Exhibit 99.1

ANNUAL INFORMATION FORM

ALMONTY INDUSTRIES INC.

100 King Street West, Suite 5700

Toronto, Ontario M5X 1C7

Canada

Tel: +1 647 438-9766

Fax: +1 416 628-2516

E-mail: info@almonty.com

FOR THE YEAR ENDED DECEMBER 31, 2025

March 18, 2026

Table of Contents

PRESENTATION OF INFORMATION AND FORWARD-LOOKING STATEMENTS

Except where the context otherwise requires, all references in this Annual Information Form (this “AIF”) to the “Company”, “Almonty”, “we”, “us”, “our” or similar are to Almonty Industries Inc. and its subsidiaries, taken together.

Unless otherwise indicated, all dollar amounts in this AIF are expressed in Canadian dollars.

This AIF contains “forward-looking statements” and “forward-looking information” within the meaning of applicable securities laws.

All statements, other than statements of present or historical facts, are forward-looking statements. Forward-looking statements involve known and unknown risks, uncertainties and assumptions and accordingly, actual results could differ materially from those expressed or implied in such statements.

You are hence cautioned not to place undue reliance on forward-looking statements. Forward-looking statements are typically identified by words such as “plan”, “development”, “growth”, “continued”, “intentions”, “expectations”, “emerging”, “evolving”, “strategy”, “opportunities”, “anticipated”, “trends”, “potential”, “outlook”, “ability”, “additional”, “on track”, “prospects”, “viability”, “estimated”, “reaches”, “enhancing”, “strengthen”, “target”, “believes”, “next steps” or variations of such words and phrases or statements that certain actions, events or results “may”, “could”, “would”, “might” or “will” be taken, occur or be achieved. Forward-looking statements in this AIF include, but are not limited to, statements with respect to: demand for tungsten; tungsten prices; tungsten recovery and production; reductions in operating and unit production costs; currency and interest rate fluctuations; expectations regarding impairments of the Company’s mineral properties; improvements in efficiencies or reduction in dilution; future remediation and reclamation activities; expectations regarding the further exploration, development and life of mine of the Company’s mineral projects, including the Sangdong Mine, the Panasqueira Mine and the Gentung Tungsten Project (as such terms are defined herein); plans and expectations regarding the Company’s mineral projects, including the re-opening of the Los Santos Mine (as defined herein), the potential of the Sangdong Molybdenum Project (as defined herein), the potential production profile of the Gentung Tungsten Project and the development of and production at the Gentung Tungsten Project; the estimation of mineral reserves and mineral resources; the realization of mineral reserve and mineral resource estimates; the timing of activities; the amount of estimated revenues and expenses; the success of exploration activities; permitting timelines; the success of mine development and construction activities; the success of future mine operations; the success of other future business operations; the U.S. Domestication (as defined herein), litigation risks; changes to governmental laws and regulations; and requirements for additional capital and sources and uses of funds.

Forward-looking statements are based upon certain assumptions and other important factors that, if untrue, could cause actual results to be materially different from future results expressed or implied by such statements. There can be no assurance that forward-looking statements will prove to be accurate. Key assumptions upon which the Company’s forward-looking information is based include, without limitation: the absence of material adverse changes in the Company’s industry or the global economy including interest rate fluctuations, inflationary pressures, supply chain disruptions, and commodity market volatility; trends in the Company’s industry and markets, including the competitive environment; the ability of the Company to maintain its interests in its mineral projects, including with respect to title, access, and permitting matters; the Company’s ability to manage risks normally incidental to the exploration, development and operation of mineral properties; the performance and results of Phase I operations at the Sangdong Mine; the Company’s ability to proceed with Phase II expansion of the Sangdong Mine; the Company’s ability to maintain good business relationships with key stakeholders, including customers, suppliers, lenders, regulators, and local communities; the Company’s ability to manage its growth effectively, both organically and through acquisitions; the Company’s ability to effectively integrate acquisitions and realize anticipated benefits; the Company’s ability to manage potential uncertainties in the interpretation of geological data, drill results and market data, including data related to pricing trends, demand forecasts, and competitive positioning; the Company’s ability to manage the possibility that future exploration, development or mining results may not be consistent with its expectations; the accuracy of the Company’s mineral resource and reserve estimates and their underlying assumptions, including with respect to cut-off grades, recovery rates, and long-term commodity prices; the adequacy and availability of infrastructure (including power, water, roads, and processing capacity) at or near the mineral properties; the timely receipt and maintenance of necessary governmental and third-party approvals, permits, licenses, authorizations and regulatory compliance obligations; the Company’s ability to comply with current and future environmental, health and safety, and other regulatory requirements and to timely obtain and maintain required regulatory approvals, licenses and permits; the Company’s expectation that its operations will not be significantly disrupted as a result of political instability, pandemics and communicable diseases, nationalization, terrorism, sabotage, social or political activism, breakdown, natural disasters, governmental or political actions, litigation or arbitration proceedings, equipment or infrastructure failure, labour shortages, transportation disruptions or accidents, or other development or exploration risks; the Company’s ability to execute construction and development activities on schedule and within budget; the Company’s ability to recruit, retain and engage qualified personnel and contractors in all required jurisdictions; the Company’s ability to raise sufficient debt or equity financing to support its continued growth; the Company’s ability to continue to have sufficient working capital to fund its operations; the performance of counterparties under offtake agreements, supply arrangements, financing agreements, and other material contracts; that input costs, including energy, labour, equipment, and materials, will not increase materially beyond current expectations; that the price of tungsten and other metals and commodities will not decline significantly or for a protracted period of time; that the global financial markets and general economic conditions (including trade and monetary policies, currency exchange rates and rates of inflation) will be stable and conducive to business in the future; the Company’s ability to maintain the security and integrity of its information technology systems and mitigate the impact of any potential cybersecurity threats; and the Company’s ability to meet increasing expectations regarding environmental, social and governance (“ESG”) matters from regulators, investors, and other stakeholders.

Forward-looking statements are also subject to risks and uncertainties facing the Company’s business, including, without limitation: the negative cash flow from the Company’s operations; the adequacy of the Company’s disclosure control and procedures and internal controls over financial reporting; the price of metals; the Company’s economic dependency on few customers; fluctuation in foreign currency; fluctuation in interest rates; inflation; tax-related risks; the risk of default under any of the Company’s credit agreements; future financing; the Company’s liquidity and level of indebtedness; risks associated with the Company’s business being carried on through foreign subsidiaries; credit risk; the Company’s ability to continue as a going concern; risks relating to the development of the Sangdong Mine, including risks relating to the start-up of commercial production, commissioning, ramp-up and process performance risk, financing risk, construction risks, risk relating to the offtake agreements for the Sangdong Mine, availability of infrastructure and skilled labour, and risks related to the implementation of technological innovations at the Sangdong Mine; risks relating to the Tungsten Oxide Facility (as defined herein), including project financing and capital cost overrun risk, execution and construction risk, and permitting and regulatory risk; the Company’s production; the Company’s mineral reserve and mineral resource estimates; the Company’s dependence on key personnel; the Company’s competition; trade risks and supply chain disruptions (including as a result of geopolitical tensions); the cost of raw materials; energy supply and power grid reliability; water supply and management; infrastructure and operational risks; the Company’s impairment of assets; risks related to property title; laws and regulations; licenses and permits; mining risks and insurance limitations; legal systems; mineral reserve and mineral resource depletion; risks related to underground stope stability; reputational risks; geopolitical risks in key operating regions; public allegations, regulatory investigations, or litigation; capital market structure and dilution risk; environmental and global climate change risks; risks related to costs of land reclamation; technological obsolescence; management of growth; cybersecurity and data protection; opposition to mining; costs and compliance risks as a result of being a public company; acquisitions and synergies; anti-corruption and anti-bribery laws; Canada’s Extractive Sector Transparency Measures Act; health and pandemic risks; and risks related to the Company’s proposed redomiciling to the United States, including disruptions to the Company’s business, Canadian corporate tax risk.

Any of these risks could have a material adverse effect on the Company’s business, financial condition, results of operations and growth prospects. Readers should consider reviewing the detailed risk discussion under the heading “Risk Factors” of this AIF for a fuller understanding of the risks and uncertainties that affect the Company’s business and operations and that could cause the Company’s actual results, performance or achievements to be materially different from any anticipated results, performance or achievements expressed or implied by forward-looking statements.

Although Almonty has attempted to identify important factors that could cause actual results, level of activity, performance or achievements to differ materially from those contained in forward-looking statements, there may be other factors that cause results, level of activity, performance or achievements not to be as anticipated, estimated or intended. There can be no assurance that forward-looking statements will prove to be accurate and even if events or results described in the forward-looking statements are realized or substantially realized, there can be no assurance that they will have the expected consequences to, or effects on, Almonty. Accordingly, readers should not place undue reliance on forward-looking statements and are cautioned that actual outcomes may vary.

Investors are cautioned against attributing undue certainty to forward-looking statements. Almonty cautions that the foregoing list of material factors is not exhaustive. When relying on Almonty’s forward- looking statements and information to make decisions, investors and others should carefully consider the foregoing factors and other uncertainties and potential events. Almonty has also assumed that material factors will not cause any forward-looking statements and information to differ materially from actual results or events. However, the list of these factors is not exhaustive and is subject to change and there can be no assurance that such assumptions will reflect the actual outcome of such items or factors.

THE FORWARD-LOOKING INFORMATION CONTAINED IN THIS AIF REPRESENTS THE EXPECTATIONS OF ALMONTY AS OF THE DATE OF THIS AIF AND, ACCORDINGLY, IS SUBJECT TO CHANGE AFTER SUCH DATE. READERS SHOULD NOT PLACE UNDUE IMPORTANCE ON FORWARD-LOOKING INFORMATION AND SHOULD NOT RELY UPON THIS INFORMATION AS OF ANY OTHER DATE. WHILE ALMONTY MAY ELECT TO, IT DOES NOT UNDERTAKE TO UPDATE THIS INFORMATION AT ANY PARTICULAR TIME, WHETHER AS A RESULT OF NEW INFORMATION, FUTURE EVENTS OR OTHERWISE, EXCEPT AS REQUIRED IN ACCORDANCE WITH APPLICABLE LAWS.

CORPORATE STRUCTURE

Almonty is a corporation continued under the Canada Business Corporations Act (the “CBCA”). The common shares of Almonty (the “Common Shares”) are listed and posted for trading on the Nasdaq Capital Market (the “Nasdaq”) in the United States under the symbol “ALM” and also trade on the Toronto Stock Exchange (the “TSX”) under the symbol “AII”, on the Australian Securities Exchange (the “ASX”) as CHESS Depositary Interests (“CDIs”), at a ratio of one CDI to one Common Share, under the symbol “AII” and on the Börse Frankfurt (Frankfurt Stock Exchange) in Germany under the symbol “ALI1”.

Almonty was incorporated on September 28, 2009 under the Business Corporations Act (British Columbia) (the “BCBCA”) under the name RCG Capital Inc. as a Capital Pool Company. On September 23, 2011, the Company completed its qualifying transaction (the “Qualifying Transaction”), whereby all of the issued and outstanding securities of 7887523 Canada Inc. were acquired in exchange for securities of the Company on a one-for-one basis and the Company changed its name to “Almonty Industries Inc.”.

On March 27, 2012, Almonty filed articles of continuance and was continued from British Columbia to the CBCA.

On July 3, 2025, Almonty filed articles of amendment for the purpose of effecting a 1.5-to-1 consolidation of its Common Shares (the “Share Consolidation”) and its Common Shares commenced trading on a post-consolidated basis on July 7, 2025. The Share Consolidation was approved by Almonty’s shareholders on April 30, 2025 at its annual general and special meeting of shareholders. No fractional Common Shares were issued in connection with the Share Consolidation and, in the event that a shareholder would otherwise be entitled to a fractional Common Share upon such consolidation, such shareholder had such fractional share cancelled. Except where otherwise noted, all information in this AIF gives effect to the Share Consolidation.

On July 15, 2025, the Company closed its initial public offering of 20,000,000 Common Shares in the United States at a price of US$4.50 per Common Share for gross proceeds of US$90 million, which common shares commenced trading on the Nasdaq on July 14, 2025 under the ticker symbol “ALM” (the “Nasdaq IPO”).

Almonty’s head and registered office is located at 100 King Street West, Suite 5700, Toronto, Ontario, M5X 1C7.

For the purposes of waivers granted by the ASX to the Company from ASX Listing Rules 7.1, 10.11 and 10.14, the Company hereby confirms that it remains subject to, and continues to comply with, the requirements of the Toronto Stock Exchange with respect to the new issue of securities.

Intercorporate Relationships

The following diagram illustrates the intercorporate relationships between the Company and its significant subsidiaries and sets out the respective jurisdictions of existence of such subsidiaries and the percentage of their voting securities owned, controlled or directed, directly or indirectly, by the Company as at the date hereof. Some of the Company’s subsidiaries, for which the subsidiary’s total assets did not exceed 10% of the consolidated assets of the Company as at December 31, 2025, and for which the subsidiary’s revenue did not exceed 10% of the consolidated revenue of the Company as at December 31, 2025, have been omitted from the diagram below. The omitted subsidiaries, taken as a whole, accounted for less than 20% of the consolidated assets and less than 20% of the consolidated revenue of the Company as at December 31, 2025.

GENERAL DEVELOPMENT OF THE BUSINESS

Three-Year History

2023

2024

2025

2026 to Date

DESCRIPTION OF BUSINESS

General

Almonty is a leading producer of tungsten concentrate, primarily for the defense industry, with plans to vertically integrate into oxide production, and Almonty holds an additional deposit of molybdenum. The Company’s flagship asset, the Sangdong tungsten mine (the “Sangdong Mine”) in South Korea, is one of the world’s largest tungsten deposits by Inferred Mineral Resource and provides tungsten of superior grade compared with global peers, and is currently in commissioning.

Almonty also has a molybdenum project with significant Inferred Mineral Resources on a separate property adjacent to the tungsten orebody at the Sangdong Mine (the “Sangdong Molybdenum Project”). This molybdenum opportunity provides access to another critical material used in aerospace alloys, energy infrastructure and nuclear defense.

The Company also owns and operates the Panasqueira tungsten mine (the “Panasqueira Mine”) in Covilha, Castelo Branco, Portugal, one of the world’s longest-producing tungsten mines, which has been operating for over a century and is renowned for its high-grade, low-impurity tungsten concentrate. Almonty’s Spanish assets include the Valtreixal tungsten mine project (“the Valtreixal Mine”) located in the province of Zamora, in Western Spain, which is currently under development, and the Los Santos tungsten mine (the “Los Santos Mine”) located near Salamanca, Spain, which is currently in care and maintenance. In addition, the Company has the exclusive right to explore, develop and mine certain unpatented tungsten mining claims located in Beaverhead County, Montana in the United States (the “Gentung Tungsten Project”).

Production, Principal Markets and Distribution Methods

The production of Almonty is currently concentrated in the Panasqueira Mine. At the Panasqueira Mine, Almonty refines tungsten ore in its milling circuits using a combination of gravity separation (spiral banks, shaking tables etc.) after the ore is crushed in a primary crusher. The milling circuit at the Panasqueira Mine processes tungsten ore into a primary concentrate product typically grading 70% or greater WO₃ concentrate or higher. The WO₃ concentrate output of the Sangdong Mine is expected to achieve grades of approximately 65% WO₃.

The principal markets for the Company’s tungsten concentrates are the United States of America, Western Europe and Japan. These regions represent significant portions of global tungsten consumption, driven by defense, high-tech manufacturing, aerospace and industrial tooling sectors. Currently, most of the revenue earned by the Company’s operations is sold to the Customer (as defined herein) in accordance with supply agreements. The Customer is located in the United States of America. Contract terms for Almonty’s sale of WO₃ in concentrate (WO₃ concentrate) allow for a price adjustment based on final assay results of the WO₃ concentrate by the Customer to determine the final content. Recognition of sales revenue for WO₃ concentrate is based on the most recently determined estimate of WO₃ concentrate (based on initial assay results carried out by Almonty) and the contract price at the date of shipment, with a subsequent adjustment made upon final determination between Almonty and the Customer after receipt of the WO₃ concentrate. If the Customer disputes the invoiced amount based on a difference of assayed values of WO₃ concentrate, then the dispute is settled by an independent third-party assaying service whose findings are binding on both parties.

The terms of WO₃ concentrate sales contracts with third parties contain provisional pricing arrangements for all material not subject to a fixed price contract, whereby the selling price for WO₃ concentrate is calculated based on the adjusted prevailing monthly average price per metric tonne unit (“MTU”) of ammonium para tungstate (“APT”) as published by London Metal Bulletin on the date of shipment to the Customer.

All WO₃ concentrate produced by the Panasqueira Mine is loaded into one-tonne bags and stored on site until a minimum of 20 bags has been accumulated. Once 20 bags have accumulated on site, Almonty then arranges for an independent logistics company to procure a 20-tonne shipping container to site where 20 one-tonne bags are then immediately loaded into the container and the container is sealed by logistics company personnel and transported by truck to the nearest port. The container is held in a bonded location in the port while awaiting shipping via ocean freighter to the destination port of the Customer. Almonty has a distribution agreement with a European customer and a distribution agreement with a Japanese customer with production facilities in New York in the United States. Under these agreements, Almonty ships material and receives partial payment within five to seven days of shipment.

Revenues

Gross revenue for the year ended December 31, 2025 totalled $32.514 million ($28.836 million for the year ended December 31, 2024).

Specialized Skills and Knowledge

The number of persons skilled in the construction, operation, development and exploration of mining properties, and in particular tungsten mineral projects, is limited and competition for such persons is intense. The Company competes with mining and other companies on a global basis to attract and retain employees at all levels with appropriate technical skills and operating experience necessary to operate its mines. In particular, the continued development of the Sangdong Mine will depend on the availability of a skilled workforce, including, but not limited to, mining and mineral, metallurgical and geological engineers, geologists, environmental and safety specialists, and mining operators to explore and develop the project. Thus far, the Company believes that it has been successful in attracting and retaining employees at all levels with the appropriate technical skills, operating experience and knowledge to operate its mines and overall business.

Competitive Conditions

The Company sells tungsten concentrates at prices determined by world markets over which the Company has no influence or control. These markets are cyclical. The Company’s competitive position is determined by its costs compared to those of other producers throughout the world and by the Company’s ability to maintain financial strength through the tungsten concentrate price cycle despite currency fluctuations. Costs are governed principally by the location, grade and nature of the ore bodies and mineral deposits, and the Company’s cost of labour, power and supplies, and, as well, by operating and management skill. Over the long term, the Company’s competitive position is determined by its ability to develop economic ore bodies and replace current production. In this regard, the Company also competes with other mining companies for mineral properties.

At present, there are a limited number of competitors producing tungsten concentrates in the Western world. The world’s largest producing country of tungsten concentrates is China. The Company competes specifically with other mining and industrial operations located in the Iberian Peninsula, and the European Union in general, in obtaining skilled labour and mining supplies.

APT pricing increased significantly during fiscal 2025, with mid-market prices rising from US$330 per MTU in January 2025 to US$862.5 per MTU by the end of fiscal 2025. In February 2025, China implemented export controls on certain rare metal products, including tungsten, contributing to tightening market supply conditions. Around the same time, increased military spending in the United States, Germany, France, Japan, the United Kingdom and among NATO member states has been associated with increased demand for tungsten in defense applications.

Near the end of fiscal 2025 and into the first quarter of fiscal 2026, APT prices increased significantly, with average mid-prices rising from US$862.5 per MTU in early January 2026 to approximately US$2,250 per MTU as at March 13, 2026, based on market quotations. APT prices have shown an upward trend since the fourth quarter of 2024. The upward trend continued into fiscal 2026. There can be no assurance that this pricing trend will continue in the future. See “Risk Factors—Financial Risks—Price of Metals”.

Management believes that the limited quantities of spot concentrate available in the market, combined with increasing strategic demand, may support continued strength in pricing over the near to mid-term. The recent pricing environment is expected to be relevant to future production from the Sangdong Mine and is reflected in the renewed contracts signed at the Panasqueira Mine.

Growth Strategy

Almonty’s objective is to build a secure, Western-focused tungsten and molybdenum supply chain capable of displacing reliance on China and meeting the escalating needs of Western industries. Given our multi-decade resource visibility, access to high-grade and recovering material, our expertise in tungsten processing, our long-term offtake agreements and experienced management team, Almonty is well-positioned to become a leading strategic supplier of “conflict-free” tungsten and molybdenum for key industries, including defense, semiconductor, and battery markets. Almonty aims to expand its global relevance and meet the needs of various industries through strategic growth and ongoing resource development.

The Company’s growth strategy is focused on the development of the Sangdong Mine in South Korea and the ongoing operations of the Panasqueira Mine in Portugal. Almonty has implemented a planned closure of the operations of Daytal Resources Spain, S.L. (“Daytal”), an indirect wholly-owned subsidiary of Almonty, which owns a 100% interest in the Los Santos Mine, by placing the Los Santos Mine into care and maintenance in February 2020. The Company is planning to re-open the Los Santos Mine to restart production from tailings inventories in late 2026, pending completion of internal planning and certain external processes, including those related to operational readiness and regulatory matters. The project pipeline also includes the Valtreixal Mine, which is under exploration and development. Almonty also has a significant molybdenum resource on a separate property adjacent to the tungsten orebody at the Sangdong Mine. Due to distinct geological and spatial characteristics, the molybdenum and tungsten zones are considered separate, standalone projects. Additionally, in November 2025, the Company acquired U.S. Tungsten Inc., a U.S.-based privately-owned minerals explorer with the exclusive right to explore, develop and mine the Gentung Tungsten Project, and a privately held Montana corporation holding a number of assets including, but not limited to, a plant permit, water rights and tungsten mining equipment for use in the processing of tungsten from the Gentung Tungsten Project. The Gentung Tungsten Project is at an advanced exploration and development stage, and the Company is evaluating a potential path toward production, subject to further technical work, permitting and financing.

The current mine and processing plant construction at the Sangdong Mine (Phase I) began commercial mining in December 2025. The processing plant is in commissioning and expected to be complected in due course. Once fully operational, the targeted ore throughput capacity is expected to reach around 640,000 tonnes per year. The Company expects to increase its throughput capacity up to 1.2 million tonnes through the Phase II planned expansion. This expansion is fully permitted under existing Phase I approvals, and during the development of Phase I, some components have been built which may support a higher throughput or expansion. It is expected that, subject to positive operating results from Phase I and prevailing market conditions, Phase II could be completed in 2027, and first ore production under Phase II could commence that same year. This would involve initiating detailed engineering and permitting activities, followed by potential construction and commissioning. The Phase II expansion is expected to unlock scale economies and support margin enhancement. Advancement to Phase II is contingent upon a formal decision point following the evaluation of Phase I performance. Any additional tungsten concentrate produced as part of the Phase II expansion could be directed to the Tungsten Oxide Facility, which the Company is currently assessing as a potential vertical integration opportunity.

Additionally, Almonty is planning an extension of the Panasqueira Mine, with the potential to extend the life of the mine and significantly increase production capacity. Key objectives of this extension include increased ore throughput and improved average head grade, while continuing to serve customers who rely on the mine’s concentrate.

The Company is continuously in the process of seeking additional potential offtake partners and evaluating new opportunities to expand our commercial partnerships. As we increase our production, we expect to sign new offtake contracts with customers with favorable economics. These offtake contracts are anticipated to supply, among others, end-use customers in the defense and military sector.

Seasonality

There is no seasonality to the Company’s mining operations. The Company sells tungsten concentrates and upgraded tungsten products at prices determined by world markets over which the Company has no influence or control. These markets are cyclical. See “Description of the Business—Competitive Conditions” for additional information on the cyclicality of the APT commodity price.

Economic Dependence

Beralt Tin & Wolfram (Portugal) S.A., an indirect wholly-owned subsidiary of Almonty, which owns a 100% interest in the Panasqueira Mine, is party to a Supply Agreement with a customer who participates in the global tungsten business (the “Customer”). Currently, the majority of the revenue earned by the Company’s operations is sold to the Customer. Almonty is economically dependent on the revenue received from the Customer in order to be able to meet its current obligations and is subject to the pricing terms set out in the Supply Agreements.

Changes to Contracts

The Company renegotiates and renews a number of its commercial agreements, including offtake agreements, in the ordinary course. The Company does not expect its business to be materially affected by the renegotiation or renewal of contracts or sub-contracts in the current financial year.

Environmental Protection

The Company’s policy and a primary business objective is to minimize the potential environmental impact of mine development on the surrounding environment, from exploration through to post-closure commitments.

As part of its business planning, the Company identifies environmental risks and reviews and updates the closure costs for each property to account for additional knowledge acquired with respect to a property, or for changes in applicable laws or regulations. This process ensures that the Company properly budgets for the costs associated with closure, and the costs associated with implementing appropriate sustainability management measures.

The financial and operational effects of environmental protection requirements on the capital expenditures and earnings for each of the Company’s mines is not significantly different than that of similar sized mines and therefore, are not expected to significantly impact the Company’s competitive position in the future.

The Company’s total liability for reclamation and closure cost obligations, including restoration guarantees and bond premiums, as at December 31, 2025 was approximately $22.654 million.

Employees

As at December 31, 2025, the Company had 3 full-time, non-unionized employees, 5 full-time consultants and 1 part-time consultant working at the corporate office; 82 full-time employees and 4 full-time consultants at the Sangdong Mine in South Korea; 101 unionized full-time employees, 144 full time employees and 6 full-time consultants at the Panasqueira Mine; 10 non-unionized full-time employees at the Los Santos Mine; 1 part-time consultant at the Valtreixal Mine in Spain; 1 full-time employee and 1 full-time consultant at the Gentung Tungsten Project in Montana.

Foreign Operations

Almonty’s functional currency is the Canadian dollar ($), but it advances funds to subsidiaries in the functional currency of the subsidiary to which funds are advanced. As such, Almonty’s consolidated balance sheet and profit or loss can be significantly affected by movements in various currencies ($, US$, KRW and €).

As at December 31, 2025 the Company had the following financial instruments denominated in foreign currencies, in 000’s:

A 5% change in the value of the Canadian dollar relative to the above currencies would have an impact on net loss for the year ended December 31, 2025 of approximately $4.9 million.

The Company’s Korean Won functional currency businesses have the following financial instruments denominated in foreign currencies, in 000s:

A 5% change in the value of the Korean Won relative to the above currencies would change net income for the year ended December 31, 2025 by approximately $6.2 million.

Almonty’s wholly-owned indirect subsidiaries, BTW and Daytal, operate in Portugal and Spain, respectively, both of which use Euros (€) as their functional currency. Their output is a commodity that is primarily priced in United States dollars (US$), which is different than the functional currency of the Company and its subsidiaries and the Company and its subsidiaries may also incur costs or obtain indebtedness in a currency that is different from their functional currency.

The Company’s Euro functional currency businesses have the following financial instruments denominated in foreign currencies, in 000’s:

A 5% change in the value of the Euro relative to the above currencies would have an impact on net loss for the year ended December 31, 2025 of approximately $103,000.

Social or Environmental Policies

The Company is committed to maintaining high standards of environmental protection and care in the conduct of all aspects of its business. The Company’s mining, exploration and development activities are subject to various levels of South Korean, Portuguese, Spanish and U.S. federal, provincial, territorial and state laws and regulations relating to the protection of the environment, including requirements for closure and reclamation of mining properties.

The Company’s approach to environmental management includes maintaining compliance with all applicable legislation, regulations and authorizations, implementing proactive strategies for environmental protection, achieving continuous improvement in performance and encouraging open communications with governments, the general public and stakeholders.

Almonty is committed to the promotion of environmental awareness and stewardship amongst employees and contractors at its mining and exploration sites by providing accurate information and responsible environmental management that ensures safety, due diligence and compliance.

Responsible environmental management is key to Almonty’s success. The Company ensures that cost-effective, best management practices are utilized in assessing, planning, constructing and operating its facilities in compliance with all applicable legislation and regulations. The Company works together with various government agencies and the public to enhance communications and understanding of Almonty’s operations and its environmental stewardship.

Almonty’s guiding environmental principles are built into the management of its daily activities and its philosophy is included in all work procedures and protocols. Every employee is committed to, and responsible for, the integrity of Almonty’s environmental management.

RISK FACTORS

The Company operates in the mining industry, which presents a variety of risks and uncertainties, many of which could materially and adversely affect the Company’s business, financial condition and results of operations and could cause actual events to differ materially from those described in the Company’s forward-looking statements. While some exposures may be reduced by the Company’s risk management strategies, many risks are driven by external factors beyond the Company’s control or are of a nature which cannot be eliminated.

The risks described therein and herein may not be the only risks faced by Almonty. Other risks which currently do not exist, or which are deemed immaterial, may surface and have a material adverse impact on Almonty’s results of operations and financial condition.

Financial Risks

Negative Cash Flows from Operations

For the 12 months ended December 31, 2025, the Company has sustained net losses from operations and has had a negative cash flow from operating activities of $19.136 million. The Company may have negative cash flow in any future period and, as a result, the Company will need to use available cash to fund any such negative cash flow.

The Company anticipates increased cash flow from operating activities as production increases at the Sangdong Mine, meaning any delay would impact the Company’s ability to be cash flow positive. The Company may, in the future, seek further financing through long-term debt from financial institutions, debt or equity financing through capital markets, or private placements. The availability of this capital is subject to general economic conditions and lender and investor interest in the Company’s projects and there can be no assurance that additional capital or financing will be available if needed or that, if available, the terms of such financings will be acceptable to the Company. Any changes in these estimates or adverse developments in the availability of capital could materially impact the Company’s financial performance and results of operations.

Weaknesses in Disclosure Control and Procedures and Financial Disclosures

In its assessment of the effectiveness of internal control over financial reporting in connection with the year ended December 31, 2019, the Company determined it had a material weakness in the design and implementation of internal controls over the financial statement close and disclosure process, including regarding assertions about the completeness, existence and accuracy of the financial information. Due to this material weakness, management concluded that internal controls over financial reporting (“ICFR”) were not effective as of December 31, 2019 and are not effective as of December 31, 2025.

A material weakness is a significant deficiency, or combination of significant deficiencies, that results in more than a remote likelihood that a material misstatement of the annual or interim financial statements will occur and not be detected by management before the financial statements are published. Controls can potentially be circumvented by the individual acts of some persons, by collusion of two or more people or by management override of the control. The design of any system of controls is also based in part upon certain assumptions about the likelihood of future events, and there can be no assurance that any design will succeed in achieving its stated goals under all potential future conditions. Over time, control may become inadequate because of changes in conditions, or the degree of compliance with the policies or procedures may deteriorate. Because of the inherent limitations in a cost-effective control system, misstatements due to error or fraud may occur and not be detected.

In light of the aforementioned material weakness, management, with the assistance of an external firm, continues to assess ICFR effectiveness and work to address material weaknesses and deficiencies as necessary. While remediation efforts are ongoing, management continues to monitor and enhance internal processes and controls designed to ensure the reliability of the Company’s financial reporting. Accordingly, management has conducted a thorough review of all significant or non-routine adjustments for the fifteen months ended December 31, 2019, for the year ended December 31, 2020, for the year ended December 31, 2021, for the year ended December 31, 2022, for the year ended December 31, 2023, for the year ended December 31, 2024 and for the year ended December 31, 2025. As a result of this review, management believes that there were no material inaccuracies or omissions of material fact and, to the best of its knowledge, believes that the consolidated financial statements for the fifteen months ended December 31, 2019, for the year ended December 31, 2020, for the year ended December 31, 2021, for the year ended December 31, 2022, for the year ended December 31, 2023, for the year ended December 31, 2024 and for the year ended December 31, 2025 fairly present in all material respects the financial condition and results of operations for the Company in conformity with International Financial Reporting Standards.

Management, including the CEO and CFO, believes that any disclosure controls and procedures (“DC&P”) or ICFR, no matter how well conceived and operated, can provide only reasonable, not absolute assurance that the objectives of the control system are met, and, as such, management continues to evaluate and, as necessary, implement additional remediation measures. The Company’s current controls and procedures and any new controls and procedures that the Company develops may also become inadequate because of various factors, including changes in the Company’s business and increased complexity resulting from any international expansion. Any failure to develop or maintain effective controls and procedures or any difficulties encountered in their implementation or improvement could result in the Company’s inability to produce accurate financial statements on a timely basis, could increase the Company’s operating costs and harm the Company’s business, could result in the Company’s failure to meet the Company’s reporting and/or listing obligations, could result in a restatement of the Company’s financial statements for prior periods, could undermine investor confidence in the Company and could adversely affect the trading price of the Company’s common shares. In addition, investors’ perceptions that the Company’s internal controls and procedures are inadequate or that the Company is unable to produce accurate financial statements on a timely basis may harm the Company’s stock price.

Please refer to the section entitled “Disclosure Control and Procedures and Internal Control of Financial Reporting” in the Company’s management’s discussion and analysis dated March 18, 2026 (“MD&A”) for the fiscal years ended December 31, 2025 and December 31, 2024 for a discussion related to the establishment and maintenance of the Company’s DC&P and ICFR, including an update on the Company’s final remediation plan with respect to the aforementioned material weakness in the Company’s ICFR.

The Company remains committed to continuous improvement in its control environment and to ensuring a sustainable and transparent financial reporting framework going forward.

Price of Metals

The Company’s earnings are directly related to commodity prices, as revenues are derived from the sale of tungsten. In common with other commodities, tungsten markets are cyclical and may be volatile.

Almonty’s policy is to maintain exposure to commodity price movements at its mining operations. The Company sells WO₃ concentrate that is denominated in US$ per MTU. Every +/- US$10.00 movement in the average price of one MTU of European APT as quoted on the Fastmarkets MB exchange impacts the Company’s revenue by +/- approximately US$8.90 per MTU of WO₃ concentrate.

Tungsten prices fluctuate and are affected by factors including demand from industrial sectors such as defense, aerospace, and energy, international economic and political trends, expectations of inflation, expectations of economic activity, the exchange rate of the U.S. dollar to other major currencies, political and economic conditions including international trade disputes and the imposition of tariffs, interest rates, global or regional consumption and demand patterns, speculative activities and increased production due to improved mining and production methods, production costs in major tungsten-producing regions, speculative positions taken by investors or traders in tungsten, wars and other conflicts, changes in supply and changing investor or consumer sentiment (including in connection with the transition to a low-carbon economy, investor interest in cryptocurrencies and other investment alternatives) as well as competition from alternative materials, all of which are beyond the Company’s control. Tungsten prices may also be negatively affected by any slowing of the global economy, increases in exports from one market economy countries, notably China, unfavourable shifts in tungsten demand in key markets such as Asia, Europe, and North America, and the release of tungsten concentrate onto the market from the U.S. National Defense Stockpile. The aggregate effect of these factors is impossible to predict with accuracy. There is thus no assurance that a profitable market will continue to exist for the sale of tungsten. Fluctuations in tungsten prices may materially adversely affect the Company’s financial performance or results of operations. If the market price of tungsten concentrates falls below the Company’s realized or anticipated all-in sustaining costs per MTU of production at one or more of its mines, projects or other properties and remains so for any sustained period, the Company may experience losses and/or may curtail or suspend some or all of its mining, exploration or development activities at such mines, projects or other property or at other mines or projects. A fall in the market price of tungsten concentrate may affect the Company’s ability to generate positive cash flow from operations. The Company’s current mine plans and mineral reserve and mineral resource estimates for the Sangdong Mine are generally based on an APT price of US$450 per MTU. If the price of tungsten falls below such level, the Sangdong Mine may be rendered uneconomic and production may be suspended. In addition, lower tungsten prices may require the mine plans to be changed, which may result in reduced production, higher costs than anticipated, or both, and the estimate of mineral reserves for the Sangdong Mine and mineral resources may be reduced. Also, increased volatility in the price of tungsten may result in the Company delaying or abandoning some of its growth projects.

From time to time, the Company enters into supply agreements with customers which fix the price of the product it sells for periods of time the Company deems appropriate.

Economic Dependency

Although the Company sells its tungsten concentrate to Japanese, European and North American customers, the majority of the revenue earned by the Company’s current operations is derived from sales to two customers and their affiliates under short-term supply agreements for the minerals produced at the Panasqueira Mine (the “Panasqueira Customers”). BTW, an indirect wholly-owned subsidiary of the Company, is a party to such agreements, which are typically renewed on an annual basis. AKTC has also entered into an Amended and Restated Supply Agreement (the “Amended and Restated Supply Agreement”), dated December 4, 2020, with Global Tungsten & Powders Corp. (“GTP”) and Plansee Holding AG (“Plansee”), parent company to GTP, for the tungsten concentrate to be mined and processed at the Sangdong Mine. Almonty is economically dependent on the revenue received from the Panasqueira Customers in order to be able to meet its current obligations and will be economically dependent on the revenue received from GTP pursuant to the Amended and Restated Supply Agreement once the Sangdong Mine reaches commercial production. There is no guarantee that Almonty would be able to find alternative customers on terms similarly advantageous in the future should the Panasqueira Customers or GTP cease operations or become unable to pay Almonty.

Foreign Currency Risk

Fluctuations in foreign currency exchange rates may adversely affect the Company’s results of operations.

The Company’s operating results and cash flow are significantly affected by changes in exchange rates. Almonty’s wholly owned subsidiary, BTW, operates in Portugal, which uses € as its functional currency. Its output is a commodity that is primarily priced in US$ which is different than the functional currency of the Company and its subsidiaries, and the Company and its subsidiaries may also incur costs or obtain indebtedness in a currency that is different from their functional currency. Additionally, Daytal’s current care and maintenance expenses, as well as any potential future operating costs, are primarily denominated in Euros, which exposes the Company to currency fluctuations between the Euro and its reporting currency. Almonty’s functional currency is the Canadian dollar but it advances funds to subsidiaries in the functional currency of the subsidiary to which funds are advanced. As such, the Company’s financial performance can be significantly affected by movements in various currencies (C$, US$, € and KRW).

The U.S. dollar/Canadian dollar exchange rate has fluctuated significantly over the last several years. From January 1, 2025 to December 31, 2025, the U.S. dollar/Canadian dollar exchange rate (as reported by the Bank of Canada) fluctuated from a high of C$1.46 per US$1.00 to a low of C$1.36 per US$1.00. Historical fluctuations in the U.S. dollar/Canadian dollar exchange rate are not necessarily indicative of future exchange rate fluctuations.

In addition, the majority of the Company’s operating costs at the Panasqueira Mine as well as the care and maintenance costs at the Los Santos Mine are incurred in euros, and a significant portion of development costs and operating expenses at the Sangdong Mine are incurred in KRW. Each of these currencies has also fluctuated significantly against the U.S. dollar over the past several years. The Company may engage in mitigating transactions to limit its exposure to such risks, but there can be no assurance that any mitigating strategy will, if entered into, be successful. There can be no assurance that foreign exchange fluctuations will not materially adversely affect the Company’s financial performance and results of operations.

Interest Rate Risk

Almonty’s exposure to the risk of changes in market interest rates relates to cash at banks and long-term debt with a floating interest rate. Of the long-term debt, $127.878 million is subject to floating interest rates and $46.750 million is subject to fixed interest rates. A portion of the floating-rate debt totaling $25.505 million is subject to a fixed spread over the six- and 12-month Euro Interbank Offered Rate (“EURIBOR”). A change of 100 basis points (1.0%) in the EURIBOR would result in a $255,000 change in annual interest costs. The remaining floating rate debt of $102.373 million is based on a fixed spread over the three-month secured overnight financing rate (“SOFR”). A change of 100 basis points (1.0%) in the three-month SOFR would result in a $1.024 million change in annual interest costs. All figures provided in this risk factor are as at December 31, 2025.

The Company may in the future become a borrower of an additional material amount of funds or repay its existing outstanding long-term debt at any time without penalty. The Company’s primary operations are located in Korea, Spain, and Portugal. The ongoing uncertainty in the financial markets may have a negative impact on both the Company’s future borrowing costs and its ability to obtain debt financing.

Inflation

The Company is also affected by inflationary pressures. Inflation rates in the jurisdictions in which the Company operates have increased significantly since 2021. A significant portion of the upward pressure on prices has been attributed to the rising costs of labour and energy. These inflationary pressures have affected the Company’s labour, commodity and other input costs and such pressures may or may not be transitory. Any continued inflation or increase in the inflation rate for the Company’s inputs, including as a result of increased tariffs affecting countries in which the Company operates or that are part of the Company’s supply chains may have a material adverse effect on the Company’s operating costs, capital expenditures for the development of its projects as well as its financial condition and results of operations.

Canadian Corporate Tax Risk

For Canadian tax purposes, on the date Almonty completes the U.S. Domestication, it will be deemed to have a year end and to have disposed of all of the Company’s property for proceeds equal to the fair market value of that property. The Company will also be subject to an additional corporate emigration tax imposed on the amount, if any, by which the fair market value of the Company’s property, net of certain liabilities, exceeds the paid-up capital of the Company’s issued and outstanding common shares.

The quantum of tax payable, if any, by the Company upon the U.S. Domestication will depend upon a number of considerations including whether the Company reorganizes and/or winds up one or more of its subsidiaries prior to the U.S. Domestication becoming effective, the valuation of the Company’s assets, the amount of its liabilities, its shareholder composition, as well as certain Canadian tax amounts, accounts and balances of the Company, each as of the time of the U.S. Domestication. There could be material adverse tax consequences that result from the U.S. Domestication or the transactions completed in relation to the U.S. Domestication in Canada. In addition, it is possible that following the U.S. Domestication, the Canada Revenue Agency may disagree with the Company’s determination of the fair market value of its properties at the relevant time and/or the Company’s determination of any of its tax accounts or tax attributes. As a result, the quantum of Canadian tax payable by the Company may materially exceed the Company’s estimates at that time. Any such adverse tax consequences could materially adversely affect the Company and its share price. For additional information on the Canadian federal income tax consequences of the U.S. Domestication, see the section entitled “Certain Canadian Federal Income Tax Considerations Related To The Arrangement” of the management information circular of the Company dated January 31, 2025 and filed on February 4, 2025, prepared for the purposes of the special meeting of the shareholders of the Company held on February 27, 2025.

Default Risk

The Company’s term loans and convertible debentures include various positive and negative covenants as well as cross-default clauses. Events beyond the Company’s control, including changes in general economic and business conditions and global health crises or pandemics, may affect the Company’s ability to satisfy these covenants, which could cause several defaults in the event the Company is in default on any of its loan agreements.

In addition, as of the date of this AIF, the Company has pledged certain of its assets as security in order to obtain additional capital through loans. Should Almonty fail to comply with its covenants, pay any outstanding amount or remedy an event of default (as defined under the loan agreements), the lender may, among other things, have the right to demand immediate repayment of the outstanding debt or to seize and dispose of the secured assets.

Future Financing

The success of exploration programs, development programs and other transactions related to concessions could have a significant impact on the need for capital. If Almonty decides to develop one of its properties, it must ensure that it has access to the required capital. The Company could finance its need for capital by using working capital, by arranging partnerships or other arrangements with other companies, through equity financing, by taking on short-term and/or long-term debt or any combination thereof. To fund its future growth plans, the Company may become dependent on securing the necessary capital through loans or permanent capital. The availability of this capital is subject to general economic conditions and lender and investor interest in the Company’s projects and there can be no assurance that additional capital or financing will be available if needed or that, if available, the terms of such financings will be acceptable to the Company. To facilitate the availability of capital, the Company maintains an investor relations program to inform all shareholders and potential investors of the Company’s developments.

Liquidity Risk

Liquidity risk is the risk that an entity will encounter difficulty in raising funds to meet commitments associated with financial instruments. As at December 31, 2025, the Company held cash of $268.41 million (of which $2.46 million represented cash restricted for use for the development of the Sangdong Mine) and a working capital position of $213.18 million (deficiency of $36.81 million as at December 31, 2024). Although Almonty has been successful in repaying liabilities in the past and issuing new debt securities, there can be no assurance that it can continue to do so. In addition, Almonty may assume additional liability in future periods or reduce its holdings of cash in connection with funding future acquisitions, existing operations, capital expenditures, dividends or in pursuing other business opportunities.

The Company’s level of indebtedness could have important consequences for its operations, including:

As of December 31, 2025, Almonty had approximately $27.27 million (December 31, 2024 – $21.89 million) in debt maturing within the next 12 months.

In addition to future cash flow from operations, potential divestment and the creation of new joint ventures and partnerships, Almonty’s potential other sources of liquidity for the payment of its expenses and principal and interest payable on its debt in 2025 include issuing additional equity or unsecured debt. Almonty’s ability to reduce its indebtedness and meet its payment obligations will depend on its future financial performance, which will be impacted by financial, business, economic and other factors. Almonty will not be able to control many of these factors, such as economic conditions in the markets in which it operates. Almonty cannot be certain that its existing capital resources and future cash flow from operations will be sufficient to allow it to pay principal and interest on Almonty’s debt and meet its other obligations. If these amounts are insufficient or if there is a contravention of its debt covenants, Almonty may be required to refinance all or part of its existing debt, sell assets, borrow more money or issue additional equity. The ability of Almonty to access the bank, public debt or equity capital markets on an efficient basis may be constrained by a dislocation in the credit markets and/or capital and/or liquidity constraints in the banking, debt and/or equity markets at the time of issuance.

Almonty is also exposed to liquidity and various counterparty risks including, but not limited to: (i) Almonty’s lenders and other banking counterparties; (ii) Almonty’s insurance providers; (iii) financial institutions that hold Almonty’s cash; (iv) companies that have payables to Almonty; and (v) companies that have received deposits from Almonty for the future delivery of equipment.

Foreign Subsidiaries

All of Almonty’s business is carried on through its foreign subsidiaries. Accordingly, any limitation on the transfer of cash or other assets between the parent corporation and such entities, or among such entities, including restrictions or costs on dividends or repatriation of earnings under applicable local law or any tax obligations, monetary transfer restrictions and foreign currency exchange regulations in the jurisdictions in which the subsidiaries operate or are incorporated, could restrict the Company’s ability to fund its operations and projects efficiently and the Company’s growth may be inhibited unless it is able to obtain additional equity or debt financing on acceptable terms. In the event of a subsidiary’s liquidation, the Company may lose all or a portion of its investment in that subsidiary. Any such limitations, or the perception that such limitations may exist now or in the future, could have an adverse impact on Almonty’s valuation and stock price.

Credit Risk

Credit risk is the risk that one party to a financial instrument will fail to discharge an obligation and cause the other party to incur a financial loss. Financial instruments that potentially subject the Company to credit risk consist of cash, trade receivables and deposits. The Company manages credit risk by depositing surplus cash with major banks of high-quality credit standing, in interest-bearing accounts that earn interest at floating rates. Trade receivables represent amounts receivable related to delivery of concentrate that have not been settled and are with the Company’s customers, all of whom have good credit ratings and the Company has not experienced any credit issues with any of its customers. Other assets include deposits. The carrying value of the cash, trade receivables and deposits totalling $271.547 million as at December 31, 2025 represents Almonty’s maximum exposure to credit risk.

Ability to Continue as a Going Concern

The Company faces risks related to its ability to continue as a going concern. The Company’s financial stability is contingent upon its ability to manage substantial long-term debt, secure additional financing, and generate sufficient cash flows from its operations. Notably, the Company’s operations and development projects, including the Sangdong Mine, are capital-intensive and subject to various risks, including delays, cost overruns, and regulatory challenges. Any adverse developments in these projects could impact the Company’s cash flow and ability to meet its financial obligations. While the Company has been actively managing its financial position and securing necessary financing to support its operations and its current forecast indicates that it will have sufficient cash flows from operations and from financings to continue as a going concern and settle obligations as they come due, any changes in these estimates or adverse developments in the Company’s operations or financing activities could materially impact its ability to continue as a going concern.

Risks Relating to the Development of the Sangdong Mine

Uncertainties and Risks Relating to the Start-Up of the Sangdong Mine

The Company’s ability to maintain current, or achieve forecast, tungsten production levels is dependent on the successful development and potential expansion of the Sangdong Mine. There are many risks and unknowns inherent in all projects. For example, the economic feasibility of projects is based upon many factors, including:

Unforeseen circumstances, including those related to the amount and nature of the mineralization at the development site, technological impediments to extraction and processing, legal requirements, governmental intervention, infrastructure limitations, transport issues, environmental issues, and local community relations or other events, could result in the development of the Sangdong Mine becoming impractical or uneconomic. Further, actual costs and economic returns may differ materially from the Company’s estimates, or the Company may fail or be delayed in obtaining the governmental permits and approvals necessary in connection with the project, in which case, the project may not proceed either on its anticipated timing or at all.

Frequently, new and/or expanded mining operations experience unexpected problems during the start-up phase, and delays can often occur prior to production reaching its expected steady-state levels. The Company may also experience actual capital and operating costs and operating results that differ materially from those anticipated. In addition, experience from actual mining or processing operations may identify new or unexpected conditions that could reduce production below, or increase capital or operating costs above, current estimates. Accordingly, the Company cannot provide assurance that its activities will result in profitable mining operations at the Sangdong Mine.

Commissioning, Ramp-Up and Process-Performance Risk

Although the Company’s flagship Sangdong Mine has entered its production phase, there can be no assurance that initial throughput, grades or metallurgical recoveries will meet design expectations or assumptions underlying the Company’s technical and financial projections. Variability in early-stage ore domains, blending ratios, reagent consumption, wear rates and replacement schedules, as well as contractor performance and other factors may result in delays or shortfalls in achieving design recoveries or concentrate specifications.

Any such delays or operational under-performance could have an effect on related project milestones, including the commissioning of ancillary systems such as water-management, paste-backfill and tailings-storage facilities. These factors could in turn affect the timing of offtake deliveries and adversely impact projected cash flows and operating margins. The Company may be required to incur additional capital expenditures or extend ramp-up timelines to attain full design capacity and process efficiency. There can be no assurance that such measures would be successful or that they would not materially and adversely affect the Company’s business, financial condition or results of operations.

Financing Risk

The development of the Sangdong Mine is heavily reliant on the KfW Facility, a government-backed lender that operates as part of the German state-owned KfW Group. The loan bears interest at the rate of SOFR plus 2.3%, capitalized quarterly, with repayment of principal quarterly over a 6.25-year period commencing in the third quarter of 2026. In addition, the Company has received an additional US$20 million in loan funding from Plansee (as defined herein).

Any delays in the achievement of production at the Sangdong Mine could impact the Company’s ability to comply with its repayment obligations with respect to the foregoing loans. The Company may also be unable to comply with its repayment obligations in the event of lower-than-expected metallurgical recoveries or future commodity prices.

Construction Risks

As a result of the substantial expenditures involved in development projects, developments are prone to material cost overruns versus budget. The capital expenditures and time required to develop new mines are considerable and changes in cost or construction schedules can significantly increase both the time and capital required to build the project.

Construction costs and timelines can be impacted by a wide variety of factors, many of which are beyond the control of the Company. It is common in new mining operations to experience such unexpected costs, problems and delays during construction, development and mine start-up. These include, but are not limited to, weather conditions, ground conditions, performance of the mining fleet, availability of appropriate material required for construction, availability and performance of contractors and suppliers, delivery and installation of equipment, design changes, accuracy of estimates and availability of accommodations for the workforce.

Project development schedules are also dependent on obtaining the governmental approvals and inspections necessary for the operation of a project. The timeline to obtain these government approvals is often beyond the control of the Company. A delay in start-up or commercial production would increase capital costs and delay receipt of revenues.

Offtake Agreement

The Company has entered into the Amended and Restated Supply Agreement with GTP and Plansee for the tungsten concentrate to be mined and processed at the Sangdong Mine. See “Material Contracts—Amended and Restated Supply Agreement” for additional information on this contract. The realization of the benefits of the Amended and Restated Supply Agreement is contingent upon Almonty’s ability to meet its obligations to deliver tungsten concentrate in accordance with the terms of the agreement. Any failure to comply with the obligations under the Amended and Restated Supply Agreement, including failure to deliver the required quantities or quality of tungsten concentrate, could result in penalties, reduced revenues, or the termination of the agreement. The variable costs of shipping and production over the term of the contract may also affect the profitability of the agreement. Fluctuations in these costs may be influenced by factors such as fuel prices, labour costs, and regulatory changes. GTP’s failure to purchase the tungsten concentrate as agreed may also have a material impact on Almonty’s revenue. As a result, there is no guarantee that the Company will realize the revenues contemplated under the terms of the Amended and Restated Supply Agreement.

Availability of Infrastructure

The continued development of the Sangdong Mine will require access to and an ability to maintain adequate and reliable infrastructure, including roads, power sources and water systems. If the required infrastructure is not readily available, it may have to be built, and there is no assurance that it can be built in a timely manner or at all. There is no assurance that the Company can access and maintain the infrastructure needed, or, where necessary, obtain rights of way, government authorizations and permits to construct, or upgrade the same at a reasonable cost, in a timely manner, or at all. Access to infrastructure may also be interrupted by natural causes, such as drought, floods, earthquakes, landslides and other weather phenomena, or man-made causes, such as blockades, sabotage, conflicts, government issues, political events, protests, rationing or competing uses, as well as global pandemics. Inadequate, inconsistent or costly infrastructure could compromise many aspects of the project’s feasibility, viability and profitability, including, but not limited to the construction schedule, capital and operating costs.

Availability of Skilled Labour

The continued development of the Sangdong Mine will depend on the availability of a skilled workforce, including, but not limited to, mining and mineral, metallurgical and geological engineers, geologists, environmental and safety specialists, and mining operators to explore and develop the project. Inadequate access to an available skilled workforce could compromise many aspects of the project’s feasibility, viability and profitability, including, but not limited to, the construction and production schedules, capital and operating costs.

Technological and Innovation Risk

The development and operation of the Sangdong Mine involve advanced technologies, such as the Mine Safety DX technology developed with KT. The successful implementation of this technology relies on the integration of advanced communication infrastructure. Any technical issues or delays in installation and operation could hinder communication and monitoring capabilities. This could lead to operational disruptions, increased costs, and production delays, negatively impacting the profitability of the Sangdong Mine.

Risks Relating to the Tungsten Oxide Facility

Project Financing and Capital Cost Overrun Risk

The Company has not yet secured all of the financing required to construct and commission its projected development of the Tungsten Oxide Facility. While a non-binding letter of intent has been entered into with KfW for up to $50 million in project financing, the finalization of this financing facility and any additional required funding remains subject to various conditions including due diligence, negotiation of definitive agreements and satisfaction of conditions precedent, such as receipt of all necessary permits.

The estimated capital cost of the Tungsten Oxide Facility is based on preliminary engineering studies and may be subject to significant change as the project advances. Unanticipated increases in construction, equipment, labour, or regulatory compliance costs could result in a funding shortfall. There can be no assurance that the Company will be able to secure the necessary project financing on acceptable terms or at all. Failure to obtain sufficient financing or to control capital costs could delay, suspend, or prevent the construction and commissioning of the Tungsten Oxide Facility, which could have a material adverse effect on the Company’s growth strategy, financial condition, and results of operations.

Execution and Construction Risk

The Tungsten Oxide Facility is a large-scale, technically complex project that remains in the pre-construction stage. The successful completion of the project is subject to numerous risks, including but not limited to: design and engineering challenges, procurement and delivery of specialized equipment, contractor and labour availability, construction delays, cost overruns, and unforeseen technical or environmental issues. Any material delay, technical failure, or increase in costs could adversely affect the project’s economics and the Company’s financial position. There can be no assurance that the Tungsten Oxide Facility will be completed on schedule, within budget, or at all, or that it will operate as intended.

Permitting and Regulatory Risk

The development and operation of the Tungsten Oxide Facility are subject to obtaining and maintaining various permits, licenses, and regulatory approvals from local, regional, and national authorities in Korea. The permitting process can be lengthy, complex, and subject to change, and there is no guarantee that all necessary approvals will be obtained in a timely manner or at all.

Operational Risks

Production

Almonty prepares estimates of future production, total cash costs and capital costs of production for particular operations. No assurance can be given that such estimates will be achieved. Failure to achieve production or cost estimates or material increases in costs could have an adverse impact on Almonty’s future cash flows, profitability, results of operations and financial condition.

Almonty’s actual production and costs may vary from estimates for a variety of reasons, including: actual ore mined varying from estimates of grade, tonnage, dilution and metallurgical and other characteristics; short-term operating factors relating to mineral or ore reserves, such as the need for sequential development of ore bodies and the processing of new or different ore grades; revisions to mine plans; unusual or unexpected ore body formations; risks and hazards associated with mining; natural phenomena, such as inclement weather conditions, increased incidence of extreme weather events, water availability, floods, and earthquakes; and unexpected labour shortages or strikes. Production may also be impacted by delays or inefficiencies in the commissioning or operation of the flotation and chemical processing plant at the Sangdong Mine. Costs of production may also be affected by a variety of factors, including: changing waste-to-ore ratios, ore grade metallurgy, labour costs, the cost of commodities, general inflationary pressures and currency exchange rates.

Accuracy of Mineral Reserve and Mineral Resource Estimates

The mineral reserves and mineral resources published by the Company are estimates and no assurance can be given that the anticipated production will be achieved or that the indicated level of recovery of tungsten will be realized. Mineral reserve and mineral resource estimates are often based on tungsten recoveries in small-scale laboratory tests and may not be indicative of the mineralization in the entire orebody and the Company may not be able to achieve similar results in larger scale tests under on-site conditions or during production. Large-scale continuity and character of the Company’s deposits will only be determined once significant additional drilling and sampling have been completed and analyzed. Actual mineralization or formations may be different from those predicted. No assurance can be given that any part or all of Almonty’s mineral resources constitute or will be converted into reserves. The ore grade actually recovered by the Company may also differ from the estimated grades of the mineral reserves and mineral resources.

Reserve and resource estimates are materially dependent on prevailing metal prices and the cost of recovering and processing minerals at the individual mine sites.

Prolonged declines in the market price of tungsten may render mineral reserves containing relatively lower grades of mineralization uneconomical to recover and could materially reduce the Company’s mineral reserves. Should such reductions occur, the Company may be required to take a material write-down of its investment in mining properties, reduce the carrying value of one or more of its assets or delay or discontinue production or the development of new projects, resulting in increased net losses and reduced cash flow. The Company estimates the recoverable amount of long-lived assets and goodwill using assumptions and if the carrying value of an asset or goodwill is then determined to be greater than its actual recoverable amount, an impairment would be recognized by reducing the Company’s earnings. Market price fluctuations of tungsten, as well as increased production costs or reduced recovery rates, may render mineral reserves containing relatively lower grades of mineralization uneconomical to recover and may ultimately result in a restatement of mineral resources. Short-term factors relating to the mineral reserve, such as the need for orderly development of ore bodies or the processing of new or different grades, the technical complexity of orebody, unusual or unexpected orebody formations, ore dilution or varying metallurgical and other ore characteristics may impair the profitability of a mine in any particular period. Failure to obtain or maintain necessary permits or government approvals, or changes to applicable tax and customs regimes or applicable legislation, could also cause the Company to reduce its mineral reserves.

Mineral resource estimates for properties that have not commenced production or at deposits that have not yet been exploited are based, in most instances, on very limited and widely spaced drill hole information, which is not necessarily indicative of conditions between and around the drill holes. Accordingly, such mineral resource estimates may require revision as more drilling information becomes available or as production experience is gained.

The estimated mineral resources and mineral reserves provided by Almonty should thus not be interpreted as assurances of commercial viability or potential or of the profitability of any future operations. Investors are cautioned not to place undue reliance on these estimates.

Dependence on Key Personnel and Employees

Recruiting and retaining appropriately qualified personnel is critical to the Company’s success. The number of persons skilled in the construction, operation, development and exploration of mining properties is limited and competition for such persons is intense. The Company competes with mining and other companies on a global basis to attract and retain employees at all levels with appropriate technical skills and operating experience necessary to operate its mines. Additionally, as the Company becomes a larger company and given that it is a publicly listed in the U.S., the Company may be required to recruit additional personnel to assist the Company in complying with new reporting requirements, listing standards and other applicable rules and regulations. The Company may not be able to fill new positions or vacancies created by expansion or turnover or attract and retain qualified personnel. Relationships between the Company and its employees may be affected by changes in the scheme of employee relations that may be introduced by relevant government authorities in the jurisdictions that the Company operates. Changes in applicable legislation or in the relationship between the Company and its employees or contractors may have a material adverse effect on the Company’s business, results of operations and financial condition.

The loss of the services of one or more of such key management personnel, including Lewis Black, the Company’s chairman, president and CEO and Brian Fox, the Company’s CFO, could have a material adverse effect on the Company. The Company’s ability to manage its operating, development, exploration and financing activities will depend in large part on the efforts of these individuals.

The Company believes that it has been successful in recruiting the necessary personnel to meet its corporate objectives but, as the Company’s business activity grows, it will require additional key financial, operational, technical, mining and management personnel, as well as additional staff on the operations side. There can be no assurance that the Company will be able to continue to attract and retain such personnel.

Competition

The mineral exploration, development and production industry is intensely competitive in all of its phases and the Company must compete in all aspects of its operations with a substantial number of large established mining companies with greater liquidity, greater access to credit and other financial resources, newer or more efficient equipment, lower-cost structures, more effective risk management policies and procedures and/or greater ability than the Company to withstand losses.

There is also a limited supply of desirable mineral properties available for claim staking, leasing, exploration or acquisition in the areas where the Company contemplates conducting activities. Many companies and individuals are engaged in the mining business and, as a result, the competition for these properties is intense. The Company may be at a competitive disadvantage in acquiring ore, talent or mining properties, as it must compete with these companies and individuals, some of which may have greater financial resources and larger technical staff than the Company or be able to leverage synergies that are not available to the Company.

The Company’s competitors may be able to respond more quickly to new laws or regulations or emerging technologies or devote greater resources to the expansion of their operations, than the Company can. In addition, current and potential competitors may make strategic acquisitions or establish cooperative relationships among themselves or with third parties. Accordingly, there can be no assurance that the Company will be able to compete successfully for new mining properties.

As global efforts to reduce dependency on Chinese tungsten increase, competition among non-Chinese producers may also intensify. This could impact pricing dynamics, market share, and long-term profitability. Failure to maintain cost competitiveness or secure strategic partnerships may adversely affect the Company’s market position.

Trade Risks

The Company operates in jurisdictions that may be subject to heightened geopolitical tensions and trade policy uncertainties and is dependent on global supply chains for certain critical inputs, including reagents and specialized equipment. Geopolitical tensions and trade policy uncertainties, including trade disputes, particularly those affecting China, Europe, and the United States, may impact the availability and pricing of tungsten. With China accounting for a significant share of global tungsten supply, any changes in laws and regulations, export restrictions, licensing requirements, quotas, tariffs, sanctions, or other trade restrictions could create volatility in the market and materially disrupt pricing, concentrate availability and counterparty behaviour, which may in turn affect the Company’s offtake agreements and revenue streams and could limit the Company’s ability to source materials or compete effectively.

Since the inauguration of Donald J. Trump as President of the United States of America on January 20, 2025, tariffs have been announced on goods imported to the United States from a lengthy list of countries around the world, including Canada, Korea, Spain, and Portugal. Almonty has determined that its tungsten ore, concentrates, oxide, and related materials are not subject to these tariffs. The imposition of any tariff on tungsten ore, concentrates, oxide, and related materials produced and sold by the Company and its subsidiaries may adversely affect the Company’s business, financial condition and results of operations.

The current U.S. administration has demonstrated a willingness to rapidly and unilaterally alter trade policy, including the imposition, increase, reduction, or removal of tariffs—sometimes at extreme levels and with limited advance notice. This highly dynamic and often unpredictable approach to trade regulation has created significant uncertainty for global markets. The imposition of these tariffs by the U.S. administration, any retaliatory tariffs and the resulting trade disputes between the United States and certain other nations, including China, as well as the effectiveness of the United States-Mexico-Canada Agreement and significant modification or termination of the North American Free Trade Agreement, could have a material adverse effect on international trade, the United States’ economy and the global economy and a multi-country trade war against the U.S. may develop. The economic impact of tariffs or a broader trade war on the Canadian economy, the U.S. economy and the global economy could negatively impact capital markets, commodity prices and the Company’s ability to raise funds to undertake capital expenditures. A Canada-U.S. or a broader trade war also has the potential to adversely impact global supply chains and make supplies that are required for the conduct of the Company’s activities more expensive, harder to obtain or unavailable. Scarcity in the global supply chain would likely increase the cost of supplies required generally, which could impair the Company’s ability to operate. The indirect effects of tariffs imposed by the U.S. or by counter tariffs in response are difficult to assess, but the potential for continued tariffs represents a risk and may adversely affect the Company’s business, financial condition and results of operations. Further, the recent enactment of the One Big Beautiful Bill Act has eliminated certain tax incentives for critical minerals, including tungsten, which may adversely affect the Company’s business, financial condition and results of operations.

Supply Chain Disruptions

Natural resource exploration, development, processing and mining activities are dependent on the availability of mining, drilling and related equipment in the particular areas where such activities are conducted. Prolonged disruptions to the procurement of equipment, or the flow of materials, supplies and services to the Company could have an adverse impact on its operating costs, capital expenditures and construction and production schedules and ability to meet production and delivery targets. These disruptions may be the result of matters outside of the Company’s control or ability to mitigate, such as from natural disasters, trade disputes, imposition of tariffs, transportation disruptions, economic instability, global pandemics or other health emergencies, international sanctions, including those imposed in the context of the invasion of Ukraine by Russia, and geopolitical concerns, such as the conflicts in the Middle East and ongoing conflict in Ukraine. Supply chain disruptions may also be manifested as rising costs or shortages of certain commodities. Furthermore, concentration of key inputs or logistics through a limited number of suppliers or geographies may exacerbate trade and geopolitical risks in the event of a supply chain interruption.

Raw Materials Cost

Unexpected increases in raw material costs could significantly impair Almonty’s profitability. Almonty’s mining operations use significant amounts of steel, petroleum products and other raw materials in various pieces of mining equipment, supplies and materials. If the price of steel, petroleum products or other input materials increases, Almonty’s operational expenses will increase, which could have a significant negative impact on its profitability.

Energy Supply and Power Grid Reliability

Mining operations are highly dependent on reliable and cost-effective energy supplies. Disruptions to the power grid, including outages, price volatility, or infrastructure failures, could significantly impact production timelines and increase operating costs. Additionally, reliance on regional energy sources may expose the Company to regulatory changes or shortages in energy supply. Any significant disruption to energy availability or cost increases could adversely affect operational efficiency and profitability.

Water Supply and Management

Water is a critical input to the Company’s present and planned mining operations, and the amount of water resources in the regions in which the Company operates requires the Company to consider current and future conditions in its management of water resources. Current and long-term risks include those that arise as a result of the Company’s operations and events that are out of the Company’s control such as extreme weather and other physical risks associated with climate change such as changes in rainfall and water availability.

Changes in the quantity of water in regions where the Company operates, whether excessive or deficient amounts, may affect exploration and development activities, mining and processing operations, water management and treatment facilities, tailings storage facilities, closure and reclamation efforts, and may increase levels of dust in dry conditions and land erosion and slope stability in case of prolonged wet conditions.

Water shortages may also result from environmental and climate events that are out of the Company’s control and ability to manage. For example, inadequate rainfall or the occurrence of drought may stop operations, which could materially affect production. Conversely, excessive rainfall or flooding may also result in operational difficulties, including geotechnical instability, increased dewatering demands, and additional water management requirements. In addition, the Company cannot predict the potential outcome of pending or future legal proceedings or negotiations related to water rights, claims, contracts and uses, which may impact the Company’s operations. The loss of water rights for any of the Company’s mines, in whole or in part, or shortages of water to which the Company has established rights, could impact existing operations or prevent future exploration. Further, laws and regulations may be introduced in the jurisdictions in which the Company operates which could limit its access to sufficient water resources. Additionally, failure to manage water discharge or contamination risks could lead to environmental liabilities and reputational damage.

Any of the foregoing could have a material adverse effect on the Company’s results of operations and financial performance.

Infrastructure and Operational Risks

The Company’s operations depend on the effective maintenance and operation of its mining infrastructure, much of which, in Portugal and Spain, has been in service for many years. Aging infrastructure may result in increased maintenance costs, unexpected equipment failures, or operational disruptions. Additionally, delays or interruptions in the transportation of tungsten concentrate to global markets, whether caused by logistical bottlenecks, weather-related events, or third-party disruptions, could adversely affect operations.

Impairment of Assets

The Company conducts annual impairment assessments of goodwill and, at the end of each reporting period, the Company assesses whether there is any indication that long-lived assets (such as mining properties and plant and equipment) may be impaired. If an indicator of impairment exists, the recoverable amount of the asset is calculated in order to determine if any impairment loss is required. Testing for impairment involves a comparison of the recoverable amount of the cash-generating unit to its’ carrying value. An impairment charge is recognized for any excess of the carrying amount of the asset group or reporting unit over its recoverable amount.

The assessment for impairment is subjective and requires management to make estimates and assumptions for a number of factors including estimates of production levels, mineral reserves and mineral resources, operating costs and capital expenditures reflected in the Company’s life-of-mine plans, as well as economic factors beyond management’s control, such as tungsten prices and observable net asset value multiples. Should management’s estimates and assumptions regarding these factors be incorrect, the Company may be required to realize impairment charges, which will reduce the Company’s earnings. The timing and amount of such impairment charges is difficult to predict.

Risks Related to Property Titles

The acquisition of title to mineral properties is a very precise and time-consuming process. Although the Company has taken reasonable measures to ensure that its property titles are valid, including receiving a title opinion from Korean counsel with respect to certain mineral rights, there is no certainty that the property titles will not be challenged or questioned. Third parties may have valid claims on underlying portions of the Company’s interests, including prior unregistered liens, agreements, transfers or claims, including land claims to the lands immediately adjacent to the Company’s leased lands, and title may be affected by, among other things, undetected defects. In addition, the Company may be unable to conduct its operations on one or more of its properties as currently anticipated or permitted or to enforce its rights in respect of its properties.

Laws and Regulations

The Company’s mining and mineral processing operations, exploration activities and properties are subject to the laws and regulations of federal, provincial, territorial, state and local governments in the jurisdictions in which the Company operates and the receipt of, and compliance with, applicable permits. These laws, regulations and permits are extensive and govern prospecting, exploration, development, production, exports, taxes, labour standards, occupational health and safety, waste disposal and tailings management, toxic substances, environmental protection, mine safety, reporting of payments to governments and other matters. Compliance with such laws, regulations and permits can be extremely time-consuming, and may increase the costs of planning, designing, drilling, developing, constructing, operating, managing, closing, reclaiming and rehabilitating mines and other facilities.

Parties engaged in mining operations may be required to compensate those suffering loss or damage by reason of the mining activities and may be liable for civil or criminal fines or penalties imposed for violations of applicable laws or regulations. The Company cannot give any assurances that such notices, notices received in the future or other regulatory actions will not result in material fines or require or otherwise result in the Company taking actions that have a material effect on its business, financial condition or results of operations.

Amendments to current laws, regulations and permitting requirements, or more stringent application of existing laws, could have a material adverse effect on Almonty and cause increases in capital expenditures or production costs or reductions in levels of production at producing properties or require abandonment or delays in development of properties.

In addition, current laws and regulations are subject to change from time to time. Any change in laws and government regulations or the implementation of new regulations or the modification of existing regulations affecting tungsten and the mining industry more generally could require significant expenditures, cause a reduction in the levels of production, or reduce demand for tungsten and other minerals and increase Almonty’s costs, any of which may have a material adverse effect on Almonty’s business, financial condition and results of operations. Changes in these regulations or in their application are beyond the control of Almonty and could adversely affect its operations, business and results of operations.

Licenses and Permits

The Company’s current and anticipated future operations, including further exploration, development and production activities on the Company’s properties, require permits from various national, state/provincial and local governmental authorities. The Company may not be able to obtain all necessary licenses and permits that may be required to carry out exploration, development and mining operations at their projects. In addition, the grant of required licenses and permits may be delayed for reasons outside the Company’s control. Failure to obtain such licenses and permits on a timely basis, or failure to comply with the terms of any such licenses and permits that the Company does obtain, may adversely affect their respective business as the Company would be unable to legally conduct its intended exploration, development, production of a commercially viable material, processing facility construction or mining work, which may result in increased costs, delay in activities or the Company losing its interest in its mineral properties.

Mining companies must obtain numerous permits, licenses and approvals that strictly regulate environmental, health, safety, access and other matters in connection with mining. Regulatory authorities exercise considerable discretion in whether or not to issue permits, licenses and approvals and the timing of such issuances. Almonty believes it (or its subsidiaries) presently holds all necessary licenses and permits to carry on the activities at its mineral properties, and that it is presently complying in all material respects with the terms of such licenses and permits. Almonty’s properties may be held in the form of permits, licenses and leases and working interests in permits, licenses and leases. There can be no guarantee, however, that Almonty or its subsidiaries will be able to obtain and maintain, at all times, all necessary licenses and permits required in connection with its mineral properties or any exploration or development activity or to place its properties into commercial production and to operate mining facilities thereon. If Almonty or the holder of any such permit, license or lease fails to meet the specific requirement of such permit, license or lease, the permit, license or lease, as applicable, may terminate or expire. There can be no assurance that any of the obligations required to maintain each permit, license or lease will be met. The termination or expiration of such permits, licenses or leases or the working interests relating to a permit, license or lease may have a material adverse effect on Almonty’s results of operations and business.

Private individuals and the public at large often possess rights to comment on and otherwise engage in the permitting, licensing and approval processes, including through intervention in the courts. Accordingly, new permits, licenses and approvals required by Almonty to fully exploit its properties may not be issued, or if issued, may not be issued in a timely fashion, or may contain requirements which restrict Almonty’s ability to conduct its mining operations or to do so in a profitable manner.

As at December 31, 2025, there is a restoration provision of $3.436 million (December 31, 2024 – $3.161 million) with respect to the Sangdong Mine based on the amount assessed by the relevant local government authorities. Actual costs may exceed the provision amount due to unforeseen circumstances, changes in regulatory requirements, or inaccuracies in the local government authorities’ initial assessment.

In addition to authorizations required in connection with its mineral properties, other mines that may be acquired by Almonty will require governmental authorizations and permits before these properties can be developed and brought into production. Access to such lands for mining purposes may be restricted by present or future legislation. Accordingly, there can be no assurance that Almonty will be able to obtain the necessary authorizations to further develop its mineral properties or other resource properties that it may acquire in the future.

To the extent such authorizations are required and not obtained, Almonty may be restricted or prohibited from proceeding with planned exploration, development and production activities.

Mining Risks and Insurance Limitations

Almonty’s exploration, development and mining operations are subject to significant risks beyond the control of management that can delay tungsten mining or delivery, or increase the cost of mining. Such risks include environmental hazards (including relating to regulated substances), industrial accidents, unusual or unexpected rock formations, changes in the regulatory environment, seismicity, cave-ins, rock bursts, rock falls, pit wall failures, flooding and ore losses (from theft or otherwise). Such risks could result in, among other things, damage to, or destruction of, mineral properties or production infrastructures and facilities, personal injury or death, environmental damage, delays in mining, monetary losses and legal liability.

Additionally, risks may arise with respect to the management of tailings and waste rock, mine closure, rehabilitation and management of closed mine sites (whether the Company operated the mine site or acquired it after operations were conducted by others). Additionally, risks may arise with respect to the management of tailings and waste rock, mine closure, rehabilitation and management of closed mine sites (whether the Company operated the mine site or acquired it after operations were conducted by others). While rare, a failure of one of the Company’s large tailings storage facilities, which are effectively large dams that must be engineered, constructed and monitored to assure structural stability and avoid leakages or structural collapse, could lead to property damage, environmental harm, or pose safety risks.

In the course of exploration, development, and production of mineral properties, several risks may be encountered, particularly those involving unexpected or unusual geological or operating conditions. It is not always possible to fully insure against such risks, and Almonty may decide not to take out insurance against certain risks due to high premiums or other reasons. Should such liabilities arise, they could reduce or eliminate any future profitability and result in an increase in costs and a decline in the value of Almonty’s securities.

While the Company maintains insurance coverage against various risks, including operational and environmental hazards, such coverage may not adequately protect against all potential liabilities. Certain risks, including rock bursts, slides, fires, earthquakes or other adverse environmental occurrences, industrial accidents, labour disputes, political and social instability, technical difficulties due to unusual or unexpected geological formations, failures of pit walls, shafts, head frames, and/or underground workings, flooding and periodic interruptions due to inclement or hazardous weather conditions, and geopolitical events, may not be fully insurable (if at all) or may result in coverage limits being exceeded. In these circumstances, the Company may incur significant costs that could have a material adverse effect on its financial performance and results of operations. Financial assurances may also be required with respect to closure and rehabilitation costs, may increase significantly over time and reserved amounts may not be sufficient to address actual obligations at the time of decommissioning and rehabilitation. Insurance against certain risks may not be available to Almonty at reasonable economic rates or at all. To the extent that Almonty is subject to liabilities that are not economically or otherwise insurable, the payment of such liabilities would reduce the funds available to Almonty.

Legal Systems

As civil law jurisdictions, Korea, Spain, and Portugal have legal systems which are different from the common law jurisdictions of Canada, Australia, and the United States. Standard legal practices in civil law jurisdictions may result in risks such as (i) a higher degree of discretion on the part of governmental authorities; (ii) the lack of judicial or administrative guidance on interpreting applicable rules and regulations, particularly where those rules and regulations are the result of recent legislative changes or have been recently adopted; (iii) inconsistencies or conflicts between and within various laws, regulations, decrees, orders and resolutions; and (iv) relative inexperience of the judiciary and courts in such matters. In the case of foreign entities such as the Company doing business in civil law jurisdictions, effective legal redress in the courts of such jurisdictions, whether in respect of a breach of law or regulation or in an ownership dispute, may be more difficult to obtain. Additionally, legislation and regulations may be susceptible to revision or cancellation and legal redress may be uncertain or delayed. There can be no assurance that joint ventures, licenses, license applications or other legal arrangements will not be adversely affected by changes in governments, the actions of government authorities or others, or the effectiveness and enforcement of such arrangements.

Reserve and Resource Depletion

The Company’s mineral reserves must be replaced to maintain production levels over the long-term. Mineral reserves can be replaced by expanding known ore bodies, locating new deposits or making acquisitions. Exploration is highly speculative in nature and identifying new ore bodies is difficult. The Company’s exploration projects involve many risks and may be unsuccessful. Mineral exploration and development involve substantial expenses and a high degree of risk, which even a combination of experience, knowledge and careful evaluation may not be able to adequately mitigate. There is no assurance that additional commercial quantities of ore will be discovered on any of the Company’s properties. There is also no assurance that, even if commercial quantities of ore are discovered, a mineral property will be brought into commercial production. The discovery of mineral deposits is dependent upon a number of factors, not the least of which is the technical skill of the exploration personnel involved. The commercial viability of a mineral deposit, once discovered, is also dependent upon a number of factors, some of which are the particular attributes of the deposit, such as size, grade and proximity to infrastructure, metal prices and government regulations, including regulations relating to royalties, allowable production, importing and exporting of minerals, and environmental protection.

In addition, assuming the discovery of a commercial ore body, depending on the type of mining operation involved, it may take a substantial amount of time from the initial phases of drilling until production is possible, during which time the economic feasibility of production may change. Substantial expenditures are required to establish proven and probable mineral reserves. As a result, there is no assurance that current or future exploration programs will be successful or that new commercially viable deposits or extensions of deposits will be discovered or developed. Depletion of mineral reserves may not be offset by discoveries or acquisitions and divestitures of assets may lead to lower mineral reserves. Reserves estimated in accordance with NI 43-101 may also decrease due to economic factors such as the use of lower metal price assumptions or increased costs assumptions. The Company’s future profitability may be affected if mineral reserves are mined without adequate replacement and the Company may not be able to sustain production to or beyond the currently contemplated mine lives based on current production rates.

Risks Related to Underground Stope Stability

The stability of underground stopes is a critical factor in ensuring the safety and efficiency of mining operations. Stope collapses or ground failures could lead to operational delays, equipment damage, safety hazards, or loss of access to ore bodies. Factors such as unexpected geological conditions, inadequate ground support systems, or seismic activity may increase the risk of collapse. The occurrence of such events could result in significant operational disruptions and financial losses.

Reputational Risk

Damage to the Company’s reputation can be the result of its actual or perceived actions or inactions and a variety of events and circumstances, and could result in negative publicity, whether or not true. Occurrences that may have an adverse effect on the Company’s reputation include the Company’s handling of matters relating to the environment (including tailings and tailings failures), employee relations, mine safety and security and dealings with local community organizations or individuals.

The Company may not be able to resolve such matters before they become public knowledge or become the subject of legal or regulatory proceedings. The growing use of social media to generate, publish and discuss community news and issues and to connect with others has made it significantly easier, among other things, for individuals and groups to share their opinions of the Company and its activities, whether true or not. The Company does not have direct control over how it is perceived by others. In the future, certain matters may affect the Company’s reputation in the view of its stakeholders. Such matters, once publicized, may negatively affect the Company’s reputation. Any damage to the Company’s reputation could result in, among other things, a decrease in the trading price of the common shares, decreased investor confidence, challenges in maintaining positive relationships with the communities in which it operates and other important stakeholders, and increased risks in obtaining permits, financing or social license for the Company’s operations, any of which could have a material adverse effect on the Company’s earnings, cash flows, financial condition or results of operations.

Geopolitical Risks in Key Operating Regions

The Company’s operations are subject to political and geopolitical risks that could adversely affect its business, financial condition, and results of operations. These risks include changes in government policies, political instability, civil unrest, trade restrictions, expropriation, and the outbreak of war or other hostilities in the regions where the Company operates, including South Korea, Spain, and Portugal and are beyond the Company’s control and may adversely affect the Company’s operations. Additionally, shifts in political attitudes or changes in mining or investment policies in these regions could impact the Company’s profitability and ability to meet its strategic objectives. This could include disruptions to supply chains, regulatory challenges, or increased costs. In particular, relations between South Korea and North Korea have been tense throughout Korea’s modern history. The level of tension between North and South Korea has fluctuated and may increase or change abruptly because of current and future events. In recent years, there have been heightened security concerns stemming from North Korea’s nuclear weapons and long-range missile programs and increased uncertainty regarding North Korea’s actions, particularly considering the recent leadership change, and possible responses from the international community. Tensions have escalated on the Korean peninsula, and there can be no assurance that the level of tension will not escalate further in the future. Any further increase in tensions, which may occur, for example, if military hostilities occur or North Korea experiences a leadership or economic crisis, could lead to infrastructure disruptions and workforce mobility constraints in addition to security escalations, any of which could have a material adverse effect on the Company’s operations, including with respect to construction, commissioning and ramp-up of the Company’s mineral projects in South Korea, and the market value of its common shares.

Furthermore, there can be no assurance that the political and economic policies of neighbouring countries, including China, Russia and North Korea, in relation to South Korea, will not have adverse economic effects on the development of the Company’s mining projects, including its ability to access power, transport (including across borders) and sell its products and access construction labour, supplies and materials.

Failure to comply strictly with applicable laws, regulations, and local practices relating to mineral rights applications and tenure could also result in substantial fines, loss, reduction, or expropriation of entitlements. While the Company operates in politically stable regions, the mining industry is inherently exposed to these risks, which could impact profitability or delay projects.

Public Allegations, Regulatory Investigations or Litigation

The Company at one time conducted exploration and mining operations in a number of jurisdictions and, as a result of such activities and operations or current or future activities and operations, may be subject to governmental or regulatory investigations and claims in or regarding those jurisdictions, including jurisdictions in which it is not currently active. A serious allegation, formal investigation by regulatory authorities or other legal claim (in each case, regardless of the ultimate decision) could have a material adverse impact on the Company, its reputation and its share price.

All industries, including the mining industry, are subject to legal claims, with and without merit. The Company has in the past and may in the future be involved in various legal proceedings. The causes of potential future litigation cannot be known and may arise from, among other things, business activities, environmental laws, volatility in stock price or failure or alleged failure to comply with disclosure obligations. The Company may be required to defend against any such public allegations, regulatory investigations or other claims that are asserted against it, or may deem it necessary or advisable to initiate legal proceedings to protect its rights. The expense and distraction of any such public allegations, regulatory investigations or other claims or proceedings, even with respect to claims that have no merit and whether or not resolved in the Company’s favour, could materially and adversely affect its business, operating results, and financial condition. There may also be considerable cost and disruption in responding to allegations, investigations or claims and taking any remedial action. Further, if an investigation, claim or proceeding were resolved against the Company or if it were to settle any such dispute, the Company may be required to pay damages and costs or refrain from certain activities, any of which could have a material adverse impact on the Company’s business, operating results, and financial condition.

The results of litigation cannot be predicted with certainty. While the Company is not aware of any possible legal proceedings that could have a material adverse effect on its financial position, future cash flow or results of operations of the Company. If the Company cannot resolve disputes favourably, or if there is significant reputational damage as a result of any real or frivolous claim, the Company may face increased costs or liabilities to third parties, impairment of assets, lost revenues and the Company’s activities and operations, financial condition, results of operations, future prospects and share price may be adversely affected.

Capital-Market Structure and Dilution Risk

The Company’s capital structure includes a number of outstanding warrants, stock options, RSUs, convertible instruments and shares represented by CDIs across multiple jurisdictions. The exercise or conversion of these securities, or any future equity or equity financing, may result in material dilution to existing shareholders. In addition, such financings or conversions could contribute to increased share-price volatility, reduced trading liquidity, or a perceived or actual overhang in the market for the Company’s shares. There can be no assurance that the Company will be able to raise additional capital on acceptable terms or that the market will absorb future issuances without adverse impact on the trading price of the Company’s shares.

Environmental and Global Climate Change Risks

Almonty’s operations are subject to numerous environmental laws and regulations, all of which can impose substantial costs and liabilities on the Company. Violations of environmental requirements or permits may result in fines, sanctions, orders to install pollution control equipment, or even suspension of operations. These regulations, often mandating standards for waste disposal, emissions, and land reclamation, can increase operational costs and complexity. Frequent amendments or new legislation may adversely affect the Company’s operations, financial condition, or competitive position. The Company may face costly claims and lawsuits by authorities and third parties relating to environmental matters.

Additionally, the potential impacts of global climate change amplify many of these environmental risks. Various governments have adopted or are considering regulations to mitigate climate change. These regulations may impose stricter emission limits, carbon taxes, or other measures that could require Almonty to incur substantial additional costs. The resulting increase in expenditures for pollution control, monitoring systems, and compliance reporting could harm the Company’s cost competitiveness. Inconsistent regulatory frameworks may complicate compliance efforts and impact the Company’s financial performance.

Heightened public awareness of climate change may generate more intense scrutiny of Almonty’s activities. Even in the absence of formal mandates, stakeholders such as investors, customers, and local communities may expect the Company to demonstrate robust sustainability practices. Failure to meet expectations or negative publicity could harm the Company’s reputation, limit financing, or reduce marketability. Physical effects of climate change, such as extreme weather, changing rainfall, water shortages, or wildfires, could disrupt operations, damage equipment, and introduce safety risks. Geographical vulnerabilities at each site compound these uncertainties and may require adaptation measures. Costs for insurance, repairs, shutdowns, and slower production cycles could increase, eroding earnings and investor confidence.

These environmental and climate-related uncertainties, regulations, and compliance efforts could negatively impact the Company’s production, operating results, and financial condition. Evolving environmental obligations and climate change challenges may require Almonty to revise strategies, allocate resources to compliance, and adopt new technologies. Inability to anticipate or respond to changes, obtain regulatory approvals, or maintain community support could affect Almonty’s access to resources, output levels, and long-term competitiveness.

Costs of Land Reclamation

Reclamation is the responsibility of the mine operator and in some cases the Company is responsible for early-stage exploration reclamation. Given the Company’s mix of producing, developing, and care-and-maintenance assets in multiple jurisdictions, it is difficult to determine the exact amounts which will be required to complete all land reclamation activities in connection with the properties in which the Company holds an interest. Reclamation bonds and other forms of financial assurance represent only a portion of the total amount of money that will be spent on reclamation activities over the life of a mine. Accordingly, it may be necessary to revise planned expenditures and operating plans in order to fund reclamation activities. Such revisions could be required on a site-specific basis, particularly where operational plans or mine life estimates are modified. Such costs may have a material adverse impact upon the financial condition and results of operations of the Company.

Technological Obsolescence

The Company’s ability to remain competitive depends on the adoption of advanced mining and processing technologies. Failure to innovate or integrate new technologies could lead to inefficiencies, higher costs, and diminished competitiveness. The capital-intensive nature of technological upgrades poses additional financial risks, especially if investments do not yield the expected returns.

Management of Growth

Almonty may be subject to growth-related risks including capacity constraints and pressure on its internal systems and controls. The ability of Almonty to manage growth effectively will require it to continue to implement and improve its operational and financial systems and to expand, train and manage its employee base. The inability of Almonty to deal with this growth could have a material adverse effect on its business, operations and prospects.

Cybersecurity and Data Protection

The Company relies on its information technology systems, including its networks, equipment, hardware, software, telecommunications and other information technology (collectively, “IT Systems”), and the IT Systems of its vendors and third-party service providers, to operate its business. IT Systems are subject to an increasing threat of risks from sources including computer viruses, cyber-attacks, ransomware, malware, security breaches, power loss, system disruptions, natural disasters, defects in design and other manipulation or improper use. These risks are evolving as IT Systems and cybersecurity attacks or breaches become more sophisticated and prevalent. These cyber-attacks are also becoming increasingly sophisticated through the use of artificial intelligence and machine learning tools and tactics and are often well-funded, including in some cases by state sponsors. These disruptions may also occur for non-malicious reasons, such as the widespread server-related outages. Any of these occurrences may result in, among other things, unauthorized access or damage to, or temporary or permanent disruption or failure of, one or more of the Company’s IT Systems (collectively, “IT Disruptions”).

The Company’s operations depend on the timely maintenance, upgrade and replacement of its IT Systems, as well as expenditures to mitigate cybersecurity risks and the possibility of IT Disruptions. Increasingly, the operating and control systems at the Company’s mines and projects rely on IT Systems to monitor and optimize performance, as the Company continues to adopt remotely controlled mining techniques and electrify its equipment. The Company’s financial control and accounting systems depend on its IT Systems and its workforce increasingly works remotely, which has further increased the Company’s reliance on its IT Systems and associated risks. Adoption of new technology that promotes operational efficiency, such as the use of artificial intelligence, fleet electrification and autonomous vehicles, may further expose the Company’s IT Systems to risk. As the Company’s use of IT Systems increases and evolves and cybersecurity attacks become more sophisticated or pervasive, the Company may have to incur significant costs to upgrade its IT Systems to protect against IT Disruptions. New or improved IT Systems that the Company procures may have defects, not be installed properly or not integrate with its other IT Systems.

Third-party vendors and service providers (including information technology service providers) may themselves be victims of IT Disruptions which may have an adverse consequential impact on the Company and its operations. For example, in July 2024, many companies experienced significant operational issues as a result of server-related outages caused by CrowdStrike’s defective software update.

The occurrence of one or more IT Disruptions could have effects, including damage to the Company’s equipment, including mining equipment, production downtimes, operational delays, loss or corruption of data, compromise of confidential or otherwise protected information, delay in the delivery of supplies and services, increased health and safety risks, increases in capital expenditures, loss of production, accidental discharge of regulated materials, expensive remediation efforts, distraction of management, damage to the Company’s reputation and events of non-compliance, which could lead to regulatory fines or penalties, or ransom payments. Any of the foregoing could have a material adverse effect on the Company’s results of operations and financial performance. There can be no assurance that the Company will not incur losses related to IT Disruptions in the future.

Opposition to Mining

Almonty’s business may be affected by environmental activists who engage in activities intended to disrupt Almonty’s business operations. As a result, there could be delays or losses in transportation and deliveries of minerals to Almonty’s customers, decreased sales of Almonty’s minerals and extension of time for payment of accounts receivable from Almonty’s customers, which could have a material adverse effect on Almonty’s business, financial condition and results of operations.

Costs and Compliance Risks as a Result of Being a Public Company

Legal, accounting and other expenses associated with public company reporting requirements have increased significantly in the past few years. Almonty anticipates that general and administrative costs associated with regulatory compliance will continue to increase with recently adopted or amended corporate governance requirements. The additional demands associated with being a public company may also disrupt regular operations of the Company’s business by diverting the attention of some of its senior management team away from revenue-producing activities to management and administrative oversight, adversely affecting the Company’s ability to attract and complete business opportunities and increasing the difficulty in both retaining professionals and managing and growing the Company’s businesses. In addition, failure to comply with any laws or regulations applicable to the Company as a public company may result in legal proceedings and/or regulatory investigations, and may cause reputational damage. Any of these effects could harm the Company’s business, financial condition and results of operations.

As a public company, particularly after the Company is no longer an “emerging growth company” as defined under the JOBS Act, the Company will incur significant legal, accounting and other expenses that the Company did not incur prior to being listed in the United States. In addition, the Sarbanes-Oxley Act, and rules implemented by the Securities and Exchange Commission and the Nasdaq, impose various other requirements on public companies, and the Company will need to spend time and resources to ensure compliance with reporting obligations under Canadian securities laws, Australian securities laws, as well as obligations in the U.S.

Acquisitions and Synergies

The Company actively considers the acquisition of exploration, development and production assets in a manner that is consistent with its acquisition and growth strategy. From time to time, it may also acquire securities of, or other interests in, companies with respect to which it may enter into acquisitions or other transactions. Acquisition transactions involve inherent risks, including:

Any one or more of these factors or other risks could cause the Company not to realize the benefits anticipated to result from the acquisition of properties or companies and could have a material adverse effect on its ability to grow and on its financial condition.

An important factor in the success of an acquisition is the ability of the acquirer’s management in managing the Company’s business and that of the acquired company and, if appropriate, integrating all or part of that company’s business with that of the acquirer. The integration of two businesses can result in unanticipated operational problems and interruptions, expenses and liabilities, the diversion of management attention and the loss of key employees and their knowledge.

There can be no assurance that a business integration will be successful or that it will not adversely affect the business, results of operations, financial condition or operating results of the acquirer and, as a result, the price of the Company’s publicly traded securities. In addition, the Company may incur charges related to the acquisition of the acquired company and related to integrating the two companies. There can be no assurance that the Company, in the case of its recent acquisitions, will not incur additional material charges in the future to reflect additional costs associated with the acquisition or that all of the benefits expected from the acquisitions will be realized.

While the Company continues to seek acquisition opportunities consistent with its acquisition and growth strategy, it cannot be certain that it will be able to identify additional suitable acquisition candidates available for sale at reasonable prices, to consummate any acquisition or to integrate any acquired business into its operations successfully. Acquisitions may involve a number of special risks, circumstances or legal liabilities. These and other risks related to acquiring and to operating acquired properties and companies could have a material adverse effect on results of operations and financial condition. In addition, to acquire properties and companies, the Company may need to use available cash, incur debt, and issue common shares or other securities, or a combination of any one or more of these. This could limit its flexibility to raise capital, to operate, explore and develop its properties and to make additional acquisitions, and could further dilute and decrease the trading price of the common shares. When evaluating an acquisition opportunity, the Company cannot be certain that it will have correctly identified and managed the risks and costs inherent in the business that it is acquiring.

While at the present time the Company has no binding agreements, it is actively considering potential acquisitions. The Company can provide no assurance that any potential transaction will be successfully completed, and, if completed, that the business acquired will be successfully integrated into its operations. The Company also cannot provide any assurance that if it issues equity securities in connection with an acquisition, such issuance will not be dilutive. If the Company fails to manage its acquisition and growth strategy successfully, it could have a material adverse effect on its business, results of operations and financial condition.

Anti-Corruption and Anti-Bribery Laws

The Company’s operations are governed by, and involve interactions with, various levels of government in numerous countries. The Company is required to comply with anti-corruption, anti-bribery and sanctions laws, including the Corruption of Foreign Public Officials Act (Canada), the Criminal Code Act (Australia) and Corporations Act (Australia) and the United States’ Foreign Corrupt Practices Act, as well as similar laws in the countries in which the Company or its contractual counterparties conduct their business. There has been a general increase in the frequency of enforcement and the severity of penalties under such laws, resulting in greater scrutiny and punishment of companies convicted of violating these laws. The Company may be found liable for violations by not only its employees, but also by its third-party agents. Measures that the Company has adopted in attempt to mitigate these risks may not be effective in ensuring that the Company, its employees or third-party agents will comply strictly with such laws. If the Company is subject to an enforcement action or is found to be in violation of such laws, this may result in significant penalties, fines and/or sanctions imposed on the Company which could result in a material adverse effect on the Company’s reputation, financial performance and results of operations. If the Company chooses to operate in additional foreign jurisdictions in the future, it may become subject to additional anti-corruption, anti-bribery and sanctions laws in such jurisdictions.

Canada’s Extractive Sector Transparency Measures Act

The Extractive Sector Transparency Measures Act (Canada) (“ESTMA”) requires public disclosure of certain payments to governments by companies engaged in the commercial development of minerals which are publicly listed in Canada. Mandatory annual reporting is required for extractive companies with respect to payments made to foreign and domestic governments, including aboriginal groups. ESTMA requires reporting on the payments of any taxes, royalties, fees, production entitlements, bonuses, dividends, infrastructure reporting or structuring payments to avoid reporting. If the Company becomes subject to an enforcement action or is in violation of ESTMA, this may result in significant penalties or sanctions which may also have a material adverse effect on the Company’s reputation.

Health and Pandemic Risks

Global health crises, such as pandemics or epidemics, can disrupt the Company’s operations by impacting employee availability, supply chains, and demand for end products. Restrictions on movement, mandatory quarantines, or other government-imposed measures may delay project timelines, increase costs, or limit access to critical infrastructure. Additionally, health crises could expose the Company to unforeseen liabilities or require additional expenditures to ensure workplace safety.

In addition, the actual or threatened spread of a pandemic or other health emergency globally, and responses of governments and others to such actual or threatened consequences, could also have a material adverse effect on the global economy, could negatively affect financial markets, including the price of tungsten and the trading price of the Company’s common shares, could adversely affect the Company’s ability to raise capital, and could cause interest rate volatility and movements that could make obtaining financing or refinancing debt obligations more challenging or more expensive. If the price of tungsten declines, the Company’s revenues from its operations will also decline. Any of these developments, and others, could have a material adverse effect on the Company’s business and results of operations.

Risks Related to the U.S. Domestication

As disclosed previously, Almonty announced the U.S. Domestication. There are certain risks related to such redomiciling and the arrangement pursuant to which the redomiciling will be accomplished (the “Arrangement”).

Disruptions to the Company’s Business

If the Company effects the U.S. Domestication, the Company anticipates significant increases in legal, accounting and other expenses. Such redomiciling may require a significant amount of time, cost and focus from management and other employees, which may divert attention from the Company’s commercial activities. In addition to shareholder approval, such redomiciling will require approval by the Nasdaq. As a U.S. public company, the Company would no longer be able to take advantage of Canadian rules and would be subject to additional governance and disclosure requirements, including Nasdaq requirements and the reporting requirements of the Exchange Act and the Sarbanes-Oxley Act. If any reincorporation activities that the Company undertakes in the future fail to achieve some or all of the expected benefits therefrom, the Company’s business, results of operations and financial condition could be materially and adversely affected.

Canadian Corporate Tax Risk

For Canadian tax purposes, on the date of the Arrangement the Company will be deemed to have a year end and to have disposed of all of the Company’s property for proceeds equal to the fair market value of that property. The Company will also be subject to an additional corporate emigration tax imposed on the amount, if any, by which the fair market value of the Company’s property, net of certain liabilities, exceeds the paid-up capital of the Company’s issued and outstanding common shares.

The quantum of tax payable, if any, by the Company upon the Arrangement will depend upon a number of considerations including whether the Company reorganizes and/or winds up one or more of its subsidiaries prior to the Arrangement becoming effective, the valuation of the Company’s assets, the amount of its liabilities, its shareholder composition, as well as certain Canadian tax amounts, accounts and balances of the Company, each as of the time of the Arrangement. There could be material adverse tax consequences that result from the Arrangement or the transactions completed in relation to the Arrangement in Canada. In addition, it is possible that following the Arrangement, the Canada Revenue Agency may disagree with the Company’s determination of the fair market value of its properties at the relevant time and/or the Company’s determination of any of its tax accounts or tax attributes. As a result, the quantum of Canadian tax payable by the Company may materially exceed the Company’s estimates at that time. Any such adverse tax consequences could materially adversely affect the Company and its share price. For additional information on the Canadian federal income tax consequences of the Arrangement, see the section entitled “Certain Canadian Federal Income Tax Considerations Related To The Arrangement” of the management information circular of the Company dated January 31, 2025 and filed on February 4, 2025, prepared for the purposes of the special meeting of the shareholders of the Company held on February 27, 2025.

MINERAL PROJECTS

The general characteristics of the Sangdong Mine are summarized in Schedule A of this AIF and are further detailed in the Technical Report (as defined in Schedule A of this AIF). Scientific and technical information contained in this AIF relating to the Sangdong Mine and the Technical Report is based upon information prepared by or under the supervision of, or approved by, Adam Wheeler, B.Sc., M.Sc., C. Eng. (the “Qualified Person”), a “qualified person” within the meaning of NI 43-101, and such scientific and technical information is included in this AIF with the consent of the Qualified Person.

After reassessing its mineral projects in light of its current business strategy, the Company has determined that the Sangdong Mine is currently its only material mineral project for the purposes of NI 43-101. This mineral project is currently the main focus of the Company and the Company anticipates it will devote the majority of its resources on the development of this property in the coming years.

The Company is also involved in the operation and development of smaller mineral projects. See “Mineral Projects—Other Mineral Projects” in Schedule A of this AIF.

DIVIDENDS

The Company has not paid any dividends on the Common Shares for the past three most recently completed fiscal years. Any future determination to pay dividends will be at the discretion of the Board and will depend upon the Company’s results of operations, capital requirements and other relevant factors.

DESCRIPTION OF CAPITAL STRUCTURE

Almonty is authorized to issue an unlimited number of Common Shares without par value. Holders of the Common Shares are entitled to receive notice of and to attend all meetings of the shareholders of the Company. Each Common Share carries one vote. In the event of the liquidation, dissolution or winding up of the Company, whether voluntary or involuntary, or any other distribution of its assets among its shareholders for the purpose of winding up its affairs, the holders of the Common Shares are entitled to receive the remaining property and assets of the Company on a pro rata basis. The shareholders are entitled to receive pro rata such dividends as may be declared by the Board out of funds legally available for such purpose.

As of the date of this AIF, the Company had 281,938,231 Common Shares issued and outstanding.

Additionally, as of the date of this AIF, the Company has outstanding 1,196,702 warrants to acquire Common Shares (“Warrants”), 184,812 CDI options to acquire Common Shares (“CDI Options”), 6,997,979 stock options (“Options”) and 3,317,329 restricted share units (“RSUs”).

There are also 5,666,075 Common Shares issuable upon the exercise of the Company’s convertible debentures as of the date of this AIF at a weighted average exercise price of $1.85 per Common Share.

MARKET FOR SECURITIES

Trading Volume and Price

The following table sets forth the high and low sale prices and volumes traded on the TSX as reported by such exchange for the fiscal year ended December 31, 2025:

⁽¹⁾ As adjusted figures are adjusted to reflect the Share Consolidation.

⁽²⁾ Reflects trading of the Common Shares on a post-consolidation basis.

Prior Sales

The following table summarizes details of the securities (other than Common Shares or CDIs) issued by the Company during the fiscal year ended December 31, 2025:

⁽¹⁾ As adjusted figures are adjusted to reflect the Share Consolidation.

DIRECTORS AND OFFICERS

Names, Occupations and Security Holdings

The following table sets out, as at the date of this AIF, for each of the directors and executive officers of the Company, the person’s name, province and country of residence, their respective positions and offices held, the date on which the person became a director, his or her principal occupation and previously held positions for the last five years, and the number and percentage of Common Shares beneficially owned, controlled or directed, directly or indirectly, on a non-diluted basis (based on information furnished by the directors and executive officers and from insider reports available under the Company’s System for Electronic Disclosure by Insiders (SEDI) at www.sedi.ca).

Name, residence, office(s) held, committee(s) and date first became a director or officer		Current principal occupation, business or employment and for last five years, and education		Shares beneficially owned, or controlled or directed, directly or indirectly
Gustave F. Perna Crane Hill, Alabama, USA Director Director since March 20, 2025		General Perna retired from the United States Army in July 2021 as the Chief Operating Officer of Operation Warp Speed, the U.S. national initiative focused on the rapid research, development, production and distribution of vaccines and therapeutics to combat COVID-19. From 2016 to 2020, General Perna served as Commander of the U.S. Army Materiel Command (AMC), comprising over 190,000 soldiers, civilians, and contractors. General Perna has held several high-ranking positions during his military career, including serving as Deputy Chief of Staff, G-4 (SVP for Logistics) for the Department of the Army (2014–2016), Commanding General (CEO) of the Joint Munitions Command (2010–2012), and Director, J-4, United States Forces – Iraq (2009–2010), overseeing multinational logistics during Operation Iraqi Freedom/New Dawn. He also led as Commanding General (CEO) of the Defense Supply Center – Philadelphia within the Defense Logistics Agency (2008–2009). General Perna holds an Associate degree in Business Administration from Valley Forge Military Academy and a Bachelors degree in business management from the University of Maryland and was awarded a Master’s degree in Logistics Management from the Florida Institute of Technology.		15,793
Alan Estevez Bethesda, Maryland, USA Director Director since May 30, 2025		Mr. Estevez served as Under Secretary of Commerce for Industry and Security from 2022 to 2025, overseeing U.S. export controls and implementation of national security-related trade measures. From 2013 to 2017, he held the position of Principal Deputy Under Secretary of Defense for Acquisition, Technology and Logistics, following his 2011–2013 tenure as Assistant Secretary of Defense for Logistics and Materiel Readiness—the first career civilian to hold that role. Earlier in his career, Mr. Estevez held multiple leadership roles at the U.S. Department of Defense and Army, focusing on acquisition, supply chain, and logistics operations. He later served as a national security and logistics advisor at Deloitte. Mr. Estevez holds a B.A. in Political Science from Rutgers University and an M.S. in National Resource Strategy from the National Defense University. His public service has been recognized with numerous honors, including three DoD Distinguished Public Service Medals, the Presidential Rank Award, and the Service to America Medal.		5,812

Notes:

Each of Almonty’s directors hold office until the end of the next annual meeting of shareholders or until his successor is duly elected or appointed, unless his office earlier becomes vacant by resignation, death, removal or other cause.

Director and Executive Officer Aggregate Ownership of Common Shares

Our directors and executive officers, as a group, beneficially own, or control, or direct, directly or indirectly, a total of 29,876,648 Common Shares, representing 10.60% of the total outstanding Common Shares as of the date of this AIF, on a non-diluted basis.

Cease Trade Orders, Bankruptcies, Penalties and Sanctions

No director or executive officer of the Company is, as at the date of this AIF, or was within 10 years before the date of this AIF, a director, chief executive officer or chief financial officer of any company (including the Company), that:

No director or executive officer of the Company, or shareholder of the Company holding a sufficient number of securities of the Company to affect materially the control of the Company:

AUDIT COMMITTEE

Audit Committee Charter

The audit committee of the Board (the “Audit Committee”) operates under a written charter that outlines its role and objectives, composition, meeting requirements, and duties and responsibilities. The full text of the charter is set out in Schedule B of this AIF.

Composition of the Audit Committee

The Audit Committee is currently comprised of Mark Trachuk (Chair), Dr. Thomas Gutschlag and Andrew Frazer, all of whom are considered independent as such term is defined in National Instrument 52-110 – Audit Committees (“NI 52-110”).

Relevant Education and Experience

All three current members of the Audit Committee are “financially literate”, as that term is defined in NI 52-110. Each has the ability to read and understand financial statements that present a breadth and level of complexity of accounting issues that are generally comparable to the breadth and complexity of issues that can reasonably be expected to be raised by the Company’s financial statements.

For a description regarding the relevant education and experience of Mr. Trachuk, Dr. Gutschlag and Andrew Frazer, see the table under “Directors and Officers – Name, Occupation and Security Holdings”, above.

As a result of their education and experience, each current member of the Audit Committee has the education or experience necessary to provide each with:

Pre-Approval Policies and Procedures

The Audit Committee’s charter requires it to pre-approve all non-audit services to be provided to the Company by its external auditors. However, the Audit Committee has not adopted any specific procedures for assessing whether or not such pre-approval should be granted in any particular case. The Audit Committee does, however, consider on an ad hoc basis the potential impact of any such non-audit services on the independence of the Company’s external auditors in light of the circumstances as they exist at that time.

External Auditor’s Fees

As set out in the Audit Committee’s charter (attached as Schedule B to this AIF), the Audit Committee is responsible for pre-approving all non-audit services to be provided to the Company by its external auditor and has pre-approved the non-audit services as set out below.

The table below sets out the aggregate fees billed by the Company’s external auditors for the fiscal year ended December 31, 2025:

CONFLICTS OF INTEREST

Certain directors and officers of the Company are, and may continue to be, involved in the mining and mineral business through their direct and indirect participation in corporations, partnerships, or joint ventures, which are potential competitors of the Company. Situations may arise in connection with potential acquisitions in investments where the other interests of these directors and officers may conflict with the interests of the Company. Directors and officers of the Company with conflicts of interest will be subject to and will follow the procedures set out in applicable corporate and securities legislation, regulations, rules and policies.

LEGAL PROCEEDINGS

The Company is involved in certain claims and litigation arising out of the ordinary course and conduct of business. Management assesses such claims and, if considered likely to result in a loss and, when the amount of the loss is quantifiable, provisions for loss are made, based on management’s assessment of the most likely outcome. Management does not provide claims for which the outcome is not determinable or claims where the amount of the loss cannot be reasonably estimated. Any settlements or awards under such claims are provided for when reasonably determinable. The Company is not currently a party to, or has any of its property as the subject of, legal proceedings which would be material to the Company’s financial condition or results of operations.

INTERESTS OF MANAGEMENT AND OTHERS IN MATERIAL TRANSACTIONS

Except as noted below, no director or executive officer of the Company, person or company that beneficially owns or controls or directs, directly or indirectly, more than 10% of the Common Shares, or associate or affiliate of any of such persons or companies had any material interest, direct or indirect, in any transaction within the three most recently completed fiscal years or during the current fiscal year that has materially affected or is reasonably expected to materially affect the Company other than the following:

During the financial year ended December 31, 2024:

During the financial year ended December 31, 2023:

TRANSFER AGENT AND REGISTRAR

The transfer agent and registrar for the Common Shares in Canada is Computershare Investor Services Inc. at its offices at 3^rd Floor – 510 Burrard Street, Vancouver, British Columbia, Canada, V6C 3B9, and in the United States is Computer Share Trust Company N.A. at its officers at 150 Royall Street, Canton, Massachusetts, United States, 02021.

MATERIAL CONTRACTS

The Company has entered into the following material contracts during the financial year ended December 31, 2025, or before such year but which remain in effect. All material contracts of the Company have been filed on the System for Electronic Data Analysis and Retrieval + (“SEDAR+”) and are available under the Company’s profile at www.sedarplus.ca.

Amended and Restated Supply Agreement

AKTC is party to the Amended and Restated Supply Agreement dated December 4, 2020 with GTP and Plansee. This agreement sets out the terms and conditions of the supply and delivery of tungsten concentrates from the Sangdong Mine by AKTC, as seller, to GTP, as purchaser. Subject to certain exceptions, the term of the agreement is 15 years from the date of first delivery of Scheelite mined and processed pursuant to the terms of the agreement (“Material”). The total contracted quantity of Material under the agreement is 3,150,000 MTU. For each month during the term of the agreement, AKTC may, subject to GTP’s right of last refusal (described below), sell tungsten-containing products from the Sangdong Mine to other parties after delivery of all applicable minimum volumes to GTP for such month. In the event that AKTC offers to sell Material or other tungsten-containing product to a third party at lower prices than the price then in effect with Buyer under the agreement, AKTC shall then offer such Material or other tungsten-containing product to GTP for purchase on the same terms.

Amendment and Restatement and Waiver Agreement (including the Amended and Restated Facility Agreement)

AKTC and Almonty are party to an Amendment and Restatement and Waiver Agreement (including the Amended and Restated Facility Agreement) dated June 30, 2022 with Plansee, KfW, and the Lenders party thereto from time to time. This agreement sets out the terms and conditions of the KfW Facility provided by KfW, the export and project finance arm of German state-owned KfW Group, which is backed by the Federal Republic of Germany. The loan bears interest at SOFR plus 2.3% and provides for principal repayment on a quarterly basis over a 6.25-year term.

2023 Amendment Agreement

ATKC is party to an Amendment Agreement dated October 16, 2023 with KfW and the Lenders party thereto from time to time, which amends the availability of the KfW Facility.

September 2024 Amendment Agreement

ATKC is party to an Amendment Agreement dated September 18, 2024 with KfW and the Lenders party thereto from time to time, which extends the availability period of the KfW Facility.

November 2024 Amendment Agreement

AKTC is party to an Amendment Agreement dated November 11, 2024 with KfW and the Lenders party thereto from time to time, which extends the availability period of the KfW Facility.

Molybdenum Offtake Agreement

Almonty is party to a Molybdenum Offtake Agreement dated January 21, 2025 with SeAH. The agreement is an offtake agreement with a floor price structure for the purchase of all of Almonty’s potential molybdenum production at the Sangdong Molybdenum Project. The term of the agreement is ongoing until exhaustion of molybdenum reserves at the Sangdong Molybdenum Project.

2025 Amendment Agreement

ATKC is party to an Amendment Agreement dated January 22, 2025 with KfW and the Lenders party thereto from time to time, which extends the availability period of the KfW Facility.

Offtake Agreement

BTW is party to an Offtake Agreement dated January 1, 2026 with Sumitomo Electric Industries, Ltd. for a significant percentage of the wolframite concentrate produced at the Panasqueira Mine. The term of the agreement is until December 31, 2026.

Contract for Tungsten Wolframite Concentrates

BTW is party to a Contract for Tungsten Wolframite Concentrates dated January 16, 2026 with Wolfram Bergbau und Hütten AG for a significant percentage of the tungsten produced at the Panasqueira Mine. The term of the agreement is until January 31, 2027.

2026 Amendment Agreement

ATKC is party to an Amendment Agreement dated January 22, 2026 with KfW and the Lenders party thereto from time to time, which extends the availability period of the KfW Facility.

INTERESTS OF EXPERTS

The audited annual consolidated financial statements of the Company for the fiscal years ended December 31, 2025 and December 31, 2024 filed under National Instrument 51-102 – Continuous Disclosure Obligations have been audited by Zeifmans LLP.

The auditors of the Company, Zeifmans LLP, report that they are independent of the Company in accordance with the rules of professional conduct under the professional standards of the Institute of Chartered Professional Accountants of Ontario.

The Technical Report (as defined in Schedule A of this AIF) was prepared by Adam Wheeler, a “qualified person” within the meaning of NI 43-101. Mr. Wheeler does not own any securities of the Company nor does he otherwise have any interest in the Company.

ADDITIONAL INFORMATION

Copies of this AIF and additional information and documentation relating to the Company may be found under the Company’s profile on SEDAR+ at www.sedarplus.ca.

Additional information regarding the Company’s directors’ and officers’ remuneration and indebtedness, principal holders of securities and securities authorized for issuance under equity compensation plans is contained in the Company’s management information circular dated March 21, 2025 and filed on SEDAR+ on March 26, 2025, prepared for the purposes of the annual general and special meeting of the shareholders of the Company held on April 30, 2025.

Additional financial information is available in the Company’s audited annual consolidated financial statements and MD&A for the fiscal years ended December 31, 2025 and December 31, 2024.

The information referred to in this AIF may also be obtained from www.almonty.com or by contacting:

Almonty Industries Inc.

100 King Street West, Suite 5700

Toronto, Ontario

M5X 1C7

Phone: (647) 438-9766

SCHEDULE A

Mineral PROJECTS

Sangdong Mine

Current Technical Report

The most recent technical report on the Sangdong Mine (the “Technical Report”) is entitled “NI 43-101 Technical Report on the Mineral Resources and Reserves of the Sangdong Project, South Korea”, dated June 23, 2025 and effective February 28, 2025, authored by the Qualified Person, a “qualified person” within the meaning of NI 43-101, and filed in accordance with NI 43-101. The Technical Report has been filed on SEDAR+ and can be accessed under the Company’s profile at www.sedarplus.ca.

All capitalized terms and measurement abbreviations used but not otherwise defined in the summary of the Sangdong Mine below have the meanings given to them in the Technical Report. All references to tables and figures under the heading “Sangdong Mine” are to tables and figures in the Technical Report.

Project Description, Location and Access

The Sangdong Mine is located at Sangdong in the south-eastern Korean Peninsula, approximately 170 km east-southeast of Seoul, the capital city of South Korea, 25 km south-west of Taebaek and 55 km south-east of Wonju, in Yeongwol County, Kangwon-Do Province on the eastern side of South Korea (37°08’N latitude and 128°50’E longitude), as shown in Figures 4-1 and 4-2 below. The main adit of the Sangdong Mine is at the head of a short, south-flowing tributary of the Oktong-ch’on river. Sangdong is a small rural village with a population of approximately 600 situated 2 km to the south of the Sangdong Mine.

Figure 4-1 – Sangdong Project Location Map

Figure 4-2 – Sangdong Mine Area

Sangdong is easily reached by paved roads from all directions and is a 3.5-hour drive from Seoul. The Sangdong Mine is well served by the Yeondong Expressway 50 from Seoul, the Jungang Expressway 55 from Wonju, Highway 38 from Jechon to Yeongwol then Highway 31 to Sangdong. A bus journey from Dong Seoul Bus Terminal typically takes 4 hours to Taebaek. Taebaek (population of over 50,000) is located approximately 25 km to the east of Sangdong by paved road and is an established coal mining town with most modern facilities, including good accommodation facilities and some mining equipment support.

The national rail network system services the region. The train journey takes 4.5 hours to Taebaek from Seoul Station. The closest railhead is situated at Yemi, 5 km north of Sangdong.

Access throughout the Sangdong Mine area is generally very good, with sealed roads forming a network throughout the district, together with numerous unsealed farm tracks up the river valleys.

Almonty owns a 100% indirect ownership interest in the Sangdong Mine through its subsidiaries. Almonty’s interest in the Sangdong Mine is held by AKTC, which owns a 100% direct interest in the Sangdong Mine. AKTC is a wholly-owned direct subsidiary of Woulfe Mining Corp. (“Woulfe”), itself a wholly-owned direct subsidiary of Almonty.

The Sangdong Mine comprises 12 mining rights with an aggregate area of 3,173 ha, held in the name of AKTC. The mining rights areas are shown in Figure 4-3 below and details of the licenses are indicated in Table 4-1 below.

Figure 4-3 – Sangdong Project: Mining Rights Areas

Table 4-1 – Sangdong Project – Mining Rights’ Details

Note:

* AKTC received a 20-year extension for License No. 74978 on May 13, 2025.

The existing exploration and mining permits cover all the active exploration and mining areas encompassing the Sangdong Mine. The exploration permits provide the right to carry out all contemplated exploration activities with no additional permitting required. Exploration permits are subject to exploration rights usage fees (a fixed annual charge) and applicable taxes. The mining permits give the right to carry out full mining and mineral processing operations in conjunction with safety and environmental certificates.

Approval for installation of mining facilities (Sangdong Portal, Woulfe Portal, Taebaek Portal, Baegun Portal and nearby quartzite mine) have been issued by East Mine Registration Office of the Ministry of Trade, Industry & Energy. Environmental certificates (Temporary Forest Land Use) have been issued by the Department of Environmental Forest of Yeongwol County.

Surface rights for mining purposes are not included in the Sangdong Mine’s permits, but AKTC have leased some of the land used for mining and processing plant activities by effecting payment of a purchase fee based on the appraised value of the land. The rest of the necessary lands for mining, waste disposal and processing plant activities (processing plant, offices and accommodations, etc.) were guaranteed by Yeongwol County, through written official documentation. The expiration date of the land leases for the site leased from Yeongwol County is December 31, 2028.

South Korea has an established Mining Industry Act which defines the mining rights guaranteed by the government of South Korea.

Except for relatively small areas in the south in the main river valley and a few small areas of vegetable farms, the Sangdong Mine is on government land. On government (i.e., non-private) land, an environmental security bond must be lodged. On private land, access must be negotiated with the individual landowner(s). In the case of mining, there is no formal mediated process for land disturbance, and the purchase or lease of the surface rights would have to be negotiated with the landowner(s).

There are no royalties, overrides, back-in rights, payments or other similar agreements or encumbrances to which the Sangdong Mine is subject.

South Korea applies a 10% value-added tax (“VAT”) on domestic sales of goods and services, including the sale of concentrates and imports. However, exports of concentrates are zero-rated for VAT purposes, meaning no VAT is charged and input VAT may be recoverable. The standard corporate income tax rate is 21%, with an additional local surtax of 10% on the national tax, resulting in a combined effective rate of approximately 23.1%. In addition, a 0.5% local resource and facility tax is levied on the value of mined minerals and paid to the local government. There is no VAT surtax on sales.

There are no significant factors or risks that might affect access or title to, or the right or ability to perform work on, the Sangdong Mine known at this time.

History

Earliest Operations (1916–1949)

Tungsten mineralization was discovered on the property comprising the Sangdong Mine in 1916 and mining took place at two locations: the Doyeop Mine and the Sungyeong Mine for several years, but then ceased. Tungsten grades at the Doyeop Mine averaged 3.3% WO₃ and ranged from 0.8% to 5.86% WO₃. Tungsten grades at the Sungyeong Mine averaged 7.55% WO₃ and ranged from 2.50% to 17.12% WO₃. Operations at both locations recommenced in 1933 and the main Sangdong deposit was discovered during the period 1939 to 1940. In 1941, the company Kobayashi Mining Corporation (“Kobayashi”) bought both mines and integrated operations into the overall Sangdong Mine. The Sungyeong Mine owners, in order of succession, were Ogama Fusajiro, Kondo Shinjiro, Shibuya Yoshihide and then Kobayashi. Apart from acquiring the Doyeop Mine and the Sungyeong Mine, Kobayashi also expanded the mining rights area for the Sangdong Mine to include tungsten, bismuth and molybdenite. The smelting plant for Kobayashi was in Seoul.

The Sangdong Mine was operated during the Second World War by Sorim Resources Co. and, during the period 1946 to 1949, under the jurisdiction of the United States military government office. With the end of the Second World War in 1945, all property owned by Japanese nationals in Korea was taken over by the United States Army Military Government in Korea (“USAMGIK”), including Kobayashi’s mines. Along with 5–6 Japanese employees, Kobayashi’s president stayed for some time as an advisor to USAMGIK for tungsten mining development, but soon returned to Japan in October 1945.

In 1946, the U.S. Army restarted the tungsten mining operations for export to the United States. In 1947, Korea’s tungsten ore was exported for the first time to the world market, branded with the name of the Republic of Korea. The tungsten concentrate was first exported through exchanges between the Korean and U.S. governments.

On November 1, 1947, the Sangdong Mine suffered a fire caused by an electrical leak at the processing site, which had just begun operation. The processing plant was completely burned down, which seriously hindered production. Despite that, the Sangdong Mine produced 939 tonnes of tungsten during that year. The operation of the processing site at the Sangdong Mine restarted in November 1948.

Korea Tungsten Mining Company Ltd. (1949–1994)

In 1948, the USAGMIK control system ended and a governance system of company presidents started, with Kim Hyun Gyung being appointed as the first president of the Korea Tungsten Mining Company.

In 1949, the Korean Tungsten Mining Company, a government agency, assumed control and operated Sangdong Mine until 1951. In 1952, the Korean Tungsten Mining Company changed its name to Korea Tungsten Mining Co. Ltd. (“KTMC”) and resumed mining, producing tungsten and scheelite, bismuth and molybdenum concentrates. There were various disruptions with the Korean War from 1950–1951, including being occupied for some of that time by North Korea. In 1951, 639 tonnes of tungsten concentrate were produced, with a monthly production rate of approximately 10,000 tonnes of ore, at a grade of 1.2–1.7% WO₃.

In 1953, mechanized equipment was installed, including slushers, loaders and mining cars. In 1954, mechanization of mine transportation started with tram operations, as well as three underground compressors. In 1957, the mining operations were downsized, going from 1,567 to 400 people at the mine site. A chemical treatment plant was started in 1959 and other significant milestones were achieved over the next 17 years.

The Sangdong Mine operated until 1994, with annual rates of production of up to 750,200 tonnes of ore. By the time of closure, the mine had been developed on 20 levels, between the elevations of 242 and 755 metres above sea level, with a cumulative length of 20 km of workings in addition to six inclines totalling 3.8 km, a ventilation incline and a 450-metre vertical shaft. The mine had tracked haulage ways.

Historical mining employed underground room and pillar methods and concentrated on four main tungsten horizons: the Upper (H1), Main (M1), Lower II (F2) and Lower III (F3) listed in stratigraphic order. Mining occurred mostly on the M1 horizon, with lesser operations on H1 and only very minor workings on F2 and F3.

Production figures over the life of the mine are not available for every year, having either been lost or having never been fully documented. During the period 1952 to 1987, annual production of tungsten concentrate varied between 994 tonnes (1955) and 3,268 tonnes (1961) and total production was 74,911 tonnes. There are indications that in the period between 1987 and 1992, mine production was limited and concentrate production was derived from toll treatment. Various quantities of APT, tungsten metal and tungsten steel were also produced.

Between 1961 and 1987, 2,930 tonnes of bismuth were recovered. Also, 2,725 tonnes of paramolybdate or molybdenum oxide were produced during the period 1967 to 1987. Gold and silver were also recovered, with maximum annual production rates of 37 kg of gold (1987) and 531 kg of silver (1974), apparently from the bismuth concentrate.

Based on tabulated data on longitudinal sections from the beginning of 1981 to the end of 1988, it is evident that the great proportion of the ore-grade mineralization was produced from the 3.5 m to 5 m thick Main horizon: 3.918 Mt. During the same period of time, about 2.041 Mt were mined from the Hangingwall (Upper) horizon in widely spaced stopes as deep as the -8 level. Data suggest that little, if any, production came from the horizon prior to that period.

From 1981 to 1988, about 88,000 tonnes of ore came from the Footwall (Lower) II horizon, mostly in the upper three levels, and 167,000 tonnes of ore from the Footwall (Lower) III horizon, also mostly in the three upper levels of the mine.

Although no statistics are available for production from the various individual horizons, it is evident from the 1989 longitudinal sections that there appear to be only pillars remaining at most levels in the core of the mine area, to at least the -15 level. Most of the remaining resources at that time were in peripheral, and probably lower grade, parts of the deposit and in the Main East orebody.

Statistics for the period from 1987 to the mine’s closure in 1992 are unavailable; however, there are indications that mine production was limited and concentrate production was derived from toll treatment. Various quantities of APT, tungsten metal and tungsten steel were also produced.

In 1959, a synthetic scheelite plant began operation, improving the grade and recovery of concentrates. In 1961, a bismuth refining plant was opened, producing 99.9% bismuth metal. The following year, a plant to produce tungsten metal was commissioned and, in 1972, an APT plant was built.

Towards the end of the 1960s, it was clear to KTMC that it was become increasingly difficult to maintain the production of extremely rich (plus 1.5% WO₃) grades from the Main zone, forcing them to make a number of important changes to the company’s operations.

From 1974 to 1987, up to 1,182 tonnes of APT was produced annually, totalling 10,624 tonnes, but between 1978 and 1987, less than 170 tonnes of tungsten metal and steels were produced. The drop in tungsten prices in the mid-1980s caused the mine to reduce production and eventually shut down in 1992. KTMC was finally dissolved in 1998.

Mr. Jae Youl Sim (Se Woo Mining Co. Ltd. (“Se Woo”)) acquired 23 mining rights over the Sangdong deposit in June 2001.

Woulfe Mining Corporation (formerly Oriental Minerals Inc.) (2006–2015)

On October 19, 2006, Oriental Minerals Inc. (“Oriental”) entered into an agreement with Se Woo, a private company based in Seoul, Republic of Korea, whereby Oriental could earn up to 100% interest in 23 mining rights with a total area of 5,924 ha (59.24 km²).

Ownership of the 23 mining rights was transferred to Oriental, a 100%-owned Korean subsidiary of Oriental Hard Metals Korea Co., Ltd. upon closing of the transaction contemplated in the Sangdong Purchase Agreement and acceptance by the TSX Venture Exchange on January 7, 2007.

On the February 25, 2010, Oriental changed its name to Woulfe Mining Corp. Subsequently, the project area was reduced to 12 mining rights with an aggregate area of 3,173 ha. In November 2011, Woulfe gained a 100% interest in the property.

Sangdong Mine Development by AKTC (2015–2024)

Almonty acquired a 100% ownership interest in Woulfe on September 11, 2015 by way of a plan of arrangement. Woulfe, through its wholly owned subsidiary, AKTC, owns a 100% interest in the Sangdong Mine.

A critical milestone in the redevelopment of the Sangdong Mine was securing adequate financing to support construction and operational activities. In 2020, Almonty achieved this by finalizing a US$75.1 million project finance loan with KfW IPEX-Bank, a German financial institution.

Following the approval of project financing in early 2020, Almonty initiated a multi-year, meticulously planned construction and development program at the Sangdong Mine. The program reflects a combination of engineering precision, ESG-aligned project management and a commitment to building the largest non-Chinese source of tungsten globally. Below is a detailed breakdown of the key phases and milestones in the development of the Sangdong Mine.

2020 – Pre-construction and Engineering

2021 – Formal Start of Construction

2022 – Ramp-up of Equipment Procurement and Civil Works

2023 – Structural Construction, Power and Underground Access

2024–2025 – Transition Toward Commissioning

Historical Resource Estimates

KTMC Historical Estimates

Two historic tungsten Mineral Resource estimates (see Table 6-3 below) were prepared for the Sangdong Mine, in 1985 and 1989. The 1985 estimate, prepared by the mine staff, contained a total of about 20 Mt at a grade of 0.5% WO₃. The 1989 estimate, prepared by Korea Resources Corp., contained about 18.8 Mt at an average grade of 0.5% WO₃.

The second estimate includes about 1.4 Mt attributed to the Sangdong East deposit and therefore the difference between the two estimates does not represent the tonnage mined in the interim. These were polygonal estimates and used a relative density of 2.9. Tungsten mineralization in Sangdong East is lower-grade than in the main mine area. Drillhole data indicated that the Hangingwall (Upper) horizon typically ranges from approximately 1.5–11 m in thickness and contains 0.01–0.24% WO₃ in grade. The partially mined Main horizon is approximately 1 m to 8.8 m in thickness and contains 0.01–0.65% WO₃. Low-molybdenum, blue-fluorescent scheelite is dominant.

Table 6-3 – Historic Resource Estimates, Sangdong Mine

West (W) Sangdong was estimated to contain 2.3 Mt at an average grade of 0.5% WO₃ but no details of the estimation process or the number of holes employed in the estimate are known. It is unknown on how many drillholes this was based, but because of the wide spacing of the drillholes (200m or more), the Mineral Resource could at best be considered Inferred under currently accepted resource evaluation methodologies.

Drill intercepts in the Main horizon varied from 0.24-0.8% WO₃ across 0.8–2.8m. Other intersections included 0.11–0.28% WO₃ across 2.3–6.8m in the Upper vein; and 0.1–3.0% WO₃ across 0.6–2.0 m in the Lower vein. In drill hole 86-6 in the Hwajeolchi area, a roughly 15 m interval in the Hangingwall (Upper) horizon of interlayered limestone and calc-silicate rock (about 50% each) was intersected, with one 3.5 m interval containing 0.32% WO₃.

A large molybdenite-quartz vein stockwork deposit located above a granitic intrusion was identified and drilled between 1980 and 1987 (22 vertical holes; 12,390 m core drilling). Up to 1987, all Mineral Resource or Mineral Reserve estimates predate both NI 43-101 and Woulfe’s involvement in the Sangdong Mine, and should not be considered to be material.

Woulfe Historical Estimates

Tetra Tech (Wardrop) (2012)

The 2012 global Mineral Resource estimate (see Table 6-4 below) estimated by Tetra Tech (“TT”) focused on the data acquired from the 2006–2008 drilling programmes, completed by Woulfe, as well as the compilation of historical data for the upper quarter of the known dip length of the mine, i.e., the section from surface to just below the water level.

The historical drilling data used in the TT(Wardrop)/Woulfe April 2010 scoping study was not used for the 2012 estimate, meaning that any down-dip extension of the mineralized zones was not represented as a Mineral Resource. The classification conformed to the Canadian Institute of Mining, Metallurgy and Petroleum (“CIM”) Definition Standards on Mineral Resources and Mineral Reserves, adopted by the CIM Council, as amended (the “CIM Definition Standards”). The Mineral Resource was split into two sections by elevation, representing the down-dip potential of the deposit below current waterline.

Table 6-4 – Sangdong, 2012 Global Resource Estimate

The previous estimate in the Wardrop 2010 scoping study was made on a very different basis to the 2012 estimate, the former relying on the holes drilled underground by KTMC and on a coarse geological interpretation of the mineralized zones; the 2010 Mineral Resource was classified as Inferred.

The 2012 estimate relied entirely on the more recent drilling programmes with associated sample quality control; however, it only covered approximately the upper quarter of the known dip length of the mineralized zones, and therefore the comparison of the two estimates would be unreliable.

In order to estimate the down-dip resource potential at the Sangdong Mine (see Table 6-4 above), TT (Wardrop) completed a separate estimation of the down-dip resource using all available samples, including those samples which could not be included in the up-dip “Indicated” Mineral Resource. Due to the unreliability of the historic data described above the Mineral Resource was classified as “Inferred” but was included in order to reconcile the 2010 and 2012 estimates.

AMC Consultants Pty Ltd (2014)

Mineral Resources were estimated using a block modelling approach, with three-dimensional (“3D”) ordinary kriging and Datamine’s™ dynamic anisotropy application being employed.

Table 6-5 below shows the Mineral Resource estimate and metal content for the Sangdong Mine as of September 15, 2014. The cut-off grade of 0.4% WO₃ was provided by WMC and was based on an assumed mining method, production rate, metallurgical recovery and metal prices. AMC Consultants Pty Ltd (“AMC”) reviewed these assumptions and considered that they met the requirement of reasonable prospects of eventual economic extraction. It appears that AMC used some results from the pre-2006 drilling in the Mineral Resource estimation.

Table 6-5 – AMC 2014 Mineral Resource Estimate

Changes that occurred between the 2012 and the 2014 Mineral Resource estimates included:

Table 6-6 below compares the TT 2012 estimate with the AMC 2014 estimate. Both estimates are reported at 0.15% WO₃ cut-off grade in this table for comparison purposes.

The following observations were made from the comparison table:

AMC considered that the decrease in grades was mainly due to the previous method (TT) of creating the mineralization volumes from the underground development surveys, and then estimating grade into those volumes from the coded intersections in the database. The coding in the database is not based on a 3D interpretation but is interpreted on a drill hole-by-drill hole basis.

Table 6-6 – Comparison of 2012 and 2014 Mineral Resource Estimates

A-Z Mining Professionals Ltd./TT (Wardrop) Feasibility Study (June 2015)

In 2014, AMC was commissioned by Woulfe to develop a resource block model completely independent of the TT geology block models. On an A-Z Mining review of the completed AMC model, A-Z Mining and Woulfe decided not to retain the AMC resource model due to the technical methodology employed.

The Feasibility Study relied on the TT 2015 updated resource block model, which included the 2013 Phase 4 drilling programme (7,200 m of additional definition drilling to significantly increase confidence in the resources).

The Indicated Mineral Resource in the TT phase 4 updated model is shown in Table 6-7 below reported at 0.15% WO₃ cut-off grade above 600 mRL. The resource is only reported above -3 level (600 mRL).

The TT reported resources were limited to the -3 level (594 mRL).

Table 6-7 – Tetra Tech Sangdong Resources, June 2015

The phase 4 Mineral Resource Estimate update included changes from previous estimates, specifically the 2012 TT Feasibility Estimate:

The Mineral Reserves (derived from the Mineral Resource block model Measured and Indicated Mineral Resources) were identified as being economically extractable, incorporating mining loses and the addition of mining dilution, by A-Z Consultants. Measured and Indicated Mineral Resources were outlined from the -2 to Taebaek levels as almost all resources below -2 Level Mineral Resources were Inferred. The Measured and Indicated Mineral Resources were further separated into the F2/F3 and Main Zones. The resources in a 50 m surface pillar allowance were subsequently removed.

Using an average processing plant recovery of 81%, a concentrate quality of 65% WO₃ and revenue per tonne of concentrate of US$15,000, a cut-off grade of 0.275% WO₃ was determined.

Mining recoveries of 100% in primary (rock walls, floor and back) stopes and 95% in secondary stopes (backfill on both sides of stope) were assigned, based on industry norms and experience in mining in these types of conditions.

Dilution for the stopes included waste inside the stope outlines in the stopes, and backfill sloughing from primary stopes in the secondary stopes. Backfill dilution was included at 5% at a 0% WO₃ grade. Development ore was not separated from stoping ore in the reserves.

The Proven and Probable Mineral Reserves in the combined F2 and F3 Zones were estimated to be 3.9 Mt with a grade of 0.610% WO₃. The Proven and Probable Mineral Reserves in the Main Zone were 2.0 Mt at a grade of 0.492% WO₃.

AKTC Historical Estimates

The A-Z Feasibility Study was updated during 2015, with a NI 43-101 technical report produced by the Qualified Person in December 2015. At a 0.15% WO₃ cut-off grade, Indicated Mineral Resources of 5.18 Mt were reported, along with Inferred Mineral Resources of 52.8 Mt. Mineral Reserves were determined of 4.7 Mt, at a grade of 0.42% WO₃.

The Qualified Person produced an updated NI 43-101 technical report for the end of July 2016. At a 0.15% WO₃ cutoff grade, Indicated Mineral Resources of 8.0 Mt were reported, at a grade of 0.51% WO₃, along with Inferred Mineral Resources of 50.7 Mt, at a grade of 0.43% WO₃. Mineral Reserves were determined of 7.9 Mt, at a grade of 0.45% WO₃.

The Qualified Person produced a Mineral Resources-only NI 43-101 technical report, related to the Molybdenum Stockwork, for the end of May 2022. At a 0.19% MoS₂ cut-off grade, Inferred Mineral Resources of 21.5 Mt were reported, at a grade of 0.26% MoS₂.

Geological Setting, Mineralization and Deposit Types

The Korean Peninsula is situated on the eastern margin of the North China-Korea Platform, which corresponds to a craton composed of three blocks: Archean metamorphic rocks, the Nangrim-Pyeongnam Block and the Gyeonggi and the Yeongnam Massifs. These blocks are separated by the northeast-trending Imjingang and Okcheon mobile belts of Phanerozoic age. The Sangdong Mine is located within the northern sector of the Okcheon Fold Belt, occupying the Cambro-Ordovician Joseon Supergroup of the Taebaek Basin.

The Sangdong Mine is situated on the gently dipping southern limb of the east-west orientated Triassic-age Hambaek Syncline. This structure consists of a thick sequence of sedimentary rocks of the Taebaek Series, composed of Cambro-Ordovician interlayered limestones, shales and quartzites of the Joseon System. This sequence is unconformably overlying the Pre-Cambrian schist and gneiss basement of the Yulri Group of the Yeongnam massif. The stratigraphy in the Sangdong area is mainly composed of the basal Jangsan quartzite, Myobong slate and the overlying Pungchon limestone formations with Cambrian age, which belong to the Joseon Supergroup.

The tungsten mineralization of the Sangdong deposit is contained in several tabular, bedding-conformable skarns in the Myobong Shale formation. The ore deposit is strata-bound, with the strike and dip of the hosting formations. These skarns have been interpreted as comprising carbonate-bearing horizons that were hydrothermally altered and mineralized by fluids ascending from the underlying Sangdong Granite.

From uppermost to lowermost, the mineralized horizons are termed as Hangingwall, Main, and Footwall horizons, as shown in Figures 7-4 and 7-5 below. The Footwall and Main horizons have thicknesses that typically range from 1 to 4 m. As well as the main mineralization on these beds, there are often thin calc-silicate layers developed on the upper and lower contacts of the Main and Footwall horizons.

The Hangingwall horizon is located near the upper contact of the Myobong shale and varies in thickness from approximately 5.0 to 30.0 m because of the irregular boundary of the shale with the overlying Pungchon Limestone. This zone has a strike length of about 600 m and a down-dip extent of about 800 m. Above the most highly altered portion of the Main horizon, the Hangingwall horizon is not tabular, but extends steeply and irregularly into the overlying limestone. The base of the Hangingwall horizon is approximately 14 m above the upper contact of the Main horizon.

The Main horizon strikes about 100° and dips northerly between 15° and 30°. The strike length is in excess of 1,300 m and thickness varies from 5.0–6.0 m. Hydrothermal alteration (skarnification) within the Main horizon forms three concentric, roughly circular zones: the inner biotite-muscovite-quartz zone, the intermediate biotite-hornblende-quartz zone and the marginal garnet-diopside zone.

The Footwall horizons comprise multiple layers: Footwall Zone 1 (F1) normally occurs 1 m below the Main horizon and can be approximately 2 m thick; Footwall Zones 2 and 3 (F2, F3) are situated approximately 35 m to 40 m below the Main horizon and average thickness is from 3 m to 4 m. Furthermore, usually smaller, Footwall Zones have been identified beyond F3 and are collectively referred to as F4 and F5, both situated not far from the contact with the underlying Jangsan quartzite formation.

Figure 7-4 – Schematic Section of the Sangdong Deposit

Local Geology

The Sangdong Mine is situated within the northern sector of the Okcheon Fold Belt in South Korea, a region that hosts Cambro-Ordovician sedimentary sequences known as the Joseon Supergroup. The deposit lies along the south-dipping southern limb of the east-west trending Hambaek Syncline and is structurally and stratigraphically controlled. The local stratigraphy consists primarily of the basal Jangsan Quartzite, overlain by the Myobong Slate, and capped by the Pungchon Limestone—units which collectively form the Joseon Supergroup. The tungsten mineralization is hosted within several tabular, bedding-conformable skarn horizons (Hangingwall, Main, and Footwall), developed through metasomatic replacement of carbonate-rich layers in the Myobong Slate and Pungchon Limestone. These zones are characterized by alternating garnet-, pyroxene-, and quartz-bearing assemblages, consistent with classic calc-silicate skarn systems. Structural controls, lithological boundaries, and proximity to the granite source collectively govern the geometry and grade distribution within the deposit.

Tungsten Skarns

The Sangdong Mine contains a tungsten skarn deposit. Skarns are contact metasomatic deposits, exploited for tungsten, with accessory molybdenum, copper, tin and zinc. They typically form in continental marginal settings, associated with syn-orogenic plutonnes that intrude and metamorphose deeply buried sequences of carbonate-shale sedimentary sequences. Skarn mineralization is typically hosted by pure and impure limestones, calcareous to carbonaceous pelites.

Due to their contact metamorphic nature, mineralization has a close spatial association with calc-alkaline granitic intrusives (tonalite, granodiorite, quartz monzonite and granites). Skarn deposits form stratiform, tabular and lens-like deposits, which can be continuous for hundreds of metres along intrusive contacts.

Principal and subordinate mineralogy comprises scheelite ± molybdenite ± chalcopyrite ± pyrrhotite ± sphalerite ± arsenopyrite ± pyrite ± powellite. Traces of wolframite, fluorite, cassiterite, galena, marcasite and bornite also occur. Reduced types are characterized by pyrrhotite, magnetite, bismuthinite, native bismuth and high pyrrhotite:pyrite ratios. Variable amounts of quartz-veining (with local molybdenite) can cut both the exo- and endoskarn.

Exoskarns occur at, and outside the granite which produced them, and comprise alterations of wall rocks. Endoskarns, including greisens, form within the granite mass itself, usually late in the intrusive emplacement and consist of cross-cutting stockworks, cooling joints and around the margins and uppermost sections of the granite itself.

Exoskarns display the following alteration zonation: an innermost zone of massive quartz may be present; an inner zone of diopside-hedenbergite ± grossular-andradite ± biotite ± vesuvianite; and an outer barren wollastonite-bearing zone.

There is commonly a late-stage alteration assemblage, comprising spessartine ± almandine ± biotite ± amphibole ± plagioclase ± phlogopite ± epidote ± fluorite ± sphene. Reduced types are characterized by hedenbergitic pyroxene, iron-rich biotite, fluorite, vesuvianite, scapolite and low garnet: pyroxene ratios, whereas oxidized types are characterized by salitic pyroxene, epidote and andraditic garnet and high garnet: pyroxene ratios. The exoskarn envelope can be associated with extensive areas of biotite hornfels.

Endoskarn alteration exhibits the following: pyroxene ± garnet ± biotite ± epidote ± amphibole ± muscovite ± plagioclase ± pyrite ±pyrrhotite ± trace tourmaline and scapolite; and local greisen developed.

The location of mineralization is usually controlled by: the presence of carbonate rocks in extensive thermal aureoles of intrusions; gently-inclined bedding and intrusive contacts; and structural and/or stratigraphic traps in sedimentary rocks and irregular parts of the pluton/country rock contacts.

Granite Related Molybdenum

Due to the paucity of information about the molybdenum-mineralized system beneath the Sangdong underground workings, it is difficult to characterize a model for this mineralization. However, important molybdenum mineralization falls into two classes: porphyry-type and granite-related molybdenum-tungsten-tin systems. There is some overlap between the two.

The tungsten mineralization of the Sangdong deposit is contained within a series of tabular skarn horizons within the Myobong Slate. Calcium carbonate horizons within the slate have undergone metasomatic replacement to mineralized skarn by hydrothermal fluids. The source of these fluids is thought to be the underlying Sangdong Granite. K-Ar age determination of phyllites within the Myobong Formation are consistent with the age of the granite below.

Swarms of quartz veins have ascended upward through the Jangsan Quartzite into the Myobong Formation where they can be seen to follow the bedding planes and also crosscut the formation. There is a correlation between the presence of quartz veins and the grade of mineralization.

Although hydrothermal alteration (skarn formation) is widespread in the Sangdong area from Sangdong West to Sangdong East and beyond, there is no evidence of a pervasive porphyry-style alteration system. Country rock above the Sangdong granite is hornfelsed, but not pervasively altered.

Vein- and greisen-type hydrothermal molybdenum-tungsten or tin-tungsten mineralization is connected with shallow-seated, highly differentiated, relatively K-rich granites. Regional zoning of tin, tungsten and molybdenum may be apparent. Where greisen is absent, mineralization may be within a sheeted or stockwork system contained within the apical portion of a granite body, or in overlying country rocks. Veins may vary from subhorizontal to vertical and replacement (skarn) bodies may be present in the wallrocks. Fluorine is an important constituent and bismuth minerals may also be present. There is no recorded alteration system (i.e., greisen) at Sangdong, and therefore the deep molybdenum mineralization is likely to comprise a system of sheeted or stockwork veins.

Exploration

It was stated by Klepper (1947) that exploration in 1939 and 1940 led to the discovery of the Sangdong scheelite body, although no further details are available.

Mineral Resource definition drilling is the only form of exploration that has been completed by Woulfe and AKTC at the Sangdong Mine after becoming operators in 2006, and there is no record of exploration other than drilling by previous operators.

An aeromagnetic map of the area was reproduced in a scoping report by Sennitt (2007), but the origin is unknown.

Drilling

KTMC Drilling

A summary of the different KTMC drilling campaigns is shown in Table 10-1 below. Between 1980 and 1985, 15 holes (8,940 aggregate metres) were drilled to investigate the East Tungsten mineralized zone, now referred to as Sangdong East, approximately 1 km to the east of the main Sangdong Mine and the deposit was further investigated with a drift approximately 1 km long. About 100,000 tonnes of ore were mined here in 1990. No additional work has been completed in this area to date.

Table 10-1 – KTMC Drillhole Summary

Between 1979 and 1989, 18 holes (16,502 aggregate metres) were drilled in the West Tungsten mineralized zone, now referred to as Sangdong West, approximately 2 km northwest of the Sangdong Mine area. This zone has not been further explored. Between 1980 and 1987, 22 vertical holes (12,390 aggregate metres) were drilled underground from the Sangdong Mine workings to investigate the extent of molybdenum mineralization in the quartzite unit that underlies the main skarn zone. No additional work has been completed in this area to date.

During an unknown period, about 780 holes with an aggregate length of 30,000 m were drilled underground to explore the mineralized zones. These historical holes were used in the 2010 scoping study.

Interpretation of Relevant Drilling Results

The drilling completed between 2006 and 2016 confirmed the presence, of the three principal skarn horizons at the Sangdong Mine: the Hangingwall (Upper), Main, and Footwall (Lower) zones. The 2016 Phase 7 underground drilling program, consisting of 20 drillholes totaling over 1,004 metres, was carried out from drill chambers in Level 2 of the underground workings and targeted the Hangingwall zone.

Mineralization in the Main and Hangingwall zones occurs to be skarn hosted in the upper Myobong Formation. The drilling confirmed the continuity in the targeted zones and contained scheelite as the primary tungsten-bearing mineral. Results were validated through extensive quality assurance/quality control, including field duplicates, blank samples, certified reference materials, and laboratory duplicates. These data supported the current Mineral Resource estimate and are considered suitable by the Qualified Person for use in resource modeling.

This data set does not have associated QA/QC information for the assay results, nor is the collar or downhole survey information adequately documented. Comparison of grade values in pre-Woulfe drillholes with nearby Woulfe drillholes showed significant differences that were considered (by AMC in 2014) as unlikely to be a result of natural variability only. Therefore, the results suggested that the pre-Woulfe location information and/or grade values were inaccurate.

AMC used the KTMC drillholes in their Mineral Resource estimate to determine the grade and tonnes below -3 level (594 mRL) only where Woulfe had not completed any drilling. This uncertainty in the location and/or grade below -3 level is reflected in the current Mineral Resource classification.

Woulfe Drilling

The exploration work undertaken by Woulfe at the Sangdong Mine was the surface drilling programme completed between November 2006 and July 2008. From June 2010, an underground resource definition drilling programme was designed and the first phase completed.

2006–2008 Drilling Programme

Woulfe (as Oriental) conducted a drill programme at the Sangdong Mine between November 2006 and July 2008. Ninety HQ/NQ surface core holes were completed, with an aggregate length of 22,800 m. HQ and NQ cores are nominally 63.5 mm and 47.6 mm in diameter, respectively.

The holes were largely drilled within the area of the former underground Sangdong tungsten deposit. Analyses for WO₃, MoS₂, bismuth and other minerals were completed and this dataset comprises some 20,355 analyses.

The holes were all drilled in the south-eastern portion of the deposit, where the mineralization occurs near surface or is outcropping, on a bearing of 135°, parallel or nearly so, to geological strike; about 30% were drilled on the opposite bearing of 315°.

The majority were drilled at a dip of 70°, although several were vertical or at a dip of about 80°. The holes were designed to test all three principal horizons of mineralization and, with several accidental exceptions, almost all penetrated well into the Jangsan Quartzite that underlies the host Myobong Formation. Difficulty was often experienced in penetrating the lower horizons due to the mined out areas of the skarn mineralization.

The drill hole collar locations were surveyed by global positioning survey (GPS; sub 0.2 m accuracy) and the down-hole positions of the holes were measured at 50 m intervals when possible. There were some uncertainties with regard to the collar elevations and Woulfe subsequently undertook additional surveying work to resolve the situation and consolidate the survey of the site in general.

Holes drilled on bearings of both 135° and 315° intersected strata and mineralization obliquely, the intersected thickness of mineralization being about a 30% greater than the true thickness.

2009–2014 Drilling Programmes

Once access was gained to the underground workings, Woulfe began a programme of infill and resource definition drilling. The drilling was largely completed from the underground workings supplemented by additional surface holes where underground access was not possible.

Underground drilling was either NQ core from a Sandvik Onram 1000 wireline rig, or BQ core from 3 Kempe pneumatic screwdrive open hole core rigs. Orientations vary based on access and the need to intersect all three ore horizons. Conical drilling patterns are common as a result of fanning out in all directions from the underground drilling platforms. Collar locations were surveyed using a Leica 1203 (total station with sub-decimetre accuracy). Downhole surveys were conducted approximately at the end of hole, as the majority of holes are less than 30 m in length. A Camteq™ multiple shot camera was used, with a stated accuracy of ± 0.5° on azimuth and ± 0.2° on dip. The downhole camera was routinely calibrated to ensure maximum performance, using a purpose designed jig.

2016 Drilling Programme

AKTC have completed a Phase 7 underground drilling campaign in 2016. This was focused in improving the resource categorization of the HW Zone (allowing some conversion of Inferred to Indicated Mineral Resources) and consisted of 20 holes, drilling just over a 1,000 m in total.

Drilling Summary

All of the recorded drillholes at Sangdong are summarized in Table 10-2.

Table 10-2 – Summary of Sangdong Drilling

[Date: 2016, Source: A. Wheeler]

Drilling Results

Table 10-3 below summarizes the mineralized intersections from the drilling programmes completed between 2012 and 2014.

Table 10-3 – Summary of Mineralized Intersections from Drilling 2012 – 2014

Sampling, Analysis and Data Verification

Sample Preparation

An overall summary of quality control samples taken during drilling campaigns from 2010 onwards is shown in Table 11-1 below.

Table 11-1 – Summary of Quality Control Samples

Sample preparation from core to pulps for analysis is completed on site. Core is sawed in half, half placed in a plastic sample bag and half replaced in the core box for archival storage. Sample tags are placed in the core box and in the sample bag and the sample number is written on the sample bag as well. Standards are placed into the sample stream at this point in the sampling process, in accordance with a sample list that has been drawn up by the geologist responsible for logging the hole.

Core samples are dried, split, crushed and pulverized on site by Woulfe personnel in a preparation lab that was purchased as a modular unit from Marc Technologies in Perth, Australia. Equipment is cleaned by brushing and the use of compressed air between each sample. Woulfe staff employed in the sample preparation facility have been trained by SGS Australia Pty Ltd. (“SGS Australia”) in Perth, Australia.

An approximately 50 g split portion of the pulverized sample is sent to SGS Australia in Perth, Australia for analysis. Blanks are inserted one in every 20 samples to ensure there is no contamination.

Analyses

From 2006 to 2008, samples were analyzed at the ALS laboratory in Brisbane, Australia, by inductively coupled plasma mass spectrometry (ICP-MS) for 41 elements and for ore grade quantities of specific elements by aqua regia or four-acid digestion followed by ICP analysis.

From 2010, molybdenum, tin and tungsten were analyzed at the SGS Australia laboratory in Perth, Australia, by X-ray fluorescence (XRF). The sample is fused in a platinum crucible using lithium metaborate/tetraborate flux and the resultant glass bead is irradiated with X-rays and the elements of interest quantified. All quantities are reported in parts per million (ppm). Both ALS and SGS laboratories are independent of the Company and AKTC.

Sample Security and Chain of Custody

The sample preparation facility comprised a fenced area beside the Woulfe accommodation facility. Sample tags are placed in the sample bag and the sample number is written on the sample bag as well. A split portion of the pulp from each sample and coarse rejects is retained in a locked facility at the project site. The pulps are placed in brown paper envelopes by the sample preparation manager, then packed in cardboard boxes, sealed and sent by DHL courier to SGS Australia in Perth by a Woulfe geologist.

Precision, Accuracy and Blank Results

Precision

Precision is the measure of variability or repeatability of an assay result. Knowing the precision of a set of assays allows for correction to any bias or accuracy problems that may occur. A lack of precision may be the result of the sample collection process, laboratory preparation process and/or the analytical process, influencing negatively the Mineral Resource Estimation.

Internal laboratory duplicates are two split pulps of the same pulverized sample. These laboratory duplicates are considered to demonstrate good precision if the absolute relative paired difference (“RPD”) is < 10%, 90% of the time. Internal laboratory duplicates quantify the precision of the chain of laboratory sample preparation and analytical procedures.

During the January 2012–September 2014 reporting period, 819 samples were re-assayed. Tungsten internal laboratory duplicate summary statistics are presented in Table 11-4 below. Molybdenum internal laboratory duplicate summary statistics are presented in Table 11-5.

Table 11-4 – Tungsten Laboratory Duplicate Summary

Table 11-5 – Molybdenum Laboratory Duplicate Samples

The correlation coefficient for both tungsten and molybdenum shows excellent agreement between the original and duplicate assays. The tungsten RPD results also show excellent agreement between the original and duplicate assays with 98% of samples below the 10% RPD threshold. The molybdenum RPD results show poorer agreement between the original and duplicate assays with 86% of samples below the 10% RPD threshold. This is less than the 90% threshold. The scatterplots show three outliers in the tungsten results and one outlier in the molybdenum results.

TT considered that the outliers were not material to the Mineral Resource Estimation and that the duplicate results demonstrate the precision of the tungsten assay results and that they supported the use of the SGS Australia results in Mineral Resource Estimation.

Independent re-assaying of selected pulps from the primary sample by a second laboratory provided a measure of both precision and accuracy. Woulfe sent 133 samples previously assayed by SGS Australia in Perth, Australia to Bureau Veritas Laboratory (“BV”) in Perth, Australia, as an external laboratory check. These external laboratory duplicates are considered to demonstrate good precision if the absolute RPD is < 20%, 90% of the time.

Tungsten duplicate summary statistics, for the January 2012–September 2014 reporting period, are presented in Table 11-6 below.

Table 11-6 – Tungsten External Laboratory Duplicate Summary

The correlation coefficient shows excellent agreement between the two laboratories. The RPD results also show excellent agreement between the two laboratories with 99% of samples below the 20% RPD threshold. The scatterplot shows one outlier.

The outliers are not considered material for the Mineral Resource estimate.

The BV results demonstrate the precision and accuracy of the SGS Australia assay results and that they support the use of the SGS Australia results in Mineral Resource Estimation.

Accuracy

Accuracy is the measure of how close the assay is to the actual sample grade. Poor accuracy can be caused by various sampling or analytical problems, including issues with analytical equipment or procedures such as machine calibrations. These situations can occur at any time. Accuracy of the analytical process must be quantified on a batch by batch basis to enable samples to be re-assayed over time periods by inserting assay certified reference material (“CRM”) standards into each batch of samples and monitoring the results.

A CRM is a standard sample that has been manufactured by a certified company and is itself certified. The manufacturing process creates a homogenized sample that has undergone an extensive and rigorous certification process. This process generates an expected value and acceptable limits for all elements in the sample.

Laboratories use CRMs to ensure that their analytical processes are accurate between calibrations of the machines. Where drift is observed, it is normal procedure for a machine to be recalibrated. It is possible for internal laboratory CRM assay results to be altered and it is now industry standard for laboratory clients to submit their own CRM samples, in order to be able to monitor the accuracy of the laboratory.

Four CRMs for tungsten and one for molybdenum are in use by Woulfe. These, along with a blank and a re-split coarse duplicate are inserted routinely at every 20^th sample interval. The CRMs were produced by CDN Resource Laboratories, Canada. A summary of the CRMs is given in Table 11-7 below. Note that CRM values are reported here as W% or Mo ppm, not WO₃ or MoS₂%. If a CRM falls outside the 1SD range, re-analyses of 10 samples before and 10 samples after the failed CRM sample are requested from SGS Australia.

Table 11-7 – CRM Summary

The CRM results for the reporting period January 30, 2012 to September 15, 2014 demonstrate that: the CRMs show good compliance for the reporting period; CRMs CDN-W1, CDN-W2 and CDN-W3 display a slight high bias in the middle third of the reporting period of up to approximately 5% but still well under 1 standard deviation of the lab mean; no significant bias is observed for the rest of the reporting period or for the other CRMs; and the molybdenum CRM is too close to the detection limit to be a useful CRM for the Sangdong Mine.

TT considered that the bias observed in the CRM plots is not material for the Mineral Resource estimate, but recommended continuous monitoring of CRM performance by batch. The results demonstrated the accuracy of the assay results and support their use in Mineral Resource Estimation.

The Qualified Person, after also checking the Phase 7 results, considers these results to be demonstrating the same accuracy as previously, which therefore supports their use in Mineral Resource Estimation.

Blank Results

Blanks are required to be inserted into the sample sequence by both the laboratory and the laboratory client. Laboratory blanks are usually flux or pure silica and are a test for cleanliness within the laboratory, where poor cleaning of equipment may result in sample contamination.

The coarse crystalline feldspar blank material used by Woulfe during the period to test for contamination during the sample preparation was certified to contain no metal. TT considered assays of blank material to be acceptable if they were less than three times the practical detection limit of the laboratory.

The tungsten bank results for the January 2012–September 2024 reporting period show three blank values out of 822 that are above the acceptable limits while the molybdenum results show two blank values out of 822 that are above the acceptable limits. TT considers that the blank value results are acceptable and demonstrate adequate care is taken by Woulfe staff during sample preparation and the lab employs correct cleanliness procedures. There were also no unacceptable blank values for the Phase 6 blank results.

The Qualified Person considers that the sample preparation, security, analytical procedures and supporting QA/QC results that were used to inform the Sangdong Mine block model estimate were collected in line with industry good practice as defined in the CIM Exploration Best Practice Guidelines and the CIM Mineral Resource, Mineral Reserve Best Practice Guidelines (the “CIM Guidelines”).

Quality Assurance/Quality Control

The QA/QC protocol included the insertion of the following control samples in the assay batches:

Data Verification

The data verification procedures applied by various qualified persons at the Sangdong Mine since 2006 are summarized below.

Watts, Griffis and McQuat (2006)

The Sangdong Mine underground workings were either inaccessible or, if open, of unknown condition. This restricted Watts, Griffis and McQuat’s (“WGM’s”) independent sampling to low-grade outcrops and waste dump material. Given the long-documented record of tungsten production at the mine, the sampling done during WGM’s site visit on November 20, 2006 was clearly not intended to be definitive, rather simply to independently confirm that economically significant grades of tungsten, in particular, were present.

All samples were put into bags and closed with uniquely numbered, locking plastic ties; they remained under lock and key or in WGM’s possession during their representative’s time in South Korea. They were taken as personal baggage to Mississauga, Ontario and shipped by courier to SGS Mineral Services (“SGS Canada”) in Lakefield, Ontario. Samples were assayed for tungsten (reported as %WO₃) and molybdenum.

SGS Canada normally inserted one blank per batch of 100 (maximum) samples, one duplicate per 20 samples and one reference standard every 20 samples.

After drying, if necessary, the samples were crushed to 75% passing 9 mesh (2 mm), and riffle split to produce a reject portion and a smaller portion which was pulverized to 85% passing 200 mesh (74 μm). A 0.2g charge of each pulverized sample was roasted for 20 minutes and mixed with 5 g of potassium pyrosulphate. The mixture was then fused, ground and pressed into a disk. Samples were analyzed by the wavelength dispersion X-ray fluorescence (WD-XRF) method having detection limits of 0.05% for each of W and Mo. The XRF method was chosen because normal ICP methods have an upper detection limit of 1% W, and it was suspected that at least two of the Sangdong samples contained appreciably more than this amount of tungsten.

Analytical results for the independent WGM samples, together with location and sample descriptions, are presented in Table 12-1 below.

Table 12-1 – Analytical Results from Independent WGM Sampling

Significant amounts of blue-white-fluorescing scheelite were observed in two dump samples from the upper and main adit levels (72119 and 72120) and lesser amounts from a third (72121), confirmed upon analysis. All samples were of compact, fine-grained dark green (amphibole-rich) skarn. The coarse character of the scheelite in sample 72120 is noteworthy.

The outcrop sampled near the upper adit portal consists of diopside-garnet skarn with subhorizontal quartz veins. There was a minor amount of local scheelite.

The most surprising result of 0.07% WO₃ was from an 8 m wide, steeply dipping (about -65°) structural zone, with multiple quartz veins, in Myobong Shale on the forestry road. Mineralized quartz veins cutting across skarn-type mineralization are documented in the Sangdong Mine, but apparently at not such a steep inclination. Other similar structural (fault or shear) zones were observed by WGM on the forestry road south of the set-up for drill hole SD-1.

Sennitt (2007)

The Sangdong project database, residing in MS ACCESS database files, includes all drill collar location, assay, quality assurance and geological data, as well as core recovery, visual estimates of key minerals and bulk density data.

The collar, assay, geological (rock type codes only) and core recovery data were extracted and input into the GEMCOM® modelling software system.

As a test of data integrity, checking of 10% of the data was made against original assay certificates. Collar coordinates were checked against the original survey forms. Results from the data checks showed zero error rate. It was concluded that the assay and survey database used for the mineral resource update was sufficiently free of error to be adequate for resource estimation.

Tetra Tech/Wardrop (2012)

Verification activities conducted during the site visit included:

Verification activities subsequent to the site visit included the selection of between 5% and 10% of the Sangdong drill holes for verification of handwritten geological logs, original field sample sheets and original ALS assay certificates against corresponding records in the Sangdong database supplied. Copies and scans of original data were supplied by Woulfe in order to carry out the verification exercise off-site.

Very minor discrepancies and errors were encountered during these processes and referred to Woulfe for clarification or correction.

Overall it was concluded by TT/Wardrop that appropriate care and attention in data entry, validation and QA/QC procedures had been applied by Woulfe and that analytical issues were identified and appropriate remedial action taken. A possible exception related to downhole surveys of relatively short drillholes, but otherwise industry standard practices had been followed and the quality of the Sangdong database meets NI 43-101 standards and CIM Guidelines.

TT/Wardrop concluded that the combination of the latest sampling and understanding derived from the wealth of historical mining data provided adequate information for the purpose of their resource estimation and technical report.

TT/Wardrop did not complete any independent exploration work, drill any holes or perform any programme of sampling and assaying on the property. During the field visit (October 2011), Wardrop did not collect any samples from the Sangdong project, but was satisfied from visual inspection of the presence of mineralization at Sangdong.

Tetra Tech/A-Z Mining Professionals Ltd. (2013)

From August 17, 2013 to September 1, 2013, inclusive, TT full-time employee and qualified person Mr. Joe Hirst made a personal inspection of the Sangdong Mine and undertook the following data verification steps:

Discussions with site geologists regarding:

Tetra-Tech made the following observations: site geologists are appropriately trained and are conscious of the specific sampling requirements of disseminated mineralization with high-grade lenses; and cross-checking the database with the original assay results did not uncover any errors.

AMC (2014)

Between August 5–15, 2014, AMC full-time employee and qualified person Dr. A. P. Fowler visited the Sangdong Mine; the data verification steps and conclusions were identical to those summarized in the TT (2013) section above.

Adam Wheeler Site Visits

The Qualified Person visited the Sangdong site during August 24–26, 2015, October 17–28, 2016 as well as from April 1–4, 2025. These visits included discussion with site geologists all aspects of sample collection, preparation and storage, as well as visiting the core storage and sample preparation areas. The updated sample database was also reviewed in 2015 and 2016, and during the resource estimation process, many aspects of the drill hole data were checked by communication with the Sangdong geologists.

In the Qualified Peron’s opinion, the geological data used to inform the Sangdong Mine block model estimates were collected in line with industry good practice as defined in the CIM Guidelines and were suitable for use in the estimation of Mineral Resources.

Mineral Processing and Metallurgical Testing

Beneficiation of Scheelite Ore from the Sangdong Mine (South Korea (U.S. Department of the Interior), 1954)

Extensive metallurgical test work has been conducted on Sangdong scheelite ore over the course of several years to de-risk the processing flowsheet and confirm economic recoverability. The test work included: (i) laboratory-based bulk sulphide flotation and multiple stage cleaning tests, (ii) locked cycle tests conducted at KIGAM to establish recovery and concentrate grade projections, and (iii) pilot plant trials conducted at Laboratório Nacional de Energia e Geologia (“LNEG”) in Portugal to confirm the viability of the full processing regime. These programs tested different reagent grades and water sources under various test conditions. Test work results confirmed that the Sangdong ore is amenable to producing high-grade tungsten concentrates using the selected flotation regime, and that recovery levels and product specifications are consistent with historical results. This test work underpins the process guarantees granted by Metso Outotec. Additional historical and third-party test results are summarized under “Mineral Processing and Metallurgical Testing” in this document.

Several processing factors and potential deleterious elements were identified during the metallurgical test programs on the Sangdong scheelite ore. Scheelite liberation is constrained in coarser fractions, requiring fine grinding (to 80% <65 μm) to ensure efficient flotation recovery. The presence of sulphide minerals such as molybdenite, bismuthinite, and chalcopyrite necessitates bulk sulphide flotation prior to scheelite recovery, as these can impact concentrate quality. Test work also indicated that excessive backfill material in the feed (approaching 10%) can negatively affect sulphide flotation efficiency. Water quality is another factor; flotation with softened mine or river water proved effective, while untreated water may interfere with reagent performance. Lastly, while earlier test work relied on a proprietary Chinese collector, subsequent trials confirmed comparable or superior performance from an alternative South African reagent, reducing sourcing risk. Overall, no critical deleterious element or processing factor has been identified that would prevent the production of market-grade scheelite concentrate, assuming appropriate process controls.

From the test work on the Sangdong scheelite ore, the following conclusions were drawn:

The test work on the Sangdong low-grade scheelite concentrate indicated the feasibility of a soda-ash roast-leach extraction of sodium tungstate to precipitate an artificial scheelite product. The product made from the first part of this calcium chloride precipitation met market specifications in both tungstic oxide content and maximum molybdenum content allowable. The subsequent precipitation products were high in molybdenum, even though the minimum grade for tungstic oxide was met.

Separation of the molybdenum from the tungsten in the pregnant solution was not attempted, as it was beyond the scope of the investigation. However, a process was used by U.S. Vanadium Co. to make this molybdenum tungsten-separation.

A calculated combination of the results of these two beneficiation procedures was made. This calculation was made to demonstrate the results possibly obtainable if a sample of the Sangdong scheelite ore were treated by tabling, flotation, magnetic separation and roasting and leaching of low-grade scheelite concentrates for reprecipitation of artificial scheelite products, as indicated by the test work. The hypothetical results indicated that the following marketable products might be prepared:

Part of the molybdenum should be recoverable from the sulphide flotation concentrates. The portion entering the pregnant solution may be precipitated with sodium sulphide solution and filtered off before tungsten precipitates. Neither of these steps was attempted, since they were not part of existing metallurgical technology; the latter technique has been applied to Korean concentrates, and it was therefore simply assumed that these methods would apply to this ore. These conjectures point to the possibility of better metallurgical results; however, the beneficiation work done has demonstrated that the Sangdong scheelite ore, as approximated by the sample submitted for beneficiation, is amenable to concentration into marketable grade products by a combination of tabling, flotation, magnetic separation, and chemical treatment.

Tetra Tech/Woulfe (2010 Scoping Study)

The following is a summary, extracted from the Mineral Resource Estimate (TT/Woulfe 2012), of the mineral processing and metallurgical testing completed during the 2010 Scoping Study.

Mineralogical studies and preliminary metallurgical test work have been conducted on four composite core samples taken from the Sangdong deposit by SGS Mineral Services Europe (“SGS Europe”). The samples represented the four historical mineralized horizons, namely A, B, C and D+E combined (although not stated the horizons are assumed to correspond to the Hangingwall, Main and Footwall (F1, F2 and F3) horizons).

The key points arising from SGS Europe test work were:

Although theoretical grade and recovery curves were established as part of the quantitative mineralogical programme, process grade and recovery data remained to be established.

A-Z Mining Professionals Ltd./Woulfe

Since publication of the TT Feasibility Study in 2012 a pilot plant scale test was completed on a bulk sample from the Sangdong deposit in late 2012. The pilot plant testwork was carried out by the GRINM. The results of this pilot plant testwork are summarized below:

The overall conclusion from the pilot plant testwork was that the flowsheet proposed by TT in the 2012 Feasibility Study and technological conditions provided by the pilot plant test could be used as the design basis for the processing plant.

Chinese Collector Alternative

In the pilot plant testwork by the GRINM in China, a proprietary Chinese collector, GYWA, was used in the plant. Because of security of supply concerns an alternative to this collector was sourced and tested. The conclusions from testing the R3-3F unit from South Africa were:

The validity of the TT flowsheet and the projected tungsten recovery were confirmed by the pilot plant and collector alternative testwork, in addition to the original metallurgical testwork presented in the TT report.

The testwork also de-risked the processing plant flowsheet and reagents used.

AKTC (2016–Onwards)

Continuing the de-risking strategy from the beginning of 2016, in terms of the plant flowsheet and reagents used, Almonty signed an agreement with the Korean Institute of Geoscience and Mineral Resources (“KIGAM”) to jointly develop a suitable method to recover the scheelite at the Sangdong Mine. This method should provide results not inferior to those reported in 2012 by the GRINM.

Since this agreement has been signed, a very significant number of metallurgical tests have been done on Sangdong mineralized material, especially on the footwall lodes. Multiple stage cleaning tests have been done in very different conditions: control tests with tap water and laboratory reagents, tests with softened mine water, tests with industrial grade reagents and tests including in the feed a portion of backfill material. To arrive at a metallurgical projection, locked cycle tests (“LCT”) were made. For the purpose of the process guaranties, granted by Metso Outotec, pilot plant trials have also been completed. In general, all these tests present results that are not inferior to those reported by the GRINM.

Until 2019, laboratory-based tests were done: multiple stage cleaning tests and LCT. KIGAM laboratories were used for this purpose. After 2021, the laboratorial tests were conducted at the Tungsten Technological Centre (“TTC”), in Portugal, at Panasqueira Mine. The pilot plant trials, concluded in 2023, took place at the LNEG installations, also in Portugal, in Porto.

The principal metallurgical tests done by Almonty at the Sangdong Mine are described in the following sections.

Bulk Sulphide Flotation

Prior to flotation of scheelite, it is necessary to remove sulphides, also by flotation, into a bulk concentrate. In Table 13-4 and Table 13-5 below, the results of two bulk sulphide flotation tests are given. The rougher sulphide concentrate was cleaned in two stages, in order to reduce the losses in WO3 to the final sulphide concentrate, as demonstrated by the results Table 13-4 below. The conditions selected to float the sulphides ensure good recoveries in Mo, Bi and Cu. The head grades presented in Table 13-4 below are typical of most of the samples that were tested. The much higher head grades presented in Table 13-5 below are an exception. Laboratorial metallurgical tests for the possible recovery of Mo and Bi, and also of Au and Ag, are scheduled for 2025 at the TTC.

Table 13-4 – Bulk Sulphide Flotation Test – KIGAM (2019)

Table 13-5 – Bulk Sulphide Flotation Test – Industrial Grade Reagents – TTC (2025)

Multiple Stage Cleaning Tests

Presented here are five multiple stage cleaning tests done in different phases of the project development. In Table 13-6 below, a test is presented that was used as preparation for the LCT (see the next section). This achieved 78.6% WO3 in the final scheelite concentrate, confirming that the production of high-grade tungsten concentrates is possible. In Table 13-7 and Table 13-8 below are presented the results of two tests that were done in the context of establishing the compatibility between the flotation process and the lime-soda process for softening water. It can be concluded that both processes are compatible. In this way, groundwater and river water, collected near Sangdong, can be used in flotation after softening. In Table 13-9 and Table 13-10 below are given the results of two tests done in the context of selecting industrial grade reagents to replace the laboratory reagents (sodium carbonate, sodium silicate, etc.). It can be concluded that the chemical industry (outside China) can produce, in quality and quantity, the reagents needed to operate the Sangdong Mine processing plant.

Bearing in mind the main purpose of a multiple stage cleaning test, from the five tests that were presented, it can be concluded that a high-grade tungsten concentrate can be produced with the proposed flotation regime, being the stage recoveries of the cleaning process always very high. Multiple stage cleaning tests were also done to measure the tolerance of sulphide and scheelite flotation to the presence of backfill material in the feed. Tests have been conducted with backfill percentages ranging from a few percent to 10%. For the lower percentages of backfill, it was concluded that neither the sulphide flotation nor the scheelite flotation suffered an impact. Only near to the upper limit was noticed some impact on sulphide flotation, characterized by an increase in mass pull.

The flotation regime applied in the multiple stage cleaning tests, and, in general, applied in the LCT and pilot plant trials, is well-known in the mining industry. It is based on the use of sodium carbonate as pH regulator, sodium silicate as depressor, and TOFA as the main scheelite collector, conducting the flotation in lukewarm water. Grinding to 80% below 65 μm seems suitable for Sangdong ore, independently from its origin in the mine.

Table 13-6 – Multiple-Stage Cleaning Test – KIGAM (2019)

Table 13-7 – Multiple-Stage Cleaning Test – Tap Water Control Test – TTC (2021)

Table 13-8 – Multiple-Stage Cleaning Test – Softened Mine Water – TTC (2021)

Table 13-9 – Multiple-Stage Control Test – Laboratory Reagents – TTC (2025)

Table 13-10 – Multiple-Stage Cleaning Test – Industrial Grade Reagents – TTC (2025)

Locked Cycle Tests

This section presents two LCT, which were made at KIGAM, that allow making a first metallurgical projection, that is, to estimate the value of the recovery and concentrate grade, with all the internal fluxes recycling. For both tests are presented the weights and assays of each product that does not recycle (Table 13-11 and Table 13-15 below), the cycle-by-cycle balance for each complete cycle of the test (Table 13-12 and Table 13-16 below), and, finally, the metallurgical projection, based on the last two cycles of each test, following two different procedures (Table 13-13, Table 13-14, Table 13-17 and Table 13-18 below). Table 13-11 and Table 13-15 below show the assays of other elements: Mo, Cu and P.

As mentioned previously, two different procedures were used in the metallurgical projection. In the first procedure, the two concentrates and the two tailings are projected as the average weights and assays for these products in cycles E and F. The feed for the test is then calculated as the sum of the products. For test no. 1, the first procedure gives a recovery of 83.7% for a final concentrate grade of 73.2% WO₃. For test no. 2, this first procedure gives a recovery of 85.4% for a final concentrate grade of 62.4% WO₃.

In the second procedure, the final concentrates are projected in the same way. However, the total tailings are then calculated as the difference between the feed and the final concentrates. In this case, the average feed is computed based on all the products presented in Table 13-11 and Table 13-15 below. For test no. 1 of the second procedure, the recovery is 83.6% for a final concentrate grade of 73.2% WO3. For test no. 2 of the second procedure, the recovery is 85.0% for a final concentrate grade of 62.4% WO₃. The similarity between the results of both procedures ensures the quality of the projections.

Table 13-11 – Results of LCT No. 1 – KIGAM (2019)

Table 13-12 – Cycle by Cycle Mass Balance for LCT No. 1 – KIGAM (2019)

Table 13-13 – Metallurgical Projection – LCT 1/ Procedure 1 – KIGAM (2019)

Table 13-14 – Metallurgical Projection – LCT 1/ Procedure 2 – KIGAM (2019)

Table 13-15 – Results of Locked Cycle Test No. 2 – KIGAM (2019)

Table 13-16 – Cycle by Cycle Mass Balance for LCT No. 2 – KIGAM (2019)

Table 13-17 – Metallurgical Projection for LCT No. 2 – Procedure 1

Table 13-18 – Metallurgical Projection for LCT No. 2 – Procedure 2

Pilot Plant Trials

In order to have a metallurgical projection in conditions more similar to those that will be found in practice in the future plant, and as a demand to get the process guaranties from Metso Outotec, several pilot plant trials were completed at the laboratories of LNEG in Porto, Portugal. For these particular campaigns, the ore was blasted in a development mine gallery in the F3 zone of the footwall of Sangdong Mine. Due to practical constraints, connected with the minimum volume for a pilot plant flotation cell, it was only possible to do four cleaning stages.

This section presents the results of the last pilot plant trials done in LNEG, in September 2023, based on which the process guaranties were granted. These last trials had a duration of four days, operating the pilot plant for a period of approximately 10 hours each day. Timed samples of the feed, sulphide concentrate, scheelite concentrate and tailings were collected on an hourly basis. During the last hour of operation, samples of all internal streams were carefully collected, so as not to disturb the circuit. All these samples were assayed in WO₃ at the TTC (see the list of streams in Table 13-19 below). Based on these assays, and on the flowrates estimated from the timed samples, it was possible, by writing the equations of mass balance, to compute the complete mass balance in terms of total mass and mass of WO3. In Table 13-20 below are given the mass balances for each day of operation. It is clear that during these four days the results here are very similar, with a slight tendency to get better in terms of recovery and concentrate grade, as the days passed. For day 1, the complete mass balance gave a recovery of 81.8% for a concentrate grade of 62.40% WO₃; for day 2, a recovery of 82.4% and a concentrate grade of 61.70% WO₃; for day 3, a recovery of 82.4% and a concentrate grade of 64.48% WO₃; and, for day 4, a recovery of 82.5% and a concentrate grade of 67.46% WO₃.

The pilot plant trial results indicate that the metallurgical projection is slightly worse than that from the locked cycle tests. However, the practical limitations imposed by LNEG’s pilot plant must be taken into consideration. Not only was the number of cleaning stages only four instead of five, which limited the final concentrate grade, but the aeration rate of the rougher and scavenger banks was deficient, which limited the recovery. The cells of these banks were old Denver no. 7 cells, of sub-A type, without the possibility of increasing the speed of the rotors. In this way, the metallurgical projection based on the locked cycle tests is considered more accurate and should be used in defining the economic model.

During 2025, as mentioned above, LNEG’s pilot plant is scheduled to explore the possibility of producing by-product concentrates of Mo and Bi/Au/Ag. It will also be given continuity to the effort of de-risking, by exploring other collectors recognized as suitable for scheelite flotation.

Table 13-19 – List of Streams for the Pilot Plant – LNEG (2023)

Table 13-20 – Mass Balance for Plant Trials – Days 1 - 4 – LNEF (2023)

Conclusion

Considering the results of all tests, it can be concluded that mill recovery will likely range from 83.6% to 85.0% and the final concentrate grade, considering the average between test no. 1 and test no. 2, will be around 67–68% WO₃.

For the current study, AKTC has decided to assume an overall global mill recovery of 85%, along with a concentrate grade of 65% WO₃.

Mineral Resource and Mineral Reserve Estimates

The evaluation work with respect to the Mineral Resource and Mineral Reserve estimates was carried out and prepared in compliance with NI 43-101. The Mineral Resources and Mineral Reserves in this estimate were calculated using the CIM Definition Standards prepared by the CIM Standing Committee on Reserve Definitions and adopted by the CIM Council on May 19, 2014.

Mineral Resource Estimate

The effective date of the Mineral Resource estimate is February 28, 2025.

The quantity, grade and quality of each category of Mineral Resources is indicated in Table 1-1 below.

Table 1-1 – Sangdong Mine – Mineral Resources

The key assumptions, parameters and methods used to estimate the Mineral Resources include: