Contract analysis

I. Executive Summary The purpose of this memorandum is to outline the comprehensive remediation workstream for Dunmore Energy Holdings Ltd. ("Dunmore" or "DEH") designed to address the compliance deficiencies identified during the course of the internal investigation into potential violations of U.S. sanctions laws—including programs administered by the Office of Foreign Assets Control ("OFAC") of the U.S. Department

II. Background: Identified Compliance Deficiencies The internal investigation and associated forensic analysis have identified compliance deficiencies across six principal areas. Each area is summarized below. These deficiencies collectively represent a compliance program that was, at the time of the relevant conduct, materially inadequate to detect or prevent the sanctions and export control violations at issue. The

III. Remediation Workstream Scope A. Overview of Workstreams Based on the compliance deficiencies identified in Section II, C&H and Marlowe Asset Management have identified five primary remediation workstreams. Each workstream is designed to address a distinct category of compliance deficiency while maintaining integration across the workstreams to ensure a cohesive and comprehensive Enhanced Program. Calderwood & Ha

1. Enhanced OFAC / Sanctions Screening Program

2. Export Control Classification and Compliance Program

3. Third-Party / Counterparty Due Diligence Protocol

4. Transaction Monitoring and Payment Controls

5. Governance, Training, and Organizational Structure Each workstream is described in detail below, including its objective, key deliverables, and assigned personnel from Marlowe Asset Management, Calderwood & Harkness, and Dunmore. B. Workstream 1: Enhanced OFAC / Sanctions Screening Program Objective: Design and implement a comprehensive OFAC and global sanctions screening program across all Dunmore entities global

IV. Timeline and Milestones The remediation workstream is organized into five phases spanning approximately 15 months, from January 2023 through March 2024, with ongoing monitoring and sustainability activities continuing beyond that period. The timeline is designed to ensure that the Enhanced Program is substantially designed, implemented, and operational before the anticipated DOJ decision point regarding prosecuti

V. Deliverables Summary Table The following table provides a comprehensive summary of all deliverables associated with the remediation workstream, organized by deliverable number, description, responsible party, target delivery date, and Dunmore approver. The target dates set forth above are ambitious but achievable provided that all parties—C&H, Marlowe Asset Management, and Dunmore—dedicate the necessary resources

VI. Budget and Resource Allocation The remediation workstream will require the commitment of significant external and internal resources. The budget and resource allocation for the workstream are summarized below. A. Pemberton Investors Solutions LLC Marlowe Asset Management's engagement encompasses the full scope of remediation design, gap assessment, policy drafting, training materials development, and implementati