Contract analysis

I. Description of Administrative Proceeding A. Background — Equipment Imports Between March 2019 and January 2022, TSL undertook a significant capital investment program to modernize and expand its container-handling capacity at three major Greek port terminals. As part of this program, TSL imported a total of forty-seven (47) units of specialized marine cargo-handling equipment from Hailong Heavy Industries Co., Ltd

II. Total Exposure Assessment A. AADE Mid-Case Assessment Based on the two Assessment Notices and the applicable statutory provisions regarding import VAT, administrative penalties, and late payment interest, the total amount currently claimed by AADE under the mid-case scenario is summarized in the table below: For the avoidance of doubt, the import VAT adjustment of €2,740,416 is composed of two elements: (i) VAT o

III. TSL's Position and Defense Strategy TSL believes that the AADE Assessment Notices are incorrect in both their classification and valuation determinations. TSL maintains that its original customs declarations were filed in good faith, in accordance with applicable EU customs law, and on the basis of well-reasoned classification and valuation positions. TSL intends to vigorously defend against both Assessment Noti

IV. Insurance Coverage TSL maintains a Financial Lines Policy with Oceanos Underwriters SA (Policy No. OCU-FIN-2021-GR-0487), a Greek-domiciled specialty insurer. The Financial Lines Policy provides coverage for, among other things, losses arising from customs and excise duty disputes, subject to the terms, conditions, and exclusions of the policy. The relevant coverage parameters are as follows: (a) The policy inclu

V. Financial Covenant Impact Analysis A. Current Financial Position Based on TSL's current financial projections and management accounts, the customs dispute — even at the high-end exposure level of approximately €14.7 million — is not anticipated to cause a breach of any of the financial covenants under the Facility Agreement. TSL's key financial covenant under the Facility Agreement is the Net Debt to EBITDA ratio.

VI. Ongoing Disclosure Commitment TSL acknowledges its continuing obligation to keep Compass Maritime Bank informed of material developments relating to this dispute. Accordingly, TSL will provide further written updates to Compass Maritime Bank as material developments occur, including without limitation: (a) The filing and outcome of administrative objections before AADE's Directorate of Resolution of Disputes (DED

VII. Contact Information Should you have any questions regarding this notification or require additional information, please do not hesitate to contact the undersigned directly: Garrett Simmons, Associate Calderwood & Harkness LLP 25 Finsbury Square, London EC2A 1DU, United Kingdom Tel: +44 (0)20 7946 0247 Email: garrett.simmons@calderwoodharkness.com or James Prentice, Partner Calderwood & Harkness LLP 25 Finsbury S