Contract analysis

I. Executive Summary This memorandum sets forth the comprehensive plan for Calderwood & Harkness LLP's ("C&H" or the "Firm") internal investigation of Dunmore Energy Holdings Ltd. ("Dunmore" or "DEH") in connection with the inquiry opened by the U.S. Department of Justice ("DOJ"), National Security Division ("NSD"), Counterintelligence and Export Control Section ("CES"), on April 19, 2022. The investigation arises fr

II. Background A. The Client Dunmore Energy Holdings Ltd. is an exempted company incorporated with limited liability under the laws of the Cayman Islands, Cayman Company Registration No. MC-334821, with its registered office at Harbour Place, 4th Floor, 103 South Church Street, George Town, Grand Cayman KY1-1002. Dunmore maintains its operational headquarters at 1200 McKinney Street, Suite 3400, Houston, Texas 77010.

III. Investigation Objectives The internal investigation is designed to accomplish the following objectives, which will guide all workstreams and inform the Firm's strategic recommendations to Dunmore:

1. Determine the full scope, nature, and dollar value of transactions between DTI and Petronova Trading FZE, Zenith Petroleum DMCC, and Caspian Logistik GmbH. This includes identifying all transactions within and potentially beyond those preliminarily identified, establishing the precise terms, pricing, and settlement mechanics of each transaction, and tracing the flow of goods and payments associated with each.

2. Identify whether and to what extent those transactions involved Volkhov Industrial Group JSC or its affiliates, directly or indirectly, including through the OFAC 50% Rule. This requires a comprehensive beneficial ownership analysis of Petronova Trading FZE, Zenith Petroleum DMCC, and Caspian Logistik GmbH, as well as an examination of the ultimate sources and destinations of crude oil and equipment involved in th

3. Assess whether transactions violated OFAC-administered sanctions programs, specifically Directive 2 under Executive Order 13662 and the full SDN blocking sanctions under Executive Order 14024, as well as the underlying statutory authority of the International Emergency Economic Powers Act ("IEEPA"), 50 U.S.C. §§ 1701–1706.

4. Determine whether oilfield equipment exports violated the Export Administration Regulations ("EAR"), 15 C.F.R. Parts 730–774, specifically §746.5 (Russia/Belarus sanctions), and the underlying statutory authority of the Export Control Reform Act ("ECRA"), 50 U.S.C. §§ 4801–4852.

5. Identify culpable individuals, assess their knowledge, intent, and roles in the conduct at issue. This is essential both for the company's cooperation obligations to the DOJ and for determining the appropriate employment, indemnification, and administrative leave decisions.

6. Evaluate the adequacy of Dunmore's pre-existing sanctions and export controls compliance program as of the time the transactions at issue occurred and at the present time, including the effectiveness of OFAC screening protocols, counterparty due diligence procedures, training programs, and escalation mechanisms.

7. Assess the jurisdictional nexus for the application of U.S. sanctions and export control laws to DTI and its employees, including the U.S. person analysis under IEEPA and OFAC regulations. This analysis is particularly important given that DTI is a DIFC-licensed entity operating in Dubai, and its employees include non-U.S. persons. The analysis must also address Natasha Sorokin's status as a Russian-American dual

8. Trace payment flows and determine whether payments were structured to evade sanctions compliance, including analyzing the intermediary accounts at Crescent Commercial Bank PJSC and identifying the beneficial owners of payment recipients.

9. Develop a cooperation strategy with the DOJ under the Corporate Enforcement Policy, including the timing and substance of proffers, the scope and pace of document productions, and the identification of cooperating witnesses.

10. Evaluate whether to recommend voluntary self-disclosure ("VSD") to OFAC and/or BIS, including an assessment of the benefits, risks, and timing considerations associated with such disclosures.

11. Inform remediation of compliance deficiencies identified through the investigation, including the design and implementation of an enhanced sanctions and export controls compliance program that meets the standards set forth in the DOJ's Evaluation of Corporate Compliance Programs and OFAC's Framework for Compliance Commitments.

12. Preserve and protect attorney-client privilege and work product throughout all aspects of the investigation, consistent with the protocols set forth in Section VIII of this memorandum.

IV. Investigation Workstreams The investigation is organized into six principal workstreams, each with a designated lead, supporting team members, defined scope, and specific deliverables. While each workstream has distinct responsibilities, extensive coordination among workstreams is essential to the success of the investigation. Weekly workstream coordination calls, chaired by Jasmine Thornton, will ensure that fin

1. Derek Hargrave, President, DTI (Dubai)

2. Natasha Sorokin, Senior Trader, DTI (Dubai)

3. Omar Al-Rashidi, Head of Middle East Operations, DTI (Dubai)

4. Yves Leclerc, Director of Logistics & Shipping, DTI (Dubai)

5. Gerald Fisk, Chief Compliance Officer (Houston)

6. Rajesh Malhotra, Controller, DTI (Dubai)

7. Callum Renshaw, Chief Executive Officer (Houston)

8. Sandra Whitfield, Chief Financial Officer (Houston)

9. Marcus Wellbourne, General Counsel (Houston) — note: collection from General Counsel requires enhanced privilege review protocols

10. Tobias Engel, Managing Director, Dunmore Renewables GmbH (Hamburg) Additional custodians will be identified as the investigation progresses and as witness interviews and document review surface additional individuals with knowledge of or involvement in the conduct at issue. Litigation Hold Notices. Litigation hold notices were issued on April 20, 2022, using a standardized template distributed to all identified c