RISK ASSESSMENTS FOR PASSENGER VESSEL OPERATIONS

Our article, Implementing risk assessments, highlighted the rise in claims which have been recorded by
the Club as a result of incidents occurring during routine shipboard operations. As the article explained,
these claims may have been avoided had a proper risk assessment been carried out. In this, the second in
our series of risk assessment articles, we focus on risk assessments for passenger vessel operations.
The carriage of passengers is a crucial operation and involves efficient supervision and care. The operator’s
responsibility for the lives of the passengers begins as soon as they board the vessel and continues
throughout the duration of the voyage until they disembark at their destination. For ease of reference, this
operation can be split into three sections – embarking/disembarking of passengers, care of passengers
during the voyage and care of passengers during emergency situations.
The charts below illustrate the type and frequency of claims recorded by the Club during the embarking
and disembarking and voyage stages:

Claims Experienced Claims Experienced

During Embarking and During the Voyage
Disembarking
12% Injury
8% Injury
Slips/Trips/Falls
31% Slips/Trips/Falls 54%
34%
61% Man Over
Man Over Board
Board

The management of passengers on board can be challenging as most often the number of passengers
carried far outweighs the number of crew. Coupled with factors such as the passengers’ movement on
board, unpredictable weather and the vessels motion, the probability of incidents occurring can increase.
For these reasons it is essential that operations on board have been carefully planned and managed and
particular attention has been paid to any potential risks.
IDENTIFYING POTENTIAL HAZARDS AND IMPLEMENTING CONTROLS
To assist Members in identifying potential hazards and implementing the appropriate controls, the Club has
produced three sample risk assessments based on the sections identified:
 Care of passengers embarking/disembarking
 Care of passengers during the voyage
 Care of passengers in emergency situations
The forms include a hazard category which has been added solely for the purpose of facilitating a better
understanding of risk assessment procedures and is not required as part of a formal risk assessment. We
The Shipowners’ Protection Limited | Registered in England No 02067444 | For and on behalf of
The Shipowners’ Mutual Protection and Indemnity Association (Luxembourg)
16, Rue Notre - Dame | L - 2240 Luxembourg | Incorporated in Luxembourg | RC Luxembourg B14228

Page 1 of 2
emphasise that these forms are for guidance purposes only. It is imperative that operators conduct their
own risk assessments based on their individual operating parameters.
We take this opportunity to remind our Members of the Club’s booklet on Learning from Passenger Vessel
Incidents and also posters on Passenger Safety and Yacht Safety.
We trust Members find this guidance useful and if further assistance is required please contact the Loss
Prevention Team.
This article was written in conjunction with the Technical and Risk team at CTRL Marine Solutions Ltd.
CTRL’s knowledgeable and experienced staff can work with your in house teams to audit and assist with
new or existing risk assessments on favourable rates and flexible terms.

The Shipowners’ Protection Limited | Registered in England No 02067444 | For and on behalf of
The Shipowners’ Mutual Protection and Indemnity Association (Luxembourg)
16, Rue Notre - Dame | L - 2240 Luxembourg | Incorporated in Luxembourg | RC Luxembourg B14228
Page 2 of 2
INSTRUCTIONS FOR USING THE RISK ASSESSMENT FORM

1. Envisage the task in hand and identify the hazards associated with carrying out the task. These hazards are to be listed
and addressed individually in the risk assessment form.

2. Once the hazard has been identified, based on the combination of the likelihood and severity/consequence of the
hazard, the risk evaluation score is to be assigned using the risk evaluation matrix on the last page. For example, a
hazard which has a likelihood of ‘unlikely’ and a severity/consequence of ‘harmful’, the risk evaluation score would be 4
(moderate risk).

3. With the determination of the risk evaluation score, using the recommended response table on the last page, appropriate
action is to be planned and implemented.

4. Using the above example of a risk evaluation score of 4 (moderate risk), appropriate controls must be applied to the risk
and these must be listed out accordingly in the form along with the person responsible of applying the control and the
completion date.

5. Once the controls have been applied, the risk must be reassessed as a whole taking into account the applied controls and
once again using the risk evaluation matrix on the last page, a residual score must be obtained.

6. If the residual risk on reassessment is ‘Trivial’ or ‘Tolerable’ (scores 1 and 2), then no additional controls are required and
only effective monitoring of the task to ensure compliance with procedures is necessary.

7. However if the reassessment of the risk again is ‘Moderate’, ‘Substantial’ or ‘Intolerable’ and yields a score higher than 2, it
implies that the applied controls are not sufficient to address the associated hazards and therefore do not bring the risk to
a safe level. This would require additional controls to be applied and steps 4 and 5 to be followed once again.

8. This process would continue until the residual risk is eventually brought down to an acceptable level (scores 1 or 2).

9. Effective supervision of the task to be carried out is necessary to ensure that there are no unauthorised and unsafe
diversions which could effectively change the entire risk assessment therefore making it inappropriate for the current task.

This form is for guidance purposes only and does not replace any company procedures or applicable statutory regulations.

The Shipowners’ Protection Limited | Registered in England No 02067444 | For and on behalf of
The Shipowners’ Mutual Protection and Indemnity Association (Luxembourg)
16, Rue Notre-Dame | L–2240 Luxembourg | Incorporated in Luxembourg | RC Luxembourg B14228
1
 VESSEL NAME: ACTIVITY: Care of passengers during PERSONNEL INVOLVED IN THE TASK: Master, Chief Officer, Deck
emergency situations Officers and Deck Crew
ACTION
CATEGORY

RISK
HAZARD

EVALUATION POSSIBLE CONTROL MEASURES RESIDUAL RISK

POTENTIAL HAZARDS REQUIRED
IDENTIFIED SCORE PERSON DATE SCORE
(refer to last page) (including existing & proposed) RESPONSIBLE COMPLETED (refer to last page)

Passengers panicking and injuring
themselves or jumping over board
during emergency situations.
Injury/Man over board
Likely (3) x Extremely • Crew formally trained in crowd Master/Chief Unlikely (2) x Slightly
Harmful (3) = 9 management to handle such Officer/Deck Harmful (1) = 2
Intolerable situations and continual on board Officers/Deck crew Tolerable
(example only) training to be provided in the form of (example only)
shipboard drills.
• Pre-boarding safety briefings to
passengers specifically advising
them what is expected of them in
the event of an emergency, such
as the identification of emergency

alarms locations, of lifejackets and of

other personal life saving equipment
and muster stations.
• Safety announcements must be
made in a calm manner to avoid
panic and must clearly instruct
passengers of what they need to do
during the emergency.
• Appropriately placed and highly
visible safety notices and mustering
instructions displayed for the
passengers’ reference.
• Crew to take charge of the situation
in a calm manner and to remain
amongst the passengers reassuring
and instructing them accordingly.

Date: Name/Rank/Sign:

The Shipowners’ Protection Limited | Registered in England No 02067444 | For and on behalf of This form is for guidance purposes only and does not replace
The Shipowners’ Mutual Protection and Indemnity Association (Luxembourg) any company procedures or applicable statutory regulations.
16, Rue Notre-Dame | L–2240 Luxembourg | Incorporated in Luxembourg | RC Luxembourg B14228 2
 RISK EVALUATION MATRIX TO OBTAIN SCORE

Severity/Consequence
Slightly Harmful Harmful Extremely harmful
(1) (2) (3)

Highly Unlikely Trivial Risk Tolerable risk Moderate Risk

(1) (Score 1) (Score 2) (Score 3)
Likelihood

Unlikely Tolerable Risk Moderate Risk Substantial Risk

(2) (Score 2) (Score 4) (Score 6)

Likely Moderate Risk Substantial Risk Intolerable risk

(3) (Score 3) (Score 6) (Score 9)

THE TABLE BELOW INDICATES THE RECOMMENDED RESPONSE IN EACH CASE.

Trivial No action is required.
Tolerable No additional controls are required.
Monitoring is required to ensure control is maintained.

Moderate Efforts are required to reduce risk.

Controls are to be implemented within a specified time.

Substantial New work not to start until risk reduced.

If work is in progress, urgent action to be taken.
Considerable resources may be required.

Intolerable Work shall not be started or continued until the risk has been reduced.
If reduction is not possible, the activity shall be prohibited.

This form is for guidance purposes only and does not replace any company procedures or applicable statutory regulations.

The Shipowners’ Protection Limited | Registered in England No 02067444 | For and on behalf of
The Shipowners’ Mutual Protection and Indemnity Association (Luxembourg)
16, Rue Notre-Dame | L–2240 Luxembourg | Incorporated in Luxembourg | RC Luxembourg B14228
3
INSTRUCTIONS FOR USING THE RISK ASSESSMENT FORM

1. Envisage the task in hand and identify the hazards associated with carrying out the task. These hazards are to be listed
and addressed individually in the risk assessment form.

2. Once the hazard has been identified, based on the combination of the likelihood and severity/consequence of the
hazard, the risk evaluation score is to be assigned using the risk evaluation matrix on the last page. For example, a
hazard which has a likelihood of ‘unlikely’ and a severity/consequence of ‘harmful’, the risk evaluation score would be 4
(moderate risk).

3. With the determination of the risk evaluation score, using the recommended response table on the last page, appropriate
action is to be planned and implemented.

4. Using the above example of a risk evaluation score of 4 (moderate risk), appropriate controls must be applied to the risk
and these must be listed out accordingly in the form along with the person responsible of applying the control and the
completion date.

5. Once the controls have been applied, the risk must be reassessed as a whole taking into account the applied controls and
once again using the risk evaluation matrix on the last page, a residual score must be obtained.

6. If the residual risk on reassessment is ‘Trivial’ or ‘Tolerable’ (scores 1 and 2), then no additional controls are required and
only effective monitoring of the task to ensure compliance with procedures is necessary.

7. However if the reassessment of the risk again is ‘Moderate’, ‘Substantial’ or ‘Intolerable’ and yields a score higher than 2, it
implies that the applied controls are not sufficient to address the associated hazards and therefore do not bring the risk to
a safe level. This would require additional controls to be applied and steps 4 and 5 to be followed once again.

8. This process would continue until the residual risk is eventually brought down to an acceptable level (scores 1 or 2).

9. Effective supervision of the task to be carried out is necessary to ensure that there are no unauthorised and unsafe
diversions which could effectively change the entire risk assessment therefore making it inappropriate for the current task.

This form is for guidance purposes only and does not replace any company procedures or applicable statutory regulations.

The Shipowners’ Protection Limited | Registered in England No 02067444 | For and on behalf of
The Shipowners’ Mutual Protection and Indemnity Association (Luxembourg)
16, Rue Notre-Dame | L–2240 Luxembourg | Incorporated in Luxembourg | RC Luxembourg B14228
1
 VESSEL NAME:
CATEGORY
HAZARD
POTENTIAL HAZARDS
IDENTIFIED
Passenger slips/falls due to
slippery/wet decks or loss of
balance on account of vessel’s
motion.
Passenger slips/trips/falls
due to poor lighting or when
transiting areas of differing
Slips, trips and falls
light intensities.
Passengers bump their heads
or feet on uneven door sills
or hurt their feet on uneven
steps.
Passenger injury due to poor
lighting or when transiting
areas of differing light
intensities.
Passenger falls over board due
Man over board
to vessels motion or due to
wave wash in heavy
weather.
The Shipowners’ Protection Limited | Registered in England No 02067444 | For and on behalf of
The Shipowners’ Mutual Protection and Indemnity Association (Luxembourg)
16, Rue Notre-Dame | L–2240 Luxembourg | Incorporated in Luxembourg | RC Luxembourg B14228
ACTIVITY: Care of passengers during the voyage PERSONNEL INVOLVED IN THE TASK: Master, Chief Officer,
Deck Officers and Deck Crew
RISK ACTION
EVALUATION RESIDUAL RISK
SCORE POSSIBLE CONTROL MEASURES REQUIRED PERSON DATE SCORE
(refer to last page) (including existing & proposed) RESPONSIBLE COMPLETED (refer to last page)
Likely (3) x • Safety briefings/announcements and Master/Chief Officer/ Unlikely (2) x
Harmful (2) = 6 appropriately placed safety notices Deck Officers/Deck Crew Slightly Harmful (1) = 2
Substantial highlighting slip/fall dangers. Tolerable
• Exposed decks which are accessible to
passengers and floors of toilets are to be
coated with an anti-slip surface.
• Crew to continually supervise the
passengers on exposed decks in wet
conditions, reminding them to hold onto
the handrails and to walk carefully.
• Supervising crew to highlight to passengers
the importance of wearing correct footwear
and escalated risk of injury by wearing
flip-flops and other such footwear.
(To be assessed and • Steps and door sills to be made Master/Chief Officer/ (To be assessed and
completed) conspicuous with high visibility markings. Deck Officers/Deck Crew completed)
• Appropriate safety warnings to be displayed
to ensure passengers are aware of the
dangers of varying illumination when
transiting different areas of the vessel.
(To be assessed and • Crew to continually supervise passengers Master/Chief Officer/ (To be assessed and
completed) ​ on exposed decks and to remind them to Deck Officers/Deck Crew completed)
hold onto handrails at all times.
• Safety announcements made to instruct
passengers to return to their seats and
to remain seated in the event of harsh
weather. Crew to ensure compliance with
the same.
This form is for guidance purposes only and does not replace
any company procedures or applicable statutory regulations.
2
 Passengers falling over board
board
due to intoxication.
over
Man
Passenger’s finger crushed
in doorways with self-closing
doors.
Passenger sustains back/
neck injuries due to vessels
movement in rough weather.
Injury
Passenger sustains burns
from spilling hot beverage
onto themselves or other
passengers.
Date:
The Shipowners’ Protection Limited | Registered in England No 02067444 | For and on behalf of
The Shipowners’ Mutual Protection and Indemnity Association (Luxembourg)
16, Rue Notre-Dame | L–2240 Luxembourg | Incorporated in Luxembourg | RC Luxembourg B14228
(To be assessed and • Dispensing of alcohol to be monitored by Master/Chief Officer/ (To be assessed and
completed) crew to identify any high consumption. Deck Officers/Deck Crew completed)
• Intoxicated passengers to be closely
monitored by the crew.
(To be assessed and • Self closing doors to be fitted with Master/Chief Officer/ (To be assessed and
completed) appropriate protection devices. Deck Officers/Deck Crew completed)
• Appropriate safety signage displayed to
alert passenger’s to the characteristics and
associated dangers of self closing doors.
• Self closing doors to be regularly inspected
to ensure that the mechanism is in good
working order and that the door does not
close too violently.
(To be assessed and • Safety announcement made to instruct Master/Chief Officer/ (To be assessed and
completed) passengers to return to their seats and Deck Officers/Deck Crew completed)
remain seated in the event of rough
weather.
• Crew to ensure that the passengers remain
seated until the weather improves.
• Seatbelts to be securely fastened
(if provided).
• Master to reduce speed to prevent the
slamming and violent motion of the vessel
due to the weather.
(To be assessed and • All hot beverages to be dispensed in Master/Chief Officer/ (To be assessed and
completed) containers with lids to avoid spillages. Deck Officers/Deck Crew completed)
• Dispensing of hot beverage to be
suspended in the event of bad weather.
• Containers with hot beverages to be placed
in receptacle (if provided).
Name/Rank/Sign:
This form is for guidance purposes only and does not replace
any company procedures or applicable statutory regulations.
3
 RISK EVALUATION MATRIX TO OBTAIN SCORE

Severity/Consequence
Slightly Harmful Harmful Extremely harmful
(1) (2) (3)

Highly Unlikely Trivial Risk Tolerable risk Moderate Risk

(1) (Score 1) (Score 2) (Score 3)
Likelihood

Unlikely Tolerable Risk Moderate Risk Substantial Risk

(2) (Score 2) (Score 4) (Score 6)

Likely Moderate Risk Substantial Risk Intolerable risk

(3) (Score 3) (Score 6) (Score 9)

THE TABLE BELOW INDICATES THE RECOMMENDED RESPONSE IN EACH CASE.

Trivial No action is required.
Tolerable No additional controls are required.
Monitoring is required to ensure control is maintained.

Moderate Efforts are required to reduce risk.

Controls are to be implemented within a specified time.

Substantial New work not to start until risk reduced.

If work is in progress, urgent action to be taken.
Considerable resources may be required.

Intolerable Work shall not be started or continued until the risk has been reduced.
If reduction is not possible, the activity shall be prohibited.

This form is for guidance purposes only and does not replace any company procedures or applicable statutory regulations.

The Shipowners’ Protection Limited | Registered in England No 02067444 | For and on behalf of
The Shipowners’ Mutual Protection and Indemnity Association (Luxembourg)
16, Rue Notre-Dame | L–2240 Luxembourg | Incorporated in Luxembourg | RC Luxembourg B14228
4
INSTRUCTIONS FOR USING THE RISK ASSESSMENT FORM

1. Envisage the task in hand and identify the hazards associated with carrying out the task. These hazards are to be listed
and addressed individually in the risk assessment form.

2. Once the hazard has been identified, based on the combination of the likelihood and severity/consequence of the
hazard, the risk evaluation score is to be assigned using the risk evaluation matrix on the last page. For example, a
hazard which has a likelihood of ‘unlikely’ and a severity/consequence of ‘harmful’, the risk evaluation score would be 4
(moderate risk).

3. With the determination of the risk evaluation score, using the recommended response table on the last page, appropriate
action is to be planned and implemented.

4. Using the above example of a risk evaluation score of 4 (moderate risk), appropriate controls must be applied to the risk
and these must be listed out accordingly in the form along with the person responsible of applying the control and the
completion date.

5. Once the controls have been applied, the risk must be reassessed as a whole taking into account the applied controls and
once again using the risk evaluation matrix on the last page, a residual score must be obtained.

6. If the residual risk on reassessment is ‘Trivial’ or ‘Tolerable’ (scores 1 and 2), then no additional controls are required and
only effective monitoring of the task to ensure compliance with procedures is necessary.

7. However if the reassessment of the risk again is ‘Moderate’, ‘Substantial’ or ‘Intolerable’ and yields a score higher than 2, it
implies that the applied controls are not sufficient to address the associated hazards and therefore do not bring the risk to
a safe level. This would require additional controls to be applied and steps 4 and 5 to be followed once again.

8. This process would continue until the residual risk is eventually brought down to an acceptable level (scores 1 or 2).

9. Effective supervision of the task to be carried out is necessary to ensure that there are no unauthorised and unsafe
diversions which could effectively change the entire risk assessment therefore making it inappropriate for the current task.

This form is for guidance purposes only and does not replace any company procedures or applicable statutory regulations.

The Shipowners’ Protection Limited | Registered in England No 02067444 | For and on behalf of
The Shipowners’ Mutual Protection and Indemnity Association (Luxembourg)
16, Rue Notre-Dame | L–2240 Luxembourg | Incorporated in Luxembourg | RC Luxembourg B14228
1
 VESSEL NAME:
CATEGORY
HAZARD
POTENTIAL HAZARDS
IDENTIFIED
Passenger slips/trips/falls
on the gangway.
Slips, trips and falls
Elderly passengers, disabled
passengers, children or
passengers with special
needs injured whilst
embarking/disembarking.
Injury
The Shipowners’ Protection Limited | Registered in England No 02067444 | For and on behalf of
The Shipowners’ Mutual Protection and Indemnity Association (Luxembourg)
16, Rue Notre-Dame | L–2240 Luxembourg | Incorporated in Luxembourg | RC Luxembourg B14228
ACTIVITY: Embarking/Disembarking PERSONNEL INVOLVED IN THE TASK: Master, Chief Officer,
of passengers Deck Officers and Deck Crew
RISK ACTION
EVALUATION RESIDUAL RISK
SCORE POSSIBLE CONTROL MEASURES REQUIRED PERSON DATE SCORE
(refer page 5) (including existing & proposed) RESPONSIBLE COMPLETED (Refer page 2)
Likely (3) x • Crew training and briefing on passenger Master/Chief Officer/ Unlikely (2) x
Harmful (2) = 6 embarking/disembarking procedures. Deck Officers/Deck Crew Slightly Harmful (1) = 2
Substantial • Passenger safety briefing on embarking/ Tolerable
(example only) prior disembarking. (example only)
• Adequate and appropriate safety
announcements and signage
highlighting the associated dangers.
• Close supervision of passengers and
offering assistance as required.
• Ensuring the gangway and associated
areas are clean, dry and free of any
obstructions.
• Gangway should have non-slip coating.
• Ensure that the moorings are tight to
restrict the vessel’s movement.
• In case of a boarding ramp, ensure that
the ramp is properly locked in position.
(To be assessed and • Crew training and briefing on rendering Master/Chief Officer/ (To be assessed and
completed) special assistance of elderly/disabled/ Deck Officers/Deck Crew completed)
special needs passengers and children.
• Priority boarding/disembarking for
such passengers and special assistance
rendered to them.
This form is for guidance purposes only and does not replace
any company procedures or applicable statutory regulations.
2
 Passengers’ feet trapped in
the gangway or in any gap
between the gangway and
the vessel whilst embarking/
disembarking.
Passenger injured from the
impact of the vessel coming
alongside quay.
Injury
The Shipowners’ Protection Limited | Registered in England No 02067444 | For and on behalf of
The Shipowners’ Mutual Protection and Indemnity Association (Luxembourg)
16, Rue Notre-Dame | L–2240 Luxembourg | Incorporated in Luxembourg | RC Luxembourg B14228
(To be assessed and • Ensure the gangway is properly rigged Master/Chief Officer/ (To be assessed and
completed) such that there is no gap between the Deck Officers/Deck Crew completed)
ship side and the gangway.
• Ensure that the gangway is firmly resting
on the quay without any gaps.
• Additional safety measures, such as
preventative brushes at the bottom of
the gangway to be installed.
(To be assessed and • Crew trained to check passenger Master/Chief Officer/ (To be assessed and
completed) movement as the vessel prepares to Deck Officers/Deck Crew completed)
come alongside the quay.
• Adequate and appropriate safety
announcements highlighting the
associated dangers.
• Ensure passengers remain seated until
vessel is moored.
• Master to ensure the vessel’s speed of
approach whilst coming alongside the
quay is kept to a minimum.
• Adequate soft fendering to be
permenantly rigged along the vessels
hull to minimise any hard contact with
the quay.
• Crew trained in responding to man
overboard situations.
This form is for guidance purposes only and does not replace
any company procedures or applicable statutory regulations.
3
 Passenger falling over the
side of the gangway whilst
embarking/disembarking or
in the gap between the ship
and the quay.
Man over board
(To be assessed and • Ensure the vessel is properly alongside Master/Chief Officer/ (To be assessed and
completed) without any open gap between the ship Deck Officers/Deck Crew completed)
and quay.
• In case of any inadvertant gaps
additional saftey measures, such as
warning notices and crew on hand

to assist passengers, should be

Passenger falling over
board due to overcrowding
of passengers at the
disembarkation point.
implemented.
• Ensure the gangway is properly rigged
with a safety net eliminating any
additional risks of passengers falling into
the water.
(To be assessed and • Crew trained in crowd management Master/Chief Officer/ (To be assessed and
completed) to control passenger movement as Deck Officers/Deck Crew completed)
neccessary.
• Ensure passengers remain seated until
the vessel is fully alongside and moored.

Date: Name/Rank/Sign:

The Shipowners’ Protection Limited | Registered in England No 02067444 | For and on behalf of This form is for guidance purposes only and does not replace
The Shipowners’ Mutual Protection and Indemnity Association (Luxembourg) any company procedures or applicable statutory regulations.
16, Rue Notre-Dame | L–2240 Luxembourg | Incorporated in Luxembourg | RC Luxembourg B14228
4
 RISK EVALUATION MATRIX TO OBTAIN SCORE

Severity/Consequence
Slightly Harmful Harmful Extremely harmful
(1) (2) (3)

Highly Unlikely Trivial Risk Tolerable risk Moderate Risk

(1) (Score 1) (Score 2) (Score 3)
Likelihood

Unlikely Tolerable Risk Moderate Risk Substantial Risk

(2) (Score 2) (Score 4) (Score 6)

Likely Moderate Risk Substantial Risk Intolerable risk

(3) (Score 3) (Score 6) (Score 9)

THE TABLE BELOW INDICATES THE RECOMMENDED RESPONSE IN EACH CASE.

Trivial No action is required.
Tolerable No additional controls are required.
Monitoring is required to ensure control is maintained.

Moderate Efforts are required to reduce risk.

Controls are to be implemented within a specified time.

Substantial New work not to start until risk reduced.

If work is in progress, urgent action to be taken.
Considerable resources may be required.

Intolerable Work shall not be started or continued until the risk has been reduced.
If reduction is not possible, the activity shall be prohibited.

This form is for guidance purposes only and does not replace any company procedures or applicable statutory regulations.

The Shipowners’ Protection Limited | Registered in England No 02067444 | For and on behalf of
The Shipowners’ Mutual Protection and Indemnity Association (Luxembourg)
16, Rue Notre-Dame | L–2240 Luxembourg | Incorporated in Luxembourg | RC Luxembourg B14228
5