Contract analysis

I. Purpose of This Letter and Acknowledgment of Your Demand Letter We write on behalf of our client, the Board of Directors of Aurelius Global Media Group PLC ("AGMG"), a public limited company incorporated in England and Wales and listed on the London Stock Exchange, in connection with the matter referenced above. We hereby acknowledge receipt of your demand letter dated April 20, 2023, sent on behalf of your client

II. Description of the Independent Investigation The AGMG Board of Directors, acting through a joint directive of its People & Culture Committee and its Audit & Risk Committee, has retained Calderwood & Harkness LLP to conduct an independent, privileged workplace investigation into the allegations of sexual harassment, retaliation, and hostile work environment raised by Ms. Morales and, to the extent relevant, any ad

III. Scope and Methodology of the Investigation The investigation is designed to be thorough, fair, and impartial, consistent with AGMG's obligations under California law and its own internal policies. To that end, the investigation will encompass the following principal components: Witness Interviews. Calderwood & Harkness will conduct interviews of all relevant witnesses, including complainants, the subject of the

IV. Interim Protective Measures Already Taken We wish to inform you of the interim protective measures that AGMG and APS have already implemented in response to the allegations raised by Ms. Morales, pending the completion of the investigation. Administrative Leave of the Subject. The subject of the investigation, Marcus Hale, President of Aurelius Pacific Studios Inc., was placed on paid administrative leave effecti

V. Ms. Morales's Participation in the Investigation Calderwood & Harkness intends to request an interview with Ms. Morales as part of the investigation. Ms. Morales's account is of central importance to the investigation, and we believe that her participation will materially contribute to a thorough and accurate assessment of the facts. We wish to confirm that Ms. Morales's participation in the investigation is entir

VI. Commitment to Non-Retaliation AGMG and APS are firmly committed to ensuring that no retaliation of any kind is taken against Ms. Morales for raising her complaints, filing her Ethics & Compliance Hotline report, retaining outside counsel, sending her demand letter, or participating in the investigation in any capacity. This commitment is grounded in both company policy and applicable law. APS's Anti-Retaliation P

VII. Limitations on Disclosure Because the investigation is privileged, ongoing, and not yet complete, Calderwood & Harkness is not in a position to share with outside parties—including counsel for complainants—the substance of witness interviews, the content of documentary evidence collected or reviewed, or any interim findings, assessments, or conclusions that may have been reached during the course of the investig

VIII. Point of Contact for Future Communications Bernard Crawford, Partner at Calderwood & Harkness LLP, has been designated as the sole point of contact for all communications relating to the investigation on behalf of AGMG and APS. Mr. Crawford may be reached at the following: Bernard Crawford, Partner Calderwood & Harkness LLP 1999 Avenue of the Stars, Suite 2800 Los Angeles, California 90067 Direct Telephone: (31

IX. Reservation of Rights AGMG and APS expressly reserve all rights, privileges, immunities, and defenses available to them under applicable law, whether arising under statute, common law, contract, or equity. Nothing in this letter, and no action taken by AGMG, APS, or Calderwood & Harkness in connection with the investigation or otherwise, should be construed as an admission of liability, an acknowledgment that any