Questions of Compliance: The Conduct of the CAMEC and Seymour Pierce Limited

13 May 2011

Full Report: Questions of Compliance

Submission to AIM Regulation

The Conduct of the Central African Mining & Exploration Company (CAMEC) plc and its Nominated Adviser, Seymour Pierce Limited

The first chapter details CAMEC’s incorporation and admission to AIM, its acquisition of DRC mining concessions and the company’s resulting corporate structure. In order to understand the final consolidation of CAMEC prior to its acquisition by ENRC, it is also necessary to review its failed bid for another Congolese company, Katanga Mining Limited, after a rival bid from AIM-traded Nikanor plc, backed by the mining magnate Dan Gertler, who had a significant holding in both companies.

The second chapter outlines the AIM rules applicable to CAMEC’s DRC acquisitions, including the AIM Rules for Companies on disclosure (general disclosure and substantial transactions), ongoing obligations arising from the Guidance for Mining, Oil and Gas Companies, and the relevance of the AIM Rules for Nominated Advisers applicable to CAMEC’s nomad, Seymour Pierce, in advising on CAMEC’s Congolese transactions.

The third and final chapter outlines the principal concerns for AIM regulation by relating substantive information on CAMEC’s DRC acquisitions to the AIM rules.

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