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Optimised Prefeasibility Study: Project NPV of US$857m with Improved Fundability Through Staged Development
Southern Palladium Limited
Incorporated in the Commonwealth of Australia
Australian Company Number 646 391 899
ASX share code: SPD
JSE share code: SDL
ISIN AU0000220808
10 July 2025
Optimised Prefeasibility Study: Project NPV of US$857m with
ASX:SPD, JSE:SDL Improved Fundability Through Staged Development
ACN: 646 399 891 Key Study Parameters
• An optimised Pre-Feasibility Study (OPFS) has been completed for the 70%-
Corporate Directory owned Bengwenyama Platinum Group Metals (PGM) Project, resulting in a
new staged development approach with lower capital expenditure estimates
Executive Chairman and significantly improving the project's funding attractiveness.
Roger Baxter
• Several OPFS scenarios were presented by the company's consultants,
Managing Director Minxcon. The SPD Board has evaluated these scenarios and believes that a
Johan Odendaal staged production option, provides the best balance between unlocking
project value and allowing the Company to fund project development with
Non-Executive Directors minimal future dilution for shareholders.
Mike Stirzaker • Key parameters of the OPFS are set out below:
Rob Thomson • Project level NPV8 (after tax, 100% basis) for the OPFS is estimated at
Daan van Heerden US$857m (A$1.3bn) and an internal rate of return of 26.4%.
Lindi Nkosi-Thomas • A staged production proposal, assuming an initial Stage 1 production rate
of 100ktpa expanding after 4 years to 200ktpa.
Company Secretary • Peak funding requirement of US$279m – representing a 38% reduction
Andrew Cooke (US$173m) to the peak funding total set out in the PFS – with Stage 2
expansion capital to be funded through cashflow.
Top 5 Shareholders
Nicolas Daniel Resources Pty ltd • Importantly, Stage 1 is expected to be a strongly cash generative project
Nurinox Investments Pty Ltd in its own right, meaning that it should be able to attract traditional
Robert Napier Keith market-related debt project financing
Legacy Platinum Corporation • Cash costs for both Stage 1 and Stage 2 remain attractive and lie within
HSBC Custody Nominees (Aus) Ltd the lowest quartile for PGM projects globally.
• The above valuations were done on the Prefeasibility Study ("PFS") (refer ASX
Company Overview Announcement 28 October2024) basket price of US$1,557/6Eoz which is 6%
Dual-listed platinum group metal below the current basket price (7 July 2025) of US$1,662/6Eoz.
(PGM) company developing the • The option to utilise existing mineral processing infrastructure in the area —
advanced, shallow, high grade which could result in further significant reductions to peak funding
Bengwenyama PGM project, located requirements — is being evaluated
in South Africa's prolific Bushveld
Complex. • Near-term catalysts: Issue of Mining Right anticipated in the near term. Fully-
funded infill drilling and metallurgical test work program, to be incorporated
Contact: with OPFS results into planned Definitive Feasibility Study (DFS).
E: info@southernpalladium.com
W: www.southernpalladium.com Note in this document:
7E or 6E+Au in this document refers to platinum, palladium, rhodium, ruthenium, iridium,
osmium and gold.
6E or 5E+Au refers to platinum, palladium, rhodium, ruthenium, iridium and gold and;
4e or 3E+Au refers to platinum, palladium, rhodium and gold
____________________________________________________________________________________________________
Southern Palladium (ASX: SPD; JSE: SDL, "Southern Palladium" or the "Company") Southern Palladium announced
the results of the Optimised Prefeasibility Study ("OPFS") for its 70%-owned Bengwenyama Project, located on
the Eastern Limb of the Bushveld Complex in South Africa, which contains approximately 72% of the world's
platinum group metals ("PGM") resources. The OPFS builds on the October 2024 Prefeasibility Study ("PFS") (refer
ASX Announcement 28 October2024), which has confirmed highly attractive economics, and supported the
advancement of the project.
The Managing Director, Johan Odendaal, said: "We are pleased to announce the results of the Optimised
Prefeasibility Study for the Tier 1 Bengwenyama Project where our primary aim has been to reduce the initial
capital requirement. The Board and its consultants have evaluated a number of options and believes that a staged
development provides a pragmatic and value-driven path forward. While the full-scale design outlined in the
original PFS remains technically and economically compelling, the substantial upfront capital required could pose
a funding challenge. A staged development approach for Bengwenyama, reducing peak funding requirements by
US$173 million (38%) to US$279 million compared to the original PFS, presents a highly attractive option for
shareholders.
Importantly, the staged approach also improves our ability to further de-risk key geological, technical, and
operational assumptions. Stage 1 of the project, designed to deliver over 200koz per year of PGMs in concentrate
will provide valuable insights into ground conditions, and metallurgical performance, supporting more informed
mine planning and optimised design for subsequent stages. It also allows us to align project development with
infrastructure roll-out and community readiness, ensuring a more sustainable and inclusive growth trajectory.
Stage 2 of the project is designed to deliver PGM production at levels forecast in the earlier study, averaging over
400koz per year for an aggregate mine life of over 20 years from Year 4 or possibly sooner.
Cash costs for both options are attractive and lie within the lowest cost quartile for the global PGM industry. Stage
1 cash costs are estimated at US$875/oz reducing to US$750/oz for Stage 2.
The Bengwenyama Project
The Project Area is located in the Greater Tubatse and Sekhukhune District Municipalities, in the Limpopo Province
of South Africa, covering 5,280 hectares on the farms Nooitverwacht 324 KT ('Nooitverwacht') and Eerstegeluk
327 KT ('Eerstegeluk), the Project has the potential to stimulate economic growth and development in rural areas
with high unemployment rates by creating significant job opportunities ( Figure 1).
Figure 1: Strategic Positioning of the Bengwenyama Project Amidst Major Platinum Mining Operations
The Bengwenyama Project is strategically located near existing mining operations with established infrastructure,
including processing plants, power supply, water supply and well-maintained access roads. This proximity has
opened the door to early-stage discussions with third parties regarding the potential shared use of such
infrastructure, reducing upfront capital requirements. These discussions, while still preliminary, present a
compelling opportunity to accelerate project development timelines, lower capital intensity, and enhance overall
project economics through strategic partnerships.
Key Optimised PFS Outcomes and Assumptions
The original detailed October 2024 PFS (refer ASX Announcement 28 October2024) outlined a mining strategy for
the UG2 reef only using underground mining techniques, with a focus on efficiently exploiting the shallow eastern
portion of the orebody. This approach emphasised the rapid commencement of full-capacity production of
2.4Mtpa through two declines — the North Decline and the South Decline.
The Optimised Prefeasibility Study (OPFS) completed by Minxcon as an addendum to the PFS: M2025-006a:
Southern Palladium Limited Pre-Feasibility Study Addendum on the Bengwenyama PGM Project, Issue Date 9 July
2025, considered as a Stage 1 option where production begins at 1.2 Mtpa from the South Decline only, increasing
to 2.4 Mtpa in Stage 2 with the introduction of the North Decline.
Figure 2: Orebody Access in relation to the total Tenement Area.
Mining
Mining will involve a strong focus on rapidly achieving full production capacity. The south decline provides faster
access to the orebody, allowing earlier extraction and optimising the development timeline. This supports a faster
production ramp-up and better use of infrastructure and resources. Mining begins with the pre-development of
blocks using off-reef twin haulages, drives, and centre gulleys (raises), enabling the advancement of infrastructure.
Twin haulages are only utilised in the early stages of mining until enough ground is opened for steady state
production build-up.
The difference between the 1.2 Mtpa ore production ramp-up to 2.4 Mtpa scenario and the original PFS case is
illustrated in Figure 3. This figure shows that a steady-state production rate of Stage 1 at 1.2 Mtpa can be achieved
from the South Decline alone. A further ramp-up to Stage 2 - 2.4 Mtpa becomes possible once the North Decline
is brought into the schedule, enabling increased access to ore and higher production volumes.
Figure 3: 1.2 Mtpa ramp-up to 2.4 Mtpa Mine Plan Schedule
Ore production over the first five years is sourced 83% from JORC Measured and Indicated resource classifications,
increasing to 92% over the first 10 years. Overall, JORC Measured and Indicated resources account for 70% of the
total Life-of-Mine (LoM) ore production.
Processing
A well-established, standard processing technology has been adopted and optimised using current state-of-the-
art MF2 (two-stage Mill and Float) infrastructure. The average 6E recovery over the Life-of-Mine (LoM) is 85%,
with a recovered 6E grade averaging 5.08 g/t during Stage 1, and 5.56 g/t across both Stages 1 and 2.
Figure 4: Annual Saleable Product - 6E
There is a well-established downstream refining process and terms in place for PGM concentrate within South
Africa. Most smelters processing the concentrate from the Eastern and Western Limbs are situated in Rustenburg,
with almost all the concentrator product in the area being transported by truck to Rustenburg. The Project PGM
concentrates are expected to be processed at one of these facilities. Initial talks have been undertaken with
smelters owners.
A production breakdown of the tonnes during Stage 1 and thereafter, are displayed in Table 1
Table 1: Production Breakdown in Life of Mine
Staged 1 and 2
Item Unit Stage 1
production
Ore Tonnes Mined kt 13,895 41,911
Total 6E Oz in Mine Plan koz 2,667.6 8,817.8
Platinum Recovered koz 858.8 2,838.8
Palladium Recovered koz 856.5 2,831.1
Rhodium Recovered koz 177.4 586.3
Gold Recovered koz 27.1 89.5
Ruthenium Recovered koz 288.2 952.7
Iridium Recovered koz 59.5 196.7
6E Grade Delivered to Plant g/t 5.97 6.54
6E Recovered grade g/t 5.08 5.56
6E Recovery % 85% 85%
Total 6E Oz Recovered oz 2,267.5 7,495.1
Copper Recovered t 2,048 7,808
Nickel Recovered t 4,761 15,578
Chrome Ore Concentrate 42% Produced kt 1,876 6,046
OPERATIONAL COST ESTIMATE
Costs reported for the Project are displayed per milled tonne, per recovered 4E ounce and per recovered 6E ounce
in Table 2. It should be noted that costs are inclusive of contingencies.
Table 2: Project Cost Indicators (Weighted Average over Life of Mine)
Description Unit Stage 1 Stage 1 and 2
Revenue ZAR/Milled tonne 4,738 5,178
Mine Cost ZAR/Milled tonne 1,414 1,312
Plant Costs ZAR/Milled tonne 479 428
Other Costs ZAR/Milled tonne 703 589
Royalties ZAR/Milled tonne 195 288
Adjusted Operating Cost ZAR/Milled tonne 2,790 2,616
Sustaining Capex ZAR/Milled tonne 235 225
Rehabilitation ZAR/Milled tonne 6 2
Off-Mine Overheads ZAR/Milled tonne 65 31
All-in Sustaining Cost (AISC) ZAR/Milled tonne 3,096 2,874
Non-Sustaining Capex ZAR/Milled tonne 339 242
Non-Current Costs ZAR/Milled tonne - -
All-in Cost (AIC) ZAR/Milled tonne 3,435 3,116
EBITDA* ZAR/Milled tonne 1,878 2,529
EBITDA Margin % 40% 49%
Table 3: Project Cost Indicators (Weighted Average over Life of Mine)
Description Unit Stage 1 Stage 1 and 2
6E oz Recovered oz 2.27m 7.50m
Revenue USD/6E oz 1,484 1,479
Mine Cost USD/6E oz 443 375
Plant Costs USD/6E oz 150 122
Other Costs USD/6E oz 220 168
Royalties USD/6E oz 61 82
Adjusted Operating Cost USD/6E oz 874 747
Sustaining Capex USD/6E oz 73 64
Reclamation USD/6E oz 2 1
Off-Mine Overheads USD/6E oz 20 9
All-in Sustaining Cost (AISC) USD/6E oz 969 821
Non-Sustaining Capex USD/6E oz 106 69
All-in Cost (AIC) USD/6E oz 1,076 890
EBITDA USD/6E oz 588 723
Infrastructure
While the PFS mining and infrastructure plans formed the basis, reduced processing capacity and initial access via
the South decline eliminated the need for several major components, particularly those tied to the North decline.
Stage 1 updates include the removal of infrastructure related to the North decline, such as box cuts, conveyors,
ventilation, and dewatering systems, with associated reductions in power, water, and compressed air needs. The
TSF was downsized and staged, with only the first two stages required and the dewatering plant resized
accordingly.
The Company is also exploring off-site processing for Stage 1, which would eliminate the requirement to build a
Stage 1 plant, defer tailings storage and significantly reduce water and power demand. If successful, off-site
processing for Stage 1 will significantly reduce the Stage 1 funding requirement.
Waste rock will be placed on the TSF footprint, designed for co-disposal. Stage 2, which includes the North decline
and a processing plant, will see the reinstatement and expansion of mining, processing, and support
infrastructure, including roads, power and water supply, TSF expansion, slurry systems, and a tailings dewatering
plant, all scaled to support full production.
The estimate includes all costs associated with access; bulk services (power and water); surface and underground
mining infrastructure and facilities; process plant and supporting infrastructure, TSF, general supporting
infrastructure, and engineering procurement, construction management ("EPCM").
The capital expenditure for the Project over the LoM is sub-divided into mining, plant and shared infrastructure
capital, as indicated in Table 4.
Table 4: Project Capital Expenditure
Stage 1 Stage 2 Total
Capital Expenditure USDm
Initial Capital
Direct Mining Capital 27 27
Capitalised Development 4 4
Plant Capital 87 87
TSF Capital 30 30
Shared Infrastructure Capital 39 39
Contingency 31 31
Total Initial Capital 219 219
Ongoing / Expansion Capital
Direct Mining Capital 3 71 74
Capitalised Development 5 39 44
Plant Capital 87 87
TSF Capital 11 25 36
Ongoing Shared Capital 0 17 17
Contingency 3 38 41
Total Ongoing Capital 22 278 300
Initial Capital is defined as direct Project capital up to and including first plant production. Ongoing Capital is
defined as direct Project capital after Initial Capital. Stay in business capital or sustaining capital consists of
renewals and replacement costs over the LoM. The study capital costs estimates are assessed to have an accuracy
of ±15 - 25%. A 20% contingency has been applied on all mining and shared infrastructure capital (initial and
ongoing) and 15% on plant and TSF capital.
Economic Input Parameters
Table 5 shows the forecasts, which is the same forecast used in the PFS, up to 2028 along with the long-term
forecast utilised in the financial model in real terms used in the financial model.
Table 5: Macro-economic Forecasts and Commodity Prices over the Life of Project
Commodity Unit Basis 2025 2026 2027 2028 Long-term
Platinum USD/oz Real 1,114 1,147 1,143 1,151 1,200
Palladium USD/oz Real 1,020 975 922 978 1,100
Rhodium USD/oz Real 5,468 5,515 5,333 5,803 6,190
Gold USD/oz Real 2,440 2,263 2,163 2,073 1,950
Ruthenium USD/oz Real 450 450 450 450 450
Iridium USD/oz Real 4,650 4,650 4,650 4,650 4,650
Chrome Conc. USD/t Real 225 225 225 225 225
42%
Copper USD/t Real 9,585 9,526 9,287 9,211 8,708
Nickel USD/t Real 17,025 17,284 17,615 17,805 18,249
Exchange Rate ZAR/USD Real 18.51 18.86 19.22 19.58 19.58
Sources: Consensus Economics, Minxcon
The positive PGM market fundamentals have also fed through to higher prices. Towards the end of June 2025,
platinum reached a 10-year high of just over US$1420/oz, after a prolonged decade period of being rangebound
between $900-1100/oz.
Structural deficits in platinum, including a >900 koz deficit in 2025, caused by declining new mine supply (down
6% to 5,4 moz) and limited scrap recovery growth (3% up to 1,6 moz) while also seeing strong growth in jewellery
demand especially in China, along with stable auto-catalyst and industrial demand and growing investment
demand, has resulted in rapidly dwindling above ground stocks for platinum.
Jewellery demand now exceeds 2,1moz, autocats 3.1 moz, industrial applications 2.1 moz and investment demand
600 koz. Platinum is expected to remain in structural deficit for the next five years. The rapid growth of demand
for platinum jewellery in China in the first half of 2025, has been a very positive development.
In 2025, palladium new mine supply is also expected to decline to 6.4 moz, but growth in recycling to 3 moz,
means a slight uptick in palladium supply to 9,4moz. Demand for palladium declined marginally to just under 10
moz, resulting in a 531 koz deficit in 2025, the fourth consecutive year of deficits. Palladium demand in autocats
at 8.3 moz and industrial applications at 1.4 moz, provided continued stable demand. The slowdown in global BEV
sales to single digit levels, combined with consumer preferences supporting growth in demand for hybrid vehicles
has resulted in continued support for PGMs in autocats.
The deficit between supply and demand and the drawdown and elimination of aboveground stocks for rhodium
has also been positive for fundamentals. The hydrogen economy opportunity for PGMs also continues to expand,
especially in heavy duty transport applications (trucking, shipping, locomotives) and will comprise a material
portion of the PGM market in 5-years' time.
Figure 5: Southern Palladium Figure 6: Southern Palladium Revenue Split
Prill Split
The current basket price (7 July 2025) of US$1,662 is 7% higher than the price used in the Optimised PFS study of
US$1,557/6Eoz, however some of the gains are is offset by a stronger ZAR/USD exchange rate.
Cash Flow
The capital expenditure, cash flow, and cumulative cash flow for Stage 1 is displayed in Figure 7, on an annual
basis USD term. The peak funding requirement USD279 million (inclusive of contingencies), with a pay-back period
of 5.5 years from start of mining or 6.0 years from start of construction.
Figure 7: Stage 1 Annual and Cumulative Cash Flow - USD (Real Terms)
Key PFS Outcomes and Assumptions
The following table summarises the results of the optimised PFS, with results presented for the options.
Table 6: Key PFS Outcomes and Assumptions
Project Value Unit Stage 1 Stage 1 and 2
NPV @ 0% ZARm 13,093 63,047
NPV @ 5% ZARm 7,292 27,075
NPV @ 8% ZARm 5,011 16,781
NPV @ 10% ZARm 3,828 12,262
NPV @ 15% ZARm 1,699 5,500
NPV @ 20% ZARm 358 2,136
NPV @ 0% USDm 669 3,221
NPV @ 5% USDm 373 1,383
NPV @ 8% USDm 256 857
NPV @ 10% USDm 196 627
NPV @ 15% USDm 87 281
IRR % 21.8% 26.4%
AISC Cost Margin % 35% 44%
Peak Funding Requirement USDm 279 279
Description Unit
LoM Years 23 33
Undiscounted Cash over Investment Ratio 3.4 12.5
Breakeven 6E Basket Price (Excluding Capex) USD/oz 896 757
Breakeven 6E Basket Price (Including Capex) USD/oz 1,076 891
Peak funding refers to the amount required before net cash flow from operations becomes sufficient to fund
further capital and operating costs. The staged project approach is expected to significantly reduce the peak
funding requirement when compared to the original PFS large project approach. Whilst the staged approach will
require significant capital expenditure to be sourced from operating cash flows (and/or new debt) to fund Stage
II, the Company considers this to be a much-improved outlook in terms of risk and return to shareholders.
The peak funding figures are made up as per the table below.
Table 7: Peak Funding Requirement (USD millions)
Stage 1 and 2
Capital expenditure:
Mining 40
Plant 138
Other 47
Stay-in-business 1
Sub-total Capex: 226
Ramp up period:
Operating costs + working cap. changes 123
Less Revenue (69)
Sub-total Opex: 53
Peak funding required 279
In addition, the Company is examining the possibility of trucking ROM ore (as mined ore) from the Project site to
an existing third party owned PGM processing plant (or plants) in the vicinity. The Company has commenced
discussions with various third parties to assess the potential for such an arrangement. If successful, this will
further significantly reduce the peak funding amount as no plant capital expenditure will need to be included in
that total – refer Table 7 above for the indicative reduction.
SENSITIVITY ANALYSIS
Based on the real cash flow calculated in the financial model, consultants and Minxcon performed single-
parameter sensitivity analyses to ascertain the impact on the NPV. The bars represent various inputs into the
model; each being increased or decreased by 15%. The left-hand side of the graph indicates a negative 15% change
in the input while the right-hand side of the graph indicating a positive 15% change in the input. A negative effect
to the NPVs represented by red bars and a positive effect represented by blue bars. Exchange rate, grade and
PGM prices have the largest impact on the Project's NPV, followed by the mining operating costs. The Project is
least sensitive to the base metal prices, capital and processing operating costs.
Figure 8: Project Sensitivity USD (NPV8.0%)
NEXT STEPS
A preliminary development schedule has been compiled for the Project. The main activities forming part of the
schedule includes:-
• Issue of Mining Right;
• Completion of required drilling (resource infill, metallurgical testwork, geotechnical and hydrogeological);
• Completion of a Definitive Feasibility Study;
• Final investment decision;
• Mine development;
• Construction; and
• Commissioning and ramp-up
Conclusion
A staged development strategy balances risk and reward by protecting capital, improving operational readiness,
and aligning growth with market and community dynamics. It positions the Bengwenyama project for long-term
success by creating a foundation of real-world performance and stakeholder alignment, before scaling to full
capacity.
JORC Competent Persons Statement
Uwe Engelmann
The information in this report that relates to Exploration Targets, Exploration Results, Mineral Resources or Ore
Reserves is based on information compiled by Mr Uwe Engelmann (BSc (Zoo. & Bot.), BSc Hons (Geol.),
Pr.Sci.Nat. No. 400058/08, FGSSA). Mr. Engelmann is a director of Minxcon (Pty) Ltd and a member of the South
African Council for Natural Scientific Professions. Minxcon provides geological consulting services to Southern
Palladium Limited. Mr. Engelmann has sufficient experience that is relevant to the style of mineralisation and
type of deposit under consideration and to the activity being undertaken to qualify as a Competent Person as
defined in the 2012 Edition of the 'Australasian Code for Reporting of Exploration Results, Mineral Resources
and Ore Reserves'. Mr. Engelmann consents to the inclusion in the report of the matters based on his
information in the form and context in which it appears. Mr Engelmann has a beneficial interest in Southern
Palladium through a shareholding in Nicolas Daniel Resources Proprietary Limited.
Daan van Heerden
The scientific and technical information contained in this announcement has been reviewed, prepared, and
approved by Mr Daan van Heerden (B Eng (Min.), MCom (Bus.Admin.), MMC, Pr.Eng. No. 20050318, AMMSA,
FSAIMM). Mr van Heerden is a director of Minxcon (Pty) Ltd and a Registered Professional Engineer with the
Engineering Council of South Africa, a Member of the Association of Mine Managers South African Council, as
well as a Fellow Member of the South African Institute of Mining and Metallurgy. Minxcon provides geological
consulting services to Southern Palladium Limited. Mr van Heerden has sufficient experience that is relevant to
the styles of mineralisation and activities being undertaken to qualify as a Competent Person, as such term is
defined in the 2012 Edition of the 'Australasian Code for Reporting of Exploration Results, Mineral Resources
and Ore Reserves'. Mr. van Heerden consents to the inclusion in the report of the matters based on his
information in the form and context in which it appears. Mr. van Heerden has a beneficial interest in Southern
Palladium through a shareholding in Nicolas Daniel Resources Proprietary Limited.
For further information, please contact:
Johan Odendaal
Managing Director
Southern Palladium
Phone: +27 82 557 6088
Email: johan.odendaal@southernpalladium.com
JSE Sponsor
Merchantec Capital
Media and investor relations inquiries:
Australia: Sam Jacobs, Six Degrees Investor Relations: +61 423 755 909
South Africa: Sherilee Lakmidas, R&A Strategic Communications: +27 79 276 2529
_____________________________________________________________________________________________________
Forward Looking Information and Cautionary Statements
This prefeasibility study contains "forward-looking information" and "forward-looking statements" (collectively,
"forward-looking information") within the meaning of applicable securities laws. This forward-looking information
includes, but is not limited to, statements concerning the expected future performance of the Bengwenyama
Project, anticipated production rates, resource estimates, mine life, financial projections, capital and operating
costs, timelines, economic viability, and other similar statements.
Forward-looking information is based on various assumptions, estimates, and expectations of future performance,
which are inherently subject to significant uncertainties and risks, including but not limited to those associated with
the mining industry. These include:-
• variability in mineral resource estimates;
• the timing and successful completion of development and construction activities;
• risks related to fluctuations in commodity prices;
• political and regulatory changes in the jurisdictions where we operate;
• potential operational difficulties, including environmental and safety risks; and
• availability of financing and unforeseen financial requirements.
Although the company believes that the forward-looking information in this report is reasonable based on
information currently available, actual results may differ materially from those anticipated in the statements.
Readers are cautioned not to place undue reliance on forward-looking information, as it is not a guarantee of future
performance.
The company disclaims any intention or obligation to update or revise forward-looking statements, whether as a
result of new information, future events, or otherwise, except as required by applicable law.
Date: 10-07-2025 08:55:00
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