Aon is a global insurance brokerage and professional services firm with approximately 50,000 employees across 120 countries that offers a wide array of risk mitigation products and structured solutions.  Aon’s Litigation Risk Group focuses on de-risking adverse outcomes in active and potential future litigation for corporate, private equity, hedge fund, law firm, and litigation finance clients through the use of insurance. Aon has spearheaded the rapid development of this insurance market over the past five years with pioneering solutions like judgment preservation insurance, insurance-backed judgment monetization, and portfolio-based “principal protection” coverage for funders and plaintiff-side law firms.  Aon’s Litigation Risk Group is the dominant market leader in the litigation and contingent risk space, having placed nearly $5 billion in total limits over just the last several years, including over $1 billion in limits in 2023 alone. Website:  https://www.aon.com/m-and-a-transaction/transactionsolutions/litigationsolutions.jsp Founded:  1982 HQ:  London (Global) and Chicago (US), with Aon’s Litigation Risk Group being based in New York About Aon’s Litigation Risk Group: Aon’s Litigation Risk Group works with a wide variety of clients across all industries and sectors of the economy, but the fastest-growing appetite for insurance solutions by far comes from litigation funders and other similar investors in litigation-related assets. Aon helps these clients protect their downside in litigation-related investments in many different circumstances, whether protecting a judgment they have obtained in a case in which they invested at inception, wrapping a loan they are making to a plaintiff-side law firm with principal protection insurance, or insuring an entire portfolio of uncorrelated investments in cases at different stages of the litigation lifecycle. Aon has fostered strong partnerships with dozens of insurance markets to bring our clients the most creative bespoke insurance solutions for the most complex litigation-related risks on the best possible coverage terms.  As the Director of Underwriting for a well-established litigation funder on whose behalf Aon has placed over $70 million in limits across a number of different investments put it:  “We have worked with the Aon’s Litigation Risk Group on a number of insurance policies over the years, and I can say unequivocally that they are second to none.  Besides being fantastic to work with, the team was also able to leverage their litigation know-how and strong relationships with insurers to obtain favorable terms for each of our policies.  Even when we had to file a claim on a policy, they jumped on it right away, handling it quickly and professionally without any need to involve a separate claims team.  We have been very happy with our partnership.”  Points of Differentiation: Innovation – Aon is a leader in terms of pushing the limits of what litigation and contingent risk insurance policies can do.  While this area of the insurance industry got its start on the defense side in the context of M&A transactions, where what is now refered to as “adverse judgment insurance” or “AJI” was used to ring-fence litigation risks that were getting in the way of an acquisition, they were the first to place insurance on plaintiff-side judgments, which led to Aon coining the term “judgment preservation insurance” or “JPI,” which is now used industry-wide and beyond. Aon was also the first to have the insight that once a judgment is insured, so long as the defendant is sufficiently creditworthy, the combination of “judgment plus JPI policy” can serve as collateral for a loan that can be made on more attractive terms than would be available without insurance.  Aon was among the first broker in the insurance industry to facilitate loans against this combination of “judgment plus insurance,” a solution they named “insurance-backed judgment monetization,” and which has now also become widespread and provided a significant boost to the broader litigation and contingent risk insurance industry.  Their team prides itself on finding new and unique uses for insurance to help our clients achieve their goals, and excels at using insurance capital to solve complex litigation-related issues. Pre-Underwriting­ – Aon’s team of former litigators has earned a reputation for submitting to insurers only the highest quality risks, after thoroughly analyzing their merits before submission to insurers. As one of the leading insurers in the litigation and contingent risk insurance space, Ambridge Partners, put it:  “We’re always happy to receive contingent risk submissions from the Aon team.  The deals are always pre-vetted and well-presented, and it’s clear that they’ve asked themselves ‘What would I want to see as an underwriter?’ – and then provide exactly that.  It makes Aon’s deals very attractive easy for us to consider.” And per Alston & Bird litigation partner Steve Penaro, “As outside counsel working with underwriters in the contingent risk space, when we see a contingent risk submission from Aon, we immediately know that is has been thoroughly vetted and the issues meticulously scrutinized.  And, once the underwriting process begins, Aon actively partners with us to ensure all relevant information is readily available and all questions have been answered allowing for a smooth close.  From the initial submission to the binding of the policy, Aon is there every step of the way.”  Given the explosive growth in this space, Aon values their underwriters’ scarce time, and enjoys a competitive advantage knowing that underwriters move Aon submissions to the top of their piles. Relationships with Insurers – Aon is not only a market leader in terms of litigation and contingent risk insurance, but also other lines of insurance written by the same carriers such as representations and warranties and tax insurance. As one lawyer we have worked with on policies for two different clients put it: “The Aon team did a magnificent job in placing adverse judgment insurance for one of my clients and judgment protection insurance for another.  They have deep contacts with the insurance market, and it was apparent to me that insurers trust their expertise and judgment.  I have not hesitated to recommend them to other attorneys.” Given the volume of business that Aon does in the broader transaction solutions insurance market, they maintain deep relationships with insurers, and that benefits their clients by helping them deliver the best possible coverage terms, pricing, and claims service. Key Metrics: Aon's Litigation Risk Group has placed billions of dollars in limits on litigation and contingent risks in the last several years, including ten separate insurance programs that each provided more than $100 million in coverage limits and four that provided at least $500 million in coverage limits. The policies placed by Aon have arisen in a variety of procedural contexts and run the gamut in terms of subject matter and types of claims – commercial litigation, breach of contract, patent infringement, trade secret misappropriation, and antitrust, just to name a few.  Aon has placed adverse judgment insurance on the defense side and judgment preservation insurance on the plaintiff side, including pre-trial, pre-judgment insurance for litigation funders to protect the value created by important evidentiary rulings that were the subject of interlocutory appeals. Aon has also placed principal protection insurance on several hundred million dollars that have been invested into early stage, pre-complaint patent litigations across multiple unique patent families. They have procured insurance for defendants who have lost significant damages verdicts at trial against the risk that an appellate court will not reverse, and have insured against adverse outcomes related to regulatory processes.  Put simply, as long as their team has access to sufficient underwritable information about the litigation risk to be insured, there are few limits on the kinds of cases or procedural postures that Aon can insure. Jurisdictions and Sectors Served: Aon’s Litigation Risk Group has insurance broking teams not only in the United States, but also in the United Kingdom (which can insure risks across much of EMEA), Bermuda, and Southeast Asia, which enables them to deliver to our clients truly global solutions across myriad jurisdictions. While the core of Aon's business remains insuring the outcome of judicial proceedings in the United States, they understand where to go to find appetite to insure litigation in other domestic courts, as well as insuring the outcome of international arbitration proceedings.  Key Stakeholders: Stephen Davidson is a Managing Director and both the Head of Aon’s Litigation Risk Group and Head of Claims for Aon’s broader Transaction Solutions team.  As Head of the LRG, Stephen works with clients and insurance markets on the development of litigation and contingent risk insurance.  As Head of Claims, Stephen manages transaction liability claims – which includes not only litigation and contingent risk insurance claims but also representation and warranty and tax insurance claims – and has overseen and helped negotiate the favorable resolution of hundreds of such claims in North America and around the world.  Prior to joining Aon in 2016, Stephen was a commercial litigation partner in DLA Piper’s New York office, and he began his career at Schulte Roth & Zabel LLP, where he worked as a litigation associate for several years. Stephen Kyriacou is a Managing Director and Senior Lawyer in Aon’s Litigation Risk Group, and was the first insurance industry hire dedicated solely to the litigation and contingent risk insurance market, which he has been working to develop and grow since 2019.  Stephen has twice received the designation of “Power Broker” from Risk & Insurance Magazine (in 2022 and 2023), which called him “a pioneer in judgment preservation insurance,” and is the only litigation and contingent risk insurance broker to have been so recognized.  While Stephen places insurance across all of Aon’s solution lines, he specializes in single-case judgment preservation insurance and adverse judgment insurance placements.  Prior to joining Aon, Stephen spent close to a decade as a complex commercial litigator at Boies, Schiller & Flexner, where he amassed significant trial, appellate, and arbitration experience representing both plaintiffs and defendants in the U.S. and abroad across a wide array of practice areas, and clerked in the U.S. District Court for the District of Columbia. Ed Conlon is a Managing Director in Aon’s Litigation Risk Group, and is the team’s resident insurance industry veteran, having been in the industry for over 15 years and having placed litigation and contingent risk insurance since 2015, when the market for such insurance was still in its embryonic stages.  While Ed brokes across all of Aon’s litigation and contingent insurance lines, he focuses primarily on developing cutting edge bespoke portfolio-based coverage structures for law firms, litigation funders, and other investors in litigation.  Ed also leverages his deep, battle-tested relationships across the broader insurance industry to bring new carriers into the growing litigation and contingent risk insurance market and to maximize limits and optimize coverage terms on Aon policies.  Prior to his current role, Ed led Aon’s Financial Institutions Group and, before that, was a complex commercial litigator and ran a complex commercial claims desk at AIG. David Hodges is a Vice President and joined Aon’s Litigation Risk Group in 2021.   David brokes across all of Aon’s litigation and contingent insurance lines, and focuses primarily on single-case judgment preservation and adverse judgment insurance placements.  Prior to joining Aon, David was a complex commercial litigator at Boies, Schiller & Flexner and Lankler Siffert & Wohl, and was also a law clerk for federal judges on the Second Circuit and D.C. District Court. Bill Baker is a Managing Director in Aon’s Litigation Risk Group and joined the team in early 2020.  Bill leads the team’s work on structured solutions, including loans that are collateralized by judgment preservation insurance policies and other financing solutions that are customized to meet the unique capital needs of our clients.  Prior to joining Aon, Bill was an investment banker at various firms throughout a 15-year career, after which time he worked in private equity and corporate roles, including strategy, corporate development, and investor relations. Mike Kenny is a Director in Aon’s Litigation Risk Group and joined the team in 2021.  Mike is responsible for the team’s structured finance solutions, including premium finance and judgment monetization.  Mike works with clients to structure bespoke credit transactions, allowing them to leverage the combination of their judgments and insurance to access the capital markets and obtain liquidity.  Mike uses his industry relationships and a broad network of investors to help clients find the best deal terms and structure for their specific needs.  Mike is also a licensed investment banker with Aon Securities.  Prior to joining Aon, Mike was an investment banker at BTIG, where he focused on M&A, public and private financing, and strategic advisory for software industry clients.  

Jamie is a Naval Academy graduate with a Johns Hopkins’ Masters in Finance. He served on a ground combat tour in Iraq, on hazardous duty in the Arabian Gulf and at the Pentagon managing an $800 million tech fund before entering the civilian sector as the CFO of a multi-million-dollar startup. He later became the COO of a 1,000-employee company owned by a NYSE listed entity. Allen then transitioned to the litigation finance sector in 2021 with the founding of Allen & Calabro. Below is our LFJ Conversation with Jamie Allen: I understand you made the transition from service member to litigation finance investor. What drove you to make this transition, and what about litigation finance has surprised you the most?  Following graduation from the US Naval Academy, I spent nearly eight years on active duty in assignments around the world.  After my service, I attended Johns Hopkins for business school (finance) and began consulting for “David like” plaintiffs in disputes stemming from the crisis of 2008.   During my own experience as an entrepreneur and an executive of a NYSE listed entity, litigation and funding thereof became my focus.  After successes with investments in probate, employment, and RICO claims, it made sense to make the transition to a full-time investor and to operate a fund, as I had managed an $800 million tech portfolio while serving at the Pentagon.  Additionally, my dad, a Navy Veteran, lawyer and seasoned entrepreneur, and J. Toji Calabro, Esq., a coast-to-coast litigator, were available to join as my co-founders.  Together, we are “business, litigation and finance,” the three staples of commercial litigation finance. The thing that has been the most surprising is the amount of open space for investments with smaller contingency based, plaintiff counsel.  Many such offices are unfamiliar with litigation finance for commercial disputes. What types of cases does Allen Calabro invest in, and what differentiates you from other funders in the market? We focus on whether the claim is meritorious first and foremost.  After that, we like small to medium investments where a small business owner or entrepreneur is out of business—or their only assets are the legal claims against the wrongdoer.  We have been in those shoes and came out successfully—and want to help our clients do the same. How does your past military and business experience inform your partnerships with your clients? The military helped me learn how to listen to varying ideas--getting along with others that may not share the same viewpoints or opinions and those with diverse backgrounds.  Listening to our clients and understanding their challenges when their backs are against the wall—enabling them with the resources to carry out the battle plan to defeat Goliath and sharing how to adapt and overcome. What are the key questions / concerns that clients ask when considering a funding partnership, and how do you allay those concerns? Clients want to know their rights and responsibilities. The amount and timing of our investment are of keen interest. We review and discuss the proposed budget explaining our risk analysis that includes the complexity of the case, defenses, the defendant’s ability to pay and an estimate of the duration of the investment among other things. The generally non-recourse nature of our investment and our willingness to provide advice from our experiences, if requested, allay many concerns. Our clients know we’ve been in “their shoes” and through our empathy and emotional support they identify with us. What are some interesting trends we should be aware of in the litigation funding space?  How do you see this sector evolving over the coming years? The trends we see are more ominous than interesting. First, there are seemingly more and more defendants that disregard the “rule of law.”  They commit clear wrongs with the knowledge that the wronged party has little ability to pursue the claim and/or “remain in the fight” as they unnecessarily prolong and add expenses to the proceedings. Second, as smaller law firms and sole practitioners become more comfortable with commercial litigation funding, we see an improvement in civil justice.  Unfortunately, we also see the potential for an economic downturn like 2008.  That will increase the demand for commercial litigation funding, and we will be there to help our “Davids.”

Montauk Metals Inc. (TSX-V: MTK) (the “Company” or “Montauk”) is pleased to announce that it has secured litigation funding for its arbitration proceedings (the “Arbitration”) brought by the Company against the Republic of Colombia (“Colombia”) to enforce the Company’s rights to compensation under the Canada-Colombia Free Trade Agreement (the “FTA”), as previously described in its news releases of March 27, 2018, February 25, 2019, February 10, 2020, November 23, 2021, September 1, 2023 and October 5, 2023, and subject to certain conditions and approvals as noted below. Background of the Claim Montauk contends that Colombia breached its obligations owed to the Company, including specific obligations under the FTA. The claims include Colombia’s refusal or failure to compensate the Company for the losses incurred as a consequence of Colombia’s prohibition of mining in the páramos (high altitude eco-systems). On March 21, 2018, Montauk filed a Request for Arbitration against the Republic of Colombia before the International Centre for Settlement of Investment Disputes (“ICSID”). The Arbitration is being conducted in two phases. Phase One will determine whether the ICSID Tribunal adjudicating Montauk’s claims (the “Tribunal”) under the FTA has jurisdiction over this case and whether Colombia has breached its obligations under the FTA and is liable for compensation to the Company. Assuming that ICSID decides in favour of Montauk in Phase 1 (the “Phase 1 Decision”), Phase 2 will involve determining the quantum of damages awarded to Montauk to compensate it for losses incurred. The Company estimates it has suffered more than USD $16 million in sunk costs and total loss of the value of up to USD $180 million in the Reina de Oro project, as well as legal and arbitration fees. Typically, an arbitral award will include an award of costs payable by the unsuccessful party to the successful party to reimburse it for its legal and arbitration fees. Certain costs of the proceedings, including arbitration fees and disbursements, have exceeded the Company’s original estimates as the Company was also required to pay Colombia’s 50% share of the arbitration fees. The Company must make an additional payment of US$200,000 to ICSID (the “ICSID Payment”) before a ruling on Phase 1 is rendered. If the Company fails to pay the required amount of US$ 200,000 to obtain a ruling on or before November 9, 2023 (the “Payment Deadline”), the ICSID Acting Secretary-General may exercise its discretion to discontinue the Arbitration. The ICSID Payment is expected to result in the issuance of a decision on jurisdiction and liability. Extension of the Payment Deadline The Company expects to apply today to ICSID to request an extension to the Payment Deadline (the “Extension”). The Company refrained from submitting an Extension application until it had received a litigation funding commitment, with such commitment being received today following the approval of the Omni’s (as defined below) investment committee. The Company strongly believes in the merits of its case and has obtained litigation funding to fund the ICSID Payment, subject to certain conditions as noted below. The Company is optimistic that ICSID will consider the Extension request. Litigation Funding Montauk has entered into a loan and option agreement (the “Loan Agreement”) with Omni Bridgeway (Fund 5) Canada Investments Ltd. (“Omni”), pursuant to which Omni has agreed to lend the Company US$200,000 (the “Loan Amount”) to fund the ICSID Payment in order for the Tribunal to render a ruling on Phase One. The Loan Amount will accrue interest at a rate of twenty percent (20%), compounded annually. In the event the Tribunal in the Arbitration finds that it does not have jurisdiction over the dispute and/or that Colombia did not breach its duties to the Company and/or any outcome which otherwise renders a Phase 2 Election (as defined below) non-viable in the sole view of Omni, the Loan Amount and any and all accrued interest must be repaid by the Company within sixty (60) days after Omni notifies the Company that Omni will not make the Phase 2 Election. The repayment of the Loan Amount and any such accrued interest shall be payable regardless of whether the Arbitration is successful and is a recourse obligation of the Company, payable from any and all assets of the Company. In connection with the Loan Agreement, the Company will deliver a promissory note (the “Note”) to Omni evidencing its obligation to repay Omni the Loan Amount and any accrued interest. In addition, the Company has granted Omni an option, exercisable in the sole discretion of Omni (the “Phase 2 Election”) to provide litigation funding to the Company pursuant to a litigation funding agreement (the “LFA”). The LFA is expected to provide an initial amount of up to US$2,325,000 (the “Non-Recourse Funding Amount”) subject to certain conditions. The Non-Recourse Funding Amount may be increased in certain circumstances as may be agreed upon between the Corporation and Omni. If Omni elects to provide the Non-Recourse Funding Amount for Phase 2 and the enforcement of any award obtained by the Company in the Arbitration, the Loan Amount and interest shall be repaid through proceeds recovered in the litigation (and in the event there are no proceeds recovered in the litigation, such amount inclusive of such interest shall be payable by the Company at the conclusion of the litigation). Omni’s return on the Non-Recourse Funding Amount (the “Omni Return”) will be limited solely to recovery from the amount of money for which the Arbitration is settled, or for which a final, non- appealable award is given in favour of the Corporation (the “Litigation Proceeds”). The Omni Return shall be an amount calculated as the sum of (i) a multiple of the amounts actually incurred of the Non-Recourse Litigation Funding Amount and (ii) a percentage of the gross recovery proceeds, both calculated when the recovery proceeds are received, as set out in the table below:

Months	Multiple	Percentage
0-12	2.0x	12%
12-24	3.0x	14%
24+	3.5x	16%

The Litigation Proceeds, if received, will be disbursed in the following order of priority: (a) Omni shall be reimbursed the Recourse Loan and the amounts actually incurred of the Non-Recourse Funding Amount; (b) Omni shall be paid the Omni Return and legal counsel shall be paid their legal fees; and (c) the balance shall be paid to the Corporation. In connection with the Loan Agreement, Note and LFA, the Company has agreed to grant Omni a continuing first priority security interest over any and all assets of the Company (whether presently held or acquired after the date hereof), including the Company’s interest in any Litigation Proceeds. The Loan Agreement is subject to certain conditions and the receipt of all necessary approvals and regulatory approvals, including the approval of the TSX Venture Exchange and the approval of the shareholders of the Company. The LFA is subject to the foregoing conditions and approvals and is subject to the settlement of the definitive LFA. The principal terms and conditions and the LFA have been agreed upon in the Loan Agreement. The Company has scheduled a special meeting of shareholders to be held on December 14, 2023 (the “Meeting”) at which shareholders of the Company will vote to ratify the Loan Agreement and approve the LFA. Additional information pertaining to the Loan Agreement and LFA may be found in the management information circular pertaining to the Meeting that is expected to be available on the Company’s profile on SEDAR+ on or around November 22, 2023. The Company cannot guarantee that it will be successful at the Arbitration, or that the estimated amounts disclosed herein will not be revised as the Arbitration proceeds. The Company also cannot guarantee that it will be able to recover all or part of its legal and arbitration costs from Colombia even if it is successful at the Arbitration. Assuming the Extension is granted and the Arbitration proceeds, the ruling from the Tribunal would be expected to be on or about the first quarter of 2024. Management of the Company will continue to provide updates on material developments of the status of the Arbitration. RISK DISCLOSURE STATEMENT: At the present time, the Company’s payment obligations are substantially in excess of its cash balances and it has no other assets. The Company is not solvent and cannot continue as a going concern.   Trading in shares of the Company and any investment in the Company is highly speculative. No trading in securities of the Company or investment should be made without being able to lose the entire amount of such funds. See below, “Cautionary Note Regarding Forward-Looking Statements”. Investors are advised to seek professional advice before making any decision to trade in or invest in the securities of the Company.