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Announcement regarding recent videos of the news on TV 24

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November 30, 2022
After reviewing the videos of the news on TV24, report by the journalists Stojancho Micevski and Aleksandar Todeski entitled “One of the two directors of the Bucim mine on the black list of the USA” released on November 26, 2022 and “Kudryakov is still in the Central Registry of Bucim, the company says that he has been dismissed ” posted on November 28, 2022, please see the below point by point factual corrections. After reviewing this, we respectfully request that this be corrected in the public record. We reserve all rights. Claim One of the two directors of the Bucim mine in Radovish is on the US blacklist – the State Department suspects Dimitry Kudryakov of Russian influence and corrupt schemes in Guatemala. Bucim says that he has been suspended. Officially, Kudryakov still appears as the manager of Bucim. Response Dmitry Kudryakov was immediately suspended as of November 18, 2022, the date that Solway learned of the US sanctions. The resolution for his recall from position as Managing Director was delivered to the Bucim for proceeding in the Central Registry of North Macedonia which .official procedure takes up to 5 working days. All the required suspension procedures were completed accordingly, and on 29th of November the change was effected in the Central Registry. Claim Dmitry Kudryakov is represented as the leader of the Russian operations of Solway in Guatemala, who, together with the Belarussian citizen Iryna Litviniuk, for years led schemes for bribery, support for corruption, misuse of state funds, in which judges, government representatives were involved. Response We reiterate that Solway Investment Group is not a Russian company, is not owned by Russian citizens and does not have any business relations with Russia. As early as 3 March 2022, Solway clearly stated its position against the war in Ukraine and announced and ultimately completed its withdrawal from its only two investments and operational projects in Russia at the time which represented less than 10% of the global operations of Solway Solway’s subsidiaries in Guatemala Compania Guatemalteca de Niquel SA (CGN), Compania Procesadora de Niquel de Isabal SA (Pronico), are not and have never been owned or controlled in whole or in part by either of the two individuals mentioned as sanctioned. These entities and Solway are not owned, associated or affiliated with the Russian state government. Only one out of the two managers sanctioned by the US was employed in North Macedonia and he is suspended as of November 18, 2022, as referenced above. Importantly, the US sanction deals with Guatemala and does not reference any activity in Macedonia. Solway has engaged lawyers and investigators to investigate the allegations in the sanctions and is doing a top to bottom and bottom to top independent review of its anti-corruption compliance systems. Solway has zero tolerance for bribery, corruption or any manner of breaking the laws of the countries where Solway operates. Employees, officers and directors of Bucim and Borov Dol take this matter very seriously and believe in strict compliance with all government laws in the conduct of our businesses. Through the U.S. law firm Seiden Law Group LLP we are fully cooperating with the US government. It is actively investigating the facts and circumstances that gave rise to the alleged conduct by the now-suspended employee related to their sanctions and is instituting measures to ensure full compliance with the sanctions and investigation of any of the alleged conduct referenced in the sanctions. Claim It is noted that Solway through the subsidiary Bucim stated that Dmitriy was suspended immediately on 18.11.2022 and is no longer employed by the Group and its subsidiaries. Response We note that Solway is not sanctioned and is in the process of working with the US to have a transparent and amicable resolution to this matter as soon as legally possible. By resolution of Bucim’s shareholders Dmitriy Kudryakov was officially revoked from any connection with Bucim, including his previous position of manager of Bucim. The official changes in current standing were effected on 29th of Novemebr. Claim It was stated that no answer was provided to the question whether Kudryakov operated from Macedonia. (Is Kudryakov on some position in your companies in Guatemala, or was he operating from Macedonia, according to the US Department of the Treasury) Response Dmitry Kudryakov has been working in North Macedonia only since June 2021. And he was permanently in Guatemala and began to periodically stay in North Macedonia only from August 2021. His stay in Macedonia was less than 180 days during the year. Claim The recent meeting with the President of the Chamber of Commerce and the President of the Macedonian Mining Association is mentioned, in connection with the energy crisis. In the narrative it mentions that Dmitry Kudryakov was leading the negotiation in the name of Bucim and Borov Dol. Response No evidence has been presented raising suspicion at this time. Solway will investigate any matter brought to its attention that involves improper conduct. High price of electricity is the main issue for all production capacities in Macedonia. Finding a solution for acceptable price range for electricity at this time is the main task for every company. In this way Bucim, as the main consumer of electricity in production process Bucim and Borov Dol, together with President of Chamber of Commerce as leading Chamber in Macedonia and Macedonia Mining Association are seeking all possible solutions for electricity price reduction which is common practice of cooperation worldwide. Claim Mining secrets publications and allegations related to bank transfers of 1,9 bln USD with Estonian banks Response The report prepared by Clifford Chance law firm indicates that at first Clifford Chance started investigating all accounts assigned to non-Estonian residents and off-shore companies. Companies mentioned in the articles could have been indicated as high-risk companies by the initial investigation according to these criteria. As far as we know none of these companies or the shareholders were included in the final Clifford Chance report. Claim Kudraykov is not unknown in the mining sector in Macedonia, he was the general director of the SASA mine since 2006 when the owner of the mine was the company Solway Investment Group, the current owner of Bucim. He returned to the country last year, as the economic director of Bucim, after he was previously delegated to Guatemala, where he is suspected of conducting several schemes for Russian influence with the Belarusian citizen Irina Litvinyuk, in which, according to the State Department, politicians, judges and government officials were involved. Response Dmitriy Kudryakov was appointed as Managing Director of Bucim in June, 2021. His area of responsibility included only technological issues of the mine, and he has never been economic director of Bucim. His responsibility as Managing director of company is stated in articles of Trade Companies Law of Macedonia and describe in the Foundation Statement of Bucim which is public document and is available in Central Registry of North Macedonia.

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