Contract analysis

1. Purpose and Legal Context This letter constitutes a formal litigation hold notice directed to you personally in your capacity as President of Dunmore Trading International Ltd. ("DTI"), DIFC License No. CL-4827. This notice imposes immediate and mandatory obligations upon you to preserve all documents and electronically stored information ("ESI") as described herein. Please read this notice carefully and in its en

2. Scope of the Litigation Hold — Subject Matter The litigation hold described in this notice covers all documents and ESI in any way related to the subjects described below, for the period from January 1, 2019 to the present. The categories set forth below are intended to be illustrative and not exhaustive. If you have any doubt as to whether a particular document or category of documents falls within the scope of t

3. Types of Documents and ESI Covered The litigation hold described in this notice applies to ALL documents and ESI, in any format, medium, or location, that fall within the subject matter scope defined in Section 2. Without limiting the generality of the foregoing, the types of documents and ESI covered by this hold include, but are not limited to, the following: (a) Electronic Mail. All emails, including all attach

4. Preservation Obligations — Specific Instructions to Derek Hargrave The following instructions are directed to you personally, Mr. Hargrave, and must be implemented immediately upon receipt of this notice. These instructions are in addition to, and not in lieu of, any broader preservation directives that may be issued by Dunmore's General Counsel or by Calderwood & Harkness to Dunmore and its subsidiaries generally

5. Obligation to Identify and Disclose In addition to your preservation obligations, you are required to promptly identify and disclose to Calderwood & Harkness LLP the following information. This disclosure is essential to ensure that the firm can take all necessary steps to preserve and collect potentially responsive documents and ESI across all relevant data sources. You are required to identify and disclose: (a)

6. Duration of Hold This litigation hold remains in effect indefinitely until you receive express written notice from Calderwood & Harkness LLP that the hold has been released, modified, or narrowed. You must not assume that the hold has been lifted or modified based upon the passage of time, the resolution of any particular stage of the DOJ investigation, the conclusion of any grand jury proceedings, or any other ev

7. Confidentiality This litigation hold notice, its contents, the existence and scope of the underlying DOJ investigation, and the fact that Calderwood & Harkness LLP has been retained to represent Dunmore in connection with this matter are strictly confidential. The disclosure of this information could prejudice Dunmore's legal interests and could interfere with the government's investigation. You must not discuss t

8. Consequences of Non-Compliance The obligation to preserve documents and ESI in connection with pending or reasonably anticipated litigation or government investigations is well-established under applicable law. Calderwood & Harkness LLP is obligated to inform you clearly and unambiguously of the potential consequences of failing to comply with this litigation hold. Failure to comply with the preservation obligatio

9. Acknowledgment and Confirmation You are required to sign and return the enclosed Acknowledgment and Confirmation Form (Enclosure A) confirming the following: (a) That you have received this litigation hold notice and have read and understood its contents in their entirety; (b) That you commit to comply fully with all preservation obligations described herein, and that you will not destroy, delete, alter, or concea

10. Contact Information For any questions regarding this litigation hold notice, to report the existence of potentially relevant documents or information, or to seek guidance on whether particular materials fall within the scope of this hold, please contact the following members of the Calderwood & Harkness team. Please reference Matter No. 1016-00009 in all correspondence. Victoria Chambers Partner, White Collar & I