Contract analysis

I. Upjohn Warning and Preliminary Matters At the outset of the interview, the undersigned advised Sandra Whitfield in accordance with the firm's standard Upjohn corporate Miranda warning protocol, as set forth in the Witness Interview Protocol dated April 18, 2022, prepared by Victoria Chambers, Responsible Partner for the Dunmore internal investigation. The warning was administered orally, and Ms. Whitfield was prov

II. Background and Role Ms. Whitfield provided the following background information regarding her employment and responsibilities at Dunmore Energy Holdings Ltd. Full Name: Sandra Whitfield Title: Chief Financial Officer, Dunmore Energy Holdings Ltd. ("DEH") Office Location: Houston, Texas — Dunmore operational headquarters, located at 1200 McKinney Street, Suite 3400, Houston, TX 77010. Tenure at Dunmore: Ms. Whitfi

III. Familiarity with Dunmore Trading International Ltd. (DTI) Operations Ms. Whitfield was asked to describe her familiarity with the operations of Dunmore Trading International Ltd. ("DTI"), the Dubai-based trading subsidiary that is the primary focus of the internal investigation. Ms. Whitfield described DTI as a significant revenue center for the Dunmore group. DTI holds DIFC License No. CL-4827 and maintains off

IV. Financial Reporting Oversight of DTI Trading Activity Ms. Whitfield was asked in greater detail about the financial reporting and internal controls applicable to DTI's trading operations, with a particular focus on the mechanisms available to the Houston finance team to monitor DTI's trading activity and identify potential irregularities. Ms. Whitfield stated that DTI's trading transactions were recorded in DTI's

V. Knowledge of Specific Counterparties and Transactions at Issue Ms. Whitfield was asked about her knowledge of the specific counterparties and transactions that are the focus of the internal investigation and the DOJ inquiry. Her responses are summarized below for each counterparty. A. Petronova Trading FZE Ms. Whitfield stated that she was generally aware that Petronova Trading FZE was a counterparty of DTI in the

VI. Knowledge of Payment Flows Through Crescent Commercial Bank PJSC Ms. Whitfield was asked about DTI's banking relationships, with a particular focus on Crescent Commercial Bank PJSC, a Dubai-based commercial bank identified in the forensic investigation as the institution through which certain suspect payment flows were routed. Ms. Whitfield confirmed that she was aware that DTI maintained accounts at Crescent Com

VII. Relationship with Gerald Fisk (Former CCO) and Compliance Oversight Ms. Whitfield was asked about her interactions with Gerald Fisk, the former Chief Compliance Officer of Dunmore Energy Holdings Ltd. The undersigned noted for the record that Fisk departed the Company on June 10, 2022, and is represented by personal counsel, Catherine Blackthorn of Blackthorn & Associates LLP, Houston, Texas. Ms. Whitfield state

VIII. Awareness of Export Control Requirements Ms. Whitfield was asked about her awareness of export control requirements applicable to Dunmore's business, specifically the Export Administration Regulations ("EAR") administered by the Bureau of Industry and Security ("BIS") of the U.S. Department of Commerce. The undersigned asked Ms. Whitfield about her familiarity with EAR §746.5, which imposes restrictions on expo

IX. Involvement with Dunmore Renewables GmbH Transaction Ms. Whitfield was briefly asked about the transaction involving Dunmore Renewables GmbH, a Hamburg-based subsidiary of DEH engaged in renewable energy development, and Caspian Logistik GmbH. The investigation team had identified a transaction or series of transactions between Dunmore Renewables and Caspian Logistik that warranted further inquiry. Ms. Whitfield

X. Internal Controls and Financial Statement Implications Ms. Whitfield was asked to provide her assessment of the adequacy of Dunmore's internal controls over financial reporting, particularly as they relate to trade finance transactions at the DTI subsidiary level, in light of the findings emerging from the forensic investigation. Ms. Whitfield acknowledged, candidly, that the internal controls framework as of Apri

XI. Board and Shareholder Communications Ms. Whitfield was asked about the timing and substance of communications with the Board of Directors and the Company's principal shareholders regarding the DOJ inquiry and the internal investigation. Ms. Whitfield confirmed that the Board was notified promptly after the grand jury subpoena, GJ No. 22-418, was received on April 19, 2022. She stated that CEO Callum Renshaw and G

XII. D&O Insurance Ms. Whitfield was briefly asked about the Company's directors and officers liability insurance coverage in connection with the current matter. She confirmed that Dunmore Energy Holdings Ltd. maintains directors and officers liability insurance ("D&O Insurance") through Garrison Mutual Insurance Co., a Bermuda-domiciled insurer. The policy is identified as Policy Number GM-DO-2021-08734. The policy

XIII. Document Preservation and Cooperation Ms. Whitfield confirmed that she is fully complying with the litigation hold notice issued on April 20, 2022, and that she has preserved all potentially relevant documents in her possession, custody, or control. This includes, without limitation, emails (both archived and current), electronic files on shared drives and local storage, financial reports and workpapers, Board

XIV. Interviewer's Assessment and Follow-Up Items A. Credibility Assessment Ms. Whitfield appeared forthcoming, cooperative, and consistent in her responses throughout the approximately two-and-a-half-hour interview. She answered questions directly, acknowledged the limits of her knowledge where appropriate, and did not appear evasive or defensive. She volunteered information on several occasions without prompting, i

1. No Direct Involvement in Suspect Transactions. Ms. Whitfield had no direct involvement in the suspect transactions involving Petronova Trading FZE, Zenith Petroleum DMCC, or Caspian Logistik GmbH. None of the flagged transactions required her personal approval under the delegation of authority framework. She had no knowledge of the Volkhov connection prior to the commencement of the investigation.

2. Summary-Level Financial Reporting. Financial reporting from DTI to the Houston finance team was at a summary level and did not provide visibility into individual counterparty beneficial ownership, payment routing through intermediary bank accounts, or end-user certifications for equipment shipments. The reporting framework was designed for consolidation and performance monitoring purposes, not for compliance monit

3. Material Internal Control Gaps. The internal controls framework as of April 2022 had material gaps with respect to trade finance transaction monitoring at the subsidiary level. These include the absence of beneficial ownership tracking in the accounting system, the lack of individual wire transfer reviews at the Houston level, and the three-year gap in internal audit coverage of DTI's trade finance operations.

4. Under-Resourced Compliance Function. The compliance function under Gerald Fisk appears to have been under-resourced, with only three compliance professionals covering the entire global Dunmore enterprise. This staffing level appears inadequate relative to the complexity and risk profile of the organization, particularly given the high-risk nature of DTI's commodity trading operations in the Middle East and Central

5. Prompt Board and Shareholder Communications. Board and shareholder communications regarding the DOJ inquiry were handled promptly following receipt of the grand jury subpoena, and the Board authorized the internal investigation and related expenditures in a timely manner. C. Follow-Up Items The following follow-up items have been identified based on the Whitfield interview:

1. Quarterly Counterparty Exposure Reports. Obtain and review the quarterly counterparty exposure reports presented to the Board of Directors for the period 2020 through 2022 to assess what information regarding the flagged counterparties was available to Ms. Whitfield and the Board during the relevant period.

2. Monthly Reporting Packages from Rajesh Malhotra. Obtain Rajesh Malhotra's monthly reporting packages submitted to the Houston finance team for the period March 2020 through April 2022 to determine what financial information was communicated from DTI to Houston and whether the suspect transactions were identifiable from the reporting data.

3. Forensic Accounting Analysis — Net Profit Margins. Coordinate with Ridgeline Advisory Group LLC (engagement lead Dr. Margaret Liu, engagement number RAG-2022-0319) regarding the net profit margin analysis for the tainted transactions to determine the actual P&L and financial statement impact, as distinguished from the gross notional values.

4. Financial Statement Disclosure Implications. Confirm with Ashford & Whitmore LLP (engagement partner Kenneth Ashford) the status of the assessment regarding potential financial statement disclosure implications, including the need for any restatement, adjustment, or supplemental disclosure.

5. Potential Follow-Up Interview. Consider whether a follow-up interview of Ms. Whitfield is warranted after the forensic accounting findings from Ridgeline Advisory Group are available and the investigation team has reviewed the documentary evidence referenced in this memorandum.

6. Internal Audit Documentation. Request documentation of the internal audit function's last review of DTI's trade finance operations, which Ms. Whitfield stated was conducted in 2019. Obtain the audit report, workpapers, and any management responses to assess the scope of the 2019 audit and whether any deficiencies were identified at that time.

XV. Certification and Distribution This memorandum was prepared based on the undersigned's recollection of the interview and the contemporaneous notes taken by Elena Vasquez, Paralegal Manager. It has been reviewed for accuracy and completeness. It is not a verbatim transcript of the interview. Prepared by: ________________________________________ Nicholas Ferreira Associate, White Collar & Investigations Calderwood