Guidelines for Corporate Disclosure

I. Purpose and status

These Guidelines protect accuracy, confidentiality, consistency, and appropriate approval in communications with stockholders, lenders, investors, counterparties, governments, communities, media, and the public. The Company is assumed to be privately held and not an Exchange Act reporting issuer. Regulation FD and stock-exchange continuous-disclosure rules are not treated as currently applicable.

II. Disclosure principles

• Communications must be accurate, balanced, understandable, appropriately supported, and not misleading by statement or omission.
• Material nonpublic information must be protected and shared only for authorized business need under appropriate confidentiality safeguards.
• Only authorized spokespersons may speak for the Company.
• Financial, reserves, production, technical, HSE, climate, and sustainability information must be verified by qualified functions before release.
• Contractual reporting to stockholders, lenders, insurers, and partners must be timely and consistent with governing agreements.

III. Potentially material information

Potentially material matters include financing, liquidity, defaults, equity issuances, acquisitions, dispositions, joint ventures, major contracts, significant well results, reserves or production changes, license grants or losses, government action, litigation, cybersecurity incidents, environmental events, fatalities, sanctions concerns, corruption allegations, senior leadership changes, and significant forecasts or impairments.

IV. Disclosure Committee

Management may establish a Disclosure Committee including the CEO, CFO, Chief Legal Officer, and relevant technical or operational leaders. It will assess materiality, audience, legal and contractual duties, confidentiality, verification, timing, spokespersons, and Board involvement. Urgent matters may be addressed by available members with prompt documentation.

V. Verification and approval

The business owner must prepare source support and identify assumptions. Finance verifies financial information; qualified technical personnel verify reserves, resources, production, and engineering information; HSE verifies incident and environmental data; Legal reviews obligations, privilege, confidentiality, sanctions, and litigation; the CEO or delegate approves external release. Board approval is required for matters reserved to the Board or carrying exceptional strategic or reputational significance.

VI. Authorized spokespersons

Unless specifically authorized, only the CEO, CFO, Chief Legal Officer, designated investor-relations personnel, or another approved spokesperson may communicate on behalf of the Company with investors, lenders, analysts, media, rating agencies, or government leaders. Employees must refer inquiries to an authorized spokesperson.

VII. Rumors, leaks, and inadvertent disclosure

The Company generally does not comment on rumors. Suspected leaks or inadvertent disclosure must be reported immediately to Legal. Management will assess corrective communication, confidentiality remediation, insider-trading restrictions, contractual notice, and regulator engagement.

VIII. Investor and lender presentations

Presentations must be reviewed for consistency with approved financial and technical information, risk factors, confidentiality, and forward-looking assumptions. Forecasts must identify material assumptions and uncertainty. Documents must not imply asset ownership, reserves, permits, contracts, or counterparties beyond verified facts.

IX. Future public-company transition

Before an IPO, public debt issuance, Exchange Act registration, or exchange listing, counsel must revise these Guidelines for Regulation FD, SEC filing controls, Form 8-K and periodic reporting, stock-exchange rules, earnings communications, public website use, and Board visibility of filings and announcements.

X. Records and training

The Company will retain final disclosures and supporting approvals under its records policy and train authorized spokespersons and relevant employees.