Contract analysis

1. Background on Oceangate Ventures Ltd. and Target Assets For the purposes of completeness, and to ensure that all relevant information is reflected in the forthcoming court applications, we set out the background to the target assets as follows. 1.1 Oceangate Ventures Ltd. is a private limited liability company incorporated in the Republic of Cyprus under Registration No. HE 401293. Its registered office is at 28 T

2. Instructions for Initiating Forced Sale Proceedings We instruct KM&P as follows in connection with the initiation of the forced sale process. 2.1 KM&P is instructed to apply immediately — and in any event within five (5) business days of the date of this letter — to the Nicosia District Court for an order for execution by forced sale of KMH's entire 100% shareholding in Oceangate Ventures Ltd. (being 10,000 ordina

3. Valuation Requirements 3.1 We anticipate that the Nicosia District Court will require, or at minimum expect, an independent valuation of the Oceangate shares prior to ordering their sale, in order to establish a reserve price or to guide the forced sale process and ensure that the shares are not sold at an undervalue. We instruct KM&P to take all necessary steps to arrange for such a valuation on an expedited basi

4. Coordination with Court Bailiff and Sale Mechanism We set out below detailed instructions for the practical steps involved in coordinating with the Cyprus court bailiff and effecting the forced sale. 4.1 Filing of the Execution Writ. KM&P should file the appropriate execution writ (or application for a warrant of execution, as the procedural form may require) with the Nicosia District Court, referencing the enforc

5. KMH Bank Accounts in Cyprus 5.1 In addition to the forced sale of Oceangate shares, KM&P is instructed to simultaneously pursue execution against KMH's Cyprus bank accounts that are subject to the Cyprus Freezing Injunction granted on 12 August 2024. We understand from the freezing injunction proceedings and from KMH's disclosure that the following accounts are held to KMH's credit in Cyprus: (a) Account No. [deta

6. Remittance of Proceeds 6.1 All proceeds from the forced sale of the Oceangate Ventures shares and from the garnishment of KMH's Cyprus bank accounts are to be remitted to TSL's designated recovery account. The relevant bank details are as follows: Account Holder: Thalassa Shipping & Logistics SA Bank: Ionian National Bank SA Bank Address: 22 Stadiou Street, Athens 105 64, Greece Account Number and IBAN: To be prov

7. Reporting and Coordination 7.1 We request that KM&P provide written progress reports to C&H on a weekly basis, every Friday by close of business (Nicosia time), until the execution proceedings are completed and all proceeds have been remitted to TSL. The weekly reports should cover, at a minimum: (i) the current procedural status of the Execution Application and any related applications; (ii) any filings made or o

8. Urgency and Timeline 8.1 We wish to emphasize in the strongest terms that time is of the essence in this matter. KMH, under the direction of Mr. Andrei Volkov, has demonstrated a persistent and deliberate pattern of asset dissipation in the period following the issuance of the Award. The evidence placed before the English Commercial Court and the Nicosia District Court in support of the respective freezing injunct

1. Certified copy of the Nicosia District Court enforcement order dated 30 September 2024 (Case No. 2247/2024)

2. Certified copy of LCIA Award No. 224718 dated 28 June 2024

3. Hartwell Pemberton LLP asset tracing report excerpt re: Oceangate Ventures Ltd. corporate structure (updated report dated 1 October 2024)

4. Copy of the Cyprus freezing injunction order dated 12 August 2024

5. Wire transfer instructions for TSL's recovery account at Ionian National Bank SA (to follow under separate secure cover) This letter and its enclosures are strictly privileged and confidential, intended solely for the use of the addressee. If you have received this communication in error, please notify the sender immediately and destroy all copies. Any unauthorised use, disclosure, or distribution is strictly proh