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23 specialist reports on mineral assets, checked against the VALMIN Code

Leo Malan CA · · 3 min read

What I did

I took a sample of 23 filed specialist reports, 21 of them from the last two years, and checked each one against the VALMIN Code and ASIC’s guidance on expert reports. 19 were valuations written for independent expert’s reports; 4 were technical reports in IPO prospectuses. I didn’t second-guess the geology or the valuer’s judgement. The only question was whether each report says what the Code requires, and whether its figures agree with the rest of the filing.

What I found

Every one of the 23 missed at least one requirement, and seven of the nine gaps appeared in more than half of them. In 18 of the 19 valuations, a step in the valuation could not be rebuilt by another practitioner from what the report shows. 18 of the 23 adopted the company’s information without saying how it was tested. 17 of the 19 valuations gave no sensitivity analysis on the value. And every report stated at least one figure or fact two ways within the same filing.

What it means

What goes missing most often is the sentence the Code asks for: how an input was tested, what the value does if it moves, who stands behind each part. That is the gap a check before the report is signed closes. See how a compliance review runs.

The figures

Figure 1: Every one of the 23 specialist reports missed at least one thing the Code asks for.
Figure 1. Every one of the 23 specialist reports missed at least one thing the Code asks for.
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Figure 2: Seven of the nine gaps appear in more than half the reports.
Figure 2. Seven of the nine gaps appear in more than half the reports.
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Figure 3: Disclaimers of liability
Figure 3. Disclaimers of liability
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Figure 4: Rebuilding the valuation
Figure 4. Rebuilding the valuation
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Figure 5: Sensitivity analysis
Figure 5. Sensitivity analysis
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Figure 6: Tenure
Figure 6. Tenure
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Figure 7: Company information
Figure 7. Company information
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Figure 8: Independence statements
Figure 8. Independence statements
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Figure 9: Declarations: one sentence each
Figure 9. Declarations: one sentence each
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Figure 10: Every report stated at least one figure or fact two ways. 232 figures or facts did not match another place in the same filing.
Figure 10. Every report stated at least one figure or fact two ways. 232 figures or facts did not match another place in the same filing.
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Source: 23 specialist reports filed with the ASX in independent expert’s reports and IPO prospectuses; Leo Malan analysis. The examples in the figures are anonymised; no firm, company, project or person is named.

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