Contract analysis

I. Introduction and Purpose This memorandum establishes a recommended post-closing sanctions monitoring protocol for Dunmore Energy Holdings Ltd. ("DEH" or "Dunmore") and its subsidiaries following the closing, on the date hereof, of the $850,000,000 aggregate principal amount of 9.375% Senior Secured Notes due 2032 (the "Notes"). The protocol set forth herein is designed to provide Dunmore's legal department and sen

II. Summary of Sanctions-Related Contractual Obligations The sanctions-related obligations arising from the Notes offering are contained in several interrelated transaction documents. This Section provides a summary of the key provisions for ease of reference by the compliance team. Full excerpted text of the relevant provisions is set forth in Appendix E to this memorandum. The compliance team should review the exce

Article V of the Purchase Agreement contains representations and warranties made by DEH, DUFC, and the Guarantors to the Initial Purchasers — Ridgeline Capital Markets LLC, Clarion Securities Inc., and Pinnacle Partners LLC — regarding, among other things, sanctions compliance. These representations and warranties were made as of both the pricing date (May 12, 2025) and the closing date (May 15, 2025). The sanctions

III. Scope of Monitoring Obligations This Section defines the universe of entities, individuals, counterparties, sanctions lists, and sanctioned countries and territories that are subject to the monitoring protocol. The scope is designed to be comprehensive, covering all persons and entities whose sanctions status is relevant to Dunmore's compliance obligations under the transaction documents and applicable law. A. E

1. Dunmore Group Entities All Issuer and Guarantor entities under the Indenture, as well as any other subsidiaries or affiliates of DEH that are involved in operations, financing, or trading activities, should be screened quarterly. As of the closing date, the Dunmore group entities subject to screening are: (a) Dunmore Energy Holdings Ltd. — the Issuer; incorporated in the Cayman Islands; the parent holding company

2. Directors, Officers, and Key Personnel All directors, officers, and senior management of each Dunmore group entity listed above should be screened quarterly. As of the closing date, the individuals subject to screening include, but are not limited to: (a) Marcus Ellingham — Chief Executive Officer, DEH (b) Deepa Rajaram — Chief Financial Officer, DEH (c) Alistair Forde — General Counsel, DEH (d) Lady Constance Har

3. Equity Holders The beneficial owners of equity interests in DEH should be screened quarterly. As of the closing date, the principal equity holders are: (a) Harborview Capital Partners Fund VI, L.P. — holding approximately 62.4% of the equity of DEH. Key individuals associated with Harborview who should be screened include Elaine Prescott, Managing Director, and David Stein, Partner. (b) Solstice Infrastructure Fun

4. Material Counterparties — Nigeria Given the heightened sanctions risk associated with Dunmore's Nigerian operations, all material counterparties in Nigeria should be subject to rigorous screening. The following categories of Nigerian counterparties should be included: (a) Nigerian National Petroleum Company (NNPC) — NNPC holds back-in rights in both OML 47 and OML 63. As a Nigerian state-owned enterprise, NNPC is

5. Material Counterparties — Senegal The following categories of Senegalese counterparties should be included in the screening scope: (a) Cayar Offshore Block joint venture partners — All entities holding participating interests in the Cayar Offshore Block, and, to the extent reasonably available, their beneficial owners and senior officers. (b) Senegalese government counterparties — The Ministère de l'Énergie and an

6. Other Material Counterparties (a) Gulf of Mexico counterparties — Counterparties to Dunmore Gulf Operations LLC in connection with the Green Canyon and Garden Banks deepwater leases. While these counterparties present lower sanctions risk given the U.S.-based nature of the operations, they should be included in the quarterly screening scope for completeness and to ensure comprehensive compliance with the Indenture

1. U.S. Lists (a) OFAC Specially Designated Nationals and blocked Persons List (SDN List) — The primary U.S. sanctions list, maintained by OFAC, identifying individuals and entities whose property and interests in property are blocked and with whom U.S. persons are generally prohibited from dealing. (b) OFAC Sectoral Sanctions Identifications List (SSI List) — A list of persons operating in identified sectors of the

2. EU Lists (a) EU Consolidated Sanctions List — The consolidated list of persons, entities, and groups subject to EU financial sanctions, maintained by the European Commission and updated pursuant to Council Regulations implementing Common Foreign and Security Policy decisions.

3. UK Lists (a) UK Office of Financial Sanctions Implementation (OFSI) Consolidated List — The consolidated list of asset freeze targets designated under UK sanctions legislation, maintained by OFSI within HM Treasury.

4. UN Lists (a) United Nations Security Council Consolidated Sanctions List — The consolidated list of individuals and entities subject to measures imposed by United Nations Security Council Sanctions Committees, including travel bans, asset freezes, and arms embargoes.

5. Other Lists as Applicable (a) Any additional sanctions lists or restricted party lists required by Nigerian regulatory authorities, including any lists maintained by the Central Bank of Nigeria, the Nigerian Financial intelligence Unit, or other relevant agencies. (b) Any additional sanctions lists or restricted party lists required by Senegalese regulatory authorities, including any lists maintained by the Banque

IV. Recommended Quarterly Screening Procedures A. Screening Frequency and Timing Quarterly Screening. A full screening of all persons and entities listed in Section III.A above against all sanctions lists and databases identified in Section III.B above should be conducted within the first fifteen (15) business days of each calendar quarter. Based on a standard business calendar, this means that each quarterly screeni

V. Nigeria-Specific Monitoring Considerations A. OML 47 and OML 63 — Niger Delta Operations Dunmore Nigeria E&P Ltd. is the operator of two significant oil mining leases in the Niger Delta region of Nigeria: • OML 47: Proved reserves of 142.6 million barrels of oil equivalent (MMboe) with a PV-10 value of $2,840,000,000 as of December 31, 2024, as estimated by Duval Howard & Partners, Dunmore's independent reserve en

VI. Senegal-Specific Monitoring Considerations A. Cayar Offshore Block Dunmore Senegal S.A. operates the Cayar Offshore Block, which holds proved reserves of 64.1 MMboe with a PV-10 value of $1,190,000,000 as of December 31, 2024, as estimated by Duval Howard & Partners. The Cayar Offshore Block is a significant growth asset for the Dunmore group, and the Phase II development program currently in planning represents

VII. Gulf of Mexico and Domestic Operations Dunmore Gulf Operations LLC operates deepwater leases in the Green Canyon and Garden Banks areas of the Gulf of Mexico, with proved reserves of 51.8 MMboe and a PV-10 value of $1,050,000,000 as of December 31, 2024. Dunmore Renewables LLC owns and operates a 220 MW solar portfolio in West Texas. These U.S.-based operations present a significantly lower sanctions compliance

VIII. Trading Operations — Dunmore Trading Ltd. Dunmore Trading Ltd., incorporated in England & Wales, serves as the offtake and trading arm of the Dunmore group. Dunmore Trading engages with a broad range of international counterparties for the sale and purchase of hydrocarbons, including crude oil, refined products, and natural gas. The international nature of Dunmore Trading's business exposes it to a diverse set