# Clint Donkin Managing Director and Chief Executive Officer ## Career chronology - **From 5 October 2026: AIC Mines** — Managing Director and Chief Executive Officer. [Quarterly Activities Report for the Period Ending 30 September 2026]() (pp.1–2 and 20, safety, production and leadership) - **Before or during AIC tenure as described by the issuer; exact dates not determined in this audit: Kamoto Copper Company** — Managing Director. [Board and management]() (Relevant named person’s current issuer biography) ## Contributions and company outcomes ### Senior role at an operating copper business [donkin_kcc_delivery] May 2021 · issuer reported · medium materiality KCC identified Donkin as managing director during a May 2021 presidential visit and plant inauguration. This confirms a role, not an incremental production or investment-return contribution. **Attribution:** Role overlaps event; causation unproven. MD role and event overlap; no independent before/after performance attribution established. **Relevance:** Relevant operating exposure with incomplete measurable success evidence. [President’s visit and Luilu inauguration]() (13 May 2021 inauguration and managing-director identification) ## Fraud and corruption ### Glencore corporate guilty pleas; no Donkin link established [donkin_bribery_context] Historical conduct; May 2022 pleas · documented · medium materiality Glencore entities pleaded guilty in 2022 to bribery and market-manipulation conspiracies. DOJ describes conduct including 2007–2018 and DRC-related payments, but does not identify Donkin; his later Copper Africa role is not proof of involvement. **Attribution:** Employer context; no individual link established. Documented employer misconduct, with no personal allegation or participation established by the reviewed record. **Relevance:** Inherited control environment is relevant; this is not an individual fraud finding. [Glencore guilty pleas to bribery and market manipulation]() (DOJ plea and conduct dates); [Katanga Mining 2019 Management Discussion and Analysis]() (p.6, 29 October 2019 KCC appointment) ## Industrial safety ### Fatal excavator accident during KCC leadership period [donkin_kcc_fatality2021] 26 October 2021 · documented · high materiality A Glencore/KCC alert reports an excavator operator killed by a mudslide in Mashamba pit on 26 October 2021. Donkin is documented as KCC MD in May/July 2021 and March 2022. The alert says an independent investigation began and recommends ground, inrush and wet-weather control reviews; its final outcome was not located. **Attribution:** Role overlaps event; causation unproven. Leadership-period overlap is supported by dated records; no personal act, negligence or regulatory liability is established. Exact MD tenure boundaries and investigation findings remain unverified. **Relevance:** Material to safety-leadership assessment; final root cause, personal remit and verified corrective-action closure remain unestablished. [KCC safety alert: excavator engulfment fatality]() (p.1 incident and investigation); [President’s visit and Luilu inauguration]() (13 May 2021 managing director); [Investigation of KCC acid spills, including signed KCC response]() (p.39, signed response July 2021); [KCC management identified at March 2022 event]() (March 2022 managing director identification) ## Environmental record ### KCC acid spills and disputed community impacts [donkin_kcc_environment2021] March–April 2021 incidents; July 2021 company response; December 2021 NGO report · disputed · high materiality AFREWATCH reported acid spills on 16 March and 7 April 2021 and alleged community and environmental harm. In a July 2021 response signed by Donkin as KCC managing director, the company described containment and disputed aspects of the alleged impacts. The subsequent correspondence shows continuing disagreement; no final court disposition was verified. **Attribution:** Role overlaps event; causation unproven. His corporate-response role is documented; personal causation or negligence is not established. NGO allegations and company rebuttals remain separate from proven liability. **Relevance:** Material containment and stakeholder-oversight context; final disposition and independently verified remediation remain unestablished. [Investigation of KCC acid spills, including signed KCC response]() (pp.9–10, 39–45: incidents, allegation and company response) ### Later spill response remains disputed [donkin_kcc_spill_later] November 2023–January 2024 response to 2021 spills · disputed · medium materiality In November 2023 Glencore said a provincial agriculture assessment found no fish-farm impacts from the 2021 KCC spill and described a fish-farming pilot. RAID/AFREWATCH disputed that assessment in January 2024 and cited an earlier mining-authority report to a prosecutor. These later exchanges establish continued disagreement; they do not establish a final judgment or independently verified remediation. **Attribution:** Role overlaps event; causation unproven. Later statements concern an incident during Donkin’s documented leadership period. They do not establish his personal liability or continued tenure in the later correspondence. **Relevance:** Updates the incident status beyond the original NGO/company exchange while preserving responsibility limits. [Public company correspondence on DRC water pollution]() (PDF pp.130 and 138–139: Glencore response and NGO rebuttal); [Investigation of KCC acid spills, including signed KCC response]() (pp.39–45, company response) ## Governance and interests ### CEO and board appointments confirmed [donkin_transition] July–October 2026 · issuer reported · high materiality The July terms anticipated 31 October or earlier by agreement; the October quarterly confirms that Donkin became Managing Director and CEO on 5 October, the same day as the disclosed director appointment. **Attribution:** Individual involvement documented. AIC confirms CEO and board commencement on 5 October. **Relevance:** His role began after the September quarter; earlier AIC results cannot be attributed to his CEO tenure. [Quarterly Activities Report for the Period Ending 30 September 2026]() (pp.1–2 and 20, safety, production and leadership) ## Suitability for the current role ### Relevant copper-operation and technology leadership [donkin_operating_fit] Assessment at cutoff · analyst inference · high materiality Issuer descriptions of KCC, African copper, technology and JV roles are relevant to AIC operations; this review does not quantify production, capital return or safety improvements attributable to Donkin. **Attribution:** Responsibility not applicable. Role history supports suitability; individual performance attribution remains incomplete. **Relevance:** Relevant plant and integration experience; measured personal delivery outcomes remain incomplete. [Board and management]() (Relevant named person’s current issuer biography); [President’s visit and Luilu inauguration]() (May 2021 managing director) ## Evidence gaps - Detailed Ausenco chronology, degree and institutions are unverified; personal LinkedIn profile was rate-limited. - No complete independently attributed cost, capital-return or exposure-adjusted safety series for his tenure was established; the 2022 KCC output setback is now quantified at company level. - DRC local-language labour-dispute lead was not corroborated to a primary ruling; no personal adverse finding is made from it. - No exhaustive DRC court, sanctions or professional-register search performed. - Final investigation and regulator/court disposition for the October 2021 fatality not located in the targeted search. - Later 2023–2024 company/NGO exchanges were reviewed, but no final acid-spill judgment or independent verification of remediation was located. - Personal ownership of Katanga accounting-control remediation and external assurance of his specific changes were not established. - The second April 2021 spill is dated 7 April in the original AFREWATCH account and 4 April in its later correspondence; the reviewed records do not reconcile that difference. - Detailed delegated operating and safety authority at AIC and independently attributable post-appointment operating results are not established. - The prior dossier and its earlier search logs were preserved separately. Prior search execution and citations not re-opened in this audit were not treated as independently verified; omitted claims require fresh source-level review.