POLICIES

EQUALITY

S.C. Marine Offshore Consultants S.A. is committed to securing equality of opportunity through the creation of an environment in which individuals are treated solely based on their education, skills and experience.

We discourage all forms of unlawful or unfair discrimination on the grounds of age, race, color, nationality, ethnic origin, gender, marital status, sexual orientation, trade union membership, disability, political views and religious or similar philosophical beliefs, and aim to ensure equal treatment for all.

Marine Offshore Consultants aims:
– to provide an appropriate and inclusive working experience for all employees and partners, irrespective of their gender, race, origin or culture, disability, religion or belief;
– to provide a positive working environment which is free of prejudice and promotes equality of opportunity;
– to recognize and celebrate people’s differences to build and maintain a culture of respect and co-operation;
– to promote an active exchange of cultural background and good practices between employees;
– to protect its partners and employees from discrimination, harassment and victimization:
• through its HR and working policies and procedures,
• while providing services for clients on company’s behalf,
• by providing equal access to any benefit, facility or service to partners and staff.
– to promote and advance equality of opportunity between people who share a protected characteristic and people who do not share it and,
– to promote and foster good relations between people who share a protected characteristic and people who do not share it.

 

 

DISABILITY

Marine Offshore Consultants recognizes the definition of disability as when a person has a “physical or mental impairment which has a substantial and long term adverse effect on that person’s ability to carry out normal day to day activities.”

Marine Offshore Consultants is committed to a fair and equal treatment of all individuals regardless of disablement.

Marine Offshore Consultants will welcome applications from people with disabilities to join their team, programs and projects.

An applicant’s disability will not prevent him/her from being offered a place unless the content, structure and delivery of the work are such that the person would be prevented from fulfilling a major part of it; or Marine Offshore Consultants would be unable to provide suitable working conditions or facilities to allow the requirements of the activities to be met.

Marine & Offshore Consultants will provide flexible and equal access to all employees, whether able or disabled as far as is practicable within a mainstream working environment. As far as resources allow, the needs of disabled employees and staff will be accounted for in the design and delivery of products/services.

The views of disabled employees and staff will be taken into consideration when their requirements are being assessed.

Marine Offshore Consultants will implement and regularly review accessibility plans aimed at:
– increasing the extent to which disabled employees can participate in company’s business;
– improving the physical environment to allow disabled employees to take best advantage of education, benefits and facilities provided; and
– improving the availability of accessible information to disabled employees.

So far as is reasonably practicable, Marine Offshore Consultants’ premises are accessible and safe so that disabled members of the community can participate in the activities performed there.

Background and overview

Key details
● Procedure prepared by: Neagu Camelia Viorica
● Approved by management: 24.05.2018
● Became operational on: 25.05.2018
● Next revision on: 25.05.2020

Context
This specific procedure appears in the context of the General Data Protection Regulation (GDPR) adopted on
April 27, 2016 and binding on May 25, 2018. GDPR is a European la on the protection of individuals with regard to the processing of personal data and on the free movement of such data in the European Union. It also refers to personal data exported to non-EU countries.

The protection provided by this Regulation refers to natural persons, alive, irrespective of their nationality or
place of residence, and refers to the processing of personal data. The Regulation does not cover the processing
of personal data of authorized persons or legal persons.

Introduction
Marine & Offshore Consultants SRL must collect and use certain personal data of employees and collaborators.

This data refers to the personal data of clients, collaborators, contacts of employees and other people with whom the organization is related.

This procedure describes how personal data is collected, handled and processed to meet the company’s data
protection standards, i.e. to comply with the law.

Why this procedure exists
This personal data protection procedure ensures that Marine & Offshore Consultants:
● Complies with the legal provisions on data protection and establishes rules of good practice in the field
● Protects the rights of employees, clients and partners
● It is transparent regarding the storage and processing of personal data
● Protects against the risk of personal data loss or theft

Personal data protection law
GDPR 679/2016 describes how organizations – including Marine & Offshore Consultants – must collect, manipulate and store personal information.

These rules apply regardless of storage mode, electronically, on paper or in other ways.

In order to comply with the legislation, personal information must be collected and used correctly, stored in secure places and not to be unlawfully disclosed.

GDPR is based on 8 important principles. They say that personal data must:
1. Be processed correctly and legally;
2. They are only obtained for legal and specific purposes;
3. Be either appropriate, relevant and not excessive;
4. Be correct and updated;
5. Do not be stored more than necessary;
6. Be processed in accordance with the rights of the persons involved;
7. Be properly protected;
8. They will not be transferred outside the European Economic Area, unless the country provides one
adequate level of protection.

Rights of individuals with regard to personal data
● Right to information – information on personal data processing may be requested at any time;
● Right to rectification – Inaccurate or incomplete personal data can be rectified;
● The right to delete the data (the “right to be forgotten”) – data can be erased if their processing was
not lawful or in other cases provided by law;
● Right to restrict processing – You may be required to restrict processing if it is disputed data accuracy, as well as in other cases provided by law;
● The right to object – may in particular oppose data processing that is based on the interest of the legitimate person;
● The right to portability of data – may, under certain conditions, receive the data provided in a format which may be read automatically or may be required to transmit that data to another operator;
● The right to file a complaint – one can complain about the way the data is processed personal data to the National Supervisory Authority for Personal Data Processing;
● Right of withdrawal of consent – in cases where processing is based on the consent of a person, it can be withdrawn at any time. Withdrawal of consent will only have effect for the future, processing prior to the withdrawal remaining valid;
● The right not to be subject to automatic or profiling decisions related to automated decisions: You
may require and obtain human intervention with respect to that processing, or you can express your
point of view about this type of processing.

 

 

 

 

People, risks and responsibilities

Purpose of the procedure
This procedure applies:
● Central Office of Marine & Offshore Consultants;
● All of the secondary offices and departments of Marine & Offshore Consultants;
● All employees and volunteers of Marine & Offshore Consultants;
● All contractors, suppliers and other people working from Marine & Offshore Consultants.

The procedure refers to all personal data owned by the company relating to individual / nominal persons.

These data include:
● Name and surname;
● Postal address;
● E-mail address;
● Phone numbers;
● Personal identification number;
● Date of birth;
● Identity Card Data;
● Civil status;
● Passport data;
● Statement;
● Studies, courses;
● Experience (CV);

Risks of data protection
This procedure protects Marine & Offshore Consultants from personal data security risks, identifying these risks and taking the necessary steps to adequately protect your personal data. So, for this purpose, Marine & Offshore Consultants highlights the main risks that may arise in protecting personal data:
● Violation of privacy rules. For example, mis-distribution of information;
● Deficiencies in offering alternatives. For example, everyone in the company must be free to
choose how personal data is used by the company;
● Damage to reputation. For example, the company suffers when hackers have access to the sensitive
data;

Responsibilities
All those who work for or with Marine & Offshore Consultants have the responsibility of providing personal data from their collection to handling and storage, according to GDPR.

Each team handling personal data must ensure that they are processed and handled in accordance with this procedure and with the legal principles of data protection.

However, the following persons have key responsibilities in data protection:
● Directors are first responsible for ensuring the legal protection of data at Marine & Offshore
Consultants;
● Human Resources Officer: keeps the personal data safe and up-to-date, handling personal data of employees and collaborators, periodically updating the responsibilities of directors for data protection, risk and problems,
periodic review of procedures and policies for personal data protection, informs employees and employees about the protection of personal data (see Annex 1 and Annex 2 Information on the protection of personal data of current and new employees), responds to questions from employees and collaborators about this procedure and GDPR, responds to employees and collaborators requests regarding data that Marine & Offshore Consultants owns (data request) and verifies and approves any contract or agreement with third parties that involves the use of sensitive data.
● IT responsible: ensures systems, services and equipment used to store personal data so as to meet legal security standards, periodically checks and scans hardware and software equipment and systems to ensure data security, evaluates third party services used by the company for the storage and processing of personal data. For example, cloud storage services.

 

 

 

 

General rules

The only people who have access to personal data are those who need this data to exercise their job.

Marine & Offshore Consultants will inform all employees and collaborators of how their personal data is used by the company and third parties, through an information note, making this procedure available, etc. (see Annex 1 – Initial Information of Employees on the Protection of Personal Data and Annex 2 – GDPR Agreement of New Employees).

Marine & Offshore Consultants processes the personal data of employees and collaborators who have
given their consent for this purpose, being properly informed of how data is used.

Personal data will not be distributed for informal purposes. When access to confidential information is
required, employees can ask the manager directly.

Marine & Offshore Consultants will ensure that employees are properly and fully informed in order to
help them understand the responsibility of handling the personal data.

Employees will keep their personal data safe, will be cautious and follow the specific procedure.

In addition, strong passwords will be used on any device with which they work and these passwords
should not be shared with others.

Personal data should not be disclosed to unauthorized persons, either within the company or outside.

Personal data must be updated periodically when it is found to be outdated. If they are no longer
needed, they can be deleted from the database or destroyed.

Employees will seek the help of the direct manager or human resource manager when they are not sure
about certain aspects of data protection.

Marine & Offshore Consultants nu proceseaza date personale sensibile (religie, orientare sexuala,
date genetice sau biometrice etc.).

Personal data processed by Marine & Offshore Consultants are required by law and can only be
accessed by authorized persons or by state institutions.

Everyone has the right to access their own personal data collected by Marine & Offshore Consultants
following a written request and at reasonable intervals to verify the lawfulness of the process.

Everyone has the right to update their personal data and the right to “forget” upon request, if the law
permits.

In Marine & Offshore Consultants personal data of employees and collaborators are analyzed manually,
they are not subject to automatic processing.

At Marine & Offshore Consultants, personal data is processed anonymously for direct marketing purposes.
Only marketing data and experience are used in marketing.

Principles of personal data protection by design and by default applies whenever personal data is processed.

As soon as Marine & Offshore Consultants finds out that it happened a breach of personal data
protection, it will notify the competent authorities of this breach, without delay and within 72 hours of
observation, if possible.

Marine & Offshore Consultants will communicate to the competent authorities and individuals involved a
personal data security breach, especially when this breach poses a high risk to a person’s rights and
freedoms, allowing him to take the necessary precautions.

The processing of sensitive personal data relating to race, ethnic origin, political opinions, religion,
philosophical beliefs of genetic or biometric data for the purpose of identifying a person, health or sex
life data is forbidden at Marine & Offshore Consultants.

 

 

 

 

Personal data storing

This paragraph describes how and where personal data should be kept so that it is safe. Questions about keeping personal data can be addressed directly to the IT manager or data processor (executives, accountants, human resources).

The data stored on the paper will be kept in a folder placed in a safe place, inaccessible to unauthorized persons.

This guide applies to electronically stored data but also to data printed on paper for various reasons:
● When not required, staff records are held in a safe, inaccessible, possibly locked place;
● Employees will be instructed not to leave behind documents that contain personal data, such as the
printer;
● When they are no longer needed, the papers containing personal data will be destroyed and discarded.

Electronically retained data will be protected from unauthorized access, accidental deletion, and hacker attack:
● Personal data will be protected with strong passwords that will be changed periodically and will not be
shared with other employees;
● When data is stored on mobile media (CD, DVD, USB), they will be locked securely when not in use;
● Personal data will be stored on specific drivers and servers and will only be saved on an approved cloud
storage service;
● Servers containing personal data are located in a safe place outside the office;
● Data is saved periodically on the server. These backups are regularly tested according to company
standards;
● Personal data will not be saved directly on your laptop or other mobile devices (tablets, smart phones);
● All servers and computers that contain personal data are protected by approved security software and
firewalls.

 

 

 

 

Using personal data

Personal data is irrelevant if Marine & Offshore Consultants can not use them. However, it will be taken into account that accessing personal data may result in their loss, theft or alteration.

When working with personal data, employees will ensure that they lock the computer / screen when they
are not around.

Personal information will not be shared for information purposes.

Data will be encrypted before being transferred electronically. The IT manager can explain to employees
how to send data to authorized external contacts.

Personal data is not transferred outside of the European Economic Area..

Employees will not save personal data in personal computers. Always access and update the
centralized data copy.

 

 

 

 

Data accuracy

The legislation in force requires Marine & Offshore Consultants to assume responsibility for the accuracy and correctness of personal data.

The accuracy and correctness of personal data is the responsibility of all employees.

Personal data will be kept in as few places as possible. Employees will not create unnecessary extra
copies.

Employees will benefit from every opportunity to ensure that personal data is accurate and complete. For example, they will update customer data when they call.

Marine &a Offshore Consultants will make it easier for you to update your personal data whenever possible. For example, through the company’s website.

Incorrect data will be erased. For example, when a customer can not be found at the phone number in
the database, it will be deleted.

The marketing manager or company directors will update the database every six months.

 

 

 

 

Applications for access to the database

All persons whose data appear in the Marine & Offshore Consultants database are entitled to:
● Ask what information the company has about them and why;
● Request access to personal data;
● Be informed about how to keep these accurate and updated data;
● Be informed about the company’s privacy policy.

When a person contacts the company asking for this information, the action is called an access request
(see Annex 3 – Application for Access to Personal Data).

Requests for access to personal data can be made by email addressed to the personal data processor (responsible human resources, accountants, directors) at office@marineoffshoreconsultants.com. The data processor may require a standard access form to be filled in.

Requests for access to personal data are not paid. The person processing the personal data will issue a response to the request within 14 business days.

The Data Controller will verify the identity of the person requesting the data before handing him any information.

 

 

 

 

Disclosure of personal data for other reasons

Under certain circumstances, the Personal Data Protection Act allows disclosure of personal data to legal institutions without the consent of the holder.

In such circumstances, Marine & Offshore Consultants will disclose the personal data requested by legal entities. In this case, the data controller will ensure that the request is legal.

 

 

 

 

Providing information

Marine & Offshore Consultants will ensure that company employees and collaborators understand how the
company processes personal data and understand:
● How to use personal data;
● How to exercise their rules.

Marine & Offshore Consultants owns the Privacy Statement that sets out how personal data is used by the company. This Statement is available on request. A version of this Statement, as well as the Privacy Policy, can be found on the company’s intranet and printed at the Reception Desk.

 

 

 

 

Initial information

Regarding the protection of personal data

Subordinated Marine & Offshore Consultants SRL, with headquarters in Constanta, Mamaia Blvd. 203 ap.8, J13/15/8.01.2013, CUI 31062445, phone +40241551515, based on art. 13 OF REGULATION (EU) 2016/679 OF
THE EUROPEAN PARLIAMENT AND THE COUNCIL/27 April 2016, we will inform you that we will collect and process your personal data requested for employment (name, email address, telephone number, home address, CNP, marital status, studies, experience, etc.) for the purpose of concluding the employment contract between you and the subscriber.

The legal basis for processing your personal data is – the conclusion and execution of a contract, and – the processing required to comply with the obligation, a legal obligation governed by labor law.

We inform you that the recipients of your personal data are the subscribed employees, the accounting department and human resources, but also the clients (who will be provided with your name, email address and telephone number when applicable), as well as state institutions and that we DO NOT intend to transfer these data to another company (marketing and advertising company).

The data will be stored for a specified period as long as there is a contract of employment in force and, in the
case of a dispute, during the settlement of the dispute and in accordance with the legislation in force as long as we have a legal obligation to keep contracts work, states and other legal documents in the accounting records and company archive.

We inform you that you have the right to request access to your personal data as well as rectification or erasure or restriction of processing under the law, as well as the right to complain to the supervisor if you believe that your rights have been disregarded.

We will establish technical and procedural measures to protect and ensure the confidentiality, integrity and accessibility of your personal data processed; prevent unauthorized use or access, and prevent personal data
breach, in accordance with applicable law.

All details on the collection, processing and storage of your personal data are in the GDPR Data Protection Procedure that can be accessed at any time in electronic or paper form.

Date: 25.05.2018

 

 

 

 

Data Processing Agreement According to GDPR

679/2016

Subordinated Marine & Offshore Consultants SRL, with headquarters in Constanta, Mamaia Blvd. 203 ap.8, J13/15 / 8.01.2013, CUI 31062445, phone +40241551515, based on art. 13 OF REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND THE COUNCIL / 27 April 2016, we will inform you that we will collect and
process your personal data requested for employment (name, email address, telephone number, home address, CNP, marital status, studies, experience, etc.) for the purpose of concluding the employment contract between you and the subscriber.

The legal basis for the processing of your personal data is the conclusion and performance of a contract as well
as the processing necessary to comply with the legal obligation, a legal obligation governed by labor law.

We inform you that the recipients of your personal data are the subscribed employees, the accounting department and human resources, but also the clients (who will be provided with your name, email address and telephone number) and state institutions, and that NO we intend to transfer these data to another company (marketing and advertising company). Also, CV data, especially those related to studies and experience, will be processed anonymously in case of collaborations with other companies (not marketing and advertising companies).

The data will be stored for a specified period as long as there is a contract of employment in force and, in the
case of a dispute, during the settlement of the dispute and in accordance with the legislation in force as long as we have a legal obligation to keep contracts work, states and other legal documents in the accounting records and company archive.

We inform you that you have the right to request access to your personal data as well as rectification or erasure or restriction of processing under the law, as well as the right to complain to the supervisor if you believe that your rights have been disregarded.

We will establish technical and procedural measures to protect and ensure the confidentiality, integrity and accessibility of your personal data processed; prevent unauthorized use or access, and prevent personal data
breach, in accordance with applicable law.

We mention that all details with regard to storage and process of personal data can be accessed anytime in the hard copy of GDPR Procedure (available on Reception).

STUDENTS COMPLAINTS POLICY

Definitions

Complaint
For the purposes of this policy a student complaint is “an expression of dissatisfaction by one or more students about provider’s action or lack of action, or about the service provided by or on behalf of the course provider.”

Feedback
A student may provide feedback which will be useful to a course provider when reviewing its policies and operations, without invoking this policy. Students are encouraged to provide feedback to the appropriate training provider in a prompt and constructive manner.

Who can use the Student Complaint Procedure?
Students applying for training courses provided by Marine Offshore Consultants may use this procedure.

This complaints procedure may only be used by an individual who is, or has been, registered as a student of Marine Offshore Consultants and who is not recorded as being a leaver (or, if they are a leaver, is complaining about events that occurred before they were a leaver, within the permitted timescales).

Applicants wishing to make a complaint should address the content of the current policy.

A group of students may use this procedure to make a collective complaint provided that one student identifies him/herself as the main contact for purposes of communication.

Anyone wishing to make a complaint is encouraged to do so personally. Where a third party (such as a company or direct manager) makes a complaint on behalf of a student, the student’s express written consent that the third party is acting on their behalf will be required. All correspondence will be copied to the student as well as to their representative unless otherwise agreed.

Anonymous complaints will not be considered unless there are exceptional and evidence-based reasons to do so. In many circumstances, raising a concern anonymously could impede investigation and communication of the outcome.

What issues constitute grounds for complaint under this policy?
The subject of the complaint should relate specifically to one or more of the following, or comparable, issues:
– failure of Marine Offshore Consultants to meet obligations including those outlined in course/student handbooks/brochures;
– misleading or incorrect information in prospectuses or promotional material and other information provided by the Marine Offshore Consultants;
– concerns about the delivery of a program, teaching, supervision or administration including, where applicable, that provided by a partner institution or contractor/trainer. (Please note: normally the student would be expected to follow the contractor/trainer institution’s complaints procedures in the first instance);
– poor quality of facilities, learning resources or services provided directly by Marine Offshore Consultants;
– complaints involving other third-parties or contractors providing a service on behalf of the University;
– complaints relating to allegations of bullying, harassment or victimisation by members of staff are associated with the Equality and Disability Policy within Marine Offshore Consultants and should be addressed to the Managing Director. If the complaint is within the scope of the Equality and Disability Policy and informal resolution is not appropriate then a formal investigation in accordance with the policy will be undertaken.

Complaints about the behaviour of students towards other students are to be treated separately with needed support provided by Marine Offshore Consultants.

What issues do not constitute grounds for complaint under this policy?
Challenges to the academic judgment of a member of staff and/or trainer. Cases where complaints are upheld and there has been a clear impact on an academic outcome may, however, lead to an academic conclusion e.g. allow a student a further attempt at an assessment.

A concern about a decision made by a member of staff and/or trainer regarding student progression, academic assessment and awards.

Dissatisfaction about the outcome of an academic misconduct or discipline process.

A concern about a decision made under specific regulations, such as fitness to practise.

A concern about the course provider’s decision relating to an extenuating circumstances claim on the basis of a procedural irregularity.

Principles of this policy
Complaints should be treated seriously and students must not suffer any disadvantage or recrimination as a result of making a complaint in good faith. However, students are required to abide by the principles of the present policy in making their complaint. It is expected that students and their representatives will conduct themselves responsibly and treat the complaints process and those members of Marine Offshore Consultants involved in the process with respect at all times.

In all cases, it is desirable that complaints are resolved informally and quickly between the relevant parties, and that the formal process is only started if that fails. Evidence of an attempt at informal resolution will be required.

Complaints must be substantiated with evidence, expressed in clear and succinct English and submitted within prescribed timescales.

Complaints submitted outside of the timescales stipulated in the procedure will only be considered in the most exceptional circumstances and where there is good reason, supported by evidence, for the late submission.
Marine Offshore Consultants is committed to ensuring that complaints are handled in accordance with its published procedure. Occasionally, it may be sensible for Marine Offshore Consultants to deviate from procedure if strict adherence to it could give rise to perceptions of prejudice or bias.

Complaint procedures are internal to a university and do not have the same degree of formality as a court of law. As such, legal representation in meetings is not necessary or appropriate for a student or Marine Offshore Consultants during the complaints process and will not, therefore, be permitted.
Complaints form part of Marine Offshore Consultants process of quality review and improvement and are considered as providing valuable feedback rather than criticism.

SECURITY AND HEALTH PROCUREMENT POLICY, ENVIRONMENT AND QUALITY

MOC is a group composed of the following four companies :
– SC Marine & Offshore Consultants SRL, active in the field of “Technical Consultancy, Industrial Inspection, Equip
ment Design, Construction, Processes, Risk Analysis, Maritime Warranty in Maritime, Petroleum and Gas and Renewable Energy, Sinking Services and Related Services of diving operations. “;
– SC Rosinav SRL, active in the field of “Design of systems and installations for the naval and industrial domains (3D modeling, technical and execution drawings); engineering studies of naval and offshore architecture”
– SC Solid Mechanichs & Environmental Engineering SRL, active in the field of Engineering for Fluid Mechanics and Structures of Resistance in Industrial, naval and offshore Engineering; environmental impact assessment;
– SC MOC Fabrication, active in the field of “Entrepreneurship in shipbuilding and floating structures”,

MOC has implemented and maintained an integrated management system in accordance with OHSAS 18001: 2007, SR EN ISO 14001: 2015 and SR EN ISO 9001: 2015, and will continue to improve this system by ensuring that the MOC Management System is communicated and understood clearly at all levels of the organization. MOC promises to comply with the applicable legislation and to ensure a safe work environment for all its employees. The implementation of our policies allows us to provide safe services to our clients. We also seek to guarantee the security of visitors, suppliers and the public that may be affected by our activity. Our policy is to allocate adequate resources to promote and maintain good practice in all aspects of work safety, environmental protection and quality.

The top management of all the companies in the group is committed to:
– Respect the applicable laws, regulations and other requirements;
– Prevent environmental pollution, work accidents and the delivery of non-compliant products to customers;
– Improve products and services to meet requirements as well as needs and future expectations;
– Continually improve the quality of the environment.
– Keep a safe job without incidents that can endanger people’s safety
– Enhance the Integrated Management System continuously, implementing new sets of “good practice”
– Ensure the existence and maintenance of work equipment so that their use is safe and free of risk
– To ensure the safety and minimization of risks (for people and for the environment) in the use, handling, storage of chemicals used to make the products of the organization;
– Provide sufficient information, instructions, training and supervision so as to ensure work safety and deliverable quality for all employees;
– Providing and maintaining safe escape routes.

MOC is committed to providing high-quality tertiary and reporting services that meet the requirements and expectations of our customers, as well as ensuring fast staff allocation and reporting in a timely manner.

It is the responsibility of all MOC employees to ensure that this engagement is obvious to both external and internal customers.

MOC will strive to set the standard for the use of new technologies, as well as to ensure the protection of the environment and the safety of all those involved.

Our commitment to continuous improvement and our customers and staff are tools for meeting our long-term
goals and maintaining a strong sense of confidence in our services.

Compliance with our customers’ requirements, specifications, national standards, and the quality requirements
described in this manual are all necessary to provide quality services to our customer.

To oversee the implementation of this policy and to achieve its objectives, management is committed to providing all the necessary natural and human resources.

This policy is reviewed annually to ensure applicability and is communicated to all employees.

STAFF POLICY

The company has defined the following policy to ensure that land and on-board staff of platforms and ships operate in an appropriate work environment, with full safety and health at work and respect for the environment.

The development of the business in terms of ensuring health and safety at work and protecting the environment is the strategic objective of the Company.

The Company’s Employee Policy is the following:
– equal opportunities are granted to all candidates irrespective of gender, religion, nationality;
– hiring is done on the basis of an interview and when there are several candidates on a job, is made on competition-base;
– the criteria for engagement are those of competence and professionalism;
– the hired personnel must have the qualifications required by national and international regulations in force and those mentioned in the job descriptions.

Organizational structures belonging to the Company will be provided with the competent personnel required by the national and international regulations in force.

The company ensures the medical and psychological monitoring of all staff.

The company’s policy on training, professionalism and personnel development is focused on the following:
– ensuring knowledge and compliance with the applicable integrated management system;
– identifying needs and appropriate forms of training and staff training;
– providing training on how to act in case of emergency;
– timely provision of the training required by the regulations in force and the development needs of thecompany;
– encouraging, promoting and rewarding staff who have achieved outstanding performance;
– promoting teamwork so that those with more experience in the Company’s activities share it with those with less;
– maintaining evidence of competence, training and staff experience. These will be submitted to the competent authorities whenever requested for verification. In any other case, they will be treated confidentially.

In order to continuously improve the integrated management system, management encourages the free exchange of ideas irrespective of the hierarchical position, being aware that this is one of the basic elements that ensure the success of the Company.

The company has established procedures for hiring staff, identifying training needs and ensuring appropriate training for all staff.

COMPANY’S POLICY ON ALCOHOL AND DRUG USE

Considering the harmful effect of alcohol and drug use on human health, the degree of danger of activities being carried out and the need for safe operation, the

Company has established and implemented this policy.

This policy applies to all persons (employees, partners or subcontractors, etc.) who operate at all work points operated by the Company, regardless of their position or hierarchical position.

The possession and consumption of alcohol is strictly forbidden at the work points operated by the Company.

Possession and drug use (hallucinogenic substances) is strictly forbidden at the work points operated by the Company.

Staff should not be under the influence of alcohol, having the obligation to present themselves in the fullness of psycho-physical skills at workplaces and / or at work points belonging to the Company.

Personnel who is under medical treatment and, on medical prescription, is in possession of drugs (drugs), must declare this to the medical staff of the Company and to the head of the working sector.

The Company reserves the right to carry out periodic checks using the alcohol tester and to ask the competent authorities for blood sampling to determine alcohol and drug presence in order to ensure that staff adhere to this Company policy.

THE COMPANY’S SMOKING POLICY

This document is issued based on the provisions of art. 19 lit. a of Law no. 307/2006 and in accordance with the provisions of art. 17 lit. c of the M.A.I. no. 163/2007 on General Norms for fire prevention and extinguishing on internal order.

This decision, based on the internal order and the rules of the company, regulates smoking on the territory of the company.

The terminology and the following technical definitions are assimilated:

The internal order from the fire prevention and extinction point of view of fire is the set of provisions to be established, enforced and respected within the economic agents before, during and at the end of activities characterized by specific fire risk factors.

Smoking is generally prohibited in all places there open fire is not permitted under these general provisions, as well as in:
a) common spaces or rooms;
b) rooms with electronic computing, measuring, control and automation equipment.

In all areas where smoking is forbidden, special alert indications for safety, as prescribed by the regulations in force will be installed.

At the company level there will be spaces where smoking is allowed, spaces equipped with ashtrays, sandbox and water reserve. These places are arranged in such a day that they do not have direct access to the production areas where smoking or open fire work is prohibited. These special places will be properly inscribed.

Smoking places outside buildings should not be located less than 40 m away from places where there is a risk of explosion (combustible gases and liquids, explosives, flammable vapors, etc.), 10 m from the places where combustible solid materials (wood, textiles, paper, asphalt, paints) exist.

Ashtrays and vases inside buildings (corridors, hallways, etc.) within the administrative building shall be placed in such a way that it is not possible to ignite the nearby combustible materials (curtains, curtains, blinds, etc.).

Throughout the society, in the bodies of existing buildings as well as in the yard of society, the throwing of cigarette scraps or burning matches at random is forbidden.

At the end of working hours, in offices where smoking is admitted, the worker before leaving the office has the obligation to empty the cigarette ashtrays after checking the contents of the ashtrays (no burning cigarette residues). Emptying ashtrays is forbidden to be done in the paper collection baskets.

The right to control the provisions of this Decision is: directors, department managers and PSI technical society.

This decision will be communicated to all staff.

CODE OF CONDUCT

Our Code of Conduct policy applies to all employees and provides the framework of principles for conducting business, dealing with other employees, Clients and suppliers. The Code of Conduct does not replace legislation and if any part of it is in conflict, then legislation takes precedence. This policy is based on the following:
– act and maintain a high standard of integrity and professionalism;
– be responsible and scrupulous in the proper use of Company information, funds, equipment and facilities;
– be considerate and respectful of the environment and others;
– exercise fairness, equality, courtesy, consideration and sensitivity in dealing with other employees, clients and suppliers;
– avoid apparent conflict of interests, promptly disclosing to a Marine & Offshore Consultants senior manager, any interest which may constitute a conflict of interest;
– promote the interests of Marine & Offshore Consultants;
– perform duties with skill, honesty, care and diligence;
– abide by policies, procedures and lawful directions that relate to your employment with Marine & Offshore Consultants and/or our Clients;
– avoid the perception that any business transaction may be influenced by offering or accepting gifts;
– under no circumstances may employees offer or accept money,
– any employee, who in good faith, raises a complaint or discloses an alleged breach of the Code, whilst following correct reporting procedures, will not be disadvantaged or prejudiced. All reports will be dealt with in a timely and confidential manner.

Marine & Offshore Consultants expects co-operation from all employees in conducting themselves in a professional, ethical and socially acceptable manner of the highest standards.

Any employee in breach of this policy may be subject to disciplinary action, including termination.

Should an employee have doubts about any aspect of the Code of Conduct, they must seek clarification from the HR Manager.

This policy will be regularly reviewed by Marine & Offshore Consultants and any necessary changes will be implemented by the HR Manager.

EQUALITY & DISABILITY

EQUALITY

S.C. Marine Offshore Consultants S.A. is committed to securing equality of opportunity through the creation of an environment in which individuals are treated solely based on their education, skills and experience.

We discourage all forms of unlawful or unfair discrimination on the grounds of age, race, color, nationality, ethnic origin, gender, marital status, sexual orientation, trade union membership, disability, political views and religious or similar philosophical beliefs, and aim to ensure equal treatment for all.

Marine Offshore Consultants aims:
– to provide an appropriate and inclusive working experience for all employees and partners, irrespective of their gender, race, origin or culture, disability, religion or belief;
– to provide a positive working environment which is free of prejudice and promotes equality of opportunity;
– to recognize and celebrate people’s differences to build and maintain a culture of respect and co-operation;
– to promote an active exchange of cultural background and good practices between employees;
– to protect its partners and employees from discrimination, harassment and victimization:
• through its HR and working policies and procedures,
• while providing services for clients on company’s behalf,
• by providing equal access to any benefit, facility or service to partners and staff.
– to promote and advance equality of opportunity between people who share a protected characteristic and people who do not share it and,
– to promote and foster good relations between people who share a protected characteristic and people who do not share it.

 

 

DISABILITY

Marine Offshore Consultants recognizes the definition of disability as when a person has a “physical or mental impairment which has a substantial and long term adverse effect on that person’s ability to carry out normal day to day activities.”

Marine Offshore Consultants is committed to a fair and equal treatment of all individuals regardless of disablement.

Marine Offshore Consultants will welcome applications from people with disabilities to join their team, programs and projects.

An applicant’s disability will not prevent him/her from being offered a place unless the content, structure and delivery of the work are such that the person would be prevented from fulfilling a major part of it; or Marine Offshore Consultants would be unable to provide suitable working conditions or facilities to allow the requirements of the activities to be met.

Marine & Offshore Consultants will provide flexible and equal access to all employees, whether able or disabled as far as is practicable within a mainstream working environment. As far as resources allow, the needs of disabled employees and staff will be accounted for in the design and delivery of products/services.

The views of disabled employees and staff will be taken into consideration when their requirements are being assessed.

Marine Offshore Consultants will implement and regularly review accessibility plans aimed at:
– increasing the extent to which disabled employees can participate in company’s business;
– improving the physical environment to allow disabled employees to take best advantage of education, benefits and facilities provided; and
– improving the availability of accessible information to disabled employees.

So far as is reasonably practicable, Marine Offshore Consultants’ premises are accessible and safe so that disabled members of the community can participate in the activities performed there.

DATA PROTECTION

Background and overview

Key details
● Procedure prepared by: Neagu Camelia Viorica
● Approved by management: 24.05.2018
● Became operational on: 25.05.2018
● Next revision on: 25.05.2020

Context
This specific procedure appears in the context of the General Data Protection Regulation (GDPR) adopted on
April 27, 2016 and binding on May 25, 2018. GDPR is a European la on the protection of individuals with regard to the processing of personal data and on the free movement of such data in the European Union. It also refers to personal data exported to non-EU countries.

The protection provided by this Regulation refers to natural persons, alive, irrespective of their nationality or
place of residence, and refers to the processing of personal data. The Regulation does not cover the processing
of personal data of authorized persons or legal persons.

Introduction
Marine & Offshore Consultants SRL must collect and use certain personal data of employees and collaborators.

This data refers to the personal data of clients, collaborators, contacts of employees and other people with whom the organization is related.

This procedure describes how personal data is collected, handled and processed to meet the company’s data
protection standards, i.e. to comply with the law.

Why this procedure exists
This personal data protection procedure ensures that Marine & Offshore Consultants:
● Complies with the legal provisions on data protection and establishes rules of good practice in the field
● Protects the rights of employees, clients and partners
● It is transparent regarding the storage and processing of personal data
● Protects against the risk of personal data loss or theft

Personal data protection law
GDPR 679/2016 describes how organizations – including Marine & Offshore Consultants – must collect, manipulate and store personal information.

These rules apply regardless of storage mode, electronically, on paper or in other ways.

In order to comply with the legislation, personal information must be collected and used correctly, stored in secure places and not to be unlawfully disclosed.

GDPR is based on 8 important principles. They say that personal data must:
1. Be processed correctly and legally;
2. They are only obtained for legal and specific purposes;
3. Be either appropriate, relevant and not excessive;
4. Be correct and updated;
5. Do not be stored more than necessary;
6. Be processed in accordance with the rights of the persons involved;
7. Be properly protected;
8. They will not be transferred outside the European Economic Area, unless the country provides one
adequate level of protection.

Rights of individuals with regard to personal data
● Right to information – information on personal data processing may be requested at any time;
● Right to rectification – Inaccurate or incomplete personal data can be rectified;
● The right to delete the data (the “right to be forgotten”) – data can be erased if their processing was
not lawful or in other cases provided by law;
● Right to restrict processing – You may be required to restrict processing if it is disputed data accuracy, as well as in other cases provided by law;
● The right to object – may in particular oppose data processing that is based on the interest of the legitimate person;
● The right to portability of data – may, under certain conditions, receive the data provided in a format which may be read automatically or may be required to transmit that data to another operator;
● The right to file a complaint – one can complain about the way the data is processed personal data to the National Supervisory Authority for Personal Data Processing;
● Right of withdrawal of consent – in cases where processing is based on the consent of a person, it can be withdrawn at any time. Withdrawal of consent will only have effect for the future, processing prior to the withdrawal remaining valid;
● The right not to be subject to automatic or profiling decisions related to automated decisions: You
may require and obtain human intervention with respect to that processing, or you can express your
point of view about this type of processing.

 

 

 

 

People, risks and responsibilities

Purpose of the procedure
This procedure applies:
● Central Office of Marine & Offshore Consultants;
● All of the secondary offices and departments of Marine & Offshore Consultants;
● All employees and volunteers of Marine & Offshore Consultants;
● All contractors, suppliers and other people working from Marine & Offshore Consultants.

The procedure refers to all personal data owned by the company relating to individual / nominal persons.

These data include:
● Name and surname;
● Postal address;
● E-mail address;
● Phone numbers;
● Personal identification number;
● Date of birth;
● Identity Card Data;
● Civil status;
● Passport data;
● Statement;
● Studies, courses;
● Experience (CV);

Risks of data protection
This procedure protects Marine & Offshore Consultants from personal data security risks, identifying these risks and taking the necessary steps to adequately protect your personal data. So, for this purpose, Marine & Offshore Consultants highlights the main risks that may arise in protecting personal data:
● Violation of privacy rules. For example, mis-distribution of information;
● Deficiencies in offering alternatives. For example, everyone in the company must be free to
choose how personal data is used by the company;
● Damage to reputation. For example, the company suffers when hackers have access to the sensitive
data;

Responsibilities
All those who work for or with Marine & Offshore Consultants have the responsibility of providing personal data from their collection to handling and storage, according to GDPR.

Each team handling personal data must ensure that they are processed and handled in accordance with this procedure and with the legal principles of data protection.

However, the following persons have key responsibilities in data protection:
● Directors are first responsible for ensuring the legal protection of data at Marine & Offshore
Consultants;
● Human Resources Officer: keeps the personal data safe and up-to-date, handling personal data of employees and collaborators, periodically updating the responsibilities of directors for data protection, risk and problems,
periodic review of procedures and policies for personal data protection, informs employees and employees about the protection of personal data (see Annex 1 and Annex 2 Information on the protection of personal data of current and new employees), responds to questions from employees and collaborators about this procedure and GDPR, responds to employees and collaborators requests regarding data that Marine & Offshore Consultants owns (data request) and verifies and approves any contract or agreement with third parties that involves the use of sensitive data.
● IT responsible: ensures systems, services and equipment used to store personal data so as to meet legal security standards, periodically checks and scans hardware and software equipment and systems to ensure data security, evaluates third party services used by the company for the storage and processing of personal data. For example, cloud storage services.

 

 

 

 

General rules

The only people who have access to personal data are those who need this data to exercise their job.

Marine & Offshore Consultants will inform all employees and collaborators of how their personal data is used by the company and third parties, through an information note, making this procedure available, etc. (see Annex 1 – Initial Information of Employees on the Protection of Personal Data and Annex 2 – GDPR Agreement of New Employees).

Marine & Offshore Consultants processes the personal data of employees and collaborators who have
given their consent for this purpose, being properly informed of how data is used.

Personal data will not be distributed for informal purposes. When access to confidential information is
required, employees can ask the manager directly.

Marine & Offshore Consultants will ensure that employees are properly and fully informed in order to
help them understand the responsibility of handling the personal data.

Employees will keep their personal data safe, will be cautious and follow the specific procedure.

In addition, strong passwords will be used on any device with which they work and these passwords
should not be shared with others.

Personal data should not be disclosed to unauthorized persons, either within the company or outside.

Personal data must be updated periodically when it is found to be outdated. If they are no longer
needed, they can be deleted from the database or destroyed.

Employees will seek the help of the direct manager or human resource manager when they are not sure
about certain aspects of data protection.

Marine & Offshore Consultants nu proceseaza date personale sensibile (religie, orientare sexuala,
date genetice sau biometrice etc.).

Personal data processed by Marine & Offshore Consultants are required by law and can only be
accessed by authorized persons or by state institutions.

Everyone has the right to access their own personal data collected by Marine & Offshore Consultants
following a written request and at reasonable intervals to verify the lawfulness of the process.

Everyone has the right to update their personal data and the right to “forget” upon request, if the law
permits.

In Marine & Offshore Consultants personal data of employees and collaborators are analyzed manually,
they are not subject to automatic processing.

At Marine & Offshore Consultants, personal data is processed anonymously for direct marketing purposes.
Only marketing data and experience are used in marketing.

Principles of personal data protection by design and by default applies whenever personal data is processed.

As soon as Marine & Offshore Consultants finds out that it happened a breach of personal data
protection, it will notify the competent authorities of this breach, without delay and within 72 hours of
observation, if possible.

Marine & Offshore Consultants will communicate to the competent authorities and individuals involved a
personal data security breach, especially when this breach poses a high risk to a person’s rights and
freedoms, allowing him to take the necessary precautions.

The processing of sensitive personal data relating to race, ethnic origin, political opinions, religion,
philosophical beliefs of genetic or biometric data for the purpose of identifying a person, health or sex
life data is forbidden at Marine & Offshore Consultants.

 

 

 

 

Personal data storing

This paragraph describes how and where personal data should be kept so that it is safe. Questions about keeping personal data can be addressed directly to the IT manager or data processor (executives, accountants, human resources).

The data stored on the paper will be kept in a folder placed in a safe place, inaccessible to unauthorized persons.

This guide applies to electronically stored data but also to data printed on paper for various reasons:
● When not required, staff records are held in a safe, inaccessible, possibly locked place;
● Employees will be instructed not to leave behind documents that contain personal data, such as the
printer;
● When they are no longer needed, the papers containing personal data will be destroyed and discarded.

Electronically retained data will be protected from unauthorized access, accidental deletion, and hacker attack:
● Personal data will be protected with strong passwords that will be changed periodically and will not be
shared with other employees;
● When data is stored on mobile media (CD, DVD, USB), they will be locked securely when not in use;
● Personal data will be stored on specific drivers and servers and will only be saved on an approved cloud
storage service;
● Servers containing personal data are located in a safe place outside the office;
● Data is saved periodically on the server. These backups are regularly tested according to company
standards;
● Personal data will not be saved directly on your laptop or other mobile devices (tablets, smart phones);
● All servers and computers that contain personal data are protected by approved security software and
firewalls.

 

 

 

 

Using personal data

Personal data is irrelevant if Marine & Offshore Consultants can not use them. However, it will be taken into account that accessing personal data may result in their loss, theft or alteration.

When working with personal data, employees will ensure that they lock the computer / screen when they
are not around.

Personal information will not be shared for information purposes.

Data will be encrypted before being transferred electronically. The IT manager can explain to employees
how to send data to authorized external contacts.

Personal data is not transferred outside of the European Economic Area..

Employees will not save personal data in personal computers. Always access and update the
centralized data copy.

 

 

 

 

Data accuracy

The legislation in force requires Marine & Offshore Consultants to assume responsibility for the accuracy and correctness of personal data.

The accuracy and correctness of personal data is the responsibility of all employees.

Personal data will be kept in as few places as possible. Employees will not create unnecessary extra
copies.

Employees will benefit from every opportunity to ensure that personal data is accurate and complete. For example, they will update customer data when they call.

Marine &a Offshore Consultants will make it easier for you to update your personal data whenever possible. For example, through the company’s website.

Incorrect data will be erased. For example, when a customer can not be found at the phone number in
the database, it will be deleted.

The marketing manager or company directors will update the database every six months.

 

 

 

 

Applications for access to the database

All persons whose data appear in the Marine & Offshore Consultants database are entitled to:
● Ask what information the company has about them and why;
● Request access to personal data;
● Be informed about how to keep these accurate and updated data;
● Be informed about the company’s privacy policy.

When a person contacts the company asking for this information, the action is called an access request
(see Annex 3 – Application for Access to Personal Data).

Requests for access to personal data can be made by email addressed to the personal data processor (responsible human resources, accountants, directors) at office@marineoffshoreconsultants.com. The data processor may require a standard access form to be filled in.

Requests for access to personal data are not paid. The person processing the personal data will issue a response to the request within 14 business days.

The Data Controller will verify the identity of the person requesting the data before handing him any information.

 

 

 

 

Disclosure of personal data for other reasons

Under certain circumstances, the Personal Data Protection Act allows disclosure of personal data to legal institutions without the consent of the holder.

In such circumstances, Marine & Offshore Consultants will disclose the personal data requested by legal entities. In this case, the data controller will ensure that the request is legal.

 

 

 

 

Providing information

Marine & Offshore Consultants will ensure that company employees and collaborators understand how the
company processes personal data and understand:
● How to use personal data;
● How to exercise their rules.

Marine & Offshore Consultants owns the Privacy Statement that sets out how personal data is used by the company. This Statement is available on request. A version of this Statement, as well as the Privacy Policy, can be found on the company’s intranet and printed at the Reception Desk.

 

 

 

 

Initial information

Regarding the protection of personal data

Subordinated Marine & Offshore Consultants SRL, with headquarters in Constanta, Mamaia Blvd. 203 ap.8, J13/15/8.01.2013, CUI 31062445, phone +40241551515, based on art. 13 OF REGULATION (EU) 2016/679 OF
THE EUROPEAN PARLIAMENT AND THE COUNCIL/27 April 2016, we will inform you that we will collect and process your personal data requested for employment (name, email address, telephone number, home address, CNP, marital status, studies, experience, etc.) for the purpose of concluding the employment contract between you and the subscriber.

The legal basis for processing your personal data is – the conclusion and execution of a contract, and – the processing required to comply with the obligation, a legal obligation governed by labor law.

We inform you that the recipients of your personal data are the subscribed employees, the accounting department and human resources, but also the clients (who will be provided with your name, email address and telephone number when applicable), as well as state institutions and that we DO NOT intend to transfer these data to another company (marketing and advertising company).

The data will be stored for a specified period as long as there is a contract of employment in force and, in the
case of a dispute, during the settlement of the dispute and in accordance with the legislation in force as long as we have a legal obligation to keep contracts work, states and other legal documents in the accounting records and company archive.

We inform you that you have the right to request access to your personal data as well as rectification or erasure or restriction of processing under the law, as well as the right to complain to the supervisor if you believe that your rights have been disregarded.

We will establish technical and procedural measures to protect and ensure the confidentiality, integrity and accessibility of your personal data processed; prevent unauthorized use or access, and prevent personal data
breach, in accordance with applicable law.

All details on the collection, processing and storage of your personal data are in the GDPR Data Protection Procedure that can be accessed at any time in electronic or paper form.

Date: 25.05.2018

 

 

 

 

Data Processing Agreement According to GDPR

679/2016

Subordinated Marine & Offshore Consultants SRL, with headquarters in Constanta, Mamaia Blvd. 203 ap.8, J13/15 / 8.01.2013, CUI 31062445, phone +40241551515, based on art. 13 OF REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND THE COUNCIL / 27 April 2016, we will inform you that we will collect and
process your personal data requested for employment (name, email address, telephone number, home address, CNP, marital status, studies, experience, etc.) for the purpose of concluding the employment contract between you and the subscriber.

The legal basis for the processing of your personal data is the conclusion and performance of a contract as well
as the processing necessary to comply with the legal obligation, a legal obligation governed by labor law.

We inform you that the recipients of your personal data are the subscribed employees, the accounting department and human resources, but also the clients (who will be provided with your name, email address and telephone number) and state institutions, and that NO we intend to transfer these data to another company (marketing and advertising company). Also, CV data, especially those related to studies and experience, will be processed anonymously in case of collaborations with other companies (not marketing and advertising companies).

The data will be stored for a specified period as long as there is a contract of employment in force and, in the
case of a dispute, during the settlement of the dispute and in accordance with the legislation in force as long as we have a legal obligation to keep contracts work, states and other legal documents in the accounting records and company archive.

We inform you that you have the right to request access to your personal data as well as rectification or erasure or restriction of processing under the law, as well as the right to complain to the supervisor if you believe that your rights have been disregarded.

We will establish technical and procedural measures to protect and ensure the confidentiality, integrity and accessibility of your personal data processed; prevent unauthorized use or access, and prevent personal data
breach, in accordance with applicable law.

We mention that all details with regard to storage and process of personal data can be accessed anytime in the hard copy of GDPR Procedure (available on Reception).

STUDENTS COMPLAINTS

STUDENTS COMPLAINTS POLICY

Definitions

Complaint
For the purposes of this policy a student complaint is “an expression of dissatisfaction by one or more students about provider’s action or lack of action, or about the service provided by or on behalf of the course provider.”

Feedback
A student may provide feedback which will be useful to a course provider when reviewing its policies and operations, without invoking this policy. Students are encouraged to provide feedback to the appropriate training provider in a prompt and constructive manner.

Who can use the Student Complaint Procedure?
Students applying for training courses provided by Marine Offshore Consultants may use this procedure.

This complaints procedure may only be used by an individual who is, or has been, registered as a student of Marine Offshore Consultants and who is not recorded as being a leaver (or, if they are a leaver, is complaining about events that occurred before they were a leaver, within the permitted timescales).

Applicants wishing to make a complaint should address the content of the current policy.

A group of students may use this procedure to make a collective complaint provided that one student identifies him/herself as the main contact for purposes of communication.

Anyone wishing to make a complaint is encouraged to do so personally. Where a third party (such as a company or direct manager) makes a complaint on behalf of a student, the student’s express written consent that the third party is acting on their behalf will be required. All correspondence will be copied to the student as well as to their representative unless otherwise agreed.

Anonymous complaints will not be considered unless there are exceptional and evidence-based reasons to do so. In many circumstances, raising a concern anonymously could impede investigation and communication of the outcome.

What issues constitute grounds for complaint under this policy?
The subject of the complaint should relate specifically to one or more of the following, or comparable, issues:
– failure of Marine Offshore Consultants to meet obligations including those outlined in course/student handbooks/brochures;
– misleading or incorrect information in prospectuses or promotional material and other information provided by the Marine Offshore Consultants;
– concerns about the delivery of a program, teaching, supervision or administration including, where applicable, that provided by a partner institution or contractor/trainer. (Please note: normally the student would be expected to follow the contractor/trainer institution’s complaints procedures in the first instance);
– poor quality of facilities, learning resources or services provided directly by Marine Offshore Consultants;
– complaints involving other third-parties or contractors providing a service on behalf of the University;
– complaints relating to allegations of bullying, harassment or victimisation by members of staff are associated with the Equality and Disability Policy within Marine Offshore Consultants and should be addressed to the Managing Director. If the complaint is within the scope of the Equality and Disability Policy and informal resolution is not appropriate then a formal investigation in accordance with the policy will be undertaken.

Complaints about the behaviour of students towards other students are to be treated separately with needed support provided by Marine Offshore Consultants.

What issues do not constitute grounds for complaint under this policy?
Challenges to the academic judgment of a member of staff and/or trainer. Cases where complaints are upheld and there has been a clear impact on an academic outcome may, however, lead to an academic conclusion e.g. allow a student a further attempt at an assessment.

A concern about a decision made by a member of staff and/or trainer regarding student progression, academic assessment and awards.

Dissatisfaction about the outcome of an academic misconduct or discipline process.

A concern about a decision made under specific regulations, such as fitness to practise.

A concern about the course provider’s decision relating to an extenuating circumstances claim on the basis of a procedural irregularity.

Principles of this policy
Complaints should be treated seriously and students must not suffer any disadvantage or recrimination as a result of making a complaint in good faith. However, students are required to abide by the principles of the present policy in making their complaint. It is expected that students and their representatives will conduct themselves responsibly and treat the complaints process and those members of Marine Offshore Consultants involved in the process with respect at all times.

In all cases, it is desirable that complaints are resolved informally and quickly between the relevant parties, and that the formal process is only started if that fails. Evidence of an attempt at informal resolution will be required.

Complaints must be substantiated with evidence, expressed in clear and succinct English and submitted within prescribed timescales.

Complaints submitted outside of the timescales stipulated in the procedure will only be considered in the most exceptional circumstances and where there is good reason, supported by evidence, for the late submission.
Marine Offshore Consultants is committed to ensuring that complaints are handled in accordance with its published procedure. Occasionally, it may be sensible for Marine Offshore Consultants to deviate from procedure if strict adherence to it could give rise to perceptions of prejudice or bias.

Complaint procedures are internal to a university and do not have the same degree of formality as a court of law. As such, legal representation in meetings is not necessary or appropriate for a student or Marine Offshore Consultants during the complaints process and will not, therefore, be permitted.
Complaints form part of Marine Offshore Consultants process of quality review and improvement and are considered as providing valuable feedback rather than criticism.

HSEQ

SECURITY AND HEALTH PROCUREMENT POLICY, ENVIRONMENT AND QUALITY

MOC is a group composed of the following four companies :
– SC Marine & Offshore Consultants SRL, active in the field of “Technical Consultancy, Industrial Inspection, Equipment Design, Construction, Processes, Risk Analysis, Maritime Warranty in Maritime, Petroleum and Gas and Renewable Energy, Sinking Services and Related Services of diving operations. “;
– SC Rosinav SRL, active in the field of “Design of systems and installations for the naval and industrial domains (3D modeling, technical and execution drawings); engineering studies of naval and offshore architecture”
– SC Solid Mechanichs & Environmental Engineering SRL, active in the field of Engineering for Fluid Mechanics and Structures of Resistance in Industrial, naval and offshore Engineering; environmental impact assessment;
– SC MOC Fabrication, active in the field of “Entrepreneurship in shipbuilding and floating structures”,

MOC has implemented and maintained an integrated management system in accordance with OHSAS 18001: 2007, SR EN ISO 14001: 2015 and SR EN ISO 9001: 2015, and will continue to improve this system by ensuring that the MOC Management System is communicated and understood clearly at all levels of the organization. MOC promises to comply with the applicable legislation and to ensure a safe work environment for all its employees. The implementation of our policies allows us to provide safe services to our clients. We also seek to guarantee the security of visitors, suppliers and the public that may be affected by our activity. Our policy is to allocate adequate resources to promote and maintain good practice in all aspects of work safety, environmental protection and quality.

The top management of all the companies in the group is committed to:
– Respect the applicable laws, regulations and other requirements;
– Prevent environmental pollution, work accidents and the delivery of non-compliant products to customers;
– Improve products and services to meet requirements as well as needs and future expectations;
– Continually improve the quality of the environment.
– Keep a safe job without incidents that can endanger people’s safety
– Enhance the Integrated Management System continuously, implementing new sets of “good practice”
– Ensure the existence and maintenance of work equipment so that their use is safe and free of risk
– To ensure the safety and minimization of risks (for people and for the environment) in the use, handling, storage of chemicals used to make the products of the organization;
– Provide sufficient information, instructions, training and supervision so as to ensure work safety and deliverable quality for all employees;
– Providing and maintaining safe escape routes.

MOC is committed to providing high-quality tertiary and reporting services that meet the requirements and expectations of our customers, as well as ensuring fast staff allocation and reporting in a timely manner.

It is the responsibility of all MOC employees to ensure that this engagement is obvious to both external and internal customers.

MOC will strive to set the standard for the use of new technologies, as well as to ensure the protection of the environment and the safety of all those involved.

Our commitment to continuous improvement and our customers and staff are tools for meeting our long-term
goals and maintaining a strong sense of confidence in our services.

Compliance with our customers’ requirements, specifications, national standards, and the quality requirements described in this manual are all necessary to provide quality services to our customer.

To oversee the implementation of this policy and to achieve its objectives, management is committed to providing all the necessary natural and human resources.

This policy is reviewed annually to ensure applicability and is communicated to all employees.

STAFF POLICY

STAFF POLOCY

The company has defined the following policy to ensure that land and on-board staff of platforms and ships operate in an appropriate work environment, with full safety and health at work and respect for the environment.

The development of the business in terms of ensuring health and safety at work and protecting the environment is the strategic objective of the Company.

The Company’s Employee Policy is the following:
– equal opportunities are granted to all candidates irrespective of gender, religion, nationality;
– hiring is done on the basis of an interview and when there are several candidates on a job, is made on competition-base;
– the criteria for engagement are those of competence and professionalism;
– the hired personnel must have the qualifications required by national and international regulations in force and those mentioned in the job descriptions.

Organizational structures belonging to the Company will be provided with the competent personnel required by the national and international regulations in force.

The company ensures the medical and psychological monitoring of all staff.

The company’s policy on training, professionalism and personnel development is focused on the following:
– ensuring knowledge and compliance with the applicable integrated management system;
– identifying needs and appropriate forms of training and staff training;
– providing training on how to act in case of emergency;
– timely provision of the training required by the regulations in force and the development needs of thecompany;
– encouraging, promoting and rewarding staff who have achieved outstanding performance;
– promoting teamwork so that those with more experience in the Company’s activities share it with those with less;
– maintaining evidence of competence, training and staff experience. These will be submitted to the competent authorities whenever requested for verification. In any other case, they will be treated confidentially.

In order to continuously improve the integrated management system, management encourages the free exchange of ideas irrespective of the hierarchical position, being aware that this is one of the basic elements that ensure the success of the Company.

The company has established procedures for hiring staff, identifying training needs and ensuring appropriate training for all staff.

ALCOHOL & DRUGS

COMPANY’S POLICY ON ALCOHOL AND DRUG USE

Considering the harmful effect of alcohol and drug use on human health, the degree of danger of activities being carried out and the need for safe operation, the Company has established and implemented this policy.

This policy applies to all persons (employees, partners or subcontractors, etc.) who operate at all work points operated by the Company, regardless of their position or hierarchical position.

The possession and consumption of alcohol is strictly forbidden at the work points operated by the Company.

Possession and drug use (hallucinogenic substances) is strictly forbidden at the work points operated by the Company.

Staff should not be under the influence of alcohol, having the obligation to present themselves in the fullness of psycho-physical skills at workplaces and / or at work points belonging to the Company.

Personnel who is under medical treatment and, on medical prescription, is in possession of drugs (drugs), must declare this to the medical staff of the Company and to the head of the working sector.

The Company reserves the right to carry out periodic checks using the alcohol tester and to ask the competent authorities for blood sampling to determine alcohol and drug presence in order to ensure that staff adhere to this Company policy.

SMOKE

THE COMPANY’S SMOKING POLICY

This document is issued based on the provisions of art. 19 lit. a of Law no. 307/2006 and in accordance with the provisions of art. 17 lit. c of the M.A.I. no. 163/2007 on General Norms for fire prevention and extinguishing on internal order.

This decision, based on the internal order and the rules of the company, regulates smoking on the territory of the company.

The terminology and the following technical definitions are assimilated:

The internal order from the fire prevention and extinction point of view of fire is the set of provisions to be established, enforced and respected within the economic agents before, during and at the end of activities characterized by specific fire risk factors.

Smoking is generally prohibited in all places there open fire is not permitted under these general provisions, as well as in:
a) common spaces or rooms;
b) rooms with electronic computing, measuring, control and automation equipment.

In all areas where smoking is forbidden, special alert indications for safety, as prescribed by the regulations in force will be installed.

At the company level there will be spaces where smoking is allowed, spaces equipped with ashtrays, sandbox and water reserve. These places are arranged in such a day that they do not have direct access to the production areas where smoking or open fire work is prohibited. These special places will be properly inscribed.

Smoking places outside buildings should not be located less than 40 m away from places where there is a risk of explosion (combustible gases and liquids, explosives, flammable vapors, etc.), 10 m from the places where combustible solid materials (wood, textiles, paper, asphalt, paints) exist.

Ashtrays and vases inside buildings (corridors, hallways, etc.) within the administrative building shall be placed in such a way that it is not possible to ignite the nearby combustible materials (curtains, curtains, blinds, etc.).

Throughout the society, in the bodies of existing buildings as well as in the yard of society, the throwing of cigarette scraps or burning matches at random is forbidden.

At the end of working hours, in offices where smoking is admitted, the worker before leaving the office has the obligation to empty the cigarette ashtrays after checking the contents of the ashtrays (no burning cigarette residues). Emptying ashtrays is forbidden to be done in the paper collection baskets.

The right to control the provisions of this Decision is: directors, department managers and PSI technical society.

This decision will be communicated to all staff.

HR

CODE OF CONDUCT

Our Code of Conduct policy applies to all employees and provides the framework of principles for conducting business, dealing with other employees, Clients and suppliers. The Code of Conduct does not replace legislation and if any part of it is in conflict, then legislation takes precedence. This policy is based on the following:
– act and maintain a high standard of integrity and professionalism;
– be responsible and scrupulous in the proper use of Company information, funds, equipment and facilities;
– be considerate and respectful of the environment and others;
– exercise fairness, equality, courtesy, consideration and sensitivity in dealing with other employees, clients and suppliers;
– avoid apparent conflict of interests, promptly disclosing to a Marine & Offshore Consultants senior manager, any interest which may constitute a conflict of interest;
– promote the interests of Marine & Offshore Consultants;
– perform duties with skill, honesty, care and diligence;
– abide by policies, procedures and lawful directions that relate to your employment with Marine & Offshore Consultants and/or our Clients;
– avoid the perception that any business transaction may be influenced by offering or accepting gifts;
– under no circumstances may employees offer or accept money,
– any employee, who in good faith, raises a complaint or discloses an alleged breach of the Code, whilst following correct reporting procedures, will not be disadvantaged or prejudiced. All reports will be dealt with in a timely and confidential manner.

Marine & Offshore Consultants expects co-operation from all employees in conducting themselves in a professional, ethical and socially acceptable manner of the highest standards.

Any employee in breach of this policy may be subject to disciplinary action, including termination.

Should an employee have doubts about any aspect of the Code of Conduct, they must seek clarification from the HR Manager.

This policy will be regularly reviewed by Marine & Offshore Consultants and any necessary changes will be implemented by the HR Manager.

14, Stucley Road, Osterley, Hounslow,
United Kingdom, TW5 0TN

office@moc-group.com
+44 203 936 3020