Global Gold Corp. (GBGD)

[BMAV1]

TO THE BOARD OF GLOBAL GOLD CORPORATION AND ITS SHAREHOLDERS

The Toukhmanuk Gold Mine has been challenged by local communities and various Environmental NGO's. I believe Mr. Ashot Poghossyan and Mr. Van Krikorian have been under-reporting to the Board and its shareholders of the challenges and material facts related to this project.


I have provided articles published by ECOLUR below. From reading these articles it is clear that:

1. The Local Community and the MELIQ Village opposes the Tailings dump/dam construction
2. Global Gold falsified minutes of the Local Community Meeting village and tried to claim the community accepted the dam
3. Complaints have been filed with authorities regarding the falsification of the minutes in March 2013
4. New Meeting rejected the Application of the Tailing Dam
5. The Area for the proposed tailings dam is in a 9 magnitude earthquake zone
6. There are apparently heavy metal contamination in the are area due to the activities of Mego-Gold
7. NGO representing 50 groups have filed a letter with the President of Armenia's Office opposing the project
8. NGO have filed criminal complaints against Global Gold/Mego-Gold


Its time that your company change its local management and remove Mr. Van Z. Krikorian as officer of the company for failing to provide timely information on the material events in Armenia. Failure to report these material events in 10K, 10Q and 8K filings is a serious breach of securities legislation potentially placing all directors of Global Gold at risk.

I have also provided to you proof that Global Gold has been keeping two accounting records in Armenia related to the mining at Toukhmnauk. Global Gold has over reported mining levels by 104% including gold grades and gold production. This information clearly puts in question the valuation of the inventory of ore and concentrate on the balance sheet of Global Gold valued currently at $559,525 on December 31, 2012.

As usual I have filed this complaint with the SEC Enforcement and the PCAOB.

Sincerely

Bill Mavridis
514-813-9200



ARTICLES: http://www.ecolur.org/en/
{ Note: ECOLUR is and Armenia Language NGO based in YErevan, Armenia. The English Translations are provided by ECOLUR}

Soil of Meliq, Rya Taza and Miraq Villages is Polluted with Heavy Metals and Toxic Elements from Tukhmanuk Gold Mine
14:02 June 13, 2013

EcoLur

Heavy and exotoxic elements such as As, Sb, Pb, Cd, Cu, Mn, V, Cr, Co, Ni, Zn, Sn, Bi are spread from Tukhmanuk gold mine via different pipes, which get accumulated in Meliq, Rya Taza and Miraq Villages, Aragatsotn Region, and other land areas, as well as in bottom sediments of Halavar and Qasagh Villages. This is what “Ecochemical Analysis of Tukhmanuk zone land and river bottom sediments” work says implemented by “ArmEcoMonitoring” SNCO Deputy Director Seyran Minasyan on “BLEJAN” NGO’s order.

According to this work, the total concentrations of potentially hazardous 17 elements and metals (Sr, Ba, Mn, V, Cr, Co, Ni, Fe, Cu, Zn, Sn, Bi, U, As, Sb, Pb, Cd) have been determined in the samples. It turned out that the concentration of the studied elements of the observation sites located above Meliq Village and below Miraq Village and interim territory of Rya Taza-Meliq exceeds MCP by 12.-2.5 times.

Reminder: Tukhmanuk gold mine is developed by “MegoGold” LLC.



EcoLur Opinion on Tailing Dump Construction Project in Meliq Village
15:16 April 25, 2013

EcoLur

“EcoLur” Informational NGO has sent its opinion on Tailing Dump Construction Project in Meliq Village to the Ministry of Nature Protection.

The opinion says, “The tailing dump construction project in Meliq village proposed by Mego Gold Company should be turned down on the following grounds: the project doesn’t reflect the factual risks and the project is isolated from complex issues of extraction, production and maintenance of industrial wastes.

The tailing dump should be the third one in the territory of Meliq village. It should collect the tails of Mega Gold gold-extracting production. The plant processes gold-bearing ore of Tukhmanuk gold mine. The data submitted in the project about the composition of tails don’t comply with the composition of ores, the data about the presence of toxic metals and toxic elements left after gold extraction are missing in the project. The assessment of background pollution of water and land areas caused by two operating tailing dumps is also missing in the project. It’s possible to indirectly judge about the pollution based on the results of the analysis carried out by the Center for Ecological Noosphere Studies of NAS RA presented to the public and by the research articles about the composition of ore in Tukhmanuk mine. The data about the probable impact on human health are missing. As Health Ministry response shows their specialists haven’t carried out any examinations in the village and they relied exclusively on the project documentation, which doesn’t reflect the real situation.

What about environmental expertise experts’ opinion, in the course of specialized hearings at Nature Protection Ministry held on 19 April, they confirmed that they relied not on the studies of the situation, which already has sharply negative background, but on the data in literature, i.e. they don’t handle the situation. The minutes of the public hearings held in Meliq Village on 27.11.2012 don’t comply with what public representatives and the locals said at the hearings proved by the video recording made by EcoLur in the course of the public hearings. In the course of the discussions held at Nature Protection Ministry on 19 April 2013 Mego Gold Company Director Ashot Poghosyan stated many times when answering to the questions that the final replies to the questions about risks raised by public can be given only when a new project for Tukhmanuk mine development will be submitted.

We propose to consider the problem of keeping industrial wastes of Tukhmanuk mine development in complete documentation package, where not only the tailing dump project will be submitted, but also the projects of mine development and gold-extracting production.”


“EcoRight” NGO Demanding Criminal Investigation for Tukhmanuk Mine Tailing Dump Project
14:21 March 12, 2013

EcoLur

“EcoIravunq” NGO (“EcoRight”) has sent a letter to Public Prosecutor Aghvan Hovsepyan on crime commission, signed by NGO Chairman Arthur Grigoryan. The letter particularly says, “On 27 November 2012 Mego Gold Company organized public hearings in Meliq Village, Aragatsots Region, on the construction project of the third tailing dump for the disposition of wastes of Tukhmanuk mine it develops. The project mentions that the tails contain the following chemical compounds, SiO2 – 46,23%; AL2O3 – 10,81%; MgO – 5,17% ; TiO2 – 0,82 %; CaO –6,41%; MnO – 0,15%; Fe2O3 – 6,4%; FeO -3,62%, but the project doesn’t say a word about heavy metals. The Center for Ecological-Noosphere Studies conducted laboratory analysis, which says that the tails contain arsenic, cadmium and lead. The divergence of the data with the project causes to suspect that the company and Lernametalurgiakan Institute intentionally misled the public by concealing the composition of the tails and their impact on the community and people’s health. The aforementioned facts point out the existing deviations of mine development from the confirmed project, which may contain the features of Articles 281 and 284 of the Criminal Code of Armenia. We think that criminal investigation needs to be carried out to reveal the creditability of the information presented in the project and to reveal to what extent the company and Lernametalurgiakan Institute intended to mislead public with this information, to what extent the activities of Tukhmanuk mine development deviates from the confirmed project and whether there are features of Articles 281 and 284 of the Criminal Code of Armenia.”


Public Demanding to Annul Minutes of Hearings on Tailing Dump Construction in Meliq Village
19:34 March 11, 2013

EcoLur

Public representatives have applied to Nature Protection Ministry demanding to annul the minutes of the hearings on the construction project of a new tailing dump in Meliq Village. The tailing dump will be the third, which Mega Gold Company, the developer of Tukhmanuk gold mine, intends to construct in the village. The application particularly says, “…In the course of the public hearings on 27 November, Meliq Village Head stated he would present the opinion of the village a month later. Nevertheless, the minutes of the hearings are dated 27 November and signed by the village head and company director. The minutes say, “The village has no objections in regard with the construction of a tailing dump…A decision was reached to approve the environmental part of Tukhmanuk dressing plant…” It’s falsification, as during the hearings many opinions were expressed about the impermissibility of constructing the third tailing dump in the village. The minutes don’t reflect the viewpoints of the villagers and public representatives. The company representatives and the project developer, who worked on the project development by company’s order, expressed their positive opinions. We demand to annul the minutes of the public hearings held by Mega Gold Company on the construction project of a new tailing dump for Tukhmanuk dressing plant in Meliq Village,” the application says. The application is corroborated with the minutes of the public hearings for 27 November and the video recording.



Public Environmental Alliance to Armenian PM: Asking to Stop “MegoGold” Company Activities
12:37 January 18, 2013

EcoLur

Public Environmental Alliance, an alliance of 50 NGOs, has addressed a letter to Armenian PM Tigran Sargsyan, which particularly says, “On 20.11.2012 the Public Environmental Alliance has filed a proposal to Nature Protection Ministry, the National Assembly Standing Committee on Agriculture and Environment to set up a working group in regard with the activities of “MegoGold” LLC in Meliq Village. We would like to ask you to assign Nature Protection Ministry, Health Ministry and Ministry of Emergency States, in the frames of their terms of reference, to conduct examination of the situation and to present the findings to the public…At present “MegoGold” Company intends to construct the third tailing dump in Meliq Village. We are asking to stop the activities of the company till the assessment of the situation on the spot.” The proposal filed to Nature Protection Ministry dated on 20.11.2012 is attached to the letter, “…According to the project (construction of a tailing dump), Meliq Village is located in the zone of nine-point seismic risks.” “MegoGold” Company intends to construct a new tailing dump in the territory of 7 ha…The company is the subsidiary of “Global Gold” Company and has been developing Tukhmanum gold mine since 2006. Ore dressing is conducted directly in the territory of Meliq Village. The village itself is in a hard situation. Numerous breakdowns of operating tailing dumps has led to the default with the water pipe of the drinking water in the village, because drinking and irrigation waters get mixed…The dust blown off the tailing dump, accumulates on the ground, which villagers cultivate and contaminate them with heavy metals. All this lead to decrease in crop productivity and caused huge damage, which hasn’t been studied and assessed. According to the villagers, they incur material and moral damage from the development of the mine and the tailing dump. Villagers’ health has been deteriorated, birth rate had reduces, cancer diseases have increased. The villagers have filed complaints to the state bodies, but to no avail,” the letter says.


Public Thinks that Mego Gold Company Should Present New Complex Project of Tukhmanuk Mine Development
12:44 December 04, 2012

EcoLur

The NGOs having taken part in the public hearings on the construction project of the tailing dump of Mego Gold Company in Meliq Village on 27 November think that a new complex project should be presented on the development of Tukhmanuk gold mine.

In their statement to Aram Harutyunyan, Minister of Nature Protection, they noted, “On 27 November 2012 “Mego Gold” Company organized public hearings on the construction project of a new tailing dump in Meliq Village, Aragatsotn Region. The public hearings were participated by Meliq villagers and Village Head Hakob Mkrtchyan, “Mego Gold” LLC Director Ahsot Poghosyan, “Mego Gold” LLC Deputy Director Henrikh Mkrtchyan, Nature Protection Ministry “Environmental Expertise” SCNO Expert Laura Balayan, Head of Environmental Department of “Lernametalurgiakan Institute” Hovik Nikoghosyan, public representatives – Greens Union Chairman Hakob Sanasaryan, “Shogher” Union Chairman Hasmik Aslanyan, Yerevan Aarhus Center Coordinator Silva Ayvazyan, Aparan Aarhus Center Coordinator Natalya Manukyan, Lawyer of Aarhus Centers Arthur Grigoryan, expert-hydrologist Qnarik Hovhannisyan, Editor of http://www.ecolur.org/ Victoria Burnazyan and mass media. Nevertheless, the minutes of the public hearings were not drawn up on the spot.

The participants put their signatures on a separate sheet of paper, which should be attached to the minutes. Meanwhile, a part of the participants, such as the representative of the Environmental Expertise Laura Balayan and Developer Hovik Nikaghosyan left the hall before the end of the hearings. Meliq Village Head Hakob Mkrtchyan stated that the villagers will express their opinions within a month.

We, public representatives, were not acquainted with the text of the minutes and think that the procedure of hearings minutes taking was violated, and consequently, the minutes, as an official document, should be recognized null and void.

Then, under the project:

1. We consider it necessary that Mego Gold Company to meet the demand of the local population and introduce it into the project:

a) the plan of reclamation of two tailing dumps with diagrams and cost of actions. If the company intends to extract the gold it contains, the activities of tail processing should also be included into the project.

b) an alternative of Tukhmanuk gold mine development in closed method,

c) to estimate the damage caused to farms in Meliq Village or plan of actions for consequence minimization,

d) in case of production expansion, to present a plan for forced resettlement.

2. In the course of the public hearings in Meliq Village on 27 November, Company Director Ashot Poghosyan stated that there are plans to expand production and mining volumes, while the issue of new tailing dumps may arise. For the purpose of correct assessment of risks for hazardous objects and supposed actions of Mego Golf Company we think it’s necessary for the company to present a complex project, where the integral part of the project will be the construction of new tailing dumps. The project should also present measures on prevention of environmental pollution.

3. In the presented project the components of tails don’t comply with scientific data (Sh. Khachatryan, “Geochemical characteristics of Tukhmanuk Gold Mine (Aragatsotn Region)”, “Procs of Yerevan State University, 3 (223), 2010). We would ask the developer company to submit the methodology and experimental findings.

4. Developer Hovik Nikaghosyan has tightly connected the construction of a new tailing dump and employment at the plant. “If there is no tailing dump, there will be no mine operating, if there is no mine operating, there will be no plant operating… Everything depends on you, if you don’t want, you can reject, and the mining industry will be closed down in Meliq Village…” We value this statement as misinformation, as the company is able to present an alternative, for example, to conclude an agreement with other ore processing plant.”

Mego Gold Company Intends to Construct Another Tailing Dump Besides Designed Third Tailing Dump (Photos)
17:35 November 28, 2012

EcoLur

Meliq villagers have to decide whether or not they agree “Mego Gold” Company to construct a new tailing dump in the territory of the village. This is what Meliq Village Head said in the course of public hearings on the project on 27 November. Like the previous tome, the minutes of the public hearings were not drawn up. It’s still unknown when the minutes will be drawn up as an official document and passed to the environmental expertise. It’s also not clear, what these minutes will include out of the expressed opinions. The public representatives considered this to be a violation of the procedure and didn’t sign under the list of participants, while the villagers expressed their extreme concern with project risks. First of all, these risks include two non-cultivated tailing dumps and a damaged irrigation system, as a result of which 60 families lost their harvest of the potatoes. People complain of bad ecology and problems with birth rate. The NGOs expressed such an opinion that the village is on the verge of resettlement, as these land areas will stop to be fertile, while after several months it won’t be possible to cultivate these land areas.

But this is not all. Besides the designed construction of the third tailing dump, the company intends to construct another tailing dump, as Mego Gold Company is going to expand its mining volumes in Tukhmanuk gold mine despite the accumulated debts.

More details about all this, about questions and answers raised in the course of the public hearings will be provided in upcoming news by EcoLur.


MegoGold Company Project in Meliq Village: “It's Early to Speak about New Tailing Dump Unless First Tailing Dump Recultivated” (Photos)
15:29 November 01, 2012

EcoLur

Meliq Village hasn't yet made a decision on the construction of a new tailing dump. 'It's early to speak about a new tailing dump, unless the first tailing dump is recultivated,' Said Meliq Village Head Hakob Mkrtchyan. The public hearings on the construction project of a new tailing dump for Megogold Company was held in Meliq Village on 30 October. Nevertheless, the villagers didn't know anything either about the project or the public hearings. Only after half an hour after the appointed time, about 20 people came to participate in the hearings and presented their problems concerning the company activities. An interesting fact: one of the participants, Karen, who had declared about the company owing him money, over 500,000 AMD as a salary, is at the same time the shareholder of American 'Global Gold Mining' Company. The certificate is issued for 250 USD. 'When the company's business was good, about 30 employees received such certificates. I still don't know, what I will gain, but I'm not going to sell it,' Karen said.

The main problem is that the company intends to take new territories from the village, but it hasn't recultivated old tailing dumps, which cause essential damage to the village.

One tailing dump is mentioned in the list of 19 tailing dumps known to the Ministry of Emergency States. The characteristics of the tailing dump are as follows: distance from Meliq Village – 2 km, projected volume – 90,000 cubic meters, fullness – 45,000 cubic meters. The second tailing dump is missing in the list.

EcoLur working group asked to help them to get familiar with the spot of new tailing dump construction and the state of the old tailing dump. Nevertheless, the official representative of the company Henrikh Mkrtchyan left and took with them the representative of Nature Protection Minister Laura Balayan and projector Hovik Nikaghosyan.

A local resident agreed to take us to the place. Outwardly, the tailing dump complied with what the residents said about it during the hearings. Water flew out of one of them through the dug out canal. There were no dams or concrete fortifications. Unfortunately, there was nobody we could ask a question about what we had seen, while the workers having come to the spot after us just forces us out of the territory. “Go away, you don't have any right, this is our territory…”, they said. The explanations that the company is the organiser of the hearings and shouldn't hinder to examine the project on the spot didn't help.

The hearings were held in tense atmosphere. In near future you can watch the video by EcoLur, which shows the Q&A session between residents and Hovik Nikaghosyan and Henrikh Mkrtchyan.


Tailing Dump To Be Constructed in Meliq Village, 9-magnitude Seismic Zone
17:35 October 29, 2012

EcoLur

“MegoGold” LLC intends to construct a tailing dump in the territory of 7 ha in Meliq village (Aragatsotn Region), a 9-magnitude seismic zone. Public hearings on the tailing dump project will be held in the administration building of Meliq Village at 12:00 p.m. on 30 November. “MegoGold” LLC is registered in Armenia and is the subsidiary of Global Gold Company. The tailing dump will be located in a distance of 1600 meters far away from the plant. “…The volume of dumps will make up 88.6 % of all the processing volume...The composition of the tails include SiO2 – 46,23%; AL2O3 – 10,81%; MgO – 5,17% ; TiO2 – 0,82 %; CaO – 6,41%; MnO – 0,15%; Fe2O3 – 6,4%; FeO -3,62%…

Emissions into atmosphere will make up 277.27 tons during construction works… Main polluting substances in the emissions near settled areas are within standards…There are two deep tectonic fractures in the territory…According to the standards of seismic construction, the territory is located in 9-magnitude seismic zone… The volume of ores taken out during the construction works will make up 3342235 tons… Risks at construction works – elimination of vegetation, pollution of territory with construction garbage… Economic damage will make up 733.117 million AMD... The presented sum is not a ground for financial liability… The total amount of damage for environment – air, water and soil, will make up 4,426,620 AMD…”, - the report says.

The report doesn’t say how many tons of raw materials mined from Tukhmanuk mine per year will be processed at the factory and how many tons of tails will be dumped into the tailing dump. Let’s make a reference to the information provided by ArmInfo News Agency in 2008, “…The data of the State Committee on Reserves say that the level of reserves in Tukhmanuk mine make up 12.1 tons of gold with gold ratio 6.74 gr per ton and 30.79 grams of silver per ton.”


“MegoGold” Proposing to Construct New Tailing Dump in Aragatsotn Region
18:27 October 16, 2012

EcoLur

The official website of Nature Protection Ministry informs that “MegoGold” LLC proposes to construct a new tailing dump for the processing plant in Aragatsotn Region. “MegoGold” LLC is developing Tukhmanuk gold mine. The tailing dump, sized 1.53 ha, shall be located next to Melik village. The insoluble part of the tails consists of SiO2 – 46,23%; AL2O3 – 10.81%; MgO – 5.17% ; TiO2 – 0.82 %; CaO – 6.41%; MnO – 0,15%; Fe2O3 – 6.4%; FeO -3.62%... During the functioning of the tailing dump, dust emissions will make up 25.6 tons per year or 0.128 tons per day...”

Photo by www.yerkirmedia.am