US$1.58 billion Claim for Damages

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 29 January 2025, the Company subsequently announced that the tribunal had issued an order that IGPL shall issue its Memorial, including the Statement of Claim, on or before 16 May 2025.

The Company announces that the Claimant has filed the Memorial in accordance with the order of the arbitral panel including a claim for damages amounting to US$1.58 billion, net of Indian taxes.

IGPL's Treaty Claims

By virtue of the measures it took resulting in the total loss of IGPL's investment, IGPL alleges that India breached the Treaty, including but not limited to, Article 3 (Promotion and Protection 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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