Contract analysis

1. Identification of the Policy This notice is submitted under the following policy of insurance: This notification is made pursuant to the Policy's notice provisions, as set forth in the relevant sections of the Policy (a copy of the applicable provisions is attached hereto as Enclosure C), and is intended to preserve all coverage rights of Dunmore and its insured persons under the Policy, including without limitati

2. Description of the Underlying Matter 2.1 Background on the Insured Dunmore Energy Holdings Ltd. is a diversified energy company operating across the oil and gas exploration, production, and trading sectors, as well as the renewable energy development sector. For the fiscal year ended December 31, 2021, Dunmore reported consolidated revenues of approximately $4.87 billion and employed approximately 3,200 persons gl

1. Callum Renshaw — Chief Executive Officer, Dunmore Energy Holdings Ltd. (Houston, Texas). Mr. Renshaw has served as CEO since 2018 and has overall supervisory responsibility for the company's global operations, including DTI.

2. Derek Hargrave — President, Dunmore Trading International Ltd. (Dubai, UAE). Mr. Hargrave has served as President of DTI since 2019 and had direct supervisory authority over the trading desk at the center of the inquiry. As of the date of this letter, Mr. Hargrave has been placed on administrative leave pending the outcome of the internal investigation. Based on our preliminary assessment and communications with t

3. Natasha Sorokin — Senior Trader, Dunmore Trading International Ltd. (Dubai, UAE). Ms. Sorokin joined DTI in 2018 and was directly responsible for executing certain of the transactions under scrutiny. Ms. Sorokin is expected to be placed on administrative leave in the near term. Based on our preliminary assessment, Ms. Sorokin may also be classified as a potential target of the investigation.

4. Gerald Fisk — Chief Compliance Officer, Dunmore Energy Holdings Ltd. (Houston, Texas). Mr. Fisk has served as Chief Compliance Officer since 2017 and was responsible for overseeing the company's sanctions and export control compliance programs during the period in question. As of the date of this letter, Mr. Fisk remains employed by Dunmore, although we note that his continued tenure is under review by the Board o

5. Omar Al-Rashidi — Head of Middle East Operations, Dunmore Trading International Ltd. (Dubai, UAE). Mr. Al-Rashidi has broad operational responsibility for DTI's activities in the Middle East region and may have had knowledge of or involvement in certain of the transactions under inquiry.

6. Yves Leclerc — Director of Logistics & Shipping, Dunmore Trading International Ltd. (Dubai, UAE). Mr. Leclerc was responsible for arranging the logistics and shipping of commodities and equipment on behalf of DTI, including arrangements that may have involved Caspian Logistik GmbH.

7. Sandra Whitfield — Chief Financial Officer, Dunmore Energy Holdings Ltd. (Houston, Texas). Ms. Whitfield has served as CFO since 2019 and has oversight of the company's financial reporting and treasury functions, including the payment channels through which certain transactions were processed.

8. Rajesh Malhotra — Controller, Dunmore Trading International Ltd. (Dubai, UAE). Mr. Malhotra oversees the accounting and financial reporting functions of DTI and may have had visibility into the payment flows at issue.

9. Marcus Wellbourne — General Counsel, Dunmore Energy Holdings Ltd. (Houston, Texas). Mr. Wellbourne has served as General Counsel since 2020 and is responsible for the company's legal affairs, including the retention of outside counsel in connection with this matter.

10. Tobias Engel — Managing Director, Dunmore Renewables GmbH (Hamburg, Germany). Mr. Engel's involvement is tangential and relates primarily to his role in overseeing Dunmore's Hamburg-based operations, which may have had interactions with Caspian Logistik GmbH through shared office services and logistics arrangements. We note that some of the individuals identified above may, in the course of the investigation or i

3. Engagement of Defense Counsel Calderwood & Harkness LLP was retained by Dunmore Energy Holdings Ltd. on April 14, 2022, to serve as lead defense counsel in connection with the matters described herein. The scope of the engagement encompasses the following: (a) Conducting a comprehensive internal investigation into the facts and circumstances underlying the DOJ inquiry; (b) Responding to Grand Jury Subpoena No. GJ

4. Retention of Additional Advisors and Vendors In connection with this matter, the following additional advisory firms and vendors have been retained or are expected to be retained in the near term. We submit that the fees and costs of these firms constitute defense costs within the meaning of the Policy and should be covered thereunder: (a) Ridgeline Advisory Group LLC (Washington, D.C.) — Ridgeline Advisory Group

5. Anticipated Defense Costs and Budget We recognize that the investigation is in its early stages and that a precise estimate of total defense costs is not yet available. However, based on our assessment of the scope and complexity of the DOJ inquiry—including the multi-jurisdictional nature of the document collection effort, the expected volume of documents to be reviewed (in excess of two million), the anticipated

6. Request for Coverage Confirmation We respectfully and formally request that Garrison Mutual Insurance Co. confirm in writing, at its earliest convenience, the following:

1. Coverage Determination. That the DOJ inquiry described in this letter constitutes a covered "Claim" or, in the alternative, covered reportable "Circumstances" under Policy No. GM-DO-2021-08734, triggering the Insurer's obligations under the Policy.

2. Defense Costs Coverage. That defense costs incurred by Dunmore and its insured persons in connection with the DOJ inquiry—including legal fees, forensic accounting fees, e-discovery and document review costs, and related expenses—are covered under the Policy, subject to the applicable terms, conditions, exclusions, and retention.

3. Approval of Defense Counsel. That the retention of Calderwood & Harkness LLP as lead defense counsel for the company is approved under the Policy. To the extent that the Policy contains a panel counsel requirement or other provisions governing the selection of defense counsel, we respectfully request a waiver of any such requirement in light of the highly specialized nature of the matter, which involves the inters

4. Approval of Advisors and Vendors. That the retention of Ridgeline Advisory Group LLC as forensic accounting consultant, Nexagen Analytics Inc. as e-discovery and document review vendor, and any future advisors or vendors reasonably necessary for the defense of this matter, is covered or approved under the Policy.

5. Advancement of Individual Defense Costs. That advancement of defense costs for individual insured persons who retain separate personal counsel—to be advanced by Dunmore in the first instance pursuant to its indemnification obligations and thereafter claimed under the Policy—will be honored by the Insurer in accordance with the Policy's terms. In addition, we request the designation of a single point of contact at

7. Reservation of Rights Dunmore Energy Holdings Ltd. expressly reserves all rights under Policy No. GM-DO-2021-08734, including but not limited to the following: (a) The right to claim coverage for all defense costs incurred in connection with the DOJ inquiry, including costs incurred by the company and by individual insured persons; (b) The right to contest any denial, limitation, or reservation of coverage by Garr

8. Privilege and Confidentiality All information provided in this letter, and all information that may be provided in future claims correspondence, investigation updates, or coverage submissions, is provided solely for purposes of the insurance coverage relationship between Dunmore and Garrison Mutual. Such information is subject to the common interest privilege, the attorney-client privilege, the work product doctri

9. Compliance with Notice Requirements This notice is being provided promptly upon the retention of counsel and the commencement of Calderwood & Harkness's internal investigation, in compliance with the notice provisions of the Policy. We note the following timeline: • April 14, 2022: Calderwood & Harkness LLP retained by Dunmore Energy Holdings Ltd. • April 19, 2022: Grand Jury Subpoena No. GJ No. 22-418 served on D

10. Contact Information and Future Correspondence All future correspondence, notices, and communications regarding this claim should be directed to the following individuals at Calderwood & Harkness LLP: Primary Contact (Billing Partner & Insurance Liaison): Howard Quinn Partner, White Collar Defense & Investigations Calderwood & Harkness LLP 450 Lexington Avenue, 38th Floor New York, New York 10017 Telephone: (212)