Frequently asked questions

What metals will Adriatic Metals mine and market?

Adriatic Metals’s Rupice deposit is what is commonly referred to as a polymetallic deposit, in that it contains many different metals. The ore contains marketable quantities of silver, zinc, lead, gold and copper. After mining the ore at Rupice it will be transported for processing at Tisovci (near Vares) where two products will be made; a silver/lead concentrate and a zinc concentrate. Gold and copper in smaller quantities, are found in both the products.

Silver, traditionally considered a precious metal, is now classed as a transition metal; one of the metals vital to the world’s transition to net zero. This is because of it use in many renewable energy sectors, specifically in photo-voltaic panels (solar panels) and in electric car charging infrastructure.

Lead remains important due to its use a battery metal, whilst vehicles are shifting to electric, they still require a (small) lead battery and moreover it is the use of industrial batteries to store renewable energy created by solar and wind ahead of distribution to the power networks that is most important to net zero transition.

And without copper electricity can neither be distributed through grids to homes and industry. To achieve net zero transition, it has been estimated that more copper is required in the next fifteen years than has been mined since its first use nearly 5,000 years ago.

Adriatic Metals, Lykos Metals and Rio Tinto are all the same company

Adriatic Metals, Lykos Metals and Rio Tinto are separate companies and not part of the same group or related in any way whatsoever. Adriatic Metals is a publicly traded company listed on both the London and Australian Stock Exchanges. Anyone can buy or sell shares in the Company via those markets, subject to the applicable stock exchange rules and securities laws. A list of major shareholders holding more than 2% of Adriatic Metals’ issued share capital can be found on the Adriatic Metals website. The Company is not aware that either Lykos Metals or Rio Tinto hold any shares in Adriatic Metals. The Company does not hold shares in Lykos Metals or Rio Tinto, has no economic interest in either company and is independent of both of them. The management of Adriatic Metals has no relationship with either company.

Documents:

Adriatic Metals has not been granted the Status of Project of Special Importance but uses the phrase as publicity material

The Ministry of Foreign Trade and Economic Relations of Bosnia and Herzegovina issued a Certificate of Recognition of the Project of Importance for Bosnia and Herzegovina, no: 05-2-19-1004-1/23 on the 23rd of March 2023.

Documents:

Adriatic Metals bribed Zenica Doboj Canton to issue the extended Concession areas and deprived the Canton of its rightful revenue from the fees

Adriatic Metals has made KM 2.8 million in concession fee payments to Zenica-Doboj Canton (“ZDK”) between 2013 and June 2023, and is forecast to make further payments of approximately KM 62 million over the life of the project. ZDK is one of two cantons in Bosnia and Herzegovina that requires a concession to be granted before exploration permits can be issued by the Ministry of Mining, Energy and Infrastructure. Exploration is inherently high risk, particularly for base metals, as the deposits are typically very difficult to find, and require extensive drilling to determine their economic viability. The global average time scale from exploration commencing to achieving first revenue in a base metals mine is over 17 years. Adriatic Metals has to date completed over 88,000 meters of drilling at a cost of KM 53 million, and is yet to produce revenue from its investment. In almost all other jurisdictions, exploration permits are granted over large areas so that geologists can use a variety of techniques such as airborne surveys, structural mapping, soil sampling and ground based geo-physical surveys, before they even consider drilling, to confirm the existence of mineralisation. To encourage further exploration, the ZDK government reduced the upfront concession fee, and substantially increased the annual fee should exploitation of an identified metal deposit occur. As a result, over the longer term, ZDK will receive substantially higher fees. This change in policy by the Canton relates to all future mining concessions, as can be seen in the attached decisions published by the ZDK government.

Documents:

Adriatic Metals was given reduced concession fees as a special favour by Zenica Doboj Canton

A one-off concession fee is immediately payable upon signing of a concession agreement and represents compensation for the granted right (for exploration and exploitation) that enables the concessionaire to conduct only exploration until such time as an exploitation permit has been granted. The concessionaire is obliged to provide the Federal Minister of Energy, Mining and Industry with all data collected during the exploration period, on both a quarterly and annual basis, which the canton can use for the issuing of new concessions, projects, or investments, regardless of the fact that all costs for exploration are borne exclusively by the concessionaire. The “continuous” concession Fee is a fee for the exploitation of a concession, i.e. it is paid when commercial production begins as a fee per tonne of processed ore.

Zenica-Doboj Canton (“ZDK”) on 18th April 2013 adopted a decision on determining the minimum fees for concessions, number: 02-14-9491/13 which, in Article 3 determines that the fee for the concession is KM 10,000.00 per hectare for nine types of concession, namely:

1. Exploration and/or exploitation of energy mineral raw materials; 2. Exploration and/or exploitation of metallic mineral raw materials; 3. Exploration and/or exploitation of limestone; 4. Exploration and/or exploitation of rocks of volcanic origin; 5. Exploration and/or exploitation of decorative limestone; 6. Exploration and/or exploitation of decorative stone of volcanic origin; 7. Exploration and/or exploitation of secondary deposits; 8. Exploration and/or exploitation of all types of salt and saline waters; and 9. Exploration and/or exploitation of gravel and sand from watercourses and alluvium.

In 2019, in order to ensure the application of the principles of equal treatment, non-discrimination and transparency, ZDK formed an inter-departmental working group with the task of reviewing the amount of the one-off concession fees granted in 2017 to the Olovo lead mine (owned by Geomet d.o.o,, a company unrelated to Adriatic Metals) and in 2018, all coal mines in the Canton (Official Gazette ZDK no. 6/13 and 16/18) and to propose appropriate changes to the relevant decision after consideration and analysis.

After the completion of the review by the inter-departmental working group the Ministry of Economy sent ZDK Government a “Proposal for a Decision on Changes in Concession Fees”, which the Government adopted with the “Decision (number 02-11-6038/20) on Determining the Minimum Fees for Concessions” dated 30th April 2020. This Decision amended the one-off concession fee for all concessions, except coal mines, from KM 10,000.00 KM per hectare to KM 150 KM per hectare for category 2 and above projects, and from KM 10,000.00 KM per hectare to KM 1,000.00 per hectare for all other categories. Additionally, this Decision changed the continuous concession fee for all categories. Specifically, for Adriatic Metals concessions, the continuous Fee was increased from KM 1.5 per tonne to KM 3.9 per tonne of ore extracted.

The accusation that Adriatic Metals was given reduced concession fees as a special favour by ZDK is entirely false. As a result of the changes in concession fees made by ZDK, the predicted total concession fees paid, or to be paid, by the Company has increased by more than 300%, when factoring in the additional mine life that has resulted from increased exploration expenditure, which would not have occurred if the one-off concession fee had remained at the 2013 level.

Documents:

Adriatic Metals is under investigation by several Bosnia and Herzegovinian and international institutions for corruption

Adriatic Metals has not been advised by any Bosnia and Herzegovinian or international institution that the Company is under investigation for corruption, or indeed any other offence. The Company has a strict Anti-Corruption and Bribery Policy, and all its staff are trained on that Policy as part of their employment induction process. Adriatic Metals is a British company, and therefore under the global jurisdiction of the “UK Bribery Act 2010”, a legislative requirement with extra jurisdictional authority to ensure that British companies, and their management, adhere to the highest standards of corporate governance. Adriatic Metals can re-iterate and confirm that it is in full compliance with the UK Bribery Act 2010, and has a statutory responsibility to warrant so annual.

Documents:

The Berne, Ramsar and Aarhus Conventions were violated in obtaining environmental permits

The Company is clear that there have been no violations of either state regulations or any international conventions, let alone those ratified by Bosnia and Herzegovina, during its process of obtaining environmental permits.

Adriatic Metals BH d.o.o. (“AMBH”), the subsidiary of Adriatic Metals, holding its Bosnian concessions has conducted three separate Environmental Impact Assessments (“EIA”) resulting in the subsequent issuance of three Environmental Permits whilst developing its Vareš project. The assessments were carried out in accordance with all legal regulations and conventions.

The remediation and closure of the former lead, zinc, and barite mine facility at the Veovača I – Tisovci:

This assessment was conducted by the state authorised firm Enova d.o.o. Sarajevo, in accordance with the provisions of Article 61 and 62 of the Law on Environmental Protection (Official Gazette of FBiH No. 33/03) and Article 8 of the Law on Amendments and Supplements to the Law on Environmental Protection (Official Gazette of FBiH No. 38/09).

A public hearing was held on 18th September 2019, at the Culture Center in Pržići, Pržići bb, Vareš. All EIA documentation was made available to the public at the Ministry of Environmental and Tourism (“FMOIT”) offices and through their website, www.fmoit.ba, as reported on 26th August 2019 in the daily newspaper Oslobođenje. FMOIT was responsible for extending invitations to all interested parties.

Following the public hearing and incorporating requests from local communities and comments from members of an expert commission, an Integrated Environmental Impact Assessment was prepared, and permit number UPI 05/2-23-11-145/19 SN was issued on 26th November 2019. FMOIT did not receive any complaints, and the permit is now in full effect.

The rehabilitation of the lead, zinc, and barite ore mining and processing plant at the Veovača I - Tisovci I - Veovača II:

This assessment was conducted by the state authorised firm Enova d.o.o. Sarajevo, in accordance with the provisions of Article 61 and 62 of the Law on Environmental Protection (Official Gazette of FBiH No. 33/03) and Article 8 of the Law on Amendments and Supplements to the Law on Environmental Protection (Official Gazette of FBiH No. 38/09).

A public hearing was held on 19th December 2019, at the Culture Centre in Pržići, Pržići bb, Vareš. All EIA documentation was made available to the public at the FMOIT offices and through the website, as reported on 29th November 2019 in the daily newspaper Oslobođenje. FMOIT was responsible for extending invitations to all interested parties.

Following the public hearing and incorporating requests from local communities and comments from members of an expert commission, an Integrated Environmental Impact Assessment was prepared, and permit number UPI 05/2-23-11-195/19 was issued on 20th May 2021. FMOIT did not receive any complaints, and the permit is now in full effect.

The underground Exploitation of complex lead, zinc, barite, and associated mineral components at the Rupice site, municipality of Vareš:

This assessment was conducted by the state authorised firm Rudarski Institut d.d. Tuzla, in accordance with the provisions of Article 61 and 62 of the Law on Environmental Protection (Official Gazette of FBiH No. 33/03) and Article 8 of the Law on Amendments and Supplements to the Law on Environmental Protection (Official Gazette of FBiH No. 38/09).

A public hearing was held on 31st August 2020, at the cultural centre of MZ Borovica. All EIA documentation was made available to the public at the FMOIT offices and through the website, as reported on 10th August 2020 in the daily newspaper Oslobođenje. FMOIT was responsible for extending invitations to all interested parties.

Following the public hearing and incorporating requests from local communities and comments from members of an expert commission, an Integrated Environmental Impact Assessment was prepared and issued for public comment on 21st January 2021. Subsequently permit number UPI 05/2-02-19-5-60/20 SC was issued on 5th May 2021. FMOIT did not receive any complaints, and the permit is now in full effect.

Further to the completion of the EIAs and issuance of the resulting permits, the Company elected to complete a two-year long, internationally compliant Environmental and Social Impact Assessment (“ESIA”), not required by Bosnian regulations or conventions. This first natural resources ESIA (in Bosnia and Herzegovina) was conducted by renown UK environmental consulting company Wardell Armstrong. It was prepared according to the guidelines of the European Bank for Reconstruction and Development and, as such, does not have, nor need to have, an official approval process.

Documents:

The environmental impact statement was not approved by the government, but rather by a paid consultant of Adriatic Metals

The environmental impact assessments, conducted in accordance with the legislation of Bosnia and Herzegovina, and required before exploitation can commence, can only be carried out by state authorised companies. The Company’s assessments were conducted out by Enova d.o.o. Sarajevo and Rudarski Institut d.d. Tuzla. After the statutory disclosure of the studies, reviews by expert panel and public hearings permits were issued.

A voluntary, internationally compliant, Environmental and Social Impact Assessment was additionally undertaken by the renowned UK environmental consulting company Wardell Armstrong. This Assessment was not mandated by the regulations of Bosnia and Herzegovina; rather, it was based on the guidelines of the European Bank for Reconstruction and Development’s 2019 Performance Requirements, as detailed in their 2019 Environmental and Social Policy. As such, it does not require an official approval process.

The commissioning of this additional impact assessment was voluntary and represents the strategic commitment of the Company to undertake as detailed an assessment as possible and therefore establish the highest possible standards of environmental protection and social well-being. It is the ESIA, which goes into far greater detail than that required for national monitoring and management plans, that defines the Company’s quality management plans for air, water, biodiversity, noise and vibrations, traffic impacts, waste management, and more, thus establishing an holistic and integrated environmental protection system. The ESIA, along with all the resulting environmental and social management plans, are available on the Adriatic Metals BH website.

Documents:

The area surrounding the Rupice Mine is a water protection zone and the mine has been permitted illegally

Adriatic Metals BH holds all necessary permits, obtained in accordance with regulations defined by Cantonal, Federal and State laws. The area of the Rupice exploitation field is outside any water protection zones whether category I, II or III.

Documents:

Underground water from the Rupice Mine will pollute the Bukovica River with heavy metals, poisoning Kakanj municipality’s drinking water supply

Since 2018 Adriatic Metals BH d.o.o (“AMBH”) has continuously conducted comprehensive research to understand both the hydrology (surface water) and hydrogeology (groundwater) of the area. The data collected has served as input for the design of the Rupice Mine and informed the various studies, reports, and permits that have been prepared and obtained. This research has been conducted by state authorised companies with the input of international consultants.

All research conducted has concluded that there will be no impact on the quantity or quality of water in the Bukovica river.

AMBH continues to conduct extensive monitoring of the quality and quantity of the surrounding hydrological and hydrogeological system to ensure that all parameters remain within the same value range as they were before the mine's opening, Monitoring includes the measurement of 37 different water quality parameters and reporting them in accordance with Bosnian regulations.

The studies, reports, and obtained permits that corroborate the aforementioned statement:

Decision on Prior Water Consent issued by the Sava River Basin Agency, reference number UP-I/25-1-40-040-4/19 dated 25th January 2019, for conducting detailed geological investigations in the expanded exploration areas of Rupice-Borovica and Veovača-Orti-Selište-Mekuše, municipality of Vareš, January 2019;

Hydrogeological Study of the Lead, Zinc, and Barite Deposits in Rupice-Vareš conducted in February 2020; and

Study for the issuance of Prior Water Consent for underground Exploitation of complex lead, zinc, and barite deposits at the Rupice site, municipality of Vareš, November 2020, conducted by the Rudarski Institut d.d. Tuzla, based on which the following was issued:

Decision on Prior Water Consent, reference number UP-I/25-1-40-393-7/20 dated 23rd October 23 2020, issued by the Sava River Basin Agency for the preparation of part of the project documentation related to the discharge of contaminated precipitation water and activities that may have specific impacts on waters during the extraction of complex lead, zinc, and barite ores with associated mineral components at the Rupice-Juraševac-Brestić deposit, Municipality of Vareš;

Decision on Water Consent, reference number UP-1-21-2-40-543-7-/21 dated 28th December 2021, issued by the Sava River Basin Agency for the main project of collecting, treating, and discharging precipitation-polluted waters – Rupice for mine waters;

Decision on Water Consent, reference number UP-1-21-40-532-9/21 dated 1st February 2022, issued by the Sava River Basin Agency, for the activity of constructing a disposal site for materials resulting from the underground exploitation of complex lead, zinc, and barite ores at the Rupice site; and

Permit for underground exploitation of complex lead, zinc, and barite ores with accompanying mineral components at the Rupice-Juraševac-Brestić exploitation field, municipality of Vareš, reference number 06-14-1-334/21 dated 16th July 16 2021, issued by the Federal Ministry of Energy. Mining and Infrastructure

During the process of obtaining this permit, a public hearing was held on 7th July 2021, at the premises of AMBH, attended by all interested parties invited by Federal Ministry for Mining, Energy and Infrastructure. Point 6 of this Decision states that the Company must conduct additional hydrogeological research and investigations to establish potential underground connections between the Exploitation field and water phenomena, structures, and watercourses in the Bukovica watershed, as well as establish continuous monitoring. This requirement was expressed by the interested party JP Vodokom Kakanj d.o.o. after the public hearing. The procedure and the manner of involving interested parties are detailed in the decision, and it is stated that "the issuance of permits took into account and protected the interests of JP Vodokom Kakanj d.o.o to the maximum extent," and that all Exploitation activities are located outside both the II and III water protection zones (further details on pages 6, 7, and 8 of the aforementioned permit).

After obtaining this permit, AMBH carried out additional hydrogeological research and investigations, which identified potential underground connections between the Rupice Exploitation Field and groundwater structures, and watercourses in the Bukovica watershed, and established continuous monitoring of this area. In this process, the following reports were prepared:

Report on the Conduct of Supplementary Hydrogeological Research of the Lead, Zinc, and Barite Deposits, April 2022; and

Report on the Possible Impact of Pollution on the Surrounding Hydrological System and Bukovica Water Intake, June 2022.

Both the report and the study were reviewed by state authorised contractors, and during the field investigations, there was regular external supervision as well as additional supervision by staff from JP Vodokom Kakanj d.o.o. The conclusion stated that mining activities will not have a negative impact on the surrounding hydrological system of the Rupice mine and the Bukovica water supply.

Upon completion of these investigations, the documentation was submitted to the following institutions:

Federal Ministry of Environment and Tourism;

Federal Ministry of Energy, Mining, and Industry;

Sava River Basin Water Agency;

Ministry of Agriculture, Forestry, and Water Management of Zenica-Doboj Canton;

JP Vodokom Kakanj; and

Municipality of Kakanj.


Continuous monitoring of all underground waters, as well as monitoring of the quantity and quality of surface waters of both the Borovički stream and Bukovica, is conducted monthly and reported quarterly to relevant institutions. Results are also provided, at their request, to both Kakanj Municipality and JP Vodokom Kakanj d.o.o.

To date none of the aforementioned institutions or companies have provided any comments on the reports, studies, and data that has been submitted by AMBH.

Documents:

Adriatic Metals destroyed the Mehoric picnic area and illegally created a road to the Rupice Mine destroying the Tristonica River

Mehorić is owned and operated by DS JP ŠPD ZDK PJ Šumarija Kakanj (State Forestry) and has been used historically as both summer accommodation for forestry workers and a marshalling point for harvested wood to be stockpiled and subsequently trucked for onward processing. The road running East from Mehorić, along the banks of the Tristionica river, and then after it forks at the confluence with the Vrući Potok to the North and South (Rupice) are forestry access roads that have been in operation for decades (as evidenced by the Cadastal Maps below). Whilst forestry operations were concentrated in a different location the roads were not in regularly use (other than by the Hunting Association) and fell into disrepair, including the rapid growth of vegetation.

The Company’s contractors both refurbished the road, with forestry’s permission, and received a permit (Urban Planning Approval Decision for a Temporary Structure, issued by Kakanj Municipality, reference number 04/1-19-5008/21 dated 13th May 2022) for the temporary construction of a concrete batch plant at Mehorić (reducing the volume of trucks transiting Kakanj municipality from the Heidelberg cement factory to Rupice).

When the Company became aware that the local citizens were concerned about the operation of the concrete batch plant at Mehorić a public hearing was held on 28th July 2022, at the Cultural Sports Centre in Kakanj. Listening to the concerns the Company acted immediately and required its contractor to remove the plant after which the Company funded rehabilitation of the Mehorić site to the approval of both Cantonal water inspectors, report number 18-21-07381/22-07-06-004-P, dated 24th August 24, 2022, and the site’s owners DS JP ŠPD ZDK PJ Šumarija Kakanj.

As a number of concerned citizens continued to raise concerns about the Mehorić site the Company engaged the services of a Kakanj NGO, CEKOR, to devise a collaborative proposal (including input from Hunting and Fishing Associates, residents and the Municipality) for the site’s development as a community recreational facility. The Company approved the funding of these works, but these have not been implemented as the owners of the site, DS JP ŠPD ZDK PJ Šumarija Kakanj have alternate plans for the location (which include removal of the Hunting Associate’s barn and the refurbishment of the accommodation and offices to be used as a summer training camp for forestry students).

The Company continues to express readiness to develop this site in accordance with the owner's stipulations, subject to prior approval from relevant authorities.

The Company has conducted a series of sampling and analyses in authorised laboratories, which conclude that neither the soil nor waters at this site have been compromised.

Documents:

Adriatic Metals discharges dirty water into Vruci Potok illegally

During the construction phase of the mine higher levels of suspended solids (clay) have irregularly been observed in the Vruci Potok stream. Such occurrences were more frequent towards the end of 2022 and the beginning of 2023.

Further the construction of the underground tunnels generates sediment-laden waters. Prior to commencing underground activities, settling ponds were established for de-sedimentation purposes, serving as a means of water treatment during the construction phase. While using the settling ponds, deviations from regular operation occurred on a small number of occasions during 2022 and 2023, prompting reporting to relevant authorities and implementation of corrective measures. These waters are not laden with heavy metals, as verified through analyses conducted by state authorised laboratories. Water from the settling ponds was tested regularly, by both AMBH and external laboratories for the presence of heavy metals, pH values, and conductivity.

A dedicated water treatment facility was commissioned in April 2023 and all water, both surface and underground, is treated in this plant before discharge. All water discharged from the site is periodically subject to analysis by authorised laboratories, and all measurement parameters to date have been below the legal thresholds.

The Company possesses permits from the Sava River Basin Agency and the Ministry of Agriculture, Water Management, and Forestry of Zenica-Doboj Canton, and all its operations have been and remain in accordance with those permits.

To the best of our knowledge, no other mine in Bosnia and Herzegovina utilises a water treatment facility.

Acquired permits:

Water Compliance Decision for the main project of collecting, treating, and discharging stormwater pollution - Rupice for sanitary and sewage wastewater, June 2022;
Water Compliance Decision for the main project of collecting, treating, and discharging stormwater pollution - Rupice for mine water, December 202;
Water System Use Decision for Sastavci, issuance date: June 2022, Vareš; and
Water Pipeline Construction Permit for Vrući p., June 2022, Vareš.

Documents:

There are endangered species in the area of the Rupice mine, but Adriatic Metals refuses to release the biodiversity report

The Environmental Impact Assessment for the underground exploitation of ore at Rupice site was conducted by the Rudarski Institut d.d. Tuzla. This study includes sections related to biodiversity and resulted in the issuance of a valid environmental permit.

Furthermore, the Company conducted an additional two year comprehensive biodiversity study for its internationally compliant Environmental and Social Impact Assessment.

Species listed on red lists are specified in the Biodiversity Action Plan, which outlines the activities that the company will undertake for biodiversity protection.

Documents:

Adriatic Metals are disposing on mine tailings in the area known as Red Rock illegally

The Company holds all necessary permits to deposit non-hazardous waste at the Red Rocks site. Only excess soil and rock from the construction of a haul road and inert waste from the Rupice mine (waste categories 17 05 04 and 17 05 06) are deposited there.

Further:

A project for the disposal of excavated material at the Red Rocks location was prepared by the authorised company "Celab d.o.o" Kakanj after which the Ministry for Environment and Tourism issued on the 8th May 2023 a decision on Environmental Impact number UPI 05/1-02-19-4-75/23 stipulating that only only excess soil and rock from excavation during the construction of a transportation route and waste from mining operations (waste categories 17 05 04 and 17 05 06) may be deposited at the "Red Rocks" disposal site;

This waste material does not fall within the categories of hazardous waste and contains all chemical components inherent to the natural composition of the geological surroundings, including heavy metals that rainwater has previously and continues to dissolve due to their natural presence in the soils and rocks of the Mount Zvijezda region;

Field surveys at this location did not identify or register endangered, vulnerable, or protected species of flora and fauna that require restrictions and priority protection according to the provisions of the Law on Nature Protection and the Habitat Directive. Due to long-term disuse, these meadows have undergone a natural succession processes into primary ecosystems (acidophilic spruce forests), which are the predominantly habitation in this broader area of Mount Zvijezda. Therefore, this does not involve a habitat type that, based on its bioecological and biodiversity characteristics, requires priority protection under the provisions of the Law on Nature Protection and implementing regulations. Despite this not being a habitat with high biodiversity values, the Company has prepared/developed a special action plan for the restoration of 6 hectares of devastated mountain meadows, handed over to succession processes, at another location to compensate for losses, based on the goals and measures outlined in the Biodiversity Action Plan and has provided all prerequisites for the implementation of this plan.

The location of the planned "Red Rocks" disposal site is situated outside the potential impact zones on watercourses, and there are no watercourses or springs nearby.

The "Red Rocks" location sits within the wider area categorised as a potential mineral resource deposit in the Spatial Plan of the Municipality of Vareš for the period 2018-2038

Documents:

Adriatic Metals has illegally removed trees from the Rupice mine site

The Company has obtained conversion approval or is in the process of obtaining conversion approval for a total of 35.1 hectares of land designated for forestry, into construction land at Rupice. As at 31st July 2023 an amount of KM 1.15m has been paid in compensation, which is calculated to include:

compensation for raising new forests and their maintenance on an area equal to the converted area; and

market value of wood per type of trees.

The Company has, to date, planted three times as many new trees as have been removed for the construction of Rupice.

In addition to the above, for the purposes of geological exploration activities in the wider Concession area, the Company has been granted a number access rights, paying fees for access and similar compensation for felled trees.

Furthermore, the Company. signed an Agreement on Cooperation with JP ŠPD Zavidovići regarding the preservation and protection of the environment. With the aim of preserving the existing forest resources, Zenica-Doboj Canton forestry commission annually organises initiatives rehabilitate and re-plant areas and the Company, based on the Agreement, actively participates in these programmes.

Documents:

Thallium and Nickel particles are being released into the air around the Rupice Mine, and will poison all agricultural land for 150km

The presence, monitoring and management of any potential heavy metals was addressed through Environmental Impact Assessments, and the monitoring of these metals is a legal obligation defined by issued Environmental Permits. The Company operates an Air and Greenhouse Gas Management Plan, and one of the monitored parameters is airborne particulate matter, including heavy metal content. Testing is conducted by a laboratory accredited according to BAS EN ISO/IEC 17025. The results to date indicate that nickel particulate matter is significantly below threshold levels, and thallium has not been detected in the samples.

Documents:

Adriatic Metals BH obtained permits for the mine in the second and third water protection zones of Bukovica

The surface drainage and groundwater flow from the Rupice exploitation area is determined by the watershed boundary. In accordance with the watershed border and the terrain morphology, it is evident that the exploitation area of the "Rupice" deposit belongs to the Vrući Potok basin area, with surface waters flowing in a northwest direction, forming the Vrući Potok stream, which is a left tributary of the Trstionica River.

The watershed boundary and the direction of surface water flow are shown on the attached map. Downstream from Kraljeva Sutjeska, the Bukovica River joins the Trstionica River as its left tributary. This means that the outflow from the Rupice exploitation area ends up in the Trstionica River through the Vrući Potok, downstream from the water catchment on the Bukovica River, as clearly seen in the map attachment, indicating that the Rupice exploitation field is located outside the II and III protective zone of the Bukovica water source.

From all the information presented, it is conclusively demonstrated that neither surface nor groundwater from the Rupice exploitation area in any way affects the quantity and quality of water from the Bukovica water source and the Bukovica water protective zone area.

Documents:

Glossary

Concession agreement - a contract that gives a company the right to operate a specific business within a government's jurisdiction, subject to particular terms.

Hydrology - the science of the properties, distribution, and effects of water on a planet's surface, in the soil and underlying rocks, and in the atmosphere.

Hydrogeology - the geology of groundwater, especially concerning the physical, biological and chemical properties of its occurrence and movement.

Hydrogeological research - provides the scientific foundation for managing and protecting the groundwater resources.

UK Bribery Act 2010 - the primary anti-corruption law in the united kingdom. It came into force in july 2011 and applies to both public and private sector bribery. The UK Bribery Act covers UK citizens, residents and organizations that originate from the UK or conduct business in the country.

Water protection zone - the primary regulatory tool used by Government to ensure water quality. A Water Protection Zone provides a legal framework for introducing bespoke local measures to reflect the needs of a specific catchment that are not being tackled by existing voluntary measures.

Exploration - the process of finding commercially viable natural resource (the objective is to locate it in the shortest possible time and at the lowest possible cost).

Exploration Field - pAn area designated by Government for the purpose of natural resources Exploration.

Exploitation - the use of natural resources for economic growth, and increasingly to procure raw materials essential to a net-zero transition.

Exploitation field - an area designated by government for the purpose of natural resources exploration.

Bukovica river - surface water body of the second category belonging to the Trstionica watershed, with an area of less than 10 km2, a sub-basin of the Bosna River.

Trstionica - surface water body of the second category, which belongs to the Bosna River sub-basin.

Vrući potok - surface water body of the second category, belonging to the Trstionica watershed, and sub-basin of the Bosna River, according to the water management plan for the Sava River basin in the Federation of Bosnia and Herzegovina (2022-2027) as well as the decision on the characterization of surface and groundwater, reference conditions, and parameters for assessing water status and water monitoring (Official Gazette of the Federation of Bosnia and Herzegovina, No. 1/14).

Rupice - polymetallic silver, lead, and zinc deposit for underground mining.

Veovača - polymetallic silver, lead, and zinc deposit for underground mining.

VPP (Vares Process Plant) - silver, lead, and zinc ore processing plant.

Tisovci - the location where the processing plant is built.

Base metals - industrial non-ferrous metals excluding precious metals. These include copper, lead, nickel and zinc.

Spatial Plan - a strategic blueprint document that sets out where and how an area should grow and develop over the medium to long term. It identifies actions for how growth should occur in an integrated and holistic way. It outlines a vision and broad set of principles, strategic directions, and actions (needs checking against Bosnian legal definition).