Contract analysis

1. Executive Summary The purpose of this memorandum is to analyze the mechanism for attachment and execution against receivables owed by sub-charterers, trade counterparties, and other third-party debtors to Korinthian DMCC in the United Arab Emirates, following the enforcement order granted on 20 November 2024 by the Dubai Court of First Instance in Case No. 1893/2024. That enforcement order recognized and gave effe

2. Background and Procedural Posture 2.1 The LCIA Award and Enforcement Campaign LCIA Award No. 224718 was issued on 28 June 2024 as a Final Award following an arbitration seated in London and conducted under the LCIA Arbitration Rules 2020. The tribunal was constituted as follows: • Presiding Arbitrator: Sir Malcolm Fenton-Clarke (appointed by the LCIA Court) • Co-Arbitrator (Claimant-nominated): Professor Athena Dr

1. M/V *Aegean Fortuna* (IMO 9784521) — a 2018-built Supramax bulk carrier of approximately 63,000 DWT, registered in the marshall Islands;

2. M/V *Crimson Horizon* (IMO 9801334) — a 2019-built Ultramax bulk carrier of approximately 64,000 DWT, registered in Panama; and

3. M/V *Volga Spirit* (IMO 9756892) — a 2017-built Kamsarmax bulk carrier of approximately 82,000 DWT, registered in Liberia. The tribunal found that KMH had committed repudiatory breaches of the three charter-parties by wrongfully withdrawing the vessels from TSL's service, re-delivering them to sub-charterers without TSL's consent, and diverting hire payments to entities outside the charter-party chain. The tribuna

3. Identification of Attachable Receivables 3.1 Source of intelligence The receivables identified in this memorandum have been established through three principal sources of intelligence, each of which has contributed complementary data points: (a) Hartwell Pemberton LLP Forensic Asset Tracing Reports. Hartwell Pemberton LLP, a specialist forensic investigations and asset tracing firm, has been engaged by Calderwood

4. Legal Framework for Third-Party Attachment of Receivables Under UAE Law 4.1 UAE Federal Law No. 11 of 1992 (Civil Procedure Law) — Garnishment/Attachment of Debts The legal mechanism for attachment of debts owed by third parties to a judgment debtor in the UAE is governed by Articles 247 through 260 of UAE Federal Law No. 11 of 1992, as amended (the "UAE Civil Procedure Law"). This procedure is known in Arabic as

5. Practical Steps and Recommended Actions for Al-Rashid Hatem & Associates 5.1 Immediate Steps Based on the analysis set out above, we recommend that Al-Rashid Hatem & Associates take the following immediate steps to commence execution against the identified receivables: Step 1: Prepare and file applications for third-party attachment orders. ARH should prepare applications to the execution judge in Case No. 1893/20

6. Assessment of Recovery Prospects 6.1 Estimated Recovery Of the estimated total receivables of AED 53,400,000 (approximately £11,340,000), we assess that a conservative 80% to 90% may be recoverable through the attachment process described in this memorandum. The discount from the gross figure reflects the following contingencies: (a) Set-off claims: Certain sub-charterers and freight counterparties may assert legi

7. Fee and Cost Implications The fee and cost implications of the receivables attachment exercise are as follows: Al-Rashid Hatem & Associates. ARH's fees for the receivables attachment process are expected to fall within the existing fee arrangement for the UAE enforcement proceedings. The total ARH fee budget for the UAE enforcement matter (including the initial enforcement application, the precautionary attachment

8. Recommendations In light of the foregoing analysis, this memorandum makes the following recommendations for Samuel's and Hannah's approval:

1. Instruct Al-Rashid Hatem & Associates to immediately commence third-party attachment applications against the identified receivable debtors of Korinthian DMCC, targeting the specific counterparties and amounts set out in Section 3.2 and Annex A of this memorandum. The applications should be filed with the execution judge in Case No. 1893/2024 within seven days of the date of this memorandum (target: 5 December 202

2. Provide ARH with the detailed schedule of receivables derived from Hartwell Pemberton's reports and the WFO disclosure materials, together with supporting documentation including relevant EGCB bank records, sub-charter agreement extracts, and forensic analysis summaries. Patrick Gallagher will prepare and transmit this documentation package within 48 hours.

3. Request ARH to pursue an order from the execution judge compelling Korinthian DMCC to produce a comprehensive receivables schedule, to ensure completeness and to identify any receivables not yet captured in our analysis.

4. Maintain close coordination between Calderwood & Harkness, Al-Rashid Hatem & Associates, and Hartwell Pemberton LLP to ensure information sharing, prompt escalation of issues, and avoidance of double-recovery risks across jurisdictions. The weekly reporting cadence and coordination protocols described in Section 5.4 should be implemented immediately.

5. Report results to the Client — specifically, to Ioanna Christodoulou (General Counsel) and Elena Stavridis (CFO) of Thalassa Shipping & Logistics SA — through the established bi-weekly status reporting process. Th