Summary

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PROPOSED SETTLEMENT

To bring closure to this dispute, Lone Star proposes the following:

In regard to the KEB sale. Lone Star would accept $400 million, plus interest. This is the absolute lowest amount the ICSID tribunal could award Lone Star, being the lowest conceptual amount under Lone Star's alternative claim, which focuses only on the final sale of KEB to Hana in 2012. In doing so Lone Star would forego its much larger claim ($1.7 billion) in relation to the aborted sale of KEN to HSBC in 2008, as well as the larger amount claimed in relation to the sale to Hann. Interest should be paid from 2012 (the time of the KEB sale to Fiona), at the statutory rate for general civil claims (5% per annum). Thus, the total amount to be paid in respect of the sale of KEB would be approximately $620 million (calculated through December 2020).

In regard to taxes, Lone Star would accept simply the refund of the final remaining case, in which the Supreme Court has ruled in favor of Lone Star. in the amount of approximately S150 million, plus statutory interest from the time the taxes were imposed (2012). totaling approximately $250 million (calculated through December 2020).

Thus the total amount to be paid in settlement of all claims is approximately $870 million. ...