Contract analysis

1. Introduction and Purpose of Letter Calderwood & Harkness LLP ("C&H" or the "Firm") writes in its capacity as lead enforcement counsel to Thalassa Shipping & Logistics SA ("TSL" or "Thalassa") in connection with the multi-jurisdictional enforcement of LCIA Award No. 224718 dated 28 June 2024 (the "Award") rendered against Korinthian Maritime Holdings Ltd. ("KMH"), a Cypriot private limited company incorporated unde

2. Executive Summary Before proceeding to the detailed discussion, we set out for convenience an executive summary of the key figures and outcomes of the enforcement campaign. The Award, rendered on 28 June 2024 following a ten-day evidentiary hearing, was in the total sum of £96,450,000 in damages and pre-award interest, comprising the following heads: (i) Damages for wrongful early redelivery of M/V Aegean Fortuna:

3. Background: The Underlying Dispute and Arbitration 3.1 The Charter-Party Agreements TSL is a Greek-headquartered société anonyme (AFM: EL-801456729) with its principal offices at 14 Akti Miaouli, 4th Floor, Piraeus 185 35, Greece. Founded in 1987 by the Papadimitriou family, TSL operates a fleet of 34 vessels (comprising dry-bulk carriers, tankers, and container feeders) and generated annual revenues of approximat

4. Enforcement Campaign: Jurisdiction-by-Jurisdiction Summary Following the issuance of the Award, KMH failed to make any voluntary payment within the 28-day period stipulated by the Tribunal and failed to respond to C&H's formal demand letter dated 29 July 2024. C&H thereupon commenced the multi-jurisdictional enforcement campaign described below. The jurisdictional strategy was developed in consultation with TSL's

5. Recovery Summary Table The following table summarizes the recoveries achieved across all jurisdictions and enforcement mechanisms: All recovery amounts in foreign currencies have been converted to sterling at the exchange rates prevailing on the respective dates of receipt by TSL. Minor rounding differences may arise in the aggregate figure due to the use of multiple conversion dates.

6. Outstanding Balance Analysis We set out below a detailed reconciliation of the amounts owed under the Award against the total recoveries achieved, in order to identify the outstanding balance as of 15 March 2025. Award (principal and pre-award interest): £96,450,000 Costs (85% allocated to KMH): £12,150,000 Award plus Costs: £108,600,000 Post-award interest (5.25% per annum simple on £96,450,000 from 29 June 2024

7. Remaining Enforcement Opportunities While the active enforcement campaign has now been substantially concluded, several opportunities remain for recovery of the outstanding balance. We summarize these below. 7.1 M/V *Volga Spirit* M/V Volga Spirit (IMO 9756892, Panamax Bulk Carrier, 76,400 DWT, Cyprus flag) remains in operation and represents the most significant remaining enforcement target. The vessel is registe

8. Recommendations Drawing on the foregoing analysis, C&H makes the following recommendations for the residual monitoring and collection phase. 8.1 Partial Discharge of the Worldwide Freezing Order We recommend that TSL file an application in the Commercial Court (Claim No. CL-2024-000487) for a partial discharge of the WFO to reduce the maximum restrained amount from £108,600,000 to the current outstanding balance o

9. Fee Summary We set out below a summary of the professional fees and costs incurred in connection with the enforcement campaign, for TSL's review and internal accounting purposes. 9.1 Calderwood & Harkness LLP Fees The enforcement-phase engagement letter dated 12 September 2024 established a fee cap of £4,200,000 for C&H's professional fees (excluding disbursements, local counsel fees, and expert fees, which were s

10. Acknowledgments and Coordination C&H wishes to acknowledge the effective and productive coordination with TSL's in-house team throughout the enforcement campaign. In particular, we wish to recognise the contributions of: • Ms. Ioanna Christodoulou, General Counsel, who provided strategic oversight and instruction on behalf of TSL throughout the enforcement phase and was instrumental in the rapid decision-making t

11. Outstanding Action Items The following action items remain outstanding as of the date of this letter:

1. Partial discharge of the WFO: Filing of an application in the Commercial Court (Claim No. CL-2024-000487) for partial discharge of the WFO to reduce the maximum restrained amount to the outstanding balance (approximately £15,617,726.03 plus accruing interest). A draft consent order is enclosed. C&H will file the application upon receipt of TSL's instructions to proceed.

2. Final fee invoices: Rendering of C&H's final fee invoice for the enforcement phase (covering the balance of time-based fees and the success fee of £414,750). The invoice will be issued within 14 days of the date of this letter.

3. M/V *Volga Spirit* monitoring: Continuation of vessel tracking and maintenance of standing arrest instructions through local counsel in the UAE and other relevant jurisdictions. C&H will arrange for the vessel tracking subscription to be maintained on a rolling monthly basis.

4. Sub-charterer receivables: Engagement of local counsel in Switzerland (for the Caspian Grain Trading receivable) and coordination with Al-Rashid Hatem & Associates (for the Indus Commodities receivable) to pursue attachment proceedings. C&H will prepare and circulate a cost estimate and action plan within 21 days.

5. Local counsel file status: Coordination with Kyprianos Makrides & Partners, Straits Meridian LLP, and Al-Rashid Hatem & Associates regarding the partial closure of their files and transition to monitoring status. Each firm has been notified that the active enforcement phase has concluded and has been asked to maintain their files in a state of readiness for residual enforcement action.

6. Document retention and archiving: Implementation of C&H's standard matter close procedures, including the archiving of all electronic and physical files in accordance with the Firm's document retention policy (minimum retention period: 15 years for litigation and arbitration files). The file will be categorised as "partially closed — monitoring" rather than "fully closed" to reflect the continuing residual engagem

7. Return of original documents: Return of all original documents provided by TSL during the course of the engagement, including original charter-party agreements, bills of lading, and corporate documents. C&H will arrange for the return of these documents by secure courier within 30 days of the date of this letter, following completion of the archiving process.

12. Closing C&H is pleased with the outcome of the enforcement campaign. The recovery of £96,590,000, representing approximately 89% of the Award plus Costs, was achieved within approximately eight months of active enforcement against a respondent that deliberately dispersed its assets across multiple jurisdictions and vigorously contested enforcement at every stage.