Thank you for reaching to us and giving the opportunity to respond to the findings of your recent report ‘Digging in the Shadows’, particularly with regard to our Client, angezur Coper and Molybdenum Combine (ZCMC) in Armenia and the alleged human rights issues. We reviewed it with interest and shared concern and would like to inform you about the following...

The Bank noted at the due diligence stage that ZCMC is compliant with the applicable legal requirements in terms environment, labor and health and safety. The existing non-compliances were identified as immaterial and were duly resolved. The Company proved to making efforts to further develop and implement management systems in line with international good practices. Being a large employer ZCMC is continuously improving its health and safety practices and is supporting the local communities through various social activities and programs. BSTDB also noted that Kajaran Mine has been in operation for about seventy years and is located in an area that has a long history of mining activities that resulted in a number of legacy issues due to past pollution. In this respect the Combine initiated a number of studies and assessments to better understand the magnitude and significance of these issues and is implementing remediation and reclamation projects. The Artsvanik Tailings Storage Facility has been operational for the last forty years and was identified as one of the key issues associated with ZCMC due to past pollution and present risks of accidental discharges or dam failure. This problem requires complex and costly long-term remedy measures and to the best knowledge of BSTDB the Combine plans to discontinue the use of the tailings facility in the coming years and is considering shifting to dry stacking the tailings...

At the same time BSTDB noted that ZCMC needs to further improve its overall environmental and social performance by increasing the transparency of its operations and engaging proactively with its stakeholders...