Contract analysis

I. Interview Logistics Witness: Omar Al-Rashidi, Head of Middle East Operations, Dunmore Trading International Ltd. ("DTI"), a wholly-owned subsidiary of Dunmore Energy Holdings Ltd. ("Dunmore" or the "Company"). Date of Interview: June 14, 2022. Time: 9:00 a.m. to 1:45 p.m. Gulf Standard Time (GST). The interview lasted approximately four hours and forty-five minutes, including one fifteen-minute break taken at appr

II. Upjohn Warnings Administered At the outset of the interview, prior to any substantive questioning, Jasmine Thornton administered the standard Upjohn corporate Miranda warning to Mr. Al-Rashidi. The warnings were delivered in accordance with the Witness Interview Protocol dated April 18, 2022, which was prepared by Victoria Chambers and distributed to all members of the Calderwood & Harkness investigation team. Th

1. Identity of the Client. Calderwood & Harkness LLP represents Dunmore Energy Holdings Ltd. and its subsidiaries, including Dunmore Trading International Ltd. Calderwood & Harkness does not represent Mr. Al-Rashidi in his personal capacity. The firm's obligations of loyalty, confidentiality, and advocacy run to the Company, not to Mr. Al-Rashidi individually.

2. Purpose of the Interview. The purpose of this interview is to gather facts in connection with an internal investigation being conducted by Calderwood & Harkness at the direction of Dunmore's General Counsel, Marcus Wellbourne, in connection with a United States Department of Justice inquiry concerning potential violations of U.S. sanctions laws and export control regulations. The investigation is being conducted t

3. Ownership of the Privilege. The attorney-client privilege applicable to the communications in this interview belongs to Dunmore Energy Holdings Ltd. and its subsidiaries, not to Mr. Al-Rashidi personally. Mr. Al-Rashidi does not have the right to assert or waive the privilege with respect to the substance of this interview.

4. Potential Waiver and Disclosure to Government. Dunmore may, at its sole discretion, choose to waive the attorney-client privilege and disclose the substance of this interview, including Mr. Al-Rashidi's statements, to the U.S. Department of Justice, the Office of Foreign Assets Control ("OFAC") of the U.S. Department of the Treasury, or other government agencies. Such a decision would be made by the Company's auth

5. Obligation of Truthfulness. Mr. Al-Rashidi is expected to be truthful and complete in his responses to all questions posed during this interview. Providing false or misleading information could have serious consequences, including potential adverse employment actions and potential legal liability.

6. Right to Personal Counsel. Mr. Al-Rashidi has the right to retain personal legal counsel at his own expense. He may also seek advancement of legal fees under Dunmore's existing indemnification obligations, subject to the terms and conditions of the applicable corporate documents and policies. Mr. Al-Rashidi acknowledged that he understood this right and affirmatively stated that he did not wish to retain personal

7. Confidentiality of Interview. Mr. Al-Rashidi was instructed not to discuss the substance of this interview, the questions asked, or his responses with other Dunmore or DTI employees, former employees, or any third parties. He was advised that unauthorized disclosure of the contents of this interview could compromise the integrity of the investigation and could result in adverse consequences. Mr. Al-Rashidi confirm

III. Background and Role at DTI A. Personal Background Mr. Al-Rashidi provided the following personal background information. His full name is Omar Al-Rashidi. He is a national of the United Arab Emirates (Emirati citizen). He is approximately 41 years of age at the time of this interview. He holds a Bachelor's degree in Business Administration from a university in the UAE and a Master of Business Administration (MBA

IV. Knowledge of Key Counterparties A. Petronova Trading FZE Mr. Al-Rashidi stated that he first became aware of Petronova Trading FZE ("Petronova") in approximately early 2020, which he estimated as around March 2020. This timeframe is consistent with the earliest suspect transaction in the investigation timeline identified by the Calderwood & Harkness team and the Ridgeline Advisory Group forensic analysis. Mr. Al-

1. First Meeting (estimated late 2020): A business dinner in Dubai arranged by Sorokin. Mr. Al-Rashidi recalled that the dinner took place at a restaurant in the DIFC area and was attended by Sorokin, Volkov, Al-Rashidi, and possibly one or two other DTI staff members. He described the dinner as primarily social and relationship-building in nature. He stated that Volkov was cordial and presented himself as an experie

2. Second Meeting (estimated mid-2021): A meeting at DTI's offices in the DIFC. Mr. Al-Rashidi believed this meeting was arranged by Sorokin to discuss ongoing trading activity. He recalled that Hargrave may also have attended this meeting, but he was not entirely certain of Hargrave's presence. Mr. Al-Rashidi described Volkov as a Russian national residing in the United Arab Emirates who presented himself as a commo

V. Description of Trading Desk Operations and Transaction Approval Process A. General Trading Desk Structure Mr. Al-Rashidi provided a description of DTI's Dubai trading desk operations that is relevant to understanding the context in which the transactions at issue were executed. He described the DTI Dubai trading desk as a relatively small operation, comprising approximately 15 to 20 staff members in total, includi

1. Deal Identification: Traders, primarily Sorokin, would identify a transaction opportunity through counterparty outreach, market monitoring, or inbound inquiries. The trader would conduct initial discussions with the counterparty to establish the basic commercial terms.

2. Deal Ticket Preparation: Upon reaching preliminary agreement on commercial terms, the trader would prepare a deal ticket summarizing the key terms of the transaction, including the counterparty identity, the commodity involved, the notional value, pricing terms, delivery or settlement terms, and any other material provisions.

3. Counterparty Screening: Prior to execution, the counterparty was supposed to be screened against OFAC sanctions lists and other applicable restricted party lists using Dunmore's sanctions screening software. This screening was administered from Houston by the compliance team under Gerald Fisk. A screening request would be submitted, and the compliance team would return a clearance or flag any potential matches.

4. Approval by Hargrave: For transactions above a certain threshold, which Mr. Al-Rashidi believed to be $10 million in notional value, Hargrave was required to approve the deal in writing, typically via email. For transactions below this threshold, Mr. Al-Rashidi was less certain of the formal approval requirements but stated that Hargrave was generally informed of all transactions.

5. Execution: Upon receipt of Hargrave's approval (and, nominally, compliance clearance), the trader would execute the transaction with the counterparty. Mr. Al-Rashidi noted, however, that the described workflow was the nominal or intended process. In practice, he observed several departures from this process that he considered significant in the context of the current investigation. Specifically, Mr. Al-Rashidi sta

VI. Knowledge of Payment Structuring A. Awareness of Crescent Commercial Bank Payment Flows Mr. Al-Rashidi confirmed that Crescent Commercial Bank PJSC ("Crescent Bank") was DTI's primary trade finance bank in the Dubai region. He identified the bank's head office as located in Al Maktoum Tower, DIFC, and confirmed that DTI's relationship manager at Crescent Bank was Khalid Mansour. Mr. Al-Rashidi described Crescent

VII. Knowledge of Derek Hargrave's and Natasha Sorokin's Activities A. Derek Hargrave Mr. Al-Rashidi provided substantive observations regarding Derek Hargrave's management style, involvement with key counterparties, and conduct during the relevant period. These observations are relevant to the investigation's assessment of Hargrave's role in the transactions at issue. Mr. Al-Rashidi described Hargrave as a "hands-on

VIII. Knowledge of Compliance Function and Gerald Fisk A. Pre-Existing Compliance Program Mr. Al-Rashidi provided his assessment of Dunmore's pre-existing sanctions compliance program as it operated during the period relevant to this investigation. His observations are relevant to the investigation's evaluation of the adequacy of the Company's compliance infrastructure and any potential defenses based on the existenc

1. Introduction of Petronova through Personal Connections: Petronova Trading FZE was introduced to DTI's trading desk by Natasha Sorokin through what appeared to be her personal or pre-existing professional connections, rather than through DTI's standard counterparty onboarding process. Mr. Al-Rashidi acknowledged that the use of personal connections to introduce a counterparty, while not inherently improper, should

2. Surname Similarity Between "Volkov" and "Volkhov." The similarity between the surname of Petronova's Managing Director (Sergei Volkov) and the name of the sanctioned Russian conglomerate (Volkhov Industrial Group / Arkady Volkhov) should have been recognized as a potential indicator of a relationship between the two entities. Mr. Al-Rashidi acknowledged that this similarity did not register with him at the time an

3. Volume and Pattern of Payments Through Crescent Commercial Bank. The volume of individual wire transfers (127 transactions for $34.2 million) relative to the number of underlying commercial transactions was disproportionate and suggestive of payment structuring. Mr. Al-Rashidi acknowledged that his observation of Malhotra "splitting payments" was consistent with this concern and should have been escalated.

4. Hargrave's Protectiveness Over the Petronova Relationship. Hargrave's discouragement of independent due diligence on Petronova and his insistence on personally managing compliance inquiries related to Petronova were unusual and should have been recognized as potential indicators that Hargrave was seeking to limit scrutiny of the relationship.

5. Sorokin's Use of Personal Encrypted Messaging. The use of personal encrypted messaging applications for what may have been business communications with counterparties was inconsistent with the Company's records retention policies and could have been motivated by a desire to avoid corporate oversight of those communications. Mr. Al-Rashidi stated that he did not escalate any of these concerns during the relevant pe

IX. Knowledge of Oilfield Equipment Exports Mr. Al-Rashidi stated that the oilfield equipment export activities under investigation were primarily managed by Yves Leclerc, Director of Logistics & Shipping at DTI, under the direction of Derek Hargrave. Mr. Al-Rashidi's involvement in these activities was minimal. He stated that he was generally aware that DTI facilitated shipments of oilfield drilling equipment and re

X. Knowledge of Tobias Engel and Dunmore Renewables GmbH Transaction When asked about any knowledge of transactions involving Dunmore Renewables GmbH, a Dunmore subsidiary based in Hamburg, Germany, and managed by Tobias Engel, Mr. Al-Rashidi stated that he had no knowledge of any such transactions. Specifically, he stated that he was not aware of any transaction between Dunmore Renewables GmbH and Caspian Logistik G

XI. Post-April 2022 Events and Cooperation A. Discovery of Potential Volkhov Exposure Mr. Al-Rashidi provided the following account of the events following the discovery of DTI's potential exposure to Volkhov Industrial Group. He confirmed that on or about April 11, 2022, Gerald Fisk sent an internal email to Dunmore personnel, including recipients at the DTI Dubai office, alerting them that a routine OFAC screening

XII. Documents Identified / Requested for Follow-Up During the course of the interview, the investigation team identified several categories of documents and materials that Mr. Al-Rashidi agreed to provide access to for purposes of the investigation:

1. DTI Email Archive: Mr. Al-Rashidi agreed to provide access to his complete DTI email archive for the period from January 2019 to the present. This collection will be performed by Nexagen Analytics Inc. (Project No. NX-DEH-2204), the e-discovery vendor engaged by Calderwood & Harkness for this matter. Mr. Al-Rashidi stated that he will cooperate with Nexagen's technical team to facilitate the collection process.

2. Personal Notes and Files Relating to Petronova: Mr. Al-Rashidi agreed to identify and produce any personal notes, memoranda, or files in his possession relating to meetings with Sergei Volkov, other Petronova representatives, or the Petronova counterparty relationship generally.

3. Calendar Entries: Mr. Al-Rashidi agreed to provide access to his electronic calendar entries for the period 2020 through 2022, with particular attention to entries reflecting meetings with counterparties, including Petronova, Zenith Petroleum, Crescent Commercial Bank, and any other relevant third parties.

4. Personal Device Communications: Mr. Al-Rashidi agreed to provide access to any text or messaging communications on his personal devices that relate to DTI business. He stated that he primarily used his DTI-issued devices (laptop, mobile phone) for business communications and that he did not use personal encrypted messaging applications for DTI matters. This stands in contrast to the reported practices of Natasha S

XIII. Credibility and Cooperation Assessment Overall Assessment: Mr. Al-Rashidi was forthcoming, composed, and detailed in his responses throughout the approximately four hours and forty-five minutes of the interview. He answered questions directly and, where he did not have specific knowledge, clearly delineated the boundaries of his awareness without attempting to speculate or fill gaps with conjecture. He did not