1016-00009 · Dunmore Energy Holdings · Litigation Hold & Preservation

litigation-hold-reminder-all-custodians.docx DOCUMENT Litigation

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MEMORANDUM

CONFIDENTIAL / ATTORNEY-CLIENT PRIVILEGED / ATTORNEY WORK PRODUCT

This memorandum is protected by attorney-client privilege and the work product doctrine. It is issued for the sole purpose of ensuring compliance with document preservation obligations in connection with pending government investigations and legal proceedings. Do not forward, copy, or disclose this memorandum to any person outside the company without prior written authorization from Calderwood & Harkness LLP or the Dunmore Legal Department. Unauthorized disclosure may constitute a waiver of privilege and may result in disciplinary action.

I. PURPOSE OF THIS REMINDER

This memorandum serves as a formal reminder and reaffirmation of the litigation hold originally issued on April 20, 2022 by Calderwood & Harkness LLP on behalf of Dunmore Energy Holdings Ltd. ("Dunmore," "DEH," or the "Company"). As you are aware, the original litigation hold was distributed to all identified custodians on that date, requiring the immediate preservation of all documents and electronically stored information ("ESI") potentially relevant to the matters described herein. This reminder is issued under the joint authority of Calderwood & Harkness LLP, in its capacity as defense counsel for Dunmore, and the Dunmore Legal Department, in its capacity as the internal steward of the Company's legal compliance obligations.

The original litigation hold remains in full force and effect. This memorandum supplements but does not replace the prior notice dated April 20, 2022. All obligations set forth in the original hold continue without modification, and this reminder is intended to reinforce those obligations and provide important updates regarding the status of the underlying investigation and related proceedings.

This reminder is being issued at this time for several reasons. First, approximately three months have elapsed since the initial hold was communicated. Experience demonstrates that compliance with preservation obligations can deteriorate over time as daily business activities resume and the urgency of the initial notice recedes. It is critical that all custodians maintain the same level of vigilance and care in preserving documents today as when the hold was first issued. Second, the scope of the government's investigation has expanded since April 2022, and additional factual areas and counterparties have come to the attention of both the government and Calderwood & Harkness LLP's investigation team. Third, Dunmore's ongoing obligations under grand jury subpoena GJ No. 22-418, issued by the U.S. District Court for the District of Columbia (Grand Jury 22-2), dated April 19, 2022, require continuous and rigorous document preservation to support rolling document productions to the U.S. Department of Justice.

All custodians who received the original hold notice — as well as any new custodians identified since April 20, 2022 — are bound by this memorandum and all preservation obligations described herein. If you are uncertain whether you were identified as a custodian under the original hold, you should treat this memorandum as applying to you in full and contact the individuals listed in Section X below for clarification.

Failure to comply with document preservation obligations may result in serious adverse legal consequences for Dunmore and may expose individual employees to personal liability, including potential criminal liability under federal obstruction of justice statutes. The importance of full compliance cannot be overstated. Please read this entire memorandum carefully and take all steps necessary to ensure your continued compliance.

II. BACKGROUND — THE DOJ INVESTIGATION

On April 19, 2022, the U.S. Department of Justice, National Security Division, Counterintelligence and Export Control Section ("DOJ NSD/CES"), opened a formal inquiry into Dunmore Energy Holdings Ltd. concerning potential violations of U.S. sanctions laws — including economic sanctions programs administered by the U.S. Department of the Treasury, Office of Foreign Assets Control ("OFAC") — and U.S. export control regulations administered by the U.S. Department of Commerce, Bureau of Industry and Security ("BIS"). The investigation is being led by a team of prosecutors within the DOJ NSD/CES, with investigative support from the Federal Bureau of Investigation ("FBI").

On the same date, the DOJ issued grand jury subpoena GJ No. 22-418, returnable before Grand Jury 22-2 sitting in the U.S. District Court for the District of Columbia. The subpoena compels the production of documents and records spanning a broad range of Dunmore's international trading activities, compliance records, and financial transactions. The subpoena's original return date of May 19, 2022 was extended by agreement with the government to July 19, 2022. Pursuant to subsequent negotiations between Calderwood & Harkness LLP and the DOJ, a rolling production protocol is now in effect, under which Dunmore is producing responsive, non-privileged documents on a phased, Bates-stamped basis (using the prefix DEH-DOJ) at regular intervals as documents are collected, processed, reviewed, and cleared for production. This rolling production protocol imposes continuous and ongoing obligations on Dunmore to identify, collect, and produce responsive documents.

The investigation concerns transactions involving Dunmore Trading International Ltd. ("DTI"), the Company's Dubai-based trading desk, and DTI's dealings with certain counterparties that are the subject of heightened scrutiny. Specifically, the investigation concerns DTI's transactions and communications with the following entities and individuals, among others:

• Petronova Trading FZE (Dubai, UAE) — a free zone entity engaged in crude oil and refined products trading, including its directors, officers, employees, and agents (including, without limitation, Sergei Volkov);

• Volkhov Industrial Group JSC (Moscow, Russia) — a Russian industrial conglomerate designated under OFAC Directive 2 pursuant to Executive Order 13662 on November 15, 2019, and subsequently added to the OFAC Specially Designated Nationals and blocked Persons List ("SDN List") pursuant to Executive Order 14024 on April 6, 2022, including its subsidiaries, affiliates, directors, officers, employees, and agents (including, without limitation, Arkady Volkhov);

• Zenith Petroleum DMCC (Dubai, UAE) — a DMCC-registered trading entity, including its directors, officers, employees, and agents (including, without limitation, Farhan Qureshi); and

• Caspian Logistik GmbH (Hamburg, Germany) — a German logistics and freight forwarding company, including its directors, officers, employees, and agents (including, without limitation, Klaus Weidemann).

The conduct under review spans approximately March 2020 through April 2022 and involves, among other things, crude oil swap transactions, oilfield equipment exports, the classification and licensing of controlled items, and related payment flows through intermediary financial institutions. The government's inquiry encompasses both the substantive transactions at issue and the adequacy of Dunmore's compliance controls, due diligence procedures, and internal reporting mechanisms during the relevant period.

Calderwood & Harkness LLP (the "Firm") serves as defense counsel for Dunmore Energy Holdings Ltd. and its subsidiaries in connection with this matter. Victoria Chambers, a partner in the Firm's White Collar & Investigations Practice Group based in the Washington, D.C. office, is the responsible partner overseeing the defense and internal investigation. All communications with the Firm regarding this matter should be directed to Ms. Chambers or the other individuals identified in Section X of this memorandum.

III. SCOPE OF THE LITIGATION HOLD — WHAT MUST BE PRESERVED

The following section sets forth the scope of the litigation hold in detail. All custodians are required to preserve all documents and ESI that fall within any of the categories described below. If you have any doubt as to whether a particular document or category of documents falls within the scope of the hold, you should err on the side of preservation and contact Calderwood & Harkness LLP or the Dunmore Legal Department for guidance. Do not make unilateral decisions to discard or delete documents that may be relevant.

A. Covered Subject Matter

All documents and electronically stored information ("ESI") relating to, referring to, or reflecting any of the following subject matter areas must be preserved:

1. Petronova Trading FZE. Any transaction, dealing, communication, or negotiation with Petronova Trading FZE, including without limitation any communications with or concerning its directors, officers, employees, or agents. This includes, specifically, any communications with or concerning Sergei Volkov, regardless of the capacity in which Mr. Volkov was acting.

2. Volkhov Industrial Group JSC. Any transaction, dealing, communication, or negotiation with Volkhov Industrial Group JSC, including its subsidiaries, affiliates, joint ventures, directors, officers, employees, or agents. This includes, specifically, any communications with or concerning Arkady Volkhov, as well as any documents reflecting awareness of or analysis relating to the OFAC designations of Volkhov Industrial Group under Directive 2 (E.O. 13662) and the SDN List (E.O. 14024).

3. Zenith Petroleum DMCC. Any transaction, dealing, communication, or negotiation with Zenith Petroleum DMCC, including its directors, officers, employees, or agents. This includes, specifically, any communications with or concerning Farhan Qureshi, as well as any documents concerning Zenith Petroleum's role as a broker, intermediary, or counterparty in any transaction involving Dunmore or its subsidiaries.

4. Caspian Logistik GmbH. Any transaction, dealing, communication, or negotiation with Caspian Logistik GmbH, including its directors, officers, employees, or agents. This includes, specifically, any communications with or concerning Klaus Weidemann, as well as any documents relating to freight forwarding, logistics, or shipping services provided by Caspian Logistik in connection with Dunmore's trading or export activities.

5. Russian-Origin Crude Oil and Petroleum Products. Any crude oil, refined products, or commodity swap transaction involving Russian-origin crude oil or refined petroleum products, from January 1, 2019 to the present. This includes, without limitation, swap confirmations, trade tickets, pricing communications, volume allocations, delivery schedules, and any analysis or discussion of the origin or provenance of crude oil or refined products.

6. Oilfield Equipment Exports and Export-Controlled Items. Any export, re-export, or transfer of oilfield equipment, drilling components, or items classified under Export Control Classification Number ("ECCN") 2B350 or 2B999, or any other controlled item, to Russia, Belarus, or any entity appearing on the OFAC SDN List, the BIS Entity List, or the Denied Persons List, from January 1, 2019 to the present. This includes export license applications, license determinations, classification requests, commodity jurisdiction requests, end-user certificates, end-use statements, and any internal analysis of export control applicability.

7. Crescent Commercial Bank PJSC Transactions. Any payment, wire transfer, or financial transaction routed through or involving Crescent Commercial Bank PJSC (Dubai, UAE) in connection with any of the foregoing subject matter areas. This includes payment instructions, wire transfer confirmations, bank statements, correspondent banking records, and any communications with Crescent Commercial Bank or its representatives.

8. Compliance Reviews and Due Diligence. Any OFAC screening, sanctions compliance review, export control classification, know-your-customer ("KYC"), know-your-business ("KYB"), or other due diligence performed on any of the above-referenced counterparties, their affiliates, beneficial owners, directors, officers, employees, or agents. This includes screening results, compliance memoranda, compliance committee reports, escalation forms, and any related internal approvals or rejections.

9. Internal Discussions and Escalations. Any internal discussion, reporting, or escalation related to sanctions compliance, export control compliance, or potential exposure to sanctioned entities in connection with any of the above subject matter areas. This includes internal emails, memoranda, presentations, meeting notes, whistleblower reports, compliance hotline records, and any communications with internal or external legal counsel regarding these topics.

10. Internal Investigation Materials. All documents relating to the internal investigation being conducted by Calderwood & Harkness LLP, including any communications with counsel, interview preparation materials, investigation memoranda, and related documents. These materials are separately maintained by Calderwood & Harkness LLP and are subject to heightened privilege protections. Custodians should not delete, alter, or disclose any such materials, and any questions about the treatment of investigation materials should be directed to Victoria Chambers or Jasmine Thornton at the Firm.

The foregoing list is intended to be comprehensive but is not exhaustive. If you possess documents or ESI that you believe may be related to the subject matter of the investigation but that do not clearly fall within one of the above categories, you should preserve those documents and contact Calderwood & Harkness LLP or the Dunmore Legal Department for guidance.

B. Time Period

The relevant time period for the litigation hold is January 1, 2019 through the present. All documents and ESI created, sent, received, modified, or stored during this period that fall within the scope of the subject matter areas described in Section III.A above must be preserved. This time period mirrors the temporal scope of grand jury subpoena GJ No. 22-418 and is consistent with the period of conduct under review by the DOJ.

The hold will remain in place until further written notice from Calderwood & Harkness LLP or the Dunmore Legal Department. No custodian is authorized to release any documents from the hold, resume routine destruction of documents within the hold's scope, or conclude that the hold has terminated, unless and until a formal written release is issued. Any informal or verbal communication suggesting that the hold has been modified or terminated should be disregarded; only a written notice signed by Victoria Chambers or Marcus Wellbourne will be effective to modify or release the hold.

C. Types of Documents and ESI Covered

The litigation hold applies to all forms of documents and ESI, regardless of format or medium of storage. The following is an illustrative list of the types of documents and ESI that must be preserved:

• Emails: All emails, including attachments, on all email platforms. This includes corporate email accounts hosted on Strathmore Data Systems / Outlook, personal email accounts (such as Northgate Software, Cascade Health IT, or other web-based email services) if used for any Dunmore business communications, and any email accounts maintained on mobile devices. Both sent and received emails, including draft emails, are covered.

• Text Messages, Instant Messages, and Encrypted Messaging Communications: All text messages (SMS and Westmark Software), instant messages, and communications transmitted via encrypted messaging applications, including but not limited to Meridian Services Inc., Signal, Kestrel Data Systems, WeChat, and any similar platform. This obligation applies to communications on both company-issued devices and personal devices if used for business purposes at any time.

• Calendar Entries and Meeting Invitations: All calendar entries, meeting invitations, meeting acceptances, and meeting notes stored in any calendaring system, including Hollowell Systems, Brightmoor Services Inc., or any other application.

• Word Processing Documents, Spreadsheets, Presentations, and PDF Files: All files created in Microsoft Word, Excel, Northgate Services Inc., Adobe Acrobat, Stonefield Health IT, Stonefield Services Inc., Pemberton Services Inc., or any comparable application, whether stored locally, on network drives, or in cloud-based storage (including Aldermere Systems, Cobalt Ridge Systems, Hollowell Health IT, Larkspur Technologies, box, or any other cloud storage platform).

• Trade Documentation: Trade tickets, deal confirmations, swap confirmations, ISDA confirmations, trade blotters, position reports, and any other records of commodity trading activity.

• Shipping and Export Documentation: Shipping documents, bills of lading, airway bills, packing lists, certificates of origin, end-user certificates, end-use statements, export license applications, export license determinations, Shipper's Export Declarations (SEDs), Electronic Export Information (EEI) filings, and customs declarations.

• Financial Transaction Records: Wire transfer records, payment instructions, SWIFT messages, bank statements, account records, letters of credit, standby letters of credit, and any other records of financial transactions.

• Compliance Records: OFAC screening logs, sanctions screening results, KYC/KYB files, counterparty due diligence files, compliance review memoranda, compliance committee minutes, escalation records, and any other records maintained by the compliance function.

• Corporate Governance Records: Board of directors minutes, audit committee minutes, risk committee minutes, compliance committee minutes, management reports, and any other records of corporate governance proceedings in which the subject matter of the hold was discussed.

• Accounting and Financial Records: Accounting records, general ledger entries, journal entries, sub-ledger entries, financial reports, audit workpapers, tax records, intercompany transfer pricing documentation, and any other financial records.

• Voicemail and Recorded Telephone Lines: Voicemail recordings stored on any device or server, and recordings from recorded telephone lines, including trading desk recorded lines operated by DTI or any other Dunmore entity.

• Hard Copy Documents: Physical documents, notebooks, handwritten notes, Post-it notes, printed copies of emails or other electronic documents, and any other tangible documents.

• Photographs, Images, and Scanned Documents: Digital photographs, images, screenshots, and scanned copies of documents stored on any device, server, or cloud platform.

• Backup Tapes, Archived Data, and Legacy System Data: Any backup tapes, disaster recovery archives, archived data stored on legacy systems, and any other historical data repositories containing documents within the scope of this hold.

• Metadata: All metadata associated with the foregoing categories of documents and ESI, including file creation dates, modification dates, author information, recipient information, and any system-generated metadata. Custodians should take care not to take any action that would alter or destroy metadata associated with potentially relevant documents.

The foregoing list is illustrative and not exhaustive. If you are uncertain whether a particular type of document or ESI is covered by the hold, you should preserve it and seek guidance from Calderwood & Harkness LLP or the Dunmore Legal Department.

IV. ENTITIES AND LOCATIONS COVERED

This litigation hold applies globally to all employees, officers, directors, contractors, consultants, temporary workers, and agents of the following Dunmore entities:

• Dunmore Energy Holdings Ltd. — Registered Office: Harbour Place, 4th Floor, 103 South Church Street, George Town, Grand Cayman, Cayman Islands. Operational Headquarters: 1200 McKinney Street, Suite 3400, Houston, TX 77010, United States.

• Dunmore Trading International Ltd. ("DTI") — Level 14, Gate Building 3, Dubai International Financial Centre, P.O. Box 506774, Dubai, United Arab Emirates. DIFC License No. CL-4827. DTI is the Company's principal commodities trading subsidiary and is a primary focus of the DOJ investigation.

• Dunmore upstream Americas LLC — 1200 McKinney Street, Suite 3400, Houston, TX 77010, United States. Registered Agent: 1209 Orange Street, Wilmington, DE 19801. EIN: 84-2937561.

• Dunmore Renewables GmbH — Überseeallee 12, 20457 Hamburg, Germany. Dunmore Renewables GmbH is included in the hold due to its proximity to Caspian Logistik GmbH and the potential for relevant documents to reside on shared European systems.

• Dunmore Exploration West Africa Ltd. — 14B Kofo Abayomi Street, Victoria Island, Lagos, Nigeria.

The hold covers operations and personnel across six jurisdictions: the Cayman Islands, the United Arab Emirates, the United States, Germany, Nigeria, and the United Kingdom. Although no Dunmore entity is domiciled in the United Kingdom, certain employees and contractors based in London — particularly those who have interacted with DTI's trading operations or who participated in relevant transactions — are also subject to this hold.

All IT personnel and records management staff at each entity listed above are specifically directed to maintain existing backup and archiving protocols and to suspend any routine document destruction, recycling, or purge schedules for the duration of the hold. This includes, without limitation:

• Suspension of any scheduled deletion of emails from corporate servers or individual mailboxes;

• Suspension of any scheduled overwriting or recycling of backup tapes;

• Suspension of any scheduled shredding, recycling, or offsite destruction of hard copy documents;

• Suspension of any decommissioning of servers, workstations, or storage devices that may contain relevant data; and

• Preservation of all access credentials and permissions for custodian accounts, including accounts of former employees who have departed the Company since January 1, 2019.

IT leadership at each entity should confirm that these measures remain in place and report any concerns or exceptions to the Dunmore Legal Department and Calderwood & Harkness LLP without delay.

V. SPECIFIC OBLIGATIONS OF ALL CUSTODIANS

Each custodian identified under this litigation hold bears personal responsibility for ensuring compliance with the preservation obligations described herein. The following sections set forth your specific obligations in detail. Please review them carefully and take immediate action where required.

A. Do Not Destroy, Delete, or Alter Any Documents

You must not destroy, delete, discard, alter, overwrite, or modify any document or ESI within the scope of this hold. This is the single most important obligation under the hold, and it applies without exception.

This obligation extends to all devices and storage locations, including:

• Company-issued desktop computers, laptops, and tablets;

• Company-issued mobile phones;

• Personal devices (including personal phones, tablets, laptops, and home computers) if any have been used at any time for Dunmore business communications;

• USB drives, external hard drives, and other portable storage media;

• Cloud storage accounts, whether corporate or personal, if they contain any Dunmore business documents; and

• Physical files, filing cabinets, desk drawers, and storage rooms.

In particular, custodians must observe the following prohibitions:

• Do not uninstall or delete any messaging applications (including Meridian Services Inc., Signal, Kestrel Data Systems, WeChat, or any similar application) that may contain relevant communications, even if you believe the application is no longer actively in use.

• Do not empty "Deleted Items" or "Trash" folders in any email account, whether corporate or personal.

• Do not defragment hard drives or reset any device to factory settings. Such actions may permanently destroy data, including deleted files that could otherwise be recovered through forensic means.

• Do not move documents from their current locations unless specifically instructed to do so by Calderwood & Harkness LLP or the Dunmore Legal Department in connection with a document collection effort.

• Do not modify, edit, or overwrite existing documents that fall within the scope of the hold. If you need to continue working with a document that is within scope, create a new copy and preserve the original in its unaltered state.

B. Suspend Routine Destruction

All automatic deletion protocols — including email auto-archive rules, auto-delete rules, and any scheduled purge processes — must remain suspended for all custodians identified in this hold. These suspensions were put in place at the time of the initial hold in April 2022 and must continue without interruption.

If you are aware of or suspect that your IT department has not yet disabled auto-delete functionality for your accounts, or if you have reason to believe that automatic deletion processes may be active for any of your accounts or devices, you must notify Elena Vasquez, Paralegal Manager, Calderwood & Harkness LLP, or the Dunmore Legal Department immediately. Contact information is provided in Section X below.

Similarly, if you have recently changed devices, migrated to a new system, or been provisioned with new accounts, you should promptly confirm with your local IT team and with the Dunmore Legal Department that appropriate hold mechanisms have been applied to the new accounts and devices.

C. Affirmative Preservation Steps

In addition to refraining from destruction, each custodian is required to take affirmative steps to ensure that potentially relevant documents are preserved:

• Review your files, devices, and accounts to ensure that all potentially relevant documents remain preserved in their current locations. This includes reviewing email folders, messaging applications, local file directories, network drives, cloud storage, and any physical files in your possession.

• Identify newly discovered repositories. If you have recently become aware of additional repositories of relevant documents not previously identified — for example, a personal cloud storage account (such as a personal Larkspur Technologies or Hollowell Health IT), an old laptop or mobile device, a filing cabinet at your home or at a remote office, or any other storage location — you must notify the Dunmore Legal Department or Calderwood & Harkness LLP's e-discovery team without delay. Notifications regarding newly discovered repositories should be directed to Thomas Bradshaw, Senior Paralegal and e-discovery Lead, who is managing the Nexagen Analytics project (Project No. NX-DEH-2204).

• Cooperate fully with document collection requests. You may be contacted by Nexagen Analytics Inc., our e-discovery vendor, or by the Dunmore Legal Department with requests to collect documents or forensic images from your devices and accounts. You are required to cooperate fully and promptly with all such requests. Collection activities are being coordinated by Brian Cavanaugh at Nexagen Analytics and Thomas Bradshaw at Calderwood & Harkness LLP.

• Report any concerns. If you become aware of any circumstance that may jeopardize the preservation of relevant documents — including potential loss, damage, or unauthorized access to documents or devices — report the matter immediately to the Dunmore Legal Department or Calderwood & Harkness LLP.

D. New Documents Created After the Hold

The litigation hold is not limited to documents that existed as of the date of the initial hold (April 20, 2022). Documents created after April 20, 2022 that fall within the scope of this hold are also subject to preservation obligations. As you continue to conduct business, you may create or receive new documents, emails, messages, or other records that relate to the subject matter areas described in Section III.A above. All such documents must be preserved.

You should continue to preserve all documents relating to the subject matter of the investigation as they are created or received. This is an ongoing obligation that will remain in effect for the duration of the hold. There is no date after which newly created documents are exempt from the hold.

VI. UPDATES SINCE THE INITIAL HOLD (APRIL 20, 2022)

Since the issuance of the initial litigation hold on April 20, 2022, several significant developments have occurred in connection with the DOJ investigation and the Company's response. These developments underscore the importance of continued strict compliance with all preservation obligations and are summarized below for your awareness.

Retention of E-discovery Vendor — Nexagen Analytics Inc. Calderwood & Harkness LLP has retained Nexagen Analytics Inc. to manage document collection, processing, hosting, and technology-assisted review for this matter. The engagement is designated as Project No. NX-DEH-2204, and the project manager is Brian Cavanaugh. Nexagen Analytics is coordinating the collection of documents and ESI from custodians across all six jurisdictions in which Dunmore entities operate. Document collection efforts are ongoing. Custodians should expect to receive collection requests and should respond promptly and cooperatively. All questions about the collection process should be directed to Thomas Bradshaw at Calderwood & Harkness LLP or Brian Cavanaugh at Nexagen Analytics.

Retention of Forensic Accounting Firm — Ridgeline Advisory Group LLC. Calderwood & Harkness LLP has retained Ridgeline Advisory Group LLC to perform forensic accounting analysis in connection with the investigation. The engagement is designated as Engagement No. RAG-2022-0319, and the engagement lead is Dr. Margaret Liu, CPA, CFE. Ridgeline Advisory is analyzing financial transaction flows, payment patterns, and related financial data. In connection with this forensic review, certain custodians may be contacted with additional document requests, particularly for financial and accounting records. Cooperation with such requests is required.

Witness Interviews. The Firm's investigation team has commenced a program of witness interviews as part of the internal investigation. The first round of interviews was conducted between May 18 and June 30, 2022. Twenty-two (22) interviews were completed across Houston, Dubai, and London. Additional interview rounds are anticipated in the coming months, and custodians who have not yet been interviewed may be contacted to schedule an interview. Participation in interviews, when requested, is expected. Custodians will be provided with individual counsel or the opportunity to consult with counsel in connection with any interview, as appropriate.

Personnel Changes. Certain individuals who were identified as custodians under the initial hold have since been placed on administrative leave or have departed the Company. Their preservation obligations continue to be managed through coordination between their personal counsel (where applicable) and Dunmore's established protocols for departing employees. The departure of a custodian does not terminate the hold as to documents that were in that individual's possession, custody, or control.

Rolling Document Production to the DOJ. A rolling document production protocol has been agreed between Calderwood & Harkness LLP and the DOJ NSD/CES. Pursuant to this protocol, responsive, non-privileged documents are being produced to the government on a rolling basis. Documents are Bates-stamped using the prefix DEH-DOJ. As of the date of this memorandum, multiple productions have been made, and additional productions will follow as document review continues. The integrity of the production process depends on the completeness of the underlying document collection, which in turn depends on custodian compliance with this hold.

Appointment of New Chief Compliance Officer. Priya Nayar has been appointed as the new Chief Compliance Officer of Dunmore Energy Holdings Ltd., effective August 1, 2022. Ms. Nayar will serve as a point of contact within the Company for compliance-related preservation matters going forward. Ms. Nayar's contact information is provided in Section X below.

These developments make clear that the investigation and related proceedings are active, extensive, and ongoing. Continued diligence in preserving all relevant documents and ESI is essential.

VII. CONSEQUENCES OF NON-COMPLIANCE

The Company and its outside counsel take document preservation obligations with the utmost seriousness, and all custodians are expected to do the same. Non-compliance with the obligations set forth in this memorandum may result in severe consequences at both the corporate and individual level.

Criminal Liability. The destruction, alteration, or concealment of documents relevant to a federal grand jury investigation may constitute obstruction of justice under federal law. Specifically, the following federal statutes, among others, may be implicated:

• 18 U.S.C. § 1503 — Obstruction of justice (influencing or injuring an officer or juror generally), which carries penalties of up to ten (10) years of imprisonment;

• 18 U.S.C. § 1512 — Tampering with a witness, victim, or informant, including the destruction or alteration of documents with the intent to impair their availability for use in an official proceeding, which carries penalties of up to twenty (20) years of imprisonment; and

• 18 U.S.C. § 1519 — Destruction, alteration, or falsification of records in federal investigations and bankruptcy, which carries penalties of up to twenty (20) years of imprisonment and applies broadly to the destruction of any document or tangible object with the intent to impede, obstruct, or influence the investigation or proper administration of any matter within the jurisdiction of any department or agency of the United States.

These statutes apply to individuals, and criminal prosecution for obstruction of justice may be brought against individual employees, officers, or directors who destroy or conceal documents relevant to the grand jury investigation, regardless of their seniority or role within the Company.

Spoliation Sanctions. Spoliation of evidence — that is, the destruction or material alteration of evidence that a party knew or should have known was relevant to pending or anticipated litigation or investigation — may result in severe adverse inferences, monetary sanctions, issue sanctions, or other penalties imposed by courts or government agencies against Dunmore. Courts may instruct juries that they may infer that destroyed documents were unfavorable to the Company, which can be devastating in litigation or enforcement proceedings.

Employment Consequences. Employees who fail to comply with this litigation hold may face disciplinary action up to and including termination of employment, in accordance with Dunmore's Code of Business Conduct and applicable employment policies.

Impact on Cooperation Credit. Dunmore's cooperation credit with the DOJ depends in substantial part on the Company's ability to demonstrate robust, good-faith document preservation and timely production. Individual non-compliance by any custodian undermines the Company's ability to demonstrate cooperation and may jeopardize the Company's position in negotiations with the government. The consequences of a single custodian's failure to preserve documents may therefore extend far beyond that individual and affect the Company and all of its employees.

VIII. CONFIDENTIALITY

The existence and content of this memorandum, the DOJ investigation, the grand jury subpoena GJ No. 22-418, and the internal investigation conducted by Calderwood & Harkness LLP are strictly confidential. The confidential nature of these matters is essential to protect the Company's legal interests, preserve applicable privileges, and comply with the obligations of secrecy that attach to grand jury proceedings.

You must observe the following confidentiality obligations:

• Do not discuss these matters with anyone outside the Company. This includes, without limitation, former employees, counterparties, business partners, vendors (other than those specifically retained in connection with the investigation, such as Nexagen Analytics and Ridgeline Advisory), competitors, industry contacts, family members, and the media.

• Do not respond to government inquiries without counsel. If you are contacted by any government agent, law enforcement officer, or representative of the DOJ, the FBI (including, without limitation, Special Agent Paul Reinhardt), OFAC, BIS, or any other federal, state, or foreign government agency in connection with any matter that may relate to this investigation, do not respond without first contacting Marcus Wellbourne, General Counsel, Dunmore Energy Holdings Ltd., or Victoria Chambers, Calderwood & Harkness LLP. You are not required to speak with any government agent, and you have the right to counsel. Please contact the individuals listed above immediately if any such contact occurs.

• Limit internal discussions. All internal discussions about the investigation and this litigation hold should be limited to those persons who have a need to know in connection with the performance of their job responsibilities and their compliance with preservation obligations. Do not discuss the investigation, the grand jury subpoena, or the internal investigation in common areas, at social events, or in any setting where the conversation could be overheard by persons who do not have a need to know.

• Exercise caution with electronic communications. When communicating about the investigation by email or other electronic means, ensure that your communications are directed only to authorized recipients and are marked as privileged and confidential where appropriate. If you are uncertain whether a particular communication should be made, consult with the Dunmore Legal Department or Calderwood & Harkness LLP before sending it.

Unauthorized disclosure of confidential information relating to the investigation may result in disciplinary action, may constitute a waiver of applicable legal privileges, and could adversely affect the Company's legal position.

IX. ACKNOWLEDGMENT REQUIREMENT

Each custodian who receives this memorandum is required to complete, sign, and return the attached Acknowledgment and Certification Form (Attachment A). The Acknowledgment and Certification Form confirms the following:

1. Receipt and Review. That the custodian has received and carefully reviewed this Litigation Hold Reminder Memorandum dated July 15, 2022.

2. Understanding. That the custodian understands the document preservation obligations described herein, including the scope of the hold, the types of documents and ESI covered, and the consequences of non-compliance.

3. Compliance Certification. That no documents within the scope of this hold have been destroyed, deleted, or altered since the issuance of the initial litigation hold on April 20, 2022. If a custodian is unable to make this certification, the custodian must immediately contact Calderwood & Harkness LLP or the Dunmore Legal Department.

4. Identification of New Repositories. Whether the custodian has identified any newly discovered repositories of potentially relevant documents that were not previously disclosed.

The signed Acknowledgment and Certification Form must be returned within five (5) business days of receipt to:

Elena Vasquez Paralegal Manager Calderwood & Harkness LLP 1750 Pennsylvania Avenue NW, Suite 800 Washington, DC 20006

Email: evasquez@calderwoodharkness.com

(via email scan or secure courier)

A copy must also be sent to:

Marcus Wellbourne General Counsel Dunmore Energy Holdings Ltd. 1200 McKinney Street, Suite 3400 Houston, TX 77010

Email: mwellbourne@dunmore-energy.com

Failure to return the signed Acknowledgment and Certification Form within the required timeframe will be escalated to the Dunmore Legal Department and may result in follow-up contact from Calderwood & Harkness LLP. All custodians are expected to comply with this requirement promptly.

X. CONTACT INFORMATION FOR QUESTIONS

All custodians are encouraged to contact any of the following individuals with questions about the scope of the hold, document identification, collection procedures, or any other matter addressed in this memorandum:

Calderwood & Harkness LLP

Dunmore Legal Department

Nexagen Analytics Inc. (e-discovery Vendor)

All custodians are reminded that questions should be directed to the contacts listed above rather than discussed among colleagues or with persons outside the Company. If you are uncertain about any aspect of your obligations under this hold, please ask — prompt inquiry is far preferable to inadvertent non-compliance.

This memorandum is issued jointly by Calderwood & Harkness LLP and the Dunmore Legal Department. Thank you for your continued cooperation and diligence in this important matter.

CALDERWOOD & HARKNESS LLP

By: ________

Name: Victoria Chambers, Esq.

Title: Responsible Partner, White Collar & Investigations

Date: July 15, 2022

DUNMORE ENERGY HOLDINGS LTD.

By: ________

Name: Marcus Wellbourne, Esq.

Title: General Counsel

Date: July 15, 2022

ATTACHMENT A

ACKNOWLEDGMENT AND CERTIFICATION FORM

Litigation Hold Reminder — July 15, 2022

Calderwood & Harkness LLP Matter No. 1016-00009

CONFIDENTIAL — ATTORNEY-CLIENT PRIVILEGED

I, the undersigned, hereby acknowledge and certify the following in connection with the Litigation Hold Reminder Memorandum dated July 15, 2022, issued by Calderwood & Harkness LLP and the Dunmore Legal Department:

I certify that I have read and understood the Litigation Hold Reminder Memorandum dated July 15, 2022 issued in connection with Calderwood & Harkness LLP Matter No. 1016-00009. I confirm that I have complied with and will continue to comply with all document preservation obligations described therein. I further certify that, to the best of my knowledge, I have not destroyed, deleted, or altered any documents or ESI within the scope of this hold since its original issuance on April 20, 2022.

Additional Repositories Disclosure:

I have NOT identified any additional repositories of potentially relevant documents not previously disclosed.

I HAVE identified additional repositories of potentially relevant documents not previously disclosed. Please describe below:

________________________________________

Custodian Signature: ________

Printed Name: ________

Date: ________

RETURN INSTRUCTIONS: This completed and signed Acknowledgment and Certification Form must be returned within five (5) business days of receipt to: