According to Turkish Law, underground resources are subject to
the exclusive ownership and disposition of the State and are not
deemed as part of the land in which they are located. Pursuant to
Article 4 of the Mining Law (published in the Official Gazette
dated June 15, 1985 and numbered 18785) (Law No. 3213) (the
"Law"), property rights over the land
exclude any existing minerals. According to Article 6 of the Law,
mining rights can be defined as the licenses and permits for
prospecting mines, that can only be granted to the following
persons and entities: (i) Turkish citizens; (ii) legal entities
incorporated under the laws of Turkey, including legal entities
having foreign shareholders, provided that the articles of
association of such legal entities shall contain a relevant clause
which authorize the entity for mining operations; (iii) public
entities; and (iv) administrative bodies. Consequently, there is no
distinction between the mining rights that may be
