Solid Minerals Sector Audit Report for the Year Ended 31 st December, 2015 EXECUTIVE SUMMARY

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1 EXECUTIVE SUMMARY

2 ii P a g e Solid Minerals Sector Audit Report for the Year Ended 31 st December, 2015

3 Contents Reconciliation Approach and Methodology... Error! Bookmark not defined. Objectives of the Assignment... Error! Bookmark not defined. Data quality and assurance... Error! Bookmark not defined. Challenges to the Assignment... Error! Bookmark not defined. Declared Payments and Revenue by Companies and Government... 4 Unilateral Disclosures... 5 Solid Minerals Financial flows to the Federation... Error! Bookmark not defined. Exploration, Production and Export... 5 Exploration... 5 Production... 6 Quantity used or sold in 2014 and Solid Minerals Production by States (Quantity Used/Sold)... 7 Export... 8 Total contribution of Solid Minerals sector... 9 Solid Minerals contribution to Gross Domestic Product... 9 Solid Minerals contribution to Export Solid Minerals contribution to Employment Royalty Verification and Validation Summary of Findings and Recommendation... Error! Bookmark not defined. iii P a g e

4 ANAN ANFO ASC ASM ASMD BOF BPE C of O CAC CAMA CBN CGT CIT CITA CSR CU DFI DSC EDT EIA EITI FCT FGN FIRS FME FMITI FMO FMoF FOB GDP ICAN ICT IFAC IFRS ISA List of Acronyms Association of National Accountants of Nigeria Ammonium Nitrate Fuel Oil Ajaokuta Steel Company Artisanal and Small Scale Mining Artisanal and Small Scale Mining Department Budget Office of the Federation Bureau of Public Enterprises Certificate of Occupancy Corporate Affairs Commission Companies and Allied Matters Act Central Bank of Nigeria Capital Gain Tax Company Income Tax Company Income Tax Act Corporate Social Responsibilities Cadastre Unit Development Finance Institution Delta Steel Company Education Tax Environmental Impact Assessment Extractive Industry Transparency Initiative Federal Capital Territory Federal Government of Nigeria Federal Inland Revenue Service Federal Ministry of Environment Federal Ministry of Industry, Trade and Investment Federal Mines Officer Federal Ministry of Finance Free on Board Gross Domestic Product Institute of Chartered Accountants of Nigeria Information and Communication Technology International Federation of Accountants International Financial Reporting Standards International Standards on Auditing iv P a g e

5 ISRE International Standards on Review Engagements ISRS International Standards on Related Services LASEMA Lagos State Emergency Management Agency LGA Local Government Area MCO Mining Cadastre Office MDAs Ministries, Departments, and Agencies MID Mines Inspectorate Department ML Mining Lease MMA Minerals and Mining Act MMSD Mining Minerals and Sustainable Development MMSD Ministry of Mines and Steel Development MTEF Medium Term Expenditure Framework MTSS Medium Term Sector Strategy NASS National Assembly NBS National Bureau of Statistics NC Not Communicated NCP National Council on Privatisation NCS Nigeria Customs Service NEITI Nigeria Extractive Industries Transparency Initiative NESREA National Environmental Standards and Regulations Enforcement Agency NESS Nigerian Exports Supervision Scheme NGSA Nigeria Geological Survey Agency NIOMCO Nigeria Iron Ore and Mining Company NIPC Nigerian Investment Promotion Commission NIWA National Inland Waterways Authority NMC Nigerian Mining Company NSE Nigeria Stock Exchange NSDA National Steel Development Authority NSWG National Stakeholder Working Group OAGF Office of the Accountant General of the Federation PAYE Pay As You Earn PIS Project Implementation Schedule QCT Quality Control Team QL Quarry Lease RFP Request for Proposal RMAFC Revenue Mobilization, Allocation and Fiscal Commission RT Reporting Template SBIR State Board of Internal Revenue SMDF Solid Minerals Development Fund v P a g e

6 SMMRP SOE SSML TIN TOR VAT WHT Sustainable Management of Mineral Resources Project State Owned Enterprises Small Scale Mining Lease Tax Identification Number Terms of Reference Value Added Tax Withholding Tax vi P a g e

7 Executive Summary Introduction The reconciliation essentially entails Extractive Companies disclosing or reporting all payments for royalties, profit taxes, dividends, and other material industry related payments while Government Entities report what was collected from the Extractive Companies under each revenue head during the same year. In 2015, there were 481 extractive companies that were identified. To bring this number to a manageable number, a materiality threshold of 3, 000,000 Naira and above of Royalty paid was approved by the NSWG. The table below gives a global summary. Global Summary Absolute Figure % No of Extractive Companies 481 Total Industry Royalty (NGN) 1,267,106,025 Materiality threshold (NGN) 3,000,000 Companies that met threshold Companies below threshold Royalty paid by the 42 companies (NGN) 1,102,238, Royalty paid by companies below threshold (NGN) 164,867, Analysis of Royalty Paid by Companies In compliance with requirement 4.1(a) of the EITI 2016 Standards which requires the NSWG to deliberate and agree on the revenues to be reconciled, NSWG approved three million naira (N3million) and above on royalty payments for 2015 solid minerals sector audit. The rationale for using royalty as a basis for materiality threshold is that it is the only industry specific financial flow that is tied to actual operations in the absence of any defined fiscal regime for the sector S/N Threshold (NGN) Number of Companies Amount Paid (NGN) % Royalty 1 100M and above 3 637,424, M but less than 100M 1 67,580, M but less than 50M ,819, M but less than 10M ,414, Sub Total 42 1,102,238, Less than 3M (Others) ,867, Total 481 1,267,106, P a g e

Approach: Established the financial and non-financial flows of the extractive companies and the Government Entities responsible for revenue collection.

8 Report Framework The report outline is in line with 2016 EITI Standards. These include: Legal and institutional framework, including allocation of contracts and licenses Exploration and Production Revenue Collection Revenue Allocations Social and Economic Spending Approach: Established the financial and non-financial flows of the extractive companies and the Government Entities responsible for revenue collection. Preliminary analysis of the data Determination of the quantity of mined minerals, volumes of quarried stones and minerals exported. Methodology: Compare what the extractive companies disclose as their payments to the government and what the government disclosed as receipts. In the event of disagreement, we reported the differences. Differences, if material, were subjected to further investigation and reconciliation for the affected stream of flows. Tripartite reconciliation meetings were held between the Government Entities, Extractive Companies and the Independent Reconciler (with NEITI as observer) in Lagos, Port-Harcourt and Abuja to clear all observed differences during reconciliation and obtained signed off from the covered entities. 2 P a g e

9 Objectives of the Assignment a) To report on the quantities of minerals produced, utilized and exported and on the revenue flows amongst the Extractive Companies in the Solid Minerals sector of the economy. b) To undertake special verification work on certain classes of transactions and report on balances payable / receivable at the end of the audit period for certain financial flows. Scope of Work The scope of work is as detailed in the RFP issued by NEITI and in the main report of 2015 Solid Minerals Audit. Challenges to the Assignment The major challenge we encountered while carrying out this assignment were: Late submission of data Lack of cooperation in granting access as well as inadequate records keeping by some extractive companies. Difficulty in locating some of the companies Payments & Receipts: Initial Data before Reconciliation The figures below show material difference between the records from the extractive companies and government agencies before reconciliation. Payment Streams Declared Companies Payment (NGN) Declared Government Revenue (NGN) Differences (NGN) Difference % a b c = (b-a) FIRS 43,235,728, ,593,745, ,358,017, % MID 30,530, ,807, ,277, % MCO 830,449, ,045,779, ,329, % Total 44,096,708, ,747,331, ,650,623, % 2015 Payments and Receipts: Data After Reconciliation We carried out verification and validation and held tripartite reconciliation meetings. After which, the earlier huge difference of over 19.5bn was drastically reduced to about 2.8bn with FIRS being responsible for over 99% of this amount. The high figure of FIRS of above 99% of the total difference is due to the following reasons: Absence of adequate book keeping by some extractive companies Some companies kept their records offshore without copies of such records in the country (Mercury Mining Investment Limited) The position is as set out in the table below. 3 P a g e

10 Payment Streams Declared Companies Payment (NGN) Declared Government Revenue (NGN) Differences Difference after Reconciliation (%) (NGN) a b c = (b-a) FIRS 59,824,707, ,593,745, ,769,037, % MID 1,111,510, ,111,778, , % MCO 125,517, ,647, , % TOTAL 61,061,735, ,831,171, ,769,435, % Payments Declared by Companies and Receipts Declared by Government The table below shows the payments and receipts declared by companies and government respectively, including unilateral disclosures. Payment Streams Declared Companies Payment (NGN) Declared Government Revenue (NGN) a b FIRS 59,824,707, ,593,745, MID 1,111,510, ,111,778, MCO 125,517, ,647, Sub-Total (A) 61,061,735, ,831,171, Unilareral Disclosures Nigeria Custom Service 2,578, Federal Ministry of Environment 7,397, Artisanal and Small-Scale Mining Department 50, SBIR 4,546,659, LGA 92,537, Community/Landowners 83,353, Federal Ministry of Trade & Investment 4,308, MID (Royalty & fees below Threshold) ,222, MCO (Annual service fees and renewals) ,226, Sub-Total - Unilateral Disclosures (B) 4,736,884, ,448, Grand Total = (A+B) 65,798,620, ,463,619, P a g e

11 Unilateral Disclosures These are payments and Receipts below the materiality threshold of three Million Naira approved by NSWG. The disclosures represent payments made to SBIR, LGA, Community/landowners, Federal Ministry of Trade and Investment by companies and receipts by MID and MCO on behalf of government in respect of Royalty, annual service fees and renewals for extractive companies below the threshold. The payments and Receipts were aggregated but not reconciled. Exploration, Production and Export Exploration Following the renewed efforts by the Federal Government to reposition the solid minerals sector, key new developments in exploration and exploitation took place in Total of 1230 new licences were issued; the significant ones are as shown in the table below. New Development in exploration and exploitation of Solid Minerals in 2015 S/N TITLE TITLE HOLDERS MINERAL STATE LGA EFF DATE EXP DATE 1 EL Kekule Worldwide Limited Gold Niger Gurara 13/01/ /01/ EL Giant Cement Works Ltd Limestone Cross River Akamkpa 13/01/ /01/ EL Indo Nig. Mining Co. Ltd. Copper, Gold Zamfara Bukkuyum 13/01/ /01/ EL Goidel Resources Ltd. Niobium, Kano Doguwa 02/02/ /02/ EL BM Mining and Quarrying Ltd Gold Osun Obokun 02/02/ /02/ SSML Yabuda Dwara Nigeria Ltd Lead, Zinc Adamawa Ganye 10/11/ /11/ SSML Alfash Trade Links Gold Zamfara Maru 12/11/ /11/ SSML Chiata - AZ Fire Armour Ltd Lead, Zinc Benue Logo 12/11/ /11/ SSML Orison Plus Ltd Lead, Zinc Taraba Wukari 12/11/ /11/ SSML Xiamen Material Co. Nigeria Ltd Columbite Kwara Irepodu 12/11/ /11/ ML Owukpa Consolidated Mines Ltd. Coal Benue/Kogi Ogbadibo/Olamaboro 04/05/ /05/ ML Dangote Industries Limited coal clay Kogi Ankpa 20/05/ /05/ ML Dangote Industries Limited Limestone Ogun Ewekoro 26/05/ /05/ ML A.A.Y International Gold Niger Borgu 27/05/ /05/ ML Cement Company of Northern Nigeria PLC. Limestone Sokoto Wamako 16/04/ /04/2040 Source:MCO, P a g e

12 Production During the year, 2015, the total volume/quantity of actual production was 30,520, tons and the total volume/quantity used or sold was 39,272, tons in 2015 with a comparative figure of 47,087, in 2014 resulting in a percentage decrease of (16.60%) approximately. Solid Minerals Actual Production, 2015 S olid Minerals Production 2015 S/N Minerals Actual Production (Tons) Value of Actual Production (NGN) % of Total 1 Limestone 19,991, ,995,148, Granite 4,615, ,180,918, Dust 233, ,273, Laterite 1,476, ,285, Clay 1,195, ,786, Shale 535, ,356, Coal 121, ,632, Marl 663, ,869, Sand 1,612, ,671, Gypsum 34, ,793, Red-alluvium , Feldspar 13, ,095, Kaolin 25, ,624, Wolframite ,436, Columbite ,568, Tin ,133, Tantalite ,250, Total 30,520, ,860,968, Production used/sold and the relevant Royalty paid by Minerals Type S/N Minerals Total Quantity Used (Tons) Jan - April Total Quantity Used (Tons) May- Dec Market Price Market Value ( ) Ad Volorem (%) Royalty Paid ( ) 1 Granite 4,352, ,482,364, ,118, ,015, , ,022,855, ,142, Dust 1,906, ,441, ,122, ,109, ,582,321, ,116, Limestone 8,174, ,087,304, ,365, ,280, ,968,214, ,410, Laterite 509, ,746, ,637, ,868, ,121,292, ,064, Sand 398, ,439, ,971, ,609, ,287,548, ,377, Shale 211, ,331, ,116, , ,105, ,605, Red-alluvium , , , ,448, , Marl 98, ,744, , , ,160, ,408, Coal 39, , ,868, ,766, , , ,176, ,155, Clay 434, ,963, ,348, , ,300, ,865, Gypsum 12, , ,556, ,477, , , ,157, ,557, Feldspar 1, , ,061, , , , ,621, ,831, Kaolin 8, , ,803, , , , ,196, ,109, Wolframite , Columbite , ,888, , , ,200, ,236, Tin , ,406, ,962, , ,292, , Tantalite ,744, ,250, ,577, Total 16,148, ,123, ,558,200, ,267,007, ,272, Solid Minerals Production, 2015 by type 6 P a g e

13 Solid Minerals Production by States (Quantity Used/Sold) Set out below is the solid minerals total production by states, value of production and Royalty paid on quantity used/sold from each state. S/N State Total Production Used/Sold Value of Production Used/Sold Royalties on Qty Used/Sold % of Royalty 1 Ogun 13,754, ,359,493, ,688, Kogi 8,577, ,130,208, ,380, Cross River 3,120, ,159,688, ,393, FCT 2,212, ,097,923, ,929, Oyo 1,064, ,127,643, ,073, Gombe 1,190, ,049,074, ,166, Ebonyi 1,381, ,161, ,143, Delta 1,259, ,489, ,275, Edo 882, ,736, ,105, Ondo 542, ,054, ,247, Lagos 863, ,041, ,462, Sokoto 607, ,444, ,277, Abia 433, ,723, ,500, Benue 379, ,577, ,570, Akwa-Ibom 409, ,744, ,893, Nasarawa 278, ,031, ,858, Niger 365, ,040, ,311, Ekiti 130, ,824, ,201, Zamfara 146, ,439, ,132, Kaduna 265, ,370, ,129, Bauchi 54, ,551, ,939, Plateau 109, ,986, ,147, Anambra 133, ,497, ,246, Kano 173, ,896, ,967, Rivers 197, ,596, ,604, Kwara 99, ,384, ,395, Osun 102, ,608, ,257, Jigawa 152, ,398, ,196, Imo 82, ,542, ,110, Taraba 105, ,117, ,641, Katsina 59, ,448, ,210, Kebbi 21, ,595, ,720, Bayelsa 75, ,165, ,500, Adamawa 21, ,645, , Enugu 16, ,033, , Yobe 2, ,022, , Borno Total Solid Minerals Production (Quantity Used/Sold) by States 39,272, ,558,200, ,267,106, Quantity used or sold in 2015 and 2014 The table below shows comparative figures and percentage change of total quantity used in 2015 and that of 2014 S/N Minerals Total Quantity Used (Tons) 2015 Total Quantity Used (Tons) 2014 % Change 1 Granite 6,368, ,274, (52.03) 2 Limestone 21,454, ,652, (16.36) 3 Laterite 2,377, ,802, (37.46) 4 Sand 2,008, , Shale 1,075, , Red-alluvium 3, , (95.94) 7 Marl 595, , (11.63) 8 Coal 121, , (4.83) 9 Clay 1,178, ,750, (32.71) 10 Others 4,089, , , Total 39,272, ,087, (16.60) 7 P a g e

Export The value of exports of solid minerals in 2015 was 1,941,726,218.25 Naira (i.e,usd9,732,963.50 converted to Naira at 2015 CBN closing average rate of N199.5/$).

14 Export The value of exports of solid minerals in 2015 was 1,941,726, Naira (i.e,usd9,732, converted to Naira at 2015 CBN closing average rate of N199.5/$). We set out below a summary of the export for This is in compliance with Requirement 3.3 (Exports) of the EITI Standard Solid Minerals Export, 2015 S/N MINERALS GROSS WEIGHT (MT) NESS FEE ADMIN. FOB VALUE USD % of FOB Values 1 Lead 16, , ,749, Copper , , Zinc 3, , , Columbite , , Zircon 1, , , Manganese ore 1, , , Tin ores , , Total in (MT) 23, , ,610, Gold Ore and Concentrates (Ounces) , , Total 918, ,732, Solid Minerals Export based on FOB Value 8 P a g e

15 % Change of FOB Value in 2015 and that of 2014 value S/N MINERALS FOB VALUE USD 2015 FOB VALUE USD 2014 % CHANGE 1 Lead and Zinc ore 8,579, ,561, (63.59) 2 Copper 17, , (96.36) 3 Columbite 503, , (30.20) 4 Zircon 406, , Gold ores and concentrates 122, , (79.58) 6 Manganese ore 83, , Tin ores 20, , (26.47) 8 Crude Mica 245, (100.00) 9 Barite 113, (100.00) 10 Beryl Ore 67, (100.00) 11 Quartz Ore 45, (100.00) 12 Tantalite 20, (100.00) 13 Kaolin 11, (100.00) 14 Monozite Sand 9, (100.00) 15 Calcium Carbonate 6, (100.00) 16 Granite Block 5, (100.00) TOTAL 9,732, ,136, (62.76) Total contribution of Solid Minerals sector to the Economy The Solid mineral sector generated N69,200,504, in 2015 out of which Cement manufacturing is 60.20% of the total accruable to the sector or N41,657,334,683.86, Construction is 31.44% or N21,756,367, of the total while Mining and Quarry is 8.36% or N5,786,802, The table below highlights this position. Contribution by Sector Amount (NGN) % Cement Manufacturing 41,657,334, Construction 21,756,367, Mining & Quarrying 5,786,802, Total Solid Mineral Sector 69,200,504, Derived from: FIRS 62,593,745, MID 1,111,778, MCO 125,647, Unilateral Disclosure by reporting Companies 4,736,884, Unilateral Disclosure by Government Agencies 632,448, Total Solid Mineral Sector 69,200,504, Contribution of Solid Minerals Sector Solid Minerals contribution to Gross Domestic Product The total contribution to GDP from solid minerals in 2015 was N109, million giving a percentage contribution of 0.12% as shown below. 9 P a g e

sector contribution to employment by the 42 companies reconciled and the comparative figures for 2014.

16 By NBS Solid Minerals contribution to Export Solid Minerals accounted for about 1.45% of the total non-oil export SM Contribution to Export Source: Nigeria Custom Service Solid Minerals contribution to Employment The table below highlights solid minerals sector contribution to employment by the 42 companies reconciled and the comparative figures for Employment Statistics Within Materiality Threshold Category of Employees Absolute Change % Change Expatriate 1,842 1, National 4,445 5,047 (602) (12) Local 8,748 7,383 1, Total 15,035 13,758 1, P a g e

17 The increase of 9% in total employment is due to the increase in the number of companies that met the materiality threshold in 2015.de Revenue comparison A comparison of 2015 and 2014 revenue position is set out below. Payment Streams Absolute Change % Change (NGN Million) (NGN Million) (NGN Million) FIRS 62, , , MCO MID 1, , (118.22) (9.61) Reconciled Revenue 63, , , Unilateral Disclosure by reporting Companies 4, , (1,475.12) (23.75) Unilateral Disclosure by Government Agencies Total 69, , , Summary of Findings and Recommendations S/N FINDINGS RECOMMENDATIONS 1 Some companies do not render monthly returns of solid minerals production to MID 2 MID lumped together records of production for different solid minerals 3 State mines Officers are unable to independently verify the completeness, accuracy and validity of production details submitted by extractive companies because of funding challenges. More regular interactive sessions among stakeholders in the industry should be encouraged, emphasizing on global best practice in reporting, records keeping etc. More regular trainings and capacity building workshop should be organized for State Mine officers to better equip them for the discharge of their functions. The State Mines Officers and surveillance team of the MMSD should be more adequately equipped with financial and material resources to efficiently and effectively carry out their responsibilities. 11 P a g e

18 4 The Mineral Resources and Environmental Management Committees (MIREMCOs) at State levels responsible for monitoring and control of Solid Minerals sector are largely non existent or in a state of comatose 5 We noted the approval of 30 Billion Naira by the Federal Executive Council for the development of the solid minerals sector. 6 We observed that most of our minerals ores are exported without beneficiation. This is inimical to economic growth of the sector. 7 It was observed with grave concern the security challenges faced by field officers in the course of discharging their duties. 8 Exports figures reported by some companies were different from those declared by Government Agencies. For example, in year 2015, Coltan mineral resources and Astro mineral resources export data were not captured by NCS. 9 Some companies who featured in the export of solid minerals for 2015 were mainly those below materiality threshold and we were unable to confirm their permit to export solid minerals in line with extant laws Government should consider the revitalization of Mineral Resources and Environmental Management Committees (MIREMCOs) for the development of the Solid Minerals sector. Guided and timely release of funds to achieve its intended objectives. The disbursements of the fund should be accompanied with defaulters clause Federal government should provide enabling environment and encourage the private sector and some government agencies to establish beneficiation plants in the minerals corridors across the country. Private and Public Partnerships may also be encouraged Government should strengthen policing of the mines: particularly, encourage increased collaboration between the Nigerian Police and Nigerian Securities and Civil Defense Corps in providing security in mines. These two government agencies have responsibility to provides security in accordance to their enabling acts; NSCDC Act Section 5(d) (i) (iii) and Police Act Section 4 Part 2. There is need for a strong synergy between the relevant government agencies (MMSD, NCS and CBN) to ensure that all minerals exports including samples have export permit duly issued by MID. There is the need for a more coordinated effort by Government to increase the capacities of the various security/anti-corruption agencies to step the tide of illegal exportation of minerals. Quantity FOB should be used as basis for royalty payments on export of minerals For the purpose of recovery, government should review year 2015 export documents to ensure that royalty payments on solid minerals were adequately confirmed at export point. 12 P a g e

19 10 The activities of unlicensed miners were observed to be prevalent within the industry, leading to loss of government revenue. 11 It was observed with concern the negative impact of multiple taxation on the operational efficiency and growth of the solid minerals sector. For instance, States, Local and other government agencies collect various taxes and levies from operators e.g NIWA and LASEMA collect royalties from companies that are engaged in sand dredging. This hinders their profitability. In order to prevent further loss of revenue, government should encourage unlicensed miners to formalise their activities by obtaining licenses accordingly. In line with Chapter 2 particularly, Sections of the Nigerian Minerals and Mining Act, 2007, Government should also promote: a) Establishment of minerals buying centres to provide market access to small scale miners b) Formation of cooperative societies by artesian miners c) Access to funding and extension services by small scale miners d) Government should encourage big operators to collaborate with artisanal miners in the management of rich mineral deposit areas to maximize mining revenue in these areas A summit should be convened for all stakeholders to discuss and address these issues in line with the existing laws of the federation. a) Section 76 of Nigeria Minerals and Mining Act 2007 bars NIWA (or any other body for that matter) from collecting royalty; yet the provision is flaunted. An appeal court judgment Ref. CA/L/589/2008 dated 05/12/14 reinforced that only MID is legally entitled to collect royalty. Hence NIWA (or any other body) must not only stop collecting royalty but be made to account for the entire amount illegally collected over time. b) The government should make it mandatory for extractive companies to keep a separate account for mining/quarry activities in order to determine the profit or loss emanating from such activities and its contribution to the group account expecially constructions and cement companies. This will enable the tax authority to determine correctly the taxes payable by such mining company and such taxes will be mining specific. 13 P a g e

20 12 We observed that some expatriate companies do not keep their accounts within the country and also prepare their accounts in language other than English e.g Mercury mining investment. The company is owned by the Chinese and on Benin Ore road, Ofusu, Ondo State. The company had not been keeping its activities records and books in the company premises but in China. No evidence of Tax payment. Any company that does not keep its books and correct records in Nigeria and does not prepare its accounts in English language should be sanctioned accordingly by MID and investigated by FIRS for tax evasion. 14 P a g e

1 P a g e. Solid Minerals Sector Audit Report for the Year Ended 31 st December, 2015

1 P a g e. Solid Minerals Sector Audit Report for the Year Ended 31 st December, 2015 FULL REPORT 1 P a g e Solid Minerals Sector Audit Report for the Year Ended 31 st December, 2015 2 P a g e Solid Minerals Sector Audit Report for the Year Ended 31 st December, 2015 Contents List of Tables...