Submission to the Ontario Securities Commission
August 12, 2025
Submitted by Shin Imai on behalf of communities and organizations listed in Appendix 1 (see full report).
We request that you investigate Dundee Precious Metals (TSX:DPM) for statements in its press release of July 7, 2025, that did not disclose that there are serious ongoing legal proceedings that could result in a lengthy suspension or even permanent closure of its Loma Larga gold project in Ecuador.
Dundee Precious Minerals is incorporated in Canada, and its principal reporting jurisdiction is Ontario. In July 2021, Dundee purchased INV Metals and acquired the Loma Larga gold project in the ecologically sensitive paramo region in the province of Azuay in Ecuador. Paramos are high altitude wetlands that provide “essential ecosystem services such as water production for urban use, irrigation and hydropower generation.” In 2022 communities in the area brought an action to suspend the mine for lack of community consultation and for concerns about drinking water downstream of the project.
When the court ordered an interim suspension in February 2022, Dundee called it a “pause” and said that the action was “without merit”. In July 2022, the court ordered a suspension of the mine. The suspension was upheld on appeal in August 20233 and was again upheld by the highest court, the Constitutional Court of Ecuador, in January 2024. As of August 2025, the mine has been suspended for over three years.
On July 7, 2025, Dundee distributed a press release that failed to disclose the possibility that Ecuadorian courts could continue the suspension for many years or even close the mine permanently. In the last few years, courts in Ecuador have permanently suspended mining projects for environmental reasons (the “los Cedros” case) and for lack of social license (the “Rio Blanco” case).
Under Ontario law, Dundee is obligated to disclose court cases which may result in the lengthy suspension of the mine. Furthermore, Dundee is relying on an outdated Feasibility Study Technical Report (NI 43-101) drafted by
INV in 2020.
Read the full submission with references here.