Berkeley Energia Limited

Career chronology

• Earlier career; exact dates not stated: WMC Resources Limited — Senior management positions. Annual Report 2026 (Directors’ Report biography / current management page; see source locator)

• Through ARMZ acquisition in 2011; exact start date not stated: Mantra Resources Limited — Founding Managing Director; later leadership/director roles. Annual Report 2026 (Directors’ Report biography / current management page; see source locator)

• Prior to or during Berkeley career; exact dates not stated: Papillon Resources Limited — Director/executive leadership roles. Annual Report 2026 (Directors’ Report biography / current management page; see source locator)

• Director since 27 April 2012; Executive Director appointment letter dated 6 March 2026; current issuer page identifies Acting MD: Berkeley Energia Limited — Director; Executive Director from 2026; Acting Managing Director. Directors & Management (Directors’ Report biography / current management page; see source locator)

Contributions and company outcomes

Mantra Resources growth and acquisition

Mantra tenure through 2011 · issuer reported · medium materiality

Berkeley’s FY2026 annual report says Behets was instrumental in Mantra Resources’ founding, growth and development through its 2011 ARMZ acquisition for approximately A$1 billion. The issuer biography directly attributes a role to him, but the reported sale price is an employer outcome, not a measure of his personal return or the operating performance of Berkeley.

Attribution: Individual involvement documented. The issuer directly describes Behets’ founding/development contribution; no claim that he alone caused the acquisition or that it establishes current Salamanca execution.

Relevance: Relevant evidence of resource-company formation and transaction experience, though distinct from developing an operational mine.

Annual Report 2026 (Directors’ Report, Robert Behets biography, printed p. 14); Directors & Management (Robert Behets biography)

Litigation and enforcement

Salamanca permitting setbacks and unresolved arbitration

2021–2027 (arbitration unresolved at cutoff) · documented · medium materiality

Berkeley’s FY2026 annual report states that Spain rejected the Nuclear Safety Council II application in 2021, Spanish courts in December 2023 nullified the urbanisation and exceptional-use authorisations after appeals by Stop Uranio and the Villavieja de Yeltes council, and several other permits were challenged. BEL’s February 2026 ICSID memorial seeks US$1.25bn; Spain’s jurisdiction objections will be heard first, scheduled for mid-2027. These are company allegations and adverse project judgments, not a final arbitration finding. No individual wrongdoing is alleged. Behets has long board tenure and current acting MD role, but specific responsibility for permit failures is not documented.

Attribution: Role overlaps event; causation unproven. Long director tenure and current Acting MD role overlap governance oversight, but the filings do not establish his personal decisions caused permit outcomes.

Relevance: Material company-level legal, permitting and project delivery risk for the Acting MD.

Annual Report 2026 (Directors’ Report, business risks—arbitration and permits, printed pp. 9–11); Directors & Management (Current title; Acting Managing Director)

Suitability for the current role

Role fit remains only partly evidenced

Current appointment through 2026-10-09 · analyst inference · low materiality

2026 annual report records B.Sc. (Hons), FAusIMM and MAIG; Berkeley biography documents geology career. Awarding university and current membership register checks were not completed. Role-fit inference: relevant disclosed experience for Acting Managing Director is supported; professional background does not negate separately documented governance findings or establish successful production.

Attribution: Responsibility not applicable. This is an analytical role-fit assessment; it does not allege responsibility for outcomes.

Relevance: Relevant to current Executive Director duties at Berkeley Energia Limited.

Annual Report 2026 (Directors’ Report, individual biography and qualifications, printed p. 14–15)

Evidence gaps

• Exact dates and independent corroboration of several pre-Berkeley employer roles are not provided in the cited biographies.

• Academic credentials and professional memberships are issuer-reported and were not independently verified with institutions or registers.

• The open-web and regulatory/court queries logged here are scoped research, not exhaustive criminal, sanctions, litigation, credential or reference checks.

• The Salamanca project’s permit status and arbitration remain unresolved at the 9 October 2026 cutoff; no arbitration award or final resolution of the permitting dispute was located.

• Company outcomes and role overlap are not proof of individual causation; the sanctioned conduct is specifically limited to Bellón and the CNMV decision.

Career chronology

• More than ten years before Berkeley; exact dates not stated: Rio Narcea Gold Mines — Senior management; operations director and general manager at Aguablanca; roles on mine development/construction/commissioning/operations. Annual Report 2026 (Directors’ Report biography / current management page; see source locator)

• After Rio Narcea and before 2011 Berkeley appointment; exact dates not disclosed: Duro Felguera — Mining Director, project management/construction/commissioning. Annual Report 2026 (Directors’ Report biography / current management page; see source locator)

• Joined 2011; promoted COO 2017; remained COO after stepping down as Berkeley board director in April 2024: Berkeley Energia Limited / Berkeley Minera España — General Manager of Operations; Chief Operations Officer; Spanish subsidiary director. Annual Report 2026 (Directors’ Report biography / current management page; see source locator)

Contributions and company outcomes

Salamanca project advanced through DFS and FEED

2011–2026 · issuer reported · medium materiality

Berkeley’s FY2026 annual report says Bellón joined in 2011, became COO in 2017, was responsible for day-to-day Spanish operations, and oversaw Salamanca from Scoping Study through Definitive Feasibility Study and Front End Engineering Design. This documents project-stage work, not construction or operating production; required permits remain unresolved.

Attribution: Individual involvement documented. The issuer expressly assigns day-to-day operations and project study/FEED oversight; no construction authorization or production outcome is shown.

Relevance: Strongly relevant technical experience, offset by the company’s unresolved permit and project-delivery position.

Annual Report 2026 (Directors’ Report, Francisco Bellón biography, printed p. 15)

Litigation and enforcement

Salamanca remains unpermitted for construction; arbitration unresolved

2021–2027 (arbitration unresolved at cutoff) · documented · high materiality

FY2026 company report states Spain rejected the NSC II application, court rulings nullified two construction-related authorisations, and the Salamanca project still requires grants or re-grants of NSC II, UL and AEUL. Berkeley’s subsidiary filed a US$1.25bn ICSID claim in February 2026; a bifurcated jurisdiction phase is set for mid-2027. Company assertions that Spanish conduct violated the ECT are contested legal claims, not findings. This is a serious project outcome during Bellón’s tenure as day-to-day Spanish operations lead; no source proves his personal role in the authorities’ decisions or that the CNMV share-dealing sanction caused the permit outcomes.

Attribution: Role overlaps event; causation unproven. Annual report identifies his day-to-day role in Spain, creating direct operational oversight overlap; permit rulings are external adjudications and no personal causation is established.

Relevance: Material to COO execution risk and project viability; claims remain unresolved.

Annual Report 2026 (Directors’ Report, Salamanca permitting/legal risk, printed pp. 9–11); Annual Report 2026 (Directors’ Report, Bellón biography, printed p. 15)

Governance and interests

Final CNMV sanction for insider dealing

2020 trade; sanction final 2024-09-17 · documented · high materiality

CNMV imposed a €40,000 fine for a very serious securities-law infringement: Bellón acquired 75,000 Berkeley shares on 11 December 2020 while possessing inside information about renewal of the Spanish subsidiary’s prior installation authorisation, then sold them on 14 December after public disclosure for an economic benefit. BOE published the sanction in May 2024; CNMV’s 17 September 2024 notice confirms the National Court recorded Bellón’s withdrawal of his judicial appeal on 3 July 2024 and that the sanction is final for all purposes. This was a final administrative/regulatory infringement, not a criminal conviction.

Attribution: Individual involvement documented. CNMV names Bellón and describes the trade; the official finality notice confirms appeal withdrawal and sanction finality.

Relevance: Directly relevant to market conduct, inside-information controls and a senior executive’s listed-company compliance obligations.

CNMV sanction publication (BOE-A-2024-11534) (CNMV resolution, 21 May 2024, BOE paragraph; trade, conduct and €40,000 fine); Register notice confirming Bellón sanction finality (CNMV notice, 17 September 2024, paragraphs 1–3; appeal withdrawn 3 July 2024 and sanction final)

Suitability for the current role

Role fit remains only partly evidenced

Current appointment through 2026-10-09 · analyst inference · low materiality

FY2026 annual report and issuer page report a mining-engineering background, MSc, MAusIMM and membership in Spanish resources/reserves specialist group; Berkeley page describes a master’s in Occupational Health and Safety. No awarding-institution or professional-register check completed. Role-fit inference: relevant disclosed experience for Chief Operations Officer is supported; professional background does not negate separately documented governance findings or establish successful production.

Attribution: Responsibility not applicable. This is an analytical role-fit assessment; it does not allege responsibility for outcomes.

Relevance: Relevant to current Chief Operations Officer duties at Berkeley Energia Limited.

Annual Report 2026 (Directors’ Report, individual biography and qualifications, printed p. 14–15)

Evidence gaps

• Exact dates and independent corroboration of several pre-Berkeley employer roles are not provided in the cited biographies.

• Academic credentials and professional memberships are issuer-reported and were not independently verified with institutions or registers.

• The open-web and regulatory/court queries logged here are scoped research, not exhaustive criminal, sanctions, litigation, credential or reference checks.

• The Salamanca project’s permit status and arbitration remain unresolved at the 9 October 2026 cutoff; no arbitration award or final resolution of the permitting dispute was located.

• Company outcomes and role overlap are not proof of individual causation; the sanctioned conduct is specifically limited to Bellón and the CNMV decision.

Career chronology

• Early career; no dates or firm named: Large international accounting firm — Accountant; firm not named by Berkeley. Annual Report 2026 (Directors’ Report biography / current management page; see source locator)

• Prior to Berkeley; exact dates/role sequence not stated in current issuer report: Papillon Resources Limited — Company-secretarial / finance role. Annual Report 2026 (Directors’ Report biography / current management page; see source locator)

• Listing completed in 2015; exact employment dates not stated: GreenX Metals Limited — Company secretary; oversaw LSE and Warsaw listings. Annual Report 2026 (Directors’ Report biography / current management page; see source locator)

• Concurrent listed-company secretary roles; exact dates not stated: Sovereign Metals Limited and other listed resources companies — Company secretary / finance services. Annual Report 2026 (Directors’ Report biography / current management page; see source locator)

• Company secretary appointed 29 October 2015; current at FY2026 report: Berkeley Energia Limited — CFO and Company Secretary. Directors & Management (Directors’ Report biography / current management page; see source locator)

Contributions and company outcomes

Exchange listings and corporate secretarial work

2015 and Berkeley listing period · issuer reported · low materiality

Berkeley’s FY2026 annual report credits Browne with successfully listing GreenX on the LSE Main Board and Warsaw Stock Exchange in 2015, and overseeing Berkeley’s LSE and Spanish-market listings. These are issuer-reported transactions; no independent evidence of Browne’s specific work product or of value created for Berkeley shareholders was located.

Attribution: Individual involvement documented. The annual report expressly connects Browne to the listing work; no broader investment performance is inferred.

Relevance: Relevant to listed-company disclosure and finance governance duties.

Annual Report 2026 (Directors’ Report, Dylan Browne biography, printed p. 15)

Litigation and enforcement

Salamanca permitting and arbitration remain unresolved

2021–2027 (arbitration unresolved at cutoff) · documented · medium materiality

FY2026 company report describes material regulatory and litigation uncertainty: key permits have been rejected or annulled, the project cannot proceed to construction without required licences, and Berkeley’s US$1.25bn ICSID claim remains unresolved with a jurisdiction hearing scheduled for mid-2027. Browne is CFO and company secretary and has long tenure, but neither sources reviewed nor the annual report attributes the government decisions or project legal dispute to him personally.

Attribution: Role overlaps event; causation unproven. His CFO/secretary role overlaps corporate reporting and governance, but no personal involvement in permit decisions or claim conduct is documented.

Relevance: Material financial and disclosure context for a long-tenured CFO/company secretary; not a personal misconduct finding.

Annual Report 2026 (Directors’ Report, litigation and permits risks, printed pp. 9–11); Annual Report 2026 (Directors’ Report, Browne biography, printed p. 15)

Suitability for the current role

Role fit remains only partly evidenced

Current appointment through 2026-10-09 · analyst inference · low materiality

FY2026 annual report states B.Com, Chartered Accountant and Associate Member of Governance Institute of Australia (Chartered Secretary). Exact university/degree specialization and direct register verification were not in reviewed sources. Role-fit inference: relevant disclosed experience for CFO and Company Secretary is supported; professional background does not negate separately documented governance findings or establish successful production.

Attribution: Responsibility not applicable. This is an analytical role-fit assessment; it does not allege responsibility for outcomes.

Relevance: Relevant to current CFO and Company Secretary duties at Berkeley Energia Limited.

Annual Report 2026 (Directors’ Report, individual biography and qualifications, printed p. 14–15)

Evidence gaps

• Exact dates and independent corroboration of several pre-Berkeley employer roles are not provided in the cited biographies.

• Academic credentials and professional memberships are issuer-reported and were not independently verified with institutions or registers.

• The open-web and regulatory/court queries logged here are scoped research, not exhaustive criminal, sanctions, litigation, credential or reference checks.

• The Salamanca project’s permit status and arbitration remain unresolved at the 9 October 2026 cutoff; no arbitration award or final resolution of the permitting dispute was located.

• Company outcomes and role overlap are not proof of individual causation; the sanctioned conduct is specifically limited to Bellón and the CNMV decision.