Contract analysis

1. Introduction — Identification of Parties and Engagement We write on behalf of our client, Thalassa Shipping & Logistics SA ("TSL"), a Société Anonyme organised under the laws of the Hellenic Republic, with its registered address at 14 Akti Miaouli, 4th Floor, Piraeus 185 35, Greece. As you are aware, this firm has acted for TSL throughout the proceedings referred to above and continues to hold full authority to co

2. Background — The LCIA Arbitration 2.1 The Charter-Party Agreements The underlying dispute arises out of three time charter-party agreements entered into between TSL (as disponent owner) and KMH (as charterer) between 2019 and 2021, relating to the charter of three dry-bulk carriers within TSL's fleet. The relevant charter-parties are as follows: (a) A time charter-party dated 15 March 2019 in respect of the vessel

3. The Final Award — Summary of the Tribunal's Findings and Amounts Awarded 3.1 KMH's Repudiatory Breaches The Tribunal found, unanimously on all material points, that KMH had committed repudiatory breaches of each of the three Charter-Parties. The Tribunal's principal findings regarding liability are summarised as follows: (a) M/V *Aegean Fortuna* — Wrongful Early Redelivery. KMH wrongfully redelivered the vessel M/

4. Demand for Payment We hereby make formal demand, on behalf of TSL, that KMH pay the full sum of £108,600,000 (one hundred and eight million, six hundred thousand pounds sterling), together with all accrued post-award interest, within 14 days of the date of this letter, that is to say, on or before 22 July 2024. Payment shall be made in pounds sterling by electronic wire transfer to TSL's designated account at: Ion

5. Post-Award Interest We draw your attention to the fact that the Award provides for post-award interest at the rate of 5.25% per annum simple on the unpaid substantive sum of £96,450,000, accruing from 29 June 2024 (the day following the date of the Award) until the date on which payment is made in full. Post-award interest will continue to accrue on all unpaid sums with each passing day that the Award remains unsa

6. Consequences of Non-Payment We wish to make the position entirely clear: if KMH fails to satisfy the Award in full within the 14-day period specified above (i.e., by 22 July 2024), TSL will, without further notice, take all steps available to it to enforce the Award and protect its rights, including but not limited to the following. 6.1 Enforcement Proceedings TSL will commence proceedings to enforce the Award in

7. Reservation of Rights Nothing in this letter shall be construed as, or shall operate as, a waiver of any of TSL's rights, remedies, or entitlements under the Award, at law, in equity, or otherwise. This letter is written entirely without prejudice to TSL's rights, all of which are expressly reserved in full. Without limiting the generality of the foregoing, TSL expressly reserves: (a) all rights and remedies avail

8. Request for Response We request written confirmation from Harkness Whitford & Co. by return — and in any event within 7 days of the date of this letter (i.e., by 15 July 2024) — as to whether KMH intends to satisfy the Award voluntarily and make payment of the full sum due within the 14-day demand period. If no response is received within 7 days, or if KMH indicates that it does not intend to comply with the Award