Publications

On August 27, 2026, Norway admitted the rules underpinning Nussir are being rewritten.September 8, 2026 – Norway's Environment Ministry admits it is delinquent in adopting the Water Framework Directive (WFD) in relation to the permitting of tailings in fjords, as amendments were postponed pending the Supreme Court’s judgment on Engebø. The consequence of the adoption of the WFD, in line with the Engebø judgment, will lead to the revocation – or substantial reduction – of Nussir’s ability to dump waste in the fjord, making Nussir financially unviable.Norway now admits its own permitting guidance is wrong – The Ministry has accepted two central passages need correcting to reflect the 2015 Weser deterioration test, but Nussir's January 2016 permit was decided using the outdated standard the Ministry itself now says was unclear.Blue Moon's own financing isn’t set in stone like management suggests – The $140m package announced in August 2025 remains largely non-binding and conditional; the company missed its own March 31, 2026 deadline for key facilities to become drawable, and has never disclosed whether that deadline was waived, extended or simply dropped.Every version of "fixing" the disposal plan still fails – Shrinking the dump, the disposal area, or the permit term doesn't avoid the legal exposure. All would require a fresh, defensible environmental assessment that Blue Moon has never disclosed, and Norway's letter provides no version of one.This has already happened next door – At Engebø, the same unresolved permitting question has already tipped Nordic Mining into distressed, bankruptcy-priced financing. Blue Moon is funding Nussir's construction with its hands over its eyes.

BMM’s CEO has been front-running an allegedly “approved” $30m Department of Defense investment in Springer to select analysts. Not only is this MNPI -- it would also be in breach of DoD contract terms.PLEASE READ IMPORTANT DISCLAIMER – PAGE 4September 4, 2026 – Subsequent to the publication of our report on BMM, Viceroy learned from multiple sources that BMM CEO, Christian Kargl-Simard, advised select analysts and investors that Springer was scheduled to receive a roughly $30m “approved” US federal grant to refurbish the Springer plant, citing a DoD "list of approved projects".This is exactly the type of reckless criminal behaviour we have come to expect from the cowboys running the BMM pump and dump. Outside of the obvious criminal element of disseminating MNPI to selected analysts:If Springer was “approved” for a $30m DoD contract, front-running this contract disclosure is a strict Defense Federal Acquisition Regulation Supplement (DFARS) breach, and grounds for withdrawal of any funding.If this story is false: then the dissemination of information regarding a false grant is grounds for debarment from future grants.Viceroy has received communications supporting this account and has now informed Canadian and US authorities.Letters to the OSC and the DoD are both attached. Letters to the SEC, DOJ and other federal oversight agencies have also been posted.

Management says the permit is optional and aggregate sales remain the plan. Have the brokers read Nussir’s own filings?September 3, 2026 - Blue Moon’s brokers circulated management’s response to our report without checking it against Nussir’s own application. Had they read the filing, they would have found that management’s account is not merely optimistic. It is a complete contradiction to what Nussir told the regulator in its own application.“THIS APPLICATION IS A MINOR PERMIT APPLICATION, THAT IS NOT MANDATORY… IF THE APPLICATION WERE DENIED, IT WOULD NOT PREVENT THE PROJECT FROM MOVING FORWARD OR AFFECT THE PROJECT TIMELINE.” THE BROKER ADDED THAT THE “PRIMARY PLAN” WAS TO SELL THE MATERIAL AS CONSTRUCTION AGGREGATE. (EXTRACT FROM BROKER COMMENTS SEPTEMBER 2, 2026)On 24 June 2026, Blue Moon told investors that Nussir's permitting framework was "complete" and that the project held "all material permits." 26 days later, on 20 July, Nussir ASA quietly applied for a permit it now admits, in its own words, "is not specifically covered by the current waste management plan." Management knows exactly how that looks, which is why brokers are now telling investors the opposite.

September 1, 2026 – Blue Moon declared Nussir's permitting "complete" in June. In July, Nussir applied for a further landfill permit which, by its own admission, no existing permit covered. In August, the Sami Parliament used that application to demand the state reassess the mine's discharge permit, arguing its approvals violate Norwegian and international law and were granted without the legally required consultation.We reiterate that the basis for Nussir's dumping permits has been invalidated by Norway's Supreme Court. We maintain that Nussir will face the same repercussions as Engebø: the court found an almost identical fjord dumping permit invalid, a defect that "cannot be repaired retrospectively", and the ESA has already concluded Norway acted unlawfully both "by authorising" and "by maintaining in force" the Nussir permit. Applying the NEA's own Engebø standard to Repparfjorden requires disposal cuts of 79-95%. The mine does not work at those volumes, and management knows it.This landfill application changes none of that. It is a sideshow to the main event, and we highlight it for what it reveals: a management team that declared permitting "complete" four weeks before its own subsidiary filed for a permit it admits nothing else covers, and that has still told the market nothing about it. Blue Moon's management does not run a mining company. It runs a promotion, and the paperwork keeps proving it.

Four decades of failed restarts meet a valuation built on fantasy tungsten prices, just as cheaper competing supply comes online.August 27, 2026 – Blue Moon continues to champion Springer as its saving grace. But its valuation, restart timeline, and “strategic US supply” status crumbles under the slightest scrutiny; built on a price with no basis in forecast, against a field of better-funded, better-resourced, and faster-moving competitors.The tungsten price Scotia relies on will trigger new competition: S&P's $360–480/mtu structural cost estimate is the level at which over 85% of ex-China tungsten projects become profitable to build. Springer needs roughly $1,100/mtu just to break even - nearly three times higher than the price its rivals’ studies assume.The race has already begun. South Korea's Sangdong and the UK's Hemerdon mines both began production in July 2026. S&P has identified another 11 ex-China projects that could add nearly 20 kt of new capacity by 2030, with a further ~20 kt stalled only on financing or permitting.Springer’s Q4 2027 start date coincides directly with this window, meaning Blue Moon is investing at the top of the price cycle and asking shareholders to wait for a return until after its rivals have already undercut the price.Springer's history contradicts the “brownfield advantage” story. Since the late 1900s, Springer has sat mostly idle, shuttered, or being prepared for a short-lived restart, some of which never came to fruition.Every study ever done on Springer contradicts its current valuation. Its only published economic study, the 2012 PEA, used $400/mtu and produced just $22.8m of NPV. Applying that same price to Scotia's own model produces a negative $267m NPV. Even Scotia's own long-term price assumption turns the valuation negative if applied from inception.Scotia's $348.7m Springer valuation (39% of Blue Moon's total NAV) rests on a tungsten price of $2,200/mtu held for seven straight years. This is a figure the model doesn't source, and no comparable project has ever used it. No peer study (Sangdong, Hemerdon, Mt Carbine, Sisson, or Springer's own 2012 PEA) has ever been priced above $450/mtu.In an inflated climate, almost any tungsten mine can be transformed from a turd into a lump of gold. The problem starts when rival mines built on that same price signal actually turn up. Springer has spent four decades proving that a restart story is not the same thing as a durable mine.

On August 28, 2026, Viceory sought information concerning BMM's Nussir project from the Ministry of Climate and Environment & the National Environmental Agency in Norway under the Freedom of Information Act and Environmental Information Act.Our requests seeks the following records:Every submission, meeting record and calendar entry between Norwegian authorities and Blue Moon, Nussir ASA, or their advisers, including any lobbying after the Supreme Court judgment.Norway's formal approval of Nussir's "Strategic Project" designation under the EU Critical Raw Materials Act. This a document that must exist, that no one has seen, and that committed the government to the project's feasibility eleven months before its dumping permit's legal basis collapsed.All correspondence with the European Commission and the EFTA Surveillance Authority concerning Nussir, the CRMA, and the Water Framework Directive.The Ministry's internal, "not yet completed" assessment of the judgment, including whether it exists at all.Records of the legally required consultations with the Sámi Parliament and reindeer-herding districts before the permit amendments Blue Moon announced seven days after the judgment, or confirmation that none took place.The full decision basis for those June 2026 approvals, including how the objections of Norway's own Institute of Marine Research were handled.Norwegian law grants a separate, stronger right of access to environmental information. We will publish what we receive.

August 24, 2025 - Viceroy wrote the the EU Commission to reassess the status of Nussir as a Strategic CRMA Project, on the grounds that recent developments raise serious doubts as to whether the project still meets Article 6(1) of Regulation (EU) 2024/1252.We requested that the Commission:confirm its awareness of ESA's 23 April 2026 Letter of Formal Notice; and advise whether Article 6(1) conditions are met considering our supporting evidence.We note that under Article 7(11) of Regulation (EU) 2024/1252, the Commission "may... withdraw the recognition of a project as a Strategic Project" where it "finds that a Strategic Project no longer fulfils the criteria laid down in Article 6(1) or, where its recognition was based on an application containing information that is incorrect to the extent that it affects its compliance with the criteria laid down in Article 6(1).”

The NEA’s temporary permit recommendation is grounded in a enormous reduction in Engebø’s disposal quantity and offers no route back to full operational capacity.August 20, 2026 – Yesterday afternoon, the Norwegian Environment Agency (NEA) published its professional assessment recommending that Nordic Mining’s Engebø project be granted a temporary permit to continue dumping tailings into Førdefjorden.The basis of that recommendation relies on an extreme reduction in tailings disposal by Engebø, which would allow the fjord to retain its “good” environmental assessment rating, and avoid the need to prove a “overriding public interest” exemption to deteriorate the fjord. An application of the same calculation standard to Nussir would require disposal in Reppafjord to be cut by 79-95%. The project is dead in the water.Nussir, and Norway’s Environment Minister Andreas Bjelland Eriksen, know that they cannot rely on the Critical Raw Minerals Act (CRMA) to prove overriding public interest. CRMA Article 10 explicitly states that strategic projects “may be considered to have an overriding public interest provided that the conditions set out in [the Water Framework Directive] are fulfilled”. The Water Framework Directive (WFD), which forms the basis for EFTA Surveillance Authority’s (ESA) intention to seek Nussir’s permit revocation, is a priority for the EU over critical minerals.In April 2026, Norway’s Ministry of Climate and Environment answered an EU consultation on reforming the WFD with a remarkable admission: "the [Water Framework] Directive effectively establishes an absolute limit, prohibiting projects that may degrade a water body below good status due to pollution", and even projects with the EU's own strategic-project stamp "might still not be approved under the WFD."Unlike with Engebø, the NEA is legally bound to enter consultation with the Sámi community in relation to any permitting issues because of the 2021 Fosen ruling (HR-2021-1975-S). The NEA will not be able to rush a “temporary permit” recommendation with a short-window consultation during Norwegian public holidays, rejection of applications for extensions, and the “suck it and see” mentality with regards to environmental surveillance.Our analysis shows a temporary permit would leave Engebø surviving on life support. Replicating that at Repparfjorden leaves Nussir with two tragic options: shrivel far enough to escape the legal test, at which point the mine's value falls into deep negatives, or continue burning cash while it meets its inevitable fate.While it is not our primary focus: this report also address some of the NEA’s garbage reasoning on granting even a “temporary” permit to Engebø: a mine that produces no critical minerals, has faced astounding municipal and political opposition, and is so severely unprofitable that the Norwegian government may be left with the cleaning bill.

On 18 August, 2026, Viceroy requested that the OSC investigate whether:Blue Moon's April 2026 Prospectus Supplement omitted a material fact;the prospectus contained a misrepresentation within the meaning of applicable securities legislation;the issuer, its officers and directors complied with section 56(1) of the Ontario Securities Act;the underwriting syndicate discharged its due diligence obligations; andinvestors who participated in the C$156m financing possess statutory rescission or damages rights under Part XXIII.Letter attached.

August 13, 2026 – Earlier today, Blue Moon Metals CEO Christian Kargl-Simard hosted a cozy fireside chat with brokers where he dismissed our work. Given the context of that discussion, we anticipate Blue Moon’s response to our report will be poor.Kargl-Simard refuses to acknowledge the established fact that the EFTA Surveillance Authority (ESA) has issued a Formal Notice for the revocation of Nussir’s PCA permit.He then explicitly states that the Supreme Court's judgment applied only to Engebø, and had no bearing on Nussir. We reiterate that this case, pursued by the EU, was against the State of Norway for issuing the permits.Not only did the court find that the permits were invalid – they also stated they “cannot... be repaired retrospectively”.Kargl-Simard then reminded brokers that Nussir is a designated Strategic Project under the EU Critical Raw Materials Act (CRMA).After receiving its designation: Nussir obtained an offtake agreement with Hartree for effectively all of the mine’s output.Hartree has just signed up as a “leading participant” in the landmark EXIM-funded ‘Project Vault’ deal and reiterated a “long standing commitment to supporting American industrial end-users and manufacturers”. This explicitly disqualifies Nussir from retaining its designated Strategic Project status under CRMA upon reassessment, which is due prior to the commercialization of the mine.Kargl-Simard also takes issue with our analysis of Springer and Apex. We reiterate that our assessment of the Springer feasibility was derived from “management best estimates” provided to the sell-side, and simply corrected for objective errors.Lastly: brokers note that Blue Moon is planning various news-flow items for Springer and Apex over the next few months. This, we could have guessed.Today’s report provides greater detail into our conviction and rebuts CEO Kargl-Simard’s poor response.

August 12, 2026 – Blue Moon Metals (TSXV : MOON) is a critical-minerals fairy tale built on a Norwegian copper project and two idle American mines bought for scrap value. Our investigation suggests Blue Moon’s Norwegian flagship cannot be lawfully mined, its American assets values are wildly overstated, and management systematically concealed adverse findings. BMM’s only real business is shameless self-promotion.Viceroy is short Blue Moon Metals. In our view, it is an ideal short: a company centered around a hastily acquired pipe dream, haphazardly held together by a flimsy permit on the brink of folding, and promoted to Canadian retail investors via paid stock promoters who almost exclusively represent shit businesses.PLEASE READ IMPORTANT DISCLAIMER

June 30, 2026 – On June 26, 2026, Abaxx Management held an analyst call with ATB. Management continued to contradict themselves, and unleashed their promotional ‘non-operational’ weapon, Jeff Currie, to prime the pump. Amongst other things: Abaxx appear to have announced that Open Interest is incentivized! Yes, we had given them credit for this, but appears we were too generous.This report outlines contradictions by management when investor calls are managed by a friendly host.