If the crew of a small ferry do not sign a Crew Agreement, where is their contract with the employer?

Elsewhere – probably in an agreement made through their union, or between each individual and the employer.

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Under the Merchant Shipping (Crew Agreements, Lists of Crew and Discharge of Seamen) Regulations, which persons are exempted from the requirement to sign a Crew Agreement?

A master joins a UK-flag, 140 GT, 69 NT passenger ferry on a UK domestic service and finds that none of the crew are on a Crew Agreement. Is this permitted?