Contract analysis

I. Acknowledgment of Representation I write on behalf of our client, Dunmore Energy Holdings Ltd. ("Dunmore" or the "Company"), in connection with the above-referenced matter. I am a partner in the White Collar & Investigations practice group of Calderwood & Harkness LLP ("Calderwood & Harkness" or the "Firm") and serve as the responsible partner and lead counsel for Dunmore in the pending inquiry by the U.S. Departm

II. Background of the Matter For purposes of establishing a mutual understanding of the matter's context, we provide the following summary, which we believe is consistent with information already known to you and your client. On April 19, 2022, the DOJ's National Security Division, Counterintelligence and Export Control Section ("CES"), opened a formal inquiry concerning potential violations of U.S. sanctions laws, i

III. Status of Mr. Hargrave's Employment and Administrative Leave As noted above, Mr. Hargrave was placed on administrative leave from Dunmore Trading International Ltd. effective July 1, 2022. This action was taken by the Company's Board of Directors in consultation with Calderwood & Harkness and the Company's General Counsel, Marcus Wellbourne, pending the outcome of the DOJ inquiry and the Company's parallel inter

IV. Communication Protocols Going forward, all communications between Calderwood & Harkness (on behalf of Dunmore Energy Holdings Ltd. and its subsidiaries) and Mr. Hargrave regarding the DOJ inquiry, the Company's internal investigation, the grand jury subpoena GJ No. 22-418, and any related regulatory proceedings—including but not limited to matters involving OFAC, BIS, or any other governmental or regulatory autho

V. Scope and Limitations on Information Sharing We wish to reiterate and formalize several points regarding the scope of Calderwood & Harkness's representation and the limitations on information sharing that necessarily follow from the distinct representation of the Company and Mr. Hargrave by separate counsel. Corporate Representation. As stated above, Calderwood & Harkness represents Dunmore Energy Holdings Ltd. an

VI. Document Preservation Obligations We take this opportunity to remind you that Mr. Hargrave was issued a formal litigation hold notice on April 20, 2022, and a supplemental reminder regarding his ongoing preservation obligations on July 15, 2022. These notices require Mr. Hargrave to preserve all documents, communications, and electronic data in his possession, custody, or control that are related to: (a) transact

VII. Indemnification and Advancement of Defense Costs Dunmore Energy Holdings Ltd. acknowledges that it has indemnification and advancement obligations with respect to Mr. Hargrave's defense costs arising from the DOJ inquiry. These obligations have been analyzed in a confidential internal memorandum prepared by Calderwood & Harkness and are provided for under the Company's articles of association and Mr. Hargrave's

VIII. Cooperation Expectations As you may be aware, Dunmore Energy Holdings Ltd. has committed to full cooperation with the DOJ in this investigation, consistent with the DOJ Corporate Enforcement Policy (as updated in September 2022) and the Company's own determination that voluntary cooperation is in its best interest. The Company's cooperation includes, among other things, the production of documents responsive to

IX. Confidentiality We remind you that Mr. Hargrave remains bound by the confidentiality provisions of his employment agreement with Dunmore Trading International Ltd. and by any applicable non-disclosure agreements, proprietary information agreements, or similar restrictive covenants to which he is a party. These obligations survive his placement on administrative leave and remain in full force and effect. We respec

X. Closing We are committed to handling this matter in a professional and cooperative manner, and we are willing to discuss any of the foregoing matters further with you at your convenience, to the extent consistent with Dunmore's interests. We recognize that the representation of individual employees in the context of a corporate investigation requires careful coordination, and we look forward to establishing an eff