Contract analysis

I. PURPOSE This memorandum documents the results of a firm-wide conflict check conducted in connection with the proposed retention of Calderwood & Harkness LLP ("C&H" or the "Firm") by Dunmore Energy Holdings Ltd. ("Dunmore" or "DEH") to represent the company and its subsidiaries in an internal investigation and defense relating to a U.S. Department of Justice ("DOJ") inquiry concerning potential violations of U.S. s

II. PROPOSED CLIENT AND AFFILIATED ENTITIES CHECKED A. Dunmore Energy Holdings Ltd. (Client) The following information was provided by the prospective client and independently verified through publicly available corporate records, commercial databases (Dunmore Enterprises, Bureau van Dijk Orbis), and the OFAC Specially Designated Nationals and blocked Persons List ("SDN List"): • Full Legal Name: Dunmore Energy Holdi

1. Dunmore Trading International Ltd. ("DTI") • Entity Type: Limited company • Jurisdiction: Dubai International Financial Centre ("DIFC") • DIFC License No.: CL-4827 • Registered Office: Level 14, Gate Building 3, DIFC, P.O. Box 506774, Dubai, UAE • President: Derek Hargrave • DTI is the entity at the center of the DOJ inquiry. The government's investigation focuses primarily on commodity trading transactions and as

2. Dunmore upstream Americas LLC ("DUA") • Entity Type: Limited liability company • Jurisdiction of Formation: Delaware • Employer Identification Number (EIN): 84-2937561 • Registered Agent: 1209 Orange Street, Wilmington, DE 19801 • Principal Office: 1200 McKinney Street, Suite 3400, Houston, TX 77010 • DUA conducts Dunmore's domestic upstream oil and gas exploration and production activities, primarily in the Permi

3. Dunmore Renewables GmbH • Entity Type: Gesellschaft mit beschränkter Haftung (GmbH) • Jurisdiction: Hamburg, Germany • Registered Office: Überseeallee 12, 20457 Hamburg, Germany • Managing Director: Tobias Engel • Dunmore Renewables GmbH operates the company's European wind and solar energy development portfolio.

4. Dunmore Exploration West Africa Ltd. ("DEWA") • Entity Type: Limited company • Jurisdiction: Lagos, Nigeria • Registered Office: 14B Kofo Abayomi Street, Victoria Island, Lagos, Nigeria • DEWA holds Dunmore's offshore exploration licenses in the Gulf of Guinea. C. Dunmore Shareholders The following shareholders of Dunmore Energy Holdings Ltd. were included in the conflict check. While the proposed engagement does

1. Greystone Capital Partners Fund IV, L.P. ("Greystone Fund IV") • Entity Type: Limited partnership • Jurisdiction of Formation: Delaware • Equity Stake in DEH: 62.5% • General Partner: Greystone Capital Management LLC (Delaware) • Managing Partner: Richard Fairbanks • Outside Counsel: Harwood & Pennington LLP (New York); lead partner Arthur Pennington III • Greystone Fund IV is the majority equity holder of Dunmore

2. Dunmore Management • Equity Stake in DEH: 22.5% • Management equity is held by Callum Renshaw (CEO), Sandra Whitfield (CFO), and other senior executives through a management equity participation plan. Specific individual holdings were not verified for purposes of this conflict check but may be requested if relevant.

3. Thornbury Infrastructure Fund II, L.P. ("Thornbury Fund II") • Entity Type: Limited partnership • Jurisdiction of Formation: Cayman Islands • Equity Stake in DEH: 15% • General Partner: Thornbury Asset Management Ltd. (London, United Kingdom) • Managing Director: Helen Cresswell • Thornbury Fund II is a minority passive investor with one board observer seat.

III. ADVERSE PARTIES, COUNTERPARTIES, AND OTHER PARTIES CHECKED In addition to the proposed client and its affiliates, the following parties were identified based on information provided by Marcus Wellbourne, publicly available court filings, OFAC designations, and press reports. All parties were run through NBICS as described in Section IV. A. U.S. Department of Justice The DOJ division and personnel handling the in

1. Petronova Trading FZE • Entity Type: Free Zone Establishment • Jurisdiction: Jebel Ali Free Zone, UAE • Registered Office: Office 1407, Al Shafar Tower, Dubai Internet City, Dubai, UAE • Managing Director: Sergei Volkov (Russian national, UAE resident) • Petronova has been identified as an intermediary in multiple flagged transactions and is alleged to serve as a front entity for Volkhov Industrial Group JSC. Petr

2. Volkhov Industrial Group JSC ("VIG") • Entity Type: Joint Stock Company • Jurisdiction: Russian Federation • Headquarters: 12 Kutuzovsky Prospekt, Moscow 121248, Russia • Chairman: Arkady Volkhov • OFAC Designations: SDN-listed on April 6, 2022, pursuant to Executive Order 14024 (Blocking property with respect to specified harmful foreign activities of the Government of the Russian Federation); prior Directive 2 d

3. Zenith Petroleum DMCC • Entity Type: DMCC company • Jurisdiction: Dubai, UAE • Registered Office: Unit 2201, Jumeirah Bay Tower X2, Cluster X, Jumeirah Lakes Towers, Dubai, UAE • Managing Director: Farhan Qureshi (Pakistani national, UAE resident) • Zenith Petroleum has been identified as a party to two flagged crude oil swap transactions involving DTI. The nature and scope of Zenith Petroleum's relationship with

4. Caspian Logistik GmbH • Entity Type: Gesellschaft mit beschränkter Haftung (GmbH) • Jurisdiction: Hamburg, Germany • Registered Office: Mönckebergstraße 22, 20095 Hamburg, Germany • Managing Director: Klaus Weidemann (German national) • Caspian Logistik facilitated oilfield equipment shipments that potentially involve export control violations under the EAR, specifically items classified under Export Control Class

1. Callum Renshaw — CEO, Dunmore Energy Holdings Ltd.

2. Derek Hargrave — President, Dunmore Trading International Ltd.

3. Natasha Sorokin — Senior Trader, Dunmore Trading International Ltd. (Russian-American dual national)

4. Omar Al-Rashidi — Head of Middle East Operations, Dunmore Trading International Ltd.

5. Yves Leclerc — Director of Logistics & Shipping, Dunmore Trading International Ltd.

6. Gerald Fisk — Chief Compliance Officer, Dunmore Energy Holdings Ltd.

7. Marcus Wellbourne — General Counsel, Dunmore Energy Holdings Ltd.

8. Sandra Whitfield — CFO, Dunmore Energy Holdings Ltd.

9. Rajesh Malhotra — Controller, Dunmore Trading International Ltd.

10. Tobias Engel — Managing Director, Dunmore Renewables GmbH

11. Priya Nayar — Identified as a potential incoming Chief Compliance Officer; checked proactively in the event she is retained by Dunmore during the pendency of this matter.

12. Sergei Volkov — Managing Director, Petronova Trading FZE

13. Arkady Volkhov — Chairman, Volkhov Industrial Group JSC

14. Klaus Weidemann — Managing Director, Caspian Logistik GmbH

15. Farhan Qureshi — Managing Director, Zenith Petroleum DMCC

16. Richard Fairbanks — Managing Partner, Greystone Capital Management LLC

17. Arthur Pennington III — Lead Partner, Harwood & Pennington LLP

18. Helen Cresswell — Managing Director, Thornbury Asset Management Ltd. F. Other Entities Checked The following entities were identified as having a relationship to the proposed engagement — either as shareholders, lenders, service providers, or other parties whose involvement in the matter could give rise to a conflict or require coordination:

1. Greystone Capital Partners Fund IV, L.P. and Greystone Capital Management LLC — Majority shareholder of Dunmore and its general partner. Checked as a potential co-client or as the holder of interests that could diverge from or conflict with Dunmore's interests as the investigation progresses, particularly if Greystone seeks to exercise governance rights, direct the investigation, or assert its own privilege claims

2. Thornbury Infrastructure Fund II, L.P. and Thornbury Asset Management Ltd. — Minority shareholder and its general partner. Checked for the same reasons as Greystone, although the risk of divergent interests is lower given Thornbury's passive minority position.

3. Harwood & Pennington LLP — Outside counsel for Greystone Capital Partners. Checked to confirm that there are no current matters in which C&H represents a party adverse to Harwood & Pennington LLP or its clients, and no prior matters that would create a duty of loyalty issue.

4. Meridian National Bank, N.A. — Primary lender to Dunmore under a $750 million senior secured revolving credit facility. Managing Director: Gregory Stanhope. Meridian's credit facility contains financial covenants, material adverse change clauses, and reporting obligations that may be triggered by the DOJ inquiry or any resulting enforcement action.

5. Crescent Commercial Bank PJSC — Trade finance bank (Dubai). Relationship Manager: Khalid Mansour. Crescent Commercial Bank served as an intermediary bank in the payment flows at issue in the DOJ inquiry. The bank's Dubai accounts processed certain of the flagged transactions.

6. Commonwealth Trust Company — Escrow agent (Wilmington, Delaware). Identified as holding certain funds in escrow pursuant to a prior acquisition transaction involving DUA.

7. Garrison Mutual Insurance Co. — Directors' and officers' ("D&O") liability insurance carrier (Hamilton, Bermuda). Claims Adjuster: Patricia Holbrook. Policy No.: GM-DO-2021-08734. The D&O policy provides $50 million in aggregate coverage with a $10 million per-claim sublimit and a $2.5 million retention.

8. Ashford & Whitmore LLP — Outside auditors of Dunmore Energy Holdings Ltd. Engagement Partner: Kenneth Ashford. The auditors may be consulted regarding internal controls over trade finance transactions and may be asked to provide work papers or testimony in the course of the investigation.

9. Ridgeline Advisory Group LLC — Forensic accounting consultant (Washington, D.C.). Anticipated retention at the direction of Calderwood & Harkness to support the internal investigation. Engagement Lead: Dr. Margaret Liu.

10. Nexagen Analytics Inc. — E-discovery vendor (New York). Anticipated retention for document collection, processing, review, and production. Project Manager: Brian Cavanaugh.

IV. CONFLICT CHECK METHODOLOGY The conflict check was conducted on April 13, 2022, using Calderwood & Harkness's New Business Intake and Conflicts System ("NBICS"). NBICS is the Firm's enterprise-wide conflicts management database, which maintains records of all current and closed client matters, adverse parties, related parties, and lateral attorney prior representations. All entity names and individual names listed

V. RESULTS OF CONFLICT CHECK A. No Direct Conflicts Identified Based on the comprehensive NBICS search and the supplemental manual reviews described in Section IV, no direct conflicts of interest have been identified that would preclude the Firm from undertaking the proposed representation of Dunmore Energy Holdings Ltd. and its subsidiaries. Specifically: • No current client relationship or active matter was identif

I. Key Dunmore Individuals — Potential Representation Issues The proposed engagement contemplates that Calderwood & Harkness will represent Dunmore Energy Holdings Ltd. and its subsidiaries as entities, not any individual director, officer, or employee in his or her personal capacity. This distinction is fundamental to the Firm's ability to manage the investigation effectively and to preserve the corporate attorney-c

VI. ETHICAL RULES CONSIDERED The conflict analysis set forth in this memorandum was conducted with reference to the following ethical rules, regulations, and policies: • Model Rules of Professional Conduct: • Rule 1.7 (Conflict of Interest — Current Clients): Analyzed in connection with the concurrent representation of Meridian National Bank, N.A. and the proposed representation of Dunmore. • Rule 1.9 (Duties to Form

VII. CONDITIONS AND RECOMMENDATIONS Based on the conflict check results and the analysis set forth in this memorandum, the Firm may proceed with the proposed representation of Dunmore Energy Holdings Ltd. and its subsidiaries, subject to the following conditions and recommendations:

1. Engagement Letter — Scope of Representation. The engagement letter must clearly and unambiguously define the client as Dunmore Energy Holdings Ltd. and its subsidiaries — specifically Dunmore Trading International Ltd., Dunmore upstream Americas LLC, Dunmore Renewables GmbH, and Dunmore Exploration West Africa Ltd. The engagement letter must expressly state that the Firm does not represent any individual officer,

2. Upjohn Warnings. Upjohn corporate warnings must be administered to all company personnel prior to the commencement of any witness interview. The warnings must make clear that (a) Calderwood & Harkness represents the company, not the individual; (b) the attorney-client privilege belongs to the company and may be waived by the company; (c) the company may elect to disclose interview content to third parties, includi

3. Ethical Wall — Meridian National Bank. A formal ethical wall must be established between the engagement team for the Dunmore matter (Matter No. 1016-00009) and the team handling the Meridian National Bank syndicated lending matter (Matter No. 1016-00009, responsible partner Lawrence Brennan). The wall should be implemented through the Firm's conflicts management system, and all affected personnel should receive wr

4. Common Interest Agreement. A common interest or joint defense agreement should be negotiated with Harwood & Pennington LLP (counsel for Greystone Capital Partners) and, when identified, counsel for Thornbury Infrastructure Fund II. The agreement will enable the privileged sharing of investigation-related information among parties with aligned interests while preserving the confidentiality and privilege protections

5. Individual Counsel Monitoring. The engagement team must actively monitor the potential need for individuals — particularly Derek Hargrave, Natasha Sorokin, and Gerald Fisk — to retain separate personal counsel as the investigation develops. If personal legal exposure becomes apparent for any individual, the Firm must ensure that its continued representation of the entity client does not create an impermissible con

6. Ongoing Conflict Monitoring. Conflict checks must be re-run as new parties, witnesses, counterparties, or subjects are identified during the course of the investigation. Given the international scope of the inquiry and the likelihood that additional entities and individuals will be identified as the investigation progresses, the engagement team should submit supplemental conflict check requests to the New Business

VIII. CONCLUSION Based on the conflict check results documented in this memorandum, Calderwood & Harkness LLP is cleared to represent Dunmore Energy Holdings Ltd. and its subsidiaries — Dunmore Trading International Ltd., Dunmore upstream Americas LLC, Dunmore Renewables GmbH, and Dunmore Exploration West Africa Ltd. — in the matter described above, subject to the conditions and recommendations set forth in Section V

IX. APPROVAL APPROVED — Responsible Partner By: ________ Name: Victoria Chambers Title: Partner, White Collar & Investigations Date: ________ APPROVED — Billing Partner By: ________ Name: Howard Quinn Title: Partner, White Collar & Investigations Date: ________ APPROVED — Conflicts Committee By: ________ Name: ________ Title: General Counsel / Chair, Conflicts Committee, Calderwood & Harkness LLP Date: ________ APPEN