The maiden drilling campaign, may be delayed further with extended COVID restrictions - currently to be in place until 26th June...... BUT, overall this announcement is
IMO - "in my opinion" only .....
(a) is underwhelming and designed to put some interest into the SP, BUT if I was a shareholder I would be ecstatic at the current market cap for a penny stock that only has some exploration tenements that has potential, and IMO the share price is being driven by expectation/s and/or hype of further acquisition/s and/or a "spin off" of Hamersley.
(b) to date highlights a management team that has been somewhat lacking, although they did initially hit the ground running with being re-listed (30/10/20) to the first announcement of activities at King Tut commencing (19/11/20) then announcing the appointment of Condor Prospecting for on ground initial exploration (2/12/20) but that is basically the only work that has been achieved thus far ....
(c) has somewhat conflicting/ambiguous statements in regards to the "
maiden drilling campaign" re:
(i) from multiple announcements released, 2/12/20, 25/1/21, 29,1,21, 5/3/21 and 18/3/21, the start for this maiden drilling campaign was anticipated/scheduled to start
Q1/2021 but was revised to be start
"early" Q2/2021 (announced 30/4/21)
(ii) from announcements released, 5/3/21 and 30/4/21 "
the Company also engaged with local authorities to enable the finalisation of required approvals and permits. It is anticipated that final approvals will be granted shortly ...(sic)" BUT as announced 16/6/21 (
6 weeks since any update/information) "
Permitting for the Company's maiden drilling program is now at an advanced stage with very constructive relationships having been established with all involved regulatory groups." and "
During May and early June, the company continued to provide additional information requested by the authorities in support of the application" -
from previously being anticipated the approvals will be granted shortly to now being in an advanced stage!
(iii) from this announcement "Considerable work has been undertaken to satisfy all regulatory requirements including:"
The
establishment of an
Environmental Impact Assessment - surely the company was aware of an existing EIA that required updating ? (
rolls eye moment, due diligence was done? but) as per Annexure B of the Prospectus re: "
Independent Solicitor's Report" in regards to:
-
King Tut Exploration Concession 168 - L- 1939:
EIA: Approved by Resolution No. 072/18 of the Secretary of Environment, Ministry of Planning and Industry dated April 6, 2018
EIS: TESA was declared the title holder of the EIS granted by Resolution No.072/18 through Resolution No. 331/18 dated November 13, 2018.
The
EIA is required to be updated prior to initiating any field work, since the
EIS expired on May 2, 2020.
Further in the Solicitors Report: EIA shall be updated and an EIS shall be granted prior to initiate any field work.
-
Diana II Exploration Concession 66-C-2005:
EIA: Approved by Resolution No. 327/18 of the Secretary of Environment, Ministry of Planning and Industry dated November 13, 2018.
Further in the Solicitors Report: An EIA was approved and is required to be updated prior to initiating any field work.
(iv) Establishing Water and Waste management plans:
Reference to waste & water is discussed in the Prospectus, 7.3 Industry Specific Risks (d) Environmental, and (e) Regulatory Risks.
The closing paragraph of this section of the prospectus, the company believes that it is in
substantial compliance with all material current laws and regulations, agreements or changes in their enforcement or regulatory interpretation could result in changes in legal requirements or in the terms of existing permits and agreements applicable to the Company or its properties -
IMO, this is baffling to the point that: the Prospectus was announced/released 30/10/2020 and how many months later these plans are only being established now?
The Company has established an environmental baseline water monitoring program, monitoring activities throughout the program will provide confirmation to regulators and
stakeholders of the Company’s compliance to environmental standards of work.
As part of the permitting of the maiden Diamond Drill Program the team have continued engagements with
key stakeholder and community groups in the province. To assist with the development of a comprehensive Social Management and Communication Plan (SMCP) the Company has contracted a local consulting group, Papi Group Latam Consulting, who have extensive experience with mining operations in Argentina.
- Assuming stakeholder/s to mean - community group/s in the La Rioja province ? ?
-
Guille Exploration Permit (from the Independent Solicitor's Report)
(i) The information in Section 2.2 (Exploration Permit “Guille”
of this Report in relation to the Guille Exploration Permit is accurate in all material respects.
(ii) We confirm that TMSA was the exclusive registered applicant and holder of the Exploration Permit. The Exploration Permit was granted by Mining Authority through Resolution issued on February 22, 2019 for a period of 300 days. The
Exploration Permit expired on January 20, 2020.
(iii) There is no evidence that TMSA has applied for a Statement of Discovery before expiration of the Exploration Permit to preserve the area. The Mining Procedure Code of La Rioja (Law 7277) says that Exploration Permits expire once the exploration period finalises. The expiration, in all cases, will be published in accordance with Article 291 of said Code.
(iv) The Mining Authority in the province of La Rioja is currently closed due COVID-19 regulations.
TMSA has informed BYA that, in order to renew its tenure of the relevant Exploration Permit area,
it will submit a Statement of Discovery at the first possible instance appealing for an exemption due to COVID-19 restrictions declared from
March 13, 2010.
**I assume this is a typo and should be
March 13, 2020?
Legal standing:
Expired.
The term of the
Exploration Permit granted by the Mining Authority via a Resolution issued on February 22, 2019 has expired.
TMSA should
have submitted a Statement of Discovery before the expiration of the exploration period.
- In Sandrino Gold's
Financial report for the year ending June 30 2020:
(a) "
Compliance and regulatory expenses, $1,008
(b) "
The impact of the Coronavirus (COVID-19) pandemic is ongoing and while it has had limited impact on the Group up to 30 June 2020 ...(sic)"
It is all well and good to cite COVID restrictions as a reason BUT the simple matter is, the exploration permit expired before COVID was declared and TMSA (Sandrino Gold the parent company) appeared to comply with some regulatory commitments, as the
Diane II exploration permit is in good standing but ultimately TMSA let the exploration permit for Guille lapse!!
It will be interesting to note what section of the budget allocated to the King Tut work program will cover the additional funds needed? for the water/waste and social plans and/or what part of the project could/will be trimmed? or was there an allowance built in?
Also consider the variances of $350,817 (expenses of the offers) and $29,951 (repayment of debt to creditors)
IMO as one of the directors is a corporate advisor and has a long list of lead manager roles in ASX listed company's credit raises, both of these variances should have been recognised and budgeted for when drafting the Prospectus? ......
cheers
