Contract analysis

I. EXECUTIVE SUMMARY This memorandum summarizes and evaluates the sanctions screening report dated April 25, 2025 (the "Sandoval Report"), prepared by Sandoval Compliance Solutions LLC ("Sandoval"), an independent compliance advisory firm located at 1120 Connecticut Avenue NW, Suite 600, Washington, DC 20036. The Sandoval Report was prepared under the direction and supervision of Rosa Medina, Lead Consultant, in conn

II. BACKGROUND AND CONTEXT A. The Transaction DEH, a Cayman Islands exempted company, and DUFC, a Delaware corporation and wholly-owned subsidiary of DEH, are offering $850,000,000 aggregate principal amount of 9.375% Senior Secured Notes due 2032. The Notes will be senior secured obligations of the Issuers, guaranteed on a senior secured basis by each of DEH's existing and future material restricted subsidiaries. Th

III. SCOPE OF SCREENING A. Dunmore Group Entities Screened Sandoval screened the following eight Dunmore Group entities, encompassing both Issuers and all material operating and holding company subsidiaries: Each entity was screened against all four Sanctions Lists using its full registered legal name, any known trading names or short-form names, former names (if applicable), and corporate registration numbers. B. Of

1. Marcus Ellingham — Chief Executive Officer, Dunmore Energy Holdings Ltd. (age 54; previously Chief Operating Officer of Praetorian Petroleum plc)

2. Deepa Rajaram — Chief Financial Officer, Dunmore Energy Holdings Ltd. (age 47; former Vice President of Finance at Kestrel Resources Corp.)

3. Alistair Forde — General Counsel, Dunmore Energy Holdings Ltd. (age 51)

4. Lady Constance Harrowby — Board Chair (Independent), Dunmore Energy Holdings Ltd. (former United Kingdom Secretary of State for Energy)

5. Elaine Prescott — Managing Director, Harborview Capital Partners; Board designee, Dunmore Energy Holdings Ltd.

6. David Stein — Partner, Harborview Capital Partners; Board designee, Dunmore Energy Holdings Ltd.

7. Additional directors and officers of subsidiary entities, including: the Managing Director and Finance Director of Dunmore Nigeria E&P Ltd.; the Directeur Général and Directeur Financier of Dunmore Senegal S.A.; the President and Vice President of Operations of Dunmore Gulf Operations LLC; the President of Dunmore Renewables LLC; and the directors and officers of Dunmore Midstream Holdings Inc. and Dunmore Trading

1. Harborview Capital Partners Fund VI, L.P. — Delaware limited partnership; 62.4% equity holder. Screening covered the fund entity, its general partner (Harborview Capital Partners GP VI LLC), and the principals and control persons of the general partner, including Elaine Prescott and David Stein.

2. Solstice Infrastructure Fund LP — Delaware limited partnership; 11.1% co-investor. Screening covered the fund entity, its general partner, and the identified principals and control persons.

3. Alderman Family Office LLC — Texas limited liability company; 8.2% co-investor. Screening covered the entity, its managing members, and the identified principals of the Alderman family. In total, eight (8) equity holder entities and individual principals were screened. Beneficial ownership analysis was traced through fund structures to identify any ultimate beneficial owners holding 50% or greater interests, consi

IV. METHODOLOGY A. Sandoval's Screening Process Sandoval conducted its sanctions screening using its proprietary compliance screening platform (the "Sandoval Platform"), which employs automated name-matching algorithms supplemented by manual review of all potential matches. The Sandoval Platform is designed to identify exact and near-exact matches between screened names and entries on the applicable Sanctions Lists,

V. RESULTS A. Summary Results Table The table below summarizes the results of Sandoval's sanctions screening across all categories of screened parties and all four Sanctions Lists: B. Potential Matches Reviewed and Cleared Sandoval's automated screening platform flagged a total of seven (7) potential or partial name matches across the four Sanctions Lists during the initial automated screening pass. Each flagged pote

1. Dunmore Group Entities. All eight Dunmore Group entities screened by Sandoval were cleared with no hits on any of the four Sanctions Lists. The following entity-specific observations are noted: Dunmore Energy Holdings Ltd. (Cayman Islands). No designation on any Sanctions List. No affiliation with any designated person or entity was identified through beneficial ownership analysis. Dunmore upstream Finance Corp. (

2. Officers, Directors, and Key Personnel. All sixteen (16) screened officers and directors were cleared with no hits on any of the four Sanctions Lists. Specific findings include: • Marcus Ellingham (CEO, DEH) — No matches on any Sanctions List. Sandoval verified Mr. Ellingham's biographical information, including his prior tenure as Chief Operating Officer of Praetorian Petroleum plc, and confirmed no adverse sanct

3. Equity Holders. All equity holders and their affiliated funds, general partners, and identified principals were cleared with no hits on any of the four Sanctions Lists: • Harborview Capital Partners Fund VI, L.P. — Not designated on any Sanctions List. Beneficial ownership analysis traced through the fund's general partner (Harborview Capital Partners GP VI LLC) and its principals confirmed no sanctioned persons a

4. Material Counterparties and JV Partners. All thirty-one (31) screened counterparty and joint-venture partner entities and individuals were cleared with no hits on any of the four Sanctions Lists. Specific findings by sub-category include: Nigerian National Petroleum Company. NNPC is not designated on any of the four Sanctions Lists. Individual NNPC officials who interact with Dunmore Nigeria in connection with OML

5. Transaction Participants. All twenty-three (23) screened transaction participant entities and individuals were cleared with no hits on any of the four Sanctions Lists. This result is consistent with expectations, given that the transaction participants are established U.S. and international financial institutions, law firms, audit firms, engineering consultancies, advisory firms, and rating agencies, each of which

VI. CALDERWOOD & HARKNESS ANALYSIS AND EVALUATION A. Adequacy of Screening Scope C&H has reviewed the scope of Sandoval's sanctions screening and has determined that it is comprehensive and appropriate for a transaction of this nature, involving operations in Nigeria and Senegal, international hydrocarbon trading activities, and a multi-jurisdictional corporate structure. The screening covered all categories of perso

VII. RECOMMENDATIONS Based on the foregoing analysis, C&H makes the following recommendations:

1. Pre-Closing Refresh. Sandoval should conduct a bring-down sanctions screening no earlier than May 13, 2025 (two business days before the expected closing date of May 15, 2025) to confirm that no new designations have been made on any of the four Sanctions Lists with respect to any previously screened party. The bring-down screening should cover all categories of screened parties identified in Section III above and

2. Representation Sign-Off. The screening results support the Dunmore Group's ability to make the sanctions representations and warranties contained in the Purchase Agreement (Section 3(nn)) and the Indenture (Section 4.25), and to execute the Side Letter — Sanctions Representations among the Issuers, Guarantors, and Initial Purchasers. C&H recommends that this memorandum and the underlying Sandoval Report be transmi

3. OM Risk Factors. No revisions to the sanctions and OFAC risk-factor disclosure in the Offering Memorandum are required based on the screening results. The existing risk factors appropriately address the heightened sanctions environment in Nigeria and Senegal, including the involvement of NNPC as a governmental counterparty, without over-stating or under-stating the level of risk. C&H recommends that the risk-facto

4. Ongoing Monitoring. C&H recommends the implementation of a quarterly sanctions monitoring protocol following the closing of the Offering. The protocol should be administered by the Dunmore Group's in-house compliance function under the supervision of Alistair Forde, with periodic review by outside counsel. The quarterly monitoring should include re-screening of all Dunmore Group entities, officers and directors, m

5. Document Retention. The Sandoval screening report (Attachment A) and this memorandum should be retained in the closing binder for the Offering and in C&H's matter files (Matter No. 1016-00003) as part of the due diligence record supporting the 10b-5 negative assurance letter to be delivered by C&H to the Initial Purchasers at closing. Retention of these documents provides a contemporaneous record of the sanctions

VIII. ATTACHMENTS The following documents are attached hereto and incorporated by reference into this memorandum: Attachment A: Sandoval Compliance Solutions LLC — Sanctions Screening Report (dated April 25, 2025) (Rosa Medina, Lead Consultant) Attachment B: Complete List of Screened Entities and Individuals (cross-reference to Counterparty and JV Partner Sanctions Checklist) Attachment C: Sandoval Methodology Statem