Contract analysis

1. Purpose of This Letter I am writing in my capacity as Responsible Partner on behalf of Calderwood & Harkness LLP to address several matters of significance following the successful conclusion of the Department of Justice inquiry into Dunmore Energy Holdings Ltd. ("Dunmore" or the "Company"). The purposes of this letter are fourfold: (1) to confirm the firm's receipt of the formal declination of prosecution issued

2. DOJ Declination — Confirmation and Summary We can now confirm that on June 28, 2024, the DOJ's National Security Division, Counterintelligence and Export Control Section, issued a formal declination letter addressed to Dunmore Energy Holdings Ltd. The declination letter was signed by Assistant United States Attorney Meredith Calloway, who served as the lead prosecutor throughout this matter. The letter communicate

3. OFAC Resolution In addition to the DOJ declination, we note for completeness the favorable resolution obtained with OFAC. On April 15, 2024, OFAC issued a Cautionary Letter (Ref. No. OCA-2024-11587) to Dunmore rather than imposing a civil monetary penalty. The Cautionary Letter represented the conclusion of OFAC's review of the voluntary self-disclosure that Dunmore filed with OFAC on June 1, 2023. That voluntary

4. Summary of the Engagement and Key Milestones Given the scope and duration of this matter, and for purposes of creating a comprehensive contemporaneous record, we set forth below a summary of the engagement and its key milestones. 4.1 Retention and Scope Calderwood & Harkness was retained by Dunmore on April 14, 2022, pursuant to a written engagement letter executed on that date by you, Marcus, on behalf of the Com

5. Financial Summary We set forth below a comprehensive summary of all costs incurred in connection with the matter. These figures are based on invoices rendered through the date of this letter and the firm's internal financial records. Dunmore's directors and officers insurance policy issued by Garrison Mutual Insurance Co. (Policy No. GM-DO-2021-08734; $50 million aggregate limit / $10 million per claim limit; $2.5

6. Formal Closure of Matter No. 1016-00009 By this letter, we hereby formally confirm that Calderwood & Harkness LLP's engagement under Matter No. 1016-00009 is closed as of the date of this letter, July 1, 2024. No further active work will be performed by the firm on this matter unless Dunmore requests additional services under a new or supplemental engagement letter executed by the parties. Should any such need ari

7. File Retention and Document Management 7.1 Calderwood & Harkness File Retention Policy Calderwood & Harkness will retain the complete matter file pertaining to Matter No. 1016-00009 — encompassing both physical and electronic materials — in accordance with the firm's standard Document Retention Policy. Under that policy, client matter files are retained for a period of ten (10) years from the date of matter closur

8. Ongoing Obligations and Recommendations While the closure of this matter marks a significant and positive milestone, we wish to highlight several considerations that merit Dunmore's ongoing attention. 8.1 Compliance Program Maintenance The DOJ declination was based in significant part on Dunmore's implementation of the Enhanced Sanctions & Export Controls Compliance Program adopted by the Board of Directors on Oct

9. Acknowledgments and Closing Remarks In closing, I wish to acknowledge the extraordinary cooperation, commitment, and professionalism demonstrated by Dunmore's leadership throughout this demanding and high-stakes engagement. CEO Callum Renshaw set the tone from the outset by authorizing immediate voluntary self-disclosure and directing the full cooperation of all Dunmore personnel, a decision that proved pivotal to

1. Copy of DOJ Declination Letter dated June 28, 2024

2. Copy of OFAC Cautionary Letter (Ref. No. OCA-2024-11587) dated April 15, 2024 Category | Amount Calderwood & Harkness LLP — Legal Fees (April 2022 – June 2024) | $14,300,000 Ridgeline Advisory Group LLC — Forensic Accounting Services | $2,100,000 Nexagen Analytics Inc. — E-discovery Services | $1,850,000 Pemberton Investors Solutions LLC — Remediation Consulting | $875,000 Individual Counsel Fees (advanced by Dunm