Contract analysis

I. UPJOHN ADMONITION At the outset of the interview, Devon Archer administered the standard Upjohn/corporate Miranda warning to Mr. Gallegos. Specifically, Archer advised Mr. Gallegos of the following:

1. Calderwood & Harkness LLP represents Aurelius Global Media Group PLC ("AGMG") and its subsidiaries, including Aurelius Pacific Studios Inc. ("APS"), in connection with an internal investigation. Calderwood & Harkness LLP does not represent Mr. Gallegos individually, and no attorney-client relationship exists between Calderwood & Harkness LLP and Mr. Gallegos personally.

2. The purpose of the interview is to gather facts in connection with the investigation being conducted at the direction of AGMG. The conversation between Mr. Gallegos and counsel is protected by the attorney-client privilege, but that privilege belongs solely to AGMG, not to Mr. Gallegos individually.

3. AGMG may, in its sole discretion, elect to waive the attorney-client privilege and disclose the substance of this interview to third parties, including, without limitation, governmental authorities, regulators, or opposing parties in litigation. The decision whether to waive or not waive the privilege rests exclusively with AGMG.

4. Mr. Gallegos should not discuss the substance of this interview with other employees, colleagues, or third parties, as doing so could jeopardize the privileged nature of the communication and the integrity of the investigation.

5. Mr. Gallegos's cooperation in this interview is expected in his capacity as a company employee, and he has an obligation to provide truthful and complete information. Following the administration of the Upjohn admonition, Archer asked Mr. Gallegos whether he understood each of the foregoing advisements. Mr. Gallegos confirmed that he understood the admonition in its entirety. Mr. Gallegos did not ask any clarifyin

II. BACKGROUND AND ROLE A. Professional History at Aurelius Pacific Studios Inc. Victor Gallegos serves as Vice President of Human Resources for Aurelius Pacific Studios Inc. ("APS"), which is headquartered at 3200 West Alameda Avenue, Suite 400, Burbank, California 91505. Gallegos has served in the VP of Human Resources role since March 2018, a period of approximately five years, and has been in the role continuousl

III. RECEIPT AND ESCALATION OF THE MORALES HOTLINE COMPLAINT A. Initial Receipt — April 18–19, 2023 Gallegos described in detail the process by which he received the complaint from Jenna Morales, Vice President of Development at APS. Gallegos explained that on April 18, 2023, Morales submitted a written complaint through the Aurelius Ethics & Compliance Hotline. The hotline is operated by a third-party vendor, Meridi

1. Seniority of the subject. The complaint involved Marcus Hale, who holds the most senior executive position at APS. Gallegos stated that any complaint implicating the President of a subsidiary warranted immediate escalation to the parent company.

2. Severity of the allegations. The complaint contained allegations of sexual harassment, including unwanted sexual advances and sexually explicit communications. Gallegos stated that the nature and gravity of these allegations required prompt attention at the highest levels of the organization.

3. Board-level awareness. Given the combination of the seniority of the subject and the severity of the allegations, Gallegos believed that the matter would ultimately require Board-level awareness, and that early escalation to the General Counsel was the appropriate conduit to ensure that the relevant Board committees were informed in a timely manner. Gallegos stated that he communicated the escalation via email to

IV. CORROBORATING COMPLAINTS — NGO AND WHITFIELD A. Claire Ngo — April 24, 2023 Gallegos stated that on April 24, 2023, approximately five days after the Morales complaint was escalated, Claire Ngo, Senior Director of Talent Relations at APS, submitted a separate complaint directly to Gallegos. Ngo did not utilize the Aurelius Ethics & Compliance Hotline to submit her complaint; rather, she approached Gallegos direct

V. INTERIM ACTIONS AND BOARD AUTHORIZATION A. Initial Protective Steps Gallegos described the interim actions that were taken between the initial receipt of the complaints and the formal engagement of Calderwood & Harkness LLP as outside counsel. During this interim period — spanning approximately from April 19, 2023 through the formal engagement of outside counsel in early May 2023 — Gallegos took the following prot

VI. DOCUMENT PRESERVATION AND COLLECTION SUPPORT Gallegos confirmed that he received the litigation hold notice dated May 2, 2023, which was drafted by Calderwood & Harkness LLP for issuance by APS to relevant custodians. Gallegos stated that he disseminated the litigation hold notice to all identified custodians within APS in accordance with the instructions provided by Calderwood & Harkness. The litigation hold not

VII. PRIOR INFORMAL COMPLAINT — SERENA WHITCOMB (JULY 2021) A. Nature of the 2021 Complaint Gallegos confirmed that a prior complaint was made against Marcus Hale in July 2021 by Serena Whitcomb, who at the time served as Executive Assistant to Hale at APS. Whitcomb was employed at APS from April 2019 through September 2021. Gallegos stated that Whitcomb's complaint alleged that Hale made inappropriate comments to he

VIII. RELEVANT POLICIES AND GALLEGOS'S FAMILIARITY A. Applicable Policies Gallegos confirmed his familiarity with the following AGMG and APS policies, each of which is relevant to the subject matter of this investigation:

1. AGMG Global Code of Conduct, Version 4.2, effective January 1, 2022. Gallegos stated that the Global Code of Conduct establishes company-wide expectations for ethical behavior, including provisions related to respectful workplace conduct, prohibition of harassment and discrimination, and the obligation to report known or suspected violations.

2. APS Employee Handbook (California Supplement), revised March 15, 2022, including the following sections: • Section 5.3 — Anti-Harassment & Anti-Discrimination Policy. This section prohibits all forms of harassment and discrimination based on protected characteristics, including sex and gender, in compliance with federal and California state law. • Section 5.7 — Anti-Retaliation Policy. This section prohibits retal

3. AGMG Board Corporate Governance Guidelines, Section 12 (Executive Conduct Standards). Gallegos stated that this section establishes the standards of conduct expected of senior executives, including requirements for compliance with applicable laws and company policies. B. Gallegos's Assessment of Policy Compliance Gallegos was asked to assess whether his handling of the 2021 Whitcomb complaint complied with the pol

IX. GALLEGOS'S OBSERVATIONS REGARDING COMPLAINANTS AND HALE A. Observations on Jenna Morales Gallegos described Jenna Morales as a strong performer in her role as Vice President of Development at APS. Gallegos stated that, based on his review of HR records and his general familiarity with the studio division's leadership team, he was not aware of any documented performance issues, performance improvement plans, or di

X. ADDITIONAL INFORMATION PROVIDED In addition to the foregoing, Gallegos provided the following information and materials to the investigation team: • Organizational charts. Gallegos provided current and historical organizational charts for APS reflecting the reporting structure under Hale, including the nine direct-report SVPs and their respective functional areas. • Identification of Cameron Briggs. Gallegos ident

XI. CLOSING At the conclusion of the interview, Mr. Gallegos was advised that he may be asked to participate in a follow-up interview if additional questions arise during the course of the investigation. Gallegos stated that he understood and that he would make himself available for any further discussions as needed. Gallegos was reminded of the Upjohn admonition that was administered at the outset of the interview,