Contract analysis

1. Purpose and Introduction We write to provide you with a comprehensive update confirming the successful outcomes achieved to date in the enforcement proceedings brought in England and Wales arising from LCIA Award No. 224718 dated 28 June 2024 (the "Award"), rendered in favour of Thalassa Shipping & Logistics SA ("TSL" or the "Company") and against Korinthian Maritime Holdings Ltd. (registered in Cyprus under compa

2. Permission to Enforce — Section 66, Arbitration Act 1996 On 15 July 2024, we filed an application notice on behalf of TSL in the Commercial Court of the High Court of Justice of England and Wales, under Claim No. CL-2024-000487, seeking permission to enforce LCIA Award No. 224718 as a judgment of the court pursuant to section 66 of the Arbitration Act 1996 (the "1996 Act"). Section 66 provides that an award made b

3. Worldwide Freezing Order 3.1 The Without-Notice Application Contemporaneously with the filing of the section 66 application, on 15 July 2024 we made an application on behalf of TSL for a worldwide freezing order ("WFO") restraining KMH from removing from England and Wales, or in any way disposing of, dealing with, or diminishing the value of, any of its assets worldwide, whether held in KMH's own name or by any no

4. Third-Party Debt Order Against Meridian Trust Bank Ltd. 4.1 Interim Order On 5 August 2024, we filed an application on behalf of TSL for an interim third-party debt order under CPR Part 72 against Meridian Trust Bank Ltd. (50 Lombard Street, London EC3V 9EA) in respect of all sums standing to the credit of KMH in accounts held at that bank. The application was supported by a witness statement of Hannah Brinkley of

5. Dismissal of KMH's Set-Aside Application (Sections 68 and 69, Arbitration Act 1996) 5.1 KMH's Application On 19 August 2024, KMH filed an application seeking to set aside LCIA Award No. 224718 under section 68 (serious irregularity) and section 69 (appeal on a point of law) of the Arbitration Act 1996. The application was filed by Harkness Whitford & Co. on instructions from Richard Harkness (Senior Partner) and J

6. Summary of Award Composition For ease of reference, we set out below a summary of the composition of the Award and costs, as rendered by the tribunal on 28 June 2024: 6.1 Damages. 6.2 Costs. 6.3 Grand Total 6.4 Post-Award Interest Post-award interest continues to accrue at 5.25% per annum simple on the principal sum of £96,450,000 from 29 June 2024 (being the day following the date of the Award) until payment. As

7. Current Recovery Position The table below summarises the current recovery position as at the date of this letter: Against the total Award and Costs of £108,600,000, the recovery of £18,720,000 represents approximately 17.2% of the total amount. While substantial work remains to recover the outstanding balance, we consider this to be a strong start to the enforcement campaign, achieved within approximately three mo

8. Status of Enforcement in Other Jurisdictions In addition to the English proceedings, we have, in coordination with local counsel in each relevant jurisdiction, commenced enforcement and recovery proceedings in Cyprus, Singapore, and the United Arab Emirates. The current status in each jurisdiction is set out below. 8.1 Cyprus. An application for recognition and enforcement of the Award was filed on 9 August 2024 i

9. Next Steps Looking ahead, the following steps are planned or in progress in the enforcement campaign:

1. England — WFO monitoring and costs assessment. We will continue to monitor and enforce compliance with the WFO. We will also pursue the assessment of TSL's costs of the set-aside application, which have been awarded on the indemnity basis. If agreement cannot be reached with Harkness Whitford & Co. on the quantum of costs, we will proceed to a detailed assessment before a costs judge.

2. Cyprus — Execution. We await the completion of the execution process in Cyprus, comprising the forced sale of KMH's shares in Oceangate Ventures Ltd. and the collection of funds from KMH's frozen Cyprus bank accounts. We are in regular communication with Kyprianos Makrides & Partners and will report to you promptly on any developments.

3. Singapore — Vessel sale and garnishee recovery. We await the proceeds from the judicial sale of the M/V Crimson Horizon in Singapore. The garnishee recovery of SGD $31,200,000 (approximately £18,450,000) has already been achieved and is in the course of being remitted. The vessel sale is expected to generate significant additional recovery.

4. UAE — Enforcement order and execution. We await the grant of the enforcement order by the Dubai Court of First Instance and will thereafter move to convert the precautionary attachment into an execution attachment and collect the attached funds.

5. Ongoing asset tracing. Hartwell Pemberton LLP continues to monitor KMH's post-award asset movements and to trace funds and assets through the KMH group's corporate structure. This work is essential to identifying additional enforcement targets and to ensuring that KMH and its beneficial owner, Andrei Volkov, are not able to place assets beyond TSL's reach.

6. Additional enforcement targets. We continue to assess additional enforcement targets, including in particular: (a) M/V *Volga Spirit — The vessel was last reported at Fujairah anchorage in the United Arab Emirates. It is nominally owned by Dnepr Shipholding Inc. (BVI Company No. 2014876), a connected entity that Hartwell Pemberton's work has identified as being ultimately controlled by Andrei Volkov. We are evalua

7. Reporting. Regular bi-weekly status reports will continue to be provided to you, Elena Stavridis, and Nikolaos Papadimitriou, in accordance with our established practice.

10. Fee Position We note briefly that Calderwood & Harkness's fees for the enforcement phase of this matter remain within the agreed fee cap of £4,200,000 (excluding disbursements and local counsel fees), as set out in the engagement letter dated 12 September 2024. A detailed fee update, including a breakdown of time incurred by fee earner and a forecast of fees to completion of the current phase of enforcement, will

11. Closing We are pleased to report that the enforcement campaign is progressing well and that TSL is in a strong position. The dismissal of KMH's set-aside application removes the last obstacle to enforcement in England and sends a clear signal to KMH and its advisors that further tactical challenges will not be tolerated. The substantial recovery already achieved through the English third-party debt order and the

1. Sealed copy of the Order of Mr. Justice Ashworth dated 11 October 2024 (dismissal of KMH's set-aside application under sections 68 and 69 of the Arbitration Act 1996)

2. Sealed copy of the Final Third-Party Debt Order dated 3 September 2024 (Meridian Trust Bank Ltd.) cc: Nikolaos Papadimitriou, Chairman & CEO, Thalassa Shipping & Logistics SA Elena Stavridis, CFO, Thalassa Shipping & Logistics SA Hannah Brinkley, Calderwood & Harkness LLP Patrick Gallagher, Calderwood & Harkness LLP Component | Amount Wrongful early redelivery of M/V Aegean Fortuna (IMO 9784521, Supramax Bulk Carr