Arbitration Update

On 26 July 2024, the Company announced that IGPL had formally issued a Notice of Arbitration ("NoA") to India in relation to the Bhukia project (the "Arbitration"). On 16 December 2024, the Company announced that the initial tribunal hearing (the "Initial Hearing") had been held.

Following the Initial Hearing, the Company now announces that the parties and the tribunal have executed the terms of appointment (the "ToA") to the Arbitration. Amongst other terms and conditions outlined in the ToA, the parties and the tribunal have agreed to:

• the Permanent Court of Arbitration ("PCA") to administer the Arbitration;
• upon request, the Secretary-General of the PCA shall designate the Appointing Authority;
• the legal seat of the arbitration is London, United Kingdom, but physical hearings may be held elsewhere;
• the PCA shall identify on its website basic information regarding the case, including the members of the Tribunal and counsel for the Parties; and
• all submissions, witness statements, expert reports, other instruments and supporting documentation shall be confidential unless a party has a legal duty to disclose.

The Company will provide further updates, including the timetable, as available.

IGPL's Treaty Claims

The Company made its initial investment in the Bhukia project (through IGPL) in or around 2004. IGPL provided substantial funding and managed the joint venture exploration programmes with MMI. IGPL's right to be granted a Prospecting Licence over the Bhukia project, through its joint venture holding, was denied and frustrated over an extended period by the Government of Rajasthan ("GoR"). In 2021, India passed a new act ("MMDR2021") to amend the Mines and Minerals (Development and Regulation) Act of 2015 ("MMDR2015"). Under Clause 13 of the MMDR2021, the preferential right to a Prospecting Licence and a Mining Lease was revoked.

By virtue of the measures it took resulting in the total loss of IGPL's investment, India breached the Treaty, including but not limited to, Article 3 (Promotion and Protection of Investments), Article 4 (Treatment of Investments) and Article 7 (Expropriation and Nationalisation). IGPL is now seeking damages from India.

There can be no certainty as to the outcome of IGPL's Treaty claims.

Bhukia Project Background

The Geological Survey of India ("GSI") published a report in 2014 after the completion of over 150 drill holes (Bulletin Series A (April 2014)), wherein it reported an indicated and inferred resource estimate of 6.7 Moz gold (excluding additional resources subsequently found through additional drilling by the GSI). The estimate was reportedly prepared according to the UNFC code. More recently, the GoR issued a gazette notification containing an updated resource estimate of 113.52 Mt at 1.96 g/t and 0.14% Cu, which amounts to 7.2 Moz of gold plus copper credits, and also with accessory nickel and cobalt. According to Indian law, the resource estimate was required to be prepared in accordance with the Minerals (Evidence of Mineral Contents) Rules 2015 ("MEMCR") which are based on the United Nations Framework Classification (UNFC) and Committee for Mineral Reserves International Reporting Standards (CRIRSCO), though modifications to these standards have been made by India in formulating the terms of the MEMCR.

• US$60m in upfront payments;
• US$60m in performance guarantees (vis-à-vis development work); and
• A 65.3% 'mineral share'.

The 'mineral share' to which India is entitled confers upon India fees equivalent to 65.3% of the value of all gold contained in ore extracted from the Bhukia project area during mining.

LCM Litigation Financing

On 25 August 2023, the Company announced that IGPL had secured up to US$13.6 million in litigation financing ("Facility") with LCM Funding SG Pty Ltd ("LCM Funding" or the "Funder"). LCM Funding is a subsidiary of Litigation Capital Management Limited ("LCM"), a firm quoted on the AIM Market of the London Stock Exchange. LCM is a leading global disputes funder with significant expertise in international arbitration and cross-border disputes, including bilateral investment treaty claims over mineral resource assets.

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