Contract analysis

1. Purpose of this Letter We write in our capacity as solicitors acting for 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. We act for TSL in connection with all matters arising out of and relating to the enforcement of the Final Award rendered on 28 June 2024 in LCIA Arbit

2. The LCIA Award As you are aware, a Final Award was issued on 28 June 2024 by the tribunal constituted in LCIA Arbitration No. 224718. The tribunal comprised Sir Malcolm Fenton-Clarke (presiding arbitrator), Professor Athena Drakopoulos (co-arbitrator appointed by TSL), and Dr. Henrik Dalmqvist (co-arbitrator appointed by KMH). The arbitration was seated in London, conducted in English, and governed by the LCIA Arb

3. Application Notice — Section 66, Arbitration Act 1996 On 15 July 2024, TSL filed an Application Notice in the Commercial Court of England and Wales under Claim No. CL-2024-000487 pursuant to section 66 of the Arbitration Act 1996. By that application, TSL seeks the permission of the court to enforce the Award in the same manner as a judgment or order of the court to the same effect, and for judgment to be entered

4. Worldwide Freezing Order On 16 July 2024, upon the application of TSL made without notice to KMH, Mr. Justice Ashworth sitting in the Commercial Court granted a Worldwide Freezing Order in Claim No. CL-2024-000487. A sealed copy of the Worldwide Freezing Order dated 16 July 2024 is enclosed with this letter. We draw KMH's attention to the following key terms of the WFO, which we summarise for convenience but witho

5. Asset Disclosure Obligation We draw KMH's specific and urgent attention to the asset disclosure provisions contained in the WFO. Pursuant to paragraph 9 of the WFO, KMH is required, within 7 days of service of this Order (i.e., by no later than 4:00 p.m. on 24 July 2024), to provide full disclosure of all its assets worldwide exceeding £25,000 in value, whether held in its own name or not, and whether solely or jo

6. Return Date The return date for the WFO is 30 July 2024 before the Commercial Court. The precise time and courtroom will be confirmed by the Listing Office, and we will communicate these details to your firm as soon as they are known. KMH is entitled to apply at the return date to vary or discharge the WFO. If KMH wishes to make such an application, it should file and serve any evidence upon which it intends to re

7. Penal Notice — Formal Contempt Warning We formally draw KMH's attention to the fact that the WFO contains a penal notice on its face. Any person who knowingly assists in or permits a breach of the terms of the WFO may be held to be in contempt of court and may be imprisoned, fined, or have their assets seized. This warning is addressed specifically, and without limitation, to KMH itself and to each of the followin

8. Third-Party Notification We further notify you that Calderwood & Harkness LLP, on behalf of TSL, intends to serve copies of the WFO upon the following financial institutions and other relevant third parties, in order to ensure that the terms of the Order are brought to their attention and that they comply with the same: (a) Meridian Trust Bank Ltd., 50 Lombard Street, London EC3V 9EA, being KMH's London correspond

9. Enclosures The following documents are enclosed with this letter:

1. Sealed copy of the Worldwide Freezing Order dated 16 July 2024 (incorporating the penal notice endorsed on its face);

2. Sealed copy of the Application Notice under section 66 of the Arbitration Act 1996, dated 15 July 2024 (Claim No. CL-2024-000487);

3. Witness Statement of Nikolaos Papadimitriou dated 14 July 2024 (first witness statement in support of the application under section 66 of the Arbitration Act 1996 and the application for the Worldwide Freezing Order), together with the exhibits thereto; and

4. Certified copy of the Final Award dated 28 June 2024 in LCIA Arbitration No. 224718. We would be grateful if you would acknowledge receipt of this letter and the above enclosures at your earliest convenience.

10. Reservation of Rights and Demand for Payment Nothing in this letter, or in the proceedings commenced to date, shall be taken as a waiver or limitation of any of TSL's rights under the Award or at law, all of which are expressly reserved. TSL hereby demands immediate and unconditional payment of the following sums: Payment of the full amount of £108,600,000, together with all accrued post-award interest calculated

11. Confirmations Requested We would be grateful if Harkness Whitford & Co. would confirm the following by return, and in any event by no later than 4:00 p.m. on 19 July 2024:

1. That you are instructed to accept service on behalf of KMH in these proceedings (Claim No. CL-2024-000487) and that you have authority to do so;

2. That you have brought the Worldwide Freezing Order and its terms — including, in particular, the asset disclosure obligation and the penal notice — to KMH's immediate attention, and that KMH's directors and officers (including Messrs. Andrei Volkov, Sergei Volkov, and Alexei Demidov, and Ms. Marina Kazakova) have been personally notified of the Order; and

3. KMH's position as to compliance with the asset disclosure requirement within 7 days of service (i.e., by 24 July 2024), and the identity of the director who will be swearing the disclosure affidavit. We look forward to receiving your prompt response on each of the above points. Yours sincerely, CALDERWOOD & HARKNESS LLP By: ________ Samuel Eklund Partner, Litigation Calderwood & Harkness LLP 45 Moorgate, London EC