EITI-C Simandou — Targeted Disclosure-Data Deepening

Methodology sub-page · Effective 17 May 2026 (v1.1.2 deploy) · Editorial responsibility: Nikesh Patel · Status: SCAFFOLD v1 — every disclosure field [Pending — verify against EITI publication]; primary-source verification is post-v1.1.2 cycle work.

What EITI-C does. EITI-C is a targeted disclosure-data deepening on named contexts only — at v1.1.2 publication, the December 2025 Simandou contract disclosures (Guinea, West African Craton, Fe). The platform's broader EITI integration is status-lookup only: a 29-country lookup rendered as a one-line composite fact and weighted into the country-composite picture at the 30/25/25/20 Fraser/TI/RGI/EITI ratio per §03. EITI-C adds a disclosure-data layer at deposit-by-deposit resolution, structured to surface fiscal terms, ownership, payments, and contract architecture where EITI publishes such disclosures. The deepening pairs with the §10.2 geopolitical risk substrate as the per-context fiscal-terms-disclosure layer.
Scaffold v1 — read before use. This page ships the structure of the Simandou disclosure-data block. The field structure below is a working hypothesis based on EITI's published disclosure schemata; populate-phase work — opening the actual December 2025 Simandou EITI publication and walking field-by-field — is post-v1.1.2 cycle. Every value below ships [Pending — verify against EITI publication]. No disclosure value is asserted on this page. When primary-source verification completes, fields move from Pending to Sourced via an audit log entry per §10.9 protocol; movements that surface material disclosure facts on the Guinea / Simandou platform context are propagated to the surfacing surfaces at the same cycle.

§1 — Scope and rationale

Three editorial choices define EITI-C v1 scope:

  1. Targeted, not generalised. EITI-C ships as a disclosure-data layer on named contexts only — at v1.1.2, the December 2025 Simandou contract disclosures (Guinea, Fe, West African Craton). The 29-country EITI status-lookup remains unchanged across all other jurisdictions; the 30/25/25/20 country-composite weighting per §03 is unaffected by EITI-C; the IC composite for West African Craton is not modified by this addition.
  2. Per-context deepening, not per-asset surfacing. Simandou is not a worked dossier in the institutional-grade dossier set (the v1.1.2 worked set remains Kamoa-Kakula, Kabanga, Manono, Loulo-Gounkoto, and Lobito Corridor). EITI-C attaches as a narrow disclosure-data block on the existing Guinea / Simandou platform context (the COUNTRY_COVERAGE Guinea 25% entry + the West African Craton opportunity field).
  3. Lobito Corridor EITI-C deferred to v1.2 Phase 2. The 2025 Lobito Corridor EITI work is structurally additive on the same pattern; Lobito's EITI-C panel ships in the v1.2 Phase 2 cycle alongside the deeper Lobito Bankability + Downstream Risk panel build cycle (Lobito Corridor is a system-level multi-jurisdiction corridor exposure and warrants its own dedicated turn). A generalised per-contract EITI disclosure surface across the broader EITI member set remains deferred pending a user or acquirer signal that one is wanted; not dated to v1.3 specifically.

The rationale for targeted-not-generalised: EITI's per-contract disclosure landscape is heterogeneous (different country chapters publish disclosures at different granularities, on different cycles, in different formats). A generalised surface requires a published per-contract field-structure standard surviving external review, plus per-publication verification discipline scaling to the full EITI member set. Neither precondition is met at v1.1.2; pulling Simandou forward as a single named context preserves the discipline.

§2 — Simandou context

Simandou is a four-block iron ore project in southeastern Guinea (Forécariah and Faranah regions; West African Craton geological province). The Simandou North blocks (1 + 2) are operated by the Baowu Winning Consortium; Simandou South blocks (3 + 4) are operated by Rio Tinto via the Simfer joint venture with Chinalco. First shipment completed 2 December 2025 (Baowu Winning Consortium, 200 kt to China per public disclosure). 2026 production guidance per public sources: 5–20 MMt ramp; full ramp toward 120 MMt by 2030 per project documentation.

The Government of Guinea holds equity stakes in Simandou operations under multi-decade infrastructure-and-mining concession architecture. The December 2025 contract disclosures published via Guinea's EITI National Secretariat are the substrate for this targeted deepening. EITI is cited here as a public-source transparency-disclosure institution per its published Standard and country-chapter reporting. No commercial or partnership relationship is implied or claimed between Afrimintel and EITI, the EITI International Secretariat, NRGI, the Government of Guinea, the Guinea EITI National Secretariat, Rio Tinto, Baowu, the Baowu Winning Consortium, Chinalco, or Simfer.

§3 — Simandou disclosure-data block (scaffold)

The disclosure-data block below is the working structure for the December 2025 Simandou EITI disclosures. Field groups are organised by the four-category schema EITI publishes for contract-level disclosures: fiscal terms, ownership and control, payments to government, and contract architecture. Every field ships [Pending — verify against EITI publication]. Source target identifies the EITI publication and supporting documents that the populate-phase will open against.

Block 1 — Fiscal terms

FieldWorking structureSource targetState
Royalty rates Per-block royalty schedule; commodity-price-linked tranching if applicable Guinea EITI December 2025 contract disclosure publication; Mining Code 2011 (as amended) royalty schedule PENDING
State participation share Government of Guinea direct equity stake per operating company (Simfer SA; Compagnie du TransGuinéen for rail-port; Baowu Winning Consortium block-specific entities) Guinea EITI publication + concession-agreement public summaries PENDING
Corporate income tax rate Mining-sector-specific rate per Guinea Mining Code; ring-fencing applicability Mining Code 2011 (as amended) + Loi de Finances 2025 PENDING
Withholding tax rates WHT on dividends, services, royalties paid abroad Guinea EITI + DGI publications PENDING
VAT and customs treatment Mining-input VAT exemptions; import-duty treatment for capital equipment; export-duty treatment on Fe ore Guinea EITI + Customs Code references PENDING
Local-content obligations Per concession agreement, where disclosed Guinea EITI contract disclosure PENDING

Block 2 — Ownership and control

FieldWorking structureSource targetState
Operating-company structure Per block: ultimate parent / operating company / joint-venture structure / state share Guinea EITI beneficial-ownership disclosure + operator regulatory filings PENDING
Beneficial ownership BO disclosure per EITI 2019 Standard requirement Guinea EITI BO register PENDING
Infrastructure-share arrangements TransGuinéen rail-port joint structure between Baowu Winning Consortium + Rio Tinto + state per concession terms Guinea EITI publication + multilateral agreements between Simandou stakeholders (public summaries) PENDING

Block 3 — Payments to government (2024 reporting year scaffold)

FieldWorking structureSource targetState
Total payments to government (USD) Aggregate of taxes, royalties, fees per EITI reconciliation; 2024 reporting year as the most recent EITI cycle pre-ramp Guinea EITI Annual Report 2024 (cycle ending 2025) PENDING
Disaggregation by payment type Royalties / corporate income tax / WHT / fees / other Guinea EITI reconciliation report PENDING
Disaggregation by recipient entity Treasury / specific public agencies / local government allocations Guinea EITI reconciliation report PENDING
Payment-flow reconciliation status Reconciled / partially reconciled / disputed per EITI methodology Guinea EITI reconciliation report PENDING

Block 4 — Contract architecture and amendments

FieldWorking structureSource targetState
Underlying agreement(s) Investment framework agreement(s); concession term; ratification status Guinea EITI contract disclosure + Government of Guinea gazette publications PENDING
Material amendments Post-2015 amendments; 2020–2025 amendment cycle; December 2025 contract publication scope Guinea EITI publication + gazette amendment record PENDING
Dispute resolution framework Arbitration forum named in concession; governing law Guinea EITI publication + concession-agreement public summaries PENDING
Environmental and social commitments Per concession agreement, where disclosed publicly Guinea EITI publication + ESIA public summaries PENDING

§4 — Populate-phase workflow

The populate-phase moves fields from Pending to Sourced through this sequence:

  1. Open the publication. Open the December 2025 Simandou EITI contract disclosure as published by the Guinea EITI National Secretariat. Confirm publication URL, date, and version.
  2. Field-structure confirmation. Walk the §3 working structure against the actual publication. Where the actual field structure differs (e.g. EITI publishes royalty in tranches not in a single rate; state participation is held via multiple SPVs not a single entity), update §3 to match the disclosed structure. Field-structure changes are non-trivial and merit an audit log entry per §10.9.
  3. Per-field population. For each field, capture the disclosed value, the precise location in the publication (page / paragraph / table reference), and the publication date. Move the field from Pending to Sourced with the citation attached.
  4. Cross-reference verification. For load-bearing values (royalty rates; state participation share; aggregate payments to government), cross-reference against at least one secondary primary source (operator regulatory filings, gazette publication, concession-agreement public summary) per the Hallucination Guard protocol.
  5. Surfacing. Material disclosure facts (e.g. a published royalty schedule with concrete rates) propagate to the Guinea / Simandou platform context surface — the COUNTRY_COVERAGE Guinea action field and the West African Craton opportunity field. Audit log entry records the surface propagation.
  6. Counterparty Extension preservation. Throughout, no claim of commercial relationship with any party named in the EITI disclosure is implied; EITI publication is cited per its published terms; named parties (Rio Tinto, Baowu, Chinalco, Government of Guinea, Simfer, Compagnie du TransGuinéen, etc.) appear strictly as publication subjects.

§5 — Relationship to broader Afrimintel surfaces

EITI status-lookup unchanged. Afrimintel's 29-country EITI status-lookup (Compliant / Validated / Candidate / Suspended / Not-yet-EITI) remains as currently surfaced across the country and methodology layers. The 30/25/25/20 Fraser/TI/RGI/EITI country-composite weighting per §03 is unaffected by EITI-C. The IC composite values in §07 Table 4 do not change as a result of this EITI-C addition.

§10 bankability and downstream-risk layer cross-references. The Simandou disclosure-data block, once populated, refines the geopolitical-risk substrate at §10.2 dimension 3 (Geopolitical risk — EITI fiscal-terms disclosure substrate) for the Guinea / Simandou context. §10.8 deferral item 4 is updated in the v1.1.2 cycle to reflect the targeted-vs-generalised framing this page establishes.

Discount-rate decomposition framework. EITI-C disclosure-data does not directly modify the Discount Rate Derivation Framework v1 components. EITI-disclosed fiscal terms feed institutional users' DCF assumptions (royalty rates, corporate income tax, withholding); the platform's discount-rate components are unaffected. Where EITI-disclosed contract architecture surfaces tenure or settlement-state facts material to πt or πd classification on a specific asset, the audit log records the propagation.

§6 — Scope, forward-state, and discipline notice

What this sub-page does at v1.1.2 publication:

What this sub-page does NOT do at v1.1.2 publication:

Forward-state. Methodological precondition for any future generalised per-contract EITI disclosure surface: published per-contract field-structure standard surviving external review, plus per-publication verification discipline scaling to the full EITI member set. Until those preconditions are met, EITI-C remains a targeted-context layer.

Discipline notice. Quality Standard three-state discipline applied throughout (Sourced — named authoritative document with date; Derived — Afrimintel calculation with published methodology; Pending — working-state awaiting primary-source verification within named cycle window; Absent — no claim made). Targeted-vs-generalised framing preserved. 29-country EITI status-lookup unchanged. 30/25/25/20 country-composite weighting per §03 unaffected. §10.2 dimension 3 framework citation. Generalised surface deferred indefinitely. Counterparty Extension preservation: EITI is cited as a public-source transparency-disclosure institution per its published reports and terms; no commercial relationship is implied with EITI, NRGI, Government of Guinea, Rio Tinto, Baowu, the Baowu Winning Consortium, Chinalco, Simfer, or any other party named.