[Translation prepared by Business & Human Rights Resource Centre]

Criminal complaint for "Crvenih Stijena" - Illegal landfill of excavations from Rupice heavy metals mine, 22 June 2023

NGG Nature Park Trstionica and Boriva filed a criminal complaint against the responsible persons and employees of Adriatic Metals BH (under the former name: Eastern Mining) d.o.o. Vareš; responsible persons in legal entities: Adriatic Metals Plc and TQM Lukavac and responsible persons and employees as well as the Minister of the Federal Ministry of Environment and Tourism.

...[T]hese persons formed a dump of excavations from the Rupica heavy metal mine in the area of the Crvena stijene locality before the finality of the Decision.

The above-mentioned persons presented false information as true, for the purpose of obtaining an environmental permit for the disposal of "non-hazardous" waste.

Further, the criminal complaint was also filed for falsifying data on biodiversity and watercourses in such a way that they denied the existence of many streams near the planned disposal site and which are threatened by pollution, which are potable mountain streams, and in such a way that they denied the existence of endangered and protected species on the same locality.

...[T]he activists brought evidence of an illegally built wide industrial road to the detriment of the forest that they cut down, damaged the surrounding trees, removed the coast and caused the appearance of smaller landslides, covered the trees on the downhill with a large amount of excavation.

...[T]he animals in this locality are endangered and fleeing from their habitats, for which there is also material evidence...