Contract analysis

1. INTRODUCTION AND PURPOSE OF THIS NOTICE 1.1. Calderwood & Harkness LLP ("Calderwood & Harkness") acts on behalf of Dunmore Energy Holdings Ltd. ("DEH" or the "Investor"), an exempted company duly incorporated and existing under the laws of the Cayman Islands, with its registered office at 4th Floor, Harbour Place, 103 South Church Street, George Town, Grand Cayman KY1-1002, Cayman Islands, and its principal busine

2. THE INVESTOR AND THE INVESTMENT 2.1. The Investor — Dunmore Energy Holdings Ltd. 2.1.1. DEH is an exempted company incorporated under the laws of the Cayman Islands, a British Overseas Territory of the United Kingdom of Great Britain and Northern Ireland. DEH was incorporated on June 18, 2012, under registration number MC-291847. A certified copy of the Certificate of Incorporation is attached hereto as Annex A. 2

3. THE MEASURES AT ISSUE — FACTUAL BASIS OF THE DISPUTE 3.1. The Dispute arises out of a series of measures adopted by the Republic of Valderia in 2021 which, individually and cumulatively, have resulted in the complete deprivation of DEH's investment. The relevant measures are set out below in chronological order. 3.1. Background — Election of President Montalvo and "Resource Sovereignty" Agenda 3.1.1. On January 15

4. LEGAL BASIS OF THE DISPUTE — TREATY PROVISIONS VIOLATED 4.1. Applicable Treaty 4.1.1. The applicable treaty is the UK-Valderia BIT, signed on May 22, 2006, and entered into force on November 1, 2006. The Treaty was extended to the Cayman Islands by the United Kingdom's territorial extension declaration of February 14, 2007. The Treaty establishes a comprehensive framework for the promotion and reciprocal protectio

5. PRELIMINARY QUANTIFICATION OF LOSSES 5.1. While a detailed quantification of damages will be provided in due course, and in particular in the context of any arbitration proceedings, DEH's losses arising from the Respondent's measures are substantial and include, without limitation, the following categories: (a) Sunk capital expenditure of approximately USD 347 million, representing the total capital investment mad

6. COOLING-OFF PERIOD AND ATTEMPTED AMICABLE RESOLUTION 6.1. Article 8 of the UK-Valderia BIT provides that, where a dispute arises between an investor of one Contracting Party and the other Contracting Party in connection with an investment, the parties to the dispute shall first seek to resolve the dispute amicably through consultation and negotiation. The Treaty prescribes a six-month period from the date of writt

7. RESERVATION OF RIGHTS 7.1. If the Dispute is not resolved amicably within the six-month cooling-off period prescribed by Article 8 of the Treaty, DEH reserves the right to submit the Dispute to international arbitration before the International Centre for Settlement of Investment Disputes (ICSID) pursuant to Article 8 of the Treaty and the Convention on the Settlement of Investment Disputes between States and Nati

8. REQUEST FOR DOCUMENT PRESERVATION 8.1. DEH hereby formally requests that the Republic of Valderia, including all ministries, agencies, instrumentalities, and state-owned enterprises (including without limitation PetroValderia S.A. and Banco Nacional de Valderia), take immediate steps to identify, collect, and preserve all documents, records, data, and communications relating to the following subjects: (a) Concessi