Cape Lambert Resources : Response to ASX Query

21 October 2019

Elizabeth Harris

Australian Securities Exchange

Level 40, Central Park

152-158 St Georges Terrace

Perth WA 6000

Via email:

[e-mail]

Dear Elizabeth,

We refer to your letter dated 14 October 2019 (14 October Letter) pursuant to which the Australian Securities Exchange (ASX) requests additional information from Cape Lambert Resources Limited (Cape Lambert or the Company) in respect to the Marampa Project.

Marampa Project Tenure

1. What interest does CFE currently have in the Marampa Project and, in particular, the Tenements?

The Marampa Iron Ore Project (Marampa Project) is a brownfields hematite iron ore project that remains at the development and permitting stage and is located 90km northeast of Freetown in Sierra Leone, West Africa.

The Marampa Project comprises one mining licence (ML05/2014) comprising 97.40km2 and one granted exploration licence (EL46A/2011) comprising 145.86km2. The Status of these tenements is as follows:

ML05/2014

In 2014, Marampa Iron Ore (SL) Limited (Marampa SL), a wholly owned subsidiary of Cape Lambert was granted the mining and environmental licences for ML05/2014 (together the Mining Licence). The Company has spent circa US$62.7m on exploration and development to date on the Marampa Project.

In September 2018, Marampa SL received a letter from the Sierra Leone Ministry of Mines (SLMOM) cancelling the Mining Licence. In 2018, Marampa SL commenced legal action in Sierra Leone to challenge SLMOM's decision to cancel the Mining Licence ML05/2014, however, the Board has agreed to place legal action against the SLMOM on hold.

Whilst no formal application has been made to date, the Company has, and will continue to be, engaged in dialogue with the relevant Sierra Leonean authorities in an attempt to have the Mining Licence reinstated or reissued by mutual agreement.

Whilst there can be no guarantee that the SLMOM will agree to reinstate or reissue a Mining Licence, if Marampa SL were to successfully recover the Mining Licence, the Board is committed to working with the relevant parties to secure access to the necessary plant and equipment and infrastructure to enable the ramp up of the Marampa Project upon the reissue of the Mining Licence for the benefit of our shareholders as well as, importantly, the Government and People of Sierra Leone.

In parallel, Management are in preliminary discussions with third parties to secure financing to fund the development of the Marampa Project.

EL46A/2011

In 2014, Marampa SL was granted exploration license EL46A/2011. In June 2014 the SLMOM extended EL46A/2011 for a further 2-year term from 31 July 2015 until 31 July 2017. Marampa SL has not paid renewal fees to the SLMOM in respect of EL46A/2011 since 31 July 2017. However, Marampa SL has not received any termination documentation or request for information from the SLMOM, therefore is of the view that EL46A/2011 remains a valid license.

Marampa SL has contacted the SLMOM asking them to confirm the status of EL46A/2011 however no response has been received to date. Marampa SL will continue to follow up with the SLMOM to determine the status of EL46A/2011.

1. Please provide ASX with documents confirming CFE's current interest in the
   Tenements. If the documents are not in English, please provide a certified translation of the documents
   Please find attached the latest documentation received in relation to EL46A/2011 (Appendix B). As outlined in question 1, Marampa SL has contacted the SLMOM asking them to confirm the status of EL46A/2011 however no response has been received to date. Marampa SL will continue to follow up with the SLMOM to determine the status of EL46A/2011.
2. Please provide details of the Relevant Licences referred to in CFE's 14 and 23 August and 11 September 2019 announcements. Are they the same as the Tenements? Do the Relevant Licences include ML 02/09?
   The licenses referred to in the 14 and 23 August and 11 September announcements are ML05/2014 and ML02/09.
   ML05/2014 is explained under question 1.
   ML02/09 is the adjacent license to ML05/2014 and was issued to Timis Mining Corporation (Timis Mining), which had acquired the assets of London Mining Marampa Mine Assets. Timis Mining later fell into administration and in 2017 the Gerald Metals Group obtained a new licence over ML02/09 (issued under ML01/2017). On 3 August 2019, the SLMOM announced that it had temporarily suspended Gerald Metals licence ML01/2017. On 2 October 2019, the Government of

Sierra Leone confirmed that Geralds Metals license ML01/2017 has now been cancelled.

The processing plant and equipment and infrastructure which Marampa SL is planning to use during the ramp up of the Marampa Project is located on ML01/2017. As such, whilst the Company does not hold an interest in ML02/09 / ML01/2017, nor has the Company applied for ML02/09 / ML01/2017 to be issued to the Company, Marampa SL is interested in the status of this tenement.

Refer to Figure 4 on the 14 August 2019 announcement for a pictorial view of ML05/2014 and ML02/09.

The Company does not hold an interest in ML01/2017 nor has the Company applied for ML01/2017 to be issued to the Company.

1. Why has CFE made an application for reissuance of the Relevant Licences?
   CFE has commenced the application process for re-issuance of ML05/2014 in line with the Company's renewed focus on the Marampa Project.
2. When did CFE make an application for reissuance of the Relevant Licences?
   Whilst no formal application has been made to date, the Company has, and will continue to be, engaged in dialogue with the relevant Sierra Leonean authorities in an attempt to have the Mining Licence reinstated or reissued by mutual agreement.
3. Please provide documents confirming CFE's application for reissuance of the
   Relevant Licences. If the documents are not in English, please provide a certified translation of the documents
   Refer to question 5.
4. Please explain the process involved in the reissuance of the Relevant Licences and the approximate time frame for the reissuance.
   Please find attached the renewal process requirements (Appendix A). The Company is currently in discussions with the SLMOM regarding a fast track approach given technical documentation hasn't changed.
5. If CFE does not currently have an interest in the Marampa Project or Tenements why has it disclosed that it has a 100% interest in the Marampa Project and the Tenements and is directing its focus to the Marampa Project?
   Refer to response under question 1.

1. What activities does CFE propose to undertake on the Marampa Project and when is it proposed that these activities will commence? In answering this question, please include a budget for the proposed exploration activities and related expenditure.
   The Company is in the process of developing an exploration program and associated budget.
2. Does CFE consider the cancellation of ML05/2014 by the Sierra Leone Ministry of Mines to be information that a reasonable person would expect to have a material effect on the price or value of its securities?
   No
3. If the answer to question 10 is "no", please advise the basis for that view.
   The carrying value of the Marampa Project in the Company's audited accounts was fully impaired as at 30 June 2016 and remains fully impaired. The Company's focus since early 2017 has been on the Kipushi Copper-Cobalt project located in the DRC. In August 2019, the Company announced that it had been unable to source project financing for the Kipushi Copper-Cobalt project and as such it's renewed focus is now back on the Marampa Project (refer ASX announcement 14 August 2019). As such, the Company's position is that that the cancellation of ML05/2014 was not material.
4. If the answer to question 10 is "yes" and CFE first became aware of the cancellation of ML05/2014 before 31 October 2018, did CFE make any announcement prior to the relevant date which disclosed this? If so, please provide details. If not, please explain why this information was not released to the market at an earlier time, commenting specifically on when you believe CFE was obliged to release the information under Listing Rules 3.1 and 3.1A and what steps CFE took to ensure that the information was released promptly and without delay.
   Not applicable.

Legal action in the High Court of Sierra Leone

1. Does CFE consider the Litigation to be information that a reasonable person would expect to have a material effect on the price or value of its securities?
   No.
2. If the answer to question 13 is "no", please advise the basis for that view.
   Refer to response under question 11.
3. If the answer to question 13 is "yes" and CFE first became aware of the Litigation before 31 October 2018, did CFE make any announcement prior to the relevant date which disclosed this? If so, please provide details. If not, please explain why this information was not released to the market at an earlier time, commenting

specifically on when you believe CFE was obliged to release the information under Listing Rules 3.1 and 3.1A and what steps CFE took to ensure that the information was released promptly and without delay.

Not applicable.

16. Please provide an update on the current status of the Litigation.

BMT Law Chambers was previously engaged to commence litigation however as outlined under question 1, the Board has agreed to place legal action against the SLMOM on hold.

Compliance and authorization

1. Please confirm that CFE is complying with the Listing Rules and, in particular, Listing Rule 3.1.
   The Board confirms that it is in compliance with the Listing Rules, in particular Listing Rule 3.1.
2. Please confirm that CFE's responses to the questions above have been authorised and approved in accordance with its published continuous disclosure policy or otherwise by its board or an officer of CFE with delegated authority from the board to respond to ASX on disclosure matters.
   The Board confirms that is responses to the questions above have been authorized and approved by the Board of the Company.

Please contact us if you have any queries.

Yours faithfully

______________________________

Tony Sage

Executive Director

Cape Lambert Resources Limited