Buriticá has a troubled history, formerly being in lands disputed by leftist guerillas and right-wing paramilitaries until about a decade ago. The town is near still-active narcotrafficking routes, and is a regional center for artisanal, illegal, and illegal artisanal mining (not all artisanal mining in Colombia is illegal).

In 2016, media & analysts visit Continental’s offices in the town of Buriticá where locals talked about their collaboration with and support of the miner (photo: Loren Moss)

When the Continental team came in, they first reached out to the mayor and locals to both explain their plans, but also get an understanding of the local situation, and how they could help. Buriticá Mayor Luis Hernando Zapata told London-based Diálogo Chino that “Continental Gold brought a social investment strategy, where there was motivating information for the territory, where the expectation of the municipality was employment, productive chains, business initiatives, and training.” On the other hand, “Zijin has only supported road construction projects and infrastructure repairs.”

This was the opposite approach to what was happening almost simultaneously with South African mining company Anglo Gold, almost 370 kilometers away near Cajamarca, Tolima. Though, Anglo had made all the right moves in the capital of Bogotá with politicians and regulators, the company failed to win the hearts and minds of the locals, and apparently did not understand the higher degree of citizen engagement and influence in Colombia. Cajamarca residents voted 6,165 to 76 against Anglo Gold!

Headline photo: The small town of Buriticá has less than 3,000 residents, with another 7,000 in the surrounding area. It is less than an hour past the popular tourist town of Santa Fé. itself 90 minutes from Medellín (photo: Loren Moss)

With such public opposition at the local level, Ashanti’s La Colosa and Quebradona projects are stalled, as Colombia’s environmental authority (ANLA) have so far refused to issue licenses. In 2019, Anglo sold a significant chunk of its Colombian assets to Royal Road Minerals.

As Continental developed its mine, it also worked to develop relationships with the local community, including with local artisanal miners who had been working in the area for centuries. Continental, which was building an environmentally friendly gold processing facility on site, instituted a program to buy and process gold ore from artisanal miners, so they wouldn’t have to try to poison themselves with mercury or sell gold to organized crime.

Continental did have to take action against illegal “claim jumpers,” who were not interested in collaborating with the company, but were mining on Continental’s claim, and causing the risk of landslides and collapses. Efforts were effective due in part to the close coordination and relationships between Continental, local, and national officials.

Unlike many mining companies, Continental employed highly qualified Colombians in top management, such as Mateo Restrepo Villegas as Executive Vice President and later, President, and Mauricio Castañeda as vice president of exploration.

“A very special recognition to the Continental Gold Women’s team, the first of its kind to participate in the National Mine Rescue Olympics and a champion of discipline, courage and bravery”. Silvana Habib Daza, President, The National Mining Agency (ANM).

Continental worked to open mining opportunities to women, and even sent an all-woman team to the 12^th International Mines Rescue Competition in West Virginia, USA. Continental employed local seamstresses in Buriticá to create the company’s uniforms, and supported local educational efforts, even opening a community center.

Investors were impressed when Continental’s management sold the mining company to China’s Zijin mining for over a billion USD. Zijin Chairman Chen Jinghe specifically said in a statement that “Zijin is conscious of the demonstrated responsibility of Continental’s operation towards the well-being of the local communities and the responsible management of environmental aspects of its operation. Zijin commits to continuing with a similar approach, focus and investment in that regard. Zijin will practice in all its operations with the same commitment of Continental towards transparency and ethics and will continue to operate in a highly responsible manner in Buriticá, Antioquia and Colombia more broadly.”

Visiting continentalgold.com features on the home page content from 2017 highlighting a video from a visit of Silvana Habib Daza, who headed Colombia’s National Mining Agency two presidential administrations ago!

However, that has not been the case.

Immediately after the 2019 transaction, Finance Colombia began to reach out to executives of the new owners with the hopes of keeping open the excellent lines of communication enjoyed with the previous management. The new Zijin-Continental Gold management never responded to outreach and appeared to have a policy of reticence towards media. The perception is that, now a business unit of a global mining conglomerate connected with the Chinese government, there was no need for investor relations, media communications, community relations, or any such inconveniences.

Zijin executives seem to be highly media-shy and prefer not to engage with the public. Visiting continentalgold.com features on the home page content from 2017 highlighting a video from a visit of Silvana Habib Daza, who headed Colombia’s National Mining Agency two presidential administrations ago! In other words, the site has apparently been untouched since Zijin took control.

From community friend to villain

Soon after Zijin purchased Continental, local relationships began to sour. There have been three documented work stoppages at the Zijin mine, something that did not happen with the previous Continental ownership. While Continental took an aggressive stance against illegal miners, it did seek to collaborate with artisanal miners, and understood the difference. Before the sale to Zijin, Continental reportedly backed to the tune of $20 million USD a government operation against illegal mines often controlled by mafias and manned by trafficked victims. The efforts were backed by artisanal miners, who were always at the risk of extortion or displacement by illegal miners.

On the other hand, just this month, the Western Antioquia Miners Association that represents artisanal miners, has asked the Colombian government to take action against Zijin, who it accuses of filling subterranean tunnels with sludge, leading to the deaths of two miners last year.

In 2021 Zijin paid approximately $11 million USD to the Colombian government, but the municipality of Buriticá only saw about $100,000 USD of that, less than the cost of a nice condominium in Medellín.

In the sludge incident last August, Zijin asked the government to intervene and remove blockades set up by residents of Buriticá to protest the death of Victor Enrique Peña Alvarez and Jesús Arturo González, Contreras. At first Zijin denied that there were no dead miners thus no reason for protests…until the bodies were found. Locals accused Zijin of entombing the miners under sludge and rocks. Peña came to Colombia as a child from Venezuela, while González was an internally displaced refugee from Urabá, a rural region of Colombia north of Buriticá that suffers from domination by the Clan del Golfo mafia.

The town of Marmato, Colombia last week issued a proclamation recognizing Collective Mining’s (TSXV: CNL) (OTCQX: CNLMF) social activities and efforts within the municipality.

Relationships between Zijin and the local community have continued to deteriorate to the point where Zijin has released a letter dated January 26 of this year, addressed to President Gustavo Petro and copied to a couple dozen other politicians, military brass, and government functionaries. Petro, in the first year of his term as Colombia’s President, promised during his campaign to be an ally of artisanal miners.

While the team that built Continental has moved on to found a new mining company called Collective Mining already winning accolades for good relations with the local community, in Colombia Zijin seems to be playing from Anglo’s playbook with efforts focused on Bogotá, locals be damned.

It is true that to a real extent, mafia groups are active in the region. Three Continental Gold geologists were killed in 2018, but at the time, Continental executives pointed out to Finance Colombia that the criminal acts took place over eight hours away by road from Buriticá. Today, Zijin is making a grave mistake in painting the resistance to its activities and conduct, or local artisanal mining as mafia related.

The letter, reproduced below and translated by Finance Colombia, is fascinating in its tone, even irony. Signed by Leizhong Li, the last sentence of the fifth paragraph on the second page says of what it calls illegal miners: “the vast majority of them are foreigners and do not belong to the community of Buriticá.” As of press time, we have been unable to confirm whether in fact, the denouncer of foreigners, Mr. Li, is a “Paisa” belonging to the community of Buriticá.

Full disclosure, let it be known the editor of this piece is too, “a foreigner and does not belong to the community of Buriticá.”

Buriticá, 26 January 2023

Lord

GUSTAVO FRANCISCO PETRO URREGO

President of the Republic of Colombia

HOUSE OF NARIÑO

Bogota D.C. E.S.D

Ref.: Urgent request for intervention

Your Excellency Mr. President,

The company Continental Gold Limited Sucursal Colombia (hereinafter referred to as the “Company”) is a subsidiary of the Chinese conglomerate Zijin Mining Group Co., Ltd., dedicated to the exploration, exploitation and development of mining properties and projects around the world, and whose main asset in Colombia is the Buriticá Gold Project, recognized as one of the “Projects of Strategic National Interest” (PINE) by the Intersectoral Commission on Infrastructure and Strategic Projects, as it is considered the first large-scale modern underground mine in Colombia.

The project, located in Buriticá, a municipality in western Antioquia, was launched in March 2020, after obtaining the corresponding approvals for its expansion and culminating with the construction phase, thus starting the large-scale commercial production of the Buriticá Mine, its main products currently being doré bars, copper concentrate, and gold.

 Our work is responsible with the environment, meets all quality standards and contributes to the territory. We have modern mining technology, we do not use mercury in any cycle of our process, and we achieve zero discharge of industrial wastewater. The company reports investments of more than 44 million dollars for the construction of the most modern water treatment plant in Colombia and one of the most modern in Latin America.

Within the framework of the above, we vehemently appreciate the support provided by the National Government, which has been key to the consolidation of the Project, as well as the immense efforts deployed by the different authorities in order to confront the situation of risk that the Illegal mining has generated in our mining work and in the municipality where we currently operate.

However, in Buriticá the action and control of illegal mining exercised by the Clan del Golfo continues, which puts at risk not only the situation of public order, but also the life and integrity of those who carry out this type of activities in an irregular way, of the Company’s personnel, their

contractors, the Public Forces and the community of the municipality of Buriticá and western Antioquia in general.

Faced with the above panorama, and despite the efforts made by the municipal and departmental authorities, we find that the situation has overwhelmed the capacity of the local Public Force, which has not been able to contain the advance of illegal mining activity that affects the municipality, and on the contrary has seen how illegal action increases over time.

Next, we allow ourselves in the most respectful way to share with you the situation of affectation of the Ilegal Mining in our operations of the Buriticá Mine.

The mining area of the company is divided into 3 development zones: high, medium and low, according to different levels, respectively called Yaraguá tunnel, Rampa Sur tunnel and Higabra tunnel. In the lower area, adjacent to the Higabra tunnel, most of the mine’s infrastructure is located: Processing Plant, Treatment Plant, Administrative Offices and Camps.

 Currently , 100% of the Yaraguá tunnel is affected by illegal mining, which has also invaded most of the Rampa Sur tunnel, forcing the Company to abandon its production mining operations in the upper and middle areas and concentrate its main efforts in the lower part of Higabra . However, at the end of 2022, illegal miners connected the structure of the Higabra tunnel, displacing Company personnel using firearms and improvised explosive devices, amid a display of violence that continues today.

According to the above, more than 50% of our underground mining bores are invaded by illegal mining; in recent months, there has been an increase in the presence of unauthorized miners in the Company’s infrastructure. It is estimated that this number has increased from 400 to 700 in the Yaraguá, Rampa Sur and Higabra tunnels. The above, together with the existence of unauthorized mining work in the municipality of Buriticá, in areas adjacent to the mining title, covers a total of approximately 2,000 people engaged in illegal mining activity, according to the calculations made by the Company, the vast majority of them are foreigners and do not belong to the community of Buriticá.

These activities are carried out through excavated accesses from private properties of third parties directed towards the underground infrastructure of the Company, from which they complete the strategy of “block domain”, invade the tunnels of the operation to carry out mining activities in a mechanized manner, with large-scale work, without control or planning, much less respect for environmental mining or safety in mining operations, also using illegally obtained explosives or artisanal manufacture that are also used to attack the Company’s personnel, its contractors, security guards and to the Public Force. It is estimated that around 100 tons of illegal explosives were used over the past year, of which approximately 70 percent were manufactured by INDUMIL. In addition, and in order to intimidate the employees of the Company, to contractors and repel the Public Force, they shoot handguns and rifles and install gas cylinders and fire extinguishers loaded with explosives in the tunnels.

 During the years 2021 and 2022 alone, the Company attended with its team of mining rescuers 16 injured by explosives, including direct personnel, contractors and Public Force, in addition to 5 people who were injured in the framework of activities unauthorized miners left in the tunnels to be rescued by Company personnel. Likewise, the discovery of 5 bodies of personnel outside the work of the Company abandoned inside the Yaraguá tunnel was reported.

Unfortunately, this situation of violence, framed by the use of firearms, illegal detonations inside the tunnels and the use of improvised explosive devices, has been increasing exponentially, as can be seen in the following comparative table:

In this way, in addition to blocking the work of the Company and putting at risk the lives of the personnel working inside the tunnels, an approximate amount equivalent to 1.5 tons of ore is illegally extracted through the illegal connections, not including the estimate of the illegal extraction in other areas of the mining title and surrounding areas, which represents for the State (according to calculations made during the year 2021) losses equivalent to:

+US$84M for theft of explosive material and blasting accessories

+US$ 3M for royalties lost

+US$11.8M for rent tax

+US$ 2M for self-withholding

The stolen ore is processed inside the illegal mining works, for which “Entables” processing plants have been built inside the tunnels, which makes them difficult to detect, causing environmental damage and human health due to the use of mercury.

As confirmed by the same authorities, mining activities in the municipality of Buriticá are permeated by the Clan del Golfo, and mean a very important income for their criminal apparatus, which adds to the resources they obtain from drug trafficking, smuggling, among other illicit activities. This is also a fuel that clearly affects the environment in the area, society as a whole and threatens the security of the region and the country. As observed by the Company in the framework of its operation, the effects of illegal mining can be summarized in the following points:

1. 1. 1. Environmental pollution: These illegal groups carry out illegal exploitation anywhere. In their activities they leave residues such as tailings anywhere without any rigorous and technical disposal, which leads to a contamination of water resources and serious erosive processes in productive lands, so important today for the country.

In their illegal extraction activities, they have even reached the point of carrying out their beneficiation process underground, with the implementation of “entables” that constantly carry mercury. It is an archaic management, which uses a substance prohibited in Colombia for this type of use because of its harmfulness to humans and the environment. It is also a dangerous and highly destructive method for ground water and general water resources.

1. 1. 2. They only focus on mineral-rich resources regardless of the effects on natural resources. They do not mind wasting natural resources without taking into account processes of prevention, mitigation, remediation and compensation. Their focus is only on high-grade exploitation for the highest possible profits. In this way they leave other minerals forgotten, which becomes an inefficient process. Proof of this is that the Company’s ore recovery rate is more than 90% and that of these people does not reach 50%, with the aggravating factor of its polluting approach.

1. 1. 3. This anti-technical mining in Buriticá shows a lack of standards and no investment in industrial safety. Illegal mining does not implement Industrial Safety, Health and Environment or technical standards, it does not think about the integrity and work environment of miners. Because of this, there are constant safety accidents, injuries and even people killed in these activities. By entering these anti-technical sinkholes, the miners risk their lives.

1. 1. 4. Miners in the area are treated like slaves. Criminal activities have several modalities to take advantage of the work of these people and obtain profits. First of all, it is through the control of illicit mining. It also occurs through an agreement between these criminal organizations and the miners through renting land or charging them through extortion from ancestral miners. At the same time, these organizations control the miners through drugs, exploiting them so that they can obtain them, consume them and work tirelessly. This is clearly a perverse situation that affects the human rights of those who exercise this activity.

1. 1. 5. These criminal organizations threaten the national economy and damage social order. They exploit and smuggle gold without paying taxes or royalties to the country. This affects the Colombian economy. Most of the miners are foreigners who, due to their economic situation, accept these precarious conditions that affect their quality of life. At the same time, local populations are affected because these activities lead to an increase in drug consumption, prostitution, theft and in general environments of chaos, insecurity and social decomposition.

This increases deinstitutionalization in the territory, destroys the value system of the communities, their culture and affects the growth of young people and their expectations of life. Many of them succumb to the possibility of obtaining easy or illicit money, which affects the education and growth of the next generation of young people.

1. 1. 6. It threatens Zijin-Continental Gold’s normal operations and the company’s legal rights. Illegal Mining permanently and with impunity connects the Company’s tunnels from the surface, which also affects productivity, tools and machinery. In their actions they have managed to connect the ventilation system and the emergency tunnels. These facilities are at permanent risk due to the intention of these organizations to seize the mining panels through violence. To do so, they shoot and send explosives, which threatens the life and integrity of our employees, causing our daily operation to be frequently compromised. They act massively in the different ramps of the Company and since September 2021 they have invaded one of them (Yaraguá) completely.

Given the alarming situation affecting the legitimate mining operation carried out by the Company; the environment through the generation of irreversible environmental impacts; to the integrity of our workers, contractors, Public Force and the people who enter these farms without an adequate technical structure in terms of support and electrical connections, exposure to gases in deficient conditions of ventilation and countless conditions of insecurity that can trigger a catastrophic event, not to mention the economic detriment that the illicit extraction of minerals represents for both the Company and the State in terms of royalties and taxes, we request your urgent intervention to restore order and guarantee the development of an operation mining whose initial and main objective has been to contribute through modern mining, with a social and environmental vocation to the economic development of the country, which is not possible to achieve without its intervention. The situation is already critical and, if immediate and forceful actions are not taken, it will put an end to this project.

Mr. President, we want to state that as a Company we have denounced all illegal mining activities, maintained contact with different local, departmental and national authorities and we have made known to the public the critical situation that the Company and the municipality of Buriticá are experiencing, as a result of the flagelo of illegal mining and the criminal organizations that have a presence in the region. Likewise, until the month of August

2022 an inter-institutional table was established, coordinated by the competent mining and environmental authorities, the Ministry of Defense and the Ministry of the Interior, spaces where the existing problems were discussed in search of solutions and that would be extremely opportune to resume.

The Company expresses its willingness to participate in all scenarios of dialogue and particularly in the Dialogue Tables convened by the authorities, Ministries and Government entities, likewise the company has always expressed its willingness according to the government’s vision to expand formalization programs and thus give more opportunities to our neighboring communities framed in the law.

I take this opportunity to reiterate our Company’s commitment to the sustainable development of Western Antioquia and our conviction that the acceptance of local, departmental and national communities and authorities is the basis of legitimacy to advance this mining operation with the highest standards and thus be able to take advantage of natural resources responsibly and rationally, as is our mission.

Finally, we reiterate the high valuation that the Company, its Board of Directors, its Management team and employees have of the work carried out by the National Government, the Ministries, the environmental authorities, the departmental and municipal authorities, the Public Force, the organs of control and justice to ensure that in Buriticá and western Antioquia human rights and freedoms can be enjoyed, the environment can be preserved and the rule of law and democratic institutions is strengthened.

We respectfully attach presentation of our company.

Cordially

LEIZHONG LI

CEO

Zijin Continental Gold.

With copy to:

Iván Velásquez Gómez, Minister of Defense Rafael Lara Losada, Deputy Minister of Defense Iván Danilo Rueda, High Commissioner for Peace

Helder Fernán Giraldo Bonilla, Commander General of the Armed Forces

Luis Mauricio Ospina Gutiérrez, Colombian National Army Commander Óscar Murillo Díaz, 7th Colombian Army Division Henry Armando Sanabria Cely, Director General of the Colombian Police

William Castaño Ramos, Commander of Carabineros and Rural Security National Police of Colombia Carlos Humberto Rojas Pabón, Commander Region Six National Police of Colombia

Irene Vélez Torres, Minister of Mines and Energy Giovanni Franco Sepúlveda, Deputy Minister of Mines

Fernando Lozano, Director of Public Safety and Infrastructure Maríto Susana Muhamad, Minister of Environment

Alfonso Prada Gil, Minister of the Interior Rodrigo Negrete, Director of ANLA Álvaro Pardo Becerra, President ANM

Aníbal Gaviria Correa, Governor of Antioquia

Jorge Alberto Jaramillo Pereira, Secretary of Mines of the Government of Antioquia

Oswaldo Juan Zapata Quijano, Secretary of Security and Justice of the Government of Antioquia Francisco Barbosa Delgado, Attorney General of the Nation

Margarita Cabello Blanco, Attorney General of the Nation Carlos Hernán Rodríguez, Comptroller General of the Nation Carlos Ernesto Camargo Assis, Ombudsman

Roy Leonardo Barreras Montealegre, President of the Senate of the Republic of Colombia Juan Camilo Nariño, President ACM

Bruce MacMaster Rojas, ANDI President

María Bibiana Botero, Executive President of Proantioquia Luis Hernando Graciano, Mayor of Buriticá

Aicardo Antonio Urrego Úsuga, Mayor of Cañasgordas Alconides Úsuga Carmona, Mayor of Giraldo

Andrés Felipe Pardo, Mayor of Santa Fe de Antioquia

Sergio Cabrera Cárdenas, Ambassador of the Republic of Colombia to the People’s Republic of China.

Continental Gold, based in Toronto, is primarily engaged in the construction and development of their gold mine in Buriticá, Colombia.

“The all-cash offer at a significant premium to market is an excellent outcome for our shareholders and is a testament to the extraordinary effort of the Continental team and its stakeholders in pioneering a new and modern gold industry in Colombia. In the span of a decade, Continental has transformed the Buriticá project from a grassroots discovery into one of the world’s largest and highest-grade gold projects,” says Continental CEO Ari Sussman.

Continental CEO Ari Sussman (center).

“With production on the horizon in 2020, the timing is right for Continental to sell to a more experienced mine operator and therefore Continental’s Board of Directors recommends that shareholders vote in favour of the Transaction. Zijin is one of the world’s fastest growing mining companies and boasts an impressive track record of successful international acquisitions and operations. Most importantly, Zijin shares common principles with Continental on what defines modern mining and, as a result, will continue to operate in a safe, transparent and inclusive manner with the employees of the Company and external stakeholders.”

Zijin is based in Fujian, China and is a leading global mining company specializing in gold, copper, zinc and other mineral resource exploration and development. It manages an extensive portfolio, primarily consisting of gold, copper, zinc, and other metals through investments in China and overseas across nine countries. Founded in 1993, it is listed on the Shanghai Stock Exchange and the Hong Kong Stock Exchange. As of November 29, 2019 Zijin has a current market capitalization of approximately US$12.13 billion.

Zijin intends to set up an Ontario acquisition entity for this transaction which will be held by a Hong Kong holding subsidiary of Zijin formed with certain strategic investors who are willing to jointly invest with Zijin in Continental.
Says Zijin Chairman Chen Jinghe: “We have been greatly impressed by Continental’s focus on safe, efficient and sustainable mining practices which closely align with Zijin’s approach to mining and development operations. Zijin is conscious of the demonstrated responsibility of Continental’s operation towards the well-being of the local communities and the responsible management of environmental aspects of its operation. Zijin commits to continuing with a similar approach, focus and investment in that regard. Zijin will practice in all its operations with the same commitment of Continental towards transparency and ethics and will continue to operate in a highly responsible manner in Buriticá, Antioquia and Colombia more broadly. We look forward to working closely with stakeholders and local communities in Colombia to deliver a world-class operation that will benefit the regional economy.”

The Transaction has been unanimously approved by the board of directors of Continental following the unanimous recommendation of a special committee of independent directors of Continental and significant shareholder Newmont GoldCorp. Maxit Capital LP has provided an opinion to the Continental board of directors and Cormark Securities Inc. has provided an opinion to the Special Committee, respectively, stating that the transaction is fair, from a financial point of view, to the Continental shareholders.
Credit Suisse is acting as financial advisor to Zijin and McCarthy Tétrault LLP is acting as Zijin’s legal counsel. Maxit Capital LP is acting as financial advisor to Continental. Cassels Brock & Blackwell LLP is acting as legal counsel to Continental and Fasken Martineau DuMoulin LLP is acting as legal counsel to the Special Committee. Cormark Securities Inc. is acting as financial advisor to the Special Committee.