Contract analysis

I. Executive Summary Omar Al-Rashidi serves as Head of Middle East Operations at DTI, based at Level 14, Gate Building 3, Dubai International Financial Centre, P.O. Box 506774, Dubai, United Arab Emirates. He has held this position since approximately 2019 and reports directly to Derek Hargrave, the former President of DTI, who was placed on administrative leave effective July 1, 2022, and whose employment was subseq

II. Background on Omar Al-Rashidi A. Professional Background and Role at DTI Omar Al-Rashidi is a UAE national with extensive experience in the Middle East energy trading sector. His full name is Omar Tariq Al-Rashidi. He holds the title of Head of Middle East Operations at Dunmore Trading International Ltd. ("DTI"), the overseas trading subsidiary that is at the center of the DOJ's inquiry. DTI is a limited company

III. Summary of Debriefing Sessions A. First Debriefing — June 14, 2022 (Round 1, Interview #11 of 22) The first debriefing of Omar Al-Rashidi was conducted on June 14, 2022, as part of the first round of witness interviews in the internal investigation. This was the eleventh of twenty-two interviews conducted during Round 1. Location: Calderwood & Harkness LLP conference facilities coordinated in Dubai, in proximity

IV. Assessment of Credibility The credibility of any potential cooperating witness is a critical factor in determining whether to present that witness to the government in a proffer setting. A witness who provides inaccurate, inconsistent, or unreliable information can undermine the company's cooperation submission and damage the credibility of the internal investigation itself. Accordingly, this section provides a d

V. Key Substantive Information Provided by Al-Rashidi This section consolidates the key substantive information provided by Al-Rashidi across his three debriefing sessions, organized thematically. This summary is intended to provide a concise reference for the investigation team and to facilitate preparation for any DOJ proffer session. A. Trading Desk Operations and Governance Al-Rashidi provided a detailed picture

VI. Evaluation for Potential DOJ Proffer A. Value as Cooperating Witness Based on the assessment of Al-Rashidi's testimony, credibility, and demeanor set forth above, it is my evaluation that Al-Rashidi would be a valuable cooperating witness in a DOJ proffer session. His value derives from several distinct contributions he can make to the government's understanding of the conduct under investigation: (i) Counterpart