Liability of Competent Person

for JORC Reports*

K Livesley1

ABSTRACT
When preparing JORC reports on Exploration Results, Mineral Resources or Ore Reserves for disclosing entities, Competent
Persons should bear in mind the potential liabilities involved. These include administrative sanctions from professional
organisations, and statutory liabilities, both civil and criminal. This paper examines these liabilities in detail, and outlines
measures that Competent Persons can undertake to minimise them. The position of Competent Persons who are also directors
is also discussed.

1. Partner, Corporate Advisory, Gadens Lawyers, 77 Castlereagh Street, Sydney NSW 2000. Email: [email protected]
* An earlier version of this paper was published as an article in the AusIMM Bulletin, Jan/Feb 2008 edition, pp 56-64.

INTRODUCTION APPLICATION OF THE JORC CODE

Disclosing entities that are subject to the Australian Securities
Exchange (ASX) Listing Rules must, when preparing Who is a Competent Person?
information on Exploration Results, Mineral Resources or A Competent Person must be a member or fellow of a
Ore Reserves for disclosure to investors, potential investors recognised professional organisation with appropriate
and their advisers, comply with the Australasian Code for experience. Clause 102 of the JORC Code provides that:
Reporting of Exploration Results, Mineral Resources and Ore A ‘Competent Person’ must have a minimum of five years
Reserves (JORC Code). experience which is relevant to the style of mineralisation
This often arises in relation to listed mining companies’ and type of deposit under consideration and to the activity
reporting requirements under ASX Listing Rule 5.6, but can which that person is undertaking.
also be relevant when preparing a report for a disclosure This minimum hurdle of required experience is in
document (such as a prospectus for an initial public offering, accordance with the third of the three principles of the
rights issue, etc), bidder or target statement, or scheme of JORC Code, namely Competence. The first two principles,
arrangement. Transparency and Materiality set the background for the
The JORC Code requires that the documentation on which obligations of the Competent Person in favour of the investors
such a report is based must be prepared by, or under the and their professional advisers. Any failure of the Competent
direction of, and signed by, a Competent Person or Persons Person in the performance of those obligations may give rise
(JORC Code, Clause 9). to liabilities.

This article provides a brief overview of the potential

liabilities faced by Competent Persons as a result of their
Changes to the JORC Code
professional role in preparing their report. This article does There were a number of changes to the 2004 JORC Code.
not intend to cover the additional duties that affect Competent One of the changes that remains important to highlight is
Persons who are also directors of the disclosing entity, nor does the recommendation to quantify risks. Under the 2004 JORC
it seek to address liabilities that may arise in the circumstances Code, Competent Persons are encouraged to quantify the
involving deliberate fraudulent intent of a Competent Person. risk and uncertainty relating to any Resource or Reserve
estimates. This is presently not a mandatory requirement;
It should be noted that all references to reports in this paper however, it is recommended for Competent Persons, on
and in the JORC Code, are those reports that are released by the grounds that it is becoming an increasingly common
the relevant company to the public. What this article focuses practice within the industry. Despite not being mandatory,
on is the documentation and material that has been prepared the fulfilment of such recommendations by a Competent
by the Competent Person and that is relied upon in any such Person may, it could be argued, assist to limit the scope of
report by the company, usually a public report. It is more liability to which a Competent Person may be subject. It has
often that a Competent Person will be providing material to been suggested, however, that by quantifying such risk and
a company for disclosure in a report by the company and not uncertainty, it could make it easier for an aggrieved party to
have his or her own report disclosed. This is to be compared take legal recourse.
to the Canadian System, which requires the Competent
Person’s report itself to be disclosed under NI 43-101. 2. Readers are referred to Clause 11 of the 2012 Code.

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The better view, in the author’s opinion, is that providing •• deal with the complaint if deemed within the authority of
a quantification of risk, depending on the particular the Complaints Committee (AusIMM By-Laws 26(d)(iv))
circumstances, is unlikely to increase the likelihood of •• refer the complaint to the Ethics Committee if breaches
litigation. At best it would assist in determining damages of the AusIMM’s Code of Ethics are alleged or suspected
suffered, but not liability. (AusIMM By-Law 26(d)(v))
It is therefore a risk management technique; it is not a •• dismiss the complaint (AusIMM By-Laws 26(d)(iv)).
panacea. If you do your job in a less than careful and thorough If the complaint is referred to the Ethics Committee, the
manner, and without your methodology and verification Ethics Committee then has powers to warn or reprimand the
clearly demonstrated, then any disclaimer or qualification of member concerned, or resolve that the membership of the
risk and uncertainty, will not help you. member concerned be suspended for a period not exceeding
There have been significant technical changes since 2004, 12 months or that the member be expelled from the AusIMM
culminating in the 2012 JORC Code.3 (AusIMM By-Law 26(g)).

Australian Institute of Geoscientists (AIG)

LIABILITY OF A COMPETENT PERSON Not dissimilar to the AusIMM procedure, the AIG Articles,
AIG Code of Ethics and the guidelines for Ethics and
Sanctions and liability Standards Complaints Management provide that the Ethics
Where a Competent Person fails to apply appropriate care and Standards Committee may recommend to the Council of
and diligence in the preparation of documentation that the Institute any one or more of the following:
is subsequently used as the basis for a public report or •• expulsion of the member
disclosure by a public company, that Competent Person may •• suspension of a member and/or demotion to a lower
be subject to liability. There are various statutory or common grade of membership
law liabilities that may be incurred by a Competent Person •• a range of more minor penalties
due to losses suffered by third parties as a result of any such •• an apology, published, or written or verbal may form part
misleading or deceptive reports. of any penalty.
While liability for a report may well initially rest with the
company that discloses it, the Competent Person may also Statutory liability
be liable for the material and documentation prepared to
produce that report. Misleading and deceptive reports – the Corporations Act
Administrative sanctions 2001 (Cth)
In addition to the disciplinary actions of the relevant
professional organisations, which can impact on a Competent
Complaints to relevant professional organisations Person’s ability to work within the profession, there are
On an administrative level, complaints made in respect of statutory provisions that also impose pecuniary and other
the professional work of a Competent Person will be dealt liabilities on a Competent Person arising from his or her
with under the disciplinary procedures of the professional material that is used in reports that are misleading and
organisation to which the Competent Person belongs, deceptive, or indeed, the reports themselves if issued by the
whether that organisation is an Australian professional Competent Person.
body or an approved ROPO (as published on ASX or JORC
websites from time to time) in the list promulgated by the ASX Civil and criminal liability
from time to time. The relevant rules of the two Australian
The relevant liability provision relating to a Competent Person
professional organisations are given below.
under the Corporations Act will depend upon the nature of
the requested use for the report. The source of liability under
The Australasian Institute of Mining and Metallurgy (AusIMM) the Corporations Act for misleading and deceptive conduct
If a complaint is raised against a Competent Person who is may apply in the following circumstances:
an AusIMM member, the complaints process as set out in •• Company takeovers, compulsory acquisitions and buy-
the AusIMM By-Laws will apply. In the first instance the outs are set out in sections 670A and 670B.
complaint is referred to the Complaints Committee.
•• Fundraising documents, such as a prospectus – sections
The Complaints Committee may then: 728 and 729.
•• recommend that the complaint be settled by alternative •• Section 1041H (dealing with financial products or financial
dispute procedures in the case of a commercial dispute services).
(AusIMM By-Laws 26(d)(i)) •• Section 1041E(1) provides a general prohibition against
•• refer the complaint to judicial processes where a breach the making of false or misleading statements. The
of the law may have been committed (AusIMM By-Laws components of the provision may be paraphrased as
26(d)(ii)) follows:
•• discuss a breach of the JORC Code with the relevant A person must not make a statement if (a) the statement is
regulatory authority and jointly agree a process for its false in a material particular or is materially misleading;
resolution (AusIMM By-Laws 26(d)(iii)) and (b) the statement is likely to induce another person;
and (c) when the person makes the statement, the person
3. Readers are directed to the JORC website (http://www.jorc.org/about.asp) for a does not care whether the statement or information is
discussion of the changes between the 2004 and 2012 JORC Codes. true or misleading or knows, or ought reasonably to

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 Liability of Competent Person for JORC Reports | K Livesley

have known, that the statement is false in a material same expert, three months earlier. There were two reports
particular or is materially misleading. on valuation. In the second report certain factors (including
•• Part 9.4 of the Corporations Act also provides specific changes in gold tax regime, moving forward of start-up dates
prohibitions against the making of false and misleading for production, etc) were referred to but it was not apparent
statements. Of particular relevance are sections 1308(2) from the assumptions and calculations used in that report
and 1308(4). how they were linked to help to explain the increase in value
Section 1308(2) provides a prohibition against persons of the mine.
making false and misleading statement in documents which Even if a clearly false or misleading statement is clarified
must be lodged or submitted to ASIC. It states: in a separate part of a report, the expert may still be liable,
A person who, in a document which is required to be lodged notwithstanding the clarification is specifically referred
or submitted to ASIC, makes or authorises the making of to (see Tonvill Pty Ltd v Stokes (Australasia) Ltd). This case
a statement that to the person’s knowledge is false and highlights the fact that if a false statement or assertion is
misleading in a material particular, or omits to mention contained in one part of a report or document, it is not
anything without which a document is, to the person’s simply cured if in some other place in that report the
knowledge, misleading in a material respect, is guilty of an statement contradicts the false comment even if that false
offence. statement is contained in a passage that directs attention to
the other passage.
Section 1308 (4) provides that a person is guilty of an
offence if, in a document required to be lodged with ASIC, Be aware of the potential impact subsequent events may
that person makes or authorises in the document false and have on an expert’s report. While not directly relevant
misleading statements without having taken reasonable steps to a report or material provided under the JORC Code,
to ensure that the statement was not false or misleading. the Solution 6 Holdings case (ASIC v Solutions 6 Holdings
Importantly, an officer or employee of a corporation Limited) is instructive in that it found that where an expert
who makes available information to a director, member or opinion is expressed or recommendation made in relation
various other entities including auditors and the ASX, may to a decision to be made at a known time in the future and
also be guilty of an offence if that information is false and the expert subsequently becomes aware of a matter that
misleading, and it was known to the officer or employee that could materially affect that opinion, it may be misleading
the information was false and misleading (section 1309). to fail to take steps to supplement or vary the report or
recommendation.
Generally, liability for a misleading statement may arise
simply if the Competent Person ‘ought reasonably to have The above cases concern discrete reports in public reports.
known’ that the statement was materially misleading. The Whilst a Competent Person may provide a stand-alone
maximum penalty for contravention of s.1041E is 200 penalty report, or in the role of a director or an officer issue a report
units ($22 000) or five years imprisonment, or both. to the public, it is more likely that the Competent Person
will provide material that will form the basis of a report to
Any documentation prepared by a Competent Person
the public. This underlines the need for a Competent Person
that is disclosed (usually via a report by the company) to
to check the form and context in which the company is
shareholders or potential investors of a company could also
providing its reports.
give rise to civil liability for damage suffered as a result of a
misleading or deceptive statement being made or information
being given. For example, section 1041I sets out the civil Materiality
liability for offence under s.1041E to s.1041H and provides The question of whether a statement that is made or
that a person who suffers loss by the contravening conduct of information that is given in a report is misleading or
another person may recover the amount of the loss or damage deceptive may turn on the issue as to whether the statement
by action against the other person. or information was materially misleading or not.
There is no hard and fast rule regarding the threshold for
Scope of liability materiality. Therefore, the Competent Person will need to
Courts have been prepared to acknowledge some practical be aware of the relevant materiality guidelines or threshold
limitations on liability of experts for misleading material, amounts of the disclosing company that will apply to a
such as that provided in documentation submitted to offerees given report, as well as considering his or her own potential
under takeover bids. There still, however, remains scope for thresholds. Materiality may be a difficult concept (especially
liability arising from misleading reports of a similar kind as if there is not a formal process determining materiality, such
that which was the subject of the Carr Boyd case (Carr Boyd as in a due diligence committee for a prospectus) depending
Minerals Ltd v Queen Margaret Gold Mines NL). on the report.
In that case an expert’s report accompanying a bidder’s The JORC Code aims for transparency in reporting such
statement was found to be misleading. Certain assumptions that readers are provided sufficient information in a clear and
and calculations made in the report were not linked nor did unambiguous manner. Therefore, some degree of balance
they explain any change in the value at the particular mine. must be applied in order to provide enough information to
Wallace J found that an expert’s report accompanying the cover the principle of materiality, while at the same time
bid statement contained a number of matters or items of not detailing excessive information so as to make the report
information that were misleading in the form and context confusing – and potentially misleading – for the audience. The
in which they appeared. In this case the plaintiff focused on JORC Code sets out guidelines for the distinction between
the misleading or inadequacies of comments in support of Exploration Results, Mineral Resources and Ore Reserves
a difference between a valuation of the gold mine at $80 M that the Competent Person must apply so as to establish an
and the valuation of that same gold mine at $60 M by the appropriate degree of materiality. Furthermore, the 2004

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JORC Code recommends that Competent Persons provide It must be noted, however, that this defence is only available
details quantifying the risks associated with the subject of for a contravention of civil penalty provisions, such as
the report, which should provide additional guidance when when the claimant is seeking damages for the economic loss
producing reports to be consistent with the JORC Code. suffered.
There are two levels of materiality. A company must It is important for the Competent Person to ensure
determine whether any particular results, for example, that appropriate internal procedures are followed for
analysed under the JORC Code, are such that they need to the preparation and release of the Competent Person’s
be disclosed. Listing rule 3.1, subject to certain carve outs, documentation to the company internally. For the benefit
provides that test.4 of the Competent Person, he or she should obtain a sign-off
This is to be distinguished from ‘materiality’ as set out in agreeing to the form and context in which the analysis will
section 4 of the JORC Code.5 If a Competent Person provides, appear.
for example, a report to a joint venture regarding a particular
mine, the context of that report needs to be borne in mind Australian Consumer Law and state equivalent Fair Trading
when both joint venturers are disclosing. The disclosure Acts
may take a different form and context if the joint venturers
The application of s.18 of the Australian Consumer Law
comprise a large multi-national on the one hand and a junior
(ACL) and state equivalent Fair Trading Acts (FTA) require
explorer on the other. Materiality, form and context may well
that:
differ. The touchstone is that the Competent Person must sign
off the form and context in which his or her report is being •• the information or advice was likely to mislead or deceive
provided, separately, to both entities in this case. •• the information or advice was given by a corporation
in trade or commerce (which can include dealing with
Consent of the Competent Person customers or communicating with shareholders)
As discussed, when a company issues its report containing •• the plaintiff suffered loss by reason of the information or
material from the Competent Person, the company must advice.
obtain consent from the Competent Person as to the form and An essential aspect is that s.18 ACL does not require a
context in which the information appears. duty of care to be established and so it would seem to have
It is important to note Clause 8 of the JORC Code.6 In a broader application than, for example, an action in tort for
particular, in the introduction to that paragraph, it states that: negligence. However, there are a number of exclusions which
restrict the scope, such as that s.52 applies to corporations
The report [that is, a public report issued by a company, only, and not to individuals.
not the documentation prepared by the Competent Person]
shall be issued with the written consent of the Competent Nonetheless there is exposure to potential secondary
Persons as to the form and context in which it appears. liability under s.236, which provides that a person who
suffers loss or damage by conduct of another person that was
If a disclosing company issues a public report or disclosure
done in contravention of, among others, s.18 may recover the
document without having obtained the written consent
amount of the loss or damage by action against that other
from the Competent Person, and such a report is potentially
person or against any person involved in the contravention.
misleading and deceptive, the company may find itself in an
action for damages by a disaffected investor. The Competent It is important to note that, despite the restrictions on the
Person must do everything to ensure that what is disclosed application of s.18 ACL, each of the state based Fair Trading
by the company in reliance on the Competent Person’s Acts have equivalent provisions to s.52 TPA but without
documentation is accurate both as to form and in context. the restrictions on their application – with the exception of
If the company does so without the Competent Person’s takeover or fundraising documentation under s.670A and
consent or alters the document or information from that s.728 respectively of the Corporations Act.
which the Competent Person disclosed, the Competent Person When is conduct ‘misleading or deceptive’, or ‘likely to
may be able to rely upon that as a defence. An indemnity mislead or deceive’ for the purposes of s18? The following
in any engagement or employment agreement between the may assist:
Competent Person and the company would assist. •• there has to be a real prospect that the conduct will
mislead, not a mere possibility; the word used is ‘likely’
Defence to civil liability •• failing to disclose information is potentially as misleading
A defence is available under s.1317S, which enables a court to as disclosing false information
relieve a person either wholly or partly from a civil liability, •• to ‘mislead’ someone is to lead that person, on a reasonable
such as s.1041I, provided the person acted honestly and the basis to reach a false or erroneous conclusion.
person ought fairly to be excused from the contravention.
Tort – negligent mis-statement
4. Listing rule 3.1 states: ‘Once an entity is or becomes aware of any information concerning
Negligent mis-statement involves proof of:
it that a reasonable person would expect to have a material effect on the price or value of
the entity’s securities, the entity must immediately tell ASX that information.’ •• the existence of a duty of care
5. As follows: ‘Materiality requires that a Public Report contains all the relevant information •• breach of the duty
which investors and their professional advisers would reasonably require, and reasonably •• causation, based on proximity and reliance, of actual
expect to find in the report, for the purpose of making a reasoned and balanced damage.
judgement regarding the Exploration Results, Mineral Resources or Ore Reserves being The test of whether there has been negligent misstatement
reported.’ is whether the advice or information was consistent with that
6. Readers are referred to Clause 9 of the 2012 Code. of a reasonably competent professional in the relevant field.

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The information or advice need not to have been given Report commissioned by company – no protection
to the recipient, being the person or company alleging they
In relation to a report prepared by a Competent Person in
suffered damage (be it the company the report is completed
accordance with the JORC Code, the link of proximity and
for, or a third party relying upon it) as long as the relationship
reliance would seem hard to unseat because the Competent
is sufficiently proximate, the information or advice was
Person expressly assumes responsibility for the statement
incompetent, was relied upon by the recipient and the loss
and such consent must be included in the public report. These
was foreseeable.
outcomes are indicative of similar actions against a disclosing
entity positioned between an expert providing a report and
ASIC Practice Note 55 a third party investor relying on the contents of that report.
It is also important for Competent Persons to be aware of Accordingly, it is not sufficient for a Competent Person to
ASIC draft PN 55, which provides that a Competent Person seek to rely on the company commissioning the report to
assumes responsibility for historical results and statements act as a buffer for any resultant liabilities – the report must
that are used, unless consent from the author of the historical be prepared with reasonable care and diligence so as not be
results or statement is received and disclosed. This is of misleading or deceptive for any third party.
relevance whether a Competent Person is preparing an So do not take at face value information presented in
original report in compliance with the JORC Code, because another report or by the company. Alternatively, mention it
it may be used again for another purpose at a later date, or – that you have not tested it, or assume it is accurate (if it is
if a Competent Person is using a previous report in a new reasonable for you to do so, get an indemnity from your client
report for another purpose, because they will need to either for the information it provides).
obtain the consent of the prior Competent Person or adopt
Circumstances in which the company may be found liable
the responsibility for the report themselves.
centre around situations when the company ought reasonably
to have known that the statements were misleading. These
EXAMPLES circumstances have included examples such as:
An example of the different liability provisions being •• the sample size used for the data was too small
applied is the case of Charben Haulage Pty Ltd (Charben) v •• the exploration program was in too early a phase relative
Environmental and Earth Sciences Pty Ltd (EES) [2004] FCA to the confidence level reported
403. EES compiled various reports for Caltex, who then •• the report was prepared by a person who is not a
passed the reports onto Charben in order to market the Competent Person under the JORC Code (ASC v MacLeod
sale of the property to Charben. Charben suffered loss and (2000) 22 WAR 255).
commenced actions against both Caltex and EES to recover
such losses.
SUMMARY
Claims against Caltex The issue for a Competent Person is one of risk management.
It was held that Carben did not have an action against Caltex The potential liabilities for Competent Persons range from
under either s.52 of the Trade Practices Act (TPA) (now administrative orders, such as reprimand, suspension or
s.18 ACL) or a negligent misstatement claim because the expulsion of membership from the professional organisation,
statements were made by EES, not Caltex. However, the case on the one hand, to statutory and civil liabilities, such
suggests that there may have been a basis for a claim under as damages for economic loss and incarceration on the
TPA (now the ACL) or negligent misstatement if Caltex had other hand. Accordingly, a number of measures must be
known that the report was misleading. undertaken to ensure that the liabilities are adequately
minimised, including:
Also, the claim of negligence against Caltex failed, as there
was no evidence that Caltex knew that the work proposed by •• Clear terms and purpose of engagement by the company
EES would be insufficient to enable EES to properly complete of the Competent Person for the preparation of the report
the report. or the documentation of analysis enabling the preparation
of the report.
Claims against Environmental and Earth Sciences •• Thorough and professional fulfilment of the service by
the Competent Person in preparing the documentation
Pty Ltd or report in accordance with the JORC Code, including
The claim under s.52 TPA (now s.18 ACL) was upheld on the express disclosure of any shortcomings or disagreements
grounds that it was part of the business of EES to prepare held by the Competent Person in relation to the use of the
such reports and that the publication of false or unjustified report by the company.
representations will ordinarily be regarded as conduct that is •• Supplied information should not be taken at face value
misleading or, at least, likely to mislead. when preparing an independent expert report. Competent
The negligent misstatement claim was rejected in this case Persons should be satisfied that the information is
due to lack of proximity. Although it was acknowledged that reasonable or should carve it out of their report.
the general facts were based on a person producing a report •• Although of limited use, disclaimers should be included.
on a technical matter for a client, knowing the report would The report should clearly outline what it is for and who
be likely to be passed onto someone else, who might rely on can rely upon it and for what purpose. The report should
the report in making a decision, this alone was not deemed directly link to the comment. The usual boilerplate (such
sufficient. (See also San Sebastien Pty Ltd v The Minister and as a disclaimer clause) at the end of a report should not be
Esanda Finance Corp v Peat Marwick Hungerfords.) used as they don’t always work.

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•• Retainer letters can be used to limit liability (but the service, although for the benefit of reporting in accordance
competitive advantage to get the business and one’s with the JORC Code, is in some ways also a means by the
tolerance to risk – commercial issues – should be disclosing entities of shifting a degree of the liability for
considered). Retainers should be limited in scope and reports over to the Competent Person.
quantum. Indemnity from the company as to the form
As a result, it is important for Competent Persons to ensure
and context in which the report may appear in any public
that the extent of their engagement is clear, whether as an
disclosure (by the company) might also be required in the
employee or an external consultant, and that the purpose for
case of the company reproducing information without
which the report is being prepared is correctly specified from
sign-off.
the outset. This will assist in enabling the Competent Person
•• While there is no need to be ‘independent’ in the JORC
some degree of confidence regarding the reasonableness of
Code, nevertheless there is a need for a Competent Person
the report and in minimising the scope of the liabilities that
to fulfil his or her professional obligations separate from
the company, whether he or she is an independent the Competent Person may be subject to.
contractor to the company, or an employee or officer of the A Competent Person must be particularly mindful of
company. To the extent of their professional obligations their position if they are also a director of the company.
as a Competent Person, they are independent. The JORC The Competent Person must consider the role they play as
Code requires full-time employee of the company to state a Competent Person as well as being mindful of their legal
that fact in any compliance statements (refer to Clause 8 duties and obligations as a director. When preparing material
of the JORC Code7). The relevant relationship should be the Competent Person should ensure full disclosure of their
disclosed, whatever it is, be it employee, independent position as a director of the company and clearly express that
contractor or officer/director of the company. their role and professional obligation when preparing the
•• The reasoning and technique employed to come to a such material is independent from their position with the
decision should be carefully considered. There may be company.
alternatives. The process adopted to arrive at a view
Finally, it is essential in the limiting of the liability of the
should be clear.
Competent Person that the distinction is clear between that
•• A clear summary of major assumptions, methodologies,
portion of a disclosure document that is by the company, as
dates, etc should be included. Working papers should
opposed to that portion of the disclosure document that has
be able to be used to ‘verify’ the statements and
the consent of the Competent Person to the inclusion of the
methodologies. Competent Persons should be aware of
how their documentation will be dealt with and disclosed report in the form and context in which it appears only.
by the company in any Public Report. The position of the Competent Person differs from
•• Misleading or deceptive statements or omissions should other experts on whose advice a company may rely. In
be avoided (refer above to the Carr Boyd case). most disclosing reports by a company, a valuer or other
•• Insurance should be considered and checked with the independent experts will often have their own report
broker to ensure an adequate level of coverage is in place. separate and discrete. The Competent Person’s position is
This is particularly important if the Competent Person is less clear. They often provide material to the company and
an employee or officer of the disclosing company. the company issues it with possible changes in context.
Competent Persons need to recognise that their engagement Nevertheless, the liability regime can still extend to a
by disclosing entities to provide the professional reporting Competent Person and he/she must ensure that what is
written and disclosed by the company is correct in the form
7. Readers are referred to Clause 9 of the 2012 Code. and context in which he/she agrees.

848 Mineral Resource and Ore Reserve Estimation