Contract analysis

I. Introductory Note and Drafting Context The risk factors set forth in Section II of this memorandum are presented as standalone draft text intended to be inserted into the Preliminary Offering Memorandum and Final Offering Memorandum under the heading "Risk Factors — Risks Related to Sanctions, Export Controls, and Anti-Corruption." These risk factors are supplemental to, and should be read together with, the other

II. Draft Risk Factor Text The following text is intended for insertion into the Offering Memorandum under the heading "Risk Factors — Risks Related to Sanctions, Export Controls, and Anti-Corruption." All defined terms used herein, unless otherwise defined, shall have the meanings set forth in the Offering Memorandum. Risk Factors — Risks Related to Sanctions, Export Controls, and Anti-Corruption Risk Factor 1: Our

III. Cross-References and Coordination Notes Internal C&H Notations — Not for Inclusion in the Offering Memorandum The following cross-references and coordination notes are provided for the information of the working group and are not intended for inclusion in the Preliminary Offering Memorandum or the Final Offering Memorandum. These notes identify related workstream documents and inter-disciplinary coordination iss

3. Barrisford Advisory Group LLC ESG Data Package. The ESG data package prepared by Barrisford Advisory Group LLC includes detailed community spend data ($14.2 million in Nigeria for FY 2024) that forms the basis for the community development expenditure disclosures in both the ESR section and Risk Factor 5. The figures should be confirmed as consistent across all sections of the Offering Memorandum. Cross-references

4. OFAC and Sanctions Compliance Memorandum (separate C&H workstream document). This memorandum provides the detailed legal analysis supporting the risk-factor disclosures contained herein. All legal conclusions reflected in the risk factors should be confirmed against the analysis in the Sanctions Compliance Memo.

5. Sanctions Screening Results Summary and Counterparty and JV Partner Sanctions Checklist. These documents, prepared by Sandoval Compliance Solutions LLC and provided to the C&H working group, contain the detailed results of the April 25, 2025 sanctions screening. The screening results should be reviewed and confirmed prior to finalization of the risk-factor language. Coordination with local counsel:

6. Abayomi Chambers (Chidinma Okafor). Nigerian local counsel has been engaged to provide advice on the Nigerian regulatory landscape, including the status and operations of NNPC and the NUPRC, the regulatory framework governing OML 47 and OML 63, and the risk of Nigerian sanctions or regulatory actions that could affect the Company's operations. The Nigerian regulatory discussion in Risk Factors 1, 2, 3, and 5 shoul

7. Theron Moss & Associates SARL (Moustapha Sy). Senegalese local counsel has been engaged to advise on the Senegalese compliance context, including the regulatory framework governing the Cayar Offshore Block production sharing contract, the role of the Ministère de l'Énergie, and applicable Senegalese AML and anti-corruption laws. The Senegalese-specific disclosures in the risk factors should be reviewed by Theron M

8. Cresswell & Greaves LLP (Fiona Halsted). UK counsel should review the UKBA-related risk-factor language in Risk Factor 5 for accuracy under English law, including the description of the UKBA offenses, the jurisdictional scope of the UKBA, and the applicability of the "adequate procedures" defense. Any comments from Cresswell & Greaves should be incorporated prior to finalization. Internal drafting coordination:

9. Indenture OFAC Covenant Drafting. These risk factors should be reviewed in parallel with the Indenture OFAC covenant drafting (see OFAC Covenant and Representation Drafting Memorandum prepared by Eric Johannsen) to ensure consistency of defined terms and scope of representations. In particular, the defined terms "Sanctions," "Sanctioned Person," "Sanctioned Country," and "Anti-Corruption Laws" as used in the Inden

IV. Cautionary Language / Forward-Looking Statement Safe Harbor The following cautionary language is intended for inclusion in the Offering Memorandum in connection with the risk factors set forth in Section II above. Certain statements contained in these risk factors constitute forward-looking statements within the meaning of Section 27A of the Securities Act of 1933, as amended, and Section 21E of the Securities Ex