Contract analysis

1. Interview Logistics On May 23, 2022, Jasmine Thornton and Nicholas Ferreira conducted a first-round witness interview of Callum Renshaw, Chief Executive Officer of Dunmore Energy Holdings Ltd. ("Dunmore" or "DEH" or the "Company"), in connection with the internal investigation arising from the U.S. Department of Justice ("DOJ") inquiry and grand jury subpoena GJ No. 22-418. The interview details are as follows: Da

2. Upjohn Warning / Corporate Miranda At the outset of the interview, and prior to any substantive questioning, Jasmine Thornton administered the standard Upjohn corporate Miranda warning to Mr. Renshaw, consistent with the Witness Interview Protocol dated April 18, 2022, which was prepared and approved by Victoria Chambers, the Responsible Partner on this matter. The warning was delivered orally and in substantially

3. Background of Callum Renshaw Ms. Thornton began the interview by asking Mr. Renshaw to describe his background, his role at Dunmore, and the Company's overall business and organizational structure. Personal and Professional Background. Mr. Renshaw's full legal name is Callum Renshaw. He currently serves as Chief Executive Officer of Dunmore Energy Holdings Ltd. Mr. Renshaw has served in the CEO role since 2018, wh

4. Organizational Structure and Reporting Lines — Dubai Trading Desk Ms. Thornton then asked Mr. Renshaw to describe in detail the organizational structure and reporting lines pertaining to Dunmore Trading International Ltd. ("DTI"), the subsidiary at the center of the investigation. Derek Hargrave — President of DTI. Mr. Renshaw stated that Derek Hargrave served as President of DTI from 2017 until 2022. Mr. Hargrave

5. Knowledge of Specific Counterparties Ms. Thornton then asked Mr. Renshaw about his knowledge of each of the specific counterparties identified in the DOJ grand jury subpoena GJ No. 22-418. 5.1 Petronova Trading FZE Mr. Renshaw stated that he was aware of Petronova Trading FZE as a counterparty name that appeared in DTI's trading reports. He described Petronova as a Dubai-based commodity trading company. When asked

6. Knowledge of the Suspect Transactions Ms. Thornton then questioned Mr. Renshaw regarding his knowledge of the specific categories of suspect transactions that have been identified in the course of the internal investigation. 6.1 Crude Oil Swap Transactions Mr. Renshaw was asked about the fourteen crude oil swap transactions totaling approximately $218.7 million in notional value, executed with Petronova Trading FZ

7. Knowledge of Compliance Infrastructure and Gerald Fisk Ms. Thornton asked Mr. Renshaw to describe Dunmore's compliance function and infrastructure as it existed prior to April 2022, with particular focus on sanctions and export control compliance. Gerald Fisk — Chief Compliance Officer. Mr. Renshaw identified Gerald Fisk as Dunmore's Chief Compliance Officer, a position Mr. Fisk held for approximately four years.

8. Knowledge of How the Inquiry Arose Ms. Thornton asked Mr. Renshaw to recount, to the best of his recollection, the sequence of events that led to the engagement of Calderwood & Harkness and the initiation of the internal investigation. Mr. Renshaw provided the following chronological account: April 6, 2022: OFAC added Volkhov Industrial Group JSC to the SDN List under Executive Order 14024, as part of a broader tr

9. Renshaw's Communications with Hargrave and Sorokin Ms. Thornton asked Mr. Renshaw to describe his communications with Derek Hargrave and Natasha Sorokin during the period from March 2020 through April 2022, which encompasses the timeframe during which the suspect transactions were executed. Communications with Derek Hargrave. Mr. Renshaw stated that his communications with Mr. Hargrave during the relevant period w

10. Interactions with Shareholders Ms. Thornton asked Mr. Renshaw about his interactions with Dunmore's equity investors in connection with the investigation and the DOJ inquiry. Reporting Obligations. Mr. Renshaw described his reporting obligations to the Company's principal equity investors, Greystone Capital Partners Fund IV, L.P. (holding approximately 62.5% of the equity) and Thornbury Infrastructure Fund II, L.

11. Renshaw's Awareness of Banking Relationships Relevant to Investigation Ms. Thornton asked Mr. Renshaw about the Company's banking relationships that may be relevant to the investigation. Meridian National Bank, N.A. Mr. Renshaw confirmed that Meridian National Bank, N.A., located in New York, serves as Dunmore's primary lender. Meridian provides a $750 million senior secured revolving credit facility to the Compa

12. Renshaw's Knowledge of D&O Insurance Ms. Thornton asked Mr. Renshaw about the Company's directors' and officers' liability insurance coverage. Mr. Renshaw confirmed that Dunmore Energy Holdings Ltd. maintains directors' and officers' ("D&O") liability insurance through Garrison Mutual Insurance Co., domiciled in Bermuda. The policy is designated as policy number GM-DO-2021-08734. The policy provides $50 million i

13. Renshaw's View on Remediation Ms. Thornton asked Mr. Renshaw about his views on remediation measures and the Company's posture going forward. Mr. Renshaw expressed strong and unequivocal support for comprehensive remediation of the Company's compliance program. He stated that the events giving rise to the investigation represented a serious failure of the Company's compliance infrastructure, and that he was perso

14. Assessment of Witness Credibility and Demeanor The following assessment of Mr. Renshaw's credibility and demeanor is based on the observations of both Jasmine Thornton and Nicholas Ferreira during the course of the interview. Mr. Renshaw was cooperative and forthcoming throughout the interview. He arrived on time, was prepared, and engaged with the questioning in a focused and attentive manner. He answered questi

15. Documents Referenced or Identified During Interview During the course of the interview, Mr. Renshaw referenced or identified the following categories of documents as relevant to his testimony and to the investigation generally. These documents have been noted for collection, production, and review:

1. Monthly Trading Desk Summary Reports: Monthly reports prepared by Derek Hargrave and/or Rajesh Malhotra at DTI and transmitted to Mr. Renshaw, covering trading volumes, revenue, key counterparties, and risk metrics. These reports are expected to be among the documents collected by Nexagen Analytics Inc., the e-discovery vendor retained for this matter, under Project No. NX-DEH-2204. These reports are a high priori

2. Quarterly Board Presentation Materials: Quarterly business review and Board meeting presentations, including the compliance section prepared by Gerald Fisk. These materials will provide insight into the information presented to the Board and senior management regarding the status of the Company's compliance program.

3. Email Correspondence Between Renshaw and Hargrave: All email communications between Mr. Renshaw and Mr. Hargrave during the relevant period (March 2020 through April 2022). This correspondence is to be captured in the e-discovery collection and reviewed for any references to the suspect counterparties, unusual transactions, or compliance concerns.

4. Board Audit & Compliance Committee Meeting Minutes: Minutes from meetings of the Board's Audit & Compliance Committee during the relevant period. These minutes have been requested for production and will be reviewed for any discussions of sanctions compliance, counterparty risk, or compliance program adequacy.

5. Dunmore Sanctions Compliance Policy Manual: The Company's existing sanctions compliance policy manual, as it existed prior to April 2022. This document will be reviewed against the Company's actual screening practices and procedures to assess any gaps between the written policy and operational reality.

16. Follow-Up Items / Open Issues Based on the interview, the following items have been identified for follow-up by the investigation team:

1. Email Review — Renshaw/Hargrave Correspondence. Obtain and review Mr. Renshaw's email correspondence with Derek Hargrave from March 2020 through April 2022. The review should focus on any references to Petronova Trading FZE, Zenith Petroleum DMCC, Volkhov Industrial Group JSC, Caspian Logistik GmbH, or any other potentially relevant counterparties or transactions. The review should also identify any communications

2. Review of Monthly Trading Desk Summary Reports. Obtain and review the monthly trading desk summary reports transmitted from DTI to Mr. Renshaw during the relevant period. The purpose of this review is to assess what information Mr. Renshaw would have had regarding counterparty concentrations, trading volumes with specific counterparties, and risk metrics that might have signaled problematic activity.

3. Cross-Reference Fisk Notification. Cross-reference Mr. Renshaw's account of the Gerald Fisk notification (which Mr. Renshaw placed on or around April 11, 2022) with Mr. Fisk's account (to be obtained in Mr. Fisk's interview, currently scheduled for June 8, 2022) and with Mr. Wellbourne's records and recollections. The purpose is to confirm the timeline and substance of the internal notification chain.

4. Assessment of CEO Oversight of DTI. Assess whether Mr. Renshaw's level of oversight of the Dubai trading desk was consistent with industry norms for a CEO of a similarly situated energy company, or whether it constituted a supervisory gap that may be relevant to the Company's culpability analysis or to DOJ's assessment of corporate cooperation and remediation. This assessment should include a comparison with gover

5. Potential Re-Interview of Renshaw. Consider whether a re-interview of Mr. Renshaw will be necessary after completion of the forensic accounting analysis being conducted by Ridgeline Advisory Group LLC (retained May 2, 2022, under Engagement No. RAG-2022-0319, with Dr. Margaret Liu as Engagement Lead). The forensic analysis may yield information that warrants additional questioning of Mr. Renshaw, particularly if d

6. Coordination with Victoria Chambers — DOJ Proffer. Coordinate with Victoria Chambers regarding any information from this interview that may be relevant to the initial proffer to Assistant United States Attorney Meredith Calloway, DOJ National Security Division, currently scheduled for July 15, 2022. Particular attention should be given to Mr. Renshaw's account of the Company's compliance infrastructure, the timeli

17. Distribution and Privilege Notation This memorandum constitutes attorney work product prepared in anticipation of litigation and in connection with the provision of legal advice to Dunmore Energy Holdings Ltd. It is protected by the attorney-client privilege and the work product doctrine. Distribution of this memorandum is strictly limited to the following members of the Calderwood & Harkness LLP investigation te