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GRAN COLOMBIA GOLD CORP. ANNUAL INFORMATION FORM FOR THE YEAR ENDED DECEMBER 31, 2011 DATED: MARCH 28, 2012

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Page 1: F E D 31, 2011 DATED M 28, 2012s21.q4cdn.com/834539576/files/doc_financials/2011/GCM-120221-AIF-(FINAL).pdfStandard and in conjunction with Pareto Commodities LLC. ... “Mandate Letter”

GRAN COLOMBIA GOLD CORP.

ANNUAL INFORMATION FORM

FOR THE YEAR ENDED DECEMBER 31, 2011

DATED: MARCH 28, 2012

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TABLE OF CONTENTS

1 GLOSSARY OF TERMS ............................................................................................................... 3

2 GENERAL MATTERS ................................................................................................................ 12

3 INFORMATION CONCERNING THE COMPANY .................................................................. 14

4 GENERAL DEVELOPMENT OF THE BUSINESS ................................................................... 16

5 DESCRIPTION OF THE BUSINESS .......................................................................................... 25

6 RISK FACTORS .......................................................................................................................... 30

7 PROPERTIES ............................................................................................................................... 42

8 DIVIDENDS AND DISTRIBUTIONS ........................................................................................ 62

9 DESCRIPTION OF CAPITAL STRUCTURE ............................................................................ 62

10 MARKET FOR SECURITIES ..................................................................................................... 65

11 ESCROWED SECURITIES AND SECURITIES SUBJECT TO CONTRACTUAL

RESTRICTION ON TRANSFER ................................................................................................ 67

12 DIRECTORS AND OFFICERS ................................................................................................... 67

13 CORPORATE CEASE TRADE ORDERS .................................................................................. 73

14 CORPORATE BANKRUPTCIES ................................................................................................ 73

15 PENALTIES OR SANCTIONS ................................................................................................... 73

16 PERSONAL BANKRUPTCIES ................................................................................................... 74

17 CONFLICTS OF INTEREST ....................................................................................................... 74

18 LEGAL PROCEEDINGS ............................................................................................................. 74

19 REGULATORY ACTIONS ......................................................................................................... 75

20 INTEREST OF MANAGEMENT AND OTHERS IN MATERIAL TRANSACTIONS ........... 75

21 TRANSFER AGENT AND REGISTRAR ................................................................................... 75

22 MATERIAL CONTRACTS ......................................................................................................... 76

23 INTERESTS OF EXPERTS ......................................................................................................... 76

24 AUDIT COMMITTEE INFORMATION .................................................................................... 77

25 ADDITIONAL INFORMATION ................................................................................................. 79

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1 GLOSSARY OF TERMS

Except as otherwise defined herein, the following terms used but not otherwise defined in this Annual

Information Form have the meanings set out below. Words importing the singular, where the context

requires, include the plural and vice versa and words importing any gender include all genders.

“Affiliate” of any Person means, at the time such determination is being made, any other Person

controlling, controlled by or under common control with such first Person, in each case, whether directly

or indirectly, and “control” and any derivation thereof means the possession, directly or indirectly, of the

power to direct or significantly influence the management and policies, business or affairs of a Person

whether through the ownership of voting securities or otherwise.

“Ag” means silver.

“Agent” means GMP Securities L.P.

“Annual Information Form” means this Annual Information Form dated March 28, 2012 in respect of

the fiscal year ended December 31, 2011.

“Associate” when used to indicate a relationship with a Person, means: (a) an issuer of which the Person

beneficially owns or controls, directly or indirectly, voting securities entitling him to more than 10% of

the voting rights attached to all outstanding voting securities of such issuer; (b) any partner of the Person;

(c) any trust or estate in which the Person has a substantial beneficial interest or in respect of which the

Person serves as trustee or in a similar capacity; or (d) in the case of a Person who is an individual, (i) that

Person’s spouse or child, or (ii) any relative of that Person or of his spouse who has the same residence as

that Person.

“Au” means gold.

“BCBCA” means the British Columbia Business Corporations Act.

“Blue Pacific” means Blue Pacific Assets Corp.

“Board” means the board of directors of the Company.

“BSD” means BSD Consultants.

“Carla” means Carla Resources, S.A.

“Carla Project” means the gold exploration project comprised of 16 gold concession contracts and

applications comprising an area of approximately 6,000 ha located in the municipalities of Remedios and

Segovia at approximately 7°04’ N, 74°43’ W in the Department of Antioquia, Colombia as more fully

described in the Carla Project Technical Report.

“Carla Project Technical Report” means the NI 43-101 compliant technical report relating to the Carla

Project titled “NI 43-101 Compliant Technical Report on the Carla Resources Gold Exploration Licences,

Antioquia, Colombia”, prepared by James Gilbertson and Colin Rawbone of SRK ES, dated July 30,

2010.

“CBSR” means Canadian Business for Social Responsibility.

“CDI” means Consorcio de Inversionistas CDI, S.A.

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“CIIGSA” means Comercializadora Internacional de Metales Preciosos y Metales Comunes Inversiones

Generales S.A. CIIGSA.

“CIM” means the Canadian Institute of Mining, Metallurgy and Petroleum.

“Colombia Goldfields” means Colombia Goldfields Ltd.

“Colombia Goldfields Warrants” means the June Colombia Goldfields Warrants and the December

Colombia Goldfields Warrants.

“Colombia Goldfields Transaction” means the transaction whereby Medoro acquired all of the issued

and outstanding securities of Colombia Goldfields in exchange for common shares and common share

purchase warrants of Medoro pursuant to an arrangement agreement dated June 5, 2009, as amended on

July 2, 2009 and as further amended on August 10, 2009, entered into by Medoro and Colombia

Goldfields, and pursuant to a statutory plan of arrangement pursuant to section 195 of the YBCA.

“Common Shares” means the common shares in the capital of the Company.

“Common Share Consolidation” means the consolidation of the Common Shares on a one-for-four basis

effective November 11, 2010.

“Company” or “Gran Colombia” means Gran Colombia Gold Corp.

“Compensation Options” means the First Gran Colombia Private Placement Options and the Second

Gran Colombia Private Placement Options.

“Concepción Project” means the exploration project comprised of four mining concession contracts and

applications with a total area of 3,534.694 ha or 35.3 km2 located in the Municipalities of Concepción,

San Vicente, El Peñol and Barbosa, Department of Antioquia, Republic of Colombia at approximately 6°

21’N, 75° 16’ W as more fully described in the Concepción Technical Report.

“Concepción Technical Report” means the NI 43-101 compliant technical report relating to the

Concepción Project titled “NI 43-101 Technical Report for the Concepción Project, Department of

Antioquia, Republic of Colombia”, prepared by Stewart D. Redwood, dated May 31, 2010.

“COP” means Colombian pesos.

“CRA” means Canada Revenue Agency.

“CVG Contract” means the Lo Increíble 4A and 4B exploitation contract entered into by Medoro with

the Corporacion Venezolana de Guyana, a Venezuelan state-owned entity, dated August 28, 1992 and

amended on January 26, 1994.

“December Colombia Goldfields Warrants” means the warrants issued by Colombia Goldfields to

shareholders thereof and assumed by Medoro (and now the Company) in connection with the Colombia

Goldfields Transaction, and which expire on December 28, 2012.

“Delegated Authority” has the meaning given to such term under the heading entitled “Audit Committee

Information – Pre-Approval Policies and Procedures”.

“deposit” means a mineralized body which has been physically delineated by sufficient drilling,

trenching, and/or underground work, and found to contain a sufficient average grade of metal or metals to

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warrant further exploration and/or development expenditures. Such a deposit does not qualify as mineral

resources, a commercially mineable ore body or as containing mineral reserves, until final legal,

technical, and economic factors have been resolved.

“Echandia Property” means the Echandia exploration property at Marmato, Colombia, acquired by the

Company in connection with the Medoro Merger.

“El Zancudo Project” means the exploration project located in the Municipalities of Titiribi, Angelopolis

and Armenia, Department of Antioquia, Republic of Colombia at 6° 04’ 30” N – 75° 47’ 26” W as more

particularly described in the El Zancudo Technical Report.

“El Zancudo Technical Report” means the NI 43-101 compliant technical report with respect to the El

Zancudo Project titled “NI 43-101 Technical Report for the El Zancudo Project, Department of Antiquia,

Republic of Colombia”, prepared for the Company by Stewart D. Redwood, dated April 6, 2010.

“Equity” means Equity Financial Trust Company.

“Facility” means the proposed US$100 million senior secured term loan facility to be provided by

Standard and in conjunction with Pareto Commodities LLC.

“FGM” means Frontino Gold Mines Ltd.

“First Gran Colombia Private Placement” means the brokered private placement financing of Gran

Colombia Panama completed on April 27, 2010 pursuant to which 22,500,000 Gran Colombia Panama

Shares were issued at a purchase price of $1.00 per share for gross proceeds of $22,500,000.

“First Gran Colombia Private Placement Compensation Options” means the 1,350,000 options

granted to the Agent in connection with the First Gran Colombia Private Placement, each such option

being exercisable to acquire one Common Share until April 27, 2012, at a price of $1.00 per Common

Share.

“Frontino Acquisition” means the acquisition whereby Gran Colombia Panama, through Zandor,

Colombian branch, acquired all of the assets of FGM.

“Frontino Acquisition Agreement” means the acquisition agreement entered into between Gran

Colombia Panama, Medoro and Zandor dated March 29, 2010 in connection with the Frontino

Acquisition.

“g/t” means grams per metric tonne.

“Gran Colombia Amalgamation” means the three-cornered amalgamation under the Panamanian Law

of Corporations, pursuant to which Gran Colombia Panama amalgamated with Panama Newco to form

Panama Amalco, resulting in Panama Amalco being a wholly-owned subsidiary of Old GCM.

“Gran Colombia Consideration Warrants” means a Warrant issued under the Gran Colombia Warrant

Indenture and in connection with the Medoro Merger, having an exercise price of $2.60 per Gran

Colombia Share per whole Warrant exercised and expiring on August 24, 2015.

“Gran Colombia Panama” means Gran Colombia Gold, S.A., a wholly-owned subsidiary of the

Company.

“Gran Colombia Panama Shares” means common shares in the capital of Gran Colombia Panama.

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“Gran Colombia Transaction” means the RTO pursuant to which Old GCM acquired all of the issued

and outstanding securities of Gran Colombia Panama by way of a three-cornered amalgamation in

exchange for the issuance of common shares in the capital of Old GCM.

“Gran Colombia Unit” means a unit issued in connection with the Second Gran Colombia Private

Placement in exchange for a subscription receipt of Gran Colombia Panama, each such unit being

comprised of one whole Common Share and one half of one Warrant.

“ha” means hectares.

“HMZ Metals” means HMZ Metals Inc.

“Indicated Mineral Resource” means that part of a mineral resource for which quantity, grade or

quality, densities, shape and physical characteristics, can be estimated with a level of confidence

sufficient to allow the appropriate application of technical and economic parameters, to support mine

planning and evaluation of the economic viability of the deposit. The estimate is based on detailed and

reliable exploration and testing information gathered through appropriate techniques from locations such

as outcrops, trenches, pits, workings and drill holes that are spaced closely enough for geological and

grade continuity to be reasonably assumed.

“Inferred Mineral Resource” means that part of a mineral resource for which quantity and grade or

quality can be estimated on the basis of geological evidence and limited sampling and reasonably

assumed, but not verified, geological and grade continuity. The estimate is based on limited information

and sampling gathered through appropriate techniques from locations such as outcrops, trenches, pits,

workings and drill holes.

“ISS” means the Colombian Social Security Institute.

“June Colombia Goldfields Warrants” means the warrants issued by Colombia Goldfields to

shareholders thereof and assumed by Medoro (and now the Company) in connection with the Colombia

Goldfields Transaction, and which expire on June 18, 2013.

“LGGC” means Lions Gate Geological Consulting Inc.

“Lo Increíble Properties” means the Lo Increíble 4A and 4B mining contracts in the El Callao

municipality of the State of Bolivar in Venezuela, as more particularly described in the Lo Increíble

Technical Report.

“Lo Increíble Technical Report” means the NI 43-101 compliant technical report relating to the Lo

Increíble Properties titled “Updated Independent Technical Review of the Lo Increíble Gold Prospect,

Bolivar State, Venezuela”, prepared for the Company by Dr. Mike Armitage and Dr. Lucy Roberts of

SRK, dated April 27, 2009.

“LOMEC” means Los Mineros de El Callao, S.A.

“Mandate Letter” means the exclusive mandate letter dated December 20, 2011 (as amended on January

31, 2011), entered into between the Company and Standard Bank in connection with the Facility.

“Marmato Project” means the Company’s gold-silver project at Marmato, Caldas Department,

Colombia, comprising of three contiguous properties: Zona Alta Property, Zona Baja Property and

Echandia Property, as more particularly described in the Marmato Technical Report.

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“Marmato Technical Report” means the NI 43-101 compliant technical report relating to the Marmato

Project titled “A NI 43-101 Mineral Resource Estimate on the Marmato Project, Colombia”, prepared by

Mike Armitage and Ben Parsons of SRK, dated September 4, 2011.

“Mazamorras Project” means the exploration project located at 1.49oN and 77.15

oW southwest of the

Republic of Colombia, some 32 km (straight line) north-northwest from San Juan de Pasto, the capital

city of the Department of Nariño, and some 488 km (straight line) south-southeast from Bogotá consisting

of four concession areas comprising a total area of 3293.60 ha, as more fully described in the Mazamorras

Technical Report.

“Mazamorras Technical Report” means the NI 43-101 compliant technical report relating to the

Mazamorras Project titled “The Mazamorras Cu-Au-Mo-Porphyry Project, Colombia – Report prepared

under the Guidelines of National Instrument 43-101”, prepared by Karen Volp Company of SRK ES,

dated July 2010.

“MCTO” means management cease trade order.

“Measured Mineral Resource” means that part of a Mineral Resource for which quantity, grade or

quality, densities, shape, and physical characteristics are so well established that they can be estimated

with confidence sufficient to allow the appropriate application of technical and economic parameters, to

support production planning and evaluation of the economic viability of the deposit. The estimate is based

on detailed and reliable exploration, sampling and testing information gathered through appropriate

techniques from locations such as outcrops, trenches, pits, workings and drill holes that are spaced closely

enough to confirm both geological and grade continuity.

“Medoro” means Medoro Resources Ltd., the predecessor of Medoro Yukon that existed under the

YBCA.

“Medoro Arrangement Agreement” means the arrangement agreement entered into by the Company

and Medoro, dated April 13, 2011 (as amended and restated as of May 4, 2011) in connection with the

Medoro Merger.

“Medoro Merger” means the acquisition of the all of the issued and outstanding securities of Medoro by

the Company in connection with the Medoro Arrangement Agreement and the Medoro Plan of

Arrangement.

“Medoro Plan of Arrangement” means the statutory plan of arrangement pursuant to section 195 of the

YBCA in connection with the Medoro Merger.

“Medoro Yukon” means Medoro Resources (Yukon) Inc., a corporation formed in connection with the

Medoro Merger and existing under the laws of the Yukon Territory.

“MIBAM” means the Ministry of Basic Industry and Mining.

“mineral resource/Mineral Resource” means a concentration or occurrence of diamonds, natural, solid

inorganic material, or natural fossilized organic material including base and precious metals, coal and

industrial minerals, in or on the Earth’s crust in such form and quantity and of such a grade or quality that

it has reasonable prospects for economic extraction. The location, quantity, grade, geological

characteristics and continuity of a mineral resource are known, estimated or interpreted from specific

geological evidence and knowledge. The terms “Mineral Resource”, “Measured Mineral Resource”,

“Indicated Mineral Resource”, “Inferred Mineral Resource” used in this Annual Information Form are

Canadian mining terms as defined in accordance with NI 43-101 under the guidelines set out in the CIM

Standards on Mineral Resource and Mineral Reserves Definitions and guidelines adopted by the CIM

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Council on December 11, 2005. While the terms “Mineral Resource”, “Indicated Mineral Resource”, and

“Inferred Mineral Resource” are recognized and required by Canadian regulations, they are not defined

terms under standards in the United States.

“Mineros Nacionales” means Mineros Nacionales, S.A.

“Mineros Nacionales Mine” means the Company’s underground producing mine located at the Zona

Baja Property in Marmato.

“m” means metres.

“mm” means millimeters.

“Moz” means million ounces.

“NEX” means the NEX trading board of the TSXV.

“NI 43-101” means National Instrument 43-101 – Standards of Disclosure for Mineral Projects issued by

the Canadian Securities Administrators.

“NI 43-101 CP” means Companion Policy 43-101CP – To National Instrument 43-101 Standards of

Disclosure for Mineral Properties.

“NI 43-101 F1” means Form 43-101F1 – Technical Report.

“NI 52-110” means National Instrument 52-110 – Audit Committees issued by the Canadian Securities

Administrators.

“Notes” means the US$80,000,000 aggregate senior unsecured silver-linked notes with a price of

US$1,000 principal amount per Note, issued on August 11, 2011, by way of short form prospectus. The

Notes are listed for trading on the TSX under the symbol “GCM.NT.U”.

“Old GCM” means Tapestry Resource Corp., a predecessor corporation to Gran Colombia that existed

under the BCBCA.

“Old GCM Shares” means common shares in the capital of Old GCM.

“Old GCM Warrants” means warrants issued by Old GCM on March 19, 2010 in connection with a

non-brokered private placement of 5,000,000 units at a price of $0.30 each for gross proceeds of

$1,500,000. For further information see the heading entitled “General Development of the Business – Old

GCM Warrants.”

“Option” means an option granted by the Company to purchase Common Shares pursuant to the

Company’s Option Plan.

“Option Plan” means the option plan of the Company dated August 6, 2010.

“ordinary kriging” means a geostatistical approach to modeling. Instead of weighting nearby data points

by some power of their inverted distance, ordinary kriging relies on the spatial correlation of the data to

determine the weighting values. This is a more rigorous approach to modeling, as correlation between

data points determines the estimated value at an unsampled point.

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“Panama Amalco” means the corporation resulting from the amalgamation of Gran Colombia Panama

and Panama Newco pursuant to the Gran Colombia Amalgamation.

“Panama Newco” means Masteri Inc., the wholly-owned subsidiary of Old GCM incorporated under the

Panamanian Law of Corporations for the purposes of completing the Gran Colombia Amalgamation.

“PDVSA” means Petróleos de Venezuela.

“Person” means any individual, sole proprietorship, partnership, firm, entity, unincorporated association,

unincorporated syndicate, unincorporated organization, trust, body corporate, governmental authority, and

where the context requires any of the foregoing when they are acting as trustee, executor, administrator or

other legal representative.

“Preliminary Feasibility Study” means a comprehensive study of the viability of a mineral project that

has advanced to a stage where the mining method, in the case of underground mining, or the pit

configuration, in the case of an open pit, has been established and an effective method of mineral

processing has been determined, and includes a financial analysis based on reasonable assumptions of

technical, engineering, legal, operating, economic, social, and environmental factors and the evaluation of

other relevant factors which are sufficient for a Qualified Person, acting reasonably, to determine if all or

part of the Mineral Resource may be classified as a Mineral Reserve.

“Preferred Shares” means the preferred shares in the capital of the Company.

“Projects” means the Segovia Operations, the Marmato Project, the El Zancudo Project, the Mazamorras

Project, the Concepción Project, and the Lo Increíble Properties.

“Probable Mineral Reserve” means the economically mineable part of an Indicated and, in some

circumstances, a Measured Mineral Resource demonstrated by at least a Preliminary Feasibility Study.

This study must include adequate information on mining, processing, metallurgical, economic, and other

relevant factors that demonstrate, at the time of reporting, that economic extraction can be justified.

“Providencia” means Compañía de Minas Providencia, S.A.

“QA/QC” means quality assurance/quality control.

“Qualified Person” has the meaning given to such term under NI 43-101, section 1.1 – Definitions and

Interpretations.

“Royalty Agreement” means the royalty agreement between Medoro and Corporacion Vengroup, S.A

and Socobal Corporation dated July 10, 2006, entered into in connection with Medoro’s acquisition of all

of the issued and outstanding securities of Panwest Seas Corporation Ltd. on same date, holding the rights

to the Lo Increíble Properties.

“RTO” means the arm’s length reverse takeover as more particularly described under the heading entitled

“General Development of the Business – August 2010 – December 31, 2011 - RTO”.

“Sabaletas” has the meaning given to such term under the heading entitled “Properties – El Zancudo

Project”.

“Second Gran Colombia Private Placement” means the $275,000,000 brokered private placement

financing of Gran Colombia Panama by way of subscription receipts sold at a price of $1.60 per

subscription receipt, pursuant to which each subscription receipt will be exchanged, for no additional

consideration and without any further action by the holder thereof, into one Gran Colombia Unit

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immediately prior to the completion of the Frontino Acquisition, comprised of one Common Share and

one-half of one Warrant.

“Second Gran Colombia Private Placement Compensation Options” means the 10,312,500 non-

transferrable options granted to the Agent in connection with the Second Gran Colombia Private

Placement, with each such option being exercisable to acquire one Gran Colombia Unit at any time prior

to 5:00 p.m. (Toronto time) on the earlier of the date that is: (i) immediately prior to the date each such

option is exchanged for an Old GCM option in connection with the Gran Colombia Amalgamation; and

(ii) August 24, 2012 at a price of $1.60 per Gran Colombia Unit.

“SEDAR” means the System for Electronic Document Analysis and Retrieval.

“Segovia Operations” means the Segovia Project and the Carla Project.

“Segovia Project” means the mining rights comprised of one private mining property and two

exploration licenses (El Silencio, Providencia and Sandra K) with a total area of 2,907 ha, located in the

municipalities of Segovia and Remedios, Department of Antioquia as more fully described in the Segovia

Project Technical Report.

“Segovia Project Technical Report” means the NI 43-101 compliant technical report relating to the

Segovia Project titled “NI 43-101 Technical Report Frontino Gold Mines Ltd., Antiquia, Colombia”,

prepared by Scott E. Wilson of SEWC and Stewart D. Redwood, dated June 9, 2010.

“SEWC” means Scott E. Wilson Consulting Inc.

“SGS” means SGS del Perú S.A.C.

SRK ES” means SRK Exploration Services Ltd.

“SRK UK” means SRK Consulting (UK) Ltd.

“Standard Bank” means Standard Bank Plc.

“Technical Reports” means, collectively, the El Zancudo Technical Report, the Segovia Project

Technical Report, the Marmato Technical Report, the Lo Increíble Technical Report, the Mazamorras

Technical Report, the Concepción Technical Report, and the Carla Project Technical Report.

“tpd” means tonnes per day.

“TSX” means the Toronto Stock Exchange.

“TSXV” means the TSX Venture Exchange.

“ValGold Resources” means ValGold Resources Ltd.

“Warrant” means a warrant of the Company issued pursuant to the Warrant Indenture listed for trading

on the TSX under the symbol “GCM.WT” providing for the holder thereof to acquire one Common Share

at an an exercise price of $2.60 per Common Share and expiring on August 24, 2015.

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“Warrant Consolidation” means consolidation of the Warrants on a one-for-four basis effective

December 1, 2010.

“Warrant Indenture” means the warrant indenture dated August 20, 2010, entered into between the

Company and Equity pursuant to which the Warrants were issued.

“YBCA” means the Business Corporations Act of the Yukon Territory.

“Zandor” means Zandor Capital S.A., the Panamanian joint venture company used by Gran Colombia

and Medoro as a vehicle for completing the Frontino Acquisition.

“Zona Alta Property” means the property located in the Zona Alta at Marmato, Colombia acquired by

the Company in connection with the Medoro Merger.

“Zona Baja Property” means the property in the Zona Baja in Marmato, Colombia acquired by the

Company in connection with the Medoro Merger. The Mineros Nacionales Mine is located at the Zona

Baja Property.

1.1 Forward-Looking Information

All statements, other than statements of historical fact, contained or incorporated by reference in this

Annual Information Form including, but not limited to, any information as to the future financial or

operating performance of Gran Colombia, constitute “forward-looking information” or “forward-looking

statements” within the meaning of certain securities laws, including the provisions of the Securities Act

(Ontario) and are based on expectations, estimates and projections as of the date of this Annual

Information Form. Forward-looking statements include, without limitation, possible events, statements

with respect to possible events, the future price of gold and silver, the estimation of mineral reserves and

resources, the realization of mineral reserve and resource estimates, the timing and amount of estimated

future production, costs of production, expected capital expenditures, costs and timing of the development

of new deposits, success of exploration, development and mining activities, permitting time lines,

currency fluctuations, requirements for additional capital, government regulation of mining operations,

environmental risks, unanticipated reclamation expenses, title disputes or claims and limitations on

insurance coverage. The words “plans”, “expects” or “does not expect”, “is expected”, “budget”,

“scheduled”, “estimates”, “targets”, “forecasts”, “intends”, “anticipates”, or “does not anticipate”, or

“believes”, or variations of such words and phrases or statements that certain actions, events or results

“may”, “could”, “would”, “should”, “might”, or “will be taken”, “occur” or “be achieved” and similar

expressions identify forward-looking statements.

Forward-looking statements are necessarily based upon a number of estimates and assumptions that,

while considered reasonable by the Company as of the date of such statements, are inherently subject to

significant business, economic and competitive uncertainties and contingencies. The estimates and

assumptions of Gran Colombia contained or incorporated by reference in this Annual Information Form,

which may prove to be incorrect, include, but are not limited to, the various assumptions set forth herein

and in the Company’s most recently filed Management’s Discussion and Analysis, or as otherwise

expressly incorporated herein by reference as well as: (1) there being no significant disruptions affecting

operations, whether due to labour disruptions, supply disruptions, power disruptions, damage to

equipment or otherwise; (2) permitting, development, operations, expansion at the Projects (including,

without limitation, land acquisitions for and permitting and construction of the new tailings facility) being

consistent with our current expectations; (3) political developments in any jurisdiction in which the

Company operates being consistent with its current expectations; (4) the viability, permitting and

development of the Segovia Operations and the Marmato Project, including, without limitation, the

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metallurgy and processing of its ore being consistent with our current expectations; (5) the exchange rate

between the Canadian dollar, COP and the U.S. dollar being approximately consistent with current levels;

(6) certain price assumptions for gold and silver; (7) prices for natural gas, fuel oil, electricity and other

key supplies remaining consistent with current levels; (8) production and cost of sales forecasts meeting

expectations; (9) the accuracy of our current mineral reserve and mineral resource estimates; and (10)

labour and materials costs increasing on a basis consistent with the Company’s current expectations.

Known and unknown factors could cause actual results to differ materially from those projected in the

forward-looking statements. Such factors include, but are not limited to: fluctuations in the currency

markets; fluctuations in the spot and forward price of gold or certain other commodities (such as diesel

fuel and electricity); changes in interest rates or gold or silver lease rates that could impact the mark-to-

market value of outstanding derivative instruments and ongoing payments/receipts under any interest rate

swaps and variable rate debt obligations; risks arising from holding derivative instruments (such as credit

risk, market liquidity risk and mark-to-market risk); changes in national and local government legislation,

taxation, controls, regulations and political or economic developments in Canada, Colombia, Venezuela

the United States, or other countries in which we do business or may carry on business in the future;

business opportunities that may be presented to, or pursued by, us; our ability to successfully integrate

acquisitions; operating or technical difficulties in connection with mining or development activities;

employee relations; the speculative nature of gold exploration and development, including the risks of

obtaining necessary licenses and permits; diminishing quantities or grades of reserves; adverse changes in

our credit rating; and contests over title to properties, particularly title to undeveloped properties. In

addition, there are risks and hazards associated with the business of gold exploration, development and

mining, including environmental hazards, industrial accidents, unusual or unexpected formations,

pressures, cave-ins, flooding and gold bullion losses (and the risk of inadequate insurance, or the inability

to obtain insurance, to cover these risks). Many of these uncertainties and contingencies can affect the

Company’s actual results and could cause actual results to differ materially from those expressed or

implied in any forward-looking statements made by, or on behalf of, the Company. There can be no

assurance that forward-looking statements will prove to be accurate, as actual results and future events

could differ materially from those anticipated in such statements. Forward-looking statements are

provided for the purpose of providing information about management’s expectations and plans relating to

the future. All of the forward-looking statements made in this Annual Information Form are qualified by

these cautionary statements and those made in our other filings with the securities regulators of Canada

including, but not limited to, the cautionary statements made in the “Risks and Uncertainties” section of

the Company’s most recently filed Management’s Discussion and Analysis. These factors are not

intended to represent a complete list of the factors that could affect the Company. The Company

disclaims any intention or obligation to update or revise any forward-looking statements or to explain any

material difference between subsequent actual events and such forward-looking statements, except to the

extent required by applicable law.

2 GENERAL MATTERS

This Annual Information Form is for the year ended December 31, 2011. All information in this Annual

Information Form is as of December 31, 2011, unless otherwise indicated.

In this Annual Information Form, unless otherwise indicated, all dollar amounts are expressed in

Canadian dollars and references to “$” are to Canadian dollars.

All financial information in this Annual Information Form has been prepared in accordance with

International Financial Reporting Standards unless otherwise expressly indicated.

The industry and other statistical data presented in this Annual Information Form, except where otherwise

noted, have been compiled from sources and participants which, although not independently verified by

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the Company, are considered by the Company to be reliable sources of information. References in this

Annual Information Form to research reports or articles should not be construed as depicting the complete

findings of the entire referenced report or article and such report or article is expressly not incorporated

by reference into this Annual Information Form.

For ease of reference, the following factors for converting Imperial measurements into metric equivalents

are provided:

To Convert from Imperial To Metric Multiply by

Acres Hectares 0.404686

Feet Metres 0.30480

Miles Kilometres 1.609344

Tons Tonnes 0.907185

Ounces (troy)/ton Grams/tonne 34.2857

Ounces

Imperial Measurement

Grams

Metric

31.1035

1 mile = 1.609 kilometres

1 yard = 0.9144 metre

1 acre = 0.405 hectare

2,204 pounds = 1 tonne (metric)

2,000 pounds/1 short ton = 0.907 tonnes

2.1 Special Note to Reader

Please note that all references in this Annual Information Form to Common Shares, Options, Warrants

and other securities as applicable, even those that pre-date the Common Share Consolidation and Warrant

Consolidation, as applicable, are stated on a post-consolidation basis.

2.2 Incorporation by Reference

The Technical Reports, prepared and filed in accordance with NI 43-101, are incorporated by reference

into, and form part of, this Annual Information Form. These documents have been filed on, and may be

accessed under the Company’s profile on SEDAR at www.sedar.com.

2.3 Exchange Rate Information

United States Exchange Rate Information 2.3.1

The following table sets out: (1) the rate of exchange for one Canadian dollar in U.S. dollars in effect at

the end of each of the periods set out immediately below; (2) the high and low rate of exchange during

those periods; and (3) the average rate of exchange for those periods, each based on the noon spot rate as

published on the Bank of Canada’s website. On March 28, 2012, the noon nominal rate for one Canadian

dollar in U.S. dollars as published by the Bank of Canada was $1.00 = US$1.0016.

High Low Average End of Period

Years ended December 31

2011 1.0583 0.9430 1.0111 1.0170

2010 1.0745 0.9946 1.0303 1.0054

2009 0.9755 0.7653 0.8757 0.9555

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2.4 Colombia Exchange Rate Information

The following table sets out: (1) the rate of exchange for one Canadian dollar in COP in effect at the end

of each of the periods set out immediately below; (2) the high and low rate of exchange during those

periods; and (3) the average rate of exchange for those periods, each based on the noon spot rate as

published on the Bank of Canada’s website. On March 28, 2012, the noon nominal rate for one Canadian

dollar in COP as published by the Bank of Canada was $1.00 = COP1,776,1989.

High Low Average End of Period

Years ended December 31

2011 1,968.5039 1,792.1147 1,867.2044 1,904.7619

2010 1,960,7843 1,709.1017 1,840.5673 1,930.5019

2009 2,079.0021 1,763.6684 1,883.2392 1,956.9472

3 INFORMATION CONCERNING THE COMPANY

3.1 Name, Address and Incorporation

The full corporate name of the Company is Gran Colombia Gold Corp. The head office of the Company

is located at 333 Bay Street, Suite 1100, Toronto, Ontario M5H 2R2 and its registered office is located at

1188 West Georgia Street, Suite 650, Vancouver, British Columbia, V6E 4A2. The Company also has

offices in Bogotá and Medellin, Colombia, Venezuela and Mali.

The Company was incorporated pursuant to the provisions of the British Columbia Company Act on May

27, 1982 under the name “Impala Resources Ltd.” On August 26, 1987, Impala Resources Ltd. changed

its name to “International Impala Resources Ltd.” On November 13, 1992, International Impala

Resources Ltd. changed its name to “Tapestry Ventures Ltd.” On December 22, 2004, Tapestry Ventures

Ltd. changed its name to “Tapestry Resource Corp.” In connection with the RTO (described herein), on

August 13, 2010, the Company changed its name from “Tapestry Resource Corp.” to “Gran Colombia

Gold Corp.”

Effective June 10, 2011, Gran Colombia completed a merger with Medoro, a TSX listed company. The

combined company continues under the name “Gran Colombia Gold Corp.” See “General Development

of the Business – 2011 – Medoro Merger” and “General Development of the Business – Significant

Acquisitions and Dispositions – Medoro Merger”.

3.2 Intercorporate Relationships

The following chart illustrates the principal subsidiaries of the Company, together with the jurisdiction of

incorporation of each company and the percentage of voting securities beneficially owned or over which

control or direction is exercised, directly or indirectly, by the Company as at the date hereof:

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Gran Colombia Gold Corp.(British Columbia)

Gran Colombia Gold, S.A.(Panama)

Mazamorras Gold Corp.

(Panama)

Remedios Gold, S.A.

(Panama)

Segovia Gold, S.A.(Panama)

Nova Partners International Corp.

(Panama)

Providencia Gold Corp.

(Panama)

Zandor Capital, S.A.

(Panama)

Zancudo Gold Corp.(Panama)

Medoro Resources (Yukon) Inc.

4,760 Shares = 0.1584%

Zancudo Gold Sucursal(Colombia)

100%

Providencia GoldSucursal

(Colombia)

100%

Segovia Gold, S.A. Sucursal

(Colombia)

100%

Mazamorras Gold Sucursal

(Colombia)

100%

Commercializadora Internacional de Metales

Preciosos y Metales Comunes Inversiones Generales S.A. CIIGSA

(Colombia)

60%

Zandor Capital, S.A. Sucursal(Colombia)

100%

100%

100% 80% 100% 100% 100% 100% 95%

100%

200 Shares = 5%

Medoro Resources Colombia Inc.

(Panama)

Medoro Andina Internacional S.A.

(Panama)

Colombia Gold Ltd.(UK)

Barona Cape Ltd.(BVI)

98,500,000 Shares = 100% 100 Shares = 100% 500 Shares = 100% 50,000 Shares = 100%

Colombia Gold AG(Switzerland)

47,854,676 Shares = 100%

Colombia Gold Ltd.(British Columbia)

Colombia Gold, S.A.S(Colombia)

1,438,384 Shares = 90.92%

2,997,880 Shares = 93.49%

Minera Croesus, S.A.S(Colombia)

Minera de Caldas, S.A.S(Colombia)

206,580 Shares = 6.44%

15,000 Shares = 1.50%

215,199 Shares = 100%

Mineros Nacionales S.A.(Colombia)

Medoro Resources Colombia Inc. Sucursal

Colombia

104,524,486 Shares = 100%1,000 Shares = 100%

Colombia Goldfields Ltd.

(Delaware)

RNC (Colombia) Ltd.(Belize)

Minerales Andinos de Occidente S.A.

(Colombia)

2,846,310 Shares = 94.7469%Gavilan Minerales, S.A.S

(Colombia)

149,498 Shares = 4.9764%

13,292 Shares = 8.86%

45,000 Shares – 4.5%

3,552 Shares = 0.1182%

1,000 Shares = 100%

97,114 Shares = 6.14%

Tolima Gold Corp.

(Colombia)

5,000,000 Shares = 4.26%

46,500 = 2.94%

94,000 = 94%

African Gold Resources Corp.

(Panama)

100%

Gold Resources du Mali SARL(Mali)

100%

Medoro Resources International Ltd.

(BVI)(Formerly Panwest)

100%

Mineria MH, CA.

(Venezuela)

Medoro de Venezuela, CA.

Lo Incredible Mining Company de

Venezuela CA.(Venezuela)

Los Mineros de El Callao, SA.

(Venezuela)

95%

100%

2,120 Shares = 0.07%

7.7%

Minority ShareholdersIndividuals - Shares

held on behalf of Company

Third Party Small Holders

138,908 Shares = 89.6%2,160 Shares = 1.39%

jsanci
Typewritten Text
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Most of the Company’s subsidiaries in the above chart identified below Medoro Yukon were acquired by

Medoro (and effectively the Company as a result of the Medoro Merger) as a result of several acquisitions

of different mining projects from a series of vendors with the strategy of consolidating the Marmato

mining district in Caldas, Colombia. Some of such acquisitions, for different reasons, were structured as

amalgamations of companies or acquisitions of off-shore holding structures. Since the vendors of these

assets were based in different countries and had distinct corporate planning strategies, these purchases by

the Company resulted in a very intricate structure of off-shore holding companies for the Company,

including companies in the UK, Switzerland, Belize, British Virgin Islands, Delaware (U.S.A.), Yukon

Territory (Canada), British Columbia (Canada) and Colombia. These structures do not provide any

advantages to the Company and instead increase costs and effort related to accounting, reporting and

operational burden. As such, the Company has commenced a process to re-organize and streamline its

subsidiaries in order to simplify the off-shore holding structure of the Company’s Colombian assets.

The Company expects to commence the re-organization during the 2012 financial year.

4 GENERAL DEVELOPMENT OF THE BUSINESS

4.1 Inception to August 2010

Since the date the Old GCM Shares commenced trading on the Vancouver Stock Exchange, Old GCM

carried out the business of exploration of minerals until being deemed inactive on June 26, 2002. On

August 18, 2003, the Old GCM Shares were transferred to the NEX.

On June 30, 2010, Old GCM announced that it had entered into an agreement to complete the RTO

pursuant to the Gran Colombia Transaction. The RTO closed on August 19, 2010, and trading of the

Common Shares and Warrants on the TSXV commenced on August 24, 2010 under the symbols “GCM”

and “GCM.WT”, respectively.

Old GCM Warrants

On March 19, 2010, Old GCM completed a non-brokered private placement of units that included non-

transferable warrants of Old GCM. Each such warrant entitled the holder to purchase one-quarter of a

Common Share at an exercise price of $0.10 until March 19, 2011. Upon completion of the Gran

Colombia Transaction, there were 22,000,000 Old GCM warrants issued and outstanding. As of the date

hereof, all Old GCM warrants have been exercised and there are no Old GCM warrants outstanding.

Previous Financings

Effective April 27, 2010, Gran Colombia Panama completed the First Gran Colombia Private Placement.

In connection with the First Gran Colombia Private Placement, Gran Colombia Panama granted the First

Gran Colombia Private Placement Compensation Options to the Agent.

On July 27, 2010, Gran Colombia Panama completed the Second Gran Colombia Private Placement.

Gran Colombia Panama paid to the Agent a cash commission equal to 6% of the gross proceeds raised in

connection therewith upon release of the proceeds from escrow. In addition, as additional compensation

in connection with the Second Gran Colombia Private Placement, Gran Colombia Panama also granted

the Second Gran Colombia Private Placement Compensation Options to the Agent.

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4.2 August 2010 – December 31, 2011

RTO

On June 30, 2010, Old GCM announced that it had entered into an agreement to complete the RTO,

thereby effecting the Gran Colombia Transaction. Under the terms of the Gran Colombia Transaction,

each Gran Colombia Panama shareholder received one Common Share for every common share in the

capital of Gran Colombia Panama held, each holder of a warrant of Gran Colombia Panama received one

warrant of the Company for every Gran Colombia Panama warrant held, each holder of a First Gran

Colombia Private Placement Compensation Option received one Option for every First Gran Colombia

Private Placement Compensation Option held, and each holder of a Second Gran Colombia Private

Placement Compensation Option received Option for every Second Gran Colombia Private Placement

Compensation Option held.

After completion of the Gran Colombia Transaction, an aggregate of 211,187,634 Common Shares were

issued and outstanding, or 329,568,877 Common Shares on a fully-diluted basis. The former Old GCM

shareholders owned 8,062,629 Common Shares, or approximately 3.82% of the issued and outstanding

Common Shares at that time. Pursuant to the Gran Colombia Transaction, the Gran Colombia Panama

shareholders were issued 203,125,000 Common Shares or approximately 96.18% of the issued and

outstanding Common Shares.

On August 19, 2010, the Company completed the RTO.

Following the completion of the RTO, the Common Shares and Warrants were listed and began trading

on the TSXV under the symbol “GCM” and “GCM.WT”, respectively.

Acquisition of 100% Interest in Zandor

On August 17, 2010, Gran Colombia Panama loaned a principal amount of COP372,500,000,000 to

Zandor, then a wholly-owned Panamanian subsidiary of Medoro, pursuant to a convertible promissory

note. The principal amount comprised COP365,000,000,000 (approximately US$201.7 million) of cash

advanced on August 17, 2010 from the proceeds of the Second Gran Colombia Private Placement and

COP7,500,000,000 (approximately US$3.9 million) relating to half of the COP15,000,000,000 deposit

already paid by Medoro.

On August 18, 2010, Zandor used these funds to complete the Frontino Acquisition (being the Segovia

Project).

On August 19, 2010, the principal amount was converted into such number of shares in the capital of

Zandor that resulted in Gran Colombia Panama holding a 95% equity interest in Zandor with Medoro

retaining a 5% equity interest in Zandor. Concurrently with the conversion of the convertible promissory

note, on August 19, 2010, Gran Colombia Panama, Medoro and Zandor entered into an Exploration,

Development and Mine Operating Agreement and Shareholders’ Venture Agreement setting out the

parties’ rights and obligations with respect to their ownership in the shares in the capital of Zandor. The

joint venture agreement included, among other provisions, the back-in right pursuant to which Medoro

had the right to increase to a 50% equity interest in Zandor within one year by paying 50% of all costs,

including acquisition costs, capital costs and the $3 million success fee paid by Gran Colombia Panama,

from the date of closing of the acquisition up to the date of the exercise of such option, plus a premium of

25% of such costs. As a result of the Medoro Merger as described below, the Company acquired the

remaining 5% interest in Zandor and the back-in right was cancelled as of June 10, 2011. For further

information see the heading entitled “Interest of Management and Others in Material Transactions”.

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On September 7, 2010, the Company announced that it had completed all the steps required to take

management and operational control of the mining assets of FGM. This followed a two-week mine

transition period set out for the liquidation and payment of severance of all former employees of FGM,

for the training of personnel, and for handing over of the operations to the Company. During the mine

transition period, no mining operations took place and the Company incurred costs of approximately

US$1.2 million, including those incurred through a vision care program offered to employees during this

period as part of the Company’s commitment to social initiatives. Mining operations resumed on

September 6, 2010 in all three acquired underground mining areas (El Silencio, Providencia and Sandra

K) located within the Segovia Project.

On June 10, 2011, the Company acquired all of the issued and outstanding securities of Medoro pursuant

to the Medoro Merger (see “General Development of the Business – 2011 – Medoro Merger” and

“General Development of the Business – Significant Acquisitions or Dispositions – Medoro Merger”), the

effect of which resulted in the Company acquiring Medoro’s 5% interest in Zandor, thereby increasing the

Company’s interest in Zandor from 95% to 100%.

Pursuant to the terms of the Frontino Acquisition Agreement, the liquidator responsible for the sale of the

FGM assets was required to use the proceeds from the disposition of the FGM assets, which were held in

an interest-bearing trust account, to fund unpaid and accrued pension liabilities estimated to amount to

approximately COP380,000,000,000. The assignment of these pension obligations to the ISS, a

governmental entity responsible for the administration and payment of the pension obligations, was

completed on March 11, 2011. On that date, the trust agent transferred COP364,922,530,792 to the ISS

and the balance of the funds in the trust account will be used by the liquidator to settle other liabilities of

FGM incurred prior to the Frontino Acquisition. The ISS has assumed responsibility for the

administration and payment of all remaining pension obligations to the former employees of FGM, and

Zandor has no further obligations in respect of these pensions. According to an amendment of the

Frontino Acquisition Agreement, if the assignment of pension obligations to the ISS was not completed

by the second month after the closing date of such acquisition, Zandor would fund monthly pension

payments to pensioners of FGM, until the assignment of such pension obligations to the ISS. From

August 2010 through March 2011, Zandor advanced additional funds from its own cash in the amount of

approximately US$5.3 million to fund monthly pension payments while the assignment of the pensions to

the ISS was in process. These advances are being recovered by Zandor through a reduction of 70% in its

quarterly “social contribution payments”, an obligation arising under the Frontino Acquisition Agreement

until the advances are fully recovered.

In addition, pursuant to the Frontino Acquisition Agreement, Zandor is obligated to make monthly health

contribution payments to the pensioners of FGM. The Company is responsible for paying approximately

COP165,000,000, or approximately US$87,000 per month, in respect of these remaining obligations.

Common Share Consolidation

Effective November 11, 2010, the Company consolidated its issued and outstanding Common Shares on a

one-for-four basis after receiving the requisite Board, regulatory and shareholder approvals.

Warrant Consolidation

Effective December 1, 2010, the Company consolidated its issued and outstanding Warrants on a one-for-

four basis after receiving the requisite Board and regulatory approvals.

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CIIGSA

On December 2, 2010, Gran Colombia Panama signed an agreement to acquire all of the shares of Nova

Partners International Corp., a Panamanian company which owned a 60% equity interest in CIIGSA. This

acquisition, which was completed at the end of December 2010, provides the Company with a controlling

interest in a fully permitted precious metals refining and smelting facility in Medellin, Colombia.

TSX Graduation

On December 22, 2010, the Company announced it had received approval by the TSX to be delisted from

the TSXV and to list the Common Shares and Warrants on the TSX. Trading commenced as of the

opening of the TSX on December 22, 2010 under the symbols “GCM” and “GCM.WT”, respectively.

4.3 2011

Operational and Exploration Update and Drilling Success of New Veins – January

On January 13, 2011, the Company announced an operational and exploration update and announced drill

success at two new veins at the Segovia Operations.

Assignment of Frontino Pension Liability

On March 13, 2011, the Company announced the successful assignment by FGM, the previous operator

of the Segovia Project, of its pension liability for its former employees to ISS, a governmental entity

responsible for the administration and payment of pension obligations.

The assignment of the FGM pension obligations to the ISS had been a material term of the acquisition of

the mining assets of FGM by the Company. However, at the time of the closing of the acquisition, ISS

had not completed the necessary calculations it required in order to formally accept the assignment of the

pension obligations. Accordingly, the Company had placed COP380 billion or approximately US$203

million, in a trust account pending completion of the assignment of the pension obligations. On March 11,

2011, the Company transferred COP365 billion or approximately US$202 million, to ISS and the balance

of the funds in the trust account will be used by the liquidator to fund costs and other expenses related to

the liquidation of FGM.

The ISS has now assumed responsibility for the administration and payment of all remaining pension

obligations to the former employees of FGM and the Company has no further obligations in respect of

these pensions.

Medoro Merger

On June 10, 2011, the Company completed the Medoro Merger. See “General Development of the

Business – Significant Acquisitions or Dispositions – Medoro Merger”, “Description of Capital Structure

– Warrants”, and “Market for Securities – Prior Sales”.

Note Offering

On July 8, 2011, the Company filed with the Canadian Securities Regulators in each of the provinces of

Canada, except Quebec, a preliminary short form prospectus, and a final prospectus on August 4, 2011, in

connection with the public offering of the Notes. A receipt for the final prospectus was granted by the

Ontario Securities Commission on August 5, 2011, and the transaction closed on August 11, 2011.

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The Notes, due on August 11, 2018, bear interest at a rate of 5.0% per year, payable semi-annually in

arrears in equal installments on December 31 and June 30 of each year. The first interest payment date

was on December 31, 2011 and consisted of interest accrued from and including the closing date of the

Note Offering. Holders of Notes will be entitled to receive the greater of (i) the principal amount of the

Note held, or (ii) the U.S. dollar financial equivalent to approximately 66.7 ounces of silver per Note, as

determined using the average realized silver price by the Company over the 6 month period immediately

prior to any repayment or redemption of principal, representing the US dollar financial equivalent of an

aggregate of five million ounces of silver. The quantity of silver per Note was determined using a notional

price of US$15 per ounce of silver, providing holders with the opportunity to benefit from silver prices in

excess of US$15 per ounce. The Company is naturally hedged against the silver price through its current

and anticipated silver production as a by-product to its gold mining operations and the development of the

significant silver resources at its 100% controlled Marmato project located in Colombia.

The Company, shall repay, on a pro rata basis, (a) 10% of the total principal amount of the Notes

outstanding on August 11, 2013, with such principal amount being repaid on the basis of the greater of (i)

10% of the total principal amount, and (ii) the US dollar financial equivalent to 6.67 ounces of silver per

Note, (b) 20% of the total principal amount of the Notes outstanding on August 11, 2016, with such

principal amount being repaid on the basis of the greater of (i) 20% of the total principal amount, and (ii)

the US dollar financial equivalent to 13.34 ounces of silver per Note, (c) 30% of the total principal

amount of the Notes outstanding on August 11, 2017, with such principal amount being repaid on the

basis of the greater of (i) 30% of the total principal amount, and (ii) the US dollar financial equivalent to

20.00 ounces of silver per Note, and (d) the remaining principal amount of the Notes on August 11, 2018

(being the maturity date) with such principal amount being settled on the basis of the greater of (i) the

balance of the principal amount of the Notes outstanding, and (ii) the US dollar financial equivalent to

approximately 26.67 ounces of silver, together in each case with all accrued and unpaid interest thereon to

the date of repayment.

See “Description of Capital Structure – Notes”. For full particulars of the Note Indenture, please refer to

the Note Indenture which can be accessed under the Company’s SEDAR profile at www.sedar.com.

Normal Course Issuer Bid – Notes

On August 25, 2011, the Company filed a Notice of Intention to commence a normal course issuer bid

with the TSX for its Notes, and later filed a revised Notice of Intention with the TSX on September 7,

2011. The Company received TSX approval for the bid on August 25, 2011.

Under the terms of the bid, the Company has the right to purchase for cancellation up to a maximum of

US$7,672,500 aggregate principal amount of Notes (representing approximately 10% of the public float

of the Notes issued and outstanding as of August 24, 2011, determined in accordance with the applicable

rules of the TSX) on the open market at any price in accordance with the terms of the Note Indenture.

Management of the Company is responsible for determining the actual number of Notes that may be

purchased and the timing of any such purchases, subject to compliance with applicable TSX rules. Daily

purchases are limited to US$1,000 principal amount of Notes, other than block purchase exceptions.

Purchases made pursuant to the bid will be made in the open market through the facilities of the TSX and

the price that the Company will pay for any such Notes will be the market price at the time of the

acquisition. The Company will not purchase Notes when the market price per Note exceeds US$1,000.

The bid commenced on August 29, 2011, and remains open until the earlier of August 28, 2012 or the

date on which the Company has purchased the maximum number of Notes permitted under the bid.

The Company is funding the repurchase of the Notes with the proceeds from the sale of its silver

production in order to capitalize on the current high market prices for silver. Under the normal course

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issuer bid, to December 31, 2011, the Company has repurchased 1,368 Notes at an average purchase price

of US$953.38 per Note. There have been no Notes repurchased subsequent to December 31, 2011 to the

date of this Annual Information Form.

Additional Drilling Results and Increase in Measured and Indicated Gold Resources at the Marmato

Project

On September 4, 2011, the Company announced a new NI 43-101 mineral resource estimate for its

Marmato Project containing 10.0 million ounces of gold in the Measured and Indicated categories and an

additional 2.4 million ounces of gold in the Inferred category at a cut-off grade of 0.3 g/t. In addition,

there are an estimated 64 million ounces of silver in the Measured and Indicated categories and a further

11 million ounces of silver in the Inferred category. This new in-pit mineral resource represents a 51%

increase in measured and indicated gold ounces and a 73% increase in measured and indicated silver

ounces compared to the previous mineral resources dated January 6, 2011 (filed on SEDAR).

In addition to this in-pit resource, SRK UK, which performed the mineral resource estimate, also

identified an underground mining resource of 2.1 million tonnes at a gold grade of 1.8 grams per tonne

representing 120,000 ounces of Measured and Indicated gold resources plus 6.4 million tonnes grading

2.3 g/t gold or 500,000 ounces of gold in the Inferred resource category.

These results are included and discussed in the Marmato Technical Report, a copy of which can be

accessed under the Company’s profile on SEDAR at www.sedar.com. See “Properties – Marmato

Project”.

Board Changes

On September 21, 2011, the Company announced the appointment of Mario Pacheco as a member of the

Board of the Company. The Company also announced the resignations of Jorge Neher, Courtney Neeb

Brewer, J. Randall Martin and Maria Consuelo Araujo from the Board in an effort to reduce the size of

the Board. Maria Consuelo Araujo remained as Chief Executive Officer of the Company.

Normal Course Issuer Bid – Common Shares

On September 27, 2011, the Company filed a Notice of Intention to commence a normal course issuer bid

with the TSX for its Common Shares listed on the TSX. The Company received TSX approval for the

bid on September 28, 2011.

Under the terms of the bid, the Company has the right to purchase for cancellation up to a maximum of

37,993,493 Common Shares through the facilities of the TSX (representing approximately 10% of the

public float of the Common Shares issued and outstanding as of September 23, 2011, determined in

accordance with the applicable rules of the TSX). Management of the Company is responsible for

determining the actual number of Common Shares that may be purchased and the timing of any such

purchases, subject to compliance with applicable TSX rules. Daily purchases are limited to 188,842

Common Shares, other than block purchase exceptions. Purchases made pursuant to the bid will be made

in the open market through the facilities of the TSX and the price that the Company will pay for any such

Common Shares will be the market price at the time of the acquisition.

The bid commenced on September 30, 2011, and remains open until the earlier of September 29, 2012 or

the date on which the Company has purchased the maximum number of Common Shares permitted under

the bid.

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The Company is funding the repurchase of the Common Shares with available cash balances and cash

generated through operations. Under the normal course issuer bid, the Company has repurchased

7,703,000 Common Shares during the financial year ended December 31, 2011 at a cost of $0.65 per

share. There have been no common shares repurchased subsequent to December 31, 2011 to the date of

this Annual Information Form.

Marmato Technical Report

In October 19, 2011, the Company announced that it had filed the Marmato Technical Report on SEDAR.

See “Properties – Marmato Project”.

Expansion at Segovia Operations and Related Financing

On December 12, 2011, the Company announced that it had retained GMP Securities L.P. to assist the

Company in the evaluation of several debt financing alternatives for the Company to fund mine and mill

expansion plans at its Segovia Operations. The project financing is intended to fund the Corporation’s

plan to increase production at its Segovia Operations through the development of a new mechanized

mining operation and the acquisition of a new 2,500 tpd mill in addition to the expansion of the Maria

Dama mill. Development of the new mining area is planned for completion in 2013 and the new 2,500

tpd mill is expected to be commissioned by the beginning of 2013.

In connection with the proposed expansion, on December 20, 2011, the Company signed the Mandate

Letter with Standard Bank in connection with the arrangement of the Facility to provide the funding for

the acquisition and installation of the new mill and mining and other equipment for the new mechanized

mining operation. Although the Mandate Letter had initially contemplated a potential closing date for the

Facility at the end of January 2012, the technical, environmental and other due diligence studies and

evaluations, many of which are being prepared by third party consultants, required by Standard Bank

have taken longer than anticipated to be completed. The Company is continuing to work with Standard

Bank on these matters in order to close the Facility as expeditiously as possible in order to commence

with this expansion project. The production guidance for the Segovia Operations in 2012 is not contingent

on the completion of this expansion project.

The Facility will provide for, among other things: (i) a gold participation program during the five year

term of the Facility whereby Standard will purchase 2,500 ounces of gold per month and participate in the

proceeds of selling the gold above US$1,300 per ounce; (ii) the Company will pay interest only on the

Facility during the first 12 months and will begin paying principal on a monthly basis at the beginning of

the second year of the Facility; and (iii) the Company will provide for certain security in connection with

the Facility.

Concepción Project Update

During the year ended December 31, 2011, the Company continued with its exploration program at the

Concepcion Project. Based on its evaluation of the findings through this work program, the Company

concluded that it would discontinue its efforts with this property and recorded a US$2.4 million write-

down in its financial results for the 2011 financial year representing all costs capitalized to-date.

4.4 Subsequent Developments

Update on Marmato Resettlement Progress

On January 9, 2012, the Company provided an update on the progress of the Marmato resettlement,

including the engagement of Social Capital Group, BSD Consultants and Replan (see “Description of the

Business – Social or Environmental Policies”). In order for the Company to build the open pit operation

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at Marmato, the existing town of Marmato will need to be moved and the existing residents re-settled to

nearby areas including the town of El Llano, approximately 1.5 km away. The exact number of people to

be resettled will be included in the Resettlement Action Plan, which was completed by Social Capital

Group in first quarter 2012. The Company regards the Marmato resettlement as an opportunity to

improve the livelihoods and the future development of the Marmato community and such planning is

being undertaken by the Company in strict accordance with international standards for resettlement as

recommended by the World Bank in their International Financing Corporation guidelines.

Miners’ Negotiations at the Marmato

On January 9, 2012, the Company announced that on November 28, 2011, the Secretary of the

Department of Caldas, Fernando Alvarez Hely Mejía, confirmed the Department’s commitment to assist

the Company in reaching an agreement with artisanal mines within the Company’s concession at the

Marmato Project, which negotiations are well underway.

At the Marmato Project, there are a few formal mining titles still to be acquired, as well as certain

artisanal miners which need to move their operations. The Company has entered into, has renegotiated,

and is in the process of, negotiating agreements with several artisanal miners at Alto El Burro,

Chaburquia, Echandia and Cieno Pesos. Under these agreements, the artisanal mines will continue to

operate for up to two years, at which time the Company anticipates commencing large scale mining at the

Marmato Project. The Company has also implemented an environmental and safety training program for

the artisanal miners, which will not only serve to immediately improve environmental and safety

conditions at Marmato, but will lay the groundwork for these artisanal miners to be available for

employment by the Company at its open-pit mine at Marmato once constructed.

The Company still has to negotiate with the remaining artisanal mines at Chaburquia, Echandia and Cien

Pesos, as well as with the remaining title-holders at Alto El Burro. The schedule for completion of this

work will largely depend on the recommended project layout and development timing presented in the

project’s pre-feasibility study.

Discovery of New, Deep Mineralization and Additional Drill Results at the Marmato Project

On January 9, 2012, the Company announced the discovery of a deep mineralization trend below the

current, preliminary pit outline at its Marmato Project, further highlighting the geological upside of this

project. Highlights from an additional 82 drill holes totalling 24,697 metres from the diamond drilling

program include hole MT-1455A which returned 1.4 grams per tonne (g/t) gold and 6.4 g/t silver over

357 metres and hole MT-1445, which returned 1.4 g/t gold and 2.3 g/t silver over 239 metres.

The current drilling has also produced a number of deep gold intersections, which include those

highlighted above, and which extend mineralization trends to approximately 300 metres below the limit

of the current preliminary pit outline. The deep mineralization is still open at depth and in all directions

except to the southwest. These deep intersections show that mineralization at the Marmato Project

extends for a vertical interval of more than 1,040 metres to the 560 metre level, and is open at depth.

Drilling on Las Aves Vein System at the Segovia Project

On January 24, 2012, the Company announced that it had completed a diamond drilling program

consisting of 86 diamond holes totaling 32,470 metres as of December 5, 2011, during the first phase of

exploration drilling at the Segovia Project. The first phase drilling campaign focused on defining new

resources by following the downward-plunge extension of the ore shoot in the Providencia Mine, and

tested a new vertical vein system which had never been drilled before, called the Las Aves Vein System,

on the western side of the property. Bonanza gold grades were intersected on both vein systems with

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maximum grades of 161 g/t Au and greater than 100 g/t Ag over 0.4 metres on the Providencia Vein, and

249 g/t Au with 162 g/t Ag over 0.4 metres on the Silencio Sur Vein, part of the Las Aves vein system.

Drilling on the Las Aves Vein System has confirmed a strike length of 3,500 metres and drilling was

carried out to 400 metres below surface. The vein is still open at depth. Some parallel veins such as Poma

Rosa were drilled, and in addition, there are a number of other veins parallel to the Las Aves Vein System

which have yet to be drilled. The southern continuation of the Silencio Vein was also drilled near its

intersection with Las Aves and returned grades up to 249.1 g/t Au over 0.4 metres.

New Mineral Resource Estimate – Segovia Operations

On March 5, 2012, the Company announced a new mineral resource estimate, prepared by SRK UK, for

its Segovia Operations containing 233,000 ounces of gold in the Measured and Indicated categories and

an additional 1.08 million ounces of gold in the Inferred category at a cut-off grade of 3.0 g/t Au. This

mineral resource represents a 76% increase in measured and indicated gold ounces compared to the

previous mineral resources dated June 9, 2010 (prepared by Scott E. Wilson, C.P.G., the Measured and

Indicated categories were calculated at a cut-off grade of 7.1 g/t Au), and includes an update of the

resource of the Providencia, El Silencio and Sandra K mines as well as initial resource estimates for the

Las Aves Vein System, which make up the Company’s Segovia Operations.

The estimate has been reported according to CIM Standards and will be supported by a NI 43-101

independent report which will be published and filed on the Company's website and SEDAR profile by

April 12, 2012.

4.5 2012 Outlook

The Company’s focus in 2012 will be to continue to: (i) increasing total annual gold production to a total

of approximately 155,000 ounces, which includes production growth to approximately 130,000 oz Au at

the Segovia Operations made possible by the completion of the expansion of the existing Maria Dama

Plant; (ii) continuing to take the actions necessary to reduce the cash production costs on a per ounce

basis at the Company’s operated mines in the Segovia Operations; (iii) completing the pre-feasibility

study with respect to the Marmato Project to determine the most suitable plan for the development and

financing of the new mine operations; (iv) obtaining the financing to fund the Company’s expansion plan

at its Segovia Operations through the development of a new mechanized mining operation and the

acquisition of a new 2,500 t/d mill; (v) commencing a 60,000m diamond drilling exploration program at

the Segovia Operations to upgrade and expand its resources; (vi) continuing with the evaluation of the

resettlement action plan in connection with the Marmato resettlement; and (vii) commencing the re-

organization of the Company’s subsidiaries as described herein.

On September 16, 2011, the Venezuelan government issued a Decree-Law nationalizing gold exploration

and mining operations in the Country, including a minimum state equity participation of 55% in gold

projects, a new 13% royalty, and the banning of export sales by producers. The Company has tried to

engage the Venezuelan Government with respect to negotiations for the Company’s properties in

Venezuela for pricing and transfer of ownership of the nationalized portion of the projects. As the

prescribed negotiations period has expired, the Company intends to pursue the remedies afforded to it by

the Agreement between Venezuela and Canada for the Promotion and Protection of Investments (which

has been in force since 1998), including, if warranted, seeking such compensation through international

arbitration. See “Risk Factors – Economical and Political Factors – Venezuela”.

The Company will also continue to seek interested parties to complete the disposition of its interests in

the Mali exploration properties or explore other alternative transactions.

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4.6 Significant Acquisitions or Dispositions

Except for the Medoro Merger described below and elsewhere herein, the Company has not completed

any significant acquisitions or dispositions during the financial year ended December 31, 2011 for which

disclosure is required under Part 8 of National Instrument 51-102 – Continuous Disclosure Obligations.

Medoro Merger

On April 13, 2011, the Company announced that it entered into the Medoro Arrangement Agreement in

connection with the Medoro Merger. Pursuant to the Medoro Merger, the Company and Medoro merged

to form a single corporation continuing under the name “Gran Colombia Gold Corp.” The arrangement

was effected pursuant to section 195 of the YBCA through the Medoro Arrangement Agreement and the

Medoro Plan of Arrangement involving a Yukon incorporated wholly-owned subsidiary of the Company

(the merged subsidiary being Medoro Yukon). The transaction was approved at meetings of the

securityholders of the Company and Medoro held on June 7, 2011, respectively, and the Company also

received the applicable approvals from the Supreme Court of Yukon and the TSX in connection with the

Medoro Merger which subsequently closed and took effect on June 10, 2011.

Under the terms of the Arrangement Agreement, each Medoro shareholder received 1.20 Common Shares

plus a Gran Colombia Consideration Warrant for each Medoro share held. Each Gran Colombia

Consideration Warrant was issued under the Warrant Indenture. Holders of Medoro options and Medoro

warrants had their securities converted into Gran Colombia securities and on exercise will obtain

Common Shares and warrants on an equivalent basis. No fractional Common Shares or Warrants were

issued and holders otherwise entitled to a fractional interest in a Common Share or Warrant received the

nearest whole number of Common Shares or Warrants with all such fractions being rounded down. See

“Description of Capital Structure – Warrants”, and “Market for Securities – Prior Sales”.

Upon completion of the merger, existing Gran Colombia and Medoro shareholders each owned

approximately 50% of the combined company, on a fully diluted basis. As at the date thereof, the

Company had 389,686,629 Common Shares, 194,438,146 Warrants and 27,744,591 Options (excluding

compensation options) issued and outstanding, of which former Medoro securityholders had received

172,886,495 Common Shares and 72,035,656 Warrants as consideration.

As a result of the Medoro Merger, the Company acquired 100% of Medoro’s interest in the Marmato

Project and Medoro’s 5% interest in Zandor.

The Company filed a Business Acquisition Report on SEDAR in connection with its acquisition of

Medoro on July 7, 2011.

5 DESCRIPTION OF THE BUSINESS

5.1 Summary

The Company is a Canadian-based gold and silver exploration and development company focused on

acquiring, developing and operating properties of merit to bring to production, with a primary emphasis

on Colombia. The Company holds 100% of the former FGM gold and silver assets, including the largest

underground gold and silver mining operation in Colombia, being the Segovia Operations. It also owns

the rights to interests in the Marmato Project, which it acquired in connection with the Medoro Merger,

which includes the Zona Alta Property, the Zona Baja Property and the Echandia Property, and operates

the producing Mineros Nacionales Mine located in Zona Baja in Marmato. These individual properties in

Marmato are held under different licenses but are contiguous and are all part of the same geological

system. It also owns several other exploration projects in Colombia. The Company is committed to

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implementing its exploration and development strategy with a comprehensive environment, safety and

community program, meeting international standards of best practice.

The Company also holds a 100% interest in the Lo Increíble Properties in Venezuela which it acquired in

connection with the Medoro Merger. Initial mineral resources based on limited diamond drilling have

identified 13.4 million tonnes grading 2.2 g/t, or 940,000 ounces of open pittable gold. On September 16,

2011, the Venezuelan government issued a Decree-Law nationalizing gold exploration and mining

operations in the Country, including a minimum state equity participation of 55% in gold projects, a new

13% royalty, and the banning of export sales by producers. The Company has tried to engage the

Venezuelan government with respect to negotiations for the Company’s properties in Venezuela for

pricing and transfer of ownership of the nationalized portion of the projects. As the prescribed

negotiation period has expired, the Company intends to pursue the remedies afforded to it by the

Agreement between Venezuela and Canada for the Promotion and Protection of Investments (which has

been in force since 1998), including, if warranted, seeking such compensation through international

arbitration. See “Risk Factors – Economical and Political Factors – Venezuela” and “Material Contracts”.

In Mali, the Company currently owns the rights to four gold exploration properties, Kangare, Samaya,

Batanko and Sindo, of which the Company is currently in the process of renewing the Sindo permit.

Three of the licenses are located in the gold-bearing Bougouni region in southern Mali, on the West

African craton. The licenses are Sindo, Kangare and Samaya, Naiouleni. The other license area,

Bantanko, is located in the west of Mali, in the Keneiba window portion of the West African craton. The

Company has ceased funding exploration activities on the Mali properties, while it seeks interested parties

to complete a disposition of its interests in these properties. These rights were acquired by the Company

in connection with the Medoro Merger.

The Company’s business activities are directed from its offices in Toronto, Ontario (333 Bay Street, Suite

1100), Bogota and Medellin, Colombia.

5.2 Production

The Company’s principal product is gold. In addition to gold, the Company also produces silver.

Although there exists worldwide gold and silver markets into which the Company can sell, the Company

is dependent on a particular purchaser located in Colombia with regard to the sale of minerals which it

produces at the Segovia Operations and the Mineros Nacionales Mine at Marmato. The Company sells its

gold and silver production through CIIGSA to international buyers. CIIGSA currently does not enter into

any derivative financial instruments in respect of these sales activities.

5.3 Segovia Operations

2010

For the period from incorporation on January 4, 2010 to December 31, 2010, the Company produced

14,509 ounces of gold, including 1,187 ounces produced by small (contract) miners at the Segovia

Operations. During the same period in 2010, the Company sold 14,071 ounces of gold at an average

realized price of US$1,385 per ounce. Total cash cost (on a by-product basis) averaged US$1,295 per

ounce of gold sold and total production cost, including depreciation and depletion, averaged US$1,537

per ounce of gold sold.

2011

For the year ended December 31, 2011, the Company produced 68,704 ounces of gold and 64,633 ounces

of silver, including 29,272 ounces of gold produced by artisanal (contract) miners at the Segovia

Operations. During the same period in 2011, the Company sold 69,115 ounces of gold and 60,836 ounces

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of silver at an average realized price of US$1,582 per ounce and US$US$31 per ounce, respectively.

Total cash cost (on a by-product basis) averaged US$1,288 per ounce of gold sold for the full year but

was lower in the fourth quarter at US$1,128 due to initiatives implemented in September.

2012

The Company expects its 2012 gold production from its Segovia Operations to be approximately 130,000

ounces and its silver production to be approximately 108,000 ounces. The Company expects that

increased productivity and tonnes mined in 2012 will reduce the cash cost at the Company-operated

mines below $1,000 per ounce of gold produced. The cash cost per ounce of gold produced by the

artisanal miners is tied to market prices for gold and is expected to be between US$1,100 and US$1,200

per ounce at current market prices of US$1,600 – US$1,700 per ounce. See “Forward-Looking

Information” and “Risk Factors”.

5.4 Marmato Operations

2010

For the year-ended December 31, 2010, the Company produced 20,426 and 32,556 ounces of silver at its

Mineros Nacionales Mine, at a weighted average price of US$1,244.90 per ounce of gold and weighted

average price of US$20.53 per ounce of silver. The average total cash costs were US$1,010.61 per ounce

of gold and silver combined. Total revenue from the sale of gold and silver combined in 2010 was

US$27,141,858.

2011

For the year ended December 31, 2011, the Company produced 22,715 ounces of gold and 35,117 ounces

of silver at its Mineros Nacionales Mine. During the same period in 2011, the Company sold 22,217

ounces of gold and 35,120 ounces of silver at an average realized price of US$1,481.53 per ounce and

US$33.06 per ounce, respectively. Total cash cost (on a by-product basis) averaged US$1,093.00 per

ounce of gold sold. Total revenue from the sale of gold from the Mineros Nacionales Mine in 2011 was

US$33,656,000, and US$1,161,000 from the sale of silver.

2012

The Company expects its 2012 gold production from its Mineros Nacionales Mine to be at approximately

25,000 ounces and its silver production to be approximately 36,000 ounces. It is expected that cash costs

of the gold produced will be similar to 2011. See “Forward-Looking Information” and “Risk Factors”.

5.5 Exploration

The Company has interests in several exploration properties in Colombia, being the El Zancudo Project,

the Segovia Operations, the Concepción Project and the Mazamorras Project (all of which were acquired

during 2010), and the Zona Alta and Echandia Property (which were acquired in October 2009 and

January 2010, respectively). In 2011, exploration activities continued at these properties; however

exploration ceased at the Concepción Project due to the lack of promissory drilling results. The

Company’s total exploration spending for these properties in 2011 was US$28 million.

The Company also has exploration properties in Venezuela and Mali. Exploration activities have been

suspended in Mali due to a change in focus of the Company. The Company has also suspended

exploration activities at the Lo Increíble Properties due to the Venezuelan government issuing a Decree-

Law nationalizing gold exploration and mining operations in the Country, including a minimum state

equity participation of 55% in gold projects, a new 13% royalty, and the banning of export sales by

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producers. See “Description of the Business – Summary” and “Risk Factors – Economical and Political

Factors – Venezuela”.

5.6 Specialized Skill and Knowledge

Operations in the gold exploration and development industry mean that the Company requires

professionals with skills and knowledge in diverse fields of expertise. In the course of its exploration,

development, and operations, the Company requires the expertise of drilling engineers, exploration

geophysicists and geologists and employs, directly and indirectly, such persons. To date, the Company

has not experienced any difficulties in hiring and retaining the professionals and experts it requires for its

operations and has found that it can locate and retain such employees and consultants and believes it will

continue to be able to do so. Further information is provided under the heading entitled “Risk Factors –

Shortage of Experienced Personnel and Equipment.”

5.7 Competitive Conditions

The precious metal mineral exploration and mining business is a competitive business. The Company

competes with numerous other companies and individuals in the search for and the acquisition of

attractive precious metal mineral properties. The ability of the Company to acquire precious metal

mineral properties in the future will depend not only on its ability to develop its present properties, but

also on its ability to select and acquire suitable producing properties or prospects for precious metal

development or mineral exploration. Although there is currently a high level of acquisition activity in

Colombia, the Company is well positioned in Colombia due to its successful acquisition of the Projects,

including the successful consolidation of the Marmato Project. Further information is provided under the

heading entitled “Risk Factors - Competition”.

5.8 Employees

As at the date hereof, the Company and its subsidiaries had seven employees at its head office in Toronto,

Canada, approximately 2,067 employees in Colombia, six employees in Venezuela and four employees in

Mali.

5.9 Foreign Operations

The Company’s material property interests are located in Colombia, and the Company also has property

interests in Venezuela and Mali. The Company’s activities in foreign jurisdictions may be affected by

possible political or economic instability and government regulations relating to the mining industry and

foreign investors therein. The risks created by this potential political and economic instability include, but

are not limited to: extreme fluctuations in currency exchange rates and high rates of inflation. Changes in

exploration or investment policies or shifts in political attitude in such jurisdictions may adversely affect

the Company’s business. Mineral exploration and mining activities may be affected in varying degrees by

government regulations with respect to restrictions on production, price controls, export controls, income

taxes, expropriation of property, maintenance of property, environmental legislation, land use, land claims

of local people, water use and property safety. The effect of these factors on the Company cannot be

accurately predicted. Further information is provided under the heading entitled “Risk Factors”.

5.10 Business Cycles

The mining business is subject to mineral price cycles. The marketability of minerals and mineral

concentrates is also affected by worldwide economic cycles. The Company’s operations are related and

sensitive to the market price of gold and, to a lesser degree, to other metal prices such as silver. Metal

prices fluctuate widely and are affected by numerous factors such as global supply, demand, inflation,

exchange rates, interest rates, forward selling by producers, central bank sales and purchases, production,

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global or regional political, economic or financial situations and other factors beyond the control of the

Company. Further information is provided under the heading entitled “Risk Factors – Metal Price

Volatility”.

5.11 Environmental Protection

The mining industry in Colombia is subject to environmental laws and regulations under varied

governmental legislation relating to the protection of the environment, including requirements for closure

and reclamation of mining properties. Compliance with such obligations and requirements can mean

significant expenditures and/or may constrain the Company’s operations in the country. Breach of

environmental obligations could lead to suspension or revocation of requisite environmental licenses and

permits, civil liability for damages caused and the possible fines and penalties, all of which may

significantly and negatively impact the Company’s position and competitiveness. Further information is

provided under the heading entitled “Risk Factors – Changes to Environmental Laws”.

As the many of the Company’s projects are currently in the exploration stage, the financial and

operational effects of environmental protection requirements are currently difficult to gauge. The

Company will have a better sense of these effects once it completes the revision of the Environmental

Management Plan at its Segovia Operations and the baseline environmental studies and Environmental

and Social Impact Assessment (ESIA) at its Marmato Project and once such plans have been submitted

and approved by the environmental authorities according to the applicable guidelines.

In addition, since the beginning of the Segovia Operations, the Company has promoted implemented

initiatives to improve the environmental performance of such operations. As part of this process, the

Company retained the Environmental Studies Institute for Development (IDEADE by its Spanish

acronym) of the Pontifical Javeriana University to update the current Environmental Management Plan.

The update seeks to address the need to improve the environmental performance of the exploitation and

supplementary activities at the Segovia Operations and was drafted in accordance with the General

Methodology for Submission of Environmental Studies, which is a guideline of The Ministry of

Environment, Housing and Territorial Development, and will be filed before the environmental authority

in April, 2012.

5.12 Social or Environmental Policies

The Company has established guidelines and management systems to comply with the laws and

regulations of Colombia, Venezuela, Mali and other countries in which it may operate. The Company has

dedicated employees responsible for all matters affecting the environment and local municipalities. While

the Company endeavours to meet all of its environmental obligations, it cannot guarantee that it has and

will be in compliance at all times. Nonetheless, management believes that operations are in substantial

compliance with all material Colombian, Venezuelan and Malian environmental laws and regulations;

however, it cannot assure that any artisanal miners operating on its properties are in compliance with such

laws and regulations.

In addition, the Company has recently instituted social awareness and responsibility programs, specific to

the areas in which it operates, which are carried out by employees in Colombia. The Company’s social

workers attend in the various municipalities where it operates to determine a community’s needs and

formulates the Company’s programs to the requirements of a particular area. The Company is

implementing human rights policies for the Marmato Project in accordance with the Free Trade

Agreement signed between Canada and Colombia.

In connection with the resettlement of the town of Marmato, Gran Colombia has hired Social Capital

Group to conduct a socio-economic analysis of the communities potentially affected by development of

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the Marmato Project, as well as a community census and to deliver a Resettlement Action Plan in

accordance with World Bank standards for involuntary resettlement. In addition, BSD, a Switzerland-

based consulting group with offices in Colombia, which has broad experience in implementing corporate

responsibility and sustainable development projects within Colombia, has been retained to advise the

Company on land purchases and the design, management and implementation of a sustainable urban

development plan for the resettlement of the Marmato community. The Company has also engaged

Replan, to perform an audit on all processes for the resettlement of Marmato and to provide

recommendations to the Company based on such audit.

Gran Colombia continually re-affirms its commitment to social responsibility initiatives in Marmato, and

in 2011 contributed approximately US$2 million to the town and its surrounding area, to be used to fund

Phase II construction of the El Llano Hospital, the construction of an administrative centre and other

community projects. Through its Mineros Nacionales Mine, Gran Colombia already pays royalties of

between 0.4% and 4% to the national government and a 6% special administrative fee for certain of its

mining titles payable to the local authorities in Marmato, totaling US$3,002,741 alone for the financial

year ended December 31, 2011. The Company, as it has done for the social development of the Segovia

district, also intends to establish a special purpose foundation, funded out of production from the

Marmato Project, the sole purpose of which will be the improvement of social conditions in the Marmato

district.

Finally, Gran Colombia has also become a member of CBSR, which is the Canadian representative in a

world-wide network committed to corporate social responsibility, and which will assist Gran Colombia

by providing key findings, opportunities and recommendations to our policies and programs, to ensure

that they are all to international standards and guidelines.

6 RISK FACTORS

The business and operations of the Company will be subject to a number of risks. The Company

considers the risks set out below to be the most significant to potential investors in the Company, but not

all of the risks associated with an investment in securities of the Company. If any of these risks

materialize into actual events or circumstances or other possible additional risks and uncertainties of

which the Company is currently unaware or which it considers to be material in relation to the Company’s

business actually occur, the Company’s assets, liabilities, financial condition, results of operations

(including future results of operations), business and business prospects, are likely to be materially and

adversely affected. In such circumstances, the price of the Company’s securities could decline and

investors may lose all or part of their investment.

Metal Price Volatility

The Company’s business is strongly affected by the world market price of gold and, to a lesser extent,

silver. If the world market price of gold or silver were to drop and the prices realized by the Company on

gold or silver sales were to decrease significantly and remain at such a level for any substantial period, the

Company’s profitability and cash flow would be negatively affected.

Gold and silver prices can be subject to volatile price movements, which can be material and can occur

over short periods of time and are affected by numerous factors, all of which are beyond the Company’s

control. Industry factors that may affect the price of gold include: industrial and jewellery demand; the

level of demand for gold as an investment; central bank lending, sales and purchases of gold; speculative

trading; and costs of and levels of global gold production by producers of gold. Gold prices may also be

affected by macroeconomic factors, including: expectations of the future rate of inflation; the strength of,

and confidence in, the U.S. dollar, the currency in which the price of gold is generally quoted, and other

currencies; interest rates; and global or regional, political or economic uncertainties.

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The effect of these factors on the price of precious metals, and therefore the economic viability of any of

the Company’s exploration and operation projects, cannot be accurately determined. As such, the

Company may determine that it is not economically feasible to continue commercial production at some

or all of its operations or the development of some or all of the Projects, as applicable, which could have

an adverse impact on the Company’s financial performance and results of operations. In such a

circumstance, the Company may also curtail or suspend some or all of its exploration activities, with the

result that depleted reserves are not replaced. In addition, the market value of the Company’s gold

inventory may be reduced and existing reserves may be reduced to the extent that ore cannot be mined

and processed economically at the prevailing prices.

Future Production Rates

The figures for the Company’s future production are estimates based on interpretation and assumptions

and actual production may be less than is currently estimated. The Company prepares estimates of future

gold and silver production for its operating mines. The Company cannot give any assurance that it will

achieve its production estimates. The failure of the Company to achieve its production estimates could

have a material and adverse effect on any or all of its future cash flows, profitability, results of operations

and financial condition. The Company’s mineral properties’ ability to demonstrate sufficient economic

returns will also affect the availability and cost of financing. These production estimates are dependent

on, among other things, the accuracy of mineral reserve estimates, the accuracy of assumptions regarding

ore grades and recovery rates, ground conditions, physical characteristics of ores, such as hardness and

the presence or absence of particular metallurgical characteristics and the accuracy of estimated rates and

costs of mining and processing.

The Company’s actual production may vary from its estimates for a variety of reasons, including: actual

ore mined varying from estimates of grade, tonnage, dilution and metallurgical and other characteristics;

short-term operating factors such as the need for sequential development of ore bodies and the processing

of new or different ore grades from those planned; mine failures, slope failures or equipment failures;

industrial accidents; natural phenomena such as inclement weather conditions, floods, droughts, rock

slides and earthquakes; encountering unusual or unexpected geological conditions; changes in power

costs and potential power shortages; shortages of principal supplies needed for operation, including

explosives, fuels, chemical reagents, water, equipment parts and lubricants; labour shortages or strikes;

civil disobedience and protests; and restrictions or regulations imposed by government agencies or other

changes in the regulatory environments. Such occurrences could result in damage to mineral properties,

interruptions in production, injury or death to persons, damage to property of the Company or others,

monetary losses and legal liabilities. These factors may cause a mineral deposit that has been mined

profitably in the past to become unprofitable forcing the Company to cease production. It is not unusual in

new mining operations to experience unexpected problems during the start-up phase. Depending on the

price of gold, silver or other minerals, the Company may determine that it is impractical to commence or,

if commenced, to continue commercial production at a particular site.

There is no assurance that the mine will produce enough silver to cover the Company’s obligations under

the Notes. However, as the Notes are linked to, but not backed by silver, the failure to achieve production

of 5.3 million ounces of silver does not in and of itself mean that the Company will not have other sources

of cash, whether from gold production or otherwise, to make its required payments under the Notes;

however, there can be no assurance that the Company will have such alternative sources of cash. Failure

to generate sufficient cash could result in the Company’s payment obligations under the Notes not being

met.

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Financing Risks

Additional funding may be required to complete the funding of the proposed or future exploration and

operational programs on the interests in the Projects and to conduct any other exploration programs, as

well as to complete the Marmato Project and the proposed expansion of the Company’s Segovia

Operations. There is no assurance that any such funds will be available. Failure to obtain additional

financing, if required, on a timely basis or on favourable terms, could cause the Company to reduce or

delay its proposed operations.

While the Company has been successful in the past in obtaining equity financing to undertake its planned

exploration and development programs, there is no assurance that it will be able to obtain adequate

financing in the future or that such financing will be on terms advantageous to the Company. Also, any

additional equity financing might involve substantial dilution to existing shareholders.

The Company has outstanding indebtedness and may incur additional indebtedness in the future,

including by way of debentures, additional notes, and/or credit facilities. A portion of the cash flow

generated by properties owned by the Company will be devoted to servicing such debt and there can be

no assurance that the Company will continue to generate sufficient cash flow from operations to meet the

required interest and principal payments on the debt.

History of Losses

The Company has a history of losses and there can be no assurance that it will ever be profitable.

Although the Segovia Operations and the Mineros Nacionales Mine are in operation, the Company

expects to continue to incur losses unless and until such time as it develops and commences larger scale

mining at the Segovia Operations or the Marmato Project or it develops and commences mining

operations at the other Projects. The development of the Projects will require the commitment of

substantial financial resources. The amount and timing of expenditures will depend on a number of

factors, some of which are beyond the Company’s control, including the progress of ongoing exploration,

studies and development, the results of consultant analysis and recommendations, the rate at which

operating losses are incurred and the execution of any joint venture agreements with any strategic

partners, if any. There can be no assurance that the Company will ever achieve profitability.

Going Concern

To continue as a going concern, the Company must generate profitable operations in the future through its

planned capital investments and expected resultant increase in mineral production and development or

continue to secure new funding. While the Company has cash balances and cash flow from production,

these may not be sufficient to fund the Company’s planned capital investment program and working

capital requirements. As such, it may need to pursue credit facilities or delay discretionary expenditures

which may have an impact on the rate of future growth in its expected mineral production. There can be

no assurance that these initiatives will be successful. These circumstances lend significant doubt as to the

ability of the Company to meet its business plan and obligations as they come due.

Current Global Markets and Economic Conditions

Current global financial conditions have been characterized by volatility and several financial institutions

have either gone into bankruptcy or have had to be rescued by governmental authorities. Access to

financing has been negatively impacted by many factors as a result of the global financial crisis. This

may impact the Company’s ability to obtain equity or debt financing in the future on terms favourable to

the Company. Additionally, global economic conditions may cause decreases in asset values that are

deemed to be other than temporary, which may result in impairment losses. If such volatility and market

turmoil continue, the Company’s operations and financial condition could be adversely impacted.

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To the extent the Company relies on the capital markets for necessary capital expenditures, the

businesses, financial condition and operations of the Company could be adversely affected by: (i)

continued disruption and volatility in financial markets; (ii) continued capital and liquidity concerns

regarding financial institutions generally and hindering the Company’s counterparties specifically; (iii)

limitations resulting from governmental action in an effort to stabilize or provide additional regulation of

the financial system; or (iv) recessionary conditions that are deeper or last longer than currently

anticipated.

Exploration, Development and Operations

Exploration and development of mineral deposits involves a high degree of risk which even a

combination of careful evaluation, experience and knowledge may not eliminate. Few properties which

are explored are ultimately developed into producing properties. Although the mineral resource figures

set out herein have been carefully prepared and reviewed or verified by an independent qualified person,

these amounts are estimates only and no assurance can be given that an identified mineral resource will

ever become a mineral reserve or in any way qualify as a commercially mineable (or viable) ore body

which can be legally and economically exploited. Estimates of mineral resources and any potential

determination as to whether a mineral deposit will be commercially viable can also be affected by such

factors as: deposit size, grade, unusual or unexpected geological formations and metallurgy; proximity to

infrastructure; metal prices which are highly cyclical; environmental factors; unforeseen technical

difficulties; work interruptions; and government regulations, including regulations relating to permitting,

prices, taxes, royalties, land tenure, land use, importing and exporting of minerals and environmental

protection. The exact effect of these factors cannot be accurately predicted.

The long term profitability of the Company’s operations will be in part directly related to the cost and

success of its exploration programs, which may be affected by a number of factors. Substantial

expenditures are required to establish reserves through drilling, to develop processes to extract the

resources and, in the case of new properties, to develop the extraction and processing facilities and

infrastructure at any site chosen for extraction. Although substantial benefits may be derived from the

discovery of a major deposit, no assurance can be given that any such deposit will be commercially viable

or that the funds required for development can be obtained on a timely basis.

Mining operations generally involve a high degree of risk. The Company’s operations are subject to all

the hazards and risks normally encountered in the exploration, development and production of gold and

silver, including unusual and unexpected geologic formations, seismic activity, rock bursts, cave-ins,

flooding and other conditions involved in the drilling and removal of material, any of which could result

in damage to, or destruction of, the mine and other producing facilities, damage to life or property,

environmental damage and possible legal liability. Although appropriate precautions to mitigate these

risks are taken, operations are subject to hazards such as equipment failure or failure of structures which

may result in environmental pollution and consequent liability. Even though the Company intends to

obtain liability insurance in an amount which it considers adequate, the nature of these risks is such that

liabilities might exceed policy limits, the liabilities and hazards might not be insurable, or the Company

might not elect to insure itself against such liabilities due to high premium costs or other reasons, in

which event the Company could incur significant costs that could have a material adverse effect upon its

financial condition.

Risks with Title to Mineral Properties

The Company does not maintain insurance against title. Title on mineral properties and mining rights

involves certain inherent risks due to the difficulties of determining the validity of certain claims as well

as the potential for problems arising from the frequently ambiguous conveyance history of many mining

properties. The Company has diligently investigated and continues to diligently investigate and validate

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title to its mineral claims; however, this should not be construed as a guarantee of title. The Company is

continuously in the process of establishing the certainty of the title of mineral concessions which it holds

either directly or through its equity interest in its subsidiaries or will be seeking to consolidate those titles

through a government-sanctioned process. The Company cannot give any assurance that title to

properties it acquired individually or through historical share acquisitions will not be challenged or

impugned and cannot guarantee that the Company will have or acquire valid title to these mining

properties. For example, there is theoretically a risk that the Colombian government may, in the future,

grant additional titles in excess of the Company’s expectations to small miners currently illegally mining

on the Company’s properties or the Company may be unable to convince currently illegal miners to

vacate the Company’s properties. Mechanisms exist to integrate into the Marmato Project the titles of

legal mineral properties in the Zona Alta (at Marmato) currently not owned by the Company. However,

there is a risk that this process could be time-consuming and costly. As the Company begins the processes

of integration, the costs of acquiring the remaining properties and associated surface rights could rise

significantly or become cost-prohibitive. Furthermore, the risk exists that one or more of the remaining

titleholders could delay the integration process through administrative avenues. The possibility also exists

that title to existing properties or future prospective properties may be lost due to an omission in the claim

of title, or by the Company’s inability to honour its contractual purchase obligations. Most of the mining

titles have a remaining duration which is shorter than the term required to develop and execute the mining

project described in the Marmato Technical Report. Mining titles generally allow for renewals and the

Company has no reason to expect that renewals will not be granted in the normal course; however, the

Company cannot give assurances that title to its mining properties will be renewed, as required to

complete the Marmato Project.

On January 23, 2012, the Minister of Mines (Colombia) announced that it will commence a public tender

to commence the legal and technical audit all exploration and exploitation licenses in Colombia, with the

contract being awarded on April 17, 2012. The audit process will take approximately 30 months. As a

result of the auditing to be carried out by the successful contractor, the Minister of Mines (Colombia) has

stated that titles may be cancelled or fines may be imposed if the audit shows that the applicable law has

not been or is not being complied with by mining companies. Although the Company believes that it is in

substantial compliance in all material respects with applicable material laws and regulations in Colombia,

the Company cannot assure that the results of the audit will not result in further inquiry or actions taken

by the Minister of Mines (Colombia).

Resettlement of the Town of Marmato

The Company’s business plan includes an open pit mine at its Marmato Project. As such, the town of

Marmato must be relocated from its current location on the Marmato Mountain to a safer location. While

the Company is currently working with municipal, departmental (i.e., state), and federal governments to

facilitate this relocation, as well as engaging directly with the community, it is subject to the risk of

political, economic, or social circumstances that could delay the Company’s ability to complete the town

relocation. If the Company is unable to complete the town relocation, the Company’s plans for an open

pit mine at its Marmato Project could be affected and, if so, the Company may review other available

mining methods for its project.

Environmental Permits

The development, construction and operation of the Marmato Project will require the completion of a

detailed environmental impact study and subsequent environmental licensing and other environmental

permits or concessions by the competent environmental authorities. Due to the complexity of the project

and of its area of influence, required environmental permits, licenses or concessions may take time and/or

be difficult to obtain or to be issued on the terms required by the Company.

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Liquidity Risks

Liquidity risk is the risk that the Company will not be able to meet its financial obligations as they fall

due. The Company’s approach to managing liquidity is to ensure that it will have sufficient liquidity to

meet its liabilities when due. To the extent that the Company does not believe it will have sufficient

liquidity to meet these obligations, management will consider securing additional funds through equity or

debt transactions. The Company manages its liquidity risk by continuously monitoring forecast cash flow

requirements. The Company’s is currently funding the expansion of the existing Maria Dama mill and the

exploration program at the Segovia Operations, as well as the completion of the Marmato Project through

the pre-feasibility stage, from cash balances and cash generated by its producing mine operations. The

Company intends to secure funding through debt transactions for its planned expansion of the Segovia

Operations and the development of its Marmato Project, including completion of the feasibility stage,

design and construction, acquisition of mining, processing and other equipment and completion of its

obligations with respect to the acquisition of mining titles and other social programs.

Operating History in Colombia

Although the Company has a limited operating history in Colombia upon which an evaluation of its future

success or failure can be made, the Company retained most of the employees and management teams of

FGM and Medoro (including the subsidiaries acquired by Medoro in 2009 and 2010), and has hired

qualified consultants with extensive experience in mining operations, both in and outside of Colombia.

The Company has earned revenues from its current Colombian operations but there can be no guarantees

that revenues or profits will be earned from Colombian operations in the future.

Mining Risks and Insurance Risks

The mining industry is subject to significant risks and hazards, including environmental hazards,

industrial accidents, unusual or unexpected geological conditions, labour force disruptions, civil strife,

unavailability of materials and equipment, weather conditions, pit wall failures, rock bursts, cave-ins,

flooding, seismic activity, water conditions and gold bullion losses, most of which are beyond the

Company’s control. These risks and hazards could result in: (i) damage to, or destruction of, mineral

properties or producing facilities; personal injury or death; environmental damage; (ii) delays in mining;

and (iii) monetary losses and possible legal liability. As a result, production may fall below historic or

estimated levels and the Company may incur significant costs or experience significant delays that could

have a material adverse effect on the Company’s financial performance, liquidity and results of operation.

The Company maintains insurance to cover some of these risks and hazards. The insurance is maintained

in amounts that are believed to be reasonable depending on the circumstances surrounding each identified

risk. No assurance can be given that such insurance will continue to be available, or that it will be

available at economically feasible premiums, or that the Company will maintain such insurance. The

Company’s property, liability and other insurance may not provide sufficient coverage for losses related

to these or other risks or hazards. In addition, the Company does not have coverage for certain

environmental losses and other risks, as such coverage cannot be purchased at a commercially reasonable

cost. The lack of, or insufficiency of, insurance coverage could adversely affect the Company’s cash flow

and overall profitability.

Integration Risks

The success of the Company will depend in large part on the success of integrating the operations,

technologies and personnel of Medoro (which was acquired in 2011) with those of the Company. The

failure of the Company to achieve such integration could result in the failure of the Company to realize

any of the anticipated benefits of the acquisition and could impair the results of operations, profitability

and financial results of the Company. In addition, the overall integration of the operations, technologies

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and personnel of acquisitions into the Company may result in unanticipated operational problems,

expenses, liabilities and diversion of management’s attention.

In addition to the integration of acquisitions, the Company may make selected acquisitions in the future.

The Company may experience problems integrating new acquisitions into existing operations, which

could have a material adverse effect on the Company. The Company’s success at completing any

acquisitions will depend on a number of factors, including, but not limited to:

identifying acquisitions that fit the Company’s strategy;

negotiating acceptable terms with the seller of the business or property to be acquired; and

obtaining approval from regulatory authorities in the jurisdictions of the business or property to

be acquired.

If the Company does make further acquisitions, any positive effect on the Company’s results will depend

on a variety of factors, including, but not limited to:

assimilating the operations of an acquired business or property in a timely and efficient manner;

maintaining the Company’s financial and strategic focus while integrating the acquired business

or property;

implementing uniform standards, controls, procedures and policies at the acquired business, as

appropriate; and to the extent that the Company makes an acquisition outside of markets in which it has previously

operated, conducting and managing operations in a new operating environment.

Acquiring additional businesses or properties could place increased pressure on the Company’s cash flow

if such acquisitions involve cash considerations or the assumption of obligations requiring cash payments.

The integration of the Company’s existing operations with any acquired business will require significant

expenditures of time, attention and funds. Achievement of the benefits expected from consolidation

would require the Company to incur significant costs in connection with, among other things,

implementing financial and planning systems. The Company may not be able to integrate the operations

of a recently acquired business or restructure the Company’s previously existing business operations

without encountering difficulties and delays. In addition, this integration may require significant attention

from the Company’s management team, which may detract attention from the Company’s day-to-day

operations. Over the short-term, difficulties associated with integration could have a material adverse

effect on the Company’s business, operating results, financial condition and the price of the Company’s

Common Shares. In addition, the acquisition of mineral properties may subject the Company to

unforeseen liabilities, including environmental liabilities.

Regulatory Approvals

The operations of the Company and the exploration agreements into which it has entered require

approvals, licenses and permits from various regulatory authorities, governmental and otherwise

(including project specific governmental decrees) that are by no means guaranteed. The Company

believes that it holds or will obtain all necessary approvals, licenses and permits under applicable laws

and regulations in respect of its main projects and, to the extent that they have already been granted,

believes it is presently complying in all material respects with the terms of such approvals, licenses and

permits. However, such approvals, licenses and permits are subject to change in various circumstances

and further project-specific governmental decrees and/or legislative enactments may be required. There

can be no guarantee that the Company will be able to obtain or maintain all necessary approvals, licenses

and permits that may be required and/or that all project-specific governmental decrees and/or required

legislative enactments will be forthcoming to explore and develop the properties on which it has

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exploration rights, commence construction or operation of mining facilities or to maintain continued

operations that economically justify the costs involved.

Changes in Legislation

The mining industry in Colombia and Venezuela is subject to extensive controls and regulations imposed

by various levels of government. All current legislation is a matter of public record and the Company

will be unable to predict what additional legislation or amendments may be enacted. Amendments to

current laws, regulations and permits governing operations and activities of mining companies, including

environmental laws and regulations which are evolving in Colombia and Venezuela, or more stringent

implementation thereof, could have a material adverse impact on the Company and cause increases in

expenditures and costs, affect the Company’s ability to expand or transfer existing operations or require

the Company to abandon or delay the development of new properties.

Labour Matters and Employee Relations

To date, the Company has not experienced any material work stoppages at its facilities at any of the

Projects, nor has it experienced any disputes with unions that have had a material effect on the

Company’s operations. However, if future disputes with labour unions should arise, they may not be

resolved without significant work stoppages or delays, which could have an adverse effect on the

Company’s revenues and the output of each Project.

The Company’s ability to achieve its future goals and objectives is dependent, in part, on maintaining

good relations with its employees and minimizing employee turnover. A prolonged labour disruption at

any of its material properties could have a material adverse impact on its operations as a whole.

Economic and Political Factors

Colombia

Although Colombia has a long-standing tradition respecting the rule of law, which has been bolstered in

recent years by the present and former government’s policies and programs, no assurances can be given

that the Company’s plans and operations will not be adversely affected by future developments in

Colombia. The Company’s property interests and proposed exploration activities in Colombia are subject

to political, economic and other uncertainties, including the risk of expropriation, nationalization,

renegotiation or nullification of existing contracts, mining licenses and permits or other agreements,

changes in laws or taxation policies, currency exchange restrictions, and changing political conditions and

international monetary fluctuations. Future government actions concerning the economy, taxation, or the

operation and regulation of nationally important facilities such as mines, could have a significant effect on

the Company. Colombia is home to South America’s largest and longest running insurgency. While the

situation has improved dramatically in recent years, there can be no guarantee that the situation will not

again deteriorate. Any increase in kidnapping and/or terrorist activity in Colombia generally may disrupt

supply chains and discourage qualified individuals from being involved with the Company’s operations.

Additionally, the perception that matters have not improved in Colombia may hinder the Company’s

ability to access capital in a timely or cost effective manner. Any changes in regulations or shifts in

political attitudes are beyond the Company’s control and may adversely affect the Company’s

business. Exploration may be affected in varying degrees by government regulations with respect to

restrictions on future exploitation and production, price controls, export controls, foreign exchange

controls, income and/or mining taxes, expropriation of property, environmental legislation and permitting

and mine and/or site safety.

The government has recently announced its intent to introduce before Congress a bill to amend the current

mining law. Although changes to the law are expected to mostly deal with applications for concessions,

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which should not affect the Company, they could also include environmental, zoning and control issues,

which, together with any local zoning regulations, could have an impact on the Company’s activities.

Venezuela

Some of the Company’s assets are located in Venezuela. On September 16, 2011, the Venezuelan

government issued a Decree-Law nationalizing gold exploration and mining operations in the Country,

including a minimum state equity participation of 55% in gold projects, a new 13% royalty, and the

banning of export sales by producers. The Decree-Law established a three month period for negotiations

for pricing and transfer of ownership of the nationalized portion of projects, which was subsequently

extended for a further three months. The Company has repeatedly tried to engage the government in such

negotiations but its communications have so far gone unanswered. The Decree-Law called for the

automatic termination of gold mining concessions and contracts at the end of the negotiation period;

however, the Company has not been notified of any such termination, nor has it lost physical control of its

mining properties.

The Company has continued its efforts in engaging the Venezuelan government in negotiations on

compensation for the genuine value of its project. As the negotiation period has expired, the Company

intends to pursue the remedies afforded to it by the Agreement between Venezuela and Canada for the

Promotion and Protection of Investments (which has been in force since 1998), including, if warranted,

seeking such compensation through international arbitration.

Mali

Mineral exploration and mining activities may be affected in varying degrees by political or economic

instability and government regulations relating to the mining industry in Mali. Any changes in regulations

or shifts in political or economic conditions are beyond the control of the Company and may adversely

affect it. More particularly, there have been discussions recently of potential reform to the Mining Code in

Mali. It is unclear if and when such reform will be implemented or what impact, if any, such reform could

have on the Company’s properties in Mali. Accordingly, there exists some uncertainty regarding the

future regulation of the mining industry in Mali and there is a risk that reform to the Mining Code may

involve new restrictions or other requirements that could impact the Company’s properties and/or future

exploration activities, if any, in Mali.

The Company may also be affected by political or economic instability in Mali. The risks include, but are

not limited to, civil unrest, terrorism, poverty, corruption, extreme fluctuations in currency exchange rates

and high rates of inflation. While the political situation in Mali has generally been improving over the last

two decades with the first democratically-elected president taking power in 1992, Mali is still facing a

significant number of challenges including poverty, illiteracy, corruption, human rights violations,

insufficient democratic culture and climatic hazards. Mali’s northern regions are affected by armed

conflicts, kidnappings, armed robberies, and the presence of landmines. In particular, armed conflict and

massive civil unrest broke out in northern Mali in early 2012, resulting in the displacement of thousands

of Malians to neighbouring countries and, in March 2012, a military coup was declared against President

Amadou Toumani Toure causing an uprising in the capital, Bamako. The effect of this and any further

political or social instability cannot be accurately predicted and whether these, or future, events could

have an effect on the Company’s properties and/or future exploration activities, if any, in Mali is

unknown at this time.

Currency Risk

The Company reports its financial results and maintains its accounts in U.S. dollars and the markets for

gold and silver are principally denominated in U.S. dollars. The Company’s operations in Colombia and

Venezuela make it subject to foreign currency fluctuations and such fluctuations may materially affect the

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Company’s financial position and results. Colombia has a free and unrestricted supply and demand

market and Venezuela currently has an exchange control regime. The Company is exposed to foreign

exchange risk from the exchange rate of COP and Venezuelan Bolívar relative to the Canadian and U.S.

dollars. Foreign exchange risk is mainly derived from assets and liabilities stated in COP and Venezuelan

Bolívars. The Company limits its foreign exchange risk by the acquisition of short-term financial

instruments and, when possible, minimizes its COP and Venezuelan Bolívars monetary asset positions.

Changes to Environmental Laws

The Company’s operations are subject to the extensive environmental risks inherent in the gold and silver

mining industry. The current or future operations of the Company, including development activities,

commencement of production on its properties, potential mining and processing operations and

exploration activities require permits from various governmental authorities and such operations are and

will be governed by laws and regulations governing prospecting, development, mining, production,

exports, taxes, labor standards, occupational health, waste disposal, toxic substances, land use,

environmental protection, mine safety and other matters.

Companies engaged in the development and operation of mines and related facilities generally experience

increased costs, and delays in production and other schedules as a result of the need to comply with

applicable laws, regulations and permits. Existing and possible future environmental legislation,

regulations and actions could cause significant additional expense, capital expenditures, restrictions and

delays in the activities of the Company. Although the Company believes that it is in substantial

compliance in all material respects with applicable material environmental laws and regulations, there are

certain risks inherent in its activities such as accidental spills, leakages or other unforeseen circumstances,

which could subject the Company to extensive liability. In addition, the Company cannot assure that the

illegal miners operating on its properties are in compliance with applicable environmental laws and

regulations.

Failure to comply with applicable laws, regulations, and permitting requirements may result in

enforcement actions thereunder, including orders issued by regulatory or judicial authorities causing

operations to cease or be curtailed, and may include corrective measures requiring capital expenditures,

installation of additional equipment, or remedial actions. Parties engaged in mining operations may be

required to compensate those suffering loss or damage by reason of the mining activities and may have

civil or criminal fines or penalties imposed for violations of applicable laws or regulations. Amendments

to current laws, regulations and permits governing operations and activities of mining companies, or more

stringent implementation thereof, could have a material adverse impact on the Company and cause

increases in capital expenditures or production costs or reduction in levels of production at producing

properties or require abandonment or delays in development of new mining properties.

Asset Retirement Obligation

Mining, processing, development and exploration activities are subject to various laws and regulations

governing the protection of the environment. The Canadian Institute of Chartered Accountants Handbook

Section 3110, Asset Retirement Obligations, addresses financial accounting and reporting for obligations

associated with the retirement of tangible long-lived assets and for the associated asset retirement costs. In

connection with the Frontino Acquisition, the Company is currently finalizing the requirements for an

environmental management and reclamation plan at the Segovia Project. At December 31, 2011, the costs

associated with this plan had not yet been determined and as such, an asset retirement obligation has not

yet been recorded. Once these costs are determinable, the Company will record the asset retirement

obligation. The Company has recorded a liability for future costs related to its legal obligation at the

Mineros Nacionales Mine site located on the Zona Baja Property with a corresponding adjustment to the

carrying amount of the related assets. Significant judgments and estimates are made when determining

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the nature and costs associated with asset retirement obligations. Changes in the underlying assumptions

used to estimate the obligation as well as changes to environmental laws and regulations could cause

material changes in the expected cost and fair value of asset retirement obligations.

Shortage of Experienced Personnel and Equipment

The ability to identify, negotiate and consummate transactions that will benefit the Company is dependent

upon the efforts of the Company’s management team. The loss of the services of any member of

management could have a material adverse effect on the Company. The Company’s future drilling

activities may require significant investment in additional personnel and capital equipment. Given the

current shortage of equipment and experienced personnel within the mining industry, there can be no

assurance that the Company will be able to acquire the necessary resources to successfully implement its

business plan.

Furthermore, while the Company has a full-time Chief Executive Officer, certain of the directors and

officers of the Company are directors and officers of other reporting issuers and, as such, will devote only

a portion of their time to the affairs of the Company.

Potential Conflicts of Interest

The Company’s directors and officers may serve as directors or officers of other companies or have

significant shareholdings in other resource companies and, to the extent that such other companies may

participate in ventures in which the Company may participate, the directors of the Company may have a

conflict of interest in negotiating and concluding terms respecting the extent of such participation. In the

event that such a conflict of interest arises at a meeting of the Company’s directors, a director who has

such a conflict will abstain from voting for or against the approval of such participation or such terms. In

determining whether or not the Company will participate in a particular program and the interest therein

to be acquired by it, the directors will primarily consider the degree of risk to which the Company may be

exposed and its financial position at that time.

Possible Volatility of Stock Price

The market price of the Common Shares, Warrants and Notes can be subject to wide fluctuations in

response to factors such as actual or anticipated variations in the Company’s results of operations,

changes in financial estimates by securities analysts, general market conditions, the issuance of Common

Shares in connection with acquisitions made by the Company or otherwise, and other factors. Market

fluctuations, as well as general economic, political and market conditions such as recessions, interest rate

changes or international currency fluctuations may adversely affect the market price of the Common

Shares, Warrants and Notes.

Repatriation of Earnings Risk

There are currently no restrictions on the repatriation from Colombia of earnings to foreign entities.

However, there can be no assurance that restrictions on repatriations of earnings from Colombia will not

be imposed in the future.

Ranking of Notes

The Notes are direct, unsecured obligations of the Company and rank equally with one another and,

except as prescribed by law, will rank equally with all other unsecured indebtedness of the Company.

Moreover, since the Notes are unsecured obligations of the Company, they are effectively subordinate to

all of the Company’s existing and future secured indebtedness to the extent of the value of the assets

securing such indebtedness. Therefore, in the event of the insolvency, bankruptcy, liquidation,

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reorganization, dissolution or winding up of the Company, the Company’s assets will be available to pay

its obligations with respect to the Notes after it has paid all of its secured creditors and all holders of any

senior indebtedness. There may be insufficient assets remaining following such payments to pay amounts

due on any or all of the Notes then outstanding.

Absence of Covenant Protection

Other than as described therein, the Note Indenture does not limit the Company’s ability to incur

additional debt or liabilities (including senior ranking indebtedness). The Note Indenture will not contain

any provision specifically intended to protect holders of the Notes in the event of a future leveraged

transaction by the Company.

Market for the Notes

Although the Notes are listed for trading on the TSX, there can be no assurance that a secondary market

for trading in the Notes will develop or that any secondary market which does develop, will continue.

Also, there can be no assurances that any such secondary market will survive.

Taxation – CRA Review

The CRA is currently reviewing its administrative policies and assessing practices with regard to

obligations such as the Notes. This review may result in changes to or adoption of policies or practices

that may affect, among other things, the CRA’s views concerning (1) whether there is a deemed accrual

of any amount of interest, bonus or premium on such obligations, and (2) whether amounts received on

the disposition of such obligations prior to maturity are on capital account or income account. There can

be no assurance that the CRA’s administrative policies and assessing practices will not be subject to

adverse development, change or qualification with respect to these or other issues. Any change in or

development of new administrative policies and assessing practices respecting obligations such as the

Notes could result in the tax considerations relevant to acquiring, holding and disposing of the Notes

being materially different from as previously described by the Company. Investors should consult and

rely on their own tax advisor about their own tax situation.

Enforcement of Civil Liabilities

Substantially all of the Company’s assets are located outside of Canada and certain of the directors and

officers of the Company are resident outside of Canada. As a result, it may be difficult or impossible to

enforce judgments granted by a court in Canada against the assets of the Company or the Company’s

directors and officers residing outside of Canada.

Forward-Looking Information may Prove Inaccurate

Investors are cautioned not to place undue reliance on forward-looking information. By their nature,

forward-looking information involves numerous assumptions, known and unknown risks and

uncertainties, of both a general and specific nature, that could cause actual results to differ materially

from those suggested by forward-looking statements or contribute to the possibility that predictions,

forecasts or projections will prove to be materially inaccurate.

Additional information on the risks, assumptions and uncertainties are found under the heading “Forward-

Looking Information”.

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Infrastructure

Mining, processing, development and exploration activities depend, to one degree or another, on adequate

infrastructure. Reliable roads, bridges, power sources and water supply are important determinants,

which affect capital and operating costs. Unusual or infrequent weather phenomena, sabotage,

community, government or other interference in the maintenance or provision of such infrastructure could

adversely affect the Company’s operations, financial condition and results of operations.

Joint Ventures

The Company may enter into joint ventures in the future. Any failure of a joint venture partner to meet its

obligations to the Company or third parties, or any disputes with respect to the parties’ respective rights

and obligations could have a material adverse effect on such joint ventures. In addition, the Company

may be unable to exert influence over strategic decisions made in respect of properties that are the subject

of such joint ventures.

Competition

The mineral exploration and mining business is competitive in all of its phases. The Company competes

with numerous other companies and individuals, including competitors with greater financial, technical

and other resources than the Company, in the search for and acquisition of exploration and development

rights on attractive mineral properties. The Company’s ability to acquire exploration and development

rights on properties in the future will depend not only on its ability to develop the properties on which it

currently has exploration and development rights, but also on its ability to select and acquire exploration

and development rights on suitable properties for exploration and development. There is no assurance

that the Company will continue to be able to compete successfully with its competitors in acquiring

exploration and development rights on such properties.

Dividends

Any payments of dividends on the Common Shares will be dependent upon the financial requirements of

the Company to finance future growth, the financial condition of the Company and other factors which

the Board may consider appropriate in the circumstance. It is unlikely that the Company will pay

dividends in the immediate or foreseeable future.

Other Risks

Foreign investments involve unique risks in addition to those mentioned above, including those related to

integration of operations across different cultures and languages, currency risks and the particular

economic, political and regulatory risks associated with specific countries. The Company may be unable

to address these risks successfully, or at all, without incurring significant costs, delay or other operating

problems. The Company’s inability to resolve any of such risks could have a material adverse impact on

its business, consolidated financial condition and consolidated results of operations.

7 PROPERTIES

The following is an overview on the Projects as set out in the summary of each Technical Report, which

is incorporated by reference into this Annual Information Form. The Technical Reports may be accessed

through the Company’s website at www.grancolombiagold.com or through its profile on SEDAR at

www.sedar.com.

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7.1 Segovia Operations

Segovia Project 7.1.1

Summary

SEWC was retained by Medoro, Gran Colombia Panama and Old GCM, to prepare the Segovia Project

Technical Report on FGM, which is located in Antioquia Colombia near the municipality of Segovia.

The Segovia Project Technical Report conforms to NI 43-101.

FGM

FGM owned a substantial land position which contained several underground mines that have been in

continuous production for more than 150 years. The major assets and facilities associated with FGM

were:

an Indicated Mineral Resource (including Probable Mineral Reserves) estimated to contain

315,000 tonnes grading 13.1 g/t Au and containing 132,000 ounces of gold at a cut‐off grade of

7.1 g/t Au;

an Inferred Mineral Resource estimated to contain 914,000 tonnes grading 15.4 g/t Au and

containing 453,000 ounces of gold at a cut‐off grade of 6.5 g/t Au;

Probable Mineral Reserves of 210,000 tonnes grading 13.3 g/t Au and containing 90,000 ounces

of gold at a cut‐off grade of 7.1 g/t Au;

three operating and producing underground mines;

an operating mill that is processing approximately 400 tonnes of ore per day;

a contiguous land position of 2,800 hectares;

8 farms and 165 other land lots; and

3 hydroelectric power generation plants.

FGM also benefited from easy access by paved roads and the availability of services and personnel in the

towns of Segovia and Remedios.

Interpretations and Conclusions

In SEWC’s opinion, the Company should continue work to advance the Segovia Project through

underground and surface drilling to better define the Mineral Resources at the Segovia Project. SEWC

considers the Segovia Project block model to be valid, reasonable, and appropriate for supporting the

Mineral Resource estimate. A main limitation to resource classification is the lack of closely spaced

drilling resulting in a lack of perceived continuity required for quantifying any more than approximately

one and one half years of production. Additional target drilling should allow the upgrade and expansion

of the Mineral Resources.

In SEWC’s opinion, the FGM sampling method and approach did not meet industry standards. The

channel sampling methods, sample sizes and inconsistent sampling techniques observed by the authors all

need improvement.

In SEWC’s opinion, due to observed QA/QC issues, the overall FGM sample preparation, analysis and

security protocols fall short of industry standards and recommendations have been made for

improvements.

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In SEWC’s opinion, the grade estimation techniques used for this report, are sufficient to classify Mineral

Resources as Indicated Mineral Resources and Inferred Mineral Resources in compliance with NI43-101.

Due to the uncertainty with the FGM sampling methods and laboratory procedures, SEWC recommended

that no Mineral Resources be classified as Measured Mineral Resources until procedural improvements

are made with sampling methods and laboratory QA/QC procedures.

Geology and Mineralization

Gold mineralization is hosted by a series of quartz veins hosted by granodiorites of the Segovia Batholith.

The veins dip at about 30° to the east or north‐east. There are also a number of steeply dipping quartz

veins with a N40W trend in the west part of the concession.

The geological history is as follows:

1. Intrusion of granodiorite into older metamorphic units.

2. Development of low angle fault system.

3. Intrusion of basic porphyry dikes along the low angle faults.

4. Formation of quartz‐sulfide veins along the low angle faults.

5. Late stage high angle reverse fault movement causes off‐sets of the quartz veins.

The veins are formed of quartz with minor calcite with coarse grained sulfides comprising pyrite, galena

and sphalerite. There are 27 principal known veins with a total strike length of about 47.2 km, and the

Company currently operates mines on three of these veins at El Silencio, Providencia and Sandra K, with

a total strike length of 5.7 km. The most extensively developed vein is El Silencio, which has been mined

to a depth of 815 m vertically and 1,600 m inclined length at a 30° dip on 43 levels, over about 2,100 m

strike length. The average vein width is 0.95 m, with a maximum of 9.00 m.

Indicated Resources

The June 9, 2010 Indicated Mineral Resources (including reserves) is reported at a 7.1 g/t Au cut-off

grade (Table 1.1).

Table 1.1 Segovia Project Indicated Mineral Resource

June 9, 2010 Indicated Mineral Resources (inclusive of reserves)

Cut off

g/t

Type Tonnes

x 1,000

Grade

g/t

Ounces

x 1,000

7.1 Gold 315 13.1 132

Inferred Mineral Resources

The June 9, 2010 Inferred Mineral Resources is reported at a 6.5 g/t Au cut-off grade (Table 1.2).

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Table 1.2 Segovia Project Inferred Mineral Resources

June 9, 2010 Indicated Inferred Resource

Cut off

g/t

Type Tonnes

x 1,000

Grade

g/t

Ounces

x 1,000

6.5 Gold 914 15.4 453

Probable Mineral Reserves

Probable Mineral Reserves represent a portion of the Indicated Mineral Resource that will be profitably

mined at the Segovia Project. The June 9, 2010 Probable Mineral Reserve is reported at a 7.1 g/t Au cut-

off grade (Table 1.3). Mineral Resources that are not Mineral Reserves do not have demonstrated

economic viability.

Table 1.3 Segovia Project Probable Mineral Reserves

June 9, 2010 Probable Mineral Reserves

Cut off

g/t

Type Tonnes

x 1,000

Grade

g/t

Ounces

x 1,000

7.1 Gold 210 13.3 90

Carla Project 7.1.2

The Carla Project comprises SRK ES independent technical report, written to be compliant with NI 43-

101, on the Gold exploration assets of Carla located in the municipalities of Remedios and Segovia at

approximately 7°04' N, 74°43' W some 200 km north east of Medellin, the Department capital of

Antioquia, Colombia. The assets comprise some 16 exploration or mining licences, Carla has options on

a further 3 licences.

SRK ES was commissioned by Old GCM, who had an option agreement in place with Carla for the

acquisition of the licences. The agreement is subject to a purchase price of US$15,000,000 payable over

18 months as follows:

US$1,000,000 which has already been paid, of which US$750,000 are refundable, upon

completion of due diligence;

US$4,000,000 by July 05, 2010, which has been paid;

US$5,000,000 by February 05, 2011, which has been paid; and

US$5,000,000 by October 05, 2011, which has been paid.

The assets are located in the foothills of the Cordillera Central of the Colombian Andes and the

topography is rugged, comprising a deeply dissected terrain with steep sided valleys. Access to individual

licences can be poor.

The climate of the area is humid tropical with an average temperature of 24ºC with wet and dry seasons,

the dry season lasting between December and April.

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Geologically the assets are located, for the most part, within the Segovia Batholith, a Granodiorite massif

which is bounded by the north south trending Otu and Nus faults to the west and east respectively.

Diabasic and Andesitic dykes intrude the Granodiorite. Known mineralization is associated with quartz

veins which have two main preferred orientations.

The Segovia Remedios district has a long history of gold mining related to quartz vein mineralization, the

adjacent Segovia Project has been operational since 1852 to the current, during which time it has

produced in excess of 5 million ounces of gold.

A number of small scale or artisanal mining operations exist on, or adjacent to, the Carla assets, these are

in general poorly developed with adits and levels developed down dip or along the strike of individual

quartz veins. The mines have limited facilities for processing ore which range from hand selection to

gravity beneficiation. Further processing of selected or beneficiated ore is carried out by local third party

processors who charge at the equivalent of 3 g/t as a consequence mine operators are very selective and

lower grade ore is excluded.

Previous exploration on the assets has been limited to geological mapping, aerial photo and satellite

image interpretation, exploration tunnels, shafts and adits exploring for and following the strike of quartz

veins and SRK ES was able to observe evidence of many such workings during its visit. Previous

exploration, however, has not been systematic. Carla had also completed programmes of sampling and

chemical analyses. SRK ES was also able to take a number of samples for analysis including duplicates of

two Carla channel sample locations.

SRK ES considers that mineralization within the Carla licences comprises multiple stage mesothermal

quartz vein hosted gold silver occurrences and that the mesothermal system is controlled by regional

structural events.

The gold mineralization is hosted in quartz veins varying from a few centimetres to more than three

metres in thickness, with an average of one metre and with dips varying from 30° to vertical. The

currently active artisanal mines have targeted the mineralised structure both down dip and along strike

with an average down dip gradient of 35°. The host rock is largely unaltered coarse granodiorite with

occasional local variations of diorite, quartz diorite, and tonalite. The gangue material of the veins is

quartz with subordinate calcite recorded in a number of localities. Accessory minerals present are pyrite,

sphalerite, galena, chalcopyrite, bornite, magnetite, and traces of molybdenite. SRK ES concludes that

the Carla licences contain projects of merit. The projects themselves are however at a relatively early

stage. While the observed mineralised veins have not, to date, been demonstrated or sampled at depth and

the maximum depth of exposure across the Carla licences is currently only around 80 m (down dip), there

is geological evidence that the observed surface mineralization does continue at depth. The presence of an

epithermal system suggests that the present surface reflects the upper levels of an epithermal/

mesothermal system and current activity at the adjacent the Segovia Project suggests that economic

mineralization may continue to depth. SRK ES recommends a systematic exploration programme is

carried out to modern international standards in order to facilitate resource /reserve reporting at later stage

to include:

Phase 1a Geophysical surveys

Phase 1b Core drilling programme

A “gradient array” IP survey is recommended as the first phase of exploration. This would produce data

that shows variations in chargeability in plan view, which can then be interpreted and incorporated into a

GIS database and overlain onto site plans and other data. The distribution of sulphide-bearing materials,

potentially including the traces of sulphide-bearing veins, could be mapped and anomalous areas or

possible vein intersections may be identified. Anomalous areas should also be further investigated with IP

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profiles with data acquired using the dipole-dipole array. These would provide cross-sectional images of

variations in chargeability and resistivity, and could therefore be used to obtain depth information for

target features. This would further aid the design of a trenching or drilling programme.

A ground-based magnetic survey should also be undertaken as part of the first phase. The data can be

acquired relatively quickly and can be presented in plan format overlain onto site plans and other data for

interpretation alongside the IP data. In this case, although mineralised areas may not be magnetically

anomalous themselves, the data may be of value in gaining a fuller understanding of the structural

geology and its control on mineralization. Indeed it may be that the host granitic rocks have a higher

magnetic signature.

Both types of geophysical survey are relatively inexpensive and can be performed quickly. If required, the

survey areas can be easily expanded beyond the main areas of interest in order to provide information on

a more regional scale.

As stated the aim of this proposed geophysical exploration is the production of a number of priority

surface drilling targets. SRK ES recommend that a minimum of 3000 m of drilling be completed over the

Gran Colombia Mine area as part of this core drilling phase and a cost estimate for this programme is

given in Table 1.4 below. SRK ES also suggest, as part of this initial phase, the construction of a cross-

cut, at Gran Colombia, into the footwall or hanging wall of the vein for the purpose of drilling a series of

underground core holes to assess the strike extent, but more importantly the down dip extension of the

vein and its grade variations.

Following completion of the initial drilling programme above and a period of review of its results a

further phase core drilling exploration, could be undertaken. SRK ES understand that the Company aims

to increase the rate of their exploration following this review and during this further phase. As this phase

will be contingent upon the results of the previous programme SRK ES has not given a cost estimate for

the work at this time.

The likely costs for these two phases of exploration are given in Table 1.4

Table 1.4 Provisional recommended exploration costs

Work

Phase Activity

Estimated Cost

(USD)

Phase Ia Ground Geophysics (IP + magnetics), trenching, surface assays

50,000 (~7 km combined total strike length of veins)

Phase Ib

Surface Drilling (including access, assays, etc.) minimum 3000 m 625,000

Underground development - Gran Colombia (500m) 350,000

Underground Drilling (NQ/BQ 1000m from 15 holes including logging

and assaying) 150,000

Subtotal: 1,175,000

Total including 15% contingency: 1,351,250

Ongoing development at the Segovia Project will provide partially or fully self funded exploration – but

attention must be paid to health and safety standards at mine and environmental standards particularly

water management and tailings disposal.

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7.2 Marmato Operations

Marmato Project

SRK UK produced an updated Mineral Resource estimate for the Marmato Project dated 6 September

2011. The deposit has been modelled and is described herein using UTM coordinate grid system with a

rotated block model orientated to 305º, which is considered to be the principle strike of the main

structures.

The estimate is based on some 180,000 m of diamond drilling and cross-cut sampling (majority diamond

drilling), completed up to 30 June 2011. In comparison the January 2011 Mineral Resource estimate, an

additional 157 drillholes is now available, representing an additional 52,485 m of drilling, 732 m of cross-

cut samples and some 26,962 new assays, representing a 39% increase in the size of the assay database

(53% in the resultant number of desurveyed samples). The latest drilling has comprised partly infill

drilling to a spacing of 25 m and extensional drilling around the 2010 block model at depth and along

strike. The results of the drilling has validated aspects of the previous interpretation, but also provided

additional information to re-define the geological model during the 2011 modelling exercise. The drilling

programme has incorporated fan drilling at depth (from underground adits) and selective infill drilling

from surface in the targeting of the less well known areas of the deposit. While this drilling has verified

certain aspects of the previous interpretation, it has also caused SRK to reinterpret the grade shell domain

to create a model that better reflects the spatial grade distribution. Exploration is currently continuing and

it is estimated that a further model update will be required on compilation of the next round of infill

drilling.

During the initial phase of the 2011 infill drilling programme the Company intersected a number of

significant intersections at depth at the Marmato Project. SRK UK reviewed the drillcore for a number of

these intersections during the site visit. These intersections display continuous mineralisation within the

porphyry zones, with limited veinlet mineralisation as seen in other areas of the deposit typically

associated with higher grades. It is thought these consistent grades over a number of samples, suggest

maybe a transitional or feeder zone to the main mineralisation. SRK UK recommends further work be

undertaken by the Company to investigate the depth and strike continuity of these zones.

The Marmato deposit is hosted by a dacite and andesite porphyry stock which extends for some 18 km

long by 3 to 6 km wide, which is elongated north to south and is one of a number of porphyry stocks in

the district. The mineralization occurs in parallel, sheeted and anastomosing veins, following a regional

structural control, which intersect broader zones of intense veinlet mineralisation, hosted by a lower grade

mineralised porphyry. The mineralised corridor is some 0.5 to 1.5 km wide and has a drill defined strike

length of approximately 1.3 km.

Mineralisation is described as being of the epithermal intermediate sulphidation type. Gold-silver

mineralisation at Marmato is hosted by a sheeted pyrite veinlet system associated with intermediate

alteration within the porphyry. Gold is associated with sulphides and is mostly free gold. Current mining

in the area is via narrow underground stoping of the highgrade vein mineralisation.

The Company has determined that the mineralisation has potential to be amenable to bulk mining due to

the relatively high number of individual veins and also the presence of lower grade gold mineralisation

seen in sulphide veinlets which occur in between the veins throughout the hosting porphyry.

The updated drilling database indicates that the vein mineralisation typically ranges between 0.5 metres

and 5 metres wide and extends for 250 metres to 1000 metres along strike and 150 metres to 750 metres

down dip. Current underground mining confirms that the vein structures have good geological continuity

and can extend for 100 to 300m along strike and 100 to at least 300m down dip. The broad zones of

veinlet mineralisation (“grade shells”) modelled during the 2011 update vary from 10 metres to 230

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metres wide and extend with good geological continuity for 240 metres to 1300 metres along strike and

150 metres to 900 metres down dip.

The 2010/2011 drilling programme has significantly increased the size of the geological database and

therefore (in addition to increasing the confidence in the geological modelling of the vein), highlighted

that the previous interpretation of the model could be improved. The 2010 model suggests the veins are

surrounded by a relatively narrow alteration halo grade shell, whereas (in light of a larger database) it is

evident that there is material of a similar grade and geological nature sub parallel to the veins that forms

structural trends on a much larger scale through the porphyry, which could be domained to better reflect

the gold grade distribution.

Drillholes, where regularly spaced, are orientated -60 and -75 degrees predominantly to the south west,

with occasional scissor holes towards the north east. Fan drilling has been utilised both at surface and

from underground adits, which are also typically orientated towards the south west, with a small number

of less extensive fans orientated towards the north east. SRK UK completed a review of the latest

drillcore during the site visit and noted a clear distinction between the mineralised porphyry and the low-

grade unmineralised porphyry material, namely by the presence of vienlet mineralisation, or more

competent material with more predominate epidote. It is SRK UK’s opinion there appears to be some

relationship between an increase in the veinlet density and areas of improved mineralisation, which

occurred over a broader scale than previously modelled and was not limited to a halo around the main

vein mineralisation.

The estimate is based on a combination of diamond core and underground cross-cut samples which were

sent for sample preparation to ACME laboratories sample preparation facility in Medellin and fire

assayed for gold by ACME in Chile. Comprehensive QAQC has demonstrated that sample preparation

and laboratory performance for both drilling campaigns provided assays which are fit for the purpose of

this estimate. Density determinations by have been provided from the previous model and made on a

combination of the vein proportion and the country rock types based on the assessment of density by rock

type.

Interpretation for the vein zone was undertaken by geologists of the Company, and was based on

structural logging, a gold cut-off grade of 1.0 g/t, and the location of planned and depleted stopes within

the Mineros Nacionales Mine, in the Zona Baja portion of the deposit.

The interpolation of the sample data was undertaken by SRK UK, guided through the application of

Leapfrog grade shells, created using a 0.1 g/t Au cut-off. The orientation of the identified structures was

confirmed using an initial spherical grade search, allowing a visual analysis of gold grade continuity.

Further analysis into the orientation of grade continuity was applied to the subsequent grade searches,

resulting in the final Leapfrog grade shell. The final Leapfrog shell was imported into Datamine and used

as a guideline, in conjunction with the updated vein interpretations to model the grade shell domain. The

initial interpretations were sent to the project geologist for review and approved as improving the

representation of the mineralisation illustrates (Figure 1-1) a typical cross section, through the deposit.

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Figure 1-1: Cross section showing comparison between grade domain wireframes in current and

previous model (August 2011).

The updated block model comprise three grade domains which comprise of the vein, sub parallel broad

grade shell structures which have been wireframed approximating a 0.1 g/t cutoff grade and the remaining

porphyry material. SRK UK has completed a statistical and geostatistical review of the updated domained

data, with the primary focus on the re-modelled grade shell which provides the majority of the tonnage

within the deposit. Although not directly comparable, the modified grade domain interpretation based on

the Leapfrog grade shells has slightly reduced the mean grade of the domain from 0.48 g/t to 0.41 g/t as a

result of incorporating lower grade samples within the broad grade shells, however the volume of material

incorporated within the domain has significantly increased, and thus resulting in an overall increase in

contained metal.

In the previous model this mineralisation was estimated in the porphyry domain which lacked any

constraints, and contained additional dilution of the low grade material.

SRK UK has produced a block model with block dimensions of 10 x 20 x 10m, which has been sub-

blocked, to appropriate levels to honour the geology. Sample composites of 5m have been selected based

on the results of statistical analysis, with composites in the veins typically composited across the

thickness of the vein (typically 1-2m). Gold and Silver grades have been estimated using a minimum of 6

composites per block in the primary search using an ordinary kriging routine. Within the vein domain

estimates have been completed using variable oriented search ellipse to follow the true dip and dip

directions of the mineralised veins (this is to account for the two principle directions and dips seen in the

veins). SRK UK undertook a sensitivity analysis (QKNA) on the estimation and found that the global

grade and tonnage of the deposit is in general not sensitive to minor changes in the estimation parameters.

The resultant block grade distribution reflects the mineralisation style which the Company and SRK UK

consider to be an important feature of the deposit Figure 1-2 and Figure 1-3.

SRK UK has treated all domains as hard boundaries in terms of the estimation process. SRK UK has

limited the influence of grades in the grade shell and porphyry domains to appropriate levels by limiting

the confidence levels to maximum search ranges of 120 x 70 x 30m and 70 x 100 x 100 m respectively,

based on the results of the semi-variogram defined ranges.

SRK UK understands the deposit to be bound to the northwest as a result of a NE-SW trending fault zone,

as suggested in geological sections provided by Mineros Nacionales. The 3D fault surface was not

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available in digital format and thus further investigation is required in this regard. SRK UK have limited

the current strike extents to 25 m beyond the limit of the drilling but further strike extents to the south east

of known mineralisation may represent some upside.

SRK UK has considered sampling density and distance from samples in order to classify the Mineral

Resource according to the terminology, definitions and guidelines given in the CIM Standards on Mineral

Resources and Mineral Reserves (December 2005) as required by NI 43-101 and has also undertaken

work to confirm that the Mineral Resource as reported has reasonable prospects for economic extraction

either by Open Pit or underground.

Figure 1-2: Example Cross Section through the Marmato Deposit (looking northwest).

Figure1-3: Example Level Plan through Marmato Deposit (1200 RL).

Table 1-1 give SRK UK’s Mineral Resource Statement. SRK has applied a cut off grade of 0.3 g/t gold

for this Mineral Resource Statement. In addition to the Open Pit Mineral Resource SRK UK has

considered there to be potential to mine the veins only via underground methodologies as is the current

practice at Mineros Nacionales. SRK UK has applied a cut-off grade to 1.2 g/t to this material.

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Data quality, drillhole spacing and the interpreted continuity of grades controlled by the banding have

allowed SRK UK to classify the over 80 % of the deposit as either Measured or Indicated within the

current pit shell. The remainder of the Mineral Resource has been classified as Inferred.

Table 1-1: Open Pit and Underground Mineral Resource Statement*, Marmato Project, Colombia,

SRK Consulting (UK) Ltd, effective date, 4 September, 2011.

Grade Metal

Quantity Au Ag Au Ag

Category Mt gpt gpt 000’oz 000’oz

Open Pit Vein** Measured

Indicated

Measured and Indicated

Inferred

7.0

38.4

45.4

8.7

2.6

2.03

2.12

1.8

17.42

11.14

12.11

8.3

590

2,500

3,090

500

3,920

13,770

17,690

2,300

Open Pit Porphyry** Measured

Indicated

Measured and Indicated

Inferred

45.6

215.6

261.3

59.5

0.86

0.82

0.82

1.0

8.49

4.87

5.5

4.6

1,270

5,660

6,930

1,900

12,460

33,760

46,220

8,800

Open Pit Combined Measured

Indicated

Measured and Indicated

Inferred

52.6

254.1

306.7

68.3

1.09

1.0

1.02

1.1

9.68

5.82

6.48

5.1

1,860

8,160

10,020

2,400

16,380

47,530

63,910

11,150

Grade Metal

Quantity Au Ag Au Ag

Category Mt gpt gpt 000’ oz 000’oz

Underground Vein*** Measured

Indicated

Measured and Indicated

Inferred

1.5

1.5

3.4

1.95

1.95

2.0

11.58

11.58

11.3

90

90

200

550

550

1,200

Underground

Prophyry***

Measured

Indicated

Measured and Indicated

Inferred

0.7

0.7

3.1

1.51

1.51

2.74

4.98

4.98

3.5

30

30

300

110

110

300

Underground Combined Measured

Indicated

Measured and Indicated

Inferred

2.1

2.1

6.4

1.82

1.82

2.3

9.54

9.54

7.6

120

120

500

660

660

1,569 * Mineral resources are reported in relation to a conceptual pit shell. Mineral resources are not mineral reserves and do not have

demonstrated economic viability. All figures are rounded to reflect the relative accuracy of the estimate. All composites have

been capped where appropriate.

** Open pit mineral resources are reported at a cut-off grade of 0.3 g/t . Cut-off grades are based on a price of US$1200 per

ounce of gold and gold recoveries of 88 percent for open pit and underground resources, without considering revenues from other

metal within a limiting pitshell.

*** Underground mineral resources are reported at a cut-off grade of 1.5 g/t and below the material considered potentially

mineable via open pit methods. Cut-off grades are based on a price of US$1200 per ounce of gold and gold recoveries of 88

percent for underground resources, without considering revenues from other metals.

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In comparison to the previous Mineral Resource estimate the new model represents an increase of 2.6

Moz of gold within the open pit portion of the deposit (approximately 25% increase). The main increases

have been due to an increase in the mean grade of the deposit above a cut-off grade of 0.3 g/t from 0.9 g/t

to 1.0 g/t, with the tonnage increasing from 342 Mt to 374 Mt, which has been attributed to the results

from infill drilling and intersection of higher grades at depth.

The primary focus of the 2011 infill drilling programme has been to increase the confidence in the

Mineral Resource in the upper portions of the deposit, and to infill areas with limited sample coverage in

the Mineral Resource at depth (previously defined as Inferred). The results of the current study show the

company has successfully converted a large portion of material previously categorised as Inferred into the

Indicated category. In comparison the Measured and Indicated portion of the deposit has increased from

226 Mt at 0.9 g/t producing 6.6 Moz to 307 Mt at 1.0 g/t producing 10.0 Moz.

The influence of the deeper drilling on the increase can be seen by the significant increase of the Indicated

and Inferred portions. The results are mainly responsible for the increase in the mean grades, with a

number of significant intersections within the core of the deposit, which have driven the updated limiting

surface deeper along strike (Figure 1-4). The strike extent has shifted in the order of 200m to the

northwest compared to the previous limits.

The other significant changes in the model has been the remodelling of the grade domains, which were

previously modelled as halos around each of the main vein structures, based on SRK UK’s statistical

review, analysis of the drill core and cross-cut sampling.

Figure 1-4: Influence of High-grade intersections on the resultant whittle shell (August 2011).

SRK UK notes that this updated Mineral Resource differs from the previous estimate on the project. The

main reason for differences can be summarised as follows:

Drilling of the deposit at depth has intersected a number of significant intersections, displaying

high grades, including MT-1386 which returned 4.8 g/t over 95 m in the deepest portion of the

deposit.

Reinterpretation of the grade (0.1g/t) boundary, which was limited in the previous model to halo’s

around each of the main veins. Review of drill core, visual inspection of the model and a

statistical review has led SRK UK to expand these zones into broader areas.

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Leapfrog software has been used to aid in the interpretation.

Use of direction anisotropy to improve the search orientation based on the true dip and dip

directions limited to the vein wireframes.

Increase in Block Size from 10x 10x10m to 10x20x10 m, and the introduction of sub-block modelling compared to a diluted regularised block model.

SRK UK recommends the company focus on the following areas during the next phase of the project:

Completion of the current Infill Drilling Programme to upgrade classification particularly at

depth.

Infill drilling and along strike of the high-grade zones at depth to improve the understanding and

confidence of high-grades at the base of the new whittle shell.

Improving the optimum estimation parameters utilised within each domain, particularly within

the grade shell zone. Although there is shown to be only limited difference in global grade

tonnage when applying minor changes to these parameters, the local estimates within in the grade

shells are indicated to be sensitive, this will become of more importance to improve the

confidence in scheduling during the first few years of production. A series of shallower closer

spaced drilling within areas defined during the pre-feasibility study as the starter pit should be

targeted.

A more detailed investigation into the geological controls between the mineralised and

unmineralised portions of the porphyry. SRK UK hypothesizes there to be relationship between

areas on increased structures (more intense strain), and the veinlet density.

Construction of a structural model could assist in updating the grade domain in future models.

7.3 Other Projects

El Zancudo Project 7.3.1

Property Description and Location

The El Zancudo Project is located in the Municipalities of Titiribi, Angelopolis and Armenia, Department

of Antioquia, Republic of Colombia at 6° 04’ 30” N – 75° 47’ 26” W. Gran Colombia Panama agreed to

the assignment and sale-purchase of the mining concessions comprising the El Zancudo Project through

an agreement signed with CDI, a privately-owned Colombian company, dated January 29, 2010, whereby

CDI assigned the mining concession contracts, exploration license, requests for mining concessions and

all assets associated with these to Gran Colombia Panama or an affiliate or subsidiary of Gran Colombia

Panama. The closing date of the agreement was April 30, 2010. The purchase price was US$15 million,

payable in four tranches.

CDI owns or controls, directly or indirectly, eight adjoining mining concession contracts and applications

at El Zancudo with a total area of 6,001.595 hectares (ha), or 60.0 square kilometers. Six of the

concessions have contracts which are registered in the National Mining Registry, with a total area of

2,619.4450 ha. Another concession, mining concession No. 5849, has a signed contract and is at the

National Mining Registry awaiting registration. The eighth, Exploration License No. 4985, is an expired

exploration license for which application for a concession contract has been submitted and awaits

approval.

CDI has a contract with Sabaletas granting Sabaletas the right to recover gold and silver from scoria at the

locality of Sitio Viejo, located on mining concession contract No. 5521. The scoria is glassy slag in

dumps from historical roasting operations carried out to recover gold and silver. As consideration for the

rights granted by CDI to Sabaletas, CDI is entitled to a monthly payment in cash equal to a percentage of

the value of the sales of the marketable minerals in the relevant month. The percentages 6.5% when the

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tenor of the gold in the reprocessed scoria is less that 6.5 g/t, and 7.0% when the tenor of the gold in the

reprocessed scoria is equal to or greater than 6.5 g/t. Sabaletas made an advance payment to CDI of COP

900,000,000, equivalent to about US$ 465,838, from which there is a schedule of deductions from the

monthly payments.

History

Mining has been carried out in the El Zancudo Project since 1793. The most important companies were

the Sociedad de El Zancudo, formed in 1848, and the Sociedad de Otra-Mina. The peak production

period was from 1885 to 1930. Gold was recovered from the ore by roasters from 1851. The El Zancudo

Project was closed in 1945 and subsequent production has been on a small scale. The Sociedad de El

Zancudo reported production of 4,157.89 kg (129,325 ounces) of gold and 30,818.81 kg (958,570 ounces)

of silver from 284,370 tonnes of ore in the 11 year period between 1912 and 1922. Total production from

the Titiribi district has been estimated at between 48,230 kg and 64,300 kg (1.5 to 2.0 Moz) of gold

equivalent.

Since 1985, several studies have been made to extract gold and silver from the slag dumps at Sitio Viejo.

These have historical proven and probable reserve of 574,000 tonnes grading 4.40 g/t gold and 222.25 g/t

silver (Flores, 1991). These reserves should be considered as historical data only and are not compliant

with the current CIM standards and definitions required by the NI 43-101.

CDI acquired the El Zancudo Project in 1993 with the objective of producing gold and silver from the

scoria and from underground vein mining. CDI built a pilot plant at Sitio Viejo to treat the scoria in 1994.

They have rehabilitated the Independencia Mine, La Matilde Mine, and El Castaño Mine, and built a

treatment plant at the Independencia Mine with capacity of 120 tpd to concentrate ore by gravimetry and

flotation. Concentrates were roasted and trucked to the pilot plant at Sitio Viejo for cyanidation. CDI state

that the plant was never fully operational due to low metal prices and debt problems. The mine and two

plants are kept on care and maintenance by CDI.

Sabaletas started operation of a plant to recover gold and silver from the re-treatment of scoria in August

2009 under contract from CDI. The plant has a capacity to treat 6,000 tonnes per month by crushing and

grinding followed by agitated cyanide leach and Merrill Crowe precipitation using zinc powder. In

January 2010, the plant processed 5,600 tonnes of scoria and recovered 17,600 grams (about 565.8

ounces) of gold with a recovery of 65% gold, and 388 kg (about 12,474 ounces) of silver with a recovery

of 51% silver. The head grade is stated by Sabaletas to be 4 to 5 g/t gold.

Geology and Mineralization

The El Zancudo deposit is located on the western side of the Central Cordillera of the Colombian Andes

which is separated from the Western Cordillera to the west by the River Cauca. The El Zancudo deposit

lies within the Romeral terrane, an oceanic terrane comprising metamorphosed mafic to ultramafic

complexes, ophiolite sequences and oceanic sediments of probable Late Jurassic to Early Cretaceous age.

The Romeral terrane is partially covered by continental sediments of the Oligocene to Lower Miocene

age Amagá Formation, comprising gray to green colored conglomerates, sandstones, shales and coal

seams. The Titiribi-El Zancudo porphyry of Late Miocene age intrudes the Arquia Complex schists and

Amagá Formation sedimentary rocks. Gold mineralization is related to the emplacement of the porphyry

stocks.

The host rocks to gold mineralization are schists of the Arquia Complex, sedimentary rocks of the Amagá

Formation, and the Late Miocene andesite porphyry intrusions. The sediments have been folded into

several synclines cut by high angle reverse faults with strike of N10W to N20W, and a steep dip of 50 to

70° east. Veining in the Independencia Mine is also controlled by the reverse faults.

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The known mineralization is gold-silver veins of the epithermal to mesothermal, intermediate sulfidation

type. Mineralization occurs in multiple veins which have been exploited over a strike length of more than

3,500 m. The average vein width is 0.35 m, and varies up to 0.50 to 0.80 m. The known vertical extent of

mineralization is at least 900 m. Gold mineralization occurs in two zones at El Zancudo Project, the

Upper Zone and the Lower Zone. Mineralization in the Upper Zone occurs in flat-lying veins and

disseminations in conglomerates and sandstones at or near the base of the sediment sequence at and above

the unconformity with the underlying schists. Mineralization in the Lower Zone is hosted by N-S

striking, steeply-dipping veins in green schists and accessed by several long cross-cuts.

The minerals, in order of abundance, are pyrite, galena, arsenopyrite, sphalerite, silver-sulfosalts,

bournonite, boulangerite and jamesonite, with minor chalcopyrite, pyrrhotite, native gold or electrum, and

native silver. The gangue minerals are quartz, calcite and clay minerals. The clay minerals identified are

kaolinite, muscovite and sericite. Wall rock alteration is sericite, carbonate and disseminated sulfides.

Exploration, Drilling and Sampling

Despite a long history of gold and silver mining, the El Zancudo Project deposit has not been

systematically explored. CDI’s focus was to develop gold and silver production from the scoria dumps

and from the Independencia Mine. As a consequence, very little exploration was carried out by CDI. The

limited programs of exploration carried out by CDI were mainly surface geological mapping, and also

surveying and channel sampling of veins in the Independencia Mine workings. CDI carried out programs

of diamond drilling at the Independencia Mine in 1999 and 2002-03 for a total of 998.2 m in 6 holes.

CDI assayed samples from veins for gold and silver at a local laboratory understood to be in Medellin and

to be uncertified. The sample preparation and analysis methods are not known, and no QA/QC program

was carried out.

Data Verification

The author of the El Zancudo Technical Report verified the data used upon in the El Zancudo Technical

Report by visiting the property and confirming the geology and mineralization, and by carrying out

independent check sampling. Nine check samples were taken and analyzed at SGS Peru. The results the

presence of high grades of gold and silver in the veins at the Independencia Mine and in the slag at Sitio

Viejo, with gold grades up to 36.0 g/t over 0.25 m and grades up to 2,147 g/t over 0.25 m.

Mineral Processing and Metallurgical Testing

The gold in the sulfide ore at the El Zancudo Project is refractory due to the very fine grained gold size

and encapsulation in pyrite, arsenopyrite and other sulfides. There are three ore treatment plants on the

project, two of which are owned by CDI and are inactive, and the third is owned by Sabaletas and is

actively re-processing scoria to recover gold and silver. CDI has a 20 tpd pilot plant at Sitio Viejo with

agitated cyanide leach tanks. CDI also has 120 tpd plant at the Independencia Mine which has crushing,

milling and flotation to produce a sulfide concentrate, which was then processed at the Sitio Viejo pilot

plant to extract gold and silver by re-grinding, agitated cyanide leach, and Merrill Crowe precipitation

with zinc. CDI state that neither of these plants has ever operated on a commercial basis.

The Sabaletas plant is located at Sitio Viejo and recovers gold and silver from the re-treatment of scoria

under contract from CDI. It has been in operation since August 2009. The plant has a capacity to treat

6,000 tonnes per month by crushing, grinding, agitated cyanide tanks and Merrill Crowe precipitation.

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Mineral Resource and Mineral Reserve Estimates

There are no mineral resource and mineral reserve estimates for the property that are compliant with the

current CIM standards and definitions required by the NI 43-101.

Mazamorras Project 7.3.2

Old GCM commissioned SRK ES to review the Mazamorras Cu-Au-Mo project in the Department of

Nariño, Republic of Colombia. Old GCM had an agreement in place with the licence holders for the

100% transfer of title on May 20, 2010 supported by a payment schedule to November 20, 2012. The

review of the Mazamorras Project was in support of fund raising for exploration work and formed part of

a listing application on the TSX.

The Mazamorras Technical Report serves to document, summarise and comment upon the historical

exploration at the Mazmaorras Project, Old GCM’s exploration, as well as SRK ES’ own sampling

programme and results. It also includes SRK ES' interpretation and recommendations for future

exploration work.

Property Description and Location

The Mazamorras Project is located at 1.49o

N and 77.15o

W in a small rural area in the southwest of

Colombia, some 32 km (straight line) north-northwest from San Juan de Pasto, the capital city of the

Department of Nariño, and some 488 km (straight line) south-southeast from the Colombian capital

Bogotá. The Mazamorras Project is readily accessible via road for about 50 km from San Juan de Pasto

to "El Empate" and then via local dry weather roads some 8.6 km to the concession boundary for a total

of about two hours drive.

History

There are limited historical artisanal workings in the area for both gold and copper. Gold production is

predominantly alluvial. No production records are available.

Historical exploration work at the Mazamorras Project commenced in 1998 comprising rock chip

sampling, limited soil sampling, and mapping at a scale of 1:10000.

Geology and Mineralization

Old GCM’s exploration work at the Mazamorras Project comprises limited surficial rock chip sampling in

February 2010.

The Mazamorras Project is situated in the convergence zone of the three Cordilleras of the Colombian

Andes, known as the Colombian Massif. The concession area contains a propylitic-phyllic-potassic-

silicic 8 x 2.5 km alteration belt localised along the Mazamorras fault oriented north-northwest to south-

southeast. At least three mineralised porphyry bodies of the Tertiary Igneous Complex have been

identified within the belt. Two of these bodies in the north and the centre of the Mazamorras Project,

with outcropping areas of approximately 2 km2 and 1 km

2 respectively have been sampled. Sampling has

been restricted to available exposures, predominantly along stream beds. Potential epithermal-related

mineralization styles remain largely unstudied.

Mineralization occurs as disseminations and disseminated aggregates with fine discontinuous pyrite

stockworks and rare quartz-pyrite veinlets. Vein systems appear controlled by the predominant north-

northwest to south-southeast trending Mazamorras fault zone and epithermal-style mineralization is

interpreted as hosted by parallel to subparallel shear zones. Predominant copper-bearing minerals

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include, in decreasing order: chalcocite, bornite, covellite, trace chalcopyrite and cuprite. Sulphides are

dominantly pyrite, and rare sphalerite and molybdenite have been observed independently in quartz

veinlets in association with pyrite.

SRK ES’ work presented was conducted by Karen Volp MAusIMM (110234) who completed a site visit

to the project between the March 9th and 11th March 2010 and is the Qualified Person for the

Mazamorras Technical Report. During the site visit, SRK ES undertook verification sampling of

historical rock chip sampling in addition to new independent sampling of the main mineralised trends.

Exploration, Drilling and Sampling

SRK ES considers that the Mazamorras Project is a very early stage exploration project that contains at

least two Cu-Au-Mo mineralised porphyry systems and several Au-Ag occurrences to which limited

modern surface exploration and techniques have been applied. There is therefore potential for the

discovery of economic Cu-Au±Mo porphyry-style and Au-Ag epithermal-style mineralization.

Copper, Au and Mo grades for all Tertiary Igneous Complex rock chip samples provide average Cu

grades of 0.11%, average Au grades of 0.09 ppm and average Mo grades of 0.003%. The SRK ES

geochemical study suggests that the mineralising porphyry may lie at depth.

On the basis of the data available to SRK ES at the time the Mazamorras Technical Report was drafted,

SRK ES considered the Mazamorras Project may be characterized as a porphyry-epithermal system

comprising porphyry Cu-Au mineralization overlain by low-sulphidation epithermal mineralization and

may be similar in deposit style to the Porgera deposit, Papua New Guinea. At the time of the Mazamorras

Technical Report, there was insufficient data upon which to make any comment with respect to tonnage

or grade.

SRK ES considers that a focussed exploration programme based on the acquisition and interpretation of

airborne geophysical and ground geophysical data and satellite imagery followed by pioneer drilling is

appropriate and justified by the exploration results to date. SRK ES has proposed an exploration

programme and schedule for the next phase of exploration work with an estimated completion in

approximately 12-15 months with a budget (excluding administration, consumables, and social and

environmental studies) of at least approximately US$640,000 and an expected budget of approximately

US$1,050,000.

SRK ES concluded that further exploration is warranted at the Mazamorras Project, particularly to

determine the potential for economic gold mineralization and for economic supergene copper

mineralization.

Concepción Project 7.3.3

Property Description and Location

The Concepción Project is located in the Municipalities of Concepción, San Vicente, El Peñol and

Barbosa, Department of Antioquia (Antioquia), Republic of Colombia. It is approximately 36 km NE of

the city of Medellin, the capital of Antioquia. The latitude and longitude of the property is approximately

6° 21’N, 75° 16’ W and the altitude is between 1,950 and 2,350 m.

The Concepción Project comprises four mining concession contracts and applications with a total area of

3,534.694 ha or 35.3 km2. One concession has a signed contract (No. 6352, area 1,309.38 ha), one has a

concession contract awaiting signature by the mining authority (area 26.414 ha), and the others are

mining requests.

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History

Placer and vein gold mining has taken place in the Concepción Project area since the mid 17th century

and was significant in the 18th century, leading to the Spanish settlement of the area. Over 33 old gold

mines are listed in a recent inventory of the Concepción district. Mining declined in importance in the

late 19th century, but has continued on a small scale up to the present day. The San Pedro, or Los

Churumbelos Mine, was mined until 1997, and the Criaderos mine until recently, both located in the

Concepción Project. The San Pedro mine is reported to have mined a head grade of 16 g/t gold for twenty

years. There is no record of the historical production from this mine or the Concepción district.

Providencia has explored the Concepción Project since 2005. All of the exploration work has been

carried out on Concession Contract No. 6352. The exploration has been reconnaissance in nature. No

exploration work has been carried out on Mining Request No. 6628. Mineros drilled 9 holes totaling

1,087.76 m at the San Pedro mine in 2006-07 for due diligence for a possible acquisition.

Geology and Mineralization

The Concepción Project is located in the Central Cordillera of the Colombian Andes. The regional

geology comprises metamorphic rocks of the Cajamarca Complex of Paleozoic age, intruded by the

Antioquia Batholith of Upper Cretaceous age. Concession Contract No. 6352 is mostly underlain by

schists which are mainly graphitic schists and also include a sequence of mineralized calc-silicate schists

at the San Pedro. A single dike of hornblende andesite has been observed.

The main deposit types present in the Concepción Project are mesothermal quartz veins with gold that are

related to oxidized intrusions, and are described by the oxidized intrusion-related gold vein model

(Sillitoe, 1991). The mineralization formed from hydrothermal fluids related to the Antioquia Batholith,

and forms veins in the batholith and surrounding schists. The quartz veins are sulfide-poor. In contrast,

sulfide-rich quartz veins are present at the San Pedro mine and adjacent areas, which are hosted by calc-

silicate schists. The calc-silicate schist wall rocks also have sulfides and contain lower grade gold

mineralization. These veins are also considered to be mesothermal veins related to oxidized intrusions.

Small deposits of placer gold derived from the quartz veins are also present.

The Company’s target is veins with high grade gold mineralization suitable for small, high grade

underground mine operations. The project also has potential for bulk mineable, low grade gold deposits,

similar to the Gramalote deposit located 42 km NE of Concepción, which has 2.4 Moz of gold grading 1.0

g/t.

There are two types of gold mineralization in concession contract No. 6352 hosted by quartz veins and by

calc-silicate-hosted quartz-sulfide veins. Quartz veins are widespread in the southern part of concession

contract no. 6352 which was visited by the author. Gold can be panned from some of the veins and check

sampling by the author returned up to 22.38 g/t Au in a quartz vein. Gold mineralization in quartz-sulfide

veins in calc-silicate schists at the San Pedro mine has grades in check samples up to 74.25 g/t Au and 55

g/t Ag. The wall rock calc-silicate schist is also mineralized.

Exploration, Drilling and Sampling

Providencia carried out reconnaissance exploration work on concession contract no. 6352 since 2005. The

exploration work has included literature search; photo-interpretation and structural analysis; geological

field reconnaissance; petrography; analysis of vein samples (110 total from two sampling programs). The

exploration work has identified structural and vein targets and made recommendations for follow up

exploration.

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Providencia is currently carrying out a program of underground exploration with excavation of a winze or

inclined shaft in the district of San Pedro Alto planned to intersect a quartz vein. It was at 72 m depth by 1

May 2010 but had not cut a vein yet. Providencia is also currently carrying out a program of prospection

and trenching in the southern part of concession contract no. 6352 which has identified numerous quartz

veins in outcrop and in overgrown small mine workings, some of which have shown with visible gold by

panning and up to 22.38 g/t Au in check sampling.

Mineros Nacionales drilled 9 diamond holes for 1,087.76 m at the San Pedro Mine in 2006-07. Three

assays are reported of 11.33 g/t, 11.38 g/t and 33.00 g/t gold but it appears that samples were only taken

of veins or visible mineralization and the whole core length was not analyzed. No other information has

been supplied about the drilling.

The Providencia and Mineros Nacionales drilling samples were assayed for Au and Ag at the Mineros

Nacionales Mine laboratory at the Marmato Mine, Caldas. Later samples were analyzed by SGS in El

Callao, Peru. Providencia did not carry out any QA-QC for the sampling programs.

The exploration work carried out by Providencia has not been carried out to CIM standards. It is

recommended that future exploration work including sample collection, QA-QC, assaying and

certification of assays be carried out in accordance with currently accepted best practice standards of the

mining industry.

Data Verification

The author of the Concepción Project has verified the data used in this report by visiting the property and

confirming the geology and mineralization, and by carrying out independent check sampling. The check

samples were analyzed by SGS in Peru. The check samples report grades up to 74.25 g/t gold, 55.0 g/t

silver, 8,903 ppm (0.89%) arsenic, and 1,793 ppm (0.18%) lead. The check samples indicate the presence

of high grades of gold and silver in some samples from quartz veins and mineralized calc-silicate schist

on concession contract no. 6352 and mining request no. LC1-08031.

Mineral Resource and Mineral Reserve Estimates

There are no mineral resource and mineral reserve estimates for the property that are compliant with the

current CIM standards and definitions required by the NI 43-101.

The Lo Increíble Properties 7.3.4

The Company’s indirect wholly-owned subsidiary, Lo Increíble Mining Company de Venezuela C.A.,

through its 92.3% interest in LOMEC and two sub-leases held by its two 100% owned subsidiaries

Mineria MH C.A. and Lo Increíble Mining Company de Venezuela C.A., holds an overall 100% indirect

interest in the mining rights for the Lo Increíble Properties.

Dr. Mike Armitage of SRK UK is an independent qualified person as defined by NI 43-101 and has

prepared or reviewed the preparation of the scientific and technical information in this Annual

Information Form in respect of the Lo Increíble Properties. Dr. Armitage is a Chartered Geologist and a

Charted Engineer and a Fellow of the Geological Society and Member of the Institute of Materials,

Minerals and Mining both of which are professional associations recognized by the Canadian regulatory

authorities. Dr Armitage’s verification included a review and validation of the applicable assay databases,

reviews of assay certificates and a review of check and replicate assays.

The Lo Increíble Technical Report

The Lo Increíble Properties are located in the El Callao area of the State of Bolivar, Venezuela and

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comprise two adjacent areas covering a total of 2,216 hectares which lie 3 km north of the town of El

Callao.

Exploration for gold in Bolivar State dates back to before Venezuelan independence in 1811 and most

likely prior to the Spanish occupation. The El Callao mining district itself is historically the most prolific

gold producing region in Venezuela, with a recorded output of 6 million ounces since 1870.

Despite the El Callao district’s impressive production history and Lo Increíble’s numerous artisanal

workings, little modern exploration had taken place on the Lo Increíble Properties until Bema Gold Ltd.

commenced work in late 1993. This work included line cutting, soil and panel sampling, trenching,

airborne magnetic and radiometric surveying, underground mapping and sampling, assaying, and limited

metallurgical studies, structural studies and finally reverse circulation and diamond drilling.

The exploration carried out by the Company at the Lo Increíble Properties has largely comprised further

mainly infill drilling at the three key prospects of La Cruz, La Sofia and El Tapon. In total, the database

used by LGGC comprised information from some 581 drillholes representing some 90,000 metres of

drilling in total.

The stratigraphy around the Lo Increíble Properties comprises a single volcano-sedimentary cycle of the

Pastora Botanamo Province. Sub-aqueous extrusion of mafic volcanics appears to have been followed by

intermediate and felsic volcanism, and eventually by the deposition of clastic sedimentary formations.

This package of rocks was then intruded by mafic and felsic dykes and sills, and late granitoid stocks and

plutons.

The gold mineralization at the Lo Increíble Properties occurs in association with the Lo Increíble Shear

which is comprised of a complex system of splays and bifurcating faults which strikes northeast-

southwest and extends for at least 15 km along strike, some 7 km of which is through the Lo Increíble

Properties where it is up to 1.5 km wide in outcrop.

The orebodies themselves comprise shallow to steeply dipping zones of quartz-carbonate veining and

disseminated sulphide mineralization containing gold which are typically continuous for hundreds of

metres along strike and down dip and which vary up to tens of metres in thickness.

LGGC’s resulting mineral resource estimates are given in the table below. This has been reported at a

0.5g/t Au block cut-off, apart from a deep high grade zone at La Cruz, which LGGC considers has the

potential to be exploited by underground mining, and which has been reported using a 4.0g/t Au cut-off.

Measured Mineral Resource

Deposit

Tonnes

(Mt) Grade

(g/t Au) Gold Content

(Ounces x1000)

La Cruz-OP 3.08 2.4 240

La Cruz-UG - - -

El Tapon - - -

La Sofia 1.11 2.2 80

TOTAL 4.19 2.3 310

Indicated Mineral Resource

Deposit

Tonnes

(Mt) Grade

(g/t Au) Gold Content

(Ounces x1000)

La Cruz-OP 3.18 1.6 160

La Cruz-UG - - -

El Tapon 4.76 2.6 400

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Deposit

Tonnes

(Mt) Grade

(g/t Au) Gold Content

(Ounces x1000)

La Sofia 1.28 1.6 70

TOTAL 9.22 2.1 630

Inferred Mineral Resource

Deposit

Tonnes

(Mt) Grade

(g/t Au) Gold Content

(Ounces x1000)

La Cruz-OP 0.26 1.1 10

La Cruz-UG 0.28 5.4 50

El Tapon 0.30 3.2 30

La Sofia - - -

TOTAL 0.84 3.3 90

At the Lo Increíble Properties, gold mineralization occurs as lode-gold shear-hosted quartz-carbonate

veins. Mineralization is associated with the east-northeast to east trending Lo Increíble shear, and is

hosted by similar lithologies and structural features to the nearby Choco 10 mine.

Medoro has used Actlabs Laboratories in Venezuela as the primary laboratory. Split HQ core samples of

4 to 5 kilograms were crushed and pulverized to 150 mesh. A 50 gram sample was split for Fire Assay

analysis using AAS finish, and gravimetric finish if Au was greater than 2.0 grams per tonne. A

comprehensive quality control program, which includes blanks, standards, field duplicates and cross

checks was employed. This quality control program included the use of certified standard reference

samples.

8 DIVIDENDS AND DISTRIBUTIONS

Since the completion of the RTO on August 19, 2010, the Company has not paid any dividends or

distributions. Other than pursuant to the TSX’s policies and the BCBCA, there are no restrictions on the

Company that would prevent it from paying a dividend or distribution. However, the Company does not

currently have a dividend or distribution policy in place.

9 DESCRIPTION OF CAPITAL STRUCTURE

9.1 Authorized Share Capital

The authorized capital of the Company consists of an unlimited number of Common Shares without par

value and an unlimited number of Preferred Shares without par value. As at March 28, 2012, there were

381,984,479 Common Shares issued and outstanding as fully paid and non-assessable, and no Preferred

Shares of the Company were outstanding or have been issued.

The following is a summary of the material provisions attaching to the Common Shares, Preferred Shares,

Warrants, Gran Colombia Consideration Warrants, Colombia Goldfields Warrants, and the Notes.

9.2 Common Shares

The holders of Common shares are entitled to receive notice of and to attend all meetings of the

shareholders of the Company and to one vote per Common Share held at meetings of the Shareholders.

Subject to the rights of the holders of Preferred Shares, the holders of Common Shares are entitled to

dividends if, as and when declared by the Board, and upon liquidation, dissolution or winding-up, to share

equally in such assets of the Company as are distributable to the holders of Common Shares.

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9.3 Preferred Shares

The Preferred Shares may be issued in one or more series and, with respect to the payment of dividends and

the distribution of assets in the event that the Company is liquidated, dissolved or wound-up, rank prior to

the Common Shares. The Preferred Shares of each series shall rank on parity with the Preferred Shares of

every other series. The Board has the authority to issue Preferred Shares in series and determine the price,

number, designation, rights, privileges, restrictions and conditions, including dividend rights, redemption

rights, conversion rights and voting rights, of each series without any further vote or action by shareholders.

The holders of Preferred Shares do not have pre-emptive rights to subscribe for any issue of securities of the

Company. At this time, the Company has no plans to issue any Preferred Shares.

9.4 Warrants

The following table describes the outstanding Warrants of the Company as at March 28, 2012:

Number of Warrants

Outstanding and Exercisable

as at March 28, 2011 Exercise Price Expiry Date

157,973,489 (1)

$2.60(2)

August 24, 2015

1,527,537(3)

$6.00(3)

December 28, 2012

3,722,333(3)

US$4.50(3)

June 18, 2013

______________________________

Notes:

(1) The Warrants were issued in respect of the private placement of 171,875,000 subscription receipts on July 27, 2010, which were

automatically exchanged into Gran Colombia Units consisting of one Common Share and one-half of one Warrant upon the closing of the

RTO. This number also includes the Gran Colombia Consideration Warrants that were issued in connection with the Medoro Merger. See

“General Development of the Business – 2011 – Medoro Merger” and “General Development of the Business – Significant Acquisitions or

Dispositions”.

(2) Effective December 1, 2010, and in conjunction with the Common Share Consolidation, the Company consolidated the Warrants on a one-for-four basis, with the result that each consolidated Warrant now entitles its holder to acquire one Common Share at a price of $2.60.

(3) In connection with the Colombia Goldfields Transaction, the Company assumed the Colombia Goldfields Warrants, whereby each December Colombia Goldfields Warrant was exercisable at an exercise price of $6.00, and whereby each June Colombia Goldfields Warrant was

exercisable at a price of US$4.50, to acquire 0.336 of a Common Share and 0.0108 of a Common Share purchase warrant of the Company,

whereby each whole warrant of the Company was exercisable into one Common Share at an exercise price of $1.50 per Common Share for a term of two years. As a result of the Medoro Merger, each December Colombia Goldfields Warrant is now exercisable at an exercise price

of $5.00, and each June Colombia Goldfields Warrants is exercisable at an exercise price of US$3.75, to acquire 0.4032 (being 0.336 of a

share multiplied by 1.2) of a Common Share for each Colombia Goldfields Warrant held, 0.0168 of a Gran Colombia Consideration Warrant for every Colombia Goldfields Warrant held, 0.0108 of an underlying warrant for every Colombia Goldfields Warrant held (where each

whole warrant is exercisable to purchase 1.2 Common Shares for at an exercise price of $1.25), and a further 0.0054 of a Gran Colombia

Consideration Warrant for every Colombia Goldfields Warrant held. See “General Development of the Business – 2011 – Medoro Merger” and “General Development of the Business – Significant Acquisitions or Dispositions – Medoro Merger”.

Warrants and Gran Colombia Consideration Warrants 9.4.1

The Warrants and the Gran Colombia Consideration Warrants were issued pursuant to the Warrant

Indenture and rank pari passu, whatever may be the actual dates of issue of the certificates representing

the warrants. The Warrant Indenture provides for and contains provisions for adjustments to the exercise

price and the number of Common Shares issuable upon the exercise of the warrants, including the amount

and kind of securities or other property issuable upon exercise, upon the occurrence of certain stated

events, including any subdivision or consolidation of the Common Shares, certain distributions of the

Common Shares or securities exchangeable for or convertible into Common Shares, certain offerings of

rights, options or warrants and certain capital reorganizations. The adjustments provided for in the

Warrant Indenture are cumulative and shall be made successively whenever an event that triggers such

adjustments occurs, subject to certain conditions. See “General Development of the Business – August

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2010 – Present – RTO” and “General Development of the Business – 2011 – Medoro Offering”. Please

refer to the Warrant Indenture, a copy of which can be accessed on the Company’s profile on SEDAR at

www.sedar.com.

9.5 Colombia Goldfield Warrants

The Colombia Goldfields Warrants were originally issued by Colombia Goldfields and assumed by

Medoro (and now the Company) in connection with the Colombia Goldfields Transaction. Each

Colombia Goldfields Warrant is evidenced by a warrant certificate. Each warrant certificate provides for

and contains provisions for adjustments to the exercise price and the number of Common Shares issuable

upon the exercise of the warrants, including the amount and kind of securities issuable upon exercise,

upon the occurrence of certain stated events, including any subdivision or consolidation of the Common

Shares, or certain distributions of the Common Shares, or the reorganization, reclassification, merger,

consolidation or disposition of assets. The adjustments provided for in the certificates are cumulative and

shall be made successively whenever an event that triggers such adjustments occurs, subject to certain

conditions.

9.6 Compensation Options

The following table summarizes information concerning outstanding and exercisable Compensation

Options of the Company as at March 28, 2012:

Number of

Compensation Options

Outstanding and Exercisable Exercise Price Expiry Date

1,350,000 (1)

$1.00 (2)

April 27, 2012

10,312,500(1)

$1.60(2)

August 24, 2012

Notes:

(1) The Compensation Options were issued to the Agent as partial consideration for its services in connection with the First Gran Colombia

Private Placement and the Second Gran Colombia Private Placement. See the heading entitled “General Development of the Business –

August 2010 - Present – Common Share Consolidation.”

(2) As a result of the Common Share Consolidation, the exercise price of the both the First and Second Gran Colombia Private Placement

Compensation Options were automatically adjusted to reflect the one-for-four consolidation.

9.7 Notes

As at March 28, 2012, there was US$78,632,000 principal amount of Notes issued and outstanding.

The Notes were issued under and are subject to the Note Indenture which provides that the Notes are

direct unsecured obligations of the Company and rank pari passu in right of payment with each other and

with all other unsecured indebtedness of the Company (subject to certain terms and conditions as set forth

in the Note Indenture). The designation of the Notes as senior notes applies to the priority in right of

payment of the Notes to certain indebtedness as more particularly described in the Note Indenture. If a

change of control (as defined in the Note Indenture) occurs at any time during which any Notes remain

outstanding, a holder of the Notes shall be entitled to require the Company to purchase and repay all or

less than all of such holder’s Notes, and the Company shall be required to purchase and repay the Notes

designated for purchase by the holder, for a purchase price equal to the applicable percentage of the

outstanding principal amount of each such Note to be purchased and repaid (as set forth therein), together

with any accrued and unpaid interest (as set forth therein). See “General Development of the Business –

2011 – Note Offering”. Please refer to the Note Indenture, a copy of which can be accessed on the

Company’s profile on SEDAR at www.sedar.com.

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10 MARKET FOR SECURITIES

10.1 Trading Price and Volume

Common Shares 10.1.1

The Common Shares are listed on the TSX under the trading symbol “GCM”. The closing price of the

Common Shares on the TSX on March 28, 2012 was $0.42.

The following table sets out the high and low trading of the Common Shares for the periods indicated, as

reported by the TSX.

Period High Low Trading Volume

March 1-28, 2012 $0.55 $0.40 10,059,353

February 2012 $0.60 $0.48 7,235,543

January 2012 $0.63 $0.39 17,955,937

December 2011 $0.60 $0.34 36,290,950

November 2011 $0.73 $0.485 11,463,130

October 2011 $0.74 $0.57 14,930,736

September 2011

$0.81 $0.51 20,853,764

August 2011 $0.97 $0.70 19,995,657

July 2011

$0.96 $0.75 16,078,166

June 2011 $1.14 $0.75 8,436,357

May 2011 $1.37 $0.85 12,467,407

April 2011 $1.88 $1.12 21,322,921

March 2011 $2.09 $1.64 18,386,418

February 2011 $2.00 $1.62 5,568,378

January 2011

$2.19 $1.61 10,237,292

Warrants 10.1.2

The Warrants are listed on the TSX under the trading symbol “GCM.WT”. The closing price of the

Warrants on the TSX on March 28, 2012 was $0.145.

The following table sets out the high and low trading of the Warrants for the periods indicated, as

reported by the TSX.

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Period High Low Trading Volume

March 1-28, 2012 $0.20 $0.14 2,345,776

February 2012 $0.215 $0.145 1,394,855

January 2012 $0.19 $0.135 1,513,713

December 2011 $0.175 $0.075 8,802,543

November 2011 $0.175 $0.115 11,779,690

October 2011 $0.18 $0.105 1,236,855

September 2011

$0.23 $0.12 25,713,013

August 2011 $0.30 $0.20 1,538,605

July 2011 $0.33 $0.23 1,236,810

June 2011 $0.60 $0.25 8,411,955

May 2011 $0.79 $0.51 560,061

April 2011 $0.89 $0.61 976,875

March 2011 $0.95 $0.75 431,312

February 2011 $0.83 $0.70 1,190,224

January 2011 $0.98 $0.72 8,415,997

Notes 10.1.3

The Notes are listed on the TSX under the trading symbol “GCM.WT.U”. The closing price of the Notes

on the TSX on March 28, 2012 was $87.00

The following table sets out the high and low trading of the Notes for the periods indicated, as reported by

the TSX. The Notes commenced trading on the TSX on August 11, 2011 and as a result there is no

trading history prior to such period.

Period High Low Trading Volume

March 1-28, 2012 $95.00 $86.00 557,000

February 2012 $92.00 $81.99 3,413,000

January 2012 $95.00 $79.99 365,000

December 2011 $89.00 $80.00 1,573,000

November 2011 $94.00 $87.00 295,000

October 2011 $94.49 $85.00 449,000

September 2011

$102.01 $85.00 2,752,000

August 2011 $101.50 $96.00 3,021,000

10.2 Prior Sales

There are no securities of the Company that were issued but not listed on a marketplace during the most

recently completed financial year of the Company and up to the date hereof, other than the following:

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Date of Grant Type of

Security

Number of

Securities

Exercise/Conversion

Price Expiry Date

January 12, 2012 Options 175,000 $0.425 January 12, 2017

October 24, 2011 Options 65,000 $0.62 October 24, 2016

September 29, 2011 Options 200,000 $0.54 September 29, 2016

September 21, 2011 Options 100,000 $0.73 September 21, 2016

September 12, 2011 Options 13,221,424 $0.73 September 12, 2016

June 7, 2011 Options(1)

300,000(1)

$1.59(1)

June 7, 2016

May 11, 2011 Options(1)

50,000(1)

$1.62(1)

May 11, 2016

May 11, 2011 Options 50,000 $1.60 May 11, 2016

January 27, 2011 Options(1)

350,000(1)

$2.20(1)

January 27, 2016

January 27, 2011 Options 350,000 $1.76 January 27, 2016

January 19, 2011 Options 150,000 $1.83 January 19, 2016

______________________________

Notes:

(1) These Options were issued by Medoro and assumed by the Company in connection with the Medoro Merger. As a result of the Medoro Merger, each Option exercisable to purchase 1.2 Common Shares at the original exercise price divided by 1.2, plus the holder of the Options

will receive upon exercise thereof, of half of one Gran Colombia Consideration Warrant.

11 ESCROWED SECURITIES AND SECURITIES SUBJECT TO CONTRACTUAL

RESTRICTION ON TRANSFER

To the Company’s knowledge, there are no securities of the Company which are subject to escrow or to

contractual restriction on transfer as at March 28, 2012.

On completion of the RTO an aggregate of 6,469,165 Common Shares held by principals of the

Company and certain other shareholders were deposited into escrow with Equity, as escrow agent,

pursuant to a Tier 1 Value Security Escrow Agreement as required by Policy 5.4 of the TSXV.

Pursuant to the terms of the escrow agreement, 1,617,291 Common Shares were released from

escrow on October 22, 2010, 1,617,291 Common Shares were released from escrow on February 23,

2011, August 23, 2011, and the remaining 1,617,291 Common Shares were released from escrow on

February 23, 2012.

On completion of the RTO, 2,770,835 Common Shares were made subject to a TSXV hold period of one

year, with such hold period expiring with respect to 20% of such Common Shares on receipt of the final

exchange bulletin in respect of the RTO and expiring in respect of a further 20% of such Common Shares

every three months thereafter. As of the date hereof, the hold period has expired and there are no further

Common Shares subject to such hold period.

12 DIRECTORS AND OFFICERS

As of March 28, 2012, the directors and executive officers of the Company (as a group) owned, or exerted

direction or control over, directly or indirectly, a total of 11,726,226 Common Shares, representing

approximately 3.07% of the Company’s total issued and outstanding Common Shares on a non-fully

diluted basis.

The following table sets forth, as of the date hereof, the name, municipality of residence of each director,

whose directorship will expire (subject to being re-elected) at the 2012 annual meeting of the Shareholders

of the Company, and executive officer of the Company, as well as such individual’s position within the

Company, principal occupation within the five preceding years and number of Common Shares

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beneficially owned by each such director or executive officer. Information as to residence, principal

occupation and Common shares owned is based upon information furnished by the person concerned and

is as at the date of this Annual Information Form.

Name, Municipality of

Residence and Current

Position with the

Company

Director Since

Present Principal Occupation or Employment

(including all officer position currently held with the

Company), Principal Occupation or Employment for

the Past Five Years or more, and Other Current

Public Directorships(1)

Number of

Common Shares

Beneficially

Owned, Directly or

Indirectly, or Over

Which Control or

Direction is

Exercised

(2)

Percentage of

Common

Shares Held

Serafino Iacono(3)

Caracas, Venezuela

Executive Co-Chairman,

Director

August 6, 2010

Executive Co-Chairman of the Board to the Company

since August 20, 2010; Co-Chairman of the board of

Pacific Rubiales Energy Corp. since January 23, 2008;

Interim Chief Executive Officer and President of Medoro

from September 2010 to June 10, 2011; Co-Chairman of

the board of Pacific Stratus Energy Corp. from August 21,

2006 to January 23, 2008; Chief Executive Officer of

Bolivar Gold Ltd., a gold producer, from February 2003 to

February 2006. Mr. Iacono is also a director of Pacific

Rubiales Energy Corp. and Pacific Coal Resources Ltd.

5,233,526 1.370%

Miguel de la Campa(3)

Caracas, Venezuela

Executive Co-Chairman,

Director

August 6, 2010 Executive Co-Chairman of the Board to the Company

since August 20, 2010; Co-Chairman of the board of

Pacific Rubiales Energy Corp. since January 23, 2008; Co-

Chairman of the board of Pacific Stratus Energy Corp.

from August 21, 2006 to January 23, 2008; President and

Chief Operating Officer of Bolivar Gold Ltd., a gold

producer, from February 2003 to February 2006. Mr. de la

Campa is also a director of Pacific Rubiales Energy Corp.,

Medoro Resources Ltd. and Pacific Coal Resources Ltd.

2,904,894 0.760%

Maria Consuelo

Araujo(3)

Bogota, Colombia

Chief Executive Officer

August 6, 2010 Chief Executive Officer of the Company since August 20,

2010; Minister of Foreign Affairs in Colombia from

August 2006 to February 2007; Minister of Culture in

Colombia from August 2002 to February 2006; and

General Manager of MCA Consulting since February

2007.

51,250 0.013%

Ronald Pantin Caracas, Venezuela

Director

August 6, 2010 Chief Executive Officer of Pacific Rubiales Energy Corp.

since May 2007; and President of Enron Venezuela from

May 2000 to March 2002. Mr. Pantin is also a director of

Pacific Rubiales Energy Corp. and Pacific Coal Resources

Ltd.

212,499 0.055%

José Francisco Arata(3)

(5)

Caracas, Venezuela

Director

August 6, 2010 President of Pacific Rubiales Energy Corp. since January

23, 2008; Chief Executive Officer and director of Pacific

Stratus from August 21, 2006 to January 23, 2008; and

Executive Vice President, Exploration of Bolivar Gold

Ltd. from July 1997 to February 2006. Mr. Arata is also a

director of Pacific Rubiales Energy Corp. and Pacific Coal

Resources Ltd.

965,723 0.252%

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Name, Municipality of

Residence and Current

Position with the

Company

Director Since

Present Principal Occupation or Employment

(including all officer position currently held with the

Company), Principal Occupation or Employment for

the Past Five Years or more, and Other Current

Public Directorships(1)

Number of

Common Shares

Beneficially

Owned, Directly or

Indirectly, or Over

Which Control or

Direction is

Exercised

(2)

Percentage of

Common

Shares Held

Ricardo Lozano(6)

Bogota, Colombia

Director

August 6, 2010 Managing Director of Dominion Estrategia Empresarial in

Bogota since September 2008; President of Asociacion

Nacional de Agencias de Viajes y Turismo ANATO from

April 2008 to September 2008; Director for the Madrid

and Ecuador offices of Proexport Colombia from April

2000 to February 2008, a former partner with the law firm

Lozano Lozano & Abogados Asociados; a former deputy

minister of the Colombian Ministry of the Interior and

Justice, and the former First Secretary in charge of

consular functions of Colombia to the Canadian

Government. He is a member of the board of directors of

Empresa de Acueducto y Alcantarillado de Bogota, and

alternate board member for Empresa de Energia de

Cundinamarca and a former board member of the District

Institute of Tourism. Mr. Lozano is a Public Law

Administrative Specialist and an Attorney from the

Colegio Mayor de Nuestra Senora del Rosario in Bogota.

Nil N/A

Stephen Wilkinson(4)

Vancouver, British

Columbia

Canada

Director

August 6, 2010 Mr. Wilkinson is a mining executive, corporate director

and business consultant based in North Vancouver, British

Columbia. Since September 2002, he has served as

President, Chief Executive Officer and Director of

ValGold Resources Ltd., an international mining

development company. Mr. Wilkinson was President,

Chief Executive Officer and Director of Northern Orion

Explorations Ltd. for the period of 1999 to 2002. From

1996 to 1999, he was the Vancouver-based mining analyst

for RBC Dominion Securities Inc. responsible for small

capitalization gold and base metal companies.

10,000 0.002%

Robert Hines(5)

Toronto, Ontario

Canada

Director

August 6, 2010 Mr. Hines has been the Managing Partner, Canada with

CTPartners, an executive search firm since March 2010.

Mr. Hines joined CTPartners from Heidrick & Struggles

where he held a number of senior leadership roles from

July 2004 to March 2010, most recently as Managing

Partner, Global Operations where he was responsible for

oversight of regional operations in Asia Pacific, Europe,

the Middle East, Latin America and North America.

Before joining the executive search industry; Mr. Hines

held a number of senior positions in investment banking

including: Managing Director, Co-Head of Mergers &

Acquisitions, CIBC World Markets; President & Chief

Executive Officer, Credit Suisse Canada; Executive Vice

President, Head of Investment Banking, Midland Walwyn

Inc.; and Vice-Chairman, Merrill Lynch Canada. Mr.

Hines is a member of the Independent Review Committee

of the Mackenzie Financial Corporation mutual funds; the

International Advisory Council of The Schulich School of

Business at York University and the Advisory Board of

True Blue Connect Inc.

25,000 0.006%

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Name, Municipality of

Residence and Current

Position with the

Company

Director Since

Present Principal Occupation or Employment

(including all officer position currently held with the

Company), Principal Occupation or Employment for

the Past Five Years or more, and Other Current

Public Directorships(1)

Number of

Common Shares

Beneficially

Owned, Directly or

Indirectly, or Over

Which Control or

Direction is

Exercised

(2)

Percentage of

Common

Shares Held

Augusto Lopez(6)

Bogota, Colombia

Director

June 10, 2011 Mr. Lopez is an electrical engineer, a designation obtained

through the Sociedad Antioqueña de Ingenieros in

Colombia, and holds an Electrical Engineering Degree

from Universidad Pontificia Bolivariana. Mr. Lopez is a

director of Pacific Rubiales Energy Corp. and has held the

position since April 2008. Mr. Lopez has worked for over

40 years in various capacities and in various industries in

South America and Europe, during 15 years as President

of Bavaria, S.A., Colombia’s largest beverage company.

Mr. Lopez also held senior positions at Inversiones

Bavaria S.A., an investment company. Mr. Lopez is the

managing partner of Prospectiva Financiera, a consulting

firm specializing in investment banking. Mr. Lopez is a

director of Petroamerica Oil Corp., of Tolima Gold Corp.,

and of Sportsat a firm operator of a national T.V channel

and producers of contents for television. Mr. Lopez also

participates on the boards of other public and private

companies in South America and Europe.

503,750 0.131%

Robert Doyle(4)

Toronto, Ontario

Canada

Director

June 10, 2011 Chief Executive Officer of Medoro from January 2008 to

October 2009; Chief Financial Officer of Coalcorp Mining

Inc., a coal producer, from November 2005 to May 2007;

Chief Financial Officer of Pacific Stratus Energy Ltd.

from October 2006 to May 2007 and Executive Vice

President from March 2006 to May 2007; and Chief

Financial Officer of Bolivar Gold Corp., a gold producer,

from January 2003 to February 2006.

42,856 0.011%

Hernan Juan Jose

Martinez Torres(6)

Barranquilla, Colombia

Director

June 10, 2011 Minister of Ministry of Mines (Colombia) from July 2006

to August 2010; President of Atunec S.A. from August

2002 to July 2006; and President and Chief Executive

Officer of Exxon Mobil Colombia S.A. from January 1964

to August 2002.

360,000 0.094%

Jaime Pèrez Branger(4)

Bogota, Colombia

Director

June 10, 2011 Managing Director of Next Ventures since 2006;

Executive Chairman of PetroMagdalena Energy Corp.

since June 2011; and President of C.A. Agropecuaria, ,

from May 2003 to October 2011.

148,874 0.038%

Robert Metcalfe(5)

Toronto, Ontario

Canada

Director

June 10, 2011 Counsel to Metcalfe, Blainey & Burns LLP since January

2001 and corporate director of numerous private and

publicly listed corporations.

73,000 0.019%

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Name, Municipality of

Residence and Current

Position with the

Company

Director Since

Present Principal Occupation or Employment

(including all officer position currently held with the

Company), Principal Occupation or Employment for

the Past Five Years or more, and Other Current

Public Directorships(1)

Number of

Common Shares

Beneficially

Owned, Directly or

Indirectly, or Over

Which Control or

Direction is

Exercised

(2)

Percentage of

Common

Shares Held

Mario Pacheco Bogota, Colombia

Director

September 21,

2011

Senior Vice President, Planning of Pacific Rubiales

Energy Corp. since 2008. Dr. Pacheco has over 27 years of

experience in the energy industry, including 17 years in

the Venezuelan oil industry. While in PDVSA, he held a

number of senior positions including Managing Director

of BITOR and Executive Director for Corporate Planning.

He holds a Ph.D. degree in Mechanical Engineering from

the Imperial College, University of London (1981). Prior

to joining Pacific Rubiales Energy Corp., he was special

advisor on strategy and energy to the Presidency of

CANTV (2005-2007). For a number of years Dr. Pacheco

lectured at Universidad Simon Bolivar and he is presently

Visiting Lecturer at the Instituto de Estudios Superiores de

Administracion (IESA) and UNIANDES.

325,000 0.085

José Oro

Bogota, Colombia

Vice President,

Production and Corporate

Development

N/A Vice-President, Production and Corporate Development of

the Company since June 10, 2011. Mr. Oro served as

Chief Operating Officer of the Company from August 20,

2010 to June 10, 2011. Mr. Oro was the Country Manager,

Colombia for Galway Resources Inc. from March 2006 to

April 2010. Prior to this position, he was a Vice President

of Kirkland Lake Gold, Inc. from February 2000 to March

2006. Mr. Oro has over 35 years working in several

different continents across the metal and mineral spectrum.

Mr. Oro is the former Director of the Mining and Geology

Department of Cuba. In addition to working with junior

and senior mining companies, Mr. Oro worked in the Latin

American Resource Sector for Coopers and Lybrand LLC.

Mr. Oro received post graduate degrees in Remote Sensing

and Geological Exploration in the Netherlands and Russia.

230,000 0.060%

Donald East Lima, Peru

Chief Operating Officer

N/A Chief Operating Officer of the Company since June 10,

2011; Chief Operating Officer of Medoro from January

2011 to June 10, 2011; Project Development Manager of

Anglo American Michiquillay from 2009-2010; Chief

Advisor of Rio Tinto Minera Peru from 2006-2009;

Director of Mining of Knight Piesold Consultores S.A.,

Lima from 2005-2006; Project Manager of Minera Gold

Fields S.A. from 2001-2005; and Project Manager of

Knight Piesold Consultants from 2003-2004.

258,000 0.067%

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Name, Municipality of

Residence and Current

Position with the

Company

Director Since

Present Principal Occupation or Employment

(including all officer position currently held with the

Company), Principal Occupation or Employment for

the Past Five Years or more, and Other Current

Public Directorships(1)

Number of

Common Shares

Beneficially

Owned, Directly or

Indirectly, or Over

Which Control or

Direction is

Exercised

(2)

Percentage of

Common

Shares Held

Michael Davies

Burlington, Ontario,

Canada

Chief Financial Officer

N/A Chief Financial Officer of the Company since August 20,

2010. Mr. Davies is a Chartered Accountant (Ontario) and

has a Bachelor of Commerce degree from the University

of Toronto. Over the last twenty years he has gained

extensive international and public company experience in

financial management, strategic planning and external

reporting. Mr. Davies has been the Chief Financial

Officer of Alange Energy Corp. (now PeteroMagdalena

Energy Corp.) since July 13, 2009, and from September

2004 to April 2007, Mr. Davies served as the Vice

President, Finance for The Clorox Company of Canada.

His diverse background also includes senior finance roles

with several public companies, including LAC Minerals,

IMAX Corporation, Amtelecom Communications,

Energentia Resources, Pamour Inc. and Giant Yellowknife

Mines.

361,873 0.094%

Peter Volk

Toronto, Ontario

Canada

General Counsel and

Secretary

N/A General Counsel and Secretary of the Company since

August 20, 2010; Vice President and General Counsel of

Medoro from January 19, 2010 to June 10, 2011; General

Counsel and Secretary of Medoro from June 2005 to

January 2010; General Counsel and Secretary of Alanage

Energy Corp. (now PetroMagdalena Energy Corp.) since

July 13, 2009; and General Counsel of Pacific Rubiales

Energy Corp. since January 23, 2008.

19,981 0.005%

Vicente Mendoza Bogota, Colombia

Vice President,

Exploration

N/A VP of the Company since June 10, 2011; VP, Exploration

of Medoro from November 2009 to June 10, 211; Vice

President, Explorations of Coalcorp Mining Inc. from June

2006 to November 2009; Vice President, Exploration of

Blue Pacific Assets Corp. from March 2009 – November

2009; and Vice President of Hecla Mining Company from

January 2000 to May 2006.

Nil N/A

Roy MacDonald Toronto, Ontario

Canada

VP, Investor Relations

N/A VP, Investor Relations of the Company since March 1,

2012; Investor Relations Consultant from 2011-2012 for a

global oil and gas company; Chief Financial Officer of

Multi-Service Switching – Nortel from 2010-2011;

Director of Mergers and Acquisitions – Nortel from 2009-

2010; and Director of Investor Relations – Nortel from

2005-2009.

Nil N/A

______________________________ Notes:

(1) This information as to principal occupation, not being within the knowledge of the Company, has been furnished by the respective directors

individually. (2) Common Shares beneficially owned, or controlled or directed, directly or indirectly, or over which control or direction is exercised.

(3) Member of the Executive Committee. Messrs. Iacono and de la Campa each serve as Co-Chair of the Executive Committee and Mr. Arata

serves as Advisor to the Executive Committee. (4) Member of the Audit Committee. Mr. Branger serves as Chair of the Audit Committee.

(5) Member of the Compensation, Corporate Governance and Nominating Committee. Mr. Arata serves as Chair of this Committee.

(6) Member of the Safety and Environmental Committee. Mr. Martinez serves as the Chair of the Safety and Environmental Committee. (7) The Board, after each annual meeting of the Shareholders of the Company, appoints the Company’s officers and committees for the ensuing

year.

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13 CORPORATE CEASE TRADE ORDERS

Except as disclosed immediately below, no director or executive officer of the Company, is, or within the

ten years prior to the date hereof, has been a director, chief executive officer or chief financial officer of

any company (including Gran Colombia) that was the subject of a cease trade order or similar order or an

order that denied the relevant company access to any exemptions under securities legislation for a period

of more than 30 consecutive days, while such director or executive officer was acting in the capacity as

director, chief executive officer or chief financial officer of the company being the subject of such order,

or that was issued after the director or executive officer ceased to be a director, chief executive officer or

chief financial officer in the company being the subject of such order and which resulted from an event

that occurred while that person was acting in the capacity as director, chief executive officer or chief

financial officer of the subject company.

Stephen Wilkinson is a director of HMZ Metals, which applied for and was granted a MCTO in

connection with the late filing of interim financial statements for the period ended June 30, 2005. The

MCTO was put into effect August 24, 2005 and revoked pursuant to a revocation order dated October 21,

2005. An MCTO was again invoked on April 9, 2008 and remained in force until May 30, 2008. HMZ

received a general cease trade order from the Ontario Securities Commission effective May 1, 2009 for

failure to file the audited annual financial statements for the year ended December 31, 2008 and the

management’s discussion and analysis relating to these audited financial statements.

Mr. Wilkinson is also an officer and director of ValGold Resources, which applied for and was granted a

MCTO in connection with the late filing of audited financial statements for the period ended July 30, 2008.

The MCTO was put into effect December 9, 2008 and revoked on January 26, 2009. In connection with the

late filing of audited financial statements for the period ended July 30, 2009, ValGold Resources applied for

but was not granted a MCTO on November 30, 2009. Cease trade orders were issued by the British

Columbia and Ontario Securities Commissions on December 7, 2009 and December 9, 2009, respectively.

ValGold Resources reported that the cease trade orders were fully revoked by December 23, 2009.

Robert J. Metcalfe, a director and Chairman of the Board, was a judge-affirmed independent director of

Hollinger Inc. from September 28, 2004 to July 21, 2005, in which capacity he was the subject of a

management and insider cease trade order (since lifted) which existed prior to his appointment to the board

of directors of Hollinger Inc., due to the inability of Hollinger Inc. to file financial statements resulting from

the non-filing of financial statements by Hollinger Inc.’s US subsidiary, Hollinger International Inc.

14 CORPORATE BANKRUPTCIES

No director or executive officer, or a shareholder holding a sufficient number of securities in the capital of

the Company to affect materially the control of the Company, is or within ten years prior to the date

hereof, has been a director or executive officer of any company (including Gran Colombia), that while

that person was acting in that capacity or within a year of that person ceasing to act in that capacity,

became bankrupt, made a proposal under any legislation relating to bankruptcy or insolvency or was

subject to or instituted any proceedings, arrangement or compromise with creditors or had a receiver,

receiver manager or trustee appointed to hold its assets.

15 PENALTIES OR SANCTIONS

No director or executive officer of the Company, and no shareholder holding a sufficient number of

securities of the Company to affect materially the control of the Company, has been subject to any

penalties or sanctions imposed by a court relating to securities legislation or by a securities regulatory

authority or has entered into a settlement agreement with a securities regulatory authority, or any other

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penalties or sanctions imposed by a court or regulatory body that would be likely to be considered

important to a reasonable investor making an investment decision.

16 PERSONAL BANKRUPTCIES

No director or executive officer of the Company, or a shareholder holding a sufficient number of

securities of the Company to affect materially the control of the Company, nor any personal holding

company of any such person, has, during the ten years prior to the date hereof, become bankrupt, made a

proposal under any legislation relating to bankruptcy or insolvency, or has been subject to or instituted

any proceedings, arrangement or compromise with creditors, or had a receiver, receiver manager or

trustee appointed to hold his, her or its assets.

The information in the foregoing sections entitled “Cease Trade Orders”, “Corporate Bankruptcies”,

“Penalties or Sanctions” and “Personal Bankruptcies”, has been furnished by the respective directors

and/or officers of the Company individually, and are not within the knowledge of the Company.

17 CONFLICTS OF INTEREST

There are potential conflicts of interest to which the directors or officers of the Company or its

subsidiaries may be subject to in connection with the operations of the Company. All of the directors and

officers are engaged in and will continue to be engaged in corporations or businesses which may be in

competition with the business of the Company. Accordingly, situations may arise where the directors and

officers will be in direct competition with the Company. Conflicts, if any, will be subject to the

procedures and remedies as provided under the BCBCA. As of the date of this Annual Information Form,

the directors and officers of the Company are not currently aware of the existence of any such conflicts of

interest.

The Company’s directors and officers may serve as directors or officers of other companies or have

significant shareholdings in other resource companies and, to the extent that such other companies may

participate in ventures in which the Company may participate, the directors of the Company may have a

conflict of interest in negotiating and concluding terms respecting the extent of such participation. If such

conflict of interest arises at a meeting of the Company’s directors, a director who has such a conflict will

abstain from voting for or against the approval of such participation or such terms. From time to time,

several companies may participate in the acquisition, exploration and development of natural resource

properties thereby allowing for the participation in larger programs, permitting involvement in a greater

number of programs and reducing financial exposure in respect of any one program. It may also occur

that a particular company will assign all or a portion of its interest in a particular program to another of

these companies due to the financial position of the Company making the assignment. In accordance with

the laws of the Province of British Columbia, the directors of the Company are required to act honestly, in

good faith and in the best interests of the Company. In determining whether or not the Company will

participate in a particular program and the interest therein to be acquired by it, the directors will primarily

consider the degree of risk to which the Company may be exposed and its financial position at that time.

18 LEGAL PROCEEDINGS

Except as disclosed below, management is not aware of any current or contemplated material legal

proceedings to which the Company is a party or which any of its property is the subject. From time to

time, the Company is the subject of litigation arising out of the Company’s operations. Damages claimed

under such litigation may be material or may be indeterminate and the outcome of such litigation may

materially impact the Company’s financial condition or results of operations. While the Company

assesses the merits of each lawsuit and defends itself accordingly, the Company may be required to incur

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significant expenses or devote significant resources to defend itself against such litigation. These claims

(if any) are not currently expected to have a material impact on the Company’s financial position.

The Company has tried to engage the Venezuelan Government with respect to negotiations for the

Company’s properties in Venezuela for pricing and transfer of ownership the nationalized portion of the

projects. As the prescribed negotiation period has expired, the Company intends to pursue the remedies

afforded to it by the Agreement between Venezuela and Canada for the Promotion and Protection of

Investments (which has been in force since 1998), including, if warranted, seeking such compensation

through international arbitration. See “Risk Factors – Economical and Political Factors – Venezuela”.

19 REGULATORY ACTIONS

There have been no penalties or sanctions imposed against the Company by a court relating to provincial

and territorial securities legislation or by a securities regulatory authority during the most recently

completed financial year of the Company.

There have been no penalties or sanctions imposed by a court or regulatory body against the Company

that would likely be considered important to a reasonable investor making an investment decision.

The Company has not entered into any settlement agreements before a court relating to securities

legislation or with a securities regulatory during the most recent completed financial year of the

Company.

20 INTEREST OF MANAGEMENT AND OTHERS IN MATERIAL TRANSACTIONS

Except as described below, no director or executive officer of the Company or any shareholder

beneficially owning or controlling, directly or indirectly, more than 10% of the issued and outstanding

Common Shares, or another of their respective associates or affiliates, has any material interest, direct or

indirect, in any transactions within the three most recently completed financial years or during the current

financial year or any proposed transactions which has materially affected or is reasonably expected to

materially affect the Company or any of its subsidiaries.

In February 2010, the Company received proceeds of US$1.0 million through two unsecured promissory

notes payable bearing interest at 12% per annum payable at maturity. A US$0.5 million promissory note

payable to Blue Pacific was immediately repaid following the completion of the First Gran Colombia

Private Placement. Three directors of the Company indirectly control, or provide investment advice to

the holders of, 67.2% of the shares of Blue Pacific. The second US$0.5 million promissory note payable

to Knottsville Capital, S.A., a shareholder of the Company, was repaid in November 2010.

In connection with the Frontino Acquisition, a success fee of US$3,000,000 was payable by Gran

Colombia to a company of which Messrs. Iacono and de la Campa are principals, in recognition of the

services rendered by Messrs. Iacono and de la Campa in negotiating and the Frontino Acquisition on

behalf of Gran Colombia.

21 TRANSFER AGENT AND REGISTRAR

Equity, 200 University Ave., Suite 400, Toronto, Ontario, M5H 4H1, is the transfer agent and registrar for

the Common Shares and Warrants, and the trustee for the Notes.

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22 MATERIAL CONTRACTS

The Company did not enter into any material contracts during the most recently completed financial year,

and has not entered into any material contract since January 1, 2002 and before the most recently

completed financial year that is still in effect, other than material contracts entered into in the ordinary

course of business that are not required to be filed under National Instrument 51-102 – Continuous

Disclosure Obligations and the contracts set forth below:

(a) the Frontino Acquisition Agreement entered into between Gran Colombia Panama, Medoro and

Zandor dated March 29, 2010 in connection with the Frontino Acquisition. For further

information see the heading entitled “General Development of the Business – Acquisition of

100% Interest in Zandor”;

(b) the acquisition agreement entered into between Old GCM and Gran Colombia Panama effective

July 26, 2010 in connection with the RTO whereby Old GCM acquired all of the issued and

outstanding securities in the capital of Gran Colombia Panama pursuant to the Gran Colombia

Amalgamation;

(c) the amalgamation agreement entered into between Panama Newco and Gran Colombia Panama

dated August 19, 2010 in connection with the Gran Colombia Amalgamation. For further

information see the heading entitled “Information Concerning the Company – Name, Address and

Incorporation”;

(d) The Royalty Agreement. In connection with the acquisition of all of the issued and outstanding

shares of Panwest Seas Corporation Ltd. on July 10, 2006, the Company is obligated to pay the

Panwest shareholders (being Corporacion Vengroup, S.A and Socobal Corporation) a royalty

equal to US$15 per each ounce of gold on all production from the Lo Increíble Properties. For

further information see the heading entitled “Properties – Other Projects – Lo Increíble

Properties”;

(e) The Warrant Indenture. For further information see the heading entitled “Description of Capital

Structure – Warrants”;

(f) The Arrangement Agreement. For further information see the heading entitled “General

Development of the Business – 2011 – Medero Merger” and “General Development of the

Business – Significant Acquisitions or Dispositions – Medoro Merger”;

(g) The Plan of Arrangement. For further information see the heading entitled “General Development

of the Business – 2011 – Medero Merger” and “General Development of the Business –

Significant Acquisitions or Dispositions – Medoro Merger”; and

(h) The Note Indenture. For further information see the heading entitled “General Development of

the Business – 2011– Note Offering” and “Market for Securities – Notes”.

The material contracts described above may be inspected at the head office of the Company at 333 Bay

Street, Suite 1100, Toronto, Ontario, M5H 2R2 during normal business hours.

23 INTERESTS OF EXPERTS

The auditors of the Company are KPMG LLP, Chartered Accountants, Toronto, Ontario, Canada. KPMG

LLP are independent within the meaning of the Rules of Professional Conduct of the Institute of

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Chartered Accountants of Ontario. KPMG LLP were first appointed auditors of the Company on August

20, 2010.

Karen Volp of SRK ES prepared the Mazamorras Technical Report, and James Gilbertson and Colin

Rawbone of SRK ES authored the Carla Project Technical Report. Scott E. Wilson of SEWC and Stewart

D. Redwood authored the Segovia Operations Technical Report. Stewart D. Redwood authored the El

Zancudo Technical Report and the Concepción Technical Report. Mike Armitage and Ben Parsons of

SRK UK authored the Marmato Technical Report. Mike Armitage and Lucy Roberts of SRK authored

the Lo Increíble Technical Report. To management’s knowledge, as of the date hereof, the authors of the

Technical Reports do not have any registered or beneficial interests, direct or indirect, in any securities or

other property of the Company, except for Scott Wilson and Stewart Redwood, who each beneficially

own, directly or indirectly, less than 1% of the outstanding securities of the Company. The Company has

determined that a reasonable person would not consider such interests to interfere with the respective

author’s judgment regarding the preparation of the respective technical reports. No director, officer, or

employee of the authors or their respective companies is expected to be elected, appointed or employed as

a director, officer or employee of the Company or of any Associate or Affiliate of the Company.

24 AUDIT COMMITTEE INFORMATION

24.1 The Audit Committee’s Charter

The full text of the Company’s Audit Committee Charter is appended hereto as Appendix “A”.

24.2 Composition of the Audit Committee and Relevant Education and Experience

The Audit Committee is comprised of three directors of the Company, Jaime Perez Branger (Chair) (who

replaced Ronald Pantin as a member of the Audit Committee effective June 10, 2011), Robert Doyle (who

replaced Robert Hines as a member of the Audit Committee effective June 10, 2011), and Stephen

Wilkinson. All of the members of the audit committee are independent and financially literate for purposes

of NI 52-110. Each has numerous years’ business experience and each has held or currently holds executive

positions that required oversight and understanding of the accounting principles underlying the preparation of

the Company’s financial statements and is aware of the internal controls and other procedures necessary for

financial control and reporting.

Jaime Perez Branger (Chair)

Mr. Perez Branger has a Master’s degree in economics from the London School of Economics and has

more than 20 years of experience in the financial and industrial sector. He is a director and member of the

audit committee of each of Pacific Coal Resources Ltd. and PetroMagdalena Energy Corp., and is the

Executive Chairman of PetroMagdalena Energy Corp. Currently, he is a member of the board of directors

of a number of companies inside and outside Venezuela related to the financial, agricultural, commercial,

and tourism sectors as well as a director of several business guild organizations. Previously, he was a

founding partner of Andino Capital Markets, a Latin American investment bank where he was directly

responsible for corporate finance and private equity investments. From 1991 to 1992, Mr. Perez Branger

managed the Corporate Finance Department at Vestcorpartners a regional investment bank. Prior to this,

he was Vice-President in charge of capital markets and corporate finance at Citibank, Caracas.

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Robert Doyle

From January 2008 to October 2009, Mr. Doyle was the Chief Executive Officer of Medoro, and from

2005 through 2006, was with Pacific Stratus Energy as Executive Vice President, Chief Financial Officer

from October 2006 to May 2007, and Vice President from March 2006 to May 2007. He also was Chief

Financial Officer of Coalcorp Mining Inc. from November 2005 to May 2007, and Chief Financial

Officer of Bolivar Gold Corp. from January 2003 to February 2006. Mr. Doyle, a chartered accountant

and a chartered director, has over 30 years’ experience in all facets of international resource exploration,

development and production. Mr. Doyle brings a broad skill set to the Board, including a thorough

understanding of operations and financial strategy of international mining companies, and has experience

in analyzing and evaluating financial statements that present a breadth and level of complexity of

accounting issues that are generally comparable to the breadth and complexity of issues that can

reasonably be expected to be raised by the Company’s financial statements, or experience actively

supervising one or more individuals engaged in such activities. Through his experience as being the

Chief Financial Officer for numerous public companies, Mr. Doyle also has an understanding of internal

controls and procedures for financial reporting.

Stephen Wilkinson

Mr. Wilkinson is a mining executive, corporate director and business consultant based in North

Vancouver, British Columbia. Since September 2002, he has served as President, Chief Executive Officer

and director of ValGold Resources, an international mining development company. Mr. Wilkinson was

President, Chief Executive Officer and Director of Northern Orion Explorations Ltd. for the period of

1999 to 2002. In his capacity as Chief Executive officer of such companies, Mr. Wilkinson developed an

understanding of interal controls and procedures for financial reporting. From 1996 to 1999, he was the

Vancouver-based mining analyst for RBC Dominion Securities Inc. responsible for small capitalization

gold and base metal companies. Mr. Wilkinson has extensive experience in the mining and finance

industries having served as an officer and director of several private and public companies, supplemented

over the past three decades by experience working for mining companies and government agencies. He

has also been a member of audit committees for several small to medium cap mining companies. Mr.

Wilkinson has a Bachelor of Science from the University of Western Ontario (Geology, 1976), a Master

of Science from Carleton University in Ottawa, Ontario (Geology, 1983) and an M.B.A. from Clarkson

University in Potsdam, New York (1995), where he studied management and financial accounting. He has

also taken instruction by accounting firms respecting the general principles and applications of IFRS.

24.3 Reliance on Certain Exemptions

At no time since the commencement of the Company’s most recently completed financial year has the

Company relied on exemptions in relation to section 2.4 of NI 52-110 (De Minimis Non-Audit Services),

section 3.2 of NI 52-110 (Initial Public Offerings), section 3.4 of NI 52-110 (Events Outside Control of

Member), section 3.5 of NI 52-110 (Death, Disability or Resignation of Audit Committee Member)

section 3.2(2) of NI 52-110 (Controlled Companies) or section 3.6 of NI 52-110 (Temporary Exemption

for Limited and Exceptional Services), section 3.9 of NI 52-110 (Acquisition of Financial Literacy) or

any exemption provided by Part 8 of NI 52-110 (Exemptions).

24.4 Audit Committee Oversight

The Audit Committee is mandated to monitor audit functions, the preparation of financial statements,

review press releases on financial results, review other regulatory documents as required, and meet with

outside auditors independently of management.

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At no time since the commencement of the Company’s most recently completed financial year was a

recommendation of the Audit Committee to nominate or compensate an external auditor not adopted by

the Board.

24.5 Pre-Approval Policies and Procedures

The Company has adopted policies and procedures with respect to the pre-approval of audit and permitted

non-audit services by KPMG LLP. The Audit Committee has established a budget for the provision of a

specified list of audit and permitted non-audit services that the Audit Committee believes to be typical,

recurring or otherwise likely to be provided by KPMG LLP. The budget generally covers the period

between the adoption of the budget and the next meeting of the Audit Committee, but at the option of the

Audit Committee it may cover a longer or shorter period. The list of services is sufficiently detailed as to

the particular services to be provided to ensure that: (i) the Audit Committee knows precisely what

services it is being asked to pre-approve; and (ii) it is not necessary for any member of management to

make a judgment as to whether a proposed service fits within the pre-approved services.

Subject to the next paragraph, the Audit Committee has delegated authority to the Chair of the Audit

Committee (or if the Chair is unavailable, any other member of the Audit Committee) to pre-approve the

provision of permitted services by KPMG LLP which have not otherwise been pre-approved by the Audit

Committee, including the fees and terms of the proposed services (“Delegated Authority”). All pre-

approvals granted pursuant to Delegated Authority must be presented by the member(s) who granted the

pre-approvals to the full Audit Committee at its next meeting.

All proposed services, or the fees payable in connection with such services, that have not already been

pre-approved must be pre-approved by either the Audit Committee or pursuant to Delegated Authority.

Prohibited services may not be pre-approved by the Audit Committee or pursuant to Delegated Authority.

24.6 External Auditor Service Fees (By Category)

The following are the aggregate fees incurred by the Company for services provided by its external

auditors during fiscal 2011 and 2010:

2011 2010

(1)

1. Audit Fees(2)

US$453,912 US$264,745

2. Audit Related Fees US$125,750(3)

US$86,750(4)

3. Tax Fees(5)

US$24,096 -

4. All Other Fees - -

Total US$603,758 US$351,495

______________________________

Note:

(1) Revised since the Company’s Annual Information Form for the December 31, 2010 year end. (2) Includes fees related to interim reviews and the annual audit.

(3) Includes fees related to services performed in connection with the Note Offering and Medoro Merger.

(4) Includes fees related to the Company’s filing statement. (5) Includes fees for services rendered from January through December of the fiscal year, notwithstanding when the fees were billed.

25 ADDITIONAL INFORMATION

Additional information about the Company, including, but not limited to, directors’ and officers’

remuneration and indebtedness, principal holders of the Company’s securities and securities authorized

for issuance under the Company’s stock option plan is contained in the management information circular

of the Company dated May 6, 2011. Additional financial information is provided in the Company’s

audited financial statements and Management’s Discussion & Analysis for the year ended December 31,

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2011 and the unaudited financial statements. This information and other pertinent information regarding

the Company can be found on SEDAR at www.sedar.com.

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APPENIDX “A”

AUDIT COMMITTEE CHARTER

(Initially adopted by the Board of Directors on September 23, 2010)

GRAN COLOMBIA GOLD CORP.

(the “Corporation”)

A. PURPOSE

The overall purpose of the Audit Committee (the “Committee”) is to ensure that the Corporation’s

management has designed and implemented an effective system of internal financial controls, to review

and report on the integrity of the consolidated financial statements of the Corporation and related

financial information, and to review the Corporation’s compliance with regulatory and statutory

requirements as they relate to financial statements, taxation matters and disclosure of financial

information. In performing its duties, the committee will maintain effective working relationships with

the board of directors of the Corporation (the “Board”), management, and the external auditors and

monitor the independence of those auditors. To perform his or her role effectively, each Committee

member will obtain an understanding of the responsibilities of committee membership as well as the

Corporation’s business, operations and risks.

B. COMPOSITION, PROCEDURES AND ORGANIZATION

1. The Committee shall consist of at least three members of the Board, each of which shall be an

independent director.

2. All of the members of the Committee shall be “financially literate”.

3. At least one member of the Committee shall have accounting or related financial management

experience.

4. The Board, at its organizational meeting held in conjunction with each annual general meeting of the

shareholders, shall appoint the members of the Committee for the ensuing year. Any member of the

Committee may be removed or replaced at any time by the Board and shall cease to be a member of

the Committee on ceasing to be a director. The Board may fill vacancies on the Committee by

election from among its number. If and whenever a vacancy shall exist on the Committee, the

remaining members may exercise all its powers so long as a quorum remains in office. Subject to

the above, each member of the Committee shall hold office as such until the next annual general

meeting of the shareholders after his/her election.

5. Unless the Board shall have appointed a chair of the Committee, the members of the Committee shall

elect a chair and a secretary from among their number.

6. The quorum for meetings shall be a majority of the members of the Committee, present in person or

by telephone or other telecommunication device that permits all persons participating in the meeting

to speak to and to hear each other. No business may be transacted by the Committee except at a

meeting of its members at which a quorum of the Committee is present.

7. The Committee shall have full and unrestricted access to such officers, employees and personnel of

the Corporation and to the Corporation’s external and internal auditors, and to such information,

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books, records and facilities of the Corporation, as it considers to be necessary or advisable in order

to perform its duties and responsibilities.

8. The Committee shall have the authority to:

a) engage independent counsel and other advisors as it determines necessary to carry out its duties

and to request any officer or employee of the Corporation or the Corporation’s external counsel

or auditors to attend a meeting of the Committee;

b) set and pay the compensation for any advisors employed by the Committee; and

c) designate members of the Committee the authority to grant appropriate pre-approvals required

in respect of non-audit services performed by the auditors and the decisions of any member to

whom authority is delegated to pre-approve an activity shall be presented to the Committee at

its first scheduled meeting following such pre-approval.

9. Meetings of the Committee shall be conducted as follows:

a) the Committee shall meet at least four times annually at such times and at such locations as may

be requested by the chair of the Committee. The external auditors or any member of the

Committee may request a meeting of the Committee;

b) the external auditors shall receive notice of and have the right to attend all meetings of the

Committee;

c) the Committee has the right to determine who shall and shall not be present at any time during a

meeting. Management representatives may be invited to attend meetings, provided that the

Committee shall hold separate, regularly scheduled meetings at which members of management

are not present; and

d) the proceedings of all meetings shall be minuted.

10. Each member of the Committee shall be entitled, to the fullest extent permitted by law, to rely on the

integrity of those persons and organizations within and outside the Corporation from whom he or she

receives information, and the accuracy of the information provided to the Corporation by such other

persons or organizations.

11. The internal auditors and the external auditors shall have a direct line of communication to the

Committee through its chair and may bypass management if deemed necessary. The Committee,

through its chair, may contact directly any employee in the Corporation as it deems necessary, and

any employee may bring before the Committee any matter involving questionable, illegal or

improper financial practices or transactions.

12. The members of the Committee shall be entitled to receive such remuneration for acting as members

of the Committee as the Board may from time to time determine.

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C. ROLES AND RESPONSIBILITIES

1. The overall duties and responsibilities of the Committee shall be as follows:

a) assist the Board in discharging its responsibilities relating to the Corporation’s accounting

principles, reporting practices and internal controls and its approval of the Corporation’s annual

and quarterly consolidated financial statements and related financial disclosure;

b) establish and maintain a direct line of communication with the Corporation’s internal and

external auditors and assess their performance;

c) ensure that the management of the Corporation has designed, implemented and is maintaining

an effective system of internal financial controls; and

d) report its deliberations and discussions regularly to the Board, including reporting on the

fulfilment of its duties and responsibilities.

2. The duties and responsibilities of the Committee as they relate to the external auditors shall be as

follows:

a) review the independence and performance of the external auditors and annually recommend to

the Board a firm of external auditors to be nominated for the purpose of preparing or issuing an

auditors’ report or performing other audit, review or attest services for the Corporation;

b) review and approve the fee, scope and timing of the audit and other related services rendered by

the external auditors;

c) review the audit plan of the external auditors prior to the commencement of the audit;

d) approve in advance provision by the external auditors of services other than auditing to the

Corporation or any of its subsidiaries;

e) annually review and discuss all significant relationships the external auditors have with the

Corporation that could impair the external auditors’ independence;

f) review with the external auditors, upon completion of their audit:

i. contents of their report;

ii. scope and quality of the audit work performed;

iii. adequacy of the Corporation’s financial and auditing personnel;

iv. co-operation received from the Corporation’s personnel during the audit;

v. internal resources used;

vi. significant transactions outside of the normal business of the Corporation;

vii. significant proposed adjustments and recommendations for improving internal

accounting controls, accounting principles or management systems; and

viii. the non-audit services provided by the external auditors;

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g) discuss with the external auditors the quality and the acceptability of the Corporation’s

accounting principles;

h) implement structures and procedures to ensure that the Committee meets the external auditors

on a regular basis in the absence of management; and

i) oversee the work of the external auditors, including the resolution of disagreements between

management and the external auditor regarding financial reporting.

3. The duties and responsibilities of the Committee as they relate to the Corporation’s internal auditors

are to:

a) periodically review the internal audit function with respect to the organization, staffing and

effectiveness of the internal audit department;

b) review and discuss with the Chief Corporate Auditor (the “CCA”) the CCA’s annual risk

assessment of the adequacy and effectiveness of the Corporation’s internal control process, the

CCA’s report to the Committee on the results of the annual audit plan and the status of the audit

issues, and the CCA’s recommendations regarding improvements to the Corporation’s controls

and processes;

c) review and approve the internal audit plan;

d) review significant internal audit findings and recommendations, and management's response

thereto; and

e) annually review with the Corporation’s legal counsel any legal matters that could have a

significant impact on the Corporation’s financial statements, the Corporation’s compliance with

applicable laws and regulations, and inquiries received from regulators or governmental

agencies.

4. The duties and responsibilities of the Committee as they relate to the internal control procedures of

the Corporation are to:

a) review the appropriateness and effectiveness of the Corporation’s policies and business

practices which impact on the financial integrity of the Corporation, including those relating to

internal auditing, insurance, accounting, information services and systems and financial

controls, management reporting and risk management;

b) review any unresolved issues between management and the external auditors that could affect

the financial reporting or internal controls of the Corporation; and

c) periodically review the Corporation’s financial and auditing procedures and the extent to which

recommendations made by the internal audit staff or by the external auditors have been

implemented.

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5. The Committee is also charged with the responsibility to:

a) review the Corporation’s quarterly financial statements and related financial information,

including the impact of unusual items and changes in accounting principles and estimates and

report to the Board with respect thereto before such information is publicly disclosed;

b) review and approve the financial sections of:

i. the annual report to shareholders;

ii. the annual information form, if required;

iii. annual and interim management’s discussion and analysis;

iv. prospectuses;

v. news releases discussing financial results of the Corporation; and

vi. other public reports of a financial nature requiring approval by the Board,

and report to the Board with respect thereto before such information is publicly disclosed;

c) ensure that adequate procedures are in place for the review of the Corporation’s public

disclosure of financial information extracted or derived from the Corporation’s financial

statements, other than the public disclosure referred to in item 5(b) above, and periodically

assess the adequacy of such procedures;

d) review regulatory filings and decisions as they relate to the Corporation’s consolidated financial

statements;

e) review the appropriateness of the policies and procedures used in the preparation of the

Corporation’s consolidated financial statements and other required disclosure documents, and

consider recommendations for any material change to such policies;

f) review and report on the integrity of the Corporation’s consolidated financial statements;

g) establish procedures for:

i. the receipt, retention and treatment of complaints received by the Corporation regarding

accounting, internal accounting controls, or auditing matters; and

ii. the confidential, anonymous submission by employees of the Corporation of concerns

regarding questionable accounting or auditing matters;

h) review and approve the Corporation’s hiring policies regarding partners, employees and former

partners and employees of the present and former external auditors of the Corporation;

i) review with management, the external auditors and, if necessary, with legal counsel, any

litigation, claim or other contingency, including tax assessments that could have a material

effect upon the financial position or operating results of the Corporation and the manner in

which such matters have been disclosed in the consolidated financial statements;

j) review the Corporation’s compliance with regulatory and statutory requirements as they relate

to financial statements, tax matters and disclosure of financial information;

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k) review annually and recommend updates to this Charter of the Committee and receive approval

of changes from the Board;

l) review the minutes of any audit committee of subsidiary companies of the Corporation; and

m) perform other functions consistent with this Charter, the Corporation’s articles and governing

law, as the Committee or the Board deems necessary or appropriate.

6. While the Committee has the responsibilities and powers set forth in this Charter, it is not the duty of

the Committee to plan or conduct audits or to determine that the Corporation’s financial statements

and disclosures are complete and accurate and in accordance with generally accepted accounting

principles and applicable rules and regulations, each of which is the responsibility of management

and the Corporation’s external auditors.

D. CURRENCY OF CHARTER

This charter was last revised and approved by the Board on September 23, 2010.