Contract analysis

1. Interview Summary and Overview This memorandum summarizes the interview of Yves Leclerc, a French national currently serving as Director of Logistics & Shipping at Dunmore Trading International Ltd. ("DTI"), a subsidiary of Dunmore Energy Holdings Ltd. ("Dunmore" or the "Company"). Mr. Leclerc is based in Dubai, United Arab Emirates. The interview was conducted in connection with the internal investigation initiat

2. Upjohn / Corporate Miranda Warning At the outset of the interview, prior to any substantive questioning, Amara Osei administered the Upjohn corporate Miranda warning to Mr. Leclerc. The warning was delivered orally and in accordance with the Witness Interview Protocol & Upjohn Warning Script dated April 18, 2022, which was prepared by Victoria Chambers and approved by the investigation team for use in all witness

3. Background and Role of Yves Leclerc 3.1 Personal Background Mr. Leclerc is a French national. He was born and raised in Marseille, France. He holds a degree in logistics and supply chain management from a French university (he identified the institution but the specific name was not recorded by the interviewer in contemporaneous notes; this detail can be confirmed in a follow-up). He also holds an MBA or equivalen

4. Leclerc's Knowledge of and Involvement with Caspian Logistik GmbH 4.1 Introduction to Caspian Logistik GmbH Mr. Leclerc was asked to describe his knowledge of and dealings with Caspian Logistik GmbH, a company registered at Mönckebergstraße 22, 20095 Hamburg, Germany, and managed by Klaus Weidemann, a German national. This entity is a central focus of the investigation. Mr. Leclerc stated that Caspian Logistik Gmb

5. Leclerc's Knowledge of Petronova Trading FZE and Volkhov Industrial Group 5.1 Petronova Trading FZE Mr. Leclerc was asked about his knowledge of Petronova Trading FZE, a company registered at Office 1407, Al Shafar Tower, Dubai Internet City, Dubai, UAE. Mr. Leclerc stated that he was aware of Petronova as a counterparty in DTI's crude oil trading operations. He identified Sergei Volkov, a Russian national and UAE

6. Leclerc's Awareness of Sanctions and Export Control Requirements 6.1 Training and Compliance Knowledge Mr. Leclerc was asked in detail about the compliance training he had received during his employment at DTI and his general understanding of sanctions and export control obligations. Mr. Leclerc recalled receiving one general compliance training session when he first joined DTI in 2016. He described this training

7. Leclerc's Relationship with Derek Hargrave and Natasha Sorokin 7.1 Reporting Structure and Dynamics Mr. Leclerc reported directly to Derek Hargrave, President of DTI, throughout the relevant period. He described Hargrave as a hands-on manager who closely controlled the trading desk's operations and exercised personal authority over key counterparty relationships, deal structuring, and commercial strategy. Mr. Lecl

8. Leclerc's Knowledge of Dunmore Renewables GmbH Connection Mr. Leclerc was asked about one particular transaction involving Dunmore Renewables GmbH (registered at Überseeallee 12, 20457 Hamburg, Germany; Managing Director: Tobias Engel) and Caspian Logistik GmbH. Mr. Leclerc stated that he was aware of a single shipment of equipment that was originally booked through Dunmore Renewables GmbH — a separate Dunmore sub

9. Leclerc's Knowledge of Payment Flows and Crescent Commercial Bank Mr. Leclerc was asked about his knowledge of the payment flows associated with the Caspian Logistik shipments and DTI's banking arrangements more broadly. Mr. Leclerc stated that he was not directly involved in payment authorization or processing for the transactions in question. Payments, including trade finance arrangements such as letters of cred

10. Zenith Petroleum DMCC Mr. Leclerc was asked about his knowledge of Zenith Petroleum DMCC, a company registered at Unit 2201, Jumeirah Bay Tower X2, Cluster X, Jumeirah Lakes Towers, Dubai, UAE, with Farhan Qureshi serving as Managing Director. Mr. Leclerc stated that Zenith Petroleum was known to him as a counterparty in DTI's crude oil swap transactions. However, he described his logistics involvement with Zenit

11. Document Preservation Mr. Leclerc confirmed that he received the litigation hold notice dated April 20, 2022, issued by Calderwood & Harkness LLP to all relevant Dunmore and DTI personnel in connection with the DOJ inquiry and the internal investigation. A copy of the litigation hold notice issued to Mr. Leclerc is attached as Appendix B. Mr. Leclerc stated that, upon receipt of the hold notice, he took steps to

12. Credibility Assessment and Counsel's Observations Based on the approximately three-and-a-quarter-hour interview, the undersigned offers the following assessment of Mr. Leclerc's credibility and the significance of his testimony to the broader investigation: Demeanor and Cooperativeness. Mr. Leclerc appeared cooperative and candid throughout the interview. He responded to questions directly and without undue hesit

13. Follow-Up Items The following action items have been identified in connection with this interview and should be assigned and tracked by the investigation team:

1. Email Correspondence with Klaus Weidemann. Obtain and review all emails between Yves Leclerc and Klaus Weidemann (Caspian Logistik GmbH) from August 2020 through January 2022. Coordinate with the Nexagen Analytics document review team to prioritize the identification, collection, and review of these communications within the broader document corpus.

2. End-User Certificates. Obtain and review all end-user certificates processed by Leclerc for shipments routed through Caspian Logistik GmbH during the relevant period. Cross-reference these certificates with the Nexagen Analytics document collection (Project No. NX-DEH-2204) and the Ridgeline Advisory Group forensic analysis to determine which certificates contain potentially false statements regarding the ultimate

3. Shipping Instruction Files and Bills of Lading. Obtain Mr. Leclerc's shipping instruction files, bills of lading, freight invoices, and related logistics documentation for the approximately $12.4 million in oilfield equipment exports shipped through Caspian Logistik. These documents should be analyzed for routing anomalies, discrepancies between stated and actual destinations, and evidence of diversion.

4. Follow-Up Interview. Schedule a follow-up interview with Mr. Leclerc after the completion of the Caspian Logistik export shipment analysis (expected July 2022) and the Ridgeline Advisory Group forensic accounting report (Engagement No. RAG-2022-0319). The follow-up interview should focus on specific transactions identified as potentially problematic by the document review and forensic analysis.

5. DOJ Proffer Assessment. Assess whether Mr. Leclerc should be included in the DOJ proffer process as a cooperative witness, potentially alongside Omar Al-Rashidi. This assessment should be made by Victoria Chambers and Jasmine Thornton in consultation with Conrad Reeves, taking into account Mr. Leclerc's level of culpability, his potential value as a witness, and the strategic considerations relating to the Company

6. EAR §746.5 Analysis. Coordinate with Conrad Reeves on the application of EAR §746.5 to Mr. Leclerc's specific shipments and the ECCN 2B350 and 2B999 classifications. Determine whether any of the shipments for which Leclerc coordinated logistics required export licenses that were not obtained.

7. Personal Counsel for Leclerc. Determine whether Mr. Leclerc should be advised to retain personal counsel. This determination should be made by Victoria Chambers based on the evolving risk assessment, including whether Mr. Leclerc faces potential individual exposure under U.S. or UAE law. If the decision is made to recommend personal counsel, the logistics of communication and joint defense arrangements should be c

14. Attachments / Appendices (Referenced) The following documents are referenced in this memorandum and are maintained in the investigation team's files: Appendix A: Witness Interview Protocol & Upjohn Warning Script (dated April 18, 2022, prepared by Victoria Chambers). Appendix B: Litigation Hold Notice issued to Yves Leclerc (dated April 20, 2022, issued by Calderwood & Harkness LLP). Appendix C: Sample end-user c