Supplementary Deck Detail

The Market, the Model, and Why Tailings Are Lower Risk

Deeper detail on the opportunity behind the numbers on the main investment page — pulled directly from the July 2026 investor deck.

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The Market & Why Now

Kenya's Artisanal Gold Sector Produces Massive Volumes of Untapped Tailings

$5.28B

Gold deposits confirmed in Kakamega (Shanta Gold, Nov 2025)

358.8 kg

Official gold production in 2024 (Economic Survey)

250,000+

People directly employed in artisanal gold mining

Royalty rate (reduced from 5% in 2024)

~$4,100/oz

Current gold price; we model at $3,500/oz conservative

The Tailings Opportunity

40–60%

Gold lost to tailings in artisanal gravity recovery

Thousands of tonnes

Of tailings discarded annually in Kakamega alone

Zero competition

No formal CIL tailings processor in Western Kenya. Government push: ASM formalization under Mining Act 2016.

The Gap We Fill

Artisanal miners capture only 40–60% of gold via gravity. The remaining 40–60% stays in tailings as fine particles too small for sluices and shaking tables. Legion Mining buys these tailings, leaches the fine gold via CIL, and sells refined doré — turning waste into revenue for both miners and investors.

The Business Model

Tailings Aggregation + CIL Processing + Gold Sale

Artisanal Miners

Gravity recovery. Coarse gold kept. Tailings sold to Legion.

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Legion Mining

Buy tailings, CIL leaching, recover fine gold.

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Licensed Buyers

Doré bars. Spot price −2–3%. Export/refining.

Revenue Streams

~90%

Primary: Gold Sales

Refined doré bars sold to licensed gold buyers at spot price minus 2–3% refining fee.

~10%

Secondary: Toll Processing

CIL processing for cooperatives with verified high-grade tailings. Higher margin, lower risk.

Value Proposition to Miners

Additional revenue stream: they sell tailings they currently discard
No process change: their gravity operation continues unchanged
Transparent pricing: assay-based, no cheating
Weekly cash payment: improves cash flow vs. monthly informal settlements

Operational Advantages

Why Tailings Processing Is Lower Risk Than Fresh Ore

Advantage	Detail	Risk
No crushing/milling required	Pre-milled to ~75–150 microns from artisanal ball mills. Direct to CIL after scrubbing/classification.	Low
Proven feed source	Miners already proved ore contains gold (recovered coarse fraction). Tailings are "de-risked" feed.	Low
70–80% water recycling	Tailings thickener + return ponds. Critical in water-scarce Kakamega.	Low
24/7 continuous operation	Diesel generator + backup rental agreement. Maximum throughput.	Medium
80% local labour	Community employment builds social license.	Medium
6-tank CIL configuration	Proven, efficient, low maintenance. 2m diameter x 2m height each.	Medium

Validated Thesis

The "no milling" claim is not theoretical. Artisanal miners in Kakamega already use ball mills as part of their gravity recovery process. Legion buys the waste tailings they discard. This is a tailings reprocessing model, not a greenfield mining operation.

Next Step

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