Mr. Andrew Dinning reports

SARAMA FILES MEMORIAL IN US$242M DAMAGES CLAIM AGAINST BURKINA FASO

Sarama Resources Ltd. has filed its written memorial detailing the company's claim against the government of Burkina Faso (GoBF) as well as damages for the sum of $242-million (U.S.) plus interest.

The proceedings arise from the unlawful expropriation of the company's Tankoro 2 exploration permit in Burkina Faso and follow the submission of its request for arbitration (RFA) to the International Centre for Settlement of Investment Disputes (ICSID) in December, 2024 (refer news release dated Dec. 12, 2024).

On Oct. 31, 2025, Sarama filed its written memorial comprising its statement of case, witness evidence and expert reports with ICSID, a division of the World Bank Group, detailing the claim against the GoBF.

The company retained Accuracy London, a qualified and experienced quantum expert, to provide an independent valuation to support the claim submitted to ICSID.

Next steps

• The GoBF is required to file its counter-memorial by Jan. 31, 2026.
• A case management conference is scheduled for Feb. 17, 2026, during which the final procedural timetable will be determined and the date for the procedural hearing will be set.
• This will be followed by a series of further written submissions, after which a hearing will be held in Washington, D.C., United States, where Sarama will present its case and supporting evidence to the tribunal.

The company is represented by Boies Schiller Flexner (U.K.) LLP (BSF), a leading international law firm with significant experience in investor-state arbitration and a strong record in the natural resources sector and has a $4.4-million (U.S.) four-year non-recourse loan facility in place to cover all fees and expenses related to the claim.

Sarama's executive chairman, Andrew Dinning, commented:

"The filing of our memorial is a significant milestone in the arbitration process and provides a comprehensive and substantiated basis for Sarama's claim for compensation. The company has invested more than a decade of work and substantial capital in advancing the Sanutura project, which was unlawfully expropriated.

"We are pursuing this process to protect shareholder value and to seek a fair and just outcome under internationally recognized mechanisms. With our legal team, expert advisors and funding arrangements in place, we remain fully committed to advancing the arbitration to its conclusion."

Claim background and arbitration proceedings

In August, 2023, the company received official notification from Burkina Faso's Ministry of Energy, Mines and Quarries that its 100-per-cent-owned Tankoro 2 exploration permit, which had previously been approved nearly two years earlier, was retroactively rejected (refer to news release dated Sept. 5, 2023).

The permit covered the Tankoro deposit which hosts a multimillion-ounce gold resource and formed the core of the company's Sanutura project, a large-scale gold development located in the Hounde greenstone belt in southwest Burkina Faso. At the time of the expropriation, the company was nearing completion of a preliminary economic assessment for the development of a mine at the project. As a result of the expropriation, all project activities were suspended in Burkina Faso.

As a Canadian company, Sarama benefits from protections under the Canada-Burkina Faso Bilateral Investment Treaty (BIT) which came into force in 2017. Pursuant to the dispute resolution provisions of the BIT, the company issued a notice of intent to arbitrate to the GoBF in November, 2023 (refer news release dated Nov. 30, 2023), initiating a mandatory 60-day consultation period. The government did not respond or engage during this period.

In December, 2024, Sarama formally commenced international arbitration proceedings by filing its RFA with ICSID.

Arbitral panel constituted and first procedural hearing held

Sarama was advised by ICSID on June 23, 2025, that the three-member arbitral tribunal had been constituted. The tribunal comprises highly experienced arbitrators with significant and relevant multinational expertise in investor-state disputes (refer news release dated Aug. 5, 2025).

The first procedural hearing took place on July 25, 2025. During the hearing, the parties discussed key procedural matters and a preliminary timetable for the arbitration. The tribunal has formally issued procedural orders reflecting the discussions during the hearing.

Non-recourse litigation funding secured

In October, 2024, Sarama entered into a litigation funding agreement (LFA) with Locke Capital II LLC, a specialist dispute resolution funder (refer to news release dated Oct. 24, 2024). The LFA provides for a four-year, non-recourse loan facility of $4.4-million (U.S.) to cover all legal and arbitration-related costs associated with the claim. Security for the facility is limited to the claim and any resulting proceeds and benefits arising from the ownership chain relating to the Sanutura project. There is no recourse to the company's assets or operations outside of the project ownership structure.

Repayment of the facility is only required in the event of a successful claim, settlement or upon default under the LFA. If a material adverse change occurs, only unused funds are subject to repayment. The funder's return is contingent on the successful outcome and timing of the arbitration or settlement process.

Experienced legal representation

The company engaged BSF as legal counsel (refer news release dated Oct. 18, 2023). BSF is a leading international law firm with significant experience in investor-state arbitration and a strong record in the natural resources sector. The firm has successfully represented clients in mining-sector disputes, having successfully represented Australian listed Indiana Resources Ltd. (IDA) and GreenX Metals Ltd. (GRX) in similar expropriation claims, which resulted in substantial awards in favour of the claimants.

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