Contract analysis

1. INTRODUCTION AND PURPOSE 1.1. We write on behalf of our client, Thalassa Shipping & Logistics SA ("TSL"), a Société Anonyme organized and existing under the laws of the Hellenic Republic, with its registered address at 14 Akti Miaouli, 4th Floor, Piraeus 185 35, Greece. Calderwood & Harkness LLP ("C&H") acts as TSL's lead international counsel in this matter and has done so since the commencement of the underlying

2. BACKGROUND TO THE DISPUTE AND ARBITRATION 2.1 The Parties 2.1.1. Claimant / Award Creditor: Thalassa Shipping & Logistics SA, as described above. TSL was the claimant in the LCIA arbitration and is now the award creditor. 2.1.2. Respondent / Award Debtor: Korinthian Maritime Holdings Ltd. ("KMH"), a private limited company incorporated in the Republic of Cyprus under Registration No. HE 387421, with its registered

3. PARALLEL ENFORCEMENT PROCEEDINGS IN OTHER JURISDICTIONS 3.1. As noted above, TSL is pursuing a coordinated multi-jurisdictional enforcement campaign. We provide the following summary of the parallel proceedings for SM's awareness and to ensure effective coordination. SM should note that the strategy in each jurisdiction is designed to complement the others, and we are taking care to avoid any risk of double recove

4. SINGAPORE-SPECIFIC INSTRUCTIONS We now turn to the specific instructions for the Singapore proceedings. SM is instructed to pursue three primary forms of relief, as detailed below. 4.1 Instruction A: Application for Leave to Enforce the LCIA Award 4.1.1. SM is instructed to prepare and file an originating summons in the Singapore High Court under section 19 of the International Arbitration Act (Cap. 143A) ("IAA"),

5. KMH'S CORPORATE STRUCTURE IN SINGAPORE 5.1. For SM's reference, we set out below the corporate structure relevant to the Singapore enforcement proceedings. 5.2. Korinthian Bulkers (Singapore) Pte. Ltd. ("KBSPL") is the key KMH group entity in Singapore. KBSPL is a private company limited by shares, registered in Singapore at 80 Robinson Road, #14-02, Singapore 068898. KBSPL is the registered owner of the M/V Crims

6. ENCLOSED DOCUMENTATION 6.1. The following documents are enclosed with this letter, by courier and in electronic form (via C&H's secure document portal): Enclosure 1: Certified copy of LCIA Award No. 224718, dated 28 June 2024 Enclosure 2: Certified copies of the three charter-party agreements: • M/V Aegean Fortuna — dated 15 March 2019 • M/V Crimson Horizon — dated 22 January 2020 • M/V Volga Spirit — dated 10 Jun

7. ASSET TRACING SUPPORT AND FORENSIC INTELLIGENCE 7.1. As noted above, Hartwell Pemberton LLP has been engaged by C&H on behalf of TSL to conduct global asset tracing of KMH and its related entities. Hartwell Pemberton is a leading forensic accounting and asset tracing firm based in London. The engagement is led by Rebecca Saunders (Partner) and Mark Huxley (Director). Their preliminary findings inform the Singapore

8. EVIDENCE OF DISSIPATION AND URGENCY 8.1. C&H wishes to emphasise the urgency of the Singapore applications. The evidence demonstrates a clear and present risk of further dissipation of KMH's assets, and delay in obtaining Singapore relief could materially prejudice TSL's ability to enforce the Award. 8.2. The specific grounds for urgency are as follows: (a) International asset dispersal: KMH has a well-established

9. KMH'S LIKELY DEFENCES 9.1. For SM's benefit, we set out below our assessment of the defences that KMH is likely to advance in the Singapore proceedings. While we consider these defences to be without merit, SM should be prepared to respond to each of them substantively. 9.1.1 Challenge to Leave to Enforce Under Section 31 of the IAA 9.1.2. KMH may apply to set aside the order granting leave to enforce the Award on

10. COORDINATION AND REPORTING 10.1. The successful enforcement of the Award requires close coordination between TSL's legal teams across all jurisdictions. C&H requests that SM adhere to the following coordination and reporting protocols: (a) Immediate confirmation: SM should provide immediate written confirmation of its acceptance of these instructions and confirm that no conflicts of interest exist with respect to

11. FEE ARRANGEMENTS 11.1. C&H has agreed with TSL a fee cap arrangement for the overall multi-jurisdictional enforcement engagement. Local counsel fees in Singapore (and in Cyprus and the UAE) are separate from and in addition to the C&H fee cap. 11.2. C&H requests that SM provide a detailed fee estimate for the Singapore engagement as soon as practicable, broken down by the following work streams: (a) Originating s

12. CLOSING AND CONTACT INFORMATION 12.1. We look forward to working with SM on this important matter for TSL. We are confident that SM's expertise in Singapore commercial litigation, enforcement, and admiralty law will be invaluable to the overall enforcement strategy. 12.2. We would welcome an introductory call to discuss the strategy and sequencing of the Singapore applications, as well as any preliminary question