[sheet: Verification Summary]

[sheet: Verification Summary]
Field | Detail
Matter Number | 1016-00003
Client | Dunmore Energy Holdings Ltd.
Transaction | $850,000,000 9.375% Senior Secured Notes due 2032
Co-Issuer | Dunmore upstream Finance Corp.
Document Verified | Final Offering Memorandum — Environmental and Social Responsibility Section
ESG Data Source | Barrisford Advisory Group LLC
Barrisford Lead Consultant | Nathan Reyes Linley CPAs LLP
Barrisford Address | 1700 K Street NW, Suite 900, Washington, DC 20006
Barrisford Report Date | April 22, 2025
Reporting Period | Fiscal Year 2024 (January 1 – December 31, 2024)
C&H Responsible Partner | Jennifer Kwon
C&H Verification Lead | Claire Dempsey
C&H Review Associate | Eric Johannsen
Verification Commenced | April 28, 2025
Verification Completed | May 12, 2025
Status | Complete — All Data Points Verified
Notes | Cross-referenced Barrisford data package against OM draft sections; clarification requests sent to Nathan Reyes Linley CPAs LLP via email on approximately April 29, 2025 regarding Scope 1 emissions methodology, methane flaring intensity calculation, and community development spend breakdown
[sheet: GHG Emissions Verification]
Item No. | OM Section Reference | Data Point Description | OM Stated Value | Unit | Barrisford Source Document / Exhibit | Barrisford Source Value | Match | Methodology / Basis Confirmed | Reporting Boundary | Notes / Comments | Verified By | Verification Date
1 | Environmental and Social Responsibility, p. 142 | Scope 1 GHG Emissions — Total Consolidated | 1.42 million metric tons CO₂e | million metric tons CO₂e | Barrisford ESG Data Package, Exhibit A-1, Table 3 | 1.42 million metric tons CO₂e | Yes | GHG Protocol Corporate Standard; operational control approach | All operated assets: OML 47, OML 63, Cayar Offshore Block, Green Canyon / Garden Banks (GoM), West Texas solar portfolio (Dunmore Renewables LLC) | Scope 1 includes direct combustion, process emissions, flaring, and fugitive emissions. Methodology confirmed via clarification email to Nathan Reyes Linley CPAs LLP. | Claire Dempsey | 2025-05-02
2 | Environmental and Social Responsibility, p. 142 | Scope 1 GHG Emissions — Nigeria Operations (OML 47 & OML 63) | 0.87 million metric tons CO₂e | million metric tons CO₂e | Barrisford ESG Data Package, Exhibit A-1, Table 3a | 0.87 million metric tons CO₂e | Yes | GHG Protocol; operational control; includes flaring at Niger Delta facilities | Dunmore Nigeria E&P Ltd. operated assets | Subset of total Scope 1; confirmed breakdown with Barrisford | Claire Dempsey | 2025-05-02
3 | Environmental and Social Responsibility, p. 142 | Scope 1 GHG Emissions — Senegal Operations (Cayar Offshore Block) | 0.14 million metric tons CO₂e | million metric tons CO₂e | Barrisford ESG Data Package, Exhibit A-1, Table 3b | 0.14 million metric tons CO₂e | Yes | GHG Protocol; operational control | Dunmore Senegal S.A. operated assets | Early-stage production; lower absolute emissions | Claire Dempsey | 2025-05-02
4 | Environmental and Social Responsibility, p. 142 | Scope 1 GHG Emissions — GoM Operations | 0.31 million metric tons CO₂e | million metric tons CO₂e | Barrisford ESG Data Package, Exhibit A-1, Table 3c | 0.31 million metric tons CO₂e | Yes | GHG Protocol; operational control; BSEE reported data cross-checked | Dunmore Gulf Operations LLC — Green Canyon and Garden Banks leases | Includes deepwater drilling and production platform emissions | Claire Dempsey | 2025-05-02
5 | Environmental and Social Responsibility, p. 142 | Scope 1 GHG Emissions — West Texas Solar and Other | 0.10 million metric tons CO₂e | million metric tons CO₂e | Barrisford ESG Data Package, Exhibit A-1, Table 3d | 0.10 million metric tons CO₂e | Yes | GHG Protocol; includes midstream operations (Dunmore Midstream Holdings Inc.) and de minimis solar O&M | Dunmore Renewables LLC and Dunmore Midstream Holdings Inc. | Sum of rows 2–5 = 0.87 + 0.14 + 0.31 + 0.10 = 1.42, consistent with row 1 total | Claire Dempsey | 2025-05-02
6 | Environmental and Social Responsibility, p. 142 | Scope 2 GHG Emissions — Total Consolidated | 0.18 million metric tons CO₂e | million metric tons CO₂e | Barrisford ESG Data Package, Exhibit A-2, Table 4 | 0.18 million metric tons CO₂e | Yes | GHG Protocol Corporate Standard; location-based method | All operated assets | Purchased electricity for offices, processing facilities, and onshore infrastructure. Confirmed methodology (location-based vs. market-based) with Barrisford. | Claire Dempsey | 2025-05-02
7 | Environmental and Social Responsibility, p. 142 | Scope 2 GHG Emissions — Nigeria Operations | 0.09 million metric tons CO₂e | million metric tons CO₂e | Barrisford ESG Data Package, Exhibit A-2, Table 4a | 0.09 million metric tons CO₂e | Yes | GHG Protocol; location-based; Nigeria grid emission factor applied | Dunmore Nigeria E&P Ltd. — onshore processing facilities and offices | Largest Scope 2 contributor due to grid carbon intensity in Nigeria | Claire Dempsey | 2025-05-02
8 | Environmental and Social Responsibility, p. 142 | Scope 2 GHG Emissions — GoM Operations | 0.05 million metric tons CO₂e | million metric tons CO₂e | Barrisford ESG Data Package, Exhibit A-2, Table 4b | 0.05 million metric tons CO₂e | Yes | GHG Protocol; location-based; ERCOT/SERC grid emission factors | Dunmore Gulf Operations LLC — onshore support facilities | Includes shore-based operations and logistics hubs | Claire Dempsey | 2025-05-02
9 | Environmental and Social Responsibility, p. 142 | Scope 2 GHG Emissions — Senegal and Other | 0.04 million metric tons CO₂e | million metric tons CO₂e | Barrisford ESG Data Package, Exhibit A-2, Table 4c | 0.04 million metric tons CO₂e | Yes | GHG Protocol; location-based | Dunmore Senegal S.A., Dunmore Renewables LLC, corporate offices | Sum of Scope 2 sub-rows: 0.09 + 0.05 + 0.04 = 0.18, consistent with row 6 total | Claire Dempsey | 2025-05-02
10 | Environmental and Social Responsibility, p. 142 | Total Scope 1 + Scope 2 GHG Emissions | 1.60 million metric tons CO₂e | million metric tons CO₂e | Barrisford ESG Data Package, Exhibit A-3 | 1.60 million metric tons CO₂e | Yes | Sum of Scope 1 and Scope 2 | All operated assets | 1.42 + 0.18 = 1.60; confirmed | Claire Dempsey | 2025-05-02
11 | Environmental and Social Responsibility, p. 142 | GHG Emissions Intensity — Consolidated | 22.4 kg CO₂e/boe | kg CO₂e/boe | Barrisford ESG Data Package, Exhibit A-4, Table 5 | 22.4 kg CO₂e/boe | Yes | Total Scope 1 + 2 emissions divided by gross operated production (boe) | All operated assets | Intensity metric based on FY 2024 production of approximately 71.4 million boe; 1,600,000 metric tons / 71,400,000 boe ≈ 22.4 kg CO₂e/boe | Claire Dempsey | 2025-05-02
12 | Environmental and Social Responsibility, p. 142 | Year-over-Year Change in Total GHG Emissions (Scope 1 + 2) | 3.2% reduction vs. FY 2023 | percentage | Barrisford ESG Data Package, Exhibit A-5 | 3.2% reduction (FY 2023: 1.653 million metric tons CO₂e) | Yes | Year-over-year comparison; FY 2023 baseline from prior Barrisford report | All operated assets | Reduction driven primarily by GoM operational efficiency improvements and reduced flaring at OML 63. (1.653 - 1.60) / 1.653 = 3.2% | Claire Dempsey | 2025-05-02
[sheet: Methane Flaring Verification]
Item No. | OM Section Reference | Data Point Description | OM Stated Value | Unit | Barrisford Source Document / Exhibit | Barrisford Source Value | Match | Industry Average Benchmark | Benchmark Source | Methodology / Basis Confirmed | Notes / Comments | Verified By | Verification Date
1 | Environmental and Social Responsibility, p. 143 | Methane Flaring Intensity — Consolidated | 3.8 m³/boe | m³/boe | Barrisford ESG Data Package, Exhibit B-1, Table 6 | 3.8 m³/boe | Yes | 5.1 m³/boe (industry average) | Barrisford industry benchmarking report (2024); World Bank GGFR data | Flaring intensity = total volume flared (m³) ÷ total production (boe); FY 2024 production across all operated assets | Dunmore's flaring intensity 25.5% below industry average. Clarification requested from Nathan Reyes Linley CPAs LLP on denominator (gross vs. net production); confirmed gross operated production used. | Claire Dempsey | 2025-05-03
2 | Environmental and Social Responsibility, p. 143 | Methane Flaring Intensity — Nigeria (OML 47 & OML 63) | 4.9 m³/boe | m³/boe | Barrisford ESG Data Package, Exhibit B-1, Table 6a | 4.9 m³/boe | Yes | 5.1 m³/boe | Barrisford | Higher flaring in Niger Delta operations; still below industry average | Nigeria flaring intensity higher than consolidated figure due to associated gas volumes at OML 47 | Claire Dempsey | 2025-05-03
3 | Environmental and Social Responsibility, p. 143 | Methane Flaring Intensity — Senegal (Cayar Offshore Block) | 2.6 m³/boe | m³/boe | Barrisford ESG Data Package, Exhibit B-1, Table 6c | 2.6 m³/boe | Yes | 5.1 m³/boe | Barrisford | Newer offshore facilities with modern gas handling systems | Lower flaring intensity reflects recent investment in gas capture at Cayar Offshore | Claire Dempsey | 2025-05-03
4 | Environmental and Social Responsibility, p. 143 | Methane Flaring Intensity — GoM | 1.2 m³/boe | m³/boe | Barrisford ESG Data Package, Exhibit B-1, Table 6b | 1.2 m³/boe | Yes | 5.1 m³/boe | Barrisford | Deepwater operations with gas capture infrastructure | BSEE regulations minimize routine flaring in GoM | Claire Dempsey | 2025-05-03
5 | Risk Factors — ESG and Climate, p. 48 | Industry Average Flaring Intensity (benchmark) | 5.1 m³/boe | m³/boe | Barrisford ESG Data Package, Exhibit B-2 | 5.1 m³/boe | Yes | N/A | World Bank GGFR 2024 Global Gas Flaring Tracker | Benchmark used in OM comparative language | Confirmed source and year with Barrisford; data reflects calendar year 2023 (most recent available) | Claire Dempsey | 2025-05-03
6 | Environmental and Social Responsibility, p. 143 | Total Volume of Gas Flared — Consolidated (FY 2024) | 271.3 million m³ | million m³ | Barrisford ESG Data Package, Exhibit B-3, Table 7 | 271.3 million m³ | Yes | N/A | N/A | Absolute volume flared; denominator for intensity calculation: 271.3M m³ / 71.4M boe ≈ 3.8 m³/boe | Confirmed volumetric data consistent with intensity figure and production base | Claire Dempsey | 2025-05-03
[sheet: Community Spend Verification]
Item No. | OM Section Reference | Data Point Description | OM Stated Value | Currency | Barrisford Source Document / Exhibit | Barrisford Source Value | Match | Category Breakdown Available | Breakdown Detail | Methodology / Basis Confirmed | Notes / Comments | Verified By | Verification Date
1 | Environmental and Social Responsibility, p. 144 | Community Development Spend — Nigeria (FY 2024, Total) | $14.2 million | USD | Barrisford ESG Data Package, Exhibit C-1, Table 8 | $14.2 million | Yes | Yes | See breakdown rows below | Aggregate spend by Dunmore Nigeria E&P Ltd. on community development initiatives in host communities surrounding OML 47 and OML 63 in the Niger Delta | Clarification email sent to Nathan Reyes Linley CPAs LLP requesting detailed breakdown by category; breakdown confirmed and verified below. | Claire Dempsey | 2025-05-04
2 | Environmental and Social Responsibility, p. 144 | Community Development — Education and Training | $4.8 million | USD | Barrisford ESG Data Package, Exhibit C-1, Table 8a | $4.8 million | Yes | N/A | Scholarships, school construction, vocational training in Niger Delta communities | Sub-total of education-related programs | Consistent with Dunmore management representations | Claire Dempsey | 2025-05-04
3 | Environmental and Social Responsibility, p. 144 | Community Development — Healthcare | $3.6 million | USD | Barrisford ESG Data Package, Exhibit C-1, Table 8b | $3.6 million | Yes | N/A | Clinic construction and medical supply programs | Sub-total of healthcare programs | Claire Dempsey | 2025-05-04
4 | Environmental and Social Responsibility, p. 144 | Community Development — Infrastructure (Roads, Water, Power) | $3.9 million | USD | Barrisford ESG Data Package, Exhibit C-1, Table 8c | $3.9 million | Yes | N/A | Road rehabilitation, clean water projects, electrification | Sub-total of infrastructure programs | Claire Dempsey | 2025-05-04
5 | Environmental and Social Responsibility, p. 144 | Community Development — Livelihoods and Economic Empowerment | $1.9 million | USD | Barrisford ESG Data Package, Exhibit C-1, Table 8d | $1.9 million | Yes | N/A | Microfinance, agricultural support, small business grants | Sub-total of livelihood programs | Sum of rows 2–5: $4.8M + $3.6M + $3.9M + $1.9M = $14.2M; reconciles to total | Claire Dempsey | 2025-05-04
6 | Environmental and Social Responsibility, p. 144 | Community Development Spend — Year-over-Year Change | 18.3% increase vs. FY 2023 | USD | Barrisford ESG Data Package, Exhibit C-2 | 18.3% increase (FY 2023: $12.0 million) | Yes | N/A | FY 2023 total community spend was $12.0M; increase of $2.2M | Year-over-year comparison to demonstrate commitment trajectory | ($14.2M - $12.0M) / $12.0M = 18.3%; confirmed | Claire Dempsey | 2025-05-04
7 | Environmental and Social Responsibility, p. 144 | Number of Host Communities Benefited | 47 communities | N/A | Barrisford ESG Data Package, Exhibit C-3 | 47 communities | Yes | N/A | Host communities across OML 47 and OML 63 concession areas | Count of distinct communities receiving at least one community development program benefit in FY 2024 | Confirmed with Barrisford and Dunmore Nigeria community liaison office | Claire Dempsey | 2025-05-04
[sheet: Net-Zero and Other ESG Claims]
Item No. | OM Section Reference | Data Point / Statement Description | OM Stated Language | Barrisford Source Document / Exhibit | Barrisford Source Confirmation | Match / Consistent | Forward-Looking Statement | Safe Harbor / Cautionary Language Reviewed | Notes / Comments | Verified By | Verification Date
1 | Environmental and Social Responsibility, p. 145 | Net-Zero by 2050 Commitment | Dunmore has committed to achieving net-zero Scope 1 and Scope 2 greenhouse gas emissions across its operated portfolio by 2050. | Barrisford ESG Data Package, Exhibit D-1 (Net-Zero Roadmap Summary) | Confirmed: Dunmore board resolution dated March 2024 establishing net-zero by 2050 target; Barrisford prepared interim milestones | Yes | Yes | Yes — reviewed by C&H (see Net-Zero Commitment Disclosure Review memo); PSLRA safe harbor and meaningful cautionary language included in OM | Forward-looking statement; appropriate cautionary language confirmed present in OM. Greenwashing liability analysis completed separately. | Claire Dempsey | 2025-05-05
2 | Environmental and Social Responsibility, p. 145 | Interim Target — 30% Reduction by 2035 | Dunmore targets a 30% reduction in Scope 1 and Scope 2 emissions intensity by 2035 relative to a 2022 baseline. | Barrisford ESG Data Package, Exhibit D-1 (Net-Zero Roadmap Summary) | Confirmed: 30% intensity reduction target by 2035 vs. 2022 baseline established in board resolution; Barrisford validated baseline calculation | Yes | Yes | Yes — reviewed in conjunction with net-zero commitment; cautionary language covers interim targets | Forward-looking statement; baseline year 2022 emissions intensity confirmed at 24.8 kg CO₂e/boe per Barrisford. | Claire Dempsey | 2025-05-05
3 | Environmental and Social Responsibility, p. 145 | 220 MW Solar Portfolio — West Texas | Dunmore Renewables LLC operates a 220 MW solar portfolio in West Texas as part of its energy transition strategy. | Barrisford ESG Data Package, Exhibit D-2 | Confirmed: 220 MW nameplate capacity; five solar installations operational as of Q4 2024 | Yes | No | N/A | Factual statement; verified against Dunmore Renewables LLC operational data and Barrisford report | Claire Dempsey | 2025-05-05
4 | Environmental and Social Responsibility, p. 145 | Carbon Capture Feasibility Study | Dunmore is conducting a feasibility study for carbon capture and storage (CCS) at its GoM operations, with results expected in 2026. | Barrisford ESG Data Package, Exhibit D-4 (CCS Feasibility Overview) | Confirmed: CCS feasibility study commissioned Q3 2024; partnership with Gulf Coast Carbon Solutions Inc.; expected completion H2 2026 | Yes | Yes | Yes — cautionary language regarding feasibility and no assurance of project proceeding included in OM | Forward-looking statement; no capital commitment yet disclosed. Confirmed study scope with Barrisford. | Claire Dempsey | 2025-05-05
5 | Risk Factors — ESG and Climate, p. 49 | Climate Transition Risk Disclosure | The transition to a lower-carbon economy, including potential carbon pricing, shifting regulatory requirements, and evolving investor expectations, could adversely affect the value of our oil and gas reserves and our ability to access capital. | Barrisford ESG Data Package, Exhibit D-3 (Transition Risk Assessment) | Consistent with Barrisford's qualitative assessment of transition risks for upstream O&G operators | Yes | Yes | Yes — reviewed in ESG Risk Factor Drafting Memorandum | Risk factor language; not a specific data point but consistency with Barrisford assessment confirmed | Claire Dempsey | 2025-05-05
6 | Risk Factors — ESG and Climate, p. 49 | Physical Climate Risk Disclosure | Our operations may be subject to physical risks associated with climate change, including increased frequency and severity of extreme weather events, which could disrupt operations and damage infrastructure. | Barrisford ESG Data Package, Exhibit D-3 (Physical Risk Assessment) | Consistent with Barrisford's physical risk assessment; GoM hurricane exposure and Niger Delta flooding risk specifically noted | Yes | Yes | Yes — reviewed in ESG Risk Factor Drafting Memorandum | Risk factor language; Barrisford assessment references IPCC AR6 and RCP 4.5/8.5 scenarios | Claire Dempsey | 2025-05-05
7 | Environmental and Social Responsibility, p. 143 | Employees — Worldwide | ~3,400 | Barrisford ESG Data Package, Exhibit E-1 (Social Metrics) | ~3,400 as of December 31, 2024 | Yes | No | N/A | Headcount confirmed with Dunmore HR and Barrisford | Claire Dempsey | 2025-05-05
8 | Environmental and Social Responsibility, p. 143 | Lost Time Injury Frequency Rate (LTIFR) | 0.32 per 200,000 work hours | Barrisford ESG Data Package, Exhibit E-2 (Safety Metrics) | 0.32 per 200,000 work hours (FY 2024) | Yes | No | N/A | Safety metric; confirmed methodology consistent with OSHA recordkeeping standards. Below industry average of 0.48 per Barrisford benchmarking. | Claire Dempsey | 2025-05-05
9 | Environmental and Social Responsibility, p. 144 | Water Recycling Rate — Consolidated | 74% | Barrisford ESG Data Package, Exhibit E-3 (Environmental Metrics) | 74% of produced water recycled or reused in operations (FY 2024) | Yes | No | N/A | Factual statement; represents percentage of produced water that is recycled or reused across all operated assets. Confirmed calculation basis with Barrisford. | Claire Dempsey | 2025-05-05
10 | Environmental and Social Responsibility, p. 145 | Renewable Energy Investment to Date | $310 million cumulative capital deployed | Barrisford ESG Data Package, Exhibit D-2 (Renewables Summary) | $310 million cumulative capital deployed through December 31, 2024 | Yes | No | N/A | Cumulative capex in Dunmore Renewables LLC since inception (2019). Verified against Barrisford and management representations. | Claire Dempsey | 2025-05-05
[sheet: Open Items and Clarifications L]
Item No. | Date Raised | Raised By | Directed To | Data Point / Question | Communication Method | Response Received Date | Response Summary | Resolution Status | Impact on OM | Notes
1 | 2025-04-29 | Claire Dempsey (C&H) | Nathan Reyes Linley CPAs LLP (Barrisford Advisory Group LLC) | Scope 1 GHG Emissions — Methodology confirmation: GHG Protocol operational control vs. equity share approach? | Email | 2025-04-30 | Confirmed operational control approach per GHG Protocol Corporate Standard. All operated assets included regardless of equity interest percentage. | Closed | No change to OM; methodology footnote added to ESG section
2 | 2025-04-29 | Claire Dempsey (C&H) | Nathan Reyes Linley CPAs LLP (Barrisford Advisory Group LLC) | Methane flaring intensity calculation — Is the denominator gross operated production or net equity production? | Email | 2025-04-30 | Confirmed gross operated production is the denominator, consistent with World Bank GGFR methodology. | Closed | No change to OM; consistent with stated 3.8 m³/boe
3 | 2025-04-29 | Claire Dempsey (C&H) | Nathan Reyes Linley CPAs LLP (Barrisford Advisory Group LLC) | Community development spend in Nigeria — Please provide category-level breakdown (education, healthcare, infrastructure, livelihoods) for FY 2024 $14.2M total. | Email | 2025-05-01 | Breakdown provided: Education $4.8M, Healthcare $3.6M, Infrastructure $3.9M, Livelihoods $1.9M. Total sums to $14.2M. | Closed | Breakdown referenced in OM narrative but aggregated total figure ($14.2M) used as primary disclosure | Sum verified: $4.8M + $3.6M + $3.9M + $1.9M = $14.2M
4 | 2025-05-01 | Claire Dempsey (C&H) | Nathan Reyes Linley CPAs LLP (Barrisford Advisory Group LLC) | Scope 2 emissions — Location-based vs. market-based methodology: which is reported in the 0.18M metric tons figure? | Email | 2025-05-02 | Confirmed location-based method. Market-based figure not separately calculated for FY 2024. | Closed | OM footnote added specifying location-based methodology for Scope 2
5 | 2025-05-03 | Claire Dempsey (C&H) | Nathan Reyes Linley CPAs LLP (Barrisford Advisory Group LLC) | Industry average flaring benchmark (5.1 m³/boe) — Please confirm source and year. | Email | 2025-05-04 | Source: World Bank GGFR 2024 Global Gas Flaring Tracker; data as of calendar year 2023 (most recent available). | Closed | No change to OM; source reference noted
6 | 2025-05-04 | Claire Dempsey (C&H) | Nathan Reyes Linley CPAs LLP (Barrisford Advisory Group LLC) | GHG emissions intensity baseline for 2022 used in 30% reduction target — Please confirm baseline figure and calculation. | Email | 2025-05-05 | Confirmed 2022 baseline emissions intensity of 24.8 kg CO₂e/boe. Calculation: 1,710,000 metric tons CO₂e (Scope 1+2) / 68,950,000 boe gross operated production = 24.8 kg CO₂e/boe. | Closed | No change to OM; baseline figure consistent with Exhibit D-1
7 | 2025-05-05 | Claire Dempsey (C&H) | Nathan Reyes Linley CPAs LLP (Barrisford Advisory Group LLC) | LTIFR methodology — Please confirm whether rate is per 200,000 or 1,000,000 work hours and whether contractors are included. | Email | 2025-05-06 | Confirmed rate of 0.32 per 200,000 work hours per OSHA methodology. Includes employees only; contractor LTIFR tracked separately at 0.41 but not disclosed in OM. | Closed | No change to OM; employee-only basis consistent with OM disclosure | Contractor LTIFR noted for reference but not included in OM
8 | 2025-05-06 | Claire Dempsey (C&H) | Nathan Reyes Linley CPAs LLP (Barrisford Advisory Group LLC) | Renewable energy cumulative capex ($310M) — Please confirm whether figure includes only Dunmore Renewables LLC or also midstream hydrogen pilot. | Email | 2025-05-07 | Confirmed $310M reflects only Dunmore Renewables LLC solar portfolio capital expenditures. Midstream hydrogen pilot ($8M) is excluded and tracked separately. | Closed | No change to OM; $310M figure is accurate as stated