Contract analysis

1. Introduction and Purpose of this Letter We write in our capacity as solicitors for Thalassa Shipping & Logistics SA ("TSL") in connection with the multi-jurisdictional enforcement of LCIA Final Award No. 224718, dated 28 June 2024 (the "Award"), rendered in the arbitration proceeding styled Thalassa Shipping & Logistics SA v. Korinthian Maritime Holdings Ltd. (LCIA Case Reference No. 224718). TSL is a Société Anon

2. Background — The Underlying Dispute and LCIA Arbitration 2.1 The Charter-Party Agreements TSL entered into three separate English-law time charter-party agreements with KMH, a private limited company incorporated in the Republic of Cyprus under Registration No. HE 387421, with its registered office at 28 Themistokli Dervi Avenue, Suite 601, Nicosia 1066, Cyprus. The three charters are as follows: (a) M/V *Aegean F

3. The LCIA Award 3.1 Issuance and Operative Provisions The Tribunal issued its Final Award on 28 June 2024. The Award is a final, binding, and enforceable award within the meaning of the LCIA Rules (2020), the English Arbitration Act 1996, and the New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards (1958). The Award was rendered unanimously by all three members of the Tribunal. A certif

4. KMH's Corporate Structure and UAE Assets — Target for Enforcement 4.1 KMH Group Structure Overview KMH is beneficially owned and controlled by the Volkov family, principally by Andrei Volkov, who is the ultimate beneficial owner ("UBO") and the de facto director of KMH and its group companies, and by his son, Sergei Volkov, who holds a formal directorship of KMH and several group entities. The Volkov family's owne

5. Parallel Enforcement Proceedings in Other Jurisdictions As noted above, the UAE enforcement forms one limb of a coordinated multi-jurisdictional enforcement campaign. It is important that ARH is aware of the status of the parallel enforcement proceedings in order to ensure consistency and to avoid any risk of conflicting positions being adopted across the various jurisdictions. The current status of proceedings in

6. Specific Instructions — UAE Enforcement Application We set out below the specific instructions that we ask ARH to carry out in respect of the UAE enforcement proceedings. These instructions should be read in conjunction with the broader strategic objectives described elsewhere in this letter, and ARH should at all times coordinate with C&H before taking any material procedural step. 6.1 Filing the Enforcement Appl

7. Enclosed Documents The following documents are enclosed with this letter, transmitted by secure courier and by encrypted electronic transmission (via C&H's secure file-sharing platform, access credentials for which will be provided to ARH separately):

1. Certified copy of LCIA Award No. 224718 (Final Award, dated 28 June 2024) — original English version, certified by the LCIA Registrar.

2. Certified Arabic translation of the Award — prepared by a certified translation firm accredited by the UAE Ministry of Justice.

3. Certified copies of the three charter-party agreements: (a) M/V Aegean Fortuna Time Charter-Party, dated 15 March 2019; (b) M/V Crimson Horizon Time Charter-Party, dated 22 January 2020; (c) M/V Volga Spirit Time Charter-Party, dated 10 June 2021; each containing the LCIA arbitration clause — original English versions.

4. Certified Arabic translations of the arbitration clauses contained in each of the three charter-party agreements.

5. Certificate from the LCIA Registrar confirming the authenticity of the Award, the proper constitution of the Tribunal, and the regularity of the arbitral proceedings.

6. Certified Arabic translation of the LCIA Registrar's certificate.

7. Copy of the Worldwide Freezing Order granted by Mr. Justice Ashworth on 16 July 2024 (Claim No. CL-2024-000487), as continued with modifications on 30 July 2024 — to be used as evidence of dissipation risk in support of the precautionary attachment application.

8. Hartwell Pemberton LLP preliminary asset tracing report, dated 15 August 2024 — identifying Korinthian DMCC's accounts at EGCB and trade receivables. This report is marked strictly confidential and is subject to litigation privilege. It should be used for the purposes of the court application as appropriate but should not be disclosed more widely without the prior consent of C&H.

9. Corporate registry extracts for: (a) Korinthian Maritime Holdings Ltd. (Cyprus Company Registry, Registration No. HE 387421); and (b) Korinthian DMCC (DMCC corporate registry, Dubai, UAE).

10. Power of attorney / authority to act — To be confirmed. ARH is requested to advise on the form of power of attorney or authority to act required by the Dubai Court of First Instance for the filing of the enforcement application and the precautionary attachment application. C&H will arrange for the necessary power of attorney to be executed by TSL and legalized as required, but we will need ARH's guidance on the f

8. Anticipated Defenses by KMH C&H anticipates that KMH, potentially through local UAE counsel, may seek to oppose both the enforcement application and the precautionary attachment application. While we are confident that the Award is enforceable in the UAE and that there is no meritorious basis for refusal, ARH should be prepared for the following potential lines of defense: 8.1 New York Convention Article V Defense

9. Reporting and Coordination The effective coordination of the UAE enforcement with the parallel proceedings in England & Wales, Cyprus, and Singapore is of paramount importance to the success of the overall enforcement campaign. Accordingly, ARH is requested to observe the following reporting and coordination protocols: (a) Acceptance of Instructions and Engagement Terms: ARH is requested to confirm acceptance of t

10. Client Information For the avoidance of doubt, the client for billing and engagement purposes is Thalassa Shipping & Logistics SA. The relevant client contact details are as follows: In-house General Counsel: Ms. Ioanna Christodoulou Email: i.christodoulou@thalassashipping.gr Direct Line: +30 210 429 7800 Chief Financial Officer: Ms. Elena Stavridis Email: e.stavridis@thalassashipping.gr Direct Line: +30 210 429

11. Urgency and Next Steps We wish to emphasize that this matter is urgent. There is an ongoing and serious risk of further dissipation of KMH's assets in the UAE, and each day that passes without a precautionary attachment in place increases the likelihood that Korinthian DMCC's EGCB accounts will be depleted or that receivables will be diverted beyond the reach of TSL's enforcement efforts. The evidence of dissipat

1. Confirmation of receipt and acceptance: Please confirm receipt of this letter and the enclosed documents, and confirm that ARH is able to accept these instructions and act with immediate effect, by no later than 20 August 2024.

2. Filing of enforcement and attachment applications: ARH is requested to file the enforcement application and the precautionary attachment application at the earliest practicable opportunity, and in any event to aim for filing by no later than 22 August 2024. If this target date is not achievable for any reason, please advise immediately so that C&H can adjust the enforcement timetable accordingly.

3. Strategy call: C&H would welcome a telephone conference call with Tariq Al-Rashid and Leila Hatem (or such other members of the ARH team as will be working on this matter) at ARH's earliest convenience to discuss the procedural strategy, timing, and any preliminary issues that ARH has identified. Please propose a time for this call, ideally on 19 or 20 August 2024.

4. Power of attorney: Please advise on the form and content of the power of attorney required by the Dubai Court by no later than 20 August 2024, so that C&H can arrange for its execution and legalization without delay.

12. Closing We are grateful for ARH's willingness to assist on this important matter and are confident that ARH's recognized expertise in UAE enforcement proceedings, DMCC-related litigation, and DIFC practice will be of great value to TSL's enforcement campaign. The successful enforcement of the Award in the UAE represents a critical element of TSL's multi-jurisdictional strategy, and we attach the highest importanc