The Data Room

September 15, 2021 TSX Venture Exchange

685 Centre Street SW Suite 2110

Calgary AB T2G

Re: Potential Unreported Material Changes and/or Misrepresentations made by Reconnaissance Energy Africa Ltd.

Introduction Through this document, Above Ground, the Center for International Environmental Law, and the Global Law Alliance for Animals and the Environment respectfully request that TSX Venture Exchange investigate the conduct of Reconnaissance Energy Africa Ltd. (“ReconAfrica” or the “Company”) (TSXV: RECO) for what may be unreported material changes to its business operations and/or material misrepresentations made in its filings on the System for Electronic Document Analysis and Retrieval (“SEDAR”) and other public communications, including on its website, in its investor presentations, and in statements to the press.

ReconAfrica, a junior oil and gas company incorporated in British Columbia, is “engaged in the identification, and the exploration and development of oil and gas assets via drilling and/or acquisition with a focus on Namibia and Botswana.”1 Through its wholly owned subsidiaries, Reconnaissance Energy Namibia (Pty) Ltd. (“REN”) and Reconnaissance Energy Botswana (Pty) Ltd. (“ReconBotswana”), ReconAfrica holds petroleum exploration licences for more than 8 million acres of the Okavango Region, which spans the Namibia-Botswana border (an area ReconAfrica refers to as the “Kavango Basin”).2

According to ReconAfrica, “the Namibia Licensed Property and the Botswana Licensed Property comprise an area comparable to the Eagle Ford Shale in Texas, USA and provide ReconAfrica with control of the entire Kavango Basin, which is potentially one of the largest onshore undeveloped hydrocarbon basins in the world.”3 As detailed below, there are indications that ReconAfrica may have: (a) made a material change to its business by shifting its focus from primarily targeting exploration and development of unconventional, shale-based oil and gas resources in the Kavango Basin to primarily or exclusively targeting conventional oil and gas resources without filing a material change report; and/or (b) made one or more material misrepresentations regarding the oil and gas resources targeted in its operations…..

Full submission is here: