1004 measures, and evaluate opportunities related to engineering, capital expenditure (Capex), implementation schedule, operating costs, product compliance, market assumptions, and the evolving business model with third parties. At the time of the review, the project was classified as a conceptual‑level study, with low engineering maturity. This condition required the adoption of elevated contingencies and highlighted the sensitivity of the economic viability to underlying technical and commercial assumptions. Significant discrepancies were identified between early Capex estimates prepared during business concept development and updated estimates produced during the independent review. These differences were not solely attributable to inflation or scope growth, but were largely related to inconsistent assumptions, incomplete documentation, and fragmented information sources. 6.2.3 Information Fragmentation and Governance Challenges A central challenge observed during the assessment was the absence of a consolidated and authoritative information base. Key data related to material properties, processing routes, cost assumptions, infrastructure requirements, and market premises were dispersed across multiple teams and external stakeholders. In several cases, critical assumptions were embedded in informal knowledge rather than formal technical documentation. Due to confidentiality constraints and the lack of integrated data systems, the review required numerous interviews with technical, operational, commercial, and corporate stakeholders in order to reconstruct the decision context. This process increased the time required for analysis and introduced additional uncertainty, particularly in areas related to risk allocation, governance responsibilities, and commercial exposure. The experience demonstrated how information silos and dispersed ownership of data can significantly delay decision‑making, reduce the transparency of risk assessments, and complicate governance in circular economy initiatives that extend beyond traditional tailings management boundaries. 6.2.4 Business Model Evolution and Risk Exposure Over the development timeline, the business model evolved from a residue‑based additive concept toward the production of higher‑value industrial products. While some intermediate products had been produced and tested in accordance with applicable standards, final products under the revised model had not yet been fully validated. This evolution transferred additional technical and commercial responsibility to the mining company, increasing exposure to product compliance and market risks. As a result, the review emphasized the need for formal testing, documentation, and traceability of assumptions prior to entering binding commercial commitments. Alternative risk‑sharing arrangements were considered as potential mitigation strategies, illustrating typical trade‑offs associated with circular economy projects. 6.2.5 Lessons Learned on Integrated Management Systems Although the project predated the implementation of a fully integrated digital management platform, the review process highlighted how the lack of structured data integration directly affected project timelines, risk evaluation, and governance clarity. The need to manually consolidate dispersed information underscored the importance of integrated systems capable of supporting: • consolidation of multidisciplinary technical and commercial data; • documentation and traceability of assumptions and decisions; • scenario comparison under evolving risk conditions; and
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