My Blog

Re: NOTICE OF INTENDED LEGAL ACTION – Unlawful Interference, Incitement,

Defamation, and Damages to Koidu Limited and Octea Limited

I write to you in my capacity as Director and acting General Counsel of Octea Limited and its group

companies (“Octea”), the parent of Koidu Limited (“Koidu” or the “Company”).

This letter concerns a pattern of unlawful, defamatory, and malicious statements and actions

attributed to your conduct, that have caused severe and ongoing damage to the Company, its

affiliates, personnel, stakeholders, and Octea, the parent of Koidu. Your actions—undertaken

without formal legal authority—have triggered a crisis that now poses a direct threat to public order,

lives, investor security, and Sierra Leone’s international standing, while also causing serious financial

harm to Octea.

Corporate Citizen

Since its establishment in July 2003, Koidu has operated in Sierra Leone with an unwavering

commitment to the laws of the country. Koidu is a major foreign investor in Sierra Leone that

employed 1,012 Sierra Leoneans (85% of its workforce) and supporting over 10,000 jobs indirectly;

we were one of the largest private employers in Sierra Leone and a consistent contributor to

national revenue and development. Since commencing operations, our audited financials shows we

have paid US$173m in taxes and royalties to the government of Sierra Leone, spent US$320m with

local suppliers to support the surrounding community, committed US$21m in resettlement funding

and donated US$15m to community development programmes.

The significant contributions to Sierra Leonean society as a whole are further emphasised by the

most recent report in January 2025 from the Sierra Leone Extractive Industries Transparency

Initiative (SLEITI), an independent publication audited by BDO, confirming Koidu made the highest

contribution of tax revenues from the entire extractive industry (31%). The report also confirms that

Koidu was fully compliant with all national regulations and adheres to strict labour laws enforced by

the National Social Security & Insurance Trust (NASSIT). Koidu was the last producing diamond

producing mine in Sierra Leone despite a global diamond industry that has been ravaged by a

precipitous collapse in rough diamond prices in recent years.

Octea Limited | Company Number: 65908

Registered Office: West Wing Frances House, Sir William Place, St Peter Port, Guernsey

Tel: +44 (0) 1481 812 000 Fax: +44 (0) 1481 812 020These and other issues have impacted all diamond mining enterprises, Koidu included. However,

these existential threats were no more severe than those caused by the COVID-19 pandemic in 2020

and the Ebola crisis in 2014, which saw Koidu adapt, protect and maintain its people as well as

survive without making any redundancies. This firmly underlines Koidu’s commitment to Kono and

its people, having never abandoned the region. That is until now, due to the illegal strike action you

and others promoted.

Community

As a reminder, Koidu was always committed to its corporate social responsibilities, dedicated to

sustainable development and actively involved in enhancing the livelihoods of Kono District

residents. We played an important role in fostering long-term growth and stability in Sierra Leone.

We provided scholarships to hundreds of university students and covered tuition fees for all Kono

District students enrolled in technical institutions, including the Kono University of Science &

Technology.

Koidu has undertaken numerous impactful projects, such as constructing and renovating institutions

like the Kono Blind School and building over 750 homes as part of the Resettlement Action Plan in

Koidu City. We constructed a police station at Kimbadu Settlement, staff mess at the Simbakoro

Barracks and Women Resource Hall at Tankoro Chiefdom; and supplied waste rock material for the

Congo Bridge in Koidu City. We have supported the construction of an ultra-modern maternity

hospital and, during the COVID-19 pandemic, we invested heavily in public health by building

screening centres at all border entry points around Kono District.

Koidu has played an essential role in enhancing the district’s electricity supply, connecting to the

West African Power Pool and paying the Electricity Distribution & Supply Authority (EDSA), leading

to significant improvements in electricity supply for the region. We donated generators to the Koidu

medical centre, we have continuously supplied fuel for all school buses serving the district and

assisted the Koidu City Mayor’s office by supplying fuel for waste collection trucks. These initiatives

were crucial in providing a stable and sustainable supply that would otherwise impair EDSA’s ability

to supply electricity to the east whilst the country faces a power outage crisis.

Illegal Actions

Calling an Illegal Strike

Koidu’s operations have consistently followed due process as per Sierra Leonean law. Despite

decades of adhering to international standards and not facing legal challenge in any jurisdiction, you

chose to promote strike action, illegal under sections 64 and 67 of the Industrial Relations & Trade

Union Act 2023 and Collective Bargaining Agreement 2022 – 2025, interfering with a successful

private company, that operated as a going concern.

2In view that Koidu has an unflinching commitment to upholding the laws and regulations of Sierra

Leone, there does not seem to be a similar commitment coming from you and your worker

representatives. In addition, there seems to have been no due diligence or simple fact checking to

any of the statements you have been making as part of your role in representing those who you

claim to be the workers of Koidu.

False Statements and defamation

You made false statements against the Company based only on hearsay evidence that you have

failed to disclose, which strongly suggests it is lacking. The Sierra Leone Anti-Corruption Commission

(ACC), an institution that investigated your own financial affairs for siphoning public and charity

funds for your personal shopping, travel and accommodation, has confirmed there was no evidence

of any corruption, bribery or similar illegal activities of Koidu. We would also like to publicly state

that we welcome any spotlight placed on state corruption and, if there is any shred of evidence

which you may have which confirms corruption between any government and Koidu representative,

the provision of this to the relevant authorities would be wholeheartedly welcomed by Koidu.

We had already addressed and resolved the alleged welfare conditions (providing cool refrigerated

bottled water underground, hygiene facilities and toilets) as inspected and confirmed by the

government. Our lowest salary exceeds the minimum wage by over three times. There is no ability

to physically touch the diamonds mined, which are processed by a fully controlled closed system

with body scanners and overseen by government officials through every step of this process. In

addition, the sales process for Koidu’s rough diamonds are witnessed not only by government

officials, but also an independent third party, at the Central Bank of Sierra Leone with no evidence of

theft whatsoever dating back to when production started in 2003.

You misrepresented the facts of the exchange rate, imposed by the Central Bank of Sierra Leone in

2016 and agreed with Koidu and the Union, that you vaguely described as “historical injustices”

.

Less than half of the current workforce remain employed on those contracts and concessions were

made by the Company, for example 110% increase in remuneration between 2016 to 2022, 50% cost

of living allowance in 2023, 25% annual bonus in 2024, 50kg bag of rice per month for each worker,

underground risk allowance, medical allowances doubled and covers five dependants per worker,

availability of the onsite medical facility and referrals to specialised medical institutions at the

Company’s expense.

It is unfortunate that your public statements reinforce the misconception that rough diamond

mining is unethical; it will merely encourage consumers to buy synthetic (lab-grown) diamonds

instead, who compete directly with an industry that Sierra Leone heavily relies upon.

Fraudulent Behaviour

You have sided with current and former employees, some dismissed for gross misconduct, they were

disgruntled, pedalling a false narrative without lodging any formal grievances to the Company.

These individuals have threatened our employees and their families with violence and intimidation.

They deceived our employees to sign for bags of rice handed out by your staff, and used their

signatures to fraudulently claim mass resignations and End of Service Benefits. I suggest you review

their disciplinary records and their respective defences to understand the very people you

represented. The Minister of Labour, Employment & Social Security and Minister of Mines and

3Minerals Resources were consistently briefed and fully aware of the tactics being used by these

individuals, further underscoring why neither took any legal action against the Company.

Such inaccuracies provide significant substance to our claim of defamation by you. This includes

misrepresentation of even chronological events, false and discriminatory statements of our

personnel, and purporting to our workers that you were involved in formal negotiations with Koidu

on their behalf.

As you will be fully aware, the Board of Directors of the Company never had any contact with you, no

video calls, emails, letters nor meetings; it dealt directly with government officials only, as per the

laws of Sierra Leone in such a matter, as the records show. Koidu’s lawyer even told you before the

strike commenced the Board of Directors must act strictly within its legal and corporate governance

framework, and engaging with you could expose them to culpability for breach of fiduciary – a duty

they unequivocally owe to the Company and must maintain at all times. You clearly have not

obtained any legal advice pertaining to the matter.

Incitement

You told the Company to close the mine and leave Kono if it did not acquiesce to your demands.

You instigated protests, threatened to “barricade” the Company, “blockade” our expatriate

employees and “storm” the Koidu mine site whilst you were surrounded by armed military

personnel. This undertone was a dangerous, particularly following similar incidents in 2007 and

2012 at Koidu’s mine site of a violent strike, storming and riots that resulted in fatalities following.

We requested that our national workers call off their illegal strike action and resume work on

numerous occasions, that you forbade as their self-proclaimed leader. You publicly stated that you

“controlled” our workforce and that only you can tell them to return to work, however you knew

that it was unlawful for the Company to negotiate with you under section 37 of the Industrial

Relations & Trade Union Act 2023. Though we remained isolated by the lack of government support

during this period, we maintained our position of not being held to ransom or to contravene the

laws of this country, with no workers reporting to work, specifically because of your direction.

Your continued incitement of hostility and provocation of unrest presented a clear and immediate

threat to life and safety. Your public statements and coordinated actions have directly contributed

to an environment where aggression was encouraged. Indeed, there were violent confrontations

and physical attacks on our personnel, their families and property; attempted intrusions; and

sabotage of critical infrastructure (including potable water supply for the local community). Even

journalists were threatened and hounded out of Koidu for reporting these incidents. Despite these

escalating threats, no formal guarantees of safety or security intervention was provided by the

authorities, nor have there been any arrests.

Legal opinion concludes that your rhetoric directed at the Koidu workers was reckless and

deliberately generated an atmosphere of potential unrest. As we were unable to guarantee a safe

working environment for our employees, as required under the Employment Act 2023, it left us with

no alternative but to evacuate all personnel except essential management from the mine site. We

therefore transitioned into care and maintenance, effectively shutting down the mine completely.

4Consequences of your action

As a direct result of your intervention, thousands of jobs of Sierra Leonean workers are now in

jeopardy, millions of US dollars in much needed revenues, taxes and royalties will be forgone by the

country, the central bank’s foreign currency reserves will severely deplete, local suppliers will not be

able to offer their goods and services to the mine, impacting thousands of individuals who are

dependent on business generated by the Koidu mine.

The initiating of illegal strike action, which has resulted in the immediate halting of operations of

one of Sierra Leone’s largest foreign direct investors, underlines the country’s precarious position

regarding its desire to attract the investment it needs from foreign investors, particularly when such

actions are endorsed and visibly supported by those who are seen as part of, if not proximate to, the

government of Sierre Leone. The macroeconomic consequences of your actions will have severe

repercussions for years to come and is potentially devastating for Sierra Leone.

Of significant concern to the wider African and indeed the international arena, it appears that your

behaviour is not only unconstitutional but also disregards the established laws of Sierra Leone that

we strictly adhere to and have done so from a position of power as the unelected First Lady of Sierra

Leone. It has never been our intention to argue our case through your desired route of having a

“social media war”, but we will seek redress with the undisputable evidence provided by you and

your acting group through national, regional and international courts and in complete adherence to

the laws of those courts which remain independent of government influence.

Financial Impact

You should also be aware that recommencing production following a period of care and

maintenance is technically complicated due to a dissipated workforce, the challenges of dewatering

underground operations, as well as impaired credit lines with suppliers. The damage wrought by

your actions will be extremely difficult to repair. The opportunity for another investor to restart

operations at Koidu, if that is your expectation, will be onerous in view of the requirement for

significant capital and the specialist technical skills (which currently can only be found outside of

Sierra Leone due to the complexities of large, commercial underground operations). These

challenges are compounded by Sierra Leone remaining a difficult jurisdiction to attract capital,

highlighted by the fact that a large foreign investor has had to shut operations because of your

actions.

To provide some additional context, your actions since the illegal strike commenced on 3 March

2025 have caused irrecoverable financial losses exceeding US$16m, which are increasing daily, and

US$20m to recommission the operation. In addition, and beyond the reputational damage to Koidu

and its management team, the collapse of income for thousands of Sierra Leonean workers and

families in the Kono District will be felt for generations to come. We are extremely concerned for

their livelihood caused by the financial hardship they could face following your illegal and

unwarranted intervention. We sincerely hope that with Koidu having fully adhered to all of its legal

commitments, the government of Sierra Leone will do similar and support all the ex-employees and

the impacted communities in Kono.

5Beyond the financial losses incurred, which we will be seeking redress for, further damages will be

sought following concerning your very public defamation, libel, malicious falsehood, incitement to

violence, abuse of influence, and unlawful interference with a legitimately operating business which

has unflinchingly adhered to the laws of Sierra Leone for the last 22 years.

Summary of Allegations

The following conduct, supported by contemporaneous evidence, is attributed directly to you:

• Tortious interference with the Company’s investment rights and property rights.

• Repeated public and private demands directed at the Company and its leadership, despite

your lack of official mandate.

• False accusations of bribery and corruption, including direct allegations against the Company

and its management.

• Attempts to suppress those accusations in exchange for payment—conduct that constitutes

blackmail and extortion.

• Malicious, fabricated and inflammatory claims that carry a harmful and defamatory

undertone, suggesting illicit or exploitative conduct with no basis in fact, and which amount

to slanderous insinuations that are both reckless and entirely without foundation.

• Widespread dissemination of knowingly false, contradictory, and reckless statements via

public platforms and social media.

• Incitement of protests, illegal blockades, threats to our employees from storming the mine

site thus putting lives and property at risk.

Legal Grounds and Enforcement

We reserve the right to take the following legal and enforcement actions against you without further

notice, seeking full damages for the financial, reputational and operational harm directly resulting

from your actions:

• Initiate civil and criminal legal proceedings in the High Court of Sierra Leone for defamation,

incitement, blackmail, unlawful interference, and related violations under national law,

• Claim for redress and your extradition under the Economic Community of West African

States (ECOWAS) Common Investment Code in Nigeria.

• File legal proceedings in the Royal Court of Guernsey, where our parent company is

domiciled, to pursue full commercial damages and injunctive relief.

6• File a formal complaint with the African Commission on Human and Peoples’ Rights in the

Gambia, and refer your conduct to other international human rights institutions.

• Launch international asset tracing investigations targeting all assets, directly or indirectly

associated with you, including those held via nominees, proxies, trusts, or offshore

structures, and worldwide freezing orders to prevent dissipation of assets.

• Seek international travel restrictions, arrest warrants and sanctions, including direct referral

to diplomatic and multilateral bodies.

• Engage foreign embassies and diplomatic missions with interests in Sierra Leone, including

but not limited to the European Union, Republic of South Africa, United Kingdom, Sweden

Philippines, Namibia, India, the United States and Zimbabwe to raise formal concerns

regarding your actions and their destabilising effect on the business climate.

These actions will be taken concurrently and aggressively in the interest of protecting the Company,

restoring the rule of law, and ensuring accountability.

Relief Sought

We hereby demand the following:

1. Payment of US$20m to restart operations so the dismissed or terminated employees can

resume their duties immediately and their entitlement to End of Services Benefits

reinstated.

2. An immediate and unconditional cease and desist from any further interference, threats,

public accusations, or communications targeting Koidu, Octea, or any of their personnel.

3. A formal and public retraction of all false, defamatory, and malicious statements made.

4. A written commitment that no further threats, blackmail, or incitement will be issued or

supported by you, directly or indirectly.

Notice of Intent

Unless we receive a full and satisfactory written response confirming your compliance with the

aforementioned relief, we reserve our rights to initiate legal and enforcement actions against you.

This letter is written without prejudice to all legal rights held by Octea, Koidu, and their affiliates, all

of which are expressly reserved.

7Yours sincerely,

Mr. Gustaf Fredrik Bodin

Director & General Counsel

For and on behalf of

Octea Limited

gbodin@octealimited.com

Cc: H.E. Dr Julius Maada Bio, President

Hon. Julius D. Mattai, Minister of Mines and Mineral Resources

Hon. David M. Sengeh, Chief Minister

Hon. Sheku A. F. Bangura, Minister of Finance

Hon. Mohamed R. Swaray, Minister of Employment, Labour & Social Security

Continue Reading