Contract analysis

1. Introduction and Purpose of This Letter We write on behalf of our client, Dunmore Energy Holdings Ltd. ("DEH"), a Cayman Islands exempted company with its registered office at 4th Floor, Harbour Place, 103 South Church Street, George Town, Grand Cayman KY1-1002, Cayman Islands, and its principal business office at 27 Curzon Street, London W1J 5HT, United Kingdom. Calderwood & Harkness LLP acts as legal counsel to

2. Background: The Facility Agreement For completeness and ease of reference, we briefly summarize the key terms of the underlying financing arrangement. On March 20, 2016, DVU, as borrower, entered into a Senior Secured Project Finance Facility Agreement (the "Facility Agreement") with CCB, as sole lender, in the amount of USD 175,000,000 (one hundred seventy-five million United States dollars) (the "Facility"). DEH

3. The Expropriation Events and Event of Default The circumstances giving rise to the current standstill arrangement are well known to CCB, but we restate them here for completeness and for the purposes of this formal request. Beginning in early 2020, the Republic of Valderia undertook a series of actions that collectively constituted the unlawful expropriation of DEH's investment in the Bloque Orinoco Sur concession

4. DEH's Operational Context Prior to Expropriation In order to underscore the substantial value of the underlying assets and the strength of DEH's investment treaty claim, it is important to briefly contextualize the scale and success of DEH's operations in Valderia prior to the expropriation. DEH, through DVU, invested heavily in the development of the Bloque Orinoco Sur concession. Between 2014 and the date of the

5. Status of ICSID Arbitration Proceedings (Case No. ARB/22/11) We now turn to the status of the international arbitration proceedings that DEH has initiated in pursuit of compensation for the expropriation. 5.1 Filing and Registration On March 15, 2022, DEH filed a Request for Arbitration with the International Centre for Settlement of Investment Disputes ("ICSID"), pursuant to Article 36 of the ICSID Convention. Th

6. DEH's Claim Quantum — Basis for Confidence in Recovery A central factor in DEH's request for a continued standstill is the substantial quantum of the ICSID claim, which significantly exceeds the outstanding amount under the Facility. 6.1 Total Claim Quantum DEH's total claim quantum in the ICSID proceedings is USD 867,000,000 (eight hundred sixty-seven million United States dollars), broken down as follows: (a) Su

7. Litigation Funding and Adverse Costs Protection DEH has taken prudent steps to ensure that the prosecution of the ICSID claim is funded on a basis that does not deplete the resources available to service or repay the CCB Facility. The key elements of DEH's funding arrangements are as follows. 7.1 Third-Party Litigation Funding DEH has secured third-party litigation funding from Beaufort Litigation Capital LLP (Jon

8. Diplomatic Consultations and Prospects for Resolution As noted in Section 5.6 above, the ICSID proceedings have been dormant since June 17, 2022, pending state-to-state diplomatic consultations between the United Kingdom and the Republic of Valderia. 8.1 Status of Diplomatic Consultations These consultations are being conducted on the UK side by the Foreign, Commonwealth & Development Office and on the Valderian s

9. Equity Structure of DEH For CCB's records and credit assessment purposes, we confirm the current equity structure of DEH as follows: DEH is an exempted company incorporated under the laws of the Cayman Islands. DVU, the borrower under the Facility Agreement, is 100% owned by DEH. DEH's corporate auditors are Ashworth & Palliser LLP, with offices at 20 Moorgate, London EC2R 6DA, United Kingdom. There have been no c

10. The Extension Request On behalf of DEH, we now formally set out the terms of the proposed extension. We respectfully request that CCB agree to extend the Standstill Agreement for a further period of twelve (12) months, from the current expiry date of March 31, 2025 to March 31, 2026. The proposed terms for the extension are as follows: (a) All existing terms and conditions of the Standstill Agreement, as original

11. Periodic Reporting Commitment In recognition of CCB's legitimate interest in being kept informed of all material developments affecting the prospects of recovery, DEH proposes to provide CCB with periodic written status reports during the extension period. Specifically, DEH undertakes to provide reports at intervals of no less than every six (6) months during the extension period. Each report will cover the follo

12. Justification Summary — Why the Extension Is Warranted For CCB's convenience, we summarize the principal reasons why the requested extension of the Standstill Agreement is warranted and in the mutual interests of both parties: • Substantial claim quantum: The ICSID claim of USD 867 million far exceeds the outstanding principal on the CCB Facility of USD 112.4 million, providing substantial headroom for recovery a

13. Request for Response We respectfully request that CCB confirm its agreement to the proposed extension at the earliest convenience and, ideally, prior to December 31, 2024, in order to allow sufficient lead time before the current standstill expiry on March 31, 2025. An early indication of CCB's position would be welcomed, as it will assist DEH in planning its strategy for the ICSID dormancy review date of Decembe

14. Reservation of Rights This letter is written and delivered on a without prejudice basis to any rights that DEH, DVU, or CCB may have under the Facility Agreement, the Standstill Agreement, or otherwise at law or in equity. Nothing in this letter, nor any discussion or correspondence arising from it, shall be construed as: (a) an admission of any liability on the part of DEH or DVU; (b) a waiver by DEH or DVU of a

15. Confidentiality This letter and its contents are confidential and are subject to legal professional privilege. We respectfully request that CCB treat the information contained herein—including, without limitation, information regarding the ICSID proceedings, the Beaufort litigation funding arrangement, DEH's quantum analysis, and DEH's strategic considerations—as strictly confidential and refrain from disclosing

1. Facility Agreement dated March 20, 2016

2. Standstill Agreement dated December 22, 2021 (together with all extension amendments)

3. ICSID Request for Arbitration (Case No. ARB/22/11), filed March 15, 2022

4. Most recent Joint Dormancy Renewal Letter to ICSID, dated June 12, 2024

5. Pemberton Valuation Advisory LLC engagement letter (upon request and subject to privilege)

6. Ridgewell Subsurface Consultants Ltd. reserves certification report dated December 31, 2020 (upon request)

7. Beaufort Litigation Capital LLP funding agreement summary (upon request and subject to confidentiality obligations) Shareholder | Holding | Basis Sir Malcolm Dunmore, KBE (via Dunmore Family Trust) | 62% | Indirect Priya Nandakumar | 8% | Direct Thomas Rearden | 4% | Direct Meridian Growth Partners Fund III, L.P. | 26% | Direct Total | 100%