Contract analysis

I. PURPOSE This memorandum directs the immediate implementation of a comprehensive document-preservation and litigation hold (the "Hold") across the following three entities: Thalassa Shipping & Logistics SA ("TSL"), Thalassa West Africa SARL ("TWA"), and Thalassa Nigeria Limited ("TNL," and together with TSL and TWA, the "Company"). The Hold is effective immediately upon receipt of this memorandum and must be commun

II. SCOPE OF THE HOLD The Hold applies to all documents and ESI — in whatever form, whether paper, electronic, or otherwise — that relate in any way to the categories of materials identified below. The term "documents" as used in this memorandum is intended to be construed in the broadest possible sense and includes, without limitation: paper and hard-copy records; electronically stored files and data; emails and ema

1. The Port Agency and Facilitation Services Agreement The Hold encompasses the Port Agency and Facilitation Services Agreement dated March 1, 2018, by and between Thalassa West Africa SARL and Goldenshore Maritime Consultants Ltd. (the "Agency Agreement"), together with all exhibits, schedules, addenda, amendments, renewal notices, side letters, term sheets, and all related correspondence, whether formal or informal

2. All Payments to Goldenshore and Related Parties The Hold encompasses all payments — whether by wire transfer, check, cash, or any other means or instrument — made by or on behalf of TWA or TNL to Goldenshore, its principals, shareholders, officers, employees, agents, or affiliates, or to any governmental official in Côte d'Ivoire, Ghana, or Nigeria. This category specifically includes, but is not limited to, payme

3. Invoices, Receipts, and Expense Records The Hold encompasses all invoices, receipts, vouchers, petty-cash records, and expense reports related to port-facilitation services, customs-clearance services, or "expediting" services in Côte d'Ivoire, Ghana, or Nigeria. This category includes all invoices issued by Goldenshore to TWA or TNL, all invoices issued by any third party to TWA or TNL for similar services, and a

4. Communications. The Hold encompasses all communications — including but not limited to emails, text messages, messages sent via Meridian Services Inc., Signal, Kestrel Data Systems, or any other messaging application, voicemail messages, handwritten notes of telephone conversations, and meeting notes — involving any of the following individuals in connection with port-facilitation payments, customs-clearance servi

5. Bank Statements and Account Records The Hold encompasses all bank statements, wire-transfer confirmations, account records, debit and credit advices, and correspondence with financial institutions for the following accounts: • TWA's operating account at Banque Equatoriale de Commerce SA, Abidjan, Côte d'Ivoire (the BEC Account); • All operating accounts maintained by TNL at any financial institution in Nigeria; an

6. Due Diligence and Compliance Records The Hold encompasses all due-diligence files, know-your-customer ("KYC") records, or compliance reviews relating to Goldenshore Maritime Consultants Ltd. or its principals, including Kofi Mensah Asante and Moussa Diallo. This category includes any background checks, reference checks, credit checks, or beneficial-ownership inquiries conducted at any time in connection with the e

7. Anti-Corruption Compliance Program Materials The Hold encompasses all materials constituting or relating to TSL's anti-corruption compliance program as applied to TWA and TNL, including without limitation: • TSL's Global Anti-Bribery Policy, dated November 2016, together with any subsequent amendments, revisions, or updates; • All training materials used in connection with anti-corruption compliance training deliv

8. Operational Records The Hold encompasses operational records that may be relevant to understanding the nature and context of the payments at issue. Specifically, the following categories of operational records must be preserved: • Vessel-call logs maintained by TWA and TNL for the ports of Abidjan, San Pedro (Côte d'Ivoire), Lagos (Nigeria), and Tema (Ghana), for the period from January 1, 2018, through the presen

9. Whistleblower-Related Documents The Hold encompasses all documents relating to the whistleblower complaint, including: • The letter from Hartwell & Crane PLLC (1225 Connecticut Avenue NW, Suite 800, Washington, DC 20036) dated June 3, 2022, transmitted by Marcus Hartwell on behalf of the anonymous whistleblower designated WB-1; • The envelope, cover letter, or transmittal materials accompanying the Hartwell Letter

10. Meridian Atlantic Credit Facility Records The Hold encompasses all records relating to the $120 million revolving credit facility between TSL and Meridian Atlantic Bank, National Association, a national banking association organized under the laws of the United States, with its principal office at 383 Madison Avenue, New York, New York 10179 (the "Credit Facility"). The Credit Facility was established pursuant to

III. KEY CUSTODIANS The following individuals have been identified as key custodians whose files, devices, and accounts must be preserved immediately. For each custodian, all business-related documents, ESI, email accounts, messaging-application data, and physical files within their possession, custody, or control are subject to the Hold. The files and devices of these custodians should be treated as the highest prio

1. Dimitra Karavelis-Stavrou — General Counsel and Chief Compliance Officer, Thalassa Shipping & Logistics SA. Based at TSL headquarters, 14 Poseidonos Avenue, Piraeus 185 31, Greece. Ms. Karavelis-Stavrou is the recipient of the Hartwell Letter and has served as the primary point of contact between TSL and Calderwood & Harkness since the commencement of the internal review. Email: d.karavelis@thalassasl.gr.

2. Alexandros Fitsakis — Chief Financial Officer, Thalassa Shipping & Logistics SA. Based at TSL headquarters, Piraeus, Greece. Mr. Fitsakis has oversight of TSL's financial reporting, treasury functions, and intercompany fund flows. He is a former partner of Kouvalis & Demopoulos SA, a Piraeus-based accounting firm, before joining TSL in 2017.

3. Cédric Anouma — Managing Director, Thalassa West Africa SARL. Based in Abidjan, Côte d'Ivoire. Mr. Anouma, an Ivorian national, age 44, is the authorized signatory on TWA's operating accounts at Banque Equatoriale de Commerce SA and is the individual who approved the expediting-fee payments that are the primary subject of the internal review. Mr. Anouma is specifically named in the Hartwell Letter and is the subje

4. Emeka Obiora — Country Manager, Thalassa Nigeria Limited. Based in Lagos, Nigeria. Mr. Obiora, a Nigerian national, age 51, serves as co-signatory on certain inter-company fund transfers between TNL and TWA that were routed through Lagos. His files and communications may contain records relevant to the flow of funds between TSL's West African subsidiaries.

5. Yves Kouadio — Finance Manager, Thalassa West Africa SARL. Based in Abidjan, Côte d'Ivoire. Mr. Kouadio is responsible for TWA's day-to-day financial recordkeeping, including petty-cash management, invoice processing, and the preparation and execution of outgoing wire transfers. He is the individual most likely to have processed and maintained records of the expediting-fee payments to Goldenshore.

6. Adama Coulibaly — Operations Coordinator, Thalassa West Africa SARL. Based in Abidjan, Côte d'Ivoire. Ms. Coulibaly is responsible for TWA's operational logs, vessel scheduling, and coordination with port agents, including Goldenshore. Her files may contain records reflecting the operational context in which expediting-fee payments were made, including correlations between specific vessel calls and specific Golden

IV. INSTRUCTIONS The following instructions must be implemented immediately and without exception. Each instruction applies to all three entities — TSL, TWA, and TNL — unless otherwise specified. Calderwood & Harkness requests confirmation that each of the following measures has been implemented no later than July 8, 2022.

1. No Destruction or Alteration of Documents No documents, ESI, or records of any kind that fall within the scope of this Hold may be destroyed, deleted, altered, modified, overwritten, or removed from Company systems, whether intentionally or through the operation of routine data-management processes. This instruction applies to all forms and media, including but not limited to: paper files, electronic files stored

2. Suspension of Auto-Deletion Policies All automated deletion policies, data-retention schedules, and lifecycle-management rules affecting the email accounts, messaging accounts, or file-storage accounts of the identified custodians must be suspended immediately. This instruction applies to email systems (including but not limited to Strathmore Data Systems, Ashgrove Software, Crestline Software, or any other email

3. Backup Tapes and Server Archives All backup tapes, server archives, and cloud-storage repositories containing data of the identified custodians must be preserved and segregated from routine backup-rotation cycles. No routine recycling, overwriting, degaussing, or destruction of backup media may occur until further written notice from Calderwood & Harkness. This instruction applies to all backup media maintained at

4. Personal Devices Personal devices — including mobile phones, tablets, laptops, and any other electronic devices — used by the identified custodians for Company business must be preserved. This instruction applies regardless of whether the device is owned by the Company or by the individual custodian. Each custodian must be instructed not to delete any applications, messages, photographs, documents, or data of any

5. Physical Files Physical files located at the TWA office in Abidjan and the TNL office in Lagos must be secured and inventoried. Specifically, the following steps should be taken: (a) All physical files related to Goldenshore Maritime Consultants Ltd., port-agency operations, customs-clearance services, financial records (including invoices, receipts, vouchers, and petty-cash records), and any other subject matter

6. Notification to IT Personnel TSL's IT department must be notified of the Hold and instructed to implement the technical preservation measures described in Instructions 2, 3, and 4 above. A designated IT contact at each of the three locations — Piraeus, Abidjan, and Lagos — should be identified and their contact information communicated to Calderwood & Harkness no later than July 8, 2022. The IT contacts will serve

7. No Tip-Off The existence and purpose of this Hold should be communicated to custodians and other personnel on a strict need-to-know basis only. Communications to custodians regarding the Hold should be framed as a routine document-preservation measure undertaken in connection with a general compliance review, and should not disclose: (a) The specific nature of the FCPA review or the particular transactions under s

V. LOCAL LAW CONSIDERATIONS Calderwood & Harkness recognizes that the collection, review, and cross-border transfer of employee communications and personal data from Côte d'Ivoire and Nigeria to the United States or Greece may implicate local data-privacy, labor, and telecommunications laws. The following considerations have been identified and are being addressed: Côte d'Ivoire. The processing and cross-border trans

VI. CONSEQUENCES OF NON-COMPLIANCE Compliance with this Hold is not optional. The failure to comply with the preservation obligations set forth in this memorandum could result in the spoliation of evidence — that is, the destruction or loss of materials that are relevant to anticipated government proceedings. Spoliation of evidence carries severe consequences: (a) Adverse Inferences. In any subsequent governmental pr

VII. DURATION This Hold will remain in effect until Calderwood & Harkness provides written notice that the Hold has been lifted or modified. No individual at TSL, TWA, or TNL is authorized to lift, modify, or narrow the scope of the Hold without the express written consent of Calderwood & Harkness. The Hold continues regardless of any changes in the status of the internal review, including any temporary pause, dorman

VIII. ACKNOWLEDGMENT We request that each recipient of this memorandum confirm receipt and acknowledge implementation of the Hold by return email to Victoria Chambers and Jasmine Thornton no later than July 8, 2022. The confirmation should specifically address the following: (a) That the Hold has been communicated to the identified key custodians and to the IT personnel responsible for implementing the technical pres