Legal Disclaimer
1. Nature of the platform
Blood Niobium is an independent intelligence platform dedicated to documenting and translating hidden legal, accounting, regulatory and humanitarian liabilities in critical minerals supply chains. It is not an NGO, not a media outlet, not a law firm.
The platform operates as a transnational accountability documentary protocol: it organises evidence with traceable primary sources, translates risks into the language of 9 stakeholder profiles, and structures notification chains for actors who have been able to benefit from the distance between the origin of the conflict and international decision-making centres.
2. Methodology and documentary admissibility
All Blood Niobium content follows the 5-Layer Methodology, organised by the 3-Tier Documentary Admissibility System:
- Layer 1 — Documentary Fact (Tier 01 · Open): Every claim is based on a verifiable document with a traceable primary source: TJ-GO court filings, CMOC Group Limited financial statements (HKEX: 3993, 2016–Q1/2026), death certificates of 6 deceased heirs, official ESG certifications and published international standards.
- Layer 2 — Standard Analysis (Tier 02 · Verified): Violations are analysed against applicable international standards with express citation of the relevant provision: IAS 37, IAS 36, ISA 540, HKEX 13.09, CSDDD, LkSG, UFLPA, UNGPs, IFRS 3.
- Layer 3 — Risk Quantification: Unprovisioned contingent liability may range from US$ 66 million (conservative) to US$ 3.5 billion (expanded estimate). Both figures are technical references and must be confirmed by competent experts.
- Layer 4 — Profile Translation (Tier 03 · Counsel-grade): Findings are rewritten in actionable language for 9 stakeholder profiles: shareholders/investors, independent auditors, market regulators, ESG certification bodies, supply chain customers, Government of Brazil, Government of China, Government of the USA, press/NGOs.
- Layer 5 — Confirmation by Investigators: All identified violations and risks are presented as potential findings and must, without exception, be confirmed by competent experts.
3. What statements are — and what they are not
4. Referenced international standards
| Standard | Scope | Potential risk identified |
|---|---|---|
| IAS 37 | Provisions and contingent liabilities (IFRS) | Zero provisioning for active litigation of up to US$ 3.5 bn |
| IAS 36 | Impairment of assets | Impairment test not recognised on 2016 acquisition goodwill |
| ISA 540 / ISA 501 | Audit of estimates / evidence | Adequacy of audit evidence on active litigation |
| HKEX 13.09 / Appendix 16 | Disclosure of material inside information | Omission in 10 annual reports (2016–2025) |
| CSDDD / LkSG | Human rights due diligence (EU/Germany) | Absence of HRIA; affected supply chain |
| UFLPA | Forced labour — US imports | Niobium eligibility for regulatory review |
| UNGPs | UN Guiding Principles on Business and Human Rights | Absence of documented remediation and HRIA |
| Art. 1,216 / 884 BCC | Restitution of proceeds and unjust enrichment | Basis for estimated contingent liability |
5. Responsibility for sending notifications
The platform provides pre-written texts for Canal 06 — Strategic Notifications by Profile, directed to regulators, auditors, ESG certifiers, shareholders, governments and press across multiple jurisdictions. By using these texts, the user acts at their own risk. Blood Niobium:
- Does not control, monitor or bear responsibility for the sending, destination or consequences of notifications;
- Does not establish any relationship of representation, mandate or legal sponsorship with the sender;
- Does not guarantee that addresses, portals and channels indicated are current;
- Is not liable for misinterpretations of the pre-written content.
6. Legal protection of the platform
- Brazilian Constitution, art. 5, IV and IX: Freedom of expression and intellectual, artistic, scientific and communication freedom;
- Brazilian Constitution, art. 5, XIV: Right of access to information;
- Art. 19 UDHR: Freedom of opinion and expression;
- UNGPs — Principle 3(a): State duty to protect human rights defenders;
- Johannesburg Principles on National Security, Freedom of Expression and Access to Information;
- IFJ Global Charter of Ethics for Journalists.
7. Operational limitations — independence statement
Glória Duarte, responsible for the platform and an active party in the litigation against CMOC Brasil Ltda., operates under procedural constraints arising from her position as a litigant. Blood Niobium was structured to function with editorial and documentary independence, regardless of the progress of the judicial proceedings.
The platform is financially independent. It does not receive funding from CMOC, its competitors, investment funds, governments or entities with a direct interest in the litigation. The dossier is maintained with the personal resources of Glória Duarte and the contributing team.
8. Accuracy and updates
Blood Niobium makes continuous efforts to ensure accuracy and currency of all data. Financial and procedural data are subject to change. The current version is published at bloodniobium.org on the date of access. The Right of Reply space remains permanently open to all parties cited.
9. Contact
Responsible party: Glória Duarte · Blood Niobium · Catalão, Goiás, Brazil.