Blu Navy SERVICE CHARTER. Ver. 20 th January 2017

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1 lu Navy SERVICE CHARTER Ver. 20 th January 2017 N di Navigazione s.p.a. Piazza Virgilio Portoferraio (Livorno) Call Centre: Fax info@blunavytraghetti.com

2 The Service Charter, which applies to the transportation sector, confirms the guarantee of citizens freedom of mobility envisaged in Art. 16 of the Italian Constitution, all citizens have the right of free movement and residence in any part of Italian territory, all citizens are free to leave the territory of the Italian Republic and to re- enter ; together with Art. 8 of the Maastricht Treaty, all citizens of the European Union have the right of free movement and residence within the territory of the Member States. Additionally, the Service Charter, which is developed annually, serves, most importantly, as the communication and information tool, through which lu Navy commits to guarantee compliance with certain quality standards for the service offered. The subsequent pages describe the values of lu Navy, the quality indicators and objectives, the communication channels with the community, and useful information on the services offered.

3 Charter Structure: Section I: Fundamental Principles of the Charter lu Navy Presentation Section II: Quality of the Service Offered 2017 Quality Objectives Section III: Passenger Relationship Dialogue Procedure: Complaints, Reimbursements, and Compensation Accessibility for Individuals with Reduced Mobility

4 SECTION I: 1. Fundamental Principles of the Charter In offering its service, lu Navy observes the Navigation Code, the specific rules in the General Transportation Conditions, and commits to provide its maritime transportation service in compliance with the following fundamental principles: 1.1 Equality and Impartiality - The service is provided in accordance with the principle of equal rights of users and employees, excluding and prosecuting any discrimination based on gender, race, language, religion, and political opinions. The equal treatment principle is consistent with forms of differentiated tariffs (ordinary and residential) that are applied based on objective and known criteria. - The Company adopts initiatives aimed at continually improving the accessibility of services for each type of user (disabled individuals, senior citizens, pregnant women). More generally, the conduct of the business toward users is guided by criteria of objectivity, justice, and impartiality. 1.2 Continuity - Service is guaranteed to be provided with continuity, regularity, and without interruption, except in the event of circumstances outside the control of the Company. - In case of labour strikes, information regarding the minimum guaranteed services will be communicated in the timeliest manner possible. This commitment is objectively conditioned by the behaviour of third parties toward the Company. Under conditions of irregular or absent functioning of the transportation service for reasons imputable to the Company, it adopts measures to inform passengers in order to cause as little inconvenience to the user as possible. 1.3 Participation - The passenger has access to information through the internet site, as well as the ticket office and business offices of the Company, which publish information and any changes to services offered. - The passenger can interact directly with the Company through the Call Centre. The Call Centre supports the customer in selecting his/her itinerary, offers logistical information, supports the reservation process, and gathers suggestions from users with regard to services offered. - The Company commits to strengthen this relationship with its passengers by periodically collecting evaluations and suggestions on the service according to the methods described in Section II of this Charter. 1.4 Efficiency and Efficacy - The Company s entire organisational process is aimed at improving efficiency and efficacy of the service offered. As such, business quality indicators will be adopted as referred to in Section II of this Charter. - lu Navy personnel wear uniforms and a badge so that passengers can easily recognise them, both on- board and on land. - With the specific intention of strengthening the relationship of trust between passengers and the Company, personnel are courteous, professional and seek to satisfy passengers needs, to the extent possible and in compliance with safety measures on- board. 1.5 Freedom of Choice - Access to information is strengthened and guaranteed through modern communication tools to facilitate passengers choice. - The Company operates transparently in the reference market, providing, where possible, information on additional solutions for the requested routes.

5 2. lu Navy Presentation lu Navy was established in 2010 with the objective of creating a RO- RO ferry to transport passengers and autos between Piombino and Elba Island. In 2010, the Company signed an important agreement with Associazione Albergatori Isola d Elba (Elba Island Association of Hotel Managers), which offers customers discounted tariffs. In 2013, the Associazione Albergatori Isola d Elba (Elba Island Association of Hotel Managers) became part of the ownership structure, along with the Elba Sol Group. The Company introduces various discounts on tariffs for residents and owners of second homes on Elba Island, which has enormous support from the local community. In 2014, lu Navy was publicly recognised for the punctuality of its connections with Elba Island. The Company is making significant investments in the commercial sector, participating in the largest domestic and international tourism fairs. In the initial months of 2015, the Acciarello passenger ship was purchased, and a complete re- styling of the lounge and bar were undertaken. The Company was the first to assist passengers on- board by introducing the role of the attendant. In the same year, the Company transferred its registered office from Milan to Elba Island, and transformed the legal structure from Srl to SpA. eginning in 2015, lu Navy launched a process for ensuring the quality standards necessary for a healthy and safe working environment for our employees/sailors, and hence also for our passengers. These procedures extend to the commercial sector and to the Company as a whole, in confirmation of its commitment to continually guarantee service that satisfies passengers, which the Company continues to pursue. The Company is committed to adopting a clear and formal business policy that observes Safety, Health and Quality on sea and on land. 2.1 Destinations and the Fleet lu Navy operates in the sector of maritime transport of persons and automobiles with Ro- Ro ferries, offering the following connections: The lu Navy fleet consists of 2 ferries: - Piombino- Portoferraio (Elba Island) Acciarello passenger ship Length: 113 metres Width: 18 metres Tonnage: 4,996 tonnes Passengers: 800 Autos: 220 Speed: 16 knots - Santa Teresa di Gallura onifacio (Sardinia - Corsica) Ichnusa passenger ship Length: 65 metres Width: 14 metres Tonnage: 2,181 tonnes Passengers: 350 Autos: 50 Speed: 15 knots

6 2.2 Social Commitment lu Navy, fully aware of its responsibility in this area, places the utmost emphasis on the safety and protection of the environment. The Company has established that all operations carried out by its personnel, both on land and on- board, must highlight the commitment to pursue the business objectives listed below: Avoid harm to individuals and loss of human life; Protect the environment, in particular, marine environments; Maintain the utmost level of technical and operational efficiency of ferries; Protect ferries and crew from the consequences of unlawful practices; Transport passengers safely and efficiently. 2.3 Safety The Company has the SM manual that serves to satisfy international quality standards for the safe management and operation of ferries, in regards to the environment and preventing pollution, as well as the safety of maritime personnel and passengers. The manual describes how the Company s policies are applied and represents a reference guide for all employees involved in the Company s activities.

7 SECTION II: 1. Quality of the Service Offered The Company focuses its operations on the service offered and passengers needs. In this context of continuous improvement, new and competitive quality objectives are set. 1.1 Quality Factors and Indicators / Standards In order to improve the service rendered, the Company has identified 10 quality factors as the basis for representing the quality level of the service provided, which began being measured in The quality factors constitute a significant aspect of the users perception of the transportation service quality. The factors identified are: 1. Trip safety 2. Personal and property safety of travellers 3. Regularity of the ferry service 4. Cleanliness and hygiene conditions on- board 5. Comfort of the trip 6. Information to customers 7. Relational and behavioural aspects of personnel who act as contact points with the Company; 8. Complaints 9. Attention to the environment 10. Additional on- board services, where envisaged Additional services are those extras that aim to improve users comfort (distributing newspapers on- board and at the ticket office windows, communicating information through loudspeakers, etc.). Some passenger areas may have televisions to make the trip more comfortable. 1.2 Monitoring Quality Standards Polls conducted of our passengers (customer satisfaction surveys) play an increasingly active role in defining the business strategies and allocation of available resources. Specifically, reporting and automated monitoring of customer satisfaction is defined as: - A tool to increase the quality of service provided as part of continuous improvement; - A tool for reasonable discourse regarding customers issues. It is in our own interest to prepare periodic reports on the situation of our lines, in terms of achieving the quality/functionality requirements that define a company as a leader in its sector. This entails the commitment of all of us to conduct customer satisfaction surveys based on a complete study. The assessment of the quality factors is performed through analyses of documents. Monitoring is carried out through the work of personnel who perform specific periodic reviews. 1.3 Privacy and Data Protection lu Navy commits to observe governing regulations regarding the protection and privacy of customer data (Italian Legislative Decree no. 196 of 30 June 2003), adopting all appropriate technical and organisational measures to safeguard said data.

8 SECTION III: 1. Passenger Relationship Since 2010, the Company offers maritime transportation services on its defined routes. As a result of the professionalism of the crews, the friendliness of staff, and the results achieved, lu Navy has established itself in the market and is growing in terms of the fleet as well as in terms of its passenger relationship. Upon purchasing a travel ticket, the passenger and the Company begin a relationship characterised by reciprocal rights and obligations. The focus on the customer means that lu Navy commits not only to place the maximum attention on service efficiency, but also to ensure that the trip is comfortable and enjoyable, to the extent possible. The fleet renewal process is aimed at improving comfort factors: ü ü ü Creating spaces where passengers can sit in comfortable armchairs; Using ferries that ensure convenient boarding and landing of vehicles; Restructuring areas dedicated to on- board services Passenger Rights and Obligations The Company seeks to safeguard, to the extent of its responsibilities, the following passengers rights: Trip safety Service continuity Transparency regarding routes and tariffs applied; Adherence to the schedule under favourable weather/sea conditions and with the exception of cases that are not the fault of the Company; Hygiene and cleanliness of ferries; Ability to identify personnel that have direct contact with the public; Compliance with the smoking ban on ferries. The passenger must respect the following obligations: Possess valid travel tickets; Occupy only one seat; Do not occupy seats reserved for individuals with reduced mobility; Comply with the smoking ban on ferries. Do not inflict damages of any type to the Company s ferries or premises; Do not disturb other travellers through improper conduct; Do not transport poisonous or dangerous materials; Do not misuse alarms or any other type of emergency device; Do not compromise trip safety and the service level in any way;

9 Comply with the provisions of the General Transportation Conditions and Safety Measures. 2. Dialogue Procedure: Complaints, Reimbursements, and Special oarding To request information on routes, services, discounted tariffs or for any other communication, the user may contact the Company as follows: Call Centre Calata Italia Portoferraio (Livorno) Call Centre: Fax info@blunavytraghetti.com info@blunavytraghetti.com Complaint Procedure If necessary, the passenger has the right to submit a complaint to the Company according to the provisions of governing regulations Total or Partial Cancellation of Tickets and Reimbursement A ticket cannot be replaced, under any circumstances, with another travel ticket having a different destination. Tickets issued at ordinary tariffs can be reimbursed provided that they are cancelled at least 24 hours prior to the scheduled departure. Reimbursements must be requested: (a) At ticket offices managed by the Carrier, for tickets purchased at one of such ticket offices or through the Carrier s internet site ( In this case, a special form will be sent to the requesting Passenger, that he/she must compile and send via to: rimborsi@blunavytraghetti.com; subsequently, the Carrier will make the reimbursement through a bank transfer; (b) At the reseller where the ticket was purchased, if the ticket was purchased through a travel agency, tour operator, ticket office not managed by the Carrier, and/or other types of resellers (including internet sites other than that of the Carrier). In this case, the reseller will make the reimbursement directly to the Passenger. The reimbursement of tickets on the Piombino- Portoferraio line is subject to the following fees: Curtailment of 10% for tickets cancelled within 30 days prior to the departure date; Curtailment of 20% for tickets cancelled within 10 days prior to the departure date; Curtailment of 30% for tickets cancelled within 48 hours prior to the departure date; Curtailment of 50% for tickets cancelled within 24 hours prior to the departure date. In calculating these fees, the ticket amount excludes booking charges. eginning 24 (twenty four) hours before department of the ferry, and up to 1 hour before, it will be possible to request the cancellation of tickets, however, the Passenger will not have the right to any reimbursement nor is he/she entitled to any other right and/or claim for said cancellation. No reimbursement will be made if: (i) The ticket was issued at a non- refundable tariff; (ii) The Passenger is not present at departure by the scheduled deadline for boarding; (iii) The ticket has not been cancelled according to the methods above at least 24 hours prior to departure. Rights deriving from the contract for the maritime transport of persons are prescribed with the time limits envisaged in the Navigation Code. The reimbursement of tickets on the Santa Teresa onifacio line is subject to the following fees:

10 Curtailment of 10% for tickets cancelled within 10 days prior to the departure date; Curtailment of 30% for tickets cancelled within 48 hours prior to the departure date; Curtailment of 50% for tickets cancelled within 12 hours prior to the departure date; eginning 12 (twelve) hours before department of the ferry, and up to 1 hour before, it will be possible to request the cancellation of tickets, however, the passenger will not have the right to any reimbursement nor is he/she entitled to any other right and/or claim for said cancellation. No reimbursement will be made if: (i) The ticket was issued at a non- refundable tariff; (ii) The passenger is not present at departure by the scheduled deadline for boarding; (iii) The ticket has not been cancelled according to the methods above at least 12 hours prior to departure. Rights deriving from the contract for the maritime transport of persons are prescribed with the time limits envisaged in the Navigation Code. Without prejudice to other provisions of applicable regulations, the financial compensation that the Company may owe to the Passenger in the event of arrival delays is calculated in relation to the ticket price paid and is guaranteed based on the minimum level pursuant to Art. 19 of EU Regulation no. 1177/2010. In any event, and without prejudice to any other legal exemptions where applicable, if the delay was caused by meteorological conditions that jeopardise the safe functioning of the ferry or by extraordinary circumstances that hinder the execution of the service, which were unavoidable even by adopting all reasonable measures, no compensation is due. Requests for financial compensation of less than Euro 6 will not be accepted, whether they are for individual tickets or subscriptions. If there are deficiencies or irregularities in the service rendered by the Company, the Passenger should make a complaint in writing to the Captain on- board or to the Company. In any event, without prejudice to legal prescriptions, should the passenger, from the time that boarding begins up to the completion of landing, suffer a personal injury, he/she must notify the Captain on- board the ferry, before final landing, providing identification details Fees for changes to ordinary tickets: Changes to the date or time of ordinary tickets will be accepted provided that they are requested before the maximum period allowed for check- in (15 minutes for passengers without cars, and 30 minutes for passenger with cars), and after verifying availability and paying any differences in tariffs for differing seasonal rates. Differences in favour of the customer for varied seasonal rates will not be reimbursed. Changes to tickets issued on the same day will not be subject to penalties. Changes are allowed only to departures published on the Carrier s internet site ( Fees for changes will be applied up to a limit of two change transactions for each ticket. Any subsequent changes will be accepted only after payment of a fixed fee of Euro 5.00 for the reimbursement of expenses (in addition to the payment of any tariff differences). A change in the number or type of passengers and/or vehicles results in the cancellation of the booking and any cancellation fees will be applied prior to re- issuing a new ticket. If a specific departure has a waiting list, preference will be given to passengers that do not have tickets for subsequent departures.

11 2.5. Transportation of Animals Due to their technical characteristics, the Company s ferries are destined solely for the transport of passengers and vehicles. They are not equipped with cages and/or other equipment for transporting animals. Therefore, pets are allowed on- board solely on the external bridges of the ferry. In addition, with the purchase of the relative ticket, each Passenger is allowed to bring a maximum of one pet, under the following conditions: From the moment of boarding until landing, hence for the entire duration of the trip, dogs must be muzzled and leashed or, alternatively, remain within an appropriate carrier, which the Passenger is responsible for bringing on- board. Cats must be kept in an appropriate carrier, and birds in an appropriate cage. Animals must be transported in conditions so as not to cause damage or inconvenience to other passengers and/or the ferry. Guide dogs providing assistance to the visually impaired, who have the relative documentation, are exempt from the requirement of a paid ticket and may have access to internal areas. This applies to service dogs for persons with disabilities or reduced mobility as provided for in EU Regulation no. 1177/2010. The Company reserves the right to request, prior to boarding, a veterinary certificate declaring that the animal is in good health as well as the animal s vaccination record. Certifications that were issued more than 90 days prior to the departure date will not be considered valid. Maintenance, custody and care of the animal during the trip is the responsibility of the Passenger and is assumed at his/her own risk. The Passenger is expected to comply with the applicable sanitation regulations issued by the competent authorities. The Passenger is required to indemnify the Company from any liability and/or obligation that may result from or as an effect of the non- compliance by the Passenger of the aforementioned regulations, as well as applicable governing laws. 3. Accessibility for Individuals with Reduced Mobility With regard to the concept of disability, it should firstly be noted that Italian Legislative Decree no. 52/2005, establishing safety requirements for individuals with reduced mobility (hereinafter IRMs), refers to a broader concept than that of mere disability, as IRMs are defined as anyone having a particular difficulty in the use of public transportation, including senior citizens, disabled people, individuals with sensory impairments, those who use wheelchairs, as well as pregnant women. As such, to facilitate the mobility of passengers with walking difficulties, lu Navy has established procedures to ensure that employees are adequately trained to carry out their duties in relation to safety and protection of these individuals. In accordance with Circular no. 10/SM of the Ministry of Transportation and EU Regulation no. 1177/2010 of 24 November 2010 of the European Parliament and Council, lu Navy s ferries: Have seats reserved for IRMs Safety information in the event of emergencies are communicated through an audio system; Escape routes in the event of evacuation of the ferry in an emergency are posted with specific signs; oarding is ensured through elevators/lifts and/or stair lifts with the assistance of personnel on- board. The on- board employee who is dedicated to assistance of IRMs has received specific training and has experience in providing assistance, in both normal operating conditions as well as in the event of an emergency. These crewmembers are easily identified: CREW is written on the back of the uniform and they have a specific identification badge. Guide dogs are permitted. REQUESTING ASSISTANCE

12 Individuals with disabilities or reduced mobility must notify the Company, upon booking or advance purchase their ticket, of any specific needs they may have, including seating requirements, requested services or the need to transport medical equipment. Tickets may be purchased through the Call Center at and following the instructions or at the ticket office at the departure port. The ticket must be purchased at least 48 hours before the assistance is required, in order to allow time to communicate the needs. The passenger will receive confirmation that the notification was received according to the method requested upon booking. CONDITIONS UNDER WHICH ASSISTANCE IS PROVIDED The Company must be informed at least 48 hours before the assistance is required. The Passenger must arrive 60 minutes prior to the posted boarding time at the designated area. The Passenger must indicate his/her specific needs upon booking or advance purchase of the ticket. If the Passenger is accompanied by a recognised service dog, the dog is accommodated with the passenger, provided that the Company was notified in advance. EXCEPTIONS AND ADDITIONAL CONDITIONS FOR ASSISTANCE The Company may refuse to accept a booking or provide a ticket. For the purposes of observing safety requirements and if the design of the passenger ship, or the port infrastructure and equipment, including the terminals, render it impossible the boarding, the landing or the transport of the individual in safe or concretely realisable conditions. In these cases, the Company will make reasonable efforts to propose an acceptable alternative to the individual. If the individual with disabilities or reduced mobility, who has a booking or ticket and has met the requirements for assistance, is then denied boarding based on EU Regulation no. 1177/2010, the individual and any accompanying person may choose between the right to reimbursement and the right to alternative transport. The right to choose between the return journey and alternative transportation is dependent on meeting all safety requirements. If necessary, the Company may require that the individual with disabilities or reduced mobility is accompanied by another individual who is able to provide the necessary assistance. The accompanying individual is transported free of charge. In all of the above cases, the Company will immediately communicate the reasons to the passenger. Upon request, these reasons are provided in writing to the individual not more than five days after the request.

13 METHODS OF ASSISTANCE According to the methods requested by the passenger, said passenger will receive indications of the meeting point, at which the individual with disabilities or reduced mobility can announce his/her arrival and request assistance. The necessary assistance will be provided free of charge in the ports and on- board the ferries, including during boarding and landing. PREGNANCY Pregnant women are not precluded from the transportation service. For a pregnancy without complications, after the sixth month of pregnancy, the woman must have a medical certificate, issued not more than 48 hours prior to departure, that authorises the trip, to be presented to an official on- board who may request it. If there are complications with the pregnancy, the woman must have a medical certificate that authorises the trip regardless of the month of the pregnancy.

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