS Code requirements, the ISO 14001:2015 Norm, the International Conventions in effect, all of the International Maritime Organization (IMO) Guides, Resolutions and recommended standards, the ISO 45001:2018 Norm, as well as the local environmental and health laws, regulations and norms within the countries we operate, as well as the vessel classification societies’ regulations applicable to our activities.

The Company commits to cooperating with the constituted authorities in the fight against drug trafficking, smuggling, terrorism and other illicit activities, with actions and procedures that promote the prevention of illegal actions and the control of its operations.

The “appointed person”, Mr. ANIBAL RAMIREZ, is responsible for the implementation, maintenance, control and continuous improvement of the Safety, Protection, Environmental Management and Health in the Workplace System, ensuring that all services are executed following the Company’s policies.

All of the Company’s staff members must acknowledge, fulfill and adhere to these policies without exception. Likewise, all providers and contractors must acknowledge and adhere to our policies and to the legal, safety and health in the workplace requisites, which the Company must communicate.

The Company is committed to: providing safe and healthy work practices, ship operations as well as activities on land, preventing damage and protecting the environment, following the identified environmental aspects, providing a reference framework for the establishment of environmental, healthy and safety in the workplace objectives, preventing wounds and health damages, eliminating dangers and reducing risks, and continuously improving safety, health and environmental protection practices among land staff and crew, as well as their preparation and training to act in operational, safety, health and environmental protection emergencies, providing the necessary means to meet these objectives.

The Company assumes all responsibility of the safe operation of its vessels, and the protection of its staff and the environment before its staff and/or representatives, by establishing this registered address:

NAVEMAR S.A.

Rca. Argentina Nª 1412 e/ Prof. Miguel Torres

Asuncion, Paraguay

Phone: 595 21 612-527/30 Fax: 595 21 612-526

E-mail: navemar @ navemar.com.py Website: www.navemar.com.py

The Board of Directors will review this Policy annually, and share it within the organization. It will be available to all parties affected by our activities.

Asunción, March 6, 2019