1. On April 17, 2018, the Ha Tinh I Construction Joint Stock Company (hereinafter referred to as "the Company") received Iinspection Conclusion No. 126 / KL-UBND dated April 13, 2018 by the Ha Tinh Province People's Committeeon the process of licensing andexploring activities in Nam Gioi Quarry Mountain, Thach Ban Commune, Thach Ha District, Ha Tinh Province (hereinafter referred to as "Inspection conclusion No.: 126 / KL-UBND" ). In Section 2, Part III, the examination conclusion No. 126 / KL-UBND stated:

“During the course of mining, the Company did not comply with the current laws on mining, land law, construction law, environmental law and Decision No. 20/2012. / QD-UBND ..., especifically as follows:

- the company did not implement seriously Conclusion No. 412 / KL-UBND dated October 3, 2012 and the Document No. 718 / UBND-CN1 dated February 28, 2014 of the Provincial People's Committee on remedying violations in the content at Article 17 of the Regulation issued together with Decision No. 20/2012 / QD-UBND dated May 16, 2012 of the People's Committee of Ha Tinh Province.

- The company did not cooperate, failed to provide documents to the inspection team and in the process of inspection, they complained about Decision 767 / QD-UBND that violating Clause 1, Article 58 of the 2010 Inspection Law; Point c, Clause 2, Article 12 of the 2011 Law on Complaints ”.

2. After obtaining the inspection conclusions No. 126 / KL-UBND, The company did many times filed a Complaint to the Commission Complainting.The entire content of inspection conclusions No. 126 / KL-UBND were completely inappropriate. Also, the Company continuously requested in writing the Committee to settle complaints regarding the following specific administrative decisions and acts:

3. i) Complaints and recommendations to the Document No. 1743 / UBND-NL2 dated April 23, 2015 signed by Mr. Le Dinh Son - Vice President of Ha Tinh Provincial People's Committee, regarding the suspension of mineral exploitation activities as a part of area due to violations of regulations on mineral mining activities;

4. ii) Complaints and recommendations of the Decision No. 37600 / QD-UBND dated September 28, 2015, signed by Mr. Le Dinh Son - Vice President of Ha Tinh Provincial People's Committee, regarding the establishment of process inspection team survey, advice and license mining activities for Ha Tinh I Construction Joint Stock Company;

iii) Complaints and recommendations text No. 5831 / UBND-NL2 dated November 4, 2016 signed by Mr. Dang Ngoc Son - Vice President of Ha Tinh Provincial People's Committee, on advising and handling related contents. to the quarry of Ha Tinh I Construction Joint Stock Company in Thach Ban Commune;

iv) Complaints and recommendations of the Decision No. 3327 / QD-UBND dated November 22, 2016 signed by Mr. Dang Ngoc Son - Vice Chairman of Ha Tinh Provincial People's Committee, on the establishment of the Council for damage assessment of Ha Tinh I Construction Joint Stock Company is located at Nam Gioi Quarry Mountain Thach Ban Commune, Thach Ha District when the state recovered land to perform ground clearance for building coastal defense routes from section of resettlement area No. 2 Communes of Thach Ban come to Cua Sot Border Guard Station;

v) Complaints and recommendations of the Decision No. 767 / QD-UBND comprehensively inspects the licensing process and mining activities at Nam Gioi Quarry Mountain,  Thach Ban Commune, Thach Ha District issued to the Joint Stock Company construction part I, Ha Tinh Province.

On April 17, 2019, the Committee issued anOfficial Letter No: 2237 / UBND-NL2 on the implementation of the conclusions on inspection process of licensing and quarrying activities at Nam Men Mountain, Thach Ban Commune (Official Letterr: No 2237 / UBND-NL2 ”). The Document No. 2237 / UBND-NL2 has the following specific contents:

“2. Requested Ha Tinh Construction Company I:

- Dismantling and relocating the construction items outside the scope of the approved planning, including: (1) security guards, (2) mines, (3) vendors, (4) petroleum depots, (5) workshops, (6) stockpile yards, crushing and screening stations in the right area of ​​land allocated by the state agency as prescribed.

- Fully paying the taxes, fees and late payment interest into the State budget; Deposit for environmental rehabilitation and restoration until June 30, 2017.

Completing the above contents, reporting the results to the Provincial People's Committee, the Provincial Examination Department, Department of Natural Resources and Environment before May 20, 2019 ”.

4. Document number: 2237 / UBND-NL2 forces the company to perform completely unrealistic and illegal, because:

5. i) Firstly, on November 5, 2013, the Committee for issuance of amended investment certificate No. 28121000051 / GCNDDC2 / 28/1, in Article 2 states: “Adjustment of the proposed land use area using Article 3 of the Investment Certificate No. 28121000051 dated July 14, 2009 as follows: Land use area: 17.1 ha (Exploited area: 14.3 ha, area of ​​public yard industry: 2.8 ha) ".

In Clause 1, Article 55 of the  Investment Law2005 stipulates :

“Article 55 Land lease, hand-over and receipt of land for implementation of investment projects

For investment projects requiring land, the investor shall contact the relevant land management body in the location where the project is to be implemented in order to carry out procedures for allocation or lease of land.”.

Therefore, according to the above-cited regulations, when the Company implemented an investment project according to the amended investment certificate No. 28121000051 / GCNDDC2 / 28/1, the competent agencies of Ha Tinh Province did not realize that it currently complied with regulations on land allocation, land lease, and business implementation of projects, leaded to damage to the Company, but the agencies of Ha Tinh Province have not yet reviewed and dealt with the responsibilities so far. according to the law.

1. ii) Similarly, in the Document No. 29 / YKTK-SXD dated March 26, 2013 on comments of the basic design of construction investment projects for mining and processing of open-pit quarry in Thien Nam Mountain area, Thach Ban Commune, Thach Ha Dstrict, Ha Tinh Povince. The Department of Construction of Ha Tinh Province determined:

"2. Conformity of basic design:

- Bebasically consistent with the socio-economic development planning; In accordance with the approved transport development plan to 2020;

- In accordance with the Mineral Planning as construction materials in Ha Tinh Province in the period of 2007-2015 approved by Ha Tinh People's Committee in the Decision No. 1651 / QD-UBND dated June 13, 2008;

- In accordance with Ha Tinh's construction material development planning till 2020 with a vision to 2030 approved by Ha Tinh People's Committee in the Decision No. 3689/2012 / QD-UBND dated December 7, 2012;

- The bases are sufficient as prescribed ”.

Therefore, the document No. 2237 / UBND-NL2 required the Company to dismantle and relocate the construction items outside the scope of the approved planning. Planning was available before or after the issuance of the Investment Certificate to the Company.

iii) In particular, at the cadastral survey of the land lot in 2009, the land use right registration of Ha TinhPeople's Committee of Thach Ban Commune; the Natural Resources and Environment Departmentof Thach Ha District; Natural Resources and Environment Department of Ha Tinh Province; The overall drawing of the project in 2009 approved by Ha Tinh People's Committee and appraised  by ConstructionDepartment of Ha Tinh Province; units negotiated by People's Committee of Thach Ha District. The company has built a 28,000m2 land area which was granted a certificate of land use right by Ha Tinh People's Committee on September 10, 2008. Therefore, the document No. 2237 / UBND-NL2 required the Company to dismantle and relocate the built items outside the approved planning area which was completely groundless and illegal;

1. iv) On the other hand, the construction of works in Nam Men QuarryMountain toke a lot of time and cost of the business. assuming, the Company complied with the dismantlement and relocation according to the document number: No 2237 / UBND-NL2 with the deadline dated May 20, 2019 which was completely unrealistic and caused many difficulties for the Company.

2. In addition, in the process of settling complaints of the Company, the Deputy Government’s  Prime Minister Vuong Dinh Hue; the Government’sOffice; The People's Committee –the Committee of the National Assembly issued documents asking the Committee to resolve the Company's complaints in accordance with the law, specifically as follows:

- On November 25, 2016, the Government’s Office issued a Document No. 10220 / VPCP-VI regarding the complaint of Ha Tinh I Construction Joint Stock Company stated: “... Ha Tinh Provincial People's Committee considered and resolved internal content of the above complaint and replied to Ha Tinh Construction Joint Stock Company; also reported the results to the Government’s Prime Minister before February 1, 2017 ”.

- On December 29, 2016, the Dan Nguyen Committee - National Assembly Standing Committee issued a document No. 478 / BND on the transfer of Mr. Truong Van Trong, the Director of Ha Tinh I Construction Joint Stock Company stated: “People’s  Committee sent Mr. Truong Van Trong's application to the president of Ha Tinh People's Committee to consider, resolve ..., respond to citizens and notify the settlement results to the Board of People for summary and report to the President of the National Assembly " ;

- On April 19, 2017, the Government’s Office issued a Document No. 3959 / VPCP-VI regarding the complaint of Ha Tinh I Construction Joint Stock Company stated: “The People's Committee of Ha Tinh Province urgently implemented the opinion direction of the Government’s Prime Minister in the Document No. 10220 / VPCP-VI dated November 25, 2016 of the Government’s Office; reported the results to the Government’s Prime Minister before July 1, 2017 ”.

However, the Ha Tinh Provincial People's Committee did not comply with legal regulations and documents directing the document No 10220 / VPCP-V.I; and the document No: 478 / UBND; the Document No. 3959 / VPCP-V.I of the Government’s Office; the Dan Nguyen Committee of the National Assembly’s Standing Committee.On the other hand, the People's Committee of Ha Tinh Province continued to cause difficulties, hindered normal activities of theCompany, created unequal "business environment", which was contrary to the policy of the Government Prime Minister on construction. Created“a favorable business environment for businesses". Therefore, the Ha Tinh People's Committee continued delaying the settlement of complaints, caused difficulties for the company that directly caused many reputable losses and damages to the Company during the implementation of complaint procedures.

GRIEVANCE:

From the above reasons, in order to ensure respect for the law, to ensure the legitimate rights and interests of the Company, the Company would like to request the People's Committee of Ha Tinh Province to consider and handle the Company's complaints. in accordance with the law,especially, the Ha Tinh Provincial People's Committee was requested to consider and decide to suspend the implementation and Inspection Conclusions No. 126 / KL-UBND; Document No. 2237 / UBND-NL2, for re-checking the whole legal basis.

In order to have the Inspection Conclusion No. 126 / KL-UBND dated April 13, 2018, there were many main contents such as: granting of mines, not leasing land, stopping mines illegally, using many documents, decisions.on  not complying with laws, intimidating, preventing production and business activities of the Company ... causing numerous difficulties and damages to the Company that were not solved, even the document no: 2237 / UBND-NL dated April 17, 2019 required the company to dismantle some works that were still not in compliance with the law, which were imposed (because there was a plan and design, within the scope of land lease, the functional departments of the province checked and implemented for years).

Since then the Company felt that the current approach of the government agencies did not only dismantle to help businesses, but also increasingly imposed and threatened businesses over the past 5 years.