Corporate

Update on the Jubilee Due Diligence

Tokyo, Jul. 28, 2011

In July 2010, MODEC, Inc. announced that as part of the lease financing for the Jubilee FPSO, under the Representations and Warranties provisions, MODEC had disclosed to the other potential equity partners in Jubilee Ghana MV21 B.V., a special purpose company incorporated in the Netherlands, and the lending banks all of the contracts that were executed for this project. At the request of one of the equity partners, MODEC undertook a due diligence review of the service agreement with Strategic Oil and Gas Resources Limited and then MODEC provided information to the Department of Justice. In January 2011, MODEC announced that an independent investigation conducted by a well-recognized law firm commissioned by the MODEC Board found no evidence of any violation of the U.S. Foreign Corrupt Practices Act or any other applicable jurisdiction's anti-bribery laws in relation to this project. Today, the Department of Justice notified MODEC that it was not going forward with any inquiry relating to MODEC at this time.

Reference