EXHIBIT 99.28

Date and Signature Page

This report entitled NI 43-101 Technical Report Caballo Mining Operations, near Potosi Bolivia effective as of January 1, 2024 was prepared and signed by the following authors:

Original document signed and sealed by:

NOTICE

JDS Energy & Mining, Inc. prepared this National Instrument 43-101 Technical Report, in accordance with Form 43-101F1, for Santacruz Silver Mining Ltd. The quality of information, conclusions and estimates contained herein is based on: (i) information available at the time of preparation; (ii) data supplied by outside sources, and (iii) the assumptions, conditions, and qualifications set forth in this report.

Santacruz Silver Mining Ltd. filed this Technical Report with the Canadian Securities Regulatory Authorities pursuant to provincial securities legislation. Except for the purposes legislated under provincial securities law, any other use of this report by any third party is at that party’s sole risk.

Table of Contents

List of Figures

List of Tables

JDS Energy & Mining Inc. (JDS) was commissioned by Santacruz Silver Mining Ltd. (Santacruz) to carry out a Technical Report for the Caballo Blanco operation (Caballo Blanco or CB) located in the state of Potosi, Bolivia.

Caballo Blanco has three operating mines: the Reserva, Colquechaquita, and Tres Amigos. All mined ore feeds the Don Diego processing plant.

This report is the first declaration of resources and reserves, for the Bolivar base metals underground mining operation since its acquisition by Santacruz. The mine is fully operational at the time of this report’s preparation. The effective date of both the resource and the reserve is January 1, 2023, which is approximately 18 months before the report date. Production data for the calendar year 2023 has been included in Section 24 Other Relevant Data and information to show the depletion and typical replenishment of resources and reserves over a calendar year.

On October 11, 2021, Santacruz entered into the Definitive Agreement with Glencore whereby Santacruz agreed to acquire a portfolio of Bolivian silver assets from Glencore, including the following: (a) a 45% interest in the Bolivar Mine and the Porco Mine, held through an unincorporated joint venture between Glencore’s wholly-owned subsidiary Contrato de Asociación Sociedad Minera Illapa S.A. (Illapa) and COMIBOL, a Bolivian state-owned entity; (b) a 100% interest in the Sinchi Wayra S.A. (Sinchi Wayra) business, which includes the producing Caballo Blanco mining complex; (c) the Soracaya exploration project; and (d) the San Lucas ore sourcing and trading business.

On March 21, 2022, Santacruz completed this purchase, including Glencore’s interest in the Caballo Blanco mining complex.

Santacruz thus owns 100% of the two Bolivian operating companies Illapa and Sinchi Wayra, which in turn own 45% of the Bolivar Mine, 45% of the Porco Mine, and 100% of the Caballo Blanco mining complex.

Sinchi Wayra is the operating company for all three active mining operations, including the Caballo mining complex.

The Caballo Blanco project consists of three separate mines and one process plant operating as one to produce Zinc and Lead concentrates. An Important part of the supporting infrastructure includes two off-site power plants that produce supplemental electric power to the mines. The mines are relatively close together and located as follows:

Reserva and Tres Amigos Mines are located 31 km southeast of the city of Potosi, in the Canton Concepcion of the first section of the Tomas Frias Province of the Department of Potosi, at an average elevation of 4,536 masl, at UTM coordinates WGS-84: 218764E and 7814967N.

Colquechaquita Mine is located 30 km southeast of the city of Potosi, in the Canton Concepcion of the first section of the Tomas Frias Province of the Department of Potosi, at an average elevation of 4,520 masl, at UTM coordinates WGS-84: 219915E and 7819380N.

The Don Diego Process plant is located about 23 km Northeast of the city of Potosi, in the Don Diego Canton, Municipality of Chaqui, Cornelio Saavedra Province, of the Department of Potosi. At an elevation of 3,550 masl at UTM coordinates WGS-84: 228933E and 7841150N.

There is a 60 km drive from the mines to the Don Diego Processing plant.

The Mines and Process plant have easy access to Potosi City which is a large industrial, mining, and population center. Road access to the Reserva mine from Potosi is 23 km south via the Potosi-Tarija interdepartmental paved highway towards Kuchu Ingenio, then 8 km East on gravel road. Road access to the Colquechaquita mine from Potosi is 16 km south via the Potosi-Tarija interdepartmental paved highway towards Kuchu Ingenio, for approximately 16 km, then 11 km East on gravel access road.

Don Diego plant also has site access to a rail spur for direct transport of concentrates to the preferred Port of Antofagasta Chile, or alternative ports of Arica, Chile, and Matarani, Peru.

Caballo Blanco is a result of business consolidation over time.

The Don Diego Plant began processing in 1977 and was originally acquired by the precursor of Sinchi Wayra S.A. (Sinchi Wayra); Compania Minera del Sur (COMSUR) in 1976. COMSUR purchased the specific mining interests from small private owners and operators loosely organized into cooperativas. The Colquechaquita mine began operating in 1977, passing to COMSUR in 1991, later changing its name to SINCHI WAYRA S.A. Sinchi Wayra took over the Reserva/TresAmigos mines in 2010. Tres Amigos obtained its environmental licenses to operate in 2005 by Sociedad Minero Metalúrgica Reserva Ltda. for its two sections of Exploitation Reserva and Tres Amigos, with a small-scale mining operation. Glencore became involved in 2005 with the purchase of COMSUR and effecting the name change to Sinchi Wayra.

Sinchi Wayra S.A. owns and operates all facets of the Caballo Blanco business; The Don Diego processing plant and Colquechaquita mine since their acquisition by Glencore in 2005, and Reserva and Tres Amigos mines from their acquisition in 2010. Glencore immediately began to develop the deposits with a higher degree of mechanization. The Power plants, Aroifilla thermal power plant, and the Yocalla hydro-electric plant which provide supplementary electric power are also owned and operated by Sinchi Wayra and are included under the management of Caballo Blanco Project.

On October 11, 2021, Santacruz entered into the Definitive Agreement with Glencore whereby Santacruz agreed to acquire a portfolio of Bolivian silver assets from Glencore. The Assets include: (a) Glencore’s 45% interest in the Bolivar Mine and the Porco Mine, held through an unincorporated joint venture between Glencore’s wholly-owned subsidiary Illapa and COMIBOL, a Bolivian state-owned entity; (b) a 100% interest in the Sinchi Wayra business, which includes the producing Caballo Blanco mining complex; (c) the Soracaya exploration project; and (d) the San Lucas ore sourcing and trading business.

On March 18, 2022, Santacruz completed this purchase, including Glencore’s interest in the Caballo Blanco mining complex. The Caballo Blanco mining complex has continued to operate since that date under the management of Santacruz.

Figure 1-1: Project History

Source: Glencore (2021)

The Bolivar, Porco and Caballo Blanco deposits are located in the central part of the Eastern Cordillera, a thick sequence of Paleozoic marine siliciclastic and argillaceous sedimentary rocks deposited on the western margin of Gondwana and deformed in a fold-thrust belt. There were two major tectonic cycles in the Paleozoic: The Lower Paleozoic Famatinian cycle (the Tacsarian and Cordilleran cycles of Bolivia), and the Upper Paleozoic Gondwana cycle (Subandean cycle of Bolivia).

The Caballo Blanco zinc, silver, lead mine, situated south of Potosi, is located in the Jayaquila – Victoria corridor, a 5-7 km north-south structural zone with three sectors, from north to south, the Colquchaquita, Reserva, and Tres Amigos mines. They are not described in the published literature. They are hosted by volcanic rocks of the Kari-Kari volcanic complex, with dimensions of 32 km north-south and 12 km wide, located on the SE side of the Los Frailes felsic volcanic field that covers an area of 8,500 square kilometre (km²) at altitudes of 4,000 - 5,200 masl. The history started with intrusion of small granitoids at about 25 Ma at Kumurana, at the southern end of the Kari massif, and Azanaques. These were followed by the formation of Kari at about 20 Ma that is interpreted to be a resurgent caldera with welded ignimbrite fill. Ash flows, domes and stocks formed in the Cebadillas episode at 17-10 Ma, including the Cerro Rico dome with Ag-Sn mineralization at 13.8 Ma (Zartman & Cunningham, 1995; Cunningham et al., 1996; Rice et al., 2005). Huge volume felsic ash flows were erupted to form the Livicucho and Condor Nasa ignimbrites at 8-7 Ma and the main Los Frailes ignimbrites at 3.5-1.5 Ma. The final stages were the eruption of large resurgent rhyolitic domes at 4-1 Ma, and the Nuevo Mundo volcanic province at <1 Ma. (Francis et al., 1981; Schneider, 1985, 1987; Schneider & Halls, 1985; Kato, 2013; Kato et al., 2014; Kay et al., 2018).

The rocks of the Kari complex are felsic, peraluminous, and rich in garnet, cordierite and tourmaline (Schneider, 1987).

Mineralization in its generality is characterized by being housed in Philonian structures divided into three domain orientations:

General mineralogy is composed of quartz-pyrite-chalcopyrite and marmatite, sphalerite, galena, boulangerite (Tres Amigos) as primary minerals; as accessory minerals we have siderite, calcite and ankerite at the trace level.

The mineralogy is quartz, pyrite, chalcopyrite, marmatite, sphalerite, galena and boulangerite with minor siderite, calcite and ankerite.

The metallurgical assumptions for recoveries and concentrate grades can be found in Table 1-1.

While both the lead and the zinc concentrates pay for the metal they are named for and for silver, a lead concentrate does not pay for zinc contained and the zinc concentrate does not pay for lead contained. The recoveries included in this report only include recovery to concentrates in which they can be paid.

Table 1-1: Recovery and Concentrate Grade Estimates

The Caballo Blanco Project is an “advanced property” and has been in continuous production since 1993. Glencore and subsequently Santacruz Silver has performed exploration and resource expansion drilling of surface and underground drillholes at the Caballo Blanco since 2010 totalling 39,562.55 m. The 128 drillholes and 19,644 underground channels in the database were supplied in electronic format by Santacruz. This included collars, downhole surveys, lithology data and assay data (i.e., Ag g/t, Pb%, Zn%, Fe%, Sn%).

Verification of the Caballo Blanco drillhole and underground sample assay databases are primarily focused on silver, lead and zinc in addition to iron, arsenic, sulphur and tin. Sample databases were supplied in Excel^TM format and in LeapFrog^TM. Checks against source data and assay certificates showed agreement. Statistical analyses used to investigate and identify errors were performed and resulted in minor issues. These have been corrected and it is recommended that a continued program of random “spot checking” the database against assay certificates be employed.

During the 2023 site visit, an extensive independent sampling verification plan was implemented with a total of 80 samples collected across from the Bolivar, Porco and Caballo Blanco operations. The Don Diego laboratory is an NB/ISO/IEC 17025:2018 accredited laboratory which performs all assay analyses for the mining and processing operations for Sinchi Wayra including Caballo Blanco. The Don Diego laboratory in owned and operated by the Issuer, Santacruz.

Results of the verification samples indicates that the regression predictions perfectly fit the data meaning that the check sampling program successfully verified and validated the data and although, these results are not a complete audit of the laboratory, they do verify that the assay results are suitable for resource estimation purposes.

The geological and lithological solid domain models were supplied by Santacruz in both Datamine^TM and LeapFrog^TM which are both industry-leading software systems. The QP imported the multiple vein domains into a similar system called MineSight^TM to verify solids volumes and ensure matching of the solids domains against the drillhole and sample database. Results confirmed location and extent of volumes are appropriate to resource estimation purposes.

Resource block models were supplied in Datamine^TM format which is an industry recognized software system used for resource estimation. These models were then imported to MineSight^TM for verification of the resource estimation. In addition, independent estimations were run using the verified sample data and vein domains employing inverse distance estimations to ensure reasonableness and verify the resources independently. Results illustrated good agreement between the original and verification models. Verification of the SG regression analysis was also performed by comparing measured versus calculated density values.

The Qualified Person evaluated the resource in order to ensure that it meets the condition of “reasonable prospects of eventual economic extraction” as suggested under NI 43-101. The criteria considered were confidence, continuity and economic cut-off. The resource listed below is considered to have “reasonable prospects of eventual economic extraction”.

Table 1-2 shows the Mineral Resource Statement for the Caballo Blanco deposit.

Table 1-2: Base-Case Total Mineral Resources at 10.0% ZnEq Cut-off

Notes:

The January 1, 2023 reserve estimate represents the validation of Santacruz’s internally-generated mineral reserve estimate by QP Goodwin. All work on the reserve by the Santacruz mine design team and the validation exercises were done in Deswik^TM. The following process was used for this work:

The QP is satisfied that this exercise resulted in a valid reserve determination.

The Mineral Reserve Estimate for Caballo Blanco is shown in Table 1-3.

Table 1-3: Mineral Reserve Estimate for Caballo Blanco (January 1, 2023)

The Caballo Blanco Mine has been in operation for 20 years. Although the mine is managed as a single business, it is actually composed of three different mines on the same mineralized trend: Reserva, Tres Amigos and Colquechaquita.

Although development to connect the mines is in process, there still exists some autonomy in how each are operated. The application of mining methods has thus been an adaptation of mining equipment technologies, evaluation and monitoring tools to the specific mineralized zones. The last decade of operations under the guidance of Glencore, the mine has seen a move to more mechanized methods to improve safety performance and mine productivity.

The three mining operations follow steeply dipping veins striking predominantly North/South. Veins vary in width from 0.2 to 2.5 m, the wider and more consistent veins being mined using more productive longhole methods.

Reserva mine is the youngest and most modern of the three mines. Mine production is about 275 t/d. A long section of the Reserva mine is shown in Figure 1-2.

All mining is done with sublevel longhole methods and trackless development. In principle, the AVOCA method being used has all the productivity advantages of longhole stoping and allows for concurrent backfill to continuously support the relatively weak hanging wall. Backfill for stoping is generated from development mining. The method is demonstrated in Figure 1-3.

Figure 1-2: Long Section Reserva Mine

Source: Glencore (2021)

Figure 1-3: Avoca Mining at Reserva Mine

Source: Glencore (2021)

Colquechaquita mine has been in production since 1991 using tracked development, and stoping by conventional shrinkage and cut and fill methods. The mine produces about 230 tonnes (t) of mineralized material per day. A long section of the Colquechaquita Mine is shown in Figure 1-4.

The transition to mechanized mining is in process but still in the early stages. Approximately 50% production continues to be generated from conventional methods. The southern portion of the mine is moving to trackless development. However, equipment brought into the mine must be disassembled and moved in the shaft which is time consuming and labor intensive.

Figure 1-4: Long Section Colquechaquita Mine

Source: Glencore (2021)

Tres Amigos, shown in Figure 1-5, remains a conventional tracked mine using mostly a modified shrinkage stoping method, as shown in Figure 1-6.

The mineralized zones are narrow and high-grade making them well suited to these more selective stoping methods. However, higher productivity trackless mechanized methods are used for primary development and ramps. Stoping takes place generally above the -200 level and mineralized material production averages approximately 300 t/d. Mineralized material is hauled by rail either to the main Catalina shaft for hoisting to surface or hauled directly to surface using trucks.

Figure 1-5: Isometric of the Tres Amigos Mine

Source: Glencore (2021)

Figure 1-6: Shrinkage Mining as Practiced at Tres Amigos

Source: Glencore (2021)

The mine employs the following mining equipment:

Key production data from 2022 are shown by mine on Table 1-4.

Table 1-4: Key Production Data from 2022

The plant flowsheet for the Don Diego mill is a typical sequential flotation circuit for lead and zinc. The feed is crushed in preparation for the grinding circuit. The grinding circuit utilizes a SAG/Ball mill combination to produce a product size P₈₀ of 100 µm for the flotation circuit.

The flotation circuit starts with the lead recovery circuit. In this circuit a rougher concentrate is produced, which is then cleaned without regrinding, in column flotation cells. The lead rougher tailings and cleaner tailings are combined and fed to the zinc circuit. The zinc circuit consists of rougher flotation and one stage of cleaning to produce a zinc concentrate. The zinc circuit tailings are deposited in the tailings pond. Both of the concentrates are filtered for shipping to the smelter. The lead concentrate is bagged for shipping, while the zinc concentrate is shipped bulk in trucks.

Figure 1-7: Don Diego Mill Flowsheet

Source: Glencore (2021)

Each of the three mining complexes that form the Caballo Blanco Project is supported by its own infrastructure, as detailed by mine in this section.

The Mina Reserva operation is surrounded by a facilities fence, inside of which are the following facilities:

The existing infrastructure for Mina Reserva is shown in Figure 1-8. Key facilities are identified by number on the drawing.

Figure 1-8: Infrastructure for Mina Reserva

Source: Santacruz (2023)

The Mina Tres Amigos operation is also surrounded by a perimeter fence and similarly equipped with all mine services, including, inside of which are the following facilities:

The existing infrastructure for Mina Reserva is shown in Figure 1-9. Key facilities are identified by number on the drawing.

Figure 1-9: Infrastructure for Mina Tres Amigos

Source: Santacruz (2023)

The Mina Colquechaquita operation is also surrounded by a perimeter fence and similarly equipped with all mine services, including, inside of which are the following facilities:

The existing infrastructure for Mina Reserva is shown in Figure 18-2Figure 1-10. Key facilities are identified by number on the drawing.

Figure 1-10: Infrastructure for Mina Colquechaquita

Source: Santacruz (2023)

Responsible environmental management is a critical part of Santacruz’s license to operate and our responsible, compliant operation of Bolivian assets has continued for the last 30 years. Environmental Compliance with national laws and regulations is the basis of Santacruz’s environmental management system and is governed by a framework of oversight by the relevant Environmental Authority. Its environmental commitments are reported to the authorities annually in an Environmental Monitoring Report, which summarizes environmental management of its operations under applicable laws and regulations.

Waste management is an important part of Santacruz’s Comprehensive Environmental Management, which includes a waste management plan to classify, handle, and store waste separately for proper disposal or treatment. Waste management complies with Environmental Law No. 1333, its Regulations on Solid Waste Management, and its supplementary regulations, focusing primarily on the sectoral requirements of the Environmental Regulation for Mining Activities for waste rock and tailings.

The Don Diego process plant is distal from the mines which feed it. The process plant along with the Tailings Storage Facility are located about 23 km Northeast of the city of Potosi, in the Don Diego Canton, Municipality of Chaqui, Cornelio Saavedra Province, of the Department of Potosi. At an elevation of 3,550 masl at UTM coordinates WGS-84: 228933E and 7841150N. There is a 60 km drive from the mines to the Don Diego Processing plant.

The Chilimocko tailings storage facility at Don Diego is inspected regularly and maintained to the standards set out by the Canadian Dam Association guidelines. The dam is under the supervision of engineers from AMEC (now Wood Engineering) and recently an external audit was conducted by Knight Piésold Consulting. The Chilimocko Dam is 55 m high, downstream-constructed dam. The Stage IV raise was completed in 2019 and current crest elevation is 3,625 m. Construction for the next expansion is planned to begin in 2024 and conclude 12 months later.

The company also monitors and manages 4 inactive tailings facilities (1, 2, 3 & Yanakasa) at the Don Diego location.

Yana Khasa is a 40 m high, upstream-constructed dam, which contains 2.2 Mm³ of tailings. Recent activities at the site include Repositioning piezometers, cleaning of the standpipe piezometers to improve groundwater monitoring, and Installation of fences to protect instrumentation; and

Dikes 1, 2, and 3 are, upstream constructed dams which contain a total of 0.4 Mm³ of tailings. Recent activities at the sites include cleaning of the standpipe piezometers to improve groundwater monitoring and Installation of fences to protect the instrumentation.

Although mine waste rock is preferentially stored underground or used as backfill, each of the mines has a permitted and designed waste rock storage area designed for stability, as well as the prevention of acid rock drainage and metal leaching. Sludge from the water treatment plants is deposited in lined ponds adjacent to the treatment plants. Given the mines’ proximity to the City of Potosi, Domestic and Medical waste disposal are managed through the Municipal Garbage Collection Service. Industrial waste such as scrap metal, used Oil, tires, etc. is temporarily stored at each mining unit and collected by companies specialized in recycling.

Each of the mines produces enough water to treat and reuse for industrial use on site. Excess treated water is discharged to the environment at regulated quality standards. Annually, a total of 2.5 Mm³ of mine water is treated and 2.4 Mm³ discharged from two water treatment plants.

Given the remote location of the process plant, which is usually the largest water consumer, each mine treats and discharges excess water to the environment. These discharges are regulated for quality and quantity by the environmental license. End uses include consumption by neighboring communities and agricultural/industrial use by llama ranchers and mining cooperatives downstream. Caballo Blanco supplies two thousand cubic meters of treated water per year to the local sanitary administration (AAPOS) to support industrial activities and discharges the remaining treated water to the Jayaquila and Mocaña rivers. Caballo Blanco is able to meet discharge requirements with aeration, pH adjustment and clarification by settling.

Don Diego process plant maximizes the recirculation of water from its tailing storage facility and draws makeup water from permitted surface sources.

Figure 1-11: Caballo Blanco Mine Water Balance

Source: Sustainability Report, Sinchi Wayra (2022)

Santacruz Silver operates the Bolivar mine as a joint venture with the Bolivian Government (COMIBOL) The structure of the contract with COMIBOL is a “Partnership Contract governing Bolivar and Porco Mines (CA-MBP), and its purpose is to develop and implement a mining operation for the treatment of the existing mineralogical reserves and resources in the Bolívar and Porco Mines, by the exploitation, preparation, beneficiation and sale of mineral concentrates. Contrato de Asociación Sociedad Minera Illapa S.A. is authorized as operator and responsible of executing on behalf of COMIBOL, all the operations and activities of the association contract. The shares of CA-MBP are 55% for COMIBOL and 45% for Contrato de Asociación Sociedad Minera Illapa S.A.” This renewable agreement expires in 2028.

Mining Contracts that grant the right to the subsoil mining resource are granted by the Mining Administrative Jurisdictional Authority (AJAM) over the ATE mining areas, and a contract is granted for each area or contiguous group of areas. Recent changes to the laws and government personnel have pushed Santacruz contract updates into a transitionary period waiting for final signatures and approvals. Santacruz holds Special Transitory Authorizations for each contract area which are officially designated “Mining Administrative Contracts for Adaptation”. As of the effective date, approximately half of the applications have been transitioned, and the remainder fall under Article 187 of Law No. 535 on Mining and Metallurgy, which states:

ARTICLE 187. (CONTINUITY OF MINING ACTIVITIES). Holders of Special Transitory Authorizations to be adapted or in the process of adaptation will continue their mining activities, with all the effects of their acquired or pre-constituted rights until the conclusion of the adaptation procedure.

Santacruz has fully complied with this administrative procedure and is waiting for the Mining Administrative Authority to issue the relevant documents. It should be noted that this public entity has a considerable delay in the issuance of these documents.

Environmental Licenses have been formally granted to allow operation for all mining activity, by the Ministry of Environment and Water. The following table shows the licenses held by Santacruz.

Table 1-5: Environmental Licenses Held by Santacruz

Santacruz mining projects are mostly well-established operations with a long history and a developed infrastructure, which provide direct benefits to employees and supporting businesses. However, the mines are located in rural to semirural areas in which the surrounding mostly agricultural communities can benefit from each operation only indirectly or through company outreach. Santacruz supports these communities by addressing services that are lacking, and helping to create value with economic development programs, and other forms of support.

Caballo Blanco comprises a business unit with mines spread across several kilometers on the same mineralized trend and an offsite process plant and tailing facility, all proximal to the city of Potosí. Unlike Bolívar and Porco, Caballo Blanco does not have an adjacent campsite. Most employees live in the communities surrounding the city of Potosí. The mines are named Colquechaquita, Reserva, and Tres Amigos. The Don Diego Plant is located 60km away by road; other supporting units are central administrative offices in Potosí, the Thermal Power Plant in Aroifilla, and the Hydroelectric Power Plant in Yocalla. Operations at Caballo Blanco are not yet consolidated and require independent management and support. Mine operations, maintenance, planning, safety and environment, groups are separate for each mine.

Since Caballo Blanco covers a wide area, it affects many small communities. Consequently, at Caballo Blanco a large area is monitored including 13 small communities which include a population of more than 500 families or around 2,500 community members. Several mining cooperatives are also involved.

In the area of Colquechaquita, Reserva and Tres Amigos, the communities are scattered and sparsely populated, but host the settlement of cooperative miners downstream from our mining operations. Additionally, camelids are bred near the wetlands of the Jayaquilla River and Mocaña Mayu.

Adjacent to the Concentrator Plant is the settlement of Don Diego, where several Santacruz employees live. There are also other more distant and less populated communities.

Santacruz’s community investment programs are aimed mostly at communities directly influenced by the operations. Community investments are designed to maximize positive impact, recognizing that each community has unique requirements and living conditions; therefore, Santacruz prioritizes based on number of beneficiaries, vulnerability, long-term sustainability, and urgency of need.

Figure 1-12: Caballo Blanco Surrounding Communities

Source: Sustainability Report, Sinchi Wayra (2022)

Figure 1-13: Caballo Blanco Community Investment

Source: Sustainability Report, Sinchi Wayra (2022)

Closure Planning for Operations has social, economic, workforce, and environmental impacts, so conceptual closure plans are shared with communities. Santacruz’s goal is to recover areas by establishing a healthy ecosystem capable of sustaining productive land use, ensuring the best possible environmental conditions, including physical, chemical, biological, and ecosystem aspects, at closure. Environmental superintendents are responsible for monitoring the environmental closure planning, and periodic reviews of these plans are conducted, including surveys of areas and activities to adjust financial provisions for closure.

Land Use and Rehabilitation - environmental challenges related to biodiversity protection, soil restoration, and land use, are addressed through dialogue with stakeholders, including local communities and relevant authorities. Our comprehensive environmental management focuses on minimizing disturbed areas. In 2022, Santacruz managed a total of 6,600 hectares of land covered by Temporary Special Authorizations (ATEs) granted by the Mining Administrative Jurisdiction Authority (AJAM), under leasing contracts with the Government through COMIBOL. However, Santacruz’s processing activities, services, and related infrastructure (industrial area) currently occupy only 400.5 hectares of land, including areas of previous mining operations and other areas with environmental closure located within the properties Santacruz manage.

In 2022, Santacruz continued with the reforestation plan in the Queaqueani Dam area, in accordance with an agreement with the community of the same name, and significant progress was made in the progressive closure of the old tailings facilities at the Don Diego Concentrator Plant.

The Caballo Blanco mine has been in continuous operation for many years. There will be, as the reserve is expanded and developed, the need for step changes in mine access, production or haulage methods, that may require large capital outlays. These will be financially justified as needed. However, the capital needs for continued operation to exploit the remaining reserves is limited to Primary mine development, Capital equipment rebuilds and replacements, and Tailing Storage Facility expansions. Average annual capital has been and is projected to be in the 11 to 12 $M range.

The historic total capital requirement for all the Bolivian operations is shown in Table 1-6, with Caballo Blanco requirements bolded and italicized. Caballo Blanco’s projected capital requirements for 2023 to 2027 is shown in Table 1-7.

Table 1-6: Actual Combined Capital Requirement for All Bolivian Operations, 2017 to 2022 ($M)

Source: Santacruz (2023)

Table 1-7: Projected Capital Requirement for all Caballo Operations, 2021 to 2027 ($M)

Source: Santacruz (2023)

Recurring exploration and primary development costs have been included in the COG calculations to better anticipate and account for total costs and make the COG more meaningful for reserve estimation and mine planning.

Costs used for cut-off grade analysis were taken from actual costs for 2022. The actual cost of corporate G&A was allocated to each of the businesses.

Table 1-8: Unit Operating Costs ($/t)

Source: Santacruz (2023)

Mine operations include direct costs of mining, including labor, energy, materials, and services.

Mine Equipment Maintenance Costs includes maintenance to all equipment related to direct development, exploitation and haulage, as well as service equipment such as pumping, ventilation, winches, etc.

Indirect costs would include Site Management, Technical services, Site Administration, Environmental and Social, Safety and Security.

Plant costs include direct Beneficiation costs as well as plant maintenance, and indirect costs.

Warehouse costs refer to Concentrate handling and storage.

General and Administration includes allocated Bolivian corporate costs.

The Reserve Estimate was generated using actual costs experienced during a stable production period following the change in management after the purchase of the mine by Santacruz Silver (2022 and beginning of 2023). Actual costs were used for mine operating, concentrate overland transport, port costs, and shipping as well as smelting fees, payment terms, and penalty charges. A simplified Cash flow model was built to model the costs and conditions used to generate the Reserve estimates stated in this report.

The Caballo Blanco mine is part of a multi-operation business. However, the Economic model treats it as a separate financial entity with Bolivian corporate costs allocated for the analysis. As well, the operation is comprised of three mines which feed one offsite Process plant. The financial modelling examines the value of the consolidated operation on a 100% basis to support the Reserve statement.

The Caballo Blanco mines have been in continuous operation for several decades and the deposits are a network of relatively narrow veins. These two aspects drive the normal exploitation process of the mine, where inferred resources are converted and exploited in the same budget year. Resources are generally proven-up by drifting and sampling instead of drilling. Therefor normal budgeting and mine planning includes resources outside of the Reserve estimate.

For the current exercise in this report, only Proven and Probable reserves are included in financial evaluation, so the production schedule represents the depletion of these reserves at average grade and current production rates. The context of the production schedule exploits the Proven and Probable reserves as part of a continuous operation and as such does not include the closure activities.

Table 1-9: Production Forecast – Mining and Processing

Notes:

FMT = Fine Metric Tonnes; DMT = Dry Metric Tonnes; FOT = Fine Ounces Troy

Source: Santacruz (2023)

Metallurgical recoveries and concentrate qualities are actual for the times and head grades that were actually mined. These parameters will necessarily be conservative considering the higher grades in the production schedule.

Table 1-10: Production Forecast - Concentrate

Notes:

FMT = Fine Metric Tonnes; DMT = Dry Metric Tonnes; FOT = Fine Ounces Troy

Source: Santacruz (2023)

That same logic follows to the net revenue generation (Table 1-11) which includes smelter charges and penalty fees.

Table 1-11: Revenue and Cost Projection ($M)

Source: Santacruz (2023)

Depreciation is a product of previous operation and annual capital expenditure incurred for the exploitation of the reserve tonnage. Capital is limited to that required to support mining, processing, and tailing storage for the reserve. Corporate G&A is that part of the in-country costs allocated to the Caballo Blanco mine.

Table 1-12: Cashflow Projection ($M)

Source: Santacruz (2023)

Income tax is 37.5% of the EBIT. As seen, the operations generate a positive cash flow after tax upon exploitation of the stated reserve at the metal prices used to generate the reserve.