Legal Mining and Compliance

ISIC: 0722 Exploration and exploitation of minerals

We operate under a simple principle: In responsible mining, legality is not asserted; it is demonstrated.

Here we publish the documents that support our right to operate, the obligations we assume, and the controls we apply to ensure continuous and verifiable compliance with authorities, communities, and allies.

Data Room Public

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Legal and Responsible Operation: Our Mining Concession

En C.I. Chocó Gold Metals Investments S.A.S. We operate in strict compliance with the Colombian legal framework. We are proud to be the owners of Mining Concession Contract No. OA4-11151, duly granted and registered by the National Mining Agency (ANM).

This contract is the result of a rigorous process of formalizing traditional mining and authorizes us to legally extract gold and platinum within the jurisdiction of the municipalities of Condoto and Nóvita, in the department of Chocó. The project has a projected technical viability of 30 years.

Our operation is based on the following commitments made to the State and the territory:

  1. Environmental Support and Compliance Our activities are protected by the Temporary Environmental License issued by the Regional Autonomous Corporation for Sustainable Development of Chocó (CODECHOCÓ) through Resolution No. 2328. We have assumed the unavoidable obligation to adopt measures for the protection of a healthy environment and the conservation of the water basins of the territory.
  2. Social Management Plan As an integral part of our Works and Projects Program (WPP), we structured and executed a Social Management PlanThis plan aims to promote the economic, social and cultural development of the communities in our area of influence, mitigating risks and fostering local opportunities with full respect for Human Rights.
  3. Contributions to the Nation and Safe Operation We guarantee the timely payment of royalties and taxes derived from our activities, contributing valuable resources to the State and the region. Furthermore, our work is carried out adhering to the strictest technical, safety, hygiene, and occupational health standards to protect the lives and well-being of all our employees and the community.

Legal Certainty: Active National Mining Registry

As a guarantee of total transparency and legal certainty for our commercial and financial partners, C.I. Chocó Gold Metals Investments S.A.S. has its Mining Registration Certificate (CRM) duly registered and in state Asset before the National Mining Agency (ANM).

This certificate (File OA4-11151) publicly and officially ratifies:

  • Exclusive Ownership: Our company is the legitimate holder for the exploitation of gold and platinum minerals in the municipality of Condoto, Chocó.
  • Long-Term Validity: The registration certifies the viability and projection of our mining operation, with a contractual validity officially registered until March 2054.

This public registry document certifies that our operation not only has the corresponding permits, but is also up-to-date and in strict legal compliance with the Colombian State.

Temporary License

Sustainability and Environment: Our Environmental License

En C.I. Chocó Gold Metals Investments S.A.S. We conceive of mining as an activity that must coexist in perfect harmony with nature. Our operation in the municipality of Condoto is duly authorized by the Environmental License granted through Resolution No. 2328 of 2023, issued by the Regional Autonomous Corporation for Sustainable Development of Chocó (CODECHOCÓ).

Our open-pit operation is governed by a strict Environmental Management Plan (EMP) which guarantees the prevention, mitigation and compensation of impacts in the territory, based on the following pillars:

  1. Responsible Mining: Zero Mercury and Water Protection We operate under a strict ban on the use of mercury at all stages of our mining process, ensuring clean and safe operations. To protect our water sources, we have implemented water recirculation systems through sedimentation ponds, preventing direct discharges into rivers. Furthermore, we rigorously respect riparian zones and water sources within the territory, ensuring the conservation of this vital resource.
  2. Reforestation and Biodiversity Conservation We have an unwavering commitment to landscape restoration and ecological connectivity. Therefore, we are implementing a forest compensation program that guarantees the planting of five (5) native species trees for every tree harvestedensuring their long-term maintenance and survival. We also implement specialized protocols for the deterrence, rescue, and protection of endemic wildlife, strictly prohibiting any hunting practices within our area of influence.
  3. Safety, Occupational Health (OHS) and Emissions Control The well-being of our employees and the community is our priority. We have a robust Occupational Health and Safety Management System (OHSMS), trained emergency response teams, and a full complement of mandatory personal protective equipment (PPE). In addition, we actively control particulate matter and noise emissions through roadway dampening systems and rigorous preventive maintenance of all our machinery.
  4. Integrated Waste Management and Community Responsibility Our company implements responsible solid and hazardous waste management practices, promoting source separation and the circular economy. Our environmental management is integrated across all our operations, working closely with local communities to ensure compliance with prior consultation agreements and to promote environmental education and ongoing community participation.

Final License

Resolución 0466 del 28 de abril de 2026

The Operational Technical Plan (PTO) defines how mining operations are carried out within the concession area, including the mining method, operational sequence, technical controls, industrial safety measures, and monitoring obligations. Its function is to ensure that the actual operation remains within the parameters approved by the mining authority and is consistent with the project's technical, social, and environmental commitments. 

Approval Order

The PTO Approval Order is the administrative act that technically validates the execution of the project under the conditions authorized by the competent authority. The public version may be requested for institutional due diligence processes.

Registration and authorizations

Authorized and Transparent Marketing: RUCOM Certification

En C.I. Chocó Gold Metals Investments S.A.S.We guarantee complete legality, due diligence, and traceability throughout our supply chain. As proof of our strict regulatory compliance with the Colombian government, we are registered and certified in the Single Registry of Mineral Traders (RUCOM) of the National Mining Agency (ANM).

Our accreditation certifies the company's suitability as an authorized marketer, operating under the following transparency guidelines:

  1. Lawful Supply Chain and Export Our RUCOM certification legally authorizes us to regularly carry out activities of marketing, purchase, sale, transformation, processing, distribution, intermediation and export of precious metals. We specialize in and are fully authorized to trade in precious metals. gold, platinum and silver minerals, as well as their respective concentrates.
  2. Institutional Support and Due Diligence Our status as an authorized distributor is the result of rigorous state scrutiny. Accreditation is granted after thorough verification and validation of our corporate, customs, and tax information with the relevant authorities. National Directorate of Taxes and Customs (DIAN) and the databases of ConfecámarasThis protects our operations from the risks of illicit economies and ensures an impeccable corporate track record.

Authenticity Verification Our certification remains valid and in continuous compliance with the regulations of the mining and energy sector. We invite our strategic partners, banks, and international clients to publicly verify our status as an authorized marketer on the official government portal.

  • Approved Registration Number: RUCOM-2024080628359
  • Online verification: Go to www.anm.gov.co and enter our registration number.

RUCOM

It accredits the authorization to market minerals within the applicable regulatory framework, strengthening traceability, due diligence and compliance in the supply chain.

It formally identifies the company to the Colombian tax authorities and confirms its status as an active taxpayer for tax, customs, and commercial purposes. It is an essential document in any process involving due diligence, bank account opening, and corporate due diligence.

It certifies the company's legal existence, its current business registration, and the legal representation authorized to act, enter into contracts, and assume obligations on behalf of the company. It is a fundamental tool for corporate transparency for clients, banks, insurance companies, and strategic partners.

Risk management/support

En C.I. Chocó Gold Metals Investments S.A.S.We understand that responsible mining requires not only good practices, but also real and tangible guarantees to the Colombian State and society.

To support our operation under the Mining Concession Contract No. OA4-11151We have a Compliance Policy valid, issued by La Previsora S.A. Insurance Company, having as beneficiary and direct insured the National Mining Agency (ANM).

The establishment and maintenance of this policy demonstrates our corporate strength and has as its main purpose:

  1. Guarantee of Mining and Environmental Obligations This instrument comprehensively and financially ensures strict compliance with all mining, technical and environmental obligations acquired by the company during the gold and platinum exploitation stage in the municipality of Condoto, department of Chocó.
  2. Transparency and Support from the State The policy acts as a protection mechanism for the Nation, guaranteeing that C.I. Chocó Gold Metals Investments S.A.S. has the necessary financial backing to ensure the optimal development of the project, the execution of the Work and Construction Program (PTO), and compliance with current regulations.

Our operation is designed to generate value safely, always backed by the strongest insurance institutions and entities in the country.

Secure and Transparent Supply Chain: Logistics of Value

En C.I. Chocó Gold Metals Investments S.A.S.We guarantee that the traceability, security and legality of our precious metals remain intact from our operation to their final destination.

For the physical handling of our production, we have a strategic and institutional alliance through a Contract for the Transportation and Custody of Securities signed with one of the most recognized security and logistics companies worldwide (Brinks de Colombia S.A.).

Our operational logistics are governed by the highest industry standards, highlighting the following non-negotiable commitments:

  1. Armored and Secured Operation The transport and temporary custody of our precious metals (gold, silver, and platinum) are carried out under strict physical and operational security protocols. The entire cash handling chain is fully covered by liability insurance policies, guaranteeing the protection of the company's assets and the peace of mind of our business partners.
  2. Transparency and Lawful Origin (SARLAFT) Our supply chain is protected against illicit economies. We operate under a rigorous Money Laundering and Terrorist Financing Risk Management System (SARLAFT)We certify under oath that all income and transported assets come exclusively from lawful activities and formal mining, complying with the due diligence requirements of national and international authorities (OFAC, UN, INTERPOL, among others).
  3. Anti-Fraud and Anti-Corruption Policy Our contractual and operational relationships are based on absolute transparency and strict adherence to the law. We maintain a zero-tolerance policy toward any form of bribery, fraud, or corruption, ensuring that the gold and platinum we trade meet the highest corporate ethical standards.

Technical reports and due diligence support

Where applicable, the company will make available to institutional counterparties the public or shareable technical documentation necessary for mining, legal, environmental and commercial evaluation processes

Anti-corruption policy and whistleblowing channel

The company maintains an integrity policy aimed at preventing bribery, fraud, conflicts of interest, money laundering, and any conduct contrary to the law or responsible operating principles. This policy includes third-party due diligence, verification of counterparties' documentation, and a confidential reporting channel for receiving requests, alerts, or complaints related to irregular conduct.

The Data Room Our Pillars

CO2

We reduce our climate footprint by tackling the biggest burdens: energy, fuel, and logistics. We measure, publish progress, and correct course with verifiable actions, not promises.

We publish a report tracking the main energy consumption of our operations, focusing on fuels, equipment, and logistics related to the movement of materials and valuables. This inventory allows us to identify the most intensive energy sources and prioritize reduction efforts.

Our energy efficiency plan focuses on three key areas: fuel consumption control, preventive equipment maintenance, and optimization of routes and operating times. Actions and progress are updated as internal operational data is consolidated.

Preventive maintenance and operational discipline reduce unnecessary consumption, downtime, and overuse of machinery. This approach aims to improve operational performance with a lower energy impact per unit mobilized.

Transport traceability is an integral part of the project's operational control. The use of specialized custodians and defined dispatch protocols reduces risk exposure, consolidates routes, and strengthens control of the logistics chain.

Water

In Chocó, water defines life and also responsible operation. That's why we prioritize water balance, recirculation, controlled water intake, and continuous monitoring with verifiable reports.

The project prioritizes water use control through operational recirculation, sediment management, and protection of water sources. The water balance consolidates the relationship between water intake, use, recirculation, and final management within the project area.

Catchment

Water collection is carried out under the conditions defined in the applicable environmental instruments and with control over the points authorized for operation.

Use

The water used in the operation is allocated to controlled mining activities, with internal monitoring to reduce losses and improve operational efficiency.

Recirculation

The operation implements recirculation and sedimentation management systems to decrease the need for new intake and reduce the risk of uncontrolled discharge. 

Discharge

The project prioritizes the prevention of direct discharges and compliance with the controls defined in the environmental management plan. Any managed discharge must comply with applicable parameters and permits.

Water management integrates prevention, control and monitoring measures on collection, conveyance, sedimentation, recirculation and protection of watercourses and water sources. 

Controls

  • Ponds or sedimentation systems

  • Protection of watercourses

  • Monitoring of water points

  • Maintenance of control structures

  • Incident and Contingency Log

Obligations

Water-related obligations are carried out in accordance with the current environmental instrument and the requirements of the competent environmental authority.

The project's environmental monitoring points are consolidated within the technical and monitoring reports required by the competent authority.

Public map

Public version of the control and monitoring points, subject to operational safety criteria and protection of the territory.

The available results will be published in a public version as the verifiable periodic reports are consolidated.

Table of results and analysis

This space will bring together monitored parameters, date, measurement point and technical reading compared against applicable reference values.

The project uses sediment management structures and practices to reduce solids runoff, protect water bodies, and improve the environmental performance of the operation.

Response procedures are maintained for operational incidents that may affect water, sediments, or environmental infrastructure.

Space intended for publishing executive versions of the project's water monitoring.

Public summary record of reportable events related to water management, with traceability of date, type of event and closure status.

Community

Responsible mining is agreed upon before operations begin. We work with measurable commitments, a monitoring committee, and a grievance mechanism that prioritizes dialogue, traceability, and resolution.

Social, Cultural and Environmental Commitment: Prior Consultation Agreements in Condoto
En C.I. Chocó Gold Metals Investments S.A.S.We reaffirm our commitment to sustainable development, respect for the land and the well-being of the communities where we operate.
As a result of a participatory and transparent process, we have successfully formalized the Prior Consultation agreements with the Condoto and Iro Community Council (COCOMACOIRO) and the Opogodo Community Council, endorsed by the Ministry of the Interior.
These agreements govern our operations and are based on the following pillars:
1. Sustainable Social and Economic Development We work hand in hand with communities to generate real development opportunities. We have agreed to jointly create a Manual of Coexistence and Social Intervention which prioritizes the employability of local labor, promotes equity through gender quotas and encourages the acquisition of goods and services directly in the territory.
We have also established mechanisms for economic participation and fair social investment that guarantee direct benefits for the co-owners and the community.
2. Respect for Culture and Ancestral Mining We recognize and deeply value the cultural legacy of the region.
Therefore, our project respects, preserves and encourages traditional mining. We have arranged guarantees so that the inhabitants can continue with their ancestral practices of "barequeo" or "mazamorreo" (making use of traditional tools such as the trough, the mop and the horn), establishing coordinated schedules (Tuesdays, Thursdays and Saturdays) that allow the harmonious coexistence of our activities in the territory.
3. Environmental Protection and Reforestation Our operation is carried out under strict environmental management measures.
We commit to:
  • Protect water: Implement water treatment systems (such as sedimentation tanks and septic tanks) and ensure that the natural flow of water sources will not be diverted.
  • Community Nursery and Reforestation: Develop a community nursery dedicated to the cultivation of oxygen-producing trees and food crops. The goal is to build an agricultural pantry that strengthens local food security.
  • In addition, we guarantee the transfer and protection of medicinal plant species identified in the area.
4. Transparency and Open Communication (PQRS Channel) Trust and communication are vital. As mandated by our agreements, we have a system of Petitions, Complaints, Claims and Suggestions (PQRS) open and available to the community. This channel allows us to listen to and efficiently resolve any concerns or requests, promoting good coexistence.
Official Verification For C.I. Chocó Gold Metals Investments S.A.S.: transparency is paramount. We invite you to verify the authenticity of the Prior Consultation Record directly in the official public repository of the Ministry of the Interior of Colombia

Space intended to publish the minutes and executive summaries of follow-up meetings with communities and stakeholders, including commitments, progress and pending issues arising from the Prior Consultation and the Social Management Plan.

Meetings

Chronological record of follow-up sessions, with date, participants and topics covered.

Decisions

Summary of decisions adopted and active agreements in execution.

Tasks

List of commitments derived from each session, with traceability of compliance

Public monitoring mechanism to visualize the status of social, environmental and operational agreements acquired with communities and territorial allies.

Advance

Percentage or qualitative status of execution of each commitment: initiated, in progress, completed or in adjustment.

Those responsible

Area or actor responsible for executing, supporting, or verifying each commitment.

Dates

Agreement date, target date, and most recent update date.

Evidence

Minutes, photographic records, documentary evidence or execution records available in public version.

We promote the hiring of local labor based on criteria of legality, safety, job profile, and operational availability, in accordance with the project's social agreements. The program prioritizes training, operational co-creation, and opportunities for participation for residents of the area of influence. 

Criteria

  • Profile and required skills

  • Safety and suitability requirements for the position

  • Territorial priority where applicable

  • Documentary and regulatory compliance

Training

Local engagement is accompanied by operational induction, safety and coexistence, according to the role and work area.

Results

Space intended to publish consolidated indicators of local participation when they are available for public dissemination.

The company promotes, when technical, legal, and operational conditions allow, the use of local suppliers for goods and services related to its operations. This approach aims to strengthen the local economy through formality, compliance, and transparency.

Supplier Registration

Channel to identify, register and evaluate potential local suppliers within the corporate compliance framework.

The project's social investment is aligned with community agreements, local priorities, and the commitments of the Social Management Plan, focusing on coexistence, local strengthening, restoration, and support for community initiatives.

Projects and metrics

This space will consolidate completed projects, beneficiary population, progress status, and available public evidence.

Territory

Caring for the land involves minimizing our footprint, controlling erosion, and restoring it in stages. We monitor the recovery with georeferenced data and regular reports.

The environmental baseline brings together the initial characterization of the project's area of influence and serves as a reference for evaluating changes, impacts, and management actions during operation.

Public summary

Executive version of the main baseline components: water, cover, fauna, flora, soil and territorial context.

Public representation of the concession area, work fronts, intervened zones and areas under management or restriction, according to the information that can be shared without compromising operational safety.

Public version

Summary document for consultation by allies, communities and due diligence processes.

The project includes actions for the progressive recovery of intervened areas, with a focus on soil stability, revegetation, erosion control and functional recovery of the environment. 

Schedule and method

The restoration is carried out in stages, according to the progress of operations, the conditions of the terrain and the applicable environmental commitments.

The monitoring assesses the evolution of recovered areas and the effectiveness of the measures implemented.

Survival

Indicator intended to report the performance of plantings and plant recovery actions.

Coverage

Indicator intended to report the evolution of restored areas and their vegetation cover.

Georeferenced evidence of the before, during and after of the restoration and territorial management actions.