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2026-11-06
◂ Monitor BCM ASX

Brazilian Critical Minerals Limited

DFS Unfunded Developer · Rare Earths · BR Rating locked: sign in to view v8.1 · bcm-20261031t153929-full
Last 2026-11-06
A$0.046
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Mkt cap
A$103.3M
EV
A$91.7M
Cash
A$12.2M
Debt
A$661.2K

People, delivery and responsibility

Management background checks

Evidence through 2026-10-31

Research assessment

Executive team

Rating locked: sign in to viewTeam rating and score are available to subscribers

Brazilian Critical Minerals combines an experienced mining executive, recently appointed finance executive external company secretary and technical advisers. The current scope of two additional technical figures remains uncertain. Ema has advanced to a feasibility study and FEED but remains pre-production and without committed project finance or offtake in the October quarterly. An ongoing disputed shareholder claim, historical environmental notices and contractor safety proceedings are company-level matters with unresolved outcomes; none establishes individual misconduct.

Decision-relevant facts

Material summary

Individual involvement and employer context shown separately

Andrew Reid

Managing Director

Current
Company SuccessIssuer Reported · High materiality

Wetar produced copper but output subsequently weakened

Finders reported 23,160 tonnes of copper cathode and A$56.3m net profit in 2017, its first full year of output. Its subsequent 2018 report described output collapsing in late 2017 and continued underperformance in 2018. Finders’ 2017 annual report dates Reid’s COO agreement from 1 June 2017; a secondary officer record lists his departure as 31 August 2018. Individual operational decisions remain unverified.

Role overlaps event; causation unproven · COO role overlaps the company outcomes according to the secondary tenure source; neither output nor deterioration establishes personal causal contribution.

FY2017 annual report · Chairman’s statement, operations
FY2018 annual report · Chairman’s letter, pp. 2–3
Former Finders officers · Former officers, Andrew Reid
FY2017 annual report · Remuneration report, executive services agreements: Reid agreement from 1 June 2017
Personal SuccessDocumented · Medium materiality

Kevitsa management role independently corroborated

BCM reports that Reid was general manager during Kevitsa’s 2011–14 construction, commissioning and transition into operations. Finnish public broadcaster Yle independently names him as former manager in July 2014; it does not quantify his personal contribution to mine construction or returns.

Individual involvement documented · Role corroborated by independent reporting; delivery and individual economic contribution are not independently quantified.

FY2026 annual report · printed p.20, Andrew Reid biography
Lapland mine expansion permission · Former manager paragraph
EnvironmentDisputed · High materiality

Brazil subsidiary contests historic forest-clearing notices

BCM’s FY2026 annual report says its Brazilian subsidiary received two January 2023 environmental infraction notices alleging unauthorised clearing. The company contests both and was awaiting a decision as of the report; it recorded an A$151,000 provision. The notices predate Reid’s 2024 managing-director appointment.

Employer context; no individual link established · The notices predate his BCM management role; no personal connection or fault is established.

FY2026 annual report · printed p.47, note 13(a), contingencies
FY2024 annual report · printed p.18, managing director appointment
LegalDisputed · High materiality

Drake loan-conversion allegations remain disputed

Drake alleged company breaches relating to loan conversion and security issuance. BCM disputes the allegations and says it will defend the matter; its October 2026 quarterly says July mediation did not resolve the proceedings. No decision on the merits was found in the reviewed sources.

Role overlaps event; causation unproven · The dispute concerns company actions during Reid’s management, not a finding of individual misconduct.

Writ of summons · p.1, writ and company response
SafetyIssuer Reported · High materiality

Brazil contractor safety claims await expert assessment

The FY2026 annual report says the Brazilian subsidiary received contractor labour lawsuits concerning work health and safety after contracts were terminated; hearings were adjourned pending expert assessment. No finding, dates of alleged conduct or personal involvement were established.

Employer context; no individual link established · The source reports proceedings and an expert process without attributing the underlying conduct to Reid.

FY2026 annual report · printed p.48, note 13(c)
EducationIssuer Reported · Medium materiality

Issuer-reported mining and economics qualifications

BCM reports a BSc in geology, postgraduate mining engineering qualifications and an MSc in mineral economics. The degrees and membership were not independently verified with institutions.

Responsibility not applicable · Educational claims are attributed to the issuer.

FY2026 annual report · printed p.20, qualifications
Evidence gaps · 4
  • Finders’ 2017 report confirms the COO agreement from 1 June 2017; the reported August 2018 departure and decision-making responsibilities are not independently established.
  • Final disposition of 2023 environmental notices and 2026 contractor safety proceedings unavailable in reviewed sources.
  • Drake merits decision and final remedy unavailable as at October 2026.
  • Degree and professional membership have not been independently confirmed.

Full background report

Andrew Reid

Managing Director

Career chronology

Education and qualifications

Issuer-reported mining and economics qualifications

undated · issuer reported · medium materiality

BCM reports a BSc in geology, postgraduate mining engineering qualifications and an MSc in mineral economics. The degrees and membership were not independently verified with institutions.

Attribution: Responsibility not applicable. Educational claims are attributed to the issuer.

Relevance: Relevant technical background, subject to credential verification.

FY2026 annual report (printed p.20, qualifications)

Personal achievements

Kevitsa management role independently corroborated

2011–2014 · documented · medium materiality

BCM reports that Reid was general manager during Kevitsa’s 2011–14 construction, commissioning and transition into operations. Finnish public broadcaster Yle independently names him as former manager in July 2014; it does not quantify his personal contribution to mine construction or returns.

Attribution: Individual involvement documented. Role corroborated by independent reporting; delivery and individual economic contribution are not independently quantified.

Relevance: Mining commissioning experience relevant to project delivery.

FY2026 annual report (printed p.20, Andrew Reid biography); Lapland mine expansion permission (Former manager paragraph)

Contributions and company outcomes

Wetar produced copper but output subsequently weakened

2017–2018 · issuer reported · high materiality

Finders reported 23,160 tonnes of copper cathode and A$56.3m net profit in 2017, its first full year of output. Its subsequent 2018 report described output collapsing in late 2017 and continued underperformance in 2018. Finders’ 2017 annual report dates Reid’s COO agreement from 1 June 2017; a secondary officer record lists his departure as 31 August 2018. Individual operational decisions remain unverified.

Attribution: Role overlaps event; causation unproven. COO role overlaps the company outcomes according to the secondary tenure source; neither output nor deterioration establishes personal causal contribution.

Relevance: Relevant mining-operations experience, tempered by a documented operating setback.

FY2017 annual report (Chairman’s statement, operations); FY2018 annual report (Chairman’s letter, pp. 2–3); Former Finders officers (Former officers, Andrew Reid); FY2017 annual report (Remuneration report, executive services agreements: Reid agreement from 1 June 2017)

Industrial safety

Brazil contractor safety claims await expert assessment

disclosed September 2026 · issuer reported · high materiality

The FY2026 annual report says the Brazilian subsidiary received contractor labour lawsuits concerning work health and safety after contracts were terminated; hearings were adjourned pending expert assessment. No finding, dates of alleged conduct or personal involvement were established.

Attribution: Employer context; no individual link established. The source reports proceedings and an expert process without attributing the underlying conduct to Reid.

Relevance: Requires context when assessing operational safety and contractor oversight.

FY2026 annual report (printed p.48, note 13(c))

Environmental record

Brazil subsidiary contests historic forest-clearing notices

2023–September 2026 · disputed · high materiality

BCM’s FY2026 annual report says its Brazilian subsidiary received two January 2023 environmental infraction notices alleging unauthorised clearing. The company contests both and was awaiting a decision as of the report; it recorded an A$151,000 provision. The notices predate Reid’s 2024 managing-director appointment.

Attribution: Employer context; no individual link established. The notices predate his BCM management role; no personal connection or fault is established.

Relevance: An ongoing environmental and licensing matter is relevant to management oversight.

FY2026 annual report (printed p.47, note 13(a), contingencies); FY2024 annual report (printed p.18, managing director appointment)

Litigation and enforcement

Drake loan-conversion allegations remain disputed

November 2025–October 2026 · disputed · high materiality

Drake alleged company breaches relating to loan conversion and security issuance. BCM disputes the allegations and says it will defend the matter; its October 2026 quarterly says July mediation did not resolve the proceedings. No decision on the merits was found in the reviewed sources.

Attribution: Role overlaps event; causation unproven. The dispute concerns company actions during Reid’s management, not a finding of individual misconduct.

Relevance: Relevant to governance and potential capital-structure uncertainty.

Writ of summons (p.1, writ and company response); September 2026 quarterly activities and cash flow report (p.4, shareholder legal action)

Suitability for the current role

Operating background relevant to a pre-production developer

assessment at 31 October 2026 · analyst inference · medium materiality

His reported rare-earth study and COO background, plus independently corroborated Kevitsa management, are relevant to advancing Ema. Ema’s BFS and FEED are development milestones, not proof of production, financing or successful construction.

Attribution: Responsibility not applicable. This is an assessment, not a measured personal track record on Ema construction.

Relevance: Separates relevant expertise from uncompleted project execution.

Investor presentation (senior management slide, Andrew Reid); Lapland mine expansion permission (Former manager paragraph); September 2026 quarterly activities and cash flow report (p.1, highlights)

Evidence gaps

  • Finders’ 2017 report confirms the COO agreement from 1 June 2017; the reported August 2018 departure and decision-making responsibilities are not independently established.

  • Final disposition of 2023 environmental notices and 2026 contractor safety proceedings unavailable in reviewed sources.

  • Drake merits decision and final remedy unavailable as at October 2026.

  • Degree and professional membership have not been independently confirmed.

Justine Lea

Chief Financial Officer

Current
Company SuccessIssuer Reported · High materiality

Emeco completed debt restructure but wrote off goodwill

Emeco completed its March 2017 debt restructuring and combinations with Andy’s and Orionstone; its FY2017 report states the resulting A$77.9m acquisition goodwill was fully impaired at year-end. Lea was appointed CFO in October 2016. The refinancing involved the board, management, advisers and creditors.

Role overlaps event; causation unproven · Her CFO role overlaps both the transaction and reported accounting outcome; no individual responsibility or misconduct is established.

Emeco FY2017 annual report · Chairman’s report and operations review, balance sheet restructure
Company SuccessIssuer Reported · Medium materiality

Podium CFO and later strategic-role transition

Podium appointed Lea CFO effective 14 September 2022. In October 2025 it appointed a new CFO and said she would move to a part-time strategic role; it cited a A$12m capital raise and research flowsheet milestone. Project progress is not commercial production.

Role overlaps event; causation unproven · Her finance role overlaps the period; issuer praise is not independent attribution of the fundraising outcome.

EducationIssuer Reported · Medium materiality

Accounting qualifications reported by issuers

BCM reports a University of Western Australia commerce degree, Chartered Accountant status and AICD graduate status; Podium independently reported a commerce degree, Chartered Accountant and graduate status in its announcement. Neither is a direct confirmation by the credentialing bodies.

Responsibility not applicable · Both are issuer biographies; independent institutional verification unavailable.

Podium appoints CFO · p.1, appointment biography
Role FitAnalyst Inference · Medium materiality

Finance capability relevant to funding Ema

Documented prior CFO appointments and Emeco’s completed restructuring are relevant to project financing; BCM’s July placement was announced before Lea joined, and the Ema funding and offtake discussions remained uncompleted at the October quarterly.

Responsibility not applicable · The fit assessment is inferred from prior roles; no personal credit is claimed for BCM’s pre-appointment placement.

Evidence gaps · 4
  • Exact Emeco integration-officer appointment and exit dates not independently verified.
  • Podium strategic role continuation after October 2025 not verified.
  • Independent verification of degree and current professional memberships unavailable.
  • Personal contribution to restructuring and performance not independently quantified.

Full background report

Justine Lea

Chief Financial Officer

Career chronology

Education and qualifications

Accounting qualifications reported by issuers

2022–2026 · issuer reported · medium materiality

BCM reports a University of Western Australia commerce degree, Chartered Accountant status and AICD graduate status; Podium independently reported a commerce degree, Chartered Accountant and graduate status in its announcement. Neither is a direct confirmation by the credentialing bodies.

Attribution: Responsibility not applicable. Both are issuer biographies; independent institutional verification unavailable.

Relevance: Relevant to financial reporting and project funding.

Appointment of chief financial officer (p.1, biography); Podium appoints CFO (p.1, appointment biography)

Contributions and company outcomes

Emeco completed debt restructure but wrote off goodwill

2016–2017 · issuer reported · high materiality

Emeco completed its March 2017 debt restructuring and combinations with Andy’s and Orionstone; its FY2017 report states the resulting A$77.9m acquisition goodwill was fully impaired at year-end. Lea was appointed CFO in October 2016. The refinancing involved the board, management, advisers and creditors.

Attribution: Role overlaps event; causation unproven. Her CFO role overlaps both the transaction and reported accounting outcome; no individual responsibility or misconduct is established.

Relevance: Substantive financing experience with a mixed measured company outcome.

Chief financial officer appointed (p.1, appointment); Emeco FY2017 annual report (Chairman’s report and operations review, balance sheet restructure)

Podium CFO and later strategic-role transition

September 2022–October 2025 · issuer reported · medium materiality

Podium appointed Lea CFO effective 14 September 2022. In October 2025 it appointed a new CFO and said she would move to a part-time strategic role; it cited a A$12m capital raise and research flowsheet milestone. Project progress is not commercial production.

Attribution: Role overlaps event; causation unproven. Her finance role overlaps the period; issuer praise is not independent attribution of the fundraising outcome.

Relevance: Relevant pre-production finance and governance experience.

Podium appoints CFO (p.1); Executive leadership transition (p.1)

Suitability for the current role

Finance capability relevant to funding Ema

31 October 2026 · analyst inference · medium materiality

Documented prior CFO appointments and Emeco’s completed restructuring are relevant to project financing; BCM’s July placement was announced before Lea joined, and the Ema funding and offtake discussions remained uncompleted at the October quarterly.

Attribution: Responsibility not applicable. The fit assessment is inferred from prior roles; no personal credit is claimed for BCM’s pre-appointment placement.

Relevance: Relevant to the next phase while preserving timing and execution uncertainty.

Appointment of chief financial officer (p.1); September 2026 quarterly activities and cash flow report (pp.1 and 4); Chief financial officer appointed (p.1)

Evidence gaps

  • Exact Emeco integration-officer appointment and exit dates not independently verified.

  • Podium strategic role continuation after October 2025 not verified.

  • Independent verification of degree and current professional memberships unavailable.

  • Personal contribution to restructuring and performance not independently quantified.

Ben Donovan

Company Secretary

Current
GovernanceIssuer Reported · Medium materiality

Disclosed Argus fees during former director term

BCM’s FY2025 annual report says Argus Corporate Partners, an entity related to Donovan, received A$30,000 for company-secretarial services during the period he was a director from 28 November 2024 to 29 May 2025. BCM said the transactions were on normal commercial terms. The disclosure is not evidence of improper conduct.

Individual involvement documented · Directorship and related-party fees are company-disclosed; no conflict breach or improper fee is established.

FY2025 annual report · directors report p.21 and related-party transactions note
EducationIssuer Reported · Medium materiality

Governance qualifications reported by BCM and Basin

BCM reports commerce and finance qualifications and Governance Institute membership. Basin’s 2023 annual report also describes him as a chartered secretary and associate member. The institutions and present membership were not independently verified.

Responsibility not applicable · Issuer reports are not verification from a professional body.

FY2026 annual report · printed p.21, company secretary
Basin Energy 2023 annual report · printed p.12, Donovan biography
Role FitAnalyst Inference · Medium materiality

Company-secretarial experience spans multiple issuers

BCM and Basin disclose Donovan’s company secretary roles and BCM reports prior ASX senior-adviser experience. His concurrent outside mandates create a time-capacity consideration; no governance failure is established by the number of roles.

Responsibility not applicable · Comparative capacity is an analytical consideration, not a documented failure.

FY2026 annual report · printed p.21, company secretary
Basin Energy 2023 annual report · printed p.12, company secretary
Evidence gaps · 3
  • BCM secretary appointment date and full current outside mandate list unconfirmed.
  • Independent degree and current professional membership verification unavailable.
  • Individual contributions to company outcomes and actual time commitment not quantified.

Full background report

Ben Donovan

Company Secretary

Career chronology

Education and qualifications

Governance qualifications reported by BCM and Basin

2023–2026 · issuer reported · medium materiality

BCM reports commerce and finance qualifications and Governance Institute membership. Basin’s 2023 annual report also describes him as a chartered secretary and associate member. The institutions and present membership were not independently verified.

Attribution: Responsibility not applicable. Issuer reports are not verification from a professional body.

Relevance: Relevant governance skills but subject to credential checks.

FY2026 annual report (printed p.21, company secretary); Basin Energy 2023 annual report (printed p.12, Donovan biography)

Governance and interests

Disclosed Argus fees during former director term

28 November 2024–29 May 2025 · issuer reported · medium materiality

BCM’s FY2025 annual report says Argus Corporate Partners, an entity related to Donovan, received A$30,000 for company-secretarial services during the period he was a director from 28 November 2024 to 29 May 2025. BCM said the transactions were on normal commercial terms. The disclosure is not evidence of improper conduct.

Attribution: Individual involvement documented. Directorship and related-party fees are company-disclosed; no conflict breach or improper fee is established.

Relevance: Related-party disclosure provides context for governance oversight.

FY2025 annual report (directors report p.21 and related-party transactions note)

Suitability for the current role

Company-secretarial experience spans multiple issuers

2023–2026 · analyst inference · medium materiality

BCM and Basin disclose Donovan’s company secretary roles and BCM reports prior ASX senior-adviser experience. His concurrent outside mandates create a time-capacity consideration; no governance failure is established by the number of roles.

Attribution: Responsibility not applicable. Comparative capacity is an analytical consideration, not a documented failure.

Relevance: Relevant to disclosure and listing-rule administration.

FY2026 annual report (printed p.21, company secretary); Basin Energy 2023 annual report (printed p.12, company secretary)

Evidence gaps

  • BCM secretary appointment date and full current outside mandate list unconfirmed.

  • Independent degree and current professional membership verification unavailable.

  • Individual contributions to company outcomes and actual time commitment not quantified.

Edmar Medeiros

Technical Manager (recent secondary listing; current status unconfirmed)

Current
Personal SuccessIssuer Reported · Medium materiality

Named technical manager and report contributor

BBX announced the appointment of chemical engineer Edmar Medeiros as technical manager in July 2020, and its 2024 Três Estados statement identifies him as a test-result compiler. A secondary profile updated in October 2026 still lists that title; the current mandate was not confirmed by a dated recent issuer release.

Individual involvement documented · The named roles and contribution are issuer-reported; personal economic performance is not measured.

BBX FY2021 annual report · printed p.11, corporate activities
Final Três Estados bioleach report · p.3, competent person statement
BCM company profile and key executives · Key executives and last-updated date
FailureIssuer Reported · Medium materiality

Earlier bioleach work and a disputed supplier invoice

The FY2026 report says the Brazilian subsidiary could not replicate the supplier’s bacterial-leaching results in Brazil, terminated the licence in June 2024, and disputes a US$350,000 supplier invoice. The annual report does not identify who made the technical or commercial decisions.

Role overlaps event; causation unproven · Technical-manager involvement is documented in 2024; no personal failure, contractual fault or decision is established.

Final Três Estados bioleach report · p.3, technical manager
FY2026 annual report · printed p.48, note 13(b)
Role FitAnalyst Inference · Medium materiality

Chemical-engineering and processing background

Issuer statements identify a chemical engineer in a technical and assay role, relevant to metallurgical work. The plant’s commercial-scale project outcome and individual contribution remain unproven.

Responsibility not applicable · Analyst inference from reported role, not a claim of production delivery.

Evidence gaps · 3
  • No dated issuer confirmation of continued technical-management role after January 2024; recent third-party list may be stale.
  • Full prior employment, degree-awarding institution, and independent professional credentials not established.
  • The source does not attribute company bioleach or litigation outcome personally; original supplier and court records unavailable.

Full background report

Edmar Medeiros

Technical Manager (recent secondary listing; current status unconfirmed)

Career chronology

Personal achievements

Named technical manager and report contributor

2020–2026 · issuer reported · medium materiality

BBX announced the appointment of chemical engineer Edmar Medeiros as technical manager in July 2020, and its 2024 Três Estados statement identifies him as a test-result compiler. A secondary profile updated in October 2026 still lists that title; the current mandate was not confirmed by a dated recent issuer release.

Attribution: Individual involvement documented. The named roles and contribution are issuer-reported; personal economic performance is not measured.

Relevance: Evidence of processing and testing involvement, with current role uncertain.

BBX FY2021 annual report (printed p.11, corporate activities); Final Três Estados bioleach report (p.3, competent person statement); BCM company profile and key executives (Key executives and last-updated date)

Business failures and setbacks

Earlier bioleach work and a disputed supplier invoice

2023–2026 · issuer reported · medium materiality

The FY2026 report says the Brazilian subsidiary could not replicate the supplier’s bacterial-leaching results in Brazil, terminated the licence in June 2024, and disputes a US$350,000 supplier invoice. The annual report does not identify who made the technical or commercial decisions.

Attribution: Role overlaps event; causation unproven. Technical-manager involvement is documented in 2024; no personal failure, contractual fault or decision is established.

Relevance: Relevant to assessing prior processing technology development.

Final Três Estados bioleach report (p.3, technical manager); FY2026 annual report (printed p.48, note 13(b))

Suitability for the current role

Chemical-engineering and processing background

31 October 2026 · analyst inference · medium materiality

Issuer statements identify a chemical engineer in a technical and assay role, relevant to metallurgical work. The plant’s commercial-scale project outcome and individual contribution remain unproven.

Attribution: Responsibility not applicable. Analyst inference from reported role, not a claim of production delivery.

Relevance: Relevant to process development.

BBX FY2021 annual report (printed p.11); Final Três Estados bioleach report (p.3)

Evidence gaps

  • No dated issuer confirmation of continued technical-management role after January 2024; recent third-party list may be stale.

  • Full prior employment, degree-awarding institution, and independent professional credentials not established.

  • The source does not attribute company bioleach or litigation outcome personally; original supplier and court records unavailable.

Antonio de Castro

Senior Consulting Geologist (external)

Current
Personal SuccessIssuer Reported · Medium materiality

Named Ema competent person and technical contributor

BCM’s 2026 disclosures identify Antonio de Castro as a senior consulting geologist through ADC Geologia and name him as a competent person for its Ema exploration disclosures. Axel’s 2025 appointment release credits him with a key role in Ema discovery and resource definition; this attribution is an issuer statement.

Individual involvement documented · Named competent-person responsibility is documented; the precise share of discovery credit is issuer-reported and not independently quantified.

FY2026 annual report · printed p.15, competent person statement
Management and technical team changes · p.2, Antonio de Castro biography
GovernanceDocumented · Medium materiality

Concurrent external geological mandates

BCM describes de Castro as an external senior consulting geologist through ADC Geologia, while Axel REE appointed him consulting chief geologist in May 2025. Third-party profiles label him BCM exploration manager, a title not confirmed in current primary records.

Individual involvement documented · Concurrent consulting relationships are disclosed; no conflict or breach is established.

December 2025 quarterly report · p.12, competent person statement
Management and technical team changes · pp.1–2, consulting appointment
EducationIssuer Reported · Medium materiality

Geology credentials reported by sources

BCM states BSc (Hons), AusIMM and CREA affiliations in its competent-person statement; a business profile reports a Federal University of Rio de Janeiro degree. Neither is direct institutional confirmation.

Responsibility not applicable · Reported qualifications are unverified by the issuing bodies.

December 2025 quarterly report · p.12, competent person statement
Antonio de Castro biography · biography and qualifications
Role FitAnalyst Inference · Medium materiality

Relevant experience with external-client commitments

His documented role in Ema technical reporting and background as described by Axel support geological fit, while externally provided services mean title, ongoing scope and time allocation remain uncertain.

Responsibility not applicable · Fit is inference; no unverified technical claims or individual resource value are assigned.

Management and technical team changes · p.2, geologist biography
FY2026 annual report · printed p.15
Evidence gaps · 4
  • BCM management authority and current contract scope beyond the FY2026 report were not independently established; third-party exploration-manager designation differs from issuer consulting title.
  • Original discovery records and personal contribution beyond issuer statements not independently quantified.
  • Degree and professional membership not independently verified.
  • Brazilian name-search results could not be attributed given namesakes; court record details remain unverified.

Full background report

Antonio de Castro

Senior Consulting Geologist (external)

Career chronology

Education and qualifications

Geology credentials reported by sources

2025–2026 · issuer reported · medium materiality

BCM states BSc (Hons), AusIMM and CREA affiliations in its competent-person statement; a business profile reports a Federal University of Rio de Janeiro degree. Neither is direct institutional confirmation.

Attribution: Responsibility not applicable. Reported qualifications are unverified by the issuing bodies.

Relevance: Relevant to geological reporting, subject to independent checks.

December 2025 quarterly report (p.12, competent person statement); Antonio de Castro biography (biography and qualifications)

Personal achievements

Named Ema competent person and technical contributor

2024–2026 · issuer reported · medium materiality

BCM’s 2026 disclosures identify Antonio de Castro as a senior consulting geologist through ADC Geologia and name him as a competent person for its Ema exploration disclosures. Axel’s 2025 appointment release credits him with a key role in Ema discovery and resource definition; this attribution is an issuer statement.

Attribution: Individual involvement documented. Named competent-person responsibility is documented; the precise share of discovery credit is issuer-reported and not independently quantified.

Relevance: Relevant experience in Brazilian exploration and technical reporting.

FY2026 annual report (printed p.15, competent person statement); Management and technical team changes (p.2, Antonio de Castro biography)

Governance and interests

Concurrent external geological mandates

2025–2026 · documented · medium materiality

BCM describes de Castro as an external senior consulting geologist through ADC Geologia, while Axel REE appointed him consulting chief geologist in May 2025. Third-party profiles label him BCM exploration manager, a title not confirmed in current primary records.

Attribution: Individual involvement documented. Concurrent consulting relationships are disclosed; no conflict or breach is established.

Relevance: Important context for technical capacity and independence.

December 2025 quarterly report (p.12, competent person statement); Management and technical team changes (pp.1–2, consulting appointment); BCM company profile and key executives (Key executives)

Suitability for the current role

Relevant experience with external-client commitments

31 October 2026 · analyst inference · medium materiality

His documented role in Ema technical reporting and background as described by Axel support geological fit, while externally provided services mean title, ongoing scope and time allocation remain uncertain.

Attribution: Responsibility not applicable. Fit is inference; no unverified technical claims or individual resource value are assigned.

Relevance: Relevant to project technical oversight.

Management and technical team changes (p.2, geologist biography); FY2026 annual report (printed p.15)

Evidence gaps

  • BCM management authority and current contract scope beyond the FY2026 report were not independently established; third-party exploration-manager designation differs from issuer consulting title.

  • Original discovery records and personal contribution beyond issuer statements not independently quantified.

  • Degree and professional membership not independently verified.

  • Brazilian name-search results could not be attributed given namesakes; court record details remain unverified.