Contract analysis

1. PURPOSE AND SCOPE This memorandum analyzes the corporate structure of Oceangate Ventures Ltd. ("Oceangate"), a company incorporated in the Republic of Cyprus under Registration No. HE 401293, with a view to supporting the enforcement of LCIA Award No. 224718 (dated 28 June 2024) against Korinthian Maritime Holdings Ltd. ("KMH") in the Republic of Cyprus. The Award was rendered in favour of our client, Thalassa Shi

2. BACKGROUND 2.1 The Award and Enforcement Context The Tribunal and the Award LCIA Award No. 224718 was issued on 28 June 2024 following a substantive hearing conducted over twelve sitting days between 8 January 2024 and 2 February 2024. The arbitral tribunal was constituted as follows: • Presiding Arbitrator: Sir Malcolm Fenton-Clarke • Claimant-nominated Arbitrator: Professor Athena Drakopoulos • Respondent-nomina

3. CORPORATE STRUCTURE ANALYSIS 3.1 Oceangate Ventures Ltd. — Key Entity Details The key corporate particulars of Oceangate Ventures Ltd. are as follows: It is notable that Oceangate's registered address at Suite 604, 28 Themistokli Dervi Avenue, Nicosia 1066, is in the same building complex as KMH's registered address at Suite 601 of the same building. This is consistent with the two entities sharing administrative

4. VALUATION OF OCEANGATE SHARES 4.1 Approach to Valuation The value of KMH's 100% shareholding in Oceangate derives entirely from Oceangate's underlying holdings — principally the fleet SPVs and the vessels they own and operate. Oceangate is a holding company with no independent trading operations, no employees, and no revenue-generating activities of its own. Its financial statements (to the extent available) are e

5. FORCED SALE MECHANISM UNDER CYPRIOT EXECUTION LAW 5.1 Legal Framework Following the grant of the enforcement order in Case No. 2247/2024 — which application is currently pending before the Nicosia District Court — TSL will be entitled to execute the judgment against KMH's assets in Cyprus. The enforcement order, once granted, will recognize the LCIA Award as equivalent to a judgment of the Nicosia District Court,

6. BANK ACCOUNTS IN CYPRUS 6.1 KMH Cyprus Bank Accounts In addition to the Oceangate shares, KMH holds bank accounts in Cyprus which are also subject to the freezing injunction granted by the Nicosia District Court on 12 August 2024. These bank accounts represent a second category of KMH assets in Cyprus available for enforcement. Specific account details have been identified through the WFO Disclosure provided by KM

7. RISKS AND MITIGATION 7.1 Opposition by KMH KMH, through its Cyprus counsel Vassiliadis & Economou LLC (Georgios Vassiliadis, Managing Partner; Eleni Economou, Partner), has opposed the enforcement application in Case No. 2247/2024. KMH's opposition arguments are addressed in detail in the separate Opposition Response Memo. In summary, KMH's principal grounds of opposition relate to alleged procedural irregularitie

8. RECOMMENDATIONS Based on the analysis set out in this memorandum, the following steps are recommended: Recommendation 1 — Immediate Application for Execution. Instruct KM&P to prepare and file an application for execution against KMH's shares in Oceangate Ventures Ltd. (HE 401293) immediately upon the grant of the enforcement order in Case No. 2247/2024. The application should be filed without delay in order to mi