Ann: Continuation of Suspension from Quotation, page-21

There'sa lot of fear and uncertainty around AMD atm. I just wanted to give a quickrecap of the facts over the past week or so to ease some of that uncertainty:

• Aug 2024 - Summary of the agreement to acquire the Niagara Bauxite project from GCB/KCB (source: https://www.listcorp.com/asx/amd/arrow-minerals-limited/news/arrow-expands-bulks-presence-with-major-bauxite-transaction-3063120.html). (See Below)

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• 14-18 May 2025: Guinea’s military government revokes 51 industrial & ~90 exploration permits for “inactivity” – part of a “use-it-or-lose-it” clean-up of the mining cadastre (source: Business Insider AfricaDiscovery Alert)
  • KC Bauxite SARLU (KCB), the title-holder of AMD’s Niagara permit #22889, was named in local French-language media among licence casualties. (Article links in French press lists of revoked exploration titles.) (Source: Guineeprgres )
• 19 May 2025: AMD requests an ASX trading halt citing “media reports concerning its tenements in Guinea”; converted to voluntary suspension pending clarification
• Permit timeline: KCB’s licence granted 2 Jun 2020, initial 3-yr term expired 1 Jun 2023 → currently in first renewal window – a soft spot regulators are targeting. (Source: Market Index Data APIDiscovery Alert
• Guinea Mining Code (Art. 145): exploration permits can be withdrawn if ≥50 % of the work-program is still outstanding after two years. (source: Discovery Alert)

Why the Guinian governmentcan yank a licence:

Guinea’s Mining Code(Arts 23-25 & 145) says:

1. Exploration work must start within 6 mths of grant;
2. >50 % of the work-program must be done within 2 yrs;
3. Fail that and the state can revoke without compensation (“use it or lose it (source: Metal.com)

KCB’s permit wasissued 2 Jun 20 for a 3-yr term — i.e. it hit the renewal window 1Jun 23. That expiry makes it an easy target if officials think progress haslagged. (source: Listcorp)

Has AMD really beenidle?

Not exactly:

• 173 RC holes drilled in 2024.
• Large resource delivered in < 12 months.
• Scoping study team on site (source: Mining Weekly)

AMD can argue thework-program box is ticked.

Guinea’s minesministry is now deciding whether Niagara’s permit gets (a) reinstated butwith tougher deadlines and maybe a local-processing obligation, (b) trimmedor re-cut—the code already forces KCB/AMD to drop half the ground on firstrenewal and the junta could also demand a fatter state stake, or (c) pulledaltogether and thrown into the state reserve for retender.

I lean toward (a)reinstatement with tougher milestones or (b) partial retention onstricter terms for three reasons:

1. Work already done – 173 holes drilled and a 185 Mt resource in less than a year show the ground isn’t idle. That ticks the “use-it” box the code is built around, giving Conakry a face-saving reason to keep the permit alive rather than scrap it outright
2. Government leverage, not expropriation – Doumbouya’s junta has repeatedly used revocation threats to force faster development or sweeter terms (higher state equity, local refineries). Re-issuing the same permit with tighter deadlines or carving off half the area achieves that goal without scaring off credible juniors
3. Infrastructure fit – Niagara sits near the new Trans-Guinean Railway corridor. The state wants shovel-ready bauxite for export and downstream value-add; a live, advancing project is more useful than starting the tender clock again

A full cancellation isstill possible, but it gives the ministry no near-term revenue or developmentwins and risks investor backlash. Holding AMD’s feet to the fire while keepingthe project in motion is the path of least resistance.