Contract analysis

I. PURPOSE AND BACKGROUND A. Purpose of This Memorandum The purpose of this memorandum is to establish the document review workflow, coding taxonomy, privilege-logging procedures, quality control protocols, and escalation procedures for the review of electronically stored information ("ESI") collected in connection with the privileged independent workplace investigation commissioned by the Board of Directors of Aurel

II. DATA COLLECTION SUMMARY A. Custodians A total of nine (9) custodians were identified for forensic collection by Linden Forensics. The custodians were selected based on preliminary information provided by the complainants, information gathered from Fiona Blackwood and Victor Gallegos, a review of APS organizational charts, and the professional judgment of the investigation team regarding individuals likely to poss

1. Marcus Hale — President, Aurelius Pacific Studios Inc. (subject of investigation)

2. Jenna Morales — Vice President of Development, Aurelius Pacific Studios Inc. (primary complainant)

3. Claire Ngo — Senior Director of Talent Relations, Aurelius Pacific Studios Inc. (complainant)

4. Darren Whitfield — Senior Vice President of Physical Production, Aurelius Pacific Studios Inc. (complainant — retaliation)

5. Victor Gallegos — Vice President of Human Resources, Aurelius Pacific Studios Inc.

6. Cameron Briggs — Senior Vice President of Production, Aurelius Pacific Studios Inc.

7. Ingrid Holt — Director of Compliance, Aurelius Pacific Studios Inc.

8. Rebecca Choi — Senior Vice President of Business Affairs, Aurelius Pacific Studios Inc.

9. Thomas Lindquist — Senior Vice President of Strategy & Operations, Aurelius Pacific Studios Inc. A complete custodian list, including data sources collected from each custodian, is attached as Appendix A to this memorandum. The investigation team reserves the right to identify additional custodians as the investigation progresses, particularly in light of information that may be obtained during witness interviews

III. REVIEW TEAM STAFFING A. Review Supervision Devon Archer (Lead Associate, Labor & Employment, Calderwood & Harkness LLP) and Nadia Petrov (Associate, Labor & Employment, Calderwood & Harkness LLP) will jointly supervise all aspects of the document review and serve as the primary quality-control reviewers and escalation points for issues arising during the review. Mr. Archer will serve as the primary point of cont

IV. REVIEW PLATFORM SETUP A. Platform Identification The document review will be conducted on Calderwood & Harkness's secure, cloud-based document review platform, hosted in a SOC 2 Type II-certified data center. Linden Forensics Group Inc. has loaded the processed and filtered dataset of approximately 38,600 items into the platform following de-duplication, processing, and application of the agreed-upon search terms

1. First-Level Review Workspace: This workspace will contain all approximately 38,600 filtered items, organized into batches for assignment to the contract review attorneys. Batch assignment will be managed by Archer or Petrov using the platform's batch assignment functionality.

2. Second-Level / QC Review Workspace: This workspace will contain documents escalated from first-level review (documents coded "Hot," "Potentially Relevant — Needs Further Review," and "Potentially Privileged — Needs Further Review") as well as the random samples selected for quality control review. Only Archer, Petrov, and Crawford will have access to this workspace.

3. Privilege Review Workspace: This workspace will contain all documents flagged as potentially privileged during first-level review. Privilege determinations will be made in this workspace by Archer and Petrov, with disputed calls elevated to Crawford. The privilege log will be maintained and updated from this workspace. E. Search and Analytics Tools The review platform provides the following search and analytics ca

V. CODING TAXONOMY The following coding taxonomy will be applied to all documents reviewed in connection with this investigation. All first-level reviewers must be thoroughly familiar with each code and its application before commencing review. A one-page quick reference guide summarizing the coding taxonomy is attached as Appendix C to this memorandum and should be kept readily accessible during review. A. Relevance

1. Text messages between Marcus Hale and Jenna Morales, with particular attention to messages dated November 14, 2022, November 29, 2022, and December 8, 2022, which are alleged to contain sexually suggestive content.

2. Communications of any type regarding the Vancouver production trip that took place in October 2022, including any communications regarding hotel arrangements, after-hours activities, interactions between Hale and Morales during the trip, or any complaints or reports arising from the trip.

3. Communications regarding the company dinner that took place on February 3, 2023, including any communications regarding seating arrangements, conduct during the dinner, interactions between Hale and any complainant at the dinner, and any complaints or reports arising from the dinner (including allegations of physical contact by Hale).

4. Communications regarding the Monarch Valley Resort off-site event that took place on February 17–18, 2023, in Ojai, California, including any communications regarding event planning, room assignments, conduct during the event, interactions between Hale and Claire Ngo during the event, and any complaints or reports arising from the event.

5. Emails, Meridian Solutions messages, or other communications regarding the reassignment of Project Meridian and Project Halcyon (combined production budgets of approximately $187 million) from Darren Whitfield to Cameron Briggs (Senior Vice President of Production) on or around February 6, 2023. These communications are central to the retaliation allegations and may reflect Hale's stated justifications for the rea

6. Any communications reflecting Marcus Hale's knowledge of, or response to, complaints about his conduct, whether formal or informal, at any time during the collection period.

7. Documents relating to the January 23, 2023 leadership meeting at which Darren Whitfield is alleged to have raised concerns about Hale's conduct, including meeting agendas, minutes, notes, and any communications before, during, or after the meeting.

8. Documents relating to the prior informal complaint filed by Serena Whitcomb in or around July 2021 and the verbal counseling issued to Marcus Hale by Victor Gallegos on August 2, 2021, including any written documentation of the complaint, the counseling session, any follow-up actions, or communications between HR, legal, or management regarding the complaint.

9. Communications reflecting the exclusion of Claire Ngo from talent-relations strategy meetings during March and April 2023, including meeting invitations, calendar entries, and any communications regarding the decision to exclude Ngo or to restructure the meeting participants.

10. Any document reflecting notice to, or involvement of, HR (Victor Gallegos or any other HR personnel), Compliance (Ingrid Holt or any other compliance personnel), or legal (Fiona Blackwood, in-house counsel, or any outside counsel) regarding Hale's conduct prior to the filing of the formal complaint, including any informal reports, escalations, or discussions. All documents coded "Hot" will be immediately escalate

1. Sexual Harassment — Morales This code should be applied to any document relating to allegations of sexual harassment by Hale against Jenna Morales. The following subcategories are available and should be applied where applicable: (a) Vancouver Hotel Room Invitations: Communications relating to alleged invitations by Hale to Morales to visit his hotel room during the October 2022 Vancouver production trip. (b) Text

2. Sexual Harassment — Ngo This code should be applied to any document relating to allegations of sexual harassment or exclusionary conduct by Hale against Claire Ngo. The following subcategories are available: (a) Monarch Valley Resort Comments: Communications relating to comments allegedly made by Hale to Ngo during the Monarch Valley Resort off-site event on February 17–18, 2023, in Ojai, California. (b) Meeting E

3. Retaliation — Whitfield This code should be applied to any document relating to allegations of retaliation by Hale against Darren Whitfield. The following subcategories are available: (a) January 23, 2023 Leadership Meeting: Communications relating to the leadership meeting on January 23, 2023, at which Whitfield is alleged to have raised concerns about Hale's conduct, and any communications reflecting Hale's resp

4. Prior Complaints / Whitcomb This code should be applied to any document relating to the prior informal complaint by Serena Whitcomb in or around July 2021, the verbal counseling of Hale by Gallegos on August 2, 2021, or any other prior complaints about Hale's conduct, whether formal or informal.

5. HR/Compliance Response & Escalation This code should be applied to any document reflecting the actions (or inactions) of HR (Gallegos or others), Compliance (Holt or others), or legal (Blackwood or others) in response to complaints, reports, or concerns about Hale's conduct, including any escalation decisions, investigations, or remedial measures.

6. Company Policy / Code of Conduct This code should be applied to any document that constitutes or references AGMG or APS policies relating to harassment, discrimination, retaliation, complaint procedures, workplace conduct, or related topics, including the AGMG Global Code of Conduct, the APS Employee Handbook (California Supplement), and the AGMG Board Corporate Governance Guidelines.

7. Hale Performance / Management Decisions This code should be applied to any document relating to Hale's management decisions, leadership style, performance evaluations, or business justifications for actions that are the subject of allegations (e.g., project reassignment, meeting exclusion). These documents are relevant to evaluating Hale's potential justifications for his actions and to assessing whether stated bu

8. Witness Corroboration This code should be applied to any document that corroborates or contradicts the accounts provided by witnesses, including but not limited to contemporaneous communications describing relevant events, communications between witnesses discussing relevant events, and documents that provide independent verification of specific facts alleged by any complainant or witness.

9. Complainant Performance Records This code should be applied to any document relating to the job performance, performance reviews, performance improvement plans, or disciplinary history of any complainant (Morales, Ngo, or Whitfield). These documents are relevant to assessing any potential pretext arguments — i.e., whether Hale may assert that adverse actions taken against complainants were based on legitimate perf

VI. REVIEW WORKFLOW A. First-Level Review The first-level review will be conducted by the two contract review attorneys described in Section III.C above. The first-level review is the initial pass through the approximately 38,600 filtered items and is designed to accomplish the following objectives: (i) code each document for relevance; (ii) apply the "Hot" designation to any document meeting the criteria set forth i

1. Any document involving communications with outside counsel, including but not limited to Thornfield & Associates LLP (counsel to Marcus Hale), Nakamura Reeves LLP, Pendleton & Warwick LLP (UK counsel to AGMG), or any other law firm. Such documents must be flagged for privilege review regardless of their substantive content.

2. Any document referencing Marcus Hale's employment agreement (dated January 7, 2019), including but not limited to any references to or discussions of the termination-for-cause provision (Section 9.2(b) of the employment agreement), compensation terms, equity award vesting provisions, severance provisions, change-of-control provisions, or any amendments or modifications to the employment agreement.

3. Any document in which a reviewer identifies content that raises a concern about potential spoliation, destruction, or alteration of evidence, or any communication suggesting that a custodian or other individual attempted to delete, conceal, or alter relevant documents or communications. B. Second-Level / Quality Control Review Archer and Petrov will conduct second-level review of the following categories of docume

1. All documents coded "Hot" by first-level reviewers.

2. All documents coded "Potentially Relevant — Needs Further Review" by first-level reviewers.

3. All documents coded "Potentially Privileged — Needs Further Review" by first-level reviewers.

4. Randomly selected samples of documents coded "Not Relevant" by first-level reviewers, as described below. QC Sampling Protocol. To ensure the accuracy and consistency of first-level review coding, Archer and Petrov will review a statistically significant random sample of documents coded "Not Relevant" by each first-level reviewer. The sampling protocol is designed to identify systemic errors in coding, including u

VII. PRIVILEGE REVIEW AND LOGGING PROCEDURES A. Privilege Review Workflow All documents flagged as potentially privileged during first-level review will be automatically routed to the dedicated Privilege Review Workspace within the review platform. The privilege review will be conducted by Archer and Petrov, who will make privilege determinations for each flagged document. Documents presenting borderline or disputed

VIII. HANDLING OF SPECIFIC DOCUMENT CATEGORIES Certain categories of documents in the review population require special attention due to their significance to the investigation, the format in which they are presented, or the privacy or privilege considerations they raise. The following sections provide guidance to reviewers on the handling of these specific categories. A. Text Messages (SMS/Westmark Software) Text me

1. Any documentation — or any notable absence of documentation — relating to the July 2021 informal complaint by Serena Whitcomb regarding Hale's conduct and the verbal counseling issued to Hale by Gallegos on August 2, 2021. The existence, content, and completeness of documentation of this prior incident are directly relevant to the investigation's assessment of whether HR and management responded appropriately to e

2. Performance reviews, feedback, and evaluations of the complainants (Morales, Ngo, and Whitfield), particularly those prepared or reviewed by Hale, and any changes in evaluation ratings or tone over time that may correlate with the timeline of complaints or the complainants' decisions to raise concerns.

3. Performance reviews, evaluations, and management assessments of Marcus Hale, including any 360-degree feedback, Board evaluations, or other assessments reflecting on Hale's leadership, interpersonal conduct, or management style.

4. Any documentation of training provided to Hale or other APS personnel on topics including anti-harassment, anti-discrimination, anti-retaliation, workplace conduct, bystander intervention, or related subjects. D. Policy Documents The following policy documents are known to be within the review population and are directly relevant to the investigation. Reviewers should code these documents as "Relevant" with the is

1. AGMG Global Code of Conduct, Version 4.2 (effective January 1, 2022): The enterprise-wide code of conduct applicable to all employees, officers, and directors of AGMG and its subsidiaries, including APS.

2. APS Employee Handbook, California Supplement (revised March 15, 2022): The employee handbook applicable to APS employees in California, with particular attention to the following sections: • Section 5.3: Anti-Harassment & Anti-Discrimination Policy • Section 5.7: Anti-Retaliation Policy • Section 8.1: Complaint & Investigation Procedures

3. AGMG Board Corporate Governance Guidelines — Section 12 (Executive Conduct Standards): The governance guidelines applicable to senior executives of AGMG and its subsidiaries, including provisions regarding expected standards of conduct and the Board's authority to take action in the event of violations.

4. Hotline Intake Records from Meridian Compliance Solutions LLC (case reference MCS-1014-00001): The records of the formal complaints filed through the third-party compliance hotline, including intake forms, complainant statements, and any correspondence from Meridian Compliance Solutions to AGMG or APS. E. Financial and Compensation Documents Documents relating to Marcus Hale's compensation and the financial terms

IX. DOCUMENT TRACKING AND METRICS A. Weekly Status Reports Nadia Petrov will prepare and circulate weekly status reports summarizing the progress of the document review. The weekly status reports will be distributed to Bernard Crawford, Renata Vasquez, and Devon Archer, and will be maintained in the matter file. The status reports will include the following information:

1. Total Documents Reviewed vs. Total in Review Set: A comparison of the number of documents reviewed to date against the total review population of approximately 38,600 items, expressed in both absolute numbers and as a percentage of the total.

2. Documents Coded by Category: A breakdown of documents coded in each relevance category (Relevant, Not Relevant, Potentially Relevant — Needs Further Review), the number of documents designated "Hot," and the number of documents coded with each privilege designation.

3. Pending Items in Escalation Queues: The number of documents pending in the Second-Level / QC Review Workspace, the Privilege Review Workspace, and any items flagged for partner escalation.

4. QC Error Rates: A summary of the QC sampling results for each first-level reviewer, including the number of documents sampled, the number of errors identified, the calculated error rate, and any remedial actions taken or recommended.

5. Estimated Completion Date: An updated estimate of the date by which the document review is expected to be completed, taking into account the current pace of review, the volume of documents remaining, and any factors that may affect the timeline (such as the identification of additional custodians, supplemental collections, or re-review requirements). B. Target Completion Date The target completion date for the doc