Contract analysis

I. Upjohn / Corporate Miranda Warning At the outset of the interview, Victoria Chambers administered the standard Upjohn corporate Miranda warning to Derek Hargrave in accordance with the firm's Witness Interview Protocol dated April 18, 2022, which was adopted for this engagement. Ms. Chambers delivered the following advisements orally and confirmed Hargrave's understanding of each:

1. Calderwood & Harkness LLP represents Dunmore Energy Holdings Ltd. and its subsidiaries (collectively, "Dunmore" or the "Company") in connection with this matter. The firm does not represent Derek Hargrave in his individual capacity.

2. The purpose of the interview is to gather facts in connection with the internal investigation being conducted at the direction of Marcus Wellbourne, General Counsel of Dunmore Energy Holdings Ltd. The investigation concerns potential sanctions and export controls compliance issues involving certain Dunmore subsidiaries, including Dunmore Trading International Ltd.

3. Communications during the interview are protected by the attorney-client privilege. However, the privilege belongs to the Company, not to Hargrave personally. Hargrave does not have the ability to assert or waive the privilege with respect to the substance of this interview.

4. The Company may, in its sole discretion, elect to waive the attorney-client privilege and disclose the substance of this interview — including Hargrave's statements — to third parties, including but not limited to the U.S. Department of Justice, the Office of Foreign Assets Control of the U.S. Department of the Treasury, the Bureau of Industry and Security of the U.S. Department of Commerce, or other governmental

5. Hargrave has the right to retain his own personal counsel at any time, including before or during this interview. If he wishes to retain personal counsel, the interview can be paused or rescheduled.

6. The interview is voluntary. Hargrave is not required to participate but is asked to provide truthful and complete answers to all questions if he chooses to participate. Providing false or misleading information to counsel conducting this investigation could have adverse consequences. Following the delivery of these advisements, Ms. Chambers asked Hargrave whether he understood each point. Hargrave confirmed that h

II. Background and Employment History Hargrave provided the following background information at the beginning of the interview. Personal Information. Hargrave's full legal name is Derek Robert Hargrave. His date of birth is noted in the investigation file but has been redacted from this memorandum. He is a British citizen and a U.S. permanent resident (green card holder). He maintains residences in both Dubai, United

III. Overview of DTI Trading Desk Operations Hargrave was asked to describe the general nature and scope of DTI's business activities. He provided the following overview. Primary Business Lines. Hargrave described DTI's primary business as crude oil and refined petroleum products trading. DTI operated as the principal international trading arm for Dunmore Energy Holdings Ltd. outside of the Americas. He stated that D

IV. Relationship with Petronova Trading FZE A. How the Relationship Began Hargrave was asked in detail about DTI's relationship with Petronova Trading FZE. He stated that the relationship originated in approximately late 2019 or early 2020, when Natasha Sorokin introduced Petronova to DTI as a potential counterparty. According to Hargrave, Sorokin described Petronova as a Dubai-based commodity trading house that spec

V. Relationship with Zenith Petroleum DMCC Hargrave confirmed that DTI also transacted with Zenith Petroleum DMCC, a Dubai-registered entity managed by Farhan Qureshi, a Pakistani national resident in the UAE. Hargrave stated that Zenith Petroleum was registered at Unit 2201, Jumeirah Bay Tower X2, Cluster X, Jumeirah Lakes Towers, Dubai, UAE. He described Zenith Petroleum as a "smaller player" in the Dubai petroleum

VI. Oilfield Equipment Exports via Caspian Logistik GmbH A. Background on Equipment Transactions Hargrave was asked about DTI's involvement in oilfield equipment procurement and export activities. He described DTI's role as facilitating the sourcing and shipment of oilfield drilling equipment and components for Dunmore's global operations. He explained that, in addition to its commodity trading activities, DTI served

VII. Payment Flows through Crescent Commercial Bank PJSC Hargrave was asked in detail about the payment structure and flows associated with DTI's transactions with Petronova Trading FZE and Zenith Petroleum DMCC. He confirmed that payments for these transactions were processed through DTI's accounts at Crescent Commercial Bank PJSC in Dubai, which was managed by relationship banker Khalid Mansour. During this portion

VIII. Knowledge of Sanctions and Compliance Framework A. OFAC and Sanctions Awareness Hargrave was asked about his general awareness of U.S. sanctions laws and their applicability to DTI's operations. He stated that he was "generally aware" that U.S. sanctions applied to Dunmore entities and their subsidiaries, including DTI, because of the company's U.S. nexus. He identified several factors that he understood to cre

IX. Relationship with Natasha Sorokin Hargrave was asked about his relationship with and supervision of Natasha Sorokin, DTI's Senior Trader. He described Sorokin as "the best trader on the desk — aggressive, well-connected in the Russian and CIS markets." He stated that Sorokin was a Russian-American dual national who joined DTI in 2018 and quickly established herself as the top revenue producer on the trading desk.

X. Events Following April 6, 2022 (OFAC SDN Designation of Volkhov Industrial Group) Hargrave was asked to describe his actions and awareness in the period following the April 6, 2022 OFAC designation of Volkhov Industrial Group JSC as a Specially Designated National. He provided the following chronology. Hargrave stated that he first learned of the Volkhov Industrial Group SDN designation from a general industry new

XI. Hargrave's Characterization of His Conduct Throughout the interview, Hargrave maintained that he did not knowingly transact with sanctioned entities or their affiliates. He was consistent in this position and returned to it multiple times, particularly when confronted with specific documentary evidence or lines of questioning that suggested a greater degree of knowledge or involvement than he acknowledged. Hargra

1. Sorokin's failure to disclose the Petronova-Volkhov connection. Hargrave stated that Sorokin was the person with the closest relationship to Petronova and Sergei Volkov, and that if anyone within DTI was aware of a connection between Petronova and Volkhov Industrial Group, it would have been Sorokin. He maintained that Sorokin did not disclose any such connection to him at any time.

2. Inadequate compliance infrastructure at DTI in Dubai. Hargrave acknowledged that the absence of a dedicated compliance officer at the DTI Dubai office created a gap in the company's ability to monitor and oversee compliance in real time. He stated that the reliance on remote compliance oversight from Houston was insufficient given the volume and complexity of DTI's trading activities.

3. Gerald Fisk's failure to implement effective OFAC screening protocols and third-party due diligence for DTI counterparties. Hargrave stated that Fisk, as Chief Compliance Officer, bore responsibility for ensuring that the company's sanctions screening and counterparty due diligence processes were adequate. He suggested that Fisk's failure to identify the Petronova-Volkhov connection during the counterparty onboard

XII. Credibility Assessment and Observations The following credibility assessment and observations are provided by Victoria Chambers, Responsible Partner, for the internal use of the investigation team and are based on her evaluation of Hargrave's demeanor, responsiveness, and the consistency of his statements with the documentary record developed to date. These observations are attorney work product and are not inte

XIII. Documents Reviewed During the Interview The following documents were shown to or discussed with Hargrave during the course of the May 25, 2022 interview:

1. Summary Schedule of Crude Oil Swap Transactions. A tabular summary prepared by the investigation team identifying 14 crude oil swap transactions between DTI and Petronova Trading FZE, and 2 crude oil swap transactions between DTI and Zenith Petroleum DMCC, executed during the period from June 2020 through February 2022, with an aggregate notional value of approximately $218.7 million. The schedule included transac

2. Sample Trade Tickets. Representative trade tickets for selected transactions from the above schedule, bearing Hargrave's electronic approval notations or initials. Hargrave confirmed recognition of his approval markings on each trade ticket presented.

3. Petronova Trading FZE Counterparty Onboarding File. The counterparty onboarding file for Petronova Trading FZE, including the completed counterparty onboarding form, corporate registration documents, and OFAC screening results dated approximately early 2020. Hargrave confirmed he had not previously reviewed this file personally.

4. Preliminary Excerpts from Crescent Commercial Bank PJSC Wire Transfer Records. Preliminary extracts of wire transfer records obtained from Crescent Commercial Bank PJSC and provided to the investigation team by Ridgeline Advisory Group. The excerpts highlighted the intermediary account structure identified in Ridgeline's preliminary analysis, including the $34.2 million in payments across 127 individual transactio

5. Sample End-User Certificates for Caspian Logistik GmbH Equipment Shipments. End-user certificates associated with selected oilfield equipment shipments facilitated through Caspian Logistik GmbH. Certain certificates contained references to end-users that the investigation team has identified as potentially connected to Volkhov Industrial Group JSC.

6. DTI Organizational Chart (Q1 2022). The organizational chart for Dunmore Trading International Ltd. as of the first quarter of 2022, reflecting the reporting structure described by Hargrave during the interview. All documents presented to Hargrave during the interview are maintained in the investigation team's secure document repository under Matter No. 1016-00009, Interview Subfolder (Hargrave — May 25, 2022).

XIV. Follow-Up Items and Open Questions Based on the substance of Hargrave's interview, the following follow-up items and open questions have been identified for further investigation:

1. Cross-reference with Natasha Sorokin interview. Hargrave's statements regarding Sorokin's role as the "primary architect" of the Petronova relationship, her handling of day-to-day communications with Sergei Volkov, and her alleged failure to disclose any Petronova-Volkhov connection must be tested against Sorokin's own account. Sorokin's interview is currently scheduled for June 2, 2022.

2. Hargrave's personal communications with Sergei Volkov. Obtain and review Hargrave's personal email, text messages, and encrypted messaging application records (including Meridian Services Inc. and Kestrel Data Systems) for any direct communications with Sergei Volkov that bypassed Sorokin. Hargrave's claim that he did not have regular direct communications with Volkov should be verified against the electronic reco

4. Gerald Fisk interview — compliance escalations. Confirm with Gerald Fisk whether Fisk raised any compliance concerns with Hargrave regarding Petronova Trading FZE, Zenith Petroleum DMCC, or Russian-nexus transactions at any time prior to April 2022. Fisk's interview is currently scheduled for June 8, 2022. Catherine Blackthorn of Blackthorn & Associates LLP will attend as Fisk's personal counsel.

5. Rajesh Malhotra — payment authorization protocols. Obtain Rajesh Malhotra's records regarding payment authorization protocols at DTI, including the specific procedures for preparing and approving wire transfer instructions. Determine whether Malhotra provided Hargrave with reports or documentation that disclosed the use of intermediary accounts in the payment chain for Petronova and Zenith Petroleum transactions.

6. Callum Renshaw — compliance officer recommendation. Analyze Hargrave's claim that he raised the need for a dedicated compliance officer at DTI's Dubai office with CEO Callum Renshaw in approximately late 2021. Cross-check this claim against Renshaw's interview memorandum. Renshaw's interview was conducted on May 23, 2022, and the memorandum should be reviewed for any corroboration or contradiction of Hargrave's ac

7. Schedule re-interview of Hargrave. A second-round interview of Hargrave should be scheduled for August or September 2022. By that time, the forensic accounting results from Ridgeline Advisory Group (Engagement No. RAG-2022-0319) should be available, and the document review being conducted by Nexagen Analytics (Project No. NX-DEH-2204) should be substantially complete. The re-interview should be designed to test Ha

8. Individual exposure assessment. Assess Hargrave's potential individual exposure under the International Emergency Economic Powers Act ("IEEPA"), 50 U.S.C. §§ 1701–1706, and the Export Control Reform Act of 2018 ("ECRA"), 50 U.S.C. §§ 4801–4852, in light of his U.S. permanent resident status, his personal approval authority over the DTI transactions at issue, and the evidence developed to date. This assessment shou