Globus Maritime

According to its Annual Report filed with the SEC for fiscal year 2018: "Our charter party agreements for our vessels restrict the charterers from calling in Iran in violation of U.S. sanctions, or carrying any cargo to Iran which is subject to U.S. sanctions. However, there can be no assurance that our vessels will not, from time to time in the future on charterer's instructions, perform voyages which would require disclosure pursuant to Exchange Act Section 13(r)."

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According to its Annual Report filed with the SEC for fiscal year 2017: "In 2017, as in prior years, one or more of our vessels made a port call to Iran, and delivered or loaded grains, urea or iron ore.

• In 2017, the vessel Moon Globe made a call to the port of Bandar Imam Khomeini on February 18, 2017, discharging corn, and remained in that port during 2017 for 35 days. During this time the Moon Globe was on time charter to Nidera SPA at a gross rate of $6,150 per day.
• In 2017, the vessel River Globe made a call to the port of Bandar Abbas on January 20, 2017, loading iron ore, and remained in that port during 2017 for seven days. During this time the River Globe was on time charter to Milestone Shipping S.A. at a gross rate of $8,950 per day.
• In 2017, the vessel Sky Globe made a call to the port of Bandar Abbas on August 29, 2017, loading iron ore, and remained in that port during 2017 for 11 days. During this time the Sky Globe was on time charter to Milestone Shipping S.A. at a gross rate of $11,800 per day.
• In 2017, the vessel Sky Globe made a call to the port of Assaluyeh on September 5, 2017, loading bulk urea, and remained in that port during 2017 for six days. During this time the Sky Globe was on time charter to Olam International Limited at a gross rate of $11,500 per day. The aggregate gross revenue attributable to these 59 days that our vessels remained in Iranian ports in 2017 was approximately $476,700.

As we do not attribute profits to specific voyages under a time charter, we have not attributed any profits to the voyages which included these port calls. Our charter party agreements for our vessels restrict the charterers from calling in Iran in violation of U.S. sanctions, or carrying any cargo to Iran which is subject to U.S. sanctions. However, there can be no assurance that the four vessels referenced above or another of our vessels will not, from time to time in the future on charterer's instructions, perform voyages which would require disclosure pursuant to Exchange Act Section 13(r).

We do not believe that any of these transactions or activities are sanctionable. January 16, 2016 was “implementation day” under the Joint Comprehensive Plan of Action (“JCPOA”) among the P5+1 (China, France, Germany, Russia, the United Kingdom, and the United States), the E.U., and Iran to ensure that Iran’s nuclear program will be exclusively peaceful, and the United States and the E.U. lifted nuclear-related sanctions on Iran. All activities, transactions and dealings reported in this section occurred after the implementation date of the JCPOA. We intend to continue to charter our respective vessels to charterers and sub-charterers, including, as the case may be, Iran-related parties, who may make, or may sub-let the vessels to sub-charterers who may make, port calls to Iran, so long as the activities continue to be permissible and not sanctionable under applicable U.S. and E.U. and other applicable laws."