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Energy Fuels Inc.

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FY2023 Annual Report · Energy Fuels Inc.
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

FORM 10-K

☒ ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

For the fiscal year ended December 31, 2023 

or

☐ TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 

1934

For the transition period from ___________________ to ___________________

Commission file number: 001-36204

ENERGY FUELS INC.
(Exact Name of Registrant as Specified in Its Charter)

Ontario,

Canada

98-1067994

(State or other jurisdiction of incorporation or organization)

(I.R.S. Employer Identification No.)

225 Union Blvd., Suite 600

Lakewood, Colorado

(Address of principal executive offices)

80228

(Zip Code)

(303) 974-2140

(Registrant’s telephone number, including area code)

Securities registered pursuant to Section 12(b) of the Act:

Title of each class

Trading Symbol(s)

Name of each exchange on which registered

Common Shares, no par value

UUUU

EFR

NYSE American

Toronto Stock Exchange

 
Securities registered pursuant to Section 12(g) of the Act:

None

(Title of Class)

Indicate by check mark if the registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities Act.   Yes ☒     No ☐

Indicate by check mark if the registrant is not required to file reports pursuant to Section 13 or Section 15(d) of the Act.   Yes ☐     No ☒

Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange 
Act of 1934 during the preceding 12 months (or for such shorter period that the registrant was required to file such reports), and (2) has been 
subject to such filing requirements for the past 90 days.   Yes ☒     No ☐

Indicate by check mark whether the Registrant has submitted electronically every Interactive Data File required to be submitted pursuant to 
Rule 405 of Regulation S-T (§ 232.405 of this chapter) during the preceding 12 months (or for such shorter period that the registrant was 
required to submit such files).   Yes ☒    No ☐

Indicate  by  check  mark  whether  the  registrant  is  a  large  accelerated  filer,  an  accelerated  filer,  a  non-accelerated  filer,  a  smaller  reporting 
company, or an emerging growth company. See the definitions of “large accelerated filer,” “accelerated filer,” “smaller reporting company,” 
and “emerging growth company” in Rule 12b-2 of the Exchange Act:

Large Accelerated Filer ☒         

Accelerated Filer ☐       

Non-Accelerated Filer  ☐        

Smaller Reporting Company ☐ 

Emerging Growth Company ☐

If an emerging growth company, indicate by check mark if the registrant has elected not to use the extended transition period for complying 
with any new or revised financial accounting standards provided pursuant to Section 13(a) of the Exchange Act.   ☐

Indicate by check mark whether the registrant has filed a report on and attestation to its management's assessment of the effectiveness of its 
internal  control  over  financial  reporting  under  Section  404(b)  of  the  Sarbanes-Oxley  Act  (15  U.S.C.  7262(b))  by  the  registered  public 
accounting firm that prepared or issued its audit report.   ☒

If  securities  are  registered  pursuant  to  Section  12(b)  of  the  Act,  indicate  by  check  mark  whether  the  financial  statements  of  the  registrant 
included in the filing reflect the correction of an error to previously issued financial statements.   Yes ☐     No ☒

Indicate  by  check  mark  whether  any  of  those  error  corrections  are  restatements  that  required  a  recovery  analysis  of  incentive-based 
compensation received by any of the registrant’s executive officers during the relevant recovery period pursuant to §240.10D-1(b).   
Yes ☐     No ☒

Indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Act).   Yes ☐     No ☒

State the aggregate market value of the voting and non-voting common equity held by non-affiliates computed by reference to the price at 
which  the  common  equity  was  last  sold,  or  the  average  bid  and  asked  price  of  such  common  equity,  as  of  the  last  business  day  of  the 
registrant’s most recently completed second fiscal quarter: $954.99 million.

If securities are registered pursuant to Section 12(b) of the Act, indicate by check mark whether the financial statements of the registrant 
included in the filing reflect the correction of an error to previously issued financial statements. ☐

Indicate by check mark whether any of those error corrections are restatements that required a recovery analysis of incentive-based 
compensation received by any of the registrant’s executive officers during the relevant recovery period pursuant to §240.10D-1(b). ☐

The number of common shares of the Registrant outstanding as of February 21, 2024 was 163,570,079. 

 
 
 
 
 
 
 
 
 
 
 
DOCUMENTS TO BE INCORPORATED BY REFERENCE

Certain information required in Items 10, 11, 12, 13 and 14 of Part III of this Annual Report on Form 10-K is incorporated by reference from 
our  proxy  statement  for  our  2024  Annual  and  Special  Meeting  of  Shareholders,  which  will  be  filed  with  the  United  States  Securities  and 
Exchange Commission within 120 days after the end of the fiscal year ended December 31, 2023.

ENERGY FUELS INC.
FORM 10-K
FOR THE YEAR ENDED DECEMBER 31, 2023
TABLE OF CONTENTS

SUBPARTS

 PART I

ITEM I: CAUTIONARY STATEMENT REGARDING FORWARD-LOOKING 
STATEMENTS AND RISK FACTOR SUMMARY
ITEM II: CAUTIONARY NOTE TO INVESTORS CONCERNING DISCLOSURE OF 
MINERAL RESOURCES AND RESERVES
ITEM III: GLOSSARY OF TECHNICAL TERMS

ITEM IV: GLOSSARY OF REGULATORY AGENCIES AND EXCHANGES

ITEM 1. DESCRIPTION OF BUSINESS

ITEM 1A. RISK FACTORS

ITEM 1B. UNRESOLVED STAFF COMMENTS

ITEM 1C. CYBERSECURITY

ITEM 2. DESCRIPTION OF PROPERTIES

ITEM 2A. OVERVIEW

ITEM 2B. SUMMARY OF MINERAL RESERVES AND RESOURCES

ITEM 2C. THE NICHOLS RANCH PROJECT

ITEM 2D. THE WHITE MESA MILL

ITEM 2E. THE PINYON PLAIN PROJECT

ITEM 2F. THE ROCA HONDA PROJECT

ITEM 2G. THE SHEEP MOUNTAIN PROJECT

ITEM 2H. THE BULLFROG PROJECT

ITEM 2I. THE LA SAL PROJECT

ITEM 2J. THE BAHIA PROJECT

ITEM 2K. NON-MATERIAL MINERAL PROPERTIES

ITEM 3. LEGAL PROCEEDINGS

ITEM 4. MINE SAFETY DISCLOSURE

 PART II

ITEM 5. MARKET FOR THE REGISTRANT’S COMMON EQUITY, RELATED 
STOCKHOLDER MATTERS AND ISSUER PURCHASES OF EQUITY SECURITIES
ITEM 6. [RESERVED]

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7

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13

36

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68

81

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96

103

111

116

126

132

137

137

138

142

ITEM 7. MANAGEMENT’S DISCUSSION AND ANALYSIS OF FINANCIAL CONDITION 
AND RESULTS OF OPERATIONS
ITEM 7A. QUANTITATIVE AND QUALITATIVE DISCLOSURES ABOUT MARKET RISK 156

143

ITEM 8. FINANCIAL STATEMENTS AND SUPPLEMENTARY DATA

ITEM 8A. REPORTS OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

ITEM 8B. CONSOLIDATED STATEMENTS OF OPERATIONS AND COMPREHENSIVE 
INCOME (LOSS)
ITEM 8C. CONSOLIDATED BALANCE SHEETS

ITEM 8D. CONSOLIDATED STATEMENTS OF CHANGES IN EQUITY

ITEM 8E. CONSOLIDATED STATEMENTS OF CASH FLOWS 
ITEM 8F. NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
ITEM 8F(1). THE COMPANY AND DESCRIPTION OF BUSINESS
ITEM 8F(2). SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES
ITEM 8F(3). MARKETABLE SECURITIES
ITEM 8F(4). RECEIVABLES

158

159

161

162

163

165
167
167
168
173
173

1

 
 
 
 
 
 
 
 
 
ITEM 8F(5). INVENTORIES

ITEM 8F(6). INVESTMENTS

ITEM 8F(7). PROPERTY, PLANT AND EQUIPMENT AND MINERAL PROPERTIES

ITEM 8F(8). ASSET RETIREMENT OBLIGATIONS AND RESTRICTED CASH

ITEM 8F(9). CAPITAL STOCK

ITEM 8F(10). BASIC AND DILUTED INCOME (LOSS) PER COMMON SHARE

ITEM 8F(11). SHARE-BASED PAYMENTS

ITEM 8F(12). INCOME TAXES

ITEM 8F(13). SUPPLEMENTAL FINANCIAL INFORMATION

ITEM 8F(14). COMMITMENTS AND CONTINGENCIES

ITEM 8F(15). FAIR VALUE ACCOUNTING

ITEM 8F(16). REVENUE

ITEM 8F(17). RELATED PARTY TRANSACTIONS

ITEM 8F(18). SUBSEQUENT EVENTS

ITEM 9. CHANGES IN AND DISAGREEMENTS WITH ACCOUNTANTS ON 
ACCOUNTING AND FINANCIAL DISCLOSURE
ITEM 9A. CONTROLS AND PROCEDURES
ITEM 9B. OTHER INFORMATION

ITEM 9C. DISCLOSURE REGARDING FOREIGN JURISDICTIONS THAT PREVENT 
INSPECTIONS

ITEM 10. DIRECTORS, EXECUTIVE OFFICERS AND CORPORATE GOVERNANCE

ITEM 11. EXECUTIVE COMPENSATION

ITEM 12. SECURITY OWNERSHIP OF CERTAIN BENEFICIAL OWNERS AND 
MANAGEMENT AND RELATED STOCKHOLDER MATTERS
ITEM 13. CERTAIN RELATIONSHIPS AND RELATED TRANSACTIONS AND 
DIRECTOR INDEPENDENCE
ITEM 14. PRINCIPAL ACCOUNTANT FEES AND SERVICES

ITEM 15. EXHIBITS AND FINANCIAL STATEMENT SCHEDULES

ITEM 16. FORM 10-K SUMMARY

174

174

176

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179

180

180

185

187

188

189

191

192

192

193

193
193

194

195

195

195

195

195

195

199

200

 PART III

 PART IV

 SIGNATURES

2

 
 
 
 
 
 
 
 
 
CAUTIONARY STATEMENT REGARDING FORWARD-LOOKING STATEMENTS 

AND RISK FACTOR SUMMARY

This  Annual  Report  on  Form  10-K  and  the  exhibits  attached  hereto  (the  “Annual  Report”)  contain  “forward-looking 
statements”  and  “forward-looking  information”  within  the  meaning  of  applicable  United  States  (“U.S.”)  and  Canadian 
securities  laws  (collectively,  “forward-looking  statements”),  which  may  include,  but  are  not  limited  to,  statements  with 
respect  to  Energy  Fuels  Inc.’s  (the  “Company's”  or  “Energy  Fuels'”):  anticipated  results  and  progress  of  our  operations  in 
future periods; planned exploration; development of our properties; plans related to our business, such as the ramp-up of our 
uranium business in response to improved uranium prices, our rare earth element (“REE”) line of business, including work on 
our  South  Bahia  heavy  mineral  sands  (“HMS”)  project  in  Brazil  (the  “Bahia  Project”)  and  our  planned  development  of 
capabilities for the commercial separation of REEs at our White Mesa Mill (the “White Mesa Mill” or the “Mill”) in Utah; 
plans related to our potential recovery of radioisotopes at the Mill for use in the production of targeted alpha therapy (“TAT”) 
medical treatments; any plans related to the acquisition of additional mineral properties; and any plans relating to the ramp-up 
of production or ongoing operations at any of our uranium, uranium/vanadium and/or HMS properties. These statements relate 
to analyses and other information that are based on forecasts of future results, estimates of amounts not yet determinable and 
assumptions of management.

Any  statements  that  express  or  involve  discussions  with  respect  to  predictions,  expectations,  beliefs,  plans,  projections, 
objectives,  schedules,  assumptions,  future  events,  or  performance  (often,  but  not  always,  using  words  or  phrases  such  as 
“expects” or “does not expect,” “is expected,” “is likely,” “budgets,” “scheduled,” “forecasts,” “intends,” “anticipates” or “does 
not  anticipate,”  “continues,”  “plans,”  “estimates,”  or  “believes,”  and  similar  expressions  or  variations  of  such  words  and 
phrases or statements stating that certain actions, events or results “may,” “could,” “would,” “might,” or “will” be taken, occur 
or be achieved) are not statements of historical fact and may be forward-looking statements.

Forward-looking statements are based on the opinions and estimates of management as of the date such statements are made. 
We believe that the expectations reflected in these forward-looking statements are reasonable, but no assurance can be given 
that these expectations will prove to be correct, and such forward-looking statements included in, or incorporated by reference 
into, this Annual Report should not be unduly relied upon. 

Readers are cautioned that it would be unreasonable to rely on any such forward-looking statements as creating any legal rights, 
and that the forward-looking statements are not guarantees and may involve known and unknown risks and uncertainties, and 
that actual results are likely to differ (and may differ materially), and objectives and strategies may differ or change, from those 
expressed or implied in the forward-looking statements as a result of various factors. Such risks and uncertainties include, but 
are  not  limited  to:  global  economic  risks,  such  as  the  occurrence  of  a  pandemic,  political  unrest  or  wars;  cybersecurity  risks 
associated  with  critical  and  other  highly  sensitive  minerals  of  international  interest,  which  are  key  to  national  security;  risks 
associated  with  the  restart  and  subsequent  operation  of  any  of  our  uranium,  uranium/vanadium  and  HMS  mines;  risks 
associated with our commercial production of an REE carbonate (“RE Carbonate”) or separated REE oxides and the planned 
expansion of such production, and risks associated with the exploration and development of our Bahia Project in Brazil; risks 
associated with the potential recovery of radioisotopes for use in the Company’s TAT initiatives; risks associated with potential 
mineral  acquisitions  internationally,  including  geopolitical  considerations;  risks  associated  with  increased  regulatory 
requirements applicable to our operations in response to pressure from special interest groups or otherwise; and risks generally 
encountered  in  the  exploration,  development,  operation,  closure  and  reclamation  of  mineral  properties  and  processing  and 
recovery  facilities.  Forward-looking  statements  are  subject  to  a  variety  of  known  and  unknown  risks,  uncertainties  and  other 
factors which could cause actual events or results to differ from those expressed or implied by the forward-looking statements, 
including, without limitation the following risks: 

3

• global  economic  risks,  including  the  occurrence  of  unforeseen  or  catastrophic  events,  such  as  political  unrest,  wars  or  the 
emergence  of  a  widespread  health  emergency,  which  could  create  operational,  economic  and  financial  disruptions  for  an 
indeterminate period of time that could materially impact our business, operations, personnel and financial condition;

• risks  associated  with  Mineral  Reserve  and  Mineral  Resource  estimates,  including  the  risk  of  errors  in  assumptions  or 

methodologies and changes to estimate disclosure rules and regulations; 

• risks associated with estimating mineral extraction and recovery, forecasting future price levels necessary to support mineral 
extraction  and  recovery,  and  our  ability  to  increase  mineral  extraction  and  recovery  in  response  to  any  increases  in 
commodity prices or other market conditions;

• uncertainties and liabilities inherent to conventional mineral extraction and recovery and/or in situ recovery (“ISR”); 
• risks  associated  with  our  commercial  production  of  RE  Carbonate,  separated  REE  oxides,  and  potentially  other  REE  and 
REE-related value-added products (collectively, “RE Products”) at the Mill or elsewhere, including risks: that we may not 
be  able  to  produce  RE  Products  that  meet  commercial  specifications  at  commercial  levels  or  at  all,  or  at  acceptable  cost 
levels; of not being able to secure adequate supplies of uranium and REE-bearing ores in the future at satisfactory costs; of 
not being able to increase our sources of uranium and REE-bearing ores to meet future planned production goals; of not being 
able  to  sell  our  RE  Products  at  acceptable  prices;  of  not  being  able  to  successfully  construct  and  operate  potential  other 
downstream REE activities, including metal-making and alloying, if pursued in the future; of legal and regulatory challenges 
and delays; and the risk of technological or market changes that could impact the REE industry or our competitive position; 
• risks  associated  with  the  uranium  reserve  program  for  the  U.S.  (the  “U.S.  Uranium  Reserve  Program”)  being  subject  to 

appropriation by the U.S. Congress, and the expansion of the U.S. Uranium Reserve Program;

• risks  associated  with  current  federal,  state  and  local  administrations  and  changes  thereto,  including  a  lack  of  support  of 

mining, uranium mining, nuclear energy, REE recovery or other aspects of our business; 

• geological,  technical  and  processing  problems,  including  unanticipated  metallurgical  difficulties,  less  than  expected 

recoveries, ground control problems, process upsets and equipment malfunctions;

• risks associated with the depletion of existing Mineral Resources through extraction without comparable replacements; 
• risks  associated  with  identifying/obtaining  adequate  quantities  of  uranium-bearing  materials  not  derived  from  conventional 
material sourced by third parties (“Alternate Feed Materials”) and other feed sources required for the operation of our Mill; 

• risks associated with labor costs, labor disturbances and unavailability of skilled labor;
• risks associated with availability and/or fluctuations in the costs of raw materials and consumables used in our production;
• risks  and  costs  associated  with  environmental  compliance  and  permitting,  including  those  created  by  changes  in 
environmental legislation and regulation, changes in regulatory attitudes and approaches, and delays in obtaining permits and 
licenses that could impact expected mineral extraction and recovery levels and costs;

• risks  associated  with  increased  regulatory  requirements  applicable  to  our  operations  in  response  to  pressure  from  special 

interest groups or otherwise;

• risks associated with our dependence on third parties in the provision of transportation and other critical services;
• risks associated with our ability to obtain, extend or renew land tenure, including mineral leases and surface use agreements, 

and to negotiate access rights on certain properties, on favorable terms or at all;

• risks associated with potential information security incidents, including cybersecurity breaches;
• risks  that  we  may  compromise  or  lose  our  proprietary  technology  or  intellectual  property  in  certain  circumstances,  which 

could result in a loss in our competitive position and/or the value of our intangible assets; 

• risks associated with our ongoing ability to successfully develop, attract and retain qualified management, Board members 

and other key personnel critical to the success of our business, given limited significant experience in our key industries;

• competition for, among other things, capital, mineral properties and skilled personnel;
• the adequacy of, and costs of retaining, our insurance coverage;
• uncertainty as to reclamation and decommissioning liabilities;
• the ability of our bonding companies to require increases in the collateral required to secure reclamation obligations;
• the potential for, and outcome of, litigation and other legal proceedings, including potential injunctions pending resolution;
• our ability to meet our obligations to our creditors and to access credit facilities on favorable terms; 
• risks associated with our relationships with our business and joint venture partners, including associated geopolitical risks;
• failure to obtain industry partner, government, and other third-party consents and approvals, when required;
• failure  to  complete  and  integrate  proposed  acquisitions,  and/or  to  incorrectly  assess  the  value  or  risks  associated  with  of 

completed acquisitions, including our acquisition of mineral concessions at the Bahia Project and any future acquisitions;

• risks  associated  with  a  Brazilian  federal  or  state  government  enacting  or  managing  a  conservation  unit  or  environmental 
protection  area  or  implementing  a  management  plan  in  connection  therewith  that  could  impact  planned  production  at  or 
restrict the Company’s ability to or prevent the Company from mining significant portions of the Company’s Bahia Project;
• risks associated with fluctuations in price levels for HMS concentrate (“HMC”) and its components, including the prices for 
ilmenite, rutile, titanium and zircon, which could impact planned production levels or the feasibility of production of HMC 
and monazite from our Bahia Project and any other HMS project the Company may acquire or participate in, which could 
impact monazite supply for our RE Carbonate, separated  REE oxide and any other REE value-added product production;

• risks posed by fluctuations in share price levels, exchange rates and interest rates, and general economic conditions;

4

• risks inherent in our and industry analysts’ forecasts/predictions of future uranium, vanadium, copper (if and when produced) 

and REE price levels, including the prices for RE Carbonates, separated REE oxides, REE metals and REE metal alloys;
• market prices of uranium, vanadium, REEs and (if relevant) copper, which are cyclical with substantial price fluctuations;
• risks associated with future uranium sales, if any, being required to be made at spot prices, unless we are able to continue to 

enter into new long-term contracts at satisfactory prices in the future; 

• risks associated with our vanadium sales, if any, generally being required to be made at spot prices; 
• risks associated with our RE Carbonate sales and REE oxide sales, if any, being tied to REE spot prices;
• failure to obtain suitable uranium sales terms at satisfactory prices in the future, including spot and term sale contracts;
• failure to obtain suitable vanadium sales terms at satisfactory prices in the future;
• failure to obtain suitable copper (if and when produced) or REE sales terms at satisfactory prices in the future;
• risks that we may not be able to fulfill all our sales commitments out of inventories or production and may be required to 

fulfill deliveries through spot purchases at a loss or through other negotiable means that are unfavorable to the Company;
• risks associated with any expectation that we will successfully help in the cleanup of historic abandoned uranium mines; 
• risks associated with asset impairment as a result of market conditions;
• risks associated with lack of access to markets and the ability to access capital;
• risks  associated  with  our  ability  to  raise  debt  financing  as  may  be  required  or  desirable  for  planned  expansion  of  our 

operations or for the development of projects with third parties in which we have a joint venture or other interest;

• risks associated with public and/or political resistance to nuclear energy or uranium extraction and recovery;
• risks associated with inaccurate or nonobjective media coverage of our activities and the impact such coverage may have on 
the  public,  the  market  for  our  securities,  government  relations,  commercial  relations,  permitting  activities  and  legal 
challenges, as well as the costs to us of responding to such coverage;

• risks associated with potential impacts of public perceptions on our commercial relations;
• uranium  industry  competition,  international  trade  restrictions  and  the  impacts  they  have  on  world  commodity  prices  of 
foreign state-subsidized production, and wars or other conflicts influencing international demand and commercial relations;
• risks associated with foreign government actions, policies and laws and foreign state-subsidized enterprises with respect to 
REE production and sales, which could impact REE prices, access to global and domestic markets for the supply of REE-
bearing ores, and our sale of RE Carbonate, separated REE oxides or REE products and services globally and domestically;
• risks associated with our involvement in industry petitions for trade remedies and the extension of the Russian Suspension 
Agreement, including costs of pursuing such remedies and the potential for negative responses or repercussions from various 
interest groups, consumers of uranium, and participants in other phases of the nuclear fuel cycle domestically and abroad;

• risks associated with governmental or regulatory agency actions, policies, laws, regulations and interpretations with respect to 
nuclear energy or uranium extraction and recovery, as well as to REE and other mineral extraction and recovery activities;

• risks related to potentially higher than expected costs related to any of our projects or facilities; 
• risks related to our ability to potentially recover copper from our Pinyon Plain Project, should we decide to pursue it; 
• risks related to stock price, volume volatility and market events and our ability to maintain inclusion in various stock indices;
• risks related to our ability to maintain our listings on NYSE American and the Toronto Stock Exchange (“TSX”);
• risks related to dilution of currently outstanding shares from additional share issuances, depletion of assets, etc.;
• risks related to our securities, including securities regulations, and our lack of dividends;
• risks related to our issuance of additional freely tradeable common shares of the Company (“Common Shares”) under our 

At-the-Market program (“ATM”) or otherwise to provide adequate liquidity in depressed commodity market situations;

• risks related to acquisition and integration issues, or related to defects in title to our mineral properties;
• risks related to our method of accounting for equity investments in other companies potentially resulting in material changes 

to our financial results that are not fully within our control;

• risks  related  to  conducting  business  operations  in  foreign  countries  including  heightened  risks  of  expropriation  of  assets, 

business interruption, increased taxation, import/export controls, or unilateral modification of concessions and contracts;

• risks  related  to  any  material  weaknesses  that  may  be  identified  in  our  internal  controls  over  financial  reporting.  If  we  are 
unable  to  implement/maintain  effective  internal  controls  over  financial  reporting,  investors  may  lose  confidence  in  the 
accuracy and completeness of our financial reports, negatively affecting the market price of our common stock;

• risks of amendment to mining laws, including the imposition of any royalties on minerals extracted from federal lands, the 
designation  of  national  monuments,  mineral  withdrawals  or  similar  actions,  which  could  adversely  impact  our  affected 
properties or our ability to operate our affected properties;

• risks  related  to  proposed  or  completed  land  exchanges  made  between  federal  and  state  agencies  that  may  impact  our 
unpatented mining claims and other rights, including: undesirable changes to our mineral tenure on exchanged lands; and/or 
the application of production royalties not previously owed on the claims; and

• risks  related  to  our  potential  recovery  of  radioisotopes  at  the  Mill  for  use  in  our  TAT  initiatives,  including  a  risk  of 
technological or market changes that could impact the industry or our competitive position, and any expectation that: such 
potential  recovery  will  be  feasible  or  that  the  radioisotopes  will  be  able  to  be  sold  on  a  commercial  basis;  all  required 
licenses, permits and regulatory approvals will be obtained on a timely basis or at all; and the cancer treatment therapeutics 
will receive the required approvals and will be commercially successful.

5

Such  statements  are  based  on  a  number  of  assumptions  which  may  prove  to  be  incorrect,  including,  but  not  limited  to,  the 
following  assumptions:  that  there  is  no  material  deterioration  in  general  business  and  economic  conditions;  that  there  is  no 
unanticipated fluctuation in interest rates and foreign exchange rates; that the supply and demand for, deliveries of, and the level 
and  volatility  of  prices  of  uranium,  vanadium,  REEs  and  our  other  primary  metals,  radioisotopes  and  minerals  develop  as 
expected;  that  uranium,  vanadium  and  REE  prices  required  to  reach,  sustain  or  increase  expected  or  forecasted  production 
levels are realized as expected; that our RE Carbonate production, planned production of separated REE oxides or any other 
proposed  REE  activities,  our  proposed  radioisotope  program,  or  other  potential  production  activities  will  be  technically  or 
commercially  successful;  that  we  receive  regulatory  and  governmental  approvals  for  our  development  projects  and  other 
operations on a timely basis; that we are able to operate our mineral properties and processing facilities as expected; that we are 
able  to  implement  new  process  technologies  and  operations  as  expected;  that  existing  licenses  and  permits  are  renewed  as 
required;  that  we  are  able  to  obtain  financing  for  our  development  projects  on  reasonable  terms;  that  we  are  able  to  procure 
mining  equipment  and  operating  supplies  in  sufficient  quantities  and  on  a  timely  basis;  that  engineering  and  construction 
timetables and capital costs for our development and expansion projects and restarting projects on standby are not incorrectly 
estimated  or  affected  by  unforeseen  circumstances;  that  costs  of  closure  of  various  operations  are  accurately  estimated;  that 
there are no unanticipated changes in collateral requirements for surety bonds; that there are no unanticipated changes to market 
competition;  that  our  Mineral  Reserve  and  Mineral  Resource  estimates  are  within  reasonable  bounds  of  accuracy  (including 
with  respect  to  size,  grade  and  recoverability)  and  that  the  geological,  operational  and  price  assumptions  on  which  these  are 
based are reasonable; that environmental and other administrative and legal proceedings or disputes are satisfactorily resolved; 
that there are no significant changes to regulatory programs and requirements or interpretations that would materially increase 
regulatory  compliance  costs,  bonding  costs  or  licensing/permitting  requirements;  that  there  are  no  significant  amendments  to 
mining laws, including the imposition of any royalties on minerals extracted from federal lands; that there are no designations 
of  national  monuments,  mineral  withdrawals,  land  exchanges  or  similar  actions,  which  could  adversely  impact  any  of  our 
material properties or our ability to operate any of our material properties; that there are no conservation units or environmental 
protection areas or management plans that could impact planned production at or restrict the Company’s ability to or prevent 
the Company from mining significant portions of the Company’s Bahia Project; and that we maintain ongoing relations with 
our employees and with our business and joint venture partners.

This  list  is  not  exhaustive  of  the  factors  that  may  affect  our  forward-looking  statements.  Some  of  the  important  risks  and 
uncertainties that could affect forward-looking statements are described further under the following section headings in Part I of 
this  Annual  Report:  Item  1.  Description  of  the  Business;  Item  1A.  Risk  Factors;  and  Item  7.  Management’s  Discussion  and 
Analysis of Financial Condition and Results of Operations. Although we have attempted to identify important factors that could 
cause  actual  results  to  differ  materially  from  those  described  in  forward-looking  statements,  there  may  be  other  factors  that 
cause results not to be as anticipated, estimated or intended. Should one or more of these risks or uncertainties materialize, or 
should underlying assumptions prove incorrect, actual results may vary materially from those anticipated, believed, estimated or 
expected. We caution readers not to place undue reliance on any such forward-looking statements, which speak only as of the 
date  made.  Except  as  required  by  applicable  law,  we  disclaim  any  obligation  to  subsequently  revise  any  forward-looking 
statements  to  reflect  events  or  circumstances  after  the  date  of  such  statements  or  to  reflect  the  occurrence  of  anticipated  or 
unanticipated  events.  Statements  relating  to  “Mineral  Reserves”  or  “Mineral  Resources”  are  deemed  to  be  forward-looking 
statements, as they involve the implied assessment, based on certain estimates and assumptions, that the Mineral Reserves and 
Mineral Resources described may be profitably extracted in the future.

Market, Industry and Other Data

This Annual Report contains estimates, projections and other information concerning our industry, our business and the markets 
for  our  products.  Information  that  is  based  on  estimates,  forecasts,  projections,  market  research  or  similar  methodologies  is 
inherently subject to uncertainties, and actual events or circumstances may differ materially from events and circumstances that 
are assumed in this information. Unless otherwise expressly stated, we obtained this industry, business, market and other data 
from our own internal estimates and research, as well as from reports, research surveys, studies and similar data prepared by 
market research firms and other third parties, industry and general publications, government data, and similar sources.

We qualify all forward-looking statements contained in this Annual Report by the foregoing cautionary statements.

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CAUTIONARY NOTE TO INVESTORS CONCERNING

DISCLOSURE OF MINERAL RESOURCES AND RESERVES

We are a U.S. domestic issuer for United States Securities and Exchange Commission (“SEC”) reporting purposes, a majority 
of our outstanding voting securities are held by U.S. residents, we are required to report our financial results under generally 
accepted accounting principles in the U.S. (“U.S. GAAP”) and our primary trading market is the NYSE American. However, 
because we are incorporated in Ontario, Canada and also listed on the TSX, this Annual Report also contains or incorporates by 
reference  certain  disclosure  that  satisfies  the  additional  requirements  of  Canadian  securities  laws  that  differ  from  the 
requirements of U.S. securities laws. 

All  mineral  estimates  constituting  mining  operations  that  are  material  to  our  business  or  financial  condition  included  in  this 
Annual  Report  for  the  year  ended  December  31,  2023,  and  in  the  documents  incorporated  by  reference  herein,  have  been 
prepared in accordance with both 17 CFR Subparts 220.1300 and 229.601(b)(96) (collectively, “S-K 1300”), the SEC’s mining 
disclosure  framework  effective  as  of  2021,  and  Canadian  National  Instrument  43-101  -  Standards  of  Disclosure  for  Mineral 
Projects (“NI 43-101”), a rule developed by the Canadian Securities Administrators (the “CSA”) that establishes standards for 
all  public  disclosure  an  issuer  makes  of  scientific  and  technical  information  concerning  mineral  projects.  Furthermore,  all 
mineral estimates constituting mining operations that are material to our business or financial condition included in this Annual 
Report are supported by pre-feasibility studies and/or initial assessments prepared in accordance with both the requirements of 
S-K 1300 and NI 43-101. S-K 1300 and NI 43-101 both provide for the disclosure of: (i) “Inferred Mineral Resources,” which 
investors  should  understand  have  the  lowest  level  of  geological  confidence  of  all  mineral  resources  and  thus  may  not  be 
considered  when  assessing  the  economic  viability  of  a  mining  project  and  may  not  be  converted  to  a  Mineral  Reserve;  (ii) 
“Indicated Mineral Resources,” which investors should understand have a lower level of confidence than that of a “Measured 
Mineral Resource” and thus may be converted only to a “Probable Mineral Reserve”; and (iii) “Measured Mineral Resources,” 
which investors should understand have sufficient geological certainty to be converted to a “Proven Mineral Reserve” or to a 
“Probable Mineral Reserve.” Investors are cautioned not to assume that all or any part of Measured or Indicated Mineral 
Resources will ever be converted into Mineral Reserves as defined by S-K 1300 or NI 43-101. Investors are cautioned 
not to assume that all or any part of an Inferred Mineral Resource exists or is economically or legally mineable, or that 
an Inferred Mineral Resource will ever be upgraded to a higher category.

For purposes of S-K 1300 and NI 43-101, as at December 31, 2023, the Company was classified as a development stage issuer 
because it was engaged in the preparation of Mineral Reserves for extraction on at least one material property. The Company 
will be considered a production stage issuer if it engages in material extraction of a Mineral Reserve from at least one material 
property.  In  late  2023,  the  Company  commenced  uranium  production  at  three  of  its  material  properties,  namely  the  Pinyon 
Plain  Project  and  the  La  Sal  and  Pandora  mines  (each  of  the  La  Sal  and  Pandora  mines  constitutes  a  portion  of  the  La  Sal 
Project).  The  Pinyon  Plain  Project  includes  a  Mineral  Reserve.  Accordingly,  the  Company  is  expected  to  be  considered  a 
production stage issuer in 2024 as a result of its commencing mining at the Pinyon Plain Project in late 2023 and its expected 
continuance of mining activities through 2024. 

All mineral disclosure reported in this Annual Report has been prepared in accordance with the definitions of both S-K 1300 
and NI 43-101.

S-K 1300 Definitions:

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Development Stage Issuer: is an issuer that is engaged in the preparation of mineral reserves for extraction on at least 
one material property.
Development Stage Property: is a property that has mineral reserves disclosed, pursuant to S-K 1300, but no material 
extraction.
Exploration Stage Issuer: is an issuer that has no material property with Mineral Reserves disclosed.
Exploration Stage Property: is a property that has no mineral reserves disclosed.
Feasibility Study: is a comprehensive technical and economic study of the selected development option for a mineral 
project, which includes detailed assessments of all applicable modifying factors, as defined in S-K 1300, together with 
any other relevant operational factors, and detailed financial analyses that are necessary to demonstrate, at the time of 
reporting, that extraction is economically viable. The results of the study may serve as the basis for a final decision by 
a proponent or financial institution to proceed with, or finance, the development of the project. 

(1) A feasibility study is more comprehensive, and with a higher degree of accuracy, than a pre-feasibility study. It 
must contain mining, infrastructure, and process designs completed with sufficient rigor to serve as the basis for 
an investment decision or to support project financing. 

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(2) The confidence level in the results of a feasibility study is higher than the confidence level in the results of a 
pre-feasibility  study.  Terms  such  as  full,  final,  comprehensive,  bankable,  or  definitive  feasibility  study  are 
equivalent to a feasibility study.

Indicated Mineral Resource: is that part of a mineral resource for which quantity and grade or quality are estimated 
on  the  basis  of  adequate  geological  evidence  and  sampling.  The  level  of  geological  certainty  associated  with  an 
indicated  mineral  resource  is  sufficient  to  allow  a  qualified  person  to  apply  modifying  factors  in  sufficient  detail  to 
support mine planning and evaluation of the economic viability of the deposit. Because an indicated mineral resource 
has  a  lower  level  of  confidence  than  the  level  of  confidence  of  a  measured  mineral  resource,  an  indicated  mineral 
resource may only be converted to a probable mineral reserve.
Inferred Mineral Resource: is that part of a mineral resource for which quantity and grade or quality are estimated on 
the basis of limited geological evidence and sampling. The level of geological uncertainty associated with an inferred 
mineral  resource  is  too  high  to  apply  relevant  technical  and  economic  factors  likely  to  influence  the  prospects  of 
economic extraction in a manner useful for evaluation of economic viability. Because an inferred mineral resource has 
the  lowest  level  of  geological  confidence  of  all  mineral  resources,  which  prevents  the  application  of  the  modifying 
factors in a manner useful for evaluation of economic viability, an inferred mineral resource may not be considered 
when assessing the economic viability of a mining project and may not be converted to a mineral reserve.
Initial  Assessment:  is  a  preliminary  technical  and  economic  study  of  the  economic  potential  of  all  or  parts  of 
mineralization to support the disclosure of mineral resources. The initial assessment must be prepared by a qualified 
person and must include appropriate assessments of reasonably assumed technical and economic factors, together with 
any  other  relevant  operational  factors,  that  are  necessary  to  demonstrate  at  the  time  of  reporting  that  there  are 
reasonable prospects for economic extraction. An initial assessment is required for disclosure of mineral resources but 
cannot be used as the basis for disclosure of mineral reserves.

• Measured Mineral Resource: is that part of a mineral resource for which quantity and grade or quality are estimated 
on  the  basis  of  conclusive  geological  evidence  and  sampling.  The  level  of  geological  certainty  associated  with  a 
measured  mineral  resource  is  sufficient  to  allow  a  qualified  person  to  apply  modifying  factors,  as  defined  in  this 
section,  in  sufficient  detail  to  support  detailed  mine  planning  and  final  evaluation  of  the  economic  viability  of  the 
deposit. Because a measured mineral resource has a higher level of confidence than the level of confidence of either an 
indicated mineral resource or an inferred mineral resource, a measured mineral resource may be converted to a proven 
mineral reserve or to a probable mineral reserve.

• Mineral Reserve: is an estimate of tonnage and grade or quality of indicated and measured mineral resources that, in 
the  opinion  of  the  qualified  person,  can  be  the  basis  of  an  economically  viable  project.  More  specifically,  it  is  the 
economically  mineable  part  of  a  measured  or  indicated  mineral  resource,  which  includes  diluting  materials  and 
allowances for losses that may occur when the material is mined or extracted.

• Mineral Resource: is a concentration or occurrence of material of economic interest in or on the earth's crust in such 
form, grade or quality, and quantity that there are reasonable prospects for economic extraction. A mineral resource is 
a  reasonable  estimate  of  mineralization,  taking  into  account  relevant  factors  such  as  cut-off  grade,  likely  mining 
dimensions, location or continuity, that, with the assumed and justifiable technical and economic conditions, is likely 
to, in whole or in part, become economically extractable. It is not merely an inventory of all mineralization drilled or 
sampled.

• Modifying Factors: are the factors that a qualified person must apply to indicated and measured mineral resources and 
then  evaluate  in  order  to  establish  the  economic  viability  of  mineral  reserves.  A  qualified  person  must  apply  and 
evaluate  modifying  factors  to  convert  measured  and  indicated  mineral  resources  to  proven  and  probable  mineral 
reserves. These factors include, but are not restricted to: mining; processing; metallurgical; infrastructure; economic; 
marketing; legal; environmental compliance; plans, negotiations, or agreements with local individuals or groups; and 
governmental factors. The number, type and specific characteristics of the modifying factors applied will necessarily 
be a function of and depend upon the mineral, mine, property, or project.
Preliminary  Feasibility  Study  (or  Pre-Feasibility  Study):  is  a  comprehensive  study  of  a  range  of  options  for  the 
technical  and  economic  viability  of  a  mineral  project  that  has  advanced  to  a  stage  where  a  qualified  person  has 
determined (in the case of underground mining) a preferred mining method, or (in the case of surface mining) a pit 
configuration, and in all cases has determined an effective method of mineral processing and an effective plan to sell 
the product. 

•

(1)  A  pre-feasibility  study  includes  a  financial  analysis  based  on  reasonable  assumptions,  based  on  appropriate 
testing,  about  the  modifying  factors  and  the  evaluation  of  any  other  relevant  factors  that  are  sufficient  for  a 
qualified person to determine if all or part of the indicated and measured mineral resources may be converted to 
mineral  reserves  at  the  time  of  reporting.  The  financial  analysis  must  have  the  level  of  detail  necessary  to 
demonstrate, at the time of reporting, that extraction is economically viable. 
(2) A pre-feasibility study is less comprehensive and results in a lower confidence level than a feasibility study. A 
pre-feasibility study is more comprehensive and results in a higher confidence level than an initial assessment.

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Preliminary Market Study: is a study that is sufficiently rigorous and comprehensive to determine and support the 
existence of a readily accessible market for the mineral. It must, at a minimum, include product specifications based on 
preliminary geologic and metallurgical testing, supply and demand forecasts, historical prices for the preceding five or 
more  years,  estimated  long  term  prices,  evaluation  of  competitors  (including  products  and  estimates  of  production 
volumes, sales, and prices), customer evaluation of product specifications, and market entry strategies. The study must 
provide  justification  for  all  assumptions.  It  can,  however,  be  less  rigorous  and  comprehensive  than  a  final  market 
study, which is required for a full feasibility study.
Probable Mineral Reserve: is the economically mineable part of an indicated and, in some cases, a measured mineral 
resource.
Production Stage Issuer: is an issuer that is engaged in material extraction of mineral reserves on at least one material 
property.
Proven Mineral Reserve: is the economically mineable part of a measured mineral resource and can only result from 
conversion of a measured mineral resource.
• Qualified Person: is an individual who is:

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(1) a mineral industry professional with at least five years of relevant experience in the type of mineralization and 
type of deposit under consideration and in the specific type of activity that person is undertaking on behalf of the 
registrant; and
(2)  an  eligible  member  or  licensee  in  good  standing  of  a  recognized  professional  organization  at  the  time  the 
technical report is prepared. For an organization to be a recognized professional organization, it must:

(i) be either:

(A) an organization recognized within the mining industry as a reputable professional association; or
(B)  a  board  authorized  by  U.S.  federal,  state  or  foreign  statute  to  regulate  professionals  in  the  mining, 
geoscience or related field;

(ii) admit eligible members primarily on the basis of their academic qualifications and experience;
(iii) establish and require compliance with professional standards of competence and ethics;
(iv) require or encourage continuing professional development;
(v)  have  and  apply  disciplinary  powers,  including  the  power  to  suspend  or  expel  a  member  regardless  of 
where the member practices or resides; and
(vi) provide a public list of members in good standing.

CIM and NI 43-101 Definitions:

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Feasibility Study: A “feasibility study” is a comprehensive technical and economic study of the selected development 
option for a mineral project that includes appropriately detailed assessments of applicable modifying factors, together 
with any other relevant operational factors and detailed financial analysis that are necessary to demonstrate, at the time 
of reporting, that extraction is reasonably justified (economically mineable). The results of the study may reasonably 
serve  as  the  basis  for  a  final  decision  by  a  proponent  or  financial  institution  to  proceed  with,  or  finance,  the 
development of the project. The confidence level of the study will be higher than that of a pre-feasibility study.
Indicated Mineral Resource: An “indicated mineral resource” is that part of a mineral resource for which quantity, 
grade  or  quality,  densities,  shape  and  physical  characteristics  are  estimated  with  sufficient  confidence  to  allow  the 
application of modifying factors in sufficient detail to support mine planning and evaluation of the economic viability 
of the deposit. Geological evidence is derived from adequately detailed and reliable exploration, sampling and testing 
and  is  sufficient  to  assume  geological  and  grade  or  quality  continuity  between  points  of  observation.  An  indicated 
mineral resource has a lower level of confidence than that applied to a measured mineral resource and may only be 
converted to a probable mineral reserve.
Inferred Mineral Resource: An “inferred mineral resource” is that part of a mineral resource for which quantity and 
grade  or  quality  are  estimated  on  the  basis  of  limited  geological  evidence  and  sampling.  Geological  evidence  is 
sufficient to imply, but not verify, geological and grade or quality continuity. An inferred mineral resource has a lower 
level of confidence than that applied to an indicated mineral resource and must not be converted to a mineral reserve. It 
is  reasonably  expected  that  the  majority  of  inferred  mineral  resources  could  be  upgraded  to  “indicated  mineral 
resources” with continued exploration.

• Measured Mineral Resource: A “measured mineral resource” is that part of a mineral resource for which quantity, 
grade  or  quality,  densities,  shape  and  physical  characteristics  are  estimated  with  confidence  sufficient  to  allow  the 
application of modifying factors to support detailed mine planning and final evaluation of the economic viability of the 
deposit. Geological evidence is derived from detailed and reliable exploration, sampling, and testing and is sufficient 
to confirm geological and grade or quality continuity between points of observation. A measured mineral resource has 
a higher level of confidence than that applied to either an indicated mineral resource or an inferred mineral resource. It 
may be converted to a proven mineral reserve or to a probable mineral reserve.

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• Mineral  Reserve:  A  “mineral  reserve”  is  the  economically  mineable  part  of  a  measured  and/or  indicated  mineral 
resource. It includes diluting materials and allowances for losses which may occur when the material is mined or is 
extracted  and  is  defined  by  studies  at  pre-feasibility  or  feasibility  level  as  appropriate  that  include  application  of 
modifying factors. Such studies demonstrate that, at the time of reporting, extraction could reasonably be justified. The 
reference point at which mineral reserves are defined, usually the point where the ore is delivered to the processing 
plant, must be stated. It is important that, in all situations where the reference point is different, such as for a saleable 
product, a clarifying statement is included to ensure that the reader is fully informed as to what is being reported. The 
public disclosure of a mineral reserve must be demonstrated by a pre-feasibility study or feasibility study.

• Mineral Resource: A “mineral resource” is a concentration or occurrence of solid material of economic interest in or 
on  the  Earth’s  crust  in  such  form,  grade  or  quality  and  quantity  that  there  are  reasonable  prospects  for  eventual 
economic  extraction.  The  location,  quantity,  grade  or  quality,  continuity  and  other  geological  characteristics  of  a 
mineral  resource  are  known,  estimated  or  interpreted  from  specific  geological  evidence  and  knowledge,  including 
sampling.

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• Modifying  Factors:  “Modifying  factors”  are  considerations  used  to  convert  mineral  resources  to  mineral  reserves. 
These include, but are not restricted to, mining, processing, metallurgical, infrastructure, economic, marketing, legal, 
environmental, social, and governmental factors.
PEA:  A  Preliminary  Economic  Assessment  performed  in  accordance  with  NI  43-101.  A  Preliminary  Economic 
Assessment is a study, other than a pre-feasibility study or feasibility study, which includes an economic analysis of 
the potential viability of mineral resources.
Pre-Feasibility Study: A “pre-feasibility study” is a comprehensive study of a range of options for the technical and 
economic viability of a mineral project that has advanced to a stage where a preferred mining method, in the case of 
underground  mining,  or  the  pit  configuration,  in  the  case  of  an  open  pit,  is  established  and  an  effective  method  of 
mineral processing is determined. It includes a financial analysis based on reasonable assumptions on the modifying 
factors and the evaluation of any other relevant factors which are sufficient for a qualified person, acting reasonably, to 
determine if all or part of the mineral resource may be converted to a mineral reserve at the time of reporting. A pre-
feasibility study is at a lower confidence level than a feasibility study.
Probable Mineral Reserve: A Probable Mineral Reserve is the economically mineable part of an Indicated, and in 
some circumstances, a Measured Mineral Resource. The confidence in the Modifying Factors applying to a Probable 
Mineral Reserve is lower than that applying to a Proven Mineral Reserve.
Proven  Mineral  Reserve:  A  Proven  Mineral  Reserve  is  the  economically  mineable  part  of  a  Measured  Mineral 
Resource. A Proven Mineral Reserve implies a high degree of confidence in the Modifying Factors.

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• Qualified Person: means an individual who:

(a) is an engineer or geoscientist with a university degree, or equivalent accreditation, in an area of geoscience, or 
engineering, relating to mineral exploration or mining;
(b) has at least five years of experience in mineral exploration, mine development or operation or mineral project 
assessment, or any combination of these, that is relevant to his or her professional degree or area of practice;
(c) has experience relevant to the subject matter of the mineral project and the technical report;
(d) is in good standing with a professional association; and
(e) in the case of a professional association in a foreign jurisdiction, has a membership designation that

(i)  requires  attainment  of  a  position  of  responsibility  in  their  profession  that  requires  the  exercise  of 
independent judgment; and
(ii) requires

A.  a  favorable  confidential  peer  evaluation  of  the  individual’s  character,  professional  judgement, 
experience, and ethical fitness; or
B. a recommendation for membership by at least two peers and demonstrated prominence or expertise in 
the field of mineral exploration or mining.

The following defined technical terms are used in this Annual Report:

GLOSSARY OF TECHNICAL TERMS

• % U3O8 Eq: Equivalent uranium grade calculated by combining uranium content and copper content by factoring in 

the grade, commodity price and metallurgical recovery for each metal.
ANM Process Area: An area (up to 2,000 hectares) granted by the Federal Government of Brazil to a Brazilian Legal 
Entity for the exploration and or the extraction of minerals.
APP: An Aquifer Protection Permit, issued by ADEQ (see “Glossary of Regulatory Agencies and Exchanges” below).
Assay: The testing of a metal or natural material to determine its ingredients and quality. 
Breccia: A rock in which angular fragments are surrounded by a mass of fine-grained materials.

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CAP: A Corrective Action Plan. 
Copper: A red-brown metal, the chemical element of atomic number 29.
Cut-off grade: The grade (i.e., the concentration of metal or mineral in rock) that determines the destination of the 
material during mining. For purposes of establishing “prospects of economic extraction,” the cut-off grade is the grade 
that distinguishes material deemed to have no economic value (it will not be mined in underground mining or if mined 
in surface mining, its destination will be the waste dump) from material deemed to have economic value (its ultimate 
destination during mining will be the processing facility). Other terms used in similar fashion as cut-off grade include 
net smelter return, pay limit, and break-even stripping ratio.
EA: Environmental Assessment prepared under NEPA for a mineral project.
EIS: Environmental Impact Statement prepared under NEPA for a mineral project.
eU3O8: This term refers to equivalent U3O8 grade derived by gamma logging of drill holes.
Extraction: The process of physically extracting mineralized material from the ground. Exploration continues during 
the extraction process, and, in many cases, mineralized material is expanded during the life of the extraction activities 
as the exploration potential of the deposit is realized.
FONSI: Finding of No Significant Impact under NEPA, as defined below, for a mineral project. 
Formation: A distinct layer of sedimentary or volcanic rock of similar composition.

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• Grade: Quantity or percentage of metal per unit weight of host rock.
• GWDP: A groundwater discharge permit, issuable by UDEQ. 
• Heavy Mineral: A mineral with a density greater than 2.9 g/cm3.
• Heavy Mineral Sand: A mineral deposit containing heavy minerals, silica sand, clay and other minerals.
• HMC: Heavy Mineral Sand concentrate, containing approximately 80-90% heavy minerals.
• HMS: Heavy Mineral Sand.
• Host Rock: The rock containing a mineral or an ore body.
•

In-situ  recovery  or  ISR:  The  recovery,  by  chemical  means,  of  the  uranium  component  of  a  deposit  without  the 
physical  extraction  of  uranium-bearing  material  from  the  ground.  ISR  utilizes  injection  of  appropriate  oxidizing 
chemicals  into  a  uranium-bearing  sandstone  deposit  by  injection  wells,  with  the  uranium-bearing  solution  being 
removed by extraction wells; also referred to as “solution mining.”

• Mineral: A naturally formed chemical element or compound having a definite chemical composition and, usually, a 

characteristic crystal form.

• Mineralization: A natural occurrence, in rocks or soil, of one or more metal yielding minerals.
• Mineralized material: Material that contains mineralization (e.g., uranium, vanadium and/or copper) and that is not 
included  in  an  SEC  Reserve  as  it  does  not  meet  all  of  the  criteria  for  adequate  demonstration  of  economic  or  legal 
extraction.

• Monazite:  A  phosphate  mineral  with  a  chemical  composition  of  (Ce,La,Nd,Th)PO4.  It  is  a  naturally  occurring 

uranium- and rare earth-bearing mineral.

• MT: A metric ton or tonne; one MT equals 1.102 tons. 
•
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NEPA: The United States National Environmental Policy Act of 1969, as amended.
NOI:  A  Notice  of  Intent,  filed  by  Energy  Fuels  to  a  regulatory  agency  as  a  part  of  a  licensing  or  permitting  action 
related to a mineral project. 

• Open Pit: Surface mineral extraction in which the mineralized material is extracted from a pit or quarry. 
• Ore:  Mineral-bearing  rock  that  can  be  mined,  processed  and  concentrated  profitably  under  current  or  immediately 
foreseeable economic conditions. A company may only refer to reserves (as that term is defined in S-K 1300) as “ore.”
• Ore  body:  A  mostly  solid  and  fairly  continuous  mass  of  in-ground  mineralization  estimated  to  be  economically 

mineable.

• Outcrop: That part of a geologic formation or structure that appears at the surface of the Earth.
•

PO:  Plan  of  Operations  for  a  mineral  project  prepared  in  accordance  with  applicable  United  States  Bureau  of  Land 
Management or United States Forest Service regulations.
Rare Earth Elements or REEs: a group of seventeen metallic elements consisting of the fifteen lanthanide elements 
along with scandium and yttrium.
Reclamation: The process by which lands disturbed as a result of mineral extraction activities are modified to support 
beneficial  land  use.  Reclamation  activity  may  include  the  removal  of  buildings,  equipment,  machinery,  and  other 
physical  remnants  of  mining  activities,  closure  of  tailings  storage  facilities,  leach  pads,  and  other  features,  and 
contouring, covering and re-vegetation of waste rock, and other disturbed areas.
RoD or Record of Decision: The final approval issued by a public land management agency for a PO.
Tonne: A metric ton (MT); one tonne equals 1.102 tons.
Uranium: a heavy, naturally radioactive, metallic element of atomic number 92. Uranium in its pure form is a heavy 
metal. Its two principal isotopes are U-238 and U-235, of which U-235 is the necessary component for the nuclear fuel 
cycle.  However,  “uranium”  used  in  this  Annual  Report  refers  to  triuranium  octoxide,  also  called  “U3O8”  and  the 

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primary component of “yellowcake,” and is produced from uranium deposits. It is the most actively traded uranium-
related commodity.
Uranium  concentrate:  a  yellowish  to  yellow-brownish  powder  obtained  from  the  chemical  processing  of  uranium-
bearing  material.  Uranium  concentrate  typically  contains  70%  to  90%  U3O8  by  weight.  Uranium  concentrate  is  also 
referred to as “yellowcake.”
V2O5: Vanadium pentoxide, or the form of vanadium typically produced at the White Mesa Mill, also called “black 
flake.”
Valuable Heavy Minerals: The portion of heavy minerals (density greater than 2.9 g/cm3) that have economic value. 
Examples include ilmenite, rutile, zircon and monazite.
Yellowcake: Another name for Uranium Concentrate (U3O8).

•

•

•

•

GLOSSARY OF REGULATORY AGENCIES AND EXCHANGES

ADEQ: The Arizona Department of Environmental Quality.
•
ANM: The Brazilian National Mining Agency (Agência Nacional de Mineração). 
•
BLM: The U.S. Bureau of Land Management, an agency of the U.S. Department of the Interior. 
•
CRA: The Canada Revenue Agency, an agency of the Government of Canada. 
•
DOC: The U.S. Department of Commerce, an executive department of the U.S. government. 
•
DOE: The U.S. Department of Energy, a cabinet-level department of the U.S. government.
•
DOI: The U.S. Department of Interior, a federal executive department of the U.S. government. 
•
DWQ: The Utah Division of Water Quality.
•
EIA: The U.S. Energy Information Administration, a principal agency of the U.S. Federal Statistical System.
•
•
EPA: The U.S. Environmental Protection Agency, an independent agency of the U.S. government.
• MSHA: The Mine Safety and Health Administration, an agency of the U.S. Department of Labor.
NRC: The Nuclear Regulatory Commission, an independent agency of the U.S. government.
•
•
NYSE American: The NYSE American stock exchange, a stock exchange based in New York, New York.
• OSC: The Ontario Securities Commission.
• OSHA: The Occupational Safety and Health Administration, an agency of the U.S. Department of Labor.
SEC: The U.S. Securities and Exchange Commission, an independent agency of the U.S. government.
•
TCEQ: Texas Commission on Environmental Quality.
•
TSX: The Toronto Stock Exchange, a stock exchange located in Toronto, Ontario, Canada.
•
UDAQ: The Utah Division of Air Quality.
•
UDEQ: The Utah Department of Environmental Quality.
•
UDOGM: The Utah Division of Oil, Gas and Mining.
•
USACE: The U.S. Army Corps of Engineers, an agency of the U.S. Department of Defense.
•
USFS: The U.S. Forest Service, an agency of the U.S. Department of Agriculture.
•
USFW: The U.S. Fish and Wildlife Service, an agency of the U.S. Department of the Interior.
•
• WDEQ: The Wyoming Department of Environmental Quality.
• WDEQ-AQD: The Air Quality Division of the WDEQ.
• WDEQ-LQD: The Land Quality Division of the WDEQ. 
• WDEQ-WQD: The Water Quality Division of the WDEQ.
• WSEO: The Wyoming State Engineer’s Office.

12

General Development of the Business

PART I

ITEM 1. DESCRIPTION OF BUSINESS

Corporate Structure

Energy  Fuels  Inc.  is  an  Ontario  corporation  with  its  corporate  offices  located  in  Lakewood,  Colorado  (a  city  in  the  Denver 
metropolitan area). It was incorporated on June 24, 1987 in the Province of Alberta under the name “368408 Alberta Inc.” In 
October 1987, 368408 Alberta Inc. changed its name to “Trevco Oil & Gas Ltd.” In May 1990, Trevco Oil & Gas Ltd. changed 
its  name  to  “Trev  Corp.”  In  August  1994,  Trev  Corp.  changed  its  name  to  “Orogrande  Resources  Inc.”  In  April  2001, 
Orogrande Resources Inc. changed its name to “Volcanic Metals Exploration Inc.” On September 2, 2005, the Company was 
continued under the Business Corporations Act (Ontario) (the “OBCA”). On March 26, 2006, Volcanic Metals Exploration Inc. 
acquired  100%  of  the  outstanding  shares  of  “Energy  Fuels  Resources  Corporation.”  On  May  26,  2006,  Volcanic  Metals 
Exploration  Inc.  changed  its  name  to  “Energy  Fuels  Inc.”  On  November  5,  2013,  the  Company  amended  its  Articles  of 
Incorporation to consolidate its issued and outstanding, freely tradable Common Shares on the basis of one post-consolidation 
Common Share for every 50 pre-consolidation Common Shares (the “Consolidation”).

The Company’s U.S.-based assets, which include uranium, vanadium and REE extraction, recovery, permitting, evaluation and 
exploration assets, are held directly and indirectly, as the case may be, by the Company’s wholly owned subsidiaries Energy 
Fuels  Holdings  Corp.  (“EF  Holdings”)  and  Strathmore  Minerals  Corp.  (“Strathmore”).  The  Company,  through  its  wholly 
owned  subsidiary  Energy  Fuels  Brazil  Ltda.,  acquired  the  Bahia  Project  in  the  State  of  Bahia,  Brazil  on  February  10,  2023, 
which  consists  of  17  mineral  concessions  totaling  approximately  37,300  acres  or  58.3  square  miles.  See  “Part  I,  Item  1. 
Description of Business - Material Transactions,” “Part I, Item 1. Description of Business - 2023 Corporate Developments” and 
Part I, Item 2. “Description of Properties - The Bahia Project,” below. On February 14, 2023, the Company sold its Alta Mesa 
Project  in  Texas  through  the  sale  of  its  three  Texas  subsidiaries,  Leoncito  Project,  LLC,  Leoncito  Plant,  LLC  and  Leoncito 
Properties, LLC. See “Part I, Item 1. Material Transactions,” below. All of the Company’s U.S.-based employees are employed 
by  its  subsidiary  Energy  Fuels  Resources  (USA)  Inc.  (“EFUSA”),  a  wholly  owned  subsidiary  of  EF  Holdings,  which  also 
serves as operator of all of the Company’s U.S. properties. A diagram depicting the organizational structure of the Company 
and  its  subsidiaries,  including  the  name,  U.S.  state,  Canadian  province  or  Brazilian  state  of  incorporation,  and  proportion  of 
ownership  interest  of  each,  is  included  as  Exhibit  21.1  to  this  Annual  Report.  Energy  Fuels  owns  a  number  of  inactive 
subsidiaries which have no material assets or liabilities and do not engage in any material business activities.

Each  of  the  Company’s  subsidiaries  has  its  principal  place  of  business  and  corporate  office  at  225  Union  Blvd.,  Suite  600, 
Lakewood,  Colorado  80228,  USA,  though  additional  support  offices  are  located  at  a  number  of  Company  properties.  The 
registered  office  of  EFUSA  and  principal  place  of  business  for  the  Company  is  at  225  Union  Blvd.,  Suite  600,  Lakewood, 
Colorado  80228,  USA,  and  the  registered  office  of  the  Company  is  located  at  82  Richmond  Street  East,  Suite  308  Toronto, 
Ontario, M5C 1P1, Canada. The Company’s website address is www.energyfuels.com. 

The primary trading market for Energy Fuels’ Common Shares is the NYSE American under the trading symbol “UUUU,” and 
the Company’s Common Shares are also listed on the TSX under the trading symbol “EFR.” Energy Fuels is a U.S. domestic 
issuer for SEC reporting purposes and, in addition, is a reporting issuer in all Canadian provinces. Options on Energy Fuels’ 
Common Shares are traded on The Chicago Board Options Exchange. The Designated Primary Market Maker for the Options is 
Group One Trading, LP. Citadel Securities is the Company’s Market Maker on the NYSE American. 

On December 5, 2023, IsoEnergy Ltd. (TSXV: ISO; OTCQX: ISENF) (“IsoEnergy”) and Consolidated Uranium Inc. (TSXV: 
CUR;  OTCQB:  CURUF)  (“CUR”)  announced  the  successful  completion  of  a  previously  announced  arrangement  whereby 
IsoEnergy acquired all the issued and outstanding common shares of CUR (the “CUR Shares”). Pursuant to the arrangement, 
CUR’s  shareholders  received  0.500  common  shares  of  IsoEnergy  for  every  one  common  share  of  CUR.  At  the  time  of  the 
arrangement,  the  Company  held  16,189,548  CUR  Shares,  which,  when  converted,  resulted  in  an  approximate  ownership 
interest in IsoEnergy’s common shares of 5.0%. Concurrently, IsoEnergy engaged in a marketed private placement offering of 
8,134,500 subscription receipts. In order to maintain its post-arrangement ownership interest in IsoEnergy, the Company agreed 
to invest additional capital in IsoEnergy by purchasing 406,650 additional common shares as a part of the capital raise. As a 
result, the Company now holds a total of 8,501,424 common shares of IsoEnergy, constituting an approximate 5.0% ownership 
interest of IsoEnergy common shares upon completion of the merger and private placement offering.   

13

Business Overview

We responsibly produce several of the raw materials needed for clean energy and advanced technologies, including uranium, 
rare earth elements and vanadium. 

Our  primary  product  is  U3O8  (also  known  as  natural  uranium  concentrate  or  yellowcake),  which,  when  further  processed, 
becomes the fuel for the generation of clean nuclear energy. According to the Nuclear Energy Institute, nuclear energy provides 
nearly 20% of the total electricity and 50% of the clean, carbon-free electricity generated in the U.S. The Company generates 
revenues from extracting and processing materials for the recovery of uranium, vanadium and REEs for our own account, as 
well as from toll processing materials for others.

Energy Fuels is engaged in conventional and ISR uranium extraction and recovery, along with the exploration, permitting, and 
evaluation  of  uranium  properties  in  the  U.S.  The  Company  also  extracts  and  recovers  vanadium  from  certain  of  its  uranium 
projects,  as  market  conditions  warrant.  In  2021,  the  Company  commenced  its  ramp-up  to  commercial  production  of  RE 
Carbonate, another byproduct of the uranium recovery process, and produced and sold commercial quantities of RE Carbonate 
in 2021, 2022 and 2023. To further its REE initiatives, the Company is currently undertaking enhancements and modifications 
to existing circuits at the Mill for the planned commercial separation of neodymium-praseodymium (“NdPr”) oxide from its 
RE Carbonate, while at the same time producing a “heavies” (Sm+) RE Carbonate. The Company also continues to evaluate the 
potential  to  recover  radioisotopes  from  its  existing  process  streams  needed  for  emerging  TAT  cancer  therapeutics.  The 
Company’s Mill is the only conventional uranium mill, and the only uranium, vanadium and REE recovery facility operating in 
the U.S., and has a licensed capacity to produce over 8 million pounds of U3O8 per year.

The Company is also securing its own sources of uranium- and REE-bearing monazite sands, and in February 2023 acquired the 
Bahia Project in Brazil (see “Part I, Item 1. Description of Business - Material Transactions,” “Part I, Item 1. Description of 
Business  -  2023  Corporate  Developments”  and  “Part  I,  Item  2.  Description  of  Properties  -  The  Bahia  Project”  below)  in 
furtherance  of  a  fully  integrated  U.S.-based  REE  supply  chain.  The  Company  continues  to  engage  in  active  discussions  to 
secure other sources of monazite sands, thereby diversifying its supply base and strengthening its REE business. In addition, 
Energy  Fuels  recovers  uranium  from  other  uranium-bearing  materials  not  derived  from  natural  or  native  ores,  referred  to  as 
“Alternate Feed Materials,” at its Mill, thereby recycling materials back into the market that would otherwise be lost to direct 
disposal.

With  its  uranium,  vanadium,  REE  and  potential  radioisotope  production,  the  Mill  is  working  to  establish  itself  as  a  critical 
minerals  hub  in  the  U.S.  Uranium  is  the  fuel  for  carbon-free,  emission-free  baseload  nuclear  power,  and  one  of  the  cleanest 
forms of energy in the world. The REEs we are now producing are used to manufacture permanent magnets for electric vehicles 
(“EVs”), wind turbines and other clean energy technologies. The radioisotopes we are evaluating for recovery from our REE 
and uranium processing streams have the potential to provide materials needed for emerging TAT cancer-fighting therapeutics. 
The very heart of our business – uranium and rare-earth production and recycling – helps us play a part in addressing global 
climate change, reducing air pollution, and making the world a cleaner and healthier place. 

The Company owns conventional uranium, uranium/vanadium and HMS properties and projects in various stages of operation, 
development, exploration and permitting, as well as fully permitted uranium and uranium/vanadium projects on standby. 

Energy Fuels also owns the Nichols Ranch Uranium Recovery Facility in Wyoming (the “Nichols Ranch Project”), which is a 
fully permitted uranium ISR facility with a licensed capacity to produce 2 million pounds of U3O8 per year. While production at 
the Nichols Ranch Project is currently being maintained on standby, the Company is undertaking exploration and development 
activities  to  expand  the  resources  at  the  Nichols  Ranch  Project  and  to  further  develop  a  wellfield  to  be  ready  for  potential 
recommencement of production in 2025. See “The Nichols Ranch ISR Project” under Item 2 below. 

ISR Operations

The Company conducts its ISR activities through its Nichols Ranch Project in northeast Wyoming, which it acquired in June 
2015 through its acquisition of Uranerz Energy Corporation (“Uranerz”).

14

The  Nichols  Ranch  Project  includes:  (i)  a  licensed  and  operating  ISR  processing  facility  (the  “Nichols  Ranch  Plant”);  (ii) 
licensed  and  operating  ISR  wellfields  (the  “Nichols  Ranch  Wellfields”);  (iii)  additional  licensed  ISR  wellfields  planned  for 
future production (the “Jane Dough Property”); and (iv) a licensed satellite ISR uranium project (the “Hank Project”), which, 
if  and  when  put  into  production  would  include  an  ISR  satellite  processing  plant  (the  “Hank  Satellite  Plant”)  that,  when 
constructed, would produce loaded-resin, and associated planned wellfields (together, the “Hank Property”). See “The Nichols 
Ranch ISR Project” under Item 2 below. Also through the acquisition of Uranerz, the Company acquired the West North Butte 
property (the “West North Butte Property”) and the North Rolling Pin property (the “North Rolling Pin Property”), as well 
as the Arkose Mining Venture (the “Arkose Mining Venture”), which is a joint venture of Wyoming ISR properties held 81% 
by Energy Fuels and 19% by United Nuclear, LLC (see “Part II, Item 8. Financial Statements and Supplementary Data - Note 
17 Related Party Transactions”). 

The Nichols Ranch Project is an ISR facility with production currently on standby that recovers uranium through a series of 
injection and recovery wells. Using groundwater fortified with oxygen and sodium bicarbonate, uranium is dissolved within a 
deposit.  The  uranium-bearing  groundwater  is  then  collected  in  a  series  of  recovery  wells  and  pumped  to  the  Nichols  Ranch 
Plant where the uranium is extracted from the water. The Nichols Ranch Plant creates a yellowcake slurry that is transported by 
truck to the Mill, where it is dried and packaged into drums that are shipped to uranium conversion facilities.

Construction of the Nichols Ranch Plant, other than the elution, drying and packaging circuits, was completed in 2013, and it 
commenced  uranium  recovery  activities  in  2014.  In  2015,  the  Company  commenced  construction  of  an  elution  circuit  at  the 
Nichols  Ranch  Plant,  which  was  completed  and  began  operations  in  early  2016.  The  Nichols  Ranch  Project  was  placed  on 
standby  in  2020.  As  a  result,  the  Company  recovered  de  minimis  pounds  of  U3O8  from  the  Project  in  2023  and  expects  to 
recover de minimis quantities of U3O8 in 2024. Nichols Ranch is expected to be able to ramp back up to commercial production 
levels with limited required capital within approximately six to twelve months of a decision to recommence production. While 
production at the Nichols Ranch Project is currently being maintained on standby, the Company is undertaking exploration and 
development activities to expand the resources at the Nichols Ranch Project and to further develop a wellfield to be ready for 
potential  recommencement  of  production  in  late  2024  or  in  2025.  See  “Part  II,  Item  7.  Operations  Update  and  Outlook  for 
2024: ISR Extraction and Recovery Activities.”

The Company sold its Alta Mesa ISR Project for total consideration of $120 million, which closed on February 14, 2023 (see 
“Part I, Item 1. Description of Business - Material Transactions” and “Part I, Item 2. Description of Properties - ISR Uranium 
Activities” below).

Conventional Operations

The Company conducts its conventional uranium, REE, vanadium and potential medical radioisotope extraction and recovery 
activities through the Mill, which is the only operating conventional uranium mill, and the only uranium, REE and vanadium 
processing facility in the United States. The Mill located near Blanding, San Juan County, Utah, is centrally located such that it 
can  conveniently  and  cost-effectively  be  fed  by  a  number  of  the  Company’s  uranium  and  uranium/vanadium  projects  in 
Colorado, Utah, Arizona and New Mexico, as well as by ore purchases or toll milling arrangements with third parties in the 
region, as market conditions warrant.

The Mill is licensed to process 2,000 tons of ore per day and over 8 million pounds of U3O8 per year. It is primarily a uranium 
recovery  facility  but  can  also  recover  REEs  and  vanadium  along  with  uranium  from  various  uranium  ores.  During  the  year 
ended  December  31,  2023,  the  Company  did  not  recover  any  pounds  of  uranium  at  the  Mill,  other  than  uranium  from  its 
monazite  processing  that  is  expected  to  remain  in  circuit  and  not  be  packaged  in  2024.  The  Mill  can  recycle  other  uranium-
bearing materials not derived from natural or native ores, known as Alternate Feed Materials, for the recovery of uranium, alone 
or in combination with other metals. In addition, the Mill is also evaluating the potential to recover certain radioisotopes from 
its existing process streams that can be used for TAT medical purposes. 

The Mill has historically operated on a campaign basis, whereby mineral processing occurs as mill feed, contract requirements 
and/or as market conditions warrant. Over the years, Company-owned and third-party owned conventional uranium properties 
in Utah, Colorado, Arizona and New Mexico have been both active and on standby in response to changing market conditions. 
Since  2007,  the  Mill  has  primarily  recovered  U3O8  from  conventional  sources,  including  its  La  Sal  Complex  (the  “La  Sal 
Project”), Daneros Project and Tony M property in Utah (the latter two of which were sold in 2021); its Arizona 1 project (the 
“Arizona 1 Project”) and its Pinenut project (the “Pinenut Project”) (which is currently in an advanced state of reclamation) 
in Arizona, as well as from a number of Alternate Feed Materials in furtherance of its core recycling program of third-party 
materials otherwise subject to direct disposal. 

15

In  2023,  the  Company  focused  on  preparing  its  La  Sal,  Beaver,  Whirlwind  and  Pinyon  Plain  Projects  for  future  potential 
production, while maintaining its Nichols Ranch Project and other conventional mining properties on standby. In late 2023, the 
Company commenced uranium production at its Pinyon Plain Project and its La Sal and Pandora mines (the La Sal and Pandora 
mines each comprise a portion of the La Sal Project). Once production is fully ramped up at the three mines, which is currently 
planned for mid- to late-2024, the Company expects to be producing uranium at a run-rate of approximately 1.1 to 1.4 million 
pounds per year. Ore mined from the three mines during 2024 will be stockpiled at the Mill for processing that is anticipated to 
start in late 2024 or in 2025, subject to market conditions, contract requirements and/or the Mill’s schedule. The Company is 
also preparing two (2) mines (the Whirlwind mine and the Nichols Ranch ISR project) to commence uranium production within 
one (1) year, which would increase Energy Fuels' uranium production to a run-rate of over two (2) million pounds of U3O8 per 
year starting in 2025, if strong market conditions continue as expected.

At the same time, the Company will continue to produce uranium from its Alternate Feed Material recycling program, which is 
expected to result in an estimated 150,000 pounds of finished U3O8 in 2024, while the Company stockpiles ore as raw materials 
from its conventional mines pending the upcoming Mill run. The Company also expects to commence an ore-buying program 
from  third-party  miners  in  2024,  which  is  expected  to  increase  the  Company’s  short-term  uranium  production  profile  even 
further.  In  2024,  the  Company  also  plans  to  advance  permitting  on  the  Roca  Honda,  Sheep  Mountain  and  Bullfrog  Projects, 
which  could  expand  the  Company’s  uranium  production  to  a  run-rate  of  up  to  five  million  pounds  of  U3O8  per  year  in  the 
coming  years.  Furthermore,  the  Company  expects  to  produce  at  a  run-rate  of  1.0-2.0  million  pounds  of  vanadium  per  year, 
which could be held as in-process inventory or processed into finished V2O5 available for sale into improving markets.

During 2024, Energy Fuels expects to sell 200,000 pounds of uranium into its existing portfolio of long-term contracts, which is 
expected to occur in Q1-2024. In addition, a utility customer has the option to purchase a further 100,000 pounds of uranium 
from Energy Fuels in 2024. The Company has already sold an additional 100,000 pounds of U3O8 on the spot market during 
Q1-2024  at  a  weighted  average  sales  price  of  $102.88  per  pound.  The  Company  holds  uncommitted  inventory  and,  with  the 
benefit of future production, will continue to evaluate additional spot and/or long-term uranium sales opportunities during 2024 
and beyond. The Company expects uranium inventories to total between approximately 585,000 to 935,000 pounds of U3O8 at 
year-end 2024, subject to unknown potential other uranium spot sales and purchases and the amount and time of ore production 
from the Pinyon Plain mine and Alternate Feed stockpiles in 2024.

In  addition  to  the  Company’s  uranium  business,  the  Company  will  also  continue  to  advance  its  REE  program  at  the  Mill  in 
2024, along with the Mill’s uranium production, to fully capitalize on the Mill's unique and valuable capabilities. As previously 
announced,  the  Mill  is  in  the  process  of  installing  the  capacity  to  produce  up  to  1,000  tonnes  of  neodymium-praseodymium 
(“NdPr”) oxide per year, subject to receipt of sufficient monazite feed. This capacity is expected to be completed in Q1 2024. 
This quantity of NdPr oxide could power up to 1 million electric vehicles (“EVs”) per year. At the current time, the Company 
expects to produce roughly 25 – 35 tonnes of NdPr oxide, plus approximately 10 – 20 tonnes of an Sm+ RE Carbonate, in Q2 
2024 as it ramps-up and optimizes the newly installed circuit, after which the Mill currently plans to focus solely on uranium 
and uranium/vanadium production through at least mid-2026. Subject to successful exploration, permitting and development of 
the Bahia Project and market conditions, the Company currently expects that monazite produced from the Company’s Bahia 
Project could be available for processing at the Mill commencing as early as 2026 to produce uranium, NdPr oxide and an Sm+ 
RE  Carbonate  (or  separated  Terbium  (“TB”)  and  Dysprosium  (“DY”)  oxides  instead  of  an  Sm+  RE  Carbonate)  along  with 
continued uranium production from the Company’s Pinyon Plain, La Sal, Pandora and potentially Whirlwind mines. Similarly, 
if the Company successfully completes its previously announced potential joint venture on the Donald Rare Earth and Mineral 
Sands Project, located in the Wimmera Region of the State of Victoria, Australia (the “Donald Project”) (see “Part I, Item 1. 
2023 Corporate Developments,” below), monazite production from that project could also be available at the Mill as early as 
2026, subject to market conditions, successful development of that project and successful development of the Company’s Phase 
2  crack  and  leach  and  Separation  Facility  (see  “Part  I,  Item  1.  Development  of  REE  Separation  Capability,”  below).  The 
Company is also in active discussions with several parties globally to acquire additional quantities of natural monazite, which, 
if  secured  and  delivered  to  the  Mill,  could  result  in  significant  additional  quantities  of  uranium  and  separated  REE  oxide 
production  as  early  as  2028.  The  Company  expects  to  sell  all  the  NdPr  it  produces  in  2024  to  Neo  Performance  Materials 
(“Neo”)  under  an  existing  contractual  arrangement  with  Neo.  Potential  REE  production  after  2024  is  currently  uncontracted. 
The  Mill's  REE  production  is  complementary  to  its  uranium  production  and  is  not  intended  to  diminish  the  Mill's  uranium 
production profile in any way.

The Company will continue to selectively sell its vanadium pentoxide (“V2O5”) inventory (approximately 905,000 pounds as of 
December  31,  2023)  on  the  spot  market  as  markets  warrant,  but  will  otherwise  continue  to  maintain  it  in  inventory.  No 
vanadium  production  is  currently  planned  for  2024,  though  the  Company  continually  monitors  its  inventory  and  vanadium 
markets to guide future potential vanadium production.

16

The  Company  currently  has  approximately  685,000  pounds  of  finished  U3O8  inventory  held  at  the  Mill  and  at  conversion 
facilities  owned  by  ConverDyn  and  Cameco,  along  with  approximately  another  436,000  pounds  of  U3O8  contained  in 
stockpiled  Alternate  Feed  Materials  and  mineralized  material  inventory  that  is  expected  to  be  processed  for  recovery  in  the 
future. In addition, there remains an estimated 1.0 to 3.0 million pounds of solubilized recoverable V2O5 remaining in the Mill’s 
tailings  facility  awaiting  future  recovery,  as  market  conditions  may  warrant.  See  Part  II,  Item  7  “Outlook:  Conventional 
Extraction and Recovery Activities.”

The  Company  also  owns  the  Sheep  Mountain  Project  (the  “Sheep  Mountain  Project”),  which  is  a  conventional  uranium 
extraction project located in Wyoming. Due to its distance from the Mill, the Sheep Mountain Project is not expected to be a 
source  of  feed  material  for  the  Mill.  The  Sheep  Mountain  Project  consists  of  permitted  open  pit  and  underground  extraction 
components (the “Sheep Mountain Extraction Operation”) and a planned processing facility to process extracted mineralized 
material (the “Sheep Mountain Processing Operation”), which has not yet been permitted.

The Company’s principal conventional properties include the following:

•

•

•

•

•

•

•

•

•

the Mill, which is an operating 2,000 ton-per-day uranium, vanadium and REE processing facility located in Utah and 
held through the Company’s subsidiary EFR White Mesa LLC. See “Part I, Item 2.D. The White Mesa Mill”;
the Pinyon Plain Project, which is a fully permitted and operating uranium project with all surface facilities and a shaft 
in place (see “Part I, Item 2.E. The Pinyon Plain Project”);
the Bahia Project, which is comprised of 17 heavy minerals concessions covering 37,300 acres or 58.3 square miles, 
held through the Company’s subsidiary Energy Fuels Brazil Ltda. (see “2023 Corporate Developments,” below); 
the Wate project (the “Wate Project”), which is a uranium deposit in the permitting stage; the Arizona 1 project (the 
“Arizona  1  Project”),  which  is  a  fully  permitted  uranium  project  on  standby;  and  the  EZ  properties  (“EZ 
Properties”), which are uranium deposits in the exploration and evaluation stage. All of the Company’s Arizona Strip 
properties  are  held  by  the  Company’s  subsidiary  EFR  Arizona  Strip  LLC,  with  the  exception  of  the  Wate  Project, 
which is held by the Company’s subsidiary Wate Mining Company LLC. See “Part I, Item 2K. Non-Material Mineral 
Properties – Other Conventional Projects – Arizona Strip”;
the  Roca  Honda  Uranium  Project  (the  “Roca  Honda  Project”),  which  is  located  near  the  town  of  Grants,  New 
Mexico, held by the Company’s subsidiaries Strathmore Resources (US), Ltd. and Roca Honda Resources LLC. See 
“Part I, Item 2.F. The Roca Honda Project”;
the Sheep Mountain Project, which is a uranium project located near Jeffrey City, Wyoming, including permitted open 
pit and underground components held by the Company’s subsidiary Energy Fuels Wyoming Inc. See “Part I, Item 2G. 
The Sheep Mountain Project”;
the Bullfrog Project (the “Bullfrog Project”), which is located in south central Utah near the town of Ticaboo, and 
which is held by the Company’s subsidiary EFR Henry Mountains LLC. See “Part I, Item 2H. The Bullfrog Project”;
the La Sal Complex of uranium and uranium/vanadium projects (the “La Sal Project”) (see “Part I, Item 2I. The La 
Sal  Project”)  and  the  Whirlwind  uranium/vanadium  project  (the  “Whirlwind  Project”),  both  of  which  are  located 
near the Colorado/Utah border (the “Colorado Plateau”) and, in addition to nearby exploration properties, are held by 
the  Company’s  subsidiary  EFR  Colorado  Plateau  LLC.  See  “Part  I,  Item  2K.  Non-Material  Mineral  Properties  – 
Other Conventional Projects – Colorado Plateau”; and
a number of non-core uranium properties, which are held in various of the Company’s subsidiaries. See “Part I, Item 
2K. Non-Material Mineral Properties.”

Mineral Exploration

Energy  Fuels  holds  a  number  of  exploration  properties  in  the  Colorado  Plateau,  Arizona  Strip,  and  Powder  River  Basin 
Districts.  Energy  Fuels  conducted  intermittent  exploration  drilling  on  numerous  projects  in  the  period  from  February  2007 
through  December  2013.  Several  of  those  projects  have  been  abandoned  or  sold.  No  further  exploration  drilling  has  been 
performed  at  these  properties  since  2013.  See  “Part  I,  Item  2K.  Non-Material  Mineral  Properties.”  The  Company  plans  to 
engage in an exploration and drilling program at its Nichols Ranch Project and further delineation at its Pinyon Plain Project in 
2024. See “Part I, Item 2. The Nichols Ranch Project, The Company’s Planned Work” and  “Part I, Item 2. The Pinyon Plain 
Project, The Company’s Planned Work.”

The Company’s Rare Earth Elements Business

REEs are a group of 17 chemical elements (the 15 elements in the lanthanum series, plus yttrium and scandium) that have a 
variety  of  industrial,  energy,  and  defense  uses,  including  advanced  permanent  magnets  for  EVs  and  wind  turbines, 
communications  technology,  clean  energy  production,  consumer  electronics,  defense  systems,  lasers  and  numerous  other 
applications. See “The Rare Earth Element Market” below.

17

On  April  13,  2020,  the  Company  announced  its  entry  into  the  REE  sector  by  embarking  on  a  program  to  evaluate  the 
production  of  REEs  and  uranium  at  the  Mill  from  uranium  and  REE-bearing  mineralized  materials,  thereby  taking  a  step 
towards  bringing  the  REE  supply  chain  back  to  the  U.S.  Later  that  year,  the  Company  successfully  produced  a  mixed  RE 
Carbonate on a pilot scale using existing Mill infrastructure and technologies, along with the contained uranium, from a sample 
of  monazite  sands.  For  reference,  RE  Carbonate  is  an  intermediate  product  which  is  sent  to  an  REE  separation  facility  for 
separation  into  individual  REE  oxides,  which  is  the  next  step  in  producing  usable  REE  products.  Additionally,  in  2020,  the 
Company secured a three-year supply agreement for natural monazite sands from The Chemours Company’s Offerman Mineral 
Sand Plant in Georgia, USA, which is currently in the process of being renegotiated after unexpected shortfalls in the monazite 
delivery schedule. 

Then, in 2021, the Company and Neo announced a new rare earth production initiative spanning European and North American 
critical material supply chains, pursuant to which Energy Fuels processes natural monazite sands for the recovery of uranium 
and  RE  Carbonate  at  the  Mill  and  ships  the  RE  Carbonate  to  Neo’s  NPM  Silmet  AS  REE  separations  facility  in  Estonia 
(“Silmet”), where it is made into separated REE materials for use in REE permanent magnets and other REE-based advanced 
materials. This is the most advanced REE material being produced in the U.S. today at scale, since it is a high-purity product 
ready for REE separation without further processing, refining or purification. 

In  February  2023,  the  Company  acquired  the  Bahia  Project  in  Brazil,  which  holds  significant  quantities  of  heavy  minerals, 
including monazite (see “Part I, Item 1. Description of Business - Material Transactions” below). The acquisition of the Bahia 
Project  is  a  part  of  the  Company’s  efforts  to  build  a  large  and  diverse  book  of  monazite  supply  for  its  advancing  REE 
processing business. The Company expects to procure monazite through Company-owned mines like the Bahia Project, joint 
ventures or other collaborations, and open market purchases. The Company is currently in advanced discussions with several 
additional current and future monazite producers around the world to potentially supply Energy Fuels’ REE initiatives.

Development of REE Separation Capability 

In producing its commercial RE Carbonate, the Company has been separating lanthanum (“La”) and cerium (“Ce”) from the 
RE  Carbonate  stream  utilizing  existing  Mill  infrastructure  in  order  to  produce  an  RE  Carbonate  product  with  higher 
concentrations  of  NdPr  and  “heavy”  REEs.  This  is  the  first  commercial-level  REE  separation  to  occur  in  the  U.S.  in  many 
years. Energy Fuels is also proceeding with the modification and enhancement of its infrastructure at the Mill (“Phase 1”) to 
expand its REE separation facilities to be capable of producing commercial quantities of separated NdPr oxide by early 2024, 
followed by planned further enhancements to expand NdPr production capability (“Phase 2”) and to produce separated Dy, Tb 
and potentially other REE materials in the future (“Phase 3”) from monazite and potentially other REE process streams. 

The  Company  began  construction  on  its  “Phase  1”  REE  separation  facilities  in  2023,  which  includes  modifications  and 
enhancements  to  the  solvent  extraction  (“SX”)  circuits  at  the  Mill.  “Phase  1”  is  expected  to  have  the  capacity  to  process 
approximately 8,000 to 10,000 MT of monazite per year from the Mill’s process streams, producing roughly 4,000 to 5,000 MT 
TREO,  containing  roughly  800  to  1,000  MT  of  recoverable  separated  NdPr  oxide  per  year,  subject  to  receipt  of  sufficient 
monazite  supply.  Because  Energy  Fuels  is  utilizing  existing  infrastructure  at  the  Mill,  “Phase  1”  capital  is  expected  to  total 
between $16 million and $18 million, or approximately $7 million to $9 million less than our initial $25 million budget. “Phase 
1” is expected to be operational in early 2024, subject to successful construction and commissioning. At the current time, the 
Company  expects  to  produce  roughly  25  –  35  tonnes  of  NdPr  oxide  plus  approximately  10  –  20  tonnes  of  an  Sm+  RE 
Carbonate in Q2 2024, as it ramps-up and optimizes the newly installed circuit. If these milestones are achieved, Energy Fuels 
believes it will be the ‘first to market’ among U.S. companies with commercial quantities of separated NdPr available to EV, 
renewable energy and other companies for offtake. 

During  “Phase  2,”  Energy  Fuels  expects  to  expand  its  NdPr  separation  capabilities,  with  an  expected  capacity  to  process 
roughly 30,000 to 50,000 MT of monazite per year, depending on the availability of monazite and expected recovery of roughly 
15,000 to 25,000 MT of TREO, containing roughly 3,000 to 5,000 MT of NdPr oxide per year, or sufficient NdPr for 1.5 to 5.0 
million EVs per year. “Phase 2” is also expected to add a dedicated monazite “crack-and-leach” circuit to the Mill’s existing 
leach circuits, which may be constructed as the first stage of Phase 2, prior to construction of the expanded NdPr separation 
capabilities.  The  Company  expects  to  complete  “Phase  2”  in  2027,  subject  to  licensing,  financing  and  receipt  of  sufficient 
monazite feed.

During “Phase 3,” Energy Fuels expects to add “heavy” REE separation capabilities, including the production of Dy, Tb, and 
potentially  other  REE  oxides  and  advanced  materials.  The  Company  will  also  evaluate  the  potential  to  produce  La  and  Ce 
products. Monazite naturally contains higher concentrations of “heavy” REEs, including Dy and Tb, versus other REE-bearing 
ores, like bastnaesite, mainly due to the presence of another REE-bearing phosphate mineral called “xenotime.” “Phase 3” is 

18

expected  to  enable  Energy  Fuels  to  produce  separated  Dy,  Tb,  and  potentially  other  “light”  and  “heavy”  products.  The 
Company also expects to have additional “heavy” REE feedstock stockpiled from “Phase 1” and “Phase 2.” During these earlier 
phases,  the  Company  expects  to  produce  NdPr  oxide  and  a  samarium-plus  (“Sm+”)  ”heavy”  REE  concentrate,  which  the 
Company  will  either  sell  or  stockpile  as  feed  for  “Phase  3”  REE  separation.  For  reference,  the  monazite  the  Company  has 
analyzed to date contains roughly 1% to 3% Dy and Tb, so 10,000 MT of monazite is expected to contain roughly 100 to 300 
MT  of  Dy  and  Tb.  The  Company  expects  to  complete  “Phase  3”  in  2028,  subject  to  licensing,  financing,  and  receipt  of 
sufficient feed. Alternatively, the Company may delay Phase 2 and combine Phase 2 and Phase 3 separation capability.

See  also  “The  Rare  Earth  Element  Market,”  below,  for  further  details  on  the  REE  market  and  “Part  II,  Item  7.  Rare  Earth 
Sales” and “Update on Rare Earth Element Initiative” for further details on the above-referenced REE developments. 

There are a number of risks inherent to the Company’s REE activities. See “Part I, Item 1A. Risk Factors.”

The Company’s Strategic Alliance for the Development of Radioisotopes for Medical Therapeutics

On July 28, 2021, the Company announced the execution of a Strategic Alliance Agreement with RadTran LLC (“RadTran”), 
a  technology  development  company  focused  on  closing  critical  gaps  in  the  procurement  of  medical  isotopes  for  TAT  cancer 
therapeutics and other applications.

TAT  is  an  in-development  method  of  targeted  radionuclide  therapy  for  various  cancers.  It  employs  radioactive  substances 
which undergo alpha decay to treat diseased tissue at close proximity. It has the potential to provide highly targeted treatment, 
especially  to  microscopic  tumor  cells.  As  in  diagnostic  nuclear  medicine,  appropriate  alpha-emitting  radionuclides  can  be 
chemically bound to a targeting biomolecule, such as a peptide, which carries the combined radiopharmaceutical to a specific 
treatment point (the cancerous cells). During the last decade, radiolabeled peptides that bind to different receptors on the tumors 
have been investigated as potential therapeutic agents both in the preclinical and clinical settings. Peptides, such as octreotide, 
alpha-melanocyte-stimulating hormone analogues, arginine-glycine-aspartic acid-containing peptides, bombesin derivatives and 
others may all be feasible for use with alpha-emitters.

The primary advantage of alpha particle emitters over other types of radioactive sources is their very high linear energy transfer 
and relative biological effectiveness. By comparison, beta particle emitters such as yttrium-90 can travel considerable distances 
beyond the immediate tissue before depositing their energy, thereby causing damage to surrounding healthy tissues, while alpha 
particles deposit their energy in 70–100 μm long tracks, thereby causing significantly less harm to surrounding healthy tissues. 
Further, alpha particles are more likely than other types of radiation to cause double-strand breaks to DNA molecules, which is 
one of several effective causes of cell death. In other words, the high level of radiobiological effectiveness of alpha particles, in 
comparison with beta emissions, requires fewer particle tracks to induce cell death.

Though many alpha emitters exist, useful isotopes need to have sufficient energy to cause damage to cancer cells, while at the 
same  time  have  a  half-life  that  is  long  enough  to  provide  a  therapeutic  dose  without  remaining  long  enough  to  damage 
surrounding healthy tissue. Clinically effective alpha particle-emitting isotopes for cancer therapy should therefore have a short 
half-life, which will limit long-term radiation exposure and allow for the production, preparation, and administration of these 
isotopes  for  clinical  use  and  application.  Radium  223  dichloride  is  the  first-in-class,  commercially  available  targeted  alpha 
therapy approved for the treatment of patients with metastatic castration-resistant prostate cancer with bone metastases. Given 
the established overall survival benefit conferred by radium 223 for patients with metastatic castration-resistant prostate cancer, 
several other targeted alpha therapies are being investigated in clinical trials across many tumor types.

Under its strategic alliance with RadTran, the Company is evaluating the feasibility of recovering Th-232 and Ra-226 from its 
existing  RE  Carbonate/uranium  and  uranium  process  streams  at  the  Mill  and,  together  with  RadTran,  is  evaluating  the 
feasibility  of  recovering  Ra-228  from  the  Th-232  and  potentially  Th-228  from  the  Ra-228  and  concentrating  Ra-226  to 
commercial specifications at the Mill. Recovered Ra-228, Th-228 and Ra-226 would then be sold to pharmaceutical companies 
and others to produce Pb-212, Ac-225, Bi-213, Ra-224 and/or Ra-223, which are the leading medically attractive TAT isotopes 
for  the  treatment  of  cancer  at  this  time.  Existing  supplies  of  these  isotopes  for  TAT  applications  are  in  short  supply,  and 
methods of production are costly and currently cannot be scaled to meet the demand created as new drugs are developed and 
approved. This is a major roadblock in the research and development of new TAT drugs as pharmaceutical companies wait for 
scalable  and  affordable  production  technologies  to  become  available.  Under  this  initiative,  the  Company  has  the  potential  to 
recover  valuable  isotopes  from  its  existing  process  streams,  thereby  recycling  back  into  the  market  material  that  would 
otherwise be lost to disposal for use in treating cancer.

Activities being undertaken by the Company at this time include evaluations of the technical feasibility of recovering Th-232, 
Ra-228  and  Th-228  from  the  Mill’s  RE  Carbonate/uranium  process  streams,  and  Ra-226  from  the  Mill’s  uranium  process 

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streams; the permitting and licensing required to separate and recover Th-232, Ra-228, Th-228 and Ra-226 at the Mill; and the 
commercial feasibility of this project. 

There are a number of risks inherent to the Company’s isotope activities. See “Item 1A. Risk Factors” under Item 1A, below.

San Juan County Clean Energy Foundation

On  September  16,  2021,  the  Company  announced  its  establishment  of  the  San  Juan  County  Clean  Energy  Foundation  (the 
“Foundation”),  a  fund  specifically  designed  to  contribute  to  the  communities  surrounding  the  Mill  in  southeastern  Utah. 
Energy Fuels deposited an initial $1 million into the Foundation at the time of formation and now provides ongoing funding 
equal to 1% of the Mill’s revenues, thereby providing an ongoing source of funding to support local priorities. The Foundation 
focuses on supporting education, the environment, health/wellness, and local economic development in the City of Blanding, 
San Juan County, the White Mesa Ute Community, the Navajo Nation and other area communities. 

A seven-person Advisory Board, comprised of local citizens from San Juan County, evaluates grant applications on a quarterly 
basis and is making its recommendations to the Foundation’s Managers for final review and approval, who are currently the 
President and Chief Executive Officer and the Executive Vice President and Chief Legal Officer of the Company. As of the 
2024 year-end, the Foundation has awarded 15 grants totaling $323,210, of which $236,710 was committed to American Indian 
initiatives.  The  Foundation’s  website  address  is:  https://sanjuancountycleanenergy.org/.  The  Foundation’s  website  and  the 
contents thereof should not be considered to be incorporated by reference into this Annual Report.

Sale of the Alta Mesa ISR Project

Material Transactions

On February 15, 2023, the Company announced that it had closed on its sale of three wholly owned subsidiaries that together 
held  Energy  Fuels’  Alta  Mesa  ISR  Project  to  enCore  Energy  (“enCore”)  for  total  consideration  of  $120  million,  paid  as 
follows:

a.
b.

$60 million cash at or prior to closing; and
$60  million  in  a  secured  convertible  note  (the  “Convertible  Note”),  payable  in  two  years  from  the  closing,  bearing 
annual  interest  of  eight  percent  (8%).  The  Convertible  Note  was  convertible  at  Energy  Fuels’  election  into  enCore 
shares  at  a  conversion  price  of  $2.9103,  being  a  20%  premium  to  the  10-day  volume-weighted  average  price  of 
enCore's  common  shares  ending  the  day  before  the  closing.  enCore  is  currently  traded  on  the  TSXV  and  NYSE 
American stock exchanges. The Convertible Note was guaranteed by enCore Energy Corp. and was fully secured by 
Alta Mesa. Except where the Company executed a block trade or similar distribution to sell the enCore common shares 
received on conversion of the Convertible Note, Energy Fuels was limited to converting the Convertible Note into a 
maximum of $10 million principal amount of the Convertible Note per thirty (30)-day period.

In  addition,  enCore  was  required  to  replace  the  existing  reclamation  bonds  for  the  Alta  Mesa  project  (approximately  $10.3 
million) shortly after the closing of the transaction, which resulted in Energy Fuels receiving an additional $3.6 million cash as 
a return of collateral from those bonds. The Company estimates that the sale of Alta Mesa reduced Energy Fuels’ cash burn by 
approximately $2 million per year, which affords the Company additional resources to allocate to Energy Fuels’ uranium, REE, 
vanadium and medical isotope business plans for the next two to three years.

During 2023, enCore redeemed $40.0 million of the principal amount of the Convertible Note and paid $1.8 million of interest 
to the Company in partial fulfillment of its obligations under the Convertible Note. On November 9, 2023, the Company sold 
the  remaining  $20.0  million  principal  amount  of  the  Convertible  Note  for  $21.0  million  plus  $1.5  million  in  unpaid  accrued 
interest,  less  a  sales  commission  of  $0.1  million  paid  to  a  third-party  broker.  As  a  result,  the  Company  received  net  cash 
proceeds of $64.2 million related to the redemptions, sale and interest received. 

Acquisition of the Bahia Project in Brazil

On February 13, 2023, the Company announced that it had completed its previously announced acquisition of seventeen (17) 
mineral  concessions  between  the  towns  of  Prado  and  Caravelas  in  the  State  of  Bahia,  Brazil,  totaling  15,089.71  hectares  (or 
approximately  37.300  acres  or  58.3  square  miles)  (the  “Bahia  Project”),  for  total  cash  consideration  of  $27.50  million.  The 
Bahia Project is a well-known HMS deposit that has the potential to supply 3,000 to 10,000 metric tons of natural monazite 
concentrate per year for decades to the Mill for processing into high-purity REE oxides and other materials. The Company is 
currently  in  the  midst  of  a  sonic  drilling  program  on  the  property  to  further  define  and  quantify  the  HMC  resource.  The 
Company is also sampling the material and sending the material to laboratories for testing, including metal assay, mineralogic 

20

characterization and process testing. The Company expects to announce drilling results this year, and to engage industry experts 
to calculate an initial mineral resource estimate compliant with S-K 1300 (U.S.) and NI 43-101 (Canada). 

2023 Corporate Developments

In addition to the Material Transactions detailed above, the Company saw the following corporate developments in 2023: 

On January 19, 2023, the Company sold 300,000 pounds of U3O8 to the U.S. Uranium Reserve Program for $18.47 million, or 
$61.57 per pound. During 2023, the Company sold a total of 560,000 pounds of uranium to the U.S. Uranium Reserve Program 
and into its portfolio of long-term contracts for a weighted-average sales price of $59.42 per pound.

During  Q1-2023,  the  Company  began  modifying  and  enhancing  its  existing  SX  circuits  at  the  Mill  to  be  able  to  produce 
separated  REE  oxides  (see  “Phase  1”  discussion  under  “Part  I,  Item  1.  Description  of  Business  -  Development  of  REE 
Separation  Capability,”  above).  Phase  1,  which  is  expected  to  be  completed  in  Q1-2024  and  commissioned  in  Q2-2024,  is 
expected to have the capacity to produce 800 to 1,000 metric tons of separated NdPr oxide, subject to successful commissioning 
and ramp-up and receipt of sufficient monazite feed.

On  December  21,  2023,  the  Company  announced  that,  in  response  to  strong  uranium  market  conditions,  it  had  commenced 
uranium  production  at  three  of  its  permitted  and  developed  uranium  mines  located  in  Arizona  and  Utah.  In  addition,  the 
Company announced that it is preparing two additional mines in Colorado and Wyoming for expected production within one 
year and advancing permitting on several other large-scale U.S. mine projects in order to increase uranium production in the 
coming years. Once production is fully ramped up at the three mines, including the Pinyon Plain Project and the La Sal and 
Pandora mines (each of the La Sal and Pandora mines constitutes a portion of the La Sal Project), the Company expects to be 
producing  uranium  at  a  run-rate  of  approximately  1.1  to  1.4  million  pounds  per  year.  Ore  will  be  stockpiled  at  the  Mill  for 
processing in 2024 or 2025, subject to market conditions, contract requirements and/or the Mill’s schedule.

On  December  27,  2023,  the  Company  announced  that  it  had  entered  into  a  non-binding  Memorandum  of  Understanding 
(“MOU”) with Astron Corporation Limited (“Astron”) to jointly develop the Donald Project in Australia. The Donald Project 
is a well-known and “shovel-ready” critical mineral deposit that the Company believes could provide it with another near-term, 
low-cost,  and  large-scale  source  of  monazite  sand  in  an  REE  concentrate  (“REEC”)  that  would  be  transported  to  the 
Company’s Mill for the recovery of REE oxides and along with the contained uranium. The Donald Project has most licenses 
and permits in place (or at an advanced stage of completion). The MOU contemplates that the joint venture (the “Venture”) 
would  initially  consist  of  operations  to  mine  7.5  million  metric  tons  of  ore  per  year  to  produce  approximately  200,000  to 
250,000 metric tons of HMC per year and approximately 7,000 to 8,000 metric tons of REEC (“Stage 1”). It is contemplated 
that, as soon as practicable after commencing Stage 1 commercial production, the Venture would double ore production to 15 
million  metric  tons  per  year  to  produce  approximately  400,000  to  500,000  metric  tons  of  HMC  per  year  and  approximately 
13,000 to 14,000 metric tons of REEC per year (“Stage 2”). The MOU sets out in broad terms the basis upon which the parties 
would enter into an Australian incorporated Venture covering the tenements MIN5532 and RL2002, which together form the 
Donald Project. The MOU provides for the continuation of due diligence by Energy Fuels and the negotiation of definitive and 
binding  agreements  governing  the  venture.  The  MOU  provides  for  Energy  Fuels  to  invest  Aus$180  million  (approximately 
$117 million at current exchange rates) to earn a 49% interest in the Venture. In addition, the Company would issue to Astron 
common shares having a value of $17.5 million in consideration of RL2002 being included in the Venture. There can be no 
assurance that the Company will enter into definitive agreements to govern the Venture, or if entered into, that the terms will be 
as set out in the MOU.

Corporate Officers

Effective  July  14,  2023,  John  L.  Uhrie  departed  from  the  Company  and  ceased  to  be  its  Chief  Operating  Officer.  Effective 
December 31, 2023, Tom L. Brock departed from the Company and ceased to be its Chief Financial Officer. Effective January 
1,  2024,  Nathan  R.  Bennett  assumed  his  appointment  as  the  Company’s  Chief  Accounting  Officer/Interim  Chief  Financial 
Officer. 

Company Strategy

Energy Fuels intends to continue to strengthen its position as a leading uranium extraction and recovery company in the U.S., 
supporting  that  goal  through  uranium  recovery  from  mined  ore,  Alternate  Feed  Materials  processing,  third-party  processing, 
monazite processing, and potential land cleanup work on abandoned uranium mines (“AUM”) throughout the western U.S. and 
elsewhere.  The  Company’s  strategy  is  to  maintain  and  advance  its  ability  to  increase  uranium  production  in  current  and 
improved market conditions through the Mill (currently operating), the Pinyon Plain Project and the La Sal and Pandora mines 

21

(each of the La Sal and Pandora mines constitutes a portion of the La Sal Project) (currently operating) and the Nichols Ranch 
Project (mining operations currently on standby, maintained in a ready-state), as well as through a large uranium resource base, 
its Alternate Feed Materials recycling program, and existing conventional projects under construction and/or in permitting. The 
Company  will  also  be  performing  exploration  activities  to  increase  its  resource  base.  In  addition,  the  Company  intends  to 
continue producing vanadium as a co-product of uranium from certain of its vanadium-base properties, as market conditions 
warrant.  In  2024,  the  Company  expects  to  continue  production  from  the  three  above-mentioned  conventional  uranium  mines 
now in operation, to prepare two additional conventional uranium mines for potential production as soon as 2025, to complete, 
commission and optimize its Phase 1 REE separation circuit in early 2024 and produce separated NdPr oxide and an Sm+ RE 
Carbonate along with uranium from monazite sands through Q2 2024. The Company also expects to advance its Bahia Project 
in  Brazil,  to  continue  to  evaluate  entering  into  a  Venture  on  the  Donald  Project  with  Astron  in  Australia,  and  to  secure 
additional  sources  of  monazite  and  potentially  other  feed  for  its  emerging  REE  business.  See  “The  Company’s  Rare  Earth 
Elements Business,” above. The Company will also continue to evaluate the potential for recovering certain radioisotopes from 
its  existing  process  streams  for  use  in  making  medical  isotopes  for  emerging  TAT  cancer  treatments.  See  “The  Company’s 
Strategic Alliance for the Development of Radioisotopes for Medical Therapeutics,” above.

As a result of the foregoing, we are now or intend to engage in the following activities in 2024:

•

•

•

•

•

•

•

•

•

•

in response to improving uranium market conditions, the Company recently began ramping up commercial uranium 
ore production at its conventional uranium Pinyon Plain and Pandora mines and its conventional uranium/vanadium La 
Sal Project. By mid- to late-2024, the Company expects to be producing uranium at a run-rate of approximately 1.1 to 
1.4 million pounds per year. Uranium-bearing ore will be stockpiled at the Mill and processed later in 2024 or 2025;

the  Company  expects  to  produce  between  150,000  and  500,000  pounds  of  finished  U3O8  during  2024  from 
conventional ore and Alternate Feed Materials, depending on the timing of ramp up of production at the Company’s 
Pinyon Plain, La Sal and Pandora mines;

the Company expects to sell between 300,000 and 600,000 pounds of uranium during 2024, of which between 200,000 
and  300,000  pounds  will  be  sold  under  its  existing  long-term  contracts  with  utilities,  with  the  remaining  sales 
occurring on the spot market;

the Company expects to perform exploration activities at its Nichols Ranch Project and further delineation drilling at 
its Pinyon Plain Project to increase its resource base;

the  Company  expects  to  prepare  two  additional  uranium  mines  (the  Nichols  Ranch  ISR  Project  and  the  Whirlwind 
Project) to be ready to resume uranium ore production as soon as 2025. The exact timing for resumption of production 
from  each  of  these  projects  will  be  subject  to  current  and  future  uranium  market  conditions  and/or  procurement  of 
additional long-term contracts;

continue  the  Company’s  ongoing  efforts  to  develop  a  fully  integrated  U.S.  REE  supply  chain,  including  the 
development  of  the  Company’s  Bahia  Project  in  Brazil;  the  potential  acquisition  of  additional  sources  of  monazite 
sands; the completion, commissioning, and optimization of the Phase 1 REE separation capabilities at the Company’s 
Mill in early 2024; and the production of NdPr oxide and an Sm+ RE Carbonate, along with uranium, from monazite 
sands through Q2 2024 (see “The Company’s Rare Earth Elements Business,” above); 

continue to pursue additional Alternate Feed Materials, third-party processing and other sources of feed for the Mill 
(including potential material recovered from AUM and other land cleanup work) and, when market conditions warrant, 
pursue the recovery of uranium and/or vanadium dissolved in the Mill’s tailings pond solutions; 

continue to maintain projects and facilities in a state of readiness for the purpose of restarting mining activities on an 
expedited basis, as contract obligations and market conditions may warrant;

advance permitting and evaluation activities for the Sheep Mountain, Roca Honda and/or Bullfrog Projects; and

continue  to  evaluate  the  potential  for  recovering  and  selling  certain  radioisotopes  from  the  Mill’s  existing  process 
streams for use in making medical isotopes for emerging TAT cancer treatments. 

22

Uranium Sales

With  recent  uranium  market  improvements,  existing  long-term  sales  commitments  and  the  improved  prospect  of  procuring 
additional  long-term  sales  commitments,  the  outlook  for  sustained  profitable  production  for  the  Company  has  improved 
significantly from the weak uranium market conditions that lasted until mid-2021.

As of the date of this Annual Report, the Company has entered into three uranium sales contracts with U.S. nuclear utilities, 
with  200,000  pounds  of  deliveries  that  occurred  in  January  2024  at  an  average  price  of  $75.13  per  pound  (totaling  $15.0 
million). The Company has also entered into agreements to sell 100,000 pounds to each of two customers at an average price of 
$102.88 per pound, with deliveries expected to occur in March 2024 (totaling $10.29 million). In addition, a utility customer 
has  the  option  to  purchase  an  additional  100,000  pounds  of  uranium  from  the  Company  in  2024  by  providing  notice  to  the 
Company  on  or  before  October  1,  2024.  The  Company  holds  uncommitted  inventory  and,  with  the  benefit  of  production  in 
2024 and beyond, will continue to evaluate additional spot and/or long-term uranium sales opportunities up to 300,000 pounds 
during  2024  and  beyond.  The  Company  may  also  evaluate  the  purchase  of  uranium  on  the  spot  market,  subject  to  market 
conditions and contract requirements. The Company also completed the purchase of 100,000 pounds of U.S. origin U3O8 during 
Q4-2023 at a price of $81.00 per pound (totaling $8.10 million). 

The Company expects uranium inventories to total between approximately 585,000 and 935,000 pounds of U3O8 at year-end 
2024,  subject  to  2024  production  levels  and  uranium  sales  and  purchases.  Energy  Fuels’  uranium  inventory  provides  the 
Company with financial flexibility, and the Company believes its existing inventories, purchases and new production will be 
sufficient to meet contract requirements through 2024 and over the life of the supply contracts, along with discretionary spot 
sales in 2024, as market conditions may warrant.

Overview of Uranium Market

The primary use of uranium is to fuel nuclear power plants for the generation of carbon- and emission-free electricity.

According to the World Nuclear Association (“WNA”), as of January 2024, there were 437 operable nuclear reactors world-
wide, which required approximately 170.7 million pounds of U3O8 annually at full operation. Worldwide, there are currently 61 
new  reactors  under  construction  with  an  additional  115  reactors  on  order  or  in  the  planning  stage  and  326  having  been 
proposed.

According to data from TradeTech LLC (“TradeTech”), the world continues to require more uranium than it produces from 
primary  extraction.  The  gap  between  demand  and  primary  supply  is  being  filled  by  stockpiled  inventories  and  secondary 
supplies, which the Company believes have dwindled significantly in recent years.

According to the WNA, the U.S. currently has 93 operating reactors, one reactor under construction, and another 21 reactors on 
order,  planned  or  proposed.  According  to  the  U.S.  Energy  Information  Administration  (“EIA”),  in  2022,  the  U.S.  produced 
approximately 18.2% of its electricity from nuclear technology, while, according to the Nuclear Energy Institute (“NEI”), the 
U.S. achieved an average capacity factor of 92.7%, leading all other carbon-free sources by a wide margin. According to the 
EIA, U.S. utilities purchased approximately 40.5 million pounds of U3O8 in 2022 (the last year reported). However, in 2022, 
U.S. uranium production was only 0.19 million pounds, of which 0.16 million pounds were produced by Energy Fuels.

In 2023, interest in the uranium and nuclear sectors continued to grow substantially, which the Company believes was driven 
by: (1) global efforts to reduce carbon emissions and a growing focus on electrification; (2) geopolitical tensions, particularly 
regarding Russia’s invasion of Ukraine; and (3) speculation based on supply and demand fundamentals. The Company believes 
that  nuclear  energy  is  essential  to  the  global  economy  and  addressing  climate  change,  as  it  reliably  and  affordably  provides 
electricity 24/7 and 365 days per year while generating lower life-cycle carbon emissions than other baseload energy sources 
(NREL, September 2021). 

The  Company  believes  the  geopolitical  uncertainty  and  market  tightness  experienced  in  the  2023  uranium  and  nuclear  fuel 
markets  will  continue  in  2024.  Russia’s  unprovoked  invasion  of  Ukraine  in  2022  continues  to  create  uncertainty  across  the 
nuclear fuel sector, including uranium mining, conversion, and enrichment, due to Russia’s control of a significant amount of 
global uranium capacity across these nuclear fuel sectors. According to World Nuclear News, Russia controls 14% of the global 
supply of U3O8, 27% of uranium conversion, and 39% of enrichment (WNN, May 5, 2022). Furthermore, it is the Company’s 
belief that nuclear utilities, particularly in the U.S. and Europe, are seeking to reduce or eliminate their reliance on Russia for 
their supply of uranium and nuclear fuel due to the potential effects of sanctions (including pending legislation in Congress to 
ban Russian uranium and nuclear fuel imports), transportation, public and investor relations and other concerns. According to 
data from TradeTech, during 2023, uranium enrichment prices rose from $110.00 per separative work unit (“SWU”) to $155.00 

23

per SWU (up 40%); uranium conversion prices rose from $40.00 per KgU to $46.00 per KgU (up 15%); and U3O8 prices rose 
from $47.60 per pound of U3O8 to $91.00 per pound of U3O8 (up 91%).

Uranium  is  not  traded  on  an  open  market  or  organized  commodity  exchange,  although  the  CME  Group  provides  financially 
settled  uranium  futures  contracts.  Typically,  buyers  and  sellers  negotiate  transactions  privately,  either  directly  or  through 
brokers and intermediaries. Spot uranium transactions typically involve deliveries that occur immediately and up to 12 months 
in the future. Term uranium transactions typically involve deliveries that occur more than 12 months in the future, with long-
term transactions involving delivery terms of at least three years. Uranium prices, both spot and term, are primarily published 
by two independent market consulting firms, TradeTech and UxC, LLC, on a weekly and monthly basis, along with daily price 
indicators.  Other  brokers,  including  Uranium  Markets  LLC,  Evolution  Markets  Inc.  and  Numerco  Ltd.,  also  publish  daily 
average uranium prices.

Historically, most nuclear utilities have sought to purchase a portion of their uranium needs through mid- and long-term supply 
contracts, while other portions are bought on the spot market. According to EIA data, in 2022, U.S. utilities purchased 15% of 
their uranium on the spot market with the remaining 85% purchased under mid- and long-term contracts; through 2032, U.S. 
utilities have approximately 179.2 million pounds of unfilled uranium requirements (EIA, Uranium Marketing Annual Report, 
2022). Buyers seek to balance the security of supply with the opportunity to take advantage of lower prices. For this reason, 
both buyers and sellers track current spot and term prices for uranium carefully, make considered projections as to future prices, 
and negotiate with one another on transactions which each deems favorable to their respective interests.

The graph, below, shows the monthly spot (blue line) and long-term (red line) uranium price from August 1969 up to January 
2024 as reported by TradeTech (not adjusted for inflation):

To give a more recent perspective over the last five years, the graph below shows the monthly spot (blue line) and long-term 
(red line) uranium price from January 2020 up to January 2024, as reported by TradeTech (not adjusted for inflation):

24

According to monthly price data from TradeTech, uranium prices during 2023 were up $43.40, or 91%, for the year. Monthly 
spot  prices  began  the  year  at  $47.60  per  pound  of  U3O8  on  December  31,  2022  and  ended  the  year  at  $91.00  per  pound  on 
December 31, 2023, reaching a high of $91.00 per pound for the month of December 2023 and a low of $47.60 per pound at the 
beginning of the period. According to TradeTech, the spot price was $102.00 per pound as of February 16, 2024. TradeTech 
price data also indicated that long-term U3O8 prices began 2023 at $53.00 per pound and ended 2023 at $68.00 per pound. The 
high long-term price for 2023 was $68.00 per pound in December 2023, and the low long-term price was $53.00 per pound for 
the months beginning with December 2022 through March 2023. The long-term price as of February 16, 2024 was $72.00 per 
pound.

According to TradeTech, U3O8 prices rose significantly in December 2023 due to:

“[T]he confluence of a number of factors that were building within the market. A combination of exceptional growth 
expectations for future nuclear power following the United Nations’ COP 28 climate conference in Dubai earlier [in 
December], along with a supply deficit set against the backdrop of growing geopolitical uncertainty, accelerated the 
rise in prices that characterized recent months.” TradeTech, The Nuclear Review – January 2024, January 31, 2024.

In  addition,  on  December  11,  2023,  the  U.S.  House  of  Representatives  passed  legislation  which  would  ban  the  import  of 
Russian  low-enriched  uranium,  or  “LEU.”  While  the  legislation  is  currently  stalled  in  the  U.S.  Senate,  “many  market 
participants [are] of the opinion that the Senate is likely to pass a ban similar to that passed in the House .… [and] most market 
participants believe it is a question of ‘when, not if’ regarding whether the Senate will take up the issue of the Russian ban on 
nuclear fuel in January. If this is the case, then it is very likely that sellers will respond by raising offer prices yet again.” As of 
the current time, the legislation remains stalled in the Senate.

It is the opinion of the Company that the Russian ban is likely to result in a further increase in uranium prices in the short term. 
However, there is significant uncertainty around the mechanisms and criteria for the U.S. government to grant waivers from the 
import ban, including how much Russian uranium will be allowed to be imported into the U.S. under waivers. Therefore, the 
market response to the Russian ban over the medium- to long-term is unknown at this time. In addition, because uranium is a 
global commodity, and Russia will continue to export uranium to other nations, including China, it is the Company’s belief that 
any price increase could be temporary and partially driven by speculation.

It is the Company’s belief that the price increase seen in early-February 2024 was driven by market fundamentals. On February 
1,  2024,  Kazatomprom,  the  state-owned  Kazakh  uranium  company  and  the  world’s  largest  uranium  producer,  stated  that  it’s 
2024 and 2025 production “will be about 20% below the amount stipulated in subsoil use agreements” (World Nuclear News, 
Kazatomprom confirms 2024 production plans as acid woes continue, February 1, 2024). In August 2022, Kazatomprom stated 
that “it planned to increase its 2024 uranium production to a 90% level relative to its subsoil use agreements”, versus 80% in 
2023.  But  that  plan  was  adjusted  “because  of  the  challenges  it  is  now  facing”,  primarily  acid  prices  and  availability,  with 
Kazatomprom  experiencing  a  33.6%  increase  in  the  cost  of  sulfuric  acid  in  2023.  Kazatomprom  further  stated  that 
“[p]roduction plans for 2025 could be ‘unfavourably’ influenced if access to sulfuric acid continues to be limited through 2024 
and delays in construction at Kazatomprom’s newly developed deposits are not reduced.” Resolution or a continuation of issues 
in Kazakhstan are likely to influence uranium market sentiment and price forecasts in the coming months.

25

As a result, the Company believes uranium prices are likely to continue to trend upward. This could be amplified by speculation 
surrounding the Russian uranium ban and other factors. However, the Company believes that there are risks to maintaining the 
currently  elevated  uranium  prices,  including  a  satisfactory  conclusion  to  the  Russia-Ukraine  conflict  causing  Russia’s  large 
nuclear fuel capacity to return to the global market, Kazatomprom resolving it’s production issues, and new uranium projects 
successfully coming online.

Uranium Market Outlook and Uranium Marketing Strategy

The Company believes that world demand for clean, carbon-free, reliable, and affordable baseload electricity is growing. As a 
result  of  the  expected  growth  of  nuclear  energy,  the  depletion  of  existing  uranium  mines  and  inventories,  and  geopolitical 
events putting a greater focus by buyers on security of supply, the Company believes the current- and long-term fundamentals 
of the uranium industry remain positive. Uranium spot prices rose sharply in 2023, due to several factors, including geopolitical 
factors,  improved  long-term  demand  forecasts,  depletion  of  existing  mines,  and  demand  by  financial  entities,  all  of  which 
created  significant  tightness  in  spot  markets.  However,  inflation,  employment  challenges  and  other  factors  are  increasing  the 
costs of uranium production. Therefore, the Company continues to believe that prices must remain at current levels or rise to 
higher levels to support the additional primary production that will be required to meet the increasing demand. We expect to see 
more nuclear units constructed around the world, while primary mine production drops due to depletion of resources, reduced 
production and low prices. According to TradeTech, world uranium requirements continue to exceed primary mine production, 
with the gap being bridged by dwindling secondary supplies and excess uranium inventories in various forms that have already 
been  mined.  At  the  same  time,  a  large  portion  of  global  uranium  production  remains  state-owned  and  state-subsidized,  and 
therefore not subject to normal market fundamentals, which the Company believes present risks to the current strong market. 
However, Russia’s invasion of Ukraine, and continued attacks on civilian populations, has increased demand for non-Russian 
uranium.  As  a  result,  uranium  prices  exhibited  strength  throughout  2023,  and  the  Company  has  observed  significantly  more 
interest in both spot transactions and long-term contracts for U3O8 from utilities. 

The Company believes that certain uranium supply and demand fundamentals point to sustained market strength and potentially 
higher prices in the future, including significant production cuts and/or shortfalls, and increased demand from utilities, financial 
entities,  traders,  and  producers.  However,  the  Company  also  believes  that  while  uranium  market  conditions  have  improved 
significantly since 2021, they still remain vulnerable, primarily as a result of secondary uranium supplies, excess inventories, 
and non-market activities of state-owned enterprises, primarily in Russia. While U.S. and European utilities are reducing their 
exposure to Russian supply, the Company believes that Russia maintains significant capabilities across the nuclear fuel cycle, 
which  could  re-enter  the  global  market  in  the  future  upon  resolution  of  the  conflict  in  Ukraine,  circumvention  of  trade 
restrictions, or other factors. As mentioned above, it remains to be seen whether Russia’s invasion of Ukraine will result in the 
U.S. and other western countries reducing Russian uranium supply over the long term, thereby increasing the demand for non-
Russian sources of uranium, which could benefit the U.S. uranium mining industry. 

The Company’s marketing strategy is to seek a base of earnings and cash flow through sales of a portion of its uranium into 
term contracts, to the extent such contracts are available at satisfactory prices. To gain exposure to increasing uranium prices, 
the Company seeks to sell a portion of its planned uranium extraction into contracts with market-related formulas, if available at 
satisfactory  prices,  and  through  future  spot  and  term  sales.  Further  exposure  to  increasing  uranium  prices  can  be  generated 
through  the  Company’s  ability  to  bring  additional  uranium  extraction  online  in  the  future  in  response  to  increasing  prices, 
which can be sold on a market-related or fixed basis at then prevailing prices.

During  2022,  the  Company  entered  into  three  long-term  uranium  sales  contracts  with  U.S.  nuclear  utilities.  Base  quantities 
under these contracts total 3.0 million pounds with deliveries to occur during the 2023 – 2030 time period. So far, the Company 
delivered 260,000 pounds of uranium under these contracts in 2023 and another 200,000 pounds so far in 2024. If the buyers 
exercise all remaining options, total delivery quantities could increase to as much as 3.6 million pounds. Annual quantities vary 
year-to-year, with lower delivery quantities in the early years, and higher quantities in the later years. Contract pricing has a 
fixed  price  component  (fully  indexed  to  inflation)  and  a  spot  market  component,  along  with  floor  and  ceiling  prices  (fully 
indexed  to  inflation).  The  Company  expects  to  fill  deliveries  during  the  early  years  of  these  contracts  from  its  significant 
existing produced inventories. The Company also entered into contracts to sell an additional 100,000 pounds of uranium on the 
spot market in Q1-2024 at a weighted average price of $102.88 per pound.

In addition, during Q4-2023, the Company completed the purchase of 100,000 pounds of U3O8 for a price of $81.00 per pound.

The Company’s uranium inventories, along with expected uranium production in 2024 and subsequent years, are expected to 
provide the Company with the flexibility to complete spot sales in 2024 in response to improved market conditions, should the 
Company  desire  to  do  so.  The  Company  will  also  continue  to  evaluate  the  potential  to  complete  opportunistic  purchases  of 
uranium during 2024.

26

The Rare Earth Element Market

REEs are a group of 17 chemical elements (the 15 elements in the lanthanum series, plus yttrium and scandium) that are used in 
a variety of clean energy and advanced technologies, including wind turbines, EVs, cell phones, computers, flat panel displays, 
advanced optics, catalysts, medicine and national defense applications. Monazite, the source of REEs currently utilized by the 
Company,  also  contains  significant  recoverable  quantities  of  uranium,  which  fuels  the  production  of  carbon-free  electricity 
using nuclear technology. According to industry analyst Wood-Mackenzie, most demand for REEs is in the form of separated 
REEs, “as most end-use applications require only one or two separated rare earth compounds or products.” (Wood Mackenzie, 
Rare  Earths,  Outlook  to  2030,  20th  Edition).  The  main  uses  for  REEs  include:  (i)  battery  alloys;  (ii)  catalysts;  (iii)  ceramics, 
pigments  and  glazes;  (iv)  glass  polishing  powders  and  additives;  (v)  metallurgy  and  alloys;  (vi)  permanent  magnets;  (vii) 
phosphors;  and  (viii)  others  (Adamas  Intelligence).  By  volume,  REEs  used  for  permanent  magnets  (neodymium  (Nd), 
praseodymium  (Pr),  dysprosium  (Dy),  and  terbium  (Tb))  and  catalysts  (cerium  (Ce)  and  lanthanum  (La))  comprised  60%  of 
total consumption, yet over 90% of the value consumed.

Typical natural monazite sands from the southeast U.S. average approximately 55% TREO and 0.20% uranium, which is the 
typical grade of uranium found in uranium mines that have historically fed the Mill. Of the 55% TREO typically found in the 
monazite sands, the NdPr comprises approximately 22% of the TREO. NdPr is among the most valuable of the REEs, as it is 
the key ingredient in the manufacture of high-strength permanent magnets, which are essential to the lightweight and powerful 
motors required in EVs and permanent magnet wind turbines used for renewable energy generation, as well as in an array of 
other  modern  technologies,  including  mobile  devices  and  defense  applications.  Monazite  concentrates  also  contains  higher 
concentrations  of  “heavy”  REEs,  including  dysprosium  (Dy)  and  terbium  (Tb)  used  in  permanent  magnets,  relative  to  other 
common REE ores. 

The Company is currently primarily focused on NdPr, Tb, Dy and, to a lesser extent, La, Ce and Sm. The REE supply chain 
starts at a mine. REEs are mined both as a primary target, like the Mountain Pass REE mine in California, and as a byproduct, 
which is the case of Chemours’ Offerman Mineral Sand Plant, where the natural monazite sands are physically separated from 
the other mined sands. Mining creates an ore, which in the case of the Chemours material is the natural monazite sands that are 
physically separated from the other mined mineral sands. The ore then goes through a process of cracking and cleaning at the 
Mill that may include acids or caustic solutions, elevated temperature and pressure to recover the uranium and free the REEs 
from  the  mineral  matrix.  After  removal  of  the  uranium,  which  will  be  sold  into  the  commercial  nuclear  fuel  cycle  for  the 
creation  of  carbon-free  nuclear  energy,  this  solution  is  cleaned  of  any  remaining  deleterious  elements  (including  remaining 
radioactive elements) and made into an RE Carbonate, which is a form acceptable as an SX feedstock for REE separation. SX 
facilities then use solvents and a series of mixer-settlers for the separation of the REEs in the RE Carbonate from each other and 
to create the desired purified REE products (often as oxides) for the market or particular end user. Separated REE products are 
typically  sold  to  various  markets,  depending  on  the  use.  Separated  REE  products  can  be  made  into  REE  metals  and  metal-
alloys, which are used for magnets and other applications.

To date, substantially all the RE Carbonate produced by the Mill has been sold to Neo. The Mill is currently modifying and 
enhancing its existing SX facilities to result in an SX REE separation circuit at the Mill, which, based on current engineering, is 
expected  to  be  capable  of  producing  up  to  1,000  tonnes  of  separated  NdPr  oxide  per  year.  The  Company  is  also  currently 
evaluating the potential to produce other downstream REE materials, including REE metals and alloys, in the future at the Mill 
or elsewhere in the U.S. 

REEs are commercially transacted in a number of forms and purities. Therefore, there is no single price for REEs collectively, 
but numerous prices for various REE compounds and materials. The primary value that the Company expects to generate in the 
short- to medium-term will come from NdPr, Dy, Tb, Ce, and La, as the price the Company receives from the sale of its RE 
Carbonate is tied to the prices of those REE oxides. In addition, the Company expects to produce separated REE oxides in the 
future,  commencing  with  NdPr  expected  in  2024.  The  following  table  sets  forth  certain  REE  compounds  and  materials  mid-
point prices in RMB¥/kg and their approximate value in USD$/kg, according to date from Asian Metal:

27

Product
NdPr Oxide
(Pr6O11: 25%;
Nd2O3): 75%)

Ce Oxide (99.9%)

La Oxide (99.9%)
Dy Oxide
Tb Oxide

December 31, 2022

December 31, 2023

(RMB¥/kg)

($/kg)

(RMB¥/kg)

($/kg)

Percent

Change

February 19, 2024

(RMB¥/kg)

($/kg)

710 

7.05

103  

445   

1.02

6.75

6.95
2,490 
14,000   

1.00
360  

2,022 

4.15
2,640   
7,600   

63 

0.96

0.59
374 
1,076 

 (37) %  

401   

 (4) %

6.55

 (40) %

 6 %  
 (46) %  

4.05
1,920   
5,650   

56 

0.92

0.57
270 
794 

The REE market is dominated by China, which produces approximately nearly 90% of refined REE products according to the 
International Energy Agency. According to Wood Mackenzie, “The rare earths industry continues to evolve under the energy 
transition. Decarbonisation of key sectors such as transport and increasing renewable energy generation is driving demand for 
rare  earth  permanent  magnets.  Global  supply  also  remains  strong  with  diversification  high  on  the  agenda  for  governments 
around the world. Prices for neodymium-praseodymium oxide were comparatively low for much of 2023. This was caused by 
adequate supply and sustained market uncertainty caused by challenging economic conditions, particularly within China. As we 
move into 2024, short term prices remain under pressure, though we expect market sentiment to improve.”

While China consumes the most REEs in its manufacturing industries, much of it is consumed in the manufacture of end-use 
goods for export and by non-Chinese companies operating within China. REE separation facilities are additionally located in 
Vietnam,  India,  as  well  as  Silmet  in  Estonia,  and  use  a  variety  of  feedstocks  and  sources  with  small-scale  or  experimental 
operational facilities located elsewhere (Russia included).

The Company sees its commercial production of RE Carbonate to date and its expected production of NdPr oxide in 2024 as the 
first  steps  in  an  effort  to  restore  the  REE  supply  chain  in  the  U.S.,  where  one  currently  does  not  exist.  Multiple  potential 
domestic sources of mined mineral sands, including monazite, exist in North America and are potential feedstocks for the Mill; 
in addition, there is one producer of REEs from hard rock mining in California, which currently ships its material to Asia. On a 
global  level,  there  is  a  potential  to  acquire  natural  monazite  sands  from  the  following  locations:  Australia,  South  Africa, 
Madagascar, New Zealand, the Philippines, Indonesia, Brazil, Malaysia, Thailand, India, Russia and others. 

As demand for clean energy technologies and other advanced technologies increases in the coming years, the Company expects 
demand and prices for REEs to increase. Increases in supply sources for REEs are expected in conjunction with this anticipated 
rising demand.

The Vanadium Market

Vanadium  is  a  metallic  element  that,  when  converted  into  ferrovanadium  (“FeV”)  (an  alloy  of  vanadium  and  iron),  is  used 
primarily as an additive to strengthen and harden steel and make it anti-corrosive. According to market consultant FastMarkets, 
over  90%  of  FeV  is  used  in  the  steel  industry.  In  addition,  vanadium  is  used  in  the  aerospace  and  chemical  industries,  and 
continues to see interest in energy storage technologies, including vanadium redox flow batteries. China is the largest global 
producer of vanadium, with additional production coming from Russia, South Africa and Brazil (Roskill). 

Vanadium markets have “shown steady declines over much of 2023,” according to reporting by Fastmarkets. The same report 
indicated that the, “end of the seasonal summer shutdown period failed to reignite end-user demand.” European ferro-vanadium 
prices at lowest since February 2021, September 25. A lower pricing environment persisted in late 2023 as one trader noted to 
Fastmarkets,  “the  reason  why  the  China  vanadium  pentoxide  exports  went  up  in  November  is  mainly  because  many  market 
participants feel the vanadium pentoxide price is at the bottom now, and they intended to stock some, which prompted more 
active spot deals.” China’s November vanadium pentoxide exports up 81.46% vs month prior; imports down 99.84%.

During the year ended December 31, 2023, the mid-point price of vanadium in Europe decreased by 31% from $9.44 per pound 
V2O5 as of December 31, 2022 to $6.53 per pound V2O5 as of December 31, 2023. The price of vanadium has ranged from a 
high of $10.80 per pound V2O5 between February 3, 2023 and February 16, 2023 and a low of $5.65 per pound V2O5 between 
December 1, 2023 and December 14, 2023. The Company believes one of the main drivers of V2O5 prices is demand for steel, 
including  global  prospects  for  economic  growth,  construction,  infrastructure  and  auto  manufacturing.  According  to 
Fastmarkets, “the continued decline in the Chinese vanadium pentoxide price comes amid fewer steel mill tenders in the run-up 
to the Lunar New Year holiday, as well as lower bids,” and “sluggish steel demand during the off-peak season has also weighed 

28

 
 
 
 
on China’s vanadium nitrogen prices.” Fastmarkets, China vanadium prices drop further on limited buying, January 25, 2024. 
The  Company  believes  that  V2O5  prices  will  increase  once  confidence  in  the  Chinese  and  global  economy  returns.  As  of 
February 16, 2024, the price of vanadium was $6.88 per pound V2O5.

As a result of strong vanadium markets during Q1-2023, the Company opportunistically sold 79,344 pounds of V2O5 (contained 
in FeV) at a weighted average price of $10.98 per pound. The Company expects to continue to sell vanadium from its inventory 
into  rising  markets  if  they  continue,  failing  which  the  Company  plans  to  maintain  its  vanadium  inventory  for  future  sales  at 
opportune times. The Company currently has 905,000 of pounds V2O5 in finished goods inventory and an estimated 1.0 to 3.0 
million pounds of V2O5 in its tailings solutions, which are available for future recovery, as market conditions warrant.

Competition

The uranium industry is highly competitive. The Company competes with mining and exploration companies for uranium sales, 
the acquisition of uranium mineral properties, and the procurement of equipment, materials and personnel necessary to explore, 
develop,  and  extract  uranium  from  such  properties.  There  is  competition  for  a  limited  number  of  uranium  acquisition 
opportunities, including competition with other companies having substantially greater financial resources, staff and facilities 
than  the  Company.  As  a  result,  the  Company  may  encounter  challenges  in  acquiring  attractive  properties,  and  exploring  and 
advancing  properties  currently  in  the  Company’s  portfolio.  In  addition,  Energy  Fuels  competes  with  other  uranium  recovery 
companies, along with traders, brokers, financial institutions, converters, enrichers, and other market actors, including some that 
are state-owned and state-subsidized, for uranium sales. Due to the Company’s limited capital, personnel and the relative size of 
its  operations,  the  Company  may  be  at  a  competitive  disadvantage  compared  to  some  other  companies  with  regard  to 
exploration  and,  if  warranted,  development  of  and  production  from  mining  properties  and  securing  uranium  sales.  The 
Company believes that competition for acquiring mineral prospects and completing uranium sales will continue to be intense in 
the future.

The REE industry is also highly competitive, particularly to the extent it is dominated by China, which produces nearly 90% of 
refined REE products according to the International Energy Agency. Chinese companies bid aggressively to acquire monazite 
and  other  minerals  to  feed  this  production.  The  Company  competes  with  Chinese  companies  and  companies  from  other 
countries  that  are  in  or  trying  to  break  into  the  REE  market,  for  sources  of  monazite  and  will  be  expected  to  compete  with 
Chinese  companies  and  companies  from  other  countries  as  they  develop  production  capacity  at  the  RE  Carbonate  crack  and 
leach, REE separation, REE metal and alloy making, REE magnet making, and REE product marketing and sales stages of the 
REE supply chain, as well as for the acquisition of monazite and other mineral properties, for mining and exploration on such 
properties, and for the procurement of equipment, materials and personnel necessary to explore, develop, and extract monazite 
from such properties. There is competition for a limited number of monazite acquisition opportunities, including competition 
with  other  companies  having  substantially  greater  financial  resources,  staff  and  facilities  than  the  Company.  As  a  result,  the 
Company may encounter challenges in acquiring attractive properties, and exploring and advancing properties currently in the 
Company’s portfolio. In addition, Energy Fuels will compete with other REE companies, along with traders, brokers, financial 
institutions, and other market actors, including some that are state-owned or state-supported or subsidized, for RE Carbonate 
and REE oxide sales. Due to the Company’s limited capital, personnel and the relative size of its operations, the Company may 
be  at  a  competitive  disadvantage  compared  to  some  other  companies  with  regard  to  the  acquisition,  exploration  and,  if 
warranted,  development  of  and  production  from  mining  properties,  production  of  REE  products  and  securing  REE  product 
sales. The Company believes that competition for acquiring monazite prospects, production of REE products and completing 
REE  product  sales  will  continue  to  be  intense  in  the  future.  To  the  extent  many  Chinese  companies  are  state-subsidized  or 
otherwise supported, the Company expects to continue to face tough competition in the REE space.

The availability of funds for the acquisition, exploration, evaluation, permitting and construction of monazite projects and the 
development of REE separation, metal and metal alloy making and magnet making is limited, and the Company may find it 
difficult to compete on an international scale with larger and more established and/or subsidized REE companies for capital. 
The Company’s inability to continue exploration, advancement, the acquisition of new properties, and the development of REE 
separation, metal and metal alloy making and magnet making, due to lack of funding, could have a material adverse effect on 
the Company’s future operations and financial position.

However, the Company believes it has a competitive advantage over many of its peers in the U.S. domestic uranium space and 
in the world REE space, outside of China, to the extent it has diversified business opportunities, including its ability to produce 
uranium, its ability to recover RE Carbonate, along with uranium, from monazite sand ores and its expected ability to produce 
separated REE oxides at the Mill in 2024, its ability to recover vanadium as market conditions may warrant, and its potential 
ability to recover certain radioisotopes for use in TAT medical therapeutics. 

29

Government Regulation

The  Company’s  properties  and  facilities  are  subject  to  extensive  laws  and  regulations  which  are  overseen  and  enforced  by 
multiple  federal,  state  and  local  authorities.  These  laws  govern  exploration,  construction,  extraction,  recovery,  processing, 
exports,  various  taxes,  labor  standards,  occupational  health  and  safety,  waste  disposal,  protection  and  remediation  of  the 
environment,  protection  of  endangered  and  protected  species,  toxic  and  hazardous  substances,  and  other  matters.  Uranium 
minerals exploration, extraction, recovery, and processing are also subject to risks and liabilities associated with the perceived 
potential for impacts to the environment and disposal of waste products occurring as a result of such activities.

Compliance with these laws and regulations may impose substantial costs on the Company and may subject the Company to 
significant potential liabilities. Changes in these regulations or changes in regulatory attitudes or interpretations could require 
the  Company  to  expend  significant  resources  to  comply  with  new  laws  or  regulations,  attitudes  or  interpretations  relating 
thereto,  or  changes  to  current  requirements  and  could  have  a  material  adverse  effect  on  the  Company’s  business  operations. 
However,  compliance  with  government  regulations  generally,  including  but  not  limited  to  environmental  regulations,  is  an 
integral part of the Company’s day-to-day business and impacts virtually all the Company’s capital expenditure and operating 
decisions at its facilities, as the Company’s facilities and operations must comply with this extensive array of environmental, 
health and safety laws and regulations. The costs of compliance with these laws and regulations are therefore well understood 
and assumed by the Company in all its capital budgeting decisions, project analyses and cost and earnings projections. As all 
the Company’s competitors in the uranium mining industry in the U.S. face the same or similar regulatory requirements, the 
Company  does  not  believe  its  need  to  comply  with  this  extensive  array  of  laws  and  regulations  materially  affects  the 
Company’s competitive position within the U.S. uranium mining industry.

As monazite is a uranium ore and is processed through the White Mesa Mill for the recovery of uranium and REEs, and all 
separation activities are expected to take place at the Mill, all the regulations applicable to uranium recovery and processing at 
the Mill apply to the processing of monazite at the Mill, the production of RE Carbonate and the planned separation of REE 
oxides at the Mill.

Environmental Regulations

Exploration,  development  and  extraction  activities  are  subject  to  environmental  regulations  which  may  prevent  or  delay  the 
continuance  of  our  activities.  In  general,  our  exploration,  evaluation  and  extraction  activities  are  subject  to  federal  and  state 
laws  and  regulations  relating  to  environmental  quality  and  pollution  control.  Such  laws  and  regulations  increase  the  costs  of 
these activities and may prevent or delay the commencement or continuance of a given operation. Specifically, we are subject to 
legislation  regarding  emissions  into  the  environment,  water  discharges,  and  storage  and  disposition  of  hazardous  wastes.  In 
addition,  legislation  has  been  enacted  which  requires  facility  sites  to  be  reclaimed  in  accordance  with  such  legislation. 
Compliance  with  these  laws  and  regulations  has  not  had  a  material  effect  on  our  operations  or  financial  condition  to  date, 
compared to industry norms.

Uranium milling in the U.S. is primarily regulated by the United States Nuclear Regulatory Commission (the “NRC”) pursuant 
to the Atomic Energy Act of 1954, as amended. Its primary function is to ensure the protection of employees, the public, and the 
environment  from  radioactive  materials,  and  it  also  regulates  most  aspects  of  the  uranium  recovery  process.  The  NRC 
regulations pertaining to uranium recovery facilities are codified in Title 10 of the Code of Federal Regulations.

On  August  16,  2004,  the  State  of  Utah  became  an  Agreement  State  for  the  regulation  of  uranium  mills.  This  means  that  the 
primary regulator for the Mill is now the State of Utah Department of Environmental Quality (“UDEQ”) rather than the NRC. 
At that time, the Mill’s NRC Source Material License was transferred to the State of Utah and became Radioactive Materials 
License Number UT 1900479 (the “Radioactive Materials License”), which was renewed in January 2018 as Amendment #8 
(Renewal),  then  reissued  as  a  Revised  Renewal  on  February  16,  2018,  by  UDEQ’s  Division  of  Waste  Management  and 
Radiation  Control  (“DWMRC”).  The  Radioactive  Materials  License  is  up  for  renewal  in  February  2028.  The  State  of  Utah 
incorporates, through its own regulations or by reference, all aspects of Title 10 pertaining to uranium recovery facilities. When 
the State of Utah became an Agreement State, it required that a Groundwater Discharge Permit (“GWDP”) be put in place for 
the Mill. The GWDP is required for all similar facilities in the State of Utah, and specifically tailors the implementation of the 
state  groundwater  regulations  to  the  Mill  site.  The  State  of  Utah  requires  that  every  operating  uranium  mill  have  a  GWDP, 
regardless of whether the facility discharges to groundwater. The GWDP for the Mill was finalized and implemented in March 
2005, then renewed in January 2018. Most recently, the GWDP renewal application was submitted in July 2022 and remains 
under consideration with DWMRC. The Mill also maintains a permit approval for air emissions with the UDEQ, Division of 
Air Quality. 

30

Conventional  uranium  extraction  is  subject  to  regulation  by  a  number  of  agencies  including:  (1)  local  county  and  municipal 
government  agencies;  (2)  the  applicable  state  divisions  responsible  for  mining  and  protecting  the  environment  within  Utah, 
Colorado, Arizona, New Mexico, and Wyoming; (3) the U.S. Bureau of Land Management (the “BLM”) and the United States 
Forest  Service  (the  “USFS”)  on  public  lands  under  their  jurisdiction;  (4)  the  U.S.  Mine  Safety  and  Health  Administration 
(“MSHA”); (5) the United States Environmental Protection Agency (the “EPA”) for radon emissions from underground mines; 
and (6) other federal agencies, including without limitation the U.S. Fish and Wildlife Service, U.S. Army Corps of Engineers 
(“USACE”)  and  the  DOE,  where  certain  conditions  exist.  In  addition,  a  uranium  processing  facility  at  the  Sheep  Mountain 
Project, if and when constructed, will be subject to regulation under the State of Wyoming, as an NRC Agreement State, as a 
uranium processing facility and for permanent disposal of the resulting tailings.

The  provisions  of  the  Atomic  Energy  Act  and  its  regulations  that  are  applicable  to  uranium  milling  also  apply  to  our  ISR 
facilities in Wyoming. The Nichols Ranch Project has a Source Material License. The Nichols Ranch Source Material License 
was originally issued by the NRC; however, the State of Wyoming became an NRC Agreement State on September 30, 2018 
and the Wyoming Department of Environmental Quality (“WDEQ”) - Land Quality Division (“WDEQ-LQD”) subsequently 
assumed all management and oversight functions. The Nichols Ranch Source Material License was issued most recently by the 
NRC on March 22, 2017 as Amendment No. 5, which is currently in timely renewal with WDEQ-LQD. Nichols Ranch is also 
regulated by the State of Wyoming and the EPA under the Clean Water Act, the Clean Air Act and the Resource Conservation 
and  Recovery  Act.  In  addition,  ISR  wellfields  require  an  Underground  Injection  Control  (“UIC”)  Permit  under  the  Safe 
Drinking  Water  Act,  as  administered  by  the  State  and/or  EPA.  ISR  operations  are  subject  to  regulations  by  the  U.S. 
Occupational, Safety and Health Administration, rather than MSHA.

Because monazite sands are a naturally occurring uranium ore, which also contain REEs, monazite sands are processed at the 
Mill under the Mill's existing Radioactive Materials License, GWDP and other permits as a uranium ore, and the resulting RE 
Carbonate and separated REE oxides are also recovered under those existing licenses and permits. The Company is evaluating 
whether  any  additional  licenses  or  permits  or  amendments  to  existing  licenses  or  permits  may  be  required  for  any  of  the 
modifications and enhancements to existing Mill facilities required for and the operation of its planned REE separation circuits 
at the Mill.

The Company currently has a Research and Development (“R&D”) license for the recovery of R&D quantities of Ra-226 at the 
Mill, issued by DWMRC in 2023. It is expected that the potential recovery and concentration of R&D quantities of Th-232, 
Ra-228 and/or Th-228 will also require similar R&D licenses or amendments to the existing Ra-226 R&D license and that the 
potential recovery and concentration of commercial quantities of Th-232, Ra-228, Th-228 and/or Ra-226 will require additional 
licensing by DWMRC at the Mill.

Reclamation bonds or the equivalent have been posted for each of the Company’s material properties that have structures or 
facilities.  Energy  Fuels  is  required  to  have  export  licenses  issued  by  the  NRC  for  its  uranium  exports,  unless  otherwise 
permissible  pursuant  to  the  Mill’s  existing  Radioactive  Materials  License  due  to  the  nature  of  the  material  in  question.  Such 
licenses are obtained by the Company as required.

Land Tenure

U.S. Land Tenure

The Company’s land holdings in the U.S. are held either by leases from the fee simple owners (private parties or the State) or 
unpatented mining claims located on property owned and managed by the U.S. Federal Government. Annual fees must be paid 
to  maintain  unpatented  mining  claims,  but  work  expenditures  are  not  required.  Holders  of  unpatented  mining  claims  are 
generally granted surface access to conduct mineral exploration and extraction activities. However, additional permits and plans 
are generally required prior to conducting exploration or mining activities on such claims.

On  July  9,  2009,  BLM  issued  a  Notice  of  Proposed  Withdrawal  (“2009  Notice”)  under  which  it  proposed  that  a  total  of 
approximately one million acres of public lands around the Grand Canyon National Park be withdrawn from location and entry 
under the Mining Law of 1872 (the “Mining Law”), subject to valid existing rights. In the 2009 Notice, BLM stated that the 
purpose of the withdrawal, if determined to be appropriate, would be to protect the Grand Canyon watershed from any adverse 
effects  of  locatable  hardrock  mineral  exploration  and  mining.  The  2009  Notice  segregated  the  lands  from  location  and  entry 
under  the  mining  laws  for  up  to  two  years  to  allow  time  for  various  studies  and  analyses,  including  appropriate  National 
Environmental Policy Act (“NEPA”) analysis. In order to allow more time for BLM to complete its NEPA analysis, the U.S. 
Department  of  the  Interior  (the  “DOI”)  published  Public  Land  Order  7773  on  June  21,  2011,  which  effected  a  six-month 
emergency withdrawal of the area. The emergency withdrawal prevented the lands from being open to location and entry under 
the  Mining  Law  upon  expiration  of  the  two-year  segregation  while  the  DOI  completed  the  decision–making  process  on  the 

31

proposed withdrawal. The emergency withdrawal was effective from July 21, 2011 to January 20, 2012. During the two-year 
segregation and six-month emergency withdrawal, the BLM, along with its cooperating agencies, completed various studies and 
analyses of resources in the withdrawal area, including an Environmental Impact Statement (“EIS”) under NEPA. These studies 
and  analyses  were  undertaken  to  provide  the  basis  for  the  final  decision  regarding  whether  to  proceed  with  the  proposed 
withdrawal or to select an alternative action. Based on this analysis, on January 9, 2012, the DOI announced its final decision to 
withdraw from location and entry under the Mining Law, subject to valid existing rights, the total of approximately one million 
acres of lands originally proposed in the 2009 Notice (the “Withdrawn Lands”), for a 20-year period. Lawsuits challenging 
this decision were filed by various industry groups and interested parties. In addition, legislation has been proposed in both the 
U.S. House of Representatives and U.S. Senate, which would make the withdrawal permanent, subject to preexisting rights. The 
Company will continue to track the progress of this and any other relevant legislation. 

Then,  on  August  8,  2023,  President  Biden  designated  the  Baaj  Nwaavjo  I’tah  Kukveni  –  Ancestral  Footprints  of  the  Grand 
Canyon  National  Monument,  which  comprised  approximately  one  million  acres  of  previously  Withdrawn  Lands  in  three 
distinct areas to the south, northeast and northwest of Grand Canyon National Park. As stated in the fact sheet for the national 
monument  designation,  “The  national  monument  designation  recognizes  and  respects  valid  existing  rights.  The  proclamation 
specifies that maintenance and upgrades to water infrastructure for flood control, utilities, water district facilities, wildlife water 
catchments,  and  other  similar  uses  may  continue;  and  that  utility  lines,  pipelines,  and  roads  can  continue  to  be  maintained, 
upgraded, and built consistent with proper care and management of the monument objects. Existing mining claims – predating a 
20-year  mineral  withdraw  initiated  in  2012  –  will  remain  in  place,  and  the  two  approved  mining  operations  within  the 
boundaries of the monument would be able to operate.” 

As a result of the 2009 withdrawal from location and entry and the 2023 national monument designation, no new mining claims 
may be staked on the Withdrawn Lands or within the boundaries of the national monument, and no new Plans of Operations 
may be approved, other than Plans of Operations on mining claims that were valid at the time of the segregation, withdrawal or 
national  monument  designation,  as  applicable,  and  that  remain  valid  at  the  time  of  plan  approval.  Case  law  indicates  that  a 
miner establishes valid Congressionally provided rights under the Mining Law through certain unilateral acts, and that such acts 
are  presumptively  recognized  as  valid  claims  in  which  the  holder  has  valid  existing  rights  unless  and  until  the  DOI  or  U.S. 
Federal Courts declare otherwise. However, the BLM and USFS, each at their discretion, may perform a mineral examination 
and  Mineral  Report,  which  involves  an  economic  evaluation  of  a  project,  in  order  to  reflect  an  agency’s  belief  about  certain 
mining claims that may be used in support of a future mining claim contest on the validity of existing rights. All the Company’s 
properties located on the Arizona Strip, with the exception of its Wate property and certain exploration properties held by the 
Company’s  subsidiary,  Arizona  Strip  Partners  LLC,  are  located  within  the  Withdrawn  Lands  and  boundaries  of  the  Grand 
Canyon  National  Monument.  A  mineral  examination  on  the  Company’s  EZ  Project  will  need  to  be  completed  by  BLM,  in 
conjunction  with  its  review  of  the  Company’s  proposed  Plan  of  Operations  for  that  project.  Mineral  examinations  were  not 
required  for  the  Company’s  Arizona  1  and  Pinenut  projects,  which  had  previously  approved  Plans  of  Operations  and  were 
previously  active.  Although  the  Company’s  Pinyon  Plain  Project  also  has  an  approved  Plan  of  Operations,  and  a  mineral 
examination is not required, the USFS voluntarily performed a mineral examination on that project in 2012 in order to clarify 
the  agency’s  own  position  on  the  underlying  claims  and  concluded  that  the  Pinyon  Plain  Project’s  claims  constituted  valid 
existing rights (“VERs”). The USFS also concluded that no additional approvals were required on the Pinyon Plain Project that 
would trigger any further NEPA analysis as a major federal action.

The  Company  believes  that  all  its  material  projects  within  the  Withdrawn  Lands  and  boundaries  of  Grand  Canyon  National 
Monument are on valid mining claims that will withstand a mineral examination. However, market conditions may postpone or 
prevent  the  performance  of  mineral  examinations  on  certain  properties  and,  if  a  mineral  examination  is  performed  on  a 
property,  there  can  be  no  guarantee  that  the  mineral  examination  would  not  result  in  one  of  more  of  the  Company’s  mining 
claims being deemed invalid and/or that ongoing litigation challenging the validity of a VER determination would not result in 
the overturn of such determination, either of which could prevent a project from proceeding.

Former President Obama additionally designated the Bears Ears National Monument by executive order in December of 2016, 
which comprised 1.35 million acres of land in San Juan County, Utah. The designated land included a portion of County Road 
258, which the Company formerly relied on for access to its formerly owned Daneros Project (for which it currently acts as 
Operator  on  behalf  of  successor-in-interest  Consolidated  Uranium  Inc.,  see  “Part  II,  Item  8.  Financial  Statements  and 
Supplementary Data - Note 17 Related Party Transactions”), and a property boundary that abutted the boundary of the Mill and 
encompassed two water sampling sites the Company monitors for the Mill. In December 2017, former President Trump issued a 
Proclamation  that  amended  former  President  Obama’s  2016  Proclamation  and  reduced  the  monument  to  two  parcels 
encompassing a total of 201,876 acres, releasing 1.15 million acres. That Proclamation was later challenged in Federal Court. 
On  December  23,  2017,  the  Company  issued  a  press  release  reiterating  its  past  and  present  support  of  Bears  Ears  National 
Monument,  and  clarifying  that  the  Company  sought  only  minor  adjustments  to  the  original  boundaries  of  the  monument  to 
prevent the boundary from directly abutting some of its existing operations, which were very minor adjustments, insignificant 

32

compared to the original size of the monument and not a reflection of former President Trump’s nearly 85% reduction. Then, on 
October 8, 2021, President Biden issued a new proclamation restoring the original borders of Bears Ears National Monument, 
which  consists  “of  those  lands  reserved  as  part  of  the  Bears  Ears  National  Monument  as  of  December  3,  2017,  and  the 
approximately  11,200  acres  added  by  Proclamation  9681,  encompassing  approximately  1.36  million  acres.”  In  doing  so,  all 
such lands and interests contained within the monument were “appropriated and withdrawn from all forms of entry, location, 
selection, sale, or other disposition under the public land laws or laws applicable to the USFS, from location, entry, and patent 
under the mining laws, and from disposition under all laws relating to mineral and geothermal leasing, other than by exchange 
that  furthers  the  protective  purposes  of  the  monument”  (see  “A  Proclamation  on  Bears  Ears  National  Monument,”  dated 
October 8, 2021). As a result, it is possible that the Mill could become subject to additional requirements, restrictions and costs 
if the reversion to the original designation is upheld in Court, pending any legal challenges by the State of Utah or otherwise.

Brazilian Land Tenure

Mineral tenure is guaranteed by the Federal Constitution in Brazil. Mineral resources are separate from the surface owners (i.e. 
split estate), and the Republic of Brazil is the owner of all mineral resources. The federal government can grant mineral rights 
for  exploration  and  production  to  Brazilian  companies  (or  foreign  companies  with  established  Brazilian  entities).  Brazilian 
entities  that  are  granted  mining  rights  have  the  ownership  of  the  product  they  are  mining.  Mineral  rights  can  be  assigned, 
transferred or subject to encumbrance, provided that legal requirements are fulfilled and that the transaction is registered with 
and approved by the Brazilian National Mining Agency (“ANM”).

Mineral rights do not grant the land where the mineral deposits are located, but do provide the possibility of creating a mineral 
easement that allows holders of the mineral rights the ability to explore or mine the mineral and take ownership of the product. 
This right of access also includes neighboring lands, as long as ANM recognizes that such lands are needed for exploration and 
production. The surface owners are entitled to a royalty and damages caused by exploration, mining and ancillary activities. A 
maximum royalty is set at half the federal government royalty. If the company and the surface owner are unable to reach an 
agreement the matter will be settled by the local court based on criteria provided in applicable laws.

The granting of mineral rights in Brazil is performed in four steps:

1. Exploration Authorization: A 1-3 year authorization that is renewable for an additional 1-3 years. Exceptions can be 
made for additional renewals following the first authorization. The purpose of this authorization is to allow a company 
to explore for a mineral of interest. The company must then submit an exploration report to ANM. ANM will approve 
or  deny  the  report  based  on  the  economic  and  technical  feasibility  of  exploiting  the  mineral  explored  for  under  the 
report. 

2. Right to Request a Mining Concession: Following approval of the exploration report the company has 1 year to apply 
for a mining concession. This request period can be renewed, upon request and justification, based on ANM’s criteria. 
If ANM does not agree with the justification, ANM may request the holder of the mineral right to proceed with the 
request  for  a  mining  concession  stage.  Eventually,  ANM  can  forfeit  the  request  right  if  there  is  clear  and  strong 
evidence of procrastination. 

3. Mining  Concession  Request:  The  request  for  a  mining  concession  has  to  include  a  mine  development  plan. 
Furthermore,  the  mining  concession  will  only  be  granted  once  an  environmental  construction  permit  is  obtained. 
Extensions  can  be  granted  if  the  environmental  permitting  process  is  delayed.  The  holder  must  use  best  efforts  to 
obtain the environmental permit and report to ANM. Eventually, ANM can deny the request if there is clear and strong 
evidence of procrastination. 

4. Mining Concession: This is the approval to mine. Once this is granted the company has six months to start mining and 

is required to provide an annual report to ANM. The mining concession is valid for the life of the mine.

Environmental and Social Efforts and Impacts

Uranium is the fuel for carbon-free, emission-free baseload nuclear power and is a key factor in successfully combating global 
climate  change.  In  addition  to  producing  uranium  from  our  mines,  we  recycle  other  companies’  uranium-bearing  tailings  or 
wastes  (Alternate  Feed  Materials)  at  the  Mill  for  the  extraction  of  uranium  that  would  otherwise  have  been  permanently 
disposed of, thereby reducing the need for new mining by maximizing extraction of existing sources and limiting the number of 
constituents  ultimately  disposed  of.  We  also  recover  previously  disposed  of  uranium  and  vanadium  by  recycling  the  Mill’s 
tailings  solutions.  Furthermore,  our  production  of  a  commercially  salable  RE  Carbonate  through  the  recycling  of  natural 
monazite  sands,  which  have  historically  been  considered  wastes  due  to  their  radioactive  content,  and  our  planned  REE 

33

separation  activities,  allow  us  to  provide  crucial  links  in  a  commercially  viable  U.S.  REE  supply  chain  for  use  in  key  green 
energy technologies, such as solar panels, wind turbines, and electric and hybrid car batteries. In addition, our program for the 
potential recovery of radioisotopes for use in the production of TAT therapeutics for cancer treatments involves recycling the 
Mill’s  existing  process  streams  for  the  recovery  of  valuable  radioisotopes  that  have  traditionally  been  considered  wastes  and 
have been permanently disposed of.

Through  these  operations  and  initiatives,  we  remain  diligent  in  our  efforts  to  ensure  our  operations  minimize  any  impacts  to 
public health, safety and the environment, including any impacts to water, air, wildlife, soil, cultural resources, the occupational 
health and safety of our workers and any impacts to members of the public. Our Environment, Health, Safety and Sustainability 
(“EHSS”)  Committee  has  been  delegated  authority  by  the  Board  to  monitor  and  guide  the  Company  in  developing  and 
implementing its core EHSS principles, including maintaining radiation exposures not only within regulatory limits but as low 
as reasonably achievable through an extensive internal audit program, as well as authority for monitoring programs to identify 
and  mitigate  risks  in  ensuring  the  highest  standards  of  environmental  protection  and  human  health  and  safety  across  the 
Company’s  operations.  The  EHSS  Committee  also  monitors  the  Company’s  sustainability  programs,  including  its  efforts  to 
pro-actively  evaluate  its  programs  and  activities  to  ensure  they  meet  the  Company’s  sustainability  goals  and  objectives.  Our 
Sustainability Report, which was first released in 2020 and is in the process of being updated, is available on the Company’s 
website at www.energyfuels.com.

Our operations are located primarily in rural and underserved areas and support the local economies, not only through the taxes 
we pay to local authorities and the salaries and wages we pay to our employees and to numerous third-party contractors, such as 
transportation  companies,  equipment  rental  companies,  equipment  vendors  and  service  providers,  but  also  indirectly  through 
the “multiplier effect” to the communities as a whole. That is, the money we pay directly to our employees, contractors, vendors 
and  providers  is  spent  by  them  in  the  communities,  thereby  providing  income  to  local  businesses  and  wages  and  salaries  to 
employees  and  owners  of  those  business,  who  in  turn  spend  their  income,  salaries  and  wages  on  other  businesses  in  the 
community. Indeed, as the largest private employer in San Juan County, Utah, the Mill is a very significant factor in the local 
economy.

In furtherance of our sustainability objectives, the Company’s Foundation contributes to the communities surrounding the Mill 
in  Southeastern,  Utah  by  providing  funding  to  support  local  priorities.  The  Foundation  focuses  on  supporting  education,  the 
environment, health/wellness, and local economic development in the City of Blanding, San Juan County, Indigenous and other 
area communities. See “San Juan County Clean Energy Foundation.”

Employees

As  of  the  date  of  this  Annual  Report,  the  Company  and  its  subsidiaries  have  approximately  147  full-time  employees, 
substantially  all  of  whom  are  employed  through  the  Company’s  wholly  owned,  indirectly  held  subsidiary  Energy  Fuels 
Resources  (USA)  Inc.  We  operate  in  established  mining  areas  where  we  have  found  sufficient  available  personnel  for  our 
business plans.

Energy  Fuels  is  an  equal  opportunity  employer  and  is  committed  to  making  employment  decisions  based  on  valid  job 
requirements,  without  regard  to  race,  color,  national  origin,  gender,  religion,  age,  sex,  sexual  orientation,  gender  identity  or 
gender  expression,  disability,  veteran  status  or  any  other  legally  protected  status.  The  Company  also  provides  reasonable 
accommodation  for  qualified  individuals  with  known  disabilities  and  employees  whose  work  requirements  interfere  with  a 
religious belief unless doing so would result in an undue hardship to the Company or cause a direct threat to health or safety.

The  Company  actively  engages  with  its  Board  of  Directors  (the  “Board”)  to  continually  make  improvements  to  diversity 
through inclusion. Pursuant to the Company’s Diversity Policy, Energy Fuels’ Governance and Nominating Committee (“GN 
Committee”) is required to monitor, on an ongoing basis, the implementation and effectiveness of the Diversity Policy and to, 
at least annually, assess: (i) the mix of diversity, skill and expertise on the Board and the Executive Team, (ii) the measurable 
objectives set pursuant to the Policy, and (iii) progress in achieving such measurable objectives, including any targets, if set. As 
a  part  of  its  annual  assessment,  the  GN  Committee  reviews  its  Diversity  Policy  for  relevance  and  effectiveness,  any  new 
shareholder  advisory  guidelines,  TSX  and  NYSE  American  company  guides  and  any  changes  to  legal  requirements,  and 
provides to the Company’s Board its Annual Report with recommendations to improve and sustain diversity at the executive 
and Board levels. Most recently, in January 2024, the GN Committee recommended to the Board, and the Board approved and 
adopted, a number of diversity-based recommendations that include maintaining its measurable objectives of having, at current 
Board size, a qualified Board that is at least 30% gender diverse (including a minimum of one woman) at all times with at least 
one qualified racially or ethnically diverse director on the Board at all times. See the Company’s Proxy Statement on Schedule 
14A, filed April 4, 2023, for our most recent disclosure on Energy Fuels’ diversity statistics. 

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Available Information

Detailed information about Energy Fuels is, and will continue to be, included in our annual reports on Form 10-K, our quarterly 
reports on Form 10-Q, current reports on Form 8-K, proxy statements on Schedules 14A and other reports, and amendments to 
those reports that we file with or furnish to the SEC and, for Canadian purposes, the Ontario Securities Commission (“OSC”). 
The Company is a U.S. domestic issuer for SEC reporting purposes, most of its shareholders are U.S. residents, the Company is 
required to report its financial results under U.S. GAAP and its primary trading market is the NYSE American. However, prior 
to January 1, 2016, we were a foreign private issuer subject to limited periodic disclosure and current reporting requirements of 
the U.S. Securities Exchange Act of 1934, as amended (the “Exchange Act”), so we did not file Forms 10-K or 10-Q prior to 
January 2016. All such Forms 10-K, 10-Q and 8-K, including any amendments to such reports, filed after January 1, 2016 are 
available  free  of  charge  on  our  website,  www.energyfuels.com,  as  soon  as  reasonably  practicable  after  we  electronically  file 
such reports with, or furnish such reports to, the SEC. However, our website and any contents thereof should not be considered 
to  be  incorporated  by  reference  into  this  Annual  Report.  In  addition,  all  public  filings,  including  Insider  Reports,  of  the 
Company  can  be  found  on  the  SEC’s  Electronic  Data  Gathering,  Analysis,  and  Retrieval  (“EDGAR”)  platform,  and  on  the 
OSC’s System for Electronic Document Analysis and Retrieval (“SEDAR”) and System of Electronic Disclosure by Insiders 
(“SEDI”). We will furnish copies of such reports free of charge upon written request to our Investor Relations department. You 
can contact our Investor Relations department at:

Energy Fuels Inc.
225 Union Blvd., Suite 600
Lakewood, Colorado, 80228
Tel: 303.974.2140
Fax: 303.974.2141
Toll Free: 1.888.864.2125
E-mail: investorinfo@energyfuels.com 

Additionally,  our  Articles  of  Incorporation  and  By-laws,  Charters  of  the  Audit,  Compensation,  GN  and  EHSS  Committees, 
Sustainability Report, and the majority of our Company policies, are available on our website. We will furnish copies of such 
information free of charge upon written request to our Investor Relations department.

35

ITEM 1A. RISK FACTORS

The following information pertains to the outlook and conditions currently known to Energy Fuels that could have a material 
impact on its financial condition. Other factors may arise in the future that are currently not foreseen by management of Energy 
Fuels that may present additional risks, including risks that the Company currently feels are immaterial. Current and prospective 
shareholders of Energy Fuels should carefully consider these risk factors when making investment decisions.

Our failure to successfully address any of the risks and uncertainties described below could have a material adverse effect on 
our  business,  financial  condition  and/or  results  of  operations,  and  the  trading  price  of  our  Common  Shares  may  fluctuate 
widely. We cannot assure you that we have or will successfully or fully address these risks or other unknown risks that may 
affect our business.

Risks Related to our Industry

We are subject to the risks normally encountered by companies in the mineral extraction industry.

We are subject to the risks normally encountered by companies in the mineral extraction industry, such as:

•
•
•
•
•
•
•
•

the discovery of unusual or unexpected geological formations;
accidental fires, floods, earthquakes, volcanic eruptions and other natural disasters;
unplanned power outages and water shortages;
controlling water and other similar mining hazards;
operating labor disruptions and labor disputes;
the ability to obtain suitable or adequate machinery, equipment or labor;
our liability for potential pollution or other hazards; and
other  known  and  unknown  risks  involved  in  the  conduct  of  exploration,  development  and  operation  of  mines, 
extraction  and  recovery  facilities  and  mills,  along  with  the  markets  for  uranium,  rare  earths,  vanadium  and  heavy 
mineral sands.

The  development  of  mineral  properties  is  affected  by  many  factors,  including,  but  not  limited  to:  the  cost  of  operations; 
variations  in  the  grade  of  mineralized  material;  fluctuations  in  metal  markets;  costs  of  extraction  and  processing  equipment; 
availability of equipment and labor; labor costs and possible labor strikes; government regulations, including without limitation, 
regulations relating to taxes, royalties, allowable extraction or production, and importing and exporting of minerals; government 
actions,  including  without  limitation  the  establishment  or  expansion  of  mineral  withdrawals,  parks  and  monuments;  land 
exchanges; foreign exchange; employment; worker safety; transportation; and environmental protection.

Our  results  of  operations  are  significantly  affected  by  the  market  prices  of  uranium,  vanadium,  rare  earth  elements  and 
heavy mineral sands, which are cyclical and subject to substantial price fluctuations.

Our earnings and operating cash flow are and will be particularly sensitive to the long- and short-term changes in the market 
prices of uranium, vanadium and REEs, as well as heavy mineral sands and their components, including the prices for ilmenite, 
rutile, titanium and zircon, which could impact planned production levels or the feasibility of production of HMC and monazite 
from  our  Bahia  Project  and  any  other  HMS  projects  and  which  could  impact  monazite  supply  for  our  RE  Carbonate  and 
planned  REE  oxide  production.  Among  other  factors,  these  prices  also  affect  the  value  of  our  resources,  reserves  and 
inventories, as well as the market price of our Common Shares.

Market  prices  are  affected  by  numerous  factors  beyond  our  control.  With  respect  to  uranium,  such  factors  include,  among 
others:  demand  for  nuclear  power;  political  and  economic  conditions  in  uranium  producing  and  consuming  countries;  public 
and political response to a nuclear incident or fear of a nuclear incident; reprocessing of used reactor fuel, the re-enrichment of 
depleted  uranium  tails  and  the  enricher  practice  of  underfeeding;  sales  of  excess  civilian  and  military  inventories  (including 
from the dismantling of nuclear weapons; the premature decommissioning of nuclear power plants; and from the build-up of 
Japanese utility uranium inventories as a result of the Fukushima incident) by governments and industry participants; uranium 
supply, including the supply from other secondary sources; production levels and costs of production, and government actions 
such as, for instance, any plans included in President Biden’s 2024 fiscal budget and those taken pursuant to the U.S. Uranium 
Reserve Program. With respect to vanadium, such factors include, among others: demand for steel; the potential for vanadium 
to  be  used  in  advanced  battery  technologies;  political  and  economic  conditions  in  vanadium  producing  and  consuming 
countries; world production levels; and costs of production. With respect to REEs, such factors include, among others: demand 
for  REEs;  political  and  economic  conditions  in  REE  producing  and  consuming  countries;  REE-bearing  ore  supply  from 
secondary  sources;  international  interest  in  the  purchase  of  RE  Carbonate  and  separated  REE  oxides,  absent  a  U.S.-based 
separation  facility;  public  and  political  response  to  REE  initiatives  at  the  Mill;  governmental  investment  in  domestic  REE 

36

infrastructure; world production levels; costs of production; risks associated with foreign governmental actions, policies, laws, 
rules, regulations and foreign state subsidized enterprises, with respect to REE production and sales, which could impact REE 
prices available to the Company and impact our access to world and domestic markets for the supply of REE-bearing ores and 
the  sale  of  RE  Carbonate,  REE  oxides,  and  other  REE  products  and  services  to  world  and  domestic  markets;  and  other 
government actions, including licensing and import requirements. With respect to HMC and its components including the prices 
for  ilmenite,  rutile,  titanium  and  zircon,  such  factors  include,  among  others:  demand  for  titanium  and  zircon;  political  and 
economic  conditions  in  HMC  producing  and  consuming  countries;  other  government  actions,  including  licensing  and  import 
requirements;  geopolitical  factors;  world  production  levels;  exploration,  mining,  processing,  refining  and  other  costs  of 
production;  grades  of  HMC  supplies;  scale  of  mining  method;  growth  in  end-use  demand  of  titanium  and  zircon,  including 
GDP  growth  in  consuming  countries;  available  mineable  deposits  and  upgrading  facilities;  currency  fluctuations;  and  other 
market demand and supply dynamics.

Other factors relating to the prices of uranium, vanadium, REEs and HMC include: levels of supply and demand for a broad 
range  of  industrial  products;  substitution  of  new  or  different  products  in  critical  applications  for  our  existing  products; 
expectations with respect to the rate of inflation; the relative strength of the U.S. dollar and of certain other currencies; interest 
rates; global or regional political or economic crises; regional and global economic conditions; and sales of uranium, vanadium, 
RE Carbonate, REE oxides and other REE products and services, and HMC by holders in response to such factors. If prices are 
below our cash costs of extraction or recovery and remain at such levels for any sustained period, we may determine that it is 
not  economically  feasible  to  continue  commercial  extraction,  recovery  or  processing  at  any  or  all  of  our  projects  or  other 
facilities and may also be required to look for alternatives other than cash flow to maintain our liquidity until prices recover. 
Our expected levels of uranium, vanadium and REE recovery and other business activity are dependent on our expectation and 
the  industry’s  expectations  of  uranium,  vanadium,  REE  and  HMC  prices,  which  may  not  be  realized  or  may  change.  In  the 
event we conclude that a significant deterioration in expected future uranium, vanadium, REE or HMC prices has occurred, we 
will assess whether an impairment allowance is necessary which, if required, could be material.

The  recent  fluctuations  in  the  price  of  many  commodities  is  an  example  of  a  situation  over  which  we  have  no  control,  and 
which could materially adversely affect us in a manner for which we may not be able to compensate. There can be no assurance 
that the price of any minerals recovered from or processed at our properties will be such that any deposits can be operated at a 
profit.

Our profitability is directly related to the market prices of uranium, vanadium, REEs and HMC recovered. We may, from time 
to  time,  undertake  commodity  and  currency  hedging  programs  with  the  intention  of  maintaining  adequate  cash  flows  and 
profitability  to  contribute  to  the  long-term  viability  of  the  business.  We  anticipate  selling  forward  in  the  ordinary  course  of 
business  if,  and  when,  we  have  sufficient  assets  and  recovery  to  support  forward  sale  arrangements  and  forward  sale 
arrangements  are  available  on  suitable  terms.  There  are,  however,  risks  associated  with  forward  sale  programs.  If  we  do  not 
have  sufficient  recovered  product  to  meet  our  forward  sale  commitments,  we  may  have  to  buy  or  borrow  (for  later  delivery 
back  from  recovered  product)  sufficient  product  in  the  spot  market  to  deliver  under  the  forward  sales  contracts,  possibly  at 
higher  prices  than  provided  for  in  the  forward  sales  contracts,  or  potentially  default  on  such  deliveries.  In  addition,  under 
forward contracts, we may be forced to sell at prices that are lower than the prices that may be available on the spot market 
when  such  deliveries  are  completed.  Although  we  may  employ  various  pricing  mechanisms  within  our  sales  contracts  to 
manage our exposure to price fluctuations, there can be no assurance that such mechanisms will be successful. There can also 
be  no  assurance  that  we  will  be  able  to  enter  into  additional  term  contracts  for  future  sales  of  uranium,  vanadium  or  RE 
Carbonate at prices or in quantities that would allow us to successfully manage our exposure to price fluctuations.

The majority of our properties do not contain Mineral Reserves under S-K 1300 and NI 43-101, and some of the Company’s 
properties, projects and facilities may not be economic at any point in time or at all.

Only two of our properties – the Sheep Mountain and Pinyon Plain mines – contain Mineral Reserves under SEC S-K 1300 and 
NI  43-101  (see  “Item  II,  Cautionary  Note  to  Investors  Concerning  Disclosure  of  Mineral  Reserve  and  Mineral  Resource 
Estimates”). Depending on uranium, vanadium, REE and HMC prices, some or all of our properties, projects and facilities may 
not be economic for uranium, vanadium, REE or HMC extraction, recovery or processing at any point in time. Generally, we 
intend to continue to hold, and in certain cases advance, properties, projects and facilities which may not be economic at any 
point in time in anticipation of possible future increases in the prices of uranium, vanadium, REEs and/or HMC, as the case 
may  be.  However,  in  those  circumstances,  there  can  be  no  assurance  at  any  time  that  such  prices  will  ever,  or  within  a 
reasonable  time  period,  increase  to  the  levels  required  to  advance  those  properties  or,  in  the  case  of  projects  or  facilities  on 
standby,  to  resume  exploration,  extraction,  recovery  or  processing  activities  at  those  projects  or  facilities.  In  the  event  of 
depressed commodity prices, we would continue to hold our standby properties, projects and facilities because we believe that 
prices  are  likely  to  rise,  to  such  levels  within  a  reasonable  time  period  to  justify  future  production.  This  ability  to  maintain 

37

scalability as commodity prices increase is a key component of our business strategy. However, as there is a cost associated 
with  holding  and,  in  some  cases,  maintaining  such  properties,  projects  and  facilities  on  standby  during  periods  of  depressed 
commodity prices, in those circumstances we continuously evaluate, on a case-by-case basis, such costs against the prospects 
for price increases, and may from time to time sell, drop or reclaim any such properties, projects or facilities.

Mining on properties having no known Mineral Resources or Mineral Reserves is inherently speculative and may not prove 
to be economic at any point in time or at all.

Mining is an inherently speculative business. Some of the properties on which we have the right to mine are not known to have 
any Mineral Reserves or Mineral Resources. There is a possibility that we will not discover uranium, vanadium, REEs and/or 
HMS, or potentially copper, on any or all of our properties which can be mined or extracted at a profit at any point in time or at 
all. Even if we do discover and mine such minerals, the deposits may not be of the quality or size necessary for us or a potential 
purchaser  of  the  property  to  make  a  profit  from  mining  it.  Few  properties  that  are  explored  are  ultimately  developed  into 
producing mines, and mines that are developed may not be profitable. Unusual or unexpected geological formations, geological 
formation pressures, fires, power outages, labor disruptions, flooding, explosions, cave-ins, landslides and the inability to obtain 
suitable or adequate machinery, equipment or labor, as well as all necessary licenses and permits, are just some of the many 
risks involved in mineral exploration programs and their subsequent development. However, we may elect, now or in the future, 
to  proceed  with  the  extraction  of  minerals  on  one  or  more  of  those  projects  without  having  completed  the  technical  work 
required to declare a Mineral Reserve. If we are then unable to extract uranium, vanadium, REEs and/or HMC, or potentially 
copper, in commercially viable quantities, the capital investment of mining such properties may be lost and could materially 
impact our business. 

Exploration, development, extraction, mining, recovery and milling of minerals, and the transportation and handling of the 
products recovered, are subject to extensive international, federal, state and local laws and regulations.

These regulations govern, among other things: acquisition of the property or mineral interests; maintenance of claims; tenure; 
expropriation;  prospecting;  exploration;  development;  construction;  extraction  and  mining;  recovery,  processing,  milling  and 
production; price controls; exports and imports; taxes and royalties; labor standards; occupational health; waste disposal; toxic 
substances;  water  use;  land  use;  American  Indian  or  other  foreign  indigenous  peoples  consultations  and  accommodations; 
environmental  protection  and  remediation;  endangered  and  protected  species;  mine,  mill  and  other  facility  decommissioning 
and reclamation; mine safety; transportation safety and emergency response; and other matters. Compliance with such laws and 
regulations has increased the costs of exploring, drilling, developing, constructing, operating and closing of our mines, mills, 
plants and other extraction, recovery and processing facilities. It is possible that, in the future, the costs, delays and other effects 
associated with such laws and regulations may impact our decision as to whether to operate existing mines or facilities, or, with 
respect  to  exploration,  development  or  construction  properties,  whether  to  proceed  with  exploration,  development  or 
construction.  It  is  also  possible  that  such  laws  and  regulations  may  result  in  our  incurring  significant  costs  to  remediate  or 
decommission  properties  if  it  is  determined  they  do  not  comply  with  applicable  environmental  standards  at  such  time.  We 
expend significant financial and managerial resources to comply with applicable laws and regulations. We anticipate continuing 
to  do  so  as  the  historic  trend  toward  stricter  government  regulation  may  continue.  However,  there  can  be  no  assurance  that 
future changes in applicable laws and regulations or attitudes and interpretations relating thereto, will not adversely affect our 
activities, operations or financial condition. New laws and regulations, amendments to existing laws and regulations or changes 
in attitudes and interpretations resulting in more stringent implementation of existing laws and regulations, including through 
stricter  license  and  permit  conditions  or  changes  in  enforcement  attitudes  and  interpretations,  could  have  a  material  adverse 
impact on us, increase costs, cause a reduction in levels of, or suspension of, extraction or recovery and/or delay or prevent the 
construction or development of new mineral extraction properties.

Mineral  extraction  is  subject  to  potential  risks  and  liabilities  associated  with  impacts  to  the  environment  and  the  disposal  of 
waste  products  occurring  as  a  result  of  mineral  exploration,  extraction,  mining,  milling,  recovery  and  production. 
Environmental liability may result from mining or mineral extraction activities conducted by others prior to our ownership of a 
property. Failure to comply with applicable laws, regulations and permitting requirements may result in enforcement actions. 
These  actions  may  result  in  orders  issued  by  regulatory  or  judicial  authorities  causing  activities  or  operations  to  cease  or  be 
curtailed, and may include corrective measures requiring capital expenditures, installation of additional equipment or remedial 
actions. Companies engaged in uranium, monazite or other exploration operations may be required to compensate others who 
suffer loss or damage by reason of such activities and may have civil or criminal fines or penalties imposed for violations of 
applicable  laws  or  regulations.  Should  we  be  unable  to  fully  fund  the  cost  of  remedying  an  environmental  problem,  the 
Company might be required to suspend activities or operations, declare bankruptcy or enter into interim compliance measures 
pending completion of the required remedy, which could have a material adverse effect on the Company. To the extent that we 
are subject to uninsured environmental liabilities, the payment of such liabilities would reduce otherwise available earnings and 
could  have  a  material  adverse  effect  on  us.  In  addition,  we  do  not  have  coverage  for  environmental  losses  generally  or  for 

38

certain  other  risks  as  such  coverage  cannot  be  purchased  at  a  commercially  reasonable  cost.  Compliance  with  applicable 
environmental laws and regulations requires significant expenditures and increases mine and facility, construction, development 
and operating costs.

While the very heart of our business – uranium production, which is the fuel for carbon-free, emission-free baseload nuclear 
power  –  and  our  recycling  programs,  help  address  global  climate  change  and  reduce  air  pollution,  the  world’s  focus  on 
addressing climate change will require the Company to continue to conduct all its operations in a manner that minimizes the use 
of resources, including the unnecessary use of energy resources, in order to continue to minimize air emissions at our facilities, 
which  can  also  increase  mine  and  facility,  construction,  development  and  operating  costs.  Regulatory  and  environmental 
standards may also change over time to address global climate change, which could further increase these costs. 

There is a risk that current and future government administrations will not support mining, uranium mining, nuclear energy or 
other aspects of our business and may limit, restrict or prevent the use of public lands for mining and other activities.

Worldwide demand for uranium is directly tied to the demand for electricity produced by the nuclear power industry, which is 
also  subject  to  extensive  government  regulation  and  policies.  The  development  of  mineral  properties  and  related  facilities  is 
contingent upon governmental approvals that are complex and time consuming to obtain and that, depending upon the location 
of  the  project,  involve  multiple  governmental  agencies.  The  duration  and  success  of  such  approvals  are  subject  to  many 
variables outside of our control. Any significant delays in obtaining or renewing permits or licenses in the future could have a 
material adverse effect on us. In addition, the international marketing of uranium is subject to governmental policies and certain 
trade restrictions, such as those imposed by the suspension agreement between the U.S. and Russia. Changes in these policies 
and restrictions may adversely impact our business.

Public acceptance of nuclear energy and competition from other energy sources is unknown.

Growth of the uranium and nuclear industry will depend upon continued and increased acceptance of nuclear technology as an 
economic means of generating electricity. Because of unique political, technological and environmental factors that affect the 
nuclear  industry,  including  the  risk  of  a  nuclear  incident  and  fears  of  nuclear  incidents  in  the  event  of  terrorism,  wars, 
insurrections  or  natural  disasters,  the  industry  is  subject  to  public  opinion  risks  that  could  have  an  adverse  impact  on  the 
demand  for  nuclear  power  and  increase  the  regulation  of  the  nuclear  power  industry.  Nuclear  energy  competes  with  other 
sources of energy, including oil, natural gas, coal, hydroelectricity and renewable energy sources. These other energy sources 
are to some extent interchangeable with nuclear energy, particularly over the longer term. Sustained lower prices of oil, natural 
gas,  coal  and  hydroelectricity  may  result  in  lower  demand  for  uranium  concentrates.  Increased  government  regulation  and 
technical requirements may make nuclear energy uneconomic, resulting in lower demand for uranium concentrates. Technical 
advancements and government subsidies in renewable and other alternate forms of energy, such as wind and solar power, could 
make these forms of energy more commercially viable and put additional pressure on the demand for uranium concentrates.

Unfavorable media coverage of mining or nuclear energy could negatively affect our business.

The Company is subject to media coverage relating to mining and the production of uranium and other forms of nuclear energy, 
as well as the production of RE Carbonate, separated REE oxides, HMC and the extraction and concentration of radioisotopes 
for use in TAT medical treatments, some of which can be inaccurate, non-objective or politically motivated. As a result, the 
Company is frequently required to address or respond to such media coverage, which can be costly and time-consuming for the 
Company. Such inaccurate and non-objective media coverage can also negatively impact public perception of the Company’s 
activities, the market for the Company’s securities, government relations, permitting activities and legal challenges.

Potential impacts of public perceptions on our commercial relations.

Given the controversial nature of the mining and nuclear industries, the Company is subject to the risk that suppliers, customers, 
co-venturers or other business relations may be discouraged from or decline to continue commercial relations with or enter into 
new commercial relations or arrangements with the Company due to fear of reprisals from the media, public or special interest 
groups based on public perceptions of the nature of the Company’s business or the nature or location of its assets, particularly 
driven by the ability of the media, public and special interest groups to influence public perceptions through the media, social 
media and the internet.

The uranium and REE industries are highly competitive.

The international uranium industry, including the supply of uranium concentrates, is highly competitive. Our uranium business 
is  in  direct  competition  with:  a  relatively  small  number  of  publicly  traded  or  privately  funded  uranium  mining  companies; 

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nationally  subsidized  uranium  companies;  uranium  produced  as  a  byproduct  of  other  mining  operations;  excess  inventories, 
including  inventories  made  available  from  decommissioning  of  nuclear  weapons;  reprocessed  uranium  and  plutonium;  used 
reactor fuel; and the use of excess Russian enrichment capacity to re-enrich depleted uranium tails. A large quantity of current 
world production is foreign state-subsidized and appears to be relatively inelastic in that uranium market prices appear to have 
little effect on the quantity supplied. In the case of foreign state-subsidized production, uranium production may not be fully 
subject to market factors and may be sold at prices that may be less, or even significantly less, than the costs of production. The 
supply of uranium from Russia is to some extent (and increasingly) impeded by a number of international trade agreements and 
policies.  These  agreements  and  any  similar  future  agreements,  governmental  policies  or  trade  restrictions  are  beyond  our 
control and may affect the supply of uranium available in North America, Europe and Australia/New Zealand.

We  compete  with  other  mining  companies  and  individuals  for  capital,  Mineral  Resources  and  Mineral  Reserves  and  other 
mining  assets,  which  may  increase  the  cost  of  acquiring  suitable  claims,  properties  and  assets.  We  also  compete  with  other 
mining companies to attract and retain key executives, employees and consultants. In addition, there are relatively few bona fide 
and legitimate customers for uranium. There can be no assurance that we will continue to be able to compete successfully with 
our competitors in acquiring such properties and assets or in attracting and retaining skilled and experienced employees.

The  REE  industry  is  competitive,  particularly  to  the  extent  it  is  dominated  by  China,  which  produces  nearly  90%  of  refined 
REE products according to the International Energy Agency. Many Chinese companies are state-supported or subsidized, and 
Chinese  companies  bid  aggressively  to  acquire  monazite  to  feed  this  production.  The  Company  competes  with  Chinese 
companies, and companies from other countries that are in or trying to break into the REE market, for sources of monazite, and 
will be expected to compete with Chinese companies and companies from other countries as they develop production capacity 
at the RE Carbonate crack and leach, REE separation, REE metal and alloy making, REE magnet making, and REE product 
marketing and sales stages of the REE supply chain, as well as for the acquisition of monazite and other mineral properties, for 
mining and exploration on such properties, and for the procurement of equipment, materials and personnel necessary to explore, 
develop  and  extract  monazite  from  such  properties.  There  is  competition  for  a  limited  number  of  monazite  acquisition 
opportunities, including competition with other companies having substantially greater financial resources, staff and facilities 
than  the  Company.  As  a  result,  the  Company  may  encounter  challenges  in  acquiring  attractive  properties  and  exploring  and 
advancing  properties  currently  in  the  Company’s  portfolio.  The  Company  believes  that  competition  for  acquiring  monazite 
prospects, production of REE products and completing REE product sales will continue to be intense in the future.

Mining operations involve a high degree of risk.

The  exploration,  construction,  development,  operation  and  other  activities  associated  with  mineral  projects,  along  with  the 
expansion of existing recovery operations and mining activities and restarting of projects, involve significant risks, including 
financial,  technical  and  regulatory  risks.  The  development  or  advancement  of  any  of  the  exploration  properties  in  which  we 
have  an  interest  is  contingent  upon  obtaining  satisfactory  exploration  results,  project  permitting  and  licensing  and  financing. 
The exploration, construction, development, operation and other activities associated with mineral projects involves significant 
financial risks over an extended period of time, which even a combination of careful evaluation, experience and knowledge may 
not  eliminate.  While  discovery  of  a  mine  or  other  facility  may  result  in  substantial  value,  few  properties  that  are  staked  and 
explored are ultimately developed into producing mines or extraction or recovery facilities. Major expenses may be required to 
establish Mineral Resources and Mineral Reserves by drilling and to finance, permit, license and construct extraction, mining, 
recovery and processing facilities. It is impossible to ensure that the current or proposed exploration, permitting, construction 
and  development  programs  on  our  mineral  properties  will  result  in  profitable  commercial  extraction,  mining  or  recovery 
operations.

Whether a mineral deposit will be commercially viable depends on a number of factors, which include, among other things: the 
accuracy of Mineral Resource and Mineral Reserve estimates; the particular attributes of the deposit, such as its size, geology, 
grade  and  accessibility;  the  ability  to  economically  recover  commercial  quantities  of  the  minerals;  proximity  to  necessary 
infrastructure and availability of personnel; financing costs; governmental regulations, including regulations relating to prices, 
taxes, reclamation bonds and royalties; the potential for litigation; land use; importing and exporting; and environmental and 
cultural protection, including but not limited to the governmental establishment of mineral withdrawals, parks and monuments 
and  land  exchanges.  The  construction,  development,  expansion  and  restarting  of  projects  are  also  subject  to:  the  successful 
completion  of  engineering  studies  with  adequate  results  to  proceed;  the  issuance  of  necessary  governmental  licenses  and 
permits;  the  availability  of  adequate  financing;  engineering  and  construction  timetables  and  capital  costs  being  correctly 
estimated for our projects, including restarting projects on standby; and such construction timetables and capital costs not being 
affected  by  unforeseen  circumstances,  including  but  not  limited  to  delays  due  to  litigation/injunctions.  The  effect  of  these 
factors cannot be accurately predicted, but the combination of these factors, along with others, may result in our not receiving 
an adequate return on invested capital.

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It is possible that actual costs and economic returns of current and new extraction, mining, or recovery operations may differ 
materially  from  our  best  estimates.  It  is  not  unusual  in  the  mining  industry  for  new  mining  operations  and  facilities  to 
experience unexpected problems during the start-up phase, to take much longer than originally anticipated to bring them into a 
recovery or producing phase, to require more capital than anticipated, to operate at a higher cost than expected and/or to have 
reclamation liabilities that are higher than expected.

There can be no assurance that, as the Company mines its properties or disposes of properties, the reduction of existing Mineral 
Resources and/or Mineral Reserves through depletion or sales will be replaced with new resources of comparable value.

There is uncertainty in the estimation of Mineral Reserves and Mineral Resources.

Only two of our properties – the Sheep Mountain and Pinyon Plain mines – contain Mineral Reserves as defined under S-K 
1300  and  NI  43-101.  See  “Item  II,  Cautionary  Note  to  Investors  Concerning  Disclosure  of  Mineral  Reserve  and  Mineral 
Resource Estimates.”

Mineral Reserves and Mineral Resources are statistical estimates of mineral content pursuant to S-K 1300 and NI 43-101 based 
on  limited  information  acquired,  in  large  part,  through  drilling  and  other  sampling  techniques  and  require  judgmental 
interpretations of geology. Successful extraction requires safe and efficient mining and processing. Our Mineral Reserves and 
Mineral Resources are estimates, and no assurance can be given that the estimated Mineral Reserves and Mineral Resources are 
accurate or that the indicated levels of uranium, vanadium, REEs or HMC will be produced economically or otherwise. Actual 
mineralization or formations may be different than predicted. Further, it may be many years from the initial phase of drilling 
before production is possible and, during that time, the economic feasibility of exploiting a discovery may change.

Mineral Reserve and Mineral Resource estimates for properties that have not commenced extraction, production or recovery are 
based,  in  many  instances,  on  limited  and  widely  spaced  drill-hole  information,  which  is  not  necessarily  indicative  of  the 
conditions  between  and  around  drill  holes.  Accordingly,  such  Mineral  Resource  and  Mineral  Reserve  estimates  may  require 
revision as more drilling information becomes available, as actual extraction, production or recovery experience is gained, and 
as methods and technologies develop further. It should not be assumed that all or any part of our Mineral Resources constitute, 
or will be converted into, Mineral Reserves. Market price fluctuations of uranium, vanadium, REEs or HMC as applicable, as 
well  as  increased  production  and  capital  costs  and/or  reduced  recovery  rates,  may  render  our  proven  and  probable  Mineral 
Reserves  unprofitable  to  develop  at  a  particular  site  or  sites  for  periods  of  time  or  may  render  Mineral  Reserves  containing 
relatively lower grade mineralization uneconomic.

Opposition to mining may disrupt our business activities.

In  recent  years,  governmental  agencies,  non-governmental  organizations,  individuals,  communities  and  courts  have  become 
more  vocal  and  active  with  respect  to  their  opposition  to  certain  mining  and  business  activities,  including  with  respect  to 
production and uranium recovery at our facilities, such as the Mill and the Pinyon Plain Project. This opposition may take on 
forms  such  as  road  blockades,  vandalism,  threats  and/or  slander,  applications  for  injunctions  seeking  to  cease  certain 
construction, development, extraction, mining and/or milling or recovery activities, refusals to grant access to lands or to sell 
lands on commercially viable terms, lawsuits for damages or to revoke or modify licenses and permits, issuances of unfavorable 
laws and regulations, changes in regulatory attitudes and interpretations and other rulings contrary to or otherwise harming our 
interests. These actions can occur in response to current activities or in respect of mines or facilities that are decades old. In 
addition,  these  actions  can  occur  in  response  to  our  activities  or  the  activities  of  other  unrelated  entities.  Opposition  to  our 
activities  may  also  result  from  general  opposition  to  nuclear  energy  and  mining.  Opposition  to  our  business  activities  are 
beyond our control. Any opposition to our business activities may cause a disruption to our business activities and may result in 
increased costs and delays, which could have a material adverse effect on our business and financial condition.

We are subject to technical innovation and obsolescence.

Requirements for our products and services may be affected by: technological changes in nuclear reactors, enrichment and used 
uranium fuel reprocessing; facilities and processes for REE and radioisotope recovery; and substitutes for REEs, HMC and the 
radioisotopes  the  Company  may  potentially  be  producing.  These  technological  changes  could  reduce  the  demand  for  our 
products  and  services  and/or  increase  the  supply  of  competitive  products  and  services.  The  cost  competitiveness  of  our 
operations  may  be  impacted  through  the  development  and  commercialization  of  other  mining,  milling,  processing  and  other 
technologies.  As  a  result,  our  competitors  may  adopt  technological  advancements  that  give  them  an  advantage  over  the 
Company or that reduce the demand for the Company’s products and services or make them obsolete.

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Mining,  extraction,  recovery,  processing,  construction,  development  and  exploration  activities  depend,  to  a  substantial 
degree, on adequate infrastructure.

Reliable roads, bridges, power sources and water supply are important determinants affecting capital and operating costs. We 
consider  the  existing  infrastructure  to  be  adequate  to  support  our  proposed  operations  and  activities.  However,  unusual  or 
infrequent weather phenomena, including drought, flooding, sabotage, government and/or other interference in the maintenance 
or  provision  of  such  infrastructure  could  adversely  affect  our  operations  and  activities,  financial  condition  and  results  of 
operations.

Mining,  mineral  extraction,  recovery  and  milling  are  subject  to  a  high  degree  of  risk,  and  we  are  not  insured  to  cover 
against all potential risks.

Our  operations  and  activities  are  subject  to  all  the  hazards  and  risks  normally  incidental  to  exploration,  construction, 
development,  extraction  and  mining  of  mineral  properties,  and  recovery,  processing  and  milling,  including:  environmental 
hazards;  industrial  accidents;  labor  disputes,  disturbances  and  unavailability  of  skilled  labor;  encountering  unusual  or 
unexpected  geologic  formations;  rock  bursts,  pressures,  cave-ins  and  flooding;  periodic  interruptions  due  to  inclement  or 
hazardous weather conditions; technological and processing problems, including unanticipated metallurgical difficulties, ground 
control problems, process upsets and equipment malfunctions; the availability and/or fluctuations in the costs of raw materials 
and  consumables  used  in  our  production  and  recovery  processes;  the  ability  to  procure  mining  and  other  equipment  and 
operating and other supplies in sufficient quantities and on a timely basis; and other extraction, mining, recovery, milling and 
processing risks, as well as risks associated with our dependence on third parties in the provision of transportation and other 
critical services. Many of the foregoing risks and hazards could result in damage to, or destruction of, our mineral properties or 
processing or recovery facilities, personal injury or death, environmental damage, delays in or interruption of or cessation of 
extraction,  mining,  production  and  recovery  from  our  mines  or  processing  facilities  or  in  our  exploration,  construction  or 
development activities, delay in or inability to receive regulatory approvals to transport our uranium, vanadium, REE or HMC 
concentrates, and costs, monetary losses and potential legal liability and adverse governmental action. In addition, due to the 
radioactive  nature  of  the  materials  handled  in  uranium  extraction,  mining,  recovery,  processing  and  transportation  (both 
trucking and shipping), additional costs and risks are incurred by us on a regular and ongoing basis.

While we may obtain insurance against certain risks in such amounts as we consider adequate, the nature of these risks are such 
that  liabilities  could  exceed  policy  limits  or  could  be  excluded  from  coverage.  There  are  also  risks  against  which  we  cannot 
insure or against which we may elect not to insure. The potential costs that could be associated with any liabilities not covered 
by  insurance  or  in  excess  of  insurance  coverage  or  compliance  with  applicable  laws  and  regulations  may  cause  substantial 
delays  and  require  significant  capital  outlays,  adversely  affecting  our  future  earnings,  financial  position  and  competitive 
position.  No  assurance  can  be  given  that  such  insurance  will  continue  to  be  available  or  will  be  available  at  economically 
feasible premiums or that it will provide sufficient coverage for losses related to these or other risks and hazards. This lack of 
insurance coverage could result in material economic harm to us.

Risks associated with our REE business.

There are a number of risks inherent to our REE activities, which include the following: 

•

•

The risk of achieving and maintaining an adequate supply of monazite sands for processing at the Mill. Although the 
Company has acquired the Bahia Project, it is currently an exploration and development project and is not an operating 
mine at this time. As a result, the Company does not currently own its own operating monazite-bearing mine(s) and is 
completely dependent on contractual arrangements for its REE feed sources at this time. There can be no guarantee 
that  the  Company  will  be  able  to  secure  adequate  monazite  supply  over  the  long-term  at  suitable  prices  or  that  the 
Bahia Project will be developed into an operating monazite-producing mine. In addition, the price the Company may 
be  required  to  pay  for  monazite  sands  is  subject  not  only  to  commercial  factors  but  also  to  the  risk  of  influence  by 
foreign policy and/or foreign state-owned enterprises. We will evaluate potential acquisitions of additional mines or 
resource properties and joint ventures with mine or resource property owners, but there can be no guarantee that any 
such acquisitions or joint ventures can be realized on acceptable terms. Further, to the extent the Company is required 
to  purchase  monazite  ore  sources  and  rely  on  REE  separation  facilities  located  outside  the  U.S.,  we  may  be  at  a 
transportation cost disadvantage compared to processing facilities in China or elsewhere that may be closer to potential 
ore sources and/or REE separation facilities;
The risk of being able to contract to sell the Mill’s REE product at satisfactory prices. The Company has entered into 
one  sales  contract  with  an  REE  separation  facility  and  intends  to  secure  potential  sales  contracts  with  other  REE 
separation facilities for the sale of the RE Carbonate produced at the Mill and with NdPr and other REE oxide users for 
any  separated  NdPr  and  other  REE  oxides  produced  by  the  Company,  but  there  can  be  no  guarantee  that  any  such 

42

contracts will be entered into on satisfactory terms, or at all, or extended, in the future. If the Company is not able to 
secure adequate contracts for the sale of its RE Carbonate, REE oxides or other REE products, we may be required to 
hold our RE Carbonate, REE oxides and other REE products in inventory until they can be sold at reasonable prices, 
which  would  require  the  commitment  of  the  Company’s  cash  resources  while  the  REE  product  is  being  held  in 
inventory. We would also bear the risk that the REE product may not be able to be sold at reasonable prices in the 
future, either due to a lack of a market for the purchase of our RE Carbonate, REE oxides or other REE products and/
or a reduction in REE commodity prices and, hence, we bear the risk of a reduction in the value of our RE Carbonate, 
REE oxides or other REE products. We anticipate that the U.S. government may take steps to support the development 
of a U.S. supply chain for REEs through price support or other mechanisms, but there can be no guarantee that any 
such support will be given, or if given, would benefit the Company;
The  risk  of  process  failures  in  the  production  of  RE  Carbonates  or  separated  REE  oxides,  such  as  the  Company’s 
ability  to  continue  producing  RE  Carbonate  and  to  potentially  produce  separated  REE  oxides  at  commercial 
specifications and on a commercial scale at acceptable costs, which could prevent future commercial production of RE 
Carbonate and/or separated REE oxides at the Mill cost-competitively or at all;
The risk that we may not be able to increase our sources of natural monazite sands or other ores in amounts sufficient 
to sustain cost-competitive production of RE Carbonate, REE oxides or other REE products at the Mill or elsewhere;
The inability of the Company to successfully or cost-competitively process other types of REEs and uranium-bearing 
ores and materials at the Mill, such as those produced from coal-based resources or Alternate Feed Materials;
The inability of the Company to successfully enhance and modify existing Mill facilities to commission or otherwise 
construct and operate its planned REE separation circuits at the Mill or elsewhere, and potentially other downstream 
REE activities, including metal-making and alloying, in the future at the Mill or elsewhere, at acceptable costs or at all; 
The risk of: permit and license challenges, the failure to obtain or retain any needed permit or license amendments, or 
changes  in  regulatory  attitudes  or  interpretations.  The  Mill  can  produce  RE  Carbonate,  along  with  uranium,  from 
natural  uranium-  and  REE-bearing  monazite  sand  ores,  but  additional  permitting  or  licensing  may  be  required  to 
permit  certain  of  the  Company’s  planned  REE  separation  circuits  and  facilities  and  potential  REE  metal  and  metal 
alloy facilities at the Mill or elsewhere. The existing licensing regime and any new or existing permits or licenses or 
amendments that may be required are subject to challenge, which could delay or prevent existing production or any 
new construction, as well as any separation and other activities; 
The current shortage of supply of REEs and the resulting prices for REEs, and the fear that supplies of REEs may not 
be  forthcoming  on  a  timely  basis  to  meet  new  demands  for  REEs,  such  as  for  permanent  magnets  for  EVs,  may 
encourage end-users to substitute away from REEs to advance and use other technologies to meet consumer demands 
for end products, which could result in a significant reduction in demand for and prices of REEs. Sustained reductions 
in the price of REEs would impact the Company’s returns from its REE initiatives and could render them infeasible; 
The risk that further exploration, permitting and development work on the Bahia Project may result in a determination 
by the Company that developing a mine on the property is not feasible;
The risks associated with HMC production at the Company’s Bahia Project or any other HMS project acquired by the 
Company  in  the  future,  and  the  risks  associated  with  HMC  pricing  could  impact  the  profitability  of  mining  the 
Company’s Bahia Project or any such other HMS projects, which could impact the supply of monazite available to the 
Company from such projects;
The risk of conducting exploration and mining activities in Brazil, including: the need to rely on English/Portuguese 
translations  provided  by  third  parties;  variations  in  laws,  labor  practices,  and  social  norms  that  could  impact  the 
Company’s ability to conduct business in a timely and effective manner; and delays caused by cross-border logistics, 
such as import and export processes; and
Increases in the supply of REEs through the addition of new mines and/or REE processing facilities could increase the 
global  supply  of  REEs  and  reduce  the  price  of  REEs  and  REE  products.  Sustained  reductions  in  the  price  of  REEs 
would impact the Company’s returns from its REE initiatives and could render them unfeasible.

•

•

•

•

•

•

•

•

•

•

Risks Associated with our TAT Radioisotope Initiatives. 

There  are  a  number  of  risks  related  to  our  potential  recovery  of  radioisotopes  at  the  Mill  for  use  in  the  development  and 
production of emerging TAT cancer treatments, including: 

•

•

•

The  risk  that  the  potential  recovery  of  such  radioisotopes  at  the  Mill  may  not  be  technically  feasible  or  that  the 
radioisotopes may not meet commercial specifications;
The  risk  that  such  radioisotopes  may  not  be  economically  feasible  to  produce  or  may  not  be  able  to  be  sold  on  a 
commercial basis at a sufficient price and quantity; 
The risk that the Company is not able to enter into commercial commitments for the sale of offtake of radioisotopes 
that are adequate to justify the capital and other expenditures required to produce the radioisotopes;

43

•

•
•

•

•

•

The risk that the Company may not be able to secure the reagents, materials, supplies and other components necessary 
for recovery of the radioisotopes on reasonable commercial terms or in adequate quantities;
The risk that all required licenses, permits and regulatory approvals may not be obtained on a timely basis or at all;
The risk that the medical isotopes derived from such radioisotopes produced at the Mill may not prove their efficacy at 
clinical trials and may not obtain all required approvals for commercial use;
The development of competing cancer treatment therapeutics that could render the TAT therapeutics less attractive or 
obsolete;
The current shortage of supply of such radioisotopes and the resulting prices for such radioisotopes, and the fear that 
supplies of the radioisotopes may not be forthcoming on a timely basis to meet new demands for cancer therapies, may 
encourage  pharmaceutical  companies  to  advance  and  use  other  technologies  to  meet  consumer  demands  for  end 
products, which could result in a significant reduction in demand for and prices of the radioisotopes the Mill is capable 
of  producing.  Sustained  reductions  in  the  price  of  such  radioisotopes  would  impact  the  Company’s  returns  from  its 
TAT initiatives and could render them infeasible; and
Increases in the supply of such radioisotopes through the addition of radioisotope processing facilities, including the 
permitting  and  retrofitting  of  other  uranium  mills  for  the  recovery  of  radioisotopes,  or  through  the  sales  of 
radioisotopes by various U.S. or foreign governments from government production or existing government stockpiles, 
could increase the global supply of such radioisotopes and reduce the price of the radioisotopes. Sustained reductions 
in the price of such radioisotopes would impact the Company’s returns from its TAT radioisotope initiatives and could 
render them unfeasible.

Risks Relating to our Regulatory Environment

Our  business  is  subject  to  extensive  environmental  regulations  that  may  make  exploring,  mining  or  related  activities 
expensive, and which may change at any time.

We  are  required  to  comply  with  environmental  protection  laws  and  regulations  and  permitting  requirements  promulgated  by 
federal agencies and various states, provinces, counties and local governments in the countries in which we operate and conduct 
our activities in connection with extraction, mining, recovery and milling operations. The uranium industry is subject not only 
to  the  worker  health  and  safety  and  environmental  risks  associated  with  all  mining  activities,  but  also  to  additional  risks 
uniquely associated with uranium extraction, mining, recovery and milling. We expend significant resources, both financial and 
managerial,  to  comply  with  these  laws  and  regulations.  The  possibility  of  more  stringent  regulations  exists  in  the  areas  of 
worker health and safety, storage of hazardous materials, standards for heavy equipment used in extraction, mining, recovery or 
milling, the disposition of wastes, the decommissioning and reclamation of exploration, extraction, mining, recovery, milling 
and in-situ sites, climate change and other environmental matters, each of which could have a material adverse effect on the 
cost or the viability of a particular project.

We cannot predict what environmental legislation, regulations or policies will be enacted or adopted in the future or how future 
laws  and  regulations  will  be  administered  or  interpreted  in  the  countries  we  operate.  The  recent  trend  in  environmental 
legislation  and  regulation  is  generally  toward  stricter  standards,  and  this  trend  is  likely  to  continue  in  the  future.  This  recent 
trend includes, without limitation, laws and regulations relating to air and water quality, mine and other facility reclamation, 
waste handling and disposal, the protection of certain species and the preservation of certain lands and cultural resources. These 
regulations may require the acquisition of permits or other authorizations for certain activities. These laws and regulations may 
also limit or prohibit activities on certain lands. Compliance with more stringent laws and regulations, changes in regulatory 
attitudes and approaches, as well as potentially more vigorous enforcement policies, stricter interpretation of existing laws and 
stricter permit and license conditions may necessitate significant capital outlays, may materially affect our results of operations 
and business or may cause material changes or delays in our intended activities. There can be no assurance of our continued 
compliance  or  ability  to  meet  stricter  environmental  laws  and  regulations  and  permit  or  license  conditions  or  changes  in 
attitudes or interpretations relating thereto. Delays in obtaining permits and licenses could impact expected production levels or 
increases in expected uranium, vanadium, REE and/or HMC extraction levels.

Our  operations  may  require  additional  analyses  in  the  future,  including  environmental,  cultural,  and  social  impact  and  other 
related studies. Certain activities require the submission and approval of environmental assessments or the more comprehensive 
environmental  impact  statements,  and  the  like.  We  cannot  provide  assurance  that  we  will  be  able  to  obtain  or  maintain  all 
necessary permits that may be required to continue operations or exploration and development of our properties or, if feasible, 
to commence construction, development, operation or other activities relating to mining facilities at such properties on terms 
that  enable  operations  or  activities  to  be  conducted  at  economically  justifiable  costs.  If  we  are  unable  to  obtain  or  maintain 
licenses,  permits  or  other  rights  for  construction,  development  and  operation  of  our  properties,  or  otherwise  fail  to  manage 
adequately future environmental issues, our uranium, vanadium, REE and/or HMC recovery operations and mining activities 
could be materially and adversely affected.

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Further,  our  business  is  subject  to  risks  associated  with  increased  regulatory  requirements  or  changes  in  attitudes  or 
interpretations relating thereto applicable to our operations in response to pressure from special interest groups or otherwise.

Changes in regulatory requirements or changes in attitudes or interpretations relating to existing regulatory requirements could 
have a material adverse effect on our operations and financial condition.

Our operations on U.S. federal lands may be impacted by mineral withdrawals or the designation of national monuments by 
the U.S. President or government, either of which could have significant impacts on the Company and our operations, as 
well as by other factors. 

Mining claims on U.S. federal lands are subject to mineral withdrawals by the federal government or the designation of national 
monuments by the President of the U.S. under the Antiquities Act. In both cases, the withdrawal or the designation of a national 
monument withdraws the area from location and entry under the Mining Law, subject to valid existing rights. What this means 
is  that  no  new  mining  claims  may  be  filed  on  the  withdrawn  or  designated  lands  and  no  new  plans  of  operations  may  be 
approved,  other  than  plans  of  operations  on  mining  claims  that  were  valid  at  the  time  of  withdrawal  or  designation  and  that 
remain valid at the time of plan approval. Whether or not a mining claim is valid must be determined by a mineral examination 
conducted by BLM or USFS, as applicable. The mineral examination, which involves an economic evaluation of a project, must 
demonstrate  the  existence  of  a  locatable  mineral  resource  and  that  the  mineral  resource  constitutes  discovery  of  a  valuable 
mineral  deposit.  We  believe  that  all  our  material  Arizona  Strip  projects  are  on  valid  mining  claims  that  would  withstand  a 
mineral  examination.  Mineral  claims  that  are  in  the  exploration  stage  and  upon  which  economic  deposits  have  not  yet  been 
delineated are generally prevented from proceeding to the plan of operations stage during the withdrawal period or indefinitely 
in the case of the designation of a national monument. See the discussions under “Part I, Item 1. Description of Business - U.S. 
Land Tenure,” above, for a discussion on the recent Grand Canyon withdrawal and designation of the Ancestral Footprints of 
the Grand Canyon National Monument in Arizona and the Bears Ears National Monument in Utah, none of which are believed 
to have significant impacts on the Company at this time, but which have the potential to significantly impact the Company in 
the future.

In addition to the Grand Canyon withdrawal and the Ancestral Footprints of the Grand Canyon National Monument and Bears 
Ears  National  Monument,  there  are  currently  other  designated  or  proposed  withdrawals  of  federal  lands  for  the  purposes  of 
mineral location and development and proposed designations of national monuments. While such proposals are not yet final and 
would require further federal action, if they were to occur, it is uncertain whether any such withdrawals or designations would 
affect in any manner our current mineral projects.

Any future withdrawal of mineral lands from location and entry or future designation of additional national monuments has the 
potential to prevent further development on exploration stage claims held by the Company in the affected area as well as the 
potential for the Company to lose the ability to continue to develop mining operations on other claims in the affected area if a 
mineral examination indicates the deposit is uneconomical and that the claim is not valid, either of which could have significant 
impacts on the Company.

The risks of exchanges of state-owned lands in mineral withdrawal areas or national monuments for federal lands outside the 
withdrawal area or national monument but that are within the boundaries of and affect any of our properties, or similar actions, 
could adversely impact our affected properties or our ability to operate our affected properties.

Possible amendments to the General Mining Law or other laws could make it more difficult or impossible for us to execute 
our business plan.

Members of the U.S. Congress have repeatedly introduced bills which would supplant or alter the provisions of the U.S. Mining 
Law, as amended. Such bills have proposed, among other things, to (i) either eliminate or greatly limit the right to a mineral 
patent; (ii) significantly alter the laws and regulations relating to uranium mineral development and recovery from unpatented 
and patented mining claims; (iii) impose a federal royalty on production from unpatented mining claims; (iv) impose time limits 
on  the  effectiveness  of  plans  of  operation  that  may  not  coincide  with  mine  or  facility  life;  (v)  impose  more  stringent 
environmental compliance and reclamation requirements on activities on unpatented mining claims; (vi) establish a mechanism 
that would allow states, localities and American Indian tribes to petition for the withdrawal of identified tracts of federal land 
from  the  operation  of  the  U.S.  general  mining  laws;  and  (vii)  allow  for  administrative  determinations  that  mining  or  similar 
activities would not be allowed in situations where undue degradation of the federal lands in question could not be prevented. If 
enacted, such legislation could change the cost of holding unpatented mining claims and could significantly impact our ability 
to develop locatable mineral resources on our patented and unpatented mining claims. Although it is impossible to predict at 
this  point  what  any  legislated  royalties  might  be,  enactment  could  adversely  affect  the  potential  for  construction  and 

45

development and the economics of existing operating mines and facilities. Passage of such legislation could adversely affect our 
financial performance.

The EPA has in recent years announced an intention to propose new rules that, if promulgated, could result in increases in mine 
surety arrangements to cover currently non-existing and unidentified potential future environmental costs, which could severely 
impact  or  render  infeasible  many  existing  or  prospective  mining  operations.  EPA  dropped  this  proposal  after  considering 
comments  received  during  the  public  participation  process.  Nevertheless,  there  is  a  risk  that  similar  regulations  could  be 
proposed in the future, which could have significant impacts on the Company and the mining industry as a whole.

The SEC’s disclosure requirements for Mineral Reserves and Mineral Resources, as codified in Subpart 1300 of Regulation 
S-K 1300, create ambiguity for issuers required to comply with both the requirements of S-K 1300 and NI 43-101, and may 
result in increased compliance costs for the Company.

S-K 1300, as promulgated by the SEC and effective starting in 2021, requires that the Company disclose specific information 
related  to  its  material  mining  operations,  including  its  Mineral  Resources  and  Mineral  Reserves.  While  S-K  1300  is 
substantively  the  same  as  NI  43-101,  it  is  relatively  new  compared  to  NI  43-101  and,  thus,  remains  subject  to  unknown 
interpretations  that  could  require  the  Company  to  incur  substantial  costs  associated  with  compliance.  Where  substantive 
disclosure  in  one  regulatory  scheme  is  more  restrictive/stringent  than  in  the  other,  the  Company  opted  to  take  the  more 
restrictive/stringent approach in its technical reports. NI 43-101 has a prescribed format, whereas S-K 1300 does not; as such, 
the Company’s technical reports follow the formatting requirements of NI 43-101. Any further revisions to, or interpretations 
of, S-K 1300 or NI 43-101 could result in the Company incurring unforeseen costs associated with compliance, both in the U.S. 
and in Canada.

We are a “large accelerated filer” and are subject to a fully integrated audit pursuant to the Sarbanes-Oxley Act.

The Company is a “large accelerated filer,” meaning that, as of December 31, 2023 (and for the first time as of December 31, 
2021): (i) we had a public float of $700 million or more as of the most recently completed second fiscal quarter; (ii) we had 
been subject to the requirements of the Exchange Act Section 13(a) or 15(d) for a period of at least 12 calendar months; (iii) we 
filed at least one annual report pursuant to the Exchange Act Section 13(a) or 15(d), and (iv) we were not eligible to use the 
requirements for “smaller reporting companies” under the applicable revenue test. 

As such, we are subject to a fully integrated audit pursuant to Section 404(b) of the Sarbanes-Oxley Act of 2002, as amended 
(“SOX”), in order to assess, as of the most recent fiscal year-end, the effectiveness of the Company’s internal control structure 
and  procedures  for  financial  reporting,  as  reported  in  an  audit  report  of  our  independent  public  accounting  firm.  As  a  result, 
there  are  risks  that  one  or  more  significant  deficiencies  or  material  weaknesses  may  be  identified  in  the  Company’s  internal 
controls and procedures requiring remediation.

Our future business and results of operations face uncertainties as a result of any action or inaction of the U.S. Government 
pursuant to its U.S. Uranium Reserve Program.

On  December  27,  2020,  the  COVID-Relief  and  Omnibus  Spending  Bill,  which  included  $75  million  for  the  proposed 
establishment  of  a  strategic  U.S.  uranium  reserve,  was  signed  into  law.  While  the  now  established  U.S.  Uranium  Reserve 
Program  has  made  a  number  of  appropriations,  with  the  Company  having  sold  some  of  its  uranium  inventory  into  the  U.S. 
Uranium Reserve Program in 2023, there remains a risk that, if any future required appropriations passed by the U.S. Congress 
are deferred, or if they are implemented in a way that does not provide the required support for the Company’s activities, and 
uranium  and  vanadium  markets  do  not  support  production  activities  and/or  the  Company’s  REE  and  TAT  initiatives  are  not 
adequate  to  otherwise  sustain  the  Company’s  other  business  activities,  we  may  reduce  our  operational  activities,  including 
potentially monetizing certain non-core assets as required in order to minimize our cash expenditures while preserving our core 
asset base for increased production in the future as market conditions may warrant.

Participation in Industry Trade Petition and related activities could have negative repercussions.

The  Company  has  previously  participated  in  industry  trade  petitions,  including  in  particular  the  filing  of  an  industry  trade 
petition under Section 232 of the Trade Expansion Act of 1962 (as amended) From Imports of Uranium Products that Threaten 
U.S. National Security with the U.S. Department of Commerce (“DOC”), and may choose to participate in similar undertakings 
now or in the future as it deems necessary and appropriate. 

Although  the  Company  believes  the  bipartisan  appropriation  was  a  significant  accomplishment  that  has  directly  benefited 
Energy Fuels through the U.S. Uranium Reserve Program's first round of contract awards and that will ultimately strengthen the 

46

U.S.  uranium  mining  industry,  bolster  national  defense,  and  improve  supply  diversification  for  U.S.  utilities  and  their 
customers, there is a risk that future contract awards, if any, may be given in a way that does not benefit the Company. There is 
also the potential for negative responses or repercussions to Energy Fuels' receipt of any such U.S. Uranium Reserve Program 
contract  awards  from  various  special  interest  groups,  government  entities,  consumers  of  uranium  and  participants  in  other 
phases of the nuclear fuel cycle, both domestically and abroad, which could have a negative impact on the Company and its 
operations. In addition, the costs of pursuing such actions have been and could continue to be significant. 

Participation in the renewal of the Russian Suspension Agreement and related activities could have negative repercussions. 

In  October  2020,  the  DOC  and  the  State  Atomic  Energy  Corporation  Rosatom,  acting  on  behalf  of  the  Government  of  the 
Russian  Federation,  together  signed  an  amendment  (the  “Russian  Amendment”)  to  the  “Agreement  Suspending  the 
Antidumping  Investigation  on  Uranium  from  the  Russian  Federation”  (the  “Russian  Agreement”),  thereby  extending 
limitations on the import of Russian low-enriched uranium into the U.S. for use as fuel for nuclear reactors until the year 2040 
and tightening restrictions in order to close loopholes identified in the original Russian Agreement. The Company participated 
with the DOC in its efforts to secure the Russian Amendment as an advocate for domestic uranium producers, which has the 
potential for negative responses or repercussions to these activities from various special interest groups, government entities, 
consumers  of  uranium  and  participants  in  other  phases  of  the  nuclear  fuel  cycle,  both  domestically  and  abroad,  and  could 
thereby negatively impact the Company and its operations.

The  new  or  lasting  impacts  of  the  USMCA  (formerly  NAFTA)  on  the  Company  remain  unclear,  and  any  action  by  the 
President  of  the  United  States  to  withdraw  from  or  materially  modify  certain  other  international  trade  agreements  in  the 
future  could  adversely  affect  our  business,  financial  condition  and  results  of  operations,  to  the  extent  dependent  on  the 
jurisdiction of our incorporation.

Although our primary trading market is the NYSE American, a majority of our outstanding voting securities are held by U.S. 
residents,  we  are  a  U.S.  domestic  issuer  for  SEC  reporting  purposes,  and  substantially  all  of  our  assets,  operations  and 
employees  are  in  the  U.S.,  the  Company  is  incorporated  in  Ontario,  Canada.  On  September  30,  2018,  trade  representatives 
acting  on  behalf  of  the  U.S.,  Mexico  and  Canada  renegotiated  the  terms  of  the  North  American  Free  Trade  Agreement 
(“NAFTA”) in what is known as the United States-Mexico-Canada Agreement (“USMCA”), which entered into force on July 
1, 2020 after being approved by the U.S. Congress. At this time, the new or lasting impacts of the USMCA on the Company 
remain  unclear.  In  addition,  if  the  President  of  the  United  States  takes  action  to  withdraw  from  or  materially  modify  certain 
other  international  trade  agreements,  and  such  actions  depend  on  the  jurisdiction  of  our  incorporation,  then  our  business, 
financial condition and results of operations could possibly be adversely affected, depending on the nature of the action.

Risks Related to Our Business

Some of our mineral properties may never be put into a state of production.

Depending  on  uranium,  vanadium,  REE  and  HMS  prices,  some  of  our  mineral  properties  may  never  be  put  into  a  state  of 
production. Two of our projects have Mineral Reserves as defined by S-K 1300 and NI 43-101 — the Sheep Mountain Project 
and the Pinyon Plain Project. Because the probability of an individual prospect ever having Mineral Reserves as defined by S-K 
1300  and  NI  43-101  is  uncertain,  our  other  properties  may  not  contain  any  Mineral  Reserves.  Even  if  Mineral  Reserves  are 
identified, depending on commodity prices, we may not put a property into a state of production due to insufficient capital or 
other reasons. Any funds spent on exploration, construction, development, extraction and recovery on any properties that are 
not put into production may be lost. We do not know with certainty that economically recoverable uranium exists on all of our 
properties  as  defined  by  S-K  1300  and  NI  43-101.  Further,  although  we  are  undertaking  uranium  extraction  activities  at  our 
Mill  and  are  mining  at  several  of  our  properties  at  current  commodity  prices,  our  lack  of  established  Mineral  Reserves  on  a 
number of our properties means that we are uncertain as to our ability to continue to generate revenue from our operations. We 
may  never  discover  additional  uranium  in  commercially  exploitable  quantities,  and,  depending  on  commodity  prices,  our 
identified  deposits  currently  classified  as  Mineral  Resources  may  never  qualify  as  commercially  mineable  Mineral  Reserves. 
We will continue to attempt to acquire the surface and mineral rights on lands that we think are geologically favorable or where 
we have historical information in our possession that indicates uranium mineralization might be present.

The exploration and, if warranted, construction relating to or development of mineral deposits involves significant financial and 
other risks over an extended period of time, which even a combination of careful evaluation, experience and knowledge may 
not  eliminate.  Few  properties  which  are  explored  are  ultimately  developed  into  producing  mines.  Major  expenditures  are 
required to establish Mineral Reserves by drilling and to construct mining and processing facilities at a site. Our operations and 
activities  are  subject  to  the  hazards  and  risks  normally  incident  to  exploration  and  production  of  uranium,  precious  and  base 
metals,  any  of  which  could  result  in  damage  to  life  or  property,  environmental  damage  and  possible  legal  liability  for  such 

47

damage.  While  we  may  obtain  insurance  against  certain  risks,  the  nature  of  these  risks  is  such  that  liabilities  could  exceed 
policy limits or could be excluded from coverage. There are also risks against which we cannot insure or against which we may 
elect not to insure. The potential costs which could be associated with any liabilities not covered by insurance, or in excess of 
insurance  coverage,  or  compliance  with  applicable  laws  and  regulations  may  cause  substantial  delays  and  require  significant 
capital outlays, adversely affecting our future earnings and competitive position and, potentially, our financial viability.

The  Mill  has  historically  been  run  on  a  campaign  basis  as  sufficient  feed  materials  are  available,  and  there  can  be  no 
assurance that sufficient mill feed will be available in the future to sustain future campaigns.

The Mill has historically operated on a campaign basis, whereby mineral processing occurs as mill feed, cash needs, contract 
requirements  and/or  market  conditions  may  warrant.  Each  milling  campaign  is  subject  to  receipt  of  sufficient  mill  feed  that 
would allow us to operate the Mill on a profitable basis and/or recover a portion of its standby costs.

Due  to  significantly  improved  uranium  prices  in  2023,  three  of  the  Company’s  conventional  mines  were  brought  back  into 
operation near the end of the year, with the remaining conventional properties remaining either on standby, in the evaluation 
and permitting phase, undertaking rehabilitation and preparedness work or inactive, and no third-party conventional properties 
are  operating  to  provide  mill  feed.  However,  in  times  of  depressed  commodity  prices  when  conventional  mine  production  is 
entirely or significantly on standby, the Mill has relied primarily on processing Alternate Feed Materials and has also recycled 
tailings  pond  solutions  for  the  recovery  of  uranium  and  vanadium.  The  Company  continuously  seeks  to  identify  and  secure 
additional  Alternate  Feed  Materials  and  other  sources  of  mill  feed,  such  as  materials  from  the  cleanup  of  AUM  sites.  The 
Company  is  also  continuing  with  its  commercial  production  of  RE  Carbonate  and  is  performing  modifications  and 
enhancements  to  the  Mill’s  circuits  to  allow  for  the  separation  of  REE  oxides.  However,  there  can  be  no  assurance  that 
sufficient conventional ores, Alternate Feed Materials, suitable tailings pond solutions and/or other sources of mill feed will be 
available  in  the  future,  or  that  our  planned  increases  to  production  of  RE  Carbonate  and  separated  REE  oxides  will  be 
successful, so as to allow us to operate the Mill on a profitable basis and/or recover a portion of the Mill’s standby costs at any 
time.

There can be no guarantee that we will be able to enter into additional new term sales contracts in the future for uranium, 
vanadium, REEs or HMC on suitable terms and conditions.

The  Company  secured  three  new  long-term  sales  contracts  with  U.S.  nuclear  utilities  in  May  2022  and  is  continuing  to 
strategically  pursue  additional  uranium  sales  commitments  with  pricing  expected  to  have  both  fixed  and  market-related 
components. The Company believes that recent price increases, volatility and focus on security of supply in light of Russia’s 
ongoing invasion of Ukraine have increased the potential for the Company to make uranium sales and procure additional term 
sales  contracts  with  utilities  at  pricing  that  sustains  production  and  covers  corporate  overhead.  However,  there  can  be  no 
guarantee that the Company will be able to enter into additional long-term contracts for the delivery of significant amounts of 
uranium at satisfactory prices in the future. Fixed-price long-term contracts for vanadium are generally not available and the 
Company’s existing contract for the sale of RE Carbonate is at prices that vary with the prices of REEs. Thus, there can be no 
guarantee that the Company will be able to enter into long-term contracts for the delivery of significant amounts of vanadium or 
RE  Carbonate  or  other  REE  products  or  HMC  at  satisfactory  prices  in  the  future.  The  failure  to  enter  into  new  term  sales 
contracts on suitable terms could adversely impact our operations and mining activity decisions and resulting cash flows and 
income.

Vanadium mineral resource estimates for the La Sal Complex are based in part on Mill production records.

For  the  Company’s  La  Sal  Complex  uranium-vanadium  property,  vanadium  assay  results  are  not  available  for  all  drill  holes 
such that the vanadium mineral resource estimate is in part based on a ratio of vanadium to uranium supported by actual mill 
production  records  from  the  Mill.  There  is  a  risk  that  the  use  of  a  ratio  based  on  Mill  production  records  may  increase  the 
potential uncertainty in vanadium grades.

We may be unable to raise debt financing as may be required or desirable.

The Company may not be able to raise debt financing as may be required or desirable for planned expansion of our operations 
or for the development of projects with third parties in which we have a joint venture or other interest. The failure to raise debt 
financing  on  suitable  terms  or  at  all  when  required  or  desirable  could  have  a  material  adverse  effect  on  our  operations  and 
financial condition.

48

We may be unable to timely pay our outstanding debt obligations, which may result in us losing some of our assets covered 
by  mortgage  and/or  other  security  arrangements,  and  which  may  adversely  affect  our  assets,  results  of  operations  and/or 
future prospects.

We may from time to time enter into arrangements to borrow money in order to fund our operations and expansion plans, and 
such  arrangements  may  include  covenants  that  restrict  our  business  in  some  way.  We  may  also  from  time  to  time  acquire 
properties whereby certain payment obligations owed to the seller are paid by us over time, with the seller’s sole remedy for 
non-payment by us being re-acquisition of the property. Events may occur in the future, including events out of our control, that 
would  cause  us  to  fail  to  satisfy  our  debt  or  financing  instruments.  In  such  circumstances,  or  if  we  were  to  default  on  our 
obligations under such debt or financing instruments, the amounts drawn in accordance with the underlying agreements may 
become due and payable before the agreed maturity date, and we may not have the financial resources to repay such amounts 
when due.

Although all our reclamation obligations are bonded, and cash and other assets have been reserved to secure a portion but not 
all the bonded amounts, to the extent the bonded amounts are not fully collateralized, we will be required to provide additional 
cash  to  perform  our  reclamation  obligations  when  they  occur.  In  addition,  the  bonding  companies  have  the  right  to  require 
increases in collateral at any time, failure of which would constitute a default under the bonds. In such circumstances, we may 
not have the financial resources to perform such reclamation obligations or to increase such collateral when due.

We may need additional financing in connection with the implementation of our business and strategic plans from time to 
time.

The exploration, construction, development and acquisition of mineral properties and the ongoing operation of mines and other 
facilities requires a substantial amount of capital and may depend on our ability to obtain financing through joint ventures, debt 
financing,  equity  financing  or  other  means.  We  may  accordingly  need  further  capital  in  order  to  take  advantage  of  further 
opportunities  or  acquisitions.  Our  financial  condition,  general  market  conditions,  volatile  uranium  and  vanadium  markets, 
volatile interest rates, legal claims against us, a significant disruption to our business or operations, or other factors may make it 
difficult  to  secure  financing  necessary  for  the  expansion  of  mining  activities  or  to  take  advantage  of  opportunities  for 
acquisitions.  Further,  volatility  in  the  credit  markets  may  increase  costs  associated  with  debt  instruments  due  to  increased 
spreads over relevant interest rate benchmarks, or may affect our ability, or the ability of third parties we seek to do business 
with,  to  access  those  markets.  Continued  volatility  in  equity  markets,  specifically  including  energy  and  commodity  markets, 
may increase the costs associated with equity financings due to a low share price and may create the potential need for us to 
offer higher discounts and other value (e.g., warrants). There is no assurance that we will be successful in obtaining required 
financing as and when needed on acceptable terms, if at all.

We  have  experienced  negative  cash  flows  from  operations  and  may  need  additional  financing  in  connection  with  the 
implementation of our business and strategic plans from time to time.

The Company has had negative cash flow from operations in prior years, and at low commodity prices a number of our mining 
properties  will  be  on  standby,  making  it  less  likely  that  the  Company  will  be  able  to  generate  positive  cash  flows  from 
operations in those circumstances. If the Company cannot generate positive cash flows from operations, its ability to fund its 
operations and implement its business plans may depend on its ability to obtain financing through joint ventures, debt financing, 
equity financing or other means. There can be no assurance that we will be able to achieve and maintain positive cash flow from 
operations  to  fund  our  financing  needs.  Further,  if  cash  flows  from  operations  are  negative,  there  is  no  assurance  that  the 
Company will be able to raise additional funds, if needed, or that if any such additional funds are raised, that the Company will 
be able to raise such funds on commercially attractive terms. If we do not achieve positive cash flows or are unable to raise 
additional funds when needed, we may not be able to continue to fund our operations.

We are subject to costs associated with decommissioning and reclamation of our properties.

For  so  long  as  we  are  and  remain  the  owner  and  operator  of  the  Mill,  the  Nichols  Ranch  Project  and  numerous  uranium, 
uranium/vanadium,  REE  and  HMS  projects  and  other  facilities  located  in  the  U.S.,  Brazil  and  elsewhere,  and  certain  other 
permitting,  construction,  development  and  exploration  properties,  we  are  obligated  to  ultimately  reclaim  or  participate  in  the 
reclamation  of  our  properties  upon  the  occurrence  of  certain  predetermined  criteria  using  closely  monitored  and  carefully 
developed, approved methods. Our reclamation obligations are bonded, and cash and other assets have been reserved to secure 
a portion, but not all, of the bonded amounts. Although our financial statements will record a liability for the asset retirement 
obligation, and the bonding requirements are generally periodically reviewed by applicable regulatory authorities, there can be 
no  assurance  or  guarantee  that  the  ultimate  cost  of  such  reclamation  obligations  will  not  exceed  the  estimated  liability  to  be 

49

provided on our financial statements. Further, to the extent the bonded amounts are not fully collateralized, we will be required 
to come up with additional cash to perform our reclamation obligations when they occur.

Decommissioning plans for our properties have been filed with applicable regulatory authorities. These regulatory authorities 
have  accepted  the  decommissioning  plans  in  concept,  not  upon  a  detailed  performance  forecast,  which  has  not  yet  been 
generated.  Over  time,  further  regulatory  review  of  the  decommissioning  plans  may  result  in  additional  decommissioning 
requirements,  associated  costs  and  the  requirement  to  provide  additional  financial  assurances,  including  as  our  properties 
approach  or  go  into  decommissioning.  It  is  not  possible  to  predict  what  level  of  decommissioning  and  reclamation  (and 
financial assurances relating thereto) may be required in the future by regulatory authorities.

Our mineral properties may be subject to defects in title or risks of forfeiture.

We have investigated our rights to explore and exploit all our material properties and, to the best of our knowledge, those rights 
are in good standing. However, no assurance can be given that such rights will not be revoked, or significantly altered, to our 
detriment.  There  can  also  be  no  assurance  that  our  rights  will  not  be  challenged  or  impugned  by  third  parties,  including  by 
governments, surface owners, and non-governmental organizations.

The validity of unpatented mining claims on U.S. public lands is sometimes difficult to confirm and may be contested. Due to 
the  extensive  requirements  and  associated  expense  required  to  obtain  and  maintain  mining  rights  on  U.S.  public  lands,  our 
properties are subject to various title uncertainties common to the industry with the attendant risk that there may be defects in 
title. In addition, certain lands have been withdrawn around the Grand Canyon National Park, including most recently in the 
newly  established  Ancestral  Footprints  of  the  Grand  Canyon  National  Monument,  from  location  and  entry  under  the  Mining 
Laws.  All  the  Company’s  properties  located  on  the  Arizona  Strip,  with  the  exception  of  its  Wate  property  and  certain 
exploration properties held by the Company’s subsidiary, Arizona Strip Partners LLC, are located within the withdrawn lands 
and boundaries of the Grand Canyon National Monument. No new mining claims may be filed on the withdrawn lands and no 
new  plans  of  operations  may  be  approved,  other  than  plans  of  operations  on  mining  claims  that  were  valid  at  the  time  of 
withdrawal and that remain valid at the time of plan approval. Whether or not a mining claim is valid must be determined by a 
mineral  examination  conducted  by  BLM  or  USFS,  as  applicable.  The  mineral  examination,  which  involves  an  economic 
evaluation of a project, must demonstrate the existence of a locatable mineral resource and that the mineral resource constitutes 
discovery of a valuable mineral deposit. We believe that all our material Arizona Strip projects are on valid mining claims that 
would  withstand  a  mineral  examination.  Further,  our  Arizona  1  Project  has  an  approved  plan  of  operations  which,  absent 
modification,  would  not  require  a  mineral  examination.  Although  our  Pinyon  Plain  Project  also  has  an  approved  plan  of 
operations, which, absent modification, would not require a mineral examination, the USFS performed a mineral examination at 
that  mine  in  2012,  and  concluded  that  the  underlying  mining  claims  are  valid  existing  rights  (a  decision  which  has  been 
involved in a court challenge). However, market conditions may postpone or prevent the performance of mineral examinations 
on certain other properties and, if a mineral examination is performed on a property, there can be no guarantee that the mineral 
examination would not result in one or more of our mining claims being considered invalid, which could prevent a project from 
proceeding.

Certain of our properties, or significant portions thereof, are mineral leases that have fixed terms, both with State and private 
parties.  Certain  of  our  properties  are  subject  to  other  agreements  that  may  affect  our  ability  to  explore,  permit,  develop  and 
operate them, including surface use, access and other agreements. There can be no guarantee that we will be able to renew or 
extend such leases and agreements on favorable terms or at all. The failure to renew any such leases or agreements could have a 
material adverse effect on our operations.

The  granting  of  mineral  rights  in  Brazil  is  performed  in  four  steps:  exploration  authorization,  right  to  request  a  mining 
concession,  mining  concession  request  and  mining  concession  grant.  Each  step  requires  that  certain  actions  must  be  taken, 
results must be achieved by the Company, and in some circumstances approvals must be obtained, within certain time periods, 
which  can  be  extended  or  renewed  in  certain  circumstances  by  the  Brazilian  National  Mining  Agency  (“ANM”).  The 
Company’s  mineral  rights  in  Brazil  are  at  risk  of  being  forfeited  if  the  Company  fails  to  take  the  required  actions,  fails  to 
achieve  the  required  results  or  fails  to  obtain  the  required  approvals,  within  the  required  time  frames  and  ANM  declines  to 
extend  or  renew  such  time  frames.  The  forfeiture  of  any  such  mineral  rights  could  have  a  material  adverse  effect  on  our 
operations. See “Part I, Item 2J. The Bahia Project.”

Because we may be unable to secure access rights to certain of our properties, we may be unable to explore and/or advance 
such properties.

We are currently in the process of negotiating and clarifying access rights to certain of our properties, such as the Roca Honda 
Project and the Wate Project, with private landholders. There can be no guarantee that we will be able to negotiate or clarify 

50

such access rights on favorable terms, or at all. The failure to negotiate or clarify such access rights on suitable terms could 
have a material adverse effect on our operations.

Risks associated with carrying on our business in foreign countries.

The Company faces a number of risks related to conducting business operations in foreign countries including heightened risks 
of  political  instability,  expropriation  of  assets,  business  interruption,  increased  taxation,  import/export  controls,  unilateral 
modification of concessions and contracts. We also face the typical risks associated with doing business in foreign countries, 
including: different market and economic forces, resulting from new business environments with new competitors and different 
consumer  preferences;  dealing  with  local  suppliers  who  may  have  a  strong  foothold  in  the  area;  the  need  to  build  up  brand 
awareness  and  trust  in  a  new  market;  different  customer  and  supplier  demographics;  language  and  cultural  barriers;  extreme 
weather events and natural disasters that can present a sustained business risk relating to supply logistics and other factors; the 
additional  requirements  of  foreign  legal  systems;  the  impacts  of  foreign  tax  requirements;  the  need  to  comply  with  foreign 
regulations  and  operations  compliance;  the  need  to  comply  with  foreign  legal  systems,  including  as  they  relate  to  contract 
enforceability; the requirement to stay abreast of and remain in compliance with changing laws and regulations; and the lack of 
purchasing power parity compared to domestic competitors. Any number of these risks could have a material adverse effect on 
our operations, liquidity and financial condition.

Our operations outside the United States and Canada require us to comply with a number of United States, Canadian and 
international regulations, violations of which could have a material adverse effect on our business, consolidated results of 
operations, and consolidated financial condition.

Our operations outside the United States and Canada require us to comply with a number of United States, Canadian and other 
international  regulations.  For  example,  our  operations  in  countries  outside  the  United  States  and  Canada  are  subject  to  the 
United  States  Foreign  Corrupt  Practices  Act  (“FCPA”),  which  prohibits  United  States  companies  and  their  agents  and 
employees from providing anything of value to a foreign official for the purposes of influencing any act or decision of these 
individuals in their official capacity to help obtain or retain business, direct business to any person or corporate entity, or obtain 
any  unfair  advantage,  as  well  as  to  the  Corruption  of  Foreign  Public  Officials  Act  (“CFPOA”),  which  is  the  Canadian 
equivalent  of  the  FCPA.  Our  activities  create  the  risk  of  unauthorized  payments  or  offers  of  payments  by  our  employees, 
agents, or joint venture partners that could be in violation of anti-corruption laws, even though some of these parties are not 
subject  to  our  control.  We  have  internal  control  policies  and  procedures  and  have  implemented  training  and  compliance 
programs for our employees and agents with respect to the FCPA and CFPOA. However, we cannot assure that our policies, 
procedures, and programs will always protect us from reckless or criminal acts committed by our employees or agents. We are 
also subject to the risks that our employees, joint venture partners, and agents outside of the United States may fail to comply 
with  other  applicable  laws.  Allegations  of  violations  of  applicable  anti-corruption  laws  have  resulted  and  may  in  the  future 
result in internal, independent, or government investigations. Violations of anti-corruption laws may result in severe criminal or 
civil  sanctions,  and  we  may  be  subject  to  other  liabilities,  which  could  have  a  material  adverse  effect  on  our  business, 
consolidated results of operations and consolidated financial condition.

Risks associated with a Brazilian federal or state government enacting or managing a conservation unit or environmental 
protection area.

There is a risk of a Brazilian federal or state government enacting or managing a conservation unit or environmental protection 
area  or  implementing  a  management  plan  in  connection  therewith  that  could  impact  planned  production  at  or  restrict  the 
Company’s ability to or prevent the Company from mining significant portions of the Company’s Bahia Project. Such an action 
could have a material adverse effect on our operations, liquidity and financial condition.

We are subject to foreign currency risks.

Our operations are subject to foreign currency fluctuations. Our operating expenses and revenues are primarily incurred in U.S. 
dollars, while some of our cash balances and expenses are measured in Canadian dollars. The fluctuation of the Canadian dollar 
in relation to the U.S. dollar will consequently have an impact on our profitability and may also affect the value of our assets 
and  shareholders’  equity.  In  addition,  any  strengthening  of  the  U.S.  dollar  relative  to  other  currencies  makes  our  mineral 
extraction and recovery less competitive in relation to similar activities in other countries. Any strengthening of the U.S. dollar 
in  relation  to  the  currencies  of  other  countries  can  have  a  material  impact  on  our  cash  flows  and  profitability  and  affect  the 
value of our assets and shareholders’ equity.

51

We may not realize the anticipated benefits of previous acquisitions.

We  may  not  realize  the  anticipated  benefits  of  acquiring:  the  Sheep  Mountain  Project  in  2012;  Denison  Mines  Corp.’s  U.S. 
Mining Division in 2012, including the Mill, certain of the Arizona Strip Properties, the Bullfrog Project and the La Sal Project; 
Strathmore in 2013, including the Roca Honda Project; Uranerz in 2015, including the Nichols Ranch Project; and the Bahia 
Project  in  Brazil  in  2023,  due  to  integration,  operational  and  uranium,  REE,  HMC  and/or  vanadium  market  challenges. 
Decreases in commodity prices have required us to place or maintain a number of acquired properties and facilities on standby 
and  to  defer  permitting  and  construction  and  development  activities  on  certain  other  acquired  assets,  until  market  conditions 
warrant  otherwise,  and,  in  some  cases,  we  have  elected  to  sell  or  abandon  certain  of  these  properties  at  a  loss.  Our  success 
following  those  acquisitions  will  depend  in  large  part  on  the  success  of  our  management  in  valuing  the  acquired  assets  and 
integrating the acquired assets into the Company. Our failure to properly value the assets and to achieve such integration and to 
mine or advance such assets could result in our failure to realize the anticipated benefits of those acquisitions and could impair 
our results of operations, profitability and financial results.

We prepare estimates of future uranium, uranium/vanadium and REE (monazite) extraction and recovery, and there are no 
assurances that such estimates will be achieved.

We  may  from  time  to  time  prepare  estimates  of  future  uranium,  vanadium,  monazite,  HMS  or  other  mineral  extraction  and 
recovery,  or  increases  in  uranium,  vanadium,  monazite,  HMS  or  other  mineral  extraction  and  recovery,  for  particular 
operations, or relating to our ability to increase uranium, vanadium, monazite, HMS or other mineral extraction and recovery in 
response to increases in commodity prices, as market conditions warrant or otherwise. No assurance can be given that any such 
extraction  and  recovery  estimates  will  be  achieved,  nor  can  assurance  be  given  that  extraction  or  recovery  increases  will  be 
achieved  in  a  cost  effective  or  timely  manner.  Failure  to  achieve  extraction  and  recovery  estimates  or  failure  to  achieve 
extraction and recovery in a cost effective or timely manner could have an adverse impact on our future cash flows, earnings, 
results  of  operations  and  financial  condition.  These  estimates  are  based  on,  among  other  things,  the  following  factors:  the 
accuracy  of  Mineral  Resource  and  Mineral  Reserve  estimates;  the  accuracy  of  assumptions  regarding  ground  conditions  and 
physical  characteristics  of  mineralized  materials,  such  as  hardness  and  presence  or  absence  of  particular  metallurgical 
characteristics;  the  accuracy  of  estimated  rates  and  costs  of  extraction,  recovery  and  processing;  assumptions  as  to  future 
commodity prices; assumptions relating to changes in laws, regulations or policies, or lack thereof, that could impact the cost 
and time required to obtain regulatory approvals, licenses and permits; assumptions relating to obtaining required licenses and 
permits  in  a  timely  manner,  including  the  time  required  to  satisfy  environmental  analyses,  consultations  and  public  input 
processes; assumptions relating to challenges to or delays in the licensing and permitting process; and assumptions regarding 
any appeals or lack thereof, or injunctions or lack thereof, relating to any approvals, licenses or permits.

Our actual uranium, vanadium, monazite, HMC or other mineral extraction and recovery may vary from estimates for a variety 
of reasons, including, among others: actual mineralized material extracted, mined or recovered varying from estimates of grade, 
tonnage,  dilution,  metallurgical  and  other  characteristics;  short-term  operating  factors  relating  to  the  Mineral  Resources  and 
Mineral  Reserves,  such  as  the  need  for  sequential  construction  or  development  of  mineralized  materials  or  deposits  and  the 
processing  of  new  or  different  mineral  grades;  risk  and  hazards  associated  with  extraction,  mining  and  recovery;  natural 
phenomena, such as inclement weather conditions, underground floods, earthquakes, pit wall failures and cave-ins; unexpected 
labor  shortages  or  strikes;  varying  conditions  in  the  commodities  markets;  and  delays  in  obtaining  or  denial,  challenges  or 
appeals of regulatory approvals, licenses and permits or renewals of existing approvals, licenses or permits.

In addition, the Company is evaluating potentially recovering copper at the Mill as a byproduct with uranium from its Pinyon 
Plain Project. There can be no assurance that this evaluation will result in the Mill being able to recover copper at the Mill as a 
byproduct on an economic basis.

We depend on the issuance of license amendments and renewals, which cannot be guaranteed.

We maintain regulatory licenses and permits in order to operate our Mill and Nichols Ranch Project and conventional mines, 
which  are  subject  to  renewal  from  time  to  time  and  are  required  in  order  to  operate  in  compliance  with  applicable  laws  and 
regulations. In addition, depending on our business requirements, it may be necessary or desirable to seek amendments to one 
or more of our licenses or permits from time to time. While we have been successful in renewing our licenses and permits on a 
timely basis in the past and in obtaining such amendments as have been necessary or desirable, there can be no assurance that 
such license and permit renewals and amendments will be issued by applicable regulatory authorities on a timely basis or at all 
in the future.

52

We will need to continuously add to our Mineral Reserve and Mineral Resource base and to expand our sources of Alternate 
Feed Materials.

The majority of our properties do not contain any Mineral Reserves under S-K 1300 and NI 43-101. See Item II, “Cautionary 
Note to Investors Concerning Disclosure of Mineral Reserve and Mineral Resource Estimates.”

Our material Mineral Resources are located at the Nichols Ranch Project, the Pinyon Plain Project, the Roca Honda Project, the 
Sheep  Mountain  Project,  the  Bullfrog  Project  and  the  La  Sal  Project.  These  projects  are  our  primary  sources  (and  potential 
sources)  of  current  and  future  uranium  concentrates.  Unless  other  Mineral  Resources  or  Mineral  Reserves  are  discovered  or 
extensions to existing resource bodies are found, our sources of extraction, production and recovery for uranium concentrates 
will  decrease  over  time  as  our  current  Mineral  Resources  and  Mineral  Reserves  (contained  at  the  Pinyon  Plain  and  Sheep 
Mountain mines) are depleted. There can be no assurance that our future exploration, construction, development and acquisition 
efforts will be successful in replenishing our Mineral Resources or finding or developing Mineral Reserves. In addition, while 
we believe that many of our properties will eventually engage in extraction or mining activities, there can be no assurance that 
they will be placed into such activities, or that they will be able to replace current extraction or mining activities.

We also recover uranium by processing Alternate Feed Materials at our Mill. There can be no assurance that additional sources 
of Alternate Feed Materials will be forthcoming in the future on commercially acceptable terms or otherwise, or that we will be 
successful  in  receiving  all  required  regulatory  approvals,  licenses  and  permits  on  a  timely  basis  to  allow  for  the  receipt  and 
processing of any such Alternate Feed Materials.

In addition, we rely on monazite for our RE Carbonate and planned REE oxides at the Mill. There can be no assurance that 
additional  sources  of  monazite  will  be  forthcoming  in  the  future  on  commercially  acceptable  terms  or  otherwise,  or  that  the 
Bahia Project, which is currently in its exploration and development phase, will be commercially profitable.

Our sales of uranium, vanadium and REE products expose us to the risk of non-payment.

Our  sales  of  uranium,  vanadium,  HMC  and  REE  products  expose  us  to  the  risk  of  non-payment.  We  manage  this  risk  by 
monitoring the credit worthiness of our customers and requiring prepayment or other forms of payment security from customers 
with  an  unacceptable  level  of  credit  risk.  Most  of  the  Company’s  uranium  sales  are  to  major  nuclear  utilities,  which  pose  a 
relatively low risk of non-payment due to their large size and capitalization.

We are dependent on key personnel and qualified and experienced employees.

Our success will largely depend on the efforts and abilities of certain senior officers and key employees, some of whom are 
approaching  retirement.  Certain  of  these  individuals  have  significant  experience  in  the  uranium  and  REE  industries.  The 
number of individuals with significant experience in these industries is small. While we do not foresee any reason why such 
officers and key employees will not remain with us, other than through retirement, if for any reason they do not, we could be 
adversely  affected.  We  have  not  purchased  key  person  life  insurance  for  any  of  these  individuals,  other  than  for  our  Chief 
Executive Officer.

Our  compensation  programs  include  cash  and  equity  incentive  compensation  components  designed  to  attract  and  retain 
qualified  personnel,  which,  in  the  case  of  our  equity  incentive  programs,  contain  both  time-vesting  and  performance-based 
requirements that also help retain qualified personnel. Further, all current and future executive officers of the Company receive, 
or  are  expected  to  receive,  employment  agreements  with  the  Company,  which  also  serve  to  attract  and  retain  qualified 
personnel. In addition, the Company prioritizes the development of its existing management personnel and the advancement of 
existing personnel to fill vacancies as they arise, which the Company believes is an important element in developing, attracting 
and retaining the most qualified management personnel.

Nevertheless, our success will depend on the availability of qualified and experienced employees to work in our operations and 
our  ability  to  develop,  attract  and  retain  such  employees.  The  number  of  individuals  with  relevant  mining  and  operational 
experience in the Company’s key industries, especially the U.S. uranium and REE industries, is small. As the Company grows 
there is a risk that we may not be able to grow our qualified workforce and management team in pace with the growth of our 
business and activities, which could hamper our growth efforts.

We are dependent on business partner, government and third-party consents and approvals.

We have a number of joint ventures and other business relationships from time to time relating to our properties and projects, 
including key projects, such as the Arkose Mining Venture, which can restrict our ability to act unilaterally with respect to those 

53

projects  in  certain  circumstances.  There  can  be  no  assurances  that  we  will  be  able  to  maintain  relationships  with  our  joint 
venture and business partners to allow for satisfactory exploration, permitting, construction, development, extraction, mining, 
recovery  or  milling  relating  to  any  such  projects.  Our  operations  and  activities  are  also  dependent  from  time  to  time  on 
receiving  government  and  other  third-party  consents  and  approvals.  There  can  be  no  assurances  that  all  such  consents  and 
approvals will be forthcoming when required.

Certain of our directors may be in a position of conflict of interest with respect to the Company due to their relationship with 
other resource companies.

Some of our directors are also directors of other companies that are similarly engaged in the business of acquiring, exploring 
and  developing  natural  resource  properties.  Such  associations  may  give  rise  to  conflicts  of  interest  from  time  to  time.  In 
particular,  one  of  the  consequences  will  be  that  corporate  opportunities  presented  to  a  director  may  be  offered  to  another 
company or companies with which the director is associated and may not be presented or made available to us. Our directors 
are required by law to act honestly and in good faith with a view to the best interests of the Company, to disclose any interest 
which they may have in any project or opportunity of the Company, and to abstain from voting on such matter. Conflicts of 
interest that arise will be subject to and governed by the procedures prescribed in our Code of Business Conduct and Ethics and 
by the OBCA.

Our relationship with our employees may be impacted by changes in labor relations.

None  of  our  operations  or  activities  currently  directly  employ  unionized  workers  who  work  under  collective  agreements. 
However, there can be no assurance that our employees or the employees of our contractors will not become unionized in the 
future, which may impact our operations and activities. Any lengthy work stoppages may have a material adverse impact on our 
future cash flows, earnings, results of operations and financial condition.

U.S. investors may have difficulty bringing actions and enforcing judgments under U.S. securities laws against an Ontario 
corporation.

Although our primary trading market is the NYSE American, a majority of our outstanding voting securities are held by U.S. 
residents,  we  are  a  U.S.  domestic  issuer  for  SEC  reporting  purposes,  and  substantially  all  of  our  assets,  operations  and 
employees  are  in  the  U.S.,  the  Company  was  incorporated  in  Ontario  and,  as  a  result,  investors  in  the  U.S.  or  in  other 
jurisdictions  outside  of  Canada  may  have  difficulty  bringing  actions  and  enforcing  judgments  against  us,  our  directors,  our 
executive  officers  and  some  of  the  experts  named  in  this  Annual  Report  based  on  civil  liabilities  provisions  of  the  federal 
securities laws or other laws of the U.S. or any state thereof or the equivalent laws of other jurisdictions of residence.

An information security incident, including a cybersecurity breach, could have a negative impact to the Company’s business 
or reputation.

To  meet  business  objectives,  the  Company  relies  on  both  internal  information  technology  (“IT”)  systems  and  networks  and 
those  of  third  parties  and  their  vendors  to  process  and  store  sensitive  data,  including  confidential  research,  business  plans, 
financial information, process technology, intellectual property and personal data that may be subject to legal protection. The 
extensive  information  security  and  cybersecurity  threats,  which  affect  companies  globally,  pose  a  risk  to  the  security  and 
availability of these IT systems and networks, and to the confidentiality, integrity, and availability of the Company’s sensitive 
data.  The  Company  continually  assesses  these  threats  and  makes  investments  to  increase  internal  protection,  detection  and 
response capabilities, as well as to ensure the Company’s third-party providers have the required capabilities and controls to 
address  this  risk  on  an  ongoing  basis.  In  addition,  we  provide  confidential  and  proprietary  information  to  our  third-party 
business partners in certain cases where doing so is necessary to conduct our business. While we obtain assurances from those 
parties  that  they  have  systems  and  processes  in  place  to  protect  such  data  and,  where  applicable,  that  they  will  take  steps  to 
ensure the protections of such data by third parties, those partners may nonetheless also be subject to data intrusion or otherwise 
compromise  the  protection  of  such  data.  Any  compromise  of  the  confidential  data  of  our  customers,  consumers,  suppliers, 
partners, employees or ourselves, or failure to prevent or mitigate the loss of or damage to this data through breach of our IT 
systems  or  other  means,  could  substantially  disrupt  our  operations,  harm  our  customers,  consumers,  employees  and  other 
business partners, damage our reputation, violate applicable laws and regulations, subject us to potentially significant costs and 
liabilities and result in a loss of business that could be material. To date, the Company has not experienced any material impact 
to the business or operations resulting from information or cybersecurity attacks; however, because of the frequently changing 
attack techniques, along with the increasing volume and sophistication of the attacks paired with the increasingly high exposure 
of the Company due to its efforts to compete internationally in the REE industry, there is the potential for the Company to be 
targeted and adversely impacted. The Company may not maintain cybersecurity insurance having sufficient coverage to cover 
all financial losses, or any at all, in the event of an information security or cyber incident.

54

The Company may compromise or lose its proprietary technology or intellectual property in certain circumstances, which 
could result in a loss in the Company’s competitive position and/or the value of its intangible assets.

The increased reliance on technology, coupled with the Company’s developing REE and radioisotope initiatives, which involve 
novel  technology  developed  in  part  by  the  Company  and  in  part  by  others  and  by  consultants,  may  expose  the  Company  to 
material  risks  of  theft  or  loss  of  proprietary  technology  and  other  intellectual  property,  including  technical  data,  business 
processes, data sets or other sensitive information. Among the risks faced by the Company are:

•
•

•
•
•

•

•

failure to obtain patents or trade rights when available;
failure  to  adequately  contractually  establish  rights  to  proprietary  technology  and  other  intellectual  property  in  joint 
venture situations or other situations where the Company and its co-venturers, other business associates or consultants 
may be jointly contributing to the development of proprietary technology and other intellectual property;
failure to adequately limit rights or access to unprotected proprietary technology and other intellectual property;
failure to adequately identify and enforce infringements of proprietary technology and other intellectual property;
the  risk  of  theft  of  technology,  data  and  intellectual  property  through  a  direct  intrusion  by  private  parties  or  foreign 
actors, including those affiliated with or controlled by state actors;
the risk of reverse engineering by joint venture partners or other parties, including those affiliated with state actors, and 
any patents the Company may have being subsequently infringed or know-how or trade secrets being stolen; and
the Company may be required to compromise protections or yield rights to technology, data or intellectual property in 
order to conduct business in or access markets in a foreign jurisdiction, either through formal written agreements or 
due to legal or administrative requirements in the host nation.

The Company takes what it considers to be reasonable steps to protect its proprietary technology and intellectual property, but 
there  can  be  no  assurance  that  it  will  successfully  protect  its  proprietary  technology  and  intellectual  property  in  all 
circumstances. There is therefore a risk that the Company may compromise or lose its proprietary technology and intellectual 
property in certain circumstances, which could result in a loss in the Company’s competitive position and/or the value of its 
intangible assets. 

We may be required to provide financial statements of one or more of our equity method investees in our annual reports on 
Form 10-K and rely on our equity method investees to provide us with these financial statements to fulfill our SEC reporting 
obligations.

We account for our economic ownership interest in our equity method investments using the equity method of accounting or at 
fair value using the fair value option (collectively, the “equity method investees”). Pursuant to Rule 3-09 of Regulation S-X 
(“Rule 3-09”), we may be required to provide in our annual reports on Form 10-K financial statements for these equity method 
investees (the “Regulation S-X Financial Statements”). If required to provide Regulation S-X Financial Statements for these 
equity method investees, we have relied, and may in the future rely, on these equity method investees to provide us with their 
Regulation  S-X  Financial  Statements.  In  addition,  we  do  not  control  the  financial  reporting  process  of  our  equity  method 
investees and cannot change the way in which these equity method investees report their respective financial results.

These  equity  method  investees  may  not  provide  us  with  the  Regulation  S-X  Financial  Statements  necessary  to  enable  us  to 
complete our SEC filings on a timely basis or at all. If we are required to provide Regulation S-X Financial Statements for any 
of our equity method investees and are unable to do so, it may cause us to no longer be deemed timely and current with our 
SEC reporting obligations. In such event, we could become ineligible to use a registration statement on Form S-3. In addition, 
the  SEC  may  not  declare  effective  any  registration  statement  that  we  file  in  connection  with  an  offering  that  requires  the 
financial statements under Rule 3-09 to be included. Any resulting inability to complete a registered offering may materially 
adversely impact our business, liquidity position, growth prospects, financial condition and results of operations.

Our method of accounting for equity investments in other companies held by the Company could result in material changes 
to the Company’s financial results that are not fully within the Company’s control.

The  Company  accounts  for  investments  over  which  it  exerts  significant  influence,  but  not  control,  over  the  financial  and 
operating policies through the fair value option of ASC Topic 825 – Financial Instruments. Changes in the fair value of these 
investments  are  recognized  in  Other  Income  (Loss)  in  the  Company’s  Consolidated  Statements  of  Operations  and 
Comprehensive Income (Loss). The resulting related gains or losses are not fully within the control of the Company and could 
be material.

55

General Risk Factors

We are subject to global economic risks. 

In the event of a general economic downturn or a recession, there can be no assurance that our business, financial condition and 
results  of  operations  would  not  be  materially  adversely  affected.  During  the  global  financial  crisis  of  2007-2008,  economic 
problems  in  the  U.S.  and  Eurozone  caused  deterioration  in  the  global  economy  as  numerous  commercial  and  financial 
enterprises either went into bankruptcy or creditor protection or had to be rescued by governmental authorities. Access to public 
financing was negatively impacted by sub-prime mortgage defaults in the U.S., the liquidity crisis affecting the asset-backed 
commercial  paper  and  collateralized  debt  obligation  markets,  and  massive  investment  losses  by  banks  with  resultant 
recapitalization  efforts.  Moreover,  the  occurrence  of  unforeseen  or  extended  catastrophic  events,  including  in  particular  the 
COVID-19  pandemic,  and  the  emergence  of  a  future  pandemic  or  other  widespread  health  emergency  (or  concerns  over  the 
possibility  of  such  an  emergency)  could  create  economic  and  financial  disruptions.  These  types  of  challenges  can  impact 
commodity prices, including for uranium, vanadium and REEs, as well as currencies and global debt and stock markets. As a 
result  of  COVID-19,  or  in  the  case  of  a  future  pandemic  or  other  widespread  health  emergency,  quarantine  or  otherwise, 
requirements or circumstances may require the Company to change the way it conducts its business and operations, including 
requiring  the  Company  to  reduce  or  cease  operations  at  some  or  all  its  facilities  for  an  indeterminate  period  of  time. 
Furthermore, our critical supply chains may similarly be disrupted for an indeterminate amount of time. All these factors could 
have a material impact on the Company’s business, operations, personnel and financial condition.

These types of challenges may impact our ability to obtain equity, debt or other financing on terms commercially reasonable to 
us, or at all. Additionally, these types of factors, as well as other related factors, may cause decreases in asset values that are 
deemed to be other than temporary, which may result in impairment losses. If these types of challenges occur, or if there is a 
material deterioration in general business and economic conditions, our operations could be adversely impacted and the trading 
price of our securities could be adversely affected.

Russia’s Invasion of Ukraine is severely and unpredictably impacting global energy markets and supply chains, and rising 
concerns over a second severe nuclear accident in Ukraine could seriously hurt public reception to nuclear energy. 

Russia’s February 2022 invasion of Ukraine continues to severely impact global energy markets and supply chains by causing 
economic uncertainty, price volatility, supply shortages and national security concerns to such a degree that the International 
Energy Agency (“IEA”) has called it “the first truly global energy crisis, with impacts that will be felt for years to come.” As 
the Company is engaged in a number of energy sectors, including uranium, REEs and vanadium, it is expected that such global 
impacts will necessarily impact the Company, though the full extent of any such impacts are not well understood at this time. 
While  supply  and  shipping  impacts  could  materially  interfere  with  our  ability  to  conduct  business,  for  example,  other  global 
responses  -  such  as  the  U.S.  Inflation  Reduction  Act’s  provision  of  funds  for  energy  and  climate  programs,  including  the 
expansion  of  tax  credits  and  incentives  to  promote  clean  energy  technologies  (see  Table  6.3  “Recent  policy  changes  and 
announcements  regarding  electricity  supply,”  World  Economic  Forum),  and  an  apparent  shift  away  from  global  reliance  on 
Russian exports via government sanctions and other means - could materially benefit our business by creating additional market 
opportunities with utilities providers attempting to lessen their reliance on Russian markets. 

The  uranium  industry  also  potentially  faces  renewed  skepticism  and  distrust  as  a  result  of  Russia’s  invasion  of  Ukraine. 
According to the World Nuclear Association (“WNA”), “In the early hours of 4 March the Zaporizhzhia plant in southeastern 
Ukraine became the first operating civil nuclear power plant to come under armed attack. Fighting between forces overnight 
resulted in a projectile hitting a training building within the site of the six-unit plant. Russian forces then took control of the 
plant. The six reactors were not affected and there was no release of radioactive material. Since late October [2022], Russia has 
repeatedly  targeted  Ukraine’s  civilian  infrastructure,  including  the  country’s  energy  system,  with  missile  strikes.  Widespread 
blackouts  have  resulted,  and  external  power  supply  to  all  four  of  the  country’s  nuclear  plants  has  been  affected.”  (WNA, 
“Ukraine:  Russia-Ukraine  War  and  Nuclear  Energy,”  Feb.  6,  2023).  Russia’s  interference  with  Ukrainian  nuclear  plants  in 
violation of Article 56 of the Additional Protocol of 1979 to the Geneva Conventions, which states that nuclear power plants 
“shall not be made the object of attack, even where these objects are military objectives, if such an attack may cause the release 
of dangerous forces and consequent severe losses among the civilian population” (WNA, 2023), may result in increased and 
serious  harm  to  global  reception  to  nuclear  energy  due  to  the  current  war’s  proximity  to  Chrenobyl,  site  of  the  then-Soviet 
Union’s 1986 nuclear accident. 

To date, no changes in the Company’s internal control over financial reporting resulting from the Russian invasion of Ukraine 
and/or supply chain disruptions have been deemed necessary. 

56

The price of our Common Shares is subject to volatility.

Securities of mining companies have experienced substantial volatility and downward pressure in the recent past, often based 
on factors unrelated to the financial performance or prospects of the companies involved. These factors include macroeconomic 
conditions in North America and globally and market perceptions of the attractiveness of particular industries. The price of our 
securities is also likely to be significantly affected by short-term changes in uranium, vanadium, REE and HMC prices, changes 
in industry forecasts of uranium, vanadium, REE and HMC prices, other mineral prices including oil and natural gas, currency 
exchange fluctuation, or in our financial condition or results of operations as reflected in our periodic earnings reports. 

Other  factors  unrelated  to  our  performance  that  may  have  an  effect  on  the  price  of  our  securities  include  the  following:  the 
extent  of  research  coverage  available  to  investors  concerning  our  business  may  be  limited  if  investment  banks  with  research 
capabilities  do  not  follow  our  securities;  adverse  proxy  voting  recommendations  or  limited  portrayals  of  the  Company’s 
business,  operations  or  executive  compensation  practices  made  to  shareholders  by  shareholder  advisory  firms  resulting  from 
their  use  of  general-purpose  formulas  that  are  not  suited  to  the  Company’s  business,  operations  or  practices,  and  that  may 
counteract the Company’s substantive disclosures, which often include detailed analyses specific to the Company and which are 
capable of mitigating apparent market concerns; lessening in trading volume and general market interest in our securities may 
affect  an  investor’s  ability  to  trade  significant  numbers  of  our  securities;  the  size  of  our  public  float  and  the  exclusion  from 
market indices may limit the ability of some institutions to invest in our securities; and a substantial decline in the price of our 
securities  that  persists  for  a  significant  period  of  time  could  cause  our  securities  to  be  delisted  from  an  exchange,  further 
reducing market liquidity. Our exclusion from certain market indices may reduce market liquidity or the price of our securities. 

If an active market for our securities does not continue, the liquidity of an investor’s investment may be limited and the price of 
our securities may decline. If an active market does not exist, investors may lose their entire investment. As a result of any of 
these  factors,  the  market  price  of  our  securities  at  any  given  point  in  time  may  not  accurately  reflect  our  long-term  value. 
Securities class-action litigation often has been brought against companies in periods of volatility in the market price of their 
securities and following major corporate transactions or mergers and acquisitions. We may in the future be the target of similar 
litigation. Securities litigation could result in substantial costs and damages and divert management’s attention and resources.

The issuance of additional Common Shares may impact the trading price of our Common Shares.

In  times  of  depressed  commodity  prices,  the  Company  may  be  required  to  raise  additional  capital  to  meet  its  liquidity 
requirements, through the issuance of additional Common Shares under our ATM or otherwise, and/or dispose of assets. If we 
raise additional funding by issuing additional equity securities or securities convertible, exercisable or exchangeable for equity 
securities,  such  financing  may  substantially  dilute  the  interests  of  our  shareholders  and  reduce  the  value  of  their  investment. 
Similar dilution could result from the sale of assets to meet liquidity requirements.

We  are  subject  to  litigation  and  other  legal  proceedings  arising  in  the  normal  course  of  business  and  may  be  involved  in 
disputes with other parties in the future which may result in litigation.

The  causes  of  potential  future  litigation  and  legal  proceedings  cannot  be  known  and  may  arise  from,  among  other  things, 
business activities, environmental laws, permitting and licensing activities, volatility in stock prices or alleged failure to comply 
with  disclosure  obligations.  The  results  of  litigation  and  proceedings  cannot  be  predicted  with  certainty  and  may  include 
injunctions pending the outcome of such litigation and proceedings. Failure to resolve any such disputes favorably may have a 
material adverse impact on our financial performance, cash flow and results of operations.

If we fail to maintain an effective system of internal controls, we may not be able to accurately report financial results and/
or prevent fraud.

Internal controls over financial reporting are procedures designed to provide reasonable assurance that transactions are properly 
authorized, assets are safeguarded against unauthorized or improper use, and transactions are properly recorded and reported. 
Disclosure controls and procedures are designed to ensure that information required to be disclosed by a company in reports 
filed with securities regulatory agencies is recorded, processed, summarized and reported on a timely basis and is accumulated 
and communicated to a company’s management, including its chief executive officer and chief financial officer, as appropriate, 
to  allow  timely  decisions  regarding  required  disclosure.  A  control  system,  no  matter  how  well  designed  and  operated,  can 
provide only reasonable, not absolute, assurance with respect to the reliability of reporting, including financial reporting and 
financial statement preparation.

57

None.

ITEM 1B. UNRESOLVED STAFF COMMENTS

ITEM 1C. CYBERSECURITY

The  Company  maintains  a  cyber  risk  management  program  designed  to  identify,  assess,  manage,  mitigate  and  respond  to 
cybersecurity  threats.  This  program  is  integrated  within  the  Company’s  enterprise  risk  management  program.  The  Company 
regularly  assesses  the  threat  landscape  and  takes  a  holistic  view  of  cybersecurity  risks,  with  a  layered  cybersecurity  strategy 
based on prevention, detection and mitigation. The Company has appointed an interdisciplinary team to oversee cybersecurity 
at  the  management  level,  as  a  part  of  which  it  reviews  all  enterprise-level  cybersecurity  risks  at  least  annually,  or  more 
frequently  as  needed.  Key  cybersecurity  risks,  including  cybersecurity  threats  associated  with  the  use  of  third-party  service 
providers, are incorporated into the Company’s enterprise risk management process as needed. Additionally, the Company has 
implemented  numerous  IT  policies  and  procedures  concerning  cybersecurity  matters,  which  include  policies  that  directly  or 
indirectly  relate  to  encryption  standards,  antivirus  protection,  remote  access,  multi-factor  authentication,  confidential 
information and the use of the internet, social media, email and wireless and personal devices for both Company business and 
personal matters while utilizing Company resources, among other relevant topics. These policies go through an internal review 
process  on  a  periodic  basis  and  are,  if  needed,  updated  and  re-approved  by  the  appropriate  members  of  management.  In 
addition, the Company’s Cybersecurity Policy, which is maintained on a confidential basis to protect some of the more sensitive 
aspects of the Company’s cybersecurity protections in place, is reviewed and approved annually by both the Audit Committee 
and the full Board of Directors. Employees receive training, as appropriate, on these policies.

The  underlying  controls  of  the  cyber  risk  management  program  are  based  on  recognized  best  practices  and  standards  for 
cybersecurity and information technology, including the National Institute of Standards and Technology (“NIST”), the Center 
for  Internet  Security  Benchmark  (“CIS”)  and  Service  Organization  Controls  Types  1  and  2  of  the  American  Institute  of 
Certified Public Accountants (“SOC”). 

The  Company  has  expanded  investments  in  IT  security,  including  additional  end-user  training,  using  layered  defenses, 
identifying and protecting critical assets, and strengthened its monitoring and alerting activities. Additionally, the Company has 
engaged  an  independent,  third-party  expert  consultant  to  assess  and  analyze  the  Company’s  enterprise  cybersecurity, 
governance,  risk  and  compliance  operations  and  programs  against  the  NIST  and  CIS  frameworks.  The  third-party  consultant 
tests the Company’s defenses by performing simulations and drills at both a technical level (including through penetration tests) 
and by reviewing its operational policies and procedures. These tests and assessments are useful tools for maintaining a robust 
cybersecurity program to protect our investors, customers, employees, vendors, and intellectual property. These tests serve as 
the foundation for the Company’s three-year plan to further enhance its cyber infrastructure.

The Company established its interdisciplinary team to monitor and assess cybersecurity risks on an ongoing basis, which is led 
by  the  Company’s  Chief  Financial  Officer.  It  is  a  cross-departmental  team  that  consists  of  legal,  finance,  internal  audit  and 
operations personnel, with all significant implementation efforts executed by our IT Manager, who has more than 20 years of 
experience  in  IT,  enterprise  security  and  cyber  risk  management,  with  support  from  the  Company’s  third-party  expert 
consultant,  as  needed.  This  team  is  in  charge  of  developing,  maintaining  and  measuring  compliance  with  the  cyber  risk 
management program, and dedicates significant resources to cybersecurity and risk management processes to adapt to the ever-
changing cybersecurity landscape and to respond to emerging threats in a timely and effective manner. 

The Company utilizes a sophisticated network monitoring service as a first line of defense for potential cybersecurity incidents, 
which is supplemented by employee training to ensure internal responsiveness where an incident may first be detected. When a 
potential incident is first detected, the matter is communicated the IT Manager as soon as possible so that the Company may 
work quickly and diligently to re-secure its systems and work to minimize any damage and further risk to the Company as a 
result  thereof;  to  this  end,  a  monitored  email  address  dedicated  solely  to  the  reporting  of  such  incidents  is  in  place.  Upon 
receipt,  the  IT  Manager  is  charged  with  immediately  investigating  the  report  to  ensure  the  existence  or  possibility  of  a 
cyberattack  and  employs  every  effort  toward  thwarting  or  limiting  a  cyberattack,  if  ongoing,  to  the  fullest  extent  possible  to 
avoid  further  damage  and  exposure  to  the  Company  and  its  systems.  As  soon  as  an  immediate  threat  or  cyberattack  is 
sufficiently contained to permit it, the IT Manager notifies designated executive officers of the situation, who are charged to 
direct the IT Manager on any additional or special measures to be taken, including but not limited to a Company-wide alert or 
directive, which the IT Manager must follow/implement without delay. Questions or concerns relating to a directive’s validity 
may be confirmed only by the IT Manager or a designated executive officer through a known form of contact not questionably 
in breach. As soon as reasonably practicable after response efforts commence, the designated executive officers are required to 
notify the Chair of the Audit Committee of the situation and to thereafter keep the Chair apprised of all material developments, 

58

who may escalate the matter to the full Board in the Chair’s discretion. The Company’s emergency response plan also sets forth 
the  Company’s  procedures  for  a  transition  back  into  normal  work  practices,  as  well  as  security  incident  investigation, 
remediation procedures, security incident recovery and mandatory reporting.

The  Audit  Committee  has  been  delegated,  by  and  on  behalf  of  the  Board  of  Directors,  direct  and  primary  oversight  of  the 
Company’s  cybersecurity  risk  exposures  and  the  steps  taken  by  management  to  monitor,  mitigate  and  manage/respond  to 
cybersecurity risks and incidents. The CFO, together with the appropriate members from the Company’s interdisciplinary team 
as  needed,  brief  the  Audit  Committee  on  the  effectiveness  of  the  Company’s  cyber  risk  management  program  on  at  least  a 
quarterly  basis,  or  more  frequently  as  needed  basis  on  a  wide  range  of  topics,  including  recent  developments,  evolving 
standards,  vulnerability  assessments,  third-party  and  independent  reviews,  the  threat  environment,  technological  trends  and 
information security considerations arising with respect to the Company, its peers and third parties. In addition, cybersecurity 
risks  are  reviewed  by  the  Board  of  Directors,  at  least  annually,  as  part  of  the  Company’s  corporate  enterprise  risk  mapping 
exercise. The Board and the Audit Committee also receive prompt and timely information regarding any cybersecurity incident 
that  meets  the  SEC,  OSC  and  stock  exchange-established  reporting  thresholds,  as  well  as  ongoing  updates  and  follow-up 
disclosures regarding any such incident until it has been wholly addressed and remediated.

The Company faces risks from “cybersecurity threats” (as defined in Item 106(a) of Regulation S-K) that could have a material 
adverse  effect  on  its  business,  financial  condition,  results  of  operations,  cash  flows  or  reputation.  The  Company  has 
experienced, and will continue to experience, immaterial “cybersecurity incidents” (as defined in Item 106(a) of Regulation S-
K) in the ordinary course of its business. However, prior cybersecurity incidents have not had, and are not reasonably likely to 
have, a material adverse effect on the Company’s business, financial condition, results of operations, or cash flows. See “Part I, 
Item 1A. Risk Factors – An information security incident, including a cybersecurity breach, could have a negative impact to the 
Company’s business or reputation.”

59

ITEM 2. DESCRIPTION OF PROPERTIES

60

Overview

Energy  Fuels  is  a  leading  U.S.-based  critical  minerals  company.  The  Company  mines  uranium  and  produces  natural  uranium 
concentrates that are sold to major nuclear utilities for the production of carbon-free nuclear energy. Energy Fuels recently began 
production of mixed RE Carbonate, an advanced REE material at the White Mesa Mill and plans to produce commercial quantities 
of  separated  REE  oxides  at  the  White  Mesa  Mill  in  2024.  Energy  Fuels  also  produces  vanadium  from  certain  of  its  projects,  as 
market  conditions  warrant,  and  is  evaluating  the  recovery  at  the  Mill  of  radionuclides  needed  for  emerging  cancer  treatments. 
Energy  Fuels  holds  two  of  America's  key  uranium  production  centers:  the  White  Mesa  Mill  in  Utah  and  the  Nichols  Ranch  ISR 
Project in Wyoming. In 2023, the Company acquired the Bahia Project in Brazil, which is believed to have significant quantities of 
titanium (ilmenite and rutile), zirconium (zircon) and REE (monazite) minerals.

ISR Uranium Activities

The Company conducts its ISR recovery activities through its Nichols Ranch Project in northeast Wyoming, which it acquired in 
June 2015 through the acquisition of Uranerz.

The  Nichols  Ranch  Project  includes:  (i)  the  Nichols  Ranch  Plant  (100%  ownership);  (ii)  the  Nichols  Ranch  Wellfields  (100% 
ownership); (iii) the Jane Dough Property (81% ownership); (iv) the Hank Project (100% ownership), which includes the permitted 
but not constructed Hank Satellite Plant; (v) North Rolling Pin (100% ownership); and (vi) West North Butte (100% ownership). 
See  “The  Nichols  Ranch  ISR  Project.”  The  Company  also  acquired  through  the  acquisition  of  Uranerz  the  Reno  Creek  Property 
(which it has since sold) and the Arkose Mining Venture, a joint venture of ISR properties held 81% by Energy Fuels. See “Non-
Material Mineral Properties - Other ISR Projects.” Production from existing wellfields at Nichols Ranch was depleted during 2021. 
In order for Nichols Ranch to engage in future uranium production, the Company will need to incur capital expenditures to develop 
additional  wellfields.  While  production  at  the  Nichols  Ranch  Project  is  currently  being  maintained  on  standby,  the  Company  is 
undertaking exploration and development activities to expand the resources at the Nichols Ranch Project and to further develop a 
wellfield to be ready for potential recommencement of production in late 2024 or in 2025.

Alta Mesa Transaction and Assignment of Convertible Note

On  February  14,  2023,  the  Company  closed  on  its  sale  to  enCore  of  three  wholly-owned  subsidiaries  that  together  held  the  Alta 
Mesa ISR Project for total consideration of $120 million (the “Alta Mesa Transaction”), paid as follows:

•
•

$60 million in cash, which included $6 million prior to closing and $54 million at closing; and
$60 million Convertible Note, payable in two years from the closing, bearing annual interest of eight percent (8%). The 
Convertible Note was convertible at Energy Fuels’ election into fully paid and non-assessable enCore common shares at a 
conversion  price  of  $2.9103  per  share,  being  a  20%  premium  to  the  10-day  volume-weighted  average  price  of  enCore 
shares ending the day before the Closing. The Convertible Note was guaranteed by enCore and fully secured by Alta Mesa. 
Except in the instance of a block trade or similar distribution to sell the enCore common shares received on conversion of 
the Convertible Note, Energy Fuels was limited to selling a maximum of $10 million of enCore common shares per thirty 
(30)-day period.

As a post-closing condition of the Alta Mesa Transaction, enCore was required to replace the $3.59 million of reclamation bonds 
then in place for Alta Mesa. Upon replacement, the original bonds were released and the Company received back the underlying 
collateral during the year ended December 31, 2023. 

Then,  on  November  13,  2023,  the  Company  announced  that,  on  November  9,  2023,  it  sold  to  MMCAP  International  Inc.  SPC 
(“MMCAP”)  the  remaining  unpaid  balance  of  $20  million  owed  under  the  secured  Convertible  Note  issued  to  the  Company  by 
enCore for total consideration of $21 million plus $1.5 million in unpaid accrued interest, less a sales commission of $100,000 paid 
to a third-party broker. As disclosed in the Company’s Form 10-Q for the quarter ended September 30, 2023, enCore previously 
paid $40 million toward the $60 million principal Convertible Note balance and $1.8 million of interest to the Company in partial 
fulfillment of its obligations under the Convertible Note. As a result of enCore’s earlier pay-down and the $22.4 million received in 
connection with the Convertible Note’s sale, the Company has now received payment in full for the Alta Mesa Transaction, and no 
further consideration is owed in connection therewith.

Conventional Uranium Activities

The  Company  conducts  its  conventional  uranium  extraction  and  recovery  activities  through  its  100%  owned  White  Mesa  Mill, 
which is the only operating conventional uranium mill in the U.S. The Mill, located near Blanding, Utah, is centrally located such 
that  it  can  be  fed  by  a  number  of  the  Company’s  uranium  and  uranium/vanadium  projects  in  Colorado,  Utah,  Arizona  and  New 

61

Mexico, as well as by ore purchase or toll milling arrangements with third party miners in the region, as market conditions warrant. 
The  Company  also  owns  the  Sheep  Mountain  Project  in  Wyoming,  which  is  a  conventional  uranium  project.  Due  to  its  distance 
from  the  White  Mesa  Mill,  the  Sheep  Mountain  Project  is  not  expected  to  be  a  source  of  feed  material  for  the  Mill.  The  Sheep 
Mountain Project consists of the Sheep Mountain Extraction Operation (both open pit and underground), which is permitted, and the 
proposed Sheep Mountain Processing Operation (heap leach), which is not permitted at this time.

The Company’s principal conventional uranium properties include the following:

•
•
•
•
•
•
•

•

the White Mesa Mill (see “The White Mesa Mill”);
the Pinyon Plain Project (see “The Pinyon Plain Project”);
the Roca Honda Project (see “The Roca Honda Project”);
the Sheep Mountain Project (see “The Sheep Mountain Project”);
the Bullfrog Project (see “The Bullfrog Project”);
the La Sal Project (see “The La Sal Project”); 
the Arizona Strip uranium properties located in north-central Arizona, including: the Arizona 1 Project, the Wate Project, 
and EZ Project (see “Non-Material Mineral Properties – Other Conventional Projects – Arizona Strip”); and
the  Whirlwind  Project  located  in  southwest  Colorado  on  the  Colorado  and  Utah  border  (see  “Non-Material  Mineral 
Properties – Other Conventional Projects – Colorado Plateau”). 

The Company has a 100% interest in all these conventional properties.

The  Mill  is  licensed  to  process  2,000  tons  of  mineralized  material  per  day.  It  is  primarily  a  uranium  recovery  facility  that  mills 
uranium mineralized materials from the Company’s uranium mines on the Colorado Plateau as well as ore purchased or toll milled 
from  third  party  miners  in  the  region,  as  market  conditions  warrant.  In  addition,  the  Mill  can  recycle  other  uranium-bearing 
materials  not  derived  from  natural  or  native  ore,  known  as  Alternate  Feed  Materials,  for  the  recovery  of  uranium,  alone  or  in 
combination with other metals. In this regard, the Company is currently evaluating a number of potential Alternate Feed Materials 
for  the  recovery  of  uranium.  The  Mill  is  also  pursuing  other  opportunities  to  process  mineralized  materials  from  the  clean-up  of 
abandoned  uranium  mines  on  the  Navajo  Reservation  and  in  the  Four  Corners  area  of  the  U.S.  Energy  Fuels  recently  began 
production of mixed RE Carbonate, an advanced REE material, at the White Mesa Mill, and plans to produce commercial quantities 
of  separated  REE  oxides  at  the  White  Mesa  Mill  in  2024.  Energy  Fuels  also  produces  vanadium  from  certain  of  its  projects,  as 
market conditions warrant, and is evaluating the recovery at the Mill of radionuclides needed for emerging cancer treatments. 

The material projects are shown on the map above and are described in further detail below. Properties that the Company does not 
consider material are summarized at the end of this Item 2.

Conventional Activities (Other)

Bahia Project

On  February  10,  2023,  the  Company  acquired  17  Agencia  Nacional  de  Mineracao  (“ANM”)  Process  Areas  totaling  15,089.71 
hectares  in  the  state  of  Bahia,  Brazil  comprising  the  Bahia  Project.  The  primary  minerals  associated  with  the  Bahia  Project  are 
ilmenite, rutile, zircon and monazite. See “Bahia Project,” below. The Company acquired the Bahia Project to expand its in-ground 
holdings of monazite for REE processing at the Mill. See Item I, “Material Transactions” above and Item 2, “The Bahia Project” 
below.  Under  S-K  1300  regulations,  Bahia  Project  is  an  exploration  stage  property  because  there  are  no  Mineral  Resources  or 
Mineral Reserves disclosed for the property.

In 2024, the Company plans to initiate permitting activities, finish phase I of drilling (2,250 meters) and initiate phase II drilling on 
the Bahia Project, which is expected to provide the necessary data to disclose Mineral Resources on a portion of the project.

Uranium, Vanadium and Rare Earth Recovery History

The  following  tables  show  the  mineralized  material  processed  and  pounds  of  uranium  and  vanadium  and  total  rare  earth  oxides 
recovered from the Company’s projects and facilities from January 1, 2019 to December 31, 2023:(1)

62

Recovery History (1)

Project or Source

2023

2022

2021

2020

2019

Alternate Feed Materials(2)

Tons (000)

 Ave. % U3O8

Recovered Pounds U3O8 (000)

Tailings Solution Recycle & Production from In-Circuit Material(4)

Recovered Pounds U3O8 (000)

Recovered Pounds V2O5 (000)

Recovered Metric Tons Total Rare Earth Oxide (TREO)

Conventional Feed Materials(5)

---

---

---

---

---

---

Tons (000)

326

Contained Grade % U3O8

0.46

Recovered Pounds U3O8 (000)(6)

Recovered Pounds V2O5 (000)

---

---

Recovered Metric Tons Total Rare Earth Oxide (TREO)

260

3

3.3

161

---

---

---

0.1

0.5

1

---

95

---

---

---

---

---

0

---

---

---

---

120

NA(2)

NA(2)

144(3)

47

67

---

--- 

 ---

 ---

---

---

Nichols Ranch(7)

Alta Mesa(8)

Recovered Pounds U3O8 (000)

0.2

0.5

0.5

6

Recovered Pounds U3O8 (000)

Total Pounds of U3O8 Recovered (000)

Total Pounds of V2O5 Recovered (000)

Total Metric Tons of TREO Recovered

Notes:

---

0.2

---

260

---

162

---

95

---

---

---

120

---

197

67

---

NA(2)

NA(2)

---

---

1,807

---

---

---

---

---

---

70

---

70

1807

---

(1)    Mineralized  material  is  shown  as  being  processed  and  pounds  recovered  during  the  year  in  which  the  materials  were 
processed at the Mill or at the Nichols Ranch Plant, which is not necessarily the year in which the materials were extracted from 
the project facilities.
(2)  All Alternate Feed Materials were processed at the Mill. A number of different Alternate Feed Materials were processed 
during the period 2019 – 2023. The table shows the average uranium grades and the total pounds recovered from all Alternate 
Feed  Materials  processed  at  the  Mill  during  each  of  the  years  in  that  period.  Because  of  the  variability  in  uranium  grades, 
pounds recovered is considered to be the relevant metric and tons fed is not considered to be relevant.
(3) The 161,000 pounds recovered in 2022 include nil pounds recovered for the accounts of third parties. The 144,000 pounds 
recovered in 2020 include nil pounds recovered for the accounts of third parties. 
(4)  Pounds contained in tailings solutions containing previously unrecovered uranium and vanadium, together with in-circuit 
mineralized material from previous conventional mine material processing, were recovered at the Mill, though tons and grade 
are not available because they cannot be tied to any specific source.
(5)  Includes uranium and TREO recovered from monazite processing.
(6) The 1,000 pounds of the 162,000 pounds of U3O8 packaged in 2022 is uranium recovered from monazite processing in 2021 
and 2022. This amount does not include an additional approximately 1,000 pounds of U3O8 recovered during 2021 and 2022, 
which was in process and not packaged as of December 31, 2022. All uranium recovered from monazite processing in 2021 was 
retained  in  process  and  not  packaged  in  2021.  A  portion  of  uranium  recovered  in  2021  was  packaged  in  2022,  with  the 
remainder held in process as at December 31, 2022. The uranium concentration of monazite is comparable to typical Colorado 

63

Plateau conventional ores processed at the Mill on a regular basis. The relatively small quantities of uranium recovered from the 
monazite processed in 2021 and 2022 is a reflection of the low tonnage of monazite processed through the Mill during those 
years.
(7) Uranium recovery commenced at the Nichols Ranch Project on April 17, 2014. Because the Nichols Ranch Project uses ISR 
instead of conventional extraction methods, grade and tons of mineralized material are inapplicable to it. 
(8) The Alta Mesa Project was sold by the Company on February 14, 2023.

Mineral Extraction

The following table shows the extraction history from 2019 to December 31, 2023 from the mineral properties currently owned by 
the Company:

Project(1)

2023

2022

2021

2020

2019

Nichols Ranch

Notes:

Pounds U3O8 (000)

0.2

0.5

0.5

6

70

(1)  All properties reported in this table were owned by the Company on December 31, 2023 and continue to be owned by the 
Company.  Nichols  Ranch  was  acquired  by  the  Company  in  June  2015  as  part  of  the  Uranerz  acquisition.  Properties  sold  or 
otherwise disposed of are not included in this table. Uranium pounds recovered since 2021 are immaterial and correspond to 
pounds captured during standby. 

Summary of Mineral Reserves and Resources

Daniel  Kapostasy,  a  Professional  Geologist  licensed  in  Wyoming  (PG-6778)  and  in  Utah  (10110615-2250),  employed  as  the 
Company’s  Vice  President,  Technical  Services,  is  the  Qualified  Person  responsible  for  the  disclosure  of  scientific  or  technical 
information concerning mineral projects in this Annual Report. Except to the extent explicitly stated, the land tenure and permitting 
efforts disclosed in this Part I, Item 2 are not made in reliance on or with reference to any of the technical reports or the preliminary 
feasibility study referenced herein and attached hereto as Exhibits 96.1 through 96.7 and are the responsibility of Daniel Kapostasy 
in his capacity as a Qualified Person.

The  following  tables  show  the  Company’s  estimate  of  Mineral  Reserves  and  Mineral  Resources  as  defined  in  S-K  1300  and  NI 
43-101  as  of  December  31,  2023.  Both  S-K  1300  and  NI  43-101  require  mineral  companies  to  disclose  Mineral  Reserves  and 
Mineral Resources using the subcategories of Proven Mineral Reserves, Probable Mineral Reserves, Measured Mineral Resources, 
Indicated  Mineral  Resources  and  Inferred  Mineral  Resources.  The  Company  reports  Mineral  Resources  exclusive  of  Mineral 
Reserves. Except as stated below, the Mineral Reserve and Mineral Resource information shown below, which was reviewed and 
approved by Daniel Kapostasy, one of the Company’s non-independent Qualified Persons, is as reported in the various Technical 
Report  Summaries  prepared  in  accordance  with  S-K  1300  and  NI  43-101  (the  “Technical  Report  Summaries”)  by  Qualified 
Persons employed by SLR International Corporation (“SLR”), Woods Process Services, Consultants in Hydrogeology, Gochnour & 
Associate,  Inc.  and  BRS  Inc.  (“BRS”),  none  of  which  is  affiliated  with  the  Company  or  any  other  entity  that  has  an  ownership, 
royalty, or other interest in the relevant property that is the subject of the Technical Report Summary. See “Material Properties.” 
Between December 31, 2022 and December 31, 2023, there were no changes to the Mineral Reserves or Mineral Resources. The 
Alta Mesa Project was sold on February 14, 2023, thus all Mineral Resources associated with that project have been removed from 
this disclosure along with the description of the Alta Mesa Project from the “Material Properties” section of this Annual Report.

Project 
Sheep Mountain (Congo 
Pit)(2)
Sheep Mountain 
(Underground)(3)
Pinyon Plain(4)(5)(6)(7)
Total Mineral Reserves

Mineral Reserve Estimates - In Situ Uranium(1)(8)(9)(10)(11)

Proven Mineral Reserves

Probable Mineral Reserves

Grade       

Tons (000s)
---

(% eU3O8)
---

Pounds 
(000s 
eU3O8)
---

Tons (000s)
3,498 

Grade       

(% eU3O8)

0.132  

Pounds 
(000s 
eU3O8)
9,248 

Metallurgical 
Recovery
 91.9 %

---

7.8

---

0.33

---

50.8
50.8

64

3,955 

0.115  

9,117 

 91.9 %

126.7   

0.60   

1,517 
19,882 

 96 %

 
 
 
 
Notes:

(1)  The Mineral Reserve estimates in this table comply with the requirements of both S-K 1300 and NI 43-101.
(2)  Mineral Reserves are estimated at a uranium grade x thickness (G.T.) cut-off grade of 0.10 G.T. (2 ft. of 0.05% eU3O8) for 
the Congo Pit.
(3) Mineral Reserves are estimated at a uranium grade x thickness (G.T.) cut-off grade of 0.45 G.T. (6 ft. of 0.075% eU3O8) for 
Sheep Underground.
(4)  Underground  Mineral  Reserves  were  estimated  by  creating  stope  shapes.  The  stope  shapes  were  created  using  a  grade 
envelope of 0.15% U3O8, with a minimum mining width of 5 ft (including hanging wall and footwall dilution), on 10 ft vertical 
stope heights. and 0.45 G.T. (6 ft. of 0.075% eU3O8) for Sheep Underground.
(5) The breakeven cut-off grade is 0.30% U3O8.
(6) A mining extraction factor of 95% was applied to the underground stopes, while underground development assumed a 100% 
mining extraction factor.
(7) The density varies according to the block model.
(8) Mineral Reserves are estimated using a long-term uranium price of $65 per pound U3O8 for Sheep Mountain and a uranium 
price  of  $60  per  pound  for  Pinyon  Plain.  The  long-term  uranium  price  for  Sheep  Mountain  is  based  on  supply  and  demand 
projections for the period 2021-2035. The uranium price for Pinyon Plain is based on anticipated spot prices from 2023-2035. 
(9) Numbers may not add due to rounding.
(10) The Mineral Reserves are fully excluded from the total Mineral Resources shown below. 
(11) Mineral Reserves are 100% attributable to the Company.

Mineral Resource Estimates – In Situ Uranium(1)(2)(3)(4)(10)

Measured Mineral 
Resources

Indicated Mineral 
Resources

Measured + Indicated

Inferred Mineral 
Resources

Project

Tons 
(000s)

Grade     
(% 
eU3O8)

Pounds 
(000s 
eU3O8)

Tons 
(000s)

Grade     
(% 
eU3O8)

Pounds 
(000s 
eU3O8)

Tons 
(000s)

Grade 
(% 
eU3O8)

Pounds 
(000s 
eU3O8)

Tons 
(000s)

Grade     
(% 
eU3O8)

Pounds 
(000s 
eU3O8)

Metallurgical  

Recovery

ISR Properties

Nichols 
Ranch(5)

11 

0.187  

41 

  2,924 

0.106   6,142    2,935    0.106    6,183 

614 

0.097   1,176 

71% (measured) 

60.4% (indicated/
inferred)

ISR Subtotal

41 

  6,142 

  6,183 

  1,176 

Conventional Properties

Pinyon 
Plain(6)(7)

---

---

---

37

0.95  

703   

37 

0.95  

703 

5

0.50  

48 

 96 %

Roca Honda

208

0.48   1,984 

  1,639 

0.48   15,638    1,847 

0.48   17,622 

  1,513 

0.46   13,842 

 95 %

Sheep 
Mountain(8)

Bullfrog

La Sal(9)

Conventional 
Subtotal

Total Mineral 
Resources

Notes:

---

---

---

---

---

---

---

  4,210 

0.11   9,570    4,210 

0.11   9,570 

---

---

---

 91.9 %

---

  1,560 

0.29   9,100    1,560 

0.29   9,100 

410

0.25   2,010 

---

---

---

---

---

---

---

823

0.26   4,281 

 95 %

 96 %

  1,984 

  35,011 

  36,995 

  20,181 

  2,025 

  41,153 

  43,178 

  21,357 

(1) The Mineral Resource estimates in this table comply with the requirements of both S-K 1300 and NI 43-101.
(2) Mineral Resources were estimated at various %eU3O8 or G.T. cut-off grades. Nichols Ranch 0.02% U3O8 (0.20 GT), Pinyon 
Plain  0.30%  (Uranium  Only)  and  0.40%  (Uranium  +  Copper)  eqv.  U3O8,  Roca  Honda  0.19%  U3O8,  Sheep  Mountain  0.05% 
U3O8 (0.10 GT Open Pit) and 0.05% U3O8 (0.3 GT Underground), Bullfrog 0.165% U3O8 (0.50 GT), and La Sal 0.17% U3O8. 

65

 
 
 
 
 
(3)  Mineral  Resources  were  estimated  using  a  long-term  uranium  price  of  $65/lb.  The  long-term  uranium  price  for  Sheep 
Mountain is based on supply and demand projections for the period 2021-2035. 
(4) Numbers may not add due to rounding.
(5) The Nichols Ranch Project is comprised of four properties: Nichols Ranch, the Hank Property, the Jane Dough Property, 
and  North  Rolling  Pin.  The  numbers  shown  represent  Energy  Fuels’  share  of  the  Nichols  Ranch  Project,  which  is  less  than 
100% due to a portion of the Jane Dough Property being held through the Arkose Mining Venture, in which the Company has 
an 81% interest. For more information, see “The Nichols Ranch Project,” below. 
(6) The name of the Canyon Project was changed to “Pinyon Plain Project” in 2020.
(7) The Pinyon Plain Measured and Indicated Mineral Resources exclude the Proven and Probable Mineral Reserves calculated 
in accordance with S-K 1300 and NI 43-101 of 1,567,800 pounds of U3O8 in 134,500 tons at a grade of 0.58%.
(8) The Sheep Mountain Indicated Mineral Resource excludes the Probable Mineral Reserves calculated in accordance with S-
K 1300 and NI 43-101 of 18,365,000 pounds of eU3O8 in 7,453,000 tons at a grade of 0.123%.
(9) The La Sal Project includes the Energy Queen, Redd Block, Beaver, and Pandora properties.
(10) Except for Nichols Ranch (see note 5), Mineral Resources are 100% attributable to the Company.

Mineral Resource Estimate – In Situ Vanadium(1)(2)(3)(4)(5)(6)(7)(8)(9)

Measured Mineral Resources   Indicated Mineral Resources  
Pounds 
V2O5 
(000)

Pounds 
V2O5 
(000)

Grade     

Grade     

Tons 
(000)
---

% V2O5
---

---  

Tons 
(000)
---

% V2O5
---

---  

Inferred Mineral Resources

Tons 
(000)
823

Grade     

% V2O5

 1.08 %  

Pounds 
V2O5 
(000)
17,746 

Metallurgical 
Recovery
 75  %

---

---

---  

---

---

---  

823

---  

17,746 

 75 %

La Sal(6)
Total 
Mineral 
Resources 
(V2O5)
Notes:

(1) Both S-K 1300 and NI 43-101 definitions were followed for all Mineral Resource categories.
(2) Mineral Resources were estimated at a %U3O8 or G.T. cut-off grade of 0.17%.
(3) The cut-off grade is calculated using a metal price of $65/lb. U3O8. The long-term uranium price is based on supply and 
demand projections for the period 2021-2035. 
(4) No minimum mining width was used in determining Mineral Resources. 
(5) Mineral Resources are based on a tonnage factor of 14.5ft3/ton (Bulk density 0.0690 ton /ft3 or 2.21 t/m3).
(6) Mineral Resources are not Mineral Reserves and do not have demonstrated economic viability.
(7) Total may not add due to rounding.
(8) Mineral Resources are 100% attributable to the Company.
(9) The La Sal Project includes the Energy Queen, Red Block, Beaver and Pandora properties.

Measured Mineral Resources

Mineral Resource Estimate – In Situ Copper(1)(2)(3)(4)(5)(6)(7)(8)
  Indicated Mineral Resources  

Inferred Mineral Resources

Tons 
(000)

Grade     
% Cu

Pounds 
Cu (000)

Tons 
(000)

Grade     
% Cu

Pounds  

Cu (000)

Tons 
(000)

Grade     
% Cu

Pounds  

Cu (000)

Metallurgical 
Recovery

Pinyon 
Plain
Total 
Mineral 
Resources 
(Cu)

Notes:

6

9.6%  

1,155   

90

5.9%  

10,553   

4

6.5%

470

 90 %

1,155     

10,553     

470

NA

(1) The Mineral Resource estimates in this table comply with the requirements of both S-K 1300 and NI 43-101. 
(2) For the Main and Juniper zones of the Pinyon Plain Project, a 0.40% uranium equivalent cut-off grade (% U3O8 Eq) was 
applied to account for both the copper and uranium mineralization. The %U3O8 Eq grade term is not the same as the eU3O8 % 
grade term with indicates probe rather than assay data listed elsewhere in this report. See the Pinyon Plain Project.
(3)  Mineral  Resources  are  estimated  using  a  long-term  uranium  price  of  $65  per  pound  and  a  Copper  price  of  $4.00  per  lb. 
These  prices  are  based  on  independent,  third-party,  and  market  analysts’  average  forecasts  as  of  2022,  and  the  supply  and 
demand projections are for the period 2023 to 2035. 
(4) A copper to U3O8 conversion factor of 18.19 was used for converting copper grades to equivalent U3O8 grades (U3O8 Eq) 
for cut-off grade evaluation and reporting.
(5) Numbers may not add due to rounding.

66

 
 
 
 
 
 
 
 
(6)  For  the  Pinyon  Plain  Project,  Mineral  Resource  tonnages  of  uranium  and  copper  cannot  be  added  as  they  overlap  in  the 
Main and Main-Lower Zones.
(7) The name of the Canyon Project was changed to “Pinyon Plain Project” in 2020. 
(8) Mineral Resources are 100% attributable to the Company.

67

The Nichols Ranch Project 

MATERIAL PROPERTIES

The  following  technical  and  scientific  description  of  the  Nichols  Ranch  Project  is  based  in  part  on  the  report  titled  “Technical 
Report  on  the  Nichols  Ranch  Project,  Johnson  and  Campbell  Counties,  Wyoming,  USA”  dated  February  22,  2022  and  effective 
December  31,  2021,  as  amended  February  8,  2023,  and  prepared  by  Grant  A.  Malensek,  M.Eng.,  P.  Eng.,  Mark  B.  Mathisen, 
C.P.G.,  Jeremy  Scott  Collyard,  PMP,  MMSA  QP,  each  a  Qualified  Person  employed  by  SLR,  Jeffrey  L.  Woods,  MMSA  QP,  a 
Qualified  Person  employed  by  Woods  Process  Services,  and  Phillip  E.  Brown,  C.P.G.,  R.P.G.,  a  Qualified  Person  employed  by 
Consultants In Hydrogeology (the “Nichols Ranch Technical Report Summary”). The Nichols Ranch Technical Report Summary 
was prepared in accordance with S-K 1300 and also constitutes a PEA pursuant to NI 43-101. The Nichols Ranch Project does not 
have known “Mineral Reserves” and is therefore considered under SEC S-K 1300 definitions to be an exploration stage property, 
despite commercial uranium extraction activities occurring as recently as 2019 (with de minimis levels of extraction more recently).

Property Description

The Nichols Ranch Uranium Complex (the “Complex”) is an existing ISR mine with associated prospective ISR properties located 
in Campbell and Johnson Counties, in eastern Wyoming, USA in the Pumpkin Buttes Mining District of the Powder River Basin, 80 
miles  northeast  of  the  city  of  Casper,  Wyoming.  The  Complex  is  located  approximately  at  latitude  43°42'  North  and  longitude 
106°01' West. The proposed Nichols Ranch Project will produce approximately 366 lb of U3O8 annually. The Complex is an ISR 
project; it is not an underground or open pit project. 

68

Excluding the Jane Dough area in which the Company owns an 81% interest, the Company owns a 100% interest in the remaining 
areas which comprise the Complex land holdings totaling 10,755 acres.

The Complex is divided into two primary areas, the Nichols Ranch Mining Unit and the Satellite Properties.
The Nichols Ranch Mining Unit includes the following:

a. Nichols Ranch Area (approximately 1,120 acres)
Jane Dough Area (approximately 3,680 acres)
b.
c. Hank Area (approximately 2,250 acres)

Nichols Ranch and Jane Dough are contiguous, and the Hank area is located approximately six miles north of Nichols Ranch.

The  Company  currently  controls  four  additional  properties  (the  Satellite  Properties)  which  are  known  to  have  significant 
mineralization, but not currently included in the mine permit. These include:

a. North Rolling Pin (NRP) Area (approximately 1,180 acres)
b. West North Butte (WNB) Area (approximately 2,360 acres)
c. East North Butte (ENB) Area (approximately 325 acres)
d. Willow Creek (WC) Area (approximately 220 acres)

69

Ownership

Except  where  noted  in  the  individual  sections  below,  all  mineral  rights  associated  with  the  Project  including  claims,  surface  use 
agreements, mineral leases, etc. were acquired through the acquisition of Uranerz in 2015. Annual land holding fees associated with 
the Projects for 2023 totaled $770,000. Details of property ownership are described below by project area.

Nichols Ranch

The permit boundary for the Nichols Ranch Area, located in Sections 7, 8, 17, and 18, T43N, R76W, encompasses 1,120.00 acres. 
Within  the  Nichols  Ranch  permit  boundary,  Energy  Fuels  Resources  (USA)  Inc.  (“EFR”)  has  38  unpatented  lode-mining  claims 
(totaling approximately 639 acres), two fee mineral leases and three Surface Use Agreements (“SUAs”). The claims and fee leases 
encompass  approximately  920  acres.  The  mineral  fee  leases  and  SUAs  have  a  10-year  primary  term  that  has  now  been  extended 
indefinitely  due  to  the  Project  being  in  production.  Provisions  are  set  by  the  SUAs  for  reimbursement  to  the  surface  owner  for 
damages resulting from operations. 

Claims do not have an expiration date, however, affidavits must be filed annually with the BLM and respective county recorder’s 
offices  in  order  to  maintain  the  claims’  validity.  In  addition,  most  of  the  unpatented  lode  claims  are  located  on  Stock  Raising 
Homestead land where the U.S. government has issued a patent for the surface to an individual and reserved the minerals to the U.S. 
government subject to the location rights by claimants as set forth in the 1872 Mining Law. The Nichols Ranch lode mining claims 
are held by Uranerz, which is 100% owned by the Company.

In Section 21, the northern portion of Section 28, eastern portion of Section 20, and northeast quarter of Section 29, unpatented lode 
mining  claims  have  an  overriding  royalty  interest  burden  of  6%  or  8%  depending  on  the  sale  price  of  uranium.  In  the  southern 
portion  of  Section  32,  20  of  the  unpatented  lode  mining  claims  have  an  overriding  royalty  of  0.25%  based  on  production.  In  the 
southern portion of Section 28 where North Jane is located, 14 fee mineral leases have royalties ranging from 2% to 10% depending 
on the sale price of uranium. In the western half of Section 29 two mineral leases have a royalty of 6% or 8% depending on the sale 
price of uranium. Surface owners have a set rate for reimbursement of any land taken out of service for mining activities and two of 
the Surface Owners could receive an extraction fee on production with a burden of 1% or 2% percent depending on the sale price of 
uranium.

The unpatented lode mining claims will remain the property of EFR provided it adheres to the required filing and annual payment 
requirements with Campbell County and the BLM. The SUA’s will remain in force so long as the mining claims are maintained. 
Legal surveys of unpatented lode mining claims are not required and are not known to have been completed.

All of the unpatented lode mining claims have annual filing requirements ($165 per claim) with the BLM, to be paid on or before 
September 1 of each year.

Jane Dough

The permit boundary for the Jane Dough area encompasses approximately 3,680 acres. Within the Jane Dough permit boundary, 
EFR  controls  117  unpatented  lode-mining  claims,  three  SUAs  and  16  fee  mineral  leases.  The  fee  mineral  leases  and  claims 
encompass approximately 3,121.43 acres. The fee mineral leases and SUAs have terms of 10 years. These leases have expiration 
dates ranging from 2027 to 2032. They can be extended indefinitely by establishing production on the lease. The SUAs have set 
provisions for reimbursement to the surface owner for damages resulting from Company operations.  In the south half of Section 28, 
T43N, R76W, the Company controls 57.29% of the fee mineral estate under various fee mineral leases mentioned above.

Portions  of  the  Jane  Dough  Area  were  formerly  held  separately  by  EFR  and  the  Arkose  Project  Joint  Venture  (“JV”).  These 
holdings have been combined. The Company retains 100% of the mineral rights for the portion it originally held and 81% of the 
mineral rights for the Arkose Project JV portion of Jane Dough. Mineral Resources for Jane Dough reflect this partition of mineral 
ownership. The Jane Dough lode mining claims are held by Uranerz, which is 100% owned by the Company. In a single instance, in 
the south half of Section 28, T43N, R76W, the JV only controls 57.29% of a fee mineral lease. The partial ownership of the lease is 
split along the JV ownership agreement with the Company holding 81%.

In  the  south  portion  of  Section  32,  twenty  of  the  unpatented  lode  mining  claims  have  an  overriding  royalty  of  0.25%  based  on 
production. In the southern half of Section 28 and northern half of section 32, five fee mineral leases have royalties ranging from 
2% to 10% depending on the sale price of uranium. In the west half of Section 29, two mineral leases have a royalty of 6% or 8% 
depending  on  the  sale  price  of  uranium.  Surface  owners  have  a  set  rate  for  reimbursement  of  any  land  taken  out  of  service  for 
mining  activities  and  two  of  the  Surface  Owners  could  receive  an  extraction  fee  on  production  with  a  burden  of  1%  or  2%, 
depending on the sale price of uranium.

70

 
The  unpatented  lode  mining  claims  will  remain  the  property  of  EFR  provided  it  adheres  to  required  filing  and  annual  payment 
requirements  with  Campbell  County  and  the  BLM.  The  SUAs  will  remain  in  force  so  long  as  the  mining  claims  are  maintained. 
Legal surveys of unpatented lode mining claims are not required and are not known to have been completed.

All of the unpatented lode mining claims have annual filing requirements with the BLM, to be paid on or before September 1 of 
each year.

Hank

The  Hank  Area  permit  boundary  encompasses  approximately  2,250  acres.  Within  the  permit  boundary,  the  Company  has  49 
unpatented lode-mining claims (totaling approximately 968 acres), and one SUA covering approximately 1,392.58 acres. The Hank 
lode mining claims are held by Uranerz, which is 100% owned by the Company. The SUA is in effect as long as the unpatented 
lode-mining claims are maintained by annual payment.

All claims were located or acquired by EFR and a portion of the claims were subject to a 6% to 8% royalty which has since been 
extinguished. Four claims may be subject to a 5% overriding royalty vested in Brown Land Company and its successors. The claims 
will remain the property of EFR provided they adhere to required filing and annual payment requirements with Campbell County 
and the BLM. All of the unpatented lode claims have annual filing requirements with the BLM, to be paid on or before September 1 
of each year.

The SUA will remain in force so long as the terms of the agreements are met. Legal surveys of unpatented claims are not required 
and are not known to have been completed.

North Rolling Pin

The  North  Rolling  Pin  (“NRP”)  Area  has  54  unpatented  lode-mining  claims  (totaling  approximately  1,018  acres)  and  one  SUA. 
There are no mineral fee leases associated with the NRP Area. There is one SUA that will remain in force so long as the terms of the 
agreement are met. All of the unpatented lode mining claims have annual filing requirements with the BLM, to be paid on or before 
September  1  of  each  year.  The  claims  area  encompasses  approximately  1,180  acres.  The  NRP  lode  mining  claims  are  held  by 
Uranerz, which is 100% owned by the Company.

Lode mining claims in the North Rolling Pin area are not subject to royalties. There are no fee mineral leases.

West North Butte

The West North Butte (“WNB”) Area claims were acquired by Uranerz, which was acquired by the Company in 2015. WNB is held 
by 109 unpatented lode-mining claims totaling approximately 1,800 acres. There are no fee leases associated with West North Butte. 
There is one SUA that will remain in force provided the terms of the agreement are met. The WNB lode mining claims are held by 
Uranerz, which is 100% owned by the Company.

East North Butte

The East North Butte (“ENB”) Area claims were acquired by Uranerz. ENB is held by 16 unpatented lode-mining claims totaling 
approximately 304 acres. There are no fee leases associated with East North Butte. There is one SUA which will remain in force so 
long  as  the  terms  of  the  agreement  are  met.  The  ENB  lode  mining  claims  are  held  by  Uranerz,  which  is  100%  owned  by  the 
Company.

None of the unpatented lode claims in the ENB Area are subject to a royalty. There are no fee mineral leases.

Willow Creek

The  Willow  Creek  (“WC”)  Area  claims  were  acquired  by  Uranerz.  WC  is  held  by  11  unpatented  lode-mining  claims  totaling 
approximately 191 acres. There are no fee leases associated with Willow Creek. There is one SUA that will remain in force so long 
as the terms of the agreement are met. The WC lode mining claims are held by Uranerz, which is 100% owned by the Company.

The claims were acquired by Uranerz and none of the unpatented lode claims in the WC Area are subject to a royalty. There are no 
fee leases associated with Willow Creek.   

71

Accessibility, Climate, Local Resources, Infrastructure and Physiography

Nichols  Ranch  is  located  80  miles  northeast  of  Casper,  Wyoming  and  accessible  via  two-wheel  drive  on  existing  county  and/or 
private  gravel  and  dirt  roads  by  proceeding  north  approximately  10  mi  from  Wyoming  Highway  387  on  the  IDT  Road  and 
approximately 12 mi northwest of the junction of Wyoming Highway 387 and Wyoming Highway 50.

NRP is accessible via two-wheel drive on existing private gravel and dirt roads, many of which have been improved by coal bed 
methane  (“CBM”)  development.  The  approximate  center  of  the  NRP  property  is  approximately  nine  miles  north  of  Wyoming 
Highway  387.  Some  road  development  and  improvements  may  be  required  at  a  later  time  to  facilitate  future  development  of 
wellfields or satellite facilities.

WNB  is  accessible  via  two-wheel  drive  on  existing  county  and/or  private  gravel  and  dirt  roads.  The  approximate  center  of  the 
Satellite  Properties  is  roughly  8  mi  to  11  mi  west  of  Wyoming  Highway  50,  and  the  southern  edge  of  the  Satellite  Properties  is 
approximately 12 mi to 15 mi north of Wyoming Highway 387. Road development and improvements may be required at a later 
time to facilitate future development of wellfields and processing facilities. The north-northwest half of the WNB Area is located in 
an area of significant topographical relief and would likely require significant excavation to construct roads to potential wellfields or 
require the use of directional drilling to develop the resource.

In the vicinity of the Complex, the climate is semi-arid and receives an annual precipitation of approximately 13 in., the majority of 
which  falls  from  February  to  April  as  snow.  Cold,  wind,  and  snow/blizzards  may  occasionally  present  challenges  for  winter 
exploration and construction work in this area however operations can take place year-round. The summer months are typically hot, 
dry, and clear, except for infrequent high-intensity, short-duration storm events.

The  Complex  is  located  in  Johnson  and  Campbell  Counties.  These  counties  are  generally  rural;  according  to  the  April  1,  2020 
United States Census, there were 8,447 people living in Johnson County and 47,026 people living in Campbell County. Most of the 
workers at the Complex are from the local area and nearby communities such as Casper, Wyoming, approximately 80 mi southwest 
of the Complex. Casper is the county seat of Natrona County and, as of the 2020 census, has a population of 59,038. Casper has 
numerous industrial supply and service companies to support mining operations. EFR maintains an office in Casper to support its 
Wyoming mining operations. 

The  Company  has  secured  sufficient  surface  access  rights  for  exploration  and  development  of  the  Complex.  The  Nichols  Ranch 
Mining Unit is a fully licensed, operable facility with sufficient sources of power, water, and waste disposal facilities for operations 
and aquifer restoration.

The basic infrastructure (power, water, and transportation) necessary to support an ISR mining operation has been established at the 
Nichols  Ranch  Mining  Unit  and  is  located  within  reasonable  proximity  of  all  satellite  properties  within  this  report.  Existing 
infrastructure is associated with local oil, gas, and CBM development.

Non-potable water is and/or will be supplied by wells developed at or near the sites. Water extracted as part of ISR operations will 
be recycled for reinjection. Typical ISR mining operations also require a disposal well for limited quantities of fluids that cannot be 
returned  to  the  production  aquifers.  Two  deep  disposal  wells  have  been  permitted  and  are  operational  at  the  Nichols  Ranch  ISR 
Plant.

The proximity of the Complex to paved roads will facilitate transportation of equipment, supplies, personnel, and product to and 
from  the  properties.  Although  the  population  within  50  miles  of  the  subject  properties  consists  mainly  of  rural  ranch  residences, 
personnel  required  for  exploration,  construction,  and  operation  are  available  in  the  nearby  towns  of  Wright,  Midwest,  Edgerton, 
Gillette, Buffalo, and Casper, Wyoming. 

Power  transmission  lines  are  located  on  or  near  parts  of  the  property.  EFR  has  secured  power  from  the  local  electrical  service 
provider to accommodate all operational needs.

Tailing  storage  areas,  waste  disposal  areas,  heap  leach  pad(s)  are  not  part  of  the  required  infrastructure  for  the  Complex,  as  ISR 
operations do not require these types of facilities. Waste disposal is accomplished via deep well injection. EFR has two such wells 
permitted and in operation at Nichols Ranch.

The  Complex  is  located  within  the  Wyoming  Basin  physiographic  province  in  the  western  portion  of  the  Powder  River  Basin, 
within the Pumpkin Buttes Mining District. The Pumpkin Buttes are a series of small buttes rising up to nearly 6,000 feet above sea 
level (ft ASL) in elevation and approximately 1,000 ft above the surrounding plains. The rock capping the top of the buttes is the 
Oligocene  age  White  River  Formation  erosional  remnant,  which  is  believed  to  have  overlain  the  majority  of  the  Powder  River 

72

Basin. The volcanic tuffs in the White River Formation have been cited as the source of uranium in the basin (Davis, 1969). Historic 
and  current  land  use  in  the  Pumpkin  Buttes  Mining  District  includes  livestock  grazing,  mineral  development,  and  oil  and  gas 
development. 

Vegetation  and  wildlife  surveys  of  the  Complex  area  were  completed  as  part  of  the  environmental  baseline  studies  required  for 
permitting  and  licensing.  Vegetation  communities  consist  primarily  of  sagebrush  shrub-land  and  mixed  grasslands,  with  limited 
juniper, greasewood, and wetland communities. The Complex area has the potential to provide habitat for mule deer, elk, pronghorn 
antelope, jackrabbit, cottontail rabbit, coyote, bobcat, mountain lion, red fox, badger, raccoon, skunk, chipmunk, rodents, songbirds, 
waterfowl,  eagles,  hawks,  owls,  sage  grouse,  chukar,  wild  turkey,  Hungarian  partridge,  mourning  dove,  magpie,  and  crow.  Most 
species  are  yearlong  residents,  however,  some  species  such  as  elk,  eagles,  songbirds,  and  waterfowl  are  more  abundant  during 
migration periods.

The Nichols Ranch Mining Unit is situated in a low-lying plain with elevations ranging from roughly 4,600 ft ASL to 4,900 ft ASL. 
There are two main ephemeral drainages at the site. Both are tributaries of Cottonwood Creek, which drains to the Cheyenne River.
The  NRP  Area  consists  of  sagebrush  and  native  grasses,  covering  rolling  hills,  steep  walled  gullies,  and  ephemeral  streams. 
Elevations range from approximately 4,800 ft ASL to 5,180 ft ASL.

The WNB is located on the west flank of the North Pumpkin Butte. This area consists of sagebrush and native grasses, covering 
rolling hills, steep walled gullies, and flat-topped North Butte. Elevations range from approximately 4,900 ft ASL to 5,800 ft ASL, 
and generally slope from northeast to southwest.

History

The Complex was originally part of a large exploration area encompassing Townships 33 through 50 North of Ranges 69 through 79 
West, on the Sixth Principal Meridian. In 1966, Mountain West Mines Inc. (“MWM”) – now Excalibur Industries) began a drilling 
exploration  program  in  this  area.  In  1967,  MWM  entered  into  an  agreement  with  Cleveland-Cliffs  Iron  Company  (“CCI”)  for 
further exploration and option if suitable resources were found. CCI exercised its option in 1976 with plans to begin underground 
mining  operations  near  North  Butte,  approximately  six  and  a  half  miles  northeast  of  Nichols  Ranch.  As  economic  conditions 
changed, and with the development of ISR mining technology, CCI’s interest in the area waned. By the late 1980s, it began selling 
select properties or allowing them to revert back to MWM.

Uranerz acquired six uranium properties in the Powder River Basin from a third party in 2005, including the Complex.

In  June  2015,  EFR  acquired  all  of  the  outstanding  shares  of  Uranerz.  Under  that  transaction,  EFR  acquired  the  Nichols  Ranch 
Project, the Hank Project, the Reno Creek Property, the West North Butte Property, the North Rolling Pin Property, and the Arkose 
Project  JV  (a  joint  venture  of  ISR  mining  properties  held  81%  by  Uranerz  and  19%  by  United  Nuclear  Corp.),  uranium  sales 
contracts, and other assets, as well as the shares of Uranerz, which holds those assets. In May 2018, EFR sold its non-core Reno 
Creek  Property  to  Uranium  Energy  Corp.  In  August  2018,  EFR  acquired  royalties  on  the  Nichols  Ranch  Project,  along  with 
royalties  on  several  operating,  standby,  and  advanced-stage  ISR  projects  in  Wyoming  owned  and  operated  by  Power  Resources, 
Inc., a wholly owned subsidiary of Cameco Corporation.

The Nichols Ranch Mining Unit includes: (i) the Nichols Ranch Plant; (ii) the Nichols Ranch Wellfields; (iii) the Jane Dough Area; 
and (iv) the Hank Area, which includes the permitted but not constructed Hank Satellite Plant and the Hank Deposit. A portion of 
the Jane Dough Area is held through the Arkose Project JV, in which the EFR has an 81% interest.

The North Rolling Pin Area is located within a large exploration area encompassing Townships 33 through 50 North of Ranges 69 
through  79  West,  on  the  Sixth  Principal  Meridian.  In  1966,  MWM  (now  Excalibur  Industries)  began  a  successful  drilling 
exploration program in a portion of the larger area. In 1967, MWM entered into an agreement with CCI for further exploration and 
option if suitable resources were found. CCI exercised its option in 1976 with plans to begin underground mining operations in the 
vicinity of North Butte. Changing economic conditions and the development of ISR mining technology reportedly ended much of 
CCI’s interest in the area.

In addition to CCI, other uranium exploration companies during the last forty years have controlled property either within or near 
the North Rolling Pin Property. These included Kerr McGee, Conoco, Texaco, American Nuclear, Tennessee Valley Authority, Rio 
Algom  Mining  Corporation  (Rio  Algom),  and  Uranerz.  The  mining  claims  and  leases  originally  controlled  by  most  of  these 
companies were let go over the years due to market conditions. These property abandonments continued into 2004.

In February 2007, Uranerz purchased the North Rolling Pin claims group from Robert Shook as part of a larger 138 Federal mining 
claims acquisition. Uranerz subsequently expanded the properties by staking additional claims in the immediate area.

73

The WNB, ENB, and Willow Creek Areas were originally part of a large exploration area encompassing Townships 33 through 50 
North of Ranges 69 through 79 West, on the 6th principal meridian. In 1966, MWM (now Excalibur Industries) began a successful 
drilling exploration program in a portion of this area. In 1967, MWM entered into an agreement with CCI for further exploration 
and option if suitable resources were found. CCI exercised its option in 1976 with plans to begin underground mining operations in 
the vicinity of North Butte. Changing economic conditions and the development of ISR mining technology reportedly ended much 
of CCI’s interest in the area.

In addition to CCI, other uranium exploration companies during the last forty years have controlled property either within or near 
the Satellite Properties. These included Kerr McGee, Conoco, Texaco, American Nuclear, Tennessee Valley Authority, and Uranerz 
U.S.A.,  Inc.  Areva  NC,  via  subsidiary  Cogema  Resources  Inc.  (Cogema),  and  Power  Resources  Inc.  (a  subsidiary  of  Cameco 
Corporation) have retained portions of their original land positions in the area. The mining claims and leases originally controlled by 
most of these companies were let go over the years due to market conditions. These property abandonments continued into 2004.

WNB, ENB, and WC cover an area of land located on the west, east and south flank of North Butte in Campbell County, Wyoming. 
Detailed disclosure pertaining to the chain of title of the properties comprising these Areas is not known to the Authors or Uranerz 
representatives  and  is  beyond  the  scope  of  this  Technical  Report.  The  following  is  a  brief  description  of  what  is  known  about 
ownership history of these Areas.

The locators of the claims acquired rights to the properties comprising the WNB Area in 1987. In January 2007, Uranerz completed 
an acquisition of an undivided one-hundred percent interest in the claims comprising the WNB Area.

The locators of the claims acquired rights to the properties comprising the ENB Area in 1987. In January 2007, Uranerz completed 
an acquisition of an undivided 100% interest in the claims comprising the East North Butte Area.

The  locators  of  the  claims  acquired  rights  to  the  properties  comprising  the  Willow  Creek  Area  in  the  1960s.  In  December  2005, 
Uranerz entered into an option agreement to acquire an undivided one-hundred percent interest in the claims comprising the Willow 
Creek Area. The terms of the option agreement were satisfied in 2007 and the transfer of the claims to Uranerz was completed.

On October 15, 1951, J. D. Love discovered uranium mineralization in the Pumpkin Buttes districts in the Wasatch Formation on 
the south side of North Pumpkin Butte in the west-central portion of the Powder River Basin. The mineralization was one of eight 
areas recommended by the U.S. Geologic Survey (USGS) in April 1950 for investigation in the search for uranium bearing lignites 
and  volcanic  tuffs.  In  response  to  this  recommendation,  an  airborne  radiometric  reconnaissance  of  most  of  these  areas  was 
undertaken  by  the  USGS  in  October  1950.  The  uranium  mineralization  discovered  by  J.  D.  Love  was  near  an  aerial  radiometric 
anomaly identified from this survey (Love, 1952).

Exploration drilling was conducted in the Jane Dough Area, Section 21 and 28, T43N, R76W, between the late 1960s and late 1970s 
by CCI. Little interest was generated by the completion of 46 holes from this drilling. Between 1968 and 1980 CCI drilled 150 holes 
and installed 3 water wells on the Nichols Ranch and Jane Dough Areas. Texas Eastern Nuclear Inc. completed limited drilling and 
exploration on the property in 1985. In the early 1990s, Rio Algom also completed limited drilling in the area. In December 2005, 
Uranerz  purchased  the  Nichols  Ranch,  Jane  Dough,  and  Hank  claims  groups  as  part  of  a  six-property  agreement  to  option  from 
Excalibur Industries. Uranerz then expanded the properties by staking additional claims in the immediate and surrounding areas.

Uranerz began exploration drilling on the Nichols Ranch Area on July 11, 2006, and continued to June 6, 2015. A total of 1,098 
holes (253 exploration holes, 105 monitor wells, and 740 production wells) were drilled during that time. A total of 51 exploration 
holes were drilled on the Hank Area in 2008. 

Uranerz received the Source Material License SUA-1597 in July of 2011. Nichols Ranch ISR operations began on April 15, 2014, 
after completion of a pre-operational inspection by the NRC Region IV office. There were two planned Production Areas (PA1 and 
PA2) in the Nichols Ranch Area. Five header houses and their respective wellfields were installed and in operation in June 2015, 
when  EFR  acquired  Uranerz,  in  Production  Area  #1.  Header  house  #6  was  commissioned  in  November  2015.  In  2016,  the  EFR 
completed drilling 12 delineation holes and drilling and casing of 86 extraction wells in Header Houses #7 and #8 in Production 
Area #1. Header House #7 was turned on in March 2016 and Header House #8 was turned on in June 2016. In Production Area #2, 
133  extraction  and  injection  wells  were  drilled  and  cased.  Header  House  #9  was  completed  and  turned  on  in  March  2017.  No 
drilling or other development activities have been performed since 2017.

In  January  2008,  Uranerz  entered  into  the  JV,  resulting  in  an  81%  undivided  interest  in  the  mineral  rights  controlled  by  the  JV. 
Uranerz  commenced  exploration  on  the  Arkose  Project  in  2008.  A  total  of  1,971  exploration  holes  were  drilled  on  the  Arkose 
Project JV from April 2008 to August 2012. A portion of the Arkose Project JV holdings were subsequently incorporated into the 

74

Jane Dough portion of the Nichols Ranch Mining Unit and remain subject to the 81% ownership, as discussed in Section 4.0 of this 
Technical Report.

Mining claims were first staked in the North Rolling Pin Area by MWM sometime before 1968. Exploration drilling was conducted 
in the North Rolling Pin Area Sections 11, 14 and 15, T43N, R76W, between 1968 and 1982 by CCI. A total of 476 exploration 
holes were drilled including 10 core holes. CCI was reported to be investigating the NRP Area for open pit mining potential but 
never carried those plans past the exploration phase. In 2008 and 2009, Uranerz drilled 18 exploration holes in Sections 11 and 14. 
This drilling was performed to evaluate the potential for mineralization below the zones explored by CCI and for confirmation of 
the previously identified mineralization in the F Sand.

Between  1968  and  1985,  CCI  drilled  approximately  380  exploratory  holes  within  the  West  North  Butte,  East  North  Butte,  and 
Willow Creek Areas. From 1983 to 1985, Texas Eastern Nuclear drilled approximately 12 exploratory holes in these Areas. From 
approximately 1990 to 1992, Rio Algom drilled approximately 5 exploratory holes. In 2006, Uranerz completed an acquisition of 
these Areas, and in 2007 and 2008, drilled approximately 127 exploratory holes.

The Complex is an advanced stage project which is licensed to operate by the NRC and the WDEQ. Construction of the processing 
facility began in 2011. Plant construction and initial wellfield installation was completed in 2014 and operations were initiated in 
April 2014. Production of 1,265,805 pounds of uranium oxide has been reported from initiation of production through December 31, 
2019, via ISR mining. Since 2019, the Nichols Ranch portion of the Complex has been on standby due to low uranium prices.

Permitting and Licensing

Energy Fuels has received all regulatory approvals necessary to conduct extraction and uranium processing activities at the Nichols 
Ranch Plant and Nichols Ranch Wellfield. In December 2010, Uranerz received its Permit to Mine for the Nichols Ranch Project 
from the WDEQ-LQD. In July 2011, Uranerz received a Source Material License from the NRC for the Nichols Ranch Plant and 
Nichols Ranch Wellfield, and construction of the Nichols Ranch Plant immediately began. Effective September 30, 2018, the State 
of  Wyoming  became  an  Agreement  State  under  the  Atomic  Energy  Act  (as  amended)  for  the  regulation  of  uranium  mills  and 
uranium ISR facilities, and regulation of the Source Material License was transferred from the NRC to WDEQ-LQD.

Both the state and federal agencies analyzed all environmental aspects of the Nichols Ranch Project including reclamation of the 
land surface following extraction operations and restoration of impacted ground water. Workplace safety and the safety of the public 
are also closely monitored by regulatory agencies. We have posted a reclamation bond with the regulatory agencies in an amount of 
$7.1  million  (most  recently  approved  on  August  15,  2023)  to  cover  the  total  estimated  cost  of  reclamation  by  a  third  party  as  a 
requirement of the licenses.

The  various  state  and  federal  permits  and  licenses  that  were  required  and  have  been  obtained  for  the  Nichols  Ranch  Project, 
exclusive of the expansion to the Jane Dough Property, are summarized below:

Primary Permits and Licenses for the Nichols Ranch Project (Nichols Ranch and Hank Units Only)

Permit, License, or Approval Name

Agency

Status

Source Material License

NRC (2011); WDEQ-LQD (2018)

Obtained

Permit to Mine (UIC Permit)

WDEQ-LQD

Aquifer Exemption

WDEQ-LQD; EPA

Permit to Appropriate Groundwater

WSEO

Wellfield Authorization

WDEQ-LQD

Class I UIC Deep Disposal Well Permits WDEQ-WQD

WYPDES

WDEQ-WQD

Plan of Operations (Hank Unit only)

BLM

Air Quality Permit

WDEQ-AQD

Notes:    

(1) NRC - Nuclear Regulatory Commission

75

Obtained

Obtained

Obtained

Obtained

Obtained

Obtained

Obtained

Obtained

(2) EPA - Environmental Protection Agency
(3) UIC - Underground Injection Control 
(4) WDEQ-LQD - Wyoming Department of Environmental Quality Land Quality Division
(5) WDEQ-WQD - Wyoming Department of Environmental Quality Water Quality Division
(6) WDEQ-AQD - Wyoming Department of Environmental Quality Air Quality Division
(7) WSEO - Wyoming State Engineer’s Office
(8) WYPDES - Wyoming Pollutant Discharge Elimination System

Under the licensed plan, the Nichols Ranch Plant has been built, and a satellite processing facility is licensed for the Hank Project. 
In  2017,  the  NRC  approved  a  source  material  license  amendment  to  add  the  Jane  Dough  Property  to  the  existing  license  for  the 
Nichols Ranch Project, and the WDEQ approved an amendment to our Permit to Mine to incorporate the Jane Dough Property. The 
Jane Dough Property is now fully licensed and permitted as part of the Nichols Ranch Project. The Jane Dough Property is adjacent 
to the Nichols Ranch Wellfield and is expected to share its infrastructure. Uranerz is now able to bring the Jane Dough Property into 
extraction operations before the Hank Project. Due to its close proximity, extracted solutions from the Jane Dough Property may be 
delivered directly to our Nichols Ranch Plant by pipeline, thus eliminating the need for a larger capital outlay to construct a satellite 
plant  as  is  planned  for  the  Hank  Project.  The  Jane  Dough  Property  includes  the  Doughstick,  South  Doughstick  and  North  Jane 
properties. Additional wellfields may be added to the extraction operations plan as the Company continues to assess geological data. 

Geological Setting, Mineralization and Deposit

The Complex is located in the Powder River Basin, which is a large structural and topographic depression sub-parallel to the trend 
of the Rocky Mountains. The Basin is bounded on the south by the Hartville Uplift and the Laramie Range, on the east by the Black 
Hills, and on the west by the Big Horn Mountains and the Casper Arch. The Miles City Arch in southeastern Montana forms the 
northern boundary of the Basin.

The Powder River Basin is an asymmetrical syncline with its axis closely paralleling the western basin margin. During sedimentary 
deposition,  the  structural  axis  (the  line  of  greatest  material  accumulation)  shifted  westward  resulting  in  the  Basin’s  asymmetrical 
shape.

Uranium  mineralization  at  the  Complex  deposits  is  hosted  by  the  Eocene  Wasatch  Formation.  The  Wasatch  Formation  was 
deposited  in  a  multi-channel  fluvial  and  flood  plain  environment.  The  climate  at  the  time  of  deposition  was  wet  tropical  to 
subtropical with medium stream and river sediment load depositing most medium grained materials. The source of the sediments, as 
evidenced by abundant feldspar grains in the sandstones, was the nearby Laramie and Granite Mountains.

Within  the  Complex,  there  is  a  repetitive  transgressive/regressive  sequence  of  sandstones  separated  by  fine-grained  horizons 
composed  of  siltstone,  mudstone,  carbonaceous  shale,  and  poorly  developed  thin  coal  seams.  The  fine-grained  materials  were 
deposited in flood plain, shallow lake (lacustrine), and swamp environments. Ultimately, deposition of the Wasatch Formation was a 
function of stream bed load entering the basin and subsidence from within the basin. However, in the central part of the Powder 
River Basin, long periods of balanced stability occurred. During these periods the stream gradients were relatively low and allowed 
for development of broad (0.5 mi to 6.0 mi wide) meander belt systems, associated over-bank deposits, and finer grained materials 
in flood plains, swamps, and shallow bodies of water.

Meander belts in the Wasatch Formation are generally 5 ft to 30 ft thick. The A Sand at Nichols Ranch Area is made up of three to 
four stacked meander belts and the F Sand at Hank Area has two to three stacked meander belts. Individual meander belt layers will 
rarely terminate at the same location twice. Meanders have been noted to frequently terminate in the interior of a belt system but are 
more likely to terminate somewhere closer to the edge of the meander stream valley. The net effect for fluvial sands is to generally 
thin away from the main axis of the meander belt system. The A Sand meander belt system at Nichols Ranch Area is approximately 
four miles wide. At Hank, the F Sand meander belt system is smaller than Nichols Ranch at approximately one and a half miles 
wide.

At the North Rolling Pin Area, the mineralized sand horizon (F Sand) occurs within the Wasatch Formation at an approximate depth 
from  surface  ranging  from  51  ft  to  403  ft  and  averaging  282  ft  to  the  top  of  the  mineralization.  Generally,  the  depth  of 
mineralization decreases from the northeast to the southwest due mainly to topography along which the surface elevation decreases 
from approximately 5,180 ft to approximately 4,800 ft. The F Sand primarily consists of two stacked sand sets, termed the Upper 
and Lower F Sands that each average 20 ft to 25 ft thick.

The mineralized sand horizons occur within the lower part of the Wasatch Formation, at an approximate depth from surface ranging 
from 482 ft to 1,012 ft at West North Butte, 540 ft to 660 ft at East North Butte, and 172 ft to 567 ft at Willow Creek. The host 
sands  are  primarily  arkosic  in  composition,  friable,  and  contain  trace  carbonaceous  material  and  organic  debris.  There  are  local 

76

sandy mudstone/siltstone intervals with the sandstones, and the sands may thicken or pinch-out in some locations. Mineral resources 
are located in the Eocene age Wasatch Formation in what is identified as the A, B, C and F host sand units of the WNB Area, the A 
and B host sands of the ENB Area and in the A and F host sand units of the WC Area.

The  uranium  mineralization  is  composed  of  amorphous  uranium  oxide,  sooty  pitchblende,  and  coffinite,  and  is  deposited  in  void 
spaces  between  detrital  sand  grains  and  within  minor  authigenic  clays.  The  host  sandstone  is  composed  of  quartz,  feldspar, 
accessory biotite and muscovite mica, and locally occurring carbon fragments. Grain size ranges from very fine to very coarse sand 
but is medium grained overall. The sandstones are weakly to moderately cemented and friable. Pyrite and calcite are associated with 
the  sands  in  the  reduced  facies.  Hematite  or  limonite  stain  from  pyrite  are  common  oxidation  products  in  the  oxidized  facies. 
Montmorillonite and kaolinite clays from oxidized feldspars are also present in the oxidized facies (Uranerz, 2010a). The uranium 
being extracted is hosted in a sandstone, roll front deposit at a depth ranging from 400 ft to 800 ft.

Wyoming uranium deposits are typically sandstone roll front uranium deposits as defined in the “World Distribution of Uranium 
Deposits  (UDEPO)  with  Uranium  Deposit  Classification”  (IAEA,  2009).  The  key  components  in  the  formation  of  roll  front  type 
mineralization include:

•

•

•

•

•

A permeable host formation:

◦

Sandstone units of the Wasatch Formation.

A source of soluble uranium:

◦

Volcanic  ash  flows  coincidental  with  Wasatch  deposition  containing  elevated  concentration  of  uranium  is  the 
probable source of uranium deposits for the Pumpkin Buttes Uranium District.

Oxidizing groundwaters to leach and transport the uranium:

◦

Groundwaters regionally tend to be oxidizing and slightly alkaline.

Adequate reductant within the host formation:

◦

Conditions resulting from periodic hydrogen sulfide (H2S gas) migrating along faults and subsequent iron sulfide 
(pyrite) precipitation created local reducing conditions.

Time sufficient to concentrate the uranium at the oxidation/reduction interface. 

◦

◦

Uranium  precipitates  from  solution  at  the  oxidation/reduction  boundary  (REDOX)  as  uraninite  (UO2,  Uranium 
oxide), which is dominant, or coffinite (USiO4, uranium silicate).
The  geohydrologic  regime  of  the  region  has  been  stable  over  millions  of  years  with  groundwater  movement 
controlled primarily by high-permeability channels within the predominantly sandstone formations of the Tertiary.

Data Verification

The  primary  assay  data  used  to  calculate  the  Mineral  Resource  estimate  for  the  Complex  is  downhole  radiometric  log  data. 
Calibration  data  for  both  natural  gamma  and  prompt  fission  neutron  (“PFN”)  geophysical  logging  units  are  available  for  both 
historical and recent drilling. When drilling is active, both the natural gamma and PFN logging trucks are calibrated at least every 
three  months.  Natural  gamma  calibration  is  performed  at  DOE  standard  calibration  facilities  located  in  Casper,  Wyoming. 
Commercial  logging  services  for  both  natural  gamma  and  PFN  logging  are  calibrated  at  the  DOE  standard  facilities  located  in 
Casper, Wyoming, and/or Grand Junction, Colorado.

Only  natural  gamma  logs  were  used  for  Resource  estimation  as  assay  data  could  lead  to  an  over  or  under  estimation  of  Mineral 
Resources due to disequilibrium. Positive disequilibrium occurs when the uranium present has not had enough time to decay and 
produce daughter isotopes, which are what are actually measured during a natural gamma assay. Under positive disequilibrium a 
natural gamma assay would indicate lower amounts of uranium than what is present. Negative disequilibrium occurs when uranium 
has had enough time to decay to produce the daughter radioisotopes but was remobilized and removed from the deposit. This would 
lead to measuring more uranium than is present. The use of a PFN logging unit, which directly measures uranium content, would 
remove this risk. The disequilibrium factor applied to the Mineral Resource is 1.0.

Mineral Resource Estimates

Mineral  Resources  have  been  estimated  using  the  GT  (Grade  x  Thickness)  contour  method  for  each  of  the  mineral  sandstone 
horizons or units identified across the deposits (1, A, B, C, F, G and H). The uranium resource can generally be defined by existing 
drilling  information  which  is  of  sufficient  density  and  continuity  to  identify  a  meandering  discontinuous  mineralized  trend.  The 
grade and mineralized zone thickness were obtained from historical and recent drilling. 

The  GT  contour  method  is  well  suited  for  estimating  tonnage  and  average  grades  of  relatively  planar  mineralized  bodies.  It  is  a 
smoothing technique that allows the geologist to apply judgment regarding the variability of the mineralization within the plane of 
the mineralized body. This technique is particularly effective in generating a realistic landscape of metal values along the plane of 

77

the  mineralized  body  and  limiting  the  effect  of  local  high  values.  The  technique  is  best  applied  to  estimate  tonnage  and  average 
grade of relatively planar bodies, i.e., where the two dimensions of the mineralized body are much greater than the third dimension 
(Agnerian  and  Roscoe,  2001).  For  these  types  of  deposits,  the  contour  method  can  provide  a  clear  view  of  the  “mineralization 
landscape”  with  “peaks  and  valleys”  along  the  plane  of  the  mineralization.  Due  to  the  two-dimensional  nature  of  the  contour 
method, data from drillhole intersections means the reported averaged assay grade is across the entire thickness of the mineralized 
body being considered. If necessary, the average intersection value is diluted to a specified minimum thickness.

The  rationale  for  all  Mineral  Resource  estimation  methods  is  that  there  is  continuity  of  mineralization  from  one  sample  point  to 
another, whether they are drillhole pierce points, underground workings, surface trenches, or wellfields. When a mineral deposit has 
been tested by many drillholes, the estimate of tonnage and average grade by all conventional methods will likely be similar. When 
a  deposit  has  been  tested  by  a  relatively  few  widely  spaced  or  irregularly  spaced  drillholes,  however,  the  estimates  by  various 
methods may vary greatly and a few high-grade or wide intercepts may have a large influence on the average grade or tonnage of 
the deposit. The contour method can be effective in reducing the influence of high-grade or wide intersections as well as the effects 
of widely spaced, irregularly spaced, or clustered drillholes. This is particularly the case for roll front uranium deposits. It can also 
be applied to estimate Mineral Reserves by deleting certain portions of the Mineral Resources estimated by the same method, such 
as  clipping  the  edges  of  the  contoured  area,  deleting  certain  parts  of  the  tonnage  estimate  as  pillars  and  sills  and/or  applying 
economic factors to the Mineral Resources.

The Mineral Resource estimates were calculated using GT contours with a minimum grade cut-off of 0.02% eU3O8 and a minimum 
mineralization thickness of 1.0 feet. The GT values of the subject sand intervals for each hole were plotted on a drillhole map and 
contour  lines  were  drawn  along  the  mineralization  trend  using  ArcGIS  software.  The  contour  map  was  developed  from  the 
calculated GTs for various GT ranges. The areas within the GT contour boundaries, up to certain distances from the drillhole and to 
certain maximum areas of influence, were used for calculating estimates for resources. All resources were limited to the extent of 
the 0.2 GT boundaries. The contained pounds of uranium were calculated using the following formula:

Mineral Resource, pounds = (Area, ft2) x (GT, %-ft) x (20 lb) x (DEF) / (RD, ft3/ton)

•
•

•
•

Area (ft2) = Area of influence in square feet (measured from contour interval)
GT (percent x feet) = Material grade in percent times feet thickness of mineralization (GT multiplied by 20 lb to convert 
from short tons to pounds as 1% of a short ton equals 20 lb)
DEF (1.00) = Disequilibrium factor (1.00)
RD (15.5) = Rock density (15.5 ft3/ton)

Tonnage was calculated based on grade, pounds and a tonnage conversion factor for a given GT contour area.

Details regarding the Mineral Resource estimate disclosed herein can be found in Section 14.0, Mineral Resource Estimates of the 
Nichols Ranch Technical Report Summary.

The table below sets out the Mineral Resources estimates for the Nichols Ranch Project as of December 31, 2023. These estimates 
are derived from the Nichols Ranch Technical Report Summary, which estimated the Mineral Resources as of December 31, 2021. 
Daniel Kapostasy, the Company’s non-independent Qualified Person, reviewed and confirmed that the Mineral Resources estimates 
set forth in the Nichols Ranch Technical Report Summary remained accurate as of December 31, 2023.

78

Classification Project Area

Nichols Ranch Remaining Mineral Resources – In Situ Uranium(1)(2)(3)(4)(5)(6)
Grade 
(%U3O8)

EFR Basis 
(%)

Cut-off 
(ft-%)(2)(8)

Tons 
(000s)

EFR Metal 
(000s lb U3O8)

Metallurgical 
Recovery(9)

Contained 
Metal 
(000s lb 
U3O8)

Measured 
Mineral 
Resources (M)

Nichols Ranch

Jane Dough

Hank

North Rolling Pin

West North Butte

Total Measured

Indicated 
Mineral 
Resources (I)

Nichols Ranch

Jane Dough

Hank

North Rolling Pin

Total Indicated

Total Measured + Indicated 
(M+I)
Inferred 
Mineral 
Resources (I)

Nichols Ranch

Jane Dough
Hank
North Rolling Pin

Total Inferred

Notes:

0.2

0.2

0.2

0.2

0.2

0.2

0.2

0.2

0.2

0.2

0.2

0.2

0.2
0.2
0.2

0.2

11

---

---

---

---

11

359

1,892

450

582

3,283

3,294

---

188
423
39

650

0.187

---

---

---

---

0.187

0.166

0.112

0.095

0.057

0.106

0.106

---

0.112
0.095
0.042

41

---

---

---

---

41

1,190

4,237

855

665

6,947

6,988

---

420
803
33

100

---

---

---

---

100

100

81

100

100

88.4

88.5

---

81
100
100

41

---

---

---

---

41

1,190

3,432

855

665

6,142

6,183

---

340
803
33

 71 %

 71 %

 71 %

 71 %

 71 %

 60.4 %

 60.4 %

 60.4 %

 60.4 %

 60.4 %

 60.4 %
 60.4 %
 60.4 %

0.097

1,256

93.6

1,176

(1)  SEC  S-K  definitions  were  followed  for  all  Mineral  Resource  categories.  These  definitions  are  also  consistent  with  CIM 
(2014) definitions in NI 43-101.
(2) The cut-off grade is calculated using a metal price of $65/lb. U3O8. The long-term uranium price is based on supply and 
demand projections for the period 2021-2035. 
(3) Mineral Resources are based on a tonnage factory of 15.0 ft3/ton (Bulk density 0.0667 ton/ft3 or 2.13 t/m3).
(4) Mineral Resources that are not Mineral Reserves do not have demonstrated economic viability.
(5) Numbers may not add due to rounding.
(6) Mineral Resources are 100% attributable to EFR for Nichols Ranch, Hank, and North Rolling Pin.
(7) Mineral Resources are 81% attributable to EFR and 19% attributable to United Nuclear Corp. in parts of Jane Dough.
(8) Cut-off grade is a GT cut-off or %U3O8 x thickness (ft).
(9)  Metallurgical  recoveries  for  ISR  operations  represent  the  percent  recovery  (71%)  for  under  pattern  Mineral  Resources. 
Measured Mineral Resources are 100% under pattern. Indicated and Inferred Mineral Resources assume 85% under pattern and 
71% recovery totaling 60.4% overall recovery of the Mineral Resource.

Current Status of Wellfields

Present Condition of the Property

All the currently planned and permitted wellfields are in Production Areas #1 and #2 of the Nichols Ranch Wellfield. The Nichols 
Ranch Wellfield is expected to have a total of 13 header-houses, with Production Area #1 comprising header-houses 1 through 8, 
and  Production  Area  #2  comprising  header-houses  9  through  13.  Each  of  the  two  planned  Nichols  Ranch  Wellfield  Production 
Areas will include a number of injection wells, recovery wells, monitoring wells, header houses and associated piping and power 
supply. Header houses will be located within the Production Areas and will distribute recovered fluids from recovery wells to trunk 
lines, and injection fluids from the processing facility through the trunk lines to injection wells. 

79

The first five header houses and their respective wellfields in Production Area #1 at the Nichols Ranch Wellfield were installed and 
extracting  uranium  at  the  time  the  Company  acquired  Uranerz  in  June  2015.  Header  house  #6  was  commissioned  in  November 
2015. Uranerz placed the 7th and 8th header-houses online in March and July 2016, respectively, thereby completing development 
of  Production  Area  #1.  In  February  2017  Uranerz  completed  construction  on  the  9th  header-house,  marking  the  beginning  of 
development  in  Production  Area  #2.  Uranium  recovery  operations  from  Production  Area  #2  commenced  in  March  of  2017. 
Currently, Production Area #1 is in restoration and Production Area #2 is on standby. In order for Nichols Ranch to engage in future 
uranium production, the Company will need to incur capital expenditures to develop additional wellfields.

Nichols Ranch Plant

In 2014, construction of the Nichols Ranch Plant was completed. The Nichols Ranch Plant is licensed to produce up to two million 
pounds  of  uranium  per  year  through  three  major  processing  solution  circuits:  (i)  a  recovery  and  extraction  circuit;  (ii)  an  elution 
circuit; and (iii) a yellowcake production circuit. The Nichols Ranch Plant is currently constructed and operated with the recovery 
and extraction circuit and the elution circuit installed. The Company retains the ability to construct and operate a yellowcake drying 
and packaging circuit at the Nichols Ranch Plant at a later date if desired.

Uranerz is still processing uranium-bearing wellfield solutions from Production Areas #1 and #2 of the Nichols Ranch Wellfield for 
de  minimis  recoveries  of  uranium.  When  not  on  standby,  yellowcake  slurry,  produced  at  the  Nichols  Ranch  Plant,  is  shipped  by 
truck  from  the  Nichols  Ranch  Project  to  the  White  Mesa  Mill  where  it  is  dried  and  packaged  in  drums  as  uranium  concentrate 
product. Prior to the completion of the elution circuit in February 2016, loaded resin was transported by truck to a third-party facility 
for elution, drying and packaging, under a toll processing arrangement.

The Nichols Ranch Plant was acquired by the Company on June 18, 2015 through the acquisition of Uranerz. As of December 31, 
2023, the total net book value attributable to the Nichols Ranch Plant on the Company’s consolidated financial statements was $7.2 
million. The total net book value attributable to the North Rolling Pin and WNB properties was $10.2 million.

The Company’s Planned Work

Production at Nichols Ranch is currently on standby and restoration, pending market conditions improving sufficiently to resume 
production. In order for Nichols Ranch to engage in future uranium production, the Company will need to incur capital expenditures 
to  develop  additional  wellfields,  as  all  existing  wellfields  are  now  depleted.  While  production  at  the  Nichols  Ranch  Project  is 
currently  being  maintained  on  standby,  in  2024  the  Company  is  undertaking  exploration  drilling  around  the  Collins  Draw  and 
Arkose portions of its larger land holdings around the Nichols Ranch Complex to expand the resources at the Nichols Ranch Project 
and  to  conduct  delineation  drilling  in  PA2  in  order  to  plan  out  future  wellfields  to  be  ready  for  potential  recommencement  of 
production in late 2024 or in 2025. 

80

The White Mesa Mill

General

The  White  Mesa  Mill  is  a  fully  licensed  uranium,  vanadium  and  REE  processing  facility  located  in  southeastern  Utah, 
approximately  six  miles  south  of  the  city  of  Blanding,  Utah.  The  Mill  offices  are  located  at  37°32’3.749”  north  latitude  and 
109°30’10.297” west longitude. It is within trucking distance of the Company’s conventional properties in Utah, Colorado, Arizona 
and  New  Mexico,  including  the  Pinyon  Plain  Project,  the  Roca  Honda  Project,  the  Bullfrog  Project,  the  La  Sal  Project  and  the 
Whirlwind  Project.  The  Mill  is  the  only  fully  operational  and  licensed  conventional  uranium  mill  in  the  U.S.  It  is  capable  of 
functioning  independently  of  off-site  support  except  for  commercial  power  from  Rocky  Mountain  Power  and  as-needed 
supplemental water supply from the City of Blanding, Utah, and the San Juan Water Conservancy District. The Mill is a uranium, 
vanadium and REE processing and recovery facility. It is not an underground or open pit project.

The Mill is licensed to process an average of 2,000 tons of ore per day and to extract over 8.0 million pounds of U3O8 per year. In 
addition  to  the  conventional  circuit,  the  Mill  has  a  separate  vanadium  by-product  recovery  circuit,  and  is  constructing  a  separate 
REE oxide separation circuit.

In  addition  to  the  Mill  processing  equipment,  which  includes  the  grinding  and  leaching  circuits,  CCD  (liquid–solid  separation), 
solvent extraction, and precipitation and drying circuits, the Mill has several days of reagent storage for sulfuric acid, hydrochloric 
acid, ammonia, salt, soda ash, caustic soda, ammonium sulfate, flocculants, kerosene, amines, and liquefied natural gas.

The onsite infrastructure also includes a stockpile area capable of storing up to 450,000 tons of mineralized material, and existing 
tailings  capacity  of  approximately  2.5  million  tons  of  solids.  In  addition,  the  Mill  has  approximately  90  acres  of  evaporation 
capacity.

81

Synthetic lined cells are used to contain tailings and solutions for evaporation. The Company operates two tailings cells and one or 
more  evaporation  ponds  during  normal  operations.  As  each  tailings  cell  is  filled,  the  water  is  drawn  off  and  pumped  to  an 
evaporation pond and the tailings solids are allowed to dry. As each tailings cell reaches final capacity, reclamation begins with the 
placement of interim cover over the tailings. Additional cells are excavated, and the overburden is used to reclaim previous cells. In 
this way, there is an ongoing reclamation process.

When  in  full  operation,  the  Mill  employs  approximately  150  people,  which  is  reduced  to  approximately  110  people  when  the 
vanadium circuit is not being operated.

Alternate Feed Materials

The Mill License (defined below) also gives the Company the right to process other uranium-bearing materials known as Alternate 
Feed  Materials  pursuant  to  an  Alternate  Feed  Guidance  published  by  the  NRC.  Alternate  Feed  Materials  are  uranium-bearing 
materials,  other  than  natural  or  native  ore,  usually  classified  as  waste  products  by  the  generators  of  the  materials,  which  can  be 
recycled by the Mill for the recovery of U3O8. The Mill License does not permit the processing of uranium-bearing materials that 
have  undergone  enrichment.  Requiring  a  routine  amendment  to  the  Mill  License  for  each  different  Alternate  Feed  Material,  the 
Company can process these uranium-bearing materials and recover uranium, in some cases at a fraction of the cost of processing 
conventionally mined material. In other cases, the generators of the Alternate Feed Materials are willing to pay a recycling fee to the 
Company to process these materials to recover uranium and then dispose of the remaining by-product in the Mill’s licensed tailings 
cells,  rather  than  directly  disposing  of  the  materials  at  a  disposal  site.  By  working  with  the  Company  and  taking  the  recycling 
approach,  the  suppliers  of  Alternate  Feed  Materials  can  significantly  reduce  their  remediation  costs,  as  there  are  only  a  limited 
number of disposal sites for such materials in the U.S. Alternate Feed Materials are particularly attractive to Energy Fuels because 
they carry no associated mining costs.

Throughout its history, the Mill has received 18 license amendments, authorizing it to process 22 different Alternate Feed Materials. 
Of these amendments, twelve have involved the processing of feeds provided by nuclear fuel cycle facilities and private industry, 
and one has involved the processing of material from the DOE. These thirteen feed materials have been relatively high in uranium 
content and relatively low in volume. The remaining five amendments have allowed the Mill to process uranium-bearing soils from 
former defense sites, known as FUSRAP sites, which were being remediated by the USACE. These materials are typically relatively 
low in uranium content but relatively high in volume.

The Mill has a separate circuit for processing certain types of Alternate Feed Materials, which was built in 2009. This circuit enables 
the Mill to process both conventionally mined material and Alternate Feed Materials simultaneously.

Rare Earth Elements

In  2021,  the  Company  began  utilizing  the  Mill  to  process  REEs  at  commercial  scale  from  a  monazite  feed  source.  Monazite  is 
typically produced as part of HMS mining operations and contains elevated quantities of the rare earth suite of elements as well as 
uranium. Since 2021, the Mill has successfully recovered rare earths as a mixed RE Carbonate product, which has been sold into the 
rare  earth  market.  The  Mill  processed  approximately  360  tons  of  monazite  in  2023  and  the  Company  is  planning  on  processing 
approximately 480 MT of monazite in early 2024. The Mill is also completing installation of a RE separation facility (Phase I) that 
will  allow  for  the  production  of  NdPr  oxide  as  well  as  heavy  RE  concentrate  products  at  the  Mill.  Installation  of  the  Phase  I 
separation  facility  is  expected  to  be  completed  near  the  end  of  Q1  2024.  Phase  I  is  expected  to  be  capable  of  processing  the 
equivalent  of  8,000  to  10,000  tonnes  of  monazite  annually.  The  Mill  is  uniquely  suited  to  process  monazite  and  extract  both  the 
REEs as well as the uranium. See “Part I, Item 1. Business Overview - The Company’s Rare Earth Elements Business” for a more 
detailed discussion of the Company’s REE initiatives. 

Potential Recovery of Radioisotopes for use in Advanced Cancer Therapeutics

In  2021,  the  Company  announced  the  execution  of  a  Strategic  Alliance  Agreement  with  RadTran,  a  technology  development 
company focused on closing critical gaps in the procurement of medical isotopes for emerging TAT cancer therapeutics and other 
applications.  Under  this  strategic  alliance,  the  Company  is  evaluating  the  feasibility  of  recovering  Th-232,  and  Ra-226,  from  its 
existing REE and uranium process streams at the Mill and, together with RadTran, is evaluating the feasibility of recovering Ra-228 
from the Th-232, potentially Th-228 from the Ra-228 and concentrating Ra-226 at the Mill. Recovered Ra-228, Th-228 and Ra-226 
would then be sold to pharmaceutical companies and others to produce Pb-212, Ac-225, Bi-213, Ra-224 and/or Ra-223, which are 
the leading medically attractive TAT isotopes for the treatment of cancer. Existing supplies of these isotopes for TAT applications 
are in short supply, and methods of production are costly and currently cannot be scaled to meet the demand created as new drugs 
are  developed  and  approved.  This  is  a  major  roadblock  in  the  research  and  development  of  new  TAT  drugs  as  pharmaceutical 
companies wait for scalable and affordable production technologies to become available. Under this initiative, the Company has the 

82

potential to recover valuable isotopes from its existing process streams, thereby recycling back into the market material that would 
otherwise be lost to disposal for use in treating cancer. See “Part I, Item 1. Business Overview - The Company’s Strategic Alliance 
for the Development of Radioisotopes for Medical Therapeutics” for a more detailed discussion of this initiative.

Accessibility, Climate, Local Resources, Infrastructure and Physiography

The  Mill  is  located  in  central  San  Juan  County,  Utah,  approximately  six  miles  (9.5  km)  south  of  the  city  of  Blanding.  It  can  be 
reached by taking a private road for approximately 0.5 miles west of U.S. Highway 191.

The climate of southeastern Utah is classified as dry to arid continental. Although varying somewhat with elevation and terrain, the 
climate in the vicinity of the Mill can be considered as semi-arid with normal annual precipitation of about 13.4 inches. The weather 
in the Blanding area is typified by warm summers and cold winters. The mean annual temperature in Blanding is about 50°F. Winds 
are usually light to moderate in the area during all seasons, although occasional stronger winds may occur in the late winter and 
spring.

The  Mill  site  is  located  on  a  gently  sloping  mesa  that,  from  the  air,  appears  similar  to  a  peninsula,  as  it  is  surrounded  by  steep 
canyons and washes and is connected to the Abajo Mountains to the north by a narrow neck of land. On the mesa, the topography is 
relatively flat, sloping at less than one (1) percent to the south and nearly horizontal from east to west.

The  natural  vegetation  presently  occurring  within  a  25-mile  (40-km)  radius  of  the  Mill  site  is  very  similar  to  that  of  the  region, 
characterized by pinyon-juniper woodland integrating with big sagebrush (Artemisia tridentata) communities.

Off-site infrastructure includes paved highway access from U.S. Highway 191 and rights-of-way for commercial power and a water 
supply pipeline from Recapture Reservoir, which brings up to 1,000 acre-feet of water per year to the Mill site. The Mill also has 
three deep (2,000+ foot) water supply wells, which are available to supply process water during normal operations.

Ownership

The White Mesa Mill is located on 4,816 acres of private land owned in fee by Energy Fuels. This land is located in Township 37S 
and 38S Range 22E Salt Lake Principal Meridian. Energy Fuels also holds 253 acres of mill site claims and a 320-acre Utah state 
lease. No facilities are planned on the mill site claims or leased land, which are used as a buffer to the operations. Total holding 
costs for the Mill in 2023 were $14,084. 

All operations authorized by the Mill’s License are conducted within the confines of the existing site boundary. The milling facility 
currently occupies approximately 50 acres, and the current tailings disposal cells encompass another 250 acres.

Permitting and Licensing

The White Mesa Mill holds a Radioactive Materials License through the State of Utah (the “Mill License”). Uranium milling in the 
U.S. is primarily regulated by the NRC pursuant to the Atomic Energy Act of 1954, as amended. The NRC’s primary function is to 
ensure the protection of employees, the public and the environment from radioactive materials, and it also regulates most aspects of 
the uranium recovery process. The NRC regulations pertaining to uranium recovery facilities are codified in Title 10 of the Code of 
Federal Regulations. These regulations also apply to our ISR facilities in Wyoming and Texas.

On August 16, 2004, the State of Utah became an Agreement State for the regulation of uranium mills. This means that the primary 
regulator for the Mill is the UDEQ rather than the NRC. At that time, the Source Material License, which was previously issued and 
regulated by the NRC, was transferred to the State and became a Radioactive Materials License. The State of Utah incorporates, 
through its own regulations or by reference, all aspects of Title 10 pertaining to uranium recovery facilities. The Mill License was 
due  for  renewal  on  March  31,  2007.  Energy  Fuels’  predecessor  timely  submitted  its  application  for  its  Mill  License  renewal  on 
February 28, 2007. The renewed Mill License was issued by UDEQ on January 19, 2018, then reissued on February 16, 2018, for a 
period  of  ten  years  (with  a  number  of  Amendments  issued  since),  after  which  another  application  for  renewal  will  need  to  be 
submitted. During the review period for each application for renewal, the Mill can continue to operate under its then existing Mill 
License until such time as the renewed Mill License is issued. The Mill License was initially issued in 1980 and was also renewed in 
1987 and 1997.

When the State of Utah became an Agreement State, it required that a GWDP be put in place for the Mill. The GWDP is required 
for all similar facilities in the State of Utah and affects the State groundwater regulations to the Mill site. The State of Utah requires 
that every operating uranium mill have a GWDP, regardless of whether the facility discharges to groundwater. The GWDP for the 
Mill  was  finalized  and  implemented  in  March  2005.  The  GWDP  required  that  the  Mill  add  over  40  additional  monitoring 

83

parameters and 15 additional monitoring wells at the site. The GWDP came up for renewal in 2010, at which time an application for 
renewal  was  timely  submitted.  The  renewed  GWDP  was  issued  by  UDEQ  on  January  19,  2018  for  a  period  of  five  years.  An 
application for renewal of the GWDP was submitted on July 15, 2022, prior to expiration of the current GWDP. The application 
remains under consideration at this time. During the review period for each application for renewal, the Mill can continue to operate 
under its then existing GWDP until such time as the renewed GWDP is issued. The Mill also maintains a permit for air emissions 
with the UDEQ, Division of Air Quality.

The  Mill  is  subject  to  decommissioning  liabilities.  Energy  Fuels,  as  part  of  the  Mill  License,  is  required  to  annually  review  its 
estimate for the decommissioning of the Mill site and submit it to UDEQ for approval. The estimate of closure costs for the Mill is 
$23.8  million  as  of  December  31,  2023,  and  financial  assurances  are  in  place  for  the  total  amount.  However,  there  can  be  no 
assurance that the ultimate cost of such reclamation obligations will not exceed the estimated liability contained in the Company’s 
financial statements.

History

The  Mill  was  originally  constructed  and  owned  by  Energy  Fuels  Nuclear,  Inc.  (“EFN”)  and  its  affiliates  (no  relation  to  the 
Company). It was licensed by the NRC and commenced operations in June 1980. In 1984, EFN transferred a 70% interest in the 
Mill to UMETCO Minerals Corp., a subsidiary of Union Carbide Corporation (“UMETCO”). UMETCO became the operator of the 
Mill in 1984 and continued to be the operator until 1994, at which time UMETCO transferred its interest in the Mill back to EFN 
and  its  affiliates.  The  Mill  was  acquired  by  Denison  Mines  Corp.  (“Denison”),  then  named  International  Uranium  Corporation 
(“IUC”)  and  its  affiliates  in  1997  and  was  operated  by  Denison  until  it  was  acquired  by  the  Company  in  June  2012.  From  the 
original commissioning in 1980 through December 31, 2023, the Mill has recovered a total of approximately 40 million pounds of 
U3O8 and 46 million pounds of vanadium.

In  late  2006,  Denison  began  a  program  to  refurbish  the  Mill.  The  refurbishment  program  included  the  purchase  of  mobile 
equipment, restoration of the vanadium roasting, fusion and packaging circuits, replacement of major pumps and component drives, 
modernization of the Mill’s instrumentation and process control systems, and completion of relining tailings Cell 4A. The total cost 
of the refurbishment program was approximately $31.0 million and was completed in 2008.

The Mill has historically operated on a campaign basis. In 2008, the Mill began processing uranium/vanadium conventional mined 
material,  extracting  uranium  concentrate  in  the  form  of  U3O8,  and  vanadium  in  the  form  of  V2O5.  Mineral  processing  continued 
through the end of March 2009, at which time maintenance activities were performed at the Mill. Mineral processing recommenced 
near the end of April 2009 but was discontinued due to a decline in uranium prices at the time. The Mill began mineral processing 
again in March 2010 and continued through June 2011. Conventional processing recommenced in November 2011 and continued 
until early March 2012, at which time it ceased for routine maintenance. Conventional mineral processing recommenced at the Mill 
in August 2012 and continued until early June 2013. Mineral processing began again in May 2014 and continued through August 
2014. The alternate feed circuit processed materials from January through December 2014 and continued processing Alternate Feed 
Materials  through  December  2015.  In  2016,  the  Company  continued  processing  several  Alternate  Feed  Materials  and  processed 
45,057  tons  of  mineralized  material  from  its  Pinenut  mine.  In  2017  and  2018,  the  Mill  continued  processing  Alternate  Feed 
Materials  as  well  as  the  recovery  of  uranium  from  tailings  pond  solutions  at  the  site.  In  2020,  Mill  activities  focused  solely  on 
processing  Alternate  Feed  Materials  and  uranium  and  vanadium  recovery  from  tailings  pond  solutions  at  the  site.  In  2021,  Mill 
activities  focused  solely  on  processing  monazite  from  heavy  mineral  sands  operation  for  the  recovery  of  U3O8  and  rare  earth 
elements. In 2023, the Mill processed monazite feeds to produce approximately 260 metric tonnes of partially separated rare earth 
oxides.

Energy Fuels acquired the Mill from Denison Mines Corp. on June 29, 2012. All mineral processing after that date has been for the 
account of Energy Fuels.

Project or Source

2023

2022

2021

2020

2019

Alternate Feed Materials(2)

Tons (000)

Ave. % U3O8

Recovered Pounds U3O8 (000)

---

---

---

3

3.3%

161

---

---

---

NA(2)

NA(2)

144(3)

NA(2)

NA(2)

---

Tailings Solution Recycle & Production from In-Circuit Material(4)

84

Recovered Pounds U3O8 (000)

Recovered Pounds V2O5 (000)

Recovered Metric Tons Total Rare Earth Oxide (TREO)

Conventional Feed Materials(5)

---

---

---

---

---

---

Tons (000)

326

0.1

Contained Grade % U3O8

0.46%

0.5%

Recovered Pounds U3O8 (000)(6)

Recovered Pounds V2O5 (000)

---

---

Recovered Metric Tons Total Rare Earth Oxide (TREO)

260

1

---

95

---

---

0

---

---

---

---

120

47

67

---

---

---

---

---

---

Nichols Ranch(7)

Alta Mesa(8)

Recovered Pounds U3O8 (000)

0.2

0.5

0.5

6

Recovered Pounds U3O8 (000)

Total Pounds of U3O8 Recovered (000)

Total Pounds of V2O5 Recovered (000)

Total Metric Tons of TREO Recovered

Notes:

---

0.2

---

260

---

162

---

95

---

---

---

120

---

197

67

---

---

1,807

---

---

---

---

---

---

70

---

70

1,807

---

(1)  Mineralized  material  is  shown  as  being  processed  and  pounds  recovered  during  the  year  in  which  the  materials  were 
processed at the Mill or at the Nichols Ranch Plant, which is not necessarily the year in which the materials were extracted from 
the project facilities.
(2) All Alternate Feed Materials were processed at the Mill. A number of different Alternate Feed Materials were processed 
during the period from 2019 through 2023. The table shows the average uranium grades and the total pounds recovered from all 
Alternate Feed Materials processed at the Mill during each of the years in that period. Because of the variability in uranium 
grades, pounds recovered is considered to be the relevant metric and tons fed is not considered to be relevant.
(3) The 161,000 pounds recovered in 2022 include nil pounds recovered for the accounts of third parties. The 144,000 pounds 
recovered in 2020 include nil pounds recovered for the accounts of third parties. 
(4)  Pounds  contained  in  tailings  solutions  containing  previously  unrecovered  uranium  and  vanadium,  together  with  in-circuit 
mineralized material from previous conventional mine material processing, were recovered at the Mill, though tons and grade 
are not available because they cannot be tied to any specific source.
(5) Includes uranium and TREO recovered from monazite processing.
(6) The 1,000 pounds of 162,000 pounds of U3O8 packaged in 2022 is uranium recovered from monazite processing in 2021 
and 2022. This amount does not include an additional approximately 1,000 pounds of U3O8 recovered during 2021 and 2022, 
which was in process and not packaged as of December 31, 2022. All uranium recovered from monazite processing in 2021 was 
retained  in  process  and  not  packaged  in  2021.  A  portion  of  uranium  recovered  in  2021  was  packaged  in  2022,  with  the 
remainder held in process as at December 31, 2022. The uranium concentration of monazite is comparable to typical Colorado 
Plateau conventional ores processed at the Mill on a regular basis. The relatively small quantities of uranium recovered from the 
monazite processed in 2021 and 2022 is a reflection of the low tonnage of monazite processed through the Mill during those 
years.
(7) Uranium recovery commenced at the Nichols Ranch Project on April 17, 2014. Because the Nichols Ranch Project uses ISR 
instead  of  conventional  extraction  methods,  grade  and  tons  of  mineralized  material  are  inapplicable  to  the  Nichols  Ranch 
Project. 
(8) The Alta Mesa Project was sold by the Company on February 14, 2023.

85

Planned Operations and Maintenance

Present Condition of the Property

The Mill recovered no pounds of U3O8 during 2019, and operations focused solely on vanadium recovery from dissolved vanadium 
in the Mill’s tailings management system not recovered from previous processing activities (“Pond Return”). The Mill recovered 
approximately 67,000 pounds of V2O5 in 2020 from Pond Return. Of these 67,000 pounds of V2O5, all were for the account of the 
Company.  During  2020,  the  Company  recovered  approximately  190,000  pounds  of  U3O8  from  the  processing  of  Alternate  Feed 
Materials and Pond Return. The Company also recovered approximately 68,000 pounds of V2O5 from Pond Returns. In 2020, the 
Company also began processing an REE feed at a pilot scale. The Company produced approximately 4 metric tons of RE Carbonate. 
In 2021, the Mill processed 400 tons of monazite and produced 120 tonnes of TREO in the form of RE Carbonate. In 2022, the Mill 
processed 184 tonnes of monazite and produced 95 tonnes of TREO in the form of RE Carbonate and, in 2023, the Mill processed 
326 tonnes of monazite and recovered 260 tonnes of TREO in the form of RE Carbonate. The Mill operations registered zero lost 
time accidents in 2019, 2020, 2021, 2022 and 2023.

Environmental Matters

Prior to Energy Fuels’ acquisition of the Mill from Denison, chloroform in the shallow aquifer at the Mill site was discovered. The 
chloroform appears to have resulted from the operation of a temporary laboratory facility that was located at the site prior to and 
during  the  construction  of  the  Mill,  and  from  septic  drain  fields  that  were  used  for  laboratory  and  sanitary  wastes  prior  to 
construction of the Mill’s Tailings Management System (“TMS”). In April 2003, Denison commenced an interim remedial program 
of  pumping  the  chloroform  affected  water  from  the  groundwater  to  the  Mill’s  TMS.  This  action  enabled  Energy  Fuels  to  begin 
cleanup  of  the  affected  areas  and  to  take  a  further  step  towards  resolution  of  this  outstanding  issue.  Pumping  from  the  wells 
continued  through  2015.  On  September  14,  2015,  the  State  of  Utah  approved  a  long-term  Corrective  Action  Plan  (“CAP”)  for 
cleanup  of  the  chloroform,  which  involves  additional  pumping  wells  and  continued  pumping  of  the  affected  water  to  the  Mill’s 
TMS.  While  the  investigations  to  date  indicate  that  this  chloroform  appears  to  be  contained  in  a  manageable  area,  the  scope  and 
costs of final remediation have not yet been determined and could be significant.

Prior to Energy Fuels’ acquisition of the Mill from Denison, elevated concentrations of nitrate and chloride were observed in some 
of  the  monitoring  wells  at  the  Mill  site  in  2008,  a  number  of  which  are  upgradient  of  the  Mill’s  TMS.  Pursuant  to  a  Stipulated 
Consent Agreement with UDEQ, Denison retained INTERA, Inc., an independent professional engineering firm, to investigate these 
elevated  concentrations  and  to  prepare  a  Contamination  Investigation  Report  for  submittal  to  UDEQ.  The  investigation  was 
completed in 2009, and the Contamination Investigation Report was submitted to UDEQ in January 2010. INTERA concluded in 
the Report that: (1) the nitrate and chloride are co-extensive and appear to originally come from the same source; and (2) the source 
is  upgradient  of  the  Mill  property  and  is  not  the  result  of  Mill  activities.  UDEQ  reviewed  the  Report  and  concluded  that  further 
investigations  were  required  before  it  could  determine  the  source  of  the  contamination  and  the  responsibility  for  cleanup.  Such 
investigations were performed in 2010 and 2011 but were considered inconclusive by UDEQ. As a result, after the investigations, it 
was determined that there are site conditions that make it difficult to ascertain the source(s) of contamination at the site, and that it 
was not possible at that time to determine the source(s), causes(s), attribution, magnitude(s) of contribution, and proportion(s) of the 
local nitrate and chloride in groundwater. For those reasons, UDEQ decided that it could not eliminate Mill activities as a potential 
cause, either in full or in part, of the contamination. The Company and UDEQ have therefore agreed that resources are better spent 
in developing and implementing a CAP, rather than continuing with further investigations as to the source(s) and attribution of the 
groundwater contamination. Pursuant to a revised Stipulated Consent Agreement, Denison submitted a draft CAP for remediation of 
the contamination to UDEQ in November 2011. The CAP proposed a program of pumping the nitrate contaminated groundwater to 
the  Mill’s  tailings  cells,  similar  to  the  chloroform  remedial  program.  On  December  12,  2012,  the  Utah  Division  of  Waste 
Management  and  Radiation  Control  (“DWMRC”),  signed  the  Stipulation  and  Consent  Order  (“SCO”),  Docket  Number 
UGW12-04,  which  approved  the  Mill’s  CAP  dated  May  7,  2012  and  required  the  Mill  to  fully  implement  all  elements  of  it.  In 
accordance  with  the  CAP,  in  2013  the  Company  commenced  pumping  nitrate/chloride  contaminated  water  from  four  monitoring 
wells for use in Mill processing or discharge into the Mill’s process or TMS. In December 2017 the Mill filed its first Corrective 
Action  Comprehensive  Monitoring  Evaluation  (“CACME”),  required  under  the  CAP  every  five  years.  By  letter  dated  June  22, 
2018, the DWMRC requested the implementation of Phase III actions specified in the CAP. Phase III actions include modeling, and 
study  of  plume  dynamics  and  assessment  of  future  actions  if  any.  The  Phase  III  report  was  submitted  to  DWMRC  in  December 
2018  and  is  currently  under  review  by  DWMRC.  Although  the  contamination  appears  to  be  contained  in  a  manageable  area,  the 
scope and costs of final remediation have not yet been determined and could be significant.

The Mill has reported consecutive exceedances of groundwater compliance limits (“GWCLs”) under the Mill’s GWDP for several 
constituents in several wells. These exceedances include wells that are up-gradient of the Mill facilities, far down-gradient of the 
Mill site cross-gradient of the Mill site and at the site itself. As required by the GWDP, these consecutive exceedances of GWCLs 

86

have  resulted  in  the  completion  of  constituent  specific  assessments  and  additional  studies  which  are  documented  in  Source 
Assessment Reports. Source Assessment Reports were submitted addressing each exceedance at the site. UDEQ has accepted the 
Source  Assessment  Reports  and  has  concluded  that  such  exceedances  are  due  to  natural  background  influences  at  the  site. 
Amendments to the GWDP issued on January 19, 2018, March 19, 2019 and March 8, 2021, respectively, include revised GWCLs 
intended to account for these background influences and put the constituents back into compliance. Most recently, a GWDP renewal 
application was submitted in July 2022 and remains under consideration by DWMRC at this time. 

Total Cost of Project

The Mill was acquired by the Company in June 2012, through the acquisition of the U.S. Mining Division from Denison. The cost 
of the Mill has been fully impaired, and as of December 31, 2023, the total net book value attributable to the Mill and its associated 
equipment on the financial statements of the Company was nil.

The Company’s Planned Work

During  2024,  the  Company  expects  to  commission  its  rare  earth  separation  circuits  (Phase  1),  which  will  allow  it  to  recover 
approximately 25 to 35 tonnes of NdPr Oxide in the form of NdPr oxalate, as well as 10 to 20 tons of SEG and heavy rare earth 
oxides in the form RE carbonate from approximately 480 tonnes of monazite. The Company also expects to recover the associated 
uranium in the monazite, which is expected to result in a few thousand pounds of U3O8. 

The  Company  also  plans  to  process  Alternate  Feed  Materials  and  uranium  ore,  which  is  expected  to  result  in  the  recovery  of 
approximately  150,000  to  500,000  pounds  of  U3O8,  depending  on  the  timing  of  ramp  up  of  production  at  the  Company's  Pinyon 
Plain, La Sal and Pandora mines.

87

The Pinyon Plain Project

The following technical and scientific description of the Pinyon Plain Project is based in part on the Preliminary Feasibility Study 
titled “Technical Report on the Pre-Feasibility Study on the Pinyon Plain Project, Coconino County, Arizona, USA,” dated February 
23,  2023,  effective  as  of  December  31,  2022,  and  prepared  by  Mark  B.  Mathisen,  C.P.G.,  R.  Dennis  Bergen,  P.  Eng.  and  Grant 
Malensek, M.Eng., P. Eng., each a Qualified Person employed by SLR, Lee (Pat) Gochnour, MMSA, a Qualified Person employed 
by  Gouchnour  &  Associate,  Inc.  and  Jeffrey  Woods,  MMSA,  a  Qualified  Person  employed  by  Woods  Process  Services  (the 
“Pinyon Plain Technical Report Summary”). The Pinyon Plain Technical Report Summary was prepared in accordance with S-K 
1300 and NI 43-101. The Pinyon Plain Project was considered under SEC S-K 1300 definitions to be a development stage property 
as  at  December  31,  2023  because  it  contains  both  Mineral  Resources  and  Mineral  Reserves.  In  January  2024,  the  Company 
commenced  uranium  production  at  the  Pinyon  Plain  Project.  If  and  when  the  Company  engages  in  material  extraction  from  the 
Pinyon Plain Project, the Project will be considered a production stage property and the Company will be considered a production 
stage issuer. 

Property Description

The Pinyon Plain Project is a fully permitted underground uranium and copper deposit in northern Arizona, located on a 17-acre site 
within the Kaibab National Forest. The property is located at latitude 35°52'58.65" N and longitude 112° 5'47.05" W. It is situated 
153 mi north of Phoenix, 86 mi northwest of Flagstaff, and seven miles southeast of Tusayan, in Sections 19 and 20, Township 29 
North,  Range  03  East,  Gila  and  Salt  River  Meridian  (GSRM),  Coconino  County,  Arizona.  Ore  haulage  from  the  Pinyon  Plain 
Project to the Mill in Blanding, Utah, is 315 miles on paved roads and 5 miles on dirt roads.

88

Ownership

The Company’s property position at the Pinyon Plain Project consists of nine unpatented lode mining claims (Canyon 64–66, 74–
76, and 84–86), located on USFS land, encompassing approximately 186 acres. All claims are held in perpetuity by annual claims 
payments due on September 1. EFR acquired the Pinyon Plain Project in June 2012 and has a 100% interest in the claims. 

Claim maintenance costs for 2023 were $1,485. The claims have a 3.5% Atomic Energy Commission Circular 5 royalty on uranium 
production, payable to a former owner of the claims.

Accessibility, Climate, Local Resources, Infrastructure and Physiography

Access to the Pinyon Plain Project site is via State Highway 64 and Federal Highway 180 to within five miles of the project site, 
then over unsurfaced public USFS roads. The Atchison, Topeka and Santa Fe railway line passes east-west 50 mi south of the site at 
Williams, and a spur of the railway, which passes 10 mi west of the Pinyon Plain Project site, services the Grand Canyon National 
Park. Airports at Flagstaff, Phoenix, Prescott and Tusayan provide air access to the area. 

The climate in northern Arizona is semi-arid, with cold winters and hot summers. January temperatures range from approximately 
7°F to 57°F and July temperatures range from 52°F to 97°F. Annual precipitation, mostly in the form of rain but with some snow, is 
about 12 in.

Northern  Arizona  is  part  of  the  Colorado  Plateau,  a  region  of  the  western  U.S.  characterized  by  semi-arid,  high-altitude,  gently 
sloping  plateaus  dissected  by  steep  walled  canyons,  volcanic  mountain  peaks,  and  extensive  erosional  escarpments.  The  Pinyon 
Plain Project is located on the Coconino Plateau within the Colorado Plateau, at an elevation of approximately 6,500 feet above sea 
level (ft ASL).

89

Although  the  Coconino  Plateau  is  sparsely  populated,  tourist  traffic  to  Grand  Canyon  National  Park  results  in  large  numbers  of 
people passing through the region daily. Personnel for future mining operations are expected to be sourced from the nearby towns of 
Williams and Flagstaff, Arizona (50 miles and 70 miles, respectively), as well as other underground mining districts in the western 
U.S.  Material  mined  at  the  Pinyon  Plain  Project  will  be  transported  320  miles  on  paved  roads  to  EFR’s  White  Mesa  Mill  in 
Blanding, Utah for processing.

In 1982, EFN, which is not part of Energy Fuels Inc., acquired the Project. From 1982 to 1987, EFN conducted exploration drilling, 
permitted the mine, constructed certain surface facilities including a headframe, hoist, and compressor, and sunk the shaft to a depth 
of 50 ft. From 1987 to 2013, the Project was put on standby due to low uranium prices. In 2012, EFR acquired the Project through 
its acquisition of Denison Mines Corporation’s US assets (Denison). Beginning in 2013, EFR refurbished the surface facilities and 
extended the shaft an additional 228 ft to a depth of 278 ft. In late 2013, the project was again placed on standby due to low uranium 
prices.  In  October  2015,  EFR  re-started  the  Project  and  committed  to  completing  the  shaft  and  underground  delineation  drilling 
program. From October 2015 to March 2017, the shaft was sunk to a depth of 1,452 ft, and three development levels were started at 
the 1,003 ft, 1,220 ft; and 1,400 ft depths, all of which have functioned as drill stations. The final depth for the shaft is 1,470 ft. 

In addition to the mine shaft, existing surface mine infrastructure includes surface maintenance shops, employee offices and change 
rooms, a water well, an evaporation pond, water treatment plant, explosive magazines, water tanks, fuel tank, and a rock stockpile 
(development rock). Electrical power is available through an existing power line that terminates at the site.  

History

The Pinyon Plain Project is located on mining claims that EFN acquired from Gulf Mineral Resources (Gulf) in 1982 who originally 
staked  the  claims  in  April  1978.  EFN  was  acquired  by  the  Concord  group  in  the  early-1990s.  The  Concord  group  declared 
bankruptcy in 1995, and most of the EFN assets, including the Pinyon Plain Project, were acquired by IUC in 1997. IUC merged 
with  Denison  Mines  Inc.  on  December  1,  2006,  and  the  new  company  changed  its  name  to  Denison  Mines  Corporation.  In  June 
2012, Energy Fuels Inc. acquired all of Denison’s mining assets and operations in the U.S. Currently the Pinyon Plain Project claims 
are held by the Company. Between 1978 and 1994, Gulf and EFN drilled 45 surface holes, including a deep water well, totaling 
62,289 ft. 

Since 1994, exploration activities undertaken on the property have only included drilling. Prior to that, exploration activities carried 
out by EFR’s predecessors from 1983 to 1987 include:

•
•
•
•
•
•

Ground control source audio magneto tellurium (CSAMT) surveys
Ground magnetics
Ground very low frequency (VLF) surveys
Time domain electro-magnetic surveys (TDEM)
Surface gravity surveys
Airborne electromagnetic (EM) surveys

During  2016  and  2017  the  Company  conducted  an  underground  exploration  drilling  campaign  during  shaft  sinking  completing 
30,314 ft. of drilling. Shaft sinking continued into 2018 finishing at a total depth of 1,470 ft.

Permitting and Licensing

The Pinyon Plain Project is located on public lands managed by the USFS and has an approved PO with the USFS. In 2020, the 
Company submitted a clean closure plan to the USFS to provide a description of how the Company will reclaim the mine to clean 
closure  standards  after  the  cessation  of  mining  operations,  as  contemplated  in  the  USFS-approved  PO,  Record  of  Decision  and 
modifications  to  the  reclamation  plan  contained  in  Appendix  B  of  the  Environmental  Impact  Statement.  The  clean  closure  plan 
included an update to the reclamation cost estimate, resulting in an increase from $461,245 to $1,407,235. In September 2009, the 
groundwater General Aquifer Protection Permit (“APP”) was obtained for the water storage pond from the ADEQ. This permit was 
up  for  renewal  in  2019,  and  an  application  for  renewal  was  timely  submitted  by  the  Company  in  2019.  General  APPs  were  also 
obtained from ADEQ for the development rock stockpile and intermediate ore stockpile in December 2011 and renewed in 2018. At 
the request of the ADEQ, the three General APPs were consolidated into an Individual APP on April 28, 2022, which resulted in a 
supplemental reclamation bond being issued in the amount of $132,581. An Air Quality Permit was issued by the ADEQ in March 
2011, renewed in 2016, amended in 2017 and renewed in 2021. The Company received EPA’s approval under the Clean Air Act 
National Emissions Standard for Hazardous Air Pollutants for the Pinyon Plain Project in September of 2015. 

Development  of  uranium-bearing  breccia  pipes  of  the  Arizona  Strip  requires  minimal  surface  disturbance,  typically  less  than  20 
acres total. Thus, the overall environmental impact is minimal. Nevertheless, the areas in the general vicinity of the Grand Canyon 

90

can be environmentally sensitive in many ways and so the permitting, development, and operation of a uranium extraction facility in 
this  area  remains  a  contentious  issue.  As  described  above,  in  2009  over  one  million  acres  of  federal  land  were  withdrawn  from 
mineral  location,  subject  to  valid  existing  rights,  and  on  August  8,  2023,  President  Biden  designated  the  Baaj  Nwaavjo  I’tah 
Kukveni – Ancestral Footprints of the Grand Canyon National Monument, which also restricted approximately one million acres of 
previously withdrawn lands from mineral location, subject to valid existing rights. The Pinyon Plain mine is located within these 
withdrawal and national monument areas, but is considered to have valid existing rights, so can continue to be mined in accordance 
with its USFS-approved PO. Reclamation at the Pinyon Plain Project is bonded at its total expected cost.

Geological Setting, Mineralization and Deposit

Parts of two distant physiographic provinces are found in Arizona: the Basin and Range Province located in the southern portion of 
the state; and the Colorado Plateau Province located across the northern and central portions of the state. Pinyon Plain lies within the 
Colorado Plateau Province. 

The  region  has  experienced  volcanic  activity  since  the  Pliocene  epoch.  A  number  of  lava-capped  buttes  rise  above  the  general 
landscape,  and  lava  flows  cover  large  areas  in  the  southern  part  of  the  district.  Faulting  has  exerted  significant  control  on  the 
geologic  development  and  geomorphic  history  of  the  region.  Major  structural  features  include  the  Grand  Wash,  Hurricane,  and 
Toroweap  fault  systems,  all  trending  generally  north-south  with  an  eastern  up-thrown  side.  These  faults  are  topographically 
prominent and show impressive scarps though other less prominent fault systems exist. 

The surface expression of the Pinyon Plain breccia pipe is a broad shallow depression in the Permian Kaibab Formation. The pipe is 
essentially  vertical  with  an  average  diameter  of  less  than  200  ft.  but  is  considerably  narrower  through  the  Coconino  and  Hermit 
horizons (80 ft in diameter). The cross-sectional area is in the order of 20,000 ft2 to 25,000 ft2. The pipe extends for at least 2,300 ft 
vertically  from  the  Toroweap  limestone  to  the  upper  Redwall  horizons.  The  ultimate  depth  of  the  pipe  is  unknown.  Uranium 
mineralization is concentrated in an annular ring within the breccia pipe. 

Mineralization  extends  vertically  both  inside  and  outside  the  pipe  over  approximately  1,700  vertical  ft,  but  potentially  economic 
grade mineralization has been found mainly in the collapsed portions of the Coconino, Hermit, and Esplanade horizons and at the 
margins of the pipe in fracture zones. Sulphide zones are found scattered throughout the pipe but are especially concentrated in a 
sulphide cap near the Toroweap-Coconino contact, where the cap averages 20 ft in thickness and consists of pyrite and bravoite, an 
iron-nickel  sulphide.  The  mineralization  assemblage  consists  of  uranium-pyrite-hematite  with  massive  copper  sulphide 
mineralization  common  in  and  near  the  uranium  zone.  The  strongest  mineralization  appears  to  occur  in  the  lower  Hermit-upper 
Esplanade horizons in an annular fracture zone. 

In  the  mineralized  zone,  the  uranium  mineralization  occurs  largely  as  blebs,  streaks,  small  veins,  and  fine  disseminations  of 
uraninite/pitchblende  (UO2).  Mineralization  is  mainly  confined  to  matrix  material,  but  may  extend  into  clasts  and  larger  breccia 
fragments, particularly where these fragments are Coconino sandstone. In addition to uranium, copper mineralization is also found 
within the Main Zone of the breccia pipe. Typically replacing the matrix material, copper occurs as chalcocite, bornite, tennantite, 
and  covelite.  Additionally,  lower  quantities  of  silver,  zinc,  lead,  molybdenum,  copper,  nickel,  and  vanadium  are  present  and 
scattered throughout the pipe.

Data Verification

The assay data used to calculate the Mineral Resource and Reserve estimate for the Project is a combination of radiometric log data 
and core. Calibration data for natural gamma is available for both historical and recent drilling. When drilling is active, the natural 
gamma logging trucks and tools are calibrated at least every three months. Natural gamma calibration is performed at DOE standard 
calibration facilities located in Grand Junction, Colorado. 

Drill  core  was  collected  from  both  historical  surface  holes  and  recent  underground  drilling.  Recent  core,  which  makes  up  the 
majority  of  data  for  the  Project  was  analyzed  at  the  Mill.  The  Company  utilized  standard  QA/QC  procedures  for  analyzing  both 
uranium and copper. This QA/QC program involved the submission of duplicate samples, certified reference materials and blank 
samples to the White Mesa Mill laboratory. It also included sending samples to 3rd Party laboratories for analysis and the submission 
of certified reference materials to those laboratories.

Utilizing  only  natural  gamma  logs  as  assay  data  could  lead  to  an  over  or  under  estimation  of  Mineral  Resources  due  to 
disequilibrium. Positive disequilibrium occurs when the uranium present has not had enough time to decay and produce daughter 
isotopes, which are what are actually measured during a natural gamma assay. Under positive disequilibrium a natural gamma assay 
would indicate lower amounts of uranium than what is present. Negative disequilibrium occurs when uranium has had enough time 
to decay to produce the daughter radioisotopes but was remobilized and removed from the deposit. This would lead to measuring 

91

more uranium than is present. The use of core to verify natural gamma logs is standard practice and allows for the calculation of a 
disequilibrium factor. The disequilibrium factor applied to the Project Mineral Resource is 1.0.

Mineral Resource Estimate

Mineral Resource estimates were prepared for the Pinyon Plain deposit using both historical surface drill hole gamma and assay data 
and  gamma  and  assay  data  collected  during  underground  drilling  in  2016  and  2017.  A  model  of  the  breccia  pipe  host  was 
constructed based on drill logs and constrains the Mineral Resource. Mineralization wireframes for U3O8 were based on assays and 
gamma data at a nominal cut-off grade of 0.15%. Low and high-grade copper wireframes were based on nominal cutoff grades of 
1%  and  8%  respectively.  Values  for  U3O8  and  copper  were  interpolated  into  blocks  using  inverse  distance  squared  or  ordinary 
kriging.  Resources  are  presented  a  0.40%  U3O8  Eq  equivalent  cut-off  grade  for  zones  that  contain  both  uranium  and  copper 
mineralization  (Main  and  Main-Lower)  and  at  a  0.30%  U3O8  cut-off  grade  for  zones  that  contain  only  uranium  mineralization 
(Main-Lower, Juniper I and Juniper II).

A  copper  mineral  resource  is  also  associated  with  the  Main  and  Main-Lower  zones  at  Pinyon  Plain.  Further  study  is  required  to 
determine if the copper associated with uranium mineralization in the zones can be economically extracted.

The  table  below  sets  out  the  Mineral  Resources  estimates  for  the  Pinyon  Plain  Project  as  of  December  31,  2023.  As  stated  in 
SK-1300 regulations, Mineral Resources must be reported exclusively of Mineral Reserves; therefore, because Mineral Resource to 
Mineral Reserve conversion was 100% in the Main Zone, no Mineral Resources are reported for the Main Zone. These estimates are 
derived from the Pinyon Plain Technical Report Summary. Daniel Kapostasy, the Company’s non-independent Qualified Person, 
reviewed  and  confirmed  that  the  Mineral  Resources  estimates  set  forth  in  the  Pinyon  Plain  Technical  Report  Summary  remained 
accurate as of December 31, 2023. 

Zone

Pinyon Plain Project – Summary of Mineral Resources – In Situ Uranium, December 31, 2023(1)(2)(3)(4)(5)(6)(7)(8)
Tonnage 
(Tons)
---

Contained Metal 
(lb U3O8)
---

Cut-Off (% 
U3O8)
0.3

Grade 
(%U3O8)
---

Metallurgical 
Recovery
---

Classification

Measured

Main Lower

Juniper I

Juniper II

Indicated

Measured + Indicated

Inferred

Measured

Indicated

Measured + Indicated

Inferred

Measured

Indicated

Measured + Indicated
Inferred

Total Measured

Total Indicated

Total Measured + Indicated

Total Inferred

Notes:

0.3

0.3

0.3

0.3

0.3

0.3

0.3

0.3

0.3

0.3
0.3
0.3

0.3

0.3

0.3

---

---

2,000

---

37,000

37,000

2,000

---

---

---
1,000

---
37,000

37,000

5,000

---

---

0.48

---

0.95

0.95

0.58

---

---

---
0.36

---
0.95

0.95

0.50

---

---

16,000

---

703,000

703,000

24,000

---

---

---
8,000

---
703,000

703,000

48,000

---

---

96%

---

96%

96%

96%

---

---

---
96%

---
96%

96%

96%

(1)  SEC  S-K  1300  definitions  were  followed  for  all  Mineral  Resource  categories.  These  definitions  are  also  consistent  with 
CIM (2014) definitions in NI 43-101.
(2) Mineral Resources are estimated at 0.30% U3O8 with an estimated metallurgical recovery of 96% for uranium.
(3)  Mineral  Resources  are  estimated  using  a  long-term  uranium  price  of  US$65  per  pound.  The  long-term  uranium  price  is 
based on supply and demand projections for the period 2021-2035. 
(4) No minimum mining width was used in determining Mineral Resources.
(5) Bulk density is 0.082 st/ft3 (12.2 ft3/ton or 2.63 ton/m3).
(6) Mineral Resources are exclusive of Mineral Reserves and do not have demonstrated economic viability.
(7) Numbers may not add due to rounding.
(8) Mineral Resources are 100% attributable to the Company.

92

The U3O8 Mineral Resource estimate for the Pinyon Plain Project dated December 31, 2023 decreased from the previously reported 
Mineral  Resource  estimate  effective  December  31,  2021  due  to  the  first-time  disclosure  of  Mineral  Reserves.  Total  Measured 
Mineral Resources decreased from 6,000 tons at 0.46% U3O8 containing 55,000 lbs U3O8 on December 31, 2021 to nil on December 
31, 2022, a 100% decrease. Total Indicated Mineral Resources decreased from 127,000 tons at 0.92% U3O8 containing 2,347,000 
lbs  U3O8  to  37,000  tons  at  0.95%  U3O8,  totaling  703,000  lbs  U3O8,  a  70%  decrease.  Total  Inferred  Mineral  Resources  decreased 
from  16,300  tons  at  0.39%  U3O8,  containing  126,000  lbs  U3O8  to  5,000  tons  at  0.50%U3O8,  totaling  48,000  lbs  U3O8,  a  62% 
decrease. The decrease in the Inferred Mineral Resource is attributable to removing the Upper and Cap Mineral Resources from the 
Mineral  Resource  estimate  and  converting  these  amounts  to  Mineral  Reserves  as  further  disclosed  below.  Daniel  Kapostasy,  the 
Company’s non-independent Qualified Person, reviewed and confirmed that the Mineral Resources estimates set forth in the Pinyon 
Plain Technical Report Summary remained accurate as of December 31, 2023. 

Pinyon Plain Project – Summary of Mineral Resources – In Situ Copper, December 31, 2023(1)(2)(3)(4)(5)(6)(7)(8)(9)(10)
Tonnage 
Zone
(Tons)
6,000

Cut-Off 
(eqv. U3O8)
0.4

Grade (%Cu) Contained Metal 

Metallurgical 
Recovery
90%

(lb Cu)
1,155,000

Classification

Measured

9.6

Main

Indicated

Measured + Indicated

Main Lower

Inferred

Measured

Indicated

Measured + Indicated

Inferred

Total Measured

Total Indicated

Total Measured + Indicated

Total Inferred

0.4

0.4

0.4

0.4

0.4

0.4

0.4
0.4

0.4

0.4

0.4

90,000

96,000

---

---

---

---

4,000
6,000

90,000

96,000

4,000

5.9

6.1

---

---

---

---

6.5
9.6

5.89

6.1

6.5

10,553,000

11,708,000

---

---

---

---

470,000
1,155,000

10,553,000

11,708,000

470,000

90%

90%

---

---

---

---

90%
90%

90%

90%

90%

Notes:

(1)  SEC  S-K  1300  definitions  were  followed  for  all  Mineral  Resource  categories.  These  definitions  are  also  consistent  with 
CIM (2014) definitions in NI 43-101.
(2) For the Main and Main-Lower zones of the Pinyon Plain Project, a 0.40% uranium equivalent cut-off grade (% U3O8 Eq) 
was applied to account for both the copper and uranium mineralization. The %U3O8 Eq grade term is not the same as the eU3O8 
%  grade  term  which  indicates  probe  rather  than  assay  data  listed  elsewhere  in  this  report.  For  details,  seethe  Pinyon  Plain 
Project below.
(3)  Mineral  Resources  are  estimated  using  a  long-term  uranium  price  of  $65  per  pound  and  a  Copper  price  of  $4.00  per  lb. 
These  prices  are  based  on  independent,  third-party,  and  market  analysts’  average  forecasts  as  of  2022,  and  the  supply  and 
demand projections are for the period 2023 to 2035.
(4) A copper to U3O8 conversion factor of 18.19 was used for converting copper grades to equivalent U3O8 grades (U3O8 Eq) 
for cut-off grade evaluation and reporting.
(5)  For  the  Pinyon  Plain  Project,  Mineral  Resource  tonnages  of  uranium  and  copper  cannot  be  added  as  they  overlap  in  the 
Main and Main-Lower zones.
(6) No minimum mining width was used in determining Mineral Resources.
(7) Bulk density is 0.082 ton/ft3 (12.2 ft3/ton or 2.63 t/m3).
(8) Mineral Resources are exclusive of Mineral Reserves and do not have demonstrated economic viability.
(9) Numbers may not add due to rounding.
(10) Mineral Resources are 100% attributable to EFR.

Mineral Reserve Estimate

Mineral Reserve estimates for Pinyon Plain are based on the Measured and Indicated Mineral Resources as of January 10, 2023, and 
a detailed mine designs and modifying factors such as external dilution and mining extraction factors. Mineral Resource to Mineral 
Reserve  conversion  was  100%  within  the  Main  Zone,  with  the  remaining  zones  (Main-Lower  and  Juniper)  not  considered  for 
inclusion as Mineral Reserves. No Inferred Mineral Resources were converted to Mineral Reserves.

93

Based on the similarity of the Pinyon Plain deposit to other past producing breccia pipe deposits in northern Arizona, the proposed 
mining methods at Pinyon Plain will include a combination of long-hole stoping, shrinkage stoping, and drifting. At the completion 
of mining, waste generated during mine development will be used to fill the mine openings per agreed upon government regulations. 
Metallurgical  test  results  provided  by  the  Company  indicated  that  metallurgical  recoveries  using  optimum  roasting  and  leach 
conditions will be approximately 96% for uranium.

Underground mine design completed by the Company were based on grade envelopes of assays at a nominal grade of 0.15% U3O8 
based on underground mining methods and processing via a toll milling agreement. 

The table below sets out the Mineral Reserves estimates for the Pinyon Plain Project as of December 31, 2023. These estimates are 
derived from the Pinyon Plain Technical Report Summary. Current economic conditions, mine design, and cash flow analysis do not 
account for processing of copper mineralization and thus copper is excluded from the Mineral Reserve estimate. Daniel Kapostasy, 
the  Company’s  non-independent  Qualified  Person,  reviewed  and  confirmed  that  the  Mineral  Resources  estimates  set  forth  in  the 
Pinyon Plain Technical Report Summary remained accurate as of December 31, 2023.

Classification

Pinyon Plain Project – Summary of Mineral Reserves, December 31, 2023(1)(2)(3)(4)(5)(6)(7)(8)
Tonnage 
(Tons)
7,800

Contained Metal 
(lb U3O8)
50,800

Cut-Off 
(%U3O8)
0.3

Grade 
(%U3O8)
0.33

Proven

Metallurgical 
Recovery
96%

Probable

Total Proven + Probable

0.3
0.3

126,700
134,500

0.6
0.58

1,517,000
1,567,800

96%
96%

Zone

Main

Notes:

(1) SEC S-K 1300 definitions were followed for all Mineral Reserve categories. These definitions are also consistent with CIM 
(2014) definitions in NI 43-101.
(2) Mineral Reserves are estimated using a long-term uranium price of US$60.00 per pound. The long-term uranium price is 
based on supply and demand projections for the period 2021-2035. 
(3)  Underground  Mineral  Reserves  were  estimated  by  creating  stope  shapes.  The  stope  shapes  were  created  using  a  grade 
envelope of 0.15% U3O8, with a minimum mining width of 5 ft (including hanging wall and footwall dilution), on 10 ft vertical 
stope heights.
(4) The breakeven cut-off grade is 0.32% U3O8.
(5) A mining extraction factor of 95% was applied to the underground stopes, while underground development assumed a 100% 
mining extraction factor.
(6) Mining Reserves are in-situ.
(7) The density varies according to the block model.
(8) Numbers may not add due to rounding.

The  Pre-Feasibility  Study  on  the  Pinyon  Plain  Project  dated  December  31,  2022  includes  a  first-time  disclosure  of  Mineral 
Reserves.  Proven  and  Probable  Mineral  Reserves  disclosed  as  of  December  31,  2021  were  nil.  Current  Mineral  Reserves  as  of 
December 31, 2022 include Proven and Probable Mineral Reserves totaling 134,500 tons at 0.58% U3O8 containing 1,567,800 lbs 
U3O8.

Present Condition of the Property and Work Completed to Date

At the Pinyon Plain Project, all surface facilities are in place. During 2017, an underground drilling program was completed, shaft 
sinking continued, and a large water tank was installed. The shaft sinking was completed by mid-March 2018. The depth of the shaft 
is approximately 1,470 feet below ground surface. Shaft stations are developed at depths of 1,000 feet (elevation 5,506 feet above 
sea level), 1,220 feet (elevation 5,286) and 1,400 feet (elevation 5,106).

The Company is evaluating the potential to recover copper from the mine as a co-product with uranium. During 2018, bench scale 
and pilot plant scale metallurgical test work was carried out by Hazen Research (“HAZEN”) in Golden, Colorado, in connection 
with the potential recovery of copper from the mine. At this time, any copper recovered would be expected to be processed using 
roasting, followed by acid leach and solvent extraction. Acid leach followed by SX is the current process used for uranium recovery. 
Following  solvent  extraction,  if  recovered,  a  saleable  copper  product  would  be  expected  to  be  produced  by  electro-winning.  To 
recover  copper  from  the  Pinyon  Plain  mineralized  material,  some  modifications  to  White  Mesa  Mill  process  circuits  would  be 
required. The copper modifications would be expected to include using the existing vanadium SX circuit for copper extraction, the 
addition  of  a  roaster  to  improve  copper  recovery,  and  the  addition  of  an  electro-winning  circuit.  Bench  and  pilot  scale  test  work 
done  by  HAZEN  in  2018  indicates  that  acid  leaching  after  roasting  pre-treatment  is  expected  to  result  in  satisfactory  copper  and 
uranium recoveries. The Company has not yet determined whether it would be feasible to recover copper along with uranium at the 
Pinyon Plain mine and may elect to forego processing copper mineralization from the mine.

94

In 2019, a 1,000,000-gallon water tank was installed, in addition to the existing 400,000-gallon tank installed in 2017. These above-
ground  storage  tanks  are  used  for  operational  flexibility  and  extra  water  storage  capacity  during  winter  months.  Three  floating, 
downcasting, enhanced evaporators have been installed in the Non-Stormwater Impoundment to aid in evaporation. The tanks and 
evaporators are part of Energy Fuels’ water balance management practices at the site.

In 2020, a fourth floating, down-casting, enhanced evaporator was installed at the site to increase the operational flexibility of the 
water  balance  management  practices.  Additionally,  a  water  capture  and  pumping  system  was  installed  in  the  shaft  to  segregate 
unimpacted water and store it for beneficial use.

In 2021, a water treatment plant was installed to process water for offsite transport. The water treatment plant was commissioned in 
April 2021. Water use agreements have been entered into with local farmers and ranchers through which they may utilize excess 
water from the Pinyon Plain Project for their own beneficial uses within the Coconino Plateau groundwater basin.

The Company decided in early 2022 to resume construction work at the Pinyon Plain mine. Site personnel were hired mid-year and 
work commenced to rehabilitate surface and underground infrastructure, including the mine shaft, hoist, shaft load out equipment, 
air compressors and mobile mine equipment. In some cases, new and used mining equipment was purchased. Engineering included 
finalizing the mine design, ventilation network and load out system. Mine development began in late 2022, which included driving 
drifts to the shaft loadout and sump clean-out.

In  continuing  to  move  the  Project  towards  production,  work  in  2023  included  the  hiring  of  new  onsite  personnel,  installation  of 
underground loading pockets, continued underground drift development, the installation of an underground shop, construction of a 
surface ore pad and starting a vent raise. The vent raise is expected to be completed in early 2024.

The  Pinyon  Plain  Project  was  acquired  by  the  Company  in  June  2012  through  the  acquisition  of  the  U.S.  Mining  Division  from 
Denison. As of December 31, 2023, the total net book value attributable to the Pinyon Plain Project and its associated equipment on 
the financial statements of the Company was $3.41 million.

The Company’s Planned Work

The Company announced in December 2023 that it was putting the Pinyon Plain mine into production, which production did not 
actually commence in any significant way until early 2024. This production will fulfill uranium contracts the Company entered into 
in  2022.  The  Company  expects  to  produce  25,000  to  30,000  tons  of  ore  from  the  Pinyon  Plain  Mine  in  2024.  In  addition  to 
production, the Company plans to complete an underground exploration drilling program during the year on the Juniper Zone of the 
deposit.

95

The Roca Honda Project

The following technical and scientific description of the Roca Honda Project is based in part on the report titled “Technical Report 
on  the  Roca  Honda  Project,  McKinley  County,  State  of  New  Mexico,  USA”  dated  February  22,  2022,  prepared  by  Grant  A. 
Malensek, M.Eng, P.Eng., Mark B. Mathisen, C.P.G., and David M. Robson, P.Eng., MBA, each a Qualified Person employed by 
SLR, Jeffrey L. Woods, MMSA QP, a Qualified Person Employed by Woods Process Services, Phillip E. Brown, C.P.G., R.P.G., a 
Qualified  Person  employed  by  Consultants  in  Hydrogeology,  and  Daniel  D.  Kapostasy,  P.G.,  SME  R.M.,  a  non-independent 
Qualified  Person  employed  with  the  Company  (the  “Roca  Honda  Technical  Report  Summary”).  The  Roca  Honda  Technical 
Report Summary was prepared in accordance with S-K 1300 and also constitutes a PEA pursuant to NI 43-101. The Roca Honda 
Project does not have known “Mineral Reserves” and is therefore considered under S-K 1300 definitions to be an exploration stage 
property, despite current ongoing permitting activities.

The Company acquired a majority of the Roca Honda Project on August 29, 2013 as a result of its acquisition of Strathmore. Certain 
adjacent properties (which now form part of the Roca Honda Project) were later acquired by the Company from URI in June 2015.

Property Description

The Roca Honda project is a proposed underground uranium mine located in McKinley County, in Central New Mexico, USA in the 
Ambrosia Lake subdistrict, immediately northeast of the city of Grants, New Mexico. The Mine is located at latitude 35°21’34.36” 
N and longitude 107°42’20.39” W.

The  Roca  Honda  Project  does  not  have  known  “Mineral  Reserves”  and  is  therefore  considered  under  S-K  1300  definitions  to  be 
exploratory in nature.

96

Ownership

Since  May  27,  2016,  the  Roca  Honda  Project  has  been  held  solely  by  Strathmore  Resources  (US)  Ltd  (Strathmore),  which  is  a 
wholly owned subsidiary of Energy Fuels Inc. Strathmore acquired the initial portion of the property on March 12, 2004, from Rio 
Algom Mining LLC (Rio Algom), a successor to Kerr-McGee Corporation (Kerr-McGee), which had staked the claims in 1965 and 
had continuously maintained them. Roca Honda Resources LLC. (RHR) was established on July 26, 2007, when Strathmore formed 
a limited liability company with Sumitomo Corporation of Japan and transferred the property to RHR. Energy Fuels Inc. acquired a 
100% interest in Strathmore in August 2013 and assumed Strathmore’s 60% ownership interest in RHR. Energy Fuels Inc. acquired 
the remaining 40% ownership interest in RHR in May 2016 and is now 100% owner of the Roca Honda Project. Total holding costs 
for 2023 were $34,275.

The Roca Honda Project covers an area of 4,440 acres and includes 63 unpatented lode-mining claims in Sections 9, 10 and 11; 64 
unpatented claims in Sections 5 and 6; 36 unpatented claims in Section 8; one adjoining New Mexico State General Mining Lease in 
Section 16; and the fee mineral interest in all of Section 17. The mining claims also extend onto a 9.4-acre narrow strip of Section 
11. The New Mexico State Lease was acquired by David Miller (former Strathmore CEO) on November 30, 2004, and subsequently 
transferred to Strathmore. Strathmore subsequently relinquished the lease and acquired it again in December 2015 (HG-0133) for a 
new  15-year  term  expiring  on  December  14,  2030.  The  “Rocca  Honda”  Claims  in  Sections  5  and  6  were  staked  by  Miller  and 
Associates in September 2004 and assigned to RHR on August 28, 2013. Strathmore acquired the “Roca Honda” claims in Section 8 
and the fee mineral interest in Section 17 on June 26, 2015, from Uranium Resource Incorporated (URI). 

Mining claim numbers RH 252, RH 279, RH 306, and RH 333, located in the southern part of Section 10, overlap into the northern 
part of Section 15, which is privately owned land, therefore, the overlapping portion of these claims are not valid. The Roca Honda 
property extends only to the Section 15 boundary. 

Mining claim numbers RH 325 to RH 333 are located along the eastern boundary of Section 10, extending west across the Section 
11 line by approximately 150 ft.

The initial 63 unpatented, contiguous mining claims (the Roca Honda group), covering an area of approximately 1,248.5 acres, are 
located on Sections 9, 10, and 11, which are federally owned lands within the Cibola National Forest administered by the USFS. 
Section 5 is also administered by the USFS while claims in Section 6 are located on U.S. Bureau of Land Management (BLM) land. 
Section 8 is split estate, the private surface belonging to Fernandez Ranch. Sections 5, 6, 9, 10, and 11 are open to the public, with 
the land used for a variety of purposes including grazing, mineral extraction, hunting, hiking, and other outdoor recreation activities. 
All  claims  are  listed  in  the  U.S.  BLM  Mining  Claim  Geographic  Index  Report  Mineral  and  Land  Record  System  (MLRS).  The 
claims covering Section 9, 10, and part of 11 have a location date of June 29 and 30, 1965. The claims in Section 8 have location 
dates  of  September  10,  1997.  The  Rocca  Honda  claims  in  Sections  5  and  6  were  located  on  September  6,  2004.  The  latest 
assessment year shown in MLRS is 2021 and the claims are shown as “Active.”

There is a 1% gross revenue, no deduction royalty payable to the original claim holders for the claims on Section 9. There are no 
royalties associated with the claims on Sections 5, 6, 8, 10, or 11.

Holding costs for the 163 claims include a claim maintenance fee of $165.00 per claim payable to the BLM before September 1 of 
each calendar year and recording an affidavit and Notice of Intent to hold with the McKinley County Clerk, New Mexico. County 
recording fees for the claims are approximately $425 per year

New Mexico General Mining Lease number HG-0133, located on Section 16, covers an area of 638 acres. The mining lease has a 
primary, secondary, tertiary, and quaternary term, each with annual rentals to be paid in advance. Strathmore first acquired a lease 
on Section 16 in November 2004 (Lease number HG-0036-002). As there was no provision to extend the lease past 2019 other than 
by production, Strathmore dropped the lease as its payment came due in December 2015. The New Mexico Land Office held an 
auction of the lease parcel that same month. Strathmore was the successful bidder, paying a $100,000 bonus. The new lease has a 
primary term of three years, and the annual rental is $1.00/acre ($640). The secondary term for years 4 and 5 will require a payment 
of $10/acre each year, and the tertiary term, years 6 through 10, will cost $3.00/acre each year. The lease will have a quaternary term 
for years 11 through 15 requiring an annual rental of $10.00 per acre plus an escalating advanced royalty of $10.00 per acre per 
year. By acquiring the new lease, Strathmore may now hold the land until production can begin up to December 14, 2030. At the 
end of the quaternary term, the lease may be automatically extended if production has begun. The lease stipulates a 5% of gross 
returns royalty to the State of New Mexico “less actual and reasonable transportation and smelting or reduction costs, up to 50% of 
the gross returns” for production of uranium, which is designated a “special mineral” in the lease.  

97

Accessibility, Climate, Local Resources, Infrastructure and Physiography

The Roca Honda Project is located approximately three miles northwest of the community of San Mateo, New Mexico, in McKinley 
County, and approximately 22 miles by road northeast of Grants, New Mexico, via State Highway NM 605. 

Climate  in  the  project  area  may  be  classified  as  arid  to  semi-arid  continental,  characterized  by  cool,  dry  winters,  and  warm,  dry 
summers. Grants has an annual average temperature of 50°F, with an average summer high of 87°F and low of 52°F, and average 
winter high of 47°F and low of 18°F. 

The  Roca  Honda  Project  would  employ  257  personnel  who  would  be  based  around  the  town  of  Grants,  Cibola  County,  New 
Mexico,  which  is  the  largest  community  near  the  Mine  area.  As  of  the  2020  census,  Cibola  County  has  a  population  of  27,172 
people of which 8,866 people reside in Grants. Additionally, the city of Albuquerque, New Mexico is located approximately 100 
miles east of the Roca Honda Project area and could be a source of most materials and technical support needed for the Roca Honda 
Project. To process mill feed from the Roca Honda Project for the 11-year mine life.

The  Roca  Honda  Project  is  located  in  an  historically  important  uranium-producing  region  of  central  New  Mexico.  All  the 
infrastructure necessary to mine and process significant commercial quantities of U3O8 currently exists. Infrastructure items include 
high voltage electrical supplies, water sources, paved roads and highways for transporting ROM mill feed crude ore and finished 
products, and accommodations for employees. Local and State infrastructure also includes hospitals, schools, airports, equipment 
suppliers, fuel suppliers, and communication systems.

The Roca Honda Project is located at elevations ranging from 7,100 ft above sea level (ft ASL) to 7,680 ft ASL with easterly and 
southerly dipping slopes. The area is sparsely populated, rural, and largely undeveloped. The predominant land uses include low-

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density livestock grazing, hay cultivation, and recreational activities such as hiking, sightseeing, picnicking, and seasonal hunting. 
Vegetation in the area consists mainly of grasses, pinyon pine, and juniper trees. 

Material mined at Roca Honda will be trucked 272 mi to the Mill in Blanding, Utah for processing. 

History

The Roca Honda Project has a long history of exploration and development with a number of owners. Kerr-McGee Oil Industries 
(Kerr-McGee), its subsidiaries, and successor (Rio Algom) completed significant work in from the mid-1960s until 1982 succeeded 
by  Western  Nuclear  Corporation  (Western  Nuclear),  Conoco,  and  Strathmore  Resources  (Strathmore).  Roca  Honda  Resources 
(RHR) was established on July 26, 2007, when Strathmore (60%) formed a limited liability company with Sumitomo Corporation 
(40%)  and  transferred  the  property  to  RHR.  In  August  2013,  EFR  acquired  a  100%  interest  in  Strathmore,  and  assumed 
Strathmore’s 60% ownership interest in RHR. In June 2015, EFR acquired a 100% interest in the mineral properties controlled by 
Uranium Resource Incorporated (URI). In May 2016, EFR completed the purchase of Sumitomo Corporation’s 40% interest in RHR 
and, since then, has a 100% interest in the Property.

No additional work has been completed on the property since its acquisition by the Company in 2013.

Permitting and Licensing

The Roca Honda Project is at an advanced stage of permitting. A Draft EIS was completed by the USFS in February 2013. In March 
2015 the USFS initiated the scoping process for a new mine dewatering alternative to be addressed in a Supplement to the Draft 
EIS.  In  September  2016,  an  additional  scoping  process  to  incorporate  Section  17  (the  “Adjacent  Properties”)  and  development 
drilling into the mine plan was initiated by the USFS. The Supplement to the Draft EIS is expected to be completed during late 2024 
or early 2025 with a Final EIS and RoD scheduled to be completed in 2025.

Other major permits required for the Roca Honda Project include a Permit to Mine to be issued by the New Mexico Mining and 
Minerals Division, a Discharge Permit issued by the New Mexico Environment Department, and a Mine Dewatering Permit issued 
by the New Mexico State Engineer’s Office. The Mine Dewatering Permit was approved in December 2013 but appealed by the 
Acoma Pueblo in January 2014. RHR subsequently proposed a new alternative for discharging treated mine water that would benefit 
a number of downstream users including the Acoma Pueblo. The Acoma Pueblo agreed to withdraw the dewatering permit appeal in 
March 2015. The dewatering permit will need to be revised to reflect a higher dewatering rate with the addition of Section 17 to the 
mine plan.

The two other major permits that are in the agency review stage are the Discharge Permit, which is expected to be issued in 2025, 
and the Permit to Mine, which is expected to be issued in 2025 following approval of the Final EIS by the USFS. Permit approvals 
from the USACE and the EPA are also required for discharge of treated mine water associated with mine activities. An application 
for the USACE permit has been submitted and the permit is expected prior to issuance of the Permit to Mine in 2025. An application 
for the EPA permit has also been submitted, however; the previous application is expected to be withdrawn and a new application 
submitted during 2024. The EPA permit for discharge of treated mine water is expected prior to issuance of the Permit to Mine in 
2025. EPA approval under the Clean Air Act National Emissions Standard for Hazardous Air Pollutants will also be required prior 
to mining.

As the project has not yet been developed or operated, we are not aware of any environmental liabilities of any significance.

No permitting is required to start milling the Roca Honda Project material at the White Mesa Mill. The White Mesa Mill is fully 
permitted with the State of Utah and has all the necessary operating licenses for a conventional uranium mill. As additional tailings 
storage  capacity  may  eventually  be  required  at  the  Mill  over  the  life  of  the  mine,  an  Amendment  to  the  White  Mesa  Mill’s 
Radioactive  Materials  License  issued  by  the  Utah  Division  of  Waste  Management  and  Radiation  Control  will  be  required  in  due 
course to construct additional tailing cells, if and when required.

Geological Setting, Mineralization and Deposit

More than 340 Mlb of U3O8 have been produced from the Grants uranium deposits in New Mexico between 1948 and 2002, and at 
least  403  Mlb  of  U3O8  remain  as  unmined  resources.  The  Grants  uranium  district  is  one  of  the  largest  uranium  provinces  in  the 
world. The Grants uranium district extends from east of Laguna to west of Gallup in the San Juan Basin of New Mexico. Three 
types of sandstone uranium deposits are recognized: tabular, redistributed (roll-front, fault-related), and remnant-primary. 

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Rocks exposed in the Ambrosia Lake subdistrict of the Grants uranium district, which includes the Roca Honda Project area, include 
marine and non-marine sediments of Late Cretaceous age, unconformably overlying the uranium-bearing Upper Jurassic Morrison 
Formation. The uppermost sequence of conformable strata consists of the Mesaverde Group, Mancos Shale, and Dakota Sandstone. 
All rocks that outcrop at the Roca Honda Project area are of Late Cretaceous age; these rocks and the Quaternary Period deposits 
that cover them in some places.

The uranium mineralization found in the Roca Honda Project area is contained within five sandstone units of the Westwater Canyon 
Member. Zones of mineralization vary from approximately one foot to 30 ft thick, 100 ft to 600 ft wide, and 200 ft to 3,000 ft in 
length in elongated pods. Uranium mineralization in the Roca Honda Project area west to east, and northwest to southeast depending 
on general area within the Roca Honda Project area, consistent with trends of the fluvial sedimentary structures of the Westwater 
Canyon Member, and the general trend of mineralization across the Ambrosia Lake subdistrict. 

Uranium mineralization in the Roca Honda Project area is believed to be predominantly primary (trend) mineralization, with some 
secondary mineralization due to oxidation and mobilization of uranium near permeable geologic structures. Uranium mineralization 
consists of dark organic-uranium oxide complexes. The uranium in the Roca Honda Project area is dark grey to black in color and is 
found between depths of approximately 1,380 ft to 2,600 ft below the surface.

Primary mineralization pre-dates the formation of the Laramide aged structures in the Mine area, with a small amount of vertical 
offset  of  mineralization  present  across  the  local  faults.  There  is  a  possibility  of  some  redistribution  and  stack  ore  along  faults; 
however, it appears that most of the Roca Honda Project mineralization is primary. Paleochannels that contain quartz-rich, arkosic, 
fluvial sandstones are the primary mineralization control associated with this trend.

Data Verification

The  assay  data  used  to  calculate  the  Mineral  Resource  estimate  for  the  Project  is  natural  gamma  radiometric  log  data.  Core  was 
collected by Strathmore Resources during a 2007 drill program to verify historical natural gamma data but was not used for Mineral 
Resource estimation. Calibration data for natural gamma logs are available for both historical and recent drilling. The majority of 
the data used in the Mineral Resource estimate is historical and collected by Kerr-McGee. Kerr-McGee regularly calibrated their 
logging  tools  at  the  DOE  calibration  test  pits  in  Grants,  NM.  The  calibration  data  associated  with  the  Kerr-McGee  drilling  is 
contained in a series of calibration notebooks and tables.

Drill core collected by Strathmore Resources was analyzed at Energy Labs in Casper, Wyoming.

Utilizing  only  natural  gamma  logs  as  assay  data  could  lead  to  an  over  or  under  estimation  of  Mineral  Resources  due  to 
disequilibrium. Positive disequilibrium occurs when the uranium present has not had enough time to decay and produce daughter 
isotopes, which are what are actually measured during a natural gamma assay. Under positive disequilibrium a natural gamma assay 
would indicate lower amounts of uranium than what is present. Negative disequilibrium occurs when uranium has had enough time 
to decay to produce the daughter radioisotopes but was remobilized and removed from the deposit. This would lead to measuring 
more uranium than is present. The use of core to verify natural gamma logs is standard practice and allows for the calculation of a 
disequilibrium factor. In addition, the Project is located in a large uranium district that never reported issues with disequilibrium. 
The disequilibrium factor applied to the Project Mineral Resource is 1.0.

Mineral Resource Estimates

Grades were estimated for the Roca Honda project using a combination of nearest neighbor, inverse distance and ordinary kriging 
methods.  Grades  were  estimated  from  historic  surface  drilling  completed  by  Kerr-McGee,  Western  Nuclear,  Conoco,  and 
Strathmore  Minerals.  Information  regarding  the  Mineral  Resource  calculation  are  given  below,  and  specific  details  regarding  the 
estimation procedure can be found in Section 14.0, Mineral Resource Estimate of the Roca Honda Technical Report Summary.

In Sections 9. 10 and 16, block grades were estimated using the Inverse Distance Cubed (ID3) method. Domain models were used as 
hard boundaries to limit the extent of influence of composite grades within the domains. 

Suitable  variograms  could  not  be  generated  for  individual  or  combined  domain  models  due  to  the  small  number  of  contained 
composite samples. Search ranges were determined visually based on continuity of mineralization and drillhole spacing.

Search  directions  were  determined  visually  for  each  domain.  Isotropic  search  ranges  in  the  major  and  semi-major  directions 
following the trend of individual domain models were applied. Minor search ranges were also determined visually and were shorter. 

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Two  grade  estimation  passes  were  run  with  the  major,  semi-major,  and  minor  search  ranges  increased  by  a  factor  of  1.5  in  the 
second estimation run. Estimation flags were stored for each estimation run based on increasing search distances. The number of 
samples and holes were stored in separate block variables for use in determining resource classification.

Octant restrictions were not enforced to preserve local grades. Only the closest composites to block centroids (adhering to defined 
trends) were used.

In Section 17, block grades were estimated using the Inverse Distance Squared (ID2), Ordinary Kriging (OK), or Nearest Neighbor 
(NN)  methods.  Domain  models  were  used  as  hard  boundaries  to  limit  the  extent  of  influence  of  composite  grades  within  the 
domains. 

Where wireframes contained only a single drillhole, the NN method was used; in cases where there was enough data to generate 
variograms, OK was used; and in all other cases, ID2 was used. ID2 was used in Section 17 instead of ID3 because the drill spacing is 
much  tighter  than  in  Sections  9,  10,  and  16  and  nearby  drillholes  were  determined  to  have  better  grade  continuity,  and  therefore 
more holes should have a greater influence on a block estimate than the nearest drillhole.

Search directions were determined visually for each domain. Anisotropic search ranges were used oriented along the major trend of 
the mineralized zones. As the mineralization tends to be tabular in nature, tops and bottoms of the mineralization were modeled as 
part of the wireframe process. Those top and bottom surfaces were used to generate unfolding models that were used in place of dip 
and plunge (Y rotation and X rotation).

Up to three grade estimation passes were run with the major, semi-major, and minor search ranges increased by a factor of 2.0 in the 
second  and  third  estimation  runs.  Estimation  flags  were  stored  for  each  estimation  run  based  on  increasing  search  distances.  The 
number of samples and holes were stored in separate block variables for use in determining resource classification.

Octant restrictions were not enforced to preserve local grades. Only the closest composites to block centroids (adhering to defined 
trends) were used.

The table below sets out the Mineral Resources estimates for the Roca Honda Project as of December 31, 2023. These estimates are 
derived from the Roca Honda Technical Report Summary, in which Mineral Resources were estimated as of December 31, 2021. 
Daniel Kapostasy, the Company’s non-independent Qualified Person, reviewed and confirmed that the Mineral Resources estimates 
set forth in the Roca Honda Technical Report Summary remained accurate as of December 31, 2023.

Roca Honda Project – Summary of Mineral Resources – In Situ Uranium(1)(2)(3)(4)(5)(6)(7)
Cut-Off Grade (% 
eU3O8)

Grade (% 
eU3O8)

Tonnage 
(Tons)

Area

0.19
0.19
0.19
0.19
0.19
0.19
0.19

0.19
0.19
0.19

Sec. 9, 10, & 16
Sec. 17
Sec. 9, 10, 16, & 17
Sec. 9, 10, & 16
Sec. 17
Sec. 9, 10, 16, & 17
Sec. 9, 10, 16, & 17

Sec. 9, 10, & 16
Sec. 17
Sec. 9, 10, 16, & 17

208,000
---
208,000
1,303,000
336,000
1,639,000
1,847,000

1,198,000
315,000
1,513,000

0.48
---
0.48
0.48
0.45
0.48
0.48

0.47
0.42
0.46

Contained 
Metal (lbs. 
U3O8)
1,984,000
---
1,984,000
12,580,000
3,058,000
15,638,000
17,622,000

11,206,000
2,636,000
13,842,000

Metallurgical 
Recovery

95%
---
95%
95%
95%
95%
95%

95%
95%
95%

Classification

Measured

Total Measured
Indicated

Total Indicated
Total Measured + 
Indicated
Inferred

Total Inferred

Notes:

(1) SEC S-K 1300 and NI 43-101 definitions were followed for all Mineral Resource categories.
(2) Mineral Resources are estimated at a U3O8 cut-off grade of 0.19% eU3O8.
(3)  Mineral  Resources  are  estimated  using  a  long-term  Uranium  price  of  US$65  per  pound.  The  long-term  uranium  price  is 
based on supply and demand projections for the period 2021-2035. 
(4) Bulk density is 0.067 tons/ft3 (15.0 ft3/ton or 2.14 t/m3).
(5) There are no Mineral Reserves for the property.
(6) Numbers may not add due to rounding.

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(7) Mineral Resources are 100% attributable to the Company.

Present Condition of the Property and Work Completed to Date

Old drill roads were previously established across the property, and an electrical line transects the northern half of Section 16 in the 
project area. The line continues along the west side of the project area into Section 17, where it terminates, and on the east side of 
Section 16 through the northwest quarter of Section 15 and along the southern section boundary of Section 10. Three monitor water 
wells were drilled by RHR in 2007 and are located on Section 16. More than 900 historic drill exploration holes were completed on 
the property from the late 1960s to the early 1980s. Except for the existing shaft on Section 17, there are no mine workings, existing 
tailings ponds, waste deposits or other improvements or facilities at the site.

The Company has not conducted any exploration activities on the Project since acquiring the properties in August 2013. 

The Roca Honda Project was acquired by the Company in August 2013, through the Company’s acquisition of Strathmore. As of 
December 31, 2023, the total net book value attributable to the Roca Honda Project on the consolidated financial statements of the 
Company was $22.10 million.

The Company’s Planned Work

The Company intends to continue its permitting and related activities at the Roca Honda Project during 2024. Permitting efforts in 
2024 include the integration of the Adjacent Roca Honda Properties into the permitting efforts underway for the Roca Honda Project 
properties, including the submittal of a revised National Pollutant Discharge Elimination System (“NPDES”) permit application to 
the EPA and continuation of the Supplement to the Draft EIS through the USFS.

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The Sheep Mountain Project 

The following technical and scientific description of the Sheep Mountain Project is based in part on a Preliminary Feasibility Study 
titled  “Preliminary  Feasibility  Study  for  the  Sheep  Mountain  Project,  Fremont  County,  Wyoming,  USA”  originally  dated  and 
effective as of December 31, 2021, as amended January 30, 2023, and prepared by Douglas Beahm, PE, PG SME R.M., a Qualified 
Person  employed  by  BRS,  as  well  as  Daniel  Kapostasy,  PG,  SME  R.M.,  a  non-independent  Qualified  Person  employed  with  the 
Company, and Terence McNulty, PE, PhD, an independent consultant (the “Sheep Mountain Technical Report Summary”). The 
Sheep Mountain Technical Report Summary was prepared in accordance with both S-K 1300 and NI 43-101. The Sheep Mountain 
Project contains both Mineral Resources and Minerals Reserves, as defined in S-K 1300 and NI 43-101 and is therefore considered 
under SEC S-K 1300 definitions to be a development stage property.

Project Description

The Sheep Mountain Project is located in portions of Sections 15, 16, 17, 20, 21, 22, 27, 28, 29, 32, and 33, Township 28 North, 
Range  92  West  at  approximate  Latitude  42º  24’  North  and  Longitude  107º  49’  West,  within  the  Wyoming  Basin  physiographic 
province in the Great Divide Basin at the northern edge of the Great Divide Basin. The project is approximately eight miles south of 
Jeffrey City, Wyoming.

The  Sheep  Mountain  Project  includes  the  open  pit  Congo  Pit,  comprised  of  the  Congo,  North  Gap,  and  South  Congo  areas,  a 
proposed heap leach facility, and the reopening of the existing underground facility (the “Sheep Underground”), which includes 
the Sheep I and Sheep II underground areas. Although alternatives were considered in the past, the current recommended recovery 
method  is  the  processing  of  extracted  materials  via  an  on-site  heap  leach  facility.  Material  from  the  underground  and  open  pit 
operations are expected to be commingled at the stockpile site located near the underground portal and in close proximity to the pit. 

103

At  the  stockpile,  the  mineralized  material  will  be  sized  if  needed,  blended,  and  then  conveyed  via  a  covered  overland  conveyor 
system to the heap leach pad where it will be stacked on a double lined pad for leaching. The primary lixiviant will be sulfuric acid. 
Pregnant leach solution (“PLS”) will be collected by gravity in a double lined collection pond and then transferred to the mineral 
processing facility for extraction and drying. The final product will be uranium concentrate (U3O8, also known as “yellowcake”). 
Energy  Fuels  owns  the  Mill  and  the  Nichols  Ranch  Plant,  which  creates  the  option  to  transport  loaded  resin  to  either  of  those 
facilities for stripping, and to the Mill for drying, and packaging of yellowcake.

Ownership

The mineral properties at the Sheep Mountain Project are comprised of 218 unpatented mining claims on land administered by the 
BLM,  and  approximately  640  acres  within  a  State  of  Wyoming  lease.  The  combination  of  the  mineral  holdings  comprises 
approximately 5,055 acres. Total holding costs for 2023 were $38,581.

In February 2012, Energy Fuels purchased 320 acres of private surface overlaying some of the federal minerals covered by 18 of the 
claims. The purchased parcel includes the SW¼ Section 28 and SE¼, E½ SW¼, and NW¼ SW¼ Section 29, T28N, R92W. A final 
payment  of  $5,000  was  made  in  January  2016  for  the  purchased  parcel.  The  combination  of  land  holdings  gives  Energy  Fuels 
mineral  rights  to  resources  as  defined  in  the  Congo  Pit  and  the  Sheep  Underground  areas.  The  Company  increased  the  Sheep 
Mountain  property  size  by  26  unpatented  mining  claims  (approximately  520  acres)  through  the  acquisition  of  Strathmore.  These 
contiguous claims form a larger buffer, with potential for additional uranium resources, along the west side of the Sheep Mountain 
Project.

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To maintain these mineral rights, the Company must comply with the lease provisions, including annual payments with respect to 
the  State  of  Wyoming  leases;  BLM  and  Fremont  County,  as  well  as  Wyoming  filing  and/or  annual  payment  requirements  to 
maintain the validity of the unpatented mining lode claims as follows. Mining claims are subject to annual filing requirements and 
payment of a fee of $165 per claim. Unpatented mining claims expire annually but are subject to indefinite annual renewal by filing 
appropriate documents and paying the fees described above. Wyoming State Mineral Lease (“ML”) 0-15536 will expire on January 
1, 2024. Annual payments to maintain ML 0-15536 are $2,560 per year. 

The original claims owned by Western Nuclear in the Sheep Mountain Project are subject to an overall sliding scale royalty of 1% 
to 4% due to Western Nuclear, based on the Nuclear Exchange Corporation Exchange (“NUEXCO”) Value. Claims which were not 
included in the agreement are not subject to this royalty. Under Wyoming State Lease ML 0-15536, there is a royalty of 5% of the 
quantity or gross realization value of the U3O8, based on the total arms-length consideration received for uranium products sold.

Uranium mining in Wyoming is subject to both a gross products (county) tax and a mineral severance tax (state). At the Federal 
level, aggregate corporate profit from mining ventures is taxable at corporate income tax rates, i.e., individual mining projects are 
not assessed Federal income tax but rather the corporate entity is assessed as a whole. For mineral properties, depletion tax credits 
are available on a cost or percentage basis, whichever is greater. The percentage depletion tax credit for uranium is 22%, among the 
highest for mineral commodities (IRS Pub. 535).

Accessibility, Climate, Local Resources, Infrastructure and Physiography

The Sheep Mountain Project is located at approximate Latitude 42°24’ North and Longitude 107° 49’ West within the Wyoming 
Basin  physiographic  province  in  the  Great  Divide  Basin  at  the  northern  edge  of  the  Great  Divide  Basin.  The  project  is 
approximately  eight  miles  south  of  Jeffrey  City,  Wyoming.  The  nearest  commercial  airport  is  located  in  Riverton,  Wyoming 
approximately 56 miles from Jeffrey City on a paved two-lane state highway. The project is accessible via 2-wheel drive on existing 
county and two-track roads.

The  Sheep  Mountain  Project  falls  within  the  inter-mountain  semi-desert  weather  province,  with  average  maximum  temperatures 
ranging from 31.1 °F (January and December) to 84.9 °F (July), average minimum temperatures ranging from 9.1 °F (January) to 
49.2 °F (July), and average total monthly precipitation ranging from 0.36 inches (January) to 2.04 inches (May). The topography 
consists of rounded hills with moderate to steep slopes. Elevations range from 6,600 feet to 8,000 feet above sea level. The ground 
is  sparsely  vegetated  with  sage  and  grasses  and  occasional  small  to  medium  sized  pine  trees  at  higher  elevations.  Year-round 
operations are contemplated for the Sheep Mountain Project.

Telephone,  electric  and  natural  gas  service  adequate  for  the  planned  extraction  and  mineral  processing  operations  have  been 
established at the Sheep Mountain Project. Electric service and a waterline have been extended via right-of-way issued by the BLM 
in 2011 to the existing Sheep 1 and 2 shafts. Adequate water rights are held by the Company for planned extraction and mineral 
processing  operations  but  need  to  be  updated  with  the  Wyoming  State  Engineer  with  respect  to  type  of  industrial  use,  points  of 
diversion, and points of use.

History

Three  companies  dominated  the  district  by  the  mid-1950s:  Western  Nuclear  Corporation  (“WNC”),  Phelps  Dodge  (“PD”)  and 
Continental Uranium Corporation (“CUC”). WNC built the Split Rock Mill at Jeffrey City in 1957 and initiated production from the 
Paydirt pit in 1961, Golden Goose 1 in 1966 and Golden Goose 2 in 1970. PD was the principal shareholder and operator of the 
Green Mountain Uranium Corporation’s Ravine Mine, which began production in 1956. CUC developed the Seismic Pit in 1956, 
the Seismic Mine in 1957, the Reserve Mine in 1961 and the Congo Decline in 1968. In 1967, CUC acquired the PD properties and 
in 1972, WNC acquired all of CUC’s Crooks Gap holdings. During the mid-1970s, PD acquired an interest in WNC, which began 
work on Sheep Mountain I in 1974, the McIntosh Pit in 1975, and Sheep Mountain II in 1976. WNC ceased production from the 
area in 1982. 

Subsequent to closure of the Sheep Mountain I by WNC, during April to September 1987, Pathfinder Mines Corp. (“PMC”) mined 
a reported 12,959 tons, containing 39,898 pounds of uranium at an average grade of 0.154% U3O8 from Sheep Mountain I, (PMC, 
1987).  U.S.  Energy-Crested  Corp.  (“USECC”)  acquired  the  properties  from  WNC  in  1988  and  during  May  to  October  1988 
USECC mined 23,000 tons from Sheep Mountain I, recovering 100,000 pounds of uranium for a mill head grade of 0.216% U3O8 
(WGM, 1999). The material was treated at PMC’s Shirley Basin mill, 130 miles east of the mine. 

In December 2004, Uranium Power Corp. (“UPC”), then known as Bell Coast Capital, entered into a Purchase and Sales Agreement 
with USECC to acquire a 50% interest in the Sheep Mountain property. The acquisition was completed in late 2007 with aggregate 
payments to USECC of $7.05 million and the issuance of four million Common Shares to USECC. USECC sold all of its uranium 

105

assets, including its 50% interest in Sheep Mountain, to Uranium One Inc. (“U1”) in April 2007. Titan Uranium Inc. acquired a 50% 
interest in the property when it acquired UPC by a Plan of Arrangement in July 2009. The ownership was subsequently transferred 
to Titan Uranium Inc.’s (“TUI”) wholly owned subsidiary, Titan Uranium USA Inc. (referred herein to as “Titan”). The remaining 
50% interest was purchased from U1 on October 1, 2009. Subsequently, Energy Fuels and TUI announced that they had entered into 
a Certificate of Arrangement giving effect to the parties’ February 29, 2012 Plan of Arrangement, whereby Energy Fuels acquired 
TUI, making Titan a wholly owned subsidiary of Energy Fuels, which is now named Energy Fuels Wyoming Inc.

Other than care and maintenance work, the Company has not performed any significant work on the Sheep Mountain Property since 
its acquisition.

Permitting and Licensing

In  June  2010,  Titan  commenced  baseline  environmental  studies  to  support  an  application  to  the  NRC  for  a  Source  Material  and 
Byproduct  Material  License  (the  “License”)  for  operation  of  a  heap  leach  facility.  Work  was  also  initiated  on  a  revision  to  the 
existing WDEQ Mine Permit, as well as a PO for the BLM. Baseline studies included wildlife and vegetation surveys, air quality 
and meteorological monitoring, ground and surface water monitoring, radiological monitoring, and cultural resource surveys.

Submission of the PO to the BLM was made in June 2011. The PO was accepted as complete by the BLM, and an EIS was initiated 
in  August  2011.  Energy  Fuels  revised  the  PO  in  July  2012,  consistent  with  the  modified  plan  presented  in  the  Sheep  Mountain 
Technical Report. In July 2013, the PO was again revised to reflect a new waste rock disposal layout for the open pit mine and an 
improved  and  more  economical  heap  leach  and  processing  facility.  The  revised  PO  also  included  the  option  of  transporting 
mineralized material off-site for processing. The Final EIS was completed in August of 2016. On January 6, 2017, the BLM issued 
its RoD and approved the PO.

In  October  2011,  Titan  submitted  a  draft  revision  to  its  existing  Mine  Permit  381C  to  WDEQ.  WDEQ  then  provided  Titan  with 
review comments as part of its “courtesy review.” The proposed permit amendment was revised and resubmitted in January 2014. In 
July 2015, the revision was approved by WDEQ. The revision includes expansion of surface and underground mining operations 
and an updated reclamation plan consistent with current reclamation practices.

Development of an application to the NRC for a license to construct and operate the uranium recovery facility has been taken to an 
advanced stage of preparation. This license would allow Energy Fuels to process the mineralized material into yellowcake at the 
Sheep  Mountain  Project  site.  The  draft  application  to  NRC  for  a  Source  Material  License  was  reviewed  in  detail  by  the  NRC  in 
October  2011.  The  NRC  audit  report  identified  areas  where  additional  information  should  be  provided.  Effective  September  30, 
2018, the State of Wyoming became an Agreement State under the Atomic Energy Act (as amended) for the regulation of uranium 
mills and heap leach facilities, and authorization for the Source Material and Byproduct Material License was transferred from the 
NRC to WDEQ-LQD. The review and approval process for this license is anticipated to take approximately four years from the date 
submitted  to  the  WDEQ-LQD.  Submittal  of  the  license  application  to  the  WDEQ-LQD  is  on  hold  pending  the  Company’s 
evaluation of off-site processing options for this project, and whether or not to proceed with an on-site uranium recovery facility, 
pending improvements in uranium market conditions.

The heap leach facility has been permitted by the State of Wyoming through issuance of the Mine Permit and by the BLM, yet still 
requires  licensing  by  the  WDEQ-LQD.  Mining  could  commence  at  this  time  under  the  existing  RoD  and  Mine  Permit,  but  the 
mined ore would need to be processed at a licensed off-site processing facility under a toll-milling or other arrangement.

Geological Setting, Mineralization and Deposit

A primary component of the geology for the Sheep Mountain Project is the Battle Spring Formation. Battle Spring is Eocene in age. 
Prior to deposition of the Battle Spring Formation and subsequent younger Tertiary formations, underlying Paleocene, Cretaceous, 
and older formations were deformed during the Laramide Orogeny. During the Laramide Orogeny, faults, including the Emigrant 
Thrust Fault at the northern end of the project area, were active and displaced sediments by over 20,000 feet. Coincident with this 
mountain  building  event,  Paleocene  and  older  formations  were  folded  in  a  series  of  echelon  anticlines  and  synclines,  generally 
trending  from  southeast  to  northwest.  The  Battle  Spring  Formation  was  deposited  unconformably  on  an  erosional  landscape 
influenced  by  these  pre-depositional  features.  Initial  stream  channels  transporting  clastic  sediments  from  the  Granite  Mountains 
formed in the synclinal valleys.

The geologic setting of the Sheep Mountain Project is important in that it controlled uranium mineralization by focusing movement 
of the groundwaters, which emplaced the uranium into the stream channels, which had developed on the pre-tertiary landscape. The 
Battle Spring Formation and associated mineralization at the Sheep Mountain Project is bounded to the east by the western flank of 

106

the Sheep Mountain Syncline and to the west by the Spring Creek Anticline. To the north the system is cut off by erosion. To the 
south the Battle Spring continues into the northern portions of the Great Divide Basin.

Mineralization  occurs  throughout  the  lower  A  Member  of  the  Battle  Spring  Formation  and  is  locally  up  to  1,500  feet  thick.  The 
upper  B  Member  is  present  only  in  portions  of  the  project  and  may  be  up  to  500  feet  thick.  Although  arkosic  sandstone  is  the 
preferred host, uranium has been extracted from all lithologies. Grade and thickness are extremely variable depending on whether 
the samples are taken from the nose or the tails of a roll front. Typically, the deposits range from 50 feet to 200 feet along a strike, 
five  feet  to  eight  feet  in  height,  and  20  feet  to  100  feet  in  width.  Deposits  in  the  Sheep  Mountain  Project  area  occur  in  stacked 
horizons from 7,127 feet in elevation down to 6,050 feet in elevation.

Most of the mineralization in the Crooks Gap District occurs in roll-front deposits. Roll fronts have an erratic linear distribution but 
are usually concordant with the bedding. Deposits have been discovered from the surface down to a depth of 1,500 feet. The two 
major  uranium  minerals  are  uranophane  and  autunite.  Exploration  drilling  indicated  that  the  deeper  roll-type  deposits  are 
concentrated in synclinal troughs in the lower Battle Spring Formation. Three possible sources for uranium have been suggested: 
post-Eocene  tuffaceous  sediments,  leached  Battle  Spring  arkoses,  and  Precambrian  granites.  Structural  controls  of  uranium 
occurrences  along  roll  fronts  include  carbonaceous  siltstone  beds  that  provide  a  local  reducing  environment  for  precipitation  of 
uranium-bearing minerals, and abrupt changes in permeability along faults, where impermeable gouge is in contact with permeable 
sandstones. Uranium has also been localized along the edges of stream channels and at contacts with carbonaceous shales.

Data Verification

The assay data used to calculate the Mineral Resource and Mineral Reserve estimate for the Project is natural gamma radiometric 
log data. Core was collected by Uranium Power Corp. starting in 2005 and continued by Titan after its acquisition in 2009 to verify 
historical  natural  gamma  data  but  was  not  used  for  Mineral  Resource  estimation.  Calibration  data  for  natural  gamma  logs  are 
available for both historical and recent drilling.

Drill core collected by Uranium Power Corp. and Titan was analyzed at Energy Labs in Casper, Wyoming.

Utilizing  only  natural  gamma  logs  as  assay  data  could  lead  to  an  over  or  under  estimation  of  Mineral  Resources  due  to 
disequilibrium. Positive disequilibrium occurs when the uranium present has not had enough time to decay and produce daughter 
isotopes, which are what are actually measured during a natural gamma assay. Under positive disequilibrium a natural gamma assay 
would indicate lower amounts of uranium than what is present. Negative disequilibrium occurs when uranium has had enough time 
to decay to produce the daughter radioisotopes but was remobilized and removed from the deposit. This would lead to measuring 
more uranium than is present. The use of core to verify natural gamma logs is standard practice and allows for the calculation of a 
disequilibrium factor. The disequilibrium factor applied to the Project Mineral Resource is 1.0.

Mineral Resources

Mineral Resource and Mineral Reserve Estimate

The  mineral  resource  estimate  was  completed  using  the  Grade  x  Thickness  Contour  Method  (also  known  as  the  GT  Method)  on 
individual mineralized zones as defined in a full 3D geological model of the deposit. The GT Method is a well-established approach 
for estimating uranium resources and has been in use since the 1950s in the U.S. The technique is most useful in estimating tonnage 
and average grade of relatively planar bodies where lateral extent of the mineralized body is much greater than its thickness, as was 
observed in drilling of the Congo and Sheep deposits.

For tabular and roll front style deposits the GT Method provides a clear illustration of the distribution of the thickness and average 
grade of uranium mineralization. The GT Method is particularly applicable to the Congo and Sheep deposits as it can be effective in 
reducing  the  undue  influence  of  high-grade  or  thick  intersections  as  well  as  the  effects  of  widely  spaced,  irregularly  spaced,  or 
clustered drill holes, all of which occur to some degree in the Congo and Sheep deposits. This method also makes it possible for the 
geologist to fit the contour pattern to the geologic interpretation of the deposit. 

Details  and  figures  regarding  the  estimation  can  be  found  in  Section  14.0,  Mineral  Resource  Estimates,  of  the  Sheep  Mountain 
Technical Report Summary.

Open Pit Mineral Resources

The current mineral resource model includes 18 separate sand units for all areas and includes deletion of the portions of the mineral 
resource model that falls within the historic mine limits determined from mine maps, which equated to approximately 25% of the 

107

initial  resource  estimate.  Historic  mining  limits  were  imported  into  the  resource  model  by  individual  sand  horizons  in  three 
dimensions. The extent of mining was taken to be the actual mapped underground mine limit or the GT boundary representing the 
historical mining cut-off (8 feet at 0.095 or a GT of 0.76), whichever was greatest. Although in many cases the mine maps showed 
remnant pillars, none of these areas were included in the Mineral Reserve estimate. Thus, the estimate of current Mineral Resources 
is conservative with respect to the exclusion of areas affected by historic mining.

The Congo sum GT, diluted to a minimum 2-foot mining thickness from the mineralized envelope for each drill hole, was plotted in 
AutoCAD. If the thickness exceeded 2 feet, no dilution was added. The diluted thickness of mineralization for each drill hole was 
also  plotted.  Resource  estimates  include  deletion  of  the  portions  of  the  mineral  resource  model  that  fall  within  the  historic  mine 
limits as previously discussed.

Underground Mineral Resources

The GT contours, diluted to a minimum 6-foot mining thickness from the mineralized envelope for each drill hole and each horizon, 
was plotted in AutoCAD™. If the thickness exceeded 6 feet no dilution was added. The diluted thickness of mineralization for each 
drill hole was also plotted. Mineral resource estimates account for the deletion of mined areas within the resource model estimated 
from surface drilling. The total reported mined tonnage from the Sheep I underground mine was 275,000 tons containing 522,500 
pounds of U3O8 and an average grade of 0.095% U3O8. However, the portions of the current mineral resource estimates which were 
within the defined previously mined area was only an estimated 62,618 tons of material containing 160,666 pounds of eU3O8 and an 
average grade of 0.128% eU3O8. From review of the Sheep, I and II as-built mine plans, it was apparent that little or no material was 
mined at Sheep II and that only development work was completed. Further, it was apparent at the Sheep I mine that many of the 
mined areas were located by underground delineation drilling rather than by surface drilling. The mine history clearly shows that 
underground  development  drilling  and  sampling  expanded  the  resource  as  compared  to  that  which  could  be  projected  from  the 
surface drilling alone.

For mine planning purposes, a three-dimensional block model was created from the Sheep GT, geologic and mineralized envelope 
models. The modeling utilized an automated routine that assigned the thickness of mineralization, GT, and mineralized elevation 
reflected  by  their  respective  contours,  to  the  centroids  of  a  uniform  25  x  25-foot  (25’x25’)  grid.  From  the  thickness  and  GT 
contours, average grade, mineralized and waste tonnages, and contained pounds was calculated and assigned to each block. Each 
25’x25’ block was then evaluated based on its grade and thickness for mine planning and scheduling.

The table below sets out the Mineral Resources estimates for the Sheep Mountain Project as of December 31, 2023. These estimates 
are derived from the Sheep Mountain Technical Report Summary, which estimated Mineral Resources as of December 31, 2021 and 
are exclusive of Mineral Reserves. Daniel Kapostasy, the Company’s non-independent Qualified Person, reviewed and confirmed 
that the Mineral Resources estimates set forth in the Sheep Mountain Technical Report Summary remained accurate as of December 
31, 2023.

Sheep Mountain Mineral Resources – In Situ Uranium(1)(2)(3)(4)(5)(6)

Classification

Zone

(G.T.) Tons (000s)

(% eU3O8)

Cut-off 

Grade     

Contained 
Metal (eU3O8 
000s)

Metallurgical 
Recovery

Measured 

Indicated 

---
Sheep Underground  
Congo Pit Area

---
0.30   
0.10   

---
2,048 
2,161 

---
0.09  
0.13  

--- ---

3,786 
5,786 

9,750 

9,750 

 91.9  %
 91.9  %

 91.9 %

 91.9 %

4,210 

 0.11 %  

4,210 

 0.11 %  

---

---

---

---

---

---

Total Indicated Resources

Total Measured and Indicated

Inferred 

Notes:

(1) S-K 1300 and NI 43-101 definitions were followed for Mineral Resources. 
(2) Mineral Resources are estimated at a uranium grade x thickness (G.T.) cut-off grade of 0.10 G.T. (2 ft. of 0.05% eU3O8 for 
the Congo Pit and 0.30 G.T. (6 ft. of 0.05% eU3O8) for the Sheep Underground.
(3) Numbers may not add due to rounding.
(4) Mineral Resources are estimated using a long-term uranium price of $65 per pound U3O8. The long-term uranium price is 
based on supply and demand projections for the period 2021-2035. 

108

 
 
 
(5) Mineral Resources are exclusive of Mineral Reserves.
(6) Mineral Resource are 100% attributable to the Company.

Mineral Reserves

Conversion of Open Pit Resources to Reserves

This  estimate  includes  deletion  of  the  portions  of  the  mineral  resource  model  that  fall  within  the  historic  mine  limits.  Historic 
mining  limits  were  imported  into  the  resource  model  by  individual  sand  horizons  in  three  dimensions.  The  extent  of  mining  was 
taken to be the actual mapped underground mine limit or the GT boundary representing the historical mining cut-off (8 feet at 0.095 
or a GT of 0.76), whichever was greatest. Although in many cases the mine maps showed remnant pillars, none of these areas were 
included in the mineral reserve estimate, though the potential exists for these to be mined. Both the estimated mineral resources and 
mineral reserves were diluted to a minimum mining thickness of two feet. The reported Probable Mineral Reserve is that portion of 
the reported Indicated Mineral Resource that is within the current open pit design.

Conversion of Underground Resources to Reserves

This estimate includes deletion of the portions of the mineral resource model which falls within the historic mine limits. Both the 
estimated Mineral Resources and Mineral Reserves were diluted to a minimum mining thickness of six feet. The reported Probable 
Mineral Reserve is that portion of the reported Indicated Mineral Resource that is within the current underground mine design.

The table below sets out the Mineral Reserve estimates for the Sheep Mountain Project as of December 31, 2023. These estimates 
are  derived  from  the  Sheep  Mountain  Technical  Report  Summary,  which  estimated  Mineral  Reserves  as  of  December  31,  2021. 
Daniel Kapostasy, the Company’s non-independent Qualified Person, reviewed and confirmed that the Mineral Reserve estimates 
set forth in the Sheep Mountain Technical Report Summary remained accurate as of December 31, 2023.

Sheep Mountain Mineral Reserves – In Situ Uranium(1)(2)(3)(4)(5)(6)

Classification

Proven 

Probable 

Total Probable Reserves

Total Proven and Probable 

Notes:

Zone

(G.T.) Tons (000s)

(% eU3O8)

Cut-off 

Grade      

Contained 
Metal (eU3O8 
000s)

Metallurgical 
Recovery 

---
Sheep 
Underground 
Congo Pit 
Area

---

---

---

---

---

0.45  

3,498 

0.132  

9,248.00 

 91.9  %

0.10  

3,955 

0.115  

9,117.00 

 91.9  %

7,453

7,453 

0.123

18,365

 91.9 %

0.123  

18,365 

 91.9 %

(1)  The Mineral Reserve estimate in this table complies with the requirements of both S-K 1300 and NI 43-101.
(2)  Mineral Reserves are estimated at a uranium grade x thickness (G.T.) cut-off grade of 0.10 G.T. (2 ft. of 0.05% eU3O8) for 
the Congo Pit and 0.45 G.T. (6 ft. of 0.075% eU3O8) for Sheep Underground.
(3)  Mineral Reserves are estimated using a long-term uranium price of $65 per pound U3O8. The long-term uranium price is 
based on supply and demand projections for the period 2021-2035. 
(4)  Numbers may not add due to rounding.
(5)  The Mineral Reserves are excluded from the Mineral Resources shown above.
(6)  Mineral Reserves are 100% attributable to the Company.

The  Probable  Mineral  Reserve  is  that  portion  of  the  Indicated  Mineral  Resource  that  is  economic  under  the  estimated  costs  and 
assumed pricing conditions. The cut-off grade of 0.075% eU3O8 at a minimum mining height of 2 foot equates to a 0.10 GT cut-off 
for the Congo Pit. The cut-off grade of 0.075% eU3O8 at a minimum mining height of 6 feet equals a 0.45 GT cut-off used for the 
Sheep underground extraction area. The cutoff grade was determined based on an assumed uranium price of $65 per pound U3O8.

109

 
Present Condition of the Property and Work Completed to Date

The  Sheep  Mountain  Project  includes  the  Congo  Pit,  a  proposed  heap  leach,  and  the  planned  reopening  of  the  existing  Sheep 
Underground mining facility. Mineral Extraction at the Sheep Underground mining facility was suspended in 1988 and the project 
has been on care and maintenance since that time.

The  Sheep  Mountain  Project  does  not  currently  have  a  processing  facility.  Transportation  of  mineralized  materials  to  the  White 
Mesa  Mill  is  not  economic  at  current  uranium  prices.  As  a  result,  it  will  be  necessary  to  permit  and  construct  a  heap  leach 
processing  facility  at  the  site  or  make  arrangements  to  process  Sheep  Mountain  mineralized  materials  at  a  third-party  processing 
facility.

The Company is subject to liabilities for mine reclamation at the Sheep Mountain Project. The Company files an annual report with 
the State of Wyoming, and the amount of the bond may be adjusted annually to ensure sufficient surety is in place to cover the full 
cost of reclamation. The Company’s reclamation of the exploration drilling performed by Titan was deemed complete in October 
2014; the drilling permit was terminated, and that bond was fully released.

The Sheep Mountain Project was acquired by the Company in February 2012, through the Company’s acquisition of Titan. As of 
December 31, 2023, the total net book value attributable to the Sheep Mountain Project on the Company's consolidated financial 
statements was $34.18 million.

The Company’s Planned Work

The  Company  will  continue  to  evaluate  its  options  for  processing  Sheep  Mountain  mineralized  material,  including  continuing  to 
pursue permitting for a heap leach facility at the site, or determining whether arrangements can be made to process Sheep Mountain 
mineralized materials at a third-party processing facility. Submittal of the license application to the WDEQ-LQD for a heap leach 
processing facility at the site is on hold pending the Company’s evaluation of off-site processing options for this project. The project 
is  currently  on  standby,  pending  completion  of  the  evaluation  of  the  processing  options  for  the  Sheep  Mountain  Project  and 
improvement in market conditions. Additional work is subject to any actions the Company may take in response to general market 
conditions.

110

The Bullfrog Project

The following technical and scientific description of the Bullfrog Project is based in part on the report titled “Technical Report on 
the Bullfrog Project, Garfield County, Utah, USA,” dated February 22, 2022, prepared by Mark B. Mathisen, C.P.G., a Qualified 
Person employed by SLR (the “Bullfrog Technical Report Summary”). The Bullfrog Technical Report Summary was prepared in 
accordance  with  S-K  1300  and  NI  43-101.  The  Bullfrog  Project  does  not  have  known  “Mineral  Reserves”  and  is  therefore 
considered  under  SEC  S-K  1300  definitions  to  be  an  exploration  stage  property.  Once  developed,  Bullfrog  will  operate  as  an 
underground mine. 

Property Description

The Bullfrog Project consists of two separate contiguous deposits, also known as Copper Bench and Indian Bench. The Bullfrog 
Project is located in eastern Garfield County, Utah, 17 miles north of Bullfrog Basin Marina on Lake Powell and approximately 40 
air miles south of the town of Hanksville, Utah. The property is located at latitude 37°48’38.71” N and longitude 110°41’50.09” W.

The  Bullfrog  Project  does  not  have  known  “Mineral  Reserves”  and  is  therefore  considered  under  S-K  1300  definitions  to  be 
exploratory in nature.

Ownership

The  Company’s  property  position  at  the  Bullfrog  Project  consists  of  127  unpatented  mining  claims  located  on  BLM  land, 
encompassing approximately 2,344 acres. Surface access to conduct exploration, development and mining activities on unpatented 

111

mining claims is granted by the BLM as long as NEPA regulations are met. The property is 100% owned by the Company and was 
acquired from Denison Mines Corp. and its affiliates in June 2012. Total holding costs in 2023 were $21,222. 

Accessibility, Climate, Local Resources, Infrastructure and Physiography

Road access to the Bullfrog Project is by paved Highway 276, running between Hanksville, Utah, and Bullfrog Basin Marina, Utah. 
An unimproved gravel road, maintained by Garfield County, extends west from Highway 276, passes by the portal of the Tony M 
Mine, and extends northerly to the Bullfrog Project. The northern end of the Bullfrog Project can be accessed by the Eggnog Star 
Spring  county  road,  approximately  10.4  miles  north  of  Ticaboo,  Utah  along  Highway  276.  A  network  of  unimproved,  dirt 
exploration roads provide access over the property except in the areas of rugged terrain.

The climate is distinctly arid with an average annual precipitation of approximately eight inches, in addition to approximately 12 in. 
of snow. Local records indicate the temperature ranges from a minimum of -10°F to a maximum of 110°F. These conditions allow 
year-round exploration to take place.

Skilled labor can be recruited from the region, which has a tradition of uranium mining. 

The Bullfrog Project is located in a relatively remote area of Utah with limited supporting infrastructure in the area. The town of 
Ticaboo, Utah, is located approximately five miles south of the Bullfrog Project. The next closest community is Hanksville, Utah, a 
small town of a few hundred people, located approximately 40 mi north of the Bullfrog Project. The Bullfrog Basin Marina airstrip 
is located approximately 15 mi south of the Bullfrog Project area. There is no line power or water service in the area, all power for 
the project will need to be generated on site and a well will need to be drilled for water.

Materials and supplies are transported to the site by truck approximately 275 mi from Salt Lake City, Utah, and approximately 190 
mi from Grand Junction, Colorado. Material mined at Bullfrog will be transported 117 road mi to Energy Fuels’ White Mesa Mill 
near Blanding, Utah, of which 107 miles are on paved roads.

112

History

In the late 1960s, Gulf Minerals (Gulf) acquired a significant land position southwest of the Bullfrog Project (formerly referred to as 
the  Henry  Mountains  Complex)  and  drilled  approximately  70  holes  with  little  apparent  success.  In  1970  and  1971,  Rioamex 
Corporation conducted a 40-hole drilling program in an east-west zone extending across the southerly end of the Bullfrog property 
and the northerly end of the Tony M–Frank M property. Some of these holes intercepted significant uranium mineralization.

The ownership history of the Bullfrog and Southwest deposits and The Tony M deposit evolved independently from the mid-1970s 
until early 2005. The Bullfrog and Southwest deposits were initially explored by Exxon Minerals Company (“Exxon”), while the 
Tony M deposit was explored and developed by Plateau, a subsidiary of Consumers Power Company (Consumers) of Michigan. In 
2005, International Uranium Corporation (“IUC”) combined the three deposits into a larger land package. In 2021, EFR divested of 
the Tony M Property and Southwest deposit, retaining the mineral claims associated with the Bullfrog Deposits (Copper Bench and 
Indian Bench).

Exxon conducted reconnaissance in the area in 1974 and 1975, resulting in staking of the first “Bullfrog” claims in 1975 and 1976. 
The  first  drilling  program  in  1977  resulted  in  the  discovery  of  what  became  the  Southwest  deposit.  Additional  claims  were 
subsequently  staked,  and  drilling  was  continued,  first  by  Exxon’s  Exploration  Group,  and  then  by  its  Pre-Development  Group. 
Several  uranium  and  vanadium  zones  were  discovered  in  the  Southwest  and  Copper  Bench  areas,  and  mineralization  exhibiting 
potential  economic  grade  was  also  discovered  in  the  Indian  Bench  area.  With  the  declining  uranium  markets  of  the  early  1980s, 
Exxon prepared a prefeasibility report and then discontinued development of the property. Subsequently, Exxon offered the property 
to Atlas Minerals Corporation (“Atlas”) in January 1982. 

Atlas entered into an agreement to purchase the Bullfrog property from Exxon in July 1982. From July 1982 to July 1983, Atlas 
completed 112 drillholes delineating the Southwest and Copper Bench deposits on approximately 100 ft centers. In August 1983, 
Atlas commissioned Pincock, Allen and Holt, Inc. (“PAH”), to conduct a feasibility study for development of the Southwest and 
Copper Bench deposits. From July 1983 to March 1984, Atlas completed a core drilling program throughout the Bullfrog property, 
as well as a rotary drillhole program to delineate the Indian Bench deposit. In November 1983, Atlas renamed the Bullfrog deposits 
as the “Edward R. Farley Jr. Deposit,” but that name is no longer used. 

Atlas continued to hold the Bullfrog property until 1990 when a corporate decision was made to consider its sale. During that year, 
Mine  Reserves  Associates,  Inc.  (MRA)  of  Tucson,  Arizona,  was  retained  to  prepare  mineral  inventory  and  mineable  reserve 
estimates  for  the  Indian  Bench  deposit  and  incorporate  the  results  into  a  project-wide  reserve  base.  Steve  Milne  of  Milne  and 
Associates (“Milne”), a principal engineer for the PAH study, was engaged in November 1990 to update the PAH feasibility study 
and to complete an optimization study on selected mining/milling scenarios. The completed Milne study was submitted to Atlas in 
December 1990. 

Atlas did not sell the Bullfrog property, and in 1991 returned it to Exxon. In late 1992, EFN, no relation to EFR, acting through its 
subsidiary Energy Fuels Exploration Company, purchased the property from Exxon. EFN conducted a geologic review and internal 
economic analysis of the Bullfrog property. In 1997, IUC became the owner of the Bullfrog property as part of an acquisition in 
which IUC acquired all of EFN’s assets. IUC performed no exploration activities on the properties. 

On  December  1,  2006,  IUC  combined  its  operations  with  those  of  DMI,  and  DMI  became  a  subsidiary  of  IUC.  IUC  was  then 
renamed Denison.

In June 2012, Energy Fuels acquired 100% of the Bullfrog Project (formerly referred to as the Henry Mountains Complex) through 
the acquisition of Denison and its affiliates’ U.S. Mining Division. The Company has not performed any work on the property since 
the Bullfrog Project was acquired in 2012.

In October 2021, EFR divested of the Tony M property and Southwest deposit to CUR, retaining the mineral claims associated with 
the Bullfrog (Copper Bench and Indian Bench) Deposits.

Although the Company has completed initial environmental baseline studies and mine plans for permitting purposes at the Bullfrog 
Property, the submittal of permit applications has been deferred pending favorable market conditions.

Permitting

113

Geologic Setting, Mineralization and Deposit

The Copper Bench and Indian Bench Deposits are classified as sandstone hosted uranium deposits. Sandstone-type uranium deposits 
typically occur in fine to coarse grained sediments deposited in a continental fluvial environment. The uranium may be derived from 
a  weathered  rock  containing  anomalously  high  concentrations  of  uranium,  leached  from  the  sandstone  itself  or  an  adjacent 
stratigraphic unit. It is then transported in oxygenated groundwater until it is precipitated from solution under reducing conditions at 
an oxidation-reduction interface. The reducing conditions may be caused by such reducing agents in the sandstone as carbonaceous 
material, sulfides, hydrocarbons, hydrogen sulfide, or brines. 

Uranium  mineralization  on  the  Bullfrog  Property  is  hosted  by  favorable  sandstone  horizons  in  the  lowermost  portion  of  the  Salt 
Wash Member of the Jurassic age Morrison Formation, where detrital organic debris is present. Mineralization primarily consists of 
coffinite,  with  minor  uraninite,  which  usually  occurs  in  close  association  with  vanadium  mineralization.  Uranium  mineralization 
occurs as intergranular disseminations, as well as coatings and/or cement on and between sand grains and organic debris. Vanadium 
occurs as montroseite (hydrous vanadium oxide) and vanadium chlorite in primary mineralized zones located below the water table.

The vanadium content of the Henry Mountains Basin deposits is relatively low compared to many other Salt Wash hosted deposits 
on the Colorado Plateau. Furthermore, the Henry Mountains Basin deposits occur in broad alluvial sand accumulations, rather than 
in  major  sandstone  channels  as  is  typical  of  the  Uravan  Mineral  Belt  deposits  of  western  Colorado.  The  Henry  Mountains  Basin 
deposits do, however, have the same general characteristic geochemistry of the Uravan deposits, and are therefore classified as Salt 
Wash type deposits.

Data Verification

The  assay  data  used  to  calculate  the  Mineral  Resource  estimate  for  the  Project  is  natural  gamma  radiometric  log  data.  Core  was 
collected by both Exxon and Atlas at various times to verify natural gamma data but was not used for Mineral Resource estimation. 
Calibration data for natural gamma logs are available for all drilling.

Utilizing  only  natural  gamma  logs  as  assay  data  could  lead  to  an  over  or  under  estimation  of  Mineral  Resources  due  to 
disequilibrium. Positive disequilibrium occurs when the uranium present has not had enough time to decay and produce daughter 
isotopes, which are what are actually measured during a natural gamma assay. Under positive disequilibrium a natural gamma assay 
would indicate lower amounts of uranium than what is present. Negative disequilibrium occurs when uranium has had enough time 
to decay to produce the daughter radioisotopes but was remobilized and removed from the deposit. This would lead to measuring 
more  uranium  than  is  present.  The  Project  is  part  of  a  larger  mining  district  with  no  history  of  disequilibrium  issues.  The 
disequilibrium factor applied to the Project Mineral Resource is 1.0.

Mineral Resource Estimates

Mineral Resources for the Bullfrog deposits were calculated using the GT contour method. The GT contour method is commonly 
used in the uranium industry and refers to the estimated grade multiplied by estimated thickness. In many uranium deposits, thin 
uranium  mineralization  can  be  mined  due  to  those  zones  being  higher  grade.  The  GT  method  allows  that  information  to  be 
accurately calculated and displayed.

For  the  GT  method,  composite  samples  were  flagged  by  each  sand  unit  for  each  deposit.  GT  contours  were  modeled  using  this 
composite data for each of the three mineralized sand zones (MU, ML and L) within the Bullfrog deposit. The modeling process 
resulted in the creation of grade and thickness grid files or rasters.

Mineral Resources have been estimated using ESRI’s ArcGIS software Spline with Barriers tool routine. The Spline with Barriers 
tool applies a minimum curvature method, as implemented through a one-directional multigrid technique that moves from an initial 
coarse  grid,  initialized  in  this  case  to  the  average  of  the  input  data,  through  a  series  of  finer  grids  until  an  approximation  of  a 
minimum curvature surface is produced at the desired row and column spacing.

The  methodology  employed  was  chosen  to  replicate  the  2012  Mineral  Resource  estimate  that  used  the  GT  contour  method 
(Agnerian  and  Roscoe,  2001),  while  allowing  for  calculating  resources  at  various  GT  cut-off  grades.  Each  of  the  deposits  was 
gridded into 25 ft by 25 ft cells and a spline interpolator was used to calculate a grade (% eU3O8) and thickness (feet) raster for each 
of the sands for the deposit. Based on the grade raster, a 0.10% eU3O8 contour was generated for each of the sand units. The 0.10% 
eU3O8 constrained grade contours were used as a maximum extent to determine a reasonable prospect for economic extraction for 
each zone. Both the grade and thickness rasters for each of the sands were constrained to the 0.10% U3O8 contour. Those two rasters 
were then multiplied together to get a GT grid.

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Interpolated grade and thickness for each 25 ft by 25 ft grid node within the grade boundary defined by 0.10% eU3O8 were exported 
into a series of Excel spreadsheets to calculate GT on a per grid node bases for the MU, ML, and L zones.

The plan areas of the MU, ML, and L zones resolved into numerous lenses of mineralization above 0.10% eU3O8. Only GT and 
thickness  interpolated  values  inside  the  0.10%  eU3O8  “cookie  cutter”  boundaries  were  retained,  and  isolated  areas  over  0.10% 
eU3O8 defined by a single drillhole were removed.

The thickness times area products for each set of grid node were summed to give a volume for each of the MU, ML, and L zones. A 
tonnage factor of 15 ft3/ton was applied to calculate the total tonnage for each domain.

The GT by area products for each grid node were summed and divided by the tonnage factor of 15 ft3/ton for a total that is converted 
to  pounds  of  contained  metal  (lb  eU3O8)  for  each  zone.  The  average  grade  of  each  node  is  obtained  from  converting  the  total 
contained pounds of metal (lb eU3O8) into tons of contained metal (ton eU3O8) divided by the total tonnage.

Specific  details  regarding  the  estimation  of  Mineral  Resources  can  be  found  in  Section  14.0  Mineral  Resource  Estimates  of  the 
Bullfrog Technical Report Summary.

The table below sets out the Mineral Resources estimates for the Bullfrog Project as of December 31, 2023. These estimates are 
derived  from  the  Bullfrog  Technical  Report  Summary,  which  estimated  Mineral  Resources  as  of  December  31,  2021.  Daniel 
Kapostasy,  the  Company’s  non-independent  Qualified  Person,  reviewed  and  confirmed  that  the  Mineral  Resources  estimates  set 
forth in the Bullfrog Technical Report Summary remained accurate as of December 31, 2023.

Bullfrog Project Mineral Resources – In Situ Uranium(1)(2)(3)(4)(5)(6)(7)(8)

Classification

Area

Cut-Off 
Grade 
(%eU3O8)

Tons 
(000s)

Grade (% 
eU3O8)

Bullfrog
Total Measured Resources
Bullfrog
Total Indicated Resources
Total Measured + Indicated Resources Bullfrog
Bullfrog
Total Inferred Resources

---

0.165
0.165
0.165
0.165

---
1,560
1,560
410

Notes:

Contained 
Metal (000s 
lbs of U3O8)
---

0.29 9,100
0.29 9,100
0.25 2,010

Metallurgical 
Recovery

 95 %
 95 %
 95 %
 95 %

(1) SEC S-K 1300 and NI 43-101 definitions were followed for all Mineral Resource categories.
(2) Cut-off grade is a 0.5 GT cut-off (minimum 0.165% eU3O8 over a minimum thickness of 3 ft.).
(3) Cut-off grade is calculated using a sale price of $65/lb. U3O8. The long-term uranium price is based on supply and demand 
projections for the period 2021-2035. 
(4) No minimum mining width was used in determining Mineral Resources.
(5) Mineral Resources based on a tonnage factory of 15.0 ft.3/ton (Bulk density 0.0667 ton/ft3 or 2.13 t/m3).
(6) Mineral Resources have not been demonstrated to be economically viable.
(7) Total may not add due to rounding.
(8) Mineral Resources are 100% attributable to EFR.

Present Condition of the Property and Work Completed to Date

There is no existing infrastructure on the Bullfrog Property.

The  Bullfrog  Project  was  acquired  by  the  Company  in  June  2012,  through  the  acquisition  of  the  U.S.  Mining  Division  from 
Denison. The cost of the Bullfrog Project has been fully impaired, and as of December 31, 2023, the total net book value attributable 
to the Bullfrog Project and its associated equipment on the financial statements of the Company was nil.

The Company’s Planned Work

Due to improvement in the uranium market, the Company is planning to conduct additional evaluation work at the Bullfrog Project 
during  2024.  The  Company  plans  on  initiating  an  engineering  study  to  determine  the  surface  and  underground  infrastructure 
required to bring the Project into production. This information will also be used in permitting activities associated with the Project.

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The La Sal Project

The following technical and scientific description of the La Sal Project is based in part on the report titled “Technical Report on the 
La Sal Project, San Juan County, Utah, USA” dated February 22, 2022, prepared by Mark B. Mathisen, C.P.G., a Qualified Person 
employed by SLR (the “La Sal Technical Report Summary”). The La Sal Technical Report Summary was prepared in accordance 
with S-K 1300 and NI 43-101. The La Sal Project does not have known “Mineral Reserves” and is therefore considered under SEC 
S-K  1300  definitions  to  be  an  exploration  stage  property,  notwithstanding  that  the  Company  commenced  production  from  the 
property starting in January 2024.

Project Description

The La Sal Project is an existing complex comprised of seven individual underground uranium mines and properties. From east to 
west,  these  are  Pine  Ridge  (reclaimed  mine),  Pandora  Mine,  Snowball  Mine,  La  Sal  Decline,  Beaver  Shaft,  Redd  Block  IV 
(property), and the Energy Queen Mine. All the properties that make up the La Sal Project is 100% controlled by the Company’s 
wholly owned subsidiary EFR Colorado. 

The area encompassed by the La Sal Project is located on two U.S. Geological Survey 7½ minute quadrangle topographic maps, La 
Sal West and La Sal East. The geographic coordinates for the approximate center of the La Sal Project are latitude 38°18’48.20” N 
and longitude 109°15’56.28” W. 

116

Ownership

The Project consists of approximately 9,500 acres of mineral rights in a combination of unpatented mining claims owned by EFR 
Colorado, unpatented mining claims leased by EFR Colorado, State of Utah mineral leases, a San Juan County surface use, access, 
and mineral lease, and mining leases on private mineral rights, all located in the La Sal Mining District. The land surface overlying 
some mineral rights is also of varying ownership. Where the federal government controls the surface and minerals, EFR Colorado 
has the right to access, explore, develop, and mine on unpatented mining claims located on land managed by the BLM or USFS, as 
long as NEPA regulations are met. All other property, regardless of ownership, is covered by access or surface lease agreements 
with landowners, including ranchers, San Juan County, and the State of Utah. Total holding costs including fee leases, surface use 
agreements and claims in 2023 were $194,856.

The Company holds 90 unpatented mining claims on various sections of both USFS and BLM land across the Project. A mining 
lease between Robert H. Sayre, Jr. and UMETCO, dated July 11, 1973, applies to the 10 unpatented Martha claims at the east end of 
the  Pandora  claims.  EFR  Colorado  is  successor  to  this  lease.  Production  from  these  claims  is  subject  to  a  royalty  to  Sayre’s 
successors  of  10%  of  the  contained  value  of  uranium  and  vanadium,  less  certain  allowable  deductions.  The  Martha  claims  lie  in 
Section  31,  Township  28  South,  Range  25  East  and  Section  5,  Township  29  South,  Range  25  East.  The  mining  lease  does  not 
include any requirement for annual advance royalties or other lease payments.

All claims, which are renewed annually in September of each year, are in good standing until September 1, 2024 (at which time they 
will be renewed for the following year as a matter of course). All unpatented mining claims are subject to an annual federal mining 
claim maintenance fee of $165 per claim plus approximately $10 per claim for county filing fees to the BLM.  

The  Company  leases  the  mineral  rights  on  119  claims  located  across  the  Project.  These  claims  are  held  through  four  separate 
mineral leases (“MLs”) described in detail below.  

Six  Crested  and  two  T&A  claims  are  covered  by  a  Mining  Lease  dated  February  1,  2009,  between  eight  individual  owners  and 
Denison, which was acquired by the Company in June 2012. These claims are located in Sections 33 and 34, Township 28 South, 
Range 24 East and Section 3, Township 29 South, Range 24 East. EFR Colorado pays an annual advance royalty determined by the 
long-term uranium price in the preceding twelve months. Production royalties are on a sliding scale for both uranium and vanadium 
depending on the respective commodity’s market price. The uranium royalty varies from 3% to 8% and the vanadium royalty from 
2%  to  6%,  less  allowable  deductions.  The  annual  $165/claim  annual  BLM  fees  are  the  responsibility  of  the  Company.  No  other 
lease costs apply to these claims.

Six  Mike  claims  are  covered  by  a  Mining  Lease  dated  August  1,  2001,  between  various  stakeholders  of  the  Mike  claims  and 
Denison, which was acquired by the Company in June 2012. This lease supersedes the original 1970 lease between UMETCO and 
the  owners.  The  claims  lie  in  Section  1,  Township  29  South,  Range  24  East.  Production  royalties  are  on  a  sliding  scale  for  both 
uranium and vanadium depending on the respective commodity’s market price. The uranium royalty varies from 3% to 8% and the 
vanadium royalty from 2% to 6%, less allowable deductions. The annual $165/claim annual BLM fees are the responsibility of the 
Company. No other lease costs apply to these claims.

The  Pandora  Mining  Lease,  dated  June  16,  1967,  was  originally  between  Robert  H.  Sayre,  Jr.  and  American  Metal  Climax,  Inc. 
(American  Metal).  Successors  to  American  Metal  include  Atlas  Minerals  in  1973  and  UMETCO  in  1988.  The  Company  is  the 
current  successor  to  the  Pandora  Mining  Lease  and  its  amendments.  The  Pandora  Mining  Lease  and  amendments  apply  to  105 
unpatented  Pandora  claims.  The  claims  lie  in  Sections  1  and  12,  Township  29  South,  Range  24  East,  Section  31,  Township  28 
South, Range 25 East, and Sections 5, 6, and 7, Township 29 South, Range 25 East. Production from these claims is subject to a 
royalty to Sayre’s successors of 10% of the contained value of uranium and vanadium, less certain allowable deductions. The annual 
$165/claim annual BLM fees are the responsibility of the Company. No other lease costs apply to these claims.

EFR  Colorado  holds  approximately  2,182  acres  under  mineral  lease  from  the  State  of  Utah  School  and  Institutional  Trust  Lands 
Administration (“SITLA”) in seven separate leases. Three of the leases (ML-18301, -49313, and –51440), covering 900 acres of the 
surface area, are owned by the State of Utah and thereby grant access to EFR Colorado for exploration and mining related work. 
The  other  1,282  acres  of  surface  are  under  private  ownership.  The  private  parcels  are  all  subject  to  valid  access  and  surface  use 
agreements with the landowners. The production royalty for all SITLA leases is 8% on uranium and 4% on vanadium. It is based on 
the gross value received under contract for the processed products less the actual processing and refining costs. Mining costs are not 
allowable deductions.

The  Utah  State  mineral  lease  ML-18301,  covering  all  of  the  640  acres  in  Section  36,  T28S,  R24E,  was  originally  issued  to  an 
individual,  Robert  Manly,  on  April  25,  1960.  Through  a  series  of  assignments  and  amendments,  the  lease  is  now  held  by  EFR 
Colorado.  The  current  term  of  the  lease  runs  through  December  31,  2024;  it  is  renewable  annually  by  making  an  annual  rental 

117

payment as well as advance royalty payments. The annual rental is $1.00/acre ($640 total) and the advance royalty payment is based 
on the previous January through November’s average uranium and vanadium market prices. Rentals and annual minimum royalties 
are credited against actual production royalties for the year in which they accrue. Mining costs are not allowable deductions. The 
surface of approximately 384 acres of the western part of the lease parcel is owned by Charles Hardison Redd and EFR Colorado 
has a surface access agreement with Redd. The surface of the eastern part of the lease, a total of 256 acres, is owned by the State of 
Utah State. Rights to necessary surface use are granted by the mineral lease. The eastern part of the Beaver/La Sal mine lies within 
this lease.

Mineral lease ML-27247 covers 40 acres in the SW¼, SW¼, Section 35, T28S, R24E. The lease was originally issued on December 
4, 1970, to an individual, Gregory Hoskin. Through a series of assignments and amendments, the lease is now held by the Company. 
The current term of the lease runs through December 31, 2024; it is renewable annually by making advance royalty payments. The 
surface of the western 20 acres of the lease parcel is owned by Redd Agri LLC (Redd Agri) and the eastern 20 acres is owned by La 
Sal Livestock. The Company has a surface access agreement with both Redd Agri and La Sal Livestock. Portions of the western part 
of the Beaver mine lie on this lease parcel. The lease is held by paying an annual rental payment and an annual minimum royalty 
based  on  the  previous  January  through  November’s  average  uranium  and  vanadium  market  prices.  Rentals  and  annual  minimum 
royalties are credited against actual production royalties for the year in which they accrue.  

As with ML-27247, the Mineral Lease ML-27248 was originally issued to Gregory Hoskin in December 1970 and is now held by 
the Company following several assignments and amendments. It covers 80 acres in the W½, NW¼, Section 2, Township 29 South, 
Range 24 East. With the exception of small parcels owned by the San Juan School District and the La Sal Recreation District, the 
surface is owned by Redd Agri. The Company has a surface use agreement with Redd Agri for those portions held by Redd Agri. 
Portions of the western part of the Beaver mine are located on this lease. The Company’s operations of the Beaver mine and any 
expected exploration drilling are not affected by access restrictions to the School and Recreation District’s acreage. The lease is held 
by paying in advance an annual rental and an annual minimum royalty based on the previous January through November average 
uranium and vanadium market prices. Rentals and annual minimum royalties are credited against actual production royalties for the 
year in which they accrue. 

In December 2010, the Company purchased Utah State mineral lease ML-49313 from Uranium One with the seller retaining a 1% 
overriding  royalty.  Uranium  One  acquired  the  lease  from  the  original  assignee,  William  Sheriff.  The  lease  was  renewed  by  the 
Company on May 1, 2014, for a second 10-year term. This lease covers about 484 acres in the S½, S½ of NW¼, and E½ of NE¼, 
Section 36, Township 28 South, Range 23 East. The southeast corner of this section is about one mile west of the Energy Queen 
shaft. It is connected to the Energy Queen lease property by BLM land (W½, Section 31, Township 28 South, Range 24 East and 
part  of  NW¼,  Section  6,  Township  29  South,  Range  24  East)  currently  covered  by  unpatented  mining  claims  (Daisy  and  DOD 
claims) held by EFR Colorado. ML-49313 is contiguous to the north border of the RM and Judas claims. No mining has taken place 
on this lease. The surface is owned by SITLA. Rights to necessary surface use are granted by the lease. This lease is held by an 
annual payment. No annual minimum royalties apply.

This lease was issued on April 30, 2004, to William Sheriff. Mr. Sheriff assigned it to Energy Metals Corporation in 2006, which 
then became Uranium One in 2009. In February 2011, Denison (acquired by the Company in June 2012) purchased it from Uranium 
One. The lease was renewed by the Company on May 1, 2014, for a second 10-year term. The lease covers 640 acres, all of Section 
32, Township 28 South, Range 25 East. This lease lies north of the eastern part of the Pandora Mine, but no mining has occurred on 
this lease. The surface is owned by Paul Redd. EFR Colorado has a surface access agreement with Mr. Redd to access a Pandora 
Mine ventilation hole. The lease is held by paying in advance an annual rental. No annual minimum royalties apply.

This lease was issued on April 30, 2004, to William Sheriff. Mr. Sheriff assigned it to Energy Metals Corporation in 2006, which 
then became Uranium One in 2009. In February 2011, Denison (acquired by the Company in June 2012) purchased it from Uranium 
One. The lease was renewed by the Company on May 1, 2014, for a second 10-year term. The lease covers almost 138 acres, mostly 
in the NE¼ and parts of the NW¼, Section 5, Township 29 South, Range 24 East. A portion of the Redd Block Mineral Resource is 
located on this lease. The surface is owned by SITLA. Rights to necessary surface use are granted by the lease. No mining has yet 
occurred. This lease is held by paying in advance an annual rental. No annual minimum royalties apply.

In September 2008, the Company was the highest bidder on a State of Utah mineral lease, ML-51440, which covers 160 acres in the 
N½ S½, Section 32, Township 28 South, Range 24 East. This lease was renewed by the Company on October 31, 2018, for a second 
10-year term. This lease borders the Redd Block Mineral Resource on the north side. The surface is owned by SITLA. Rights to 
necessary  surface  use  are  granted  by  the  lease.  An  annual  payment  is  required  to  hold  this  lease.  No  annual  minimum  royalties 
apply.

The Company has leased the mineral rights on numerous parcels from various private landowners. The Redd family, as individuals 
or  in  legal  entities,  namely  La  Sal  Livestock  and  Redd  Agri,  LLC,  has  owned  much  of  the  subject  land  for  many  decades,  both 

118

mineral  rights  and  surface.  A  few  small  parcels  have  joint  ownership  of  minerals  with  parties  other  than  the  Redd  family.  The 
surface estate has been split from the minerals on numerous parcels. The Company has surface use and access agreements in place 
with all the private landowners that allow for any activities pertaining to exploration, development, and mining. The expiration dates 
for  these  leases  range  from  2026  to  2031  but  can  be  held  indefinitely  through  production.  All  fee  leases  are  subject  to  annual 
payment, which may require adjustments based on the long-term spot price of uranium and vanadium.

Most of the mineral ownership east and north of the Energy Queen Mine is vested in Redd Royalties, Ltd. The Energy Queen lease 
at the west end of the district is not owned by Redd Ranches (a partnership of 11 members of the Redd family) or its affiliates.

The Company entered into a 30-day option with Markle Ranch Holdings, LLC on November 15, 2006, to lease the Energy Queen 
surface  rights.  A  lease  was  signed  on  December  15,  2006,  for  a  term  of  twenty  years,  which  is  extendable  if  mineral  production 
occurs  on  a  continuing  basis.  The  lease  gives  EFR  the  right  to  use  any  of  the  702  acres  for  exploration,  development,  or  mining 
purposes. Markle will be paid a small percentage of market value for any material mined on adjoining properties, if such minerals 
are removed by use of the mineshaft located on the Markle property.

The  Company  also  entered  into  a  30-day  option  to  lease  the  Energy  Queen  mineral  rights  from  Superior  Uranium  (Superior)  on 
November 15, 2006. A Mining Lease Agreement was signed on December 13, 2006, for a term of twenty years, which is extendable 
if mineral production occurs on a continuing basis.

The mineral lease and surface lease cover the same 702 acres located in most of Section 6 and the N½ NE¼ and NE¼ NW¼ Section 
7,  Township  29  South,  Range  24  East.  A  production  royalty  will  be  paid  on  a  sliding  scale  for  both  uranium  and  vanadium 
depending on the market prices of uranium.

The  surface  and  minerals  of  this  parcel  were  leased  previously  to  Hecla  Mining  with  the  surrounding  properties  controlled  by 
UMETCO. These two companies operated the mine, then known as the Hecla Shaft, in a joint venture. The shaft and other surface 
facilities for the Energy Queen Mine are located in the northeast corner of Section 6.

The leased parcel referred to as Redd 1-A covers 160 acres in the SE¼ Section 31, Township 28 South, Range 24 East, immediately 
north  of  the  Energy  Queen  Mine.  This  lease  was  once  part  of  a  much  larger  mining  lease  dated  June  1,  1971,  between  Union 
Carbide Corporation (Union Carbide) and Redd Ranches, a partnership of 11 members of the Redd family. The other parcels were 
released in November 1999. Through a succession of assignments, the Company became the owner of the Mining Lease with the 
acquisition of Denison’s U.S. Mining Division in June 2012. It is the intent of the Company to continue to hold the lease. No mining 
has  occurred  on  this  parcel.  The  production  royalty  is  a  percentage  of  “gross  value.”  The  gross  value  is  the  combination  of  the 
Uranium Base plus the Vanadium Base. The Uranium Base is determined by a table that has specified dollar amounts based on the 
U3O8  grade  of  the  ore  produced.  The  Uranium  Base  is  adjusted  from  the  table  value  by  the  actual  price  received  for  sale  of 
concentrates  in  the  preceding  six  months.  The  Vanadium  Base  is  determined  by  the  V2O5  component  of  an  ore  purchase  price 
offered by the Mill or other price of V2O5 contained in ore prevailing in the area at the time the ore is fed to the initial process. 
Surface access is granted to this land in an agreement with La Sal Livestock. 

The leased parcel referred to as Redd 1-B was entered at the same time and in the same form as the Redd 1-A lease described above, 
but covering different parcels of land. The Redd 1-B Mining Lease applies to 1,720 acres in the following sections: S½ SW¼ and 
SW¼ SE¼, Section 25, NE¼ NE¼, Section 35, N½ NW¼ and W½ SW¼ Section 36, Township 28 South, Range 23 East; E½ SE¼ 
and SE¼ NE¼ Section 34 and W½ NW¼ Section 35, Township 28 South, Range 24 East; all of Section 2, Township 29 South, 
Range 24 East, except the W½ NW¼; the SE¼, E½ SW¼ and E¼ NE¼, Section 3, Township 29 South, Range 24 East; and the N½ 
Section  11,  Township  29  South,  Range  24  East.  An  annual  advance  royalty  is  paid  to  hold  this  lease.  It  is  the  intent  of  EFR 
Colorado to continue to hold the lease. The production royalty is a percentage of the “gross value”; gross value is defined the same 
here as under the Redd Royalties Block 1-A mining lease. EFR Colorado is granted access to the surface of this Mining Lease under 
agreements with both La Sal Livestock and Redd Agri.

This lease was entered into on February 5, 2008, between Denison (acquired by the Company in June 2012) and Redd Royalties for 
a 20-year term to cover some of the land previously part of the Redd 1-A that had been released from the 1-A lease in 1999. The 
leased  land  lies  in  the  following  parcels:  NE¼  Section  31,  Township  28  South,  Range  24  East;  S½  NE¼  and  SE¼  Section  4, 
Township 29 South, Range 24 East; and SE½ Section 5, Township 29 South, Range 24 East. It totals approximately 683 acres. An 
annual  advance  royalty  is  paid  to  hold  this  lease.  No  mining  has  occurred  on  the  subject  land.  If  mining  occurs  on  the  lease.  a 
“market value” production royalty will be due on a sliding scale. The “market value” is determined to be the published prices for the 
two  products,  uranium  and  vanadium,  in  the  month  the  ore  is  fed  to  process  multiplied  by  the  contained  pounds  less  allowable 
deductions. The allowable deductions include sales brokerage fees, costs of transporting processed concentrates to point of sale, and 
applicable  production  and  sales  taxes.  Payments  for  surface  access  agreements  are  made  to  Lowry  Redd  and  Charles  Redd  for 
specific surface parcel ownership.

119

On January 31, 1968, Union Carbide entered a mining lease with Redd Ranches, a partnership of 11 members of the Redd family, 
for the rights to more than 3,680 acres north and east of La Sal, Utah. Since then, various parcels have been dropped from the lease.  
The  current  lease  held  by  the  Company  is  applicable  to  only  60  acres  described  as  SE¼  SW¼  and  E½  SW¼  SW¼  Section  31, 
Township 28 South, Range 25 East. It is the intent of the Company to continue to hold the lease. A production royalty is based upon 
the “gross value”; gross value is defined the same here as under the Redd Royalties Block 1-A mining lease. Mining in portions of 
the Snowball Mine took place on the subject land up to the cessation of mining in the Pandora/Snowball Mines in December 2012.

Denison (acquired by the Company in June 2012) entered into a mining lease with Redd Royalties on February 5, 2008, to cover an 
area previously in the Pine Lodge Unit (described above) that had been dropped from the older lease. The current lease held by the 
Company  applies  to  100.4  acres  described  as  W½  NE¼  SW¼;  NW¼  SW¼;  and  Lots  2  and  3,  Section  31,  Township  28  South, 
Range 25 East. An annual advance royalty is paid to hold this lease. It is the intent of the Company to continue to hold this lease. No 
mining has occurred on the subject land. When ore production commences, a “market value” production royalty will be due on a 
sliding scale. The “market value” is determined to be the published prices for the two products, uranium and vanadium, in the month 
the  ore  is  fed  to  process  multiplied  by  the  contained  pounds,  less  allowable  deductions.  The  allowable  deductions  include  sales 
brokerage fees, costs of transporting processed concentrates to point of sale, and applicable production and sales taxes. 

Union Carbide entered into a lease with Katheryn Anne Redd Mullins and 10 other members of the Redd family on April 16, 1973. 
It covered 50% of the mineral ownership of 280 acres located in S½ SW¼ and S½ SE¼, Section 33, Township 28 South, Range 24 
East and SE¼ SW¼ and W½ SE¼, Section 34, Township 28 South, Range 24 East. The remaining 50% mineral ownership of these 
parcels is discussed in the subsections Crawford-Kelly portion of Redd-Mullins Land and Barton Norton Estate portion of Redd-
Mullins Land.

The lease has undergone various assignments and amendments. The lease is held by an annual advance royalty payment. It is the 
Company’s intent to continue to hold this lease. The production royalty on the 50% mineral ownership on this leased land is due at a 
percentage of “gross value”; gross value is defined the same here as under the Redd Royalties Block 1-A mining lease. Production 
from the western end of the Beaver Shaft has occurred on the Section 34 portion of this lease. Surface access is secured through 
agreements with both La Sal Livestock and Redd Agri for various portions of the leased land.

A 20-year mining lease was entered into between Denison (acquired by the Company in June 2012) and the Erma Crawford Family 
Trust on April 1, 2008. It applies to the Crawford’s 25% mineral ownership of 240 acres of land situated in S½ SW¼ and SW¼ 
SE¼, Section 33, Township 28 South, Range 24 East and SE¼ SW¼ and W½ SE¼, Section 34, Township 28 South, Range 24 East. 
An  annual  advance  royalty  payment  is  made  to  hold  this  lease.  The  production  royalty  is  based  on  a  sliding  scale.  The  “market 
value” is determined to be the published prices for the two products, uranium and vanadium, in the month the ore is fed to process 
multiplied  by  the  contained  pounds,  less  allowable  deductions.  The  allowable  deductions  include  sales  brokerage  fees,  costs  of 
transporting processed concentrates to point of sale, and applicable production and sales taxes.

Two additional, identical mining leases were made effective May 1, 2008, and May 12, 2008, between Denison (acquired by the 
Company  in  June  2012)  and  Robert  and  Pamela  Fergusson,  and  between  Denison  (acquired  by  the  Company  in  June  2012)  and 
Carole and Fay Giles, respectively, to lease equally the remaining 25% of mineral rights in the same land parcels. These two leases 
combined are referred to as the Keller Estate portion of the Redd-Mullins Mining Lease. The annual advance royalty, determined in 
the same manner as the Crawford portion, is paid in four equal parts to the heirs of the Keller Estate. The Keller Estate lease carries 
the same production royalty as the Crawford portion.

Denison (acquired by the Company in June 2012) entered into a mining lease with Joel Norton, representative of the Thora Barton 
Norton  Estate  on  April  25,  2008.  The  lease  covers  a  50%  mineral  ownership  on  40  acres  located  in  the  SE¼  SE¼,  Section  33, 
Township  28  South,  Range  24  East.  The  other  50%  mineral  right  resides  with  Redd  Royalties,  as  described  in  the  Redd-Mullins 
Mining  Lease  subsection.  An  annual  advance  royalty  payment  is  made  to  hold  the  Barton  Norton  mineral  lease.  The  vanadium 
“market value” royalty is variable. The “market value” is determined to be the published prices for the two products, uranium and 
vanadium,  in  the  month  the  ore  is  fed  to  process  multiplied  by  the  contained  pounds,  less  allowable  deductions.  The  allowable 
deductions include sales brokerage fees, costs of transporting processed concentrates to point of sale, and applicable production and 
sales  taxes.  A  portion  of  the  Redd  Block  Mineral  Resource  is  located  on  this  parcel.  No  mining  has  taken  place  on  this  mineral 
lease. Surface access is covered by the La Sal Livestock Agreement.

A Metalliferous Mineral Lease between San Juan County, Utah, and Hecla Mining Company was signed April 17, 1967. This gave 
Hecla the right to explore and mine 262.69 acres located in the S½ S½, Section 32, Township 28 South, Range 24 East and most of 
the NW¼, Section 5, Township 29 South, Range 24 East. Two small private parcels in the NW¼ of Section 5 are excluded. A very 
small parcel, 0.18 acres in Section 10, Township 29 South, Range 24 East, is included in the lease. Hecla assigned 50% interest in 
the lease to Union Carbide in December 1976 as part of the Hecla-Union Carbide joint venture (JV). This JV operated the Hecla 

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Shaft (now Energy Queen) immediately west of Section 5 on the Superior Uranium Lease. The San Juan County Mineral Lease is 
held by an annual payment. It is the intent of the Company to continue to hold this lease. An amendment to the lease in January 
1968 changed the production royalty to match that used by the State of Utah on it metalliferous leases. When the Energy Queen 
Mine (Hecla Shaft) ceased operation in 1983, a development drift had advanced into the County land by a few tens of feet. Very 
little if any ore was produced at that time. The drift was developing toward mineral resources that are now part of the Redd Block 
Mineral Resources. The mineral lease allows for surface use as necessary for exploration and mining.

Accessibility, Climate, Local Resources, Infrastructure and Physiography

The La Sal Project is easily accessed from the all-weather Utah State Highway 46. Utah 46 enters the La Sal Project land about one 
mile west of the Energy Queen lease. Utah 46 stays within or very near the La Sal Project for the next eight miles to the east. The 
Energy Queen headframe, visible from the highway, is located approximately 500 ft south of Utah 46 and is accessed by a gravel 
road. 

The area of the La Sal Project is semi-arid. Temperatures range between an average low of 41°F to an average high of 72°F. Less 
than  10  in.  of  precipitation  falls  per  year.  Winters  are  not  particularly  severe,  although  there  are  numerous  snowstorms.  The 
temperature drops below 0°F at times, and snow can accumulate to over a foot in the lower elevations and more than two feet at 
higher elevations.

It is anticipated that most personnel will be hired from the local area with other personnel being hired from other mining districts 
around the country.

La Sal, Utah, is a small town consisting of a Post Office and general store. Most supplies necessary for mining operations can be 
found locally in the towns of Moab, Utah, or Monticello, Utah, 24 mi northwest or 34 mi south of the La Project, respectively.

121

The primary infrastructure as well as electricity and water are already in place at the Project. The mines associated with the Project 
were in commercial production between 2009 and 2012, before being placed on standby. A test-mining program that began in April 
2018 and ran through May 2019 included the rehabilitation of both the La Sal and Pandora declines and re-established underground 
utilities  to  most  of  the  mine  workings.  An  airport  in  Moab,  Utah  provides  daily  service  to  Salt  Lake  City,  Utah,  and  Denver, 
Colorado, both of which have international airports. 

Electric  transmission  and  distribution  lines  exist  throughout  the  project  area,  of  sufficient  size  to  supply  the  load  the  mines 
demanded in the past. Many portions of the electrical distribution system were replaced or refurbished as part of a test-mining and 
rehabilitation  program  that  occurred  at  the  Project  between  April  2018  and  May  2019.  The  electrical  supply  is  also  adequate  for 
additional demand should more ventilation fans, compressors, and even another production shaft with hoisting equipment be added 
when production resumes and expands. Natural gas is also available for any future production needs.

Water for the mine is purchased from a local rancher who maintains a water well near the Beaver Shaft. Water pumped from the 
well  is  either  transported  by  truck  to  the  facilities  where  it  is  distributed  to  the  mines  or  by  utility  drops  located  throughout  the 
Project. The eastern end of the Project, including all the current mine workings associated with the Beaver Shaft, La Sal Decline, 
and Pandora Mines are dry. The Energy Queen Mine workings and shaft are currently flooded and will need to be dewatered prior to 
mining.

History

In the late 1960s, three mining companies controlled most of the Project. Union Carbide had leases and claims in the central portion 
of the Project including the La Sal Decline, Snowball Mine, Beaver Shaft, and most of the Redd Block IV property; Union Carbide 
reorganized in the early 1980s and became UMETCO. American Metal Climax held the lease on the Pandora Mine as the east end 
of the Project; that lease was assigned to Atlas Minerals in 1973 and Atlas Minerals assigned it to UMETCO in 1988, retaining an 
overriding  royalty.  Hecla  Mining  held  the  Energy  Queen  and  San  Juan  County  leases  on  the  west  end  of  the  Project.  Hecla  and 
Union Carbide formed a joint venture on those properties in 1976.

UMETCO and EFN (no relation to the Company) entered into an agreement in 1984 whereby UMETCO owned 70% capacity in, 
and  was  the  operator  of,  the  Mill.  That  operating  agreement  was  restructured  in  1988  wherein  EFN  became  20%  owner  of  the 
UMETCO uranium-vanadium properties in Colorado and Utah, including the La Sal properties. In 1994, UMETCO gave back its 
interest in the Mill to EFN and assigned all interest in the La Sal properties, among others, to EFN, thereby giving EFN control of 
all previous UMETCO, Hecla, and Atlas properties in the Project. Many of the UMETCO personnel continued working for EFN. 
Original  data  of  the  previous  operators  also  transferred  to  EFN  ownership.  EFN  bought-out  the  Atlas  Minerals  royalty  on  the 
Pandora Mine in the mid-1990s. The Hecla 50% interest was also acquired by EFN.

IUC bought all assets of EFN in 1997 including the Project and the Mill. IUC did not retain the Superior Uranium lease (Energy 
Queen lease). Again, many personnel and all data on the Project transferred to IUC. In 2006, IUC acquired Denison and changed its 
name to Denison Mines Corporation (Denison). EFR Colorado entered into a new lease on the Energy Queen property in late 2006. 
The  Company  acquired  Denison’s  U.S.  Mining  Division  in  June  2012,  thereby  becoming  owner  and  operator  (through  various 
subsidiaries) of the entire Project and the Mill. Several Company staff have been associated with all or portions of the Project since 
the 1980s. All historical data on the Project is the property of the Company.

Following the end of commercial mining at the Project in October 2012, the Project was placed on care and maintenance. In 2018 
the La Sal, Beaver, and Pandora portions of the Complex were reopened and rehabilitated as part of a test mining program. In May 
2019 the Project was placed back into care and maintenance mode.

Permitting

Mineral extraction facilities on private and public lands in Utah require an approved Notice of Intent (“NOI”) with the UDOGM. If 
the  facility  generates  water,  a  ground  water  discharge  permit  is  required  for  the  treatment  plant  and  ponds,  and  a  surface  water 
discharge  permit  is  required  for  discharge  of  treated  water.  Both  permits  are  issued  through  DWQ.  Air  permits  for  air  emissions 
including radon are issued by the Utah Division of Air Quality. Water well permits, water rights, and stream alteration permits are 
issued through the Division of Water Rights. On federal land, all the state permits listed above are required, as well as a Plan of 
Operations approved through a NEPA review by the responsible federal land managing agency.

The Company’s mineral facilities at the La Sal Project are all existing facilities in historic mining areas, and approvals by the BLM 
and USFS have been obtained under EAs and FONSIs under NEPA. The Energy Queen and Redd Block IV Properties are located 
on private land and were permitted with UDOGM in the early 1980s by Union Carbide. The Energy Queen Property was developed 

122

and has conducted mineral extraction, but the Redd Block IV Property was discontinued soon after the start of construction. An NOI 
amendment  for  the  Energy  Queen  Property  was  approved  by  the  UDOGM  on  September  22,  2009.  This  amendment  allows  the 
Company to install water treatment and other new surface facilities to support extraction of up to 250 tons per day of mineralized 
materials. Water discharge permits to allow initial and ongoing discharge of water from underground workings were also approved 
by the DWQ in 2009 and renewed most recently in 2018. Energy Fuels initiated permitting plans for additional facility expansion in 
2012, but then deferred these plans when the Redd Block IV resource was acquired in the Denison acquisition. As market conditions 
may warrant, the Company intends to perform engineering studies to determine if the Redd Block IV resource can be extracted from 
the Energy Queen shaft and surface facilities. If this proves to be the case, the Energy Queen UDOGM permit would be updated to 
include  the  Redd  Block  IV  area  as  well  as  other  resources  that  have  been  acquired  since  the  2009  amendment.  A  Small  Source 
Exemption  that  is  in  place  for  air  emissions  would  also  need  to  be  replaced  with  an  air  permit  because  of  the  increased  surface 
disturbance. A groundwater discharge permit through DWQ may also be required prior to resuming dewatering operations at the 
Energy Queen Property.

Existing mining operations at the Pandora, Beaver, La Sal and Snowball Properties are fully permitted with the State of Utah, the 
BLM,  and  the  USFS.  In  order  to  allow  expansion  of  the  existing  mines,  Energy  Fuels  has  obtained  regulatory  approvals  for 
expansion of the Pandora, Beaver, and La Sal operations through the UDOGM, the BLM, and the USFS. In late 2014, an EA, draft 
Decision Notice and FONSI were issued for public comment. In March 2015, in response to an objection filed by an environmental 
interest group, the USFS ruled that additional analysis was required before a modified Plan of Operations and EA could be approved 
for the proposed expansion. An expanded EA was finalized by the USFS and BLM in September 2017. On February 23, 2018, the 
BLM and USFS issued the EA, Decision Record (BLM)/Decision Notice (USFS), and FONSI approving the expansion, conditional 
upon  the  Company  incorporating  certain  specific  requirements  into  the  Plan  of  Operations  amendment  and  having  the  required 
reclamation  bond  in  place.  On  September  26,  2018,  the  USFS  approved  the  Plan  of  Operations  amendment  and  surety  bond.  In 
November 2020, the Large Mine NOI permit expansion was approved through UDOGM. All other regulatory approvals needed for 
project expansion, including an air emissions permit, are in place.

Geologic Setting, Mineralization and Deposit

The Colorado Plateau covers nearly 130,000 square miles in the Four Corners regions. The La Sal Project lies in the Canyon Lands 
Section in the east-central part of the Plateau in Utah. The La Sal Mountains Intrusion is located to the north and east of the La Sal 
Project and the peaks are visible from most of the La Sal Project.

The La Sal deposits are classified as sandstone hosted uranium-vanadium deposits. Sandstone-type uranium deposits typically occur 
in fine to coarse grained sediments deposited in a continental fluvial environment. The La Sal Trend uranium-vanadium deposits are 
a similar type to those elsewhere in the Uravan Mineral Belt. The Uravan Mineral Belt was defined by Fisher and Hilpert (1952) as 
a curved, elongated area in southwestern Colorado where the uranium-vanadium deposits in the Salt Wash Member of the Morrison 
Formation generally have closer spacing, larger size, and higher grade than those in adjacent areas and the region as a whole. The 
location and shape of mineralized deposits are largely controlled by the permeability of the host sandstone. Most mineralization is in 
trends where Top Rim sandstones are thick, usually 40 feet or greater.

The La Sal Trend is a large channel of Top Rim sandstone that trends due east, possibly as a major trunk channel to tributaries that 
fanned-out to the east to make a portion of the Uravan Mineral Belt. The Energy Queen deposit appears to be at the location of the 
junction of a tributary channel that joins the main channel from the southwest. The uranium may be derived from a weathered rock 
containing anomalously high concentrations of uranium, leached from the sandstone itself or an adjacent stratigraphic unit. It is then 
transported  in  oxygenated  groundwater  until  it  is  precipitated  from  solution  under  reducing  conditions  at  an  oxidation-reduction 
interface.  The  reducing  conditions  may  be  caused  by  such  reducing  agents  in  the  sandstone  as  carbonaceous  material,  sulfides, 
hydrocarbons, hydrogen sulfide, or brines.

Data Verification

The primary assay data used to calculate the Mineral Resource estimate for the Project is natural gamma radiometric log data. Core 
was collected by Union Carbide to determine vanadium assays and core was collected by the Company in 2019 to verify vanadium 
assays and to verify natural gamma grades, where core data was available it was used in place of natural gamma data. Calibration 
for natural gamma completed by the Company was done at the DOE test pits in Casper, WY. No calibration records are available 
from Atlas or Union Carbide, but it is assumed that they followed standard operating procedures for calibrating their natural gamma 
equipment. 

Core analysis from Union Carbide was completed at their own laboratories. Core analysis by the Company was done at the White 
Mesa  Mill  in  Blanding,  Utah.  The  Company  submitted  uranium  standards  and  blanks  to  the  mill  as  part  of  a  standard  QA/QC 
procedure.

123

Utilizing  only  natural  gamma  logs  as  assay  data  could  lead  to  an  over  or  under  estimation  of  Mineral  Resources  due  to 
disequilibrium. Positive disequilibrium occurs when the uranium present has not had enough time to decay and produce daughter 
isotopes, which are what are actually measured during a natural gamma assay. Under positive disequilibrium a natural gamma assay 
would indicate lower amounts of uranium than what is present. Negative disequilibrium occurs when uranium has had enough time 
to decay to produce the daughter radioisotopes but was remobilized and removed from the deposit. This would lead to measuring 
more  uranium  than  is  present.  The  Project  is  part  of  a  larger  mining  district  with  no  history  of  disequilibrium  issues.  The 
disequilibrium factor applied to the Project Mineral Resource is 1.0.

Mineral Resources Estimates

Uranium block grade estimations for the La Sal Project were based on radiometric drillhole logs on the five principal mineralized 
domains (La Sal West, Energy Queen, Redd Block, Beaver/La Sal, and Pandora). Mineral Resources were estimated using Vulcan 
software  using  inverse  distance  squared  methods.  Vanadium  grades  were  calculated  based  on  the  uranium  grades  utilizing  a 
regression analysis. A power relationship was observed between the uranium grade (% U3O8) and the vanadium to uranium ratio 
(V2O5:U3O8). The relationship is given by the equation below:

y = 2.4805x-0.382

Where  y  is  the  V2O5:U3O8  ratio  and  x  is  the  uranium  grade  (%U3O8).  The  vanadium  grade  (%V2O5)  for  La  Sal  can  then  be 
calculated by the equation:

%V2O5 = V2O5: U3O8
              %U3O8

Additional  details  regarding  the  estimation  technique  can  be  found  in  Section  14.0  Mineral  Resource  Estimate  in  the  La  Sal 
Technical Report Summary.

The  table  below  sets  out  the  Mineral  Resources  estimates  for  the  La  Sal  Project  as  of  December  31,  2023.  These  estimates  are 
derived  from  the  La  Sal  Technical  Report  Summary,  which  estimated  the  Mineral  Resources  as  of  December  31,  2021.  Daniel 
Kapostasy,  the  Company’s  non-independent  Qualified  Person,  reviewed  and  confirmed  that  the  Mineral  Resources  estimates  set 
forth in the La Sal Technical Report Summary remained accurate as of December 31, 2023.

La Sal Mineral Resources – In Situ Uranium and Vanadium(1)(2)(3)(4)(5)

Classification

Zone
Energy Queen
Redd Block
Beaver/La Sal
La Sal Inferred 
Resources
Pandora
Total Inferred Resources

Notes:

Cut-Off 
Grade 
(%U3O8)
0.17
0.17
0.17
0.17
0.17

Tons 
(000)
147
336
118
222
823

Grade     

% eU3O8
0.25
0.29
0.23
0.24
0.26

Pounds 
eU3O8 (000)
749
1,918
552
1,061
4,281

Metallurgical 
Recovery 
(U3O8)
96%
96%
96%
96%
96%

Grade     

% V2O5
1.07
1.14
1.01
1.02
1.08

Pounds 
V2O5 
(000)
3,129
7,679
2,388
4,551
17,746

Metallurgical 
Recovery 
(V2O5)
75%
75%
75%
75%
75%

(1)  SEC  S-K  definitions  were  followed  for  all  Mineral  Resource  categories.  These  definitions  are  also  consistent  with  CIM 
(2014) definitions in NI 43-101.
(2) Mineral Resources are estimated at a cut-off grade of 0.17% U3O8.
(3)  The  cut-off  grade  is  calculated  using  a  metal  price  of  $65/lb  U3O8.  The  long-term  uranium  price  is  based  on  supply  and 
demand projections for the period 2021-2035. 
(4) No minimum mining width was used in determining Mineral Resources.
(5) Mineral Resources are based on a tonnage factory of 14.5 ft3/ton (Bulk density 0.0690 ton/ft3 or 2.21 t/m3).
(6) Mineral Resources are not Mineral Reserves and do not have demonstrated economic viability.
(7) Total may not add due to rounding.
(8) Mineral Resources are 100% attributable to EFR.

124

Present Condition of the Property and Work Completed to Date

Permanent structures existing at the Energy Queen Property include the head frame and a metal building containing an office, shop, 
showers,  warehouse,  and  the  hoist.  The  compressor  is  located  in  a  separate  building.  One  cased  vertical  ventilation  hole  was 
established into the underground working level. A small water treatment building and settling ponds are located on the San Juan 
County land in Section 5. In the past, water was treated with barium chloride to remove radium.

The Beaver and La Sal Properties are accessed through the La Sal decline with rubber-tired equipment. The principal shop, offices, 
and warehouse facilities used by all properties in the district are housed at the surface facilities of the La Sal decline. There are large 
fenced-in yards, as well as buildings for equipment and supply storage. It is used as a central receiving site for bulk and large orders, 
which are then distributed to the other Energy Fuels’ properties in the district and other parts of the region. The shop areas include 
facilities specific to electrical equipment, drills, mobile diesel equipment, and welding. Engineering, geology, safety, environmental, 
and supervisory and clerk offices are also located near the La Sal decline, in addition to staff and underground crew’s dry rooms. 
Ample stockpile space is available for easy truck load-out for transporting mineralized material to the White Mesa Mill. Electrical 
lines and substations exist and are adequately sized for any future extraction potential of the Mineral Resources. The Beaver and La 
Sal Properties are dry, so no water treatment facilities are needed.

The surface infrastructure at the Beaver shaft location consists of the hoist house, hoist, and head frame. The shaft is 690 feet deep 
to the underground haulage level and 750 feet in total depth. There are three loading pockets, two of 70-ton capacity and one of 90-
ton  capacity.  This  arrangement  allows  for  separation  of  mineralized  material  and  waste.  The  skips  dump  into  a  surface  bin  from 
which the mineralized material is trucked a short distance to a stockpile and subsequently loaded into highway trucks for haulage to 
the White Mesa Mill. The shaft conveyance system is certified for man trips, although the routine access for personnel is through the 
La Sal decline. Another building houses the compressors, which supply compressed air for the underground workings in the Beaver 
Project. Power lines and substations are in place. The Beaver Property is dry underground; therefore, no water treatment facilities 
exist.

Access into the Pandora Property is through a decline with rubber-tired equipment. Surface facilities here are less than at the other 
projects. They consist of a small office and shop buildings. A third building is used for storage of materials and equipment. Power 
lines exist to the property with enough capacity for the required load of potential future mining activities. The Pandora Property is 
dry underground.

Reclamation work on the Snowball development rock area was completed in 2021.

The Company acquired the Energy Queen Property in December 2006. The remainder of the La Sal Project was acquired by the 
Company in June 2012, through the acquisition of the Denison US Mining Division. As of December 31, 2023, the total net book 
value attributable to the La Sal Project and its associated equipment on the financial statements of the Company was $0.40 million. 

The Company’s Planned Work

The Company announced in December 2023 that it was putting the La Sal Project back into production. The Company is utilizing 
employees that were working on rehabilitation of the Whirlwind mine decline during the summer of 2023 as well as some additional 
personnel to mine the La Sal/Beaver portion of the La Sal Complex. The Company has hired a contract mining company to mine the 
Pandora portion of the La Sal Complex. At full production, the La Sal/Beaver and Pandora mines can each produce approximately 
4,000 tons of uranium/vanadium ore per month (8,000 tons total). The mines will ramp up production during early 2024 and should 
achieve full production by mid-year.

125

The Bahia Project

The following technical and scientific description of the Bahia Project is based in part on a number of historical exploration reports 
provided by previous owners to the Brazilian Mining Agency, Agência Nacional de Mineração (National Mining Agency (“ANM”). 
These reports were submitted to ANM between 10/20/2016 and 4/29/2022 and do not comply with S-K 1300 or NI 43-101. Daniel 
Kapostasy,  a  Qualified  Person  employed  by  the  Company  and  currently  serving  as  the  Company’s  Vice  President,  Technical 
Services, has reviewed these reports in detail and held various discussions with the people who collected the samples and wrote the 
reports. The Company is currently collecting the data and conducting the test work required to prepare an S-K 1300 compliant initial 
assessment  and  NI  43-101  compliant  technical  report,  including  a  Mineral  Resource  estimate  if  the  test  work  is  successful  in 
confirming a Mineral Resource, and expects to disclose its results in Q1 2025. Currently, the Bahia Project has no S-K 1300 or NI 
43-101 Mineral Resources or Mineral Reserves and is therefore considered to be an exploration stage property.

Project Description

The  Bahia  Project  is  an  exploration  stage  property  comprised  of  seventeen  individual  ANM  Process  Areas  between  the 
municipalities  of  Prado  and  Caravelas  in  the  state  of  Bahia,  Brazil,  prospective  for  heavy  mineral  sands  (“Heavy  Minerals”), 
including ilmenite, rutile, zircon and monazite. All seventeen of the Process Areas are 100% controlled by the Company’s wholly 
owned subsidiary Energy Fuels Brazil Ltda. If the Project is put into production, it will be comprised of multiple shallow open pits.

The  geographic  coordinates  for  the  Bahia  Project  are  approximately  latitude  17°17’27.6”  S  and  longitude  39°13’26.4”  W  for  the 
northern  extent,  latitude  17°44’27.6”  S  and  longitude  39°13’15.6”  W  for  the  southern  extent,  and  latitude  17°30’56.6”  S  and 
longitude 39°13’15.6” W for the approximate center of the Project.

126

Ownership

The  Project  consists  of  approximately  15,089.71  hectares  (37,300  acres  or  58.3  square  miles)  of  mineral  rights  controlled  by  the 
Company’s wholly owned subsidiary Energy Fuels Brazil Ltda. 

ANM Process Area
870.267/2016

Title Holder
Energy Fuels Brazil Ltda.

Stage
Mining Concession Request

Area (Hectares)
112.68

870.270/2016

870.271/2016

870.864/2011

870.866/2011

870.868/2011

870.869/2011

870.871/2011

870.872/2011

870.873/2011

870.874/2011

870.875/2011

870.876/2011

873.520/2011

873.723/2011

873.724/2011

871.441/2018
Total

Energy Fuels Brazil Ltda.

Exploration Authorization

Energy Fuels Brazil Ltda.

Exploration Authorization

Energy Fuels Brazil Ltda.

Mining Concession Request

Energy Fuels Brazil Ltda.

Mining Concession Request

Energy Fuels Brazil Ltda.

Mining Concession Request

Energy Fuels Brazil Ltda.

Exploration Authorization

607.07

1,142.78

769

1,136.2

1,195.32

1,778.17

Energy Fuels Brazil Ltda.

Right to Apply for Mining Concession 1,322.54

Energy Fuels Brazil Ltda.

Mining Concession Request

Energy Fuels Brazil Ltda.

Mining Concession Request

Energy Fuels Brazil Ltda.

Mining Concession Request

Energy Fuels Brazil Ltda.

Mining Concession Request

Energy Fuels Brazil Ltda.

Mining Concession Request

Energy Fuels Brazil Ltda.

Mining Concession Request

Energy Fuels Brazil Ltda.

Mining Concession Request

Energy Fuels Brazil Ltda.

Mining Concession Request

Energy Fuels Brazil Ltda.
Energy Fuels Brazil Ltda.

Mineral Research Permit

703.43

334.67

755.96

592.48

1,112.92

1,055.34

799.93

982.1

689.12
15,089.71

Mineral tenure is guaranteed by the Federal Constitution in Brazil. Mineral resources are separate from the surface owners (i.e. split 
estate),  and  the  Republic  of  Brazil  is  the  owner  of  all  mineral  resources.  The  federal  government  can  grant  mineral  rights  for 
exploration and production to Brazilian companies (or foreign companies with established Brazilian entities). Brazilian entities that 
are granted mining rights have the ownership of the product they are mining. Mineral rights can be assigned, transferred or subject 
to  encumbrance,  provided  that  legal  requirements  are  fulfilled  and  that  the  transaction  is  registered  with  and  approved  by  the 
Brazilian National Mining Agency (“ANM”).

Mineral  rights  do  not  grant  the  land  where  the  mineral  deposits  are  located  but  do  provide  the  possibility  of  creating  a  mineral 
easement that allows holders of the mineral rights the ability to explore or mine the mineral and take ownership of the product. This 
right  of  access  also  includes  neighboring  lands,  as  long  as  ANM  recognizes  that  such  lands  are  needed  for  exploration  and 
production.  The  surface  owners  are  entitled  to  a  royalty  and  damages  caused  by  exploration,  mining  and  ancillary  activities.  A 
maximum  royalty  is  set  at  half  the  federal  government  royalty.  If  the  Company  and  the  surface  owner  are  unable  to  reach  an 
agreement the matter will be settled by the local court based on criteria provided in applicable laws.

The granting of mineral rights in Brazil is performed in four steps:

1. Exploration Authorization: A 1-3 year authorization that is renewable for an additional 1-3 years. Exceptions can be made 
for additional renewals following the first authorization. The purpose of this authorization is to allow a company to explore 
for a mineral of interest. The company must then submit an exploration report to ANM. ANM will approve or deny the 
report based on the economic and technical feasibility of exploiting the mineral explored for under the report. Four of the 
mineral rights underlying the Bahia Project currently fall within this category (870.270/2016, 870.271/2016, 870.869/2011 
and 871.441/2018).

2. Right to Request a Mining Concession: Following approval of the exploration report the company has 1 year to apply for a 
mining concession. This request period can be renewed, upon request and justification, based on ANM’s criteria. If ANM 
does not agree with the justification, ANM may request the holder of the mineral right to proceed with the request for a 
mining  concession  stage.  Eventually,  ANM  can  forfeit  the  request  right  if  there  is  clear  and  strong  evidence  of 
procrastination. One of the mineral rights underlying the Bahia Project currently falls within this category (870.871/2011).

127

3. Mining Concession Request: The request for a mining concession has to include a mine development plan. Furthermore, 
the  mining  concession  will  only  be  granted  once  an  environmental  construction  permit  is  obtained.  Extensions  can  be 
granted if the environmental permitting process is delayed. The holder must use best efforts to obtain the environmental 
permit and report to ANM. Eventually, ANM can deny the request if there is clear and strong evidence of procrastination. 
Twelve of the mineral rights underlying the Bahia Project currently fall within this category (870.267/2016, 870.864/2011, 
870.866/2011,  870.868/2011,  870.872/2011,  870.873/2011,  870.874/2011,  870.785/2011,  870.876/2011,  873.520/2011, 
873.723/2011 and 873.724/2011).

4. Mining Concession: This is the approval to mine. Once this is granted the company has six months to start mining and is 

required to provide an annual report to ANM. The mining concession is valid for the life of the mine.

Under the terms of the purchase agreement with the previous owners no royalty payment is due. Under the terms of a finders’ fee 
agreement with an agent that assisted in the purchase of the Process Areas a 4% gross revenue royalty is due on Heavy Minerals 
concentrates  sold  from  the  Project.  A  2%  gross  revenue  royalty  is  due  to  the  Brazilian  government  and  a  maximum  1%  gross 
revenue royalty is due to the surface owners where production occurs.

Accessibility, Climate, Local Resources, Infrastructure and Physiography

The Bahia Project is easily accessed from the all-weather Bahia State Road 001 (BA-001), which runs north to south through and 
along  the  western  edge  of  the  project.  Additional  local  paved  roads  and  dirt  roads  for  various  ranches  provide  access  to  the 
individual  Process  Areas.  Airports  in  Porto  Seguro,  BA,  approximately  230  km  to  the  north  and  Teixeira  de  Freitas,  BA 
approximately 60 km to the west provide commercial air service. A port on the Caravelas River at the extreme southern end of the 

128

project area was last operated in 2021 but has been maintained in a standby condition and could be used for the Project. The closest 
deepwater port is the Port of Ilheus approximately 380 km to the north. There is no rail near the Project.

The  State  of  Bahia  is  approximately  564,692  square  kilometers,  of  which,  68.7%  are  considered  semi-arid.  Near  the  project,  the 
climate  is  tropical  to  subtropical  with  average  temperatures  between  21  and  25°C.  Relative  humidity  is  approximately  80%  on 
average and annual rainfall is around 1,500 – 1,750 mm.

Prado, Alcobaça and Caravelas are the nearest municipalities to the project and have populations of approximately 28,000, 22,500 
and 22,000 people respectively. The municipalities are sufficient for providing necessities for initial work at the project including 
personnel, lodging, and supplies. Larger equipment and more technical items can be purchased in the larger surrounding cities of 
Teixeira de Freitas, Itamaraju or Eunapolis. Belo Horizonte, a large city and home to a number of mining service providers, is 750 
km away.

It is anticipated that most personnel will be hired from the local area with other technical personnel being hired from other mining 
districts around Brazil.

Electric transmission and distribution lines exist throughout the project area, supplying the three major municipalities in the area. 
Groundwater in the region is relatively shallow and depending on the season or portion of the project can range from near surface to 
10 meters below the surface. It is anticipated that water for the operation will be supplied by groundwater wells.

History

Sixteen of the ANM Process Areas were acquired from G-4 Esmeralda and URBtopo who did the majority of the exploration work 
on the Project including the drilling of over 3,300 hand auger drill holes. In addition to the drilling, these groups conducted a gamma 
survey of the region. Monazite, one of the heavy minerals of interest contains both uranium and thorium and is therefore naturally 
radioactive. Surveying for this radioactivity with gamma detectors provides an indication of mineralization and therefore can focus 
drilling efforts.

The data from the drilling was used to publish exploration reports for each of the Process Areas to ANM. This is a required process 
under Brazilian law to move the Process Areas towards mine production. The reports detail in-situ mineral inventory and then apply 
economics to declare “reserves” and provide evidence to ANM that the Process Areas are able to economically produce the mineral 
being  applied  for  in  the  Process  Area.  The  reports  are  extremely  detailed  and  are  the  sources  of  the  historical  resource  provided 
below. It should be noted that the numbers given in the table are historical in nature and a Qualified Person has not done sufficient 
work to classify the estimates as a current estimate of Mineral Resources, Mineral Reserves or exploration results. The Company is 
not treating the following as a current estimate of Mineral Resources, Mineral Reserves or exploration results. Further drilling and 
data collection might not prove out the numbers in the table below.  

ANM Process 
Area

Date of 
Report

Mineralized 
Area (m2)

870.267/2016
870.270/2016

12/10/2016
3/31/2018

870.271/2016

3/20/2019

870.864/2011

10/20/2016

133,200
94,300

607,100

745,200

870.866/2011

10/20/2016

3,559,300

870.868/2011

10/20/2016

870.869/2011

870.871/2011

870.872/2011

870.873/2011
870.874/2011
870.875/2011
870.876/2011
873.520/2011
873.723/2011

11/7/2017

3/20/2017

2/20/2017

5/20/2017
6/20/2017
2/20/2017
8/15/2017
10/20/2016
10/20/2016

571,400

543,000

4,346,200

233,000

1,378,800
1,767,400
211,200
3,451,500
190,900
196,300

Mineralized 
Thickness 
(m)
8.01
7.79

4.71

2.4

2.83

2.65

4.12

4.33

2.81

4.33
3.98
2.02
5.2
2.63
3.81

Mineralized 
Volume (m3)

Specific 
Gravity

Sand 
(tonnes)

1,066,932
734,597

2,859,552

1,790,288

2.7
2.72

2.7

2.7

2,880,716
1,998,104

7,732,864

4,833,778

10,061,088

2.69

27,064,327

2.7

2.7

2.73

2.69

2.7
2.69
2.69
2.72
2.7
2.68

4,091,339

6,040,332

51,333,026

1,685,635

16,119,551
18,922,138
1,149,017
48,772,497
1,353,111
2,005,471

1,515,740

2,237,160

18,825,701

626,630

5,970,204
7,034,252
427,325
17,946,636
501,996
748,310

129

Heavy 
Mineral 
(%)(1)(2)
2.65
4.4

3.01

2.75

3.12

2.54

3.19

4.8

2.33

3.14
2.68
2.4
3.38
2.55
2.19

Heavy 
Mineral 
(tonnes)
76,339
87,917

232,708

133,041

845,430

104,071

192,687

2,466,474

39,275

506,154
507,113
27,545
1,649,943
34,503
43,998

2/10/2016

4/29/2022

873.724/2011
871.441/2018(3)
Total

Notes:

800,500

3.27

2,619,246

2.69

7,045,772

965,718
203,993,394

2.41

6.79
3.52

169,976

65,594
7,182,767

1. Heavy Minerals represent all the heavy minerals greater than specific gravity 2.9, those of primary economic interest are 

ilmenite, rutile, zircon and monazite, but also include minerals such as kyanite, garnet, staurolite and magnetite.

2. Heavy mineral percentages are reported at a cutoff grade of 2.0%, although no work was done to justify this value as an 

economic cutoff grade

3. Process Area 871.441/2018 was owned by a different party and the calculations provided in the exploration report differed 

from the calculations by G-4 Esmeralda and URBtopo. The data in the blank columns was not provided.

Limited data was collected and provided in the exploration reports on the concentrations of the valuable minerals (ilmenite, rutile, 
zircon,  monazite  and  kyanite)  at  the  Project.  The  data  contained  in  the  table  below  is  taken  from  the  same  historical  exploration 
reports listed in the table above, dated between October 20, 2016 and April 29, 2022. The values in the table were determined using 
microscopic mineral identification and point counting. Based on this limited data, the Company expects concentrations in the ranges 
below. As with the table above, it should be noted that the numbers given in the table are historical in nature, and a Qualified Person 
has not done sufficient work to classify the estimates as a current estimate of Mineral Resources, Mineral Reserves or exploration 
results.  The  Company  is  not  treating  the  following  as  a  current  estimate  of  Mineral  Resources,  Mineral  Reserves  or  exploration 
results. Further drilling and data collection might not prove out the numbers in the table below.

Mineral
Ilmenite

Rutile

Zircon

Monazite

Kyanite

Low Concentration (%) High Concentration (%)
78.4

48.1

1.5

0.76

0.66

3.49

Permitting

16.3

20.2

13.1

37

Limited  permitting  work  has  been  conducted  at  the  Project.  The  Company  has  engaged  a  local  consulting  firm  to  provide  an 
overview  of  the  permitting  process,  identify  any  significant  issues  and  initiate  a  stakeholder  engagement  program.  Permitting  is 
expected to commence in 2024. As more information is available and the permitting process begins, additional information will be 
provided.

Geologic Setting, Mineralization and Deposit

The Barreiras Group is a unit that occurs along the coast of Brazil, from the State of Amapá to Rio de Janeiro. It is an alluvial fan 
deposit composed of clay, sand and gravel and was by fluvial systems. Overlying the Barreiras Group are the mineral bearing beach/
dune sand deposits of Holocene age. These mineralized beach/dune deposits are referred to below as placers. 

Most  of  the  Heavy  Minerals  were  brought  down  from  the  higher  interior  of  Brazil  by  rivers  and  reworked  along  the  Brazilian 
coastline by wave action and currents. This primarily occurred during the last 6,000 years during a sea level decline of about 3 to 4 
meters. This event and the deposition of material from the various rivers gave rise to extensive plains of coastal dunes. One of these 
plains, Belmonte, is located in the southern part of the state of Bahia, which is part of the Jequitinhonha River delta. Another plain 
of considerable size stretches from the Prado region to Caravelas, where the clear strands of beachfront can be seen and makes up 
the majority of the Project area. All coastal dunes are reworked by the wind, most prominently in the frontal dunes. The study of the 
geometry, orientation and truncation patterns of coastal ridges can provide a great deal of information about the evolution of these 
plains, sediment dispersion patterns and past episodes of severe erosion that affected the coastline. 

Placer deposits form from the concentration of a diverse group of valuable, resistant, detrital minerals resulting from the erosion of 
its  source  rock.  These  resistant  minerals  include  gold,  cassiterite,  zircon,  rutile,  ilmenite,  monazite,  magnetite,  platinum  group 
minerals,  chromite  and  various  gemstones.  It  is  important  to  emphasize  that  the  source  of  the  placer  minerals  might  not  be  of 
economic value, but the erosion and concentration of the mineral can make the placer economically viable. In the case of the Bahia 
Project, detrital minerals concentrated in the placers are referred to as heavy minerals, due to their high specific gravity (greater than 
2.9  g/cm3),  higher  than  quartz  (2.65  g/cm3).  Typically,  the  heaviest  minerals  such  as  gold  and  platinum  are  not  transported  long 

130

                                                
distances  and  are  found  close  to  the  source  rocks.  Lighter  heavy  minerals  such  as  ilmenite,  rutile,  monazite  and  zircon  can  be 
transported longer distances and typically end up in coastal environments.

In the region from Prado to Caravelas (passing through Alcobaca), the placers are classified as placer beach disseminated. This type 
of deposit forms by waves and currents concentrating the heavy minerals and typically contains the lighter heavy minerals such as 
ilmenite, rutile, zirconite, monazite, garnet and magnetite.

Placer deposits, similar to those found at the Project, can be found globally in places such as South Africa, Australia, Madagascar, 
India, Thailand, and the Southeastern United States. In Brazil, similar placers were mined in São Francisco de Itabapoana, Rio de 
Janeiro, and Cumuruxatiba (located 30 km to north of Prado), in Bahia.

Data Verification

The data collected and provided in this disclosure is derived entirely from the exploration reports for each of the seventeen ANM 
Process  Areas.  Daniel  Kapostasy,  Vice  President,  Technical  Services  and  Qualified  Person  for  the  Company  has  reviewed  these 
reports  in  detail  and  discussed  the  methods  used  with  the  project  geologist  in  charge  of  field  and  laboratory  activities  for  the 
previous owners. This person is also currently an employee of Energy Fuels Brazil Ltda. Heavy mineral concentrations were derived 
for every meter drilled using heavy liquid separations, a standard method of heavy mineral determination. 

To determine the concentration of the various Heavy Minerals in a sample, the heavy fraction is separated from the silica sand by 
using  heavy  liquid  separation.  The  heavy  fraction  is  then  mounted  in  epoxy  or  dispersed  on  slide  glass  and  viewed  under  a 
microscope. A geologist then can identify the various minerals and determine the concentration of each mineral through a process 
called  point  counting,  whereby  the  geologist  identifies  each  sand  grain  individually,  tallies  the  number  of  each  mineral  and  then 
divides by the total.

Verification of the Heavy Minerals concentration was started by the Company in September 2022, when it hired a contract driller to 
collect samples using a sonic rig. While no laboratory analyses have been received to date, visual estimation of the Heavy Minerals 
quantity indicates that the historical values seen at the various Process Areas are valid. The Company expects to start receiving data 
from its confirmation drilling program in early 2024. 

Present Condition of the Property and Work Completed to Date

The  Project  is  a  greenfield  project  in  that  no  mining  has  taken  place  on  the  ANM  Process  Areas.  Most  of  the  surface  use  in  the 
region  is  for  farming  and  ranching.  As  mentioned  previously,  the  former  owners  carried  out  an  extensive  auger  drill  exploration 
program completing over 3,300 holes. Between September 20, 2022 and February 14, 2023, the Company drilled 2,266 meters of 
sonic drill core on various ANM Process Areas to confirm the prior drilling and collect samples and data for use in an S-K 1300/NI 
43-101 compliant technical report for publication in Q1 2025.  

As of December 31, 2023, the net book value of the Bahia Project was $29.13 million.

The Company’s Planned Work

The  Company  plans  to  start  a  Phase  II  drilling  program  in  Q1  2024,  utilizing  its  own  sonic  drill  rig.  The  purchase  of  a  drill  rig 
provides the Company with flexibility in drilling out this large project. Additional work planned in 2024 includes continuation of 
permitting  and  community  engagement  activities,  continuation  of  metallurgical  test  work  and  engineering  design.  The  Company 
plans to use this information to prepare an S-K 1300 compliant initial assessment and NI 43-101 compliant technical report in Q1 
2025, including an estimate of Mineral Resources if Mineral Resources are confirmed.

131

Non-Material Mineral Properties

This section describes certain non-material mineral properties held by the Company. As these properties are not considered material 
to the Company’s business, the Company may choose to pursue or to take into consideration the potential sale, joint venture, trade 
or  other  transaction  involving  one  or  more  of  these  projects.  None  of  the  Company’s  non-material  properties  have  any  Mineral 
Resources or Mineral Reserves.

The Company holds the following non-material mineral properties:

Other ISR Projects

The Company’s Properties located in the Powder River Basin, Wyoming are as follows:

The Company’s properties in the Powder River Basin of Wyoming, but outside of the Nichols Ranch Project, include 4,359 acres 
owned  100%  by  the  Company  through  its  wholly  owned  subsidiary,  Uranerz.  These  properties,  located  at  Arkose,  include  the: 
Verna Ann, Niles Ranch, Arvina, Streeter, Table Mountain, Heldt Draw, Drew, Collins Draw and Jack properties. The Company, 
through Uranerz, also holds an 81% interest in the Arkose Joint Venture, which holds 40,852 net acres in the Powder River Basin. 

In September 2016, Uranerz elected to forfeit 298 unpatented lode mining claims covering approximately 6,157 acres from its North 
Willow Creek (50 claims), Hat (61 claims), Divide (36 claims), North Nichols (107 Claims) and East Nichols (44 claims) properties, 
which constitutes all the claims in those projects.

132

In  general,  these  ISR  projects  are  located  in  basins  containing  sandstones  of  Tertiary  age  with  known  uranium  mineralization. 
Limited exploration was conducted by Uranerz on each project.

Arkose Joint Venture, Powder River Basin, Wyoming:

The Company, through its wholly owned subsidiary Uranerz, holds an undivided 81% interest in the Arkose Joint Venture, which 
holds an additional 40,852 net acres in the Powder River Basin. Uranerz completed the acquisition of its interest in the Arkose Joint 
Venture  mineral  properties  on  January  15,  2008.  This  acquisition  was  completed  pursuant  to  a  purchase  and  sale  agreement 
previously  announced  on  September  19,  2007  between  Uranerz,  NAMMCO,  Steven  C.  Kirkwood,  Robert  W.  Kirkwood  and 
Stephen L. Payne (collectively, the “NAMMCO Sellers”).

In  connection  with  the  acquisition  of  its  interest  in  the  Arkose  Joint  Venture,  Uranerz  entered  into  a  venture  agreement  dated 
January 15, 2008 (the “Venture Agreement”) with United Nuclear, LLC (“United Nuclear”), a limited liability company wholly 
owned by the NAMMCO Sellers and their designee under the purchase and sale agreement. Under the Venture Agreement, United 
Nuclear  retained  its  nineteen  percent  (19%)  working  interest  in  the  Arkose  Joint  Venture,  and  Uranerz  assumed  operations  and 
management  responsibilities  of  the  Venture.  Uranerz  and  United  Nuclear  agreed  to  contribute  funds  to  programs  and  budgets 
approved under the Arkose Mining Venture in accordance with their respective interests in the Venture.

The Arkose Mining Venture includes the following property units on which Uranerz has conducted exploration:

North Jane*
South Doughstick
Cedar Canyon
East Buck
South Collins Draw
Sand Rock
Little Butte
Beecher Draw

•
•
•
•
•
•
•
•
• Monument
Stage
•

*Now included in the Nichols Ranch Project as part of the Jane Dough Property.

In September 2016, the Arkose Joint Venture elected to forfeit 190 unpatented lode mining claims covering 3,925 acres from its 
Kermit property and 144 claims covering 2,975 acres from its Lone Bull property, which constitute all of the Arkose claims in those 
projects.  In  addition,  four  mineral  leases  comprising  592  acres  in  the  East  Buck  project  were  allowed  to  expire  in  2016  without 
attempting to negotiate extensions to those leases. In 2017, mineral leases in the Monument, Cedar Canyon, Sand Rock, East Buck 
and  House  Creek  projects  were  allowed  to  expire;  however,  the  expiry  of  those  property  interests  did  not  materially  affect  the 
Company’s ability to continue exploration and extraction activities on its properties.

133

Other Conventional Projects

Arizona Strip

The Pinenut Project has been reclaimed except for a two-acre disturbance associated with a monitor well. Mineral extraction at the 
Company’s  Arizona  1  Project  commenced  in  December  2009  and  continued  until  the  project  was  placed  on  standby  in  February 
2014 due to the depletion of the readily available resources. The Wate Project and EZ Project are in the evaluation stage. Permitting 
at the Wate and EZ Projects are currently on hold.  

134

Colorado Plateau

The Whirlwind Project comprises 126 unpatented lode mining claims covered by three Mineral Leases and a Utah State Mineral 
Lease of 320 acres for a total acreage of about 2,800 acres. The property size has been reduced since the acquisition. The retained 
property continues to cover the known mineralized areas. The Whirlwind Project straddles the Utah/Colorado state line 4.5 miles 
southwest of Gateway, Colorado. Exploration drill projects were conducted in 2007, 2008, 2009, 2010, 2011 and 2012. In 2022, the 
Company initiated work at Whirlwind to rehabilitate the existing decline. Work progressed until December 2022, when it was put 
on hold due to inclement weather. The Company finished rehabilitation work on the decline in 2023.

135

Internal Controls Relating to Exploration, Mineral Resource and Mineral Reserve Estimation Efforts 

The  primary  exploration  tool  used  for  uranium  projects  is  a  downhole  gamma  probe.  The  gamma  probe  provides  an  equivalent 
%U3O8 grade by measuring decay products of U-238. The Company regularly calibrates its gamma probe during drilling programs 
at  one  of  a  number  of  DOE  test-pits.  This  is  standard  procedure  in  the  uranium  industry.  To  verify  gamma  probe  readings,  the 
Company will either collect core and send that material to a 3rd party lab for assay or use a prompt fission neutron (“PFN”) probe 
that  directly  measures  the  downhole  uranium  concentrations.  Similar  to  the  gamma  probe  the  PFN  probe,  when  in  operation,  is 
regularly calibrated at the DOE test-pit.  

To  verify  uranium  grades  or  to  assay  for  other  metals,  such  as,  vanadium  and  copper,  core  is  collected  during  drilling,  logged, 
sampled and sent out for assay either at the Company’s Mill or at 3rd party labs. Assaying of the materials includes the submission of 
standards and blanks and assay verification by other laboratories.

The primary risk associated with a Mineral Resource or Mineral Reserve estimate on a uranium project is disequilibrium. As stated 
above, a gamma probe measures the decay products of U-238. It is possible that, under the correct conditions, the uranium could 
have produced decay products but, later, the uranium is dissolved by oxidized groundwater and moved out of the system (negative 
disequilibrium) so that the measured value is overestimating the amount of uranium present. The opposite can also be true, uranium 
could  have  moved  into  the  system  and  not  decayed  long  enough  to  produce  the  decay  products  to  calculate  the  uranium  present 
(positive disequilibrium). Both situations can be quantified by either collecting core and assaying for uranium directly or measuring 
uranium in the ground with a PFN tool.

Exploration  for  Heavy  Minerals  employs  different  procedures  than  those  noted  for  uranium  exploration  and  quantification.  The 
Company utilizes a sonic drill rig for Heavy Minerals exploration as this type of rig is able to collect relatively undisturbed cores of 
loose  sediment.  Following  retrieval  of  the  core  (typically  in  2  meter  intervals),  the  core  is  logged  by  the  onsite  geologist  and  a 
sample of each meter is collected and panned (similar to gold panning) to get a visual estimate of Heavy Minerals concentration. 
The samples are then taken back to the field office where they are split, dried and analyzed for grain size, utilizing a standard set of 
wire  mesh  sieves.  A  second  fraction  of  the  split  is  then  sent  to  a  3rd  party  analytical  lab  for  heavy  liquid  separation,  elemental 
analysis and mineralogical characterization (XRD or QEMSCAN). Elements of interest include Ti, Fe, Zr, the REEs, uranium and 
thorium. Standards and blanks will be submitted to the lab as part of the quality assurance/quality control program. Samples will 
also be sent to other third-party labs to verify the analyses by the primary lab.

136

ITEM 3. LEGAL PROCEEDINGS

Other  than  routine  litigation  incidental  to  our  business,  or  as  described  below,  the  Company  is  not  currently  a  party  to  any 
material pending legal proceedings that management believes would be likely to have a material adverse effect on our financial 
position, results of operations or cash flows.

White Mesa Mill

In 2011, the Ute Mountain Ute Tribe filed an administrative appeal of the State of Utah Division of Air Quality’s (“UDAQ”) 
decision to approve a Modification to the Air Quality Approval Order at the Mill. Then, in 2013, the Ute Mountain Ute Tribe 
filed a Petition to Intervene and Request for Agency Action challenging the Corrective Action Plan approved by UDEQ relating 
to nitrate contamination in the shallow aquifer at the Mill. In August 2014, the Ute Mountain Ute Tribe filed an administrative 
appeal to the Utah Division of Radiation Control’s (“DRC”) Radioactive Materials License Amendment 7 approval regarding 
alternate  feed  material  from  Dawn  Mining.  The  challenges  remain  open  at  this  time  and  may  involve  the  appointment  of  an 
administrative law judge (“ALJ”) to hear the matters. The Company does not consider these actions to have any merit. If the 
petitions  are  successful,  the  likely  outcome  would  be  a  requirement  to  modify  or  replace  the  existing  Air  Quality  Approval 
Order,  Corrective  Action  Plan  or  license  amendment,  as  applicable.  At  this  time,  the  Company  does  not  believe  any  such 
modifications or replacements would materially affect its financial position, results of operations or cash flows. However, the 
scope and costs of remediation under a revised or replaced Air Quality Approval Order, Corrective Action Plan and/or license 
amendment have not yet been determined and could be significant.

The UDEQ renewed in January 2018, then reissued with minor corrections in February 2018, the Mill License for another ten 
years and the GWDP for another five years, after which further applications for renewal of the Mill License and GWDP are 
required to be submitted. During the review period for each application for renewal, the Mill can continue to operate under its 
existing Mill License and GWDP until such time as the renewed Mill License or GWDP is issued. Most recently, on July 15, 
2022, the routine GWDP renewal application was submitted to UDEQ, which remains under consideration at this time.

In  2018,  the  Grand  Canyon  Trust,  Ute  Mountain  Ute  Tribe  and  Uranium  Watch  (collectively,  the  “Mill  Plaintiffs”)  served 
Petitions for Review challenging UDEQ’s renewal of the Mill License and GWDP and Requests for Appointment of an ALJ, 
which they later agreed to suspend pursuant to a Stipulation and Agreement with UDEQ, effective June 4, 2018. The Company 
and the Mill Plaintiffs held multiple discussions over the course of 2018 and 2019 in an effort to settle the dispute outside of 
any judicial proceeding. In February 2019, the Mill Plaintiffs submitted to the Company their proposal for reaching a settlement 
agreement.  The  proposal  remains  under  consideration  by  the  Company.  The  Company  does  not  consider  these  challenges  to 
have any merit and, if a settlement cannot be reached, the Company intends to participate with UDEQ in defending against the 
challenges.  If  the  challenges  are  successful,  the  likely  outcome  would  be  a  requirement  to  modify  the  renewed  Mill  License 
and/or  GWDP.  At  this  time,  the  Company  does  not  believe  that  any  such  modification  would  materially  affect  its  financial 
position, results of operations or cash flows.

On August 26, 2021, the Ute Mountain Ute Tribe filed a Petition to Intervene and Petition for Review challenging the UDEQ’s 
approval  of  Amendment  No.  10  to  the  Mill  License,  which  expanded  the  list  of  Alternate  Feed  Materials  that  the  Mill  is 
authorized to accept and process for its source material content. Then, on November 18, 2021, the Tribe filed its Request for 
Appointment of an ALJ, followed shortly thereafter by a stay on the request in accordance with a Stipulation and Agreement 
between the Tribe, UDEQ and Company. Thereafter, discussions between the Company and the Tribe commenced in an effort 
to resolve the dispute and other outstanding matters without formal adjudication. However, the Company does not consider this 
action to have any merit. If resolution is not achieved, the stay is lifted and the petition is successful before an ALJ, the likely 
outcome would be a requirement to modify or revoke the Mill License amendment. At this time, the Company does not believe 
any such modification or revocation would materially affect its financial position, results of operations or cash flows.

The mine safety disclosures required by section 1503(a) of the Dodd-Frank Wall Street Reform and Consumer Protection Act 
and Item 104 of Regulation S-K are included in Exhibit 95.1 of this Annual Report.

ITEM 4. MINE SAFETY DISCLOSURE

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ITEM 5. MARKET FOR THE REGISTRANT’S COMMON EQUITY, RELATED STOCKHOLDER

MATTERS AND ISSUER PURCHASES OF EQUITY SECURITIES

PART II

Market Information

Our  Common  Shares  are  listed  for  trading  on  the  NYSE  American  under  the  symbol  “UUUU”  and  on  the  Toronto  Stock 
Exchange under the symbol “EFR.” As of February 21, 2024, the closing bid quotation for our Common Shares was $6.25 per 
share as quoted by the NYSE American and was $8.46 per share as quoted by the TSX. As of February 21, 2024, Energy Fuels 
had 163,570,079 Common Shares issued and outstanding, held by an estimated 115,000 or more shareholders. 

Dividend Policy

We  have  never  declared  cash  dividends  on  our  Common  Shares.  We  anticipate  that  we  will  retain  any  earnings  to  support 
operations  and  to  finance  the  growth  of  our  business.  Therefore,  we  do  not  expect  to  pay  cash  dividends  in  the  foreseeable 
future.  Any  further  determination  to  pay  cash  dividends  will  be  at  the  discretion  of  our  Board  of  Directors  and  will  be 
dependent  on  the  financial  condition,  operating  results,  capital  requirements,  and  other  factors  that  our  Board  of  Directors 
deems relevant.

Recent Sales of Unregistered Securities

None.

Use of Proceeds

None.

Repurchase of Equity Securities

During 2023, neither we nor any of our affiliates repurchased any of our Common Shares registered under Section 12 of the 
Exchange Act. 

Equity Compensation Plan Information

The following table provides information as of December 31, 2023, concerning stock options, restricted stock units (“RSUs”) 
and  stock  appreciation  rights  (“SARs”)  outstanding  pursuant  to  our  2021  Amended  and  Restated  Omnibus  Equity  Incentive 
Compensation Plan (the “Compensation Plan”), which has been approved by the Company’s shareholders. The Company does 
not have an equity compensation plan that has not been approved by shareholders. The table also includes stock options that the 
Company assumed as part of the Uranerz acquisition. 

Number of Common
Shares to be issued
upon exercise
of outstanding
options, warrants
and rights(1)

3,004,835(2)(4)(5)(6)

Nil

3,004,835

Weighted average
exercise price
of outstanding
options, warrants
and rights (US$)(1)(3)

Number of Common
Shares remaining available
for future issuance(1)

$4.89(7)

Nil

$4.89

13,261,080

Nil

13,261,080

Plan Category
Equity compensation plans 
approved by security holders
Equity compensation plans not 
approved by security holders

Total

(1)  The  number  of  Common  Shares,  and  the  exercise  price  thereof,  has  been  adjusted  to  take  into  account  the  Consolidation.  There  are  no  warrants 

outstanding at this time.

(2)   Includes 523,469 stock options and 641,839 RSUs. With a few exceptions, each RSU vests annually at approximately the following intervals: as to 
50% on January 27 approximately one year after the date of grant, as to another 25% on January 27 approximately two years after the date of 
grant and as to the remaining 25% on January 27 approximately three years after the date of grant. Upon vesting, each RSU entitles the holder to 
receive one Common Share without any additional payment.

(3)  641,839 RSUs have been excluded from the weighted average exercise price because there is no exercise price.
(4)   Includes 816,854 SARs granted in 2019 and earned in 2018 (excluding any SARs granted but since forfeited). Each SAR granted entitles the 
holder,  on  exercise,  to  a  payment  in  cash  or  shares  (at  the  election  of  the  Company)  equal  to  the  difference  between  the  market  price  of  the 
Common  Shares  at  the  time  of  exercise  and  $2.92  (the  market  price  at  the  time  of  grant)  over  a  five-year  period,  but  vest  only  upon  the 

138

(5) 

(6) 

achievement of the following performance goals: as to one-third of the SARs granted upon the 90-calendar-day VWAP of the Common Shares 
on  the  NYSE  American  equaling  or  exceeding  $5.00  for  any  continuous  90-calendar-day  period;  as  to  an  additional  one-third  of  the  SARs 
granted, upon the 90-calendar-day VWAP of the Common Shares on the NYSE American equaling or exceeding $7.00 for any continuous 90-
calendar-day period; and as to the final one-third of the SARs granted, upon the 90-calendar-day VWAP of the Common Shares on the NYSE 
American equaling or exceeding $10.00 for any continuous 90-calendar-day period. Further, notwithstanding the foregoing vesting schedule, no 
SARs were able to be exercised by the holder for an initial period of one year from the date of grant; the date first exercisable being January 22, 
2020.  As  of  December  31,  2023,  the  first  two  performance  goals  had  been  achieved  with  the  underlying  SARs  now  vested.  These  SARs  are 
currently in the last year of their five-year term. 
Includes 788,253 SARs granted in 2022 and earned in 2021 (excluding any SARs granted but since forfeited). Each SAR granted entitles the 
holder,  on  exercise,  to  a  payment  in  cash  or  shares  (at  the  election  of  the  Company)  equal  to  the  difference  between  the  market  price  of  the 
Common  Shares  at  the  time  of  exercise  and  $6.47  (the  market  price  at  the  time  of  grant)  over  a  five-year  period,  but  vest  only  upon  the 
achievement of the following performance goals: as to one-third of the SARs granted upon the 90-calendar-day VWAP of the Common Shares 
on  the  NYSE  American  equaling  or  exceeding  $12.00  for  any  continuous  90-calendar-day  period;  as  to  an  additional  one-third  of  the  SARs 
granted, upon the 90-calendar-day VWAP of the Common Shares on the NYSE American equaling or exceeding $14.00 for any continuous 90-
calendar-day period; and as to the final one-third of the SARs granted, upon the 90-calendar-day VWAP of the Common Shares on the NYSE 
American equaling or exceeding $16.00 for any continuous 90-calendar-day period. Further, notwithstanding the foregoing vesting schedule, no 
SARs were able to be exercised by the holder for an initial period of one year from the date of grant; the date first exercisable being January 25, 
2023. As of December 31, 2023, none of the performance goals had been achieved and none of the underlying SARs have vested.
Includes 234,421 SARs granted in 2023 and earned in 2022 (excluding any SARs granted but since forfeited). Each SAR granted entitles the 
holder,  on  exercise,  to  a  payment  in  cash  or  shares  (at  the  election  of  the  Company)  equal  to  the  difference  between  the  market  price  of  the 
Common  Shares  at  the  time  of  exercise  and  $7.36  (the  market  price  at  the  time  of  grant)  over  a  five-year  period,  but  vest  only  upon  the 
achievement of the following performance goals: as to one-third of the SARs granted upon the 90-calendar-day VWAP of the Common Shares 
on  the  NYSE  American  equaling  or  exceeding  $12.00  for  any  continuous  90-calendar-day  period;  as  to  an  additional  one-third  of  the  SARs 
granted, upon the 90-calendar-day VWAP of the Common Shares on the NYSE American equaling or exceeding $14.00 for any continuous 90-
calendar-day period; and as to the final one-third of the SARs granted, upon the 90-calendar-day VWAP of the Common Shares on the NYSE 
American equaling or exceeding $16.00 for any continuous 90-calendar-day period. Further, notwithstanding the foregoing vesting schedule, no 
SARs were able to be exercised by the holder for an initial period of one year from the date of grant; the date first exercisable being January 25, 
2024. As of December 31, 2023, none of the performance goals had been achieved and none of the underlying SARs have vested.

(7)  Represents  a  weighted  average  exercise  price  of:  (i)  $4.90,  which  is  the  weighted  average  exercise  price  of  stock  options  and  SARs  pursuant  to  the 

Omnibus Equity Incentive Plan, and (ii) $4.48, which is the weighted average exercise price of the Uranerz Replacement Stock Options. 

Energy Fuels Compensation Plan

The Compensation Plan was approved by the Board of Directors on each of January 28, 2015, March 29, 2018 and March 18, 
2021 and by shareholders on each of June 18, 2015, May 30, 2018 and May 26, 2021 (amended, restated and approved every 
three years). The Compensation Plan supersedes and replaces the Energy Fuels Stock Option Plan, which was the Company’s 
prior  equity  incentive  program.  All  stock  options  previously  granted  pursuant  to  the  Energy  Fuels  Stock  Option  Plan  which 
remain outstanding are incorporated into the Compensation Plan. Employees, directors, and consultants of the Company and its 
affiliates are eligible to participate in the Compensation Plan. The Board of Directors, or a Committee authorized by the Board 
of Directors (the “Committee”), administers the Compensation Plan. The Committee may grant awards for non-qualified stock 
options,  incentive  stock  options,  stock  appreciation  rights,  restricted  stock,  deferred  share  units,  restricted  stock  units, 
performance shares, performance units, and share-based awards to eligible participants. The ability to grant a broad range of 
equity  incentive  awards  is  consistent  with  the  practices  of  similar  public  companies.  Pursuant  to  the  rules  of  the  TSX,  the 
Compensation Plan must be renewed by approval of Energy Fuels shareholders every three years.

Uranerz Options

On June 18, 2015, in connection with the acquisition of Uranerz, Energy Fuels issued 2,048,000 stock options of Energy Fuels, 
by assuming the then-existing stock options granted pursuant to the Uranerz 2005 Stock Option Plan, as amended on June 10, 
2009 (the “2005 Stock Option Plan”). These stock options are now exercisable for Common Shares, subject to the exchange 
ratio  set  out  in  the  Merger  Agreement  that  governed  the  acquisition  of  Uranerz.  No  further  stock  options  will  be  granted 
pursuant to the 2005 Stock Option Plan. The stock options have varying expiry dates with the last stock options expiring in June 
2025.

Stock Performance Graph(1)

The  performance  graph  below  shows  Energy  Fuels’  cumulative  total  5-year  return  based  on  an  initial  investment  of  $100  in 
Energy Fuels Common Shares beginning on December 31, 2018, as compared with the Russell 2000 Index, NYSE American 
Natural Resources Index, NYSE Composite, NASDAQ Composite, and a peer group consisting of Cameco, NexGen Energy, 
Fission  Uranium,  Uranium  Energy  Corp,  Ur-Energy,  Paladin  Energy,  GoviEx  Uranium,  Denison  Mines,  Deep  Yellow  Ltd., 
Peninsula Energy and Boss Resources. The chart shows yearly performance marks over a five-year period. This performance 
chart  assumes:  (1)  $100  was  invested  on  December  31,  2018  in  Energy  Fuels  Common  Shares  along  with  the  Russell  2000 
Index,  NYSE  American  Natural  Resources  Index,  NYSE  Composite,  NASDAQ  Composite,  and  the  peer  group’s  common 
stock; and (2) all dividends are reinvested. Dates on the chart represent the last trading day of the indicated fiscal year.

139

Notes:

(1)  This  peer  group  represents  a  broad  range  of  companies  operating  within  the  U.S.  uranium  industry  generally  and  is 
distinct  from  the  more  select  peer  group  used  for  the  Company’s  executive  officer  compensation  decisions  as  reported 
annually in the Company’s proxy circular. 

Exchange Controls 

There are no governmental laws, decrees or regulations in Canada that restrict the export or import of capital, including foreign 
exchange controls, or that affect the remittance of dividends, interest or other payments to nonresident holders of the securities 
of Energy Fuels, other than Canadian withholding tax. See “Certain Canadian Federal Income Tax Considerations for Non-
Residents of Canada,” below.

Certain Canadian Federal Income Tax Considerations for Non-Residents of Canada

The  following  is,  as  of  the  date  hereof,  a  summary  of  the  principal  Canadian  federal  income  tax  considerations  generally 
applicable  under  the  Income  Tax  Act  (Canada)  and  the  regulations  promulgated  thereunder  (the  “Tax  Act”)  to  a  holder  who 
acquires, as beneficial owner, our Common Shares, and who, for purposes of the Tax Act and at all relevant times: (i) holds the 
Common Shares as capital property; (ii) deals at arm’s length with, and is not affiliated with, us; (iii) is not, has not been, and 
will not be or deemed to be, resident in Canada; (iv) is not a “foreign affiliate” (as defined in the Tax Act) of a person resident 
in  Canada;  (v)  has  not  entered  into  a  “dividend  rental  arrangement”,  a  “derivative  forward  agreement”  or  a  “synthetic 
disposition arrangement” (as such terms are defined in the Tax Act) in respect of our Common Shares; and (vi) does not use or 
hold  and  will  not  be  deemed  to  use  or  hold,  our  Common  Shares  in  a  business  carried  on  in  Canada  (a  “Non-Resident 
Holder”).  Generally,  our  Common  Shares  will  be  considered  to  be  capital  property  to  a  Non-Resident  Holder  provided  the 
Non-Resident  Holder  does  not  hold  our  Common  Shares  in  the  course  of  carrying  on  a  business  of  trading  or  dealing  in 
securities and has not acquired them in one or more transactions considered to be an adventure or concern in the nature of trade. 

140

Special rules, which are not discussed in this summary, may apply to a Non-Resident Holder that is an insurer that carries on an 
insurance business in Canada and elsewhere or is an authorized foreign bank (as defined in the Tax Act). Such Non-Resident 
Holders should seek advice from their own tax advisors.

This summary is based upon the provisions of the Tax Act in force as of the date hereof, all specific proposals to amend the Tax 
Act  that  have  been  publicly  and  officially  announced  by  or  on  behalf  of  the  Minister  of  Finance  (Canada)  prior  to  the  date 
hereof (the “Proposed Amendments”) and management’s understanding of the current administrative policies and assessing 
practices  of  the  Canada  Revenue  Agency  (the  “CRA”)  published  in  writing  by  it  prior  to  the  date  hereof.  This  summary 
assumes  the  Proposed  Amendments  will  be  enacted  in  the  form  proposed.  However,  no  assurance  can  be  given  that  the 
Proposed Amendments will be enacted in their current form, or at all. This summary is not exhaustive of all possible Canadian 
federal  income  tax  considerations  and,  except  for  the  Proposed  Amendments,  does  not  take  into  account  or  anticipate  any 
changes in the law or any changes in the CRA’s administrative policies or practices, whether by legislative, governmental, or 
judicial action or decision, nor does it take into account or anticipate any other federal or any provincial, territorial or foreign 
tax considerations, which may differ significantly from those discussed herein.

Non-Resident Holders should consult their own tax advisors with respect to an investment in our Common Shares. This 
summary is of a general nature only and is not intended to be, nor should it be construed to be, legal or tax advice to any 
prospective  purchaser  or  holder  of  our  Common  Shares,  and  no  representations  with  respect  to  the  income  tax 
consequences to any prospective purchaser or holder are made. Consequently, prospective purchasers or holders of our 
Common Shares should consult their own tax advisors with respect to their particular circumstances.

Currency Conversion

Generally, for purposes of the Tax Act, all amounts relating to the acquisition, holding, or disposition of our Common Shares, 
including  dividends,  adjusted  cost  base  and  proceeds  of  disposition,  must  be  converted  into  Canadian  dollars  based  on  the 
exchange rates as determined in accordance with the Tax Act. The amounts subject to withholding tax and any capital gains or 
capital losses realized by a Non-Resident Holder may be affected by fluctuations in the value of the Canadian dollar relative to 
other currencies.

Disposition of Common Shares

A  Non-Resident  Holder  will  not  generally  be  subject  to  tax  under  the  Tax  Act  on  any  capital  gain  arising  on  an  actual  or 
deemed disposition of our Common Shares, unless the Common Shares constitute “taxable Canadian property” (as defined in 
the Tax Act) of the Non-Resident Holder at the time of disposition and the Non-Resident Holder is not entitled to relief under 
an applicable income tax treaty or convention.

Provided our Common Shares are listed on a “designated stock exchange,” as defined in the Tax Act (which currently includes 
the TSX and NYSE American) at the time of disposition, the Common Shares will generally not constitute taxable Canadian 
property  of  a  Non-Resident  Holder  at  that  time,  unless  at  any  time  during  the  60-month  period  immediately  preceding  the 
disposition the following two conditions are satisfied concurrently: (i) (a) the Non-Resident Holder; (b) persons with whom the 
Non-Resident Holder did not deal at arm’s length; (c) partnerships in which the Non-Resident Holder or a person described in 
(b) holds a membership interest directly or indirectly through one or more partnerships; or (d) any combination of the persons 
and partnerships described in (a) through (c), owned 25% or more of the issued shares of any class or series of our shares; and 
(ii) more than 50% of the fair market value of our shares was derived directly or indirectly from one or any combination of: real 
or immovable property situated in Canada, “Canadian resource properties,” “timber resource properties” (each as defined in the 
Tax Act), and options in respect of, or interests in or for civil law rights in, such properties, whether or not such property exists. 
Notwithstanding  the  foregoing,  in  certain  circumstances  set  out  in  the  Tax  Act,  the  Common  Shares  could  be  deemed  to  be 
taxable Canadian property. Even if the Common Shares are taxable Canadian property to a Non-Resident Holder, such Non-
Resident  Holder  may  be  exempt  from  tax  under  the  Tax  Act  on  the  disposition  of  such  Common  Shares  by  virtue  of  an 
applicable income tax treaty or convention. A Non-Resident Holder contemplating a disposition of Common Shares that 
may constitute taxable Canadian property should consult a tax advisor prior to such disposition.

Receipt of Dividends 

Dividends received or deemed to be received by a Non-Resident Holder on our Common Shares will be subject to Canadian 
withholding tax under the Tax Act. The general rate of withholding tax is 25%, although such rate may be reduced under the 
provisions of an applicable income tax convention between Canada and the Non-Resident Holder’s country of residence. For 
example, under the Canada-United States Income Tax Convention (1980) as amended (the “Canada-U.S. Treaty”), the rate is 
generally reduced to 15% (or to 5% for a company that holds at least 10% of the voting stock of the corporation paying the 

141

dividend)  where  the  Non-Resident  Holder  is  a  resident  of  the  U.S.  for  the  purposes  of,  and  is  entitled  to  the  benefits  of,  the 
Canada-U.S.  Treaty.  The  Multilateral  Convention  to  Implement  Tax  Treaty  Related  Measures  to  Prevent  Base  Erosion  and 
Profit Shifting of which Canada is a signatory, affects many of Canada’s bilateral tax treaties (but not the Canada-U.S. Treaty), 
including  the  ability  to  claim  benefits  thereunder.  Non-Resident  Holders  should  consult  their  own  tax  advisors  to  determine 
their entitlement to relief under an applicable income tax treaty or convention.

ITEM 6. [RESERVED]

142

ITEM 7. MANAGEMENT’S DISCUSSION AND ANALYSIS OF FINANCIAL CONDITION AND RESULTS OF 
OPERATIONS

The  following  discussion  and  analysis  should  be  read  in  conjunction  with  our  financial  statements  for  the  three  years  ended 
December 31, 2023 and the related notes thereto. The purpose of this Item 7 is: (i) to provide material relevant to an assessment 
of the financial condition and results of operations of Energy Fuels Inc., including an evaluation of the amounts and certainty of 
cash  flows  from  operations  and  from  outside  information  sources;  and  (ii)  to  focus  specifically  on  material  events  and 
uncertainties known to management that are reasonably likely to cause reported financial information not necessarily indicative 
of future operating results or of future financial condition. This Discussion and Analysis contains forward-looking statements 
that  involve  risks,  uncertainties,  and  assumptions.  Our  actual  results  may  differ  materially  from  those  anticipated  in  these 
forward-looking statements as a result of many factors, including, but not limited to, those set forth in “Part I, Item 1A. Risk 
Factors” and elsewhere in this Annual Report. See “Item II, Cautionary Statement Regarding Forward-Looking Statements.”

All  dollar  amounts  stated  herein  are  in  U.S.  dollars,  except  share  and  per  share  amounts  and  currency  exchange  rates 
unless specified otherwise. References to “Cdn$” refer to Canadian dollars, “Aus$” refer to Australian dollars and “$” to 
U.S. dollars.

Operations Update and Outlook for 2024

Overview

The Company continues to believe that uranium supply pressure and demand fundamentals point to higher sustained uranium 
prices in the future. The Company believes that the advancement of reliable nuclear energy, fueled by uranium, is experiencing 
a global resurgence with an increased focus by governments, policymakers, and citizens on decarbonization, electrification, and 
security of energy supply. In addition, Russia’s invasion of Ukraine and the entry into the uranium market by financial entities 
purchasing uranium on the spot market to hold for the long-term has the potential to result in higher sustained spot and term 
prices and, perhaps, induce utilities to enter into more long-term contracts with non-Russian producers, like Energy Fuels, to 
foster security of supply, avoid transportation and logistic issues, and ensure more certain pricing.

In  2022,  we  entered  into  three  long-term  uranium  contracts  with  major  U.S.  utilities.  To  deliver  under  these  contracts,  the 
Company readied three of its permitted and developed conventional uranium mines, Pinyon Plain, La Sal and Pandora, located 
in Arizona and Utah for uranium production in late Q4-2023. At the start of 2024, all three uranium mines have commenced 
production. Once production is fully ramped up at Pinyon Plain, La Sal and Pandora by mid- to late-2024, the Company expects 
to be producing uranium at a run-rate of approximately 1.1 to 1.4 million pounds per year. The Company stockpiles ore from 
production  at  its  three  conventional  mines  for  processing  in  late  2024  or  in  2025,  subject  to  market  conditions,  contract 
requirements and the Mill’s schedule and will continue to produce uranium from its alternate feed recycling program, which is 
expected to total approximately 150,000 pounds of finished U3O8 in 2024. Total uranium production for 2024 is expected to be 
between  150,000  to  500,000  pounds  of  finished  U3O8,  depending  on  the  timing  of  ramp  up  of  production  at  the  Company's 
Pinyon Plain, La Sal and Pandora mines.

Along with the sites in production, the Company is preparing two additional mines in Colorado and Wyoming (Whirlwind and 
Nichols  Ranch)  for  expected  production  within  one  year  and  advancing  permitting  on  several  other  large-scale  U.S.  mine 
projects in order to increase uranium production in the coming years in response to strong uranium market conditions. If strong 
market  conditions  continue  as  expected,  the  Whirlwind  and  Nichols  Ranch  mines  could  potentially  increase  Energy  Fuels' 
uranium  production  to  a  run-rate  of  over  two  million  pounds  of  U3O8  per  year  as  early  as  2025.  In  2024,  the  Company  also 
plans to advance permitting and development on the Roca Honda, Sheep Mountain and Bullfrog projects, which could expand 
the  Company's  uranium  production  to  a  run-rate  of  up  to  five  million  pounds  of  U3O8  per  year  in  the  coming  years.  The 
Company  also  expects  to  commence  an  ore  buying  program  from  third-party  miners  in  2024,  which  is  expected  to  further 
increase  the  Company's  uranium  production  profile.  Until  such  time  when  the  Company  has  ramped  back  up  to  commercial 
uranium  production,  it  can  rely  on  its  uranium  inventories  including  its  recent  purchases  of  U.S.  origin  uranium  on  the  spot 
market to fulfill its new contract requirements.

The Company’s decision to ramp-up uranium production at this time was driven by several favorable market and policy factors, 
including  strengthening  spot  and  long-term  uranium  prices,  increased  buying  interest  from  U.S.  nuclear  utilities,  U.S.  and 
global government policies supporting nuclear energy to address global climate change, and the need to reduce U.S. reliance on 
Russian  and  Russian-controlled  uranium  and  nuclear  fuel.  Underscoring  these  positive  trends,  attendees  at  the  recently 
concluded World Climate Action Summit of the 28th Conference of the Parties of the U.N. Framework Convention on Climate 
Change Summit (“COP28”) hosted in Dubai, UAE from November 30, 2023 to December 12, 2023, emphasized the need for 
more  nuclear  energy,  fueled  by  uranium,  to  lower  global  carbon  emissions  and  help  address  climate  change.  According  to  a 
December 1, 2023 U.S. Department of Energy (“DOE”) news release, more than 20 countries on four continents, including the 

143

U.S., pledged to triple nuclear energy output by 2050, recognizing “the key role of nuclear energy in achieving global net-zero 
greenhouse gas emissions by 2050 and keeping the 1.5-degree goal within reach.”

The Company continually seeks new sources of revenue, including through its emerging REE business, as well as new sources 
of  Alternate  Feed  Materials  and  new  feed  processing  opportunities  at  the  Mill  that  can  be  processed  without  reliance  on 
uranium  sales  prices.  The  Company  also  expects  to  produce  at  a  run-rate  of  1.0  –  2.0  million  pounds  of  vanadium  per  year 
starting as early as 2025, assuming the La Sal and Whirlwind mines are brought into production as contemplated, which could 
be held as in-process inventory or processed into finished V2O5 available for sale into improving markets.

The  Company  is  seeking  additional  sources  of  natural  monazite  sands  to  supply  feedstock  to  its  emerging  REE  projects  (in 
addition  to  the  recent  acquisition  of  the  Bahia  Project  discussed  in  Note  7  –  Property,  Plant  and  Equipment  and  Mineral 
Properties). The Company is also evaluating the potential to recover radioisotopes from its existing process streams for use in 
the development of TAT medical isotopes for the treatment of cancer and continues its support of U.S. governmental activities 
to  assist  the  U.S.  uranium  mining  industry,  including  expanding  the  U.S.  Uranium  Reserve  Program,  supporting  efforts  to 
restore domestic nuclear fuel capabilities, and advocating for the responsible sourcing of uranium and nuclear fuel.

We continually evaluate the optimal mix of production, inventory and purchases in order to retain the flexibility to deliver long-
term value.

Mill Activities

During  the  year  ended  December  31,  2023,  the  Mill  focused  on  its  mixed  RE  Carbonate  production  and  produced 
approximately  355  tonnes  of  high  purity,  partially  separated  mixed  RE  Carbonate,  containing  approximately  160  tonnes  of 
TREO while working to secure additional monazite ore feedstock to increase production. During the year ended December 31, 
2023, the uranium recovered from processing monazite ore was retained in-circuit and was not packaged as final U3O8 product. 
The Mill did not recover any vanadium in 2023.

The Company purchased an additional 480 tonnes of monazite from Chemours that it expects to receive in early 2024, which 
the Company expects to process for the recovery of uranium and production of 25 – 35 tonnes of separated NdPr oxide and 10 – 
20 tonnes Sm+ RE Carbonate upon commissioning of the Mill’s Phase 1 REE separation circuit in early 2024 (see “Rare Earth 
Element  Initiatives”  below).  No  vanadium  production  is  currently  planned  during  2024,  though  the  Company  continually 
monitors its inventory and vanadium markets to guide future potential vanadium production. 

The  Company  is  also  actively  pursuing  opportunities  to  process  additional  sources  of  natural  monazite  sands,  new  and 
additional  Alternate  Feed  Material  sources,  and  new  and  additional  low-grade  mineralized  materials  from  third  parties  in 
connection with various uranium clean-up programs.

Conventional Mine Activities

During  the  year  ended  December  31,  2023,  the  Company  performed  rehabilitation  and  development  work  on  its  La  Sal 
Complex  and  Whirlwind  and  Pinyon  Plain  Projects  in  preparation  for  production  at  those  mines,  including  engineering, 
procurement,  construction  management,  increased  development  activities,  significant  workforce  expansion  and  needed 
rehabilitation of surface and underground infrastructure. As of the date of this Annual Report, the Company has commenced 
production at the La Sal mine, Pinyon Plain Project and Pandora mine. Once production is fully ramped up at the three mines, 
which is currently planned for mid- to late-2024, the Company expects to be producing uranium at a run-rate of approximately 
1.1 to 1.4 million pounds per year. Ore mined from these three mines during 2024 will be stockpiled at the Mill for processing 
that is anticipated to start in late 2024 or in 2025, subject to market conditions, contract requirements and the Mill’s schedule.

The  Company  expects  to  continue  rehabilitation  and  development  work  at  its  Whirlwind  mine  as  it  is  prepared  for  future 
production. Although the timing of the Company’s plans to extract and process mineralized materials from the Whirlwind mine 
will  be  based  on  current  contract  requirements,  inventory  levels,  sustained  improvements  in  general  market  conditions, 
procurement of suitable sales contracts and/or the continuation of the U.S. Uranium Reserve Program or similar government 
programs,  the  Company  currently  expects  the  Whirlwind  mine,  along  with  the  Company’s  Nichols  Ranch  ISR  project,  to 
commence  uranium  production  within  one  (1)  year,  which  could  increase  Energy  Fuels'  uranium  production  to  a  run-rate  of 
over two (2) million pounds of U3O8 per year starting in 2025, if strong market conditions continue as expected. 

In  2024,  the  Company  also  plans  to  advance  permitting  and  development  on  its  Roca  Honda  Project,  a  large,  high-grade 
conventional project, in New Mexico, its Sheep Mountain Project, a large conventional project in Wyoming, and its Bullfrog 
Project in Utah, which could expand the Company’s uranium production to a run-rate of up to five million pounds of U3O8 per 
year  in  the  coming  years.  The  Company  is  also  continuing  to  maintain  required  permits  at  its  other  conventional  projects, 

144

including  the  Energy  Queen  mine  and  Sheep  Mountain  Project.  All  these  projects  serve  as  important  pipeline  assets  for  the 
Company’s future conventional production capabilities, as market conditions may warrant.

In  addition  to  the  Company’s  uranium  business,  the  Company  will  also  continue  to  advance  its  REE  program  at  the  Mill  in 
2024, along with the Mill’s uranium production, to fully capitalize on the Mill’s unique and valuable capabilities. As previously 
announced, the Mill is in the process of installing its Phase 1 capacity to produce up to 1,000 tonnes of NdPr oxide per year, 
subject to receipt of sufficient monazite feed. This capacity is expected to be completed in Q1 2024. At the current time, the 
Company expects to produce roughly 25 – 35 tonnes of NdPr oxide plus approximately 10 – 20 tonnes of an Sm+ RE Carbonate 
in Q2 2024, as it ramps-up and optimizes the newly installed circuit.

ISR Extraction and Recovery Activities

Although the Company expects to produce insignificant quantities of U3O8 in the year ending December 31, 2024 from Nichols 
Ranch, the Company plans to undertake exploration and development activities in 2024 to expand the resources at the Nichols 
Ranch  Project  and  to  further  develop  a  wellfield  to  be  ready  for  potential  recommencement  of  production  in  late  2024  or  in 
2025,  if  strong  market  conditions  continue  as  expected.  The  Company  currently  holds  34  fully  permitted,  undeveloped 
wellfields at Nichols Ranch, including four additional wellfields at the Nichols Ranch wellfields, 22 wellfields at the adjacent 
Jane Dough wellfields, and eight wellfields at the Hank Project, which is fully permitted to be constructed as a satellite facility 
to the Nichols Ranch Plant.

Inventories

As of December 31, 2023, the Company had approximately 685,000 pounds of finished uranium inventories located at certain 
conversion  facilities  in  North  America.  Additionally,  the  Company  has  approximately  436,000  pounds  of  additional  U3O8 
contained in stockpiled Alternate Feed Materials and other ore inventory at the Mill that can potentially be recovered relatively 
quickly  in  the  future,  as  general  market  conditions  may  warrant.  During  the  year  ended  December  31,  2023,  the  Company 
purchased 220,000 additional pounds of uranium and sold 300,000 pounds of uranium to the U.S. Uranium Reserve Program 
and another 260,000 pounds under a uranium term contract.

The  Company  sold  79,344  pounds  of  vanadium  during  the  year  ended  December  31,  2023.  As  of  December  31,  2023,  the 
Company holds approximately 905,000 pounds of finished V2O5 in inventory, and there remains an estimated 1.0 to 3.0 million 
pounds  of  additional  solubilized  recoverable  V2O5  remaining  in  tailings  solutions  awaiting  future  recovery,  as  market 
conditions may warrant.

Sales Update and Outlook for 2024

The Company sells uranium into its existing long-term contracts and continually evaluates selling a portion of its inventories on 
the spot market in response to future upside uranium price movements. The Company also continually evaluates the potential to 
purchase  uranium  on  the  spot  market  to  replace  sold  inventory,  meet  contract  obligations  and  gain  exposure  to  future  price 
increases.

Uranium Sales

The Company entered into four uranium sale and purchase agreements in 2022: three with major U.S. nuclear utilities and one 
with the U.S. Uranium Reserve Program. Under these contracts, the Company sold 560,000 pounds of U3O8 during 2023 with a 
weighted-average sales price of $59.42 per pound, which was partially subject to the then-prevailing market prices at the time 
of delivery. 

The  three  utility  contracts  require  deliveries  of  uranium  between  2023  and  2030,  with  base  quantities  totaling  3.0  million 
pounds  of  uranium  over  the  period,  and  up  to  4.1  million  pounds  of  uranium  if  all  remaining  options  are  exercised.  Having 
observed a marked uptick in interest from nuclear utilities seeking long-term uranium supply, the Company remains actively 
engaged in pursuing additional selective long-term uranium sales contracts.

In  January  2023,  the  Company  completed  the  sale  of  300,000  pounds  of  its  uranium  inventories  located  at  the  Metropolis 
Works  uranium  conversion  facility  (“ConverDyn”)  to  the  U.S.  Uranium  Reserve  Program  for  $18.47  million  ($61.57  per 
pound), which resulted in a gross profit of $35.85 per pound of uranium. In May 2023, the company sold 80,000 pounds of its 
inventories located at the Cameco Corporation conversion facility in Blind River, Ontario, Canada for $4.34 million ($54.19 per 
pound).  In  September  2023,  the  Company  sold  an  additional  180,000  pounds  of  its  U3O8  inventory  located  at  the  Cameco 
Corporation conversion facility in Blind River, Ontario, Canada for $10.47 million ($58.18 per pound). During January 2024, 
the Company sold 200,000 pounds of uranium into its existing portfolio of long-term contracts. One of the Company's utility 
customers has the option to purchase an additional 100,000 pounds of uranium from Energy Fuels in 2024. The Company holds 

145

uncommitted  inventory  and,  with  the  benefit  of  future  production,  will  continue  to  evaluate  additional  spot  and/or  long-term 
uranium sales opportunities during 2024 and beyond.

To provide the Company with additional flexibility to fulfill its contract obligations and gain direct exposure to potential future 
uranium  price  increases,  the  Company  purchased  100,000  pounds  of  U.S.  origin  uranium  on  the  spot  market  for  $81.00  per 
pound in late 2023. 

Vanadium Sales

As  a  result  of  then  strengthening  vanadium  markets,  during  the  year  ended  December  31,  2023,  the  Company  sold 
approximately  79,344  pounds  of  the  Company’s  existing  inventory  of  V2O5  at  a  weighted  average  sales  price  of  $10.98  per 
pound  of  V2O5.  The  Company  expects  to  sell  its  remaining  finished  vanadium  product  when  justified  into  the  metallurgical 
industry, as well as other markets that demand a higher purity product, including the aerospace, chemical, and potentially the 
vanadium battery industries. The Company expects to sell to a diverse group of customers in order to maximize revenues and 
profits. The vanadium produced in the 2018/19 Pond Return campaign was a high-purity vanadium product of 99.6%-99.7% 
V2O5. The Company believes there may be opportunities to sell certain quantities of this high-purity material at a premium to 
reported spot prices. The sales during February and March 2023 were at a $0.60 per pound premium to the average spot price 
for V2O5.

The Company intends to continue to selectively sell its V2O5 inventory on the spot market as markets warrant but will otherwise 
continue to maintain its vanadium in inventory.

Rare Earth Sales

During the year ended December 31, 2023, the Company sold approximately 153,353 kilograms of RE Carbonate at an average 
price of $18.57 per kilogram of RE Carbonate, to Neo for separation at Silmet. At the current time, the Company expects to 
produce roughly 25 – 35 tonnes of NdPr oxide plus approximately 10 – 20 tonnes of an Sm+ RE Carbonate in Q2 2024, as it 
ramps-up and optimizes the Mill’s newly installed Phase 1 separation circuit, all of which it intends to sell to Neo. 

While  the  Company  continues  to  make  progress  on  its  mixed  RE  Carbonate  production  and  additional  funds  are  spent  on 
process enhancements, improving recoveries, product quality and other optimization, profits from this initiative are expected to 
be minimal until such time when monazite throughput rates are increased and optimized. Throughout this process, the Company 
is gaining important knowledge, experience and technical information, all of which are valuable for current and future mixed 
RE Carbonate production and planned future production of separated REE oxides and other advanced REE materials at the Mill 
or elsewhere.

Rare Earth Element Initiatives

The Company is in advanced discussions with several sources of natural monazite (in addition to the Bahia Project) to secure 
additional supplies of monazite sands by offtake or otherwise, which if successful, would be expected to allow the Company to 
increase REE production.

The  Company  continues  to  make  progress  toward  full  REE  separation  capabilities  at  the  Mill  to  produce  both  “light”  and 
“heavy” separated REE oxides in the coming years. Energy Fuels is also proceeding with the modification and enhancement of 
its infrastructure at the Mill (“Phase 1”) to expand its “light” REE separation facilities to be capable of producing commercial 
quantities  of  separated  NdPr  oxide  in  early  2024,  followed  by  planned  further  enhancements  to  expand  NdPr  production 
capability  (“Phase  2”)  and  to  produce  separated  Dy,  Tb  and  potentially  other  REE  materials  in  the  future  (“Phase  3”)  from 
monazite and potentially other REE process streams. 

In  2022,  the  Company  began  construction  on  its  “Phase  1”  REE  separation  facilities,  which  includes  modifications  and 
enhancements  to  the  SX  circuits  at  the  Mill.  “Phase  1”  is  expected  to  have  the  capacity  to  process  approximately  8,000  to 
10,000  MT  of  monazite  per  year,  producing  roughly  4,000  to  5,000  MT  TREO,  containing  roughly  800  to  1,000  MT  of 
recoverable  separated  NdPr  oxide  per  year.  Because  Energy  Fuels  is  utilizing  existing  infrastructure  at  the  Mill,  “Phase  1” 
capital is expected to total between $16 million and $18 million, or approximately $7 million to $9 million less than our initial 
$25  million  budget.  “Phase  1”  is  expected  to  be  operational  in  2024,  subject  to  receipt  of  sufficient  monazite  supply  and 
successful construction and commissioning. 

During  “Phase  2,”  Energy  Fuels  expects  to  expand  its  NdPr  separation  capabilities,  with  an  expected  capacity  to  process 
roughly  30,000  to  50,000  MT  of  monazite  per  year,  depending  on  the  availability  of  monazite  and  expected  recovery  of 
approximately  15,000  to  25,000  MT  of  TREO,  containing  approximately  3,000  to  5,000  MT  of  NdPr  oxide  per  year,  or 
sufficient NdPr for 1.5 to 5.0 million EVs per year. “Phase 2” is also expected to add a dedicated monazite “crack-and-leach” 

146

circuit to the Mill’s existing leach circuits, which may be constructed as the first stage of Phase 2, prior to construction of the 
expanded NdPr separation capabilities. The Company expects to complete “Phase 2” in 2027, subject to licensing, financing, 
and receipt of sufficient monazite feed.

During “Phase 3,” Energy Fuels expects to add “heavy” REE separation capabilities, including the production of Dy, Tb, and 
potentially  other  REE  oxides  and  advanced  materials.  The  Company  will  also  evaluate  the  potential  to  produce  La  and  Ce 
products. Monazite naturally contains higher concentrations of “heavy” REEs, including Dy and Tb, versus other REE-bearing 
ores, like bastnaesite, mainly due to the presence of another REE-bearing phosphate mineral called “xenotime.” “Phase 3” is 
expected  to  enable  Energy  Fuels  to  produce  separated  Dy,  Tb,  and  potentially  other  “light”  and  “heavy”  products.  The 
Company also expects to have additional “heavy” REE feedstock stockpiled from “Phase 1” and “Phase 2.” During these earlier 
phases, the Company expects to produce NdPr oxide and an Sm+ “heavy” REE concentrate, which the Company will either sell 
or  stockpile  as  feed  for  “Phase  3”  REE  separation.  For  reference,  the  monazite  the  Company  has  analyzed  to  date  contains 
roughly 1% to 3% Dy and Tb, so 10,000 MT of monazite is expected to contain roughly 100 to 300 MT of Dy and Tb. The 
Company expects to complete “Phase 3” in 2028, subject to licensing, financing, and receipt of sufficient feed. Alternatively, 
the Company may delay Phase 2 and combine Phase 2 and Phase 3 separation capability.

In addition, the Company completed its purchase of the Bahia Project in Brazil on February 10, 2023. The Bahia Project is a 
well-known HMS deposit that has the potential to supply 3,000 – 10,000 tonnes of natural monazite sand concentrate per year 
to the Mill for decades for processing into high-purity REE oxides and other materials. While Energy Fuels’ primary interest in 
acquiring the Bahia Project is the REE-bearing monazite, the Bahia Project is also expected to produce large quantities of high-
quality titanium (ilmenite and rutile) and zirconium (zircon) minerals that are also in high demand.

Natural monazite of 3,000 – 10,000 tonnes of monazite contains approximately 1,500 – 5,000 tonnes of TREO, including 300- 
1,000 tonnes of NdPr and significant commercial quantities of Dy and Tb. The Company is focused on monazite at the current 
time, as it has superior concentrations of these four critical REEs compared to other REE-bearing minerals. These REEs are 
used in the powerful neodymium-iron-boron (“NdFeB”) magnets that power the most efficient electric vehicles (“EVs”), along 
with uses in other clean energy and defense technologies. For reference, a typical EV utilizes approximately one (1) to two (2) 
kilograms  of  NdPr  oxide  in  its  drivetrain.  Based  on  this  assumption,  monazite  from  the  Bahia  Project  alone  is  expected  to 
supply  enough  NdPr  oxide  to  power  150,000  to  1  million  EVs  per  year.  The  uranium  contained  in  the  monazite,  which  is 
expected to be comparable to typical Colorado Plateau uranium deposits, will also be recovered at the Mill.

The acquisition of the Bahia Project is a part of the Company’s efforts to build a large and diverse book of monazite supply for 
its rapidly advancing REE processing business. The Company expects to procure monazite through Company-owned mines like 
the Bahia Project, joint ventures or other collaborations, and open market purchases, like the Company’s current arrangement 
with  The  Chemours  Company.  The  Company  is  currently  in  advanced  discussions  with  several  additional  current  and  future 
monazite producers around the world to supply Energy Fuels’ initiative. 

Collaboration with RadTran on Recovering Medical Isotopes for Advanced Cancer Therapies

On  July  28,  2021,  the  Company  announced  the  execution  of  a  Strategic  Alliance  Agreement  with  RadTran,  a  technology 
development  company  focused  on  closing  critical  gaps  in  the  procurement  of  medical  isotopes  for  emerging  TAT  cancer 
therapeutics  and  other  applications.  Under  this  strategic  alliance,  the  Company  is  evaluating  the  feasibility  of  recovering 
Th-232,  and  Ra-226  from  its  existing  RE  Carbonate/uranium  and  uranium  process  streams  at  the  Mill  and,  together  with 
RadTran,  is  evaluating  the  feasibility  of  recovering  Ra-228  from  the  Th-232,  Th-228  from  the  Ra-228  and  concentrating 
Ra-226 at the Mill. Recovered Ra-228, Th-228 and/or Ra-226 would then be sold to pharmaceutical companies and others to 
produce  Pb-212,  Ac-225,  Bi-213,  Ra-224  and/or  Ra-223,  which  are  the  leading  medically  attractive  TAT  isotopes  for  the 
treatment of cancer. Existing supplies of these isotopes for TAT applications are in short supply, and methods of production are 
costly and currently cannot be scaled to meet the demand created as new drugs are developed and approved. This is a major 
roadblock in the research and development of new TAT drugs as pharmaceutical companies wait for scalable and affordable 
production technologies to become available. Under this initiative, the Company has the potential to recover valuable isotopes 
from its existing process streams, therefore recycling back into the market material that would otherwise be lost to disposal for 
use in treating cancer. See “Part I, Item 1. Business Overview” for a more detailed discussion of this initiative.

The Company currently has an R&D license for the recovery of R&D quantities of Ra-226 at the Mill, issued by DWMRC in 
2023. It is expected that the potential recovery and concentration of R&D quantities of Th-232, Ra-228 and/or Th-228 will also 
require  similar  R&D  licenses  or  amendments  to  the  existing  Ra-226  R&D  license  and  that  the  potential  recovery  and 
concentration of commercial quantities of Th-232, Ra-228, Th-228 and/or Ra-226 will require additional licensing by DWMRC 
at the Mill.

147

The San Juan County Clean Energy Foundation

On September 16, 2021, the Company announced its establishment of the Foundation, a fund specifically designed to contribute 
to the communities surrounding the Mill in southeastern Utah. Energy Fuels deposited an initial $1 million into the Foundation 
at the time of formation and now provides ongoing funding equal to 1% of the Mill’s revenues, thereby providing an ongoing 
source  of  funding  to  support  local  priorities.  The  Foundation  focuses  on  supporting  education,  the  environment,  health/
wellness,  and  local  economic  development  in  the  City  of  Blanding,  San  Juan  County,  the  White  Mesa  Ute  Community,  the 
Navajo Nation and other area communities. 

A seven-person Advisory Board, comprised of local citizens from San Juan County, evaluates grant applications on a quarterly 
basis and makes recommendations to the Foundation’s Managers for final review and approval, who are currently the President 
and Chief Executive Officer and the Executive Vice President and Chief Legal Officer of the Company. As of the December 
31,  2023,  the  Foundation  has  awarded  15  grants  totaling  $323,210,  of  which  $236,710  was  committed  to  American  Indian 
initiatives.

Sale of Alta Mesa property to enCore Energy

On  November  14,  2022,  the  Company  announced  that  it  had  entered  into  a  definitive  agreement  to  sell  three  wholly-owned 
subsidiaries that together hold the Alta Mesa ISR Project to enCore Energy Corp. for total consideration of $120 million. The 
proceeds from the transaction are expected to help the Company fully finance much of its uranium, REE, vanadium and medical 
isotope business plans for the next 2 to 3 years while minimizing dilution to shareholders. The transaction closed on February 
14,  2023.  See  “Part  I,  Item  1.  Description  of  Business  -  Material  Transactions”  for  a  more  detailed  discussion  of  this 
transaction.

Known Trends or Uncertainties

The  Company  has  had  negative  net  cash  flows  from  operating  activities  and  net  losses  in  previous  years,  in  part  due  to 
depressed uranium and vanadium prices, along with low quantities of monazite to process into salable RE Carbonate, which has 
not allowed the Company to realize economies of scale. We are not aware at this time of any trends or uncertainties that have 
had  or  are  reasonably  likely  to  have  a  material  impact  on  revenues  or  income  of  the  Company,  other  than:  (i)  recent 
strengthening  of  uranium  markets,  which  could  result  in  the  Company  selling  inventories  and  future  production  at  increased 
prices and/or signing additional contracts with nuclear utilities for the long-term supply of uranium; (ii) U.S. government laws 
and programs, including a potential ban on Russian uranium imports and efforts to restore domestic nuclear fuel capabilities, 
which  could  result  in  improved  uranium  sales  prices;  (iii)  volatility  of  prices  of  uranium,  vanadium,  REEs  and  our  other 
primary metals; and (iv) the Company’s REE and TAT radioisotope initiatives, which, if successful, could result in improved 
results from operations in future years. We are not aware at this time of any events that are reasonably likely to cause a material 
change in the relationship between costs and revenue of the Company.

Continued Efforts to Minimize Costs

Although the Company is pursuing two new initiatives - its REE and TAT radioisotope initiatives - in addition to its existing 
uranium and vanadium products, and is restarting operations at three of its uranium and uranium/vanadium mines and taking 
other steps to advance its uranium production capabilities, which will require the Company to grow certain of its operations, the 
Company  will  nevertheless  continue  to  seek  ways  to  minimize  the  costs  of  all  its  operations  where  feasible  while  achieving 
these objectives and maintaining its critical capabilities, manpower and properties.

148

Results of Operations

The  following  table  summarizes  the  results  of  operations  for  the  years  ended  December  31,  2023  and  2022  (in  thousands  of 
U.S. dollars, except per share amounts):

Years Ended December 31,

2023

2022

Increase
(Decrease)

Percent
Change

Revenues
Uranium concentrates
Vanadium concentrates
RE Carbonate
Alternate Feed Materials, processing and other
Total revenues 
Costs applicable to revenues
Costs applicable to uranium concentrates
Costs applicable to vanadium concentrates
Costs applicable to RE Carbonate
Underutilized capacity production costs applicable to 
RE Carbonate
Total costs applicable to revenues
Other operating costs and expenses
Exploration, development and processing
Standby
Accretion of asset retirement obligations
Selling, general and administration (excluding share-
based compensation)
Share-based compensation
Total operating loss
Other income (loss)
Gain on sale of assets
Other income (loss)
Total other income (loss)
Income (loss) before income taxes
Income tax expense
Net income (loss)

Basic net income (loss) per common share
Diluted net income (loss) per common share

*Not meaningful.

$ 

33,278  $ 
871 
2,848 
931 
37,928 

15,318 
551 
2,312 

— 
18,181 

15,531 
7,476 
1,192 

—  $ 

8,778 
2,122 
1,615 
12,515 

— 
3,769 
1,317 

2,758 
7,844 

9,346 
13,221 
1,556 

23,290 
4,625 
(32,367)   

20,845 
4,641 
(44,938)   

33,278 
(7,907) 
726 
(684) 
25,413 

15,318 
(3,218) 
995 

(2,758) 
10,337 

6,185 
(5,745) 
(364) 

2,445 
(16) 
12,571 

119,257 
13,142 
132,399 
100,032 

(276)   
99,756  $ 

366 
(15,372)   
(15,006)   
(59,944)   

— 
(59,944)  $ 

118,891 
28,514 
147,405 
159,976 
(276) 
159,700 

0.63  $ 
0.62  $ 

(0.38)  $ 
(0.38)  $ 

1.01 
1.00 

$ 

$ 
$ 

*
*
 34 %
 (42) %
 203 %

*
*
 76 %

*
 132 %

 66 %
 (43) %
 (23) %

 12 %
 — %
 (28) %

*
*
*
*
*
*

*
*

149

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The following table sets forth selected operating data and financial metrics for the years ended December 31, 2023 and 2022.

Volumes sold

Uranium concentrates (lbs.)

Vanadium concentrates (lbs.)

RE Carbonate (kgs)

Realized sales price

Uranium concentrates ($/lb.)

Vanadium concentrates ($/lb.)

RE Carbonate ($/kg)

Costs applicable to revenues

Uranium concentrates ($/lb.)

Vanadium concentrates ($/lb.)

RE Carbonate ($/kg)

*Not meaningful.

Years Ended December 31,

Increase

2023

2022

(Decrease)

Percent

Change

560,000 

79,344 

153,353 

— 

641,928 

88,860 

560,000 

(562,584) 

64,493 

$ 

$ 

$ 

$ 

$ 

$ 

59.42  $ 

10.98  $ 

18.57  $ 

—  $ 

13.67  $ 

23.88  $ 

27.35  $ 

6.94  $ 

15.08  $ 

—  $ 

5.87  $ 

14.82  $ 

59.42 

(2.69) 

(5.31) 

27.35 

1.07 

0.26 

*

*

 73 %

*

 (20) %

 (22) %

*

 18 %

 2 %

Year Ended December 31, 2023 Compared to Year Ended December 31, 2022

For  the  year  ended  December  31,  2023,  we  earned  net  income  of  $99.76  million  or  $0.63  per  share  compared  to  net  loss  of 
$59.94 million or $0.38 per share for the year ended December 31, 2022. The changes between periods was due to (i) a gain of 
$119.26 million recognized on the sale of our Alta Mesa ISR Project in February 2023 and sale of our PFN tool in May 2023; 
(ii) an increase in revenues of $25.41 million due the sales of uranium concentrates for $33.28 million during 2023, partially 
offset by lower sales of vanadium concentrates of $7.91 million between periods; (iii) lower standby costs between periods of 
$5.75 million due to the Alta Mesa divestiture and lower standby costs incurred at the Company’s Colorado Plateau mines and 
the Mill; (iv) a net gain of $4.45 million during the year ended December 31, 2023 compared to a loss of $17.26 million for the 
year  ended  December  31,  2022  related  to  mark-to-market  investments  and  marketable  securities  accounted  for  at  fair  value 
between periods; (v) a realized gain on the early redemptions and sale of our Convertible Note of $1.43 million during the year 
ended December 31, 2023; (vi) an increase in interest income, net of $5.86 million between periods due to interest earned on 
marketable debt securities and our Convertible Note, partially offset by (a) higher total costs applicable to revenues of $10.34 
million due to increased revenues; (b) higher exploration, development and processing costs between periods of $6.19 million 
associated with our Bahia and Whirlwind Projects, as well as continued progression of the RE Carbonate production program at 
the Mill; (c) higher selling, general and administrative expenses between periods of $2.43 million due to increased salaries and 
benefits in connection with additional headcount associated with the current and future growth in activity in our uranium and 
REE operations between periods; and (d) lower unrealized gain on foreign currency of $1.64 million between periods. 

Revenues

Uranium concentrates

Revenues  from  uranium  concentrates  were  $33.28  million  for  the  year  ended  December  31,  2023  due  to  the  completed  total 
sales of 560,000 pounds of our inventories to the U.S. Uranium Reserve Program and a major U.S. nuclear utility at a weighted-
average  sales  price  of  $59.42  per  pound  of  U3O8.  There  were  no  revenues  from  uranium  concentrates  for  the  year  ended 
December 31, 2022.

Vanadium concentrates

Revenues from vanadium concentrates decreased by $7.91 million to $0.87 million for the year ended December 31, 2023 from 
$8.78 million for the year ended December 31, 2022 primarily due to lower volumes sold and lower realized prices between 
periods.  Lower  sales  volumes  (calculated  as  the  change  in  year-to-year  sales  volumes  times  the  prior  period  realized  price) 
accounted for an approximate $7.69 million decrease in vanadium revenue between periods. Lower realized prices (calculated 

150

 
 
 
 
 
 
 
 
 
as the change in the year-to-year average realized price times current year sales volumes sold) accounted for an approximate 
$0.21 million decrease in vanadium revenue between periods.

RE Carbonate

Revenues from RE Carbonate increased by $0.73 million to $2.85 million for the year ended December 31, 2023 from $2.12 
million for the year ended December 31, 2022 primarily due to increased volumes sold, partially offset by lower realized prices. 
Higher sales volumes (calculated as the change in year-to-year sales volumes times the prior period realized price) accounted 
for an approximate $1.54 million increase in RE Carbonate revenue between periods. Lower realized prices (calculated as the 
change in the year-to-year average realized price times current year sales volumes sold) accounted for an approximate $0.81 
million decrease in RE Carbonate revenue between periods.

Alternate Feed Materials processing and other

Revenues from Alternate Feed Materials, processing and other decreased by $0.68 million to $0.93 million for the year ended 
December 31, 2023 from $1.62 million for the year ended December 31, 2022 primarily due to lower Alternate Feed Materials 
received and processed between periods.

Costs Applicable to Revenues

Costs applicable to uranium concentrates

Costs applicable to uranium concentrates were $15.32 million for the year ended December 31, 2023 due to the completed sales 
for a total of 560,000 pounds of our finished U3O8 concentrate to the U.S. Uranium Reserve Program and a major U.S. nuclear 
utility  at  a  weighted  average  cost  of  $27.35  per  pound.  There  were  no  costs  applicable  to  uranium  concentrates  for  the  year 
ended December 31, 2022.

Costs applicable to vanadium concentrates

Costs applicable to vanadium concentrates decreased by $3.22 million to $0.55 million for the year ended December 31, 2023 
from  $3.77  million  for  the  year  ended  December  31,  2022  primarily  due  to  lower  volumes  sold  partially  offset  by  increased 
weighted average costs per pound sold between periods. Lower sales volumes (calculated as the change in year-to-year sales 
volumes times the prior period weighted average cost) accounted for an approximate $3.30 million decrease in costs applicable 
to vanadium concentrates between periods. Higher weighted average costs per pound (calculated as the change in the year-to-
year  weighted  average  cost  per  pound  times  current  year  sales  volumes  sold)  accounted  for  an  approximate  $0.08  million 
increase in costs applicable to vanadium concentrates between periods.

Costs applicable to RE Carbonate

Costs  applicable  to  RE  Carbonate  increased  by  $0.99  million  to  $2.31  million  for  the  year  ended  December  31,  2023  from 
$1.32  million  for  the  year  ended  December  31,  2022  primarily  due  to  increased  volumes  sold,  as  well  as  higher  weighted 
average costs per kilogram. Higher sales volumes (calculated as the change in year-to-year sales volumes times the prior period 
weighted average cost per kilogram) accounted for an approximate $0.95 million increase in costs applicable to RE Carbonate 
revenues between periods. Higher weighted average costs per kilogram (calculated as the change in the year-to-year weighted 
average cost per kilogram times current year sales volumes sold) accounted for an approximate $0.04 million increase in costs 
applicable to RE Carbonate between periods.

Underutilized capacity production costs applicable to RE Carbonate

Underutilized capacity production costs applicable to RE Carbonate were $2.76 million for the year ended December 31, 2022. 
The  underutilized  capacity  production  costs  were  due  to  low  throughput  rates  as  the  Mill  ramps  up  to  commercial-scale 
production of RE Carbonate. To date, the Mill has focused on producing commercially salable RE Carbonate at low throughput 
rates and has shipped its resulting product to Silmet. The Mill expects to increase its throughput rates as its supplies of monazite 
sands increase. There were no underutilized production capacity costs applicable to RE Carbonate for the year ended December 
31, 2023.

Other Operating Expenses

Exploration, development and processing

151

Exploration, development and processing costs increased by $6.19 million to $15.53 million for the year ended December 31, 
2023 from $9.35 million for the year ended December 31, 2022. Higher exploration, development and processing costs between 
periods  were  primarily  related  to  expenses  for  our  Bahia  and  Whirlwind  Projects  and  other  development  projects,  as  well  as 
continued progression of the RE Carbonate production program at the Mill, which includes net realizable value adjustments to 
RE Carbonate inventory.

While we expect the amounts relative to the items listed above have added future value to the Company, the Company expenses 
these costs in part due to the fact that the Company has not established Proven Mineral Reserves or Probable Mineral Reserves 
as defined by S-K 1300 or NI 43-101 through the completion of a feasibility or pre-feasibility study for any of the Company’s 
projects as of the year ended 2023, with the exception of its Sheep Mountain and Pinyon Plain Projects.

Standby

Standby costs related to the care and maintenance of the standby mines are expensed along with standby costs incurred when 
the Mill in standby status is operating at minimal levels of production or packaging.

Standby costs decreased by $5.75 million to $7.48 million for the year ended December 31, 2023 from $13.22 million for the 
year ended December 31, 2022 primarily due to the Alta Mesa divestiture on February 14, 2023, as well as lower costs incurred 
at the Company’s Colorado Plateau mines and the Mill between periods.

Selling, general and administrative (excluding share-based compensation)

Selling,  general  and  administrative  expenses  (excluding  share-based  compensation)  increased  by  $2.45  million  to  $23.29 
million  for  the  year  ended  December  31,  2023  from  $20.85  million  for  the  year  ended  December  31,  2022  primarily  due  to 
increased salaries and benefits in connection with additional headcount associated with the current and future growth in activity 
in  our  uranium  and  REE  operations,  partially  offset  by  reduced  contract  and  professional  services  between  periods.  Our 
headcount increased to 147 full-time employees as of December 31, 2023 from 129 full-time employees as of December 31, 
2022. 

Share-based compensation

Share-based compensation was relatively consistent at $4.63 million and $4.64 million for the years ended December 31, 2023 
and 2022, respectively.

Other Income (Loss)

Gain on sale of assets

For the year ended December 31, 2023, we recognized a gain on sale of assets of $119.26 million related to the sale of our Alta 
Mesa  ISR  Project  to  enCore  for  total  consideration  of  $120  million  consisting  of  $60  million  cash  and  the  $60  million 
Convertible Note, as well as the completed sale of our PFN tool utilized at Alta Mesa to enCore for total cash consideration of 
$3.10 million. See Note 7 – Property, Plant and Equipment and Mineral Properties for more information.

Other income (loss)

Other income (loss) for the year ended December 31, 2023 was $13.14 million income, net. These amounts primarily consist of 
mark-to-market unrealized gains on investments accounted for at fair value including marketable securities of $14.94 million, 
partially offset by a realized loss of $10.49 million due to decreased share prices since acquisition related to our investment in 
CUR  following  the  completion  of  IsoEnergy's  acquisition  of  CUR,  upon  which  the  Company  does  not  exercise  significant 
influence over IsoEnergy and the investment is no longer accounted for as an equity method investment. As a result, there is a 
change  to  the  prospective  accounting  for  this  investment  whereby  it  is  accounted  for  as  a  marketable  security.  Additionally, 
income consisted of a realized gain on the redemptions and sale of our Convertible Note of $1.43 million and a gain on foreign 
exchange of $0.42 million.

Other income (loss) was $15.37 million loss, net for the year ended December 31, 2022. These amounts primarily consist of a 
mark-to-market loss on investments of $16.81 million, partially offset by a gain on foreign exchange of $2.06 million.

Income tax expense

Income tax expense was $0.28 million for the year ended December 31, 2023 due to the gain related to the sale of our Alta 
Mesa ISR Project including cash received for early redemption and sale of the Convertible Note.

152

Year Ended December 31, 2022 compared to Year Ended December 31, 2021

Refer to “Part I, Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations - Results of 
Operations”  in  our  Annual  Report  on  Form  10-K  for  the  year  ended  December  31,  2022  for  a  discussion  on  the  results  of 
operations for the year ended December 31, 2022 compared to the year ended December 31, 2021.

LIQUIDITY AND CAPITAL RESOURCES

Funding of Major Cash Requirements

Our primary short-term and long-term cash requirements are to fund working capital needs and operating expenses (including 
our  contractual  lease,  decommissioning  and  other  obligations  as  described  in  “Contractual  Obligations”  below),  capital 
expenditures  and  potential  future  growth  opportunities  through  ongoing  initiatives  such  as  our  REE  program,  Bahia  Project, 
REE oxide separation project, TAT radioisotope initiative and operational readiness at our Whirlwind and Nichols Ranch mines 
as well as potential business and property acquisitions.

We  expect  to  be  able  to  fund  working  capital  and  operating  expenses,  capital  expenditures  and  currently  planned  growth 
initiatives  over  the  next  12  months  through  available  cash  balances  and  product  inventory  sales,  if  needed.  We  may  also 
increase  our  working  capital  through  issuances  of  Common  Shares  pursuant  to  the  ATM  in  appropriate  circumstances.  We 
intend to continue to pursue the acquisition of monazite mineral rights and other uranium producing assets.

Shares Issued for Cash

The Company has an ATM in place, which allows the Company to make Common Share distributions to the extent qualified 
under a U.S. shelf registration statement on Form S-3 and one or more prospectus supplements. The Company’s current U.S. 
shelf  registration  statement  was  declared  effective  on  March  18,  2021  and  permits  the  Company  to  sell  any  combination  of 
Securities  (as  defined  therein)  in  one  or  more  offerings  having  an  aggregate  offering  price  of  up  to  $300.00  million.  Most 
recently, on January 3, 2022, we filed a prospectus supplement with the SEC to our U.S. shelf registration statement, qualifying 
for  distribution  up  to  $50.00  million  in  additional  Common  Shares  under  the  ATM.  Sales  made  pursuant  to  the  above  noted 
U.S. shelf registration statement and prospectus supplement are made on the NYSE American at then-prevailing market prices, 
or any other existing trading market of the Common Shares in the U.S. During the year ended December 31, 2023, we issued 
4,047,832 shares for net proceeds of $31.81 million under our ATM. See Note 9 – Capital Stock for more information.

Working Capital and Future Requirements for Funds

As  of  December  31,  2023,  the  Company  had  working  capital  of  $222.34  million,  including  $57.45  million  in  cash  and  cash 
equivalents, $133.04 million in marketable securities, approximately 685,000 pounds of uranium finished goods inventory and 
approximately  905,000  pounds  of  vanadium  finished  goods  inventory.  The  Company  believes  it  has  sufficient  cash  and 
resources to carry out its business plan for at least the next twelve months.

We manage our liquidity risk through the management of our working capital and capital structure.

Cash and Cash Flows

The following table summarizes our cash flows (in thousands):

Net cash used in operating activities

Net cash used in investing activities

Net cash provided by financing activities
Effect of exchange rate fluctuations on cash held in foreign currencies

Less: restricted cash related to assets held for sale

Plus: release of restricted cash related to sale of assets

Net change in cash, cash equivalents and restricted cash
Cash, cash equivalents and restricted cash, beginning of period
Cash, cash equivalents and restricted cash, end of period

153

Year Ended December 31,

2023

2022

(15,409)  $ 

(49,702) 

(23,853)   

30,415 
12 

— 

3,590 

(5,245)   
80,269 
75,024  $ 

(7,065) 

7,870 
(66) 

(3,590) 

— 

(52,553) 
132,822 
80,269 

$ 

$ 

$ 
$ 

$ 

$ 

$ 
$ 
$ 

 
 
 
 
 
Year Ended December 31, 2023 Compared to Year Ended December 31, 2022 

Net cash used in operating activities

Net cash used in operating activities decreased by $34.29 million to $15.41 million for the year ended December 31, 2023 from 
$49.70  million  for  the  year  ended  December  31,  2022  primarily  due  to  sales  of  uranium  concentrates  of  $33.28  million, 
partially  offset  by  higher  selling,  general  and  administrative  expenses  and  higher  exploration,  development  and  processing 
expenses between periods.

Net cash used in investing activities

Net cash used in investing activities increased by $16.79 million to $23.85 million for the year ended December 31, 2023 from 
$7.07 million for the year ended December 31, 2022 primarily due to increased purchases of marketable securities for $163.19 
million between periods, the acquisition of the Bahia Project and additions to mineral properties for $29.27 million, as well as 
increased additions to property, plant and equipment primarily related to the REE oxide separation project and equipment for 
readying the Pinyon Plain for Production of $13.44 million, partially offset by $56.88 million in proceeds from the sale of the 
Alta Mesa ISR Project and PFN tool, maturities of marketable securities of $79.04 million and proceeds of $60.89 million from 
the early redemptions and sale of the Convertible Note. See Note 7 – Property, Plant and Equipment and Mineral Properties for 
more information.

Net cash provided by financing activities

Net cash provided by financing activities increased by $22.55 million to $30.42 million for the year ended December 31, 2023 
from  $7.87  million  for  the  year  ended  December  31,  2022  primarily  due  to  increased  net  proceeds  of  $23.93  million  for  the 
issuance of Common Shares for cash under the ATM between periods, partially offset by increased cash paid to settle and fund 
employee income tax withholding due upon exercise of stock appreciation rights of $1.52 million. See Note 9 – Capital Stock 
for more information.

Year Ended December 31, 2022 Compared to Year Ended December 31, 2021

Refer to “Part I, Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations - Liquidity 
and  Capital  Resources  -  Cash  Flows”  in  our  Annual  Report  on  Form  10-K  for  the  year  ended  December  31,  2022  for  a 
discussion on cash and cash flows for the year ended December 31, 2022 compared to the year ended December 31, 2021.

Contractual Obligations

The following table summarizes our contractual obligations as of December 31, 2023 (in thousands).

2024

Year Ended December 31,
2026

2025

2027

2028

Thereafter

Total

Operating lease 
obligations
Undiscounted 
decommissioning 
liabilities 
Total contractual 
obligations

$ 

384  $ 

391  $ 

398  $ 

405  $ 

273  $ 

—  $ 

1,851 

—   

211   

2,889   

2,731   

1,602   

25,942   

33,375 

$ 

384  $ 

602  $ 

3,287  $ 

3,136  $ 

1,875  $ 

25,942  $ 

35,226 

The Company entered into commitments with federal and state agencies and private individuals to lease surface and mineral 
rights. These leases are primarily renewable annually and are expected to total $1.60 million for the year ended December 31, 
2024.

CRITICAL ACCOUNTING ESTIMATES

The preparation of these consolidated financial statements in accordance with U.S. GAAP requires the use of certain critical 
accounting  estimates  and  judgments  that  affect  the  amounts  reported.  It  also  requires  management  to  exercise  judgment  in 
applying the Company’s accounting policies. These judgments and estimates are based on management’s best knowledge of the 
relevant  facts  and  circumstances  taking  into  account  previous  experience.  Although  the  Company  regularly  reviews  the 
estimates and judgments made that affect these financial statements, actual results may be materially different.

Significant estimates made by management include:

154

 
a.      Development Stage

The Company has established the existence of multiple Mineral Resources and extracts and processes saleable uranium from its 
operations and has established Proven Mineral Reserves or Probable Mineral Reserves, as defined under SEC S-K 1300, at each 
of its Sheep Mountain and Pinyon Plain Projects. As a result, the Company is a “Development Stage Issuer” as defined by S-K 
1300, as it is engaged in the preparation of Mineral Reserves for extraction on at least one material property.

As the Company’s material properties having only Mineral Resources are still in the exploration stage, the Company continues 
to expense most amounts that would normally be capitalized and subsequently depreciated or depleted over the life of Mineral 
Reserve-based mining operations. Items, such as the construction of wellfields and related header houses, additions to recovery 
facilities and advancement of properties, are expensed in the period incurred. As a result, the Company’s consolidated financial 
statements may not be directly comparable to the financial statements of mining companies having numerous Mineral Reserves 
in the development stage or production stage.

b.      Resource and reserve estimates utilized

The Company utilizes estimates of its Mineral Resources and Mineral Reserves based on information compiled by Qualified 
Persons, as defined by S-K 1300. Geological information relating to the size, depth and shape of the deposits requires complex 
geological  judgments  to  interpret.  The  estimation  of  future  cash  flows  related  to  Mineral  Resources  and  Mineral  Reserves  is 
based  upon  a  number  of  factors,  such  as  estimates  of  future  uranium  prices,  future  construction  and  operating  costs  and 
geological  assumptions  and  judgments  made  in  estimating  the  size  and  grade  of  the  Mineral  Resource  or  Mineral  Reserve. 
Changes in the Mineral Resource and Mineral Reserve estimates may impact the carrying value of mining and recovery assets, 
goodwill, reclamation and remediation obligations and depreciation and impairment. 

Following  the  SEC’s  codification  of  S-K  1300,  which  represented  significant  changes  by  the  SEC  to  the  existing  mining 
disclosure framework to better align it with international industry and regulatory practice, the Company, in March 2022, filed 
for the first time joint S-K 1300/NI 43-101 Technical Report Summaries for the following Projects: Sheep Mountain, Nichols 
Ranch, Alta Mesa, Pinyon Plain, Roca Honda, Bullfrog and La Sal, thereby replacing their previously filed NI 43-101 reports. 
In response to three SEC Staff Comments set forth in a letter to the Company, dated December 21, 2022, the Company filed 
amended joint S-K 1300/NI 43-101 technical report summary for the Sheep Mountain and Nichols Ranch Projects as Exhibits 
96.1 and Exhibit 96.5 to its Annual Report on Form 10-K for the year ended December 31, 2022 (the “2022 Annual Report”), 
which  are  also  filed  as  Exhibits  96.1  and  96.5  to  this  Annual  Report.  The  Company  also  replaced  its  February  22,  2022 
“Technical Report on the Pinyon Plain Project, Coconino County, Arizona, USA” with the Project’s first Prefeasibility Study, 
filed as Exhibit 96.2 to its 2022 Annual Report and also is S-K 1300/NI 43-101 compliant, which is also filed as Exhibit 96.2 to 
this  Annual  Report.  These  three  new  technical  report  summaries  have  resulted  in  the  following  material  adjustments  to  the 
Mineral Reserve and Mineral Resource estimates, as compared to the estimates set out in the Company’s Annual Report for the 
year ended December 31, 2021:

•

•

•

Pinyon  Plain:  the  Measured  Mineral  Resources  (uranium)  decreased  from  55,000  pounds  of  U3O8  to  0.0  pounds  of 
U3O8;  the  Indicated  Mineral  Resources  (uranium)  decreased  from  2,347,000  pounds  of  U3O8  to  703,000  pounds  of 
U3O8; the Inferred Mineral Resources (uranium) decreased from 126,000 pounds of U3O8 to 48,000 pounds of U3O8; 
the total uranium Mineral Resources decreased from 2,528,000 pounds of U3O8 to 751,000 pounds of U3O8; and the 
average grade of the uranium Mineral Resources increased from 0.85% U3O8 to 0.89% U3O8;

Pinyon Plain: the Measured, Indicated and Inferred Mineral Resources related to copper remained unchanged;

Pinyon Plain: the Proven Mineral Reserves (uranium) increased from 0.0 pounds U3O8 to 50,800 pounds of U3O8; the 
Probable Mineral Reserves (uranium) increased from 0.0 pounds U3O8 to 1,517,000 pounds of U3O8; the total uranium 
Mineral Reserves increased from 0.0 pounds of U3O8 to 1,567,800 pounds of U3O8 at an average grade of 0.58% U3O8; 
and

The Mineral Resources attributed to the Alta Mesa Project, which was sold to enCore on February 14, 2023, See “Part I, Item 1. 
Description  of  Business  -  Material  Transactions,”  remain  in  this  disclosure  because  they  were  held  by  the  Company  on 
December 31, 2022. At the time of the filing of this disclosure they will no longer be attributed to the Company.

Mineral Resources were reported for non-material properties in 2021 and were not covered by the joint S-K 1300/NI 43-101 
reports. No changes have been made to the materiality of these properties and no Mineral Resources were reported in 2022.

155

 c.      Depreciation of mining and recovery assets acquired

For mining and recovery assets actively extracting and recovering uranium, we depreciate the acquisition costs of the mining 
and  recovery  assets  on  a  straight-line  basis  over  our  estimated  lives  of  the  mining  and  recovery  assets.  The  process  of 
estimating the useful life of the mining and recovery assets requires significant judgment in evaluating and assessing available 
geological, geophysical, engineering and economic data, projected rates of extraction and recovery, estimated commodity price 
forecasts and the timing of future expenditures, all of which are, by their very nature, subject to interpretation and uncertainty.

Changes  in  these  estimates  may  materially  impact  the  carrying  value  of  the  Company’s  mining  and  recovery  assets  and  the 
recorded amount of depreciation.

 d.      Impairment testing of mining and recovery assets

We undertake a review of the carrying values of our mining and recovery assets whenever events or changes in circumstances 
indicate  that  their  carrying  values  may  exceed  their  estimated  net  recoverable  amounts  determined  by  reference  to  estimated 
future operating results and undiscounted net cash flows. An impairment loss is recognized when the carrying value of a mining 
or  recovery  asset  is  not  recoverable  based  on  this  analysis.  In  undertaking  this  review,  we  are  required  to  make  significant 
estimates of, among other things, future production and sale volumes, forecasted commodity prices, future operating and capital 
costs and reclamation costs to the end of the mining asset’s life. These estimates are subject to various risks and uncertainties, 
which may ultimately have an impact on the expected recoverability of the carrying values of mining and recovery assets. We 
have not recorded an impairment loss related to our mining and recovery assets for the years ended December 31, 2023, 2022 
and 2021.

 e.     Asset retirement obligations

Asset retirement obligations are recorded as a liability when an asset that will require reclamation and remediation is initially 
acquired. For disturbances created on a property owned that will require future reclamation and remediation, we record asset 
retirement obligations for such disturbance when occurred. We have accrued our best estimate of the cost to decommission our 
mining  and  milling  properties  in  accordance  with  existing  laws,  contracts  and  other  policies.  The  estimate  of  future  costs 
involves  a  number  of  estimates  relating  to  timing,  type  of  costs,  mine  closure  plans  and  review  of  potential  methods  and 
technical  advancements.  Furthermore,  due  to  uncertainties  concerning  environmental  remediation,  the  ultimate  cost  of  our 
decommissioning liability could differ from the amounts provided. The estimate of our obligation is subject to change due to 
amendments to applicable laws and regulations and as new information concerning our operations becomes available. We are 
not able to determine the impact on its financial position, if any, of environmental laws and regulations that may be enacted in 
the  future.  Additionally,  the  expected  cash  flows  in  the  future  are  discounted  at  our  estimated  credit-adjusted  risk-free  rate 
based on the periods the Company expects to complete the reclamation and remediation activities. Differences in the expected 
periods of reclamation or in the credit-adjusted risk-free rates used could have a material difference in the actual settlement of 
the obligations compared with the amounts provided.

ITEM 7A. QUANTITATIVE AND QUALITATIVE DISCLOSURES ABOUT MARKET RISK

The Company is exposed to risks associated with commodity prices, interest rates and credit. Commodity price risk is defined 
as the potential loss that we may incur as a result of changes in the market value of uranium, vanadium, and REEs. Interest rate 
risk results from our debt and equity instruments that we issue to provide financing and liquidity for our business. Credit risk 
arises from the extension of credit throughout all aspects of our business. Industry-wide risks can also affect our general ability 
to finance exploration, and development of exploitable resources; such effects are not predictable or quantifiable. Market risk is 
the  risk  to  the  Company  of  adverse  financial  impact  due  to  changes  in  the  fair  value  or  future  cash  flows  of  financial 
instruments as a result of fluctuations in interest rates and foreign currency exchange rates.

Commodity Price Risk

Our profitability is directly related to the market price of uranium, vanadium, REEs and HMC recovered. We may, from time to 
time,  undertake  commodity  and  currency  hedging  programs,  with  the  intention  of  maintaining  adequate  cash  flows  and 
profitability  to  contribute  to  the  long-term  viability  of  the  business.  We  anticipate  selling  forward  in  the  ordinary  course  of 
business  if,  and  when,  we  have  sufficient  assets  and  recovery  to  support  forward  sale  arrangements,  and  forward  sale 
arrangements  are  available  on  suitable  terms.  There  are,  however,  risks  associated  with  forward  sale  programs.  If  we  do  not 
have  sufficient  recovered  product  to  meet  our  forward  sale  commitments,  we  may  have  to  buy  or  borrow  (for  later  delivery 
back  from  recovered  product)  sufficient  product  in  the  spot  market  to  deliver  under  the  forward  sales  contracts,  possibly  at 
higher  prices  than  provided  for  in  the  forward  sales  contracts,  or  potentially  default  on  such  deliveries.  In  addition,  under 
forward contracts, we may be forced to sell at prices that are lower than the prices that may be available on the spot market 

156

when  such  deliveries  are  completed.  Although  we  may  employ  various  pricing  mechanisms  within  our  sales  contracts  to 
manage our exposure to price fluctuations, there can be no assurance that such mechanisms will be successful. There can also 
be no assurance that we will be able to enter into term contracts for future sales of uranium, vanadium, RE Carbonate, separated 
REE oxides or other REE products or HMC at prices or in quantities that would allow us to successfully manage our exposure 
to price fluctuations.

Interest Rate Risk

The Company is exposed to interest rate risk on its cash equivalents, deposits, and restricted cash. The Company does not use 
derivatives to manage interest rate risk. Our interest income is earned in U.S. dollars and is not subject to currency risk. 

Currency Risk

The  foreign  exchange  risk  relates  to  the  risk  that  the  value  of  financial  commitments,  recognized  assets  or  liabilities  will 
fluctuate due to changes in foreign currency rates. The Company does not use any derivative instruments to reduce its exposure 
to  fluctuations  in  foreign  currency  exchange  rates.  As  the  U.S.  Dollar  is  the  functional  currency  of  our  U.S.  operations,  the 
currency  risk  has  been  reduced.  We  maintain  a  nominal  balance  in  Canadian  dollars  and  Brazilian  Real,  resulting  in  a  low 
currency risk relative to our cash and cash equivalent balances. We also hold equity marketable securities in Canadian dollars.

The following table summarizes, in U.S. dollar equivalents, the Company’s major foreign currency (Cdn$/R$) exposures as of 
December 31, 2023 (in thousands):

Cash and cash equivalents

Marketable securities

Total

$ 

$ 

754 

21,407 

22,161 

The table below summarizes a sensitivity analysis for significant unsettled currency risk exposure with respect to our financial 
instruments as of December 31, 2023 with all other variables held constant. It shows how net income would have been affected 
by changes in the relevant risk variables that were reasonably possible at that date (in thousands).

Strengthening net earnings

+1% change in US dollar / Cdn$ or R$ $ 

Weakening net earnings

-1% change in US dollar / Cdn$ or R$ $ 

298 

(298) 

Change for
Sensitivity Analysis

Increase (decrease) in 
Net income

Credit Risk

Credit risk relates to cash and cash equivalents, trade, and other receivables that arise from the possibility that any counterparty 
to an instrument fails to perform. The Company primarily transacts with highly rated counterparties and a limit on contingent 
exposure has been established for any counterparty based on that counterparty’s credit rating. As of December 31, 2023, the 
Company’s  maximum  exposure  to  credit  risk  was  the  carrying  value  of  cash  and  cash  equivalents  and  trade  and  note 
receivables.

157

 
ITEM 8. FINANCIAL STATEMENTS AND SUPPLEMENTARY DATA

ENERGY FUELS INC.
CONSOLIDATED FINANCIAL STATEMENTS
December 31, 2023

Reports of Independent Registered Public Accounting Firm (KPMG LLP, Denver, CO, Auditor Firm ID: 185)
Financial Statements:

Consolidated Statements of Operations and Comprehensive Income (Loss) for the years ended 
December 31, 2023, December 31, 2022 and December 31, 2021
Consolidated Balance Sheets as of December 31, 2023 and December 31, 2022
Consolidated Statements of Changes in Equity for the years ended December 31, 2023, December 31, 
2022 and December 31, 2021
Consolidated Statements of Cash Flows for the years ended December 31, 2023, December 31, 2022 
and December 31, 2021
Notes to the Consolidated Financial Statements

159

161

162
163

165
167

158

Report of Independent Registered Public Accounting Firm

To the Shareholders and Board of Directors
Energy Fuels Inc.:

Opinions on the Consolidated Financial Statements and Internal Control Over Financial Reporting

We  have  audited  the  accompanying  consolidated  balance  sheets  of  Energy  Fuels  Inc.  and  subsidiaries  (the 
Company)  as  of  December  31,  2023  and  2022,  the  related  consolidated  statements  of  operations  and 
comprehensive income (loss), changes in equity, and cash flows for each of the years in the three-year period 
ended December 31, 2023, and the related notes (collectively, the consolidated financial statements). We also 
have audited the Company’s internal control over financial reporting as of December 31, 2023, based on criteria 
established  in  Internal  Control  –  Integrated  Framework  (2013)  issued  by  the  Committee  of  Sponsoring 
Organizations of the Treadway Commission.

In our opinion, the consolidated financial statements referred to above present fairly, in all material respects, the 
financial position of the Company as of December 31, 2023 and 2022, and the results of its operations and its 
cash  flows  for  each  of  the  years  in  the  three-year  period  ended  December  31,  2023,  in  conformity  with  U.S. 
generally accepted accounting principles. Also in our opinion, the Company maintained, in all material respects, 
effective  internal  control  over  financial  reporting  as  of  December  31,  2023  based  on  criteria  established  in 
Internal  Control  –  Integrated  Framework  (2013)  issued  by  the  Committee  of  Sponsoring  Organizations  of  the 
Treadway Commission.

Basis for Opinions

The  Company’s  management  is  responsible  for  these  consolidated  financial  statements,  for  maintaining 
effective internal control over financial reporting, and for its assessment of the effectiveness of internal control 
over financial reporting, included in the accompanying Management's Report on Internal Control over Financial 
Reporting. Our responsibility is to express an opinion on the Company’s consolidated financial statements and 
an  opinion  on  the  Company’s  internal  control  over  financial  reporting  based  on  our  audits.  We  are  a  public 
accounting firm registered with the Public Company Accounting Oversight Board (United States) (PCAOB) and 
are required to be independent with respect to the Company in accordance with the U.S. federal securities laws 
and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.

We  conducted  our  audits  in  accordance  with  the  standards  of  the  PCAOB.  Those  standards  require  that  we 
plan  and  perform  the  audits  to  obtain  reasonable  assurance  about  whether  the  consolidated  financial 
statements  are  free  of  material  misstatement,  whether  due  to  error  or  fraud,  and  whether  effective  internal 
control over financial reporting was maintained in all material respects.

Our  audits  of  the  consolidated  financial  statements  included  performing  procedures  to  assess  the  risks  of 
material misstatement of the consolidated financial statements, whether due to error or fraud, and performing 
procedures  that  respond  to  those  risks.  Such  procedures  included  examining,  on  a  test  basis,  evidence 
regarding  the  amounts  and  disclosures  in  the  consolidated  financial  statements.  Our  audits  also  included 
evaluating the accounting principles used and significant estimates made by management, as well as evaluating 
the  overall  presentation  of  the  consolidated  financial  statements.  Our  audit  of  internal  control  over  financial 
reporting included obtaining an understanding of internal control over financial reporting, assessing the risk that 
a material weakness exists, and testing and evaluating the design and operating effectiveness of internal control 
based  on  the  assessed  risk.  Our  audits  also  included  performing  such  other  procedures  as  we  considered 
necessary in the circumstances. We believe that our audits provide a reasonable basis for our opinions.

Definition and Limitations of Internal Control Over Financial Reporting

A  company’s  internal  control  over  financial  reporting  is  a  process  designed  to  provide  reasonable  assurance 
regarding the reliability of financial reporting and the preparation of financial statements for external purposes in 
accordance with generally accepted accounting principles. A company’s internal control over financial reporting 
includes those policies and procedures that (1) pertain to the maintenance of records that, in reasonable detail, 
accurately  and  fairly  reflect  the  transactions  and  dispositions  of  the  assets  of  the  company;  (2)  provide 
reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements 
in  accordance  with  generally  accepted  accounting  principles,  and  that  receipts  and  expenditures  of  the 
company are being made only in accordance with authorizations of management and directors of the company; 

159

and (3) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use, 
or disposition of the company’s assets that could have a material effect on the financial statements.

Because  of  its  inherent  limitations,  internal  control  over  financial  reporting  may  not  prevent  or  detect 
misstatements. Also, projections of any evaluation of effectiveness to future periods are subject to the risk that 
controls may become inadequate because of changes in conditions, or that the degree of compliance with the 
policies or procedures may deteriorate.

Critical Audit Matter

The  critical  audit  matter  communicated  below  is  a  matter  arising  from  the  current  period  audit  of  the 
consolidated  financial  statements  that  was  communicated  or  required  to  be  communicated  to  the  audit 
committee  and  that:  (1)  relate  to  accounts  or  disclosures  that  are  material  to  the  consolidated  financial 
statements and (2) involved our especially challenging, subjective, or complex judgments. The communication 
of a critical audit matter does not alter in any way our opinion on the consolidated financial statements, taken as 
a whole, and we are not, by communicating the critical audit matter below, providing a separate opinion on the 
critical audit matter or on the accounts or disclosures to which it relates.

Asset retirement obligation costs

As  discussed  in  Note  8  to  the  consolidated  financial  statements,  the  Company  recorded  an  asset 
retirement  obligation  (ARO)  liability  of  $10.9  million  as  of  December  31,  2023. The  estimate  of  future 
costs involves a number of estimates relating to timing, planned decommissioning activities, and review 
of potential methods and technical advancements.

We identified the evaluation of the future costs for decommissioning activities as a critical audit matter. 
Specialized  skills  and  knowledge  were  required  to  evaluate  the  Company’s  determination  of 
decommissioning activities and their related costs to satisfy ARO. In addition, the ARO was sensitive to 
minor changes to significant assumptions, such as decommissioning cost.

The  following  are  the  primary  procedures  we  performed  to  address  this  critical  audit  matter.  We 
evaluated  the  design  and  tested  the  operating  effectiveness  of  certain  internal  controls  related  to  the 
Company’s ARO process, including certain controls related to the estimation of decommissioning costs. 
We tested the determination of the planned decommissioning activities used in the estimate by inquiring 
of management, inspecting minutes of the board of directors, and reviewing underlying documentation. 
We  involved  environmental  professionals  with  specialized  skills  and  knowledge,  who  assisted  in 
evaluating  the  Company’s  planned  remediation  activities  for  certain  sites  and  changes  in  the  liability 
and  assumptions  from  those  used  in  the  prior  period,  including  comparing  the  Company’s  planned 
remediation activities to those communicated to regulatory authorities.

/s/ KPMG LLP

We have served as the Company’s auditor since 2017. 

Denver, Colorado
February 23, 2024

160

ENERGY FUELS INC.
Consolidated Statements of Operations and Comprehensive Income (Loss) 
(Expressed in thousands of U.S. dollars, except per share amounts)

Years Ended December 31,

2023

2022

2021

$ 

33,278  $ 

—  $ 

871 

2,848 

931 

37,928 

15,318 

551 

2,312 

— 

18,181 

15,531 

7,476 

1,192 

27,915 

8,778 

2,122 

1,615 

12,515 

— 

3,769 

1,317 

2,758 

7,844 

9,346 

13,221 

1,556 

25,486 

(32,367)   

(44,938)   

119,257 

13,142 

132,399 
100,032 

(276)   

366 

(15,372)   

(15,006)   
(59,944)   

— 

99,756 

(59,944)   

— 
— 

(3,889)   
(3,889)   

99,756  $ 

(63,833)  $ 

99,862  $ 

(59,849)  $ 

(106)   
99,756  $ 

(95)   
(59,944)  $ 

99,862  $ 

(63,738)  $ 

(106)   

(95)   

99,756  $ 

(63,833)  $ 

0.63  $ 

0.62  $ 

(0.38)  $ 

(0.38)  $ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

— 

74 

1,385 

1,725 

3,184 

— 

48 

1,235 

531 

1,814 

10,750 

9,462 

1,284 

15,299 

(35,425) 

35,733 

1,140 

36,873 
1,448 
— 

1,448 

(365) 
(365) 

1,083 

1,541 

(93) 
1,448 

1,176 

(93) 

1,083 

0.01 

0.01 

Revenues

Uranium concentrates

Vanadium concentrates

RE Carbonate

Alternate Feed Materials, processing and other

Total revenues 

Costs applicable to revenues

Costs applicable to uranium concentrates

Costs applicable to vanadium concentrates

Costs applicable to RE Carbonate

Underutilized capacity production costs applicable to RE Carbonate

Total costs applicable to revenues

Other operating costs and expenses

Exploration, development and processing

Standby

Accretion of asset retirement obligations

Selling, general and administration

Total operating loss

Other income (loss)

Gain on sale of assets (Note 7)

Other income (loss) (Note 13)

Total other income (loss)
Income (loss) before income taxes
Income tax expense

Net income (loss)

Items that may be reclassified in the future to income (loss)

Foreign currency translation adjustment
Other comprehensive loss

Comprehensive income (loss)
Net income (loss) attributable to:

Owners of the Company

Non-controlling interests

Comprehensive income (loss) attributable to:

Owners of the Company

Non-controlling interests

Basic net income (loss) per common share (Note 10)

Diluted net income (loss) per common share (Note 10)

See accompanying notes to the consolidated financial statements.

161

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ENERGY FUELS INC.
Consolidated Balance Sheets
(Expressed in thousands of U.S. dollars, except share amounts)

ASSETS
Current assets

Cash and cash equivalents 

Marketable securities (Notes 3 and 15)
Trade and other receivables, net of allowance for credit losses of $223 and $223 
as of December 31, 2023 and 2022, respectively

Inventories (Note 5)

Prepaid expenses and other current assets 

Property, plant and equipment and other assets held for sale, net (Note 7)

Total current assets

Mineral properties (Note 7)

Property, plant and equipment, net (Note 7)

Inventories (Note 5)

Operating lease right of use asset

Investments (Note 6)

Other long-term receivables

Restricted cash (Note 8)

Total assets

LIABILITIES & EQUITY

Current liabilities

Accounts payable and accrued liabilities (Note 13)

Operating lease liability

Deposits for assets held for sale

Asset retirement obligation and other liabilities held for sale (Note 8)

Total current liabilities

Operating lease liability

Asset retirement obligations (Note 8)
Deferred revenue

Total liabilities
Equity

Share capital

Common shares, without par value, unlimited shares authorized; shares 
issued and outstanding 162,659,155 and 157,682,531 as of December 31, 
2023 and 2022, respectively

Accumulated deficit

Accumulated other comprehensive loss

Total shareholders' equity

Non-controlling interests

Total equity

Total liabilities and equity

Commitments and contingencies (Note 14)

See accompanying notes to the consolidated financial statements.

162

$ 

$ 

December 31,

2023

2022

$ 

57,445  $ 

133,044 

816 

38,868 

2,522 

— 

232,695 

119,581 

26,123 

1,852 

1,219 

1,356 

1,534 

17,579 

62,820 

12,192 

519 

38,155 

9,529 

12,375 

135,590 

83,539 

12,662 

2,465 

1,376 

19,329 

1,537 

17,449 

401,939  $ 

273,947 

10,161  $ 

199 

— 

— 

10,360 

1,120 

10,922 
332 

22,734 

733,450 

(356,258) 

(1,946) 

375,246 

3,959 

379,205 

6,929 

59 

6,000 

5,636 

18,624 

1,319 

9,595 
— 

29,538 

698,493 

(456,120) 

(1,946) 

240,427 

3,982 

244,409 

273,947 

$ 

401,939  $ 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ENERGY FUELS INC.
Consolidated Statements of Changes in Equity
(Expressed in thousands of U.S. dollars, except share amounts)

Balance as of December 31, 
2020

Net income

Other comprehensive loss

Shares issued for cash by at-the-
market offering

Share issuance cost

Share-based compensation

Shares issued for exercise of 
stock options

Shares issued for the vesting of 
restricted stock units

Cash paid to fund employee 
income tax withholding due 
upon vesting of restricted stock 
units

Shares issued for exercise of 
warrants

Shares issued for consulting 
services

Shares issued for exercise of 
stock appreciation rights

Cash paid to settle and fund 
employee income tax 
withholding due upon exercise 
of stock appreciation rights

Contributions attributable to 
non-controlling interest

Balance as of December 31, 
2021

Net loss

Other comprehensive loss

Shares issued for cash by at-the-
market offering

Share issuance cost

Share-based compensation

Shares issued for exercise of 
stock options

Shares issued for the vesting of 
restricted stock units
Cash paid to fund employee 
income tax withholding due 
upon vesting of restricted stock 
units

Shares issued for consulting 
services

Shares issued for exercise of 
stock appreciation rights
Cash paid to settle and fund 
employee income tax 
withholding due upon exercise 
of stock appreciation rights

Contributions attributable to 
non-controlling interest

Balance as of December 31, 
2022

Net income (loss)

Share-based compensation

Common Stock

Shares

Amount

Accumulated 
Earnings 
(Deficit)

Accumulated
Other
Comprehensive
Income (Loss)

Total
Shareholders'
Equity

Non-
Controlling
Interests

Total Equity

  134,311,033  $ 

549,317  $ 

(397,812)  $ 

2,308  $ 

153,813  $ 

3,733  $ 

157,546 

— 

— 

— 

— 

16,627,512 

108,653 

— 

— 

(2,445) 

2,158 

775,814 

2,290 

478,781 

— 

— 

(659) 

4,016,023 

26,603 

47,393 

5,643 

— 

— 

242 

— 

(256) 

— 

1,541 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

(365) 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

1,541 

(365) 

108,653 

(2,445) 

2,158 

2,290 

— 

(659) 

26,603 

242 

— 

(256) 

— 

(93) 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

311 

1,448 

(365) 

108,653 

(2,445) 

2,158 

2,290 

— 

(659) 

26,603 

242 

— 

(256) 

311 

  156,262,199  $ 

685,903  $ 

(396,271)  $ 

1,943  $ 

291,575  $ 

3,951  $ 

295,526 

— 

— 

769,779 

— 

— 

256,314 

362,350 

— 

— 

8,068 

(182) 

4,641 

753 

— 

— 

(884) 

28,254 

3,635 

— 

— 

205 

— 

(11) 

— 

(59,849) 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

(3,889) 

(59,849) 

(3,889) 

(95) 

— 

(59,944) 

(3,889) 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

8,068 

(182) 

4,641 

753 

— 

(884) 

205 

— 

(11) 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

126 

8,068 

(182) 

4,641 

753 

— 

(884) 

205 

— 

(11) 

126 

  157,682,531  $ 

698,493  $ 

(456,120)  $ 

(1,946)  $ 

240,427  $ 

3,982  $ 

244,409 

— 

— 

— 

99,862 

4,625 

— 

— 

— 

99,862 

(106) 

99,756 

4,625 

— 

4,625 

163

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Shares issued for the vesting of 
restricted stock units

Cash paid to fund employee 
income tax withholding due 
upon vesting of restricted stock 
units

Shares issued for exercise of 
stock options
Shares issued for exercise of 
stock options from consulting 
services

Shares issued for exercise of 
stock appreciation rights

Cash paid to settle and fund 
employee income tax 
withholding due upon exercise 
of stock appreciation rights

Shares issued for cash by at-the-
market offering

Share issuance cost

Contributions attributable to 
non-controlling interest

Balance as of December 31, 
2023

312,662 

— 

— 

(918) 

207,866 

140,672 

267,592 

718 

252 

— 

— 

(1,533) 

4,047,832 

— 

— 

32,545 

(732) 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

(918) 

718 

252 

— 

(1,533) 

32,545 

(732) 

— 

— 

— 

— 

— 

— 

— 

— 

— 

83 

— 

(918) 

718 

252 

— 

(1,533) 

32,545 

(732) 

83 

  162,659,155  $ 

733,450  $ 

(356,258)  $ 

(1,946)  $ 

375,246  $ 

3,959  $ 

379,205 

See accompanying notes to the consolidated financial statements.

164

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ENERGY FUELS INC.
Consolidated Statements of Cash Flows
(Expressed in thousands of U.S. dollars)

OPERATING ACTIVITIES

Net income (loss) for the period
Adjustments to reconcile net income (loss) to net cash used in operating 
activities:

Depletion, depreciation and amortization

Share-based compensation

Accretion of asset retirement obligations

Unrealized foreign exchange (gain) loss

Unrealized (gain) loss on investments

Realized loss on investments

Realized gain on marketable securities

Gain on sale of assets

Realized gain on convertible note redemptions and sale

Change in value of warrant liabilities

Other, net

Changes in current assets and liabilities

Marketable securities

Inventories

Trade and other receivables

Prepaid expenses and other current assets

Accounts payable and accrued liabilities

Net cash used in operating activities

INVESTING ACTIVITIES

Additions to property, plant and equipment

Additions to mineral properties

Acquisition of mineral properties

Purchases of marketable securities
Maturities of marketable securities

Purchase of investments without a readily determinable fair value
Deposits for assets held for sale

Proceeds from sale of assets

Proceeds from convertible note redemptions and sale, net

Years Ended December 31,

2023

2022

2021

$ 

99,756  $ 

(59,944)  $ 

1,448 

2,751 

4,625 

1,192 

3,269 

4,641 

1,556 

(431)   

(2,080)   

3,189 

2,158 

1,284 

129 

(15,472)   

16,808 

(6,311) 

10,491 

(1,141)   

— 

— 

— 

— 

(119,257)   

(366)   

(35,733) 

(1,430)   

— 

84 

530 

(100)   

(237)   

423 

2,807 

— 

— 

(93)   

456 

(8,571)   

1,837 

(8,886)   

1,671 

— 

8,078 

(156) 

(795) 

(3,219) 

(1,249) 

(257) 

2,140 

(15,409)   

(49,702)   

(29,294) 

(1,996)   

(1,368) 

(15,437)   

(6,782)   

(22,491)   

(174,622)   
79,041 

(1,324)   
— 

56,875 

60,887 

— 

— 

(11,435)   

— 

— 
6,000 

366 

— 

— 

— 

— 
2,554 

— 
— 

2,000 

— 

3,186 

Net cash provided by (used in) investing activities

(23,853)   

(7,065)   

FINANCING ACTIVITIES

Issuance of common shares for cash, net of issuance costs
Cash paid to fund employee income tax withholding due upon vesting of 
restricted stock units

Cash received from exercise of stock options

Cash received from exercise of warrants
Cash paid to settle and fund employee income tax withholding due upon 
exercise of stock appreciation rights

Cash received from non-controlling interest

31,813 

7,886 

106,208 

(918)   

(884)   

970 

— 

(1,533)   

83 

753 

— 

(11)   

126 

(538) 

2,375 

9,840 

(256) 

311 

165

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Net cash provided by financing activities

Effect of exchange rate fluctuations on cash held in foreign currencies

Less: restricted cash related to assets held for sale

Plus: release of restricted cash related to sale of assets

Net change in cash, cash equivalents and restricted cash

Cash, cash equivalents and restricted cash, beginning of period
CASH, CASH EQUIVALENTS AND RESTRICTED CASH, END OF 
PERIOD

30,415 

12 

— 

3,590 

7,870 

(66)   

(3,590)   

— 

117,940 

5 

— 

— 

(5,245)   

(52,553)   

80,269 

132,822 

91,837 

40,985 

$ 

75,024  $ 

80,269  $ 

132,822 

Supplemental disclosure of cash flow information:

Cash paid during the period for interest
Increase (decrease) in accrued capital expenditures and accounts payable 
for property, plant and equipment

$ 

186  $ 

25  $ 

701 

(161)   

Non-cash investing and financing transactions:

Issuance of common shares for consulting services

Acquisition of convertible note

See accompanying notes to the consolidated financial statements.

$ 

—  $ 

205  $ 

59,457 

— 

54 

182 

242 

— 

166

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ENERGY FUELS INC.
NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
(Tabular amounts expressed in thousands of U.S. dollars except share and per share amounts)

1. 

THE COMPANY AND DESCRIPTION OF BUSINESS

Energy  Fuels  Inc.  was  incorporated  under  the  laws  of  the  Province  of  Alberta  and  was  continued  under  the  Business 
Corporations Act (Ontario).

Energy  Fuels  Inc.  and  its  subsidiary  companies  (collectively,  the  “Company”  or  “Energy  Fuels”)  are  together  engaged  in 
conventional and in situ recovery (“ISR”) uranium extraction, recovery and sales of uranium from mineral properties, and the 
recycling  of  uranium-bearing  materials  generated  by  third  parties,  along  with  the  exploration,  permitting  and  evaluation  of 
uranium  properties  in  the  United  States  (the  “U.S.”).  As  a  part  of  these  activities,  the  Company  also  acquires,  explores, 
evaluates  and,  if  warranted,  permits  uranium  properties.  The  Company’s  final  uranium  product,  uranium  oxide  concentrate 
(“U3O8” or “uranium concentrate”), known more commonly as “yellowcake,” is sold to customers for further processing into 
fuel for nuclear reactors. The Company also produces vanadium pentoxide (“V2O5”) as a co-product of uranium at the White 
Mesa Mill (the “White Mesa Mill” or the “Mill”), from certain of its Colorado Plateau properties and at times from solutions in 
its Mill tailings impoundment system, each as market conditions warrant. The Mill is also ramping up to commercial production 
of rare earth element (“REE”) carbonate (“RE Carbonate”) from various uranium- and REE-bearing materials acquired from 
third  parties  and  is  working  on  modifications  and  enhancements  to  its  existing  infrastructure  for  the  potential  production  of 
separated REE oxides. Additionally, the Company is evaluating the potential to recover radioisotopes from its existing uranium 
process streams at the Mill for use in targeted alpha therapy (“TAT”) therapeutics for the treatment of cancer. 

With  its  uranium,  vanadium,  REE  and  potential  radioisotope  production,  the  Mill  is  working  to  establish  itself  as  a  critical 
minerals hub in the U.S.

Uranium is the fuel for carbon-free, emission-free baseload nuclear power – one of the cleanest forms of energy in the world; 
REEs  are  used  to  manufacture  permanent  magnets  for  electric  vehicles  (“EVs”),  wind  turbines  and  other  clean  energy  and 
modern technologies. Energy Fuels produces both. Concurrently, the Company's recycling program (known as its “Alternate 
Feed Program”), works to reduce the levels of new production and natural disturbances needed to meet global energy demand 
by  recycling  feed  sources  that  would  have  otherwise  been  lost  to  direct  disposal  and  extracting  additional  valuable  minerals 
from them. In short, through its uranium and REE production and long-standing recycling program, Energy Fuels works to help 
address global climate change by producing materials that ultimately reduce reliance on carbon dioxide (“CO2”) emitters, such 
as  fossil  fuels,  while  also  ensuring  that  materials  already  extracted  but  only  partially  utilized  are  instead  used  to  the  fullest 
extent  practicable  so  as  to  limit  the  global  mining  footprint  and  reduce  the  number  of  constituents  ultimately  disposed  of. 
Additionally, certain radioisotopes, which the Company is evaluating for recovery from its uranium processing streams, have 
the potential to provide the isotopes needed for emerging TAT cancer-fighting therapeutics.

As  of  December  31,  2023,  the  Company  is  a  “development  stage  issuer”  as  defined  by  S-K  1300,  as  it  is  engaged  in  the 
preparation of Mineral Reserves for extraction of at least one material property.

Mining Activities

The  Company's  mining  activities  consist  of  the  Mill,  multiple  conventional  mining  projects  and  an  ISR  mining  project 
(complete  with  an  ISR  recovery  facility  on  standby).  The  conventional  mining  projects  are  located  on  the  Colorado  Plateau, 
including the Pinyon Plain, Whirlwind, La Sal, Bullfrog, Arizona Strip and Roca Honda Projects, all of which are in the vicinity 
of the Mill, as well as the Sheep Mountain Project located in Wyoming and the Bahia Project (defined in Note 7 – Property, 
Plant  and  Equipment  and  Mineral  Properties)  located  in  Brazil.  The  Company's  Nichols  Ranch  Project  (including  the  Jane 
Dough and Hank Satellite deposits) is an ISR project located in Wyoming.

As  of  December  31,  2023,  the  Company  was  performing  rehabilitation  and  development  work  on  its  La  Sal,  Whirlwind  and 
Pinyon Plain Projects, as well as exploration drilling and analysis at its Bahia Project. Other conventional mining projects in the 
vicinity of the Mill and Sheep Mountain are on standby and are being evaluated for continued mining and other activities and/or 
are  in  the  process  of  being  permitted.  The  Mill  continues  to  receive  third-party  uranium-bearing  mineralized  materials  from 
mining and other industry activities for its own processing and recycling, while also expanding its REE initiatives and pursuing 
its TAT cancer-fighting therapeutics initiatives.

167

2. 

SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES

Basis of Presentation

The consolidated financial statements have been prepared in accordance with generally accepted accounting principles in the 
United States (“U.S. GAAP”) and are presented in thousands of U.S. dollars (“USD”), except for share and per share amounts. 
Certain footnote disclosures, where indicated, have share prices that are presented in Canadian dollars (“Cdn$”).

Use of Estimates

The preparation of the Company’s consolidated financial statements in accordance with U.S. GAAP requires the Company to 
make estimates and assumptions that affect the reported amounts of assets and liabilities and the related disclosure of contingent 
assets  and  liabilities  as  of  the  date  of  the  consolidated  financial  statements  and  the  reported  amounts  of  expenses  during  the 
reporting period. The Company must make these estimates and assumptions because certain information used is dependent on 
future events, cannot be calculated with a high degree of precision from data available or simply cannot be readily calculated 
based on generally accepted methodologies.

The  more  significant  areas  requiring  the  use  of  management  estimates  and  assumptions  relate  to  expectations  of  the  future 
prices  of  uranium  and  REE  as  well  as  estimates  of  recoverable  mineral  resources  that  are  the  basis  for  future  cash  flow 
estimates utilized in assessing fair value for business combinations and impairment calculations; the determination of whether 
an  acquisition  represents  a  business  combination  or  an  asset  acquisition;  the  use  of  management  estimates  and  assumptions 
related to environmental, reclamation and closure obligations; marketable securities and derivative instruments; and share-based 
compensation expense. Actual results may differ significantly from these estimates.

Principles of Consolidation

These  consolidated  financial  statements  include  the  accounts  of  the  Company  together  with  subsidiaries  controlled  by  the 
Company. Intercompany transactions, balances and unrealized gains and losses on transactions between the Company and its 
subsidiaries are eliminated. Management has evaluated how the Company is organized and managed and has identified that the 
Company is organized and managed as one segment. The functional currency of the Company’s operations is the USD.

Extracting and Recovery Activities While in the Development Stage

The Company extracts or recovers mineralized uranium from mining activities, mill tailings, pond solutions and Alternate Feed 
Materials, resulting in saleable uranium concentrates from its Mill and, when operating, its Nichols Ranch Project. While the 
Company has established the existence of multiple Mineral Resources and extracts and processes saleable uranium from these 
operations,  the  Company  has  only  established  proven  or  probable  Mineral  Reserves,  as  defined  under  SEC  S-K  1300,  at  its 
Sheep Mountain and Pinyon Plain projects.

Costs incurred before the establishment of proven and probable reserves are expensed and classified as development expense. 
As  a  result,  the  Company’s  consolidated  financial  statements  may  not  be  directly  comparable  to  the  financial  statements  of 
mining companies in the development stage having multiple Mineral Reserves or in the production stage.

Impairment of Long-Lived Assets

The Company reviews and evaluates its long-lived assets for impairment when events or changes in circumstances indicate that 
the related carrying amounts may not be recoverable. Mineral properties are monitored for impairment based on factors such as 
mineral  prices,  government  regulation  and  taxation,  the  Company's  continued  right  to  explore  the  area,  exploration  reports, 
assays, technical reports, drill results and its continued plans to fund exploration programs on the property.

At each reporting date, the Company conducts a review of potential triggering events for all its mineral properties. When events 
or  changes  in  circumstances  indicate  that  the  related  carrying  amounts  may  not  be  recoverable,  the  Company  carries  out  a 
review  and  evaluation  of  its  long-lived  assets  in  accordance  with  its  accounting  policy.  Impairment  losses  are  recognized  in 
profit or loss.

Recoverability  is  measured  by  comparing  the  undiscounted  future  net  cash  flows  to  the  net  book  value.  When  the  net  book 
value exceeds future net undiscounted cash flows, the fair value is compared to the net book value and an impairment loss may 
be  measured  and  recorded  based  on  the  excess  of  the  net  book  value  over  fair  value.  Fair  value  for  operating  mines  is 
determined using a combined approach, which uses a discounted cash flow model for the existing operations and non-operating 
properties  with  available  cash  flow  models  and  a  market  approach  for  the  fair  value  assessment  of  non-operating  and 
exploration  properties  where  no  cash  flow  model  is  available.  Future  cash  flows  are  estimated  based  on  quantities  of 

168

recoverable  mineralized  material,  expected  uranium  or  REE  prices  (considering  current  and  historical  prices,  trends  and 
estimates),  production  levels,  operating  costs,  capital  requirements  and  reclamation  costs,  all  based  on  life-of-mine  plans.  In 
estimating future cash flows, assets are grouped at the lowest level, for which there are identifiable cash flows that are largely 
independent of future cash flows from other asset groups. The Company's estimates of future cash flows are based on numerous 
assumptions, and it is possible that actual future cash flows will be significantly different than the estimates, as actual future 
quantities of recoverable minerals, uranium prices, production levels, costs and capital are each subject to significant risks and 
uncertainties.

No impairment of property, plant and equipment and mineral properties were recorded during the years ended December 31, 
2023, 2022 and 2021.

Cash, Cash Equivalents and Restricted Cash

Cash and cash equivalents consist of all cash balances and highly liquid investments with an original maturity of three months 
or less. Because of the short maturity of these investments, the carrying amounts approximate their fair value. Restricted cash is 
excluded from cash and cash equivalents and is included in other current or long-term assets, depending on the nature of the 
restriction. See Note 8 – Asset Retirement Obligations and Restricted Cash for more information.

Marketable Securities

Marketable debt securities consist of excess cash invested in U.S. government notes, U.S. government agencies and tradeable 
certificates of deposits. The Company classifies and accounts for its marketable debt securities under the fair value option. After 
consideration of the Company's risk versus reward objectives, as well as its liquidity requirements, the Company may sell these 
debt securities prior to their stated maturities. As management views these securities as available to support current operations, 
the  Company  classifies  highly  liquid  securities  with  maturities  beyond  12  months  as  current  assets  under  the  caption 
Marketable securities on the Consolidated Balance Sheet. The Company received a secured convertible note (the “Convertible 
Note”) as partial consideration for the Alta Mesa Transaction (defined in Note 7 – Property, Plant and Equipment and Mineral 
Properties). The Company elected the fair value option for the Convertible Note, as it had the option of converting the principal 
due into fully paid and non-assessable common shares of enCore Energy Corp. (“enCore”). During the year ended December 
31,  2023,  the  Convertible  Note  was  partially  redeemed  and  the  remaining  principal  balance  was  sold.  Subsequent  to  initial 
recognition, marketable debt securities are measured at fair value and changes therein are recognized as a component of Other 
income (loss) in the Consolidated Statements of Operations and Comprehensive Income (Loss).

Marketable equity securities consist of investments in publicly traded equity securities. The Company classifies and accounts 
for  its  marketable  equity  securities  as  available-for-sale.  Subsequent  to  initial  recognition,  marketable  equity  securities  are 
measured  at  fair  value  and  changes  therein  are  recognized  as  a  component  of  Other  income  (loss)  in  the  Consolidated 
Statements of Operations and Comprehensive Income (Loss).

Accounts Receivable

Trade accounts receivable are recorded at the invoiced amount and do not bear interest. The Company evaluates its estimate of 
expected credit losses based on historical experience and current and forecasted future economic conditions for each portfolio 
of customers. As of December 31, 2023 and 2022, the Company did not have an allowance for expected credit losses for trade 
accounts receivable.

Inventories

Inventories are valued at the lower of average cost or net realizable value. Net realizable value represents the estimated future 
sales price of the product based on current and long-term prices, less the estimated costs to bring the product to sale. Inventories 
are  comprised  of  stockpiles  or  raw  materials,  work-in-process  inventories  and  finished  goods.  Expenditures  related  to  the 
extraction  and  recovery  of  uranium  concentrates  and  depreciation  of  the  acquisition  cost  of  the  Extracting  and  Recovery 
Operations are inventoried as stockpiles and in-process and concentrate inventories.

Property, Plant and Equipment

Recognition and measurement

Property, plant and equipment is measured at cost less accumulated depreciation and any accumulated impairment losses. Costs 
include  expenditures  that  are  directly  attributable  to  the  acquisition  of  the  asset.  Subsequent  costs  are  included  in  the  asset’s 
carrying amount or recognized as a separate asset, when it is replaced, and the cost of the replacement asset is expensed.

169

Depreciation

Depreciation of property, plant and equipment is calculated using the straight-line method over the estimated useful lives less 
the salvage value of assets. The estimated useful lives of the Company's assets range from 3 to 15 years depending upon the 
asset type. Uncertainties that may impact these estimates of useful lives include, among others, changes in laws and regulations  
or  changes  in  attitudes  or  interpretations  of  such  laws  and  regulations  relating  to  environmental  matters,  restoration  and 
abandonment requirements, economic conditions and supply and demand for the Company’s services in the areas in which it 
operates. When assets are placed into service, management makes estimates with respect to useful lives and salvage values that 
it  believes  are  reasonable.  When  assets  are  retired  or  sold,  the  resulting  gains  or  losses  are  reflected  in  current  earnings  as  a 
component of other income or expense. Salvage values, method of depreciation and useful lives of the assets are reviewed at 
least annually and any change in estimate is applied prospectively.

Non-Operating Assets

Non-operating assets consist of mineral properties and rights, along with data and analyses related to the properties, which are 
in various stages of evaluation and permitting. Costs to acquire the non-operating assets are capitalized at cost or fair value if 
such assets were acquired as part of a business combination.

Mining  activities  for  non-operating  assets  involve  the  search  for  minerals,  the  determination  of  technical  feasibility  and  the 
assessment of commercial viability of an identified resource. Expenditures incurred in relation to such mining activities include 
costs  which  are  directly  attributable  to  researching  and  analyzing  existing  exploration  data;  conducting  geological  studies, 
exploratory drilling and sampling; examining and testing extraction and treatment methods; and completing pre-feasibility and 
feasibility studies. Such expenditures are expensed as incurred.

Mineral properties, that are not held for production, and any related surface access to the minerals generally require periodic 
payments  and/or  certain  expenditures  related  to  the  property  in  order  for  the  Company  to  retain  its  interest  in  the  mineral 
property (collectively, “Holding Costs”). The Company expenses all Holding Costs in the period they are incurred.

Stand-by Properties

Stand-by properties are mineral properties that have extracted mineral resources in the past but are currently non-operating or 
properties, which could extract mineral resources in the future. Expenditures related to these properties are primarily related to 
maintaining  the  assets  and  permits  in  a  condition  that  will  allow  re-start  of  the  operations  or  development  given  appropriate 
commodity prices. All costs related to stand-by assets are expensed as incurred.

The Mill operates on a campaign basis. When the Mill is not recovering material, all related costs are expensed as incurred.

Leases

The  Company  accounts  for  leases  under  Financial  Accounting  Standards  Board  (the  “FASB”)  Accounting  Standard 
Codification (“ASC”) Topic 842, Leases, which requires leases to be recognized as assets and liabilities on the balance sheet for 
the  rights  and  obligations  created  by  all  leases  with  terms  of  more  than  12  months.  The  Company  recognizes  in  the  balance 
sheet a liability to make lease payments (the lease liability) and the right-of-use asset representing the right to the underlying 
asset for the lease term. For leases with a term of twelve months or less, the Company has made an accounting policy election 
by class of underlying asset not to recognize lease assets and lease liabilities. 

Investments

Investments Accounted for at Fair Value

The Company accounts for equity method investments over which the Company exerts significant influence, but not control, 
over the financial and operating policies through the fair value option of FASB ASC Topic 825, Financial Instruments. The 
Company  elected  the  fair  value  option  based  on  practical  expedience,  variances  in  reporting  timelines  and  cost-benefit 
considerations. The cost of such investments is measured at the fair value of the assets given up, shares issued and liabilities 
assumed at the date of acquisition plus costs directly attributable to the acquisition. Subsequent to initial recognition, they are 
measured  at  fair  value.  The  fair  value  of  the  investee’s  common  shares  is  measured  based  on  its  closing  market  price.  The 
Company  uses  the  Black-Scholes  option  pricing  model  to  estimate  the  fair  value  of  its  investment  in  warrants  with  the 
following  assumptions:  (i)  the  investee’s  closing  market  price  on  the  valuation  date,  (ii)  the  risk-free  interest  rate  computed 
based on the U.S. Treasury yield, (iii) an expected term equal to the remaining contractual term, (iv) a dividend yield of zero, 
and  (v)  the  expected  stock  price  volatility  calculated  based  on  the  historical  volatility  of  the  common  shares  of  the  investee. 

170

Changes in the fair value of these investments are recognized in Other income (loss) in the Company’s Consolidated Statements 
of Operations and Comprehensive Income (Loss). See Note 6 – Investments for more information.

Investments Without a Readily Determinable Fair Value

The Company measures equity investments without readily determinable fair values at cost, less any impairment, adjusted for 
observable  price  changes  from  orderly  transactions  for  identical  or  similar  investments  of  the  same  issuer.  See  Note  6  – 
Investments for more information.

Asset Retirement Obligations

The Company’s asset retirement obligations (“ARO”) relate to expected mine, wellfield, plant and mill reclamation and closure 
activities, as well as costs associated with reclamation of exploration drilling. The Company’s activities are subject to numerous 
governmental laws and regulations. Estimates of future reclamation liabilities for ARO are recognized in the period when such 
liabilities  are  incurred.  These  estimates  are  updated  on  a  periodic  basis  and  are  subject  to  changing  laws,  regulatory 
requirements,  technology  and  other  factors,  which  will  be  recognized  when  appropriate.  Liabilities  related  to  site  restoration 
include long-term treatment and monitoring costs and incorporate total expected costs net of recoveries. Expenditures incurred 
to dismantle facilities, restore and monitor closed resource properties are charged against the related ARO.

The present value of AROs is measured by discounting the expected cash flows using a discount factor that reflects the credit-
adjusted risk-free rate of interest, while taking into account an inflation rate. The ARO liability is accreted to full value over 
time through periodic accretion charges recorded to operations as accretion expense. The Company adjusts the estimate of the 
ARO  for  changes  in  the  amount  or  timing  of  underlying  future  cash  outflows.  The  impact  of  these  adjustments  to  the  ARO 
amounts are expensed as incurred.

Warrant Liabilities

The  Company  issued  several  tranches  of  warrants  for  various  equity  transactions  in  2016  all  of  which  were  either  settled  or 
expired in 2021 and thus, no longer outstanding as of December 31, 2022 and 2023. The Company accounted for its warrants 
issued in accordance with FASB ASC Topic 815, Derivative and Hedging (“ASC 815”), which required instruments within its 
scope to be recorded on the balance sheet as either an asset or liability measured at its fair value, with changes in fair value 
recognized  in  earnings.  In  accordance  with  ASC  815,  the  Company  classified  the  warrants  as  liabilities.  The  warrants  were 
subject to re-measurement at each balance sheet date, with any change in fair value recognized as a component of Other income 
(loss) in the Consolidated Statements of Operations and Comprehensive Income (Loss). The Company estimated the fair value 
of these warrants using market prices, if available, or the Black-Scholes option pricing model. The Black-Scholes option pricing 
model  is  based  on  the  estimated  market  value  of  the  underlying  common  stock  at  the  measurement  date,  the  remaining 
contractual term of the warrant, risk-free interest rates and expected dividends on, and expected volatility of the price of the 
underlying common stock.

Revenue

Sale of goods

Revenue  from  the  sale  of  mineral  concentrates  is  recognized  when  control  transfers  to  customers  at  amounts  to  which  the 
Company expects to be entitled. For uranium concentrates, revenue is typically recognized when delivery is evidenced by book 
transfer at the applicable uranium storage facility. For vanadium concentrates, revenue is typically recognized when delivery is 
evidenced by book transfer at the applicable vanadium storage facility. For RE Carbonate, revenue is typically recognized when 
delivery of the mixed RE Carbonate material has arrived at the applicable separations facility.

Rendering of services

Revenue  from  the  delivery  of  mineralized  material  received  from  the  clean-up  of  a  third-party  uranium  mine  or  for  other 
Alternate Feed Materials is typically recognized upon delivery to the White Mesa Mill. Revenue from toll milling services is 
recognized  as  material  is  processed  in  accordance  with  the  specifics  of  the  applicable  toll  milling  agreement.  Revenue  and 
unbilled  accounts  receivable  are  recorded  as  related  costs  are  incurred  using  billing  formulas  included  in  the  applicable  toll 
milling agreement.

Taxes  assessed  by  a  governmental  authority  that  are  both  imposed  on  and  concurrent  with  a  specific  revenue-producing 
transaction, that are collected by the Company from a customer, are excluded from revenue.

171

Share-Based Compensation

The  Company  measures  share-based  compensation  awards  exchanged  for  director,  employee  and  contractor  services  at  fair 
value  on  the  date  of  the  grant  and  expenses  the  awards  in  the  Consolidated  Statements  of  Operations  and  Comprehensive 
Income  (Loss)  over  the  requisite  employee  service  period.  The  fair  value  of  restricted  stock  units  (“RSUs”)  is  based  on  the 
Energy  Fuels’  closing  stock  price  on  the  date  of  grant.  The  fair  value  of  stock  appreciation  rights  (“SARs”)  with  market 
conditions is based on a Monte Carlo simulation performed by a third-party valuation firm. The fair value of stock options is 
determined using the Black-Scholes valuation model. Share-based compensation expense related to awards with only service 
conditions  having  a  graded  vesting  schedule  is  recorded  on  a  straight-line  basis  over  the  requisite  service  period  for  each 
separately vesting portion of the award as if the award was, in substance, multiple awards, while expense for all other awards 
are  recognized  on  a  straight-line  basis.  The  Company’s  estimates  may  be  impacted  by  certain  variables  including,  but  not 
limited  to,  stock  price  volatility,  employee  stock  option  exercise  behaviors,  additional  stock  option  grants,  the  Company's 
performance and related tax impacts.

Foreign Currency

Transactions in foreign currencies are translated to the respective functional currency of the Company’s subsidiaries and joint 
ventures at exchange rates at the dates of the transactions. Monetary assets and liabilities denominated in foreign currencies are 
translated to the functional currency at the exchange rate as of the reporting date. Non-monetary assets and liabilities that are 
measured at fair value in a foreign currency are translated to the functional currency at the exchange rate when the fair value 
was determined. Foreign currency differences are generally recognized in profit or loss. Non-monetary items that are measured 
based on historical cost in a foreign currency are not translated.

The assets and liabilities of entities whose functional currency is not the U.S. dollar are translated into the U.S. dollar at the 
exchange  rate  as  of  the  reporting  date.  The  income  and  expenses  of  such  entities  are  translated  into  the  U.S.  dollar  using 
average exchange rates for the reporting period. Exchange differences on foreign currency translations are recorded in Other 
comprehensive income (loss). The Company’s functional currency is the U.S. dollar.

Income Taxes

The Company uses the asset and liability method of accounting for income taxes. Under this method, deferred income tax assets 
and liabilities are recorded based on differences between the financial statement carrying values of existing assets and liabilities 
and  their  respective  income  tax  bases  (temporary  differences),  and  losses  carried  forward.  Deferred  income  tax  assets  and 
liabilities are measured using the enacted tax rates which will be in effect when the temporary differences are likely to reverse. 
The effect on deferred income tax assets and liabilities of a change in tax rates is included in operations in the period in which 
the change is enacted.

The Company records a valuation allowance to reduce deferred income tax assets to the amount that is believed more likely 
than not to be realized. When the Company concludes that all or part of the deferred income tax assets are not realizable in the 
future, the Company makes an adjustment to the valuation allowance that is charged to income tax expense in the period such 
determination is made.

Net Income (Loss) per Share

The  Company  presents  basic  income  (loss)  per  share  data  for  its  common  shares,  calculated  by  dividing  the  income  (loss) 
attributable to common shareholders of the Company by the weighted average number of common shares outstanding during 
the period. Diluted income (loss) per share is determined by adjusting the income (loss) attributable to common shareholders 
and the weighted average number of common shares outstanding for the effects of all potential dilutive instruments based on 
the  number  of  common  shares  that  would  be  issuable  if  the  end  of  the  period  was  also  the  end  of  the  performance  period 
required  for  the  vesting  of  the  awards.  Potentially  dilutive  instruments  include  stock  options,  restricted  stock  units,  stock 
appreciation rights and warrants, which are included in the diluted income (loss) per share calculation using the treasury stock 
method.

Recently Issued Accounting Standards

Segment Reporting

In  November  2023,  the  FASB  issued  Accounting  Standard  Update  (“ASU”)  2023-07,  “Segment  Reporting  (Topic  280): 
Improvements  to  Reportable  Segment  Disclosures.”  This  ASU  requires  annual  and  interim  disclosures  about  significant 
segment expenses that are regularly provided to the chief operating decision maker and included within each reported measure 

172

of segment profit or loss as well as the amount and composition of other segment items. The Company will adopt this standard 
prospectively on January 1, 2024 and does not expect a material impact on the Company's consolidated financial statements.

Income Tax Disclosures

On  December  14,  2023,  the  FASB  issued  ASU  2023-09,  “Improvements  to  Income  Tax  Disclosures.”  This  ASU  requires 
disaggregated  information  about  a  reporting  entity’s  effective  tax  rate  reconciliation,  as  well  as  information  on  income  taxes 
paid. The standard is intended to benefit investors by providing more detailed income tax disclosures that would be useful in 
making  capital  allocation  decisions.  The  Company  will  adopt  this  standard  prospectively  on  January  1,  2025  and  does  not 
expect a material impact on the Company's consolidated financial statements.

3. 

MARKETABLE SECURITIES 

The  Company  has  elected  the  fair  value  option  for  its  marketable  debt  securities  and  records  these  instruments  on  the 
Consolidated Balance Sheet at their fair value including interest income. Changes in fair value and interest income are recorded 
in Other income (loss) in the Consolidated Statements of Operations and Comprehensive Income (Loss). The fair value option 
was  elected  for  these  marketable  debt  securities  as  the  Company  may  sell  them  prior  to  their  stated  maturities  after 
consideration  of  the  Company's  risk  versus  reward  objectives  as  well  as  its  liquidity  requirements.  The  stated  contractual 
maturity dates of marketable debt securities held as of December 31, 2023 and 2022 are due in one to two years. Marketable 
equity  securities  are  measured  at  fair  value  as  of  each  reporting  date,  and  realized  and  unrealized  gains  (losses)  and  interest 
income  are  recorded  in  Other  income  (loss)  in  the  Condensed  Consolidated  Statements  of  Operations  and  Comprehensive 
Income (Loss).

The following table summarizes our marketable securities by significant investment categories:

December 31, 2023
Marketable debt securities(1)
Marketable equity securities

Total marketable securities

December 31, 2022
Marketable debt securities(1)
Marketable equity securities
Total marketable securities

Cost Basis

Gross 
Unrealized 
Losses

Gross 
Unrealized 
Gains

Fair Value

106,791  $ 

28,159   

134,950  $ 

—  $ 

(2,581)  

(2,581) $ 

675  $ 

—   

675  $ 

107,466 

25,578 

133,044 

11,435  $ 

2,876   
14,311  $ 

(310) $ 

(1,809)  
(2,119) $ 

—  $ 

—   
—  $ 

11,125 

1,067 
12,192 

$ 

$ 

$ 

$ 

(1)   As of December 31, 2023 and 2022, marketable debt securities are comprised primarily of U.S. Treasury Bills and Government Agency Bonds.

4. 

RECEIVABLES

The components of trade and other receivables are as follows:

Trade receivables

Notes receivable, net

Other
Total receivables

December 31,

2023

2022

406  $ 

343 

67 

816  $ 

92 

343 

84 
519 

$ 

$ 

173

 
 
 
 
 
 
 
 
During the year ended December 31, 2014, the Company received two notes with a combined principal totaling $1.05 million 
due in 2018 in connection with the sale of certain assets previously recorded as held for sale. The note with principal totaling 
$0.50  million  was  collected  during  the  year  ended  December  31,  2018.  Alternatively,  the  note  with  a  principal  payment  of 
$0.55 million due November 7, 2018 was not paid and the Company notified the issuing party (“Default Party”) of its default 
on November 9, 2018. The Company has an allowance for credit losses of $0.22 million as of December 31, 2023 and 2022 
against the collectability of this note. The promissory note is secured by all issued and outstanding stock of the Default Party 
and all of the assets sold to the Default Party.

5. 

INVENTORIES

Inventories consisted of the following items:

Concentrates and work-in-progress

Inventory of ore in stockpiles

Raw materials and consumables

Total inventories

6. 

INVESTMENTS

December 31,

2023

2022

$ 

$ 

35,807  $ 

3,072 

1,841 

40,720  $ 

35,476 

940 

4,204 

40,620 

As of December 31, 2022, the Company owned a 17.4% interest in Consolidated Uranium Inc. (“CUR”) and a 13.5% interest 
in Virginia Energy Resources, Inc. (“Virginia Energy”). The Company had significant influence, but not control, over these 
investments. As such, Virginia Energy and CUR were accounted for as equity method investments with the fair value option 
elected and classified as Investments on the Consolidated Balance Sheet. Changes in value of these investments are included in 
Other  income  (loss)  in  the  Consolidated  Statement  of  Operations  and  Comprehensive  Income  (Loss).  For  the  years  ended 
December  31,  2023,  2022  and  2021,  the  Company  had  a  net  unrealized  gain  of  $4.98  million,  an  unrealized  loss  of 
$16.81 million and a unrealized gain of $6.31 million, respectively.

On  January  24,  2023,  CUR  acquired  100%  of  the  issued  and  outstanding  common  shares  of  Virginia  Energy  in  for  0.26 
common shares of CUR for every one common share of Virginia Energy. As a result, the Company’s 9,439,857 common shares 
of  Virginia  Energy  were  converted  into  2,454,362  million  common  shares  of  CUR  (the  “Conversion”).  Following  the 
Conversion,  the  Company  owned  16,189,548  common  shares  of  CUR,  which  represented  an  ownership  interest  of  16.7%  in 
CUR as of closing. 

On December 5, 2023, IsoEnergy Ltd. (“IsoEnergy”) acquired all of the issued and outstanding common shares of CUR (the 
“CUR Shares”). Pursuant to the arrangement, CUR’s shareholders received 0.500 common shares of IsoEnergy for every CUR 
Share.  When  converted,  the  Company's  CUR  Shares  results  in  an  approximate  ownership  interest  in  IsoEnergy  of  5.0%.  On 
October 19, 2023, IsoEnergy completed its marketed private placement offering of 8,134,500 subscription receipts of IsoEnergy 
(the  “Subscription  Receipts”)  at  a  price  of  Cdn$4.50  per  Subscription  Receipt;  in  order  to  retain  its  post-arrangement 
ownership  interest  in  IsoEnergy,  the  Company  purchased  406,650  Subscription  Receipts  for  Cdn$1.83  million.  Each 
outstanding  Subscription  Receipt  has  been  converted  into  one  common  share  of  IsoEnergy.  Following  completion  of  this 
arrangement,  the  Company  owned  8,501,424  shares  of  IsoEnergy  for  an  approximate  ownership  interest  of  5.0%  as  of 
December 5, 2023.

Upon  completion  of  this  arrangement,  the  Company  does  not  have  significant  influence  over  IsoEnergy  as  a  result  of  no 
representation on the Board of Directors of IsoEnergy and its reduced ownership interest. Therefore, the investment is no longer 
accounted for as an equity method investment. The Company's judgment regarding the level of influence over its equity method 
investments  includes  considering  key  factors  such  as  the  Company's  ownership  interest,  representation  on  the  Board  of 
Directors  and  participation  in  the  policy-making  decisions  of  equity  method  investees.  As  such,  the  Company's  shares  in 
IsoEnergy are accounted for as marketable securities with the fair value option elected on its Consolidated Balance Sheet and 
changes in value are included in Other income (loss) in the Consolidated Statement of Operations and Comprehensive Income 
(Loss).

174

 
 
 
 
 
CUR

As of December 5, 2023 and December 31, 2022, the fair value of the Company’s investment in CUR was $23.63 million and 
$16.50 million, respectively.

Pursuant to Rule 3-09 of Regulation S-X (“Rule 3-09”), the Company is required to file separate audited financial statements of 
CUR if either the investment test or income test as set forth in that rule equals or exceeds the 20% level individually. As of 
December  31,  2022,  the  income  test  was  met  at  the  20%  significance  level  for  CUR.  The  Company  will  amend  this  Annual 
Report to include as an exhibit the separate audited financial statements for the year ended December 31, 2022 and unaudited 
financial statements for the period ending December 5, 2023.

In  accordance  with  Rule  4-08(g)  of  Regulation  S-X  (“Rule  4-08(g)”),  the  summarized  financial  information  for  CUR  is  set 
forth below on a one-quarter lag, which precedes the date of the Company’s investment for the year ended December 31, 2021. 
CUR  prepares  its  financial  statements  in  accordance  with  International  Financial  Reporting  Standards  as  issued  by  the 
International Accounting Standards Board (“IFRS”) and uses Cdn$ as its reporting currency. As such, the Company has made 
certain adjustments to CUR’s summarized financial information to address differences between IFRS and GAAP that materially 
impact the summarized financial information and to convert such information to US$.

Current assets

Non-current assets

Current liabilities

Non-current liabilities

September 30,

2023

2022

$ 

$ 

$ 

$ 

7,522  $ 

31,717  $ 

3,589  $ 

319  $ 

16,586 

17,437 

2,285 

— 

Twelve Months Ended September 30,
2022

2021

2023

Loss from continuing operations

Net loss and net loss attributable to the entity

$ 

$ 

(8,817)  $ 

(8,902)  $ 

(23,103)  $ 

(17,890)  $ 

(4,253) 

(4,570) 

Virginia Energy

The fair value of the Company's investment in Virginia Energy was $3.39 million and $2.83 million as of January 24, 2023 and 
December 31, 2022, respectively.

Pursuant  to  Rule  3-09,  the  Company  is  required  to  file  separate  audited  financial  statements  of  Virginia  Energy  if  either  the 
investment test or income test as set forth in that rule equals or exceeds the 20% level individually. As of December 31, 2021, 
the income test was met at the 20% significance level for Virginia Energy. Exhibit 99.1 to this Annual Report includes separate 
audited financial statements for the year ended December 31, 2021 and unaudited financial statements for the twenty-three day 
period ended January 23, 2023 and the year ended December 31, 2022 of Virginia Energy.

In accordance with Rule 4-08(g), summarized financial information for Virginia Energy is set forth below on a one-quarter lag. 
Virginia  Energy  prepares  its  financial  statements  in  accordance  with  IFRS.  The  Company  determined  that  no  adjustments  to 
Virginia  Energy’s  summarized  financial  information  were  necessary  to  address  differences  between  IFRS  and  GAAP  that 
materially impact the summarized financial information. 

Current assets

Non-current assets

Current liabilities

Non-current liabilities

January 23, 2023

September 30, 2022

$ 

$ 

$ 

$ 

133  $ 

4,253  $ 

2  $ 

2  $ 

163 

3,753 

223 

2 

175

Loss from continuing operations, net loss and net loss 
attributable to the entity

$ 

(226)  $ 

(371)  $ 

(275) 

For the Period 
October 1, 2022 to 
January 23, 2023

Twelve Months Ended September 30,

2022

2021

Tate Transition Metals Ltd

On  November  29,  2023,  the  Company  entered  into  an  agreement  with  Tate  Transition  Metals  Ltd  (“Tate”)  whereby  the 
Company  subscribed  for  199,000  Subscription  Ordinary  Shares  for  Aus$1.99  million,  which  represents  a  19.9%  interest  in 
Tate. As of December 31, 2023, Tate was included in Investments on the Consolidated Balance Sheet for $1.36 million and is 
accounted for as an investment without a readily determinable fair value. The Company does not have significant influence in 
its investment in Tate.

7. 

PROPERTY, PLANT AND EQUIPMENT AND MINERAL PROPERTIES

The following is a summary of property, plant and equipment, net:

Estimated
Useful Lives

December 31,

2023

2022

Land
Plant facilities

Mining equipment

Light trucks and utility vehicles
Office furniture and equipment

Construction-in-progress
Total property, plant and equipment

Less: accumulated depreciation

Property, plant and equipment, net

N/A
12 - 15 years

5 years

5 years
4 - 7 years

N/A

$ 

$ 

$ 

642  $ 

29,750 

13,019 
3,256 

1,754 

13,627 
62,048  $ 

(35,925)   

26,123  $ 

642 

29,509 

10,560 
2,867 

1,585 

673 
45,836 

(33,174) 

12,662 

As of December 31, 2022, the net book value of the property, plant and equipment attributable Alta Mesa, which the Company 
sold to enCore effective February 14, 2023, was $8.21 million and is included in Property, plant and equipment and other assets 
held for sale, net on the Consolidated Balance Sheet.

For the years ended December 31, 2023, 2022 and 2021, the Company recognized depreciation expense of $2.75 million, $3.27 
million  and  $3.19  million,  respectively,  in  Exploration,  development  and  processing  and  Standby  in  the  Consolidated 
Statements of Operations and Comprehensive Income (Loss).

For  the  years  ended  December  31,  2023,  2022  and  2021,  the  Company  capitalized  $0.10  million,  $0.24  million  and  $0.10 
million, respectively, of depreciation expense related to the Mill that was included in the capitalized costs to inventory on the 
Consolidated Balance Sheet.

The following is a summary of mineral properties:

176

 
 
 
 
 
 
 
 
 
 
 
Sheep Mountain

Bahia Project

Nichols Ranch ISR Project

Roca Honda

Pinyon Plain

Other

Mineral properties total

Bahia Project

December 31,

2023

2022

$ 

34,183  $ 

29,130 

25,974 

22,095 

6,512 

1,687 

$ 

119,581  $ 

34,183 

— 

25,974 

22,095 

— 

1,287 

83,539 

On  February  10,  2023,  the  Company  closed  on  two  purchase  agreements  to  acquire  a  total  of  17  mineral  concessions  in  the 
State of Bahia, Brazil totaling approximately 37,300 acres or 58.3 square miles (the “Bahia Project”). Under the terms of the 
purchase  agreements,  the  Company  entered  into  mineral  rights  transfer  agreements  with  the  sellers  to  acquire  the  17  heavy 
mineral sands concessions.

The  total  purchase  price  under  the  purchase  agreements  was  $27.50  million,  which  consisted  of  deposit  payments  of 
$5.90  million  due  upon  reaching  certain  stipulated  milestones  and  the  remaining  $21.60  million  due  at  closing.  Upon  final 
payment  on  February  10,  2023,  the  transfer  and  assignment  of  the  mineral  rights  was  completed  (the  “Bahia  Closing”). 
Additionally, the Company incurred direct deal costs related to such asset acquisitions of $1.63 million. The purchase deposit 
payments and direct transaction costs were capitalized as Prepaid expenses and other current assets in the Consolidated Balance 
Sheet as of December 31, 2022 and reclassified to Mineral properties upon closing within the Consolidated Balance Sheet. The 
Bahia  Closing  followed  the  Brazilian  Government's  approval  of  the  transfers  to  Energy  Fuels'  wholly  owned  Brazilian 
subsidiary Energy Fuels Brazil Ltda.

Alta Mesa Transaction

On February 14, 2023, the Company closed on its sale to enCore of three wholly-owned subsidiaries that together held Alta 
Mesa,  which  was  classified  as  “held  for  sale”  on  the  Consolidated  Balance  Sheet  as  of  December  31,  2022,  for  total 
consideration of $120 million (the “Alta Mesa Transaction”), paid as follows:

a.

b.

$60 million in cash, which included $6 million prior to closing and $54 million at closing; and

$60 million Convertible Note, payable in two years from the closing, bearing annual interest of eight percent 
(8%). The Convertible Note is convertible at Energy Fuels’ election into fully paid and non-assessable enCore 
common  shares  at  a  conversion  price  of  $2.9103  per  share,  being  a  20%  premium  to  the  10-day  volume-
weighted  average  price  of  enCore  shares  ending  the  day  before  the  Closing  (the  “Conversion  Option”). 
enCore  is  currently  traded  on  the  TSX-V  and  NYSE  American.  The  Convertible  Note  is  guaranteed  by 
enCore  and  fully  secured  by  Alta  Mesa.  Unless  a  block  trade  or  similar  distribution  is  executed  by  Energy 
Fuels to sell the enCore common shares received on conversion of the Convertible Note, Energy Fuels will be 
limited to selling a maximum of $10 million of enCore common shares per thirty (30)-day period.

The Company recognized a gain on sale of assets from the Alta Mesa Transaction of $116.50 million, which is calculated as the 
total fair value of the consideration received of $119.46 million consisting of $60 million in cash and the Convertible Note with 
a fair value of $59.46 million, less the net book value attributable to the Alta Mesa assets and liabilities after working capital 
adjustments of $3.40 million, net of transaction costs. Receipt of the Convertible Note represents a non-cash investing activity 
at its initial fair value. See Note 15 – Fair Value Accounting for more information on the fair value of the Convertible Note.

As  a  post-closing  condition  of  the  Alta  Mesa  Transaction,  enCore  was  required  to  replace  the  $3.59  million  of  reclamation 
bonds  then  in  place  for  Alta  Mesa.  Upon  replacement,  the  original  bonds  were  released  and  the  Company  received  back  the 
underlying collateral during the year ended December 31, 2023. The Company reclassified $3.59 million cash as a release of 
collateral from those bonds from Property, plant and equipment and other assets held for sale, net to cash and cash equivalents 
on its Condensed Consolidated Balance Sheets.

In connection with the Alta Mesa Transaction, on May 3, 2023, the Company completed the sale of its Prompt Fission Neutron 
assets,  including  the  underlying  contracts,  technology,  licenses  and  intellectual  property  (collectively,  the  “PFN  Assets”),  to 

177

 
 
 
 
 
 
 
 
 
 
 
enCore in exchange for cash consideration received at closing of $3.10 million, which resulted in a gain of $2.75 million. At 
closing, the PFN Assets, which the Company had purchased in 2020 for cash consideration of $0.50 million, had a net book 
value  of  $0.35  million.  The  PFN  Assets  were  used  exclusively  at  the  Alta  Mesa  ISR  Project.  Should  the  Company  have  the 
need  for  the  use  of  a  PFN  tool  in  the  future,  the  Company  retained  a  20-year  usage  right  as  a  condition  of  this  sale  during 
which, subject to the availability of the PFN Assets, the Company has the right to purchase, lease and/or license at least one 
fully  functional  PFN  tool  and  all  related  and/or  required  equipment,  technology  and  licenses,  as  reasonably  requested,  on 
commercially reasonable terms and conditions no less favorable than those offered by enCore to third parties. As of December 
31, 2023, the Company has not purchased, leased and/or licensed a PFN tool.

Disposal of Certain Properties

On  July  15,  2021,  the  Company  and  CUR  jointly  announced  the  signing  of  a  definitive  asset  purchase  agreement  (the 
“Agreement”) for CUR to acquire a portfolio of the Company's non-core conventional uranium projects located in Utah and 
Colorado, including the Daneros mine, the Tony M mine, the Rim mine, the Sage Plain project, and several U.S. Department of 
Energy leases (the “Sale”).

On  October  27,  2021  (the  “Closing  Date”),  the  parties  closed  the  Sale  in  accordance  with  the  terms  of  the  Agreement,  as  a 
result of which the aforementioned properties and leases were transferred to CUR in exchange for the following consideration:

•

•

•

•

•

$2,000,000 in cash on the Closing Date; 

the  issuance  of  11,860,101  common  shares  of  CUR,  constituting  19.9%  of  the  outstanding  CUR  common  shares 
immediately after the Closing Date, at a price per share of Cdn$2.95 equal to the closing price of the CUR common 
shares on the TSXV on the last trading day immediately prior to issuance; 

an  additional  Cdn$3,000,000  in  cash  payable  on  or  before  the  18-month  anniversary  of  the  Closing  Date  (“Second 
Payment”);

an  additional  Cdn$3,000,000  in  cash  payable  on  or  before  the  36-month  anniversary  of  the  Closing  Date  (“Third 
Payment” and together with the Second Payment, the “Deferred Cash Payments”); and

the commitment to make production payments on a per-project basis totaling Cdn$5,000,000 as set forth pursuant to 
individual production payment agreements executed on the Closing Date.

As part of the Agreement, the Company has entered into a mine operating agreement pursuant to which it will act, through its 
indirect  wholly  owned  subsidiary  Energy  Fuels  Resources  (USA)  Inc.,  as  Operator  to  the  Sale  projects  in  accordance  with  a 
program and budget determined annually, in exchange for which the Company will receive reimbursement for all direct costs in 
addition  to  an  overhead  allocation  and  management  fee.  In  addition,  the  Company  has  entered  into  a  toll  milling  agreement 
pursuant to which it will process all ore mined from the properties at the Mill, in exchange for which the Company will receive 
reimbursement  of  direct  costs  in  addition  to  a  milling  fee.  Pursuant  to  an  investor  rights  agreement,  for  so  long  as  the 
Company’s equity ownership in CUR remains at or above 10%, it will be entitled to equity participation rights to maintain its 
pro-rata equity ownership in the Company and to appoint one nominee to the CUR Board of Directors. The Company’s CEO 
was appointed to the CUR Board of Directors at the Closing Date.

These non-core conventional uranium project assets had no carrying value at the Closing Date. The Company recognized a gain 
on  the  disposal  of  $35.73  million  at  the  Closing  Date  and  subsequently  derecognized  asset  retirement  obligations  of 
$0.27 million prior to December 31, 2021 upon being legally released from being the primary obligor under the liabilities. For a 
period of three years, if CUR issues common shares or other securities convertible into common shares in a private placement 
or prospectus offering, the Company has the right to accelerate a portion of the Deferred Cash Payments, in cash or securities, 
up to a maximum amount equal to the product of (i) the gross proceeds of the financing multiplied by (ii) the Company’s then 
current cumulative percentage ownership of CUR common stock on a non-diluted basis prior to the completion of the financing 
(the “Acceleration Right”). On November 22, 2021, CUR completed such a financing under which the Company elected its 
Acceleration Right and received 1,875,085 common shares of CUR and 937,542 warrants to purchase common shares of CUR 
which are exercisable for a period of two years from issuance at a price of Cdn$4.00. The receipt of these CUR common shares 
and warrants satisfied the Second Payment in full and satisfied Cdn$1.97 million of the Third Payment. 

178

8. 

ASSET RETIREMENT OBLIGATIONS AND RESTRICTED CASH

Asset Retirement Obligations

The following table summarizes the Company’s asset retirement obligations:

Asset retirement obligations, beginning of period

 Revision of estimate

 Accretion of liabilities
 Held for sale(1)
 Disposal of Alta Mesa asset retirement obligations(1)
Asset retirement obligations, end of period

December 31,

2023

2022

9,595  $ 

214 

1,192 

— 

(79)   

10,922  $ 

13,687 

(238) 

1,556 

(5,410) 

— 

9,595 

$ 

$ 

(1) Asset retirement obligations held for sale as of December 31, 2022 were related to Alta Mesa and are included as Asset retirement obligation and other 
liabilities held for sale on the Consolidated Balance Sheet. Disposal of Alta Mesa retirement obligations is related to the accretion expense incurred on 
these obligations through the closing date and is included within Gain on sale of assets on the Consolidated Statements of Operations and Comprehensive 
Income (Loss). See Note 7 – Property, Plant and Equipment and Mineral Properties for more information.

The  Company’s  asset  retirement  obligations  are  subject  to  legal  and  regulatory  requirements.  Estimates  of  the  costs  of 
reclamation  are  reviewed  periodically  by  the  Company  and  the  applicable  regulatory  authorities.  The  above  provision 
represents the Company’s estimate of the present value of future reclamation costs, discounted using credit adjusted risk-free 
interest  rates  ranging  from  11.62%  to  12.88%  and  inflation  rates  ranging  from  2.25%  to  3.97%.  The  total  undiscounted 
decommissioning liability as of December 31, 2023 and 2022 is $33.38 million and $42.91 million, respectively.

The upward revision of estimate of $0.21 million for the year ended December 31, 2023 includes net changes in estimated costs 
of  future  reclamation  activities.  These  revisions  were  recognized  in  Property,  plant  and  equipment,  net  on  the  Consolidated 
Balance Sheet and will be depreciated over the useful life of the related asset.

The downward revision of estimate of $0.24 million for the year ended December 31, 2022 includes net changes in estimated 
costs  of  future  reclamation  activities.  These  revisions  were  recognized  in  Exploration,  development,  permitting,  and  land 
holding and Standby costs in the Consolidated Statement of Operations and Comprehensive Income (Loss).

Restricted Cash

The  Company  has  cash,  cash  equivalents  and  fixed  income  securities  as  collateral  for  various  bonds  posted  in  favor  of  the 
applicable  state  regulatory  agencies  in  Arizona,  Colorado,  New  Mexico,  Texas,  Utah  and  Wyoming,  and  the  U.S.  Bureau  of 
Land  Management  and  U.S.  Forest  Service  for  estimated  reclamation  costs  associated  with  the  White  Mesa  Mill,  Nichols 
Ranch, Alta Mesa and other mining properties. The restricted cash will be released when the Company has reclaimed a mineral 
property,  sold  a  mineral  property  to  a  party  having  assumed  the  applicable  bond  requirements  or  restructured  the  surety  and 
collateral arrangements. See Note 14 – Commitments and Contingencies for more information.

The following table summarizes the Company’s restricted cash:

Restricted cash, beginning of period

Additional collateral posted

Held for sale

Restricted cash, end of period

December 31,

2023

2022

$ 

$ 

17,449  $ 

130 

— 

17,579  $ 

20,305 

734 

(3,590) 

17,449 

179

 
 
 
 
 
 
 
 
 
 
 
 
 
9. 

CAPITAL STOCK

Authorized Capital Stock

The  Company  is  authorized  to  issue  an  unlimited  number  of  Common  Shares  without  par  value,  unlimited  Preferred  Shares 
issuable  in  series  and  unlimited  Series  A  Preferred  Shares.  The  Preferred  Shares  issuable  in  series  will  have  the  rights, 
privileges,  restrictions  and  conditions  assigned  to  the  particular  series  upon  the  Board  of  Directors  approving  their  issuance. 
The Series A Preferred Shares issuable are non-redeemable, non-callable, non-voting and have no right to dividends.

Issued Capital Stock

During the years ended December 31, 2023, 2022 and 2021, the Company issued 4,047,832, 769,779 and 16,627,512 Common 
Shares,  respectively,  under  its  ATM  offering  for  net  proceeds  of  $31.81  million,  $7.89  million  and  $106.21  million, 
respectively.

Share Purchase Warrants

The  following  table  summarizes  the  Company’s  share  purchase  warrants  denominated  in  U.S.  dollars.  These  warrants  are 
accounted for as derivative liabilities, as the functional currency of the entity issuing the warrants, Energy Fuels Inc., is Cdn$.

Month Issued
September 2016(1)

Expiry Date

Exercise Price

Warrants
Outstanding

Fair value as of 
December 31, 
2023

September 20, 2021

$ 

2.45 

—  $ 

— 

(1) The warrants issued in September 2016 were classified as Level 1 under the fair value hierarchy. Each warrant was exercisable until September 20, 2021 
and entitled the holder thereof to acquire one common share upon exercise at an exercise price of $2.45 per common share. These warrants are accounted 
for as a derivative liability, as the functional currency of the entity issuing the warrant is Cdn$.

On September 20, 2021, 149,807 warrants issued in September 2016 expired unexercised. 

10. 

BASIC AND DILUTED INCOME (LOSS) PER COMMON SHARE

The following is a reconciliation of weighted average common shares outstanding:

Issued shares at beginning of period 
Effect of stock options exercised
Effect of shares issued for settlement of vesting of restricted stock units
Effect of shares issued for settlement of exercises of stock appreciation 
rights
Effect of shares issued for exercise of share purchase warrants
Effect of shares issued for consulting services
Effect of shares issued in public offerings
Weighted average common shares outstanding

Basic and diluted income (loss) per common share

Years Ended December 31,
2022
  156,262,199 
155,509 
335,546 

2023
  157,682,531 
105,819 
290,390 

2021
  134,311,033 
474,072 
443,364 

120,291 
— 
42,202 
865,806 
  159,107,039 

2,679 
— 
16,064 
571,253 
  157,343,250 

2,316 
1,737,981 
35,933 
9,899,825 
  146,904,524 

The calculation of basic and diluted income (loss) per share after adjustment for the effects of all potential dilutive common 
shares, calculated as follows:

180

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Net income (loss) attributable to owners of the Company

$ 

99,862  $ 

(59,849)  $ 

1,541 

Years Ended December 31,

2023

2022

2021

Basic weighted average common shares outstanding
Dilutive impact of stock options, restricted stock units, and warrants
Diluted weighted average common shares outstanding 
Basic net income (loss) per common share
Diluted net income (loss) per common share

  159,107,039 
1,047,001 
  160,154,040 
$ 
$ 

0.63  $ 
0.62  $ 

  157,343,250 
— 
  157,343,250 

  146,904,524 
2,816,593 
  149,721,117 
0.01 
0.01 

(0.38)  $ 
(0.38)  $ 

For the years ended December 31, 2023, 2022 and 2021, 0.11 million, 0.06 million and 6.87 million stock options, restricted 
stock units, and warrants, respectively, and the potential conversion of the Convertible Debentures have been excluded from the 
calculation  of  diluted  net  income  (loss)  per  common  share  as  their  effect  would  have  been  anti-dilutive.  In  addition,  the 
Company excluded stock appreciation rights of 1.85 million, 2.45 million, and 1.67 million for the years ended December 31, 
2023, 2022, and 2021, respectively as they are contingently issuable based on specified market prices of the Company’s stock 
which were not achieved as of the end of each period.

11. 

SHARE-BASED COMPENSATION

The  Company  maintains  an  equity  incentive  plan,  known  as  the  2021  Amended  and  Restated  Omnibus  Equity  Incentive 
Compensation Plan (the “Compensation Plan”), for directors, executives, eligible employees and consultants. Existing equity 
incentive awards include employee non-qualified stock options, RSUs and SARs. The Company issues new Common Shares to 
satisfy exercises and vesting under its equity incentive awards. As of December 31, 2023, a total of 16,265,915 common shares 
were authorized for future equity incentive plan awards.

The Company’s share-based compensation expense, by type of award, is as follows:

RSUs(1)
SARs

Years Ended December 31,

2023

2022

2021

$ 

2,595  $ 

2,244  $ 

1,583 

2,038 

1,562 

273 

Stock options
Total share-based compensation expense(2)
(1) The fair value of the RSUs granted under the Compensation Plan for the years ended December 31, 2023, 2022 and 2021 was estimated at the date of 

4,625  $ 

4,641  $ 

2,158 

447 

323 

359 

$ 

grant, using the stated market price on the NYSE American.

(2) Share-based compensation is recorded in Selling, general and administration in the Consolidated Statements of Operations and Comprehensive Income 

(Loss).

As  of  December  31,  2023,  there  were  $0.19  million,  $0.84  million  and  $0.31  million  of  unrecognized  compensation  costs 
related to the unvested stock options, RSU awards and SARs, respectively, to be recognized over a weighted average period of 
1.03 years, 1.87 years, and 0.67 years, respectively.

Restricted Stock Units

The Company grants RSUs to directors, executives and eligible employees. Awards for executives and eligible employees are 
determined as a target percentage of base salary and generally vest over three years. Holders of unvested RSUs do not have 
voting  rights  on  those  RSUs.  The  RSUs  are  subject  to  forfeiture  risk  and  other  restrictions.  Upon  vesting,  the  employee  is 
entitled to receive one Common Share of the Company for each RSU at no additional payment.

A summary of the Company’s RSU unvested activity is as follows:

181

 
 
 
 
 
 
 
 
 
 
 
Unvested, December 31, 2020

 Granted

 Vested

 Forfeited

Unvested, December 31, 2021

 Granted

 Vested

 Forfeited

Unvested, December 31, 2022

 Granted

 Vested

 Forfeited

Unvested, December 31, 2023

Number of Shares

Weighted Average 
Grant Date Fair 
Value

1,094,056  $ 

441,241 

(635,233)   

— 

900,064  $ 

411,467 

(518,856)   

(45,250)   

747,425  $ 

450,232 

(448,883)   

(106,935)   

641,839  $ 

1.98 

3.89 

1.94 

— 

2.94 

6.52 

2.93 

5.40 

4.77 

7.36 

4.24 

7.03 

6.57 

The total fair value of RSUs that vested and were settled for equity was $3.00 million, $2.93 million and $2.67 million for the 
years ended December 31, 2023, 2022 and 2021, respectively. 

Stock Appreciation Rights

The Company grants SARs to executives and eligible employees.

2019 Stock Appreciation Rights Grants

During the year ended December 31, 2019, the Company’s Board of Directors issued SARs under the Compensation Plan with 
a fair value of $1.25 per SAR. These SARs are intended to provide additional long-term performance-based equity incentives 
for  the  Company’s  senior  management.  The  SARs  are  performance-based  because  they  only  vest  upon  the  achievement  of 
performance goals designed to significantly increase shareholder value.

Each SAR granted entitles the holder to receive, upon a valid exercise, payment from the Company in cash or Common Shares 
(at the sole discretion of the Company) in an amount representing the difference between the fair market value (“FMV”) of the 
Company’s Common Shares on the date of exercise and $2.92 (the closing market price or “Grant Price” at the time of grant). 
Fair Market Value as used herein means the closing price of the Shares on the TSX or the NYSE American on the last trading 
day  immediately  prior  to  the  date  of  exercise.  The  term  of  the  SARs  grant  is  five  years,  with  SARs  vesting  only  upon  the 
achievement of the following performance goals: as to one-third of the SARs granted, automatically upon the 90-calendar-day 
volume-weighted average price (“VWAP”) of the Company’s Common Shares on the NYSE American equaling or exceeding 
$5.00 for any continuous 90-calendar-day period; as to an additional one-third of the SARs granted, automatically upon the 90-
calendar-day  VWAP  of  the  Company’s  Common  Shares  on  the  NYSE  American  equaling  or  exceeding  $7.00  for  any 
continuous 90-calendar-day period; and as to the final one-third of the SARs granted, automatically upon the 90-calendar-day 
VWAP  of  the  Company’s  Common  Shares  on  the  NYSE  American  equaling  or  exceeding  $10.00  for  any  continuous  90-
calendar-day period. Further, notwithstanding the foregoing vesting schedule, no SARs were able to be exercised by the holder 
for an initial period of one year from the Date of Grant; the date first exercisable being January 22, 2020. The first two tranches 
of these vesting performance goals were met prior to the year ended December 31, 2023. 

2022 Stock Appreciation Rights Grants

During the year ended December 31, 2022, the Company’s Board of Directors issued SARs under the Compensation Plan. The 
fair value of the SARs granted during the year ended December 31, 2022 was estimated at the date of grant using a Monte Carlo 
simulation. 

182

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Each SAR granted entitles the holder to receive, upon a valid exercise, payment from the Company in cash or Common Shares 
(at the sole discretion of the Company) in an amount representing the difference between the FMV of the Company’s Common 
Shares on the date of exercise and $6.47 (the Grant Price at the time of grant). The term of the SARs grant is five years, with 
SARs  vesting  only  upon  the  achievement  of  the  following  performance  goals:  as  to  one-third  of  the  SARs  granted, 
automatically  upon  the  90-calendar-day  VWAP  of  the  Company’s  Common  Shares  on  the  NYSE  American  equaling  or 
exceeding $12.00 for any continuous 90-calendar-day period; as to an additional one-third of the SARs granted, automatically 
upon the 90-calendar-day VWAP of the Company’s Common Shares on the NYSE American equaling or exceeding $14.00 for 
any continuous 90-calendar-day period; and as to the final one-third of the SARs granted, automatically upon the 90-calendar-
day VWAP of the Company’s Common Shares on the NYSE American equaling or exceeding $16.00 for any continuous 90-
calendar-day period. Further, notwithstanding the foregoing vesting schedule, no SARs may be exercised by the holder for an 
initial period of one year from the date of grant; the date first exercisable being January 25, 2023. As a result, the SARs granted 
in the first quarter of 2022 for 2021 performance are a long-term equity incentive and are 100% performance based.

2023 Stock Appreciation Rights Grants

On  January  26,  2023,  the  Company’s  Board  of  Directors  issued  SARs  under  the  Compensation  Plan,  which  are  intended  to 
provide additional long-term equity incentives for the Company’s senior management. 

Each SAR granted entitles the holder to receive, upon a valid exercise, payment from the Company in cash or Common Shares 
(at the sole discretion of the Company) in an amount representing the difference between the FMV of the Company’s Common 
Shares on the date of exercise and $7.36 (being the greater of (i) the VWAP of the Company’s Common Shares on the NYSE 
American for the five trading days immediately prior to the date of grant, and (ii) the Grant Price). Fair Market Value as used 
herein means the closing price of the Common Shares on the TSX or the NYSE American on the last trading day immediately 
prior to the date of exercise. The term of the SARs grant is five years, with SARs vesting only upon the achievement of the 
following  goals:  as  to  one-third  of  the  SARs  granted,  automatically  upon  the  90-calendar-day  VWAP  of  the  Company’s 
Common  Shares  on  the  NYSE  American  equaling  or  exceeding  $12.00  for  any  continuous  90-calendar-day  period;  as  to  an 
additional one-third of the SARs granted, automatically upon the 90-calendar-day VWAP of the Company’s Common Shares 
on the NYSE American equaling or exceeding $14.00 for any continuous 90-calendar-day period; and as to the final one-third 
of  the  SARs  granted,  automatically  upon  the  90-calendar-day  VWAP  of  the  Company’s  Common  Shares  on  the  NYSE 
American  equaling  or  exceeding  $16.00  for  any  continuous  90-calendar-day  period.  Further,  notwithstanding  the  foregoing 
vesting schedule, no SARs were able to be exercised by the holder for an initial period of one year from the date of grant, the 
date first exercisable being January 26, 2024.

The following table with the following weighted average assumptions used to determine fair values:

Years Ended December 31,

2023

2022

Risk-free interest rate
Expected life (in years)(1)
Expected volatility(2)
Expected dividend yield

 3.58 %

5.00 years
 55.00 %

 — %

Weighted average grant date fair value

$ 

3.45 

$ 

 1.68 %

4.98 years
 72.81 %

 — %

3.99 

(1) Monte Carlo analysis of SARs assumes employee suboptimal exercise at first vesting time for each tranche.
(2) Expected volatility is measured based on the Company’s historical share price volatility over a period equivalent to the expected life of the SARs.

183

A summary of the Company’s SARs activity is as follows:

Number of Shares

Weighted Average
Exercise Price

Weighted Average 
Remaining 
Contractual Life 
(Years)

Intrinsic Value

Outstanding, December 31, 2020

 Exercised

Outstanding, December 31, 2021

Granted

Exercised

Forfeited

1,720,623  $ 

(48,201)   

1,672,422  $ 

833,315 

(6,730)   

(46,239)   

Outstanding, December 31, 2022

2,452,768  $ 

 Granted

 Exercised

 Forfeited

 Expired

Outstanding, December 31, 2023

Exercisable, December 31, 2023

308,333 

(842,107)   

(79,466)   

— 

1,839,528  $ 

250,036  $ 

2.92 

2.92 

2.92 

6.47 

2.92 

5.95 

4.07 

7.36 

2.92 

7.30 

— 

5.01 

2.92 

1.86 $ 

0.06 $ 

4,056 

1,068 

The total intrinsic value for exercised SARs was $3.55 million, $0.05 million and $0.26 million for the years ended December 
31, 2023, 2022 and 2021, respectively.

A summary of the Company’s unvested SARs activity is as follows:

184

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Unvested, December 31, 2020

Granted

Vested

Forfeited

Unvested, December 31, 2021

Granted

Vested

Forfeited

Unvested, December 31, 2022

 Granted

 Vested

 Forfeited

Unvested, December 31, 2023

Employee Stock Options

Number of Shares

Weighted Average 
Grant Date Fair 
Value

1,720,623  $ 

— 

(1,147,074)   

— 

573,549  $ 

833,315 

— 

(46,239)   

1,360,625  $ 

308,333 

— 

(79,466)   

1,589,492  $ 

1.25 

— 

1.27 

— 

1.19 

3.99 

— 

4.13 

2.81 

3.45 

— 

3.58 

2.89 

The Company, under the Compensation Plan, may grant stock options to directors, executives, employees and consultants to 
purchase common shares of the Company. The exercise price of the stock options is set as the higher of the Company’s closing 
share  price  on  the  NYSE  American  on  the  last  trading  day  before  the  grant  date  and  the  five-day  VWAP  on  the  NYSE 
American ending on the last trading day before the grant date. Stock options granted under the Compensation Plan generally 
vest  over  a  period  of  two  years  or  more  and  are  generally  exercisable  over  a  period  of  five  years  from  the  grant  date,  such 
period not to exceed 10 years. 

The fair value of the stock options granted under the Compensation Plan is estimated at the date of grant, using the Black-
Scholes Option Valuation Model, with the following weighted average assumptions:

Risk-free interest rate

Expected life (in years)
Expected volatility(1)
Expected dividend yield

Years Ended December 31,

2023

2022

2021

 3.98 %

3.2 years

 74.00 %
 — %

 2.43 %
3.2 years

 73.21 %
 — %

 0.44 %
5.0 years

 61.96 %
 — %

Weighted average grant date fair value

$ 

3.80 

$ 

4.93 

$ 

2.06 

(1)   Expected volatility is measured based on the Company’s historical share price volatility over a period equivalent to the expected life of the stock options.

A summary of the Company’s stock option activity is as follows:

185

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Range of 
Exercise 
Prices

Number of 
Shares

Weighted 
Average
Exercise 
Price

Weighted 
Average 
Remaining 
Contractual 
Life (Years)

Intrinsic 
Value

Outstanding, December 31, 2020

$1.70 - $15.61  

1,609,087  $ 

 Granted

 Exercised

 Forfeited

 Expired

3.89 - 8.41  

169,310 

1.70 - 7.42  

(775,814)   

1.76 - 5.91  

(8,048)   

1.70 - 15.61  

(51,653)   

Outstanding, December 31, 2021

$1.70 - $8.41  

942,882  $ 

 Granted

 Exercised

 Forfeited

 Expired

5.84 - 10.03  

118,318 

1.70 - 5.46  

(256,315)   

3.06 - 10.03  

(20,700)   

1.76 - 5.18  

(16,507)   

Outstanding, December 31, 2022

$1.70 - $8.41  

767,678  $ 

 Granted

 Exercised

 Forfeited

 Expired

5.34 - 8.60  

153,299 

1.70 - 6.47  

(348,538)   

3.89 - 7.36  

(32,250)   

1.76 - 6.47  

(16,720)   

Outstanding, December 31, 2023

$1.76 - $8.60  

523,469  $ 

Exercisable, December 31, 2023

$1.76 - $8.41  

354,286  $ 

2.91 

3.99 

2.95 

3.16 

8.14 

2.79 

6.52 

2.93 

5.91 

2.52 

3.24 

7.20 

2.83 

6.74 

3.75 

4.48 

3.24 

2.31 $ 

1.55 $ 

1,448 

1,400 

The  total  intrinsic  value  of  options  exercised  was  $1.53  million,  $2.23  million  and  $2.88  million  for  the  years  ended 
December 31, 2023, 2022 and 2021, respectively.

A summary of the Company’s unvested stock option activity is as follows:

Unvested, December 31, 2020

 Granted

 Vested
 Forfeited

Unvested, December 31, 2021
 Granted

 Vested

 Forfeited

Unvested, December 31, 2022

 Granted

 Vested

 Forfeited

Unvested, December 31, 2023

Number of Shares

Weighted Average 
Grant Date Fair 
Value

403,990  $ 

169,310 

(351,934)   
(8,049)   

213,317  $ 
118,318 

(170,349)   

(20,700)   

140,586  $ 

153,299 

(92,453)   

(32,250)   

169,182  $ 

0.94 

2.06 

1.23 
1.60 

1.34 
4.93 

1.15 

4.54 

4.12 

3.71 

3.57 

3.78 

4.11 

12. 

INCOME TAXES

For financial reporting purposes, income before taxes includes the following components:

186

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Canada

Foreign

Total

Years Ended December 31,

2023

2022

2021

$ 

$ 

(5,229)  $ 

105,261 

(23,964)  $ 
(35,980)   

100,032  $ 

(59,944)  $ 

(7,549) 
8,997 

1,448 

A reconciliation of income tax expense (benefit) and the product of accounting income before income tax, multiplied by the 
combined Canadian federal and provincial income tax rate (the rate applicable to the Canadian parent company) is as follows:

Income (loss) before income taxes

Combined federal and provincial rate

Expected income tax (benefit)

Share-based compensation

Other non-deductible/non-taxable items

Unrecognized deferred tax assets
Income tax expense

Years Ended December 31,
2022

2021

2023

$ 

100,032 

$ 

(59,944) 

$ 

1,448 

 26.5 %

 26.5 %

 26.5 %

26,508 

(893) 

2,015 

(27,354) 
276 

(15,885) 

572 

3,977 

11,336 
— 

$ 

$ 

$ 

384 

(89) 

159 

(454) 
— 

The components of the net deferred tax assets as of December 31, 2023 and 2022 are as follows:

Inventories

Short-term investments

Operating loss carry forwards

Capital loss carry forwards

Deferred revenue and other

Mineral properties and deferred costs, United States

Mineral properties and deferred costs, Canada

Asset retirement obligations

Property, plant and equipment

Total deferred tax assets

Less: valuation allowance

Net deferred tax assets

Years Ended December 31,
2022
2023

$ 

547  $ 

209 

93,241 

849 

2,431 

16,872 

1,726 
2,894 

986 

$ 

$ 

119,755  $ 

(119,755)   

—  $ 

5,984 

209 

108,827 

881 

5,433 

18,727 

1,815 
3,976 

1,079 

146,931 

(146,931) 

— 

As of December 31, 2023, and 2022, the Company recorded a valuation allowance against the net deferred tax assets for the 
above related items in the financial statements as management did not consider it more likely than not that the Company will be 
able to realize the deferred tax assets in the future.

The following table summarizes the changes to the valuation allowance:

For the Years Ended
December 31,
2023
2022

Balance
Beginning of Period
$ 
$ 

146,931  $ 
135,503  $ 

Additions (1)

Deductions (2)

Balance
End of Period

—  $ 
11,927  $ 

(27,176)  $ 
(499)  $ 

119,755 
146,931 

(1) There  were  no  additions  to  the  valuation  allowance  for  the  year  ended  December  31,  2023.  For  the  year  ended  December  31,  2022,  additions  to  the 
valuation allowance were due to additional losses incurred and increases to other tax assets such as mineral property, reclamation obligations and deferred 
revenue.

(2) For the year ended December 31, 2023, the reductions to the valuation allowance were due to the utilization of loss carryforwards and the decrease to tax 
assets  such  as  inventory,  mineral  property  and  property,  plant  and  equipment.  For  the  year  ended December  31,  2022,  the  reductions  to  the  valuation 
allowance are primarily due to the decreases to other tax assets such as inventories.

187

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The  following  table  summarizes  the  Company's  capital  losses  and  net  operating  losses  as  of  December  31,  2023  that  can  be 
applied against future taxable profit.

Country
Canada
Canada
Canada
United States
United States

Type
Non-capital losses
Allowable capital losses
Investment tax credits
Pre-2018 net operating losses
Post-2017 net operating losses

Amount

51,555 
3,204 
1,165 
194,499 
105,802 

$ 
$ 
$ 
$ 
$ 

Expiry Date
2027 - 2039
None
2023-2027
2026-2036
None

Under  Section  382  of  the  Internal  Revenue  Code  of  1986,  a  corporation  that  undergoes  an  ownership  change  is  subject  to 
limitations  on  its  use  of  pre-change  tax  attributes  and  carryforwards  to  offset  future  taxable  income.  The  Company  had  an 
ownership change in 2015 and is subject to an annual limitation for the use of loss carryforwards generated prior to 2015.

In addition, as a result of the Tax Cuts and Jobs Act, United States net operating loss carryforwards generated after December 
31, 2017, are limited to usage at 80% of taxable income and will be permitted to be carried forward indefinitely. 

Utilization of the Canadian loss carry forwards will be subject to the Acquisition of Control Rules in any year as a result of 
previous changes in ownership.

The Company files income tax returns in the U.S. federal and various state jurisdictions with varying statutes of limitations. The 
Company’s NOL from all years may be subject to adjustment for three or four years following the year in which utilized. We 
do  not  anticipate  that  any  potential  tax  adjustments  will  have  a  significant  impact  on  our  financial  position  or  results  of 
operations.

The Company’s policy is to include interest and penalties related to uncertain tax positions in the income tax expense line on 
the financial statements. As of December 31, 2023, the Company does not have any uncertain tax positions.

13. 

SUPPLEMENTAL FINANCIAL INFORMATION

The Company’s sales to major customers (purchases in excess of 10% of total sales) are as follows:

Customer 1
Customer 2
Customer 3
Customer 4
Customer 5
Customer 6

The Company’s revenues by country of customer are as follows:

U.S.
Estonia
Other
Total revenues

Years Ended December 31,
2022

2023

2021

18,470  $ 
10,472 
4,335 
2,848 
866 
— 

—  $ 
— 
— 
2,592 
8,778 
445 

— 
— 
— 
1,385 
— 
1,571 

Years Ended December 31,
2022

2023

2021

34,514  $ 
2,848 
566 
37,928  $ 

9,473  $ 
2,592 
450 
12,515  $ 

1,721 
1,385 
78 
3,184 

$ 

$ 

$ 

188

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The Company’s outstanding trade receivables from its major customers are as follows:

Customer 1

December 31,

2023

2022

$ 

291  $ 

— 

The Company’s outstanding trade receivables by country of customer are as follows:

U.S.

Estonia

Total trade receivables

The components of other income (loss) are as follows:

Unrealized gain (loss) on investments

Realized loss on investments

Unrealized gain (loss) on marketable securities

Realized gain on maturities of marketable securities

Realized gain on convertible note

Change in value of warrant liabilities

Foreign exchange gain (loss)

Department of Energy awards

Interest income, net and other

Other income (loss)

The components of accounts payable and accrued liabilities are as follows:

Accounts payable

Accrued operating expenses
Accrued payroll liabilities

Accrued capital expenditures

Accrued taxes

Other accrued liabilities

December 31,

2023

2022

$ 

$ 

115  $ 

291 

406  $ 

92 

— 

92 

Years Ended December 31,

2023

2022

2021

$ 

15,472  $ 

(16,808)  $ 

6,311 

(10,491)   

(530)   

1,141 

1,430 

— 

423 

— 

5,697 

— 

(456)   

— 

— 

— 

2,058 

— 

(166)   

$ 

13,142  $ 

(15,372)  $ 

December 31,

2023

2022

$ 

1,006  $ 

4,391 
4,162 

205 

393 

4 

— 

795 

— 

— 

(8,078) 

(128) 

1,900 

340 

1,140 

1,850 

1,783 
2,929 

22 

240 

105 

6,929 

Total accounts payable and accrued liabilities

$ 

10,161  $ 

14. 

COMMITMENTS AND CONTINGENCIES

General Legal Matters

Other  than  routine  litigation  incidental  to  our  business,  or  as  described  below,  the  Company  is  not  currently  a  party  to  any 
material pending legal proceedings that management believes would be likely to have a material adverse effect on our financial 
position, results of operations or cash flows.

189

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
White Mesa Mill

In 2011, the Ute Mountain Ute Tribe filed an administrative appeal of the State of Utah Division of Air Quality’s (“UDAQ”) 
decision to approve a Modification to the Air Quality Approval Order at the Mill. Then, in 2013, the Ute Mountain Ute Tribe 
filed a Petition to Intervene and Request for Agency Action challenging the Corrective Action Plan approved by the State of 
Utah Department of Environmental Quality (“UDEQ”) relating to nitrate contamination in the shallow aquifer at the Mill. In 
August 2014, the Ute Mountain Ute Tribe filed an administrative appeal to the State of Utah Division of Radiation Control’s 
(“DRC”)  Radioactive  Materials  License  Amendment  7  approval  regarding  alternate  feed  material  from  Dawn  Mining.  The 
challenges  remain  open  at  this  time  and  may  involve  the  appointment  of  an  administrative  law  judge  (“ALJ”)  to  hear  the 
matters.  The  Company  does  not  consider  these  actions  to  have  any  merit.  If  the  petitions  are  successful,  the  likely  outcome 
would  be  a  requirement  to  modify  or  replace  the  existing  Air  Quality  Approval  Order,  Corrective  Action  Plan  or  license 
amendment,  as  applicable.  At  this  time,  the  Company  does  not  believe  any  such  modifications  or  replacements  would 
materially affect its financial position, results of operations or cash flows. However, the scope and costs of remediation under a 
revised  or  replaced  Air  Quality  Approval  Order,  Corrective  Action  Plan  and/or  license  amendment  have  not  yet  been 
determined and could be significant.

The UDEQ renewed in January 2018, then reissued with minor corrections in February 2018, the Mill’s radioactive materials 
license (the “Mill License”) for another ten years and the Groundwater Discharge Permit (the “GWDP”) for another five years, 
after which further applications for renewal of the Mill License and GWDP are required to be submitted. During the review 
period for each application for renewal, the Mill can continue to operate under its existing Mill License and GWDP until such 
time as the renewed Mill License or GWDP is issued. Most recently, on July 15, 2022, the routine GWDP renewal application 
was submitted to UDEQ, which remains under consideration at this time.

In  2018,  the  Grand  Canyon  Trust,  Ute  Mountain  Ute  Tribe  and  Uranium  Watch  (collectively,  the  “Mill  Plaintiffs”)  served 
Petitions for Review challenging UDEQ’s renewal of the Mill License and GWDP and Requests for Appointment of an ALJ, 
which they later agreed to suspend pursuant to a Stipulation and Agreement with UDEQ, effective June 4, 2018. The Company 
and the Mill Plaintiffs held multiple discussions over the course of 2018 and 2019 in an effort to settle the dispute outside of 
any judicial proceeding. In February 2019, the Mill Plaintiffs submitted to the Company their proposal for reaching a settlement 
agreement.  The  proposal  remains  under  consideration  by  the  Company.  The  Company  does  not  consider  these  challenges  to 
have any merit and, if a settlement cannot be reached, the Company intends to participate with UDEQ in defending against the 
challenges.  If  the  challenges  are  successful,  the  likely  outcome  would  be  a  requirement  to  modify  the  renewed  Mill  License 
and/or  GWDP.  At  this  time,  the  Company  does  not  believe  that  any  such  modification  would  materially  affect  its  financial 
position, results of operations or cash flows.

On August 26, 2021, the Ute Mountain Ute Tribe filed a Petition to Intervene and Petition for Review challenging the UDEQ’s 
approval  of  Amendment  No.  10  to  the  Mill  License,  which  expanded  the  list  of  Alternate  Feed  Materials  that  the  Mill  is 
authorized to accept and process for its source material content. Then, on November 18, 2021, the Tribe filed its Request for 
Appointment of an ALJ, followed shortly thereafter by a stay on the request in accordance with a Stipulation and Agreement 
between the Tribe, UDEQ and Company. Thereafter, discussions between the Company and the Tribe commenced in an effort 
to resolve the dispute and other outstanding matters without formal adjudication. However, the Company does not consider this 
action to have any merit. If resolution is not achieved, the stay is lifted and the petition is successful before an ALJ, the likely 
outcome would be a requirement to modify or revoke the Mill License amendment. At this time, the Company does not believe 
any such modification or revocation would materially affect its financial position, results of operations or cash flows.

Mineral Property Commitments

The Company enters into commitments with federal and state agencies and private individuals to lease mineral rights. These 
leases are renewable annually, and annual renewal costs are expected to total $1.60 million for the year ended December 31, 
2024. 

Surety Bonds

The  Company  has  indemnified  third-party  companies  to  provide  surety  bonds  as  collateral  for  the  Company’s  AROs.  The 
Company is obligated to replace this collateral in the event of a default and is obligated to repay any reclamation or closure 
costs  due.  As  of  December  31,  2023,  the  Company  has  $17.58  million  posted  as  collateral  against  an  undiscounted  ARO  of 
$33.38 million. As of December 31, 2022, the Company has $21.04 million posted as collateral against an undiscounted ARO 
of $42.91 million.

190

Commitments

The  Company  is  contractually  obligated  under  a  Sales  and  Agency  Agreement  appointing  an  exclusive  sales  and  marketing 
agent for all vanadium pentoxide produced by the Company.

15. 

FAIR VALUE ACCOUNTING

Assets and Liabilities Measured at Fair Value on a Recurring Basis

Assets  and  liabilities  are  classified  in  their  entirety  based  on  the  lowest  level  of  input  that  is  significant  to  the  fair  value 
measurement.

Fair value accounting utilizes a fair value hierarchy that prioritizes the inputs to valuation techniques used to measure fair value. 
The hierarchy gives the highest priority to unadjusted quoted prices in active markets for identical assets and liabilities (Level 1 
measurements)  and  the  lowest  priority  to  unobservable  inputs  (Level  3  measurements).  The  three  levels  of  the  fair  value 
hierarchy are described below:

Level  1  –  Unadjusted  quoted  prices  in  active  markets  that  are  accessible  at  the  measurement  date  for  identical, 

unrestricted assets or liabilities;

Level 2 – Quoted prices in markets that are not active, or inputs that are observable, either directly or indirectly, for 

substantially the full term of the asset or liability; and

Level 3 – Prices or valuation techniques that require inputs that are both significant to the fair value measurement and 

unobservable (supported by little or no market activity).

The Company’s financial instruments include cash, restricted cash, accounts receivable, accounts payable and current accrued 
liabilities.  These  instruments  are  carried  at  cost,  which  approximates  fair  value  due  to  the  short-term  maturities  of  the 
instruments. Allowances for doubtful accounts are recorded against the accounts receivable balance to estimate net realizable 
value.

As of December 31, 2023 and 2022, the fair values of cash, restricted cash, short-term deposits, receivables, accounts payable 
and accrued liabilities approximate their carrying values because of the short-term nature of these instruments.

The  Company’s  investments  in  marketable  equity  securities  are  publicly  traded  stocks  measured  at  fair  value  and  classified 
within Level 1 and Level 2 in the fair value hierarchy. Level 1 marketable equity securities use quoted prices for identical assets 
in active markets, while Level 2 marketable equity securities utilize inputs based upon quoted prices for similar instruments in 
active markets. The Company’s investments in marketable debt securities are valued using quoted prices of a pricing service 
and as such, are classified within Level 2 of the fair value hierarchy. The Company’s investments include certain investments 
accounted for at fair value consisting of Common Shares are valued using quoted market prices in active markets and as such 
are classified within Level 1 of the fair value hierarchy. The Company’s investments include certain investments accounted for 
at fair value consisting of warrants are valued using the Black-Scholes option model based on observable inputs and as such are 
classified within Level 2 of the hierarchy.

The Convertible Note received as part of the Alta Mesa Transaction was valued as of February 14, 2023, upon closing, using a 
binomial  lattice  model.  The  fair  value  calculation  uses  significant  unobservable  inputs,  including:  (i)  volatility  60%,  and  (ii) 
yield of 9.5%. Increases or decreases in the volatility and/or the selected yield can result in an increase or decrease in the fair 
value of the Convertible Note. Between February 14, 2023 and November 3, 2023, enCore early redeemed $40.00 million of 
the  principal  value  of  the  Convertible  Note.  On  November  9,  2023,  the  Company  sold  the  remaining  unpaid  balance  of 
$20  million  owed  under  the  secured  Convertible  Note  for  total  consideration  of  $21.00  million  plus  $1.50  million  in  unpaid 
accrued interest, less a sales commission of $100,000 paid to a third-party broker. As a result of enCore’s earlier pay-down and 
the $22.40 million received in connection with the sale of the Convertible Note, the Company has now received payment in full 
for the Alta Mesa Transaction, and no further consideration is owed in connection therewith.

The following tables set forth the fair value of the Company’s assets and liabilities measured at fair value on a recurring basis 
(at  least  annually)  by  level  within  the  fair  value  hierarchy.  Assets  and  liabilities  are  classified  in  their  entirety  based  on  the 
lowest level of input that is significant to the fair value measurement.

191

December 31, 2023
Cash equivalents(1)
Marketable equity securities

Marketable debt securities

December 31, 2022
Cash equivalents(1)
Investments accounted for at fair value

Marketable equity securities

Marketable debt securities

Level 1

Level 2

Level 3

Total

$ 

—  $ 

40,512  $ 

—  $ 

25,554 

— 

24 

107,466 

— 

— 

$ 

25,554  $ 

148,002  $ 

—  $ 

$ 

—  $ 

30,336  $ 

—  $ 

19,263 

1,033 

— 

66 

34 

11,125 

— 

— 

— 

$ 

20,296  $ 

41,561  $ 

—  $ 

40,512 

25,578 

107,466 

173,556 

30,336 

19,329 

1,067 

11,125 

61,857 

(1)  Cash and cash equivalents are comprised of U.S. Treasury Bills, Government Agency Bonds, U.S. Non-Redeemable Term Deposits and mutual funds 

purchased within three months of their maturity date.

Changes in Level 3 Fair Value Measurements

The  following  table  is  a  reconciliation  of  the  beginning  and  ending  balance  recorded  for  the  Convertible  Note  classified  as 
Level 3 in the fair value hierarchy:

Beginning balance, February 14, 2023

Principal redeemed and sale

Realized gain included in other income (loss)

Ending balance, December 31, 2023

16. 

REVENUE

$ 

$ 

59,457 

(60,887) 

1,430 
— 

All revenue recognized is a result of contracts with customers by way of uranium, vanadium and RE Carbonate sales contracts, 
Alternate Feed Material processing contracts and/or byproduct disposal agreements with other ISR facilities.

Uranium Concentrates

The Company's sales of uranium concentrates are derived from contracts with major U.S. utilities. Revenue is recognized when 
delivery is evidenced by book transfer at the applicable uranium storage facility. The sales contracts specify the quantity to be 
delivered,  the  price,  payment  terms  and  the  year  of  the  delivery.  The  Company's  agreements  with  major  U.S.  utilities  have 
terms greater than one year. The Company is not required to disclose the transaction price allocated to remaining performance 
obligations because the variable consideration is allocated entirely to a wholly unsatisfied performance obligation. Under these 
contracts,  each  delivery  product  transferred  to  the  customer  represents  a  separate  performance  obligation;  therefore,  future 
quantities are wholly unsatisfied and disclosure of the transaction price allocated to remaining performance obligations is not 
required.

The  Company  will  also  sell  uranium  concentrate  to  the  U.S.  Uranium  Reserve  or  other  third  parties  and  such  contracts  are 
short-term  in  nature  with  a  contract  term  of  one  year  or  less.  Accordingly,  the  Company  is  exempt  from  disclosure  of  the 
transaction price allocated to remaining performance obligations if the performance obligation is part of a contract that has an 
original expected duration of one year or less.

Under the Company's uranium contracts, it invoices customers after the performance obligations have been satisfied, at which 
point payment is unconditional. Accordingly, the Company’s uranium contracts do not give rise to contract assets or liabilities. 

192

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Vanadium Concentrates

The Company's sales of vanadium concentrates are recognized when delivery is evidenced by book transfer at the applicable 
vanadium  storage  facility.  Under  the  Company's  vanadium  contracts,  it  invoices  customers  after  the  performance  obligations 
have been satisfied, at which point payment is unconditional. Accordingly, the Company’s vanadium contracts do not give rise 
to contract assets or liabilities.

RE Carbonate

The Company's sales of RE Carbonate revenue is recognized when delivery of the mixed RE Carbonate material has arrived at 
the applicable separation facility. Additionally, the Company will recognize revenue when the customer further processes the 
product from the RE Carbonate that the Company delivered and it is sold to a third party. Additionally, under this contract, each 
delivered product transferred to the customer represents a separate performance obligation; therefore, future volumes are wholly 
unsatisfied and disclosure of the transaction price allocated to remaining performance obligations is not required. Accordingly, 
the Company’s contracts do not give rise to contract assets or liabilities.

Alternate Feed Materials

Revenue  from  the  delivery  of  mineralized  material  received  from  the  clean-up  of  a  third-party  uranium  mine  or  for  other 
Alternate Feed Materials is typically recognized upon delivery to the Mill. Revenue from toll milling services is recognized as 
material is processed in accordance with the specifics of the applicable toll milling agreement. Revenue and unbilled accounts 
receivable are recorded as related costs are incurred using billing formulas included in the applicable toll milling agreement.

As of December 31, 2023 and 2022, the Company's receivables from its contracts with customers was $0.41 million and $0.09 
million, respectively.

17. 

RELATED PARTY TRANSACTIONS

Robert W. Kirkwood, a member of the Company’s Board of Directors, is a principal of the Kirkwood Companies, including 
Kirkwood  Oil  and  Gas  LLC,  Wesco  Operating,  Inc.,  and  United  Nuclear  LLC  (“United  Nuclear”).  United  Nuclear  owns 
a 19% interest in the Company’s Arkose Mining Venture while the Company owns the remaining 81%. The Company acts as 
manager  of  the  Arkose  Mining  Venture  and  has  management  and  control  over  operations  carried  out  by  the  Arkose  Mining 
Venture. The Arkose Mining Venture is a contractual joint venture governed by a venture agreement dated as of January 15, 
2008 and entered into by United Nuclear and Uranerz Energy Corporation, a wholly owned, indirectly held subsidiary of the 
Company (“Uranerz”) and United Nuclear (the “Venture Agreement”).

United Nuclear contributed $0.08 million, $0.13 million and $0.31 million to the expenses of the Arkose Joint Venture based on 
the approved budget for the years ended December 31, 2023, 2022 and 2021, respectively. 

On October 27, 2021, after closing on the sale of certain conventional uranium assets to CUR, the Company began providing 
services to CUR under a mine operating agreement. See Note 7 – Property, Plant and Equipment and Mineral Properties for 
more  information.  Pursuant  to  that  agreement,  the  Company  earned  $0.57  million  and  $0.45  million  during  the  years  ended 
December 31, 2023 and 2022, respectively. As of December 31, 2023 and 2022, the Company was due $0.05 million and $0.08 
million, respectively, from CUR for revenues earned under the mine operating agreements. Additionally, the Company accrued 
$1.53  million  and  $1.54  million  as  of  December  31,  2023  and  2022,  respectively,  in  Other  long-term  receivables  related  to 
deferred cash payments for production thresholds pursuant to the terms of the asset purchase agreement with CUR.

18. 

SUBSEQUENT EVENTS

Issued Capital Stock

The  Company  issued  a  total  of  0.62  million  Common  Shares  under  the  ATM  for  net  proceeds  of  $4.79  million,  after  share 
issuance costs, through various transactions from December 31, 2023 to February 23, 2024.

Issuance of RSUs and Stock Options

On January 25, 2024, the Company granted $2.78 million of RSUs at a grant price of $7.48 per share, $0.68 million of non-
incentive stock options with an exercise price of $7.48 per share, and $0.97 million of non-incentive stock options at a 10% 

193

premium with an exercise price of $8.23 per share to its employees and directors. The stock options carry a five-year life and 
vest as follows: 50% on January 25, 2025; and 50% on January 25, 2026. The RSUs vest as follows: 50% on January 27, 2025; 
25% on January 27, 2026; and 25% on January 27, 2027. Additionally, the Company granted $0.31 million non-incentive stock 
options with an exercise price of $7.48 per share to certain consultants (“Consultant Options”). The Consultant Options carry 
a three-year life and vest as follows: 50% on January 25, 2025; and 50% on January 25, 2026.

194

ITEM 9. CHANGES IN AND DISAGREEMENTS WITH ACCOUNTANTS ON ACCOUNTING AND FINANCIAL 
DISCLOSURE

During the period covered by this Annual Report, no director or officer of the Company adopted or terminated a “Rule 10b5–1
Trading Arrangement” or “non-Rule 10b5–1 trading arrangement,” as each term is defined in Item 408 of Regulation S-K.

Evaluation of Disclosure Controls and Procedures

ITEM 9A. CONTROLS AND PROCEDURES 

As of the end of the period covered by this Annual Report, an evaluation was carried out under the supervision of and with the 
participation of the Company’s management, including the Chief Executive Officer (“CEO”) and CFO, of the effectiveness of 
the design and operation of the Company’s disclosure controls and procedures (as defined in Rule 13a – 15(e) and Rule 15d – 
15(e) under the Exchange Act). Based on that evaluation, the CEO and the CFO have concluded that as of the end of the period 
covered  by  this  Annual  Report,  the  Company’s  disclosure  controls  and  procedures  were  effective  in  ensuring  that:  (i) 
information required to be disclosed by the Company in reports that it files or submits to the SEC under the Exchange Act is 
recorded, processed, summarized and reported within the time periods specified in applicable rules and forms; and (ii) material 
information  required  to  be  disclosed  in  its  reports  filed  under  the  Exchange  Act  is  accumulated  and  communicated  to  its 
management,  including  its  CEO  and  CFO,  as  appropriate,  to  allow  for  accurate  and  timely  decisions  regarding  required 
disclosure.

It  should  be  noted  that  while  the  CEO  and  CFO  believe  that  the  Company’s  disclosure  controls  and  procedures  provide  a 
reasonable level of assurance that they are effective, they do not expect that the Company’s disclosure controls and procedures 
or internal control over financial reporting will prevent all errors and fraud. A control system, no matter how well conceived or 
operated, can provide only reasonable, not absolute, assurance that the objectives of the control system are met.

Management’s Report on Internal Control over Financial Reporting

Management  is  responsible  for  establishing  and  maintaining  adequate  internal  control  over  financial  reporting,  as  defined  in 
Rule  13a-15(f)  under  the  Exchange  Act.  The  Company’s  management  has  employed  a  framework  consistent  with  Exchange 
Act Rule 13a-15(c), to evaluate the Company’s internal control over financial reporting described below. A company’s internal 
control  over  financial  reporting  is  a  process  designed  to  provide  reasonable  assurance  regarding  the  reliability  of  financial 
reporting  and  the  preparation  of  financial  statements  for  external  purposes  in  accordance  with  generally  accepted  accounting 
principles.

The senior executive officers, including the Company’s CEO and CFO, conducted an evaluation of the effectiveness, design 
and  operation  of  the  Company’s  internal  control  over  financial  reporting  as  of  December  31,  2023,  based  on  the  criteria 
established in Internal Control – Integrated Framework issued by the Committee of Sponsoring Organizations of the Treadway 
Commission  2013  framework.  This  evaluation  included  review  of  the  documentation  of  controls,  evaluation  of  the  design 
effectiveness of controls, testing of the operating effectiveness of controls and a conclusion on this evaluation. Based on this 
evaluation,  management  has  concluded  that  the  Company’s  internal  control  over  financial  reporting  was  effective  as  of 
December 31, 2023 and no material weaknesses were discovered. 

The effectiveness of our assessment of internal control over financial reporting as of December 31, 2023 has been audited by 
KPMG LLP, an independent registered public accounting firm, as stated in their report which appears herein. 

Changes in Internal Control Over Financial Reporting

During the year ended December 31, 2023, there were no changes in the Company’s internal control over financial reporting
that materially affected, or are likely to materially affect, the Company’s internal control over financial reporting.

None.

ITEM 9B. OTHER INFORMATION.

195

ITEM 9C. DISCLOSURE REGARDING FOREIGN JURISDICTIONS THAT PREVENT INSPECTIONS.

None.

196

PART III

ITEM 10. DIRECTORS, EXECUTIVE OFFICERS AND CORPORATE GOVERNANCE

Information  relating  to  this  item  will  be  included  in  the  proxy  statement  for  our  2024  Annual  and  Special  Meeting  of 
Shareholders and is incorporated by reference in this report.

Information  relating  to  this  item  will  be  included  in  the  proxy  statement  for  our  2024  Annual  and  Special  Meeting  of 
Shareholders and is incorporated by reference in this report.

ITEM 11. EXECUTIVE COMPENSATION

ITEM 12. SECURITY OWNERSHIP OF CERTAIN BENEFICIAL OWNERS AND MANAGEMENT AND 
RELATED STOCKHOLDER MATTERS

Information  relating  to  this  item  will  be  included  in  the  proxy  statement  for  our  2024  Annual  and  Special  Meeting  of 
Shareholders and is incorporated by reference in this report.

ITEM 13. CERTAIN RELATIONSHIPS AND RELATED TRANSACTIONS AND DIRECTOR INDEPENDENCE

INTEREST OF MANAGEMENT & OTHERS IN MATERIAL TRANSACTIONS

Information  relating  to  this  item  will  be  included  in  the  proxy  statement  for  our  2024  Annual  and  Special  Meeting  of 
Shareholders and is incorporated by reference in this report.

ITEM 14. PRINCIPAL ACCOUNTANT FEES AND SERVICES

Information  relating  to  this  item  will  be  included  in  the  proxy  statement  for  our  2024  Annual  and  Special  Meeting  of 
Shareholders and is incorporated by reference in this report.

ITEM 15. EXHIBITS AND FINANCIAL STATEMENT SCHEDULES

PART IV

Documents Filed as Part of This Report.

(1) Financial Statements

Report of Independent Registered Public Accounting Firm

Consolidated Statements of Operations and Comprehensive Income (Loss) for the years ended 
December 31, 2023, 2022 and 2021

Consolidated Balance Sheets as of December 31, 2023 and 2022
Consolidated Statements of Changes in Equity for the years ended December 31, 2023, 2022 and 2021

Consolidated Statements of Cash Flows for the years ended December 31, 2023, 2022 and 2021

Notes to the Consolidated Financial Statements

(2) Financial Statement Schedules

Schedules are omitted and are not applicable or not required, or the required information is shown in the financial statements or 
notes thereto.

197

 
 
 
 
 
 
(3) Exhibits

Where an exhibit is filed by incorporation by reference to a previously filed registration statement or report, such registration 
statement or report is identified in parentheses.

Exhibit 
No.

Document Description

3.1

3.2

3.3

4.1

4.2

10.1

10.2

10.3

10.4

10.5

10.6

10.7

Articles of Continuance dated September 2, 2005 (1)

Articles of Amendment dated May 26, 2006 (2)

By-laws (3)

Shareholder Rights Plan Agreement between Energy Fuels Inc. and American Stock Transfer & Trust Company, 
LLC dated March 18, 2021 (4)

Description of the Company’s Securities Registered Under Section 12 of the Securities Exchange Act of 1934

Uranerz Energy Corporation 2005 Nonqualified Stock Option Plan, Amended and Restated June 2011 (5)

2021 Omnibus Equity Incentive Compensation Plan, as amended and restated as of March 18, 2021 (6)

Form of Indemnity Agreement between Energy Fuels Inc. and its officers and directors (7)

Amended and Restated Employment Agreement by and between Energy Fuels Resources (USA) Inc. and Mark S. 
Chalmers dated March 31, 2023 (8)

Amended and Restated Employment Agreement by and between Energy Fuels Resources (USA) Inc. and David 
C. Frydenlund dated March 31, 2023 (9)

Amended and Restated Employment Agreement by and between Energy Fuels Resources (USA) Inc. and Curtis 
H. Moore dated March 31, 2023 (10)

Employment  Agreement  by  and  between  Energy  Fuels  Inc.  and  Dee  Ann  Nazarenus  dated  September  1,  2020 
(11)

10.8

Employment Agreement by and between Energy Fuels Inc. and Scott Bakken dated September 1, 2020 (12)

10.9

Sales Agreement by and among Energy Fuels Inc., Cantor Fitzgerald & Co., H.C. Wainwright & Co., LLC and 
Roth Capital Partners, LLC, dated May 6, 2019 (13)

14.1

Energy Fuels Inc. Code of Business Conduct and Ethics 

19.1

21.1

Energy Fuels Inc. Insider Trading Policy 

An organizational chart showing Energy Fuels Inc.’s direct and indirect subsidiaries

23.1

Consent of KPMG LLP

23.2

Consent of Grant A. Malensek

198

 
 
 
 
 
 
 
 
 
 
 
 
 
Exhibit 
No.

Document Description

23.3

Consent of Jeremy Scott Collyard

23.4

Consent of Phillip E. Brown

23.5

Consent of David M. Robson

23.6

Consent of Mark B. Mathisen

23.7

Consent of Douglas L. Beahm

23.8

Consent of Daniel Kapostasy

23.9

Consent of Terence McNulty

23.10

Consent of Jeffrey Woods

23.11

Consent of R. Dennis Bergen

23.12

Consent of Lee (Pat) Gochnour

23.13

Consent of Travis Boam 

23.14

Consent of Smythe LLP

31.1

Certification of Chief Executive Officer pursuant to Rule 13a-14(a) of the Exchange Act

31.2

Certification of Chief Financial Officer pursuant to Rule 13a-14(a) of the Exchange Act

32.1

32.2

Certification of Chief Executive Officer pursuant to Rule 13a-14(b) of the Exchange Act and 18 U.S.C. Section 
1350, as adopted pursuant to Section 906 of the Sarbanes-Oxley Act of 2002

Certification of Chief Financial Officer pursuant to Rule 13a-14(b) of the Exchange Act and 18 U.S.C. Section 
1350, as adopted pursuant to Section 906 of the Sarbanes-Oxley Act of 2002

95.1

Mine Safety Disclosure

96.1

96.2

96.3

“Preliminary Feasibility Study for the Sheep Mountain Project, Fremont County, Wyoming, USA,” dated January 
30, 2023 with an effective date of December 31, 2021 (14)

“Technical Report on the Pre-Feasibility Study on the Pinyon Plain Project, Coconino County, Arizona, USA,” 
dated February 23, 2023 with an effective date of December 31, 2022 (15)

“Technical Report on the Roca Honda Project, McKinley County, New Mexico, USA,” dated February 22, 2022 
(16)

96.4

“Technical Report on the Bullfrog Project, Garfield County, Utah, USA,” dated February 22, 2022 (17)

199

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Exhibit 
No.

96.5

Document Description

“Technical  Report  on  the  Nichols  Ranch  Project,  Campbell  and  Johnson  Counties,  Wyoming  USA,”  dated 
February 22, 2022 with an effective date of December 31, 2021, as amended February 8, 2023 (18)

96.6

“Technical Report on the La Sal Project, San Juan County, Utah, USA,” dated February 22, 2022 (19)

96.7

“Technical Report Summary for the Alta Mesa Uranium Project, Brooks and Jim Hogg Counties, Texas, USA,” 
dated December 31, 2021 (20)

97.1

Energy Fuels Inc. Incentive-Based Compensation Clawback Policy 

99.1

Unaudited Consolidated Financial Statements of Virginia Energy Resources Inc. as at January 23, 2023 and for 
the 23-day period ended January 23, 2023, as at December 31, 2022 and the year ended December 31, 2022 and 
the Audited Consolidated Financial Statements of Virginia Energy Resources Inc. for the year ended December 
31, 2021

101.INS        XBRL Instance Document.
101.SCH 
XBRL Taxonomy Extension Schema Document.
101.CAL  XBRL Taxonomy Extension Calculation Linkbase Document.
XBRL Taxonomy Extension Definition Linkbase Document. 
101.DEF 
101.LAB  XBRL Taxonomy Extension Labels Linkbase Document. 
101.PRE 
104 

XBRL Taxonomy Extension Presentation Linkbase Document.
Cover Page Interactive Data File (embedded within the Inline XBRL document)

Certain schedules and exhibits have been omitted in compliance with Regulation S-K Item 601(a)(5). The Company agrees to 
furnish a copy of any omitted schedule or exhibit to the SEC upon its request. 

(1) Incorporated by reference to Exhibit 3.1 of Energy Fuels’ Form F-4 filed with the SEC on May 8, 2015.
(2) Incorporated by reference to Exhibit 3.2 of Energy Fuels’ Form F-4 filed with the SEC on May 8, 2015.
(3) Incorporated by reference to Exhibit 3.3 of Energy Fuels’ Form F-4 filed with the SEC on May 8, 2015.
(4) Incorporated by reference to Appendix B of Energy Fuels’ Schedule 14A filed with the SEC on April 2, 2021.
(5) Incorporated by reference to Exhibit 4.2 to Energy Fuels’ Form S-8 filed with the SEC on June 24, 2015. 
(6) Incorporated by reference to Appendix A to Energy Fuels’ Schedule 14A filed with the SEC on April 2, 2021. 
(7) Incorporated by reference to Exhibit 10.4 to Energy Fuels’ Form 10-K filed with the SEC on March 15, 2016.
(8) Incorporated by reference to Exhibit 10.1 to Energy Fuels’ Form 8-K filed with the SEC on April 4, 2023.
(9) Incorporated by reference to Exhibit 10.3 to Energy Fuels’ Form 8-K filed with the SEC on April 4, 2023.
(10) Incorporated by reference to Exhibit 10.5 to Energy Fuels’ Form 8-K filed with the SEC on April 4, 2023.
(11) Incorporated by reference to Exhibit 10.5 to Energy Fuels’ Form 10-Q filed with the SEC on November 2, 2020. 
(12) Incorporated by reference to Exhibit 10.6 to Energy Fuels’ Form 10-Q filed with the SEC on November 2, 2020.
(13) Incorporated by reference to Exhibit 10.1 to Energy Fuels’ Form 10-Q filed with the SEC on August 5, 2019. 
(14) Incorporated by reference to Exhibit 99.2 to Energy Fuels’ Form 8-K filed with the SEC on March 1, 2023.
(15) Incorporated by reference to Exhibit 99.3 to Energy Fuels’ Form 8-K filed with the SEC on March 1, 2023. 
(16) Incorporated by reference to Exhibit 99.6 to Energy Fuels’ Form 8-K filed with the SEC on March 11, 2022. 
(17) Incorporated by reference to Exhibit 99.2 to Energy Fuels’ Form 8-K filed with the SEC on March 11, 2022. 
(18) Incorporated by reference to Exhibit 99.1 to Energy Fuels’ Form 8-K filed with the SEC on March 1, 2023. 
(19) Incorporated by reference to Exhibit 99.3 to Energy Fuels’ Form 8-K filed with the SEC on March 11, 2022. 
(20) Incorporated by reference to Exhibit 99.1 to Energy Fuels’ Form 8-K filed with the SEC on March 11, 2022.

None.

ITEM 16. FORM 10-K SUMMARY

200

Pursuant to the requirements of Section 13 or 15(d) of the Securities Exchange Act of 1934, the registrant has duly caused this 
report to be signed on its behalf by the undersigned, thereunto duly authorized.

SIGNATURES 

ENERGY FUELS INC. 

By:

/s/ Mark S. Chalmers
Mark S. Chalmers, President & Chief Executive 
Officer
Principal Executive Officer
Date: February 23, 2024

201

 
 
 
 
 
 
 
In accordance with the Securities Exchange Act, this report has been signed below by the following persons on behalf of the 
registrant and in the capacities and on the dates indicated.

Per:  /s/ Mark S. Chalmers

Mark S. Chalmers, President & Chief Executive 
Officer
(Principal Executive Officer) and Director 
Date: February 23, 2024

Per:

/s/ Nathan R. Bennett
Nathan R. Bennett, Chief Accounting Officer and 
Interim Chief Financial Officer
(Principal Financial Officer)
Date: February 23, 2024

Per:  /s/ J. Birks Bovaird 

J. Birks Bovaird, Director
Date: February 23, 2024

Per:  /s/ Benjamin Eshleman III

Benjamin Eshleman III, Director
Date: February 23, 2024

Per:

/s/ Ivy V. Estabrooke
Ivy V. Estabrooke, Director
Date: February 23, 2024

Per:  /s/ Barbara A. Filas

Barbara A. Filas, Director
Date: February 23, 2024

Per:  /s/ Bruce D. Hansen 

Bruce D. Hansen, Director
Date: February 23, 2024

Per:

/s/ Jaqueline Herrera
Jaqueline Herrera, Director
Date: February 23, 2024

Per:

/s/ Dennis L. Higgs
Dennis L. Higgs, Director
Date: February 23, 2024

Per:

/s/ Robert Kirkwood
Robert Kirkwood, Director
Date: February 23, 2024

Per:

/s/ Alexander Morrison
Alexander Morrison, Director
Date: February 23, 2024

202

 
  
 
  
 
  
 
  
  
 
 
  
 
  
 
  
  
 
 
  
 
  
 
  
  
 
 
  
 
  
 
  
  
 
 
  
 
  
 
  
  
 
 
 
  
 
DESCRIPTION OF THE REGISTRANT’S SECURITIES
REGISTERED PURSUANT TO SECTION 12 OF THE
SECURITIES EXCHANGE ACT OF 1934

Exhibit 4.2

As of the date of the Annual Report on Form 10-K of which this Exhibit 4.2 is a part, Energy Fuels Inc. (the “Company”) has 
one  class  of  securities  registered  under  Section  12  of  the  Securities  Exchange  Act  of  1934,  as  amended:  (1)  the  Company’s 
common shares (the “Common Shares”).

Description of Common Shares

The  following  description  of  our  Common  Shares  is  a  summary  and  does  not  purport  to  be  complete.  It  is  subject  to  and 
qualified in its entirety by reference to our Articles of Continuance, Articles of Amendment and our By-laws, each of which are 
incorporated by reference as an exhibit to the Annual Report on Form 10-K of which this Exhibit 4.2 is a part. 

Authorized Capital Shares 

We are authorized to issue an unlimited number of Common Shares, without par value. 

Voting Rights

Holders of Common Shares are entitled to one vote per Common Share at all meetings of shareholders, including the election of 
directors. Our Common Shares do not have cumulative voting rights.

Dividend and Liquidation Rights

The holders of Common Shares are entitled to receive dividends as and when declared by our Board of Directors and to receive 
a pro rata share of the assets of the Company available for distribution to the holders of Common Shares in the event of the 
liquidation, dissolution or winding-up of the Company.

Other Rights and Preferences

There are no preemptive, conversion or redemption rights attached to the Common Shares. 

Listing

The  primary  trading  market  for  the  Common  Shares  is  the  NYSE  American  under  the  trading  symbol  “UUUU,”  and  the 
Common Shares are also listed on the TSX under the trading symbol “EFR.”

ENERGY FUELS INC.
CODE OF BUSINESS CONDUCT AND ETHICS

(As Approved by the Board on January 25, 2024)

Exhibit 14.1 

Energy  Fuels  Inc.,  together  with  its  subsidiaries  (collectively,  “Energy  Fuels”  or  the  “Company”),  is 
committed  to  conducting  its  business  in  accordance  with  all  applicable  laws  and  regulations  and  the 
highest  ethical  standards.  This  Code  of  Business  Conduct  and  Ethics  (the  “Code”)  summarizes  the 
standards  that  guide  the  actions  of  Energy  Fuels’  directors,  officers  and  employees.  This  Code  is  to  be 
read  together  with  Energy  Fuels’  Corporate  Disclosure  Policy,  Insider  Trading  Policy,  Whistleblower 
Policy, Environment, Health, Safety and Sustainability Policy, Employee Handbook and other policies of 
the Company.

All  directors,  officers,  and  employees  of  Energy  Fuels  must  read  and  fully  comply  with  this  Code.    In 
addition, all directors, officers, and employees must take all reasonable steps to prevent contraventions of 
this Code, to identify and raise issues before they lead to problems, and to seek additional guidance when 
necessary.  If  breaches  of  this  Code  occur,  they  must  be  reported  promptly.  Employees  with  questions 
concerning this Code may contact the Chief Legal Officer (“CLO”) (or the CLO’s designee) at any time.  
Complaints  or  concerns  are  to  be  reported  to  the  CLO  or  Vice  President,  Human  Resources  and 
Administration  or,  in  the  case  of  complaints  or  concerns  raised  by  directors,  to  the  Chair  of  the  Audit 
Committee  (the  “Audit  Committee”)  of  the  Board  of  Directors  of  the  Company  (the  “Board”).    In 
addition,  any  complaints  or  concerns  arising  under  this  Code  may  be  reported  under  the  Company’s 
Whistleblower Policy.

Violations of this Code by a director, officer or employee are grounds for disciplinary action, up to and 
including immediate termination and possible legal prosecution.

Energy Fuels also expects all agents, consultants and contractors to comply with this Code.  

This Code has been implemented pursuant to the provisions of National Instrument 58-201 – Corporate 
Governance  –  promulgated  by  the  Canadian  Securities  Administrators  and  complies  with  the 
requirements  for  a  “code  of  ethics”  as  set  forth  in  section  406  of  the  Sarbanes-Oxley  Act  of  2002 
(“SOX”) and the rules of the NYSE American Company Guide.

1. Core Principles

This Code sets out written standards that are designed to deter wrongdoing and to promote:

• Honest  and  ethical  conduct,  including  the  ethical  handling  of  actual  or  apparent  conflicts  of 

interest between personal and professional relationships;

•

Full,  fair,  accurate,  timely  and  understandable  disclosure  in  reports  and  documents  that  Energy 
Fuels  files  with,  or  submits 
in  other  public 
communications made by Energy Fuels;

to,  applicable  securities  regulators  and 

• Compliance with applicable laws, rules and regulations;

•

The prompt internal reporting to an appropriate person or persons of violations of this Code; and

• Accountability for adherence to this Code.

While covering a wide range of business practices and procedures, this Code cannot, and does not, cover 
every issue that may arise, or every situation in which ethical decisions must be made, but rather sets forth 
key guiding principles of business conduct that Energy Fuels expects of all of its directors, officers and 
employees. 

2. Conduct Under the Law

Compliance with Laws, Rules, and Regulations

Energy Fuels, and each of Energy Fuels’ directors, officers and employees, shall conduct their business 
affairs with honesty and integrity and in full compliance with all applicable laws, rules, regulations, and 
this Code.

• No director, officer or employee shall commit an illegal or unethical act, or instruct or authorize 
others  to  do  so,  for  any  reason,  in  connection  with  any  act,  decision  or  activity  that  is  or  may 
appear to be related to that person’s employment by or position with Energy Fuels;

• All situations shall be avoided which could be perceived as improper, unethical or indicative of a 

casual attitude towards compliance with the law or regulations; and

• All  directors,  officers  and  employees  are  expected  to  be  sufficiently  familiar  with  the  laws  and 
regulations that apply to their jobs and shall recognize potential liabilities, seeking advice where 
appropriate.  

• All  directors,  officers and  employees have an individual responsibility for accurate and truthful 
statements in all matters, including without limitation SOX controls (to the extent applicable).

Insider Trading  

All  non-public  information  about  Energy  Fuels  or  its  partners  should  be  considered  confidential 
information. Directors, officers, and employees of Energy Fuels must always maintain the confidentiality 
of  such  non-public  information  and  never  trade  in  Energy  Fuels  securities  when  aware  of  such 
information,  nor  use  such  information  to  “tip”  others  who  might  be  reasonably  expected  to  make  an 
investment decision on the basis of this information.  Such actions are not only unethical, but also illegal. 
The  Company  has  adopted  a  Corporate  Disclosure  Policy  and  an  Insider  Trading  Policy  that  set  forth 
these principles. All levels of management and all employees are responsible for compliance with those 
policies.  For  further  information,  please  see  the  Company’s  Corporate  Disclosure  Policy  and  Insider 
Trading Policy. If you have any questions, please consult Energy Fuels’ CLO.  

Fraud, Bribery and Corruption  

Directors, officers, and employees are strictly prohibited from engaging in, condoning, or tolerating fraud, 
bribery, corruption, or other illegal or unethical actions. Fraud is an intentional act or omission designed 
to deceive another person or to obtain a benefit to which one is not entitled. Bribery is an intentional offer 
of  monetary  or  other  benefit  to  another  person,  government  official,  company  or  other  organization  to 
secure,  or  attempt  to  secure,  a  benefit  in  the  performance  of  a  duty,  to  obtain  or  retain  business,  or  to 
obtain  any  other  improper  advantage  in  the  conduct  of  business.  Fraud  can  include  a  wide  range  of 
activities,  such  as  falsifying  records  or  timesheets,  creating  false  benefits  claims,  and  misappropriating 
corporate assets, including proprietary information and corporate opportunities for personal gain. Bribery 
can take different forms, such as cash payments, bartering transactions, kickbacks, directing business to a 
particular person, extravagant hospitality, or providing other services or things of value.  

Fair Competition

Energy Fuels believes in fair competition and is committed to complying with the laws of all countries 
which prohibit restraints of trade, unfair practices or abuses of power. Directors, officers, and employees 
of  Energy  Fuels  shall  not  discuss  or  enter  into  arrangements  with  business  partners  or  competitors  that 
unlawfully  restrict  Energy  Fuels’  ability  to  compete  with  other  businesses,  or  the  ability  of  any  other 
business to compete freely with Energy Fuels.

Payments to Government Personnel; Political Contributions

The  U.S.  Foreign  Corrupt  Practices  Act  prohibits  giving  anything  of  value,  directly  or  indirectly,  to 
officials of foreign governments or foreign political candidates in order to obtain or retain business. It is 
strictly prohibited to make illegal payments to government officials of any country.

In addition, the U.S. government has a number of laws and regulations restricting the giving of business 
gratuities to U.S. government personnel. The promise, offer or delivery to an official or employee of the 
U.S.  government  of  a  gift,  favor  or  other  gratuity  in  violation  of  these  rules  would  not  only  violate 
Company  policy  but  could  also  be  a  criminal  offense.  State  and  local  governments,  as  well  as  foreign 
governments, may have similar rules.

The Company may contribute, directly or indirectly, to political campaigns or parties from time to time 
with the approval of the Chief Executive Officer or the Chief Financial Officer. Employees, officers and 
members  of  the  Board  may  not  use  Company  expense  accounts  to  pay  for  any  personal  political 
contributions  or  seek  any  other  form  of  Company  reimbursement.  In  addition,  employees,  officers  or 
members  of  the  Board  should  not  use  Company  facilities  or  Company  assets,  including  the  time  of 
Company personnel for the benefit of any party or candidate, including an employee, officer or member 
of the board individually running for office.

Payments to Domestic and Foreign Officials

Employees  and  officers  of  the  Company  must  comply  with  all  applicable  laws  prohibiting  improper 
payments  to  domestic  and  foreign  officials,  including  the  Corruption  of  Foreign  Public  Officials  Act 
(Canada) and the Foreign Corrupt Practices Act (United States) (collectively, the “Acts”).

The Acts make it illegal for any person, in order to obtain or retain an advantage in the course of business, 
directly or indirectly, to offer or agree to give or offer a loan, reward, advantage or benefit of any kind to 
a  foreign  public  official  or  to  any  person  for  the  benefit  of  a  public  official.  Foreign  public  officials 
include persons holding a  legislative, administrative or judicial position of a foreign state, persons who 
perform public duties or functions for a foreign state (such as persons employed by board, commissions 
or government corporations), officials and agents of international organizations, foreign political parties 
and candidates for office.

Although  “facilitated  payments”  or  certain  other  transactions  may  be  exempted  or  not  illegal  under 
applicable  law,  the  Company’s  policy  is  to  avoid  them.  If  any  employee  or  officer  has  any  questions 
about the application of this policy to a particular situation, please report to the Chief Executive Officer, 
Chief Financial Officer or CLO or such other senior officer as may be designated by the Company from 
time to time who, with the advice of counsel as necessary, will determine acceptability from both a legal 
and a corporate policy point of view, and any appropriate accounting treatment and disclosures which are 
applicable to the particular situation. 

Violation of the Acts is a criminal offence, subjecting the Company to substantial fines and penalties and 
any officer, director or employee acting on behalf of the Company to imprisonment and fines. Violation 

of  this  Code  on  this  basis  may  result  in  disciplinary  actions  up  to  and  including  discharge  from  the 
Company.

3. Conduct within Energy Fuels

Conflicts of Interest

All directors, officers and employees have an obligation to act in the best interest of the Company. Any 
situation  that  presents  an  actual  or  potential  conflict  between  a  director,  officer  or  employee’s  personal 
interests  and  the  interests  of  Energy  Fuels  should  be  reported  to  the  CLO  or,  in  the  case  of  reports  by 
directors, to the Chair of the Company’s Audit Committee.  

Any  Director,  officer  or  employee  has  a  conflict  of  interest  when  his  or  her  personal  interests, 
relationships  or  activities,  or  those  of  a  member  of  his  or  her  immediate  family  or  business  associate, 
interfere  or  conflict,  or  even  appear  to  interfere  or  conflict,  with  Energy  Fuels’  interests.  A  conflict  of 
interest  can  arise  when  any  director,  officer  or  employee  takes  an  action  or  has  a  personal  interest  that 
may  adversely  influence  his  or  her  objectivity  or  the  exercise  of  sound,  ethical  business  judgment. 
Conflicts  of  interest  can  also  arise  when  any  director,  officer  or  employee,  or  a  member  of  his  or  her 
immediate family, receives improper personal benefits as a result of his or her position at Energy Fuels. 
No director, officer or employee shall improperly benefit, directly or indirectly, from his or her status as 
director, officer or employee of Energy Fuels, or from any decision or action by Energy Fuels that he or 
she is in a position to influence.  

By way of example, a conflict of interest may arise if any director, officer or employee:

• Has a material personal interest in a transaction or agreement involving Energy Fuels;

• Accepts  a  gift,  service,  payment  or  other  benefit  (other  than  a  nominal  gift)  from  a  competitor, 
supplier,  or  customer  of  Energy  Fuels,  or  any  entity  or  organization  with  which  Energy  Fuels 
does business or seeks or expects to do business;

•

Lends to, borrows from, or has a material interest in a competitor, supplier, or customer of Energy 
Fuels, or any entity or organization with which Energy Fuels does business or seeks or expects to 
do business (other than routine investments in publicly traded companies);

• Knowingly competes with Energy Fuels or diverts a business opportunity from Energy Fuels;

•

Serves as an officer, director, employee, consultant, or in any management capacity, in an entity 
or organization with which Energy Fuels does business or seeks or expects to do business (other 
than  routine  business  involving  immaterial  amounts,  in  which  the  director,  officer  or  employee 
has no decision-making or other role);

• Knowingly acquires, or seeks to acquire an interest in property (such as real estate, patent rights, 

securities, or other properties) where Energy Fuels has, or might have, an interest; or

•

Participates in a venture in which Energy Fuels has expressed an interest. 

Directors,  officers  and  employees  are  expected  to  use  common  sense  and  good  judgment  in  deciding 
whether a potential conflict of interest may exist.

Protection and Proper Use of Corporate Assets and Opportunities  

Theft, carelessness and waste have a direct, negative impact on Energy Fuels’ image and profitability, and 
will  not  be  tolerated.  Directors,  officers  and  employees  owe  a  duty  to  Energy  Fuels  to  advance  its 
legitimate  interests  when  the  opportunity  to  do  so  arises.  All  directors,  officers  and  employees  shall 
endeavor to protect Energy Fuels’ assets and ensure their efficient use.  

Directors, officers and employees are prohibited from (a) taking for themselves property, security or any 
business  interest,  or  other  opportunities  that  are  discovered  through  the  use  of  Energy  Fuels’  property, 
information or position; and (b) using Energy Fuels’ property, information, or position for personal gain.  
By way of example, the following types of activities are prohibited:

• Using Energy Fuels assets for other business or personal endeavors; or

• Obtaining,  or  seeking  to  obtain,  any  personal  benefit  from  the  use  or  disclosure  of  information 
that is confidential or proprietary to Energy Fuels, or from the use or disclosure of confidential or 
proprietary  information  about  another  entity  acquired  as  a  result  of  or  in  the  course  of 
employment with Energy Fuels. 

All of Energy Fuels’ assets should only be used for legitimate business purposes, and the use of Energy 
Fuels’  property  for  any  unlawful,  unauthorized  or  unethical  purpose  is  strictly  prohibited.  No  directors, 
officers  or  employees  shall  intentionally  damage  or  destroy  the  property  of  Energy  Fuels  or  commit  or 
condone theft.  

Confidentiality of Corporate Information  

Directors, officers and employees must maintain the confidentiality of information entrusted to them by 
Energy  Fuels  or  its  customers,  except  when  disclosure  is  authorized  or  legally  mandated.  Confidential 
information includes (without limitation) all non-public information that might be of use to competitors or 
might be harmful to Energy Fuels or its partners and associates, if disclosed. For further information, see 
the Company’s Corporate Disclosure Policy.

Proper Use of Computers and the Internet

Energy Fuels’ information technology systems, including (without limitation) computers, email, internet, 
telephones,  and  voicemail,  are  the  property  of  Energy  Fuels  and  are  to  be  used  primarily  for  business 
purposes. Corporate information technology systems may be used for minor or incidental use, provided 
that such use is kept to a minimum and is in compliance with corporate policy. Energy Fuels’ information 
technology systems shall not be used to send harassing, threatening or obscene messages or chain letters, 
to  access  the  internet  for  inappropriate  use,  or  to  send  or  distribute  copyrighted  documents  (without 
proper  permissions).  Energy  Fuels  may  monitor  the  use  of  its  information  technology  systems  for 
business  purposes  or  to  conduct  internal  investigations  if  approved  by  the  Chief  Executive  Officer  and 
CLO.

4. Conduct with the Company’s Shareholders and the Public

Quality of Public Disclosure  

Energy Fuels is committed to providing information about the Company to the public in a manner that is 
consistent with all applicable legal and regulatory requirements and that promotes investor confidence by 
facilitating  fair,  orderly,  and  efficient  behavior.  Energy  Fuels’  reports  and  documents  filed  with  or 
submitted to securities and other regulators in Canada, the United States, Brazil and elsewhere as may be 

required,  and  Energy  Fuels’  other  public  communications,  must  include  full,  fair,  accurate,  timely,  and 
understandable  disclosure.  All  directors,  officers  and  employees  who  are  involved  in  Energy  Fuels’ 
disclosure  process  are  responsible  for  using  their  best  efforts  to  ensure  that  Energy  Fuels  meets  such 
requirements. Directors, officers and employees are prohibited from knowingly misrepresenting, omitting 
or causing others to misrepresent or omit material information about Energy Fuels to others, including to 
Energy  Fuels’  independent  auditors.  For  further  information,  see  the  Company’s  Corporate  Disclosure 
Policy.

Retention of Records

Energy  Fuels  retains  all  business  records  in  accordance  with  laws  and  regulations.  The  term  “business 
records”  covers  a  broad  range  of  files,  reports,  business  plans,  receipts,  policies  and  communications, 
including  hard  copy  and  electronic  whether  maintained  at  work  or  at  home.  Energy  Fuels  prohibits  the 
unauthorized destruction of or tampering with any records, whether written or in electronic form, where 
Energy Fuels is required by law or government regulation to maintain such records or where it has reason 
to know of a threatened or pending government investigation or litigation relating to such records.

5. Conduct  with  Customers,  Security  Holders,  Vendors,  Suppliers,  Competitors  and 

Employees

Dealing with Security Holders, Customers, Suppliers, Competitors and Employees

Directors,  officers  and  employees  shall  deal  honestly,  fairly  and  ethically  with  all  of  Energy  Fuels’ 
security  holders,  customers,  vendors,  suppliers,  competitors  and  employees.  In  all  such  dealings, 
directors,  officers  and  employees  shall  comply  with  all  laws,  rules  and  regulations  and  not  take  any 
actions  that  would  bring  into  question  the  integrity  of  Energy  Fuels  or  any  of  its  directors,  officers  or 
employees.

All  directors,  officers,  and  employees  shall  ensure  that  Energy  Fuels’  assets  are  used  for  legitimate 
business purposes only and that all transactions shall be made exclusively on the basis of price, quality, 
service and suitability to Energy Fuels’ needs.

Energy Fuels shall only deal with vendors, suppliers and contractors who comply with all applicable legal 
requirements  and  Energy  Fuels’  published  standards  and  policies,  including  this  Code  of  Business 
Conduct and Ethics and those relating to health and safety, environmental protection, sustainability, anti-
corruption and workplace rights.

Agreements with Agents, Consultants and Contractors

Agreements  with  agents,  consultants  and  contractors  should  include  terms  requiring  compliance  with 
applicable  laws,  regulations,  and,  where  applicable,  this  Code  and  providing  for  remedies,  up  to  and 
including termination, for failure to so comply.

6. Conduct with respect to Health, Safety, the Environment and Sustainability

Health and Safety  

Energy Fuels is committed to making the work environment safe, secure and healthy for its employees 
and  others  and  complies  with  all  applicable  laws  and  regulations  relating  to  worker  health  and  safety. 
Energy Fuels expects each director, officer, and employee to promote a positive working environment for 
all and to comply with Energy Fuels’ policies concerning health and safety matters. An employee should 
immediately report any unsafe or hazardous conditions or materials, injuries and accidents connected with 

Energy  Fuels’  business  and  any  activity  that  compromises  his  or  her  security  to  his  or  her  supervisor.  
Directors,  officers  and  employees  must  not  possess  or  use,  buy  or  sell  illegal  drugs  or  report  for  work 
under  the  influence  of  such  drugs,  marijuana,  or  alcohol,  and  must  comply  with  all  applicable  internal 
policies relating thereto. All threats or acts of physical violence or intimidation are prohibited. For further 
information, please see the specific safety manuals and procedures applicable to the Company’s various 
areas of operations.

Environmental Protection and Sustainability  

Energy Fuels is committed to the operation of its facilities in a manner that puts the safety of its workers, 
its contractors, its community, the environment and the principles of sustainable development above all 
else.  Whenever  issues  of  safety  conflict  with  other  corporate  objectives,  safety  shall  be  the  first 
consideration. The Company has adopted an Environment, Health, Safety and Sustainability Policy that 
sets  forth  these  principles.  All  levels  of  management  and  all  employees  are  responsible  for  compliance 
with  the  Environment,  Health,  Safety  and  Sustainability  Policy  within  their  areas  of  responsibility.  For 
further information, please see the Company’s Environment, Health, Safety and Sustainability Policy.

7. Conduct within the Workplace

Respect for Our Employees  

The  Company’s  employment  decisions  will  be  based  on  reasons  related  to  its  business,  such  as  job 
performance,  individual  skills  and  talents,  and  other  business-related  factors.  Energy  Fuels  requires 
adherence  to  all  applicable  federal,  state  and  provincial  employment  laws.  In  addition  to  any  other 
requirements of applicable laws in a particular jurisdiction, Energy Fuels prohibits discrimination in any 
aspect of employment based on race, color, appearance, religion, sex, gender, sexual orientation, gender 
identity  or  gender  expression,  national  origin,  ethnicity,  disability  or  age  (collectively,  “Diversity”), 
within the meaning of applicable laws.  

Abusive or Harassing Conduct Prohibited  

Energy  Fuels  and  its  directors,  officers  and  employees  shall  treat  each  other  with  professional  courtesy 
and  respect  at  all  times  and  specifically  must  not  subject  any  other  employee  to  unwelcome  sexual 
advances, requests for sexual favors, verbal or physical conduct which might be construed as sexual or 
harassing in nature, comments based on Diversity, or other non-business personal comments of conduct 
that  makes  others  uncomfortable  in  their  employment  with  Energy  Fuels.  Any  employee  who  believes 
that he or she has been subjected to sexual harassment by any other employee should immediately advise 
his  or  her  supervisor  and  the  CLO  or  Vice  President,  Human  Resources  and  Administration  of  the 
incident.  The  identity  of  those  involved  shall  be  kept  strictly  confidential.  The  incident  shall  be 
thoroughly investigated and documented with appropriate action taken.

Privacy  

Energy Fuels (and third parties who may be authorized by Energy Fuels) collects and maintains personal 
information  that  relates  to  each  employee’s  employment,  including  compensation,  medical  and  benefit 
information. Energy Fuels  follows procedures and applicable laws to protect information wherever  it is 
stored  or  processed,  and  access  to  employees’  personal  information  is  restricted.  Employee  personal 
information  will  only  be  released  to  outside  parties  in  accordance  with  Energy  Fuels’  policies  and 
applicable  legal  requirements.  Employees  who  have  access  to  personal  information  must  ensure  that 
personal  information  is  not  disclosed  in  violation  of  Energy  Fuels’  policies  or  practices  or  applicable 
laws.

8. Administration of this Code

Periodic Review by Board

This  Code  has  been  adopted  by  the  Board  and  will  be  reviewed  on  an  annual  basis  by  the  Audit 
Committee and by the Board and amended or supplemented as required from time to time.

Compliance with this Code and Reporting of Any Illegal or Unethical Behavior  

Directors,  officers  and  employees  are  expected  to  comply  with  all  of  the  provisions  of  this  Code.  This 
Code  will  be  strictly  enforced.  Violations  will  be  dealt  with  immediately,  including  subjecting  the 
director,  officer  or  employee  to  corrective  and/or  disciplinary  action,  including  without  limitation, 
dismissal or removal from office. Violations of this Code that involve unlawful conduct will be reported 
to the appropriate authorities.  

Situations  that  may  involve  a  violation  of  ethics,  laws,  or  this  Code  may  not  always  be  clear  and  may 
require  difficult  judgment.  Directors,  officers  or  employees  who  have  concerns  or  questions  about 
violations of laws, rules or regulations, or of this Code should report them to the CLO or, in the case of 
reports by directors, to the Chair of the Audit Committee. Any concern under this Code, as well as any 
concerns  that  involve  accounting,  internal  controls  and  auditing  matters,  may  also  be  reported  by 
employees on a confidential and anonymous basis under Energy Fuels’ Whistleblower Policy.  

Following receipt of any complaints submitted hereunder, the CLO or Chair of the Audit Committee, as 
the  case  may  be,  will  investigate  each  matter  so  reported  and  report  to  the  Audit  Committee. 
Notwithstanding  the  foregoing,  matters  of  fraud,  bribery  and  corruption  shall  be  escalated  to,  and  have 
direct  executive  oversight  from,  the  Chief  Executive  Officer.  The  Audit  Committee  will  have  primary 
authority and responsibility for the enforcement of this Code, subject to the supervision of the Board.  

Energy Fuels encourages all directors, officers, and employees to report promptly any suspected violation 
of  this  Code  to  the  CLO,  Vice  President,  Human  Resources  and  Administration,  or,  in  the  case  of 
directors, to the Chair of the Audit Committee.  Open communication of issues and concerns without fear 
of  retribution  or  retaliation  is  vital  to  the  successful  implementation  of  this  Code.    Therefore,  Energy 
Fuels will tolerate no retaliation for reports or complaints regarding suspected violations of this Code that 
were  made  in  good  faith.  Energy  Fuels  will  take  such  disciplinary  or  preventive  action  as  it  deems 
appropriate to address any violations of this Code that are brought to its attention.

Waivers and Amendments  

Any  waivers  from  this  Code  that  are  granted  for  the  benefit  of  Energy  Fuels’  directors  or  executive 
officers  (including  without  limitation,  Energy  Fuels’  Chief  Executive  Officer,  Chief  Financial  Officer, 
CLO,  Senior  Vice  President  of  Marketing  and  Corporate  Development  and  persons  performing  similar 
functions)  shall  be  granted  by  the  Board.    Any  waivers  for  all  other  employees  shall  be  granted 
exclusively by the Chief Executive Officer or by any other executive officer as may be designated by the 
Audit  Committee.  Material  amendments  to  or  waivers  of  the  provisions  in  this  Code  will  be  promptly 
publicly disclosed in accordance with applicable laws and regulations. 

Distribution of this Code

This Code will be circulated to all directors, officers and employees of Energy Fuels on an annual basis 
and more frequently whenever changes are made, and all employees are required to certify in writing their 
acknowledgement of the Code on an annual basis. New directors, officers and employees will be provided 
with a copy of this Code and will be advised of its importance.

Affirmation by Directors and Officers  

At the time of each annual meeting of shareholders, the directors and officers of Energy Fuels will affirm 
their compliance with this Code in writing.

ENERGY FUELS INC.
 INSIDER TRADING POLICY

(As Approved by the Board on January 25, 2024)

Exhibit 19.1

PURPOSE

Energy Fuels Inc. (the “Company”) is a publicly traded company listed on the Toronto Stock Exchange 
(the  “TSX”)  and  the  NYSE  American  LLC  (the  “NYSE  American,”  and  together  with  the  TSX,  the 
“Exchanges”). As such, trades in the Company’s securities[1] are subject to Canadian and U.S. securities 
laws, rules and regulations, as well as the rules and regulations of the Exchanges (collectively, “securities 
laws”). Securities laws generally prohibit trading or dealing in the securities of a company at a time when 
the person making the trade possesses material non-public information. Anyone violating these securities 
laws  is  subject  to  personal  liability  and  could  face  criminal  and  civil  penalties,  fines,  or  imprisonment, 
and  risks  causing  significant  damage  to  the  Company’s  reputation.  While  the  regulatory  authorities 
concentrate their efforts on the individuals who trade, or who tip inside information to others who trade, 
the  United  States  federal  securities  laws  also  impose  potential  liability  on  companies  and  other 
“controlling  persons”  if  they  fail  to  take  reasonable  steps  to  prevent  insider  trading  by  company 
personnel.

The  purpose  of  this  Policy  is  to  assist  Company  Personnel  (as  defined  below)  in  complying  with  their 
obligations.  This  Policy  does  not  replace  your  responsibility  to  understand  and  comply  with  the  legal 
prohibitions on insider trading and, if applicable, your obligation for insider reporting.

It  is  also  important  that  Company  Personnel  avoid  the  appearance  of  impropriety  and  remain  in  full 
compliance with securities laws while trading in securities of the Company, including without limitation 
the purchase and sale of common shares, the sale of shares resulting from vested grants of restricted stock 
units  (“RSUs”),  and  the  exercise  of  stock  options,  stock  appreciation  rights  (“SARs”)  or  other  equity 
awards  and  the  sale  of  any  shares  resulting  from  any  such  exercises.    Accordingly,  you  must  exercise 
good judgment when engaging in securities transactions and when relaying to others information obtained 
as a result of your employment with, or other relationship to, the Company. If you have any doubt as to 
whether a particular situation requires refraining from effecting a transaction in the Company’s securities 
or sharing information with others, such doubt should be resolved against taking such action. 

COMPANY PERSONNEL

The following persons are required to observe and comply with this Policy:

a.

all directors, officers and employees of the Company or its subsidiaries;

b. any  other  person  retained  by  or  engaged  in  business  or  professional  activity  on  behalf  of  the 
Company or any of its subsidiaries (such as a consultant, independent contractor or adviser), that 
the Company’s Compliance Officer designates as being subject to this Policy;

c.

any family member, spouse or other person living in the household or a dependent child of any of 
the individuals referred to in Sections (a) or (b) above; and

d. partnerships,  trusts,  corporations,  Registered  Retirement  Savings  Plans  (“RRSPs”)  and  similar 

entities over which any of the above-mentioned individuals exercise control or direction.

For  the  purposes  of  this  Policy,  the  persons  listed  above  are  collectively  referred  to  as  “Company 
Personnel.”  Sections  (c)  and  (d)  should  be  carefully  reviewed  by  Company  Personnel;  those  sections 
have the effect of making various family members or holding companies or trusts of the persons referred 
to  in  Sections  (a)  and  (b)  subject  to  the  Policy.  You  are  responsible  for  the  transactions  of  these  other 
persons  and  therefore  should  make  them  aware  of  the  need  to  confer  with  you  before  they  trade  in  the 
Company’s securities.

In this Policy, the Company’s “Compliance Officer” is the Company’s Chief Legal Officer.

MATERIAL NON-PUBLIC INFORMATION

“Material non-public information” is information that:

a.

b.

could reasonably be expected to have a significant effect, positive or negative, on the market price 
or value of the Company’s securities; or

 a reasonable investor would consider important in making an investment decision regarding the 
purchase or sale of the securities of the Company,

and that has not been previously disclosed or published by means of a broadly disseminated news release 
or  securities  filing  with  a  reasonable  amount  of  time  having  been  given  for  investors  to  consider  the 
information.  

Examples of information that could be considered to be material information include but are not limited 
to: financial results and changes in financial performance; projections and strategic plans; drilling results; 
resource and reserve estimates; corporate acquisitions and dispositions; negotiations concerning contracts 
with outside parties; changes to assets and operations; changes in ownership of the Company’s securities 
that  may  affect  the  control  of  the  Company;  changes  in  senior  management  or  the  Board  of  Directors; 
litigation  or  regulatory  challenges;  environmental  liabilities  or  regulatory  non-compliance;  changes  in 
corporate structure, such as reorganizations; changes in capital structure; new debt or events of default; 
public  or  private  sale  of  additional  securities;  receipt  of,  or  any  delay  in  receipt  or  failure  to  receive 
governmental  approvals;  entering  into  or  loss  of  contracts;  labor  disputes  or  disputes  with  contractors, 
customers or suppliers; takeover bids and issuer bids; and any decision to implement such a change by the 
Company’s Board of Directors or by senior management who believe that confirmation of the decision by 
the Company’s Board of Directors is probable.

If  you  have  any  doubt  whether  certain  information  is  “material,”  you  should not  trade  or  communicate 
such information. Information is “non-public” until it has been made available to investors generally, such 
as in publicly available reports filed with the applicable Exchanges or securities commission or in press 
releases  issued  by  a  company.  In  general,  information  may  be  presumed  to  have  been  available  to 
investors after one full trading day following the formal release of such information. If, for example, the 
Company were to make an announcement prior to the opening of trading on a Monday, you should not 
trade in the Company’s securities until the opening of trading on Tuesday. If an announcement were made 
on  a  Monday,  but  after  the  opening  of  trading  on  that  day,  you  should  not  trade  in  the  Company’s 
securities until the opening of trading on Wednesday.

In addition, it is the policy of the Company that no Company Personnel who, in the course of working for 
the Company, learns of material non-public information about another company with which the Company 
does  business,  including  a  customer  or  supplier  of  the  Company,  or  a  counterparty  in  negotiation  of  a 
material potential transaction, may trade in that other company’s securities until the information becomes 
publicly available or is no longer material.

Remember,  anyone  scrutinizing  your  transactions  will  be  doing  so  after  the  fact,  with  the  benefit  of 
hindsight. As a practical matter, before engaging in any transaction, you should carefully consider how 
enforcement authorities and others might view the transaction in hindsight.

PROHIBITED ACTIVITIES APPLICABLE TO ALL COMPANY PERSONNEL

The following activities are prohibited for all Company Personnel:

Insider Trading: Subject to the limited exceptions set out below, you must not engage in trading in any 
securities,  whether  of  the  Company  or  of  any  other  public  companies,  while  in  possession  of  material, 
non-public information regarding such securities (“insider trading”). 

Under this Policy, “trading” includes any sale or purchase of securities of the Company, including but not 
limited to: (a) hedging or monetization transactions or similar arrangements with respect to securities of 
the  Company;  (b)  holding  Company  securities  in  a  margin  account  or  pledging  Company  securities  as 
collateral  for  a  loan;  (c)  buying  or  selling  puts  or  calls  or  other  derivative  securities  on  the  Company’s 
securities; (d) the exercise of stock options or SARs granted under the Company’s equity awards plans; 
and (e) the purchase of any other securities under any other Company benefit plan or arrangement.

Transactions that may be necessary or justifiable for independent reasons (such as the need to raise money 
for  an  emergency  expenditure)  are  not  excepted  from  this  Policy.  The  securities  laws  do  not  recognize 
such mitigating circumstances, and, in any event, even the appearance of an improper transaction must be 
avoided to preserve the Company’s reputation for adhering to the highest standards of conduct.

Tipping:    You  must  not  disclose  material,  non-public  or  other  confidential  information  relating  to  the 
Company, or other companies when obtained in the course of service to the Company, to anyone, inside 
or outside of the Company (including family members) (“tipping”), except on a strict need-to-know basis 
as is necessary in the course of the Company’s business and under circumstances that make it reasonable 
to  believe  that  the  information  will  not  be  misused  or  improperly  disclosed  by  the  recipient.  You  must 
treat  all  information  concerning  the  Company  as  confidential  and  proprietary  to  the  Company.  Any 
uncertainty  concerning  the  disclosure  of  any  such  information  to  other  persons  in  the  course  of  the 
Company’s  business  should  be  immediately  brought  to  the  attention  of  the  Company’s  Compliance 
Officer for resolution. You must also refrain from recommending or suggesting that any person engage in 
transactions in securities, whether of the Company or any other company, while in possession of material, 
non-public  information  about  those  securities  or  that  company.  Both  the  person  who  provides  the 
information and the person who receives the information are liable under securities laws if the person who 
receives the information trades in securities based on the provided non-public information.  

Trading During Blackout Periods:  Company Personnel who are Restricted Personnel (defined below) 
must  not,  directly  or  indirectly,  trade  in  securities  of  the  Company  during  any  Blackout  Period.  See 
“Blackout Periods,” below.

ADDITIONAL PROHIBITED TRANSACTIONS APPLICABLE ONLY TO INSIDERS:

The  following  additional  activities  are  prohibited  for  directors  and  reporting  officers  (meeting  the 
definition  of  “officer”  pursuant  to  Section  16a-1(f)  (“Section  16”)  of  the  United  States  Securities 
Exchange Act of 1934, as amended (the “Exchange Act”), as well as the definition of “reporting insider” 
pursuant  to  Canadian  National  Instrument  (“NI”)  55-104  “Insider  Reporting  Requirements  and 
Exemptions”) of the Company or any of its subsidiaries, as well as:

a.

 any family member, spouse or other person living in the household or a dependent child of any 
such director or reporting officer; and

b. partnerships,  trusts,  corporations,  RRSPs  and  similar  entities  over  which  any  such  director  or 

reporting officer exercise control or direction,

collectively referred to in this Policy as “Insiders.”

Short Term or Speculative Transactions in the Company’s Securities:

The  Company  considers  it  improper  and  inappropriate  for  any  Insiders  to  engage  in  short-term  or 
speculative  transactions  in  the  Company’s  securities.  It  therefore  is  the  Company’s  policy  that  Insiders 
may not engage in any of the following transactions:

Short-term Trading.  Short-term trading of the Company’s securities may be distracting and may 
unduly focus Insiders on the Company’s short-term stock market performance instead of the Company’s 
long-term  business  objectives.  For  these  reasons,  any  Insider  who  purchases  Company  securities  in  the 
open market may not sell any Company securities of the same class during the six months following the 
purchase without pre-clearance. Under very special circumstances, short-term trading may be permitted. 
The person wishing to sell Company securities during the six months following the open market purchase 
must  first  pre-clear  the  proposed  transaction  with  the  Company’s  Compliance  Officer.  Any  request  for 
pre-clearance  of  a  short-term  trading  arrangement  must  be  submitted  to  the  Company’s  Compliance 
Officer at least five (5) trading days prior to the proposed execution of the transaction and must set forth a 
justification for the proposed transaction.

U.S.  securities  laws  additionally  prohibit  Insiders  from  realizing  any  “short-swing  profit”  in 
securities of the Company. Any profit realized by directors or officers of the Company or its subsidiaries 
on a purchase and sale or sale and purchase of the Company’s equity securities within any six (6)-month 
period  belongs  to  and  is  recoverable  by  the  Company.  See  “Section  16  Short  Swing  Trading  Rules,” 
below.

Short  Sales.    No  Insider  shall  directly  or  indirectly  engage  in  a  short  sale  of  the  Company’s 
securities  (other  than  in  connection  with  “cashless”  exercises  of  stock  options  under  the  Company’s 
equity compensation plans and the number of securities acquired on such exercise equals or exceeds the 
number of securities sold). A short sale is a sale of securities not owned or fully paid for by the seller or, 
if owned and fully paid, not delivered against such sale within twenty (20) days thereafter. Investing in 
securities of the Company provides an opportunity to share in the growth of the Company. However, a 
short sale of the Company’s securities evidences an expectation on the part of the seller that the securities 
will decline in value. Such sales put the personal gain of the Insider in conflict with the best interests of 
the Company.  

In addition, Section 16(c) of the Exchange Act prohibits officers and directors from engaging in 

short sales.  

Publicly Traded Options.  A transaction in publicly traded options is, in effect, a bet on the short-
term movement of the Company’s stock and may create the appearance that the Insider is trading based 
on  inside  information.  Transactions  in  options  also  may  focus  such  person’s  attention  on  short-term 
performance  at  the  expense  of  the  Company’s  long-term  objectives.    Accordingly,  transactions  in  puts, 
calls  or  other  derivative  securities  by  Insiders,  on  an  exchange  or  in  any  other  organized  market,  are 
prohibited by this Policy. Option positions arising from certain types of hedging transactions are governed 
by the section captioned “Hedging Transactions,” below.

Hedging Transactions.  In order to ensure the effectiveness of share ownership policies aimed at 
aligning  the  interests  of  Insiders  with  shareholders,  Insiders  are  not  permitted  to  purchase  financial 
instruments, including, for greater certainty, prepaid variable forward contracts, equity swaps, collars, or 

units  of  exchange  funds,  that  are  designed  to  hedge  or  offset  a  decrease  in  market  value  of  equity 
securities of the Company granted as compensation or held, directly or indirectly, by the Insider. These 
types  of  transactions  allow  a  person  to  lock  in  much  of  the  value  of  his  or  her  stock  holdings,  often  in 
exchange for all or part of the potential for upside appreciation in the stock. These transactions allow the 
person  to  continue  to  own  the  covered  securities,  but  without  the  full  risks  and  rewards  of  ownership. 
When  that  occurs,  the  person  may  no  longer  have  the  same  objectives  as  the  Company’s  other 
shareholders. Therefore, the Company prohibits Insiders from engaging in such transactions.

Pledges.  Securities pledged (or hypothecated) as collateral for a loan may be sold in foreclosure 
if the borrower defaults on the loan. Because a foreclosure sale may occur at a time when the pledgor is 
aware  of  material  non-public  information  or  otherwise  is  not  permitted  to  trade  in  Company  securities, 
Insiders  are  prohibited  from  pledging  Company  securities  as  collateral  for  a  loan.  An  exception  to  this 
prohibition may be granted where a person wishes to pledge Company securities as collateral for a loan 
(not  including  margin  debt)  and  clearly  demonstrates  the  financial  capacity  to  repay  the  loan  without 
resort to the pledged securities.  Any Insider who wishes to pledge Company securities as collateral for a 
loan  must  submit  a  request  for  approval  to  the  Company’s  Compliance  Officer  at  least  five  (5)  trading 
days prior to the proposed execution of documents evidencing the proposed pledge.

Prohibition  on  Holding  Securities  in  Margin  Accounts.    Because  securities  held  in  a  margin 
account with a broker or bank may be sold without the accountholder’s consent in the event of a margin 
call, to avoid any risk that a margin call results in the sale of securities issued by the Company at a time 
when  an  individual  has  knowledge  of  confidential  material  information  or  is  otherwise  prohibited  from 
trading, no Insider shall purchase on margin or hold in a margin account with a brokerage firm, bank or 
other entity any securities of the Company. This means such persons are prohibited from borrowing from 
a  brokerage  firm,  bank  or  other  entity  in  order  to  purchase  the  Company  securities  (other  than  in 
connection  with  “cashless”  exercises  of  stock  options  under  the  Company’s  equity  compensation  plans 
and the exercise price of the securities acquired on such exercise equals or exceeds the amount borrowed).

Pre-Clearance: 

Insiders must not, directly or indirectly, trade in securities of the Company (in Canada, the United States 
or  any  other  country  or  jurisdiction),  except  in  accordance  with  the  pre-clearance  procedures  described 
below.

POST-TERMINATION TRANSACTIONS

This Policy continues to apply to your transactions in Company securities even after your employment or 
other relationship with the Company and its subsidiaries terminates, for so long as you continue to be in 
possession of material non-public information. If you are in possession of material non-public information 
when your employment or other relationship terminates, you may not trade in Company securities until 
that information has become public or is no longer material.

BLACKOUT PERIODS

The restrictions on trading in the Company’s securities set out in this section will apply to the following 
persons:

a.

all directors, officers and salaried employees of the Company or its subsidiaries;

b. any  other  employee  that  the  Company’s  Compliance  Officer  designates  as  being  subject  to  this 

section;

c.

any  other  person  retained  by  or  engaged  in  business  or  professional  activity  on  behalf  of  the 
Company or any of its subsidiaries (such as a consultant, independent contractor or adviser), that 
the Company’s Compliance Officer designates as being subject to this section;

d. any family member, spouse or other person living in the household or a dependent child of any of 

the individuals referred to in Sections (a), (b) or (c) above; and

e. partnerships,  trusts,  corporations,  RRSPs  and  similar  entities  over  which  any  of  the  above-

mentioned individuals exercise control or direction,

collectively referred to in this Policy as “Restricted Personnel.”

Subject  to  the  limited  exceptions  set  out  below,  Restricted  Personnel  are  prohibited  from  trading  the 
Company’s securities during each period of time when financial statements are being prepared but results 
have  not  yet  been  publicly  disclosed  (a  “Scheduled  Blackout  Period”).  A  Scheduled  Blackout  Period 
will commence at 8:00 am (Toronto time) on the first trading day after the period that is 14 calendar days 
after the end of each fiscal quarter or fiscal year end, as the case may be, and ending after one (1) full 
trading day following the formal release of such information. If, for example, the Company were to issue 
a  news  release  disclosing  the  quarterly  or  annual  financial  results  prior  to  the  opening  of  trading  on  a 
Monday,  Restricted  Personnel  would  be  prohibited  from  trading  in  the  Company’s  securities  until  the 
opening  of  trading  on  Tuesday.  If  the  news  release  were  made  on  a  Monday,  but  after  the  opening  of 
trading on that day, Restricted Personnel would be prohibited from trading in the Company’s securities 
until the opening of trading on Wednesday. In this Policy, a “trading day” shall mean any full day on 
which any of the Company’s securities trade on either of the Exchanges (or on any other exchanges the 
Company may become listed on in the future).

Additional  restrictions  on  trading  may  be  prescribed  from  time  to  time  by  the  Company’s  Compliance 
Officer  as  a  result  of  special  circumstances  (an  “Additional  Blackout  Period”  and,  together  with  a 
Scheduled  Blackout  Period,  a  “Blackout  Period”).  All  parties  with  knowledge  of  such  special 
circumstances shall be covered by such Additional Blackout Period. Affected parties may include external 
advisors,  such  as  legal  counsel,  investment  bankers  and  counterparties  in  negotiations  of  material 
potential transactions.

Every  person  subject  to  a  Blackout  Period  who  intends  to  purchase  or  sell  securities  of  the  Company, 
directly or indirectly, (or who stands to benefit from a purchase or sale of securities of the Company by a 
family  member)  during  a  trading  restriction  is  required  to  obtain  the  prior  approval  of  the  Company’s 
Compliance  Officer.  The  Company’s  Compliance  Officer  may  waive  the  application  of  any  particular 
Blackout Period in respect of one or more such person(s) where the Company’s Compliance Officer has 
determined  that  it  is  not  inappropriate,  and  the  person(s)  is/are  not  privy  to  non-public  material 
information. Such waiver shall be reported to the Company’s Disclosure Committee.

Blackout Periods do not apply to:

•

•

trading activities pursuant to a Pre-Approved Trading Plan (defined below); 

the issuance of shares under vested RSUs which were granted previously at a time that did not 
fall  within  a  Blackout  Period,  provided  that  the  Blackout  Period  will  apply  to  the  sale  of  any 
shares  issued  under  the  RSUs.  Applicable  laws  will  be  complied  with  in  determining  and 
implementing Blackout Periods associated with any other benefit plans the Company may have; 
and

•

the exercise by the Company of a pre-arranged tax withholding right pursuant to which Restricted 
Personnel  elect  to  have  the  Company  withhold  and  sell  shares  subject  to  vested  RSUs  or  other 
equity award to satisfy tax withholding requirements.  

Remember that trading outside the Blackout Periods or being excluded from the list of persons subject to 
the  Blackout  Periods  will  not  relieve  you  from  liability  if  you  are  aware  of  material  non-public 
information.

All  efforts  will  be  made  to  advise  of  Blackout  Periods  as  soon  as  possible;  however,  it  is  your 
responsibility to ensure that you are not in violation of the prohibition against trading during a Blackout 
Period by pre-clearing transactions in accordance with this Policy. 

PRE-CLEARANCE

To help prevent inadvertent violations of securities laws and to avoid even the appearance of trading on 
inside information, Insiders and any other persons designated by the Company’s Compliance Officer as 
being subject to the Company’s pre-clearance procedures, together with their family members, may not 
engage in any transaction in the Company’s securities (including a gift, contribution to a trust, or similar 
transfer) without first obtaining pre-clearance of the transaction from the Company’s Compliance Officer.  

The Company’s Compliance Officer will maintain and publish a list of the persons that are subject to the 
pre-clearance  requirements.  A  request  for  pre-clearance  should  be  submitted  to  the  Company’s 
Compliance Officer at least one (1) trading day in advance of the proposed transaction. The Company’s 
Compliance Officer shall record the date each request is received and the date and time each request is 
approved or disapproved. Unless revoked, a grant of permission will normally remain valid until the close 
of  trading  five  (5)  trading  days  following  the  day  on  which  it  was  granted.  If  the  transaction  does  not 
occur  during  the  five  (5)-day  period,  pre-clearance  of  the  transaction  must  be  re-requested.  The 
Company’s Compliance Officer is under no obligation to approve a trade submitted for pre-clearance and 
may determine not to permit the trade.

Pre-clearance is not required for purchases and sales of securities under a Pre-Approved Trading Plan (as 
defined below). With respect to any purchase or sale under a Pre-Approved Trading Plan, the third-party 
effecting transactions on behalf of the Insider should be instructed to send duplicate confirmations of all 
such transactions to the Company’s Compliance Officer or the Compliance Officer’s designee.

In the absence of the Compliance Officer, transactions may be pre-cleared by the Chief Financial Officer, 
provided  that  any  transaction  by  the  Chief  Financial  Officer  or  the  Chief  Financial  Officer’s  family 
members  may,  in  the  absence  of  the  Compliance  Officer,  only  be  approved  by  the  Chief  Executive 
Officer.

In  any  case  where  this  Policy  would  require  the  Company’s  Compliance  Officer  or  the  Compliance 
Officer’s family members to obtain pre-clearance of a plan or transaction, such pre-clearance may not be 
granted  by  the  Company’s  Compliance  Officer  and  must  instead  be  granted  by  the  Chief  Financial 
Officer, or in the Chief Financial Officer’s absence, the Chief Executive Officer. In any case where this 
Policy  would  require  the  Chief  Executive  Officer  or  President  or  their  family  members  to  obtain  pre-
clearance of a plan or transaction, such pre-clearance may not be granted by the Company’s Compliance 
Officer and must instead be granted by the approval of any two (2) of the Chair of the Company’s Board 
of Directors, the Chief Financial Officer and the Company’s Compliance Officer.

PRE-APPROVED TRADING PLANS

Notwithstanding  any  of  the  prohibitions  contained  in  this  Policy,  Company  Personnel  may  trade  in 
Company securities at any time pursuant to a contract, instruction or trading plan that has been properly 
adopted and is properly administered in accordance with Rule 10b5-1 under the Exchange Act (a “Rule 
10b5-1  Plan”)  and  an  automatic  securities  purchase  plan  or  automatic  securities  disposition  plan,  as 
defined in National Instrument 55-104 (an “Automatic Securities Purchase or Disposition Plan,” and 
together  with  a  Rule  10b5-1  Plan,  a  “Pre-Approved  Trading  Plan”  or  “Plan”).  All  adopted  Pre-
Approved  Trading  Plans  must  comply  with  all  applicable  policies  established  by  the  Company,  in 
addition  to  complying  with  applicable  Canadian  and  United  States  laws.  As  all  Plans  trading  in  the 
Company’s securities must be duly compliant with the aforementioned Canadian and U.S. securities laws, 
the more restrictive laws between the two are deemed to apply in each case.

The rules applicable to Pre-Approved Trading Plans are complex and technical in nature, so you should 
not employ a Pre-Approved Trading Plan without obtaining advice from legal counsel. A Pre-Approved 
Trading Plan may not be adopted at any time when you are aware of material non-public information or 
are subject to a Blackout Period.

Prior to adopting, amending, suspending or terminating a Pre-Approved Trading Plan, the creator of the 
Plan (the “Plan Creator”) must confer with, and obtain the prior approval of, the Company’s Compliance 
Officer, which will be provided promptly.  

Each  Pre-Approved  Trading  Plan  must  satisfy  the  following  criteria  in  order  to  be  approved  by  the 
Company’s Compliance Officer:

a.

the Plan must be in writing;

b.

c.

the  Plan  must  not  be  entered  into  at  a  time  when  the  Plan  Creator  has  material  non-public 
information (for the avoidance of doubt, adoption of a Plan while aware of such information, but 
where such information is subsequently disclosed prior to any trades made under the Plan, is not 
sufficient to rely on the Rule 10b5-1 safe harbor);

at the time the Plan is entered into, the Plan Creator must be in compliance with this Policy and 
any  applicable  Company  share  ownership  policies,  and  entering  into  the  Plan  must  not  be 
inconsistent with those policies;

d.

the Plan may not be adopted during a Blackout Period;

e. The Plan must have a term of at least six (6) months and no more than two (2) years in order to 

minimize the need for any voluntary modifications, terminations or suspensions; 

f.

if a director or a reporting officer subject to Section 16, the Plan Creator is required to include a 
representation in the Plan certifying that, at the time the Plan Creator enters into the Plan, the Plan 
Creator is not aware of any material non-public information about the security or Company, and 
that  the  Plan  Creator  is  adopting  the  Plan  in  good  faith  and  not  as  part  of  a  plan  or  scheme  to 
evade the prohibitions of Rule 10b5-1 or other applicable securities laws;

g. no purchases or sales may occur until the expiration of a mandatory waiting period (also known 
as  a  cooling  off  period)  of  at  least  30  days  between  establishment  of  the  Plan  and  the  date  the 
initial  trade  is  made  under  the  Plan;  provided  that,  where  the  Plan  Creator  is  an  Insider,  no 
purchases or sales may occur until the expiration of a mandatory waiting period of the later of: (1) 
90 days following adoption of the Plan, or (2) two business days following the disclosure of the 

Company’s financial results in a Form 10-Q or Form 10-K for the fiscal quarter in which the Plan 
was adopted or modified (but, in any event, not to exceed 120 days following Plan adoption) (the 
“Mandatory Waiting Period”);

h. The Plan shall prohibit any modification, termination, suspension or lifting of a suspension of the 
Plan during a Blackout Period. Any modification or change to the amount, price or timing of the 
purchase  or  sale  of  securities  under  a  Plan,  including  any  other  change  that  has  any  of  these 
effects (such as a suspension or lifting of a suspension), will be deemed to be a termination of the 
Plan and the adoption of a new Plan and must be subject to Company review and pre-approval 
similar to when the Plan was initially adopted. Consequently, a new mandatory waiting period in 
accordance with the Mandatory Waiting Period must be observed following the adoption of the 
new Plan (which, for the avoidance of doubt, must also meet the requirements of Rule 10b5-1 at 
the time of adoption);

i.

In  order  to  eliminate  any  appearance  that  the  Plan  Creator  is  trying  to  trade  before  a  material 
development is announced, the Plan must not be designed to result in large trades at the beginning 
of  the  Plan  term  (Plans  that  could  result  in  large  trades  at  the  beginning  of  the  Plan  term  are 
permitted  if  the  large  trades  are  the  result  of  a  formula  that  does  not  favor  large  trades  at  the 
beginning  of  the  Plan  term)  and,  further,  Plans  designed  to  effect  the  open-market  purchase  or 
sale of the total amount of securities in a single open market transaction may not be used by the 
Plan Creator more than once in a 12-month period, except for Qualified Sell-to-Cover Plans (as 
defined below); 

j. The  Plan’s  terms  shall  specify  a  non-discretionary  trading  method,  such  as  through  a  specified 
amount of securities to be purchased or sold and the price and date for each purchase or sale or a 
written formula, algorithm or computer program for determining the amount, price and date for 
each  transaction,  and  in  any  event  the  Plan  shall  not  allow  the  Plan  Creator  to  exercise  any 
subsequent influence over how, when or whether to make purchases or sales;

k.

l.

the Plan shall not delegate discretion for trading decisions to a broker or other agent, in order to 
avoid any inference of the Plan Creator’s improper influence or discretion over the Plan;

all  Plans  must  use  a  broker  accepted  by  the  Company  as  suitable  to  implement  Pre-Approved 
Trading Plans, rather than necessarily the Plan Creator’s own individual broker, in order to avoid 
any perception that an Insider is inappropriately communicating with or influencing the broker. 
This will also support timely trade notifications for Section 16(a) filings;

m.

the Company’s Compliance Officer will require a pre-approved form of Plan, which would allow 
flexibility on specific trading terms of the Plan while ensuring that other Plan provisions remain 
consistent;

n. each  Plan  Creator  shall  have  no  more  than  one  Pre-Approved  Trading  Plan  outstanding  at  any 
time,  except  for:  (1)  a  Plan  that  is  limited  to  the  sale  of  that  number  of  securities  necessary  to 
satisfy tax withholding obligations arising exclusively from the vesting of a compensatory award, 
provided  the  Plan  Creator  does  not  otherwise  exercise  control  over  the  timing  of  such  sales  (a 
“Qualified  Sell-to-Cover  Plan”);  (2)  separate  contracts  with  multiple  broker-dealers  or  agents 
that,  when  taken  together  as  a  whole,  meet  all  of  the  applicable  conditions  of  and  remain 
collectively  subject  to  the  provisions  of  Rule  10b5-1;  or  (3)  a  “replacement”  Plan  pursuant  to 
subpart  (h),  above,  that  complies  with  the  Mandatory  Waiting  Period  and  under  which  no 
transactions  occur  until  all  trade  under  the  previous  Plan  are  completed  or  the  previous  Plan 
expires without execution; and

o.

the Plan shall otherwise comply with all applicable securities laws. 

Transactions must be made strictly in accordance with the terms of the Pre-Approved Trading Plan; the 
Plan Creator must not alter or deviate from the Plan (whether by changing the amount, price or timing of 
the sale or purchase, or otherwise), except to the extent explicitly permitted in subpart (h) above, and the 
Plan Creator must not enter into or alter a corresponding or hedging transaction or position with respect to 
the Company’s securities subject to the Plan. Any transactions made subsequent to a Plan’s termination 
(whether  voluntarily  or  due  to  its  natural  expiry)  should  be  carefully  considered  to  avoid  unfavorable 
inferences by the market, regardless of legality. 

The  Company  may  restrict  the  number  of  securities  authorized  to  be  traded  through  a  Pre-Approved 
Trading  Plan  at  any  one  time  or  during  any  specified  trading  day  or  period,  based  on  the  total  trading 
volume at such time or during such day or period, the total number of securities traded at any one time or 
during  any  one  period  under  all  outstanding  Pre-Approved  Trading  Plans,  or  such  other  criteria  as  the 
Company may consider appropriate.

Entering into, renewing, amending, modifying, terminating, suspending or lifting a suspension of a Pre-
Approved Trading Plan must be done (1) when the Plan Creator is not aware of any material non-public 
information about the Company or its securities and (2) in good faith and not as part of a plan or scheme 
to evade the applicable securities laws.

The Company may at any time conduct an internal review of Company Personnel trades and compliance 
with their Pre-Approved Trading Plans. Such reviews may be conducted annually or more frequently, and 
trades may also be reviewed following extreme price swings in the Company’s share price.  

Once  a  Pre-Approved  Trading  Plan  is  established,  the  Plan  Creator  may  not  trade  securities  of  the 
Company outside of the Plan (other than in underwritten public offerings, the grant of securities by the 
Company to the Plan Creator pursuant to any Company equity plan, or the acquisition of shares upon the 
exercise of stock options or SARs by the Plan Creator).  

The  Company  reserves  the  right  to  consider  and  determine  whether  public  announcement  of  a  Pre-
Approved  Trading  Plan  should  be  made,  which  may  include  announcement  of  the  adoption,  any 
modification to, and the termination or suspension of the Plan, either through a press release or by a Form 
8-K or otherwise. All transactions reported to the U.S. Securities and Exchange Commission (“SEC”) on 
Forms  4  and  5,  which  are  intended  to  qualify  for  the  Rule  10b5-1  safe  harbor,  must  clearly  state  such 
intent. 

TRANSACTIONS UNDER COMPANY PLANS:

Receipt of Shares Pursuant to RSUs or Similar Equity Awards.  The receipt of shares pursuant to 
vested RSUs or a similar equity award (other than through the exercise of stock options or SARs) and the 
exercise  of  a  pre-arranged  tax  withholding  right  pursuant  to  which  you  previously  elected  to  have  the 
Company  withhold  and  sell  shares  subject  to  vested  RSUs  or  another  equity  award  to  satisfy  tax 
withholding requirements is exempt from this Policy.

Related Sales.  This Policy applies to any sale of stock acquired pursuant to any Company equity 
plans, including any sale as part of a broker-assisted cashless exercise of an option and any sale necessary 
to generate the cash needed to pay taxes or any applicable exercise price except through a Pre-Approved 
Trading Plan or pre-arranged tax withholding right. In other words, even though your acquisition of stock 
under a Company equity plan may be exempt from or permitted by this Policy, you may not sell the stock 
you acquire under the Company equity plan, sell stock in anticipation of your acquisition, or engage in 

any other transactions involving Company securities unless you do so in compliance with this Policy or 
pursuant to a Pre-Approved Trading Plan or pre-arranged tax withholding right.  

INSIDER REPORTING OBLIGATIONS

Immediately after becoming a reporting Insider (as defined in applicable securities law), and immediately 
following  the  purchase,  sale  or  bona  fide  gift  of  securities  of  the  Company,  a  reporting  Insider  must 
complete all Insider reports required by applicable securities laws within the prescribed time periods. The 
Corporate  Secretary  of  the  Company  will  provide  guidance  and  inform  those  individuals  who  meet  the 
applicable definitions of reporting Insiders and may provide filing support to them as deemed appropriate. 
However, the Company is not responsible for alerting reporting Insiders of their obligations or for filing 
Insider trading reports, other than in connection with the initial issuance of securities by the Company or 
from the Company’s treasury.

SECTION 16 SHORT SWING TRADING RULES

Section 16(b) of the Exchange Act prevents Insiders from realizing any “short-swing profit” in Company 
securities.  Any  profit  realized  by  an  Insider  on  a  purchase  and  sale  or  sale  and  purchase  of  equity 
securities of the Company within any six-month period belongs to and is recoverable by the Company, 
and any stockholder may bring an action for collection on behalf of the Company. Your transactions will 
be matched so that the greatest profit may be recovered.  Insiders should carefully review with their legal 
advisor any proposed transaction to ensure that it will not result in their “profit” being disgorged to the 
Company.

RULE 144 REQUIREMENTS

All Company securities sold by or on behalf of Insiders in the public market must be sold in accordance 
with the technical requirements of Rule 144, including the filing of a Form 144 with the SEC prior to or 
concurrently with the trade, even if the securities were purchased in the open market. A knowledgeable 
broker can assist you with the necessary paperwork. Please provide advance notice of a proposed sale to 
the  Company’s  Compliance  Officer  in  order  to  expedite  the  process,  resolve  any  issues  and  avoid  any 
Rule 144 violations. Please note that special considerations apply to the preparation and filing of Forms 
144 that relate to sales pursuant to Pre-Approved Trading Plans.

COMPLIANCE

Your actions with respect to matters governed by this Policy are significant indications of your judgment, 
ethics, and competence. Any actions in violation of this Policy may be grounds for disciplinary action, up 
to and including immediate dismissal, as well as exposure to civil and criminal liability. 

EFFECTIVE DATE

This Policy was approved by the Board of Directors of the Company on November 5, 2015 and became 
effective on that date, with the exception of the following sections, all of which are effective as of January 
1, 2016:
•

“Short  Term  Trading”  (under  the  general  headings  “Additional  Prohibited  Transactions 
Applicable  Only  to  Insiders:  Short  Term  or  Speculative  Transactions  in  the  Company’s 
Securities”);
“Pre-Clearance”  (under  the  general  heading:  “Additional  Prohibited  Transactions  Applicable 
Only to Insiders”);
“Pre-Clearance”;  
“Section 16 Short Swing Trading Rules”; and 

•

•
•

•

“Rule 144 Requirements.”

[1]  “Securities”  include  common  shares  and  any  other  security  that  the  Company  may  issue  including 
preferred shares, options, deferred share units, performance units, restricted stock, restricted stock units, 
stock appreciation rights, debentures, warrants, puts, calls and other derivative instruments with respect to 
such securities and any other securities that are convertible or exchangeable into such securities.

KPMG LLP
Suite 800 
1225 17th Street 
Denver, CO 80202-5598

EX 23.1

Consent of Independent Registered Public Accounting Firm

We  consent  to  the  incorporation  by  reference  in  the  registration  statements  (Nos.  333-205182, 
333-217098,  333-226654,  333-254559,  and  333-194900)  on  Form  S-8  and  registration  statements  (Nos. 
333-253666  and  333-226878)  on  Form  S-3  of  our  report  dated  February  23,  2024,  with  respect  to  the 
consolidated  financial  statements  of  Energy  Fuels  Inc.  and  the  effectiveness  of  internal  control  over 
financial reporting.

Denver, Colorado
February 23, 2024

/s/ KPMG LLP

                       
CONSENT OF GRANT A. MALENSEK

Exhibit 23.2

I  consent  to  all  references  to  my  name  and  any  quotation  from,  or  summarization  of,  Sections 
1.2, 1.3.11, 1.3.13, 19, 21, 22, and 30, and my contributions to Section 27 of the technical report 
summary  entitled  “Technical  Report  on  the  Roca  Honda  Project,  McKinley  County,  State  of 
New  Mexico,  USA”  dated  February  22,  2022  (the  "New  Mexico  Technical  Report");  and 
Sections  1.2,  1.3.11,  1.3.13,  19,  21,  22,  and  30  and  my  contributions  to  Section  27  of  the 
technical report summary entitled “Technical Report on the Nichols Ranch Project, Johnson and 
Campbell  Counties,  Wyoming,  USA”  dated  February  22,  2022  (the  "Wyoming  Technical 
Report"), as amended on February 8, 2023; and Sections 1.2, 1.3.12, 1.3.14, 19, 21, 22, 30, and 
my contributions to Section 27 of the technical report summary entitled “Technical Report on the 
Pre-Feasibility  Study  on  the  Pinyon  Plain  Project,  Coconino  County,  Arizona,  USA”  dated 
February  23,  2023  (the  Arizona  Technical  Report",  and  together  with  New  Mexico  Technical 
Report and the Wyoming Technical Report, "Technical Reports"), prepared by me, included or 
incorporated by reference in: 

(i) 

(ii) 

(iii) 

the Annual Report on Form 10-K for the period ended December 31, 2023 (the “10-K”) 
of Energy Fuels Inc. (the “Company”) being filed with the United States Securities and 
Exchange Commission, and any amendments or supplements thereto; 

the  Company’s  Form  S-3  Registration  Statements  (File  Nos.  333-253666  and 
333-226878), and any amendments or supplements thereto; and 

the  Company’s  Form  S-8  Registration  Statements  (File  Nos.  333-217098,  333-205182, 
333-194900, 333-226654 and 333-254559), and any amendments or supplements thereto. 

I further consent to the filing of the Technical Reports as exhibits to the 10-K.    

/s/ Grant A. Malensek

Grant A. Malensek, M.Eng., P. Eng.

Technical Director - U.S. Mining Advisory

Date: February 23, 2024

Exhibit 23.3

CONSENT OF JEREMY SCOTT COLLYARD

I  consent  to  all  references  to  my  name  and  any  quotation  from,  or  summarization  of,  Sections 
1.1.1.5, 1.3.12, 4.3, 4.6, 20, and 25.5 and my contributions to Section 27 of the technical report 
summary  entitled  “Technical  Report  on  the  Nichols  Ranch  Project,  Johnson  and  Campbell 
Counties,  Wyoming,  USA”  dated  February  22,  2022,  as  amended  on  February  8,  2023  (the 
"Technical Report"), prepared by me, included or incorporated by reference in: 

(i) 

(ii) 

(iii) 

the Annual Report on Form 10-K for the period ended December 31, 2023 (the “10-K”) 
of Energy Fuels Inc. (the “Company”) being filed with the United States Securities and 
Exchange Commission, and any amendments or supplements thereto; 

the  Company’s  Form  S-3  Registration  Statements  (File  Nos.  333-253666  and 
333-226878), and any amendments or supplements thereto; and 

the  Company’s  Form  S-8  Registration  Statements  (File  Nos.  333-217098,  333-205182, 
333-194900, 333-226654 and 333-254559), and any amendments or supplements thereto. 

I further consent to the filing of the Technical Report as an exhibit to the 10-K.                

/s/ Jeremy Scott Collyard
Jeremy Scott Collyard, PMP, MMSA, QP
Mining and Minerals Sector Lead

Date: February 23, 2024

Exhibit 23.4

Phillip E. Brown
Consultant in Hydrogeology 2
6241 Wolverine Trail
Evergreen, Colorado 80439
hydrobro@aol.com

CONSENT OF PHILLIP E. BROWN

I  consent  to  all  references  to  my  name  and  any  quotation  from,  or  summarization  of,  Sections 
1.1.1.3, 1.1.2.3, 16.6, 25.3, and 26.3 and my contributions to Section 27 of the technical report 
summary  entitled  “Technical  Report  on  the  Roca  Honda  Project,  McKinley  County,  State  of 
New Mexico, USA” dated February 22, 2022 (the "New Mexico Technical Report"); and Section 
1.1.1.2,  1.1.2.2,  1.3.8,  16,  25.2,  and  26.2  and  my  contributions  to  Section  27  of  the  technical 
report summary entitled “Technical Report on the Nichols Ranch Project, Johnson and Campbell 
Counties,  Wyoming,  USA”  dated  February  22,  2022,  as  amended  on  February  8,  2023  (the 
"Wyoming  Technical  Report",  and  together  with  the  New  Mexico  Technical  Report,  the 
"Technical Reports"), prepared by me, included or incorporated by reference in: 

(i) 

(ii) 

(iii) 

the Annual Report on Form 10-K for the period ended December 31, 2023 (the “10-K”) 
of Energy Fuels Inc. (the “Company”) being filed with the United States Securities and 
Exchange Commission, and any amendments or supplements thereto; 

the  Company’s  Form  S-3  Registration  Statements  (File  Nos.  333-253666  and 
333-226878), and any amendments or supplements thereto; and 

the  Company’s  Form  S-8  Registration  Statements  (File  Nos.  333-217098,  333-205182, 
333-194900, 333-226654 and 333-254559), and any amendments or supplements thereto. 

I further consent to the filing of the Technical Reports as exhibits to the 10-K.    

/s/ Phillip E. Brown
Phillip E. Brown, C.P.G., R.P.G.
Principal Consulting Hydrogeologist
Consultants in Hydrogeology

Date: February 23, 2024

CONSENT OF DAVID M. ROBSON

Exhibit 23.5

I  consent  to  all  references  to  my  name  and  any  quotation  from,  or  summarization  of,  Sections 
1.1.1.2,  1.1.2.2,  1.3.9,  16.1  to  16.5,  16.7  to  16.10,  25.2,  and  26.2,  and  my  contributions  to 
Section  27  of  the  technical  report  summary  entitled  “Technical  Report  on  the  Roca  Honda 
Project, McKinley County, State of New Mexico, USA” dated February 22, 2022 (the "Technical 
Report"), prepared by me, included or incorporated by reference in: 

(i) 

(ii) 

(iii) 

the Annual Report on Form 10-K for the period ended December 31, 2023 (the “10-K”) 
of Energy Fuels Inc. (the “Company”) being filed with the United States Securities and 
Exchange Commission, and any amendments or supplements thereto; 

the  Company’s  Form  S-3  Registration  Statements  (File  Nos.  333-253666  and 
333-226878), and any amendments or supplements thereto; and 

the  Company’s  Form  S-8  Registration  Statements  (File  Nos.  333-217098,  333-205182, 
333-194900, 333-226654 and 333-254559), and any amendments or supplements thereto. 

I further consent to the filing of the Technical Report as an exhibit to the 10-K.    

/s/ David M. Robson
David M. Robson, P.Eng., MBA
Principal Mining Engineer

Date: February 23, 2024

 
 
 
 
CONSENT OF MARK B. MATHISEN

Exhibit 23.6

I  consent  to  all  references  to  my  name  and  any  quotation  from,  or  summarization  of,  Sections 
1.1.1.1, 1.1.2.1, 1.3.1 to 1.3.7, 2, 3, 4.1, 4.2, 4.4, 4.5, 5.1 to 5.4, 5.6, 6 to 12, 14, 15, 23, 24, 25.1, 
and 26.1 and my contributions to Section 27 of the technical report summary entitled “Technical 
Report on the Nichols Ranch Project, Johnson and Campbell Counties, Wyoming, USA” dated 
February  22,  2022,  as  amended  on  February  8,  2023  (the  "Wyoming  Technical  Report"); 
Sections 1.1.1.1, 1.1.2.1, 1.3.1, 1.3.2, 1.3.4 to 1.3.8, 2, 3, 4.1, 4.2, 4.4, 4.5, 5.1 to 5.6, 6 to 12, 14, 
15, 23, 24, 25.1, and 26.1, and my contributions to Section 27 of the technical report summary 
entitled “Technical Report on the Roca Honda Project, McKinley County, State of New Mexico, 
USA” dated February 22, 2022 (the "New Mexico Technical Report"); sections 1.1.1.1, 1.1.2.1, 
1.3.1-1.3.7, 2-12, 14, 23, 24, 25.1, and 26.1, and my contributions to Section 27 of the technical 
report  summary  entitled  “Technical  Report  on  the  Pre-Feasibility  Study  on  the  Pinyon  Plain 
Project,  Coconino  County,  Arizona,  USA”  dated  February  23,  2023  (the  "Arizona  Technical 
Report"); all sections of the technical report summary entitled “Technical Report on the La Sal 
Project, San Juan County, Utah, USA” dated February 22, 2022 (the "San Juan County Technical 
Report");  and  all  sections  of  the  technical  report  summary  entitled  “Technical  Report  on  the 
Bullfrog Project, Garfield County, Utah, USA” dated February 22, 2022 (the "Garfield County 
Technical  Report,"  and  together  with  the  Wyoming  Technical  Report,  New  Mexico  Technical 
Report,  Arizona  Technical  Report,  and  the  San  Juan  County  Technical  Report,  the  "Technical 
Reports"), prepared by me, included or incorporated by reference in:  

(i) 

(ii) 

(iii) 

the Annual Report on Form 10-K for the period ended December 31, 2023 (the “10-K”) 
of Energy Fuels Inc. (the “Company”) being filed with the United States Securities and 
Exchange Commission, and any amendments or supplements thereto; 

the  Company’s  Form  S-3  Registration  Statements  (File  Nos.  333-253666  and 
333-226878), and any amendments or supplements thereto; and 

the  Company’s  Form  S-8  Registration  Statements  (File  Nos.  333-217098,  333-205182, 
333-194900, 333-226654 and 333-254559), and any amendments or supplements thereto. 

I further consent to the filing of the Technical Reports as exhibits to the 10-K.    

/s/ Mark B. Mathisen
Mark B. Mathisen, C.P.G.
Principal Geologist

Date: February 23, 2024

 
 
 
 
 
 
CONSENT OF DOUGLAS L. BEAHM

Exhibit 23.7

I consent to all references to my name and any quotation from, or summarization of, Sections 3, 14-16 and 
22-27  and  my  contributions  to  Sections  1,  2  and  21  of  the  Preliminary  Feasibility  Study  entitled 
“Preliminary Feasibility Study for the Sheep Mountain Project, Fremont County, Wyoming, USA” dated 
January  30,  2023  with  an  effective  date  of  December  31,  2021  (the  "Preliminary  Feasibility  Study"), 
prepared by me, included or incorporated by reference in:  

(i) 

(ii) 

(iii) 

the Annual Report on Form 10-K for the period ended December 31, 2023 (the “10-K”) of Energy 
Fuels  Inc.  (the  “Company”)  being  filed  with  the  United  States  Securities  and  Exchange 
Commission, and any amendments or supplements thereto; 

the  Company’s  Form  S-3  Registration  Statements  (File  Nos.  333-253666  and  333-226878),  and 
any amendments or supplements thereto; and 

the  Company’s  Form  S-8  Registration  Statements  (File  Nos.  333-217098,  333-205182, 
333-194900, 333-226654 and 333-254559), and any amendments or supplements thereto. 

I further consent to the filing of the Preliminary Feasibility Study as an exhibit to the 10-K.    

/s/ Douglas L. Beahm
Douglas L. Beahm, P.E., P.G.

Date: February 23, 2024

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
CONSENT OF DANIEL D. KAPOSTASY

Exhibit 23.8

I  consent  to  (a)  all  references  to  my  name  and  or  any  quotation  from,  or  summarization  of,  Sections 
1.1.1.6, 1.3.12, 4.3, 18.9.2, 20, and 25.6 of the technical report summary entitled “Technical Report on the 
Roca  Honda  Project,  McKinley  County,  State  of  New  Mexico,  USA”  dated  February  22,  2022  (the 
"Technical  Report");  and  Sections  4-12  and  18-20  and  my  contributions  to  Sections  1  and  2  of  the 
preliminary  feasibility  study  entitled  “Preliminary  Feasibility  Study  for  the  Sheep  Mountain  Project, 
Fremont County, Wyoming, USA” dated January 30, 2023 with an effective date of December 31, 2021 
(the  "Preliminary  Feasibility  Study"),  each  prepared  by  me;  and  (b)  the  filing  of  the  written  disclosure 
regarding certain scientific, technical, land tenure and permitting information concerning mineral projects 
prepared by me (the “Technical Disclosure”), included or incorporated by reference in:  

(i) 

(ii) 

(iii) 

the Annual Report on Form 10-K for the period ended December 31, 2023 (the “10-K”) of Energy 
Fuels  Inc.  (the  “Company”)  being  filed  with  the  United  States  Securities  and  Exchange 
Commission, and any amendments or supplements thereto; 

the  Company’s  Form  S-3  Registration  Statements  (File  Nos.  333-253666  and  333-226878),  and 
any amendments or supplements thereto; and 

the  Company’s  Form  S-8  Registration  Statements  (File  Nos.  333-217098,  333-205182, 
333-194900, 333-226654 and 333-254559), and any amendments or supplements thereto. 

I  further  consent  to  the  filing  of  the  Technical  Report,  Preliminary  Feasibility  Study,  and  the  Technical 
Disclosure as exhibits to the 10-K.                

/s/ Daniel D. Kapostasy
Daniel D. Kapostasy, P.G., SME R.M.
Vice President, Technical Services
Energy Fuels Inc. 

Date: February 23, 2024

CONSENT OF TERENCE MCNULTY

Exhibit 23.9

I consent to all references to my name and any quotation from, or summarization of, Sections 13, 17, and 
my contributions to Section 21 of the Preliminary Feasibility Study entitled “Preliminary Feasibility Study 
for the Sheep Mountain Project, Fremont County, Wyoming, USA” dated January 30, 2023 and effective 
as of December 31, 2021, prepared by me, included or incorporated by reference in:

(i) 

(ii) 

(iii) 

the Annual Report on Form 10-K for the period ended December 31, 2023 (the “10-K”) of Energy 
Fuels  Inc.  (the  “Company”)  being  filed  with  the  United  States  Securities  and  Exchange 
Commission, and any amendments or supplements thereto; 

the  Company’s  Form  S-3  Registration  Statements  (File  Nos.  333-253666  and  333-226878),  and 
any amendments or supplements thereto; and 

the  Company’s  Form  S-8  Registration  Statements  (File  Nos.  333-217098,  333-205182, 
333-194900, 333-226654 and 333-254559), and any amendments or supplements thereto. 

I further consent to the filing of the Preliminary Feasibility Study as an exhibit to the 10-K.                

/s/ Terence McNulty
Terence McNulty, PE, PhD

Date: February 23, 2024

CONSENT OF JEFFREY L. WOODS

Exhibit 23.10

I  consent  to  all  references  to  my  name  and  any  quotation  from,  or  summarization  of,  Sections 
1.1.1.4, 1.1.1.5, 1.1.2.4, 1.3.3, 1.3.10, 5.5, 13, 17, 18.1 to 18.8, 18.9.1, 18.10, 18.11, 25.4, 25.5, 
and 26.4 and my contributions to Section 27 of the technical report summary entitled “Technical 
Report  on  the  Roca  Honda  Project,  McKinley  County,  State  of  New  Mexico,  USA”  dated 
February  22,  2022  (the  "New  Mexico  Technical  Report");  Section  1.1.1.3,  1.1.1.4,  1.1.2.3, 
1.1.2.4, 1.3.9, 1.3.10, 5.5, 13, 17, 18, 25.3, 25.4, 26.3, and 26.4 and my contributions to Section 
27  of  the  technical  report  summary  entitled  “Technical  Report  on  the  Nichols  Ranch  Project, 
Johnson  and  Campbell  Counties,  Wyoming,  USA”  dated  February  22,  2022,  as  amended  on 
February 8, 2023 (the "Wyoming Technical Report"); and my contributions to Sections 1.1.1.4, 
1.1.1.5,  1.1.2.4,  1.3.3,  1.3.10,  1.3.11,  5.5,  13,  17,  18,  25.3,  25.4,  26.3,  26.4  and  27  of  the  pre-
feasibility  study  entitled  “Technical  Report  on  the  Pre-Feasibility  Study  on  the  Pinyon  Plain 
Project,  Coconino  County,  Arizona,  USA”  dated  February  23,  2023  (the  "Arizona  Technical 
Report", and together with the New Mexico Technical Report and Wyoming Technical Report, 
the "Technical Reports"), prepared by me, included or incorporated by reference in:

(i) 

(ii) 

(iii) 

the Annual Report on Form 10-K for the period ended December 31, 2023 (the “10-K”) 
of Energy Fuels Inc. (the “Company”) being filed with the United States Securities and 
Exchange Commission, and any amendments or supplements thereto; 

the  Company’s  Form  S-3  Registration  Statements  (File  Nos.  333-253666  and 
333-226878), and any amendments or supplements thereto; and 

the  Company’s  Form  S-8  Registration  Statements  (File  Nos.  333-217098,  333-205182, 
333-194900, 333-226654 and 333-254559), and any amendments or supplements thereto. 

I further consent to the filing of the Technical Reports as exhibits to the 10-K.                

/s/ Jeffrey L. Woods
Jeffrey L. Woods, MMSA QP
Principal Consulting Metallurgist 
Woods Process Services

Date: February 23, 2024

 
 
 
 
 
 
 
 
CONSENT OF R. DENNIS BERGEN

Exhibit 23.11

I  consent  to  all  references  to  my  name  and  any  quotation  from,  or  summarization  of,  Sections 
1.1.1.2, 1.1.2.2, 1.3.8, 1.3.9, 15, 16, 25.2, 26.2 and 27 of the technical report summary entitled 
“Technical Report on the Pre-Feasibility Study on the Pinyon Plain Project, Coconino County, 
Arizona, USA” dated February 23, 2023 (the "Technical Report"), prepared by me, included or 
incorporated by reference in:  

(i) 

(ii) 

(iii) 

the Annual Report on Form 10-K for the period ended December 31, 2023 (the “10-K”) 
of Energy Fuels Inc. (the “Company”) being filed with the United States Securities and 
Exchange Commission, and any amendments or supplements thereto; 

the  Company’s  Form  S-3  Registration  Statements  (File  Nos.  333-253666  and 
333-226878), and any amendments or supplements thereto; and 

the  Company’s  Form  S-8  Registration  Statements  (File  Nos.  333-217098,  333-205182, 
333-194900, 333-226654 and 333-254559), and any amendments or supplements thereto. 

I further consent to the filing of the Technical Report as an exhibit to the 10-K.                

/s/ R. Dennis Bergen, P.Eng.
R. Dennis Bergen, P.Eng. 
Associate Principal Mining Engineer

Date: February 23, 2024

 
 
 
 
CONSENT OF LEE (PAT) GOCHNOUR

Exhibit 23.12

I  consent  to  all  references  to  my  name  and  any  quotation  from,  or  summarization  of,  Sections 
1.1.5,  1.1.2.5,  1.3.13,  4.3,  20,  25.5,  26.5  and  27  of  the  technical  report  summary  entitled 
“Technical Report on the Pre-Feasibility Study on the Pinyon Plain Project, Coconino County, 
Arizona, USA” dated February 23, 2023 (the “Technical Report”), prepared by me, included or 
incorporated by reference in:  

(i) 

(ii) 

(iii) 

the Annual Report on Form 10-K for the period ended December 31, 2023 (the “10-K”) 
of Energy Fuels Inc. (the “Company”) being filed with the United States Securities and 
Exchange Commission, and any amendments or supplements thereto; 

the  Company’s  Form  S-3  Registration  Statements  (File  Nos.  333-253666  and 
333-226878), and any amendments or supplements thereto; and 

the  Company’s  Form  S-8  Registration  Statements  (File  Nos.  333-217098,  333-205182, 
333-194900, 333-226654 and 333-254559), and any amendments or supplements thereto. 

I further consent to the filing of the Technical Report as an exhibit to the 10-K.               

/s/ Lee (Pat) Gochnour
Lee (Pat) Gochnour, MMSA QP

Associate Principal Environmental Specialist

Principal of Gochnour & Associates, Inc. 

Date: February 23, 2024

CONSENT OF TRAVIS BOAM

Exhibit 23.13

I  consent  to  all  references  to  my  name  and  any  quotation  from,  or  summarization  of,  Sections 
3-10 and 13 and my contributions to Sections 1, 2, 14, and 23-27 of the technical report summary 
entitled “Technical Report Summary for the Alta Mesa Uranium Project, Brooks and Jim Hogg 
Counties,  Texas,  USA”  dated  December  31,  2021  (the  “Technical  Report”),  prepared  by  me, 
included or incorporated by reference in:  

(i) 

(ii) 

(iii) 

the Annual Report on Form 10-K for the period ended December 31, 2023 (the “10-K”) 
of Energy Fuels Inc. (the “Company”) being filed with the United States Securities and 
Exchange Commission, and any amendments or supplements thereto; 

the  Company’s  Form  S-3  Registration  Statements  (File  Nos.  333-253666  and 
333-226878), and any amendments or supplements thereto; and 

the  Company’s  Form  S-8  Registration  Statements  (File  Nos.  333-217098,  333-205182, 
333-194900, 333-226654 and 333-254559), and any amendments or supplements thereto. 

I further consent to the filing of the Technical Report as an exhibit to the 10-K.                

/s/ Travis Boam
Travis Boam, PG
Senior Geologist
Energy Fuels Inc.

Date: February 23, 2024

Consent of Independent Accounting Firm

EX 23.14

The Board of Directors

Energy Fuels Inc.:

We consent to the incorporation by reference into the registration statements (No. 333-205182, 
333-217098, 333-226654, 333-254559 and 333-194900) on Form S-8 and registration statements 
(Nos. 333-253666 and 333-226878) on Form S-3 of Energy Fuels Inc. (the “Company”) of our 
report  dated  March  29,  2022,  with  respect  to  the  consolidated  financial  statements  of  Virginia 
Energy Resources Inc., which is included in this Annual Report on Form 10-K of the Company 
being filed with the United States Securities and Exchange Commission.

/s/ Smythe LLP

Vancouver, British Columbia
February 23, 2024

EXHIBIT 31.1

CERTIFICATION OF CHIEF EXECUTIVE OFFICER
PURSUANT TO RULE 13a-14(a) OF THE
SECURITIES EXCHANGE ACT OF 1934

I, Mark S. Chalmers, certify that:

1.

2.

3.

4.

5.

I have reviewed this annual report on Form 10-K of Energy Fuels Inc.;

Based  on  my  knowledge,  this  report  does  not  contain  any  untrue  statement  of  a  material  fact  or  omit  to  state  a 
material fact necessary to make the statements made, in light of the circumstances under which such statements were 
made, not misleading with respect to the period covered by this report;

Based  on  my  knowledge,  the  financial  statements,  and  other  financial  information  included  in  this  report,  fairly 
present in all material respects the financial condition, results of operations and cash flows of the registrant as of, and 
for, the periods presented in this report;

The registrant's other certifying officer and I are responsible for establishing and maintaining disclosure controls and 
procedures (as defined in Exchange Act Rules 13a-15(e) and 15d-15(e)) and internal control over financial reporting 
(as defined in Exchange Act Rules 13a-15(f) and 15d-15(f)) for the registrant and have:

(a)

(b)

(c)

(d)

Designed  such  disclosure  controls  and  procedures,  or  caused  such  disclosure  controls  and 
procedures to be designed under our supervision, to ensure that material information relating to the 
registrant,  including  its  consolidated  subsidiaries,  is  made  known  to  us  by  others  within  those 
entities, particularly during the period in which this report is being prepared;

Designed  such  internal  control  over  financial  reporting,  or  caused  such  internal  control  over 
financial reporting to be designed under our supervision, to provide reasonable assurance regarding 
the reliability of financial reporting and the preparation of financial statements for external purposes 
in accordance with generally accepted accounting principles;

Evaluated  the  effectiveness  of  the  registrant's  disclosure  controls  and  procedures  and  presented  in 
this report our conclusions about the effectiveness of the disclosure controls and procedures, as of 
the end of the period covered by this report based on such evaluation; and

Disclosed in this report any change in the registrant's internal control over financial reporting that 
occurred during the registrant's most recent fiscal quarter (the registrant's fourth fiscal quarter in the 
case of an annual report) that has materially affected, or is reasonably likely to materially affect, the 
registrant's internal control over financial reporting; and

The registrant's other certifying officer and I have disclosed, based on our most recent evaluation of internal control 
over financial reporting, to the registrant's auditors and the audit committee of the registrant's board of directors (or 
persons performing the equivalent functions):

(a)

(b)

All  significant  deficiencies  and  material  weaknesses  in  the  design  or  operation  of  internal  control 
over  financial  reporting  which  are  reasonably  likely  to  adversely  affect  the  registrant's  ability  to 
record, process, summarize and report financial information; and

Any  fraud,  whether  or  not  material,  that  involves  management  or  other  employees  who  have  a 
significant role in the registrant's internal control over financial reporting.

Date: February 23, 2024

/s/ Mark S. Chalmers
Mark S. Chalmers
Chief Executive Officer
(Principal Executive Officer)

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EXHIBIT 31.2

CERTIFICATION OF CHIEF FINANCIAL OFFICER
PURSUANT TO RULE 13a-14(a) OF THE
SECURITIES EXCHANGE ACT OF 1934

I, Nathan Bennett, certify that:

1.

2.

3.

4.

5.

I have reviewed this annual report on Form 10-K of Energy Fuels Inc.;

Based  on  my  knowledge,  this  report  does  not  contain  any  untrue  statement  of  a  material  fact  or  omit  to  state  a 
material fact necessary to make the statements made, in light of the circumstances under which such statements were 
made, not misleading with respect to the period covered by this report;

Based  on  my  knowledge,  the  financial  statements,  and  other  financial  information  included  in  this  report,  fairly 
present in all material respects the financial condition, results of operations and cash flows of the registrant as of, and 
for, the periods presented in this report;

The registrant's other certifying officer and I are responsible for establishing and maintaining disclosure controls and 
procedures (as defined in Exchange Act Rules 13a-15(e) and 15d-15(e)) and internal control over financial reporting 
(as defined in Exchange Act Rules 13a-15(f) and 15d-15(f)) for the registrant and have:

(a)

(b)

(c)

(d)

Designed  such  disclosure  controls  and  procedures,  or  caused  such  disclosure  controls  and 
procedures to be designed under our supervision, to ensure that material information relating to the 
registrant,  including  its  consolidated  subsidiaries,  is  made  known  to  us  by  others  within  those 
entities, particularly during the period in which this report is being prepared;

Designed  such  internal  control  over  financial  reporting,  or  caused  such  internal  control  over 
financial reporting to be designed under our supervision, to provide reasonable assurance regarding 
the reliability of financial reporting and the preparation of financial statements for external purposes 
in accordance with generally accepted accounting principles;

Evaluated  the  effectiveness  of  the  registrant's  disclosure  controls  and  procedures  and  presented  in 
this report our conclusions about the effectiveness of the disclosure controls and procedures, as of 
the end of the period covered by this report based on such evaluation; and

Disclosed in this report any change in the registrant's internal control over financial reporting that 
occurred during the registrant's most recent fiscal quarter (the registrant's fourth fiscal quarter in the 
case of an annual report) that has materially affected, or is reasonably likely to materially affect, the 
registrant's internal control over financial reporting; and

The registrant's other certifying officer and I have disclosed, based on our most recent evaluation of internal control 
over financial reporting, to the registrant's auditors and the audit committee of the registrant's board of directors (or 
persons performing the equivalent functions):

(a)

(b)

All  significant  deficiencies  and  material  weaknesses  in  the  design  or  operation  of  internal  control 
over  financial  reporting  which  are  reasonably  likely  to  adversely  affect  the  registrant's  ability  to 
record, process, summarize and report financial information; and

Any  fraud,  whether  or  not  material,  that  involves  management  or  other  employees  who  have  a 
significant role in the registrant's internal control over financial reporting.

Date: February 23, 2024

/s/ Nathan Bennett
Nathan Bennett
Chief Accounting Officer and Interim Chief Financial Officer
(Principal Financial Officer)

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
CERTIFICATION PURSUANT TO
18 U.S.C. §1350
AS ADOPTED PURSUANT TO
SECTION 906 OF THE SARBANES-OXLEY ACT OF 2002

EXHIBIT 32.1

In  connection  with  the  Annual  Report  of  Energy  Fuels  Inc.  (the  "Company")  on  Form  10-K  for  the  period  ended 
December  31,  2023  as  filed  with  the  Securities  and  Exchange  Commission  on  the  date  hereof  (the  "Report"),  I,  Mark  S. 
Chalmers, Chief Executive Officer, certify, pursuant to 18 U.S.C. §1350, as adopted pursuant to Section 906 of the Sarbanes-
Oxley Act of 2002, that:

(1) The Report fully complies with the requirements of Section 13(a) or 15(d) of the Securities Exchange Act of 1934, as 

amended; and

(2) The information contained in the Report fairly presents, in all material respects, the financial condition and results of 

operations of the Company.

/s/ Mark S. Chalmers

Mark S. Chalmers

Chief Executive Officer
(Principal Executive Officer)

Date: February 23, 2024

A  signed  original  of  this  written  statement  required  by  Section  906,  or  other  document  authenticating,  acknowledging,  or 
otherwise adopting the signature that appears in typed form within the electronic version of this written statement required by 
Section  906,  has  been  provided  to  the  Company  and  will  be  retained  by  the  Company  and  furnished  to  the  Securities  and 
Exchange Commission or its staff upon request.

CERTIFICATION PURSUANT TO
18 U.S.C. §1350
AS ADOPTED PURSUANT TO
SECTION 906 OF THE SARBANES-OXLEY ACT OF 2002

EXHIBIT 32.2

In  connection  with  the  Annual  Report  of  Energy  Fuels  Inc.  (the  "Company")  on  Form  10-K  for  the  period  ended 
December  31,  2023  as  filed  with  the  Securities  and  Exchange  Commission  on  the  date  hereof  (the  "Report"),  I,  Nathan  R. 
Bennett,  Interim  Chief  Financial  Officer,  certify,  pursuant  to  18  U.S.C.  §1350,  as  adopted  pursuant  to  Section  906  of  the 
Sarbanes-Oxley Act of 2002, that:

(1) The Report fully complies with the requirements of Section 13(a) or 15(d) of the Securities Exchange Act of 1934, as 

amended; and

(2) The information contained in the Report fairly presents, in all material respects, the financial condition and results of 

operations of the Company.

/s/ Nathan Bennett
Nathan Bennett
Chief Accounting Officer and Interim 
Chief Financial Officer
(Principal Financial Officer)

Date: February 23, 2024

A  signed  original  of  this  written  statement  required  by  Section  906,  or  other  document  authenticating,  acknowledging,  or 
otherwise adopting the signature that appears in typed form within the electronic version of this written statement required by 
Section  906,  has  been  provided  to  the  Company  and  will  be  retained  by  the  Company  and  furnished  to  the  Securities  and 
Exchange Commission or its staff upon request.

Mine Safety Disclosure

Exhibit 95.1

Pursuant to Section 1503(a) of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the “Dodd-Frank 
Act”), issuers that are operators, or that have a subsidiary that is an operator, of a coal or other mine in the United States, and 
that is subject to regulation by the Federal Mine Safety and Health Administration under the Mine Safety and Health Act of 
1977  (“Mine  Safety  Act”),  are  required  to  disclose  in  their  periodic  reports  filed  with  the  SEC  information  regarding 
specified  health  and  safety  violations,  orders  and  citations,  related  assessments  and  legal  actions,  and  mining-related 
fatalities. 

The following table sets out the information concerning mine safety violations or other regulatory matters required by Section 
1503(a)  of  the  Dodd  Frank  Wall  Street  Reform  and  Consumer  Protection  Act  for  the  period  January  1,  2023  through 
December 31, 2023 covered by this report:

Section 
104(d)  
Citations 
and 
Orders4
(#)
Nil

Section 
110(b)(2)  
Violations5
(#)
Nil

Section 
107(a)  
Orders6
(#)
Nil

Total Dollar 
Value of 
MSHA 
Assess-
ments 
Proposed7
($)
$0.00

Total 
Number of 
Mining 
Related 
Fatalities
(#)
Nil

Received 
Notice of 
Pattern of 
Violations 
or Potential 
Thereof 
Under 
Section 
104(e)8
(yes/no)
No

Legal 
Actions 
Pending 
as of Last 
Day of 
Period9
(#)
Nil

Legal 
Actions 
Initiated 
During 
Period
(#)
Nil

Legal 
Actions 
Resolved 
During 
Period
(#)
Nil

Nil

Nil

Nil

Nil

Nil

Nil

Nil

Nil

Nil

Nil

Nil

Nil

Nil

Nil

Nil

$0.00

$477.00

$0.00

$0.00

$0.00

Nil

Nil

Nil

Nil

Nil

No

No

No

No

No

Nil

Nil

Nil

Nil

Nil

Nil

Nil

Nil

Nil

Nil

Nil

Nil

Nil

Nil

Nil

Section 
104(a) S&S
Citations2
(#)
Nil

Section 
104(b) 
Orders3
(#)
Nil

Nil

57.13021

Nil

Nil

Nil

Nil

Nil

Nil

Nil

Nil

Property
Arizona 11
Beaver/
La Sal1
Pinyon 
Plain1
Energy 
Queen1
Pandora1
Whirlwind1

1. The Company’s Arizona 1 Project and the Energy Queen Property were on standby and not mined during the period. The 
Whirlwind mine, portions of the La Sal Project (i.e., the Beaver property and Pandora property) and the Pinyon Plain mine 
each operated during portions of the period. 

2. Citations  and  Orders  are  issued  under  Section  104  of  the  Federal  Mine  Safety  and  Health  Act  of  1977  (30  U.S.C.  814) 
(“MSHA”) for violations of MSHA or any mandatory health or safety standard, rule, order or regulation promulgated under 
MSHA.  A Section 104(a) “Significant and Substantial” or “S&S” citation is considered more severe than a non-S&S citation 
and  generally  is  issued  in  a  situation  where  the  conditions  created  by  the  violation  do  not  cause  imminent  danger,  but  the 
violation  is  of  such  a  nature  as  could  significantly  and  substantially  contribute  to  the  cause  and  effect  of  a  mine  safety  or 
health hazard.  It should be  noted that, for purposes of this table, S&S citations that are included in another column, such as 
Section 104(d) citations, are not also included as Section 104(a) S&S citations in this column.  

3. A Section 104(b) withdrawal order is issued if, upon a follow up inspection, an MSHA inspector finds that a violation has not 
been  abated  within  the  period  of  time  as  originally  fixed  in  the  violation  and  determines  that  the  period  of  time  for  the 
abatement should not be extended.  Under a withdrawal order, all persons, other than those required to abate the violation and 
certain  others,  are  required  to  be  withdrawn  from  and  prohibited  from  entering  the  affected  area  of  the  mine  until  the 
inspector determines that the violation has been abated.  

4. A citation is issued under Section 104(d) where there is an S&S violation and the inspector finds the violation to be caused by 
an unwarrantable failure of the operator to comply with a mandatory health or safety standard.  Unwarrantable failure is a 
special negligence finding that is made by an MSHA inspector and that focuses on the operator’s conduct.  If during the same 
inspection or any subsequent inspection of the mine within 90 days after issuance of the citation, the MSHA inspector finds 
another violation caused by an unwarrantable failure of the operator to comply, a withdrawal order is issued, under which all 
persons, other than those required to abate the violation and certain others, are required to be withdrawn from and prohibited 
from entering the affected area until the inspector determines that the violation has been abated.  

5. A flagrant violation under Section 110(b)(2) is a violation that results from a reckless or repeated failure to make reasonable 
efforts to eliminate a known violation of a mandatory health or safety standard that substantially and proximately caused, or 
reasonable could have been expected to cause, death or serious bodily injury.  

6. An imminent danger order under Section 107(a) is issued when an MSHA inspector finds that an imminent danger exists in a 
mine.  An imminent danger is the existence of any condition or practice which could reasonably be expected to cause death or 
serious physical harm before such condition or practice can be abated.  Under an imminent danger order, all persons, other 
than those required to abate the condition or practice and certain others, are required to be withdrawn from and are prohibited 
from  entering  the  affected  area  until  the  inspector  determines  that  such  imminent  danger  and  the  conditions  or  practices 

which caused the imminent danger no longer exist.  

8.

7. These  dollar  amounts  include  the  total  amount  of  all  proposed  assessments  under  MSHA  relating  to  any  type  of  violation 
during the period, including proposed assessments for non-S&S citations that are not specifically identified in this exhibit, 
regardless of whether the Company has challenged or appealed the assessment. 
 A Notice is given under Section 104(e) if an operator has a pattern of S&S violations.  If upon any inspection of the mine 
within 90 days after issuance of the notice, or at any time after a withdrawal notice has been given under Section 104(e), an 
MSHA inspector finds another S&S violation, an order is issued, under which all persons, other than those required to abate 
the violation and certain others, are required to be withdrawn from and prohibited from entering the affected area until the 
inspector determines that the violation has been abated. 

9. There were no legal actions pending before the Federal Mine Safety and Health Review Commission as of the last day of the 
period  covered  by  this  report.    In  addition,  there  were  no  pending  actions  that  are  (a)  contests  of  citations  and  orders 
referenced in Subpart B of 29 CFR Part 2700; (b) complaints for compensation referenced in subpart D of 29 CFR Part 2700; 
(c) complaints of discharge, discrimination or interference referenced in Subpart E of 29 CFR Part 2700; (d) applications for 
temporary relief referenced in Subpart F of 29 CFR Part 2700; or (e) appeals of judges’ decisions or orders to the Federal 
Mine Safety and Health Review Commission referenced in Subpart H of 29 CFR Part 2700.

Exhibit 97.1

ENERGY FUELS INC.
INCENTIVE-BASED COMPENSATION 
CLAWBACK POLICY

(As Approved by the Board on January 25, 2024)

1. PURPOSE

The  board  of  directors  (the  “Board”)  of  Energy  Fuels  Inc.  (the  “Company”)  has  adopted  this 
Incentive-Based  Compensation  Clawback  Policy  (the  “Policy”)  in  accordance  with  Section  10D  of  the 
Securities Exchange Act of 1934 (the “Exchange Act”) and Section 811 (“Section 811”) of the NYSE 
American Company Guide (the “NYSE Guide”). 

The  Board  shares  in  the  belief,  as  highlighted  in  the  Final  Rule  “Listing  Standards  for  Recovery  of 
Erroneously Awarded Compensation” of the U.S. Securities and Exchange Commission (the “SEC”) on 
the legislative history of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the 
“Dodd-Frank Act”), that “an executive officer should not retain incentive-based compensation that, had 
the issuer’s accounting been correct in the first instance, would not have been received by the executive 
officer,  regardless  of  any  fault  of  the  executive  officer  for  the  accounting  errors.”  The  Board  also  feels 
that  it  should  have  discretion  to  recover  incentive-based  compensation  where  gross  negligence, 
intentional  misconduct  or  fraud  on  the  part  of  any  of  its  executive-level  or  other  senior  employees  is 
identified. In accordance with these beliefs, the Company, through this Policy, adopts rules for when it 
must recover incentive-based compensation in excess of amounts actually earned from its executive-level 
employees  due  to  an  accounting  restatement  and  when  it  may  recover  incentive-based  compensation  in 
full  or  in  part  from  both  its  executive  level  and  senior  employees  due  to  gross  negligence,  intentional 
misconduct or fraud. 

2. APPLICATION

This  Policy  applies  where  the  Company  is  required  to  prepare  an  accounting  restatement  due  to  the 
material  noncompliance  of  the  Company  with  any  financial  reporting  requirement  under  the  federal 
securities  laws,  including  any  required  accounting  restatement  to  correct  an  error  in  previously  issued 
financial statements that is material to the previously issued financial statements, or that would result in a 
material misstatement if the error were corrected in the current period or left uncorrected in the current 
period (an “Accounting Restatement”). An Accounting Restatement does not include situations in which 
financial  statement  changes  did  not  result  from  material  non-compliance  with  financial  reporting 
requirements,  such  as,  but  not  limited  to  retrospective:  (i)  application  of  a  change  in  accounting 
principles;  (ii)  revision  to  reportable  segment  information  due  to  a  change  in  the  structure  of  the 
Company’s internal organization; (iii) reclassification due to a discontinued operation; (iv) application of 
a  change  in  reporting  entity,  such  as  from  a  reorganization  of  entities  under  common  control;  (v) 
adjustment  to  provision  amounts  in  connection  with  a  prior  business  combination;  and  (vi)  revision  for 
stock splits, stock dividends, reverse stock splits or other changes in capital structure.

As used in this Policy, “Financial Reporting Measures” are measures that are determined and presented 
in accordance with the accounting principles used in preparing the Company’s financial statements, and 
any measures that are derived wholly or in part form such measures, including but not limited to stock 
price  and  total  shareholder  return,  and  whether  or  not  presented  within  the  financial  statements  or 
included in a filing with the SEC.

Types of Compensation Subject to Recovery

This Policy applies to any incentive-based compensation that is granted, earned or vested based wholly or 
in part upon the attainment of a Financial Reporting Measure (“FRM”) (“FRM Compensation”), as well 
as to any incentive-based compensation that is not granted, earned or vested based wholly or in part upon 
the attainment of an FRM, such as time-vesting awards, discretionary awards and awards based wholly on 
subjective  standards,  strategic  measures  or  operational  measures  (“Non-FRM  Compensation”  and, 
together  with  FRM  Compensation,  “Incentive  Compensation”).  Incentive  Compensation  may  include, 
without  limitation,  cash  bonus  compensation  and  equity  grants  made  under  the  Company’s  Omnibus 
Equity  Incentive  Compensation  Plan,  Short-Term  Incentive  Plan,  Long-Term  Incentive  Plan,  Stock 
Appreciation Right Plan and/or at the Board or Company’s discretion, having been received by Executive 
Officers and Senior Employees (as defined below) while the Company had a class of securities listed on a 
national  securities  exchange  or  a  national  securities  association.  This  policy  covers  Incentive 
Compensation received by a person after beginning service as an Executive Officer or Senior Employee 
and  who  served  as  an  Executive  Officer  or  Senior  Employee  at  any  time  during  the  performance  or 
vesting period for that Incentive Compensation. 

FRM  Compensation  is  deemed  “received”  in  the  Company’s  fiscal  period  during  which  the  Financial 
Reporting Measure specified in the FRM Compensation award is attained, even if the payment or grant of 
the  FRM  Compensation  occurs  after  the  end  of  that  period.  Non-FRM  Compensation  is  deemed 
“received” in the fiscal year in which it is paid, even if deemed earned in a prior year.

Current and Former Employees Covered by the Policy

All  executive  officers,  defined  as  the  Company’s  president,  principal  financial  officer,  principal 
accounting officer (or if there is no such accounting officer, the controller), any vice-president in charge 
of  a  principal  business  unit,  division,  or  function  (such  as  sales,  administration  or  finance),  any  other 
officer  who  performs  a  significant  policy-making  function,  or  any  other  person  who  performs  similar 
significant  policy-making  functions  for  the  Company  (each,  an  “Executive  Officer”),  are  subject  to 
Section 3 “Mandatory Recovery” of this Policy and to Section 4 “Discretionary Recovery” of this Policy. 
For the purposes of this Policy, executive officers of the Company’s parent(s) or subsidiaries are deemed 
Executive Officers if they perform such significant policy-making functions for the Company. Executive 
Officers will include at a minimum executive officers identified pursuant to Item 401(b) of Regulation S-
K. 

“Senior  Employees,”  defined  as  salaried  management  personnel,  including  Management  Directors, 
Controllers,  Assistant  Controllers,  non-executive  officers,  and  managers  are  subject  to  Section  4 
“Discretionary Recovery” of this Policy only.

(i) All former Executive Officers who served at any time during the period for which recovery of FRM 
Compensation received is legally mandated, and (ii) all former Executive Officers and Senior Employees 
who  served  at  any  time  during  the  period  for  which  recovery  of  Non-FRM  Incentive  Compensation 
received is compelled by the Board, are subject to this Policy to the same extent as are current Executive 
Officers and Senior Employees. 

3. MANDATORY RECOVERY 

Where  an  Accounting  Restatement  has  occurred,  the  Board  shall  recover  reasonably  promptly[1]  from 
each current and former Executive Officer affected the total amount of FRM Compensation received that 
exceeds  the  amount  of  FRM  Compensation  that  otherwise  would  have  been  received  had  it  been 
determined based on the restated amounts without regard to any taxes paid (the “Erroneously Awarded 
Compensation”)  for  the  three  (3)  completed  fiscal  years,  including  transition  periods  resulting  from  a 

change  in  the  Company’s  fiscal  year  as  provided  in  paragraph  (c)(1)(i)(D)  of  Section  811,  or  other 
applicable  securities  exchange  rules,  immediately  preceding  the  date  from  which  the  Company  is 
“required” to prepare an Accounting Restatement. Such date shall be the earlier to occur of: 

i.

the date the Board, a committee of the Board, or the officers of the Company authorized to take 
such action if Board action is not required, concludes, or reasonably should have concluded, that 
the Company is required to prepare an Accounting Restatement; or 

ii.

the  date  a  court,  regulator  or  other  legally  authorized  body  directs  the  Company  to  prepare  an 
Accounting Restatement. 

The Company’s obligation to recover Erroneously Awarded Compensation is not dependent on if or when 
the restated financial statements are filed. 

Where  FRM  Compensation  is  based  on  stock  price  or  total  shareholder  return  where  the  amount  of 
Erroneously  Awarded  Compensation  is  not  subject  to  mathematical  recalculation  directly  from  the 
information  in  an  Accounting  Restatement,  paragraph  (c)(1)(iii)(A)  and  (B)  of  Section  811,  or  other 
applicable securities exchange rules, shall govern the applicable amounts to be recovered. 

The  only  exceptions  to  recovery  of  Erroneously  Awarded  Compensation  that  apply  are  those  set  out  in 
paragraphs  (c)(1)(iv)(A),  (B)  and  (C)[2]  of  Section  811,  or  other  applicable  securities  exchange  rules, 
where one such condition must be met in addition to a determination by the Compensation Committee or 
a majority of the independent members serving on the Board that recovery would be impracticable. 

4. DISCRETIONARY RECOVERY 

For purposes of this Section 4 only, the definition of “Erroneously Awarded Compensation” shall also 
include the full amount of Incentive Compensation received by an Executive Officer or Senior Employee 
during  a  fiscal  year  in  which  the  Board  determines  in  its  sole  discretion  that  such  Executive  Officer  or 
Senior Employee engaged in gross negligence, intentional misconduct or fraud. 

Where  the  Board,  in  its  sole  discretion,  determines  that  an  Executive  Officer  or  Senior  Employee  has 
received  Erroneously  Awarded  Compensation,  then  the  Board  may,  in  its  full  discretion,  to  the  fullest 
extent permitted by governing laws and to the extent it determines that it is in the Company’s best interest 
to do so, recover in whole or in part the Erroneously Awarded Compensation from such Executive Officer 
or  Senior  Employee,  above  and  beyond  any  Erroneously  Awarded  Compensation  subject  to  mandatory 
recovery under Section 3 of this Policy. 

5. METHOD OF RECOVERY

The  Board  may  use  its  discretion  in  determining  how  to  recover  reasonably  promptly  Erroneously 
Awarded  Compensation  under  Sections  3  or  4  above  and  may  opt,  as  it  sees  fit  depending  on  the 
particular facts and circumstances, to seek reimbursement, reduction, cancellation, forfeiture, repurchase, 
recoupment  and/or  offset  against  future  compensation,  in  whole  or  in  part,  of  Erroneously  Awarded 
Compensation  from  the  Executive  Officer  or  Senior  Employee.  Such  reimbursement,  reduction, 
cancellation,  forfeiture,  repurchase,  recoupment  and/or  offset  against  future  compensation  shall  not 
exceed the Erroneously Awarded Compensation received by such Executive Officer or Senior Employee, 
and amounts paid or payable pursuant or with respect thereto. When exercising its discretion, the Board 
should act in a manner that aligns most closely with the purpose of this Policy. 

Without limiting the generality of the foregoing, the Board has discretion to establish a deferred payment 
plan  that  allows  an  Executive  Officer  or  Senior  Employee  to  repay  the  Erroneously  Awarded 

Compensation as soon as possible while avoiding unreasonable economic hardship. If so requested by an 
Executive  Officer  or  Senior  Employee,  the  Board  shall  make  every  reasonable  effort  to  grant  and 
implement  the  request  in  a  timely  manner.  A  deferred  payment  plan  shall  not  be  considered  a  personal 
loan to an Executive Officer or Senior Employee by the Company. 

Before  the  Board  makes  a  final  determination  as  to  whether  any  recoupment  of  Erroneously  Awarded 
Compensation  will  be  undertaken  under  the  Policy,  the  Board  shall  provide  the  Executive  Officer  or 
Senior Employee with written notice thereof and the opportunity to be heard at a duly held meeting of the 
Board, which may take place either in person or by way of a conference or video call, as determined by 
the Board.

To  the  extent  practicable  and  as  permitted  by  all  applicable  laws,  including,  without  limitation,  federal 
securities  laws  and  the  rules  and  standards  of  the  applicable  national  securities  exchange,  all 
investigations  and  related  findings  under  this  Policy  shall  be  conducted,  undertaken  and  treated  in  a 
confidential manner.

6. ADOPTION AND COMPLIANCE

This  Policy  was  first  approved  by  the  Board  on  November  2,  2023,  and  applies  to  all  Incentive 
Compensation  received  by  Executive  Officers  and  Senior  Employees  on  or  after  October  2,  2023  (the 
“Effective  Date”).  Without  limiting  the  scope  or  effectiveness  of  this  Policy,  Incentive  Compensation 
granted  or  received  prior  to  the  Effective  Date  remains  subject  to  the  Company’s  prior  Incentive 
Compensation  Claw-Back  Policy  dated  January  26,  2023,  which  prior  policy  will  not  apply  to  any 
Incentive Compensation received by Executive Officers and Senior Employees on or after the Effective 
Date. In addition, this Policy is intended to be and will be incorporated as an essential term and condition 
of any Incentive Compensation agreement, plan or program that the Company establishes or maintains on 
or after the Effective Date. 

All Executive Officers and Senior Employees, and their beneficiaries, heirs, executors, administrators or 
other  legal  representatives,  are  required  to  comply  with  this  Policy.  Upon  receipt  of  this  Policy,  each 
Executive  Officer  and  Senior  Employee  is  required  to  complete  the  Receipt  and  Acknowledgement 
attached as Schedule “A” to this Policy. The Board may require that any employment agreement, grant 
award  agreement  or  similar  agreement  relating  to  Incentive  Compensation  received  on  or  after  the 
Effective Date shall, as a condition to the grant of any benefit thereunder, require an Executive Officer or 
other  Senior  Employee  to  agree  to  abide  by  the  terms  of  this  Policy.  Any  right  of  recovery  under  this 
Policy is in addition to, and not in lieu of, any (i) other remedies or rights of compensation recovery that 
may  be  available  to  the  Company  pursuant  to  the  terms  of  any  similar  policy  in  any  employment 
agreement, or similar agreement relating to Incentive Compensation, unless any such agreement expressly 
prohibits  such  right  of  recovery,  and  (ii)  any  other  legal  remedies  available  to  the  Company.  The 
provisions of this Policy are in addition to (and not in lieu of) any rights to repayment the Company may 
have under Section 304 of the Sarbanes-Oxley Act of 2002 and other applicable laws.

This  Policy  shall  be  administered  by  the  Board  or,  if  so  designated  by  the  Board,  its  Compensation 
Committee,  in  which  case,  all  references  herein  to  the  Board  shall  be  deemed  references  to  the 
Committee. Any determinations made by the Board shall be final and binding on all affected individuals.

It is intended that this Policy be interpreted in a manner that is consistent with the requirements of Section 
10D  of  the  Exchange  Act  and  any  applicable  rules  or  standards  adopted  by  the  SEC  or  any  national 
securities exchange on which the Company’s securities are listed. 

The Company is prohibited from indemnifying any Executive Officer or former Executive Officer or any 
Senior  Employee  or  former  Senior  Employee  against  the  loss  of  Erroneously  Awarded  Compensation, 

including by paying or reimbursing for premiums for any insurance policy covering any potential losses, 
nor  shall  the  Company  advance  any  costs  or  expenses  to  any  Executive  Officer  or  Senior  Employee  in 
connection with any action to recover excess Incentive Compensation.

7. AMENDMENT AND TERMINATION

The  Board  may  amend  this  Policy  from  time  to  time  in  its  discretion  and  shall  amend  this  Policy  as  it 
deems necessary to reflect changes in regulations adopted by the SEC under Section 10D of the Exchange 
Act  and  to  comply  with  any  rules  or  standards  adopted  by  any  securities  exchange  on  which  the 
Company’s shares are listed in the future. 

[1]  “Reasonably  promptly”  shall  refer  to  the  exercise  of  the  Board’s  fiduciary  duty  to  safeguard  the 
Company’s assets by pursuing the most appropriate balance of cost and speed depending on the particular 
facts and circumstances. 

[2]  (A)  where  the  direct  expense  of  enforcement  would  exceed  the  amount  to  be  recovered;  (B)  where 
recovery would violate home country law; and (C) where recovery would likely cause an otherwise tax-
qualified retirement plan to fail to meet applicable regulations (see Section 811 for full requirements

Schedule “A”

INCENTIVE COMPENSATION CLAWBACK POLICY
RECEIPT AND ACKNOWLEDGEMENT

I, __________________________________________, hereby acknowledge that I have received and read 
a  copy  of  the  “Energy  Fuels  Inc.  Incentive  Compensation  Clawback  Policy”  (the  “Policy”).  As  a 
condition of my receipt of any future Incentive Compensation as defined in the Policy, I hereby agree to 
the  terms  of  the  Policy.  I  further  agree  that  if  reimbursement  is  required  pursuant  to  the  Policy,  the 
Company  shall,  to  the  full  extent  permitted  by  governing  laws,  require  reimbursement,  reduction, 
cancellation, forfeiture, repurchase, recoupment and/or offset against future compensation from me. If any 
such  reimbursement,  reduction,  cancellation,  forfeiture,  repurchase,  recoupment  and/or  offset  against 
future compensation does not fully satisfy the amount of reimbursement due, I agree to immediately pay 
the remaining unpaid balance to the Company; provided, I shall be entitled to request a deferred payment 
plan in accordance with the Policy. 

Signature

Date

CONSOLIDATED	FINANCIAL	STATEMENTS	

FOR	THE	PERIODS	ENDED	

JANUARY	23,	2023	(unaudited),	

DECEMBER	31,	2022	(unaudited),	

and	DECEMBER	31,	2021

(expressed	in	US	dollars)	

	
	
	
EXPLANATORY	NOTE

The	 unaudited	 consolidated	 financial	 statements	 herein	 include	 the	 unaudited	 financial	 statements	 for	
Virginia	 Energy	 Resources	 Inc.	 (the	 “Company”)	 as	 at	 January	 23,	 2023	 and	 for	 the	 23-day	 period	 ended	
January	23,	2023,	as	at	December	31,	2022	and	for	the	year	ended	December	31,	2022	and	audited	financial	
statements	for	the	year	ended	December	31,	2021.	Audited	financial	statements	as	at	January	23,	2023	and	
for	the	23-day	period	ended	January	23,	2023	and	as	at	December	31,	2022	and	for	the	year	ended	December	
31,	2022	were	not	required	to	be	publicly	filed	by	the	Company	with	any	securities	regulatory	authorities	in	
Canada	or	the	United	States.

On	January	24,	2023,	the	Company	was	acquired	by	Consolidated	Uranium	Inc.	(TSXV:	CUR;	OTCQB:	CURUF)	
as	further	described	in	Note	13	of	these	financial	statements.

	
INDEPENDENT	AUDITORS’	REPORT

TO	THE	DIRECTORS	OF	VIRGINIA	ENERGY	RESOURCES	INC.

Opinion
We	have	audited	the	consolidated	financial	statements	of	Virginia	Energy	Resources	Inc.	and	its	subsidiaries	(the	
"Company"),	which	comprise:
t	
t		
t		
t		

the	consolidated	statement	of	loss	and	comprehensive	loss	for	the	year	ended	December	31,	2021;
the	consolidated	statement	of	changes	in	shareholders’	equity	for	the	year	ended	December	31,	2021;
the	consolidated	statement	of	cash	flows	for	the	year	ended	December	31,	2021;	and
the	notes	to	the	consolidated	financial	statements,	including	a	summary	of	significant	accounting	policies.

In	 our	 opinion,	 the	 accompanying	 consolidated	 financial	 statements	 present	 fairly,	 in	 all	 material	 respects,	 the	
consolidated	 financial	 performance	 and	 its	 consolidated	 cash	 flows	 for	 the	 year	 ended	 December	 31,	 2021	 in	
accordance	 with	 International	 Financial	 Reporting	 Standards	 (“IFRS”)	 as	 issued	 by	 the	 International	 Accounting	
Standards	Board.	

Basis	for	Opinion	
We	conducted	our	audit	in	accordance	with	Canadian	generally	accepted	auditing	standards.	Our	responsibilities	
under	 those	 standards	 are	 further	 described	 in	 the	 Auditors'	 Responsibilities	 for	 the	 Audit	 of	 the	 Consolidated	
Financial	 Statements	 section	 of	 our	 report.	 We	 are	 independent	 of	 the	 Company	 in	 accordance	 with	 the	 ethical	
requirements	 that	 are	 relevant	 to	 our	 audit	 of	 the	 consolidated	 financial	 statements	 in	 Canada,	 and	 we	 have	
fulfilled	 our	 other	 ethical	 responsibilities	 in	 accordance	 with	 these	 requirements.	 We	 believe	 that	 the	 audit	
evidence	we	have	obtained	is	sufficient	and	appropriate	to	provide	a	basis	for	our	opinion.

Material	Uncertainty	Related	to	Going	Concern
We	draw	attention	to	Note	1	in	the	consolidated	financial	statements,	which	indicates	that	the	Company	incurred	
a	net	loss	of	$280,353	during	the	year	ended	December	31,	2021.	As	stated	in	Note	1,	these	events	or	conditions,	
along	with	other	matters	as	set	forth	in	Note	1,	indicate	that	a	material	uncertainty	exists	that	may	cast	significant	
doubt	 on	 the	 Company’s	 ability	 to	 continue	 as	 a	 going	 concern.	 Our	 opinion	 is	 not	 modified	 in	 respect	 of	 this	
matter.

Emphasis	of	Matter	–	US	generally	accepted	accounting	principles	information
IFRS	as	issued	by	the	International	Accounting	Standards	Board	vary	in	certain	significant	respects	from	accounting	
principles	generally	accepted	in	the	United	States	of	America.		Information	relating	to	the	nature	and	effect	of	such	
differences	is	presented	in	Note	12	in	the	consolidated	financial	statements.

	
Responsibilities	 of	 Management	 and	 Those	 Charged	 with	 Governance	 for	 the	 Consolidated	 Financial	
Statements
Management	is	responsible	for	the	preparation	and	fair	presentation	of	the	consolidated	financial	statements	in	
accordance	 with	 IFRS,	 and	 for	 such	 internal	 control	 as	 management	 determines	 is	 necessary	 to	 enable	 the	
preparation	of	consolidated	financial	statements	that	are	free	from	material	misstatement,	whether	due	to	fraud	
or	error.

In	preparing	the	consolidated	financial	statements,	management	is	responsible	for	assessing	the	Company's	ability	
to	 continue	 as	 a	 going	 concern,	 disclosing,	 as	 applicable,	 matters	 related	 to	 going	 concern	 and	 using	 the	 going	
concern	basis	of	accounting	unless	management	either	intends	to	liquidate	the	Company	or	to	cease	operations,	or	
has	no	realistic	alternative	but	to	do	so.

Those	charged	with	governance	are	responsible	for	overseeing	the	Company's	financial	reporting	process.

Auditors'	Responsibilities	for	the	Audit	of	the	Consolidated	Financial	Statements
Our	objectives	are	to	obtain	reasonable	assurance	about	whether	the	consolidated	financial	statements	as	a	whole	
are	free	from	material	misstatement,	whether	due	to	fraud	or	error,	and	to	issue	an	auditors'	report	that	includes	
our	opinion.	Reasonable	assurance	is	a	high	level	of	assurance,	but	is	not	a	guarantee	that	an	audit	conducted	in	
accordance	with	Canadian	generally	accepted	auditing	standards	will	always	detect	a	material	misstatement	when	
it	 exists.	 Misstatements	 can	 arise	 from	 fraud	 or	 error	 and	 are	 considered	 material	 if,	 individually	 or	 in	 the	
aggregate,	they	could	reasonably	be	expected	to	influence	the	economic	decisions	of	users	taken	on	the	basis	of	
these	 consolidated	 financial	 statements.	 As	 part	 of	 an	 audit	 in	 accordance	 with	 Canadian	 generally	 accepted	
auditing	standards,	we	exercise	professional	judgment	and	maintain	professional	skepticism	throughout	the	audit.	
We	also:

t	

Identify	and	assess	the	risks	of	material	misstatement	of	the	consolidated	financial	statements,	whether	due	
to	fraud	or	error,	design	and	perform	audit	procedures	responsive	to	those	risks,	and	obtain	audit	evidence	
that	 is	 sufficient	 and	 appropriate	 to	 provide	 a	 basis	 for	 our	 opinion.	 The	 risk	 of	 not	 detecting	 a	 material	
misstatement	resulting	from	fraud	is	higher	than	for	one	resulting	from	error,	as	fraud	may	involve	collusion,	
forgery,	intentional	omissions,	misrepresentations,	or	the	override	of	internal	control.

t	 Obtain	an	understanding	of	internal	control	relevant	to	the	audit	in	order	to	design	audit	procedures	that	are	
appropriate	in	the	circumstances,	but	not	for	the	purpose	of	expressing	an	opinion	on	the	effectiveness	of	the	
Company's	internal	control.

t	

Evaluate	the	appropriateness	of	accounting	policies	used	and	the	reasonableness	of	accounting	estimates	and	
related	disclosures	made	by	management.

t	 Conclude	on	the	appropriateness	of	management's	use	of	the	going	concern	basis	of	accounting	and,	based	on	
the	audit	evidence	obtained,	whether	a	material	uncertainty	exists	related	to	events	or	conditions	that	may	
cast	significant	doubt	on	the	Company's	ability	to	continue	as	a	going	concern.	If	we	conclude	that	a	material	
uncertainty	exists,	we	are	required	to	draw	attention	in	our	auditors'	report	to	the	related	disclosures	in	the	
consolidated	 financial	 statements	 or,	 if	 such	 disclosures	 are	 inadequate,	 to	 modify	 our	 opinion.	 Our	
conclusions	are	based	on	the	audit	evidence	obtained	up	to	the	date	of	our	auditors'	report.	However,	future	
events	or	conditions	may	cause	the	Company	to	cease	to	continue	as	a	going	concern.

t	

Evaluate	 the	 overall	 presentation,	 structure	 and	 content	 of	 the	 consolidated	 financial	 statements,	 including	
the	disclosures,	and	whether	the	consolidated	financial	statements	represent	the	underlying	transactions	and	
events	in	a	manner	that	achieves	fair	presentation.

	
t	 Obtain	 sufficient	 appropriate	 audit	 evidence	 regarding	 the	 financial	 information	 of	 the	 entities	 or	 business	
activities	 within	 the	 Company	 to	 express	 an	 opinion	 on	 the	 consolidated	 financial	 statements.	 We	 are	
responsible	for	the	direction,	supervision	and	performance	of	the	group	audit.	We	remain	solely	responsible	
for	our	audit	opinion.

We	 communicate	 with	 those	 charged	 with	 governance	 regarding,	 among	 other	 matters,	 the	 planned	 scope	 and	
timing	of	the	audit	and	significant	audit	findings,	including	any	significant	deficiencies	in	internal	control	that	we	
identify	during	our	audit.

We	 also	 provide	 those	 charged	 with	 governance	 with	 a	 statement	 that	 we	 have	 complied	 with	 relevant	 ethical	
requirements	 regarding	 independence,	 and	 to	 communicate	 with	 them	 all	 relationships	 and	 other	 matters	 that	
may	reasonably	be	thought	to	bear	on	our	independence,	and	where	applicable,	related	safeguards.

The	engagement	partner	on	the	audit	resulting	in	this	independent	auditors'	report	is	Sukhjit	Gill.

Chartered	Professional	Accountants

Vancouver,	British	Columbia
March	29,	2022

	
VIRGINIA	ENERGY	RESOURCES	INC.		
Consolidated	Statements	of	Financial	Position
(expressed	in	US	dollars)	

(Unaudited)
As	at	January	
23,	2023

(Unaudited)
As	at	December	
31,	2022

Note

Assets
Current
	Cash	
	Commodity	taxes	receivable
	Other	assets

Exploration	and	evaluation	assets	

5

$	

118,681	 $	
9,534	
5,032	
133,247	
4,253,300	

534,000	
8,238	
6,471	
548,709	
4,253,300	

Total	assets

$	

4,386,547	 $	

4,802,009	

Liabilities	
Current
	Accounts	payable	and	accrued	liabilities

Non-current
	Loans	payable

Total	liabilities

Shareholders’	equity
	Capital	stock	
	Contributed	surplus
	Deficit
Total	shareholders’	equity

9

$	

1,721	 $	

222,173	

2,000	

2,000	

3,721	

224,173	

6

53,201,546	
159,596	
(48,978,316)	 	
4,382,826	

53,156,349	
173,249	
(48,751,762)	
4,577,836	

Total	liabilities	and	shareholders’	equity

$	

4,386,547	 $	

4,802,009	

Going	concern	(Note	1)
Subsequent	event	(Note	13)

The	accompanying	notes	are	an	integral	part	of	these	unaudited	consolidated	financial	statements

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VIRGINIA	ENERGY	RESOURCES	INC.		
Consolidated	Statements	of	Loss	and	Comprehensive	Loss
(expressed	in	US	dollars)		

Expenses
	 Compensation	and	benefits	
	 Stock	based	compensation
	 Public	relations
	 Professional	and	legal	fees	
	 General	and	administrative	

Other	income	/	(loss)
	 Interest	income	
	 Timber	sales	and	other	income
	 Foreign	exchange	gain	(loss)

Note

$	

9
6,	9

For	the	23	
day	period	
ended	
Jan.	23,	2023
(Unaudited)

For	the	year	
ended	
Dec.	31,	
2022
(Unaudited)

For	the	year	
ended	
Dec.	31,	
2021

$	

24,401	
4,729	
742	
144,083	
70,914	
(244,869)	

$	

58,068	
29,813	
820	
516,882	
123,849	
(729,432)	

57,002	
—	
819	
172,903	
80,109	
(310,833)	

893	
18,221	
(799)	
18,315	

680	
60,343	
18,394	
79,417	

—	
35,800	
(5,320)	
30,480	

Net	 loss	 and	 comprehensive	 loss	 for	 the	
year
Basic	and	diluted	loss	per	share
Weighted	 average	 number	 of	 common	
shares	outstanding

(226,554)	
0.00	

$	

(650,015)	

(0.01)	 $	

(280,353)	
0.00	

$	

69,797,788	

65,968,440	

59,505,614	

The	accompanying	notes	are	an	integral	part	of	these	unaudited	consolidated	financial	statements

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VIRGINIA	ENERGY	RESOURCES	INC.		
Consolidated	Statements	of	Changes	in	Shareholders’	Equity	
(expressed	in	US	dollars)

Capital	Stock

Common	
Shares

Amount

Contributed
Surplus

Deficit

Total	
Shareholders’	
Equity	

Balance,	December	31,	2020

57,230,614	 $	 50,621,328	 $	

475,815	 $	 (47,821,394)	 $	

3,275,749	

Private	placement	

6,500,000	

1,033,959	

Share	issue	costs

-	

(14,448)	

-	

-	

Stock	options	exercised

175,000	

30,079	

(12,168)	

-	

-	

-	

1,033,959	

(14,448)	

17,911	

Net	loss	for	the	year

-	

-	

-	

(280,353)	

(280,353)	

Balance,	December	31,	2021

63,905,614	

51,670,918	

463,647	

(48,101,747)	

4,032,818	

Private	placement	(Unaudited)
Stock	options	exercised	

(Unaudited)

Stock	based	compensation	

(Unaudited)

Net	loss	for	the	year	(Unaudited)

Balance,	December	31,	2022	

(Unaudited)

Stock	options	exercised	

(Unaudited)

Stock	based	compensation	

(Unaudited)

Net	loss	for	the	period	

(Unaudited)

Balance,	January	23,	2023	

(Unaudited)

2,000,000	

735,677	

-	

3,840,000	

749,754	

(320,211)	

-	

-	

-	

735,677	

429,543	

29,813	

-	

-	

-	

-	

29,813	

-	

(650,015)	

(650,015)	

69,745,614	

53,156,349	

173,249	

(48,751,762)	

4,577,836	

400,000	

45,197	

(18,382)	

-	

-	

-	

-	

4,729	

-	

(226,554)	

(226,554)	

-	

-	

26,815	

4,729	

70,145,614	 $	 53,201,546	 $	

159,596	 $	 (48,978,316)	 $	

4,382,826	

The	accompanying	notes	are	an	integral	part	of	these	unaudited	consolidated	financial	statements

5	|	P	a	g	e	

	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
VIRGINIA	ENERGY	RESOURCES	INC.		
Consolidated	Statements	of	Cash	Flows	
(expressed	in	US	dollars)	

Cash	from	operating	activities
Net	loss	for	the	year
Non-cash	items:

Foreign	exchange	
Stock	based	compensation

Net	changes	in	non-cash	working	capital	
items

Commodity	taxes	receivable
Other	assets
Accounts	payable	and	accrued	liabilities

Cash	used	in	operating	activities

Cash	used	in	investing	activities

Exploration	and	evaluation	assets

Cash	used	in	investing	activities

Cash	from	financing	activities

Private	Placement
Share	issue	costs
Stock	options	exercised

Cash	generated	by	financing	activities

Increase	(decrease)	in	cash
Foreign	exchange	effects	on	cash
Cash,	beginning	of	the	period
Cash,	end	of	the	period

$	

For	the	period	
ended
January	23,	2023
(Unaudited)

For	the	year	ended
December	31,	
2022

For	the	year	ended
December	31,	
2021

(Unaudited)

$	

(226,554)	 $	

(650,015)	 $	

(280,353)	

799 	

4,729	

(18,394)	 	
29,813	

5,343	
-	

(1,296)	 	
1,439	
(220,452)	 	
(441,335)	 	

(7,991)	
(1,045)	
194,630	
(453,002)	 	

30
854
(505,507)	
(779,633)	

-	
-	

(500,000)	 	
(500,000)	 	

-	
-	

-	
-	
26,815	
26,815	

(414,520)	 	
(799)	 	

534,000	
118,681	 $	

735,677	
-	
429,543	
1,165,220	

212,218	
18,394	
303,388	
534,000	 $	

1,033,959	
(14,448)	
17,911	
1,037,422	

257,789	
(5,343)	
50,942	
303,388	

The	accompanying	notes	are	an	integral	part	of	these	unaudited	consolidated	financial	statements

6	|	P	a	g	e	

	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
VIRGINIA	ENERGY	RESOURCES	INC.		
Notes	to	the	Unaudited	Consolidated	Financial	Statements	
For	the	periods	ended	January	23,	2023	and	December	31,	2022	and	2021	
(expressed	in	US	dollars)	

1. NATURE	OF	OPERATIONS	AND	GOING	CONCERN	

Virginia	Energy	Resources	Inc.	(the	“Company”	or	“Virginia”)	is	a	resource	company	focused	on	the	exploration	
and	development	of	uranium	deposits	located	in	the	southern	part	of	the	state	of	Virginia	in	the	United	States	
of	America.	Virginia	was	incorporated	in	the	Yukon	on	August	31,	2007	and	was	continued	to	British	Columbia	
under	the	British	Columbia	Corporations	Act	on	May	21,	2009.		The	head	office	of	the	Company	is	located	at	
650	 –	 1021	 West	 Hastings	 Street,	 Vancouver,	 British	 Columbia,	 Canada,	 V6E	 0C3.	 	 On	 January	 24,	 2023,	 the	
Company	was	acquired	by	Consolidated	Uranium	Inc.	(TSXV:	CUR;	OTCQB:	CURUF)	as	further	described	in	Note	
13	of	these	financial	statements.

These	 unaudited	 consolidated	 financial	 statements	 have	 been	 prepared	 on	 a	 going	 concern	 basis,	 which	
contemplates	 that	 the	 Company	 will	 continue	 in	 operation	 for	 the	 foreseeable	 future	 and	 will	 be	 able	 to	
realize	its	assets	and	discharge	its	liabilities	in	the	normal	course	of	business,	rather	than	through	a	process	of	
forced	liquidation.	The	Company	incurred	a	net	loss	of	$226,553	for	the	23	day	period	ended	January	23,	2023,	
a	 net	 loss	 of	 $650,015	 for	 the	 year	 ended	 December	 31,	 2022	 (2021	 -	 $280,353)	 and	 had	 an	 accumulated	
deficit	 of	 $48,978,316	 as	 at	 January	 23,	 2023	 (December	 31,	 2022	 -	 $48,751,762).	 The	 Company’s	 ability	 to	
continue	as	a	going	concern	is	dependent	upon	the	ability	of	the	Company	to	raise	additional	equity	financing	
to	 meet	 general	 working	 capital	 requirements	 and	 ultimately	 to	 sell	 or	 to	 complete	 the	 exploration	 and	
development	of	its	uranium	deposits	and	the	attainment	of	profitable	operations,	which	may	require	a	change	
to	 Virginia	 state	 law.	 The	 Company	 will	 be	 required	 to	 raise	 additional	 financing	 in	 order	 to	 complete	 these	
objectives.	Although	the	Company	has	been	successful	in	raising	funds	to	date,	there	can	be	no	assurance	that	
adequate	or	sufficient	funding	will	be	available	in	the	future,	or	under	terms	acceptable	to	the	Company.		

In	addition,	the	Company’s	actual	results	could	differ	materially	from	those	anticipated	due	to	the	failure	of	
the	 Company’s	 court	 challenges	 to	 cause	 the	 lifting	 of	 the	 moratorium	 on	 uranium	 mining	 in	 the	 State	 of	
Virginia.	The	Company	has	been	engaged	in	a	lawsuit	against	the	Commonwealth	of	Virginia	to	overturn	the	
state’s	moratorium	on	uranium	mining	in	Virginia,	the	site	of	all	of	the	Company’s	properties.	Unfortunately,	
on	July	30,	2020	the	Circuit	Court	of	Wise	County,	Virginia	issued	a	ruling	against	Virginia	Energy’s	subsidiary,	
Virginia	Uranium	Inc.	in	its	takings	claim	against	the	Commonwealth	of	Virginia.	On	November	16,	2020,	the	
Company	filed	a	Petition	for	Appeal	with	the	Virginia	Supreme	Court	requesting	the	Court	to	grant	its	appeal	
and	 revise	 the	 Circuit	 Court’s	 judgment	 and	 remand	 the	 matter	 for	 further	 proceedings.	 On	 September	 30,	
2021	the	Company	received	notice	that	the	Virginia	Supreme	Court	had	denied	the	Petition	for	Appeal.

These	 matters	 indicate	 the	 existence	 of	 material	 uncertainties	 that	 may	 cast	 significant	 doubt	 on	 the	
Company’s	 ability	 to	 continue	 as	 a	 going	 concern.	 The	 Company’s	 discretionary	 activities	 have	 considerable	
scope	for	flexibility	in	terms	of	the	amount	and	timing	of	expenditures,	which	may	be	adjusted	accordingly.	
These	unaudited	consolidated	financial	statements	do	not	give	effect	to	adjustments	that	would	be	necessary	
to	the	carrying	values	and	classification	of	assets	and	liabilities	should	the	Company	be	unable	to	continue	as	a	
going	 concern.	 If	 the	 going	 concern	 assumptions	 were	 not	 appropriate	 for	 these	 unaudited	 consolidated	
financial	statements	then	adjustments	would	be	necessary	to	the	carrying	value	of	assets	and	liabilities,	the	
reported	 expenses,	 and	 the	 statement	 of	 financial	 position	 classifications	 used.	 Such	 adjustments	 could	 be	
material.	

7	|	P	a	g	e	

VIRGINIA	ENERGY	RESOURCES	INC.		
Notes	to	the	Unaudited	Consolidated	Financial	Statements	
For	the	periods	ended	January	23,	2023	and	December	31,	2022	and	2021	
(expressed	in	US	dollars)	

2.		 BASIS	OF	PRESENTATION	

Statement	of	compliance	

The	 unaudited	 consolidated	 financial	 statements	 have	 been	 prepared	 in	 accordance	 with	 International	
Financial	Reporting	Standard	(“IFRS”),	as	issued	by	the	International	Accounting	Standards	Board	(“IASB”),	are	
consistent	 with	 interpretations	 by	 the	 International	 Financial	 Reporting	 Interpretations	 Committee	 (“IFRIC”)	
and	are	reported	in	US	dollars.

These	unaudited	consolidated	financial	statements	were	finalized	for	issuance	on	February	5,	2024.

Basis	of	measurement	

These	 unaudited	 consolidated	 financial	 statements	 have	 been	 prepared	 on	 an	 historical	 cost	 basis	 with	 the	
exception	 of	 certain	 financial	 instruments	 that	 are	 measured	 at	 fair	 value.	 In	 addition,	 these	 unaudited	
consolidated	financial	statements	have	been	prepared	using	the	accrual	basis	of	accounting,	except	for	cash	
flow	information.	

Basis	of	consolidation	

These	unaudited	consolidated	financial	statements	include	the	accounts	of	the	Company	and	its	wholly-owned	
subsidiaries,	listed	below.	

Subsidiaries	are	those	entities	which	the	Company	controls	by	having	the	power	to	govern	the	financial	and	
operating	 policies.	 The	 existence	 and	 effect	 of	 potential	 voting	 rights	 that	 are	 currently	 exercisable	 or	
convertible	 are	 considered	 when	 assessing	 whether	 the	 Company	 controls	 another	 entity.	 Subsidiaries	 are	
fully	consolidated	from	the	date	on	which	control	is	obtained	by	the	Company	and	are	de-consolidated	from	
the	date	that	control	ceases.		All	significant	intercompany	balances	and	transactions	have	been	eliminated.

Name	of	Subsidiary

Virginia	Uranium	Inc.	(“VirginiaCo”)

Nature	of	Operations
Exploration	and
development	of	uranium	deposits

Place	of	Incorporation

Virginia,	USA

Southside	Cattle
Company	LLC	(“Southside”)

Functional	and	presentation	currency	

Holding	Company

Virginia,	USA

The	unaudited	consolidated	financial	statements	are	presented	in	US	dollars,	which	is	the	functional	currency	
of	the	Company	and	its	subsidiaries.

8	|	P	a	g	e	

	 	
VIRGINIA	ENERGY	RESOURCES	INC.		
Notes	to	the	Unaudited	Consolidated	Financial	Statements	
For	the	periods	ended	January	23,	2023	and	December	31,	2022	and	2021	
(expressed	in	US	dollars)	

2.	 BASIS	OF	PRESENTATION	(continued)	

Use	of	estimates	and	judgments	

The	 preparation	 of	 these	 unaudited	 consolidated	 financial	 statements	 in	 conformity	 with	 IFRS	 requires	
management	to	make	judgments,	estimates	and	assumptions	that	affect	the	reported	amounts	of	assets	and	
liabilities	 and	 contingent	 liabilities	 at	 the	 date	 of	 the	 unaudited	 consolidated	 financial	 statements	 and	 the	
reported	amounts	of	revenues	and	expenses	during	the	reporting	periods.		

Estimates	and	assumptions	are	continually	evaluated	and	are	based	on	management’s	experience	and	other	
factors,	including	expectations	of	future	events	that	are	believed	to	be	reasonable	under	the	circumstances.	
However,	actual	outcomes	can	differ	from	these	estimates,	which,	by	their	nature,	are	uncertain.		The	impacts	
of	such	estimates	and	judgments	are	pervasive	throughout	the	unaudited	consolidated	financial	statements,	
and	may	require	accounting	adjustments	based	on	future	occurrences.	Revisions	to	accounting	estimates,	or	
changes	to	judgments,	are	recognized	in	the	period	in	which	the	estimate	is	revised	and	may	affect	both	the	
period	of	revision	and	future	periods.

Significant	assumptions	that	management	has	made	about	current	unknowns,	the	future,	and	other	sources	of	
estimated	uncertainty,	could	result	in	a	material	adjustment	to	the	carrying	amounts	of	assets	and	liabilities	in	
the	event	that	actual	results	differ	from	assumptions	made.		Such	significant	assumptions	include,	but	are	not	
limited	to,	the	following	areas:

Critical	accounting	estimates

Critical	 accounting	 estimates	 are	 estimates	 and	 assumptions	 made	 by	 management	 that	 may	 result	 in	 a	
material	adjustment	to	the	carrying	amounts	of	assets	and	liabilities	within	the	next	financial	year	and	include,	
but	are	not	limited	to,	the	following:	

•

•

•

Recoverable	value	of	interests	in	exploration	and	evaluation	assets	–	The	carrying	value	of	exploration	and	
evaluation	assets	and	the	likelihood	of	future	economic	recoverability	of	these	carrying	values	is	subject	
to	 significant	 management	 estimates.	 The	 application	 of	 the	 Company’s	 accounting	 policy	 for	 and	
determination	 of	 recoverability	 of	 capitalized	 assets	 is	 based	 on	 assumptions	 about	 future	 events	 or	
circumstances.	 New	 information	 may	 change	 estimates	 and	 assumptions	 made.	 If	 information	 becomes	
available	indicating	that	recovery	of	expenditures	are	unlikely,	the	amounts	capitalized	are	impaired	and	
recognized	as	a	loss	in	the	period	that	the	new	information	becomes	available.	A	change	in	estimate	could	
result	in	the	carrying	amount	of	capitalized	assets	being	materially	different	from	their	presented	carrying	
costs.	

Recognition	of	income	tax	assets	–	In	assessing	the	probability	of	realizing	income	tax	assets,	management	
makes	estimates	related	to	expectations	of	future	taxable	income,	applicable	tax	opportunities,	expected	
timing	 of	 reversals	 of	 existing	 temporary	 differences	 and	 the	 likelihood	 that	 tax	 positions	 taken	 will	 be	
sustained	upon	examination	by	applicable	tax	authorities.			

Stock	based	compensation	–	The	fair	value	of	stock	based	compensation	is	subject	to	the	limitations	of	
the	 Black-Scholes	 option	 pricing	 model	 that	 incorporates	 market	 data	 and	 involves	 uncertainty	 in	
estimates	 used	 by	 management	 in	 the	 assumptions.	 Because	 the	 Black-Scholes	 option	 pricing	 model	
requires	the	input	of	highly	subjective	assumptions,	including	the	volatility	of	share	prices,	changes	in	the	
subjective	input	assumptions	can	materially	affect	the	fair	value	estimate.

9	|	P	a	g	e	

VIRGINIA	ENERGY	RESOURCES	INC.		
Notes	to	the	Unaudited	Consolidated	Financial	Statements	
For	the	periods	ended	January	23,	2023	and	December	31,	2022	and	2021	
(expressed	in	US	dollars)	

2.	 BASIS	OF	PRESENTATION	(continued)

Use	of	estimates	and	judgments	(continued)	

Critical	accounting	judgments

Information	about	critical	judgments	in	applying	accounting	policies	that	have	the	most	significant	effect	on	
the	amounts	recognized	in	the	unaudited	consolidated	financial	statements	are	as	follows:	

•

•

Carrying	 value	 and	 recoverability	 of	 exploration	 and	 evaluation	 assets	 –	 Assets	 or	 cash-generating	 units	
(“CGUs”)	 are	 evaluated	 at	 each	 reporting	 date	 to	 determine	 whether	 there	 are	 any	 indications	 of	
impairment.	The	Company	considers	both	internal	and	external	sources	of	information	when	making	the	
assessment	of	whether	there	are	indications	of	impairment	for	the	Company’s	exploration	and	evaluation	
assets.

The	going	concern	assumption	–	The	assessment	of	the	Company’s	ability	to	continue	as	a	going	concern	
and	to	raise	sufficient	funds	to	pay	its	ongoing	operating	expenditures,	meet	its	liabilities	for	the	ensuing	
year,	and	to	fund	planned	and	contractual	exploration	programs,	involves	significant	judgment	based	on	
historical	 experience	 and	 other	 factors,	 including	 expectation	 of	 future	 events	 that	 are	 believed	 to	 be	
reasonable	under	the	circumstances.

•   Determination	of	functional	currency	–	The	determination	of	the	functional	currency	for	the	Company	and	
its	subsidiaries	is	based	on	management's	judgment	of	the	underlying	transactions,	events	and	conditions	
relevant	to	each	entity.	

3.		 MATERIAL	ACCOUNTING	POLICIES	

Exploration	and	evaluation	assets	

The	Company	capitalizes	the	costs	of	acquiring	licenses	for	the	right	to	explore	as	exploration	and	evaluation	
assets.	Subsequent	to	the	acquisition,	all	direct	and	indirect	costs	related	to	the	exploration	and	development	
of	exploration	and	evaluation	assets	are	expensed.		

The	 exploration	 and	 evaluation	 assets	 remain	 capitalized	 until	 these	 assets	 are	 placed	 into	 production,	
disposed	 of	 through	 sale	 or	 determined	 to	 be	 without	 value	 should	 management	 determine	 there	 to	 be	
complete	 impairment.	 If	 an	 exploration	 and	 evaluation	 asset	 is	 abandoned,	 the	 acquisition	 costs	 capitalized	
will	be	written	off	to	operations	in	the	period	of	abandonment.	If	an	exploration	and	evaluation	asset	is	sold	
within	the	same	CGU,	the	proceeds	will	be	deducted	from	the	capitalized	costs.	

At	 each	 reporting	 date,	 exploration	 and	 evaluation	 assets	 are	 reviewed	 on	 a	 property	 by	 property	 basis	 to	
consider	 if	 there	 is	 any	 indicator	 of	 impairment.	 If	 any	 indication	 of	 impairment	 exists,	 an	 estimate	 of	 the	
exploration	and	evaluation	assets’	recoverable	amount	is	calculated.		

The	recoverable	amount	is	determined	as	the	higher	of	fair	value	less	costs	of	disposal	for	the	exploration	and	
evaluation	property	interest	and	their	value	in	use.	The	fair	value	less	costs	of	disposal	and	the	value	in	use	are	
determined	 for	 an	 individual	 exploration	 and	 evaluation	 property	 interest,	 unless	 the	 exploration	 and	
evaluation	property	interest	does	not	generate	cash	inflows	that	are	largely	independent	of	other	exploration	
and	 evaluation	 property	 interests.	 If	 this	 is	 the	 case,	 the	 exploration	 and	 evaluation	 property	 interests	 are	
grouped	together	into	CGUs	for	impairment	purposes.

10	|	P	a	g	e	

VIRGINIA	ENERGY	RESOURCES	INC.		
Notes	to	the	Unaudited	Consolidated	Financial	Statements	
For	the	periods	ended	January	23,	2023	and	December	31,	2022	and	2021	
(expressed	in	US	dollars)	

3.		 MATERIAL	ACCOUNTING	POLICIES	(continued)
Exploration	and	evaluation	assets	(continued)

If	the	recoverable	amount	of	an	asset	is	estimated	to	be	less	than	its	carrying	amount,	the	carrying	amount	of	
the	asset	is	reduced	to	its	recoverable	amount	and	the	impairment	loss	is	recognized	in	profit	or	loss	for	the	
period.		

Where	an	impairment	loss	subsequently	reverses,	the	carrying	amount	of	the	asset	is	increased	to	the	revised	
estimate	of	its	recoverable	amount,	but	to	an	amount	that	does	not	exceed	the	carrying	amount	that	would	
have	been	determined	had	no	impairment	loss	been	recognized	for	the	asset	in	prior	periods.	A	reversal	of	an	
impairment	loss	is	recognized	immediately	in	profit	or	loss.	

Reclamation	liabilities	

Reclamation	 liabilities	 are	 legal	 obligations	 associated	 with	 the	 retirement	 of	 long-lived	 assets	 that	 the	
Company	is	required	to	settle.	The	Company	recognizes	a	provision	for	these	costs	as	the	related	disturbances	
occur,	using	the	best	estimate	of	future	costs	based	on	information	available	at	the	consolidated	statement	of	
financial	 position	 date,	 including	 an	 adjustment	 for	 risk	 when	 there	 is	 significant	 variability	 in	 possible	
outcomes.	 The	 Company	 discounts	 the	 provision	 using	 a	 current	 inflation	 adjusted	 pre-tax	 risk-free	 interest	
rate	 and	 includes	 the	 accretion	 of	 the	 discounted	 amount	 over	 time	 in	 finance	 costs	 in	 the	 consolidated	
statement	of	loss	and	comprehensive	loss.	The	carrying	amount	of	the	related	long-lived	asset	is	increased	by	
the	 same	 amount	 as	 the	 liability.	 At	 January	 23,	 2023,	 and	 December	 31,	 2022,	 the	 Company	 had	 not	
undertaken	disturbances	that	would	require	recognition	of	a	reclamation	liability.	

Capital	stock	

Capital	stock	issued	for	non-monetary	consideration	is	valued	at	the	pre-determined	private	placement	price	
where	 applicable.	 The	 proceeds	 from	 the	 issuance	 of	 units	 are	 allocated	 between	 common	 shares	 and	
warrants	based	on	the	residual	value	method.	Under	this	method,	the	proceeds	are	allocated	first	to	capital	
stock	based	on	the	fair	value	of	the	common	shares	at	the	time	the	units	are	priced	and	any	residual	value	is	
allocated	to	the	warrants	reserve,	a	component	of	contributed	surplus.	Consideration	received	for	the	exercise	
of	warrants	is	recorded	in	capital	stock	and	the	related	residual	value	is	transferred	from	warrant	reserve	to	
capital	stock.	For	unexercised	warrants	that	expire,	the	recorded	value	is	transferred	to	deficit.	

Stock	based	compensation

The	 Company	 grants	 stock	 options	 and	 restricted	 share	 units	 (“RSUs”)	 to	 acquire	 common	 shares	 of	 the	
Company	to	directors,	officers,	employees	and	consultants.	An	individual	is	classified	as	an	employee	when	the	
individual	 is	 an	 employee	 for	 legal	 or	 tax	 purposes	 or	 provides	 services	 similar	 to	 those	 performed	 by	 an	
employee.	The	fair	value	of	stock	options	or	RSUs	granted	to	employees	is	measured	on	the	date	of	grant,	and	
is	recognized	over	the	vesting	period	as	stock	based	compensation	expense	with	a	corresponding	increase	in	
reserves	(contributed	surplus).	When	stock	options	are	exercised,	share	capital	is	increased	by	the	sum	of	the	
consideration	 paid	 and	 the	 related	 portion	 of	 share-based	 compensation	 previously	 recorded	 in	 reserves.	
When	 RSUs	 vest,	 share	 capital	 is	 increased	 by	 the	 related	 portion	 of	 share-based	 compensation	
previously	recorded	in	reserves.	Upon	expiry	of	stock	options,	the	fair	value	of	unexercised	options	is	
transferred	to	deficit.

Share-based	compensation	to	non-employees	is	measured	at	the	fair	value	of	goods	or	services	received	or	the	
fair	value	of	the	equity	instruments	issued,	if	it	is	determined	the	fair	value	of	the	goods	or	services	cannot	be	
reliably	measured,	and	are	recorded	at	the	date	the	goods	or	services	are	received.	

11	|	P	a	g	e	

VIRGINIA	ENERGY	RESOURCES	INC.		
Notes	to	the	Unaudited	Consolidated	Financial	Statements	
For	the	periods	ended	January	23,	2023	and	December	31,	2022	and	2021	
(expressed	in	US	dollars)	

3.	MATERIAL	ACCOUNTING	POLICIES	(continued)

Stock	based	compensation	(continued)	

The	fair	value	of	option	awards	is	calculated	using	the	Black-Scholes	option	pricing	model,	which	considers	the	
following	 factors:	 exercise	 price,	 expected	 life,	 expected	 volatility,	 forfeiture	 rate,	 current	 market	 price	 of	
underlying	shares,	risk-free	interest	rate	and	dividend	yield.		The	fair	value	of	RSU	awards	is	calculated	using	
the	current	market	price	of	the	underlying	shares,	and	the	anticipated	forfeiture	rate.

Foreign	currency	translation	

Transactions	in	foreign	currencies	are	initially	recorded	in	the	functional	currency	at	the	rate	in	effect	at	the	
date	of	the	transaction.	Monetary	assets	and	liabilities	denominated	in	foreign	currencies	are	retranslated	at	
the	spot	rate	of	exchange	in	effect	at	the	reporting	date.	Non-monetary	items	that	are	measured	in	terms	of	
historical	 cost	 in	 a	 foreign	 currency	 are	 translated	 using	 the	 exchange	 rate	 as	 at	 the	 date	 of	 the	 initial	
transaction.	 Non-monetary	 items	 measured	 at	 fair	 value	 in	 a	 foreign	 currency	 are	 translated	 using	 the	
exchange	 rates	 at	 the	 date	 when	 the	 fair	 value	 was	 determined.	 All	 exchange	 differences	 are	 recorded	 in	
foreign	exchange	gain	or	loss	in	the	consolidated	statement	of	loss	and	comprehensive	loss.		

Financial	instruments	

Financial	assets	

(a) Recognition	and	measurement	of	financial	assets	

The	 Company	 recognizes	 a	 financial	 asset	 when	 it	 becomes	 a	 party	 to	 the	 contractual	 provisions	 of	 the	
instrument.		

(b) Classification	of	financial	assets	

The	 Company	 classifies	 financial	 assets	 at	 initial	 recognition	 as	 financial	 assets:	 measured	 at	 amortized	
cost,	 measured	 at	 fair	 value	 through	 other	 comprehensive	 income	 or	 measured	 at	 fair	 value	 through	
profit	or	loss.

Financial	assets	measured	at	amortized	cost	

A	financial	asset	that	meets	both	of	the	following	conditions	is	classified	as	a	financial	asset	measured	at	
amortized	cost.	
•

The	Company’s	business	model	for	the	such	financial	assets,	is	to	hold	the	assets	in	order	to	collect	
contractual	cash	flows.	
The	contractual	terms	of	the	financial	asset	gives	rise	on	specified	dates	to	cash	flows	that	are	solely	
payments	of	principal	and	interest	on	the	amount	outstanding.	

•

	 A	 financial	 asset	 measured	 at	 amortized	 cost	 is	 initially	 recognized	 at	 fair	 value	 plus	 transaction	 costs	
directly	 attributable	 to	 the	 asset.	 After	 initial	 recognition,	 the	 carrying	 amount	 of	 the	 financial	 asset	
measured	at	amortized	cost	is	determined	using	the	effective	interest	method,	net	of	impairment	loss,	if	
necessary.		

12	|	P	a	g	e	

VIRGINIA	ENERGY	RESOURCES	INC.		
Notes	to	the	Unaudited	Consolidated	Financial	Statements	
For	the	periods	ended	January	23,	2023	and	December	31,	2022	and	2021	
(expressed	in	US	dollars)	

3.		 MATERIAL	ACCOUNTING	POLICIES	(continued)

Financial	instruments	(continued)	
Financial	assets	(continued)	

Financial	assets	measured	at	fair	value	through	other	comprehensive	income	(“FVTOCI”)	

A	financial	asset	measured	at	fair	value	through	other	comprehensive	income	is	recognized	initially	at	fair	
value	 plus	 transaction	 cost	 directly	 attributable	 to	 the	 asset.	 After	 initial	 recognition,	 the	 asset	 is	
measured	at	fair	value	with	changes	in	fair	value	in	other	comprehensive	income.		

Financial	assets	measured	at	fair	value	through	profit	or	loss	(“FVTPL”)	

A	financial	asset	measured	at	fair	value	through	profit	or	loss	is	recognized	initially	at	fair	value	with	any	
associated	transaction	costs	being	recognized	in	profit	or	loss	when	incurred.	Subsequently,	the	financial	
asset	is	re-measured	at	fair	value,	and	a	gain	or	loss	is	recognized	in	profit	or	loss	in	the	reporting	period	in	
which	it	arises.

(c) Derecognition	of	financial	assets	

The	 Company	 derecognizes	 a	 financial	 asset	 if	 the	 contractual	 rights	 to	 the	 cash	 flows	 from	 the	 asset	
expire,	 or	 the	 Company	 transfers	 substantially	 all	 the	 risks	 and	 rewards	 of	 ownership	 of	 the	 financial	
asset.	 Any	 interests	 in	 transferred	 financial	 assets	 that	 are	 created	 or	 retained	 by	 the	 Company	 are	
recognized	as	a	separate	asset	or	liability.	Gains	and	losses	on	derecognition	are	generally	recognized	in	
the	 consolidated	 statement	 of	 income	 (loss).	 However,	 gains	 and	 losses	 on	 derecognition	 of	 financial	
assets	classified	as	FVTOCI	remain	within	accumulated	other	comprehensive	income.	

Financial	liabilities	

(a) Recognition	and	measurement	of	financial	liabilities	

The	Company	recognizes	financial	liabilities	when	it	becomes	a	party	to	the	contractual	provisions	of	the	
instruments.		

(b) Classification	of	financial	liabilities	

The	 Company	 classifies	 financial	 liabilities	 at	 initial	 recognition	 as	 financial	 liabilities:	 measured	 at	
amortized	cost	or	measured	at	fair	value	through	profit	or	loss.	

Financial	liabilities	measured	at	amortized	cost	

A	 financial	 liability	 at	 amortized	 cost	 is	 initially	 measured	 at	 fair	 value	 less	 transaction	 cost	 directly	
attributable	 to	 the	 issuance	 of	 the	 financial	 liability.	 Subsequently,	 the	 financial	 liability	 is	 measured	 at	
amortized	cost	based	on	the	effective	interest	rate	method.

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VIRGINIA	ENERGY	RESOURCES	INC.		
Notes	to	the	Unaudited	Consolidated	Financial	Statements	
For	the	periods	ended	January	23,	2023	and	December	31,	2022	and	2021	
(expressed	in	US	dollars)	

3.		 MATERIAL	ACCOUNTING	POLICIES	(continued)

Financial	instruments	(continued)	
Financial	liabilities	(continued)

Financial	liabilities	measured	at	fair	value	through	profit	or	loss	

A	financial	liability	measured	at	fair	value	through	profit	or	loss	is	initially	measured	at	fair	value	with	any	
associated	transaction	costs	being	recognized	in	profit	or	loss	when	incurred.	Subsequently,	the	financial	
liability	is	re-measured	at	fair	value,	and	a	gain	or	loss	is	recognized	in	profit	or	loss	in	the	reporting	period	
in	which	it	arises.	

(c) Derecognition	of	financial	liabilities	

The	 Company	 derecognizes	 a	 financial	 liability	 when	 the	 financial	 liability	 is	 discharged,	 cancelled	 or	
expired.	Generally,	the	difference	between	the	carrying	amount	of	the	financial	liability	derecognized	and	
the	 consideration	 paid	 and	 payable,	 including	 any	 non-cash	 assets	 transferred	 or	 liabilities	 assumed,	 is	
recognized	in	the	consolidated	statement	of	loss	and	comprehensive	loss.		

Offsetting	financial	assets	and	liabilities	

Financial	 assets	 and	 liabilities	 are	 offset	 and	 the	 net	 amount	 is	 presented	 in	 the	 consolidated	 statement	 of	
financial	 position	 only	 when	 the	 Company	 has	 a	 legally	 enforceable	 right	 to	 set	 off	 the	 recognized	 amounts	
and	intends	either	to	settle	on	a	net	basis,	or	to	realize	the	asset	and	settle	the	liability	simultaneously.	

Impairment	of	financial	assets	at	amortized	cost	

The	Company	recognizes	a	loss	allowance	for	expected	credit	losses	on	financial	assets	that	are	measured	at	
amortized	cost.	At	each	reporting	date,	the	Company	measures	the	loss	allowance	for	the	financial	asset	at	an	
amount	 equal	 to	 the	 lifetime	 expected	 credit	 losses	 if	 the	 credit	 risk	 on	 the	 financial	 asset	 has	 increased	
significantly	since	initial	recognition.	If	at	the	reporting	date,	the	financial	asset	has	not	increased	significantly	
since	initial	recognition,	the	Company	measures	the	loss	allowance	for	the	financial	asset	at	an	amount	equal	
to	 the	 twelve	 month	 expected	 credit	 losses.	 The	 Company	 shall	 recognize	 in	 the	 consolidated	 statement	 of	
loss,	as	an	impairment	gain	or	loss,	the	amount	of	expected	credit	losses	(or	reversal)	that	is	required	to	adjust	
the	loss	allowance	at	the	reporting	date	to	the	amount	that	is	required	to	be	recognized.	

Fair	value	hierarchy	

Fair	value	measurements	of	financial	instruments	are	required	to	be	classified	using	a	fair	value	hierarchy	that	
reflects	the	significance	of	inputs	used	in	making	the	measurements.	The	levels	of	the	fair	value	hierarchy	are	
defined	as	follows:	

Level	1	-	 Quoted	prices	(unadjusted)	in	active	markets	for	identical	assets	or	liabilities.	

Level	2	-	 Inputs	other	than	quoted	prices	included	within	Level	1	that	are	observable	for	the	asset	or	liability,	

either	directly	or	indirectly.	

Level	3	-	 Inputs	for	assets	or	liabilities	that	are	not	based	on	observable	market	data.	

14	|	P	a	g	e	

VIRGINIA	ENERGY	RESOURCES	INC.		
Notes	to	the	Unaudited	Consolidated	Financial	Statements	
For	the	periods	ended	January	23,	2023	and	December	31,	2022	and	2021	
(expressed	in	US	dollars)	

3.		 MATERIAL	ACCOUNTING	POLICIES	(continued)

Income	taxes	

Income	 tax	 expense	 consisting	 of	 current	 and	 deferred	 tax	 expense	 is	 recognized	 in	 the	 consolidated	
statement	of	loss.	Current	tax	expense	is	the	expected	tax	payable	on	the	taxable	income	for	the	year,	using	
tax	rates	enacted	or	substantively	enacted	at	year-end,	adjusted	for	amendments	to	tax	payable	with	regard	
to	previous	years.	

Deferred	tax	assets	and	liabilities	and	the	related	deferred	income	tax	expense	or	recovery	are	recognized	for	
deferred	 tax	 consequences	 attributable	 to	 differences	 between	 the	 financial	 statement	 carrying	 amounts	 of	
existing	 assets	 and	 liabilities	 and	 their	 respective	 tax	 basis.	 Deferred	 tax	 assets	 and	 liabilities	 are	 measured	
using	 the	 enacted	 or	 substantively	 enacted	 tax	 rates	 expected	 to	 apply	 when	 the	 asset	 is	 realized	 or	 the	
liability	settled.	The	effect	on	deferred	tax	assets	and	liabilities	of	a	change	in	tax	rates	is	recognized	in	income	
in	the	period	that	substantive	enactment	occurs.	

	A	deferred	tax	asset	is	recognized	to	the	extent	that	it	is	probable	that	future	taxable	income	will	be	available	
against	which	the	asset	can	be	utilized.	To	the	extent	that	the	Company	does	not	consider	it	probable	that	a	
deferred	tax	asset	will	be	recovered,	the	deferred	tax	asset	is	not	recognized.	Deferred	tax	assets	and	liabilities	
are	offset	when	there	is	a	legally	enforceable	right	to	set	off	tax	assets	against	tax	liabilities	and	when	they	
relate	to	income	taxes	levied	by	the	same	taxation	authority	and	the	Company	intends	to	settle	its	tax	assets	
and	liabilities	on	a	net	basis.	

Earnings	(loss)	per	share	

Basic	 earnings	 (loss)	 per	 share	 is	 calculated	 using	 the	 weighted	 average	 number	 of	 common	 shares	
outstanding	 during	 the	 year.	 The	 Company	 uses	 the	 treasury	 stock	 method	 for	 calculating	 diluted	 earnings	
(loss)	per	share.	Under	this	method,	the	dilutive	effect	on	earnings	per	share	is	calculated	on	the	use	of	the	
proceeds	that	could	be	obtained	upon	exercise	of	options,	warrants	and	similar	instruments.	It	assumes	that	
the	proceeds	of	such	exercise	would	be	used	to	purchase	common	shares	at	the	average	market	price	during	
the	 year.	 However,	 the	 calculation	 of	 diluted	 loss	 per	 share	 excludes	 the	 effects	 of	 various	 conversions	 and	
exercise	 of	 options	 and	 warrants	 that	 would	 be	 anti-dilutive.	 Shares	 held	 in	 escrow,	 other	 than	 where	 their	
release	is	subject	to	the	passage	of	time,	are	not	included	in	the	calculation	of	the	weighted	average	number	
of	common	shares	outstanding.	

Revenue

Revenue	from	the	sale	of	timber	is	measured	based	on	the	rates	negotiated	with	the	customers,	net	of	rebates	
and	discounts,	if	any.	Revenue	is	recognized	when	control	over	a	product	transfers	from	the	Company	to	the	
customer.	 As	 the	 customer	 is	 generally	 responsible	 for	 harvesting	 and	 shipping	 the	 timber,	 the	 timing	 of	
transfer	of	control	is	generally	on	the	date	of	cutting	of	the	timber.

15	|	P	a	g	e	

VIRGINIA	ENERGY	RESOURCES	INC.		
Notes	to	the	Unaudited	Consolidated	Financial	Statements	
For	the	periods	ended	January	23,	2023	and	December	31,	2022	and	2021	
(expressed	in	US	dollars)	

4.		 NEWLY	ADOPTED	ACCOUNTING	STANDARDS	AND	NEW	ACCOUNTING	STANDARDS	AND	INTERPRETATIONS	

NOT	YET	ADOPTED	

The	IASB	has	issued	a	number	of	amendments	to	standards	and	interpretations,	some	of	which	were	not	yet	
effective	 in	 2023.	 Amendments	 not	 yet	 effective	 have	 not	 been	 applied	 in	 preparing	 these	 unaudited	
consolidated	 financial	 statements.	 	 It	 is	 anticipated	 that	 these	 amendments	 will	 have	 no	 impact	 on	 the	
Company’s	financial	statements	when	they	are	adopted	in	future	years.

New	accounting	policies	adopted	January	1,	2023

Disclosure	of	Accounting	Policies	(Amendment	to	IAS	1	and	IFRS	Practice	Statement	2)	

In	February	2021,	the	IASB	issued	amendments	to	IAS	1,	Presentation	of	Financial	Statements,	and	the	IFRS	
Practice	 Statement	 2,	 Making	 Materiality	 Judgements,	 to	 provide	 guidance	 on	 the	 application	 of	 materiality	
judgments	 to	 accounting	 policy	 disclosures.	 The	 amendments	 to	 IAS	 1	 replace	 the	 requirement	 to	 disclose	
‘significant’	 accounting	 policies	 with	 a	 requirement	 to	 disclose	 ‘material’	 accounting	 policies.	 Guidance	 and	
illustrative	 examples	 are	 added	 in	 the	 Practice	 Statement	 to	 assist	 in	 the	 application	 of	 materiality	 concept	
when	making	judgments	about	accounting	policy	disclosures.

These	amendments	are	effective	for	annual	financial	statements	for	periods	beginning	on	or	after	January	1,	
2023.	There	was	no	 material	 impact	on	the	Company’s	consolidated	financial	statements	resulting	from	the	
adoption	of	these	amendments.

Accounting	standards	and	interpretations	not	yet	adopted

Several	new	standards,	amendments	to	standards,	and	interpretations	were	not	yet	effective	for	the	period	
ended	 January	 23,	 2023	 and	 have	 not	 been	 applied	 in	 preparing	 these	 unaudited	 consolidated	 financial	
statements,	including:

Classification	of	Liabilities	as	Current	or	Non-Current	(Amendments	to	IAS	1)

The	IASB	has	published	amendments	to	IAS	1	which	clarify	the	guidance	on	whether	a	liability	should	be	
classified	as	either	current	or	non-current.		The	amendments	clarify	that	the	classification	of	liabilities	as	
current	 or	 non-current	 should	 only	 be	 based	 on	 rights	 that	 are	 in	 place	 "at	 the	 end	 of	 the	 reporting	
period.”	 	 In	 addition,	 updates	 clarify	 that	 classification	 is	 unaffected	 by	 expectations	 about	 whether	 an	
entity	 will	 exercise	 its	 right	 to	 defer	 settlement	 of	 a	 liability.	 Finally,	 the	 amendments	 make	 clear	 that	
settlement	of	a	liability	includes	transfers	to	the	counterparty	of	cash,	equity	instruments,	other	assets	or	
services	 that	 result	 in	 extinguishment	 of	 the	 liability.	 	 This	 amendment	 is	 effective	 for	 annual	 periods	
beginning	 on	 or	 after	 January	 1,	 2024,	 and	 is	 not	 expected	 to	 have	 a	 significant	 impact	 on	 Virginia’s	
unaudited	consolidated	financial	statements.

5.	 EXPLORATION	AND	EVALUATION	ASSETS

Balance,	December	31,	2021
Land	lease	payments
Balance,	December	31,	2022	and	January	23,	2023

$3,753,300
$500,000
$4,253,300

16	|	P	a	g	e	

VIRGINIA	ENERGY	RESOURCES	INC.		
Notes	to	the	Unaudited	Consolidated	Financial	Statements	
For	the	periods	ended	January	23,	2023	and	December	31,	2022	and	2021	
(expressed	in	US	dollars)	

6.		 CAPITAL	STOCK	

Authorized	
	Unlimited	number	of	common	shares	without	par	value.	

Issued	and	outstanding	
	As	of	January	23,	2023	there	were	70,145,614	(December	31,	2022	–	69,745,614)	common	shares	issued	and	
outstanding.	

During	the	23-day	period	ended	January	23,	2023,	the	Company	issued	400,000	common	shares	in	satisfaction	
of	the	exercise	of	stock	options	for	gross	proceeds	to	the	Company	of	$26,815.

During	 the	 year	 ended	 December	 31,	 2022,	 the	 Company	 issued	 2,000,000	 common	 shares	 in	 a	 private	
placement	 at	 CAD$0.50	 per	 common	 share.	 Gross	 proceeds	 were	 $735,677.	 In	 addition,	 stock	 options	 were	
exercised	to	purchase	3,840,000	common	shares	for	gross	proceeds	to	the	Company	of	$429,543	in	2022.		

During	 the	 year	 ended	 December	 31,	 2021,	 the	 Company	 issued	 6,500,000	 common	 shares	 in	 a	 private	
placement	 at	 CAD$0.20	 per	 common	 share.	 Gross	 proceeds	 were	 $1,033,959	 and	 share	 issuance	 costs	 paid	
totaled	 $14,448.	 In	 addition,	 stock	 options	 were	 exercised	 to	 purchase	 175,000	 common	 shares	 for	 gross	
proceeds	to	the	Company	of	$17,911	in	2021.

Stock	options
The	 Company	 has	 a	 rolling	 stock	 option	 plan	 (the	 “Plan”)	 allowing	 for	 the	 reservation	 of	 common	 shares	
issuable	under	the	Plan	to	a	maximum	of	10%	of	the	number	of	the	issued	and	outstanding	common	shares	of	
the	Company	at	any	given	time.	The	options	granted	to	any	one	person	in	a	total	in	any	twelve-month	period	
shall	 not	 exceed	 5%	 of	 the	 issued	 and	 outstanding	 shares	 of	 the	 Company.	 The	 options	 granted	 to	 any	 one	
consultant	 to	 the	 Company	 as	 a	 total	 in	 any	 twelve-month	 period	 shall	 not	 exceed	 2%	 of	 the	 issued	 and	
outstanding	 shares	 of	 the	 Company.	 Options	 granted	 to	 all	 employees,	 consultants	 and	 their	 associates	
engaged	 in	 investor	 relations	 activities	 for	 the	 Company	 in	 aggregate	 in	 any	 twelve-month	 period	 shall	 not	
exceed	2%	of	the	issued	and	outstanding	shares	of	the	Company.	The	term	of	stock	options	granted	under	the	
Plan	may	not	exceed	five	years	and	the	exercise	price	may	not	be	less	than	the	closing	price	of	the	Company’s	
shares	on	the	last	business	day	immediately	preceding	the	date	of	grant,	less	any	permitted	discount.	

On	January	19,	2023,	shareholders	approved	the	adoption	of	an	RSU	equity	plan,	allowing	for	the	issuance	of	
RSUs	representing	up	to	5%	of	the	number	of	the	issued	and	outstanding	common	shares	of	the	Company	at	
any	given	time,	provided	that,	together	with	the	stock	option	Plan,	the	number	of	shares	issuable	under	either	
of	 these	 plans	 is	 no	 more	 than	 10%	 of	 the	 number	 of	 the	 issued	 and	 outstanding	 common	 shares	 of	 the	
Company	at	any	given	time.

When	the	Company	issues	stock	options	or	RSUs,	it	records	stock	based	compensation	expense	in	the	periods	
over	which	the	options	or	RSUs	vest.	RSUs	are	valued	at	the	most	recent	closing	price	on	the	date	of	grant.		
Stock	 option	 expense	 is	 estimated	 based	 on	 a	 series	 of	 assumptions.	 The	 expected	 volatility	 is	 based	 on	
management’s	best	estimate	of	forward-looking	volatility,	using	historical	volatility	of	the	Company’s	common	
shares	 as	 a	 guide.	 The	 risk-free	 interest	 rate	 is	 based	 on	 yield	 curves	 on	 Canadian	 government	 zero	 coupon	
bonds	with	a	remaining	term	equal	to	the	expected	life	of	the	stock	options.	The	Company	uses	historic	data	
to	estimate	option	 exercise,	 forfeiture	and	employee	termination	within	the	valuation	model.	The	Company	
has	 not	 paid	 and	 does	 not	 anticipate	 paying	 dividends	 on	 its	 common	 shares.	 Based	 on	 their	 best	 estimate,	
management	applied	an	estimated	forfeiture	rate	of	0%.	

17	|	P	a	g	e	

	
VIRGINIA	ENERGY	RESOURCES	INC.		
Notes	to	the	Unaudited	Consolidated	Financial	Statements	
For	the	periods	ended	January	23,	2023	and	December	31,	2022	and	2021	
(expressed	in	US	dollars)	

6.		 CAPITAL	STOCK	(continued)
Stock	options	(continued)		

1,850,000	incentive	stock	options	were	issued	on	May	25,	2020	and	are	exercisable	at	CAD$0.09	until	May	25,	
2025.	The	Black	Scholes	option	pricing	model	was	used	to	value	the	incentive	stock	options	with	the	following	
inputs:	an	expected	life	of	5.0	years,	an	annualized	volatility	of	95%,	dividend	payment	and	forfeiture	rates	of	
zero,	the	fair	value	of	the	share	at	the	grant	date	of	CAD$0.09,	and	a	risk-free	interest	rate	of	0.31%.

Stock	option	transactions	are	summarized	as	follows:	

Outstanding,	December	31,	2020
			Exercised,	April	2021
Outstanding,	December	31,	2021
			Exercised,	August	and	November	2022
Outstanding,	December	31,	2022
			Exercised,	January	2023
Outstanding,	January	23,	2023
Number	exercisable

Stock	Options

Number	of	
Options
5,790,000
(175,000)
5,615,000
(3,840,000)
1,775,000
(400,000)
1,375,000
1,375,000

Weighted	Average
Exercise	Price	
(CAD$)
0.13
0.12
0.13
0.15
0.09
0.09
0.09
0.09

Weighted	Average
Remaining	Life	
(years)
2.52

1.51

2.40

2.34

As	at	January	23,	2023,	and	December	31,	2022	and	2021,	the	Company	had	the	following	outstanding	stock	
options:	

December	31,	2021
Number	of	options

December	31,	2022
Number	of	options

January	23,	2023
Number	of	options

Exercise	Price	
(CAD$)

Date	of	Expiry

3,840,000	
1,775,000	
5,615,000	

-	
1,775,000	
1,775,000	

-	
1,375,000	
1,375,000	

$	
$	

Aug	21,	2022
0.15	
0.09	 May	25,	2025

During	the	year	ended	December	31,	2021,	175,000	stock	options	were	exercised	with	a	common	share	price	
on	 the	 date	 of	 exercise	 of	 CAD	 $0.30.	 	 During	 the	 year	 ended	 December	 31,	 2022,	 3,500,000	 stock	 options	
were	exercised	with	a	common	share	price	on	the	date	of	exercise	of	CAD	$0.30,	and	340,000	stock	options	
were	 exercised	 with	 a	 common	 share	 price	 on	 the	 date	 of	 exercise	 of	 CAD	 $0.35.	 During	 the	 period	 ended	
January	23,	2023,	400,000	stock	options	were	exercised	with	a	common	share	price	on	the	date	of	exercise	of	
CAD	$0.30.		

The	Company	granted	500,000	RSUs	on	August	8,	2022,	vesting	on	August	8,	2024,	or	on	change	of	control	of	
the	Company,	subject	to	regulatory	and	shareholder	approval.		On	January	19,	2023,	shareholders	granted	the	
required	 approval.	 	 These	 RSUs	 were	 still	 outstanding	 at	 December	 31,	 2022.	 	 At	 December	 31,	 2021,	 there	
were	no	RSUs	outstanding.

18	|	P	a	g	e	

	
	
	
	
	
	
	
	
	
VIRGINIA	ENERGY	RESOURCES	INC.		
Notes	to	the	Unaudited	Consolidated	Financial	Statements	
For	the	periods	ended	January	23,	2023	and	December	31,	2022	and	2021	
(expressed	in	US	dollars)	

7.	 FINANCIAL	INSTRUMENTS	AND	RISK	MANAGEMENT	

Financial	instruments	include	cash,	accounts	payable	and	accrued	liabilities	and	loans	payable.	The	Company	
has	exposure	to	the	following	risks	associated	with	its	financial	instruments:	

Other	price	risk	

Other	price	risk	is	the	risk	that	the	fair	value	or	future	cash	flows	of	a	financial	instrument	will	fluctuate	due	to	
changes	 in	 market	 prices,	 other	 than	 those	 arising	 from	 interest	 rate	 risk.	 The	 Company	 is	 not	 exposed	 to	
other	price	risk.	

Liquidity	risk	and	fair	value	hierarchy	

Liquidity	risk	is	the	risk	that	the	Company	will	not	be	able	to	meet	its	financial	obligations	as	they	are	due.		The	
Company	manages	its	liquidity	risk	by	managing	cash	expenditures,	and	by	preparing	and	monitoring	forecasts	
of	cash	expenditures	to	ensure	that	it	will	have	sufficient	liquidity	to	meet	liabilities	when	due.	As	at	January	
23,	 2023,	 the	 Company	 had	 a	 cash	 balance	 of	 $118,681	 (December	 31,	 2022	 -	 $534,000)	 to	 settle	 current	
liabilities	of	$1,721	(2022	-	$222,173).	

The	 carrying	 values	 for	 financial	 instruments,	 including	 cash	 and	 accounts	 payable	 and	 accrued	 liabilities	
approximate	 fair	 values	 due	 to	 their	 short-term	 maturities.	 The	 Company’s	 accounts	 payable	 and	 accrued	
liabilities	generally	have	maturities	of	less	than	90	days,	while	loans	payable	have	maturities	of	greater	than	
one	year.

Currency	risk	

The	Company	is	exposed	to	foreign	currency	risk,	as	it	operates	in	the	United	States	and	Canada	and	certain	
expenditures	are	denominated	in	non-US	dollar	currencies.	Canadian	dollar	denominated	balances	generated	
foreign	exchange	gains	and	losses	that	are	reported	on	the	consolidated	statement	of	loss	and	comprehensive	
loss.	A	strengthening	of	10%	in	the	US	dollar	against	the	Canadian	dollar	would	have	increased	the	Company’s	
net	loss	and	comprehensive	loss	by	$3,681		(December	31,	2022	–	decrease	of	$10,034)	due	to	the	impact	of	
the	exchange	rate	fluctuation	on	Canadian	dollar	denominated	financial	instruments.

The	 balances	 listed	 below	 are	 the	 Canadian	 dollar	 denominated	 balances	 of	 their	 reported	 US	 dollar	
equivalent.	

Canadian	dollar	amounts
Cash
Commodity	taxes	receivable
Accounts	payable	and	accrued	liabilities

January	23,	
2023
39,256	
12,875	
(2,422)	
49,709	

$	

$	

19	|	P	a	g	e	

$	

December	31,	
2022
125,902	
11,154	
(272,921)	
(135,865)	

$	

	
	
	
	
VIRGINIA	ENERGY	RESOURCES	INC.		
Notes	to	the	Unaudited	Consolidated	Financial	Statements	
For	the	periods	ended	January	23,	2023	and	December	31,	2022	and	2021	
(expressed	in	US	dollars)	

7.	 FINANCIAL	INSTRUMENTS	AND	RISK	MANAGEMENT	(continued)	

Interest	rate	risk	

Interest	rate	risk	is	the	risk	that	future	cash	flows	will	fluctuate	as	a	result	of	changes	in	market	interest	rates.	
Interest	 earned	 on	 cash	 is	 at	 nominal	 interest	 rates,	 and	 therefore	 the	 Company	 does	 not	 consider	 interest	
rate	risk	to	be	significant.		

Credit	risk	

Credit	risk	is	the	risk	of	financial	loss	to	the	Company	if	a	customer	or	counterparty	to	a	financial	instrument	
fails	 to	 meet	 its	 contractual	 obligations.	 The	 Company	 has	 no	 significant	 concentration	 of	 credit	 risk	 arising	
from	operations.	Cash	is	held	with	major	financial	institutions.	The	maximum	exposure	to	credit	risk	is	limited	
to	amounts	shown	on	the	consolidated	statement	of	financial	position.		

Other	risks	

COVID-19	has	severely	impacted	economies	around	the	globe.	In	many	countries,	including	Canada,	businesses	
have	 been	 forced	 to	 cease	 or	 limit	 operations.	 Measures	 taken	 to	 contain	 the	 spread	 of	 the	 virus	 have	
triggered	 significant	 disruptions	 to	 businesses	 worldwide,	 resulting	 in	 significant	 unemployment	 and	 an	
economic	slowdown.	Global	stock	markets	have	also	experienced	great	volatility	and	a	significant	weakening	
of	 certain	 sectors.	 Governments	 and	 central	 banks	 have	 responded	 with	 monetary	 and	 fiscal	 interventions	
designed	 to	 stabilize	 economic	 conditions.	 To	 date,	 the	 Company’s	 operations	 have	 not	 been	 significantly	
negatively	affected	by	these	events.

8.		 CAPITAL	MANAGEMENT	

The	Company’s	objective	when	managing	capital	is	to	safeguard	the	Company’s	ability	to	continue	as	a	going	
concern	in	order	to	pursue	the	exploration	and	development	programs	on	its	mineral	properties,	by	defending	
its	 legal	 right	 to	 explore	 and	 mine	 these	 properties,	 while	 minimizing	 any	 increases	 in	 equity	 dilution	 to	
shareholders.	 The	 Company	 manages	 its	 capital	 structure,	 consisting	 of	 shareholders’	 equity	 of	 $4,382,826	
(December	31,	2022	-	$4,577,836)	and	makes	adjustments	to	it,	based	on	funds	available	to	the	Company,	in	
order	to	support	the	exploration	and	development	of	its	mineral	properties.	The	Company	relies	primarily	on	
the	issuance	of	common	shares	for	its	capital	requirements.	All	of	the	Company’s	cash	is	available	for	payment	
of	 accounts	 payable	 and	 accrued	 liabilities,	 as	 well	 as	 for	 conducting	 further	 exploration	 and	 development	
programs	and	administrative	operations.		The	Company	has	not	changed	its	approach	to	capital	management	
during	 the	 period	 ended	 January	 23,	 2023	 and	 the	 years	 ended	 December	 31,	 2022,	 and	 2021	 and	 is	 not	
subject	to	any	external	capital	restrictions.	

20	|	P	a	g	e	

VIRGINIA	ENERGY	RESOURCES	INC.		
Notes	to	the	Unaudited	Consolidated	Financial	Statements	
For	the	periods	ended	January	23,	2023	and	December	31,	2022	and	2021	
(expressed	in	US	dollars)	

9.		 RELATED	PARTY	TRANSACTIONS	

Related	party	transactions	are	in	the	normal	course	of	business	and	measured	at	fair	value.	

The	key	management	personnel	of	the	Company	are	the	directors	and	officers	of	the	Company.	Compensation	
awarded	to	officers	and	directors	for	the	periods	ended	below	are	as	follows:	

Salaries	and	consulting	fees	paid	to:

Officers	
Stock	based	compensation	(Note	6)
Directors	(for	administration	and	legal)	
services)

January	23,	
2023

$	

27,560	
4,729	
$																					Nil

December	31,	
2022

$	

49,929	
29,813	
$																			Nil

December	31,	
2021

$	

18,000	
Nil
$																			Nil

Included	in	accounts	payable	and	accrued	liabilities	is	$nil	(2022	-	$33,030)	due	to	related	parties	for	services	
performed	during	the	period.	Interest	is	not	charged	on	outstanding	balances	and	there	are	no	specified	terms	
of	repayment.

10.		INCOME	TAXES		

Reconciliation	of	effective	tax	rate

The	 provision	 for	 income	 tax	 differs	 from	 the	 amount	 that	 would	 have	 resulted	 by	 applying	 the	 combined	
Canadian	federal	and	British	Columbia	statutory	income	tax	rates	of	27%	(2022	-	27%		and	2021	-	27%).		

$	

Loss	before	income	taxes
Statutory	rates
Income	tax	recovery	at	statutory	rates
Expenses	not	tax	deductible
Foreign	exchange	on	tax	assets	and	liabilities
Under(over)	provided	in	prior	years
Unused	tax	losses	and	tax	offsets	not	recognized
Origination	and	reversal	of	temporary	differences 	
Income	tax	recovery

$	

Jan	23,
2023
(226,554)	
	27.00%	
(61,170)	
1,277	
-	
-	
59,677	
216	
-	

$	

Dec	31,
2022
(650,015)	
	27.00%	
(175,504)	
-	
-	
-	
40,394	
135,110	
-	

Dec	31,
2021
(280,353)	
	27.00%	
(75,696)	
-	
(2,675)	
2,432	
70,793	
5,146	
-	

21	|	P	a	g	e	

	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
VIRGINIA	ENERGY	RESOURCES	INC.		
Notes	to	the	Unaudited	Consolidated	Financial	Statements	
For	the	periods	ended	January	23,	2023	and	December	31,	2022	and	2021	
(expressed	in	US	dollars)	

10.		INCOME	TAXES	(continued)	

Unrecognized	deferred	tax	assets	

Deferred	income	tax	assets	have	not	been	recognized	in	respect	of	the	following	items:	

Non-capital	loss	carry	forwards
Capital	loss	carry	forwards
Net	deferred	income	tax	assets	

Jan	23,
2023
23,589,365	 $	

2,932,340	

26,521,705	 $	

Dec	31,
2022
23,357,283	
2,932,340	
26,289,623	

$	

$	

Dec	31,
2021
23,207,270	
2,950,382	
26,157,652	

$	

$	

The	 tax	 effected	 items	 that	 give	 rise	 to	 significant	 portions	 of	 the	 deferred	 income	 tax	 assets	 and	 deferred	
income	tax	liabilities	at	the	period-ends	are	presented	below:	

Deferred	income	tax	asset:
Non-capital	losses
Valuation	provision

Total	deferred	income	tax	asset

Deferred	income	tax	liabilities:
Exploration	and	evaluation	assets

Total	deferred	income	tax	liabilities
Net	deferred	income	tax	assets	

Non-capital	loss	carry	forward

Jan	23,
2023

Dec	31,
2022

Dec	31,
2021

7,464,058	 $	
(6,315,667)	 	
1,148,391	 $	

7,454,857	 $	
(6,306,466)	 	
1,148,391	 $	

7,279,376	
(6,265,962)	
1,013,414	

(1,148,391)	 $	
(1,148,391)	 $	
-	 $	

(1,148,391)	 $	
(1,148,391)	 $	
-	 $	

(1,013,414)	
(1,013,414)	
-	

$	

$	

$	
$	
$	

As	at	January	23,	2023,	the	Company	had	the	following	unrecognized	income	tax	attributes	to	carry	forward:	

Canada
United	States

Amounts

1,615,294	
21,974,071	
23,589,365	

$	

$	

Available	to
2034	–	2043
2027	–	2042

Deferred	tax	assets	have	not	been	recognized	in	respect	of	these	items	because	it	does	not	appear	probable	
that	future	taxable	profit	will	be	available	against	which	the	Company	can	realize	benefits	of	the	tax	benefits.		

22	|	P	a	g	e	

	
	
	
	
	
VIRGINIA	ENERGY	RESOURCES	INC.		
Notes	to	the	Unaudited	Consolidated	Financial	Statements	
For	the	periods	ended	January	23,	2023	and	December	31,	2022	and	2021	
(expressed	in	US	dollars)	

11.		SEGMENTED	DISCLOSURE	

The	Company	currently	operates	in	one	industry	segment,	being	mineral	exploration,	with	all	long-term	assets	
in	one	geographical	area,	being	the	United	States.	Timber	sales	and	other	income	is	derived	from	the	United	
States.	

12.		RECONCILIATION	TO	US	GAAP	

The	 Company’s	 unaudited	 consolidated	 financial	 statements	 are	 prepared	 in	 accordance	 with	 IFRS,	 which	
differ	 from	 those	 generally	 accepted	 in	 the	 United	 States	 (“US	 GAAP”).	 The	 significant	 differences,	 as	 they	
apply	to	the	Company,	and	their	effect	on	net	income	and	equity	are	shown	and	summarized	as	follows:

Note

January	23,	
2023	($)

For	the	periods	ended
December	31,	
2022	($)

December	31,	
2021	($)

Net	loss	per	IFRS

(226,554)	 	

(650,015)	 	

(280,353)	

Adjustments	to	match	US	GAAP
Foreign	exchange	loss
Net	loss	per	US	GAAP

Shareholder’s	equity	per	IFRS

Adjustments	to	match	US	GAAP

Accumulated	Other
Comprehensive	Income
Accumulated	Deficit

Shareholder’s	equity	per	US	GAAP

*

*
*

799 	
(225,755)	 	

(18,394)	 	
(668,409)	 	

5,320	
(275,033)	

4,382,826	

4,577,836	

4,032,818	

(120,711)	 	
120,711	
4,382,826	

(119,912)	 	
119,912	
4,577,836	

(138,308)	
138,308	
4,032,818	

* 	Under	US	GAAP,	the	parent	company’s	functional	currency	is	Canadian	dollars,	accordingly	gains	or	losses	
from	 the	 translation	 of	 an	 entity’s	 balances	 are	 recorded	 in	 other	 comprehensive	 income	 (a	 separate	
component	 of	 stockholder's	 equity).	 	 Under	 IFRS,	 the	 parent	 company’s	 functional	 currency	 is	 USD	 dollars,	
accordingly	these	gains	or	losses	are	recorded	in	earnings	or	loss.

13.		SUBSEQUENT	EVENT	

The	Company’s	shareholders	received	an	offer	to	purchase	their	shares	in	exchange	for	consideration	of	0.26	
of	one	common	share	of	Consolidated	Uranium	Inc.	per	Company	share.		Shareholders	voted	to	approve	the	
transaction	 at	 a	 Special	 General	 Meeting	 of	 shareholders	 on	 January	 19,	 2023.	 	 The	 Company	 became	 a	
subsidiary	of	Consolidated	Uranium	Inc.	on	January	24,	2023.

23	|	P	a	g	e