DRUG POLICY

As a prudent and responsible ship management company, Union Commercial condemns any and all drug involvement, and is committed to preventing drugs onboard the company's vessels. The company works as closely as possible with Customs and other authorities in their efforts to stamp out the use of illegal drugs.

All company vessels are supplied with various posters, notices, leaflets and detailed instructions relating to prevention of drug smuggling and abuse. Upon signing on, crews are familiarized with existing regulations and other material available on board. Diligent drug searches are carried out at random intervals and when required.

ALCOHOL POLICY

Union Commercial, expressly calls its employees' attention to the United States Code of Federal Regulations, Title 33, Part 95, effective January 13, 1988: "No intoxicants may be consumed within four hours of any scheduled work, nor may there be intoxicated crew members aboard the vessel at any time, nor may a crew member consume intoxicants while on watch duty."

In case of violation, the company is authorized and entitled to terminate the Shipboard Employment Contract for cause and without any previous notice.