Clint Donkin

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

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

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

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

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

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

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

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.