We note that you attribute certain information throughout your registration statement to Clarksons Research. Please provide the date of such report, and explain, if true, that you commissioned such report.

Please revise to disclose the percentage of revenues attributable to your top five customers and disclose whether any customer represented 10% or more of your revenues for the year ended December 31, 2023.

We note that BW Group Limited, owned by corporate interests associated with the Sohmen family, is currently a major shareholder. Please disclose whether you will be a “controlled company” as defined under the relevant NYSE listing rules and, if so, whether you intend to rely on the exemptions as a controlled company. If applicable, please include risk factor disclosure that discusses the effect, risks and uncertainties of being designated a controlled company, including but not limited to, the result that you may elect not to comply with certain corporate governance requirements.

We note your disclosure indicating the 192% increase in voyage charter revenue for 2022 compared to 2021 was due to stronger freight rates and bigger fleet size. Please expand your discussion and analysis to clarify the extent to which changes in revenues are attributable to changes in volumes and separately to changes in prices to comply with Item 5.A.1 of Form 20-F.

We note your disclosure here regarding certain credit facilities. Please revise to disclose the material terms of the facilities and file as an exhibit every contract that is material to you. In this regard, we also note your disclosure on page 175 relating to the agreements with BW Group Limited. Refer to Instruction 4 of Instructions as to Exhibits of Form 20-F.

Please clarify, if true, that the members of the Nomination Committee are not members of the Board of Directors but are affiliated with your major shareholder, BW Group Limited.

We note your disclosure explaining that you changed your dividend policy towards the end of 2022 and that under the new policy you intend to pay dividends ranging from 50% to 80% of net profit, adjusted for extraordinary items, where the applicable percentages will be based on a net loan-to-value measure, involving debt associated with vessels owned, leased or in pools, and vessel values.

We note your disclosure regarding the exclusive jurisdiction provision. Revise your disclosure to state whether you will have an exclusive jurisdiction provision if shareholders approve the redomiciliation to Singapore and whether the federal district courts of the United States will continue to be the exclusive forum for the resolution of any complaint asserting a cause of action arising under the Securities Act or the Exchange Act. Please ensure that the exclusive forum provision in the governing documents states this clearly. Also, please revise to include a risk factor regarding the exclusive forum provision, clearly describing any risks or other impacts on investors and addressing any uncertainty about enforceability. Please also disclose that investors cannot waive compliance with the federal securities laws and the rules and regulations thereunder. In that regard, we note that Section 22 of the Securities Act creates concurrent jurisdiction for federal and state courts over all suits brought to enforce any duty or liability created by the Securities Act or the rules and regulations thereunder.

that the Company’s constitution after the Redomiciliation, if approved by the shareholders, will contain an exclusive jurisdiction clause;

that investors cannot waive compliance with the federal securities laws and the rules and regulations thereunder; and

that Section 22 of the Securities Act creates concurrent jurisdiction for federal and state courts over all suits brought to enforce any duty or liability created by the Securities Act or the rules and regulations thereunder.