Contract analysis

I. Purpose and Legal Obligation Aurelius Pacific Studios Inc. ("APS" or the "Company"), a wholly owned subsidiary of Aurelius Global Media Group PLC ("AGMG"), has a legal duty to preserve all documents and electronically stored information ("ESI") that may be relevant to pending or reasonably anticipated claims, investigations, or litigation. This duty arises under both federal and California state law, including the

II. Effective Date and Preservation Period This litigation hold is effective immediately as of May 2, 2023. All recipients of this notice are required to take immediate action to identify and preserve all documents and ESI within the scope of this hold, as described in Section III below, and to cease any destruction, deletion, alteration, or modification of such materials. The temporal scope of materials to be preser

III. Scope of Materials to Be Preserved A. Subject Matter All documents, communications, and ESI relating to, referencing, or concerning any of the following subject matter areas must be preserved. This list is intended to be comprehensive but not exhaustive; if you have questions about whether particular materials fall within the scope of this hold, you should err on the side of preservation and contact Victor Galle

1. Marcus Hale (President, APS) — including, without limitation, his conduct, management decisions, management style, interactions with employees (whether professional or personal in nature), travel and entertainment activities, expense reports, use of Company resources, and any communications to, from, or concerning Hale in any context relevant to the subject matter of this hold.

2. Jenna Morales (Vice President of Development, APS) — including, without limitation, her employment history at APS, work assignments, project responsibilities, complaints (whether formal or informal) made by or regarding her, interactions with Marcus Hale, performance evaluations, compensation history, any changes to her role, responsibilities, or reporting structure, and any communications to, from, or concerning

3. Claire Ngo (Senior Director of Talent Relations, APS) — including, without limitation, her employment history at APS, complaints (whether formal or informal) made by or regarding her, any instances of exclusion from meetings, events, or decision-making processes, interactions with Marcus Hale, performance evaluations, compensation history, and any communications to, from, or concerning Ngo relevant to the subject

4. Darren Whitfield (SVP of Physical Production, APS) — including, without limitation, his employment history at APS, work assignments, project responsibilities, any concerns raised by Whitfield about Hale's conduct, the reassignment of production projects from Whitfield to other personnel (including but not limited to projects known internally as "Project Meridian" and "Project Halcyon"), performance evaluations, co

5. Cameron Briggs (SVP of Production, APS) — including, without limitation, the reassignment of Project Meridian and Project Halcyon to Briggs from Whitfield, Briggs's communications with Hale regarding such reassignments, any communications to, from, or concerning Briggs relevant to the subject matter of this hold, and any documents relating to the decision-making process surrounding those project reassignments.

6. Serena Whitcomb (former Executive Assistant to Marcus Hale, employed approximately April 2019 through September 2021) — including, without limitation, any prior complaints made by or regarding Whitcomb, interactions between Whitcomb and the Human Resources department, the circumstances of her separation from the Company, any exit interview documentation, any severance or separation agreements, and any communicatio

7. Any allegations, complaints, reports, or concerns regarding sexual harassment, inappropriate conduct, hostile work environment, discrimination, or retaliation involving any APS employee, whether made formally through the Company's complaint procedures, informally to a manager or Human Resources representative, or through any other channel, including the AGMG Ethics & Compliance Hotline.

8. The Ethics & Compliance Hotline complaint filed on April 18, 2023 (Meridian Compliance Solutions LLC case reference MCS-1014-00001), including the original complaint, any intake notes, investigative memoranda, communications with the reporter, follow-up actions taken, and any related hotline reports filed before or after this date that concern the same or similar subject matter.

9. Any HR investigations, counseling, warnings, or disciplinary actions involving Marcus Hale, including without limitation the verbal counseling issued to Hale on or about August 2, 2021, any documentation of that counseling session, any follow-up actions or monitoring undertaken in connection therewith, and any other formal or informal disciplinary measures, performance improvement plans, or counseling sessions inv

10. Company off-site events, retreats, dinners, and production travel, including but not limited to the following: • The off-site event held on February 17–18, 2023 at the Monarch Valley Resort, Ojai, California, including all planning documents, attendee lists, expense reports, photographs, communications regarding the event, and any incident reports or complaints arising from the event; • The production trip to Van

11. Performance reviews, personnel files, and employment records for Marcus Hale, Jenna Morales, Claire Ngo, Darren Whitfield, Cameron Briggs, and Serena Whitcomb, including all documents maintained in the Company's HRIS (Human Resources Information System), physical personnel files, and any records maintained by individual managers.

12. All policies, handbooks, and training materials relating to anti-harassment, anti-discrimination, anti-retaliation, and complaint procedures, including but not limited to: • The AGMG Global Code of Conduct, Version 4.2, effective January 1, 2022, and all prior versions in effect during the Preservation Period; • The APS Employee Handbook, California Supplement, revised March 15, 2022, in particular Sections 5.3 (

IV. Custodians The following individuals are identified as custodians whose documents and ESI must be preserved pursuant to this litigation hold. Additional custodians may be identified and notified as the investigation proceeds, in coordination between Victor Gallegos and Calderwood & Harkness LLP. Each custodian listed below will receive a copy of this notice and is required to comply with all obligations described

1. Marcus Hale — President, Aurelius Pacific Studios Inc. Mr. Hale has been placed on paid administrative leave effective May 3, 2023. His system access, including email, Meridian Solutions, VPN, and all Company network access, has been suspended as of that date. The IT department is directed to preserve all data associated with Mr. Hale's accounts and devices in place, in their current state, and to ensure that no d

2. Jenna Morales — Vice President of Development, Aurelius Pacific Studios Inc.

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

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

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

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

7. Additional SVP-level direct reports of Marcus Hale, to be identified in coordination with Calderwood & Harkness LLP. Once identified, these individuals will be provided with a copy of this notice and will be subject to the same preservation obligations.

8. Any current or former employee who may be identified as a relevant witness during the course of the investigation. Such individuals will be notified and provided with a copy of this notice as they are identified. Note Regarding Former Employees: With respect to Serena Whitcomb (former Executive Assistant to Marcus Hale, employed approximately April 2019 through September 2021) and any other former employees who ma

V. Obligations of Custodians Each custodian identified in Section IV above is personally responsible for ensuring the preservation of all materials within their custody, possession, or control that fall within the scope of this hold. The preservation obligation extends to all locations and devices where relevant materials may be stored, including Company systems, Company-issued devices, personal devices used for busi

1. Immediately cease any destruction, deletion, or alteration of potentially relevant materials. This includes ceasing any manual deletion of emails, text messages, instant messages, voicemails, files, or any other documents or ESI that may fall within the scope of this hold. Do not "clean up," reorganize, or otherwise alter any files, folders, or communications.

2. Search for and identify all physical and electronic locations where relevant materials may be stored. This includes, without limitation: • Company-issued laptops, desktops, and other computing devices; • Company-issued mobile phones and tablets; • Personal devices (phones, laptops, tablets) used for Company business; • Home offices, including any paper files, notes, or documents stored at your residence; • Persona

3. Disable any auto-delete functions on email accounts, messaging applications (including Meridian Solutions, Meridian Services Inc., Harborline Technologies, and any other applications with message expiration or auto-delete features), and mobile devices. If you are unsure how to disable auto-delete functions, contact the IT department or Victor Gallegos immediately for assistance.

4. Preserve all relevant materials in their current location and format. Do not move, copy to a new format, reorganize, rename, or otherwise alter materials unless specifically directed to do so by Calderwood & Harkness LLP or Victor Gallegos. The goal is to maintain materials in their existing state to preserve their integrity, including all associated metadata.

5. Promptly notify Victor Gallegos if any relevant materials have already been deleted, destroyed, or are at risk of loss. If you are aware of any materials that were destroyed or deleted before or after the date of this notice that may fall within the scope of this hold, you must report this immediately. Similarly, if you become aware of any materials that are at risk of loss or destruction (for example, due to devi

6. Do not discuss the substance of this litigation hold or the underlying investigation with other employees, other than as directed by Calderwood & Harkness LLP or Victor Gallegos. The integrity of the investigation depends on maintaining confidentiality. You should not discuss the contents of this notice, the fact that you received it, or any aspect of the underlying allegations with colleagues, subordinates, or an

VI. IT Department Obligations The APS Information Technology department, under the supervision of the Chief Information Officer or the most senior IT leader within APS, is directed to take the following actions immediately and to continue these measures for the duration of this litigation hold:

1. Suspend all auto-delete, auto-archive, or recycling routines for email (Outlook / Exchange), Meridian Solutions, Northgate Data Systems, and any other messaging or collaboration platforms in use at APS, for all custodians identified in Section IV above. This includes any Company-wide or departmental auto-purge schedules, mailbox size limitations that trigger automatic deletion, and any retention policies that woul

2. Preserve backup tapes and system images that may contain data within the Preservation Period (January 1, 2019 to the present). No backup tapes, disaster-recovery media, or system snapshots that contain or may contain data within the scope of this hold shall be overwritten, recycled, degaussed, or destroyed. The IT department shall maintain a current inventory of all backup media subject to this preservation direct

3. Preserve the APS Meridian Solutions workspace data, including all channels (both public and private) and all direct messages for identified custodians. If Meridian Solutions data is subject to any data retention limits or automatic deletion policies, these must be suspended immediately. The IT department shall coordinate with Calderwood & Harkness LLP regarding the export and preservation of Meridian Solutions dat

4. Ensure that the email account and all system access credentials for Marcus Hale (currently suspended due to his administrative leave status) remain preserved and accessible for forensic collection. Mr. Hale's email account, Meridian Solutions account, network home directory, Cobalt Ridge Systems or Aldermere Systems data, and any other data repositories associated with his accounts must not be deleted, purged, or

5. Cooperate with Linden Forensics Group Inc. (201 Mission Street, Suite 1400, San Francisco, CA 94105), the digital forensics firm retained by Calderwood & Harkness LLP, in connection with any forensic data collection, imaging, or analysis efforts. The IT department shall provide Linden Forensics Group with such access to Company systems, devices, and data as may be reasonably necessary to carry out forensic preserv

6. Maintain chain-of-custody documentation for any data preserved, collected, or produced pursuant to this hold. All transfers of data, devices, or media must be documented with the date, time, individuals involved, description of materials, and purpose of the transfer. Chain-of-custody logs shall be maintained in a secure location and made available to Calderwood & Harkness LLP upon request.

7. Do not alter, modify, or reset any passwords or security settings for custodian accounts without prior written authorization from Victor Gallegos. Any changes to access controls, authentication credentials, or security configurations for custodian accounts could compromise the integrity of preserved data and must be coordinated with counsel. The IT department should designate a single point of contact for all matt

VII. Consequences of Non-Compliance The obligation to preserve relevant evidence when litigation or an investigation is pending or reasonably anticipated is a serious legal duty imposed by law. All recipients of this notice are expected to comply fully and promptly with every requirement set forth herein. Failure to comply with this litigation hold may have severe consequences, including but not limited to the follow

VIII. Acknowledgment and Confirmation Each recipient of this notice is required to confirm receipt and understanding of this Litigation Hold Notice by completing, signing, and returning the acknowledgment form below to Victor Gallegos, Vice President of Human Resources, within three (3) business days of receipt. The signed acknowledgment form may be delivered in person, by interoffice mail, or by email (scanned copy)

IX. Contact Information for Questions All questions regarding the scope of materials to be preserved, how to handle specific documents or categories of ESI, technical issues with preservation (such as disabling auto-delete functions or preserving data on personal devices), or any other aspect of this litigation hold should be directed to one of the following contacts without delay: Victor Gallegos Vice President of H