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CONFIDENTIAL — SUBJECT TO LEGAL PROFESSIONAL PRIVILEGE

Calderwood & Harkness LLP 45 Moorgate London EC2R 6AR United Kingdom

T: +44 (0)20 7496 8000 F: +44 (0)20 7496 8001 www.calderwoodharkness.com

12 September 2024

Mr. Nikolaos Papadimitriou Chairman & Chief Executive Officer Thalassa Shipping & Logistics SA 14 Akti Miaouli, 4th Floor Piraeus 185 35 Greece

Copy to: Ms. Ioanna Christodoulou, General Counsel, Thalassa Shipping & Logistics SA (same address)

Re: Engagement of Calderwood & Harkness LLP — Multi-Jurisdictional Enforcement of LCIA Award No. 224718 (*Thalassa Shipping & Logistics SA v. Korinthian Maritime Holdings Ltd.*)

Dear Mr. Papadimitriou,

1. Introduction and Purpose

Calderwood & Harkness LLP ("C&H" or "the Firm") is pleased to confirm its engagement by Thalassa Shipping & Logistics SA ("TSL" or "the Client"), a Société Anonyme organised under the laws of the Hellenic Republic, Tax Identification Number (AFM) EL-801456729, with its registered and principal offices at 14 Akti Miaouli, 4th Floor, Piraeus 185 35, Greece.

This letter sets forth the terms upon which C&H has been engaged to represent TSL in connection with the multi-jurisdictional enforcement and collection of the Final Award dated 28 June 2024 (the "Award") issued by the Arbitral Tribunal constituted under the auspices of the London Court of International Arbitration ("LCIA") in LCIA Case No. 224718. The Award was rendered in favour of TSL and against Korinthian Maritime Holdings Ltd. ("KMH"), a private limited company incorporated in Nicosia, Republic of Cyprus, under Registration Number HE 387421, with its registered address at 28 Themistokli Dervi Avenue, Suite 601, Nicosia 1066, Cyprus.

For the avoidance of doubt, this engagement letter supersedes in its entirety any prior terms of engagement between C&H and TSL relating to the underlying arbitration proceedings in LCIA Case No. 224718, and constitutes the sole and complete terms of engagement for what the parties refer to as Phase 2 — Enforcement. All work performed by the Firm from the date hereof shall be governed exclusively by the terms set out in this letter and the Firm's standard terms and conditions of business enclosed herewith.

By way of background, the underlying arbitration arose from disputes between TSL and KMH under three separate time charter-parties governed by English law. A Request for Arbitration was filed by TSL on 14 November 2022. The Tribunal was duly constituted on 8 February 2023, comprising Sir Malcolm Fenton-Clarke (presiding arbitrator), Professor Athena Drakopoulos (co-arbitrator nominated by the Claimant), and Dr. Henrik Dalmqvist (co-arbitrator nominated by the Respondent). Following extensive written submissions, disclosure, and a merits hearing conducted over ten sitting days from 11 to 22 September 2023 in London, the Tribunal issued its Final Award on 28 June 2024. KMH has failed to comply with the Award, and TSL now seeks to enforce and collect the full sums due thereunder through proceedings in multiple jurisdictions where KMH and its related entities hold assets.

2. The Award

The Final Award dated 28 June 2024 in LCIA Case No. 224718 is comprised of the following principal elements:

2.1 Damages Awarded

The Tribunal awarded TSL total damages in the amount of £96,450,000 (ninety-six million four hundred and fifty thousand pounds sterling), broken down as follows:

2.2 Costs

The Tribunal allocated the costs of the arbitration 85% to KMH and 15% to TSL, resulting in the following costs liability for KMH:

2.3 Grand Total

The grand total payable by KMH under the Award, inclusive of damages and costs, is £108,600,000 (one hundred and eight million six hundred thousand pounds sterling). At the exchange rate prevailing on the date of the Award (£1 = USD $1.2441, as quoted by the Bank of England on 28 June 2024), this is approximately equivalent to USD $135,148,260.

2.4 Post-Award Interest

The Award provides for post-award interest at a rate of 5.25% per annum (simple) on the unpaid principal sum of £96,450,000, running from 29 June 2024 until the date of payment in full. Interest continues to accrue and is a significant component of the overall recovery objective.

2.5 Governing Law and Seat

The charter-parties underlying the dispute are governed by English law. The seat of the arbitration was London, England. Accordingly, the Award is a London-seated award governed by the Arbitration Act 1996 and is enforceable internationally under the Convention on the Recognition and Enforcement of Foreign Arbitral Awards (New York, 1958) (the "New York Convention").

3. Scope of Engagement

3.1 General Scope

C&H is engaged to act as lead enforcement counsel for TSL in the enforcement and collection of the Award across multiple jurisdictions worldwide. The scope of this engagement covers all steps reasonably necessary to convert the Award into enforceable judgments, orders, and decrees in each relevant jurisdiction, and to execute upon the assets of KMH and, where legally permissible, its related entities in order to achieve the maximum possible recovery for the Client.

The enforcement effort will be directed against KMH and, to the extent legally permissible under applicable law (including, where appropriate, through veil-piercing, alter ego, or similar doctrines), against KMH's related entities. Based on the Firm's understanding of KMH's corporate structure, developed during the arbitration proceedings and through preliminary asset tracing, the relevant related entities include, but are not limited to:

(a) Korinthian Bulkers (Singapore) Pte. Ltd., a private limited company incorporated in Singapore, with registered offices at 80 Robinson Road, #14-02, Singapore 068898;

(b) Dnepr Shipholding Inc., a company incorporated in the British Virgin Islands under Company No. 2014876, the registered owner of certain vessels operated within the KMH fleet;

(c) Korinthian DMCC, a company registered in the Dubai Multi Commodities Centre, United Arab Emirates, with offices at Unit 3407, Almas Tower, Jumeirah Lakes Towers, Dubai, UAE; and

(d) Oceangate Ventures Ltd., a company incorporated in the Republic of Cyprus under Registration No. HE 401293.

Based on information obtained during the arbitration, the above entities and KMH itself are beneficially owned and controlled by the Volkov family through a network of British Virgin Islands and Cypriot holding structures. Andrei Volkov is identified as the ultimate beneficial owner and de facto director of KMH and its related entities. Sergei Volkov serves as a director of certain entities within the group, including KMH and Korinthian DMCC.

The engagement encompasses, without limitation, the following categories of legal work: applications for recognition and enforcement of the Award; applications for freezing and conservatory relief; applications for third-party debt orders, garnishee orders, and analogous execution measures; admiralty arrests and potential judicial sale of vessels; coordination with local counsel in each enforcement jurisdiction; coordination with forensic accountants and other experts; and defence against any applications by KMH to set aside, resist, or otherwise challenge the enforcement of the Award.

3.2 England & Wales

In England and Wales, C&H will handle the enforcement proceedings directly without the need for local counsel. The scope of work in this jurisdiction includes:

(a) Enforcement under Section 66 of the Arbitration Act 1996. C&H has already initiated proceedings to enforce the Award as a judgment of the Commercial Court under Section 66 of the Arbitration Act 1996, by way of an application issued on 15 July 2024 in Claim No. CL-2024-000487 in the Business and Property Courts of England and Wales, Queen's Bench Division, Commercial Court. C&H will continue to prosecute this application to completion.

(b) Worldwide Freezing Order. C&H will apply for (and, if granted, seek to enforce and maintain) a worldwide freezing injunction restraining KMH from dealing with, disposing of, or diminishing the value of its assets up to the value of the Award. The application will be made to the Commercial Court on an urgent basis.

(c) Third-Party Debt Orders and Other Execution. Following entry of judgment, C&H will pursue all available execution mechanisms, including third-party debt orders against banks and other institutions holding funds belonging to KMH. In particular, C&H will seek third-party debt orders against Meridian Trust Bank Ltd., 50 Lombard Street, London EC3V 9EA, which is believed to hold one or more accounts in the name of KMH and/or its related entities.

(d) Defence Against Set-Aside Applications. KMH's counsel, Harkness Whitford & Co., has indicated to C&H informally that KMH may challenge the Award under Section 68 (serious irregularity) and/or Section 69 (appeal on a point of law) of the Arbitration Act 1996. C&H will robustly defend against any such applications and will seek their summary dismissal where appropriate.

(e) Ancillary Relief. C&H will apply for any additional ancillary relief available under English law, including disclosure orders, examination of judgment debtors, and orders for the provision of information regarding KMH's assets.

3.3 Cyprus

In the Republic of Cyprus, the enforcement effort will focus on KMH's jurisdiction of incorporation and the location of certain of its key corporate assets. The scope of work includes:

(a) Recognition and enforcement of the Award under the New York Convention, as implemented in Cyprus by the International Commercial Arbitration Law of 1987 (Law 101/1987) and the Cyprus Arbitration Law (Cap. 4), by application to the Nicosia District Court.

(b) Freezing injunctions over KMH's Cyprus-situated assets, including (without limitation) KMH's shareholding in Oceangate Ventures Ltd. (Registration No. HE 401293), any bank accounts maintained by KMH or its related entities with Cypriot banks, and any other identifiable assets within the jurisdiction.

(c) Execution against KMH's Cyprus-registered assets, including enforcement against shares, bank balances, receivables, and real property, if any, registered in the name of KMH or its related entities in Cyprus.

Proceedings in Cyprus will be conducted through Kyprianos Makrides & Partners, located at 15 Grivas Digenis Avenue, Nicosia 1066, Cyprus. The principal contacts at that firm will be Andreas Kyprianos, Senior Partner, and Nadia Makrides, Partner. Kyprianos Makrides & Partners has been selected on the basis of their extensive experience in international arbitration enforcement and asset recovery matters in Cyprus.

C&H anticipates that KMH will oppose enforcement in Cyprus through its Cypriot counsel, Vassiliadis & Economou LLC, 7 Stasinou Avenue, 3rd Floor, Nicosia 1060, Cyprus, led by Georgios Vassiliadis, Managing Partner, and Eleni Economou, Partner. C&H and Kyprianos Makrides & Partners will prepare for contested proceedings, including potential challenges to enforcement on grounds available under Article V of the New York Convention.

3.4 Singapore

Singapore is a critical enforcement jurisdiction given the presence of Korinthian Bulkers (Singapore) Pte. Ltd. and the trading patterns of KMH's vessels in the region. The scope of work in Singapore includes:

(a) Enforcement of the Award under the International Arbitration Act (Cap. 143A) in the Singapore High Court (General Division), pursuant to which the Award may be recognised and enforced with leave of the court in the same manner as a judgment of the court.

(b) Garnishee proceedings (or "garnishment orders" under the current Rules of Court 2021) against Pinnacle Bank (Singapore) Ltd., located at 6 Battery Road, #20-01, Singapore 049909, in respect of accounts held in the name of Korinthian Bulkers (Singapore) Pte. Ltd. (80 Robinson Road, #14-02, Singapore 068898). Preliminary intelligence suggests that this entity maintains significant operational balances in Singapore.

(c) Admiralty arrest and potential judicial sale of vessels. C&H will seek to arrest the M/V Crimson Horizon (IMO 9801334, Handymax Bulk Carrier, 37,500 DWT, registered under the Liberian flag) should the vessel call at or transit through Singapore or its waters. If arrested, C&H will apply for judicial sale of the vessel in satisfaction of the Award, in whole or in part. The M/V Crimson Horizon was one of the three vessels at the centre of the underlying dispute, and its arrest is a key component of the enforcement strategy.

Proceedings in Singapore will be conducted through Straits Meridian LLP, located at 1 Raffles Place, #44-01 One Raffles Place Tower 2, Singapore 048616. The principal contacts at that firm will be David Teo Wei Lin, Partner, and Priya Subramaniam, Senior Associate. Straits Meridian LLP has deep experience in admiralty and international arbitration enforcement matters in Singapore.

3.5 United Arab Emirates

Enforcement proceedings in the United Arab Emirates are directed at KMH's Dubai-based operations conducted through Korinthian DMCC. The scope of work includes:

(a) Enforcement of the Award under UAE Federal Law No. 6 of 2018 (the UAE Arbitration Law) and the New York Convention, to which the UAE is a signatory, by application to the Dubai Court of First Instance. C&H will ensure that the necessary formalities for enforcement in the UAE are met, including certified Arabic translations of the Award, the arbitration agreement, and supporting documentation.

(b) Precautionary attachment over the assets of Korinthian DMCC, including but not limited to its accounts at Emirates Gulf Commercial Bank PJSC, Gate Village 3, DIFC, Dubai, UAE. The attachment will be sought to preserve assets pending full enforcement of the Award.

(c) Execution against any identified assets of KMH or Korinthian DMCC within the UAE, including bank balances, receivables, and tangible property.

Proceedings in the UAE will be conducted through Al-Rashid Hatem & Associates, located at Office 1802, Emirates Financial Towers (South Tower), DIFC, Dubai, UAE. The principal contacts at that firm will be Tariq Al-Rashid, Managing Partner, and Leila Hatem, Partner. Al-Rashid Hatem & Associates has particular expertise in the enforcement of foreign arbitral awards before the Dubai courts and the DIFC Courts.

3.6 Additional Jurisdictions

As the enforcement effort progresses and additional intelligence regarding KMH's global asset position becomes available (including through asset tracing conducted by Hartwell Pemberton LLP and through disclosure obtained in the English proceedings), C&H may recommend that enforcement proceedings be commenced in further jurisdictions.

In particular, C&H wishes to draw the Client's attention to the potential for the arrest of additional vessels associated with the KMH group, including:

(a) M/V Volga Spirit (IMO 9756892, Panamax Bulk Carrier, 76,400 DWT, Cyprus flag), owned by Dnepr Shipholding Inc. (BVI), which regularly trades in the Mediterranean, Black Sea, and Far East; and

(b) M/V Aegean Fortuna (IMO 9784521, Supramax Bulk Carrier, 58,200 DWT, marshall Islands flag), also owned by Dnepr Shipholding Inc. (BVI), which has recently been trading in South East Asian waters.

Arrests of these vessels may be pursued in any port jurisdiction where they call, subject to the availability of appropriate in rem or arrest procedures under local law. Such jurisdictions could include, without limitation, South Africa, India, the People's Republic of China, the Republic of Korea, or any jurisdiction within the European Union.

Any extension of the scope of this engagement to additional jurisdictions will be discussed with the Client in advance and will be subject to the Client's approval. Estimated fees, costs, and tactical considerations for each additional jurisdiction will be presented to the Client before any proceedings are commenced.

3.7 Asset Tracing and Forensic Support

A critical element of the enforcement strategy is the identification, tracing, and valuation of KMH's assets worldwide. To that end, C&H will coordinate with the following experts:

(a) Hartwell Pemberton LLP, Forensic Accountants, 25 Old Broad Street, London EC2N 1HN. The principal contacts at Hartwell Pemberton are Rebecca Saunders, Partner, Forensic Services, and Mark Huxley, Director. Hartwell Pemberton will be engaged to conduct global asset tracing, forensic analysis of KMH's corporate structure, ownership chains, and intercompany transactions, as well as to identify patterns of asset movement and dissipation. Hartwell Pemberton will also provide updated interest calculations and damages quantification support as required during the enforcement phase.

(b) Northcape Maritime Advisory Ltd., 3 Thomas More Square, London E1W 1WY. The principal contact is Captain Ian Forsyth, Managing Director. Northcape Maritime Advisory will be engaged to provide independent vessel valuations in respect of the M/V Crimson Horizon, M/V Volga Spirit, M/V Aegean Fortuna, and any other vessels within the KMH fleet that may become the subject of arrest or judicial sale proceedings. Such valuations will be essential for the purposes of security applications, judicial sale proceedings, and cost-benefit analysis.

Both Hartwell Pemberton and Northcape Maritime Advisory will be engaged on the Client's behalf and will operate under the supervision and coordination of C&H. Their reports and workpapers will be protected by litigation privilege to the extent permitted by applicable law.

3.8 Opposing Counsel

For the Client's records and the avoidance of doubt, the following counsel are known to represent KMH and/or its related entities:

(a) In England: Harkness Whitford & Co., 12 Fetter Lane, London EC4A 1JP (SRA No. 614823). Principal contacts: Richard Harkness, Senior Partner; Catherine Whitford, Partner, International Arbitration; and James Thornbury, Associate. Harkness Whitford acted for KMH throughout the arbitration proceedings and has been placed on notice of the Section 66 enforcement application.

(b) In Cyprus: Vassiliadis & Economou LLC, 7 Stasinou Avenue, 3rd Floor, Nicosia 1060, Cyprus. Principal contacts: Georgios Vassiliadis, Managing Partner; and Eleni Economou, Partner. Vassiliadis & Economou are believed to act for KMH and certain of its Cypriot subsidiaries.

Opposing counsel in Singapore and the UAE have not yet been identified but will be communicated to the Client once known.

4. Engagement Team

The following members of C&H will constitute the core engagement team for this matter:

Responsible Partner: Samuel Eklund. Mr. Eklund will bear overall responsibility for the strategic direction and conduct of the enforcement proceedings, the management of the client relationship, and the supervision of all work performed by the C&H team and local counsel across jurisdictions. Mr. Eklund is a partner in the Firm's International Arbitration and Dispute Resolution Group and has over twenty years' experience in the enforcement of major international arbitration awards, with particular expertise in the maritime and energy sectors. Mr. Eklund will be the Client's principal point of contact for strategic matters and will attend all key hearings.

Billing Partner: Linda Osei. Ms. Osei will be responsible for all financial aspects of the engagement, including billing, fee arrangements, management of the Fee Cap, coordination of invoices from local counsel and experts, and financial reporting to the Client. Ms. Osei is a partner in the Firm's Dispute Resolution Group with extensive experience in the management of multi-jurisdictional enforcement mandates.

Lead Associate: Hannah Brinkley. Ms. Brinkley will be responsible for the day-to-day conduct of the enforcement proceedings across all jurisdictions, including the preparation of all applications, affidavits, and submissions in the English proceedings; the coordination with and supervision of local counsel in Cyprus, Singapore, and the UAE; liaison with Hartwell Pemberton LLP and Northcape Maritime Advisory Ltd.; and the preparation of status reports for the Client. Ms. Brinkley will serve as the Client's principal day-to-day point of contact and will be the primary point of coordination with all local counsel. Ms. Brinkley is a senior associate in the Firm's International Arbitration and Dispute Resolution Group and has significant experience in cross-border enforcement and asset recovery.

Working Associate: Patrick Gallagher. Mr. Gallagher will support Ms. Brinkley across all workstreams, with particular responsibility for legal research, drafting, document preparation, court filings, and liaison with local counsel on procedural matters. Mr. Gallagher is an associate in the Firm's Dispute Resolution Group.

Additional C&H lawyers may be assigned to the matter from time to time as the volume and complexity of the work requires. The Client will be informed promptly of any material changes to the composition of the engagement team and, in particular, of any change to the Responsible Partner or Lead Associate.

5. Fee Arrangements

5.1 Hourly Rates

The Firm's current standard hourly rates applicable to this engagement are as follows:

Time is recorded in units of six minutes (0.1 of one hour). All time entries will include a brief narrative description of the work performed. Invoices will set out time charges by fee earner, with total hours and amounts for each fee earner clearly identified.

The rates set out above are the Firm's current rates as of the date of this letter. Rates are subject to annual review, with any adjustments typically taking effect on 1 January of each calendar year. The Client will be given at least thirty (30) days' prior written notice of any rate adjustment. Any rate increase will not affect time already recorded prior to the effective date of the increase.

5.2 Fee Cap

Notwithstanding the hourly rate structure described in Section 5.1 above, the total professional fees charged by C&H for work performed under this engagement (Phase 2 — Enforcement) shall not exceed £4,200,000 (four million two hundred thousand pounds sterling) (the "Fee Cap").

The Fee Cap is inclusive of all professional fees charged by C&H's lawyers for time spent on the matter, but is exclusive of the following, each of which will be billed separately to the Client:

(a) All disbursements, including but not limited to court filing fees, process server and service costs, travel expenses, accommodation costs, courier and postage charges, certified translation and interpretation fees, document legalization and apostille costs, and similar out-of-pocket expenses (as further described in Section 5.4 below);

(b) Fees of local counsel in each enforcement jurisdiction, namely Kyprianos Makrides & Partners (Cyprus), Straits Meridian LLP (Singapore), and Al-Rashid Hatem & Associates (UAE) (as further described in Section 5.5 below);

(d) Fees of Northcape Maritime Advisory Ltd. for vessel valuations and related maritime advisory services.

If, during the course of the engagement, circumstances arise that may cause the Fee Cap to be exceeded — including, by way of example, the commencement of enforcement proceedings in additional jurisdictions not presently contemplated, unexpected and heavily contested interlocutory proceedings, or an appeal from the enforcement of the Award in any jurisdiction — C&H will promptly discuss the matter with the Client, providing a revised fee estimate and an explanation of the circumstances necessitating the increase. Any increase to the Fee Cap requires the Client's prior written consent. C&H will not incur fees in excess of the Fee Cap without such consent.

5.3 Success Fee

In addition to the hourly fees described in Section 5.1 (subject to the Fee Cap set out in Section 5.2), the Client agrees to pay C&H a success fee (the "Success Fee") calculated as follows:

2.5% of all amounts recovered in excess of £80,000,000 (eighty million pounds sterling) in connection with the enforcement of the Award.

For the purposes of this Section 5.3, "Amounts Recovered" means all sums actually received by or on behalf of TSL from or in respect of KMH, its related entities, or their respective assets, howsoever collected — whether by way of garnishment, third-party debt order, execution, admiralty arrest and sale, voluntary payment, settlement, or otherwise — net of any sums subsequently returned, refunded, or required to be disgorged by TSL by order of any court or tribunal.

The Success Fee shall become due and payable within thirty (30) days following the final determination or agreed close of the enforcement phase, being the date on which C&H and the Client mutually agree that enforcement efforts have been concluded or are no longer reasonably capable of producing further recoveries, or, if earlier, the date on which this engagement is terminated in accordance with Section 13.

By way of illustration, the Success Fee would be calculated as follows in the scenarios set out below:

The Success Fee is intended to reflect the substantial additional benefit to TSL of recoveries in excess of the £80,000,000 threshold, and to align the Firm's interests with the Client's objective of maximising recovery.

5.4 Disbursements

The Client is responsible for all disbursements incurred by C&H in connection with the engagement. Major categories of anticipated disbursements include, without limitation:

(a) Court filing fees in all jurisdictions (including England & Wales, Cyprus, Singapore, and the UAE);

(b) Process server and service of process costs, including international service under the Hague Service Convention or applicable bilateral treaties;

(c) Travel and accommodation expenses, principally in connection with hearings and meetings in London, Nicosia, Singapore, and Dubai, as well as any additional enforcement jurisdictions;

(d) Certified translation fees, including Arabic translations of the Award, arbitration agreement, and supporting documentation required for UAE proceedings, as well as any Greek translations required for proceedings in Cyprus or Greece;

(e) Document legalization and apostille costs;

(f) Expert fees payable to Hartwell Pemberton LLP (forensic accountants) and Northcape Maritime Advisory Ltd. (vessel valuations), to the extent not covered under separate fee arrangements described in Sections 5.5 and 5.6;

(g) Courier, printing, and communication costs; and

(h) Any other out-of-pocket expenses reasonably incurred in the conduct of the enforcement proceedings.

C&H will seek the Client's prior approval before incurring any single disbursement or category of related disbursements expected to exceed £10,000 (ten thousand pounds sterling). Smaller disbursements will be incurred in the ordinary course and reported on monthly invoices.

5.5 Local Counsel Fees

The Client is responsible for the professional fees of all local counsel engaged by C&H on the Client's behalf in each enforcement jurisdiction. Based on the scope of work presently anticipated, C&H has obtained the following fee estimates from local counsel in each jurisdiction:

These estimates are indicative and are based on the scope of work currently anticipated in each jurisdiction. Actual fees may vary depending on the complexity of proceedings, the degree of opposition from KMH, and any unforeseen procedural developments. C&H will keep the Client informed of any material deviation from these estimates.

Unless the Client instructs otherwise, local counsel will be formally engaged on the Client's behalf and will render their invoices through C&H. C&H will review all local counsel invoices for reasonableness and consistency with the agreed scope of work before transmitting them to the Client for payment. If the Client prefers to enter into direct billing arrangements with any local counsel firm, C&H will facilitate the necessary introductions and documentation. In either case, C&H will exercise reasonable oversight of local counsel fee estimates and billing practices.

5.6 Hartwell Pemberton LLP (Forensic Accountants) Fees

Hartwell Pemberton LLP will provide asset tracing, forensic analysis of KMH's corporate structure and financial flows, and interest calculations. The estimated fees for Hartwell Pemberton's services are approximately £345,000 (three hundred and forty-five thousand pounds sterling), based on the scope of work presently contemplated. Hartwell Pemberton will bill on an hourly basis, and their invoices will be rendered through C&H for review and onward transmission to the Client.

As with local counsel, actual fees may vary depending on the complexity and extent of the asset tracing required. C&H will keep the Client informed of the progress of Hartwell Pemberton's work and any material deviation from the fee estimate.

6. Billing and Payment

Invoices in respect of C&H's fees and disbursements will be rendered monthly in arrears, generally within ten (10) business days following the end of each calendar month.

Payment of each invoice is due within thirty (30) days of the date of the invoice. Late payments will bear interest at the rate of 4% per annum above the base rate of the Bank of England from time to time in force, calculated on a daily basis from the due date until the date of actual payment.

All invoices will be directed to:

Elena Stavridis Chief Financial Officer Thalassa Shipping & Logistics SA 14 Akti Miaouli, 4th Floor Piraeus 185 35, Greece

with a copy to:

Ioanna Christodoulou General Counsel Thalassa Shipping & Logistics SA (same address)

All fees quoted in this engagement letter are stated exclusive of Value Added Tax ("VAT"). Where VAT is chargeable under UK law in respect of services supplied by C&H, it will be added to invoices at the applicable rate. The Client should seek independent tax advice as to the recoverability of any VAT charged.

All funds recovered on behalf of TSL in connection with the enforcement of the Award shall be remitted, net of any locally applicable deductions required by law, to TSL's designated recovery account at:

Ionian National Bank SA 22 Stadiou Street Athens 105 64, Greece

Account details to be confirmed by the Client in writing prior to receipt of the first recovery.

C&H reserves the right to request payment on account from the Client in respect of anticipated significant disbursements, such as court fees for freezing order applications, admiralty arrest costs, or large translation and legalization expenses. Any request for payment on account will be made in writing with reasonable advance notice and will specify the nature and estimated amount of the anticipated disbursement.

7. Coordination with Local Counsel

Given the multi-jurisdictional nature of this enforcement, effective coordination between C&H and local counsel in each jurisdiction is essential. The parties agree to the following coordination framework:

C&H will serve as the central coordinating hub for all enforcement activity across jurisdictions. All instructions to local counsel will be issued by C&H on behalf of and in consultation with the Client. C&H will instruct, supervise, and receive reports from local counsel in Cyprus (Kyprianos Makrides & Partners), Singapore (Straits Meridian LLP), and the UAE (Al-Rashid Hatem & Associates).

Hannah Brinkley will serve as the primary point of coordination with all local counsel, ensuring consistent strategy, alignment of timing across jurisdictions, and the efficient exchange of information and documentation. Mr. Eklund will participate in coordination discussions on all matters of strategic significance.

Regular coordination calls and/or video conferences will be scheduled as needed, with a minimum frequency of bi-weekly during active enforcement phases. During periods of heightened activity — for example, in connection with freezing order applications, vessel arrests, or contested enforcement hearings — coordination calls may be held daily or as circumstances require.

All material filings, applications, submissions, and strategic decisions by local counsel in each jurisdiction will be reviewed and approved by C&H before submission to the relevant court or authority. Local counsel will provide draft documents to C&H with sufficient lead time to allow for meaningful review and comment.

C&H will keep the Client informed of all material developments in each jurisdiction through the bi-weekly status reports described in Section 8 below, or more frequently as circumstances warrant. The Client will be consulted on all significant strategic decisions, including the timing of applications, the sequencing of enforcement actions across jurisdictions, and any proposed settlements or compromises.

8. Reporting

C&H will provide bi-weekly written status reports to the Client, summarising progress across all enforcement jurisdictions. Each report will cover, at a minimum:

(a) A summary of material developments in each jurisdiction since the last report;

(b) A description of work in progress and anticipated next steps;

(d) An update on asset tracing and forensic investigation results;

(e) A recovery tracker setting out all amounts recovered to date, the jurisdiction and source of each recovery, outstanding balances, and accruing interest; and

(f) Any matters requiring the Client's attention, decision, or approval.

Status reports will be addressed to Ioanna Christodoulou, General Counsel, with copies to Nikolaos Papadimitriou, Chairman & CEO, and Elena Stavridis, CFO. Reports will be transmitted by email in PDF format, marked as confidential and privileged.

In addition to the bi-weekly reports, C&H will promptly notify the Client by email or telephone of any material development requiring urgent attention or decision, including without limitation: the granting or refusal of freezing or conservatory relief; the arrest of any vessel; any significant court ruling or order; any communication from KMH or its counsel regarding potential settlement; any indication that KMH is dissipating or concealing assets; and any change to the anticipated timetable or strategy in any jurisdiction.

C&H will maintain a multi-jurisdictional recovery tracker in electronic form, recording all amounts recovered, the jurisdiction and method of recovery, outstanding balances on each component of the Award, and accruing post-award interest. The recovery tracker will be shared with the Client as part of each bi-weekly status report and will be updated in real time as recoveries are received.

9. Client Responsibilities

In order for C&H to conduct the enforcement proceedings effectively and efficiently, the Client will:

(a) Provide C&H promptly with all information, documents, records, and data reasonably requested in connection with the enforcement, including (without limitation) copies of the charter-parties, financial records relating to the claims, any information in the Client's possession regarding KMH's assets and corporate structure, and any communications between TSL and KMH following the issuance of the Award;

(b) Make available the following key contacts for the purposes of this engagement:

• Ioanna Christodoulou, General Counsel — the Client's primary legal contact, responsible for day-to-day communication with C&H on legal matters;

• Elena Stavridis, Chief Financial Officer — responsible for financial matters, banking information, wire instructions, and receipt and reconciliation of recovered funds;

• Captain Dimitrios Kouretas, Head of Chartering & Operations — responsible for factual and operational matters relating to the charter-parties and the vessels (including the M/V Aegean Fortuna, M/V Crimson Horizon, and M/V Volga Spirit), as well as vessel tracking and intelligence regarding KMH fleet movements; and

• Nikolaos Papadimitriou, Chairman & CEO — responsible for strategic decisions, authorisations, and approvals of material actions (including settlement discussions, if any);

(c) Make available witnesses for the swearing of affidavits, the provision of witness statements, and, if required, attendance at court hearings in connection with enforcement applications. C&H anticipates that witness evidence may be required from, among others, Mr. Papadimitriou, Ms. Stavridis, and Captain Kouretas. C&H will provide reasonable advance notice of any such requirements;

(d) Provide confirmed banking details and wire instructions for TSL's designated recovery account at Ionian National Bank SA in Athens, and promptly notify C&H of any change to those details; and

(e) Respond promptly to requests for instructions, decisions, and approvals, recognising that enforcement proceedings often move on compressed timetables and that delays in client instructions may prejudice the outcome of applications.

10. Confidentiality

All information and documents communicated between C&H and the Client in connection with this engagement are, and shall remain, subject to legal professional privilege (including litigation privilege and legal advice privilege) to the fullest extent available under English law and applicable law in each enforcement jurisdiction. C&H will treat all such information as strictly confidential.

C&H will not disclose confidential information relating to the Client or this engagement to any third party without the Client's prior written consent, except:

(a) As required by law, regulation, or court order in any jurisdiction;

(b) As reasonably necessary in the course of the enforcement proceedings (including, without limitation, information disclosed in court filings, affidavits, and submissions);

(c) As required by the Firm's professional regulatory obligations, including obligations to the Solicitors Regulation Authority; or

(d) To the extent necessary for the performance of this engagement, including disclosure to local counsel in each enforcement jurisdiction (Kyprianos Makrides & Partners, Straits Meridian LLP, Al-Rashid Hatem & Associates), forensic accountants (Hartwell Pemberton LLP), experts (Northcape Maritime Advisory Ltd.), and any other professional advisers engaged on the Client's behalf.

The Client acknowledges and agrees that the sharing of confidential information with local counsel, forensic accountants, and experts engaged in connection with this matter is authorised under this engagement and does not constitute a waiver of privilege or confidentiality. C&H will take reasonable steps to ensure that all such recipients are bound by obligations of confidentiality no less protective than those set out in this Section 10.

11. Conflicts of Interest

C&H has conducted a thorough conflicts check across all offices and practice groups of the Firm and confirms that, as of the date of this letter, the Firm has no conflict of interest in acting for TSL against KMH or any of its related entities. In particular, C&H confirms that it does not currently act for, and has not at any time acted for:

(a) Korinthian Maritime Holdings Ltd.;

(b) Korinthian Bulkers (Singapore) Pte. Ltd.;

(d) Korinthian DMCC;

(e) Oceangate Ventures Ltd.;

(f) Andrei Volkov or Sergei Volkov, or any member of the Volkov family;

(g) Harkness Whitford & Co. or any other counsel known to represent KMH or its related entities; or

(h) Vassiliadis & Economou LLC.

C&H's internal conflicts clearance confirmation, dated 10 September 2024, is enclosed with this letter for the Client's records.

Should a potential conflict of interest arise during the course of this engagement, C&H will promptly notify the Client in writing and take all appropriate steps in accordance with the Solicitors Regulation Authority's Code of Conduct and applicable professional rules, including, where necessary, seeking the Client's informed consent to continue acting or, if consent cannot be obtained, withdrawing from the engagement in accordance with Section 13 below.

12. Limitation of Liability

C&H's aggregate liability to the Client arising out of or in connection with this engagement (whether in contract, tort, negligence, breach of statutory duty, or otherwise) shall be limited to the amount of coverage available under the Firm's professional indemnity insurance policy as maintained from time to time. Details of the Firm's professional indemnity insurance coverage, including the identity of the insurer and the current policy limits, are available upon request from Linda Osei.

This limitation of liability shall not apply to, and nothing in this Section 12 shall operate to exclude or restrict, any liability:

(a) Arising from fraud, dishonesty, or wilful default on the part of C&H or any of its members, partners, or employees;

(b) For death or personal injury caused by C&H's negligence; or

(c) Which cannot lawfully be excluded or limited under the laws of England and Wales or under the rules and regulations of the Solicitors Regulation Authority.

The Client acknowledges that C&H shall not be liable for the acts or omissions of local counsel, forensic accountants, experts, or any other third-party service providers engaged in connection with this matter, except to the extent that C&H has been negligent in the selection or supervision of such third parties.

13. Termination

Either party may terminate this engagement upon thirty (30) days' written notice to the other party. Notice of termination shall be given in writing and shall be effective upon receipt by the other party.

Upon termination of this engagement for any reason:

(a) The Client shall remain liable for all fees (at the hourly rates set out in Section 5.1, subject to the Fee Cap) and disbursements properly incurred by C&H up to and including the effective date of termination;

(b) The Client shall remain liable for any Success Fee that has accrued in accordance with Section 5.3, calculated by reference to Amounts Recovered prior to the effective date of termination;

(c) C&H will provide all reasonable cooperation in the orderly transfer of the matter to successor counsel nominated by the Client, including the delivery of all files, documents, and workpapers (subject to C&H's lien over such materials in respect of any unpaid fees and disbursements, to the extent permitted by applicable law and professional rules); and

(d) C&H will take all steps reasonably necessary to protect the Client's interests during the transition period, including seeking any necessary adjournments or extensions from courts and tribunals in all jurisdictions.

C&H may also terminate this engagement immediately if the Client fails to pay any invoice within sixty (60) days of its due date, provided that C&H has given the Client at least fourteen (14) days' prior written notice of its intention to terminate on this ground and the Client has not remedied the default within that notice period.

14. Regulatory Information

CONFIDENTIAL — SUBJECT TO LEGAL PROFESSIONAL PRIVILEGE
Calderwood & Harkness LLP 45 Moorgate London EC2R 6AR United Kingdom
T: +44 (0)20 7496 8000 F: +44 (0)20 7496 8001 www.calderwoodharkness.com
12 September 2024
Mr. Nikolaos Papadimitriou Chairman & Chief Executive Officer Thalassa Shipping & Logistics SA 14 Akti Miaouli, 4th Floor Piraeus 185 35 Greece
Copy to: Ms. Ioanna Christodoulou, General Counsel, Thalassa Shipping & Logistics SA (same address)
Re: Engagement of Calderwood & Harkness LLP — Multi-Jurisdictional Enforcement of LCIA Award No. 224718 (*Thalassa Shipping & Logistics SA v. Korinthian Maritime Holdings Ltd.*)
Dear Mr. Papadimitriou,
1. Introduction and Purpose
Calderwood & Harkness LLP ("C&H" or "the Firm") is pleased to confirm its engagement by Thalassa Shipping & Logistics SA ("TSL" or "the Client"), a Société Anonyme organised under the laws of the Hellenic Republic, Tax Identification Number (AFM) EL-801456729, with its registered and principal offices at 14 Akti Miaouli, 4th Floor, Piraeus 185 35, Greece.
This letter sets forth the terms upon which C&H has been engaged to represent TSL in connection with the multi-jurisdictional enforcement and collection of the Final Award dated 28 June 2024 (the "Award") issued by the Arbitral Tribunal constituted under the auspices of the London Court of International Arbitration ("LCIA") in LCIA Case No. 224718. The Award was rendered in favour of TSL and against Korinthian Maritime Holdings Ltd. ("KMH"), a private limited company incorporated in Nicosia, Republic of Cyprus, under Registration Number HE 387421, with its registered address at 28 Themistokli Dervi Avenue, Suite 601, Nicosia 1066, Cyprus.
For the avoidance of doubt, this engagement letter supersedes in its entirety any prior terms of engagement between C&H and TSL relating to the underlying arbitration proceedings in LCIA Case No. 224718, and constitutes the sole and complete terms of engagement for what the parties refer to as Phase 2 — Enforcement. All work performed by the Firm from the date hereof shall be governed exclusively by the terms set out in this letter and the Firm's standard terms and conditions of business enclosed herewith.
By way of background, the underlying arbitration arose from disputes between TSL and KMH under three separate time charter-parties governed by English law. A Request for Arbitration was filed by TSL on 14 November 2022. The Tribunal was duly constituted on 8 February 2023, comprising Sir Malcolm Fenton-Clarke (presiding arbitrator), Professor Athena Drakopoulos (co-arbitrator nominated by the Claimant), and Dr. Henrik Dalmqvist (co-arbitrator nominated by the Respondent). Following extensive written submissions, disclosure, and a merits hearing conducted over ten sitting days from 11 to 22 September 2023 in London, the Tribunal issued its Final Award on 28 June 2024. KMH has failed to comply with the Award, and TSL now seeks to enforce and collect the full sums due thereunder through proceedings in multiple jurisdictions where KMH and its related entities hold assets.
2. The Award
The Final Award dated 28 June 2024 in LCIA Case No. 224718 is comprised of the following principal elements:
2.1 Damages Awarded
The Tribunal awarded TSL total damages in the amount of £96,450,000 (ninety-six million four hundred and fifty thousand pounds sterling), broken down as follows:
2.2 Costs
The Tribunal allocated the costs of the arbitration 85% to KMH and 15% to TSL, resulting in the following costs liability for KMH:
2.3 Grand Total
The grand total payable by KMH under the Award, inclusive of damages and costs, is £108,600,000 (one hundred and eight million six hundred thousand pounds sterling). At the exchange rate prevailing on the date of the Award (£1 = USD $1.2441, as quoted by the Bank of England on 28 June 2024), this is approximately equivalent to USD $135,148,260.
2.4 Post-Award Interest
The Award provides for post-award interest at a rate of 5.25% per annum (simple) on the unpaid principal sum of £96,450,000, running from 29 June 2024 until the date of payment in full. Interest continues to accrue and is a significant component of the overall recovery objective.
2.5 Governing Law and Seat
The charter-parties underlying the dispute are governed by English law. The seat of the arbitration was London, England. Accordingly, the Award is a London-seated award governed by the Arbitration Act 1996 and is enforceable internationally under the Convention on the Recognition and Enforcement of Foreign Arbitral Awards (New York, 1958) (the "New York Convention").
3. Scope of Engagement
3.1 General Scope
C&H is engaged to act as lead enforcement counsel for TSL in the enforcement and collection of the Award across multiple jurisdictions worldwide. The scope of this engagement covers all steps reasonably necessary to convert the Award into enforceable judgments, orders, and decrees in each relevant jurisdiction, and to execute upon the assets of KMH and, where legally permissible, its related entities in order to achieve the maximum possible recovery for the Client.
The enforcement effort will be directed against KMH and, to the extent legally permissible under applicable law (including, where appropriate, through veil-piercing, alter ego, or similar doctrines), against KMH's related entities. Based on the Firm's understanding of KMH's corporate structure, developed during the arbitration proceedings and through preliminary asset tracing, the relevant related entities include, but are not limited to:
(a) Korinthian Bulkers (Singapore) Pte. Ltd., a private limited company incorporated in Singapore, with registered offices at 80 Robinson Road, #14-02, Singapore 068898;
(b) Dnepr Shipholding Inc., a company incorporated in the British Virgin Islands under Company No. 2014876, the registered owner of certain vessels operated within the KMH fleet;
(c) Korinthian DMCC, a company registered in the Dubai Multi Commodities Centre, United Arab Emirates, with offices at Unit 3407, Almas Tower, Jumeirah Lakes Towers, Dubai, UAE; and
(d) Oceangate Ventures Ltd., a company incorporated in the Republic of Cyprus under Registration No. HE 401293.
Based on information obtained during the arbitration, the above entities and KMH itself are beneficially owned and controlled by the Volkov family through a network of British Virgin Islands and Cypriot holding structures. Andrei Volkov is identified as the ultimate beneficial owner and de facto director of KMH and its related entities. Sergei Volkov serves as a director of certain entities within the group, including KMH and Korinthian DMCC.
The engagement encompasses, without limitation, the following categories of legal work: applications for recognition and enforcement of the Award; applications for freezing and conservatory relief; applications for third-party debt orders, garnishee orders, and analogous execution measures; admiralty arrests and potential judicial sale of vessels; coordination with local counsel in each enforcement jurisdiction; coordination with forensic accountants and other experts; and defence against any applications by KMH to set aside, resist, or otherwise challenge the enforcement of the Award.
3.2 England & Wales
In England and Wales, C&H will handle the enforcement proceedings directly without the need for local counsel. The scope of work in this jurisdiction includes:
(a) Enforcement under Section 66 of the Arbitration Act 1996. C&H has already initiated proceedings to enforce the Award as a judgment of the Commercial Court under Section 66 of the Arbitration Act 1996, by way of an application issued on 15 July 2024 in Claim No. CL-2024-000487 in the Business and Property Courts of England and Wales, Queen's Bench Division, Commercial Court. C&H will continue to prosecute this application to completion.
(b) Worldwide Freezing Order. C&H will apply for (and, if granted, seek to enforce and maintain) a worldwide freezing injunction restraining KMH from dealing with, disposing of, or diminishing the value of its assets up to the value of the Award. The application will be made to the Commercial Court on an urgent basis.
(c) Third-Party Debt Orders and Other Execution. Following entry of judgment, C&H will pursue all available execution mechanisms, including third-party debt orders against banks and other institutions holding funds belonging to KMH. In particular, C&H will seek third-party debt orders against Meridian Trust Bank Ltd., 50 Lombard Street, London EC3V 9EA, which is believed to hold one or more accounts in the name of KMH and/or its related entities.
(d) Defence Against Set-Aside Applications. KMH's counsel, Harkness Whitford & Co., has indicated to C&H informally that KMH may challenge the Award under Section 68 (serious irregularity) and/or Section 69 (appeal on a point of law) of the Arbitration Act 1996. C&H will robustly defend against any such applications and will seek their summary dismissal where appropriate.
(e) Ancillary Relief. C&H will apply for any additional ancillary relief available under English law, including disclosure orders, examination of judgment debtors, and orders for the provision of information regarding KMH's assets.
3.3 Cyprus
In the Republic of Cyprus, the enforcement effort will focus on KMH's jurisdiction of incorporation and the location of certain of its key corporate assets. The scope of work includes:
(a) Recognition and enforcement of the Award under the New York Convention, as implemented in Cyprus by the International Commercial Arbitration Law of 1987 (Law 101/1987) and the Cyprus Arbitration Law (Cap. 4), by application to the Nicosia District Court.
(b) Freezing injunctions over KMH's Cyprus-situated assets, including (without limitation) KMH's shareholding in Oceangate Ventures Ltd. (Registration No. HE 401293), any bank accounts maintained by KMH or its related entities with Cypriot banks, and any other identifiable assets within the jurisdiction.
(c) Execution against KMH's Cyprus-registered assets, including enforcement against shares, bank balances, receivables, and real property, if any, registered in the name of KMH or its related entities in Cyprus.
Proceedings in Cyprus will be conducted through Kyprianos Makrides & Partners, located at 15 Grivas Digenis Avenue, Nicosia 1066, Cyprus. The principal contacts at that firm will be Andreas Kyprianos, Senior Partner, and Nadia Makrides, Partner. Kyprianos Makrides & Partners has been selected on the basis of their extensive experience in international arbitration enforcement and asset recovery matters in Cyprus.
C&H anticipates that KMH will oppose enforcement in Cyprus through its Cypriot counsel, Vassiliadis & Economou LLC, 7 Stasinou Avenue, 3rd Floor, Nicosia 1060, Cyprus, led by Georgios Vassiliadis, Managing Partner, and Eleni Economou, Partner. C&H and Kyprianos Makrides & Partners will prepare for contested proceedings, including potential challenges to enforcement on grounds available under Article V of the New York Convention.
3.4 Singapore
Singapore is a critical enforcement jurisdiction given the presence of Korinthian Bulkers (Singapore) Pte. Ltd. and the trading patterns of KMH's vessels in the region. The scope of work in Singapore includes:
(a) Enforcement of the Award under the International Arbitration Act (Cap. 143A) in the Singapore High Court (General Division), pursuant to which the Award may be recognised and enforced with leave of the court in the same manner as a judgment of the court.
(b) Garnishee proceedings (or "garnishment orders" under the current Rules of Court 2021) against Pinnacle Bank (Singapore) Ltd., located at 6 Battery Road, #20-01, Singapore 049909, in respect of accounts held in the name of Korinthian Bulkers (Singapore) Pte. Ltd. (80 Robinson Road, #14-02, Singapore 068898). Preliminary intelligence suggests that this entity maintains significant operational balances in Singapore.
(c) Admiralty arrest and potential judicial sale of vessels. C&H will seek to arrest the M/V Crimson Horizon (IMO 9801334, Handymax Bulk Carrier, 37,500 DWT, registered under the Liberian flag) should the vessel call at or transit through Singapore or its waters. If arrested, C&H will apply for judicial sale of the vessel in satisfaction of the Award, in whole or in part. The M/V Crimson Horizon was one of the three vessels at the centre of the underlying dispute, and its arrest is a key component of the enforcement strategy.
Proceedings in Singapore will be conducted through Straits Meridian LLP, located at 1 Raffles Place, #44-01 One Raffles Place Tower 2, Singapore 048616. The principal contacts at that firm will be David Teo Wei Lin, Partner, and Priya Subramaniam, Senior Associate. Straits Meridian LLP has deep experience in admiralty and international arbitration enforcement matters in Singapore.
3.5 United Arab Emirates
Enforcement proceedings in the United Arab Emirates are directed at KMH's Dubai-based operations conducted through Korinthian DMCC. The scope of work includes:
(a) Enforcement of the Award under UAE Federal Law No. 6 of 2018 (the UAE Arbitration Law) and the New York Convention, to which the UAE is a signatory, by application to the Dubai Court of First Instance. C&H will ensure that the necessary formalities for enforcement in the UAE are met, including certified Arabic translations of the Award, the arbitration agreement, and supporting documentation.
(b) Precautionary attachment over the assets of Korinthian DMCC, including but not limited to its accounts at Emirates Gulf Commercial Bank PJSC, Gate Village 3, DIFC, Dubai, UAE. The attachment will be sought to preserve assets pending full enforcement of the Award.
(c) Execution against any identified assets of KMH or Korinthian DMCC within the UAE, including bank balances, receivables, and tangible property.
Proceedings in the UAE will be conducted through Al-Rashid Hatem & Associates, located at Office 1802, Emirates Financial Towers (South Tower), DIFC, Dubai, UAE. The principal contacts at that firm will be Tariq Al-Rashid, Managing Partner, and Leila Hatem, Partner. Al-Rashid Hatem & Associates has particular expertise in the enforcement of foreign arbitral awards before the Dubai courts and the DIFC Courts.
3.6 Additional Jurisdictions
As the enforcement effort progresses and additional intelligence regarding KMH's global asset position becomes available (including through asset tracing conducted by Hartwell Pemberton LLP and through disclosure obtained in the English proceedings), C&H may recommend that enforcement proceedings be commenced in further jurisdictions.
In particular, C&H wishes to draw the Client's attention to the potential for the arrest of additional vessels associated with the KMH group, including:
(a) M/V Volga Spirit (IMO 9756892, Panamax Bulk Carrier, 76,400 DWT, Cyprus flag), owned by Dnepr Shipholding Inc. (BVI), which regularly trades in the Mediterranean, Black Sea, and Far East; and
(b) M/V Aegean Fortuna (IMO 9784521, Supramax Bulk Carrier, 58,200 DWT, marshall Islands flag), also owned by Dnepr Shipholding Inc. (BVI), which has recently been trading in South East Asian waters.
Arrests of these vessels may be pursued in any port jurisdiction where they call, subject to the availability of appropriate in rem or arrest procedures under local law. Such jurisdictions could include, without limitation, South Africa, India, the People's Republic of China, the Republic of Korea, or any jurisdiction within the European Union.
Any extension of the scope of this engagement to additional jurisdictions will be discussed with the Client in advance and will be subject to the Client's approval. Estimated fees, costs, and tactical considerations for each additional jurisdiction will be presented to the Client before any proceedings are commenced.
3.7 Asset Tracing and Forensic Support
A critical element of the enforcement strategy is the identification, tracing, and valuation of KMH's assets worldwide. To that end, C&H will coordinate with the following experts:
(a) Hartwell Pemberton LLP, Forensic Accountants, 25 Old Broad Street, London EC2N 1HN. The principal contacts at Hartwell Pemberton are Rebecca Saunders, Partner, Forensic Services, and Mark Huxley, Director. Hartwell Pemberton will be engaged to conduct global asset tracing, forensic analysis of KMH's corporate structure, ownership chains, and intercompany transactions, as well as to identify patterns of asset movement and dissipation. Hartwell Pemberton will also provide updated interest calculations and damages quantification support as required during the enforcement phase.
(b) Northcape Maritime Advisory Ltd., 3 Thomas More Square, London E1W 1WY. The principal contact is Captain Ian Forsyth, Managing Director. Northcape Maritime Advisory will be engaged to provide independent vessel valuations in respect of the M/V Crimson Horizon, M/V Volga Spirit, M/V Aegean Fortuna, and any other vessels within the KMH fleet that may become the subject of arrest or judicial sale proceedings. Such valuations will be essential for the purposes of security applications, judicial sale proceedings, and cost-benefit analysis.
Both Hartwell Pemberton and Northcape Maritime Advisory will be engaged on the Client's behalf and will operate under the supervision and coordination of C&H. Their reports and workpapers will be protected by litigation privilege to the extent permitted by applicable law.
3.8 Opposing Counsel
For the Client's records and the avoidance of doubt, the following counsel are known to represent KMH and/or its related entities:
(a) In England: Harkness Whitford & Co., 12 Fetter Lane, London EC4A 1JP (SRA No. 614823). Principal contacts: Richard Harkness, Senior Partner; Catherine Whitford, Partner, International Arbitration; and James Thornbury, Associate. Harkness Whitford acted for KMH throughout the arbitration proceedings and has been placed on notice of the Section 66 enforcement application.
(b) In Cyprus: Vassiliadis & Economou LLC, 7 Stasinou Avenue, 3rd Floor, Nicosia 1060, Cyprus. Principal contacts: Georgios Vassiliadis, Managing Partner; and Eleni Economou, Partner. Vassiliadis & Economou are believed to act for KMH and certain of its Cypriot subsidiaries.
Opposing counsel in Singapore and the UAE have not yet been identified but will be communicated to the Client once known.
4. Engagement Team
The following members of C&H will constitute the core engagement team for this matter:
Responsible Partner: Samuel Eklund. Mr. Eklund will bear overall responsibility for the strategic direction and conduct of the enforcement proceedings, the management of the client relationship, and the supervision of all work performed by the C&H team and local counsel across jurisdictions. Mr. Eklund is a partner in the Firm's International Arbitration and Dispute Resolution Group and has over twenty years' experience in the enforcement of major international arbitration awards, with particular expertise in the maritime and energy sectors. Mr. Eklund will be the Client's principal point of contact for strategic matters and will attend all key hearings.
Billing Partner: Linda Osei. Ms. Osei will be responsible for all financial aspects of the engagement, including billing, fee arrangements, management of the Fee Cap, coordination of invoices from local counsel and experts, and financial reporting to the Client. Ms. Osei is a partner in the Firm's Dispute Resolution Group with extensive experience in the management of multi-jurisdictional enforcement mandates.
Lead Associate: Hannah Brinkley. Ms. Brinkley will be responsible for the day-to-day conduct of the enforcement proceedings across all jurisdictions, including the preparation of all applications, affidavits, and submissions in the English proceedings; the coordination with and supervision of local counsel in Cyprus, Singapore, and the UAE; liaison with Hartwell Pemberton LLP and Northcape Maritime Advisory Ltd.; and the preparation of status reports for the Client. Ms. Brinkley will serve as the Client's principal day-to-day point of contact and will be the primary point of coordination with all local counsel. Ms. Brinkley is a senior associate in the Firm's International Arbitration and Dispute Resolution Group and has significant experience in cross-border enforcement and asset recovery.
Working Associate: Patrick Gallagher. Mr. Gallagher will support Ms. Brinkley across all workstreams, with particular responsibility for legal research, drafting, document preparation, court filings, and liaison with local counsel on procedural matters. Mr. Gallagher is an associate in the Firm's Dispute Resolution Group.
Additional C&H lawyers may be assigned to the matter from time to time as the volume and complexity of the work requires. The Client will be informed promptly of any material changes to the composition of the engagement team and, in particular, of any change to the Responsible Partner or Lead Associate.
5. Fee Arrangements
5.1 Hourly Rates
The Firm's current standard hourly rates applicable to this engagement are as follows:
Time is recorded in units of six minutes (0.1 of one hour). All time entries will include a brief narrative description of the work performed. Invoices will set out time charges by fee earner, with total hours and amounts for each fee earner clearly identified.
The rates set out above are the Firm's current rates as of the date of this letter. Rates are subject to annual review, with any adjustments typically taking effect on 1 January of each calendar year. The Client will be given at least thirty (30) days' prior written notice of any rate adjustment. Any rate increase will not affect time already recorded prior to the effective date of the increase.
5.2 Fee Cap
Notwithstanding the hourly rate structure described in Section 5.1 above, the total professional fees charged by C&H for work performed under this engagement (Phase 2 — Enforcement) shall not exceed £4,200,000 (four million two hundred thousand pounds sterling) (the "Fee Cap").
The Fee Cap is inclusive of all professional fees charged by C&H's lawyers for time spent on the matter, but is exclusive of the following, each of which will be billed separately to the Client:
(a) All disbursements, including but not limited to court filing fees, process server and service costs, travel expenses, accommodation costs, courier and postage charges, certified translation and interpretation fees, document legalization and apostille costs, and similar out-of-pocket expenses (as further described in Section 5.4 below);
(b) Fees of local counsel in each enforcement jurisdiction, namely Kyprianos Makrides & Partners (Cyprus), Straits Meridian LLP (Singapore), and Al-Rashid Hatem & Associates (UAE) (as further described in Section 5.5 below);
(c) Fees of Hartwell Pemberton LLP, forensic accountants (as further described in Section 5.6 below); and
(d) Fees of Northcape Maritime Advisory Ltd. for vessel valuations and related maritime advisory services.
If, during the course of the engagement, circumstances arise that may cause the Fee Cap to be exceeded — including, by way of example, the commencement of enforcement proceedings in additional jurisdictions not presently contemplated, unexpected and heavily contested interlocutory proceedings, or an appeal from the enforcement of the Award in any jurisdiction — C&H will promptly discuss the matter with the Client, providing a revised fee estimate and an explanation of the circumstances necessitating the increase. Any increase to the Fee Cap requires the Client's prior written consent. C&H will not incur fees in excess of the Fee Cap without such consent.
5.3 Success Fee
In addition to the hourly fees described in Section 5.1 (subject to the Fee Cap set out in Section 5.2), the Client agrees to pay C&H a success fee (the "Success Fee") calculated as follows:
2.5% of all amounts recovered in excess of £80,000,000 (eighty million pounds sterling) in connection with the enforcement of the Award.
For the purposes of this Section 5.3, "Amounts Recovered" means all sums actually received by or on behalf of TSL from or in respect of KMH, its related entities, or their respective assets, howsoever collected — whether by way of garnishment, third-party debt order, execution, admiralty arrest and sale, voluntary payment, settlement, or otherwise — net of any sums subsequently returned, refunded, or required to be disgorged by TSL by order of any court or tribunal.
The Success Fee shall become due and payable within thirty (30) days following the final determination or agreed close of the enforcement phase, being the date on which C&H and the Client mutually agree that enforcement efforts have been concluded or are no longer reasonably capable of producing further recoveries, or, if earlier, the date on which this engagement is terminated in accordance with Section 13.
By way of illustration, the Success Fee would be calculated as follows in the scenarios set out below:
The Success Fee is intended to reflect the substantial additional benefit to TSL of recoveries in excess of the £80,000,000 threshold, and to align the Firm's interests with the Client's objective of maximising recovery.
5.4 Disbursements
The Client is responsible for all disbursements incurred by C&H in connection with the engagement. Major categories of anticipated disbursements include, without limitation:
(a) Court filing fees in all jurisdictions (including England & Wales, Cyprus, Singapore, and the UAE);
(b) Process server and service of process costs, including international service under the Hague Service Convention or applicable bilateral treaties;
(c) Travel and accommodation expenses, principally in connection with hearings and meetings in London, Nicosia, Singapore, and Dubai, as well as any additional enforcement jurisdictions;
(d) Certified translation fees, including Arabic translations of the Award, arbitration agreement, and supporting documentation required for UAE proceedings, as well as any Greek translations required for proceedings in Cyprus or Greece;
(e) Document legalization and apostille costs;
(f) Expert fees payable to Hartwell Pemberton LLP (forensic accountants) and Northcape Maritime Advisory Ltd. (vessel valuations), to the extent not covered under separate fee arrangements described in Sections 5.5 and 5.6;
(g) Courier, printing, and communication costs; and
(h) Any other out-of-pocket expenses reasonably incurred in the conduct of the enforcement proceedings.
C&H will seek the Client's prior approval before incurring any single disbursement or category of related disbursements expected to exceed £10,000 (ten thousand pounds sterling). Smaller disbursements will be incurred in the ordinary course and reported on monthly invoices.
5.5 Local Counsel Fees
The Client is responsible for the professional fees of all local counsel engaged by C&H on the Client's behalf in each enforcement jurisdiction. Based on the scope of work presently anticipated, C&H has obtained the following fee estimates from local counsel in each jurisdiction:
These estimates are indicative and are based on the scope of work currently anticipated in each jurisdiction. Actual fees may vary depending on the complexity of proceedings, the degree of opposition from KMH, and any unforeseen procedural developments. C&H will keep the Client informed of any material deviation from these estimates.
Unless the Client instructs otherwise, local counsel will be formally engaged on the Client's behalf and will render their invoices through C&H. C&H will review all local counsel invoices for reasonableness and consistency with the agreed scope of work before transmitting them to the Client for payment. If the Client prefers to enter into direct billing arrangements with any local counsel firm, C&H will facilitate the necessary introductions and documentation. In either case, C&H will exercise reasonable oversight of local counsel fee estimates and billing practices.
5.6 Hartwell Pemberton LLP (Forensic Accountants) Fees
Hartwell Pemberton LLP will provide asset tracing, forensic analysis of KMH's corporate structure and financial flows, and interest calculations. The estimated fees for Hartwell Pemberton's services are approximately £345,000 (three hundred and forty-five thousand pounds sterling), based on the scope of work presently contemplated. Hartwell Pemberton will bill on an hourly basis, and their invoices will be rendered through C&H for review and onward transmission to the Client.
As with local counsel, actual fees may vary depending on the complexity and extent of the asset tracing required. C&H will keep the Client informed of the progress of Hartwell Pemberton's work and any material deviation from the fee estimate.
6. Billing and Payment
Invoices in respect of C&H's fees and disbursements will be rendered monthly in arrears, generally within ten (10) business days following the end of each calendar month.
Payment of each invoice is due within thirty (30) days of the date of the invoice. Late payments will bear interest at the rate of 4% per annum above the base rate of the Bank of England from time to time in force, calculated on a daily basis from the due date until the date of actual payment.
All invoices will be directed to:
Elena Stavridis Chief Financial Officer Thalassa Shipping & Logistics SA 14 Akti Miaouli, 4th Floor Piraeus 185 35, Greece
with a copy to:
Ioanna Christodoulou General Counsel Thalassa Shipping & Logistics SA (same address)
All fees quoted in this engagement letter are stated exclusive of Value Added Tax ("VAT"). Where VAT is chargeable under UK law in respect of services supplied by C&H, it will be added to invoices at the applicable rate. The Client should seek independent tax advice as to the recoverability of any VAT charged.
All funds recovered on behalf of TSL in connection with the enforcement of the Award shall be remitted, net of any locally applicable deductions required by law, to TSL's designated recovery account at:
Ionian National Bank SA 22 Stadiou Street Athens 105 64, Greece
Account details to be confirmed by the Client in writing prior to receipt of the first recovery.
C&H reserves the right to request payment on account from the Client in respect of anticipated significant disbursements, such as court fees for freezing order applications, admiralty arrest costs, or large translation and legalization expenses. Any request for payment on account will be made in writing with reasonable advance notice and will specify the nature and estimated amount of the anticipated disbursement.
7. Coordination with Local Counsel
Given the multi-jurisdictional nature of this enforcement, effective coordination between C&H and local counsel in each jurisdiction is essential. The parties agree to the following coordination framework:
C&H will serve as the central coordinating hub for all enforcement activity across jurisdictions. All instructions to local counsel will be issued by C&H on behalf of and in consultation with the Client. C&H will instruct, supervise, and receive reports from local counsel in Cyprus (Kyprianos Makrides & Partners), Singapore (Straits Meridian LLP), and the UAE (Al-Rashid Hatem & Associates).
Hannah Brinkley will serve as the primary point of coordination with all local counsel, ensuring consistent strategy, alignment of timing across jurisdictions, and the efficient exchange of information and documentation. Mr. Eklund will participate in coordination discussions on all matters of strategic significance.
Regular coordination calls and/or video conferences will be scheduled as needed, with a minimum frequency of bi-weekly during active enforcement phases. During periods of heightened activity — for example, in connection with freezing order applications, vessel arrests, or contested enforcement hearings — coordination calls may be held daily or as circumstances require.
All material filings, applications, submissions, and strategic decisions by local counsel in each jurisdiction will be reviewed and approved by C&H before submission to the relevant court or authority. Local counsel will provide draft documents to C&H with sufficient lead time to allow for meaningful review and comment.
C&H will keep the Client informed of all material developments in each jurisdiction through the bi-weekly status reports described in Section 8 below, or more frequently as circumstances warrant. The Client will be consulted on all significant strategic decisions, including the timing of applications, the sequencing of enforcement actions across jurisdictions, and any proposed settlements or compromises.
8. Reporting
C&H will provide bi-weekly written status reports to the Client, summarising progress across all enforcement jurisdictions. Each report will cover, at a minimum:
(a) A summary of material developments in each jurisdiction since the last report;
(b) A description of work in progress and anticipated next steps;
(c) An update on the status of all pending applications and proceedings;
(d) An update on asset tracing and forensic investigation results;
(e) A recovery tracker setting out all amounts recovered to date, the jurisdiction and source of each recovery, outstanding balances, and accruing interest; and
(f) Any matters requiring the Client's attention, decision, or approval.
Status reports will be addressed to Ioanna Christodoulou, General Counsel, with copies to Nikolaos Papadimitriou, Chairman & CEO, and Elena Stavridis, CFO. Reports will be transmitted by email in PDF format, marked as confidential and privileged.
In addition to the bi-weekly reports, C&H will promptly notify the Client by email or telephone of any material development requiring urgent attention or decision, including without limitation: the granting or refusal of freezing or conservatory relief; the arrest of any vessel; any significant court ruling or order; any communication from KMH or its counsel regarding potential settlement; any indication that KMH is dissipating or concealing assets; and any change to the anticipated timetable or strategy in any jurisdiction.
C&H will maintain a multi-jurisdictional recovery tracker in electronic form, recording all amounts recovered, the jurisdiction and method of recovery, outstanding balances on each component of the Award, and accruing post-award interest. The recovery tracker will be shared with the Client as part of each bi-weekly status report and will be updated in real time as recoveries are received.
9. Client Responsibilities
In order for C&H to conduct the enforcement proceedings effectively and efficiently, the Client will:
(a) Provide C&H promptly with all information, documents, records, and data reasonably requested in connection with the enforcement, including (without limitation) copies of the charter-parties, financial records relating to the claims, any information in the Client's possession regarding KMH's assets and corporate structure, and any communications between TSL and KMH following the issuance of the Award;
(b) Make available the following key contacts for the purposes of this engagement:
•  Ioanna Christodoulou, General Counsel — the Client's primary legal contact, responsible for day-to-day communication with C&H on legal matters;
•  Elena Stavridis, Chief Financial Officer — responsible for financial matters, banking information, wire instructions, and receipt and reconciliation of recovered funds;
•  Captain Dimitrios Kouretas, Head of Chartering & Operations — responsible for factual and operational matters relating to the charter-parties and the vessels (including the M/V Aegean Fortuna, M/V Crimson Horizon, and M/V Volga Spirit), as well as vessel tracking and intelligence regarding KMH fleet movements; and
•  Nikolaos Papadimitriou, Chairman & CEO — responsible for strategic decisions, authorisations, and approvals of material actions (including settlement discussions, if any);
(c) Make available witnesses for the swearing of affidavits, the provision of witness statements, and, if required, attendance at court hearings in connection with enforcement applications. C&H anticipates that witness evidence may be required from, among others, Mr. Papadimitriou, Ms. Stavridis, and Captain Kouretas. C&H will provide reasonable advance notice of any such requirements;
(d) Provide confirmed banking details and wire instructions for TSL's designated recovery account at Ionian National Bank SA in Athens, and promptly notify C&H of any change to those details; and
(e) Respond promptly to requests for instructions, decisions, and approvals, recognising that enforcement proceedings often move on compressed timetables and that delays in client instructions may prejudice the outcome of applications.
10. Confidentiality
All information and documents communicated between C&H and the Client in connection with this engagement are, and shall remain, subject to legal professional privilege (including litigation privilege and legal advice privilege) to the fullest extent available under English law and applicable law in each enforcement jurisdiction. C&H will treat all such information as strictly confidential.
C&H will not disclose confidential information relating to the Client or this engagement to any third party without the Client's prior written consent, except:
(a) As required by law, regulation, or court order in any jurisdiction;
(b) As reasonably necessary in the course of the enforcement proceedings (including, without limitation, information disclosed in court filings, affidavits, and submissions);
(c) As required by the Firm's professional regulatory obligations, including obligations to the Solicitors Regulation Authority; or
(d) To the extent necessary for the performance of this engagement, including disclosure to local counsel in each enforcement jurisdiction (Kyprianos Makrides & Partners, Straits Meridian LLP, Al-Rashid Hatem & Associates), forensic accountants (Hartwell Pemberton LLP), experts (Northcape Maritime Advisory Ltd.), and any other professional advisers engaged on the Client's behalf.
The Client acknowledges and agrees that the sharing of confidential information with local counsel, forensic accountants, and experts engaged in connection with this matter is authorised under this engagement and does not constitute a waiver of privilege or confidentiality. C&H will take reasonable steps to ensure that all such recipients are bound by obligations of confidentiality no less protective than those set out in this Section 10.
11. Conflicts of Interest
C&H has conducted a thorough conflicts check across all offices and practice groups of the Firm and confirms that, as of the date of this letter, the Firm has no conflict of interest in acting for TSL against KMH or any of its related entities. In particular, C&H confirms that it does not currently act for, and has not at any time acted for:
(a) Korinthian Maritime Holdings Ltd.;
(b) Korinthian Bulkers (Singapore) Pte. Ltd.;
(c) Dnepr Shipholding Inc.;
(d) Korinthian DMCC;
(e) Oceangate Ventures Ltd.;
(f) Andrei Volkov or Sergei Volkov, or any member of the Volkov family;
(g) Harkness Whitford & Co. or any other counsel known to represent KMH or its related entities; or
(h) Vassiliadis & Economou LLC.
C&H's internal conflicts clearance confirmation, dated 10 September 2024, is enclosed with this letter for the Client's records.
Should a potential conflict of interest arise during the course of this engagement, C&H will promptly notify the Client in writing and take all appropriate steps in accordance with the Solicitors Regulation Authority's Code of Conduct and applicable professional rules, including, where necessary, seeking the Client's informed consent to continue acting or, if consent cannot be obtained, withdrawing from the engagement in accordance with Section 13 below.
12. Limitation of Liability
C&H's aggregate liability to the Client arising out of or in connection with this engagement (whether in contract, tort, negligence, breach of statutory duty, or otherwise) shall be limited to the amount of coverage available under the Firm's professional indemnity insurance policy as maintained from time to time. Details of the Firm's professional indemnity insurance coverage, including the identity of the insurer and the current policy limits, are available upon request from Linda Osei.
This limitation of liability shall not apply to, and nothing in this Section 12 shall operate to exclude or restrict, any liability:
(a) Arising from fraud, dishonesty, or wilful default on the part of C&H or any of its members, partners, or employees;
(b) For death or personal injury caused by C&H's negligence; or
(c) Which cannot lawfully be excluded or limited under the laws of England and Wales or under the rules and regulations of the Solicitors Regulation Authority.
The Client acknowledges that C&H shall not be liable for the acts or omissions of local counsel, forensic accountants, experts, or any other third-party service providers engaged in connection with this matter, except to the extent that C&H has been negligent in the selection or supervision of such third parties.
13. Termination
Either party may terminate this engagement upon thirty (30) days' written notice to the other party. Notice of termination shall be given in writing and shall be effective upon receipt by the other party.
Upon termination of this engagement for any reason:
(a) The Client shall remain liable for all fees (at the hourly rates set out in Section 5.1, subject to the Fee Cap) and disbursements properly incurred by C&H up to and including the effective date of termination;
(b) The Client shall remain liable for any Success Fee that has accrued in accordance with Section 5.3, calculated by reference to Amounts Recovered prior to the effective date of termination;
(c) C&H will provide all reasonable cooperation in the orderly transfer of the matter to successor counsel nominated by the Client, including the delivery of all files, documents, and workpapers (subject to C&H's lien over such materials in respect of any unpaid fees and disbursements, to the extent permitted by applicable law and professional rules); and
(d) C&H will take all steps reasonably necessary to protect the Client's interests during the transition period, including seeking any necessary adjournments or extensions from courts and tribunals in all jurisdictions.
C&H may also terminate this engagement immediately if the Client fails to pay any invoice within sixty (60) days of its due date, provided that C&H has given the Client at least fourteen (14) days' prior written notice of its intention to terminate on this ground and the Client has not remedied the default within that notice period.
14. Regulatory Information
Calderwood & Harkness LLP is a limited liability partnership registered in England and Wales under registration number OC 342178, with its registered office at 45 Moorgate, London EC2R 6AR, United Kingdom.
The Firm is authorised and regulated by the Solicitors Regulation Authority ("SRA") under SRA number 528641. A list of members of the LLP is available for inspection at the Firm's registered office.
The Firm maintains professional indemnity insurance as required by the SRA Indemnity Insurance Rules. Details of the Firm's insurers and the territorial coverage of the policy are available upon request.
The Firm's complaints handling procedures are available upon request. In the event that the Client is dissatisfied with any aspect of the services provided by C&H, the Client is encouraged to raise the matter in the first instance with Samuel Eklund (Responsible Partner) or, if preferred, with the Firm's Complaints Partner, whose details will be provided upon request. If the matter cannot be resolved to the Client's satisfaction through the Firm's internal complaints procedure, the Client may have the right to refer the matter to the Legal Ombudsman, subject to the applicable eligibility criteria.
15. Governing Law and Jurisdiction
This engagement letter and any non-contractual obligations arising out of or in connection with it shall be governed by and construed in accordance with the laws of England and Wales.
Any dispute arising out of or in connection with this engagement letter, including any question regarding its existence, validity, or termination, shall be subject to the exclusive jurisdiction of the courts of England and Wales.
16. Acceptance
We should be grateful if you would confirm your acceptance of the terms set out in this engagement letter by signing and returning the enclosed duplicate copy to the Firm at your earliest convenience. By signing below, you confirm that you have read and understood the terms of this engagement letter and that you have authority to bind Thalassa Shipping & Logistics SA to the obligations set out herein.
This engagement letter, together with the Firm's standard terms and conditions of business (enclosed herewith), constitutes the entire agreement between C&H and TSL in relation to the engagement described herein and supersedes all prior discussions, negotiations, and agreements relating to the same subject matter.
We look forward to working with you and your team on this important matter and to achieving the best possible recovery for TSL.
Yours faithfully,
CALDERWOOD & HARKNESS LLP
By: ________
Name: Samuel Eklund
Title: Partner
Date: ________
ACCEPTED AND AGREED:
THALASSA SHIPPING & LOGISTICS SA
By: ________
Name: Nikolaos Papadimitriou
Title: Chairman & Chief Executive Officer
Date: ________
Enclosures
1.  Duplicate copy of this engagement letter for countersignature and return
2.  Calderwood & Harkness LLP — Standard Terms and Conditions of Business (September 2024 edition)
3.  Conflicts Clearance Confirmation — Internal memorandum reference SC/CON/2024-0912, dated 10 September 2024
Calderwood & Harkness LLP is a limited liability partnership registered in England & Wales (OC 342178). Authorised and regulated by the Solicitors Regulation Authority (SRA No. 528641). A list of members is available at 45 Moorgate, London EC2R 6AR. The term "partner" refers to a member of Calderwood & Harkness LLP or an employee or consultant with equivalent standing and qualifications.
Component | Amount (GBP)
Damages for wrongful early redelivery of M/V Aegean Fortuna | £42,300,000
Outstanding hire and damages in respect of M/V Crimson Horizon | £28,150,000
Restitution of fabricated off-hire deductions in respect of M/V Volga Spirit | £2,740,000
Loss of profit and market differential damages | £16,480,000
Pre-award interest (5.25% per annum, simple) | £6,780,000
Total Award | £96,450,000
Cost Category | Amount (GBP)
LCIA administrative charges and Tribunal fees | £3,240,000
TSL's legal costs (recoverable portion) | £8,910,000
Total Costs Payable by KMH | £12,150,000
Team Member | Role | Hourly Rate (GBP)
Samuel Eklund | Partner | £850
Linda Osei | Partner | £825
Hannah Brinkley | Senior Associate | £540
Patrick Gallagher | Associate | £420
Total Recovery (GBP) | Amount Above £80m | Success Fee (2.5%)
£80,000,000 or less | Nil | Nil
£90,000,000 | £10,000,000 | £250,000
£96,590,000 | £16,590,000 | £414,750
£108,600,000 (full Award + Costs) | £28,600,000 | £715,000
Local Counsel Firm | Jurisdiction | Estimated Fees
Kyprianos Makrides & Partners | Cyprus | Approximately €285,000
Straits Meridian LLP | Singapore | Approximately SGD $480,000
Al-Rashid Hatem & Associates | UAE | Approximately AED 620,000

CONFIDENTIAL — SUBJECT TO LEGAL PROFESSIONAL PRIVILEGE

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