1017-00005 · Aurelius Global Media Group · Correspondence/Nakamura Reeves

letter-to-nakamura-reeves-re-investigation-scope.docx DOCUMENT Funds

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CALDERWOOD & HARKNESS LLP

ATTORNEYS AT LAW

1999 Avenue of the Stars, Suite 2800 Los Angeles, California 90067 Telephone: (310) 553-4000 Facsimile: (310) 553-4001 www.calderwoodharkness.com

May 10, 2023

VIA EMAIL AND U.S. MAIL

Sandra Reeves, Esq. Partner Nakamura Reeves LLP 515 South Flower Street, Suite 3600 Los Angeles, CA 90071

Re: Jenna Morales — Independent Investigation by Aurelius Global Media Group PLC Matter No.: 1017-00005

Dear Ms. Reeves:

I. Purpose of This Letter and Acknowledgment of Your Demand Letter

We write on behalf of our client, the Board of Directors of Aurelius Global Media Group PLC ("AGMG"), a public limited company incorporated in England and Wales and listed on the London Stock Exchange, in connection with the matter referenced above.

We hereby acknowledge receipt of your demand letter dated April 20, 2023, sent on behalf of your client, Jenna Morales, Vice President of Development at Aurelius Pacific Studios Inc. ("APS"), a wholly owned subsidiary of AGMG. Your letter was addressed to Victor Gallegos, Vice President of Human Resources at APS, at 3200 West Alameda Avenue, Suite 400, Burbank, California 91505.

Your demand letter alleged, among other things, that Ms. Morales was subjected to conduct constituting violations of the California Fair Employment and Housing Act ("FEHA"), Cal. Gov. Code §§ 12940 et seq., including claims of sexual harassment, retaliation for protected activity, and the creation and maintenance of a hostile work environment. Your letter further demanded the immediate preservation of all documents and electronically stored information relevant to Ms. Morales's complaints.

Mr. Gallegos appropriately referred your demand letter to AGMG's General Counsel, Fiona Blackwood, who in turn referred the matter to this firm in connection with the independent investigation described more fully below. The purpose of this letter is to inform you of the investigation that has been initiated, the interim protective measures that have been implemented, and the procedures that will govern Ms. Morales's participation in the investigation, should she choose to participate.

II. Description of the Independent Investigation

The AGMG Board of Directors, acting through a joint directive of its People & Culture Committee and its Audit & Risk Committee, has retained Calderwood & Harkness LLP to conduct an independent, privileged workplace investigation into the allegations of sexual harassment, retaliation, and hostile work environment raised by Ms. Morales and, to the extent relevant, any additional complaints or information that may bear upon those allegations. The engagement was formally executed on May 2, 2023, pursuant to an engagement letter between Calderwood & Harkness LLP and AGMG, acting through its Board of Directors.

Bernard Crawford, Partner in the firm's Employment Investigations and Counseling Practice, has been designated as the responsible partner leading the investigation. Mr. Crawford is supported by a team of attorneys within the firm who specialize in workplace investigations, employment litigation, and related regulatory matters.

The investigation encompasses the full scope of the complaints raised by Ms. Morales, including but not limited to the detailed allegations set forth in the report Ms. Morales submitted through the company's confidential Ethics & Compliance Hotline on April 18, 2023 (Report No. ECH-2023-0418-0037), as well as the additional allegations and supporting information contained in your April 20, 2023 demand letter.

In order to ensure the independence and integrity of the investigation, Elliot Vane, Chief Executive Officer of AGMG, has been formally recused from any oversight of, participation in, or access to information regarding the investigation. This recusal was deemed necessary and appropriate given Mr. Vane's direct reporting relationship with the individual who is the subject of the investigation, as described further below, and to avoid any actual or perceived conflict of interest. Mr. Vane has been informed of his recusal in writing and has acknowledged the same.

We wish to make clear that this investigation is being conducted at the direction of counsel and under the protection of the attorney-client privilege and the work-product doctrine. The privilege belongs exclusively to AGMG. No individual employee, officer, or director of AGMG or APS is a client of Calderwood & Harkness in connection with this matter, and no individual holds or may waive the privilege. The Board of Directors retains sole authority over any decisions regarding waiver of privilege.

III. Scope and Methodology of the Investigation

The investigation is designed to be thorough, fair, and impartial, consistent with AGMG's obligations under California law and its own internal policies. To that end, the investigation will encompass the following principal components:

Witness Interviews. Calderwood & Harkness will conduct interviews of all relevant witnesses, including complainants, the subject of the investigation, and other individuals reasonably believed to possess pertinent knowledge regarding the allegations. Witnesses will be identified through a combination of information provided by Ms. Morales (including in her Ethics & Compliance Hotline report and your demand letter), information provided by the subject of the investigation, information provided by Human Resources and other company personnel, and information that emerges during the course of the investigation itself. All witness interviews will be conducted by attorneys from Calderwood & Harkness.

Document Collection and Review. The investigation will include the collection and review of relevant documents and electronic communications, including but not limited to email correspondence, text messages, Meridian Solutions messages, calendar entries, memoranda, reports, personnel files, performance evaluations, and any other materials reasonably related to the allegations under investigation. Calderwood & Harkness has engaged an independent forensic technology vendor to assist with the preservation, collection, and processing of electronically stored information in a forensically sound manner.

Policy Analysis. The investigation will analyze the applicable company policies that bear upon the allegations, including the following:

• The AGMG Global Code of Conduct (Version 4.2, effective January 1, 2022);

• The APS Employee Handbook, California Supplement (revised March 15, 2022), including specifically:

• Anti-Harassment & Anti-Discrimination Policy (Section 5.3);

• Anti-Retaliation Policy (Section 5.7); and

• Complaint & Investigation Procedures (Section 8.1);

• Any other internal policies, procedures, or guidelines applicable to the conduct at issue.

Legal Analysis. The investigation will assess the allegations under applicable California law, including FEHA (Cal. Gov. Code §§ 12940 et seq.), as well as any other state or federal statutes, regulations, or common law principles that may be implicated by the facts as they are developed during the investigation.

Calderwood & Harkness is committed to conducting this investigation in a manner that is thorough, fair, and impartial. All witnesses will be treated with respect and professionalism, and all credible evidence will be considered and evaluated without predisposition or bias toward any party.

IV. Interim Protective Measures Already Taken

We wish to inform you of the interim protective measures that AGMG and APS have already implemented in response to the allegations raised by Ms. Morales, pending the completion of the investigation.

Administrative Leave of the Subject. The subject of the investigation, Marcus Hale, President of Aurelius Pacific Studios Inc., was placed on paid administrative leave effective May 3, 2023, pending the completion of Calderwood & Harkness's investigation. Mr. Hale has been instructed not to contact Ms. Morales, directly or indirectly, for any reason during the pendency of the investigation, and has been further instructed not to contact any potential witnesses regarding the substance of the investigation or the underlying allegations.

Suspension of System Access. Mr. Hale's access to all company email accounts, Meridian Solutions workspaces, internal content management systems, shared network drives, and all other AGMG and APS internal systems has been suspended effective May 3, 2023. Mr. Hale's access credentials have been deactivated, and his physical access badge for the Burbank office and all other AGMG and APS facilities has been temporarily disabled.

Litigation Hold and Document Preservation. A company-wide litigation hold and document preservation notice was issued on May 2, 2023, under the direction of Calderwood & Harkness and AGMG's General Counsel. The preservation notice was distributed to all relevant custodians and directed the immediate preservation of all documents, electronic communications, electronically stored information, and other materials of any kind that are relevant or potentially relevant to the matters under investigation. The scope of the preservation notice is consistent with, and in our view fully responsive to, the preservation demand set forth in your April 20, 2023 letter. The litigation hold is being administered by Calderwood & Harkness with the assistance of AGMG's in-house legal department and the company's information technology team.

These interim measures were implemented promptly and are designed to protect the integrity of the investigation, safeguard potentially relevant evidence, and ensure the safety and well-being of Ms. Morales and all other employees during the pendency of the investigation.

V. Ms. Morales's Participation in the Investigation

Calderwood & Harkness intends to request an interview with Ms. Morales as part of the investigation. Ms. Morales's account is of central importance to the investigation, and we believe that her participation will materially contribute to a thorough and accurate assessment of the facts.

We wish to confirm that Ms. Morales's participation in the investigation is entirely voluntary. While we strongly encourage her cooperation, we recognize and respect her right to decline to participate or to participate on terms that she and her counsel deem appropriate.

As counsel of record for Ms. Morales, you will be notified in advance of any interview request directed to Ms. Morales. We will work with you to identify a mutually convenient date, time, and location for any such interview, and we will make reasonable accommodations with respect to scheduling and logistics.

We acknowledge that Ms. Reeves, as Ms. Morales's personal counsel, may be present during Ms. Morales's interview. However, the interview itself will be conducted by Calderwood & Harkness attorneys, and we respectfully request that any questions or clarifications from counsel be reserved for appropriate intervals so as not to disrupt the flow of the interview.

Consistent with our ethical obligations and standard investigative practice, Calderwood & Harkness will provide Ms. Morales with a clear Upjohn admonition at the outset of any interview. Specifically, Ms. Morales will be advised that:

(a) Calderwood & Harkness LLP represents Aurelius Global Media Group PLC, and not Ms. Morales individually;

(b) The purpose of the interview is to gather facts in connection with the company's investigation;

(c) The conversation is protected by the attorney-client privilege, but that privilege belongs exclusively to AGMG, not to Ms. Morales;

(d) AGMG may, in its sole discretion, choose to waive the privilege and disclose the contents of the interview to third parties, including government agencies or regulators; and

(e) Ms. Morales should consult with her own counsel, Ms. Reeves, regarding any questions about her individual legal rights.

We trust that this process is consistent with your expectations. Should you have any questions or concerns regarding the interview process or the Upjohn admonition, we welcome the opportunity to discuss them with you in advance.

VI. Commitment to Non-Retaliation

AGMG and APS are firmly committed to ensuring that no retaliation of any kind is taken against Ms. Morales for raising her complaints, filing her Ethics & Compliance Hotline report, retaining outside counsel, sending her demand letter, or participating in the investigation in any capacity.

This commitment is grounded in both company policy and applicable law. APS's Anti-Retaliation Policy, set forth at Section 5.7 of the APS Employee Handbook, California Supplement, expressly prohibits retaliation against any employee who, in good faith, reports or complains about conduct that the employee reasonably believes to be unlawful or in violation of company policy, or who participates in any investigation of such conduct. The AGMG Global Code of Conduct similarly prohibits retaliatory conduct and requires all employees, officers, and directors to cooperate fully and honestly with internal investigations.

Ms. Morales's position, compensation, benefits, reporting structure, and all other terms and conditions of her employment will remain unchanged during the pendency of the investigation, and no adverse action of any kind will be taken against her in connection with the matters described herein.

Should Ms. Morales experience or become aware of any conduct that she believes may constitute retaliation—whether by Mr. Hale, any other AGMG or APS employee, or any third party acting on behalf of the company—we ask that she or you immediately bring such conduct to the attention of Bernard Crawford at Calderwood & Harkness LLP, or to Victor Gallegos, Vice President of Human Resources at APS. Any such report will be promptly and thoroughly investigated.

VII. Limitations on Disclosure

Because the investigation is privileged, ongoing, and not yet complete, Calderwood & Harkness is not in a position to share with outside parties—including counsel for complainants—the substance of witness interviews, the content of documentary evidence collected or reviewed, or any interim findings, assessments, or conclusions that may have been reached during the course of the investigation. We trust you will appreciate that maintaining the confidentiality of the investigation while it is ongoing is essential to preserving its integrity and ensuring the candor and cooperation of all participants.

Upon completion of the investigation, Calderwood & Harkness will present its findings and recommendations to the AGMG Board of Directors, acting through its People & Culture Committee and Audit & Risk Committee. The Board will then determine, in its sole discretion, what information, if any, may appropriately be shared with outside parties, and what remedial or corrective actions, if any, will be taken.

We anticipate that the investigation will be completed in a timely manner, consistent with AGMG's obligations under Cal. Gov. Code § 12940(k) to take all reasonable steps necessary to prevent and correct discriminatory and harassing conduct, including the obligation to conduct a fair, timely, and thorough investigation of complaints. We are committed to proceeding with appropriate diligence while also ensuring that the investigation is sufficiently thorough to address all relevant issues.

VIII. Point of Contact for Future Communications

Bernard Crawford, Partner at Calderwood & Harkness LLP, has been designated as the sole point of contact for all communications relating to the investigation on behalf of AGMG and APS. Mr. Crawford may be reached at the following:

Bernard Crawford, Partner Calderwood & Harkness LLP 1999 Avenue of the Stars, Suite 2800 Los Angeles, California 90067 Direct Telephone: (310) 553-4127

Email: b.crawford@calderwoodharkness.com

We respectfully request that all future correspondence from Nakamura Reeves LLP regarding this matter—including any supplemental complaints, document requests, scheduling inquiries, or other communications—be directed exclusively to Mr. Crawford at Calderwood & Harkness LLP, rather than directly to AGMG, APS, or any of their officers, directors, or employees, including Mr. Gallegos. This channeling of communications is intended to facilitate an orderly and efficient investigation and to ensure that all communications are properly received, reviewed, and responded to in a timely manner.

IX. Reservation of Rights

AGMG and APS expressly reserve all rights, privileges, immunities, and defenses available to them under applicable law, whether arising under statute, common law, contract, or equity. Nothing in this letter, and no action taken by AGMG, APS, or Calderwood & Harkness in connection with the investigation or otherwise, should be construed as an admission of liability, an acknowledgment that any violation of law or company policy has occurred, or a concession regarding the merits of any claim or allegation.

This letter is not intended to waive, and does not waive, any privilege, protection, or immunity, including without limitation the attorney-client privilege, the work-product doctrine, the joint defense or common interest privilege, or any other applicable privilege or protection. AGMG expressly reserves the right to assert all such privileges and protections in any future proceeding.

We appreciate your courtesy in bringing Ms. Morales's concerns to the company's attention, and we take the allegations raised in your demand letter with the utmost seriousness. Calderwood & Harkness is committed to conducting a thorough, fair, and impartial investigation, and we are confident that the process described above will serve the interests of all parties involved.

Should you have any questions or concerns regarding the substance or procedures described in this letter, or should you wish to discuss any aspect of Ms. Morales's participation in the investigation, please do not hesitate to contact me directly at the number or email address provided above. We look forward to working with you cooperatively throughout this process.

Very truly yours,

CALDERWOOD & HARKNESS LLP

By: ________

Bernard Crawford Partner Direct: (310) 553-4127

Email: b.crawford@calderwoodharkness.com

cc: Fiona Blackwood, General Counsel, Aurelius Global Media Group PLC cc: Devon Archer, Calderwood & Harkness LLP cc: Renata Vasquez, Calderwood & Harkness LLP

CONFIDENTIALITY NOTICE: This letter and its contents are privileged and confidential, are protected by the attorney-client privilege and the work-product doctrine, and are intended solely for the use of the individual or entity to whom they are addressed. If you are not the intended recipient of this communication, you are hereby notified that any review, disclosure, copying, distribution, or use of the contents of this communication is strictly prohibited. If you have received this communication in error, please notify the sender immediately by telephone and destroy all copies of this communication and any attachments. Thank you.

CALDERWOOD & HARKNESS LLP
ATTORNEYS AT LAW
1999 Avenue of the Stars, Suite 2800 Los Angeles, California 90067 Telephone: (310) 553-4000 Facsimile: (310) 553-4001 www.calderwoodharkness.com
May 10, 2023
VIA EMAIL AND U.S. MAIL
Sandra Reeves, Esq. Partner Nakamura Reeves LLP 515 South Flower Street, Suite 3600 Los Angeles, CA 90071
Re: Jenna Morales — Independent Investigation by Aurelius Global Media Group PLC Matter No.: 1017-00005
Dear Ms. Reeves:
I. Purpose of This Letter and Acknowledgment of Your Demand Letter
We write on behalf of our client, the Board of Directors of Aurelius Global Media Group PLC ("AGMG"), a public limited company incorporated in England and Wales and listed on the London Stock Exchange, in connection with the matter referenced above.
We hereby acknowledge receipt of your demand letter dated April 20, 2023, sent on behalf of your client, Jenna Morales, Vice President of Development at Aurelius Pacific Studios Inc. ("APS"), a wholly owned subsidiary of AGMG. Your letter was addressed to Victor Gallegos, Vice President of Human Resources at APS, at 3200 West Alameda Avenue, Suite 400, Burbank, California 91505.
Your demand letter alleged, among other things, that Ms. Morales was subjected to conduct constituting violations of the California Fair Employment and Housing Act ("FEHA"), Cal. Gov. Code §§ 12940 et seq., including claims of sexual harassment, retaliation for protected activity, and the creation and maintenance of a hostile work environment. Your letter further demanded the immediate preservation of all documents and electronically stored information relevant to Ms. Morales's complaints.
Mr. Gallegos appropriately referred your demand letter to AGMG's General Counsel, Fiona Blackwood, who in turn referred the matter to this firm in connection with the independent investigation described more fully below. The purpose of this letter is to inform you of the investigation that has been initiated, the interim protective measures that have been implemented, and the procedures that will govern Ms. Morales's participation in the investigation, should she choose to participate.
II. Description of the Independent Investigation
The AGMG Board of Directors, acting through a joint directive of its People & Culture Committee and its Audit & Risk Committee, has retained Calderwood & Harkness LLP to conduct an independent, privileged workplace investigation into the allegations of sexual harassment, retaliation, and hostile work environment raised by Ms. Morales and, to the extent relevant, any additional complaints or information that may bear upon those allegations. The engagement was formally executed on May 2, 2023, pursuant to an engagement letter between Calderwood & Harkness LLP and AGMG, acting through its Board of Directors.
Bernard Crawford, Partner in the firm's Employment Investigations and Counseling Practice, has been designated as the responsible partner leading the investigation. Mr. Crawford is supported by a team of attorneys within the firm who specialize in workplace investigations, employment litigation, and related regulatory matters.
The investigation encompasses the full scope of the complaints raised by Ms. Morales, including but not limited to the detailed allegations set forth in the report Ms. Morales submitted through the company's confidential Ethics & Compliance Hotline on April 18, 2023 (Report No. ECH-2023-0418-0037), as well as the additional allegations and supporting information contained in your April 20, 2023 demand letter.
In order to ensure the independence and integrity of the investigation, Elliot Vane, Chief Executive Officer of AGMG, has been formally recused from any oversight of, participation in, or access to information regarding the investigation. This recusal was deemed necessary and appropriate given Mr. Vane's direct reporting relationship with the individual who is the subject of the investigation, as described further below, and to avoid any actual or perceived conflict of interest. Mr. Vane has been informed of his recusal in writing and has acknowledged the same.
We wish to make clear that this investigation is being conducted at the direction of counsel and under the protection of the attorney-client privilege and the work-product doctrine. The privilege belongs exclusively to AGMG. No individual employee, officer, or director of AGMG or APS is a client of Calderwood & Harkness in connection with this matter, and no individual holds or may waive the privilege. The Board of Directors retains sole authority over any decisions regarding waiver of privilege.
III. Scope and Methodology of the Investigation
The investigation is designed to be thorough, fair, and impartial, consistent with AGMG's obligations under California law and its own internal policies. To that end, the investigation will encompass the following principal components:
Witness Interviews. Calderwood & Harkness will conduct interviews of all relevant witnesses, including complainants, the subject of the investigation, and other individuals reasonably believed to possess pertinent knowledge regarding the allegations. Witnesses will be identified through a combination of information provided by Ms. Morales (including in her Ethics & Compliance Hotline report and your demand letter), information provided by the subject of the investigation, information provided by Human Resources and other company personnel, and information that emerges during the course of the investigation itself. All witness interviews will be conducted by attorneys from Calderwood & Harkness.
Document Collection and Review. The investigation will include the collection and review of relevant documents and electronic communications, including but not limited to email correspondence, text messages, Meridian Solutions messages, calendar entries, memoranda, reports, personnel files, performance evaluations, and any other materials reasonably related to the allegations under investigation. Calderwood & Harkness has engaged an independent forensic technology vendor to assist with the preservation, collection, and processing of electronically stored information in a forensically sound manner.
Policy Analysis. The investigation will analyze the applicable company policies that bear upon the allegations, including the following:
• The AGMG Global Code of Conduct (Version 4.2, effective January 1, 2022);
• The APS Employee Handbook, California Supplement (revised March 15, 2022), including specifically:
• Anti-Harassment & Anti-Discrimination Policy (Section 5.3);
• Anti-Retaliation Policy (Section 5.7); and
• Complaint & Investigation Procedures (Section 8.1);
• Any other internal policies, procedures, or guidelines applicable to the conduct at issue.
Legal Analysis. The investigation will assess the allegations under applicable California law, including FEHA (Cal. Gov. Code §§ 12940 et seq.), as well as any other state or federal statutes, regulations, or common law principles that may be implicated by the facts as they are developed during the investigation.
Calderwood & Harkness is committed to conducting this investigation in a manner that is thorough, fair, and impartial. All witnesses will be treated with respect and professionalism, and all credible evidence will be considered and evaluated without predisposition or bias toward any party.
IV. Interim Protective Measures Already Taken
We wish to inform you of the interim protective measures that AGMG and APS have already implemented in response to the allegations raised by Ms. Morales, pending the completion of the investigation.
Administrative Leave of the Subject. The subject of the investigation, Marcus Hale, President of Aurelius Pacific Studios Inc., was placed on paid administrative leave effective May 3, 2023, pending the completion of Calderwood & Harkness's investigation. Mr. Hale has been instructed not to contact Ms. Morales, directly or indirectly, for any reason during the pendency of the investigation, and has been further instructed not to contact any potential witnesses regarding the substance of the investigation or the underlying allegations.
Suspension of System Access. Mr. Hale's access to all company email accounts, Meridian Solutions workspaces, internal content management systems, shared network drives, and all other AGMG and APS internal systems has been suspended effective May 3, 2023. Mr. Hale's access credentials have been deactivated, and his physical access badge for the Burbank office and all other AGMG and APS facilities has been temporarily disabled.
Litigation Hold and Document Preservation. A company-wide litigation hold and document preservation notice was issued on May 2, 2023, under the direction of Calderwood & Harkness and AGMG's General Counsel. The preservation notice was distributed to all relevant custodians and directed the immediate preservation of all documents, electronic communications, electronically stored information, and other materials of any kind that are relevant or potentially relevant to the matters under investigation. The scope of the preservation notice is consistent with, and in our view fully responsive to, the preservation demand set forth in your April 20, 2023 letter. The litigation hold is being administered by Calderwood & Harkness with the assistance of AGMG's in-house legal department and the company's information technology team.
These interim measures were implemented promptly and are designed to protect the integrity of the investigation, safeguard potentially relevant evidence, and ensure the safety and well-being of Ms. Morales and all other employees during the pendency of the investigation.
V. Ms. Morales's Participation in the Investigation
Calderwood & Harkness intends to request an interview with Ms. Morales as part of the investigation. Ms. Morales's account is of central importance to the investigation, and we believe that her participation will materially contribute to a thorough and accurate assessment of the facts.
We wish to confirm that Ms. Morales's participation in the investigation is entirely voluntary. While we strongly encourage her cooperation, we recognize and respect her right to decline to participate or to participate on terms that she and her counsel deem appropriate.
As counsel of record for Ms. Morales, you will be notified in advance of any interview request directed to Ms. Morales. We will work with you to identify a mutually convenient date, time, and location for any such interview, and we will make reasonable accommodations with respect to scheduling and logistics.
We acknowledge that Ms. Reeves, as Ms. Morales's personal counsel, may be present during Ms. Morales's interview. However, the interview itself will be conducted by Calderwood & Harkness attorneys, and we respectfully request that any questions or clarifications from counsel be reserved for appropriate intervals so as not to disrupt the flow of the interview.
Consistent with our ethical obligations and standard investigative practice, Calderwood & Harkness will provide Ms. Morales with a clear Upjohn admonition at the outset of any interview. Specifically, Ms. Morales will be advised that:
(a) Calderwood & Harkness LLP represents Aurelius Global Media Group PLC, and not Ms. Morales individually;
(b) The purpose of the interview is to gather facts in connection with the company's investigation;
(c) The conversation is protected by the attorney-client privilege, but that privilege belongs exclusively to AGMG, not to Ms. Morales;
(d) AGMG may, in its sole discretion, choose to waive the privilege and disclose the contents of the interview to third parties, including government agencies or regulators; and
(e) Ms. Morales should consult with her own counsel, Ms. Reeves, regarding any questions about her individual legal rights.
We trust that this process is consistent with your expectations. Should you have any questions or concerns regarding the interview process or the Upjohn admonition, we welcome the opportunity to discuss them with you in advance.
VI. Commitment to Non-Retaliation
AGMG and APS are firmly committed to ensuring that no retaliation of any kind is taken against Ms. Morales for raising her complaints, filing her Ethics & Compliance Hotline report, retaining outside counsel, sending her demand letter, or participating in the investigation in any capacity.
This commitment is grounded in both company policy and applicable law. APS's Anti-Retaliation Policy, set forth at Section 5.7 of the APS Employee Handbook, California Supplement, expressly prohibits retaliation against any employee who, in good faith, reports or complains about conduct that the employee reasonably believes to be unlawful or in violation of company policy, or who participates in any investigation of such conduct. The AGMG Global Code of Conduct similarly prohibits retaliatory conduct and requires all employees, officers, and directors to cooperate fully and honestly with internal investigations.
Ms. Morales's position, compensation, benefits, reporting structure, and all other terms and conditions of her employment will remain unchanged during the pendency of the investigation, and no adverse action of any kind will be taken against her in connection with the matters described herein.
Should Ms. Morales experience or become aware of any conduct that she believes may constitute retaliation—whether by Mr. Hale, any other AGMG or APS employee, or any third party acting on behalf of the company—we ask that she or you immediately bring such conduct to the attention of Bernard Crawford at Calderwood & Harkness LLP, or to Victor Gallegos, Vice President of Human Resources at APS. Any such report will be promptly and thoroughly investigated.
VII. Limitations on Disclosure
Because the investigation is privileged, ongoing, and not yet complete, Calderwood & Harkness is not in a position to share with outside parties—including counsel for complainants—the substance of witness interviews, the content of documentary evidence collected or reviewed, or any interim findings, assessments, or conclusions that may have been reached during the course of the investigation. We trust you will appreciate that maintaining the confidentiality of the investigation while it is ongoing is essential to preserving its integrity and ensuring the candor and cooperation of all participants.
Upon completion of the investigation, Calderwood & Harkness will present its findings and recommendations to the AGMG Board of Directors, acting through its People & Culture Committee and Audit & Risk Committee. The Board will then determine, in its sole discretion, what information, if any, may appropriately be shared with outside parties, and what remedial or corrective actions, if any, will be taken.
We anticipate that the investigation will be completed in a timely manner, consistent with AGMG's obligations under Cal. Gov. Code § 12940(k) to take all reasonable steps necessary to prevent and correct discriminatory and harassing conduct, including the obligation to conduct a fair, timely, and thorough investigation of complaints. We are committed to proceeding with appropriate diligence while also ensuring that the investigation is sufficiently thorough to address all relevant issues.
VIII. Point of Contact for Future Communications
Bernard Crawford, Partner at Calderwood & Harkness LLP, has been designated as the sole point of contact for all communications relating to the investigation on behalf of AGMG and APS. Mr. Crawford may be reached at the following:
Bernard Crawford, Partner Calderwood & Harkness LLP 1999 Avenue of the Stars, Suite 2800 Los Angeles, California 90067 Direct Telephone: (310) 553-4127
Email: b.crawford@calderwoodharkness.com
We respectfully request that all future correspondence from Nakamura Reeves LLP regarding this matter—including any supplemental complaints, document requests, scheduling inquiries, or other communications—be directed exclusively to Mr. Crawford at Calderwood & Harkness LLP, rather than directly to AGMG, APS, or any of their officers, directors, or employees, including Mr. Gallegos. This channeling of communications is intended to facilitate an orderly and efficient investigation and to ensure that all communications are properly received, reviewed, and responded to in a timely manner.
IX. Reservation of Rights
AGMG and APS expressly reserve all rights, privileges, immunities, and defenses available to them under applicable law, whether arising under statute, common law, contract, or equity. Nothing in this letter, and no action taken by AGMG, APS, or Calderwood & Harkness in connection with the investigation or otherwise, should be construed as an admission of liability, an acknowledgment that any violation of law or company policy has occurred, or a concession regarding the merits of any claim or allegation.
This letter is not intended to waive, and does not waive, any privilege, protection, or immunity, including without limitation the attorney-client privilege, the work-product doctrine, the joint defense or common interest privilege, or any other applicable privilege or protection. AGMG expressly reserves the right to assert all such privileges and protections in any future proceeding.
We appreciate your courtesy in bringing Ms. Morales's concerns to the company's attention, and we take the allegations raised in your demand letter with the utmost seriousness. Calderwood & Harkness is committed to conducting a thorough, fair, and impartial investigation, and we are confident that the process described above will serve the interests of all parties involved.
Should you have any questions or concerns regarding the substance or procedures described in this letter, or should you wish to discuss any aspect of Ms. Morales's participation in the investigation, please do not hesitate to contact me directly at the number or email address provided above. We look forward to working with you cooperatively throughout this process.
Very truly yours,
CALDERWOOD & HARKNESS LLP
By: ________
Bernard Crawford Partner Direct: (310) 553-4127
Email: b.crawford@calderwoodharkness.com
cc: Fiona Blackwood, General Counsel, Aurelius Global Media Group PLC cc: Devon Archer, Calderwood & Harkness LLP cc: Renata Vasquez, Calderwood & Harkness LLP
CONFIDENTIALITY NOTICE: This letter and its contents are privileged and confidential, are protected by the attorney-client privilege and the work-product doctrine, and are intended solely for the use of the individual or entity to whom they are addressed. If you are not the intended recipient of this communication, you are hereby notified that any review, disclosure, copying, distribution, or use of the contents of this communication is strictly prohibited. If you have received this communication in error, please notify the sender immediately by telephone and destroy all copies of this communication and any attachments. Thank you.

CALDERWOOD & HARKNESS LLP

ATTORNEYS AT LAW

VIA EMAIL AND U.S. MAIL

CALDERWOOD & HARKNESS LLP

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