SecProbe.io

March 3, 2025
Ibrahima Tall
Chief Executive Officer
Namib Minerals
71 Fort Street, PO Box 500
Grand Cayman, Cayman Islands, KY1-1106
Tulani Sikwila
Chief Financial Officer
Greenstone Corporation
71 Fort Street, PO Box 500
Grand Cayman, Cayman Islands, KY1-1106
Re:Namib Minerals
Amendment No. 3 to Registration Statement on Form F-4
Filed February 25, 2025
File No. 333-283650
Dear Ibrahima Tall and Tulani Sikwila:
            We have reviewed your amended registration statement and have the following
comments.
            Please respond to this letter by amending your registration statement and providing
the requested information. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information
you provide in response to this letter, we may have additional comments. Unless we note
otherwise, any references to prior comments are to comments in our February 18, 2025 letter.
Amendment No. 3 to Registration Statement on Form F-4
Greenstone Corporation Financial Statements
3.3 Property and equipment, page F-108
We have read your response to comment 1. We understand your inferred resource
estimates are primarily based upon the expectation of future upgrades and recoveries
and they lack data and information generated by any mineral exploration program. In 1.

March 3, 2025
Page 2
the absence of adequate geological evidence, your estimates of inferred resources
should be excluded from consideration in the determination of the useful life of your
mining assets. As a result, please provide the following:
•Tell us how the exclusion of inferred resources impacts your depreciation expense
for mining assets under the application of the straight-line and units-of-production
methods for the periods presented.
•Provide us with the results of your calculation of both methods, highlighting the
difference between historical depreciation expense and the revised amounts and
the impact it has on your results of operations and financial position for the
periods presented.
•Tell us how you reconsidered the application of the units-of-production method
rather than the straight-line method and evaluated whether this depreciation
method may better reflect the pattern of consumption of future economic benefits,
as explained in IAS 16.
Namib Minerals
Audited Financial Statements, page F-137
2.Please update to include the subsequent interim financial statements of at least the
first six months of the financial year. We refer you to Item 8.A.5 of the requirements
to Form 20-F.
            Please contact Brian McAllister at 202-551-3341 or Shannon Buskirk at 202-551-
3717 if you have questions regarding comments on the financial statements and related
matters. Please contact Anuja Majmudar at 202-551-3844 or Irene Barberena-Meissner at
202-551-6548 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:Barbara Jones