Contract analysis

I. INTRODUCTION AND PURPOSE 1.1 Background of the Consent Decree This Supplemental Environmental Project Description and Budget (this "SEP Description") is submitted in connection with the proposed consent decree in the multi-site enforcement action styled United States of America and State of Montana v. Torchlight Mining Corp., et al., Civil Action No. 9:24-cv-00087-DWM, pending in the United States District Court f

II. PROJECT DESCRIPTION 2.1 Overview The Project consists of the comprehensive upgrade of the existing municipal water treatment facility and associated distribution infrastructure serving the Town of Battle Mountain, Lander County, Nevada. Battle Mountain is an unincorporated community located along the Humboldt River corridor in north-central Nevada, with a population of approximately 3,600 residents. The community

III. PROJECT IMPLEMENTATION 3.1 Implementation Schedule The following table sets forth the anticipated implementation schedule for the Project. All milestone dates are measured from the Effective Date of the consent decree. The target Effective Date is June 14, 2025, which is 30 calendar days after the expected date of entry of the consent decree by the Court on May 15, 2025. The implementation schedule is subject to

IV. BUDGET 4.1 Total Project Budget The total budget for the Battle Mountain Community Drinking Water Improvement Project is $3,500,000. This amount represents the minimum financial commitment by Torchlight Mining Corp. for the Project, as required under the consent decree. The budget is structured to ensure full implementation of all five Project components, plus engineering and design, project management, and a con

V. REPORTING AND CERTIFICATION REQUIREMENTS 5.1 Progress Reports Torchlight Mining Corp. shall submit semi-annual progress reports to EPA Region 9 and to DOJ ENRD throughout the implementation of the Project. Progress reports shall be submitted to: • EPA Region 9: Attention Jennifer Whitfield, EPA Project Coordinator for the Bonanza Creek Gold Mine • DOJ ENRD: Attention Philip Orenstein, Lead Trial Attorney Each prog

VI. ENVIRONMENTAL AND PUBLIC HEALTH BENEFITS 6.1 Nexus to Bonanza Creek Violations The Project addresses drinking water quality concerns in the community closest to the Bonanza Creek Gold Mine, where multiple unpermitted releases of cyanide-bearing and mercury-laden process solutions occurred between 2022 and 2023. As described in Section 1.3 above, the Bonanza Creek facility is located approximately 28 miles south o

VII. LEGAL AND REGULATORY FRAMEWORK 7.1 Consent Decree Authority The Project is authorized under the consent decree entered in United States of America and State of Montana v. Torchlight Mining Corp., et al., Civil Action No. 9:24-cv-00087-DWM, in the United States District Court for the District of Montana, Missoula Division. The consent decree requires the Defendants to implement three Supplemental Environmental Pr

VIII. CONTACT INFORMATION 8.1 Torchlight Mining Corp. General Counsel: Miriam Soo-Hwan Park Torchlight Mining Corp. 750 Copper Ridge Boulevard, Suite 200 Helena, Montana 59601 Vice President, Environmental Health & Safety: Gareth Linford Torchlight Mining Corp. 750 Copper Ridge Boulevard, Suite 200 Helena, Montana 59601 Chief Financial Officer: Carolyn Bracebridge Torchlight Mining Corp. 1800 Bayfield Tower, 401 Bay

IX. CERTIFICATION AND SIGNATURES The undersigned, on behalf of Torchlight Mining Corp., hereby certify that the information contained in this Supplemental Environmental Project Description and Budget is true, accurate, and complete to the best of their knowledge and belief, and that Torchlight Mining Corp. commits to implement the Battle Mountain Community Drinking Water Improvement Project in accordance with the ter