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PRIVILEGED AND CONFIDENTIAL — ATTORNEY-CLIENT COMMUNICATION

CALDERWOOD & HARKNESS LLP Solicitors and International Arbitration Counsel 45 Moorgate, London EC2R 6AR, United Kingdom Tel: +44 (0)20 7496 8000

18 August 2024

By email and courier

Tariq Al-Rashid, Esq. Managing Partner Al-Rashid Hatem & Associates Office 1802, Emirates Financial Towers (South Tower) DIFC, Dubai, United Arab Emirates

Our Client: Thalassa Shipping & Logistics SA ("TSL")

Our Reference: SE/HB/PG/TSL-ENF-2024

Re: Enforcement of LCIA Award No. 224718 — Thalassa Shipping & Logistics SA v. Korinthian Maritime Holdings Ltd. — Instructions for UAE Enforcement Proceedings

Dear Mr. Al-Rashid,

1. Introduction and Purpose of this Letter

We write in our capacity as solicitors for Thalassa Shipping & Logistics SA ("TSL") in connection with the multi-jurisdictional enforcement of LCIA Final Award No. 224718, dated 28 June 2024 (the "Award"), rendered in the arbitration proceeding styled Thalassa Shipping & Logistics SA v. Korinthian Maritime Holdings Ltd. (LCIA Case Reference No. 224718).

TSL is a Société Anonyme organized and existing under the laws of the Hellenic Republic, with its registered and principal offices at 14 Akti Miaouli, 4th Floor, Piraeus 185 35, Greece (Tax Identification Number (AFM): EL-801456729). TSL is a substantial shipping operator and charterer with a long-standing presence in the international dry-bulk trades.

The purpose of this letter is to formally instruct Al-Rashid Hatem & Associates ("ARH") to act as TSL's local enforcement counsel in the United Arab Emirates in respect of the recognition, enforcement, and execution of the Award against assets of Korinthian Maritime Holdings Ltd. ("KMH") and its UAE-incorporated subsidiary, Korinthian DMCC, situated within the territory of the UAE. We understand that ARH has significant experience in UAE enforcement proceedings, including proceedings before the Dubai Courts and within the DIFC judicial framework, and we are confident that ARH is well placed to handle this important mandate.

The UAE enforcement forms one limb of a coordinated, simultaneous enforcement campaign that TSL is pursuing across four jurisdictions — namely, England & Wales, the Republic of Cyprus, the Republic of Singapore, and the United Arab Emirates. Calderwood & Harkness LLP ("C&H") has been engaged by TSL as lead enforcement counsel with overall responsibility for the coordination and strategic direction of the enforcement programme in all jurisdictions. Accordingly, ARH will take day-to-day instructions from the C&H enforcement team — principally from Hannah Brinkley (Lead Associate) and Patrick Gallagher (Working Associate), under the supervision of the undersigned as responsible partner — and will report directly to the C&H team on all material developments. This arrangement has been expressly approved by TSL's in-house General Counsel, Ms. Ioanna Christodoulou.

We should be grateful if you would confirm, at your earliest convenience and in any event by no later than 20 August 2024, that ARH is able to accept these instructions, that you have completed any necessary conflict checks and that no conflict of interest exists, and that you are in a position to act with immediate effect. Please also provide any standard engagement terms or retainer letter that ARH requires for our review and onward transmission to the client.

The balance of this letter sets out the relevant background, the detail of the Award, the enforcement targets in the UAE, and the specific instructions that we ask ARH to carry out.

2. Background — The Underlying Dispute and LCIA Arbitration

2.1 The Charter-Party Agreements

TSL entered into three separate English-law time charter-party agreements with KMH, a private limited company incorporated in the Republic of Cyprus under Registration No. HE 387421, with its registered office at 28 Themistokli Dervi Avenue, Suite 601, Nicosia 1066, Cyprus. The three charters are as follows:

(a) M/V *Aegean Fortuna (IMO 9784521) — a Supramax Bulk Carrier of 58,200 DWT, registered under the flag of the Republic of the marshall Islands. The time charter-party in respect of this vessel was executed on 15 March 2019 (the "Aegean Fortuna* Charter").

(b) M/V *Crimson Horizon (IMO 9801334) — a Handymax Bulk Carrier of 37,500 DWT, registered under the flag of the Republic of Liberia. The time charter-party in respect of this vessel was executed on 22 January 2020 (the "Crimson Horizon* Charter").

(c) M/V *Volga Spirit (IMO 9756892) — a Panamax Bulk Carrier of 76,400 DWT, registered under the flag of the Republic of Cyprus. The time charter-party in respect of this vessel was executed on 10 June 2021 (the "Volga Spirit* Charter").

Each of the three charter-party agreements is governed by English law and contains an arbitration clause referring disputes to arbitration under the rules of the London Court of International Arbitration ("LCIA"), with the seat of arbitration in London, England. Certified copies of all three charters, together with certified Arabic translations of the relevant arbitration clauses, are enclosed with this letter as described in Section 7 below.

2.2 KMH's Repudiatory Breaches

Beginning in the middle of 2022, KMH engaged in a course of conduct amounting to repudiatory breaches of all three charter-party agreements. In summary, the breaches were as follows:

(a) Wrongful early redelivery of M/V *Aegean Fortuna*: KMH wrongfully and without contractual justification redelivered the M/V Aegean Fortuna to TSL on 18 June 2022, approximately fourteen (14) months before the earliest redelivery date permitted under the Aegean Fortuna Charter. TSL was thereby deprived of the benefit of the charter-hire for the unexpired term and suffered significant market-differential losses, the dry-bulk market having substantially softened by the date of early redelivery.

(b) Failure to pay hire on M/V *Crimson Horizon*: KMH ceased making hire payments due under the Crimson Horizon Charter with effect from 1 July 2022. As of the date on which TSL exercised its contractual right to withdraw the vessel on 15 September 2022, the accumulated hire arrears stood at approximately £4,280,000. KMH's failure to pay hire constituted a clear repudiatory breach of the charter.

(c) Fabricated off-hire deductions on M/V *Volga Spirit*: Over a period of several months in 2022, KMH purported to make off-hire deductions from the hire payable under the Volga Spirit Charter in the aggregate amount of approximately £2,740,000. These deductions were based on fabricated or grossly exaggerated claims that the vessel was off-hire due to mechanical deficiencies and were not supported by the vessel's operational records. The Tribunal found these deductions to be entirely without merit and amounting to a dishonest scheme by KMH to reduce its chartering expenditure.

2.3 The LCIA Arbitration

TSL filed its Request for Arbitration with the LCIA on 14 November 2022 (LCIA Case Reference No. 224718). The arbitral tribunal (the "Tribunal") was constituted on 8 February 2023, comprising the following members:

• Presiding Arbitrator: Sir Malcolm Fenton-Clarke

• Co-Arbitrator (Claimant-nominated): Professor Athena Drakopoulos

• Co-Arbitrator (Respondent-nominated): Dr. Henrik Dalmqvist

• Tribunal Secretary: Ms. Fiona Beckett

The arbitration proceeded through a full cycle of written submissions, disclosure, witness statements, and expert evidence. The evidentiary hearing took place over ten hearing days from 11 to 22 September 2023 at the International Dispute Resolution Centre ("IDRC") in London.

KMH was represented throughout the entirety of the arbitral proceedings by Harkness Whitford & Co. (SRA No. 614823), of 12 Fetter Lane, London EC4A 1JP. The partner team acting for KMH comprised Richard Harkness (Senior Partner), Catherine Whitford (Partner), and James Thornbury (Associate). KMH participated fully in the proceedings, filed substantial written submissions and evidence, cross-examined TSL's witnesses and experts at the hearing, and made extensive oral closing submissions. There is accordingly no basis whatsoever for any suggestion that KMH was denied an opportunity to present its case or was not given proper notice of the proceedings.

3. The LCIA Award

3.1 Issuance and Operative Provisions

The Tribunal issued its Final Award on 28 June 2024. The Award is a final, binding, and enforceable award within the meaning of the LCIA Rules (2020), the English Arbitration Act 1996, and the New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards (1958). The Award was rendered unanimously by all three members of the Tribunal. A certified copy of the Award, together with a certified Arabic translation, is enclosed herewith.

3.2 Amounts Awarded

The Award provides for the following sums payable by KMH to TSL:

At the prevailing exchange rate as of the date of the Award (£1 = USD $1.2441, as of 28 June 2024), the total award amount is equivalent to approximately USD $120,000,000.

3.3 Costs. The Tribunal allocated costs 85% to KMH as the unsuccessful respondent. The costs component of the Award is as follows:

3.4 Grand Total and Post-Award Interest

The grand total payable by KMH to TSL under the Award (inclusive of all heads of damages, pre-award interest, and costs) is £108,600,000.

The Award further provides for post-award interest at the rate of 5.25% per annum simple on all unpaid sums from 29 June 2024 until the date of full payment. Post-award interest continues to accrue and should be included in the enforcement application.

3.5 Non-Payment. As of the date of this letter, KMH has failed to make any payment whatsoever in satisfaction of the Award, whether in respect of the substantive award amounts, the costs, or any part thereof. KMH has not communicated any intention to comply with the Award voluntarily. To the contrary, as described below, there is strong evidence that KMH is actively seeking to restructure its corporate holdings and dissipate its assets in order to frustrate enforcement.

4. KMH's Corporate Structure and UAE Assets — Target for Enforcement

4.1 KMH Group Structure Overview

KMH is beneficially owned and controlled by the Volkov family, principally by Andrei Volkov, who is the ultimate beneficial owner ("UBO") and the de facto director of KMH and its group companies, and by his son, Sergei Volkov, who holds a formal directorship of KMH and several group entities. The Volkov family's ownership of KMH is routed through a series of British Virgin Islands and Cypriot holding structures.

According to the preliminary intelligence gathered by our forensic accountants (as described further below), the KMH group has an estimated pre-dispute net asset value of approximately USD $280 million, comprising principally a fleet of approximately eighteen (18) dry-bulk carriers held through various single-purpose vehicle ("SPV") subsidiaries. The key officers of the KMH group, in addition to the Volkov family members, include:

• Marina Kazakova — Chief Financial Officer

• Alexei Demidov — Director of Fleet Operations

The principal intermediate holding company through which the Volkov family holds its interest in the operating entities is Oceangate Ventures Ltd., a company incorporated in the Republic of Cyprus under Registration No. HE 401293, with its registered address at 28 Themistokli Dervi Avenue, Suite 604, Nicosia 1066, Cyprus. The primary fleet SPV is Dnepr Shipholding Inc., a company incorporated in the British Virgin Islands under Company No. 2014876, with its registered office c/o Vantage Corporate Services Ltd., Road Town, Tortola, BVI. Dnepr Shipholding Inc. is believed to hold registered title to a number of the vessels in the KMH fleet, including the M/V Volga Spirit.

4.2 Korinthian DMCC — The UAE Target Entity

The primary target for enforcement in the UAE is Korinthian DMCC, a free zone company incorporated under the laws of the Dubai Multi Commodities Centre ("DMCC") in Dubai, UAE. The key details of this entity are as follows:

• Full legal name: Korinthian DMCC

• Entity type: DMCC free zone company (limited liability company)

• Registered address: Unit 3407, Almas Tower, Jumeirah Lakes Towers ("JLT"), Dubai, United Arab Emirates

• Function within KMH group: Korinthian DMCC acts as the KMH group's regional operational and commercial hub for its chartering and ship-management activities in the Arabian Gulf region. It holds operational funds, collects trade receivables from sub-charterers and freight payers in the region, and manages the commercial aspects of KMH's dry-bulk trading operations in the Middle East.

Critically, based on preliminary intelligence received from Hartwell Pemberton LLP (forensic accountants, 25 Old Broad Street, London EC2N 1HN; lead partner Rebecca Saunders; director Mark Huxley), Korinthian DMCC maintains significant bank accounts at Emirates Gulf Commercial Bank PJSC ("EGCB"), Dubai branch, located at Gate Village 3, DIFC, Dubai. Hartwell Pemberton's preliminary asset tracing report, dated 15 August 2024 (a copy of which is enclosed), indicates that Korinthian DMCC holds substantial receivables from a number of sub-charterers in the region, and that its EGCB accounts receive regular incoming payments in respect of charter-hire and freight. While we are not yet in a position to confirm the precise balance of the EGCB accounts, the available intelligence suggests that the funds held are material and that these accounts represent a significant and realizable enforcement target.

We draw your attention to the fact that Korinthian DMCC is, on our analysis, a subsidiary or alter ego of KMH, and that the Award should be enforceable against its assets on the basis that it is part of the same corporate group and is used as a vehicle for holding and managing KMH's assets and revenues. We will provide ARH with a full memorandum of law on this point, together with the supporting corporate intelligence and documentation, to assist in establishing the corporate link before the Dubai Court.

4.3 M/V *Volga Spirit* — Potential Additional UAE-Connected Asset

We also wish to bring to ARH's attention the M/V Volga Spirit (IMO 9756892, Panamax Bulk Carrier, 76,400 DWT, Cyprus flag), which is owned by Dnepr Shipholding Inc. (BVI), a KMH group entity. This vessel is one of the three vessels that was the subject of the underlying chartering dispute. Vessel tracking intelligence indicates that the M/V Volga Spirit has been trading in the Arabian Gulf in recent weeks, and the most recent intelligence suggests that it may call at UAE ports, including the Port of Fujairah, in the near term.

While the arrest of the M/V Volga Spirit does not form part of our immediate instructions to ARH, we note this vessel as a potential future enforcement target should it be located within UAE territorial waters. We would ask that ARH maintain readiness to act on an urgent basis — including on very short notice and potentially outside normal court hours — in the event that C&H instructs ARH to pursue an arrest application in respect of this vessel. We understand that UAE admiralty arrest procedures may provide a basis for the arrest of a vessel owned by a group entity of the award debtor, and we would welcome ARH's preliminary advice on the available legal basis for such an arrest.

5. Parallel Enforcement Proceedings in Other Jurisdictions

As noted above, the UAE enforcement forms one limb of a coordinated multi-jurisdictional enforcement campaign. It is important that ARH is aware of the status of the parallel enforcement proceedings in order to ensure consistency and to avoid any risk of conflicting positions being adopted across the various jurisdictions. The current status of proceedings in each jurisdiction is as follows:

5.1 England & Wales

TSL filed an application to enforce the Award as a judgment of the English High Court under Section 66 of the Arbitration Act 1996 on 15 July 2024 in the Commercial Court, Queen's Bench Division, High Court of Justice (Claim No. CL-2024-000487). Permission to enforce was granted on 2 August 2024 by Mr. Justice Ashworth.

In support of the enforcement, TSL obtained a Worldwide Freezing Order ("WFO") on an ex parte basis on 16 July 2024, freezing KMH's assets worldwide up to the value of £108,600,000. The WFO was granted by Mr. Justice Ashworth on the basis of compelling evidence of a real risk of dissipation, including evidence of post-award transfers of funds from KMH's London bank accounts, the restructuring of corporate entities within the KMH group, and the Volkov family's history of asset concealment. The WFO was continued with certain modifications at the return date hearing on 30 July 2024.

An interim third-party debt order was granted on 5 August 2024 against Meridian Trust Bank Ltd. (50 Lombard Street, London EC3V 9EA) in respect of funds held in KMH's accounts at that bank.

We note that KMH has filed an application to set aside the Award under Sections 68 and 69 of the Arbitration Act 1996, dated 19 August 2024. C&H is currently assessing this application and considers the prospects of success to be low. We do not anticipate that the set-aside application will have any material bearing on the enforcement proceedings in the UAE, but we will keep ARH informed of any significant developments.

5.2 Cyprus. An application for recognition and enforcement of the Award was filed on 9 August 2024 in the Nicosia District Court (Case No. 2247/2024) under the New York Convention and the Cyprus Arbitration Law (Cap. 4). A freezing injunction over the shares of Oceangate Ventures Ltd. and KMH's Cyprus bank accounts was granted on 12 August 2024. Local counsel in the Cyprus proceedings is:

Kyprianos Makrides & Partners Andreas Kyprianos (Senior Partner) and Nadia Makrides (Partner) 15 Grivas Digenis Avenue, Nicosia 1066, Cyprus

5.3 Singapore. An application to enforce the Award under the International Arbitration Act (Cap. 143A) was filed on 14 August 2024 in the Singapore High Court (Originating Summons No. 872/2024). The M/V *Crimson Horizon was successfully arrested in Singapore waters on 20 August 2024. In addition, garnishee proceedings have been initiated against Pinnacle Bank (Singapore) Ltd. (6 Battery Road, #20-01, Singapore 049909) in respect of accounts held by Korinthian Bulkers (Singapore) Pte. Ltd.* (80 Robinson Road, #14-02, Singapore 068898), a further KMH group entity. Local counsel in the Singapore proceedings is:

Straits Meridian LLP David Teo Wei Lin (Partner) and Priya Subramaniam (Senior Associate) 1 Raffles Place, #44-01 One Raffles Place Tower 2, Singapore 048616

5.4 Relevance of the English WFO to the UAE Proceedings

We draw to ARH's particular attention the fact that the WFO obtained in England extends worldwide and, on its terms, applies to KMH's assets in the UAE, including the assets of any entity that KMH has the power to cause to comply with the order. However, the WFO does not of itself constitute an order of the UAE courts and cannot be directly executed against UAE-situated assets without a separate local enforcement and attachment proceeding. It is for this reason that the local enforcement and precautionary attachment applications described in Section 6 below are necessary and urgent.

That said, the existence and terms of the English WFO are highly relevant to the UAE precautionary attachment application, as they constitute compelling evidence that a court of competent jurisdiction has already found a real risk of dissipation of KMH's assets. A copy of the WFO is enclosed for use in the UAE proceedings.

6. Specific Instructions — UAE Enforcement Application

We set out below the specific instructions that we ask ARH to carry out in respect of the UAE enforcement proceedings. These instructions should be read in conjunction with the broader strategic objectives described elsewhere in this letter, and ARH should at all times coordinate with C&H before taking any material procedural step.

6.1 Filing the Enforcement Application

ARH is instructed to prepare and file an application for the recognition and enforcement of LCIA Award No. 224718 in the Dubai Court of First Instance (Execution Division) as soon as practicable and, in any event, no later than the target date specified in Section 11 below.

The legal basis for the enforcement application is:

(a) UAE Federal Law No. 6 of 2018 (the "UAE Arbitration Law"), which governs the recognition and enforcement of arbitral awards in the UAE and provides a framework consistent with international best practice; and

(b) The New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards (1958), to which the United Arab Emirates has been a party since 19 November 2006. The Award is a "foreign arbitral award" within the meaning of the New York Convention, having been rendered at a seat (London, England) in the territory of a fellow Contracting State (the United Kingdom). The UAE's accession to the New York Convention was without reservation as to reciprocity or the commercial nature of the dispute, and the Convention applies to the Award as of right.

The enforcement application should seek enforcement of the full Award amount of £96,450,000, together with costs of £12,150,000, totaling £108,600,000, together with post-award interest at the rate of 5.25% per annum simple on all unpaid sums from 29 June 2024 to the date of payment. ARH should convert the sterling amounts into the equivalent in UAE Dirhams (or US Dollars, as the court may require) at the prevailing exchange rate as of the date of filing, and should seek enforcement in both the sterling amount and the local currency equivalent.

The respondent to the enforcement application should be identified as:

Korinthian Maritime Holdings Ltd. Registration No. HE 387421 28 Themistokli Dervi Avenue, Suite 601 Nicosia 1066, Cyprus

In addition, Korinthian DMCC (Unit 3407, Almas Tower, JLT, Dubai, UAE) should be identified as an entity whose assets are subject to execution as a subsidiary and/or alter ego of KMH. ARH should present such arguments as are available under UAE law to establish that the corporate veil between KMH and Korinthian DMCC should be pierced, or alternatively that Korinthian DMCC's assets are properly subject to execution in satisfaction of the Award on the basis that they are in substance the assets of KMH. C&H will provide ARH with a detailed memorandum addressing the corporate link, including the relevant corporate registry documents, the beneficial ownership chain, and the factual evidence of Korinthian DMCC's role as a conduit for KMH's funds.

6.2 Precautionary Attachment Application

Simultaneously with, or immediately following, the filing of the enforcement application, ARH is instructed to apply for a precautionary attachment (or conservatory attachment) over all accounts, funds, credit balances, and receivables of Korinthian DMCC held at Emirates Gulf Commercial Bank PJSC ("EGCB"), Dubai branch, Gate Village 3, DIFC, Dubai, UAE.

The precautionary attachment should be drafted in the broadest available terms and should cover:

(a) All sums standing to the credit of Korinthian DMCC in any and all accounts maintained at EGCB, whether denominated in AED, USD, GBP, EUR, or any other currency;

(b) All receivables due or to become due to Korinthian DMCC from third parties, including but not limited to charter-hire payments, freight payments, demurrage claims, and any other sums arising from Korinthian DMCC's chartering and commercial operations in the region; and

(c) Any other assets of Korinthian DMCC that may be identified and that fall within the scope of the court's attachment jurisdiction.

The legal basis for the precautionary attachment application is the precautionary attachment provisions under the UAE Civil Procedure Law (Federal Law No. 11 of 1992, as amended), and any other applicable provisions of UAE law permitting conservatory measures in support of enforcement proceedings.

The grounds on which the attachment is sought include the following:

(i) TSL holds a final, binding, and enforceable arbitral award for a sum in excess of £108 million, which KMH has failed to satisfy in whole or in part;

(ii) There is a real and demonstrable risk of dissipation of KMH's assets, including the assets of Korinthian DMCC. This risk is evidenced by: (a) KMH's post-award transfers of funds from its London bank accounts, which prompted the English Commercial Court to grant a Worldwide Freezing Order; (b) the ongoing restructuring of KMH's corporate entities, including changes to the directorship and shareholding of certain group companies, which are consistent with an attempt to place assets beyond the reach of creditors; and (c) KMH's complete failure to engage constructively with TSL's enforcement efforts or to make any voluntary payment in satisfaction of the Award;

(iii) The English Commercial Court has already found, on the basis of the evidence before it, that there is a real risk of dissipation sufficient to justify a worldwide freezing order — the grant of the WFO constitutes powerful and independent evidence of dissipation risk that should carry significant weight before the Dubai Court; and

(iv) In the absence of a precautionary attachment, there is a serious risk that Korinthian DMCC's EGCB accounts will be emptied or that receivables will be diverted to other accounts or entities, thereby frustrating TSL's ability to execute on the Award in the UAE.

We request that ARH seek the attachment order on an urgent, ex parte basis if this is available under UAE procedure. We understand that the UAE Civil Procedure Law may permit the court to grant precautionary attachment orders without prior notice to the respondent in cases of urgency, and we submit that the present circumstances — involving a multi-million-pound unpaid arbitral award, clear evidence of dissipation risk, and the ease with which bank balances may be transferred — warrant such an approach. ARH should advise C&H immediately if ex parte relief is not available or if there are any procedural constraints on urgency.

6.3 Translation and Legalization Requirements

C&H is aware that the UAE courts require certified Arabic translations of all foreign-language documents submitted in evidence, and that foreign public documents must be duly legalized or apostilled in accordance with the requirements of UAE law. We have made arrangements accordingly, as follows:

C&H has arranged for certified Arabic translations of the following key documents through a translation firm accredited by the UAE Ministry of Justice:

(a) LCIA Award No. 224718 (Final Award, dated 28 June 2024);

(b) The LCIA arbitration clauses contained in each of the three charter-party agreements; and

(c) The certificate from the LCIA Registrar confirming the authenticity of the Award and the proper constitution of the Tribunal.

Legalization of these documents is being obtained through the UK Foreign, Commonwealth and Development Office ("FCDO") apostille process, followed by authentication by the Embassy of the United Arab Emirates in London. We anticipate that the legalized and apostilled originals will be available for courier delivery to ARH no later than 21 August 2024, in advance of the target filing date.

We would ask ARH to advise promptly if any additional translations, legalization steps, notarization requirements, or local procedural requirements are needed for filing in the Dubai Court of First Instance. In particular, please advise whether:

• The Dubai Court requires the full text of the charter-party agreements (as opposed to the arbitration clauses alone) to be translated and legalized;

• Any additional certificates, declarations, or attestations are required from C&H, from TSL, or from the LCIA;

• There are any specific requirements as to the form or presentation of the Arabic translations (e.g., notarization by a UAE-accredited notary public); and

• Any filing fees, court deposits, or guarantees are required, and if so, the anticipated amounts.

7. Enclosed Documents

The following documents are enclosed with this letter, transmitted by secure courier and by encrypted electronic transmission (via C&H's secure file-sharing platform, access credentials for which will be provided to ARH separately):

1. Certified copy of LCIA Award No. 224718 (Final Award, dated 28 June 2024) — original English version, certified by the LCIA Registrar.

2. Certified Arabic translation of the Award — prepared by a certified translation firm accredited by the UAE Ministry of Justice.

3. Certified copies of the three charter-party agreements:

(a) M/V Aegean Fortuna Time Charter-Party, dated 15 March 2019; (b) M/V Crimson Horizon Time Charter-Party, dated 22 January 2020; (c) M/V Volga Spirit Time Charter-Party, dated 10 June 2021;

each containing the LCIA arbitration clause — original English versions.

4. Certified Arabic translations of the arbitration clauses contained in each of the three charter-party agreements.

5. Certificate from the LCIA Registrar confirming the authenticity of the Award, the proper constitution of the Tribunal, and the regularity of the arbitral proceedings.

6. Certified Arabic translation of the LCIA Registrar's certificate.

7. Copy of the Worldwide Freezing Order granted by Mr. Justice Ashworth on 16 July 2024 (Claim No. CL-2024-000487), as continued with modifications on 30 July 2024 — to be used as evidence of dissipation risk in support of the precautionary attachment application.

8. Hartwell Pemberton LLP preliminary asset tracing report, dated 15 August 2024 — identifying Korinthian DMCC's accounts at EGCB and trade receivables. This report is marked strictly confidential and is subject to litigation privilege. It should be used for the purposes of the court application as appropriate but should not be disclosed more widely without the prior consent of C&H.

9. Corporate registry extracts for:

(a) Korinthian Maritime Holdings Ltd. (Cyprus Company Registry, Registration No. HE 387421); and (b) Korinthian DMCC (DMCC corporate registry, Dubai, UAE).

10. Power of attorney / authority to act — To be confirmed. ARH is requested to advise on the form of power of attorney or authority to act required by the Dubai Court of First Instance for the filing of the enforcement application and the precautionary attachment application. C&H will arrange for the necessary power of attorney to be executed by TSL and legalized as required, but we will need ARH's guidance on the form, content, and any local requirements.

Please confirm receipt of all of the above documents upon delivery.

8. Anticipated Defenses by KMH

C&H anticipates that KMH, potentially through local UAE counsel, may seek to oppose both the enforcement application and the precautionary attachment application. While we are confident that the Award is enforceable in the UAE and that there is no meritorious basis for refusal, ARH should be prepared for the following potential lines of defense:

8.1 New York Convention Article V Defenses

Under Article V of the New York Convention, the grounds on which recognition and enforcement of a foreign arbitral award may be refused are limited and exhaustive. The likely grounds that KMH may seek to invoke include the following:

(a) Procedural objections (Article V(1)(b) — improper notice / inability to present case): KMH may argue that it was not given proper notice of the arbitral proceedings or was otherwise unable to present its case. This argument is entirely without merit. As set out in Section 2.3 above, KMH was fully represented throughout the LCIA arbitration by experienced English solicitors (Harkness Whitford & Co.) and participated actively in all phases of the proceedings, including a ten-day evidentiary hearing at which KMH's counsel cross-examined TSL's witnesses and presented KMH's own evidence and submissions.

(b) Public policy (Article V(2)(b)): KMH may seek to invoke the public policy exception to enforcement. There is, however, no credible public policy basis on which to refuse enforcement of a London-seated LCIA award arising from a purely commercial shipping dispute between sophisticated commercial parties. The Award was rendered by a properly constituted tribunal of eminent arbitrators, following a full and fair hearing conducted in accordance with the LCIA Rules, and the UAE courts have consistently recognized that the public policy exception under the New York Convention is to be construed narrowly and applied only in exceptional circumstances.

(c) Scope of the arbitration agreement (Article V(1)(c)): KMH may argue that certain heads of damages awarded by the Tribunal fell outside the scope of the arbitration agreement. Again, this argument lacks merit; the LCIA arbitration clauses in the three charters were broadly drafted and encompassed all disputes arising out of or in connection with the charters.

8.2 Separate Legal Entity Defense

Perhaps the most significant defense that KMH is likely to raise in the UAE proceedings is an argument that Korinthian DMCC is a separate legal entity that is not bound by the Award and whose assets cannot be attached or executed upon in satisfaction of KMH's liabilities. ARH should be prepared to counter this argument by establishing the corporate link between KMH and Korinthian DMCC, including by demonstrating that:

• Korinthian DMCC is a wholly owned subsidiary (directly or indirectly) of KMH, controlled by the same beneficial owners (the Volkov family);

• Korinthian DMCC functions as KMH's operational and financial conduit in the Arabian Gulf, receiving and holding funds that are in substance the assets and revenues of KMH;

• The corporate structure of the KMH group has been deliberately designed to obscure the true ownership and control of the group's assets and to hinder the enforcement of claims against KMH; and

• On a proper analysis, the corporate veil between KMH and Korinthian DMCC should be pierced, or alternatively that Korinthian DMCC's assets are properly subject to execution in satisfaction of the Award.

C&H will provide ARH with a full memorandum on this issue, including the relevant corporate intelligence, beneficial ownership documentation, and a comparative analysis of the veil-piercing principles applicable under UAE law. We would also welcome ARH's preliminary advice on the approach of the UAE courts to corporate veil-piercing in the enforcement context and the likelihood of success on this point.

8.3 UAE-Specific Defenses

ARH should further advise on any UAE-specific procedural or substantive defenses that may be available to KMH under UAE law, including but not limited to:

• Any requirements under UAE law as to the finality or enforceability of the award (e.g., whether the pendency of the English set-aside proceedings could constitute grounds for adjourning or refusing enforcement);

• Any procedural objections relating to the form or legalization of the documents submitted in support of the enforcement application;

• Any requirements under DMCC free zone regulations that may affect the attachment of Korinthian DMCC's assets; and

• The expected timeline for the court's consideration of the enforcement application and any opposition, including typical adjournment practices and the availability of expedited procedures.

9. Reporting and Coordination

The effective coordination of the UAE enforcement with the parallel proceedings in England & Wales, Cyprus, and Singapore is of paramount importance to the success of the overall enforcement campaign. Accordingly, ARH is requested to observe the following reporting and coordination protocols:

(a) Acceptance of Instructions and Engagement Terms: ARH is requested to confirm acceptance of these instructions and to provide any standard engagement terms, retainer letter, or terms of business that ARH requires. Please confirm that no conflict of interest exists.

(b) Timeline: ARH is requested to confirm the estimated timeline for: (i) filing the enforcement application; (ii) filing the precautionary attachment application; (iii) obtaining the precautionary attachment order; and (iv) obtaining a final enforcement order.

(c) Fee Estimate: ARH is requested to provide a detailed fee estimate for the enforcement proceedings, including estimated court fees, translation costs, and any other disbursements. C&H notes that the current estimated budget allocation for ARH's fees in connection with the UAE enforcement is AED 620,000 (approximately GBP £135,000 at current exchange rates). Please confirm whether this budget is adequate, and if not, please provide a revised estimate with a breakdown of anticipated costs by phase of work.

(d) Power of Attorney: ARH is requested to advise on the form of power of attorney or authority to act required by the Dubai Court of First Instance, and to provide a template or draft for C&H's review. We will arrange for the power of attorney to be executed by TSL and legalized as required.

(e) Reporting: ARH is requested to report to C&H (attention: Hannah Brinkley and Patrick Gallagher, with copies to Samuel Eklund) on all material developments promptly as they arise, and to provide formal written status updates at least on a bi-weekly basis (i.e., every two weeks). Status updates should include a summary of work undertaken, a description of any pending deadlines or upcoming hearing dates, a report on any contact with the opposing side, and an updated assessment of the enforcement prospects.

(f) Coordination: ARH must coordinate with C&H before taking any material procedural step in the UAE proceedings, including but not limited to: the filing of any application or pleading; the making of any concession or offer to the opposing side; the acceptance of any adjournment; and the taking of any enforcement or execution step. This requirement applies to all communications with KMH's UAE counsel and to any substantive engagement with the court.

(g) Copies of Correspondence and Filings: ARH is requested to copy C&H on all substantive correspondence, court filings, court orders, and judicial communications in the UAE proceedings. Where documents are in Arabic, ARH should provide an English-language summary or translation for C&H's records.

C&H's contact details for day-to-day instructions are as follows:

Hannah Brinkley — Lead Associate

Email: h.brinkley@calderwoodharkness.com

Direct Line: +44 (0)20 7496 8147 Mobile: +44 (0)7700 944 218

Patrick Gallagher — Working Associate

Email: p.gallagher@calderwoodharkness.com

Direct Line: +44 (0)20 7496 8263 Mobile: +44 (0)7700 961 553

Samuel Eklund — Responsible Partner

Email: s.eklund@calderwoodharkness.com

Direct Line: +44 (0)20 7496 8004 Mobile: +44 (0)7770 832 140

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

10. Client Information

For the avoidance of doubt, the client for billing and engagement purposes is Thalassa Shipping & Logistics SA. The relevant client contact details are as follows:

In-house General Counsel: Ms. Ioanna Christodoulou

Email: i.christodoulou@thalassashipping.gr

Direct Line: +30 210 429 7800

Chief Financial Officer: Ms. Elena Stavridis

Email: e.stavridis@thalassashipping.gr

Direct Line: +30 210 429 7815

Client Principal Address: Thalassa Shipping & Logistics SA 14 Akti Miaouli, 4th Floor Piraeus 185 35 Greece

TSL's primary operating bank, for the receipt of any enforcement proceeds recovered in the UAE proceedings, is:

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

Wire transfer details for the receipt of funds will follow under separate cover. In the event that any enforcement proceeds are recovered in the UAE, ARH should not release any funds without the prior written authorization of C&H and should hold all recovered sums in ARH's client account pending instructions.

All invoices, fee notes, and engagement correspondence from ARH should be directed to C&H at the address and email coordinates set out above. C&H will coordinate the review and approval of all invoices with the client.

11. Urgency and Next Steps

We wish to emphasize that this matter is urgent. There is an ongoing and serious risk of further dissipation of KMH's assets in the UAE, and each day that passes without a precautionary attachment in place increases the likelihood that Korinthian DMCC's EGCB accounts will be depleted or that receivables will be diverted beyond the reach of TSL's enforcement efforts. The evidence of dissipation, which was sufficient to persuade the English Commercial Court to grant a worldwide freezing order, applies with equal force to the UAE-situated assets.

Accordingly, ARH is requested to take the following steps as a matter of priority:

1. Confirmation of receipt and acceptance: Please confirm receipt of this letter and the enclosed documents, and confirm that ARH is able to accept these instructions and act with immediate effect, by no later than 20 August 2024.

2. Filing of enforcement and attachment applications: ARH is requested to file the enforcement application and the precautionary attachment application at the earliest practicable opportunity, and in any event to aim for filing by no later than 22 August 2024. If this target date is not achievable for any reason, please advise immediately so that C&H can adjust the enforcement timetable accordingly.

3. Strategy call: C&H would welcome a telephone conference call with Tariq Al-Rashid and Leila Hatem (or such other members of the ARH team as will be working on this matter) at ARH's earliest convenience to discuss the procedural strategy, timing, and any preliminary issues that ARH has identified. Please propose a time for this call, ideally on 19 or 20 August 2024.

4. Power of attorney: Please advise on the form and content of the power of attorney required by the Dubai Court by no later than 20 August 2024, so that C&H can arrange for its execution and legalization without delay.

12. Closing

We are grateful for ARH's willingness to assist on this important matter and are confident that ARH's recognized expertise in UAE enforcement proceedings, DMCC-related litigation, and DIFC practice will be of great value to TSL's enforcement campaign. The successful enforcement of the Award in the UAE represents a critical element of TSL's multi-jurisdictional strategy, and we attach the highest importance to the prompt and effective execution of these instructions.

We very much look forward to working with you and your colleagues at ARH on this matter and to a productive and collaborative professional relationship. Please do not hesitate to contact the undersigned or any member of the C&H enforcement team at any time should you have any questions or require any additional information.

We thank you in advance for your prompt attention to this matter.

Yours faithfully,

CALDERWOOD & HARKNESS LLP

By: ________

Samuel Eklund Partner, Litigation Calderwood & Harkness LLP 45 Moorgate, London EC2R 6AR United Kingdom

Direct Line: +44 (0)20 7496 8004

PRIVILEGED AND CONFIDENTIAL — ATTORNEY-CLIENT COMMUNICATION
CALDERWOOD & HARKNESS LLP Solicitors and International Arbitration Counsel 45 Moorgate, London EC2R 6AR, United Kingdom Tel: +44 (0)20 7496 8000 | Fax: +44 (0)20 7496 8001 www.calderwoodharkness.com
18 August 2024
By email and courier
Tariq Al-Rashid, Esq. Managing Partner Al-Rashid Hatem & Associates Office 1802, Emirates Financial Towers (South Tower) DIFC, Dubai, United Arab Emirates
Our Client: Thalassa Shipping & Logistics SA ("TSL")
Our Reference: SE/HB/PG/TSL-ENF-2024
Re: Enforcement of LCIA Award No. 224718 — Thalassa Shipping & Logistics SA v. Korinthian Maritime Holdings Ltd. — Instructions for UAE Enforcement Proceedings
Dear Mr. Al-Rashid,
1. Introduction and Purpose of this Letter
We write in our capacity as solicitors for Thalassa Shipping & Logistics SA ("TSL") in connection with the multi-jurisdictional enforcement of LCIA Final Award No. 224718, dated 28 June 2024 (the "Award"), rendered in the arbitration proceeding styled Thalassa Shipping & Logistics SA v. Korinthian Maritime Holdings Ltd. (LCIA Case Reference No. 224718).
TSL is a Société Anonyme organized and existing under the laws of the Hellenic Republic, with its registered and principal offices at 14 Akti Miaouli, 4th Floor, Piraeus 185 35, Greece (Tax Identification Number (AFM): EL-801456729). TSL is a substantial shipping operator and charterer with a long-standing presence in the international dry-bulk trades.
The purpose of this letter is to formally instruct Al-Rashid Hatem & Associates ("ARH") to act as TSL's local enforcement counsel in the United Arab Emirates in respect of the recognition, enforcement, and execution of the Award against assets of Korinthian Maritime Holdings Ltd. ("KMH") and its UAE-incorporated subsidiary, Korinthian DMCC, situated within the territory of the UAE. We understand that ARH has significant experience in UAE enforcement proceedings, including proceedings before the Dubai Courts and within the DIFC judicial framework, and we are confident that ARH is well placed to handle this important mandate.
The UAE enforcement forms one limb of a coordinated, simultaneous enforcement campaign that TSL is pursuing across four jurisdictions — namely, England & Wales, the Republic of Cyprus, the Republic of Singapore, and the United Arab Emirates. Calderwood & Harkness LLP ("C&H") has been engaged by TSL as lead enforcement counsel with overall responsibility for the coordination and strategic direction of the enforcement programme in all jurisdictions. Accordingly, ARH will take day-to-day instructions from the C&H enforcement team — principally from Hannah Brinkley (Lead Associate) and Patrick Gallagher (Working Associate), under the supervision of the undersigned as responsible partner — and will report directly to the C&H team on all material developments. This arrangement has been expressly approved by TSL's in-house General Counsel, Ms. Ioanna Christodoulou.
We should be grateful if you would confirm, at your earliest convenience and in any event by no later than 20 August 2024, that ARH is able to accept these instructions, that you have completed any necessary conflict checks and that no conflict of interest exists, and that you are in a position to act with immediate effect. Please also provide any standard engagement terms or retainer letter that ARH requires for our review and onward transmission to the client.
The balance of this letter sets out the relevant background, the detail of the Award, the enforcement targets in the UAE, and the specific instructions that we ask ARH to carry out.
2. Background — The Underlying Dispute and LCIA Arbitration
2.1 The Charter-Party Agreements
TSL entered into three separate English-law time charter-party agreements with KMH, a private limited company incorporated in the Republic of Cyprus under Registration No. HE 387421, with its registered office at 28 Themistokli Dervi Avenue, Suite 601, Nicosia 1066, Cyprus. The three charters are as follows:
(a) M/V *Aegean Fortuna (IMO 9784521) — a Supramax Bulk Carrier of 58,200 DWT, registered under the flag of the Republic of the marshall Islands. The time charter-party in respect of this vessel was executed on 15 March 2019 (the "Aegean Fortuna* Charter").
(b) M/V *Crimson Horizon (IMO 9801334) — a Handymax Bulk Carrier of 37,500 DWT, registered under the flag of the Republic of Liberia. The time charter-party in respect of this vessel was executed on 22 January 2020 (the "Crimson Horizon* Charter").
(c) M/V *Volga Spirit (IMO 9756892) — a Panamax Bulk Carrier of 76,400 DWT, registered under the flag of the Republic of Cyprus. The time charter-party in respect of this vessel was executed on 10 June 2021 (the "Volga Spirit* Charter").
Each of the three charter-party agreements is governed by English law and contains an arbitration clause referring disputes to arbitration under the rules of the London Court of International Arbitration ("LCIA"), with the seat of arbitration in London, England. Certified copies of all three charters, together with certified Arabic translations of the relevant arbitration clauses, are enclosed with this letter as described in Section 7 below.
2.2 KMH's Repudiatory Breaches
Beginning in the middle of 2022, KMH engaged in a course of conduct amounting to repudiatory breaches of all three charter-party agreements. In summary, the breaches were as follows:
(a) Wrongful early redelivery of M/V *Aegean Fortuna*: KMH wrongfully and without contractual justification redelivered the M/V Aegean Fortuna to TSL on 18 June 2022, approximately fourteen (14) months before the earliest redelivery date permitted under the Aegean Fortuna Charter. TSL was thereby deprived of the benefit of the charter-hire for the unexpired term and suffered significant market-differential losses, the dry-bulk market having substantially softened by the date of early redelivery.
(b) Failure to pay hire on M/V *Crimson Horizon*: KMH ceased making hire payments due under the Crimson Horizon Charter with effect from 1 July 2022. As of the date on which TSL exercised its contractual right to withdraw the vessel on 15 September 2022, the accumulated hire arrears stood at approximately £4,280,000. KMH's failure to pay hire constituted a clear repudiatory breach of the charter.
(c) Fabricated off-hire deductions on M/V *Volga Spirit*: Over a period of several months in 2022, KMH purported to make off-hire deductions from the hire payable under the Volga Spirit Charter in the aggregate amount of approximately £2,740,000. These deductions were based on fabricated or grossly exaggerated claims that the vessel was off-hire due to mechanical deficiencies and were not supported by the vessel's operational records. The Tribunal found these deductions to be entirely without merit and amounting to a dishonest scheme by KMH to reduce its chartering expenditure.
2.3 The LCIA Arbitration
TSL filed its Request for Arbitration with the LCIA on 14 November 2022 (LCIA Case Reference No. 224718). The arbitral tribunal (the "Tribunal") was constituted on 8 February 2023, comprising the following members:
• Presiding Arbitrator: Sir Malcolm Fenton-Clarke
• Co-Arbitrator (Claimant-nominated): Professor Athena Drakopoulos
• Co-Arbitrator (Respondent-nominated): Dr. Henrik Dalmqvist
• Tribunal Secretary: Ms. Fiona Beckett
The arbitration proceeded through a full cycle of written submissions, disclosure, witness statements, and expert evidence. The evidentiary hearing took place over ten hearing days from 11 to 22 September 2023 at the International Dispute Resolution Centre ("IDRC") in London.
KMH was represented throughout the entirety of the arbitral proceedings by Harkness Whitford & Co. (SRA No. 614823), of 12 Fetter Lane, London EC4A 1JP. The partner team acting for KMH comprised Richard Harkness (Senior Partner), Catherine Whitford (Partner), and James Thornbury (Associate). KMH participated fully in the proceedings, filed substantial written submissions and evidence, cross-examined TSL's witnesses and experts at the hearing, and made extensive oral closing submissions. There is accordingly no basis whatsoever for any suggestion that KMH was denied an opportunity to present its case or was not given proper notice of the proceedings.
3. The LCIA Award
3.1 Issuance and Operative Provisions
The Tribunal issued its Final Award on 28 June 2024. The Award is a final, binding, and enforceable award within the meaning of the LCIA Rules (2020), the English Arbitration Act 1996, and the New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards (1958). The Award was rendered unanimously by all three members of the Tribunal. A certified copy of the Award, together with a certified Arabic translation, is enclosed herewith.
3.2 Amounts Awarded
The Award provides for the following sums payable by KMH to TSL:
At the prevailing exchange rate as of the date of the Award (£1 = USD $1.2441, as of 28 June 2024), the total award amount is equivalent to approximately USD $120,000,000.
3.3 Costs. The Tribunal allocated costs 85% to KMH as the unsuccessful respondent. The costs component of the Award is as follows:
3.4 Grand Total and Post-Award Interest
The grand total payable by KMH to TSL under the Award (inclusive of all heads of damages, pre-award interest, and costs) is £108,600,000.
The Award further provides for post-award interest at the rate of 5.25% per annum simple on all unpaid sums from 29 June 2024 until the date of full payment. Post-award interest continues to accrue and should be included in the enforcement application.
3.5 Non-Payment. As of the date of this letter, KMH has failed to make any payment whatsoever in satisfaction of the Award, whether in respect of the substantive award amounts, the costs, or any part thereof. KMH has not communicated any intention to comply with the Award voluntarily. To the contrary, as described below, there is strong evidence that KMH is actively seeking to restructure its corporate holdings and dissipate its assets in order to frustrate enforcement.
4. KMH's Corporate Structure and UAE Assets — Target for Enforcement
4.1 KMH Group Structure Overview
KMH is beneficially owned and controlled by the Volkov family, principally by Andrei Volkov, who is the ultimate beneficial owner ("UBO") and the de facto director of KMH and its group companies, and by his son, Sergei Volkov, who holds a formal directorship of KMH and several group entities. The Volkov family's ownership of KMH is routed through a series of British Virgin Islands and Cypriot holding structures.
According to the preliminary intelligence gathered by our forensic accountants (as described further below), the KMH group has an estimated pre-dispute net asset value of approximately USD $280 million, comprising principally a fleet of approximately eighteen (18) dry-bulk carriers held through various single-purpose vehicle ("SPV") subsidiaries. The key officers of the KMH group, in addition to the Volkov family members, include:
• Marina Kazakova — Chief Financial Officer
• Alexei Demidov — Director of Fleet Operations
The principal intermediate holding company through which the Volkov family holds its interest in the operating entities is Oceangate Ventures Ltd., a company incorporated in the Republic of Cyprus under Registration No. HE 401293, with its registered address at 28 Themistokli Dervi Avenue, Suite 604, Nicosia 1066, Cyprus. The primary fleet SPV is Dnepr Shipholding Inc., a company incorporated in the British Virgin Islands under Company No. 2014876, with its registered office c/o Vantage Corporate Services Ltd., Road Town, Tortola, BVI. Dnepr Shipholding Inc. is believed to hold registered title to a number of the vessels in the KMH fleet, including the M/V Volga Spirit.
4.2 Korinthian DMCC — The UAE Target Entity
The primary target for enforcement in the UAE is Korinthian DMCC, a free zone company incorporated under the laws of the Dubai Multi Commodities Centre ("DMCC") in Dubai, UAE. The key details of this entity are as follows:
• Full legal name: Korinthian DMCC
• Entity type: DMCC free zone company (limited liability company)
• Registered address: Unit 3407, Almas Tower, Jumeirah Lakes Towers ("JLT"), Dubai, United Arab Emirates
• Function within KMH group: Korinthian DMCC acts as the KMH group's regional operational and commercial hub for its chartering and ship-management activities in the Arabian Gulf region. It holds operational funds, collects trade receivables from sub-charterers and freight payers in the region, and manages the commercial aspects of KMH's dry-bulk trading operations in the Middle East.
Critically, based on preliminary intelligence received from Hartwell Pemberton LLP (forensic accountants, 25 Old Broad Street, London EC2N 1HN; lead partner Rebecca Saunders; director Mark Huxley), Korinthian DMCC maintains significant bank accounts at Emirates Gulf Commercial Bank PJSC ("EGCB"), Dubai branch, located at Gate Village 3, DIFC, Dubai. Hartwell Pemberton's preliminary asset tracing report, dated 15 August 2024 (a copy of which is enclosed), indicates that Korinthian DMCC holds substantial receivables from a number of sub-charterers in the region, and that its EGCB accounts receive regular incoming payments in respect of charter-hire and freight. While we are not yet in a position to confirm the precise balance of the EGCB accounts, the available intelligence suggests that the funds held are material and that these accounts represent a significant and realizable enforcement target.
We draw your attention to the fact that Korinthian DMCC is, on our analysis, a subsidiary or alter ego of KMH, and that the Award should be enforceable against its assets on the basis that it is part of the same corporate group and is used as a vehicle for holding and managing KMH's assets and revenues. We will provide ARH with a full memorandum of law on this point, together with the supporting corporate intelligence and documentation, to assist in establishing the corporate link before the Dubai Court.
4.3 M/V *Volga Spirit* — Potential Additional UAE-Connected Asset
We also wish to bring to ARH's attention the M/V Volga Spirit (IMO 9756892, Panamax Bulk Carrier, 76,400 DWT, Cyprus flag), which is owned by Dnepr Shipholding Inc. (BVI), a KMH group entity. This vessel is one of the three vessels that was the subject of the underlying chartering dispute. Vessel tracking intelligence indicates that the M/V Volga Spirit has been trading in the Arabian Gulf in recent weeks, and the most recent intelligence suggests that it may call at UAE ports, including the Port of Fujairah, in the near term.
While the arrest of the M/V Volga Spirit does not form part of our immediate instructions to ARH, we note this vessel as a potential future enforcement target should it be located within UAE territorial waters. We would ask that ARH maintain readiness to act on an urgent basis — including on very short notice and potentially outside normal court hours — in the event that C&H instructs ARH to pursue an arrest application in respect of this vessel. We understand that UAE admiralty arrest procedures may provide a basis for the arrest of a vessel owned by a group entity of the award debtor, and we would welcome ARH's preliminary advice on the available legal basis for such an arrest.
5. Parallel Enforcement Proceedings in Other Jurisdictions
As noted above, the UAE enforcement forms one limb of a coordinated multi-jurisdictional enforcement campaign. It is important that ARH is aware of the status of the parallel enforcement proceedings in order to ensure consistency and to avoid any risk of conflicting positions being adopted across the various jurisdictions. The current status of proceedings in each jurisdiction is as follows:
5.1 England & Wales
TSL filed an application to enforce the Award as a judgment of the English High Court under Section 66 of the Arbitration Act 1996 on 15 July 2024 in the Commercial Court, Queen's Bench Division, High Court of Justice (Claim No. CL-2024-000487). Permission to enforce was granted on 2 August 2024 by Mr. Justice Ashworth.
In support of the enforcement, TSL obtained a Worldwide Freezing Order ("WFO") on an ex parte basis on 16 July 2024, freezing KMH's assets worldwide up to the value of £108,600,000. The WFO was granted by Mr. Justice Ashworth on the basis of compelling evidence of a real risk of dissipation, including evidence of post-award transfers of funds from KMH's London bank accounts, the restructuring of corporate entities within the KMH group, and the Volkov family's history of asset concealment. The WFO was continued with certain modifications at the return date hearing on 30 July 2024.
An interim third-party debt order was granted on 5 August 2024 against Meridian Trust Bank Ltd. (50 Lombard Street, London EC3V 9EA) in respect of funds held in KMH's accounts at that bank.
We note that KMH has filed an application to set aside the Award under Sections 68 and 69 of the Arbitration Act 1996, dated 19 August 2024. C&H is currently assessing this application and considers the prospects of success to be low. We do not anticipate that the set-aside application will have any material bearing on the enforcement proceedings in the UAE, but we will keep ARH informed of any significant developments.
5.2 Cyprus. An application for recognition and enforcement of the Award was filed on 9 August 2024 in the Nicosia District Court (Case No. 2247/2024) under the New York Convention and the Cyprus Arbitration Law (Cap. 4). A freezing injunction over the shares of Oceangate Ventures Ltd. and KMH's Cyprus bank accounts was granted on 12 August 2024. Local counsel in the Cyprus proceedings is:
Kyprianos Makrides & Partners Andreas Kyprianos (Senior Partner) and Nadia Makrides (Partner) 15 Grivas Digenis Avenue, Nicosia 1066, Cyprus
5.3 Singapore. An application to enforce the Award under the International Arbitration Act (Cap. 143A) was filed on 14 August 2024 in the Singapore High Court (Originating Summons No. 872/2024). The M/V *Crimson Horizon was successfully arrested in Singapore waters on 20 August 2024. In addition, garnishee proceedings have been initiated against Pinnacle Bank (Singapore) Ltd. (6 Battery Road, #20-01, Singapore 049909) in respect of accounts held by Korinthian Bulkers (Singapore) Pte. Ltd.* (80 Robinson Road, #14-02, Singapore 068898), a further KMH group entity. Local counsel in the Singapore proceedings is:
Straits Meridian LLP David Teo Wei Lin (Partner) and Priya Subramaniam (Senior Associate) 1 Raffles Place, #44-01 One Raffles Place Tower 2, Singapore 048616
5.4 Relevance of the English WFO to the UAE Proceedings
We draw to ARH's particular attention the fact that the WFO obtained in England extends worldwide and, on its terms, applies to KMH's assets in the UAE, including the assets of any entity that KMH has the power to cause to comply with the order. However, the WFO does not of itself constitute an order of the UAE courts and cannot be directly executed against UAE-situated assets without a separate local enforcement and attachment proceeding. It is for this reason that the local enforcement and precautionary attachment applications described in Section 6 below are necessary and urgent.
That said, the existence and terms of the English WFO are highly relevant to the UAE precautionary attachment application, as they constitute compelling evidence that a court of competent jurisdiction has already found a real risk of dissipation of KMH's assets. A copy of the WFO is enclosed for use in the UAE proceedings.
6. Specific Instructions — UAE Enforcement Application
We set out below the specific instructions that we ask ARH to carry out in respect of the UAE enforcement proceedings. These instructions should be read in conjunction with the broader strategic objectives described elsewhere in this letter, and ARH should at all times coordinate with C&H before taking any material procedural step.
6.1 Filing the Enforcement Application
ARH is instructed to prepare and file an application for the recognition and enforcement of LCIA Award No. 224718 in the Dubai Court of First Instance (Execution Division) as soon as practicable and, in any event, no later than the target date specified in Section 11 below.
The legal basis for the enforcement application is:
(a) UAE Federal Law No. 6 of 2018 (the "UAE Arbitration Law"), which governs the recognition and enforcement of arbitral awards in the UAE and provides a framework consistent with international best practice; and
(b) The New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards (1958), to which the United Arab Emirates has been a party since 19 November 2006. The Award is a "foreign arbitral award" within the meaning of the New York Convention, having been rendered at a seat (London, England) in the territory of a fellow Contracting State (the United Kingdom). The UAE's accession to the New York Convention was without reservation as to reciprocity or the commercial nature of the dispute, and the Convention applies to the Award as of right.
The enforcement application should seek enforcement of the full Award amount of £96,450,000, together with costs of £12,150,000, totaling £108,600,000, together with post-award interest at the rate of 5.25% per annum simple on all unpaid sums from 29 June 2024 to the date of payment. ARH should convert the sterling amounts into the equivalent in UAE Dirhams (or US Dollars, as the court may require) at the prevailing exchange rate as of the date of filing, and should seek enforcement in both the sterling amount and the local currency equivalent.
The respondent to the enforcement application should be identified as:
Korinthian Maritime Holdings Ltd. Registration No. HE 387421 28 Themistokli Dervi Avenue, Suite 601 Nicosia 1066, Cyprus
In addition, Korinthian DMCC (Unit 3407, Almas Tower, JLT, Dubai, UAE) should be identified as an entity whose assets are subject to execution as a subsidiary and/or alter ego of KMH. ARH should present such arguments as are available under UAE law to establish that the corporate veil between KMH and Korinthian DMCC should be pierced, or alternatively that Korinthian DMCC's assets are properly subject to execution in satisfaction of the Award on the basis that they are in substance the assets of KMH. C&H will provide ARH with a detailed memorandum addressing the corporate link, including the relevant corporate registry documents, the beneficial ownership chain, and the factual evidence of Korinthian DMCC's role as a conduit for KMH's funds.
6.2 Precautionary Attachment Application
Simultaneously with, or immediately following, the filing of the enforcement application, ARH is instructed to apply for a precautionary attachment (or conservatory attachment) over all accounts, funds, credit balances, and receivables of Korinthian DMCC held at Emirates Gulf Commercial Bank PJSC ("EGCB"), Dubai branch, Gate Village 3, DIFC, Dubai, UAE.
The precautionary attachment should be drafted in the broadest available terms and should cover:
(a) All sums standing to the credit of Korinthian DMCC in any and all accounts maintained at EGCB, whether denominated in AED, USD, GBP, EUR, or any other currency;
(b) All receivables due or to become due to Korinthian DMCC from third parties, including but not limited to charter-hire payments, freight payments, demurrage claims, and any other sums arising from Korinthian DMCC's chartering and commercial operations in the region; and
(c) Any other assets of Korinthian DMCC that may be identified and that fall within the scope of the court's attachment jurisdiction.
The legal basis for the precautionary attachment application is the precautionary attachment provisions under the UAE Civil Procedure Law (Federal Law No. 11 of 1992, as amended), and any other applicable provisions of UAE law permitting conservatory measures in support of enforcement proceedings.
The grounds on which the attachment is sought include the following:
(i) TSL holds a final, binding, and enforceable arbitral award for a sum in excess of £108 million, which KMH has failed to satisfy in whole or in part;
(ii) There is a real and demonstrable risk of dissipation of KMH's assets, including the assets of Korinthian DMCC. This risk is evidenced by: (a) KMH's post-award transfers of funds from its London bank accounts, which prompted the English Commercial Court to grant a Worldwide Freezing Order; (b) the ongoing restructuring of KMH's corporate entities, including changes to the directorship and shareholding of certain group companies, which are consistent with an attempt to place assets beyond the reach of creditors; and (c) KMH's complete failure to engage constructively with TSL's enforcement efforts or to make any voluntary payment in satisfaction of the Award;
(iii) The English Commercial Court has already found, on the basis of the evidence before it, that there is a real risk of dissipation sufficient to justify a worldwide freezing order — the grant of the WFO constitutes powerful and independent evidence of dissipation risk that should carry significant weight before the Dubai Court; and
(iv) In the absence of a precautionary attachment, there is a serious risk that Korinthian DMCC's EGCB accounts will be emptied or that receivables will be diverted to other accounts or entities, thereby frustrating TSL's ability to execute on the Award in the UAE.
We request that ARH seek the attachment order on an urgent, ex parte basis if this is available under UAE procedure. We understand that the UAE Civil Procedure Law may permit the court to grant precautionary attachment orders without prior notice to the respondent in cases of urgency, and we submit that the present circumstances — involving a multi-million-pound unpaid arbitral award, clear evidence of dissipation risk, and the ease with which bank balances may be transferred — warrant such an approach. ARH should advise C&H immediately if ex parte relief is not available or if there are any procedural constraints on urgency.
6.3 Translation and Legalization Requirements
C&H is aware that the UAE courts require certified Arabic translations of all foreign-language documents submitted in evidence, and that foreign public documents must be duly legalized or apostilled in accordance with the requirements of UAE law. We have made arrangements accordingly, as follows:
C&H has arranged for certified Arabic translations of the following key documents through a translation firm accredited by the UAE Ministry of Justice:
(a) LCIA Award No. 224718 (Final Award, dated 28 June 2024);
(b) The LCIA arbitration clauses contained in each of the three charter-party agreements; and
(c) The certificate from the LCIA Registrar confirming the authenticity of the Award and the proper constitution of the Tribunal.
Legalization of these documents is being obtained through the UK Foreign, Commonwealth and Development Office ("FCDO") apostille process, followed by authentication by the Embassy of the United Arab Emirates in London. We anticipate that the legalized and apostilled originals will be available for courier delivery to ARH no later than 21 August 2024, in advance of the target filing date.
We would ask ARH to advise promptly if any additional translations, legalization steps, notarization requirements, or local procedural requirements are needed for filing in the Dubai Court of First Instance. In particular, please advise whether:
• The Dubai Court requires the full text of the charter-party agreements (as opposed to the arbitration clauses alone) to be translated and legalized;
• Any additional certificates, declarations, or attestations are required from C&H, from TSL, or from the LCIA;
• There are any specific requirements as to the form or presentation of the Arabic translations (e.g., notarization by a UAE-accredited notary public); and
• Any filing fees, court deposits, or guarantees are required, and if so, the anticipated amounts.
7. Enclosed Documents
The following documents are enclosed with this letter, transmitted by secure courier and by encrypted electronic transmission (via C&H's secure file-sharing platform, access credentials for which will be provided to ARH separately):
1. Certified copy of LCIA Award No. 224718 (Final Award, dated 28 June 2024) — original English version, certified by the LCIA Registrar.
2. Certified Arabic translation of the Award — prepared by a certified translation firm accredited by the UAE Ministry of Justice.
3. Certified copies of the three charter-party agreements:
(a) M/V Aegean Fortuna Time Charter-Party, dated 15 March 2019; (b) M/V Crimson Horizon Time Charter-Party, dated 22 January 2020; (c) M/V Volga Spirit Time Charter-Party, dated 10 June 2021;
each containing the LCIA arbitration clause — original English versions.
4. Certified Arabic translations of the arbitration clauses contained in each of the three charter-party agreements.
5. Certificate from the LCIA Registrar confirming the authenticity of the Award, the proper constitution of the Tribunal, and the regularity of the arbitral proceedings.
6. Certified Arabic translation of the LCIA Registrar's certificate.
7. Copy of the Worldwide Freezing Order granted by Mr. Justice Ashworth on 16 July 2024 (Claim No. CL-2024-000487), as continued with modifications on 30 July 2024 — to be used as evidence of dissipation risk in support of the precautionary attachment application.
8. Hartwell Pemberton LLP preliminary asset tracing report, dated 15 August 2024 — identifying Korinthian DMCC's accounts at EGCB and trade receivables. This report is marked strictly confidential and is subject to litigation privilege. It should be used for the purposes of the court application as appropriate but should not be disclosed more widely without the prior consent of C&H.
9. Corporate registry extracts for:
(a) Korinthian Maritime Holdings Ltd. (Cyprus Company Registry, Registration No. HE 387421); and (b) Korinthian DMCC (DMCC corporate registry, Dubai, UAE).
10. Power of attorney / authority to act — To be confirmed. ARH is requested to advise on the form of power of attorney or authority to act required by the Dubai Court of First Instance for the filing of the enforcement application and the precautionary attachment application. C&H will arrange for the necessary power of attorney to be executed by TSL and legalized as required, but we will need ARH's guidance on the form, content, and any local requirements.
Please confirm receipt of all of the above documents upon delivery.
8. Anticipated Defenses by KMH
C&H anticipates that KMH, potentially through local UAE counsel, may seek to oppose both the enforcement application and the precautionary attachment application. While we are confident that the Award is enforceable in the UAE and that there is no meritorious basis for refusal, ARH should be prepared for the following potential lines of defense:
8.1 New York Convention Article V Defenses
Under Article V of the New York Convention, the grounds on which recognition and enforcement of a foreign arbitral award may be refused are limited and exhaustive. The likely grounds that KMH may seek to invoke include the following:
(a) Procedural objections (Article V(1)(b) — improper notice / inability to present case): KMH may argue that it was not given proper notice of the arbitral proceedings or was otherwise unable to present its case. This argument is entirely without merit. As set out in Section 2.3 above, KMH was fully represented throughout the LCIA arbitration by experienced English solicitors (Harkness Whitford & Co.) and participated actively in all phases of the proceedings, including a ten-day evidentiary hearing at which KMH's counsel cross-examined TSL's witnesses and presented KMH's own evidence and submissions.
(b) Public policy (Article V(2)(b)): KMH may seek to invoke the public policy exception to enforcement. There is, however, no credible public policy basis on which to refuse enforcement of a London-seated LCIA award arising from a purely commercial shipping dispute between sophisticated commercial parties. The Award was rendered by a properly constituted tribunal of eminent arbitrators, following a full and fair hearing conducted in accordance with the LCIA Rules, and the UAE courts have consistently recognized that the public policy exception under the New York Convention is to be construed narrowly and applied only in exceptional circumstances.
(c) Scope of the arbitration agreement (Article V(1)(c)): KMH may argue that certain heads of damages awarded by the Tribunal fell outside the scope of the arbitration agreement. Again, this argument lacks merit; the LCIA arbitration clauses in the three charters were broadly drafted and encompassed all disputes arising out of or in connection with the charters.
8.2 Separate Legal Entity Defense
Perhaps the most significant defense that KMH is likely to raise in the UAE proceedings is an argument that Korinthian DMCC is a separate legal entity that is not bound by the Award and whose assets cannot be attached or executed upon in satisfaction of KMH's liabilities. ARH should be prepared to counter this argument by establishing the corporate link between KMH and Korinthian DMCC, including by demonstrating that:
• Korinthian DMCC is a wholly owned subsidiary (directly or indirectly) of KMH, controlled by the same beneficial owners (the Volkov family);
• Korinthian DMCC functions as KMH's operational and financial conduit in the Arabian Gulf, receiving and holding funds that are in substance the assets and revenues of KMH;
• The corporate structure of the KMH group has been deliberately designed to obscure the true ownership and control of the group's assets and to hinder the enforcement of claims against KMH; and
• On a proper analysis, the corporate veil between KMH and Korinthian DMCC should be pierced, or alternatively that Korinthian DMCC's assets are properly subject to execution in satisfaction of the Award.
C&H will provide ARH with a full memorandum on this issue, including the relevant corporate intelligence, beneficial ownership documentation, and a comparative analysis of the veil-piercing principles applicable under UAE law. We would also welcome ARH's preliminary advice on the approach of the UAE courts to corporate veil-piercing in the enforcement context and the likelihood of success on this point.
8.3 UAE-Specific Defenses
ARH should further advise on any UAE-specific procedural or substantive defenses that may be available to KMH under UAE law, including but not limited to:
• Any requirements under UAE law as to the finality or enforceability of the award (e.g., whether the pendency of the English set-aside proceedings could constitute grounds for adjourning or refusing enforcement);
• Any procedural objections relating to the form or legalization of the documents submitted in support of the enforcement application;
• Any requirements under DMCC free zone regulations that may affect the attachment of Korinthian DMCC's assets; and
• The expected timeline for the court's consideration of the enforcement application and any opposition, including typical adjournment practices and the availability of expedited procedures.
9. Reporting and Coordination
The effective coordination of the UAE enforcement with the parallel proceedings in England & Wales, Cyprus, and Singapore is of paramount importance to the success of the overall enforcement campaign. Accordingly, ARH is requested to observe the following reporting and coordination protocols:
(a) Acceptance of Instructions and Engagement Terms: ARH is requested to confirm acceptance of these instructions and to provide any standard engagement terms, retainer letter, or terms of business that ARH requires. Please confirm that no conflict of interest exists.
(b) Timeline: ARH is requested to confirm the estimated timeline for: (i) filing the enforcement application; (ii) filing the precautionary attachment application; (iii) obtaining the precautionary attachment order; and (iv) obtaining a final enforcement order.
(c) Fee Estimate: ARH is requested to provide a detailed fee estimate for the enforcement proceedings, including estimated court fees, translation costs, and any other disbursements. C&H notes that the current estimated budget allocation for ARH's fees in connection with the UAE enforcement is AED 620,000 (approximately GBP £135,000 at current exchange rates). Please confirm whether this budget is adequate, and if not, please provide a revised estimate with a breakdown of anticipated costs by phase of work.
(d) Power of Attorney: ARH is requested to advise on the form of power of attorney or authority to act required by the Dubai Court of First Instance, and to provide a template or draft for C&H's review. We will arrange for the power of attorney to be executed by TSL and legalized as required.
(e) Reporting: ARH is requested to report to C&H (attention: Hannah Brinkley and Patrick Gallagher, with copies to Samuel Eklund) on all material developments promptly as they arise, and to provide formal written status updates at least on a bi-weekly basis (i.e., every two weeks). Status updates should include a summary of work undertaken, a description of any pending deadlines or upcoming hearing dates, a report on any contact with the opposing side, and an updated assessment of the enforcement prospects.
(f) Coordination: ARH must coordinate with C&H before taking any material procedural step in the UAE proceedings, including but not limited to: the filing of any application or pleading; the making of any concession or offer to the opposing side; the acceptance of any adjournment; and the taking of any enforcement or execution step. This requirement applies to all communications with KMH's UAE counsel and to any substantive engagement with the court.
(g) Copies of Correspondence and Filings: ARH is requested to copy C&H on all substantive correspondence, court filings, court orders, and judicial communications in the UAE proceedings. Where documents are in Arabic, ARH should provide an English-language summary or translation for C&H's records.
C&H's contact details for day-to-day instructions are as follows:
Hannah Brinkley — Lead Associate
Email: h.brinkley@calderwoodharkness.com
Direct Line: +44 (0)20 7496 8147 Mobile: +44 (0)7700 944 218
Patrick Gallagher — Working Associate
Email: p.gallagher@calderwoodharkness.com
Direct Line: +44 (0)20 7496 8263 Mobile: +44 (0)7700 961 553
Samuel Eklund — Responsible Partner
Email: s.eklund@calderwoodharkness.com
Direct Line: +44 (0)20 7496 8004 Mobile: +44 (0)7770 832 140
Postal Address: Calderwood & Harkness LLP 45 Moorgate London EC2R 6AR United Kingdom
10. Client Information
For the avoidance of doubt, the client for billing and engagement purposes is Thalassa Shipping & Logistics SA. The relevant client contact details are as follows:
In-house General Counsel: Ms. Ioanna Christodoulou
Email: i.christodoulou@thalassashipping.gr
Direct Line: +30 210 429 7800
Chief Financial Officer: Ms. Elena Stavridis
Email: e.stavridis@thalassashipping.gr
Direct Line: +30 210 429 7815
Client Principal Address: Thalassa Shipping & Logistics SA 14 Akti Miaouli, 4th Floor Piraeus 185 35 Greece
TSL's primary operating bank, for the receipt of any enforcement proceeds recovered in the UAE proceedings, is:
Ionian National Bank SA 22 Stadiou Street Athens 105 64, Greece
Wire transfer details for the receipt of funds will follow under separate cover. In the event that any enforcement proceeds are recovered in the UAE, ARH should not release any funds without the prior written authorization of C&H and should hold all recovered sums in ARH's client account pending instructions.
All invoices, fee notes, and engagement correspondence from ARH should be directed to C&H at the address and email coordinates set out above. C&H will coordinate the review and approval of all invoices with the client.
11. Urgency and Next Steps
We wish to emphasize that this matter is urgent. There is an ongoing and serious risk of further dissipation of KMH's assets in the UAE, and each day that passes without a precautionary attachment in place increases the likelihood that Korinthian DMCC's EGCB accounts will be depleted or that receivables will be diverted beyond the reach of TSL's enforcement efforts. The evidence of dissipation, which was sufficient to persuade the English Commercial Court to grant a worldwide freezing order, applies with equal force to the UAE-situated assets.
Accordingly, ARH is requested to take the following steps as a matter of priority:
1. Confirmation of receipt and acceptance: Please confirm receipt of this letter and the enclosed documents, and confirm that ARH is able to accept these instructions and act with immediate effect, by no later than 20 August 2024.
2. Filing of enforcement and attachment applications: ARH is requested to file the enforcement application and the precautionary attachment application at the earliest practicable opportunity, and in any event to aim for filing by no later than 22 August 2024. If this target date is not achievable for any reason, please advise immediately so that C&H can adjust the enforcement timetable accordingly.
3. Strategy call: C&H would welcome a telephone conference call with Tariq Al-Rashid and Leila Hatem (or such other members of the ARH team as will be working on this matter) at ARH's earliest convenience to discuss the procedural strategy, timing, and any preliminary issues that ARH has identified. Please propose a time for this call, ideally on 19 or 20 August 2024.
4. Power of attorney: Please advise on the form and content of the power of attorney required by the Dubai Court by no later than 20 August 2024, so that C&H can arrange for its execution and legalization without delay.
12. Closing
We are grateful for ARH's willingness to assist on this important matter and are confident that ARH's recognized expertise in UAE enforcement proceedings, DMCC-related litigation, and DIFC practice will be of great value to TSL's enforcement campaign. The successful enforcement of the Award in the UAE represents a critical element of TSL's multi-jurisdictional strategy, and we attach the highest importance to the prompt and effective execution of these instructions.
We very much look forward to working with you and your colleagues at ARH on this matter and to a productive and collaborative professional relationship. Please do not hesitate to contact the undersigned or any member of the C&H enforcement team at any time should you have any questions or require any additional information.
We thank you in advance for your prompt attention to this matter.
Yours faithfully,
CALDERWOOD & HARKNESS LLP
By: ________
Samuel Eklund Partner, Litigation Calderwood & Harkness LLP 45 Moorgate, London EC2R 6AR United Kingdom
Direct Line: +44 (0)20 7496 8004
Email: s.eklund@calderwoodharkness.com
Enclosures: As listed in Section 7 above (Items 1–10)
cc (by email):
Ioanna Christodoulou, General Counsel, Thalassa Shipping & Logistics SA — i.christodoulou@thalassashipping.gr
Hannah Brinkley, Lead Associate, Calderwood & Harkness LLP — h.brinkley@calderwoodharkness.com
Patrick Gallagher, Working Associate, Calderwood & Harkness LLP — p.gallagher@calderwoodharkness.com
PRIVILEGED AND CONFIDENTIAL — ATTORNEY-CLIENT COMMUNICATION This letter and its enclosures are privileged and confidential and are intended solely for the use of the named addressee. If you have received this letter in error, please notify the sender immediately and destroy all copies. Unauthorized use, disclosure, or distribution is strictly prohibited.
Component | Amount (GBP)
Damages for wrongful early redelivery of M/V Aegean Fortuna | £42,300,000
Outstanding hire and damages for M/V Crimson Horizon | £28,150,000
Restitution of fabricated off-hire deductions for M/V Volga Spirit | £2,740,000
Loss of profit / market differential damages (across all three charters) | £16,480,000
Pre-award interest (5.25% p.a. simple, blended from various breach dates to 28 June 2024) | £6,780,000
Total Award Amount | £96,450,000
Component | Amount (GBP)
LCIA administrative costs and Tribunal fees | £3,240,000
TSL's legal costs (solicitors and counsel) | £8,910,000
Total Costs | £12,150,000

PRIVILEGED AND CONFIDENTIAL — ATTORNEY-CLIENT COMMUNICATION

CALDERWOOD & HARKNESS LLP

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