Aya Gold & Silver
2021  ESG Report
Published on  July 25, 2022
Aya Gold & Silver is a rapidly growing, Canadian-based silver producer with a strong presence in Morocco.

Listed on the TSX, the Corporation operates the Zgounder Silver Mine, an underground silver mine located 260km east of Agadir in Morocco. In addition to advancing its Boumadine polymetallic project, Aya Gold & Silver is actively drilling its Imiter bis exploration property located along the prolific Anti-Atlas belt that is host to Zgounder and Managem’s Imiter Mine.
Disclaimer and Forward Looking Statements
Company Profile
Organizational Profile
Name Aya Gold & Silver
Describe nature of activities, brands, products and services Aya Gold & Silver's goal is to create
shareholder value by generating revenue and
growth through its operations and exploration
programs. Our experienced team of directors
and officers have extensive experience
launching and operating precious metals mines
around the world.

Together with ongoing Zgounder operational
improvements, Aya Gold & Silver is focused on
extending Zgounder high-grade mineralization
through drill programs with the aim of
expanding plant capacity from 700 tpd to 2,700
tpd.
Link to Corporate Website https://ayagoldsilver.com/
Industry Classification NAICS:
2122 Metal ore mining
21222 Gold and silver ore mining
Market Capitalization $100 Million up to $1 Billion USD
Type of Operations Primarily production oriented
Company Headquarters Mont-Royal, Canada
Link to company's statements of: Purpose, Vision, Mission and Values; Sustainability/ESG strategy; previously published Sustainability/ESG performance or reports. (URL)
ESG Accountability
Role and Name of highest authority within company for Environment, Social and Governance strategy, programs and performance. Benoit La Salle, President & CEO
ESG Reporting Period
Unless otherwise noted, all data contained in this report covers the following period:
From 2021-01-01
To 2021-12-31
Geographic Scope of Report
Unless otherwise noted, the data in this report covers ESG matters related to the following locations of operations Morocco
Identify notable exclusions, and reference any existing or planned reports that do or will address these (e.g, assets recently divested or acquired, non-managed joint ventures, specific exploration activities, recently closed sites, etc.) Aya Gold & Silver holds five exploration assets
located in Morocco and Mauritania. This report
focuses on our ongoing operations at the
Zgounder Silver Mine. It does not cover
exploration sites in Morocco or Mauritania as
no exploration was conducted in 2021.
Imiter Bis Exploration Project Description

Boumadine Exploration Project Description

Amizmiz Exploration Project Description
Fragile and Conflict-Affected Situations
Identify all of the entity's countries of operations that align with the World Bank's list of "Fragile and Conflict-Affected Situations" None
Business Operations Scope of Report
Identify notable exclusions, and reference any existing or planned reports that do or will address these (e.g, assets recently divested or acquired, non-managed joint ventures, specific exploration activities, recently closed sites, etc.) Aya Gold & Silver holds five exploration assets
located in Morocco and Mauritania. This report
does not cover these exploration sites as no
exploration was conducted in 2021.
Mineral Resource Types in Scope
Which of the following mineral resource types are covered by this report
   •  Inferred
   •  Indicated
   •  Measured
2021 Fourth Quarter Production
HighlightsPress Release
Mineral Reserve Types in Scope
Which of the following mineral reserve types are covered by this report
   •  Proven
   •  Probable
Currency
Unless otherwise noted, all financial figures referenced in this report are in the following currency USD
Audit Status
Identify the degree to which any inputs of the report are third-party checked: Self-Declared
Reporting Practice
Provide a list of all entities included in the organization’s consolidated financial statements or equivalent documents Aya Gold & Silver Inc. (the “Corporation or
“Aya”) is a Canadian-based precious metals
mining corporation  focusing on the
exploration, development, production and
acquisition of precious metals mining projects.
The Corporation is concentrated on producing
silver and exploration activities at its flagship
project, the Zgounder property.
Aya owns 85% of Zgounder Millennium Silver
Mine S.A (“ZMSM”), which owns the Zgounder
property.

The Corporation also owns 85% of the
Boumadine polymetallic project and is the sole
owner of the permits related to the Amizmiz,
Azegour and Imiter Bis properties.

All of these properties are located in the
Kingdom of Morocco.

Following the acquisition of Algold Resources
Ltd. (“Algold”) completed on June 11, 2021, Aya
owns 75% of the Tijirit project located in
Mauritania.

Our subsidiaries include:
•     Compagnie Minière Maya-Maroc S.A.
(“CMMM”)
•     Zgounder Millennium Silver Mining S.A.
(“ZMSM”)
•     Boumadine Global Mining S.A. (“BGM”)
•     Atlas Gold & Silver S.A.R.L.(“AGS”)
•     Kanosak (Barbados) Limited (“KANOSAK”)
•     Algold Resources Ltd. (“Algold”)
•     Algold Mauritania SARL (“ALGOLD SARL”)
•     Société Tijirit Recherche et Exploration
SARL (“TIREX”)

Aya Gold & Silver Financial Reports
Report whether any entity included in the organization’s consolidated financial statements or equivalent documents is not covered by the report There are no exclusions related to this report.
However, the 2021 ESG report  focuses
primarily on Zgounder Millennium Silver
Mining S.A. (“ZMSM”) as all 2021 operating
activities  were carried out in the ZMSM
concession.
Provide an explanation of the process for defining the report content and the topic boundaries Our ESG Report will provide transparent,
comprehensive and appropriate content,
addressing Aya Gold & Silver's material aspects
and impacts, as well as our stakeholders'
material topics.
Provide an explanation of how the organization has implemented the Reporting Principles for defining report content Our material sustainability topics were
determined on the basis of approved GRI
methodology. While our identified material
topics are key, our wider efforts continue to
address topics beyond those in our material
section.
Provide a list of the material topics identified in the process for defining report content
   •  General Disclosure
   •  Compliance
   •  Greenhouse Gas Emissions
   •  Emissions
   •  Energy
   •  Water and Effluents
   •  Water
   •  Waste
   •  Effluents and Waste
   •  Waste Management
   •  Employment
   •  Labour Relations
   •  Occupational Health and Safety
   •  Workforce Health and Safety
   •  Training and Education
   •  Local Communities
   •  Community Relations
   •  Water Management
   •  Anti-corruption
Report the effect of any restatements of information given in previous reports, and the reasons for such restatements No restatement
Report significant changes from previous reporting periods in the list of material topics and topic Boundaries The 2021 ESG report does not contain any
significant changes in the list of material topics
and topic boundaries.
If applicable, report the date of the most recent previous report 2021-06-15
Provide the contact point for questions regarding the report or its contents For questions regarding this report, please
contact the following:
David Vilder, HSEC Manager,
david.vilder@ayagoldsilver.com.
Choose the statement as to whether the organization has chosen the CORE or COMPREHENSIVE options in preparing the GRI aligned report This report has been prepared in accordance
with the GRI Standards: Comprehensive option
If the report has been externally assured, provide:
i. A reference to the external assurance report, statements, or opinions. If not included in the assurance report accompanying the sustainability report, a description of what has and what has not been assured and on what basis, including the assurance standards used, the level of assurance obtained, and any limitations of the assurance process This is a self-declared report. No external audit
has been conducted.
Raw Material Produced
Metals: 45.378
Aya Gold & Silver has only one project in
operations, the Zgounder Silver Mine, which
produces silver. In 2021, The Zgounder Silver
Mine produced 1600646 ounces of silver.
Silver (Ag) (tonne) 45.378
Finished Product for Sale
Metals: 0
Silver (Ag) (tonne) 0
Organizational Profile
Provide a list of externally-developed economic, environmental and social charters, principles, or other initiatives to which the organization subscribes, or which it endorses, e.g., GRI, UN Global Compact In 2021, the Corporation was not a member of
any associations and did not participate in any
external initiatives.
For the purpose of this report, Aya Gold &
Silver is disclosing information aligned with the
following standards:

•     CDP - Carbon Disclosure Project
•     GRI - Global Reporting Initiative
•     GRI Comprehensive - Global Reporting
Initiative – Comprehensive
•     GRI Core - Global Reporting Initiative – Lite
•     GRI MM Supplement - Global Reporting
Initiative - Mining and Metals Supplement
•     ICMM - International Council on Mining &
Metals
•     IFC - International Finance Corporation -
Equator Principles
•     ISS - ISS & Glass Lewis - Proxy Advisors
•     ONYEN - Institutional and Investor
Questions
•     OSHA - Occupational Safety and Health
Administration
•     PRI - Principles of Responsible Investing
•     SASB - Value Reporting Foundation
•     SASB Modified - Value Reporting
Foundation – Modified
•     UGC - UN Global Compact – Sustainable
Development Goals (SDGs)
Strategy
Provide a statement from the most senior decision-maker of the organization (i.e., CEO, chair, or equivalent senior position) about the relevance of sustainability to the organization and its strategy for addressing sustainability (CEO's message for this report) As Aya Gold & Silver (“Aya” or “the
Corporation”) celebrates its second year of
existence, I am proud to share our second
Sustainability Report with you.
The report, which covers our performance in
2021, follows up on the environmental, social
and governance (“ESG”) baseline provided last
year that characterized my appointment as
President and CEO.
CEO Statement
Benoit La Salle, CEO
Provide a description of key impacts, risks, and opportunities, The impacts, risks and opportunities  of the
Zgounder Silver Mine are outlined in the
Zgounder Silver Mine ESIA.

Please refer to the link below for further
information.
Zgounder Expansion Project ESIA
Ethics and Integrity
Provide a description of the organization’s values, principles, standards, and norms of behaviour The Board of Directors of Aya Gold & Silver is
committed to ethical practices and high
standards of corporate governance.

Our mission is to leverage our extensive
expertise to play a leadership role in building
and operating viable precious metals mines that
create value for our shareholders and
community stakeholders.
Aya Gold & Silver Code of Business Conduct
and Ethics


Aya Gold & Silver HSEC Policy

Aya Gold & Silver Strategy
a. Describe internal and external mechanisms for:
i. Seeking advice about ethical and lawful behaviour, and organizational integrity We have a strong commitment to conduct our
business in a lawful and ethical manner.
Employees are encouraged to report violations
of laws, rules, regulations and the Code of
Conduct and Ethics either to their supervisor,
member of senior management or through the
confidential whistleblower mechanism detailed
in the Corporation’s Handling of Complaints -
Whistle Blowing Policy. We prohibit retaliatory
action against any employee who, in good faith,
reports a possible violation. It is unacceptable
to file a report knowing it to be false.
Aya Gold & Silver Code of Business Conduct
and Ethics
ii. Reporting concerns about unethical or unlawful behavior, and organizational integrity Aya Gold & Silver  is committed to the highest
standards of openness, honesty and
accountability as outlined in the Corporation’s
Code of Business Conduct and Ethics (the
“Code”). The latter also provides guidance on
alternative methods of reporting employee
concerns and directs that employees inform
designated members of management regarding
known or suspected instances of irregularities,
fraud or misconduct.
Aya Gold & Silver Code of Business Conduct
and Ethics


Aya Gold & Silver Handling of Complaints –
Whistle-Blowing Policy and Procedure
Supply Chain
a. Provide a description of the organization’s supply chain, including its main elements as they relate to the organization’s activities, primary brands, products, and services The Zgounder Silver Mine's supply chain's
primary elements include:
- chemical products for metal processing
- machinery and parts
- consulting services for engineering, health and
safety, environment, and human resources
management.
a. Report on significant changes to the organization’s size, structure, ownership, or supply chain, including: In 2021, there were no significant changes in
the Zgounder Silver Mine's size, structure,
ownership or supply chain.
Changes in Locations and Operations
i. Changes in the location of, or changes in, operations, including facility openings, closings, and expansions There were no changes in the location of, or
changes in, operations, including facility
openings, closings, and expansions in 2021.
Changes in Capital Structure
ii. Changes in the share capital structure and other capital formation, maintenance, and alteration operations (for private sector organizations) There were no changes in the share capital
structure and other capital formation,
maintenance, and alteration operations in
2021.
Changes in Supply Chain
iii. Changes in the location of suppliers, the structure of the supply chain, or relationships with suppliers, including selection and termination There were no changes in the location of
suppliers, the structure of the supply chain, or
relationships with suppliers, including selection
and termination in 2021.
Precautionary Principle
a. Report whether and how the organization applies the Precautionary Principle or approach Where there is potential for environmental or
social harm, lack of certainty cannot be
accepted as a reason for inaction. At Aya Gold
& Silver, we believe that the use of the
precautionary principle is a key directive of
responsible environmental and social
governance and an important factor in the
journey towards a more sustainable future.

Although applying the precautionary principle
means taking action despite scientific
uncertainty, it does not negate the need for, or
value of, pursuing a risk-based approach –
remaining informed of the best available
information and taking uncertainties into
account. Our dedicated Environment, Health
and Safety department takes the lead on
assessing the potential for environmental and
social harm and taking preventative measures
where possible, erring on the side of caution
where extensive scientific knowledge of risks is
lacking.
Membership of Associations
List of the major memberships of industry or other associations, and national or international advocacy organizations Aya Gold & Silver does not belong to industry
or other associations, including national and
international advocacy organizations.
Environment
Compliance
a. Report fines and non-monetary sanctions for non-compliance with environmental laws and/or regulations in terms of:
i. Total monetary value of significant fines 0
ii. Total number of non-monetary sanctions 0
iii. Cases brought through dispute resolution mechanisms 0
b. If the organization is in compliance with environmental laws and/or regulations, a brief statement if this fact is sufficient In 2021, Aya Gold & Silver was in compliance
with all environmental laws and/or regulations.
Greenhouse Gas Emissions
Scope 1
For your operations, disclose the gross global Scope1 greenhouse gas (GHG) emissions to the atmosphere of the seven GHGs covered under the Kyoto Protocol (tonne CO₂-e):
Carbon dioxide (CO₂) (tonne CO₂-e) 3103.758
Methane (CH₄) (tonne CO₂-e) 0
Nitrous oxide (N₂O) (tonne CO₂-e) 0
Hydrofluorocarbon-23 (CHF₃) (tonne CO₂-e) 0
Hydrofluorocarbon-32 (CH₂F₂) (tonne CO₂-e) 0
Sulphur hexafluoride (SF₆) (tonne CO₂-e) 0
Nitrogen trifluoride (NF₃) (tonne CO₂-e) 0
Perfluoromethane (CF₄) (tonne CO₂-e) 0
Perfluoroethane (C₂F₆) (tonne CO₂-e) 0
Perfluorobutane (C₄F₁₀) (tonne CO₂-e) 0
Perfluorohexane (C₆F₁₄) (tonne CO₂-e) 0
The total amount of gross global Scope 1 GHG emissions (CO₂-e) (tonne) 3103.758
The percentage of its gross global Scope 1 GHG emissions that are covered under an emissions-limiting regulation or program that is intended to directly limit or reduce emissions, such as cap-and-trade schemes, carbon tax/fee systems, and other emissions control (e.g., command-and-control approach) and permit-based mechanisms. 0.0000%
Discuss any change in its emissions from the previous reporting period, including whether the change was due to emissions reductions, divestment, acquisition, mergers, changes in output, and/or changes in calculation methodology. In the 2020 report, Aya Gold & Silver did not
disclose its GHG emissions as they were not
material.
In the case that current reporting of GHG emissions to the CDP or other entity (e.g., a national regulatory disclosure program) differs in terms of the scope and consolidation approach used, the entity may disclose those emissions. Aya Gold & Silver is reporting its emissions
based on CDP disclosure guidelines.
The entity may discuss the calculation methodology for its emissions disclosure, such as if data are from continuous emissions monitoring systems (CEMS), engineering calculations, or mass balance calculations. In the 2021 report, Aya Gold & Silver is
reporting GHG Scope 1 emissions based on the
output of light vehicle and the diesel
consumption of mining mobile equipment.
The entity may, where relevant, provide a breakdown of its emissions by mineral or business unit. Scope 1 emissions represent operations at the
Zgounder Silver Mine only. Aya Gold & Silver
had no operations in any of its other assets or
jurisdictions in 2021.
The entity shall discuss its long-term and short-term strategy or plan to manage its Scope 1 greenhouse gas (GHG) emissions. Scope 1 emissions are generated mostly by
operating machinery to mine ore. The type of
machinery that we currently operate does not
exist in electric form. As a result, it is currently
impossible for us to significantly reduce our
Scope 1 emissions.

We plan to monitor new emerging technologies
and evaluate other opportunities when our
mining equipment needs replaced.
The percentage reduction against the base year, with the base year representing the first year against which emissions are evaluated toward the achievement of the target 0
In 2021, Aya Gold & Silver did not have any
target got emissions reduction.
Total base year GHG emmissions 0
Present year GHG emmissions 0
The timelines for the reduction activity
iii The context for any significant changes in emissions that triggered recalculations of the base year emissions In this reporting period, Aya Gold and Silver did
not recalculate any of its base year emissions.
Source of the emission factors and the global warming potential (GWP) rates used, or a reference to the GWP source The source of emission factors is the Onyen
reporting platform.
Consolidation approach for emissions - whether equity share, financial control, or operational control Operational control
Standards, methodologies, assumptions, and/or calculation tools used For the purpose of this report, we used Carbon
Disclosure Project guidelines  as a calculation
tool.
Scope 2
Disclose the gross location-based energy indirect (Scope 2) global greenhouse gas (GHG) emissions to the atmosphere (tonne CO₂-e):
Carbon dioxide (CO₂) (tonne CO₂-e) 9556.717
Methane (CH₄) (tonne CO₂-e) 66.5
Nitrous oxide (N₂O) (tonne CO₂-e) 12307.4
Hydrofluorocarbon-23 (CHF₃) (tonne CO₂-e) 0
Hydrofluorocarbon-32 (CH₂F₂) (tonne CO₂-e) 0
Sulphur hexafluoride (SF₆) (tonne CO₂-e) 0
Nitrogen trifluoride (NF₃) (tonne CO₂-e) 0
Perfluoromethane (CF₄) (tonne CO₂-e) 0
Perfluoroethane (C₂F₆) (tonne CO₂-e) 0
Perfluorobutane (C₄F₁₀) (tonne CO₂-e) 0
Perfluorohexane (C₆F₁₄) (tonne CO₂-e) 0
The total amount of gross global Scope 2 GHG emissions (CO₂-e) (tonne) 21930.617
Percentage of its gross global Scope 2 GHG emissions that are covered under an emissions-limiting regulation or program that is intended to directly limit or reduce emissions, i.e., cap-and-trade schemes, carbon tax/fee systems, and other emissions control (e.g., command-and-control approach) and permit-based mechanisms 0.0000%
Discussion of long-term and short-term strategy or plan to manage Scope2 emissions, emissions reduction targets, and an analysis of performance against those targets In 2024, Aya Gold & Silver will  sign a Power
Purchasing Agreement with a clean energy
provider connected to the Moroccan National
Grid. By 2025, the Corporation will  effectively
reduce its scope 2 emissions to zero  at its
Zgounder Silver Mine in Morocco.
iii The context for any significant changes in emissions that triggered recalculations of the base year emissions No  significant change in emissions triggered
recalculation of our 2020 emissions.
Source of the emission factors and the global warming potential (GWP) rates used, or a reference to the GWP source For the purpose of this report, we utilized the
International Energy Agency (IEA) defined
emission factors (2021).
Standards, methodologies, assumptions, and/or calculation tools used In this report, Aya Gold & Silver utilized the
Carbon Disclosure Project Calculation
guidelines.
GHG Calculation Tool
Intensity Ratio
The total amount of gross global Scope 1 GHG emissions (CO₂-e) (tonne) 3103.758
The total amount of gross global Scope 2 GHG emissions (CO₂-e) (tonne) 21930.617
GHG emissions intensity ratio for the organization 112.085
The total amount of organization's specific metric chosen to calculate the intensity ratio. 223.352
The above number (223,352) is in thousands of
tonnes of ore produced.
The organizations specific metric unit of measure. Note: when choosing a company specific metric, it must be used throughout all calculations Production volume
The intensity ratio is thousands of tonnes of ore
processed by tonnes of CO2.
Types of GHG emissions included in the intensity ratio; whether Scope 1, Scope 2 and/or Scope 3
   •  Scope 1
   •  Scope 2
Carbon Offset
Credits
How much CO₂ (metric tonnes) offset credits were purchased? 0
Emissions
Emissions Management
Disclose the management approach regarding Emissions In 2021, Aya Gold & Silver evaluated the
principal sources of its GHG emissions,
assessed electrification of its fleet and finding a
green energy producer. As a result,
management will seek a clean energy producer
in the Moroccan national electrical grid to
reduce its Scope 2 emissions.
Air Emissions
Report emissions of air pollutants that are released into the atmosphere:
Emissions of carbon monoxide, reported as CO (tonne) 0
Aya Gold & Silver is not currently monitoring
air emissions but will in the future monitor and
disclose as per the Environmental and Social
Management Plan included in the Zgounder
Silver Mine 2022 ESIA.
Ozone-Depleting Substances (ODS)
The reporting organization shall report the following information
Production, imports, and exports of Ozone Depleting Substances (ODS) in metric tonnes of CFC-11 (trichlorofluoromethane) equivalent:
Production of of ODS in metric tonnes of CFC-11 (trichlorofluoromethane) equivalent 0
ODS produced in metric tonnes of CFC-11 (trichlorofluoromethane) 0
Amount of ODS destoyed by approved technologies 0
Amount of ODS entirely used as feedstock in the manufacture of other chemicals 0
Import amount of ODS in metric tonnes of CFC-11 (trichlorofluoromethane) 0
Export amount of ODS in metric tonnes of CFC-11 (trichlorofluoromethane) equivalent 0
Source of the emission factors used Aya Gold & Silver does not utilize equipment in
its operations that can produce ozone-
depleting substances.
Significant Air Emissions
The reporting organization shall report the following information
Significant air emissions, in kilograms or multiples, for each of the following
iii. Persistent Organic Pollutants (POPs): 0
Aya Gold & Silver does not produce Persistent
Organic Pollutants as a result of its operations.
iv. Volatile Organic Compounds (VOCs) 0
Aya Gold does not utilize equipment in its
operations that can produce Volatile Organic
Compounds.
v. Hazardous Air Pollutants (HAPs) 0
Mining Sector:
Acetone (also known as propanone) 0
Acetaldehyde 0
Antimony (Sb) 0
Arsenic (As) 0
Asbestos 0
Benzene (including benzene from gasoline) 0
1,3-Butadiene 0
Cadmium (Cd) 0
Carbon Dioxide (CO2) 0
Carbon Monoxide (CO) 0
Chloroform 0
Chromium (Cr) 0
Copper (Cu) 0
Cyanide (CN) 0
2,3-dimethylbutane 0
Ethylbenzene 0
Hexachlorobenzene 0
Hydrogen Cyanide (HCN) 0
Hydrogen Sulphide (H2S) 0
Iron (Fe) 0
p-isopropyltoluene 0
Lead (Pb) 0
Manganese (Mn) 0
Mercury (Hg) 0
Aya Gold & Silver considers mercury emissions
a material topic but we were not able to
monitor these emissions in 2021. The
Corporation will monitor and disclose in the
future as per the Environmental and Social
Management Plan included in the Zgounder
Silver Mine 2022 ESIA.
Methane (CH4) 0
Methylene chloride (Dichloromethane) 0
Methyl tert butyl ether (MTBE) 0
Nickel (Ni) 0
Nitrous Oxides (NOx) 0
Particulate Matter (PM2.5) 0
Particulate Matter (PM10) 0
i-pentane 0
Polychlorinated Biphenyls (PCBs) 0
Polyhalogenated Aromatic Hydrocarbons (PAHs) 0
Propene (also known as propylene or methyl ethylene) 0
Sulphur Dioxide (SO2) 0
Sulphur Oxides (SOx) 0
2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) 0
2,3,7,8-tetrachlorodibenzofurans (TCDF) 0
Thallium (Tl) 0
Toluene 0
Tetrachloroethylene (also known as perchloroethylene or PCE) 0
o-Xylenes 0
m-Xylenes 0
p-Xylenes 0
Zinc (Zn) 0
vi. Total Particulate Matter (TPM): 0
PM2.5 0
PM10 0
vii. Other standard categories of air emissions identified in relevant regulations Aya Gold & Silver does not currently monitor
air emissions. In the future, it will monitor and
disclose as per the Environmental and Social
Management Plan included in the 2022
Zgounder Silver Mine  ESIA.
Energy Management
Total energy consumed in aggregate, in gigajoules (GJ) (hydrocarbons and electricity) including the fuel types used (e.g., biomass, hydro-electric power or bioenergy) 47970.133
Percentage energy consumed that was supplied by grid electricity 100.0000%
Percentage of energy consumed that is renewable energy 37.0000%
Energy Consumption
c. Report the energy consumed in gigajoules for the following :
Electricity consumption (gigajoules, GJ) 47970.133
The figure provided here is for the global
electricity consumption at the Zgounder Silver
Mine in 2021, and does not include the
administrative offices in Casablanca.
Heating consumption (gigajoules, GJ) 0
Cooling consumption (gigajoules, GJ) 0
Steam consumption (gigajoules, GJ) 0
d. Report energy sold in gigajoules and report the totals for each:
Electricity sold (gigajoules, GJ) 0
Heating sold (gigajoules, GJ) 0
Cooling sold (gigajoules, GJ) 0
Steam sold (gigajoules, GJ) 0
f. Report the standards, methodologies, assumptions, and/or calculation tools used To calculate this data, the
Corporation  converted the KWh purchased
from the national grid to gigajoules, GJ.
g. Report the source of the conversion factors used To calculate this data, the Corporation
converted the KWh purchased from the
national grid to gigajoules, GJ.
Energy Intensity Ratio
Report the energy intensity ratio for inside the organization. This intensity ratio is the total ratio for all countries in which the company operates 0.215
Energy Intensity
The total energy consumption within the organization, in gigajoules 47970.133
The organizations specific metric chosen to calculate the intensity. Note: when choosing a company specific metric, it must be used throughout all calculations 223352
Organization-specific metric to identify the denominator: Production volume
Reduction in Energy Consumption
Report the amount of reductions (from the previous reporting period) in energy consumption achieved as a direct result of conservation and efficiency initiatives, in gigajoules (GJ). Note - if you did not report in the previous reporting period, please indicate with a statement in the details section, "This is our foundational (for clarity, our first) ESG report for the organization". 0
Report the basis for calculating reductions in energy consumption, i.e. base year or baseline, including the rationale for choosing it This is Aya Gold & Silver's first ESG report that
discloses energy consumption. The Corporation
is focused on acquiring and analyzing its data
before planning reductions.
Reduction in Energy Requirements
Report the reductions in energy requirements of sold products and services in this reporting period (from the previous reporting period), in gigajoules (GJ). Note - if you did not report in the previous reporting period, please indicate with a statement in the details section, "This is our foundational (for clarity, our first) ESG report for the organization", (e.g., if you used electric vehicles this year as opposed to last year, please indicate). 0
Report the basis for calculating reductions in energy requirements, i.e., base year or baseline, including the rationale for choosing it This is Aya Gold & Silver's first ESG report that
discloses energy consumption. The Corporation
is focused on acquiring and analyzing
data  before planning reductions.
Water
Efficiency
Proportion of water reused and recycled by the site to reduce the overall consumptive water demand: 56.2427%
Intensity
Total volume of water consumed per tonne/unit of material moved, ore mined, ore processed: 0.2136%
Water Management
Disclose the amount of water that was withdrawn from freshwater sources (in thousands of cubic meters): 195.611
Analyze and list all operations for water risks and identify activities that withdraw and consume water in locations with High (40–80%) or Extremely High (>80%) Baseline Water Stress as classified by the World Resources Institute’s (WRI) Water Risk Atlas tool, Aqueduct. Aya Gold & Silver's Zgounder Silver Mine and
production facility are located across the limits
between an area with low Baseline Water
Stress and an area with extremely high Baseline
Water Stress as classified by the World
Resources Institute's (WRI) Water Risk Atlas
tool.
World Resources Institute’s (WRI) Water Risk
Atlas tool, Aqueduct
Disclose the freshwater withdrawn in locations with High or Extremely High Baseline Water Stress as a percentage of the total water withdrawn 100.0000%
Disclose water withdrawn in locations with High or Extremely High Baseline Water Stress (in thousands of cubic meters): 195.611
Disclose freshwater consumed in locations with High or Extremely High Baseline Water Stress as a percentage of the total water consumed: 100.0000%
Disclose the amount of water that was consumed in its operations (in thousands of cubic meters) 195.611
Total water consumed in locations with high or extremely high baseline water stress (in thousands of cubic meters) 195.611
Was your organization subject to any fines, enforcement orders, and/or other penalties for water-related regulatory violations No
Total number of instances of non-compliance, including violations of a technology-based standard and exceedances of quality-based standards. 0
Disclosure of incidents governed by national, state, and local statutory permits and regulations, including, but not limited to, the discharge of a hazardous substances, violation of pretreatment requirements, or total maximum daily load (TMDL) exceedances. Aya Gold & Silver was not subject to any
national, state or local authority regulation
violation relating to the environment.
Water and Effluents
Interactions with Water As A Shared Resource
Describe how the organization interacts with water, including how and where water is withdrawn, consumed, and discharged, and the water-related impacts caused or contributed to, or directly linked to the organization’s activities, products or services by a business relationship (e.g., impacts caused by runoff) Aya Gold & Silver's Zgounder operations draw
freshwater from the Macoste spring, which is
located 5km upstream from our operations.

Water is consumed by the processing plant and
the base camp. There is no discharge into the
environment.

For the purpose of this report, potential water-
related impacts include the use of a shared
water resource, and pollution from operations
due to accidental runoff or infiltration.
Describe the approach used to identify water-related impacts, including the scope of assessments, their timeframe, and any tools or methodologies used Water risks are assessed through the
Corporation's risk management system, where
mitigation measures are identified, and
mitigation plans are developed and
incorporated into the annual CAPEX and OPEX
budgets.
The Environmental and Social
Impact  Assessment for the Zgounder Silver
Mine (approved by Moroccan authorities in Q1
2022) also provided Aya Gold and Silver's
management with updated baseline
information and impact identification.
Describe how water-related impacts are addressed, including how the organization works with stakeholders to steward water as a shared resource, and how it engages with suppliers or customers with significant water-related impacts In 2021, Aya Gold & Silver implemented
physical control measures in its operations and
initiated an environmental monitoring program
with a third-party accredited lab.

In addition, in 2020, the Corporation identified
that increased water storage could have a
significant water-related impact by enabling
operations to capture excess water in the rainy
season and reduce extraction during the dry
season.

In 2021, Aya Gold & Silver began construction
of a 60,000 m3 water storage basin. The result
of this investment will be disclosed in the 2022
ESG report.
Explain the process for setting any water-related goals and targets that are part of the organization’s management approach, and how they relate to public policy and the local context of each area with water stress In 2021, Aya Gold & Silver set up an internal
committee to monitor water-related efforts
and report to executive management and the
Board of Directors.

The Corporation's water-related goals, targets
and  performance are established by this
committee.
Water Withdrawal
Total freshwater withdrawn by segment, in megaliters (ML): 195.611
i. Surface water (total in ML): 195.611
Freshwater (≤1,000 mg/L Total Dissolved Solids or TDS) 195.611
Other water (>1,000 mg/L Total Dissolved Solids or TDS) 0
ii. Groundwater (total in ML): 0
Freshwater (≤1,000 mg/L Total Dissolved Solids or TDS) 0
Other water (>1,000 mg/L Total Dissolved Solids or TDS) 0
iii. Seawater (total in ML): 0
Freshwater (≤1,000 mg/L Total Dissolved Solids or TDS) 0
Other water (>1,000 mg/L Total Dissolved Solids or TDS) 0
iv. Produced water (total in ML): 0
Freshwater (≤1,000 mg/L Total Dissolved Solids or TDS) 0
Other water (>1,000 mg/L Total Dissolved Solids or TDS) 0
v. Third-party water (total in ML): 0
Freshwater (≤1,000 mg/L Total Dissolved Solids or TDS) 0
Other water (>1,000 mg/L Total Dissolved Solids or TDS) 0
Report on the total water withdrawal from all areas with water stress in megaliters (ML), and a breakdown of this total by the following sources: 195.611
ii. Groundwater (total in ML): 0
Freshwater (≤1,000 mg/L Total Dissolved Solids or TDS) 0
Other water (>1,000 mg/L Total Dissolved Solids or TDS) 0
iii. Seawater (total in ML): 0
Freshwater (≤1,000 mg/L Total Dissolved Solids or TDS) 0
Other water (>1,000 mg/L Total Dissolved Solids or TDS) 0
iv. Produced water (total in ML): 0
Freshwater (≤1,000 mg/L Total Dissolved Solids or TDS) 0
Other water (>1,000 mg/L Total Dissolved Solids or TDS) 0
v. Third-party water, in megaliters (ML), and a breakdown of this total by the withdrawal sources: 0
Surface water source Not applicable
Surface water 0
Groundwater source Not applicable
Groundwater 0
Seawater source Not applicable
Seawater 0
Produced water source Not applicable
Produced water 0
Report any contextual information necessary to understand how the data have been compiled, i.e., any standards, methodologies, and assumptions used Data is estimated from the annual tonnage of
processed ore and a recirculation rate of 59%
from TSF reclaim water.
Water Consumption
Report the total water consumption from all areas in megaliters 500.488
Report the total water consumption from all areas with water stress in megaliters 195.611
Report the change in water storage in megaliters, if water storage has been identified as having a significant water related impact, 0
In 2020, Aya Gold & Silver identified that
increased water storage could have a
significant water-related positive impact as
storage enables operations to capture excess
water in the rainy season and reduces
withdrawals during the dry season.

In 2021, the Corporation begun construction of
a 60,000 m3 water storage basin. The results of
this investment will be disclosed in the 2022
ESG report.
Report any contextual information necessary to understand how the data was compiled, including standards, methodologies, and assumptions used, including whether the information is calculated, estimated, modeled, or sourced from direct measurements, and the approach taken for this, i.e., the use of any sector-specific factors Data is estimated from the annual tonnage of
processed ore and a recirculation rate of 59%
from TSF reclaim water.
Water Discharge-Related Impacts
Provide a description of any minimum standards set for the quality of effluent discharge, and how these minimum standards were determined, including:
i. How standards for facilities operating in locations with no local discharge requirements were determined The Zgounder Silver Mine does not discharge
effluent into the environment.
The Zgounder Silver Mine is designed to be a
zero-discharge facility.  The company does not
have operational water discharges and/or
runoff into the Zgounder river derived from its
operations.
ii. Water quality standards or guidelines developed internally Aya Gold & Silver's water monitoring program
tests water quality against national and World
Health Organization (WHO) drinking water
standards. Water quality is evaluated monthly
to ensure compliance.
iii. Sector-specific standards considered As per above, at the Zgounder Silver Mine, the
Corporation tests water quality against
national and WHO drinking water standards.
iv. Profile of the receiving waterbody considered The Zgounder Silver Mine does not discharge
effluent into the environment.
Water Discharge
Report the total water discharge to all areas in megaliters: 0
The Zgounder Silver Mine is designed to be a
zero-discharge facility.  The facility does not
have operational water discharges and/or
runoff into the Zgounder river derived from its
operations.
i. Surface water 0
ii. Groundwater 0
iii. Seawater 0
iv. Third-party water (total) 0
iv. Third-party water that is sent for use to other organizations, if applicable 0
Report the breakdown of total water discharge to all areas in megalitres by the following categories 0
i. Surface water (total):
Freshwater (≤1,000 mg/L Total Dissolved Solids or TDS) 0
Other water (>1,000 mg/L Total Dissolved Solids or TDS) 0
ii. Groundwater (total):
Freshwater (≤1,000 mg/L Total Dissolved Solids or TDS) 0
Other water (>1,000 mg/L Total Dissolved Solids or TDS) 0
iii. Seawater (total):
Freshwater (≤1,000 mg/L Total Dissolved Solids or TDS) 0
Other water (>1,000 mg/L Total Dissolved Solids or TDS) 0
v. Produced water (total):
Freshwater (≤1,000 mg/L Total Dissolved Solids or TDS) 0
Other water (>1,000 mg/L Total Dissolved Solids or TDS) 0
v. Third-party water (total):
Freshwater (≤1,000 mg/L Total Dissolved Solids or TDS) 0
Other water (>1,000 mg/L Total Dissolved Solids or TDS) 0
iv. Third-party water that is sent for use to other organizations: 0
Freshwater (≤1,000 mg/L Total Dissolved Solids or TDS) 0
Other water (>1,000 mg/L Total Dissolved Solids or TDS) 0
Report the total water discharge to all areas with water stress in megalitres 0
i. Surface water (total): 0
Freshwater (≤1,000 mg/L Total Dissolved Solids or TDS) 0
Other water (>1,000 mg/L Total Dissolved Solids or TDS) 0
ii. Groundwater (total): 0
Freshwater (≤1,000 mg/L Total Dissolved Solids or TDS) 0
Other water (>1,000 mg/L Total Dissolved Solids or TDS) 0
iii. Seawater (total): 0
Freshwater (≤1,000 mg/L Total Dissolved Solids or TDS) 0
Other water (>1,000 mg/L Total Dissolved Solids or TDS) 0
iv. Produced water (total): 0
Freshwater (≤1,000 mg/L Total Dissolved Solids or TDS) 0
Other water (>1,000 mg/L Total Dissolved Solids or TDS) 0
iv. Third-party water that is sent for use to other organizations: 0
Freshwater (≤1,000 mg/L Total Dissolved Solids or TDS) 0
Other water (>1,000 mg/L Total Dissolved Solids or TDS) 0
Report the substances of concern, in priority, where discharges are treated
Alachlor 0
Anthracene 0
Atrazine 0
Benzene 0
Brominated diphenylether 0
Cadmium and its compounds 0
(depending on water hardness classes) 0
Carbon-tetrachloride 0
C10-13 Chloroalkanes 0
Chlorfenvinphos 0
Chlorpyrifos (Chlorpyrifos-ethyl) 0
Cyclodiene pesticides: 0
Aldrin 0
Dieldrin 0
Endrin 0
Isodrin 0
DDT total 0
para-para-DDT 0
1,2-Dichloroethane 0
Dichloromethane 0
Di(2-ethylhexyl)-phthalate (DEHP) 0
Diuron 0
Endosulfan 0
Fluoranthene 0
Hexachloro-benzene 0
Hexachloro-butadiene 0
Hexachloro-cyclohexane 0
Isoproturon 0
Lead and its compounds 0
Mercury and its compounds 0
Naphthalene 0
Nickel and its compounds 0
Nonylphenol (4-Nonylphenol) 0
Octylphenol ((4-(1,1′,3,3′-tetramethylbutyl)-phenol)) 0
Pentachloro-benzene 0
Pentachloro-phenol 0
Polyaromatic hydrocarbons (PAH) 0
Benzo(a)pyrene 0
Benzo(b)fluor-anthene 0
Benzo(k)fluor-anthene 0
Benzo(g,h,i)-perylene 0
Indeno(1,2,3-cd)-pyrene 0
Simazine 0
Tetrachloro-ethylene 0
Trichloro-ethylene (7) 0
Tributyltin compounds (Tributhyltin-cation) 0
Trichloro-benzenes 0
Trichloro-methane 0
Trifluralin 0
i. How priority substances of concern were defined, and any international standard, authoritative list, or criteria used 0
ii. The approach for setting discharge limits for priority substances of concern The Zgounder Silver Mine does not discharge
effluent into the environment.
iii. Number of incidents of non-compliance with discharge limits 0
a. Report the total volume of planned and unplanned water discharges by (exclude collected rainwater and domestic sewage): 0
The Zgounder Silver Mine is designed to be a
zero-discharge facility.  The facility does not
have operational water discharges and/or
runoff into the Zgounder river derived from its
operations.
i. Volume of planned discharge to surface water (e.g., wetlands, lakes, rivers) 0
i. Unplanned discharge to surface water (e.g., wetlands, lakes, rivers) 0
i. Planned discharge to groundwater 0
i. Unplanned discharge to groundwater 0
i. planned discharge to seawater 0
i. Unplanned discharge to seawater 0
i. Planned third-party water discharge 0
i. Unplanned third-party water discharge 0
i. Planned third-party water discharge that is sent for use to other organizations 0
i. Unplanned third-party water discharge that is sent for use to other organizations 0
ii. Quality of the water of the planned discharge to surface water (e.g., wetlands, lakes, rivers) The Zgounder Silver Mine does not discharge
effluent into the environment.
ii. Treatment method for the planned discharge to surface water Not Applicable
ii. Quality of the water of the unplanned discharge to surface water (e.g. wetlands, lakes, rivers) Aya Gold & Silver did not have unplanned water
discharge during this reporting period.
ii.Treatment method of unplanned discharge to surface water Not Applicable
ii. Quality of the water of the planned discharge to groundwater The Zgounder Silver Mine does not discharge
effluent into the environment.
ii. Treatment method for the planned discharge to groundwater Not Applicable
ii. Quality of the unplanned discharge to groundwater Aya Gold & Silver did not have unplanned water
discharge during this reporting period.
ii. Treatment method of the unplanned discharge to groundwater Not Applicable
iii. Was the water of the unplanned discharge to groundwater reused by another organization No
ii. Quality of the planned discharge to seawater The Zgounder Silver Mine does not discharge
effluent into the environment.
ii. Treatment method of the planned discharge to seawater Not Applicable
ii. Quality of the unplanned discharge seawater Aya Gold & Silver did not have unplanned water
discharge during this reporting period.
ii. Treatment method of the unplanned discharge to seawater Not Applicable
ii. Quality of the planned third-party water discharge The Zgounder Silver Mine does not discharge
effluent into the environment.
ii. Treatment method of the planned third-party water discharge Not Applicable
ii. Quality of the unplanned third-party water discharge Aya Gold & Silver did not have unplanned water
discharge during this reporting period.
ii. Treatment method of the unplanned third-party water discharge Not Applicable
ii. Quality of the planned third-party water discharge that is sent for use to other organizations The Zgounder Silver Mine does not discharge
effluent into the environment or send it to third
parties.
ii. Treatment method of the planned third-party water discharge that is sent for use to other organizations Not Applicable
ii. Quality of unplanned third-party water discharge that is sent for use to other organizations Aya Gold & Silver did not have unplanned water
discharge during this reporting period.
ii. Treatment method of unplanned third-party water discharge that is sent for use to other organizations Not Applicable
b. Standards, methodologies, and assumptions used The Zgounder Silver Mine does not discharge
effluent into the environment. Aya Gold &
Silver did not have unplanned water discharge
during this reporting period.
Waste
Waste Generation and Significant Waste-Related Impacts
The reporting organization shall report the following information
i. Describe the inputs, activities, and outputs that lead or could lead to these impacts; Waste streams that may be generated during
the operational phase of mining activities
include:
• Residues from mining/processing operations
(overburden and tailings);
• Hazardous waste (waste oil, chemicals,
solvents, batteries, laboratory waste and
medical waste);
• Industrial waste (scrap metal, wood
packaging, plastics);
• Household waste (inert waste such as
plastics, glass and building materials);
• Organic waste (food and plant material).
ii. Describe whether these impacts relate to waste generated in the organization’s own activities or to waste generated upstream or downstream in its value chain These impacts relate to waste generated by the
Corporation's own activities at the Zgounder
Silver Mine.
Report the total amounts generated of the following and associated risks (tonnes) 293099
Overburden amount (tonnes) 0
Overburden is not applicable to the Zgounder
Silver Mine as this is an underground operation
as of 2021.
Overburden risks Not Applicable
Rock amount (tonnes) 74844
Rock risks Not Applicable
In 2021, the Zgounder Silver Mine was an
underground mining operation, and as such the
volumes of waste rock generated are very low.
Waste rock is used for mine back-fill and as
material for civil engineering.

Aya Gold & Silver commissioned a third-party
audit of its waste rock in 2021, and the results
showed no significant potential for acid
generation.
Tailings amount (tonnes) 218255
Tailing risks
   •  Disposal location
   •  Type of waste material disposed
   •  Other, please specify
Tailings contain cyanide.
Sludges amount (tonnes) 0
Sludges risks Not Applicable
Report actions, including circularity measures, taken to prevent waste generation in the organization’s own activities and upstream and downstream in its value chain, and to manage significant impacts from waste generated Aya Gold & Silver implemented a Waste
Management Plan (WMP) in 2021 for its
Zgounder Silver Mine.

The WMP seeks to identify sources of waste
generation, promote its sorting, pickup and
disposal, in addition to its recycling through
partnership with contractors.
If the waste generated by the organization in its own activities is managed by a third party, a description of the processes used to determine whether the third party manages the waste in line with contractual or legislative obligations. In 2021, Aya Gold & Silver contracted a third
party to remove large quantities of scrap metal
that could not be reused internally.  The
provider was  selected through a tender
process that qualified bidders through a
rigorous compliance process that verified
permits, government issued operation permits,
ISO 9001 certification, and previous
experience. The third party purchased the
scrap metal by weight to recycle and repurpose.
In 2022, Aya Gold & Silver will establish a
partnership with an accredited third-party to
dispose of all solid waste present on site that
cannot be processed internally: hazardous
waste, industrial waste, and domestic waste.
Describe the processes used to collect and monitor waste-related data Waste quantity is roughly estimated using the
number of pick-up trucks that collect waste
twice a week from the Zgounder Silver Mine.
Waste Generated
Report the total weight of waste generated (tonne) 293213
Report the composition breakdown of the total waste (tonne) The total waste (in tonnes) generated by the
Zgounder Silver Mine in 2021 is as follows:
•     Sterile Rock: 74 844
•     Tailings: 218 255
•     Scrap metal: 300
•     Toxic waste (oil): 5
•     Tires: 25
•     Other industrial waste: 20
•     Domestic waste: 34
Explain the relevance to the companies sector or activities, e.g., tailings for an organization in the mining sector, electronic waste for an organization in the consumer electronics sector, or food waste for an organization in the agriculture or in the hospitality sector In 2021, relevant waste for the Zgounder Silver
Mine was:

• Sterile rock;
• Tailings;
• Scrap metal;
• Toxic waste (oils and batteries);
• Tires;
• Other industrial waste;
• Domestic waste.
Materials that are present in the waste
   •  Biomass
   •  Metals
   •  Plastics
   •  Textiles
Report contextual information necessary to understand the data and how the data has been compiled Waste rock and tailings were calculated based
on production numbers for 2021.

Domestic waste was estimated based on the
number of trucks per week and typical load per
truck.

Toxic waste was estimated by the site
maintenance department.
Waste Diverted from Disposal
Total weight of waste diverted from disposal (tonne) 400
Total weight of hazardous waste diverted from disposal (tonne), and a breakdown of this total by the following recovery operations: 0
i. Preparation for reuse (total, tonne) 0
Preparation for reuse - Onsite 0
Preparation for reuse - Offsite 0
ii. Recycling (total, tonne) 0
Recycling - Onsite 0
Recycling - Offsite 0
iii. Other recovery operations (total, tonne) 0
Other recovery operations - Onsite 0
Other recovery operations - Offsite 0
Report the total weight of non-hazardous waste diverted from disposal (tonnes), and a breakdown of this total by the following recovery operations: 400
i. Preparation for reuse (total, tonne) 100
Preparation for reuse - Onsite 100
Preparation for reuse - Offsite 0
ii. Recycling (total, tonne) 300
Recycling - Onsite 0
Recycling - Offsite 300
iii. Other recovery operations (total, tonne) 0
Other recovery operations - Onsite 0
Other recovery operations - Offsite 0
Disclose contextual information necessary to understand the data and how the data has been compiled In 2021, Aya Gold & Silver contracted a third
party to purchase scrap metal by the tonne to
be recycled and reused. The data was obtained
by weighing the trucks when leaving the
Zgounder Silver Mine.
Scrap metal is also reused internally by the
fixed maintenance department. The number for
reuse - onsite was estimated.
Waste Directed to Disposal
Report the total weight of waste directed to disposal (tonne). 54
Total weight of hazardous waste directed to disposal (tonne), and a breakdown of this total by the following recovery operations: 0
i. Incineration (with energy recovery), (tonne) 0
Incineration (with energy recovery) - Onsite 0
Incineration (with energy recovery) - Offsite 0
ii. Incineration (without energy recovery), (tonne) 0
Incineration (without energy recovery) - Onsite 0
Incineration (without energy recovery) - Offsite 0
iii. Landfilling (total, tonne) 0
Landfilling - Onsite 0
Landfilling - Offsite 0
iv. Other recovery operations (total, tonne) 0
Other recovery operations - Onsite 0
Other recovery operations - Offsite 0
Report the total weight of non-hazardous waste diverted from disposal (tonnes), and a breakdown of this total by the following recovery operations: 54
i. Incineration (with energy recovery), (tonne) 0
Incineration (with energy recovery) - Onsite 0
Incineration (with energy recovery) - Offsite 0
ii. Incineration (without energy recovery), (tonnes) 54
Incineration (without energy recovery) - Onsite 54
Incineration (without energy recovery) - Offsite 0
iii. Landfilling (total, tonne) 0
Landfilling - Onsite 0
Landfilling - Offsite 0
iv. Other recovery operations (total, tonne) 0
Other recovery operations - Onsite 0
Other recovery operations - Offsite 0
Disclose contextual information necessary to understand the data and how the data has been compiled Data on  on-site incineration waste  is
estimated based on domestic and industrial
waste generated in 2021.
Effluents and Waste
Water Bodies Affected by Water Discharge
a. The reporting organization shall report the water bodies and related habitats that are significantly affected by water discharges and/or runoff: The Zgounder Silver Mine is located in the
immediate vicinity of the Zgounder seasonal
river.
The Zgounder Silver Mine is designed to be a
zero-discharge facility.  The company does not
have operational water discharges and/or
runoff into the Zgounder river derived from its
operations.
i. The size of the water body and related habitat 74
The Zgounder River is part of the  Zgounder
watershed that  covers a total area of 74 km2.
ii. Whether the water body and related habitat is designated as a nationally or internationally protected area No
iii. The biodiversity value, i.e., total number of protected species Other, please specify
The Zgounder seasonal river is dry from April
to October. In the remaining months, the river
is utilized by minor fauna that are not on any
lists of endangered or protected species.
Waste Type and Disposal
a. Report the total weight of hazardous waste (tonnes): 5
i. Reuse 0
ii. Recycling 0
iii. Composting 0
iv. Recovery, including energy recovery 0
v. Incineration (mass burn) 0
vi. Deep well injection (Oil & Gas) 0
vii. Landfill 0
viii. On-site storage 5
ix. Other (to be specified by the organization) 0
b. Total weight of non-hazardous waste (tonnes): 479
i. Reuse 100
ii. Recycling 300
iii. Composting 0
iv. Recovery, including energy recovery 0
v. Incineration (mass burn) 54
vi. Deep well injection (Oil & Gas) 0
vii. Landfill 0
viii. On-site storage 25
ix. Other (to be specified by the organization) 0
c. How the waste disposal method has been determined:
i. Reuse Disposed of directly by the organization, or
otherwise directly confirmed
ii. Recycling Information provided by the waste disposal
contractor
iii. Composting Not Applicable
iv. Recovery, including energy recovery Not Applicable
v. Incineration (mass burn) Disposed of directly by the organization, or
otherwise directly confirmed
vii. Landfill Not Applicable
viii. On-site storage Disposed of directly by the organization, or
otherwise directly confirmed
ix. Other (to be specified by the organization) Not Applicable
Significant Spills
The reporting organization shall report the following information
a. Total number of recorded significant spills: 0
Oil spills 0
Fuel spills 0
Spills of wastes 0
Spills of chemicals 0
Other, as specified by the organization 0
b. Additional information as reported in the organization’s financial statements for significant spills
i. Location of spill:
ii. Volume of spill as recorded in the financial statements for significant spills (in megaliters)
iii. Material and impacted surface of spill:
Oil spills Not Applicable
Fuel spills Not Applicable
Spills of wastes Not Applicable
Spills of chemicals Not Applicable
Other, as specified by the organization Not Applicable
c. Impacts of significant spills Aya Gold & Silver did not have any significant
spills as a result of its operations in 2021.
Transport of Hazardous Waste
The reporting organization shall report the following information
a. Total weight for each of the following:
i. Hazardous waste transported (tonne) 0
ii. Hazardous waste imported (tonne) 0
iii. Hazardous waste exported (tonne) 0
iv. Hazardous waste treated (tonne) 0
b. Percentage of hazardous waste shipped internationally: Does Not Apply
c. Standards, methodologies, and assumptions used In 2021, Aya Gold & Silver stored its hazardous
waste onsite while evaluating its options for
contracting a third party to transport and
remove waste safely.
Waste Management
Total amount of tailings waste generated from mining activities by the entity during the reporting period (tonne) 218255
Percentage of tailings waste that was recycled during the reporting period: 34.2920%
Weight of tailings waste material that was reused (tonne) 0
Weight of recycled or remanufactured (through treatment or processing) by the entity (tonne), e.g., backfill 74844
In 2021, the Zgounder Silver Mine operated
underground only. As such, the volumes of
sterile rocks are relatively low compared to
open pit mining, and the Corporation recycles
all this material for road maintenance and
backfill.
Amount of tailings waste sent externally for further recycling (tonne) 0
Total amount of mineral processing waste generated by the entity during the reporting period (tonne), e.g. tailings and slag 218255
Percentage of mineral processing waste that was recycled during the reporting period: 34.2920%
Tailings impoundments according to the following U.S. Mine Safety and Health Administration (MSHA) hazard potential classification: 4
High hazard potential (number) 0
Significant hazard potential (number) 2
Aya Gold & Silver's Zgounder Silver Mine has a
total of 4 tailings dams. Each of the tailings
dams have a maximum storage capacity of  no
more that 4.5 acre-feet. Two of the tailings
dams are closed and no longer in operation. The
remaining two active tailings dams would not
cause loss of life nor disrupt important utilities
or cause economic loss due to their distance to
surrounding communities. They could
potentially cause harm to the surrounding
environment.
Low hazard potential (number) 2
Disclose the total amount of non-mineral waste generated (tonne) 384
Disclose the total weight of tailings produced (tonne) 218255
Disclose the total amount of waste rock generated (tonne) 74844
Disclose the total amount of overburden removed (tonne) 0
Disclose the total weight of waste generated that was hazardous (tonne) 5
Disclose the total weight of hazardous waste generated that was recycled (tonne). 0
Disclose the total number of significant incidents associated with handling, storage, transportation, or disposal of hazardous materials used in mineral processing activities and hazardous waste generated. 0
Describe the policies and procedures that are set forth by the company's waste and hazardous materials management strategy. In 2021, Aya Gold & Silver implemented a
Waste Management Plan at its Zgounder Silver
Mine. As per that plan, hazardous waste was
stored onsite in 2021 while the Corporation
evaluated third parties to safely dispose of
hazardous waste.
Describe how its policies and procedures compare with those required by local jurisdictions that apply to the entity. The Corporation is in compliance with all
policies and procedures required by the
Ministry of Energy, Mines and Sustainable
Development (MEM) of the Kingdom of
Morocco. In addition, it generally strives to
apply international best practices.
Describe its approach to waste management during the entire project life cycle. Please refer to the  attached document  for a
description of Aya Gold & Silver's approach to
waste management.
Aya Gold & Silver's Approach to Waste Management
Describe the approach to the management of hazardous materials used in processing At the Zgounder Silver Mine, hazardous
material used in processing consists primarily
of processing solution.
In 2021, Aya Gold & Silver implemented a
hazardous material management plan to assess
risks,  provide safe storage, handling and
disposal of hazardous material.
Describe how waste and hazardous materials management efforts are coordinated among business partners (e.g., contractors and subcontractors). Please refer to the answer above on the
Corporation's approach to waste management
during the entire project life cycle.
Describe how the company ensures compliance and conformance with waste and hazardous material management policies and procedures. In 2021, a third-party provider was selected
through a tender process that qualified bidders
through a rigorous compliance process
involving verification of permits, government-
issued operation permits, ISO 9001
certification, and previous experience.
Tailings Storage Facilities Management
Does your company manage Tailings Storage Facilities Yes
Provide an inventory of all talings storage facilities (TSFs):
TSF #1: (1) facility name "Historical Tailings"
The "Historical Tailings" were operated
between 1980 and 1990 by the Société minière
de Sidi Lahcen (SOMIL). In 2021, Aya Gold &
Silver developed a NI 43-101 Feasibility Study
("FS") for the Zgounder Silver Mine Expansion
Project, in which the reprocessing of the
historical tailings was added to the project for
an estimated 817,000 ounces of indicated
silver.

As per the mining plan described in the FS, the
Historical Tailings will be reprocessed towards
the end of life of the Zgounder Silver Mine, and
the Corporation will then proceed to TSF
closure and environmental rehabilitation.
TSF #1: (2) location Morocco
TSF #1: (3) ownership status Company owned
TSF #1: (4) operational status Not in operation
TSF #1: (5) construction method Upstream
TSF #1: (6) maximum permitted storage capacity 0
Maximum permitted storage is unknown for
this facility.
TSF #1: (7) current amount of tailings stored 318000
Total tailings stored are calculated in tons.
TSF #1: (8) consequence classification Low
TSF #1: (9) date of most recent independent technical review 1980-01-01
The date of the most recent independent
technical review is unknown for this TSF, as it
was decommissioned in 1990.
TSF #1: (10) material findings No
TSF #1: (11) mitigation measures Not applicable to the results of the most recent
independent technical review.
TSF #1: (12) site-specific EPRP No
The TSF was decommissioned in 1990 and does
not present any stability risks at present.
TSF #2: (1) facility name "Ancient Tailings"
The Ancient Tailings facility is currently under
rehabilitation, and revegetation has begun to
close the facility.
TSF #2: (2) location Morocco
TSF #2: (3) ownership status Company owned
TSF #2: (4) operational status Not in operation
TSF #2: (5) construction method Upstream
TSF #2: (6) maximum permitted storage capacity 0
Maximum permitted storage is unknown for
this facility.
TSF #2: (7) current amount of tailings stored 0
The current amount of tailings stored is
unknown.
TSF #2: (8) consequence classification Low
TSF #2: (9) date of most recent independent technical review 2021-04-01
TSF #2: (10) material findings No
TSF #2: (11) mitigation measures Not applicable to the results of the most recent
independent technical review.
TSF #2: (12) site-specific EPRP No
The "ancient tailings" facility were operated by
the previous management for about one year,
in 2019. Decommissioning was already
underway when new management started at
the Zgounder Silver Mine in mid-2020.

In 2021, Aya Gold & Silver organized a third-
party audit to get an independent assessment
of the stability of the structure.
Recommendations were immediately
implemented and the Corporation is now
evaluating the process of environmental
rehabilitation for this TSF.
TSF #3: (1) facility name "Flotation Tailings"
TSF #3: (2) location Morocco
TSF #3: (3) ownership status Company owned
TSF #3: (4) operational status In operation
TSF #3: (5) construction method Upstream
TSF #3: (6) maximum permitted storage capacity 0
Aya Gold & Silver's permitting from the
Ministry of Energy, Mine and Sustainable
Development does not have a maximum
permitted storage capacity. Maximum
permitted storage is unknown for this facility.
TSF #3: (7) current amount of tailings stored 156532
Amount of tailings stored in 2021 in tonnes.
TSF #3: (8) consequence classification Low
TSF #3: (9) date of most recent independent technical review 2021-10-28
TSF #3: (10) material findings No
TSF #3: (11) mitigation measures Construction of a concrete ditch at the foot of
the TSF to collect potential leaks at the foot of
the dam. These will be pumped back into the
process to build a contingency dam.
TSF #3: (12) site-specific EPRP No
Aya Gold & Silver is developing its Emergency
Preparedness and Response Plans for
conclusion in 2022.
TSF #4: (1) facility name "Cyanidation Tailings"
TSF #4: (2) location Morocco
TSF #4: (3) ownership status Company owned
TSF #4: (4) operational status Operational
TSF #4: (5) construction method Upstream
TSF #4: (6) maximum permitted storage capacity 0
Aya Gold & Silver's permit from the Ministry of
Energy, Mines and Sustainable Development
does not state a maximum permitted storage
capacity.  Maximum permitted storage is
unknown for this facility.
TSF #4: (7) current amount of tailings stored 130000
This amount is an estimation as Aya Gold &
Silver does not have data from prior operators
of the Zgounder Silver Mine.

In 2021, Aya Gold and Silver added 58,360
tonnes of tailings to the facility.
TSF #4: (8) consequence classification Significant
TSF #4: (9) date of most recent independent technical review 2021-10-28
TSF #4: (10) material findings No
TSF #4: (11) mitigation measures Installation of a secondary pumping mechanism
for water evacuation, and a network of
auscultation and piezometer devices.
TSF #4: (12) site-specific EPRP No
Aya Gold & Silver is in the process of
developing its Emergency Preparedness and
Response Plans. These will be concluded in
2022.
Provide a summary of the tailings management systems used to monitor and maintain the structural integrity of tailings facilities and to minimize the risk of a catastrophic failure. In 2021, Aya Gold & Silver implemented
quarterly audits by external third parties to
review the structural integrity and overall
status of the two operating tailings facilities,
with the objective of applying the Global
Industry Standard on Tailings Management
(GIST) retroactively to operating TSFs.
As per the Feasibility Study for the Zgounder
Silver Mine Expansion Project, a new TSF will
be constructed ("Site C") in 2023. The GIST will
be applied from the beginning of the planning
process.
Provide summary of tailings management systems and governance structure used to monitor and maintain the stability of tailings storage facilities In addition to quarterly audits, Aya Gold &
Silver implements monthly internal audits to
monitor the implementation of the
recommendations issued by the external third-
party audits.
The results of these audits are reported to the
VP of Operations and the Board of Directors.
Disclose the approach to the development of Emergency Preparedness and Response Plans (EPRPs). The Corporation is in the process of developing
its Emergency Preparedness and Response
Plans. These will be concluded in 2022.
Disclose its approach to engagement concerning Emergency Preparedness and Response Plans (EPRPs) at tailings storage facilities, including the preparedness of local stakeholders. Aya Gold & Silver's approach to the
development of the Emergency Preparedness
and Response Plans includes engagement and
coordination with local authorities.
Innovation
Describe nature of spending on Research, Development and Technologies for waste management compliance and improvement In 2021, Aya Gold & Silver focused on
upgrading its waste-sorting facility in order to
improve its waste-management efficiency.
Materials
Materials Stewardship
Identify programs related to materials stewardship and report on their progress In 2021, Aya Gold & Silver did not have any
programs related to materials stewardship.
By Weight and Volume
a. Report the total weight or volume of materials that are used to produce and package the organization’s primary products and services during the reporting period, by:
Total Weight (tonnes) 0
Aya Gold & Silver does not use any materials to
produce and package the organization’s
primary products and services.
Total Volume (cubic metres) 1
i. Weight of non-renewable materials used, (tonnes) 0
i. Volume of non-renewable materials used (cubic metres) 0
ii. Weight of renewable materials used (tonnes) 0
ii. Volume of renewable materials used (cubic metres) 0
Supplier Environmental Assessment
New Suppliers Screened
a. Report the percentage of new suppliers that were screened using environmental criteria: 0.0000%
Negative Impacts in the Supply Chain and Results
a. Report the number of suppliers assessed for environmental impacts 0
In 2021, Aya Gold & Silver did not evaluate
suppliers based on their environmental impact.
During their selection, suppliers are
systematically evaluated on criteria such as
competitiveness, responsiveness, and
reputation in the Moroccan market, which
takes into account environmental acceptability
factors.

In 2022, the Corporation will implement a new
approach for the Expansion Project which
includes the pre-selection of suppliers. Each
work package/tender will include a
questionnaire that screens for environmental
factors. This questionnaire will allow the
Corporation to rank suppliers and eliminate
those with a potential history of negative
environmental impacts.
b. Report the number of suppliers identified as having significant actual and potential negative environmental impacts 0
In 2021, the Corporation did not identify any
suppliers as currently exerting or likely to exert
adverse environmental impact. Raw materials
that could potentially impact the environment
are imported from global suppliers that respect
HSEC international standards and supply
leading mining groups in Morocco.
c. Report significant actual and potential negative environmental impacts identified in the supply chain 0
d. Report the percentage of suppliers identified as having significant actual and potential negative environmental impacts with which improvements were agreed upon as a result of assessment: 0.0000%
e. Report the percentage of suppliers identified as having significant actual and potential negative environmental impacts with which relationships were terminated as a result of assessment, and why: 0.0000%
Biodiversity
Management Plan
Disclose the approach to biodiversity management Please refer to the attached document for a
description of Aya Gold & Silver's approach to
Biodiversity Management.
Aya Gold & Silver's Biodiversity Management Plan
Describe significant impacts of activities, products and services on biodiversity in protected areas and areas of high biodiversity value outside protected areas None of Aya Gold & Silver's operations are
located in protected areas or in areas of high
biodiversity value outside of protected areas.
List the environmental and biodiversity management plan(s) implemented at active sites The following plans are implemented at the
Zgounder Silver Mine:
•     Water Management Plan
•     Waste Management
•     Environmental and Social Management Plan
1.1 Mine lifecycle stages to which the plan(s) apply
   •  Site development
   •  Production
   •  During closure
   •  Decommissioning
   •  Restoration
1.2 The topics addressed by the plan(s)
   •  Ecological and biodiversity impacts
   •  Waste generation
   •  Noise impacts
   •  Emissions to air
   •  Discharges to water
   •  Natural resource consumption
   •  Hazardous chemical usage
1.3 The underlying references for its plan(s), including whether they are codes, guidelines, standards, or regulations; whether they were developed by the entity, an industry organization, a third-party organization (e.g., a non-governmental organization, a governmental agency, or some combination of these groups) Water and Waste management plans were
developed internally and follow the typical ISO
14001 structure as they are part of our
Environmental and Social Management System.
The Environmental and Social Management
Plan was developed by NOVEC, the consulting
firm that developed the 2022 Environmental
and Social Impact Assessment for the Zgounder
Silver Mine Expansion Project.
Impacts of Policies and Procedures
Where relevant, describe specific policies and practices that apply to areas with protected conservation status and/or areas of critical habitat, which are defined by the International Finance Corporation (IFC) Performance Standard 6: Aya Gold & Silver does not have any specific
policies that apply to areas with protected
conservation status and/or areas of critical
habitat as the  Corporation does not have
operations in such areas.
If the management policies and practices do not apply to all of the entity’s sites or operations, indicate the percentage of sites to which they were applied. 0
Where environmental management policies and practices differ significantly by mineral resource (e.g., bauxite mining as compared to silver mining) then describe differences for each resource. Currently, Aya Gold & Silver only produces
silver.
Disclose the degree to which its policies and practices are aligned with the International Finance Corporation’s (IFC) Performance Standards on Environmental and Social Sustainability, January 1, 2012, including specifically:
IFC Performance Standard 1 — Assessment and Management of Environmental and Social Risks and Impacts. Full alignment
IFC Performance Standard 3 — Resource Efficiency and Pollution Prevention. Full alignment
IFC Performance Standard 4 — Community Health, Safety, and Security. Full alignment
IFC Performance Standard 6 — Biodiversity Conservation and Sustainable Management of Living Natural Resources. Full alignment
Impacts
Percentage of its mine sites (by annual production output from mines in tonnes) where acid-generating seepage into surrounding surface water and/or groundwater is: predicted to occur 0.0000%
Percentage of mine sites (by annual production output from mines in tonnes) where acid-generating seepage into surrounding surface water and/or groundwater is: actively mitigated 0.0000%
Percentage of mine sites (by annual production output from mines in metric tonnes) where acid-generating seepage into surrounding surface water and/or groundwater is: under treatment or remediation 0.0000%
Provide a breakdown by business unit where acid rock drainage occur, is activelly mitigated and/or under treatment or remediation Acid rock drainage does not occur at the
Zgounder Silver Mine.
Does access to the site involve traversing a protected area No
Do any of the entities concessions share a watershed with a protected area No
Provide context and description of site access involving traversing protected areas, and/or watersheds shared with a protected area. Include reference to measures in place to assure access, any proactive programs to support the biodiversity of the protected area, and any formal complaints or compliance issues and related steps to resolve Not applicable to the Corporation's Zgounder
Silver Mine.

The Zgounder Mine is accessible from the City
of Agadir on the well-maintained paved
highways  of N10 and P1706 that run east for
205 km to Taliouine in the Taroudant Province.
Most of the remaining 61 km to the mine is
traveled on a paved road to the village of
Askaoun. The final five (5) km drive to the mine
is via a dirt road. The Zgounder Silver Mine is
also accessible with a 278 km drive on paved
highways from the City of Marrakesh.
Percentage of proved reserves in sites with protected conservation status or in areas of endangered species habitat: 0.0000%
Grade (in percentage %) of proved reserves located in areas either with protected conservation status or in areas of endangered species habitat 0
Fossil Fuel:
Coal 0
Natural Gas 0
Liquid Petroleum Gas (LPG) 0
Nuclear Fuel:
Uranium (U) 0
Thorium (Th) 0
Gemstones:
Flourite (CaF₂) 0
Diamond 0
Metals:
Aluminium (Al) 0
Antimony (Sb) 0
Bauxite (Al₂H₂O₄) 0
Bismuth (Bi) 0
Cobalt (Co) 0
Copper (Cu) 0
Chromium (Cr) 0
Feldspar (KAlSi₃O₈) 0
Gold (Au) 0
Iron ore (Fe) 0
Lead (Pb) 0
Lithium (Li) 0
Manganese (Mn) 0
Mercury (Hg) 0
Mica 0
Nickel (Ni) 0
Niobium (Nb) 0
Palladium (Pd) 0
Platinum (Pt) 0
Silicon (Si) 0
Silver (Ag) 0
Tin (Sn) 0
Titanium (Ti) 0
Zinc (Zn) 0
Percentage of probable reserves in sites with protected conservation status or in areas of endangered species habitat: 0.0000%
Grade (in percentage %) of probable reserves located in areas either with protected conservation status or in areas of endangered species habitat 0
Fossil Fuel:
Coal 0
Natural Gas 0
Liquid Petroleum Gas (LPG) 0
Nuclear Fuel:
Uranium (U) 0
Thorium (Th) 0
Gemstones:
Flourite (CaF₂) 0
Diamond 0
Metals:
Aluminium (Al) 0
Antimony (Sb) 0
Bauxite (Al₂H₂O₄) 0
Bismuth (Bi) 0
Cobalt (Co) 0
Copper (Cu) 0
Chromium (Cr) 0
Feldspar (KAlSi₃O₈) 0
Gold (Au) 0
Iron ore (Fe) 0
Lead (Pb) 0
Lithium (Li) 0
Manganese (Mn) 0
Mercury (Hg) 0
Mica 0
Nickel (Ni) 0
Niobium (Nb) 0
Palladium (Pd) 0
Platinum (Pt) 0
Silicon (Si) 0
Silver (Ag) 0
Tin (Sn) 0
Titanium (Ti) 0
Zinc (Zn) 0
Percentage of inferred, indicated and measured reserves in sites with protected conservation status or in areas of endangered species habitat: 0.0000%
Amount of land (owned or leased, and managed for production activities or extractive use) disturbed or rehabilitated (hectares).
Total land disturbed and not yet rehabilitated (A: opening balance); 100
This is an estimation.
Total amount of land newly disturbed within the reporting period (B); 0
Total amount of land newly rehabilitated within the reporting period to the agreed end use (C) 0
Total land disturbed and not yet rehabilitated (D= A+B-C; closing balance). 100
Total cumulative land rehabilitated since the beginning of the operaion (hectars). 0
The number and percentage of total sites identified as requiring biodiversity management plans (BMP) according to stated criteria, and the number (percentage) of those sites with plans in place
Identify the total number of sites 1
Report criteria for deciding that a BMP is required.
   •  Scale of impact
   •  Sensitivity of the area
   •  Local community use of biodiversity
   •  Ecosystems services provided by the local
environment – e.g. wetlands (water
purification, carbon sequestration), etc.
   •  Cultural relevance
   •  Protected status (or proximity to protected
areas)
   •  Iconic species or red listed species
   •  Potential post closure use
   •  Business case/risk aspects
Report the number of total sites that have been assessed under the criteria as in need of a BMP 0
As per IFC PS6 guidelines, the Zgounder Silver
Mine does not require Biodiversity
Management Plans. However, as per Aya Gold
& Silver's precautionary principles and values,
the Corporation will conduct a semi-annual
biodiversity assessment as per the
Environmental and Social  Management Plan
included in the 2022 ESIA for the Zgounder
Silver Mine.
Report the percentage of total sites that have been assessed under the criteria as in need of a BMP 0.0000%
Of the number of sites in need of a BMP, report the number that have a BMP in place and operational 0
Of the number of sites in need of a BMP, report the percentage that have a BMP in place and operational Does Not Apply
Protected Areas
For each operational site owned, leased, managed in, or adjacent to, protected areas and areas of high biodiversity value outside protected areas, report the following information:
i. Geographic location Aya Gold & Silver does not have any
operational sites owned, leased, managed or
adjacent to protected areas and areas of high
biodiversity value outside of protected areas.
ii. Subsurface and underground land that may be owned, leased, or managed by the organization Aya Gold & Silver does not have any
operational sites owned, leased, managed or
adjacent to protected areas and areas of high
biodiversity value outside of protected areas.
iii. Position in relation to the protected area (in the area, adjacent to, or containing portions of the protected area) or the high biodiversity value area outside protected areas Aya Gold & Silver does not have any
operational sites owned, leased, managed or
adjacent to protected areas and areas of high
biodiversity value outside of protected areas.
Significant Impacts of Activities, Products and Services
Report the nature of significant direct and indirect impacts on biodiversity with reference to one or more of the following:
i. Construction or use of manufacturing plants, mines, and transport infrastructure Processing/Production
ii. Pollution (introduction of substances that do not naturally occur in the habitat from point and non-point sources) Yes
iii. Introduction of invasive species, pests, and pathogens Not Applicable
iv. Reduction of species No
v. Habitat conversion No
vi. Changes in ecological processes outside the natural range of variation (i.e., salinity or changes in groundwater level) Not Applicable
Significant direct and indirect positive and negative impacts with reference to the following:
i. Species affected Not Applicable
ii. Extent of areas impacted Not Applicable
iii. Duration of impacts Not Applicable
Habitats Protected or Destroyed
The reporting organization shall report the following information:
Size and location of all habitat areas protected or restored, and whether the success of the restoration measure was or is approved by independent external professionals There are no  significant habitats surrounding
the Zgounder Silver Mine or impacted by its
operation.
Whether partnerships exist with third parties to protect or restore habitat areas distinct from where the organization has overseen and implemented restoration or protection measures No partnerships exist with third parties to
protect or restore habitat areas as this is not a
material issue for the Zgounder Silver Mine.
IUCN Red List Species and National Conservation List Species
Report the total number of IUCN Red List species with habitats in areas affected by the operations of the organization, by level of extinction risk. Note to reader, as there are 37,400 species on the IUCN Red List that are classified in nine categories, you may choose from the nine categories
i. Not Evaluated Not applicable to the Zgounder SIlver Mine.
ii. Data Deficient Not applicable to the Zgounder SIlver Mine.
iii. Least Concern Not applicable to the Zgounder SIlver Mine.
iv. Near threatened Not applicable to the Zgounder SIlver Mine.
v. Vulnerable Not applicable to the Zgounder SIlver Mine.
vi. Endangered Not applicable to the Zgounder SIlver Mine.
vii. Critically Endangered Not applicable to the Zgounder SIlver Mine.
viii. Extinct in the Wild Not applicable to the Zgounder SIlver Mine.
ix. Extinct Not applicable to the Zgounder SIlver Mine.
Social
Employment
Scale of the Organization
i. Report the total number of direct employees worldwide (exclude contractors) 257
For this reporting period, Aya Gold & Silver is
only reporting on its operations in Morocco. In
2021, the Corporation retained 17 direct
employees and 6 contract employees at its
corporate office in Montreal, Quebec. These
employees' statistics are not included in this
report.
ii. Report the total number of contract employees worldwide 262
Aya Gold & Silver includes data on contractors
from its Zgounder operation. For this reporting
period, the Corporation has identified
contractors as those with contracts exceeding
6 months.
Female employees and contractors as percentage of total employees and contractors 3.4749%
Male employees and contractors as percentage of total employees and contractors 96.5318%
Non-binary employees and contractors as percentage of total employees and contractors 0.0000%
Total number of employees and contractors with gender not disclosed 0
Employees and contractors with gender not disclosed as percentage of total employees and contractors 0.0000%
Contractors as percentage of total employed workforce worldwide 50.4817%
Report the total number of operations 1
Employee Information
Report the total number of direct employees by employment type (permanent and temporary), by gender: 257
Total number of permanent employees 252
Total number of permanent employees - female 18
Total number of permanent employees - male 234
Total number of permanent employees - Non-binary 0
Total number of permanent employees - Gender not disclosed 0
Total number of temporary employees 5
Total number of temporary employees - female 0
Total number of temporary employees - male 5
Total number of temporary employees - Non-binary 0
Total number of temporary employees - Gender not disclosed 0
Report the total number of contractors by employment type (permanent and temporary), by gender: 262
In 2021, Aya Gold & Silver did not collect
contractor hire data by gender and
employment type for the Zgounder Silver Mine.
This data will be collected and reported in
subsequent years.
Report the total number of employees by employment type (full-time and part-time), by gender: 257
Total number of full-time employees - female 18
Total number of part-time employees - female 0
Total number of full-time employees - male 239
Total number of part-time employees - male 0
Total number of full-time employees - Non-binary 0
Total number of part-time employees - Non-binary 0
Total number of full-time employees - Gender not disclosed 0
Total number of part-time employees - Gender not disclosed 0
Report the total number of contractors by employment type (full-time and part-time), by gender: 262
In 2021, Aya Gold & Silver did not collect data
from contractors on employment by type, by
gender for the Zgounder Silver mine. This data
will be collected and reported in subsequent
years..
Total number of full-time contractors - female 0
Total number of part-time contractors - female 0
Total number of full-time contractors - male 262
Total number of part-time contractors - male 0
Total number of full-time contractors - Non-binary 0
Total number of part-time contractors - Non-binary 0
Total number of full-time contractors - Gender not disclosed 0
Total number of part-time contractors - Gender not disclosed 0
Turnover
Report the total number and rate of employee turnover during the reporting period, by age group, and gender
All Employees:
Total number of turnover (the number that left during the period) 11
Rate of turnover 2.6253%
Voluntary Turnover:
Total number of turnover (the number that left voluntarily during the period) 6
Rate of turnover 1.4320%
Involuntary Turnover:
Total number of turnover (the number that left involuntarily during the period) 5
Rate of turnover 1.1933%
Female employees:
Total number of turnover (the number of females that left during the period) 2
Rate of turnover, females 12.9032%
Male employees:
Total number of turnover (the number of males that left during the period) 9
Rate of turnover, males 2.2305%
Non-binary employees:
Total number of turnover (the number non-binary that left during the period) 0
Rate of turnover, non-binary Does Not Apply
Turnover & Age Breakdown
Employees aged 30 years old and under:
Total number of turnover (the number that left during the period) 3
As percent of total employees 23.5067%
Rate of turnover 3.2787%
Employees aged between 30 and 50 years old:
Total number of turnover (the number that left during the period) 8
As percent of total employees 61.0790%
Rate of turnover 3.0829%
Employees over 50 years old:
Total number of turnover (the number that left during the period) 0
As percent of total employees 15.4143%
Rate of turnover 0.0000%
Identify types of employees captured in the turnover rate calculations All employees on the payroll
Average age of employees 38
New Hires and Rate of Hire
i. Report the total number and rate of new employee hires during the reporting period, by age group, gender and region
All employees:
Total hires during the reporting period 211
Rate of hire 40.6551%
Female employees:
Total female hires during the reporting period 7
Females as percent of total new hires 3.3175%
Male employees:
Total males hires during the reporting period 204
Males as percent of total new hires 96.6825%
Non-binary employees:
Total non-binary hires during the reporting period 0
Non-binary as percent of total new hires 0.0000%
Employees aged 30 years old and under:
Total hires during the reporting period (30 yr and under) 93
30 yr and under as percent of total new hires 44.0758%
Employees aged between 30 and 50 years old:
Total hires during the reporting period (30-50 yrs) 114
30-50 yrs as percent of total new hires 54.0284%
Employees over 50 years old:
Total hires during the reporting period (50+ yrs) 4
50+ yrs as percent of total new hires 1.8957%
Identify types of employees captured in the hire rate calculations All employees on the payroll
Full-time Employee Benefits
Report the benefits which are standard for full-time employees of the organization but are not provided to temporary or part-time employees, by significant locations of operation Not Applicable
Aya Gold & Silver's part-time employees
receive the same benefits as full-time
employees at our Zgounder Silver Mine site.
Provide the definition used for ‘significant locations of operation’ In this reporting period, Aya Gold and SIlver is
disclosing information exclusively from its
Zgounder Silver Mine.
Parental leave
Report the total number of employees that were entitled to parental leave, by gender:
Male 11
Female 0
Non-binary 0
Report the total number of employees that took parental leave, by gender:
Male 11
Female 0
Non-binary 0
Report the total number of employees that returned to work in the reporting period after parental leave ended, by gender:
Male 11
Female 0
Non-binary 0
Report the total number of employees that returned to work after parental leave ended that were still employed 12 months after their return to work, by gender:
Male 11
Female 0
Non-binary 0
Report the return to work rates of employees that took parental leave, by gender:
Male 100.0000%
Female Does Not Apply
Non-binary Does Not Apply
Report the retention rates of employees that took parental leave, by gender:
Male Does Not Apply
Female Does Not Apply
Non-binary Does Not Apply
Labour Relations
Collective Bargaining Agreements
Percentage of total direct employees covered by collective bargaining agreements: 0.0000%
Notice Periods
Minimum number of weeks’ notice typically provided to employees and their representatives prior to the implementation of significant operational changes that could substantially affect them 4 weeks
Collective Bargaining Agreements - US & Foreign Workforce
Report the percentage of U.S. employees in the active workforce that are covered under collective bargaining agreements: Does Not Apply
Report the percentage of foreign employees in the active workforce that are covered under collective bargaining agreements: 0.0000%
Disclose the number of work stoppages of work stoppages involving 1,000 or more workers lasting one full shift or longer. 0
Disclose the total duration, in worker days idle, of work stoppages involving 1,000 or more workers lasting one full shift or longer. 0
Report total number of strikes and lock-outs exceeding one week's duration
Number of lock-outs exceeding one week's duration 0
Number of stikes exceeding one week's duration 0
Number of operations with closure plans 1
Percent of operations with closure plans 100.0000%
Report on the overall financial provision for closure, or include a reference to the relevant financial statements. Aya Gold & Silver has designed a closure plan
and expansion project for the Zgounder
operation. Please see attached NI 43-101
Technical Report Feasibility Study, page 379.
NI 43-101 Zgounder Feasibility Study
Freedom of Association and Collective Bargaining
Operations and Suppliers At Risk
Report the operations and suppliers in which workers’ rights to exercise freedom of association or collective bargaining may be violated or at significant risk either in terms of:
i. Type of operation (i.e., manufacturing plant) and supplier Aya Gold & Silver's operations at the Zgounder
Silver Mine consist of underground mining and
metal processing activities. Suppliers consist
mostly of contractors working on site.
ii. Countries or geographic areas with operations and suppliers considered at risk Morocco
The Corporation's Zgounder Silver Mine is
located in the jurisdiction of Morocco
considered by international organizations to
have lax statutes on organizing labor.
Report measures taken by the organization in the reporting period intended to support rights to exercise freedom of association and collective bargaining As per the Kingdom of Morocco's Labor code,
the Zgounder Silver Mine  has elected worker
representatives.
Occupational Health and Safety
Health & Safety Management System
For employees and for workers who are not employees, but whose work and/or workplace is controlled by the organization, report the following:
A statement of whether an occupational health and safety management system has been implemented Yes
i. The system has been implemented because of legal requirements and, if so, a list of the requirements Yes, the OHS System for the Zgounder Silver
Mine has been implemented to meet the
following  legal requirements:
- Moroccan labor code (Loi n°65-99)
- Occupational environment (Arrêté N° 93-08
du 6 joumada I 1489 (BO n° 5680 du 06/11/08)
- Moroccan mining code
ii. The system has been implemented based on recognized risk management and/or management system standards/guidelines and, if so, a list of the standards/guidelines The system implemented is based on risk
management and ISO 45001:2018.
A description of the scope of workers, activities, and workplaces covered by the occupational health and safety management system, and an explanation of why any workers, activities, or workplaces are not covered The safety management system applies to all
activities and business processes, namely:
geology, mining, process, maintenance,
laboratory, logistics, purchasing, projects, etc.
Hazard Identification, Risk Assessment, and Incident Investigation
For employees and for workers who are not employees, but whose work and/or workplace is controlled by the organization, report the following:
A description of the processes used to identify work-related hazards and assess risks on a routine and non-routine basis, and to apply the hierarchy of controls in order to eliminate hazards and minimize risks, including: For routine tasks and operations, the
Corporation uses its occupational risk analysis
standard for workstations to identify hazards
and assess risks according to the
FMECA  (Failure mode, effects and criticality
analysis) hazard method. Risk assessments are
conducted as follows:
1- Division of activities.
2- Identification of workstations and associated
tasks.
3-Identification of hazards and associated risks.
4-Assessment and prioritization of risks
according to an evaluation grid
5- Interpretation of the Risk Score
6- Action plan & Operating mode.
For non-routine activities, the company uses
work permits, standards, assesses risks and
applies control measures.
i. How the organization ensures the quality of these processes, including the competency of persons who carry them out The Corporation ensures the quality of the risk
assessment process through its risk assessment
standard, training participants tasked with this
process, incident analysis and periodic updating
of the risk analysis.

The risk assessment is led by a qualified HSE
team.
ii. How the results of these processes are used to evaluate and continually improve the occupational health and safety management system The final product of the risk assessment is in
the form of an action plan in which the actions,
persons responsible and deadlines for
completion are defined. There are also
operating modes relating to the identified
workstations.

The implementation of the action plan is
monitored by the HSE manager in consultation
with department managers.
A description of the processes for workers to report work-related hazards and hazardous situations, and an explanation of how workers are protected against reprisals The Corporation has set up charters for
monthly departmental safety meetings in which
departmental employees participate and which
provide an opportunity to report risky
situations. Additionally, HSE inspections and
interviews are carried out by the HSE team
with employees.

Reporting is also conducted through worker
representatives. Hygiene, health and safety
committee meetings are held quarterly in the
presence of staff representatives to discuss
aspects relating to the health and safety of staff
and working conditions.
A description of the policies and processes for workers to remove themselves from work situations that they believe could cause injury or ill health, and an explanation of how workers are protected against reprisals In 2021, Aya Gold & Silver did not have a formal
process whereby workers could remove
themselves from work situations that they
believed could cause injury or ill health.

The Zgounder Silver Mine Occupational Health
& Safety (OHS) Charter, however, states that
Aya's Gold & Silver managerial team is
responsible for the health & safety of all
employees and must assume exemplary
behavior and leadership.
A description of the processes used to investigate work-related incidents, including the processes to identify hazards and assess risks relating to the incidents, to determine corrective actions using the hierarchy of controls, and to determine improvements needed in the occupational health and safety management system The OHS charter signed by the CEO requires
that all accidents, first aid injuries and  incidents
in relation to the Corporation's activities be
analyzed and communicated, in order to learn
lessons and take steps necessary to avoid their
recurrence.

Aya Gold & Silver has a site-specific standard
for incident Investigation that defines the
requirements and rules relating to the
classification, investigation, analysis and
reporting of accidents.
Health Services
The reporting organization shall report the following information for employees and for workers who are not employees, but whose work and/or workplace is controlled by the organization:
A description of the occupational health services’ functions that contribute to the identification and elimination of hazards and minimization of risks, and an explanation of how the organization ensures the quality of these services and facilitates workers’ access to them The Zgounder Silver Mine's on-site clinic is
equipped for first-aid treatment with health
services provided  by an occupational doctor
and 3 nurses. The clinic is accessible to all on-
site employees who are under
the  Corporation's operational control.
Worker Participation and Communication on Health & Safety
The reporting organization shall report the following information for employees and for workers who are not employees, but whose work and/or workplace is controlled by the organization
A description of the processes for worker participation and consultation in the development, implementation, and evaluation of the occupational health and safety management system, and for providing access to and communicating relevant information on occupational health and safety to workers Worker consultation and participation  in the
health and safety management system is
ensured through monthly safety meetings (SCS,
CGS, CHS) as well as through worker
representatives.
Where formal joint management–worker health and safety committees exist, a description of their responsibilities, meeting frequency, decision-making authority, and whether and, if so, why any workers are not represented by these committees The Zgounder Silver Mine  has the following
worker-management committees:
1- Safety Governance Committee composed of
heads and representatives of  each different
department and workers.
2- Service Safety Sub-Committee composed of
management and workers from each
department.

Both of these committees have the following
objectives.

a. Lead and manage safety within departments;
b. Encourage participation and consult
employees on aspects relating to working
conditions in order to build a preventative
culture at site level;
c. Supervise meetings in order to achieve
OHS&E objectives;
d. Ensure effective communication based on
respect and active listening;
e. Ensure the involvement and participation of
non-managerial employees in the OHS&E
approach;
f. Establish an effective action plan to improve
working conditions, eliminate risky situations
and examine the safety behavior of staff.

3-The Health and safety committee is a legally
required committee that meets quarterly.
Promotion of Worker Health
The reporting organization shall report the following information for employees and for workers who are not employees but whose work and/or workplace is controlled by the organization:
An explanation of how the organization facilitates workers’ access to non-occupational medical and healthcare services, and the scope of access provided Aya Gold & Silver's primary operation, the
Zgounder Silver Mine, is located in the foreign
jurisdiction of Morocco. Zgounder workers are
covered under Morocco's public health
services.
A description of any voluntary health promotion services and programs offered to workers to address major non-work-related health risks, including the specific health risks addressed, and how the organization facilitates workers’ access to these services and programs In 2021, the Corporation did not provide  any
voluntary health promotion services or
programs to workers to address major non-
work-related health risks.
Prevention and Mitigation of Health & Safety Impacts
The reporting organization shall report the following information:
A description of the organization’s approach to preventing or mitigating significant negative occupational health and safety impacts that are directly linked to its operations, products or services by its business relationships, and the related hazards and risks Aya Gold & Silver requires new Zgounder Mine
hires to undergo medical exams to ensure their
fitness for work. Workers performing high-risk
activities are required to complete medical
tests on a quarterly basis.
The reporting organization shall report the following information
If the organization has implemented an occupational health and safety management system based on legal requirements and/or recognized standards/guidelines:
i. The number all workers who are not employees, but whose work and/or workplace is controlled by the organization, who are covered by such H&S system 262
This is an average calculation as the number of
contractors varies from month to month at the
Zgounder Silver Mine.
i. Percentage of all employees and workers who are not employees, but whose work and/or workplace is controlled by the organization, who are covered by such H&S system; 100.0000%
ii. The number of all employees, who are covered by such H&S system that has been internally audited 257
ii. Percentage of all employees and workers who are not employees, but whose work and/or workplace is controlled by the organization, who are covered by such H&S system that has been internally audited; 100.0000%
iii. The number of all employees, who are covered by such H&S system that has been externally audited 0
iii. Percentage of all employees and workers who are not employees, but whose work and/or workplace is controlled by the organization, who are covered by such H&S system that has been externally audited; 0.1927%
Whether and, if so, why any workers have been excluded from this disclosure, including the types of worker excluded No workers have been excluded from this
disclosure.
Any contextual information necessary to understand how the data have been compiled, i.e., any standards, methodologies, and assumptions used The number of all workers who are not
employees, but whose work and/or workplace
is controlled by the organization, is an average
calculation. The number of contractors varies
from month to month at the Zgounder Silver
Mine.
Work-related Injuries
Injuries - For all employees:
i. Number of fatalities as a result of work-related injury 0
i. Rate of fatalities resulting from work-related injury. Note: calculating per 200,000 hours worked 0
ii. Number of high-consequence work-related injuries (excluding fatalities) 2
ii. Rate of high-consequence work-related injuries (excluding fatalities) 0.788
iii. Number of recordable work-related injuries 2
iii. Rate of recordable work-related injuries 0.788
iv. Main types of work-related injury, e.g., confined space, trips, falls, etc. The two high-consequence, work-related
injuries reported in 2021 relate to activities
requiring tool and machines handling, working
at height, and internal circulation.
v. Number of hours worked 507872
Lost Time Injuries (LTIs) 4
Lost Time Injuries Rate (LTIR) 1.575
Injuries - workers who are not employees but whose work and/or workplace is controlled by the organization:
i. Number of fatalities as a result of work-related injury 1
i. Rate of fatalities resulting from work-related injury. Note: calculating per 200,000 hours 0.296
ii. Number of high-consequence work-related injuries (excluding fatalities) 0
ii. Rate of high-consequence work-related injuries (excluding fatalities) 0
iii. Number of recordable work-related injuries 2
iii. Rate of recordable work-related injuries 0.592
iv. Main types of work-related injury, e.g., confined space, trips, falls, etc. The fatality reported in 2021 occurred when a
contract employee was working underground.
No other personnel were injured in the
accident.

Following the accident, Aya Gold & Silver
enacted a series of mitigation measures
including increased awareness of mining
hazards for all workers, review of safety
procedures, recruitment and hiring of a
dedicated underground safety manager and
purchase of a remote-controlled scoop to
prevent this from reoccurring.

The  recordable work injuries included
activities resulting from  tool and machine
handling,  and falling objects.
v. Number of hours worked 675238
Lost Time Injuries (LTIs) 2
Lost Time Injuries Rate (LTIR) 0.592
Combined (Employees and non-employees, but controlled by the organization):
Total Hours Worked 1183110
Total number of all work-related injuries 7
Rate of work-related injuries 1.183
Total Lost Time Injuries (LTIs) 6
Lost Time Injuries Rate (LTIR) 1.014
Report the work-related hazards that pose a risk of high-consequence injury, including:
i. How have these hazards been determined Workplace hazards are determined by
workplace safety inspections, risk analyses, and
incident investigations.
ii. Which of these hazards have caused or contributed to high-consequence injuries during the reporting period In this reporting period, the following hazards
contributed to high-consequence injuries:
1) Falls;
2) Use of mobile equipment;
3) Energy isolation;
4) Falling objects;
5) Working at heights; and
6) Internal circulation.
iii. Actions taken or underway to eliminate these hazards and minimize risks using the hierarchy of controls The following actions were taken to eliminate
these hazards:
1)  Reinforcement of the HSE department by
HSE coordinators;
2) Improvement of collective protective
equipment and infrastructure;
3) Introduction of new technologies meeting
safety requirements for work at the
underground mine;
4) Development and deployment of operational
standards and procedures; and
5) Training and increasing staff awareness.
Report on actions taken or underway to eliminate other work-related hazards and minimize risks using the hierarchy of controls Other hazards and their mitigation programs
are determined and developed through
workplace safety inspections, risk analysis and
incident investigation.
Whether and, if so, why any workers have been excluded from this disclosure, including the types of worker excluded, e.g., short-term contractors No workers have been excluded from this
disclosure.
Disclose any contextual information necessary to understand how the data have been compiled, i.e., any standards, methodologies, and assumptions used Aya Gold & Silver used standards and
methodologies based on ISO 45001 to compile
the data presented in this report.
Work-related Ill-health
The reporting organization shall report the following information
For all employees:
i. The number of fatalities as a result of work-related ill health 0
ii. The number of cases of recordable work-related ill health 0
iii. The main types of work-related ill health Not Applicable
For all workers who are not employees, but whose work and/or workplace is controlled by the organization:
i. The number of fatalities as a result of work-related ill health 0
ii. The number of cases of recordable work-related ill health 0
iii. The main types of work-related ill health Not Applicable
The work-related hazards that pose a risk of ill health, including:
i. How these hazards have been determined Ill health hazards are determined through H&S
risk assessments.
ii. Which of these hazards have caused or contributed to cases of ill health during the reporting period No cases of ill health hazards were recorded in
this reporting period.
iv. Whether and, if so, why any workers have been excluded from this disclosure, including the types of worker excluded No workers under  the operational control of
Aya Gold & Silver at the Zgounder Silver Mine
were excluded from this report.
Workforce Health and Safety
For U.S.-based workforce (full-time employees and contract employees), the entity shall disclose:
For non-U.S.-based workforce (full-time employees and contract employees), the entity shall disclose:
All-Incidence Rate (AIR) for full-time employees based on U.S. Mine Safety and Health Administration (MSHA) Form 7000-1, where incidents include: 272
1. Fatalities, or work-related injuries resulting in death to employees on active mine property - full-time employees 0
2. Nonfatal, Days Lost (NFDL) cases, or occupational injuries that result in loss of one or more days from the entity’s scheduled work or days of limited or restricted activity while at work - full-time employees 661
3. No Days Lost (NDL) cases, or occurrences requiring only medical treatment (beyond first aid); that is, non-fatal injury occurrences resulting only in loss of consciousness or medical treatment other than first aid - full-time employees 31
Fatality rate for full-time employees 0
All-Incidence Rate (AIR) for contract employees based on U.S. Mine Safety and Health Administration (MSHA) Form 7000-1, where incidents include: 0
1. Fatalities, or work-related injuries resulting in death to employees on active mine property - contract employees 1
2. Nonfatal, Days Lost (NFDL) cases, or occupational injuries that result in loss of one or more days from the entity’s scheduled work or days of limited or restricted activity while at work - contract employees 0
3. No Days Lost (NDL) cases, or occurrences requiring only medical treatment (beyond first aid); that is, non-fatal injury occurrences resulting only in loss of consciousness or medical treatment other than first aid - contract employees 0
Fatality rate for contract employees 0
Disclose the near miss frequency rate (NMFR) for work-related near misses - full-time employees:
Full-time employees - number of unplanned incidents in which no property or environmental damage or personal injury occurred, but where damage or personal injury easily could have occurred but for a slight circumstantial shift 13
Contract employees - number of unplanned incidents in which no property or environmental damage or personal injury occurred, but where damage or personal injury easily could have occurred but for a slight circumstantial shift 2
Occupational Health and Safety
Safety Training
Disclose the average number of training hours provided to its workforce for health, safety, and emergency management training.
Average hours of health, safety, and emergency response training for (a) full-time/direct employees: 1.59
Average hours of health, safety, and emergency response training for (b) contract employees: 1.77
Training and Education
Annual Training
Report the average hours of training that the organization’s employees have undertaken during the reporting period
i. By gender:
Average training hours per employee 1.68
Total number of training hours provided to all employees 872
Total number of employees 519
Average training hours per male employee 1.709
Total number of training hours provided to male employees 856
Total number of male employees 501
Average training hours per female employee 0.889
Total number of training hours provided to female employees 16
Total number of female employees 18
Average training hours per non-binary employee 0
Total number of training hours provided to non-binary employees 0
Total number of non-binary employees 0
ii. Report the average training hours of employees by employee category
Senior Management:
Average hours Male 0.889
Average hours Female 0.889
Average hours Non-binary 0
Average hours under 30 years of age 2.182
Average hours between 30 and 50 years of age 0.276
Average hours over 50 years of age 1.6
Salaried (excluding Senior Management):
Average hours Male 0
Average hours Female 0
Average hours Non-binary 0
Average hours under 30 years of age 0
Average hours between 30 and 50 years of age 0
Average hours over 50 years of age 0
Technical Employees (skilled hourly):
Average hours Male 0.558
Average hours Female 2
Average hours Non-binary 0
Average hours under 30 years of age 1.143
Average hours between 30 and 50 years of age 0.571
Average hours over 50 years of age 0
Production Employees (unskilled hourly):
Average hours Male 2.333
Average hours Female 0
Average hours Non-Binary 0
Average hours under 30 years of age 1
Average hours between 30 and 50 years of age 2.851
Average hours over 50 years of age 2.24
Contractors:
Average hours Male 1.771
Average hours Female 0
Average hours Non-Binary 0
Average hours under 30 years of age 1.776
Average hours between 30 and 50 years of age 1.772
Average hours over 50 years of age 1.762
Skills Upgrading Programs
Report the type and scope of programs implemented and assistance provided to upgrade employee skills In 2021, Aya Gold & Silver conducted an
assessment into the need to implement
programs to upgrade employee
skills.  However, due to the scale and speed at
which new employees were being added, it was
decided to postpone the programs to
2022.  The only training programs implemented
in 2021 were related to Health & Safety
procedures.
Report on transition assistance programs provided to facilitate continued employability and the management of career endings resulting from retirement or termination of employment In 2021, Aya Gold & Silver assessed the need to
implement transition assistance programs in
order to facilitate continued
employability.  However, due to the scale and
speed at which new employees were being
added, the Corporation decided to postpone
these programs to 2022.
Performance Reviews
Report the percentage of total employees by gender and by employee category who received a regular performance and career development review during the reporting period
i. By gender:
Percentage of all employees who received a regular performance and career development review during the reporting period 8.6705%
Total number of all employees who received a regular performance and career development review during the reporting period 45
In 2021, Aya Gold & Silver implemented
performance reviews solely for management.
Total number of all employees 519
Percentage of all male employees who received a regular performance and career development review during the reporting period 7.1856%
Total number of all male employees who received a regular performance and career development review during the reporting period 36
Total number of all male employees 501
Percentage of all female employees who received a regular performance and career development review during the reporting period 50.0000%
Total number of all female employees who received a regular performance and career development review during the reporting period 9
Total number of all female employees 18
Percentage of all non-binary employees who received a regular performance and career development review during the reporting period Does Not Apply
Total number of all non-binary employees who received a regular performance and career development review during the reporting period 0
Total number of all non-binary employees 0
Diversity and Equal Opportunity
b. Report the percentage of employees per employee category in each of the following diversity categories
Board of Directors:
Total Board of Directors 7
Percent Male 85.7143%
Percent Female 14.2857%
Percent Non-Binary 0.0000%
No employees at the Zgounder Silver Mine
have self-identified as non-binary.  Aya Gold &
Silver, as part of its Code of Business Ethics and
Conduct, values the diversity of its employees
and is committed to providing equal
opportunity in all aspects of employment.
Percent under 30 years of age 0.0000%
Percent between 30 and 50 years of age 0.0000%
Percent over 50 years of age 100.0000%
Senior Management:
Total Senior Managers 45
Percent Male 80.0000%
Percent Female 20.0000%
Percent Non-Binary 0.0000%
No employees at the Zgounder Silver Mine
have self-identified as non-binary.  Aya Gold &
Silver, as part of its Code of Business Ethics and
Conduct, values the diversity of its employees
and is committed to providing equal
opportunity in all aspects of employment.
Percent under 30 years of age 24.4444%
Percent between 30 and 50 years of age 64.4444%
Percent over 50 years of age 11.1111%
iii. Number of minority or vulnerable groups 0
Salaried (excluding Senior Management):
Total Middle Managers 21
Percent Male 76.1905%
Percent Female 23.8095%
Percent Non-Binary 0.0000%
No employees at the Zgounder Silver Mine
have self-identified as non-binary.  Aya Gold &
Silver, as part of its Code of Business Ethics and
Conduct, values the diversity of its employees
and is committed to providing equal
opportunity in all aspects of employment.
Percent under 30 years of age 33.3333%
Percent between 30 and 50 years of age 52.3810%
Percent over 50 years of age 14.2857%
iii. Number of minority or vulnerable groups 0
Technical Employees (skilled hourly):
Total Technical Employees 47
Percent Male 91.4894%
Percent Female 8.5106%
Percent Non-Binary 0.0000%
No employees at the Zgounder Silver Mine
have self-identified as non-binary.  Aya Gold &
Silver, as part of its Code of Business Ethics and
Conduct, values the diversity of its employees
and is committed to providing equal
opportunity in all aspects of employment.
Percent under 30 years of age 29.7872%
Percent between 30 and 50 years of age 59.5745%
Percent over 50 years of age 10.6383%
iii. Number of minority or vulnerable groups 0
Production Employees (unskilled hourly):
Total Production Employees 144
Percent Male 100.0000%
Percent Female 0.0000%
Percent Non-Binary 0.0000%
No employees at the Zgounder Silver Mine
have self-identified as non-binary. Aya Gold &
Silver, as part of its Code of Business Ethics and
Conduct, values the diversity of its employees
and is committed to providing equal
opportunity in all aspects of employment.
Percent under 30 years of age 22.2222%
Percent between 30 and 50 years of age 60.4167%
Percent over 50 years of age 17.3611%
iii. Number of minority or vulnerable groups 0
Contractors:
Total Contractors 262
Percent Male 100.0000%
Percent Female 0.0000%
Percent Non-Binary 0.0000%
No employees at the Zgounder Silver Mine
have self-identified as non-binary.  Aya Gold &
Silver, as part of its Code of Business Ethics and
Conduct, values the diversity of its employees
and is committed to providing equal
opportunity in all aspects of employment.
Percent under 30 years of age 22.1374%
Percent between 30 and 50 years of age 61.8321%
Percent over 50 years of age 16.0305%
iii. Number of minority or vulnerable groups 0
Salary Ratio Between Genders
Report the ratio of the basic salary and remuneration of women to men for each employee category, by significant locations of operation
Senior Management:
Ratio Salary Male to Female 1.272
Ratio Salary Female to Male 0.786
Ratio Salary Non-Binary to Male 0
No employees at the Zgounder Silver Mine
have self-identified as non-binary.  Aya Gold &
Silver, as part of its Code of Business Ethics and
Conduct, values the diversity of its employees
and is committed to providing equal
opportunity in all aspects of employment.
Ratio Salary Non-Binary to Female 0
No employees at the Zgounder Silver Mine
have self-identified as non-binary. Aya Gold &
Silver, as part of its Code of Business Ethics and
Conduct, values the diversity of its employees
and is committed to providing equal
opportunity in all aspects of employment.
Ratio Salary Female to Male under 30 years of age 0.782
Ratio Salary Female to Male between 30 and 50 years of age 1.131
Ratio Salary Female to Male over 50 years of age 0
Salaried (excluding Senior Management):
Ratio Salary Male to Female 0.946
Ratio Salary Female to Male 1.057
Ratio Salary Non-Binary to Male 0
No employees at the Zgounder Silver Mine
have self-identified as non-binary.  Aya Gold &
Silver, as part of its Code of Business Ethics and
Conduct, values the diversity of its employees
and is committed to providing equal
opportunity in all aspects of employment.
Ratio Salary Non-Binary to Female 0
No employees at the Zgounder Silver Mine
have self-identified as non-binary.  Aya Gold &
Silver, as part of its Code of Business Ethics and
Conduct, values the diversity of its employees
and is committed to providing equal
opportunity in all aspects of employment.
Ratio Salary Female to Male under 30 years of age 1.206
Ratio Salary Female to Male between 30 and 50 years of age 1.305
Ratio Salary Female to Male over 50 years of age 0
Technical Employees (skilled hourly):
Ratio Salary Male to Female 0.907
Ratio Salary Female to Male 1.102
Ratio Salary Non-Binary to Male 0
No employees at the Zgounder Silver Mine
have self-identified as non-binary.  Aya Gold &
Silver, as part of its Code of Business Ethics and
Conduct, values the diversity of its employees
and is committed to providing equal
opportunity in all aspects of employment.
Ratio Salary Non-Binary to Female 0
No employees at the Zgounder Silver Mine
have self-identified as non-binary.  Aya Gold &
Silver, as part of its Code of Business Ethics and
Conduct, values the diversity of its employees
and is committed to providing equal
opportunity in all aspects of employment.
Ratio Salary Female to Male under 30 years of age 1.257
Ratio Salary Female to Male between 30 and 50 years of age 1
Ratio Salary Female to Male over 50 years of age 1
Production Employees (unskilled hourly):
Ratio Salary Male to Female 0
Ratio Salary Female to Male 0
Ratio Salary Non-Binary to Male 0
No employees at the Zgounder Silver Mine
have self-identified as non-binary.  Aya Gold &
Silver, as part of its Code of Business Ethics and
Conduct, values the diversity of its employees
and is committed to providing equal
opportunity in all aspects of employment.
Ratio Salary Non-Binary to Female 0
No employees at the Zgounder Silver Mine
have self-identified as non-binary.  Aya Gold &
Silver, as part of its Code of Business Ethics and
Conduct, values the diversity of its employees
and is committed to providing equal
opportunity in all aspects of employment.
Ratio Salary Female to Male under 30 years of age 0
Ratio Salary Female to Male between 30 and 50 years of age 0
Ratio Salary Female to Male over 50 years of age 0
Contractors:
Ratio Salary Male to Female 0
Ratio Salary Female to Male 0
Ratio Salary Non-Binary to Male 0
No employees at the Zgounder Silver Mine
have self-identified as non-binary.  Aya Gold &
Silver, as part of its Code of Business Ethics and
Conduct, values the diversity of its employees
and is committed to providing equal
opportunity in all aspects of employment.
Ratio Salary Non-Binary to Female 0
No employees at the Zgounder Silver Mine
have self-identified as non-binary. Aya Gold &
Silver, as part of its Code of Business Ethics and
Conduct, values the diversity of its employees
and is committed to providing equal
opportunity in all aspects of employment.
Ratio Salary Female to Male under 30 years of age 1
Ratio Salary Female to Male between 30 and 50 years of age 0
Ratio Salary Female to Male over 50 years of age 0
Non-Discrimination
Incidents and Corrective Action
Total number of incidents of discrimination during the reporting period: 0
Race 0
Colour 0
Gender 0
Religion 0
Political Opinion 0
National Extraction (place of birth) 0
Social Origin (social class /social caste) 0
Age 0
Disability 0
Migrant Status (foreign birth, foreign citizenship, moving temporarily into a new country) 0
HIV/AIDS 0
Sexual Orientation (LGBTQQIP2SAA stands for lesbian, gay, bisexual, transgender, questioning, queer, intersex, pansexual, two-spirit (2S), androgynous and asexual. Two-spirit is term used by some indigenous North Americans to describe those who fulfil a traditional third-gender ceremonial role). 0
Genetic Predisposition (an increased likelihood of developing a particular disease based on a person's genetic makeup) 0
Lifestyle (healthy diet, not smoking, minimizing alcohol use) 0
Report the status of the incidents and actions taken with reference to the following:
i. Incident reviewed by the organization In 2021, Aya Gold & Silver did not record
any  incidents or corrective actions with regard
to non-discrimination across its operations.
Child Labour
Operations and Suppliers At Risk
The reporting organization shall report the following information
Disclose operations and suppliers considered to have significant risk for incidents of:
i. Child labour In 2021, child labour was not considered a risk
at the Zgounder Silver Mine.
ii. Young workers exposed to hazardous work In 2021, young workers were not exposed to
hazardous work as child labour is not
considered a risk at the Zgounder Silver Mine.
Disclose operations and suppliers considered to have significant risk for incidents of child labour either in terms of:
i. Type of operation (i.e., manufacturing plant) and supplier In 2021, neither Zgounder Silver Mine
operations nor its suppliers were considered to
be significant risks for incidents of child labour.
Forced or Compulsory Labour
Operations and Suppliers At Risk
The reporting organization shall report the following information .
Disclose operations and suppliers considered to have significant risk for incidents of forced or compulsory labor either in terms of:
i. Type of operation (i.e., manufacturing plant) and supplier In 2021, forced or compulsory labour was not
considered a risk at the Zgounder Silver Mine.
Security, Human Rights and Rights of Indigenous People
Identify the countries of operations within the World Bank's list of “Fragile and Conflict-Affected Situations” None
Describe the nature of any social risks, for all operating countries, that could have a material risk to operations In 2021, social risks were not considered
significant at the Zgounder Silver Mine.
Percentage of proved reserves that are located in or near areas of active conflict: 0.0000%
The total amount of proved reserves 28700
Proven reserves in tonnes.
Grade of proved reserves located in or near areas of active conflict As per the Uppsala Conflict Data Program, the
Zgounder Silver Mine does not operate in or
near an area of active conflict.
Percentage of probable reserves that are located in or near areas of active conflict: 0.0000%
The total amount of probable reserves 42100
Probable reserves provided in ounces.
Grade of probable reserves locate in or near areas of active conflict As per the Uppsala Conflict Data Program, the
Zgounder Silver Mine does not operate in or
near areas of active conflict.
Percentage of inferred, indicated and measured reserves that are located in or near areas of active conflict: 0.0000%
Total amount of inferred, indicated and/or measured reserves 102447
Percentage of proved reserves that are located in or near areas that are considered to be indigenous peoples’ land: 0.0000%
The total amount of proved reserves 28700
Grade of proved reserves locate in or near areas that are considered to be indigenous peoples’ land The Zgounder Silver Mine does not operate in
or near areas that are considered to be
indigenous peoples' land.
Percentage of probable reserves that are located in or near areas that are considered to be indigenous peoples’ land: 0.0000%
The total amount of probable reserves 42100
Grade of probable reserves locate in or near areas that are considered to be indigenous peoples’ land The Zgounder Silver Mine does not operate in
or near areas that are considered to be
indigenous peoples' land.
Percentage of inferred, indicated and measured reserves that are located in or near areas that are considered to be indigenous peoples’ land: 0.0000%
Total amount of inferred, indicated and measured reserves 102447
Describe due diligence practices and procedures with respect to indigenous rights of communities in which it operates or intends to operate The Zgounder Silver Mine does not operate in
or near areas that are considered to be
indigenous peoples' land.
Describe its due diligence practices and procedures with respect to human rights Aya Gold & Silver has not conducted a
complete human rights due diligence exercise
for the Zgounder Silver Mine. However, the
Corporation has identified and remediated its
risks. For example, Aya Gold & Silver requested
clarification of land tenure from authorities in
the Kingdom of Morocco to ensure this right
was respected. The Corporation will evaluate
the need for further due diligence in human
rights in the future.
Human Rights
Indigenous Rights
The reporting entity shall disclose:
Report the number of sites on or adjacent to indigenous territories 0
Rights of Indigenous Peoples
Incidents of Violations
Report the total number of identified incidents of violations involving the rights of indigenous peoples during the reporting period 0
Human Rights Assessment
Operations Reviews and Assessments
Report the total number and percentage of operations that have been subject to human rights reviews or human rights impact assessments, by country:
Report the total number of operations that have been subject to human rights reviews or human rights impact assessments 0
Report the total percentage of operations that have been subject to human rights reviews or human rights impact assessments, by country 0.0000%
Employee Training on Human Rights Policies
Report the total number of hours and percentage in the reporting period devoted to training on human rights policies or procedures concerning aspects of human rights that are relevant to operations:
Report the total number of hours in the reporting period devoted to training on human rights policies or procedures concerning aspects of human rights that are relevant to operations 0
Report the percentage of employees trained during the reporting period in human rights policies or procedures concerning aspects of human rights that are relevant to operations 0.0000%
Contracts and Agreements
Report the total number and percentage of significant investment agreements and contracts that include human rights clauses or that underwent human rights screening:
Number of agreements that include human rights clauses or underwent human rights screening 0
Local Communities
Operations with Local Community
Report the percentage of operations with implemented local community engagement, impact assessments, and/or development programs:
Percentage of operations with social impact assessments, including gender impact assessments, based on participatory processes 100.0000%
Has (Have) the operation(s) incuded the use of the following:
i. Social impact assessments, including gender impact assessments, based on participatory processes; Yes
ii. Environmental impact assessments and ongoing monitoring Yes
iii. Public disclosure of results of environmental and social impact assessments Yes
iv. Local community development programs based on local communities’ needs Yes
v. Stakeholder engagement plans based on stakeholder mapping Yes
vi. Broad based local community consultation committees and processes that include vulnerable groups Yes
vii. Works councils, occupational health and safety committees and other worker representation bodies to deal with impacts Yes
viii. Formal local community grievance processes Yes
Significant disputes relating to land use, customary rights of local communities and indigenous peoples The status of the land where the Zgounder
Silver Mine is located was not clearly defined in
the past. However, recently the Moroccan state
declared this land as land collectively owned by
local villages. More than 40% of Morocco’s land
is held collectively by villages. The State via the
Ministry of Interior is the trustee of collectively
owned land.
To avoid confusion, Aya Gold & Silver
approached the Ministry of Interior to clarify
the land tenure status of the mine. After a due
process that included consultation with village
representatives conducted by the government,
without the Corporation's participation or
influence, on March 2, 2022, the Ministry of
Interior invited Aya Gold & Silver to sign a lease
agreement with the government for the
required land use. The agreement, which is for
9 years, allows for indefinite renewals provided
the Corporation gives the government a 6-
month prior notice of intent to renew.
Number of significant disputes relating to land use, customary rights of local communities and indigenous peoples 1
Description of significant disputes relating to land use, customary rights of local communities and indigenous peoples The status of the land where the Zgounder
Silver Mine is located was not clearly defined in
the past.  However, recently the Moroccan
state declared this land as collective land
owned by  local villages. More than 40% of
Morocco’s land is held collectively. The State
via the Ministry of Interior is the trustee of
collectively owned  land.
The extent to which grievance mechanisms were used to resolve disputes relating to land use, customary rights of local communities and indigenous peoples, and the outcomes In observance of customary decision-making
processes, Aya Gold & Silver's grievance
mechanism has been established in
collaboration with local authorities.
As per this process, local authorities receive
grievances and forward them to the
Corporation. The community relations team at
the Zgounder Silver Mine, in conjunction with
local authorities, investigate the grievance and
resolve as required. In addition, local
authorities can set up independent, ad hoc
dispute-resolution committees to investigate
the grievance and provide a response and
resolution.
Operations With Negative Impacts
Report operations with significant actual and potential negative impacts on local communities, including:
i. Identify the location of the operations Morocco
ii. List the factors that could cause significant actual and potential negative impacts to local communities and provide details about vulnerabilities and risks to the communities from these factors, including intensity, likely duration, reversibility and scale of impact.
   •  Physical or economic isolation of the local
community
   •  Use of hazardous substances that impact
the environment and human health in general,
and specifically impact reproductive health
   •  Natural resource consumption
The Zgounder Silver Mine utilizes hazardous
substances in its processing plant, requires
water consumption, and is the major employer
in the region. All of the impacts described are
reversible and have a low to medium impact.

Aya Gold & Silver has implemented controls
and safeguards for hazardous material
transportation and management. The company
is monitoring its water usage and consumption,
and has made efforts to employ as many
workers from local communities. In 2021, 45%
of the Zgounder Silver Mine workforce resided
in local villages. Only 1% of the mine's
workforce are expats.
Community Relations
Artisanal and Small-Scale Mining
Number of company operating sites where artisanal and small-scale mining (ASM) takes place on, or adjacent to, the site (not controlled by company/unauthorized): 0
Percentage of company operating sites where artisanal and small-scale mining (ASM) takes place on, or adjacent to, the site Does Not Apply
Programs
Report on community relations programs, objectives and achievements in the past 3 years Aya Gold & Silver aims to share the benefits of
responsible mining and ensure that we leave
positive  socio-economic and environmental
legacies in the areas in which we operate.
In addition to local procurement and local
employment, the Corporation's CSR plan is
expected to help build mutually beneficial
relationships between the Aya Gold & Silver
and its local stakeholders by contributing to
long-term improvements in the quality of life of
local communities, and helping to create an
environment conducive to private
investment.  At the Zgounder Silver Mine, the
Corporation is concentrating its efforts and its
development strategy on  income-generating
activities (IGAs), education, health, and access
to water.
Discuss the processes, procedures, and practices to manage risks and opportunities associated with the rights and interests of communities in areas where it conducts business National legislation in Morocco does not
require a CSR strategy or community
development.

However, Aya Gold & Silver strives to comply
with international best practices, such as
International Finance Corporation (IFC)
guidelines. In the spirit of best practices, the
Corporation has developed a framework of
collaboration with local authorities.
This framework includes the following
methodology:
i. Choice of projects
CSR projects will be chosen according to the
following criteria:
Aligned with the strategic axes defined by the
Corporation;
Aligned with the strategic axes of Morocco
defined by the INDH;
Aligned with the recommendations of the
Environmental and Social Impact Assessment
of the Zgounder Silver Mine expansion project.

ii. Consultation
The Corporation will undertake consultations
with the relevant delegations and institutions
for each project developed.

iii. Communication and reporting
The Corporation will communicate its CSR
strategy, program development and execution
performance monitoring with local authorities
on a quarterly basis.

An annual report will be produced summarizing
the actions carried out by Aya Gold & Silver.
Risks
The entity shall discuss its processes, procedures, and practices to manage risks and opportunities associated with the rights and interests of communities in areas where it conducts business, where community rights and interests include: Aya Gold & Silver's CSR strategy aims to be a
vehicle for sharing the benefits of responsible
mining and ensuring a legacy of positive socio-
economic and environmental impact in the
areas in which we operate. In addition to local
procurement and local employment, the plan is
expected to help build mutually beneficial
relationships between the Corporation and its
local stakeholders, bringing about long-term
improvement in the quality of life of local
communities. and helping create an
environment conducive to private investment.
Aya Gold & Silver wishes to concentrate its
efforts and its development strategy on the
areas of income-generating activities (IGAs),
education, health, and access to water.
Economic rights and interests, including, but not limited to, employment, fair wages, payment transparency, national resource governance, and respect of infrastructure and agricultural land. Aya Gold & Silver respects and abides by the
Kingdom of Morocco's national legislation on
labour as follows:
1) Code du Travail (loi n°65-99)
2) Dahir n° 1-60-007 du 5 rejeb 1380 (24
décembre1960) portant statut du personnel
des entreprises minières.
Environmental rights and interests, including, but not limited to clean local air and water, as well as safe discharge and disposal of waste. An Environmental and Social Impact
Assessment was conducted in 2021 in order to
update the environmental and social baselines
and assess potential impacts. The result is an
Environmental and Social Management Plan
that  provides mitigation and control measures
to protect the environment and social rights
and interests.
During the ESIA process, water, air emissions
(dust) and hazardous materials were identified
as potential risks to the environment. Aya Gold
& Silver has developed mitigation controls and
management plans for these potential impacts.
Social rights and interests, including, but not limited to adequate health care, education, and housing. An Environmental and Social Impact
Assessment was conducted in 2021 in order to
update the environmental and social baselines
and assess potential impacts. The result is an
Environmental and Social Management Plan
that  provides mitigation and control measures
to protect the environment and social rights
and interests.
The ESIA-updated analysis identified
community health and safety in addition to
local employment and economic opportunities
as potential social risks and interests. Aya Gold
& Silver is aligning its environmental-social
management plans to the results from its
extensive consultation process with villages
through their local authorities.
Cultural rights and interests, including, but not limited to protection of places of cultural significance (e.g., sacred sites or burial sites). Sacred sites are managed by the Ministry of
Interior in the Kingdom of Morocco. No sacred
sites have been identified in the project
footprint of the Zgounder Silver Mine.
The entity shall disclose the following, where relevant:
Lifecycle stages to which its practices apply
   •  Mineral production
   •  During closure
   •  Decommissioning and restoration
The community rights and interests (enumerated above) specifically addressed by the practices. Aya Gold & Silver is concentrating its efforts on
managing two primary rights and interests:
1) Community health and safety and;
2) Local employment and economic
opportunities.
The underlying references for its procedures, including whether they are codes, guidelines, standards, or regulations and whether they were developed by the entity, an industry organization, a third-party organization (e.g., a non-governmental organization), a governmental agency, or some combination of these groups. Aya Gold & Silver develops and implements its
procedures internally based on the experience
of its HSEC managers and IFC Performance
Standards.
These procedures reference  IFC and ICMM
guidelines and documentation.
Risks associated with community relations include: Other, please specify
Aya Gold & Silver monitors and closely
manages its water withdrawal and usage to
avoid potential impacts derived from the use of
this shared resource. In 2021, as a result of the
ESIA, the Corporation improved the water
efficiency plans for its expanded mine and
processing plant project to avoid consuming
additional shared resources.
Opportunities
The entity shall discuss its processes, procedures, and practices to manage risks and opportunities associated with the rights and interests of communities in areas where it conducts business, where community rights and interests include: National legislation in Morocco does not
require a CSR strategy or community
development. However, in addition to local
procurement and local employment, the
Corporation's CSR plan is expected to help
build mutually beneficial relationships between
the Aya Gold & Silver and its local stakeholders
by contributing to long-term improvements in
the quality of life of local communities, and
helping to create an environment conducive to
private investment.

Please refer to the attached document.
Community Relations: Processes, Procedures and Practices
Economic rights and interests, including, but not limited to, employment, fair wages, payment transparency, national resource governance, and respect of infrastructure and agricultural land. Aya Gold & Silver respects and abides by the
Kingdom of Morocco's national legislation on
labour as follows:
1) Code du Travail (loi n°65-99)
2) Dahir n° 1-60-007 du 5 rejeb 1380 (24
décembre1960) portant statut du personnel
des entreprises minières
Environmental rights and interests, including, but not limited to clean local air and water, as well as safe discharge and disposal of waste. An Environmental and Social Impact
Assessment was conducted in 2021 in order to
update Aya Gold & Silver's knowledge of the
environmental and social baseline and  to
assess potential impacts.
The result is an Environmental and Social
Management Plan that is designed to provide
mitigation and control measures to protect
environment and social rights and interests.
Social rights and interests, including, but not limited to adequate health care, education, and housing. An Environmental and Social Impact
Assessment was conducted in 2021 in order to
update the Corporation's knowledge of the
environmental and social baseline and assess
potential impacts. The result is an
Environmental and Social Management Plan
that is designed to provide mitigation and
control measures to protect environment and
social rights and interests.
Cultural rights and interests, including, but not limited to protection of places of cultural significance (e.g., sacred sites or burial sites). Sacred sites are managed by the Ministry of
Interior in the Kingdom of Morocco. No sacred
sites have been identified in the project
footprint of the Zgounder Silver Mine.
The entity shall disclose the following, where relevant:
Lifecycle stages to which its practices apply
   •  Mineral production
   •  During closure
   •  Decommissioning and restoration
The community rights and interests (enumerated above) specifically addressed by the practices. The Environmental and Social Management
Plans that resulted from the 2021 ESIA for the
Zgounder Silver Mine expansion project
include the following rights and interests:
1) Economic rights and interests, including, but
not limited to employment, fair wages, payment
transparency, national resource governance,
and respect of infrastructure and agricultural
land.
2) Environmental rights and interests,
including, but not limited to clean local air and
water, as well as safe discharge and disposal of
waste.
3) Social rights and interests, including, but not
limited to adequate job creation, health care,
education, and housing.
The underlying references for its procedures, including whether they are codes, guidelines, standards, or regulations and whether they were developed by the entity, an industry organization, a third-party organization (e.g., a non-governmental organization), a governmental agency, or some combination of these groups. Aya Gold & Silver develops and implements its
procedures internally based on the experience
with its HSEC management and IFC
Performance Standards.
The underlying references for its procedures
are aligned with IFC and ICMM available
guidelines and documentation.
Opportunities associated with community relations include: Other, please specify
At the Zgounder Silver Mine, Aya Gold & Silver
has implemented local recruitment programs
that have resulted in a 45% local workforce.
The Corporation has also signed a collaboration
agreement with local authorities to foster
programs that will increase economic
opportunities for villages and promote
programs that allow villages to prepare for
emergencies within their communities.
Risks and Opportunities
Disclose the degree to which its policies and practices are aligned with the International Finance Corporation’s (IFC) Performance Standards on Environmental and Social Sustainability, January 1, 2012, including specifically:
Performance Standard 4 — Community Health, Safety, and Security The breadth, depth, and type of analysis is
proportionate to the nature and scale of the
proposed project’s risks to and potential
impacts on the health and safety of the local
community
Performance Standard 5 — Land Acquisition and Involuntary Resettlement 100% aligned
Performance Standard 8 — Cultural Heritage 100% aligned
The discussion shall include how practices apply to business partners, i.e., contractors, sub-contractors, suppliers, and joint venture partners Aya Gold & Silver's HSEC policy and corporate
standards are shared with suppliers, as well as
the Zgounder Silver Mine's Environmental and
Social Management Plan that is included in the
2022 ESIA.

In the future, and specifically as per the
Zgounder Silver Mine Expansion Project, Aya
will develop a Health & Safety, Environment
and Community (HSEC) Management Plan to
be shared with all contractors and suppliers
involved in the construction of the Project. The
HSEC Management Plan will summarize and
cite all of Aya's existing applicable practices
and will be shared during the tendering
process. The HSEC Management Plan, along all
other management plans related to the
Project's construction, will serve
as contractual obligations.
Cyanide providers are all registered with the
International Cyanide Management Code. The
ESMP and ESIA will be shared with suppliers
for the Zgounder Silver Mine expansion project
as well.
Describe efforts to eliminate or mitigate community risks and/or address community concerns:
The use of Social Impact Assessment (SIA) that evaluates, manages, and mitigates risks Yes
Efforts to engage with stakeholders, build consensus, and collaborate with communities Yes
“Shared” or “blended” value projects that provide quantifiable benefits to the community and the entity Yes
7.2.1 Discuss how the site risks differ and manifest themselves from country (national), regional (state), community (local) levels, and project levels Water is the Zgounder Silver Mine's primary
risk. In terms of ESG, this risk is shared with
local villages and the Kingdom of Morocco.
7.2.2 Sites that are affected by Sovereign Risk (defined as the potential for a central bank or government-backed entity to willingly or unwillingly default on debt obligations, or significantly alter key economic variables, i.e., currency exchange rates, import ratios, and money supply):
Site 1 No
7.3 The organization should identify and describe country risks specific to its projects and unique operating context
7.2 and 7.3.1 The organization will include the identification of country, regional, community and site risks and/or the discussion of specific projects:
Risks General license to operate
7.3.2 Discuss how the entity has mitigated these risks (e.g., through community engagement partnerships, and blended value projects); the entity shall quantify this reduction in risk according to the methods described above (reduction in Value at Risk):
Risk Mitigation In addition to its ESIA management for risk
identification and mitigation, Aya Gold & Silver
has developed social management processes
and procedures aligned with international best
practices and local customs. These have
generated efficient procedures for dispute
resolutions and alliances for social investment
that can potentially outlast the life of mine.
7.3.3 The organization will disclose the country risk classification applied
Disclose the total number of site shutdowns or project delays due to non-technical factors. 0
Disclose the total aggregate duration (in days) of site shutdowns or project delays due to non-technical factors. 0
Resettlement
Have there been community resettlements in order to accommodate business activities and if so, please provide details about the specific sites. No
The Zgounder Silver Mine did not require any
village resettlement. Economic displacement
was compensated after a thorough due
diligence conducted by Aya Gold & Silver
through the ESIA and the Moroccan Ministry of
Interior. The Corporation signed an economic
compensation agreement with the Ministry of
the Interior and has also signed an agreement
of collaboration with local authorities to
promote economic development in villages
affected by the economic displacement.
Economic Performance
Economic Value
The reporting organization shall report the following information. When compiling the information specified in Disclosure 201-1, the reporting organization shall, if applicable, compile the EVG&D from data in the organization’s audited financial or profit and loss (P&L) statement, or its internally audited management accounts
Direct economic value generated and distributed (EVG&D) on an accruals basis, including the basic components for the organization’s global operations as listed below. If data are presented on a cash basis, report the justification for this decision in addition to reporting the following basic components
i. Direct Economic Value Generated (EVG): Revenues ($ Millions) 34301914
ii. Economic Value Distributed (EVD or D): operating costs, employee wages and benefits payments to providers of capital, payments to government by country, and community investments (expenses) ($ Millions) 31629315
Operating Costs ($ Millions) 26675908
Employee wages ($ Millions) 1747006
Benefits payments to providers of capital ($ Millions) 0
Payments to government by country ($ Millions) 3021411
Payments made to Moroccan government -
2,516,478
Payments made to Mauritanian government -
504,933
Community investments (expenses) ($ Millions) 184990
iii. Economic value retained ($ Millions): 2672599
Direct economic value generated ($ Millions) 34301914
Economic distributed ($ Millions) 31629315
Economic Value Generated and Distributed
Report countries of operation that are either candidate to or compliant with the Extractive Industries Transparency Initiative (EITI). Not Applicable
For this purpose of this report, Aya Gold &
Silver is only disclosing information on its
Zgounder Silver Mine located in the Kingdom
of Morocco. The host government is not an EITI
signatory.
Financial Implications
The reporting organization shall report the following information
Risk 1 - Risks posed by climate change that have the potential to generate substantive changes in operations, revenue, or expenditure, including:
i. A description of the risk and its classification as either physical, regulatory, or other Direct Short-term Physical - changes in sea
level, ambient temperature, and water
availability
ii. A description of the impact associated with the risk Increased capital and operational costs
iii. The financial implications of the risk before action is taken ($ Millions) 0
iv. The methods used to manage the risk Other, please specify
As part of its corporate risk management
system, Aya Gold & Silver has invested in
infrastructure to capture and store water
during the rainy season in order to offset
potential loss due to an extended or excessively
dry season at the Zgounder Silver Mine.
v. The costs of actions taken to manage the risk ($ Millions). Note: if the reporting organization does not have a system in place to calculate the financial implications or costs, or to make revenue projections, it shall report its plans and timeline to develop the necessary systems to do so. 0
Benefit and Retirement Plans
The reporting organization shall report the following information
If the plan’s liabilities are met by the organization’s general resources, the estimated value of those liabilities 0
Aya Gold & Silver is subscribed to a retirement
plan in which the employee and the
Corporation contribute on a monthly basis in
order towards the employee's retirement.
If a separate fund exists to pay the plan’s pension liabilities:
i. The extent to which the scheme’s liabilities are estimated to be covered by the assets that have been set aside to meet them Pensions are managed by a pension fund
belonging to an external organization.
ii. The basis on which that estimate has been arrived at Contributions are a percentage of salary.
iii. When that estimate was made 2021-01-01
Percentage of salary contributed by the organization (employer) 9.0514%
Level of participation, as a percentage, in retirement plans:
Voluntary schemes (%) 98
Mandatory schemes (%) 100
Regional, country-based schemes, or other - please specify. 0
Government Financial Assistance
The reporting organization shall report the following information by country:
Total monetary value of financial assistance received by the organization from any government during the reporting period, including ($ Millions): 0
i. Tax relief and tax credits 0
ii. Subsidies 0
iii. Investment grants, research and development grants, and other relevant types of grant 0
iv. Awards; 0
v. Royalty holidays 0
vi. Financial assistance from Export Credit Agencies (ECAs) 0
vii. Financial incentives 0
1) Corporate tax rate is capped at 20%
applicable to exporting (and mining) companies,
instead of 31% according to the normal scale.
2) Suspensive regime for exporting companies
according to which the company can make
certain local purchases previously authorized,
without VAT.
viii. Other financial benefits received or receivable from any government for any operation 0
Whether, and the extent to which, any government is present in the shareholding structure Through ONHYM (Office National des
Hydrocarbures et des Mines), the Moroccan
government holds 15% of the capital of ZMSM
and BGM.
Market Presence
Wage Ratios in the Market
The reporting organization shall report the following information
When most employees are compensated subject to minimum wage rules, report the ratio of the entry level wage by gender at significant locations of operation to the minimum wage
Site 1- Male: 1
Site 1 - Female: 1
Site 1 - Non-binary: 0
No employees at the Zgounder Silver Mine
have self-identified as non-binary. Aya Gold &
Silver as part of its Code of Business Ethics and
Conduct values the diversity of our employees
and is committed to providing equal
opportunity in all aspects of employment.
If a local minimum wage is absent or variable, reference which minimum wage is being used (by gender):
Male Not Applicable
Female Not Applicable
Non-binary Not Applicable
The definition used for ‘significant locations of operation’ In this report, Aya Gold & Silver is only
disclosing information relative to its Zgounder
Silver Mine.
Management Representation
The reporting organization shall report the following information
Percentage of senior management at significant locations of operation that are hired from the local community: 0.0000%
The definition used for ‘senior management’ People who have decision-making powers and
who are experts in their field of activity.
The organization’s geographical definition of ‘local’ Local refers to the immediate villages around
the mine, within an approximate50km radius.
The definition used for ‘significant locations of operation’ Morocco
In significant locations of operation, report proportion (percentage) of the facility’s total workforce from the local community. 45.1362%
Indirect Economic Impacts
Infrastructure Investments and Services Supported
The reporting organization shall report the following information:
Extent of development of significant infrastructure investments and services supported In 2021, through its collaboration agreement
with local authorities, the Corporation
provided in-kind assistance to help refurbish
local roads.
Current or expected impacts on communities and local economies, including positive impacts where relevant The aid provided in 2021 improved transit
between villages.
Types of investments In-Kind
Significant Indirect Economic Impacts
The reporting organization shall report the following information:
Examples of significant positive indirect economic impacts of the organization
   •  Economic development in areas of high
poverty (such as changes in the total number of
dependents supported through the income of a
single job)
   •  Economic impacts of improving or
deteriorating social or environmental
conditions (such as changing job market in an
area converted from small farms to large
plantations, or the economic impacts of
pollution)
   •  Availability of products and services for
those on low incomes (such as preferential
pricing of pharmaceuticals, which contributes
to a healthier population that can participate
more fully in the economy, or pricing structures
that exceed the economic capacity of those on
low incomes)
   •  Enhanced skills and knowledge in a
professional community or in a geographic
location (such as when shifts in an organization’
s needs attract additional skilled workers to an
area, who, in turn, drive a local need for new
learning institutions)
   •  Number of jobs supported in the supply or
distribution chain (such as the employment
impacts on suppliers as a result of an
organization’s growth or contraction)
   •  Economic impacts from the use of products
and services (such as economic growth
resulting from the use of a particular product or
service)
Examples of significant negative indirect economic impacts of the organization Economic impacts from the use of products and
services (such as economic growth resulting
from the use of a particular product or service)
Significance of the indirect economic impacts in the context of external benchmarks and stakeholder priorities, i.e., national and international standards, protocols, and policy agendas The positive indirect economic impacts of the
presence of the Zgounder Silver Mine align
with local and national interests for economic
stimulation.
Aya Gold & Silver is monitoring the potential
increase in indirect local economic demands to
determine the potential level of impact on
increased costs of goods and services as a
result of market demand.
Procurement Practices
Local Spending
a. Report the percentage of the procurement budget used for significant locations of operation that is spent on suppliers local to that operation (i.e., percentage of products and services purchased locally): 15.9052%
Supplier Assessment
Suppliers Screened Using Social Criteria
Report the percentage of new suppliers that were screened using social criteria: 0.0000%
Negative Social Impacts in the Supply Chain
Number of suppliers assessed for social impacts 0
Number of suppliers identified as having significant actual and potential negative social impacts 0
List of significant actual and potential negative social impacts identified in the supply chain
   •  No harsh and inhumane treatment
including any sexual harassment, sexual abuse,
corporal punishment, mental or physical
coercion or verbal abuse of workers, or threat
of such treatment
   •  Potential for exposure to safety hazards
are to be identified and assessed
   •  Potential emergency situations and events
are to be identified and assessed
   •  Procedures and systems are to be in place
to prevent, manage, track and report
occupational injury and illness
   •  Worker exposure to chemical, biological
and physical agents is to be identified,
evaluated, and controlled according to the
hierarchy of controls
   •  Exposure to the hazards of physically
demanding tasks
   •  Production and other machinery shall be
evaluated for safety hazards
   •  Workers are to be provided with ready
access to clean toilet facilities, potable water
and sanitary food preparation, storage, and
eating facilities
   •  Provide workers with appropriate
workplace health and safety information and
training in the language of the worker or in a
language the worker can understand for all
identified workplace hazards that workers are
exposed to
   •  All required environmental permits
approvals and registrations are to be obtained,
maintained and kept
   •  Emissions and discharges of pollutants and
generation of waste are to be minimized or
eliminated at the source
   •  Chemicals and other materials posing a
hazard to humans or the environment are to be
identified, labelled and managed
   •  Implement a systematic approach to
identify, manage, reduce, and responsibly
dispose of or recycle solid waste (non-
hazardous)
   •  Adhere to all applicable laws, regulations
and customer requirements regarding
prohibition or restriction of specific substances
   •  implement a water management program
that documents, characterizes, and monitors
water sources, use and discharge
   •  Highest standards of integrity are to be
upheld in all business interactions
   •  Bribes or improper advantage prohibited
   •  Business dealings should be transparently
performed and accurately reflected
   •  Ensure the confidentiality, anonymity and
protection of supplier and employee
whistleblowers
   •  Commitment to compliance and continual
improvement
   •  Senior management reviews the status of
the management system on a regular basis
   •  Process to identify, monitor and
understand applicable laws, regulations and
customer requirements
   •  Process to identify the legal compliance,
environmental, health and safety and labor
practice and ethics risks associated with
operations
   •  Effective grievance mechanism, to assess
employees’ understanding of and obtain
feedback
   •  Process for timely correction of
deficiencies identified by internal or external
assessments
   •  Creation and maintenance of documents
and records to ensure regulatory compliance
   •  Process to communicate conduct code
requirements to suppliers and monitor
compliance
Locations of suppliers Morocco
In 2021, all of Aya Gold & Silver's contractors
for the Zgounder Silver mine were located in
the Kingdom of Morocco. Highly specialized
goods and services may also be purchased from
other locations worldwide.
Socio-Economic Compliance
Non-Compliance
Report significant fines and non-monetary sanctions for non-compliance with laws and/or regulations in the social and economic area in terms of: Applicable
i. Total monetary value of significant fines 0
ii. Total number of non-monetary sanctions 0
iii. Cases brought through dispute resolution mechanisms 0
If the organization has not identified any non-compliance with laws and/or regulations, a brief statement of this fact is sufficient In 2021, Aya Gold and Silver was in compliance
with all legally mandated social and economic
obligations for its Zgounder Silver Mine.
Governance
Climate Change
Oversight
Is there board-level oversight of climate-related issues within your organization Yes
Responsibility
Provide the highest management-level position(s) or committee(s) with responsibility for climate-related issues: Other committee, please specify
Aya Gold & Silver's ESG Committee is
responsible for overseeing climate-related
issues.
Nature of primary responsibility Assessing climate-related risks and
opportunities
Reporting
Frequency of reporting to the board on climate-related issues Annually
Incentives
Do you provide incentives for the management of climate-related issues, including the attainment of targets Yes
Key management is awarded incentives for
water management at the Zgounder Silver
Mine.
Risk and Opportunity Management
Does your organization have a process for identifying, assessing, and responding to climate-related risks and opportunities Other, please specify
For the Zgounder Silver Mine, Aya Gold &
Silver aligns its climate-change management
strategies with the continuous feedback from
investors and rating agencies.
Risk Assessments
Have you identified any inherent climate-related risks with the potential to have a substantive financial or strategic impact on your business Yes
Provide details of identified risks in your direct operations with the potential to have a substantive financial or strategic impact on your business, and your response to those risks
Risk 1:
Where in the value chain does the risk driver occur Direct operations
Risk type and primary driver Chronic Physical - Changes in precipitation
patterns and extreme variability in weather
patterns
Time horizon of risk Other, please specify
From short-term to long-term.
Likelihood of impact Very likely
Magnitude of impact High
Potential impact financial figure and explanation Stoppage of operations due to change in
weather pattern and less precipitation.
Primary potential financial impact Other, please specify
The primary potential financial impact of a
reduced water supply would be lower
production output and higher operating costs.
Cost of response to risk and description In 2021, Aya Gold and Silver's primary
response to water scarcity was to invest more
capital in water retention infrastructure in
order to capitalize on the excess water in rainy
seasons. In 2021, Aya invested USD
694,373.00 in response to the risk of change in
precipitation.
Opportunity Assessments
Have you identified any climate-related opportunities with the potential to have a substantive financial or strategic impact on your business No
Strategy
Have climate-related risks and opportunities influenced your organization’s strategy and/or financial planning Yes, and we have developed a low-carbon
transition plan
Water Management
Quality and Quantity Dependency
Rate the importance (current and future) of freshwater quality and quantity to the success of your business:
Direct use importance rating Vital
Indirect use importance rating Important
Rate the importance (current and future) of sufficient quantity of recycled, brackish and/or produced water for the success of your business:
Direct use importance rating Neutral
Indirect use importance rating Neutral
Risk Assessments
Does your organization undertake a water-related risk assessment Yes, water-related risks are assessed
Select the options that best describe your procedures for identifying and assessing water-related risks:
i. Coverage Full
ii. Risk Assessment Procedure Water risks are assessed as part of an
enterprise risk management framework
iii. Frequency of Risk Assessment Other, please specify
Aya Gold & Silver assessed water-related risks
during the development of the NI 43-101
Feasibility Study for the Zgounder Silver Mine
Expansion Project. The assessment covers the
life of mine.
iv. How far into the future are risks considered More than 6 years
Aya Gold & Silver assessed water-related risks
during the development of the NI-43101
Feasibility Study for the Zgounder Silver Mine
Expansion Project. The assessment covers the
remaining life of mine.
Have you identified any inherent water-related risks with the potential to have a substantive financial or strategic impact on operations Yes, only within our direct operations
Provide details of identified risks in your direct operations with the potential to have a substantive financial or strategic impact on your business, and your response to those risks
Risk 1:
Type of risk Physical
Primary risk driver Physical - Seasonal supply variability/inter
annual variability
Primary potential impact Reduction or disruption in production capacity
Risk timeframe More than 6 years
Applicable to Life of Mine
Magnitude of potential impact High
Likelihood of potential impact More likely than not
Potential impact financial figure and explanation Potential reduction in production capacity due
to water shortage, estimated at a maximum
reduction of 30% or USD 10.5M of revenue per
annum.
Primary response Increase capital expenditure
Cost of response and description of response In 2021, Aya Gold & Silver's primary response
to water scarcity was to increase CAPEX on
water retention infrastructure in order to
capitalize on the excess water in rainy seasons.

Cost  of USD 700,000 to construct 60,000 m3
water retention basin in 2021 (Completed in
2022)
Risk 2
Type of risk Physical
Primary risk driver Physical - Acid rock drainage and metal
leaching (metals & mining sector only)
Primary potential impact Loss of license to operate
Risk timeframe More than 6 years
Applicable to Life of Mine
Magnitude of potential impact High
Likelihood of potential impact More likely than not
Potential impact financial figure and explanation To be verified
Primary response Improve monitoring
Cost of response and description of response The Corporation's primary response was to
implement third-party monitoring of water
quality for 15 control points and management
committee to discuss and review monitoring
results and actions to be taken.

Cost of monitoring: USD 45,688 /year.
Risk 3:
Type of risk Physical
Primary risk driver Physical - Rupture of tailings dams and toxic
spills (metals & mining sector only)
Primary potential impact Fines, penalties or enforcement orders
Risk timeframe More than 6 years
Applicable to Life of Mine
Magnitude of potential impact High
Likelihood of potential impact Unlikely
Potential impact financial figure and explanation Quantification of the potential impact was not
completed in 2021.
Primary response Increase capital expenditure
Cost of response and description of response In 2020 and 2021, the Corporation's primary
response was to spend capital reinforcing
tailing dams. Tailings dams were raised and
reinforced, and storm water control
infrastructure was built.

Tailing basin improvements totaled USD
550,000 in 2021 .
In 2021, a secondary response was to
implement third-party quarterly audits on the
two TSFs in operation at the Zgounder Silver
Mine.
Opportunity Assessments
Have you identified any water-related opportunities with the potential to have a substantive financial or strategic impact on your business Yes, we have identified opportunities, and some
or all are being realized
Opportunity 1:
Type of opportunity Efficiency: Improved water efficiency in
operations
Opportunity timeframe More than 6 years
Applicable to life of mine.
Magnitude of potential impact High
Potential impact financial figure and explanation To be verified
Opportunity 2:
Type of opportunity Efficiency: Other, please specify
Aya Gold & Silver has improved its water
retention infrastructure to capitalize on excess
precipitations during the rainy season.
Opportunity timeframe More than 6 years
Applicable to Life of Mine
Magnitude of potential impact High
Potential impact financial figure and explanation To be verified
Responsibility
Provide the highest management-level position(s) or committee(s) with responsibility for water-related issues Other C-Suite Officer, please specify
Aya Gold & Silver's VP of Operations is
responsible for assessing and managing water-
related issues at the Zgounder Silver Mine.
Policy
Does your organization have a documented water policy Other, please specify
Aya Gold & Silver has an HSEC Policy that
includes all environmental aspects and
performance management.

Aya Gold & Silver HSEC Policy
Select the options that best describe the scope and content of your organizations' water policy
   •  Description of water-related performance
standards for direct operations
   •  Reference to international standards and
widely-recognized water initiatives
   •  Commitment to align with public policy
initiatives, such as the Sustainable
Development Goals (SDGs)
   •  Commitments beyond regulatory
compliance
Reporting
Frequency of reporting to the board on water-related issues Annually
Incentives
Do you provide incentives to C-suite employees or board members for the management of water-related issues Yes
Aya Gold & Silver's VP of Operations has
incentives for water-related performance at
the Zgounder Silver Mine.
Strategy
Are water-related issues integrated into any aspects of your long-term strategic business plan: Yes, water-related issues are integrated
If water-related issues are integrated into any aspects of your long-term strategic business plan, please describe further Aya Gold & Silver integrated water-related
issues into the feasibility study for the
Zgounder Silver Mine Expansion Project and its
accompanying business plan that drives the
operations for the life of mine.
If water-related issues are integrated into any aspects of your long-term strategic business plan, identify the associated long-term time horizon 5-10 years
General Disclosure
Structure
a. Report the governance structure of the organization, including committees of the highest governance body, e.g., the Board of Directors, the Executives, the Board Environment Committee, Board Safety Committee, the Advisory Committee, etc. Aya Gold & Silver's Board of Directors has four
committees as follows:

1) Audit;
2) Compensation; and
3) Corporate Governance

In addition, in 2021, the ESG committee was
added to the governance body.
Aya Gold & Silver Board of Directors
Committees
Committees
b. Report the committees responsible for decision-making on economic, environmental, and social topics, e.g., the Board of Directors, the Executives, the Board Environment Committee, Board Safety Committee, the Advisory Committee, etc. In 2021, the ESG committee was tasked with
overseeing economic, environmental and social
topics.
Responsibility
a. Has the organization appointed an executive-level position or positions with responsibility for economic, environmental, and social topics , e.g., is it part of the Governance structure of the company, the CFO or internal audit reporting to the Board Yes
Reporting Structure
b. Report whether position holders report directly to the highest governance body or CEO Aya Gold & Silver's CEO is responsible for all
ESG issues and reports directly to the Board of
Directors.
Consultation Process
Report the processes for consultations between stakeholders and the highest governance body on economic, environmental and social topics, e.g., for most mining companies it would be the executives and operations and not the Board, and if delegated, explain how The Board of Directors receives regular
feedback from investors, financial institutions
and rating agencies.

In addition, C-Suite executives provide
quarterly reports and presentations on ESG
topics communicated by stakeholders at the
Zgounder Silver Mine.
Composition
Report the composition of the highest governance body and its committees by:
Number of executive members 7
Number of non-executive members 0
Number of independent members 4
Less than 3 years 4
3-6 years 2
6-9 years 1
More than 10 years 0
Lists of each individual’s other significant positions and commitments, and the nature of the commitments, e.g., other boards and executive positions Please refer to the link below for a biographical
description of Aya Gold and Silver's Board of
Directors and the significant positions and
commitments they currently hold.
Below please find the list of significant
positions and commitments of Aya Gold &
Silver's individual Board members.
1) Benoit La Salle
2) Robert Taub
3) Marc Nolet de Brauwere
4) Yves Grou
5) Nikolaos Sofronis
6) Dr. Elena Clarici
7) Dr. Jürgen Hambrecht

Board of Directors Biographical Information

Aya Gold & Silver's AIF
Number of Male governance body members 6
Number of Female governance body members 1
Number of members from under-represented social groups 0
Description of competencies relating to economic, environmental, and social topics Aya Gold & Silver's Board members'
competencies relating to economic,
environmental, and social topics are described
on the company website.
Please refer to the link below.

Aya Gold & Silver's Board of Directors
Description of stakeholder representation Aya Gold & Silver takes a proactive approach to
stakeholder engagement and feedback to
incorporate into its management practices.

Feedback is received from investors,
shareholders, financial institutions as well as
employees, Canadian and Moroccan
authorities, and village representatives.
Non-Executive Director
Is the chair of the highest governance body also an executive officer in the organization Yes
If the chair is also an executive officer, describe his or her function within the organization’s management and the reasons for this arrangement Benoit La Salle is President & Chief Executive
Officer of Aya Gold & Silver.
Conflicts of Interest
Report the processes for the highest governance body to ensure conflicts of interest are avoided and managed, e.g., list procedures Conflicts, if any, are subject to the procedures
and remedies under the Canada Business
Corporations Act. No conflicts of interest
currently exist between the Corporation or its
subsidiaries and a director or officer of the
Corporation or its subsidiaries.

Unresolved potential conflicts involving
employees,  senior management or Directors
are referred to the Board of Director's
Nominating and Corporate Governance
Committees.
Aya Gold & Silver Code of Ethics and Business
Conduct
Report whether conflicts of interest are disclosed to stakeholders, including, as a minimum: Yes
To incentivize disclosure, a quarterly
questionnaire is sent out to all members of the
Board, as well as senior management, and
collected by the corporate secretary regarding
any conflicts in the course of the quarter.
i. Cross-board membership Yes
ii. Cross-shareholding with suppliers and other stakeholders Yes
iii. Existence of controlling shareholder Yes
iv.Related third party disclosures Yes
Transparency
Report the highest governance body’s and senior executives’ roles in the development, approval, and updating of the organization’s purpose, value or mission statements, strategies, policies, and goals related to economic, environmental, and social topics Aya Gold & Silver's corporate governance
policies are approved by the Board of Directors
and shareholders at the Annual General
Meeting.
Report on the measures taken to develop and enhance the highest governance body’s collective knowledge of economic, environmental, and social topics, e.g., board training In 2021, Aya Gold & Silver did not provide
training on ESG topics for the Board of
Directors.
Report the actions taken in response to evaluation of the highest governance body’s performance with respect to governance of economic, environmental, and social topics, including, as a minimum, changes in membership and organizational practice, (response to external evaluations) In 2021, Aya Gold & Silver conducted an
internal evaluation of ESG issues and
developed key ESG performance indicators
that are tracked by the organization.
Report the highest governance body’s role in identifying and managing economic, environmental, and social topics and their impacts, risks, and opportunities – including its role in the implementation of due diligence processes, (committee roles) In 2021, Aya Gold & Silver created a board-
level ESG committee to oversee economic,
environmental and social impacts, risks and
opportunities.
Is stakeholder consultation used to support the highest governance body’s identification and management of economic, environmental, and social topics and their impacts, risks, and opportunities, and if delegated, explain how Yes
The Board of Directors continuously receive
feedback from investors, financial institutions
and rating agencies. In addition, C-Suite
executives provide quarterly reports and
presentations on ESG issues communicated by
stakeholders, and reported by site department
heads at the Zgounder Silver Mine.
Remuneration
Report how performance criteria in the remuneration policies relate to the highest governance body’s and senior executives’ objectives for economic, environmental, and social topics In 2021, Aya Gold & Silver included water-
related key performance indicators for its VP of
Operations and site teams at the Zgounder
Silver mine.
How are stakeholders’ views sought and taken into account regarding remuneration Remuneration packages for directors, C-Suite
and Senior Managers at Aya Gold & Silver are
approved by shareholders at Annual General
Meetings.
Ethics
Describe the management system and due diligence procedures for assessing and managing corruption and bribery risks internally and associated with business partners in its value chain. Issues such as corruption and bribery are
addressed in Aya Gold & Silver's International
Business Conduct Policy. Please refer to the
link below.
Aya Gold & Silver International Business
Conduct Policy
Aya Gold and Silver’Aya Gold & Silver's International Business Conduct Policy
Report net production from activities located in the countries with the 20 lowest rankings in Transparency International’s Corruption Perception Index (CPI) (Saleable tonne): 0
Anti-corruption
Communication and Training
i. Total number of governance body members that the organization´s anti-corruption policies and procedures have been communicated to 7
ii. Total percentage of governance body members that have been communicated to on anti-corruption: 100.0000%
Total number and percentage of employees that have have been communicated to on anti-corruption:
1a. Total number of employees that have been communicated to on anti-corruption 0
In 2021, Aya Gold & Silver concentrated its
anti-corruption efforts on transactional due
diligence with suppliers and with regards to
potential mergers and acquisitions.
Communication to employees of anti-
corruption policies will be conducted in 2022.
1b. Total percentage of employees that have been communicated to on anti-corruption 0.0000%
2a. Total number of senior employees that have been communicated to on anti-corruption 0
2b. Percentage of senior employees that have been communicated to on anti-corruption 0.0000%
3a. Total number of middle management employees that have been communicated to on anti-corruption 0
3b. Percentage of middle management employees that have been communicated to on anti-corruption Does Not Apply
4a. Total number of technical employees that have been communicated to on anti-corruption 0
4b. Percentage of technical employees that have been communicated to on anti-corruption 0.0000%
5a. Total number of production employees that have been communicated to on anti-corruption 0
5b. Percentage of production employees that have been communicated to on anti-corruption 0.0000%
6a. Total number of administrative employees that have been communicated to on anti-corruption 0
6b. Percentage of administrative employees that have been communicated to on anti-corruption Does Not Apply
i. Total number and percentage of business partners that the organziation's anti-corruption policies and procedures have been communicated to:
ii. Total percentage of suppliers that the organization´s anti-corruption policies and procedures have been communicated to 100.0000%
Total number of suppliers that that the organization´s anti-corruption policies and procedures have been communicated to 90
ii. Total percentage of agents that the organization´s anti-corruption policies and procedures have been communicated to Does Not Apply
Total number of agents that that the organization´s anti-corruption policies and procedures have been communicated to 0
ii. Total percentage of lobbyists and other intermediaries that the organization´s anti-corruption policies and procedures have been communicated to Does Not Apply
Total number of lobbyists and other intermediaries that that the organization´s anti-corruption policies and procedures have been communicated to 0
ii. Total percentage of joint-venture and consortia parnters that the organization´s anti-corruption policies and procedures have been communicated to Does Not Apply
Total number of joint-venture and consortia parnters that that the organization´s anti-corruption policies and procedures have been communicated to 0
ii. Total percentage of government partners that the organization´s anti-corruption policies and procedures have been communicated to Does Not Apply
Total number of government parnters that that the organization´s anti-corruption policies and procedures have been communicated to 0
ii. Total percentage of customer/client partners that the organization´s anti-corruption policies and procedures have been communicated to Does Not Apply
Total number of customer/client partners that that the organization´s anti-corruption policies and procedures have been communicated to 0
Have the anti-corruption policies and procedures been communicated to any other persons or organizations No
i. Total number of governance body members that have received training on anti-corruption, broken down by region 0
In 2021, Aya Gold & Silver's Board approved
the company's  International Business Conduct
Policy that requires periodic training on bribery
and anti-corruption with a minimum frequency
of once every three years. In 2021, training was
not implemented.
Security Practices
Policy and Procedure Training
Report the percentage of security personnel who have received formal training in the organization’s human rights policies or specific procedures and their application to security: 0.0000%
Aya Gold & Silver's security personnel at the
Zgounder Silver mine do not carry person-
restraining equipment. Their functions are
limited to conducting vehicle checks,  metal
checks at entrances and exits, and registering
visitors. In case of situations requiring further
action, security personnel are instructed to
follow the company's chain of command
structure and immediately advise the site
Director of Operations and, if required, local
authorities.
General Disclosure
Delegation of Authority
Report the process for delegating authority for economic, environmental, and social topics from the highest governance body to senior executives and other employees At the Zgounder Silver Mine, ESG topics are
identified and managed on site by the HSE and
CR departments.
Information on potential ESG risks, and
opportunities are reported quarterly to the
ESG Committee at the board-level.

All Aya Gold & Silver employees are assigned
HSE key performance indicators as part of their
performance evaluations.
If consultation is delegated, describe to whom it is delegated and how the resulting feedback is provided to the highest governance body The HSE and CR departments are overseen by
the Corporation's HSEC Manager who reports
to the VP of Operations and the CEO.
Highest Governance Body
Report the nomination and selection processes for the highest governance body and its committees The CEO and Chairman of Aya Gold & Silver
seek qualified candidates who wish to be
considered for nomination as directors.
Proposed nominations are subject to review
and approval by the Board.
Any new appointees or nominees to the Board
must have a favourable track record in general
business management, special expertise in
areas of strategic interest to the Corporation,
and the ability to devote the time required.
i. Stakeholders (including shareholders) are involved Aya Gold & Silver's shareholders participate in
the election of Board of Directors.
ii. Diversity is considered While Aya Gold & Silver adheres to its equal
opportunity statement, no formal mechanisms
have been put into place for diversity
considerations at the Board level.
Please see the Code of Ethics and Business
Conduct Policy below.

Code of Ethics and Business Conduct Policy
iii. Independence is considered In accordance with the  Canadian regulatory
National Instruments (NI) and the TSX
corporate manual, the majority of Aya Gold &
Silver's Board of Directors are independent.
TSX Issuer Resources : Corporate Governance
iv. Expertise and experience relating to economic, environmental, and social topics are considered Nominations for Board membership are made
by the Board's Nominating and Corporate
Governance Committee which screens
potential candidates based on their expertise
and experience in economic, environmental and
social topics.
Risk Management
Report the highest governance body’s role in reviewing the effectiveness of the organization’s risk management processes for economic, environmental, and social topics ESG issues are reported to the ESG Committee
on a quarterly basis and advice is sought from
the Board on improving the organization's
effectiveness in managing ESG issues.
Review Frequency
Report the frequency of the highest governance body’s review of economic, environmental, and social topics and their impacts, risks, and opportunities Quarterly
Highest Review Position
Report the highest committee or position that formally reviews and approves the organization’s sustainability report and ensures that all material topics are covered ESG Committee
Escalation Process
Report the process for communicating critical concerns to the highest governance body ESG issues are reported to the ESG Committee
on a quarterly basis and advice is sought from
the Board on improving the organization's
effectiveness in managing ESG issues.
Critical Concerns
i. Report the number of critical concerns that were communicated to the highest governance body 1
ii. Report the nature of critical concerns that were communicated to the highest governance body In 2021, Aya Gold & Silver reported a fatal
accident as a critical concern to the Board of
Directors.
Report the mechanism(s) used to address and resolve critical concerns The incident was communicated to the Board
immediately and discussed in a special session
convened to provide context, mitigation, and
remediation measures.
Remuneration
Report which of the following remuneration policies apply to the highest governance body and senior executives:
i. Fixed pay Yes
i. Variable pay Yes
i. Performance-based pay Yes
i. Equity-based pay Yes
i. Bonuses Yes
i. Deferred and vested shares Yes
ii. Sign-on bonuses Yes
ii. Recruitment incentive payments Yes
iii. Termination payments Yes
iv. Clawbacks Yes
v. Retirement benefits, including the difference between benefit schemes and contribution rates for the highest governance body, senior executives, and all other employees Yes
Report the process for determining remuneration In 2021, Aya Gold & Silver implemented a
compensation program for directors and
executive management incorporating fixed pay
and variable pay compensation policies.
The new management team has subsequently
worked tirelessly to attract top-tier talent and
has hired over a dozen executives from the
mining industry. In this transition year, given
the significant number of hires, the company
engaged an external compensation consultant
to help establish a normalized competitive
benchmark for compensation across the
Corporation, namely for top executives and
management.
Report whether remuneration consultants are involved in determining remuneration and whether they are independent of management Independent Consultants
Report any other relationships that the remuneration consultants have with the organization Remuneration consultants utilized by Aya
Silver & Gold have no other business
relationships with the Corporation.
Compensation
The reporting organization shall report the following information
The organization shall calculate the ratio of the annual total compensation for the organization’s highest-paid individual in each country of significant operations to the median annual total compensation for all employees (excluding the highest-paid individual) in the same country as follows
Country 1:
Identify highest paid individual in the reporting period as defined by total compensation 133875
Calculate the median annual total compensation for all employees, except the highest-paid individual 6409
Calculate the ratio of the annual total compensation of the highest-paid individual to the median annual total compensation for all employees 20.887
For the ratio calculation:
List types of compensation included in the calculation All
Specify whether full-time and part-time employees are included in the calculation Yes
Specify whether full-time equivalent pay rates are used for each part-time employee in this calculation No
Specify which operations or countries are included, if the organization chooses to not consolidate this ratio for the entire organization For the purpose of this report, the ratio
calculated includes the Zgounder Silver Mine in
the Kingdom of Morocco.
Report the ratio of the percentage increase in annual total compensation for the organization’s highest-paid individual in each country of significant operations to the median percentage increase in annual total compensation for all employees (excluding the highest-paid individual) in the same country
4.6.2 Percentage increase in annual total compensation for the organization’s highest-paid individual: 90.9020%
4.6.1 Highest-paid individual for the reporting period, as defined by total compensation 133875
Annual salary in USD
Report the median percentage increase in annual total compensation for all employees (excluding the highest-paid individual): 78.1245%
4.6.3 Median annual total compensation for all employees except the highest-paid individual for the present reporting period 6409
4.6.4 Percentage increase of the median annual total compensation from the last reporting period to the present reporting period: 78.0097%
Increase of the median annual total compensation from the current reporting period for all employees 6421
4.6.5 Calculate the ratio of the annual total compensation percentage increase of the highest-paid individual to the median annual total compensation percentage increase for all employees 1.165
Stakeholder Engagement
Provide a list of stakeholder groups engaged by the organization Aya Gold & Silver continuously engages with
the following stakeholders:
1. Canadian and host country authorities at the
national and local levels;
2. Canadian and host country administrative
and regulating bodies (Ministry of health,
education, etcetera);
3. International and local civil society
organizations (NGO's, associations and co-ops);
4. Investors and shareholders, TSX authorities
and financial institutions;
5. Employees; and,
6. Supply chain buyers and service providers
Report the basis for identifying and selecting stakeholders with whom to engage Aya Gold & Silver undertakes stakeholder
mapping exercises to determine the level of
interest and influence of national and local
stakeholders in its operating asset in the
Kingdom of Morocco.
Report the organization’s approach to stakeholder engagement, including frequency of engagement by type and by stakeholder group, and an indication of whether any of the engagement was undertaken specifically as part of the report preparation process Aya Gold & Silver's stakeholder engagement is
based on the interest and influence of
stakeholders resulting in the following:
1. Continuous engagement is maintained with
host country authorities, and regulating bodies;
2.  Project- specific engagement
with  administrative bodies and civil society to
implement CSR initiatives;
3. Civil society organizations are also engaged
to obtain feedback on needs, interests and
expectations of stakeholders on their
relationship to the Zgounder Mine; and
4. In 2021, Aya Gold & Silver additionally
received feedback on the Zgounder Silver Mine
Expansion Project through the ESIA expansion
project engagement process and its public
consultation.
Report on key topics and concerns that have been raised through stakeholder engagement, including: During the 2021 ESIA consultation process,
stakeholders identified the following primary
concerns:

1.  Local employment
2.  Water management
3.  General environmental impacts
i. How the organization has responded to those key topics and concerns, including through its reporting Aya Gold & Silver has a local employment
process that has been communicated to
contractors for the expansion project. Water
concerns were added to the design criteria for
the feasibility study of the  Zgounder Silver
Mine Expansion Project.
ii. The stakeholder groups that raised each of the key topics and concerns All concerns enumerated above were raised by
the totality of our stakeholders during the
consultation process.
Material Topics
Process to determine material topics
Describe the process followed to determine its material topics, including:
i. How has the organization identified actual and potential, negative and positive impacts on the economy, environment, and people, including impacts on their human rights, across its activities and business relationships; provide details.
   •  Environmental impact assessment
   •  Social impact assessment
   •  Civil society organizations
ii. How has the organization prioritized the impacts for reporting based on their significance; In 2021,  the Corporation used the output of
the ESIA risk assessment and the output of its
internal risk analysis to determine the material
topics for the Zgounder Silver Mine.

In addition, we included stakeholder concerns
communicated through our continual
engagement.
Specify the stakeholders and experts whose views have informed the process of determining its material topics and provide details.
   •  Civil society organizations
   •  Customers
   •  Employees and other workers
   •  Governments
   •  Local communities
   •  Non-governmental organizations
   •  Shareholders and other capital providers
   •  Suppliers
List of material topics
List the organization's material topics
   •  Energy
   •  Water
   •  Emissions
   •  Effluents and Waste
   •  Overall environmental
   •  Occupational Health and Safety
   •  Training and Education
   •  Local Communities
   •  Anti-corruption
   •  Emergency Preparedness
List the organization's non-material topics
   •  Economic Performance
   •  Market Presence
   •  Indirect Economic Impacts
   •  Procurement Practices
   •  Materials
   •  Biodiversity
   •  Products and Services
   •  Compliance
   •  Transport
   •  Supplier
   •  Environmental Assessment
   •  Environmental Grievances
   •  Employment
   •  Labor/Management Relations
   •  Diversity and Equal Opportunity
   •  Equal Remuneration for Women and Men
   •  Supplier Assessment for Labor Practices
   •  Labor Practices
   •  Grievance Mechanisms
   •  Human Rights Investment
   •  Non-discrimination
   •  Freedom of Association and Collective
Bargaining
   •  Child Labor
   •  Forced or Compulsory Labor
   •  Security Practices
   •  Indigenous Rights
   •  Supplier Human Rights Assessment
   •  Human Rights Grievance Mechanisms
   •  Public Policy
   •  Anti-competitive Behavior
   •  Supplier Assessment for Impacts on Society
   •  Grievance Mechanisms for Impacts on
Society
   •  Artisanal and Small-scale mining
   •  Resettlement
   •  Closure Planning
   •  Customer Health and Safety
   •  Product and Service Labeling
   •  Marketing
   •  Communications
   •  Customer Privacy
   •  Materials Stewardship
Provide reason for considering such topics not material, provide details. Not applicable
Report changes to the list of material topics compared to the previous reporting period. In this 2021 disclosure, Aya Gold & Silver has
included GHG emissions in its materiality
analysis.
Management of material topics
For the top 5 material topics, the reporting organization shall report the following information:
Topic #1: Water
An explanation of why the topic is material; describe the actual and potential, negative and positive impacts on the economy, environment, and people, including impacts on their human rights. Use of water resources, or water stress, is both
an operational and a societal risk.
Report the boundary for the material topic:
i. Where the impacts occur For operations, water is taken from a
spring  located 5 km upstream and brought
gravitationally by aqueduct to the mine.
Expansion of the Zgounder Silver Mine is
dependent on finding new water sources, which
communities require for drinking and
agriculture.
ii. The organization’s involvement with the impacts. e.g., whether the organization has caused or contributed to the impacts, or is directly linked to the impacts through its business relationships The expansion of the Zgounder Silver Mine is
dependent on finding new water sources.
Any specific limitation regarding the topic boundary The Zgounder project is located in an area of
high-water stress.
Report whether the organization is involved with the negative impacts through its activities or as a result of its business relationships, and describe the activities or business relationships; Activities
Describe/provide a link to the corporate policies or commitments regarding the topic Please refer to the Aya Gold & Silver HSEC
Policy in the link below.
Aya Gold & Silver's HSEC Policy
Explain how the organization manages the topic; describe actions taken and related impacts, including:
i. actions to prevent or mitigate potential negative impacts; Water risks are assessed through the
Corporation's risk management system, where
mitigation measures are identified and
mitigation plans are developed and
incorporated in the annual CAPEX and OPEX
budgets.
In 2021, Aya Gold & SIlver refurbished the
Macoste spring infrastructure (piping and
reservoir), and built 2 water basins with a
30,000m3 of water storage capacity.
ii. actions to address actual negative impacts, including actions to provide for or cooperate in their remediation; In 2021, no negative impacts related to water
were identified in local communities.

The 2021 CAPEX investment aimed to mitigate
potential future impacts related to the
expansion project.
iii. actions to manage actual and potential positive impacts; Aya Gold & Silver, together with national
authorities, is evaluating the feasibility of
building a retention dam or  similar
infrastructure to  take advantage of excess
water during the rainy season.
Report the following information about tracking the effectiveness of the actions taken:
i. processes used to track the effectiveness of the actions;
   •  Internal auditing
   •  Impact assessments
   •  Measurement systems
   •  Stakeholder feedback
   •  Grievance mechanisms
ii. goals, targets, and indicators used to evaluate progress; The Zgounder Silver Mine Expansion Project is
currently assessing the feasibility study. Goals,
targets and indicators will be established as per
the validation process of the impact
assessment.
iii. the effectiveness of the actions, including progress toward the goals and targets; any related adjustments. Does not apply at this stage of development.
iv. lessons learned and how these have been incorporated into the organization’s operational policies and procedures Does not apply at this stage of development.
Describe how engagement with stakeholders has informed the actions taken and how it has informed whether the actions have been effective. Does not apply at this stage of development.
Topic #2: Water
An explanation of why the topic is material; describe the actual and potential, negative and positive impacts on the economy, environment, and people, including impacts on their human rights. Use of water resources, or water stress, is both
an operational and a societal risk.
Use of water resources, or water stress, is both
an operational and a societal risk.
Report the boundary for the material topic:
i. Where the impacts occur During its due diligence process for the
acquisition of the Zgounder Silver Mine, Aya
Gold & Silver determined the asset had a
history of weak water management. Water
pollution is often the first topic that comes up
when talking to local communities and local
authorities about the Zgounder Silver Mine.
The Corporation's quarterly water quality
sampling reports show that river water in the
immediate vicinity of the mine has regularly
shown traces of pollution since 2015. Although
it remains contained (sample points 3 km
downstream are always negative), the
Corporation’s management team considers this
an extremely urgent matter.
ii. The organization’s involvement with the impacts. e.g., whether the organization has caused or contributed to the impacts, or is directly linked to the impacts through its business relationships Aya Gold & Silver's analysis concluded that the
water pollution stems from a pulp overflow
from the cyanide processing plant.
Please refer to Aya Gold & Silver's 2020
Sustainability Report for further information.

Aya Gold & Silver 2020 Sustainability Report
Any specific limitation regarding the topic boundary There are no specific limitations regarding this
material topic.
Report whether the organization is involved with the negative impacts through its activities or as a result of its business relationships, and describe the activities or business relationships; Activities
Describe/provide a link to the corporate policies or commitments regarding the topic Please refer to Aya Gold and Silver's HSEC
Policy below.
Aya Gold & Silver HSEC Policy
Explain how the organization manages the topic; describe actions taken and related impacts, including:
i. actions to prevent or mitigate potential negative impacts; In 2021, Aya Gold & Silver implemented
physical control measures in its operations and
initiated an environmental monitoring program
with a third-party accredited lab.
ii. actions to address actual negative impacts, including actions to provide for or cooperate in their remediation; In 2021, Aya Gold & Silver implemented
physical control measures in its operations and
initiated an environmental monitoring program
with a third-party accredited lab.
iii. actions to manage actual and potential positive impacts; No positive impacts have been identified
regarding this material topic.
Report the following information about tracking the effectiveness of the actions taken:
i. processes used to track the effectiveness of the actions;
   •  Internal auditing
   •  External auditing or verification
   •  Impact assessments
   •  Measurement systems
   •  Stakeholder feedback
   •  Grievance mechanisms
ii. goals, targets, and indicators used to evaluate progress; Aya Gold & Silver's water monitoring program
tests water quality against national and WHO
drinking water, and sampling is carried out
monthly to ensure compliance.
iii. the effectiveness of the actions, including progress toward the goals and targets; any related adjustments. In 2021, the water monitoring program was in
its initial stage of implementation. In 2022, the
effectiveness of the measures described above
will be assessed and reported.
iv. lessons learned and how these have been incorporated into the organization’s operational policies and procedures Not applicable at this stage of development.
Describe how engagement with stakeholders has informed the actions taken and how it has informed whether the actions have been effective. Stakeholder engagement and information were
provided in 2021 through the ESIA stakeholder
consultation process.
Topic #3: Effluents and Waste
An explanation of why the topic is material; describe the actual and potential, negative and positive impacts on the economy, environment, and people, including impacts on their human rights. TSF dam leakages or dam failures can impact
host populations and the environment.

For further information please refer to the
Corporations's 2020 Sustainability Report.
Aya Gold & Silver 2020 Sustainability Report
Report the boundary for the material topic:
i. Where the impacts occur This material topic is linked to the Company's
TSF obligations.

There are four TSFs at the Zgounder Silver
Mine. One is the “historical TSF” that was used
by operations until the 1990s.
The satellite imagery clearly shows the
presence of historical leakage under this TSF,
observable by the grayish coloration of the soil
downstream. The second TSF was used for the
new flotation plant built in 2019, but was
closed immediately by new management due to
instability. Currently, there are 2 active TSFs:
one for the cyanidation and the other for the
flotation plant. Originally built in 2002, the
cyanidation TSF was expanded in 2014 to its
current footprint. The dam of the cyanidation
TSF shows sign of leakage in the layers built
during the early 2000s.
ii. The organization’s involvement with the impacts. e.g., whether the organization has caused or contributed to the impacts, or is directly linked to the impacts through its business relationships Impacts are directly linked to the Zgounder
Mine site operations.
Any specific limitation regarding the topic boundary No limitations are identified.
Report whether the organization is involved with the negative impacts through its activities or as a result of its business relationships, and describe the activities or business relationships; Activities
Describe/provide a link to the corporate policies or commitments regarding the topic Please refer to Aya Gold and Silver's HSEC
Policy below.
Aya Gold & Silver HSEC Policy
Explain how the organization manages the topic; describe actions taken and related impacts, including:
i. actions to prevent or mitigate potential negative impacts; In 2020, the Corporation’s management team
conducted an internal audit of the four TSFs
present at the Zgounder Silver Mine.
After extensive repairs in 2020, in 2021,
internal quarterly audits were conducted with
the objective of implementing GIST standards.
ii. actions to address actual negative impacts, including actions to provide for or cooperate in their remediation; Please refer to the 2020 sustainability report
below.
iii. actions to manage actual and potential positive impacts; No positive impacts have been identified for
this material issue.
Report the following information about tracking the effectiveness of the actions taken:
i. processes used to track the effectiveness of the actions;
   •  Internal auditing
   •  External auditing or verification
   •  Measurement systems
   •  Stakeholder feedback
ii. goals, targets, and indicators used to evaluate progress; Goals, target and indicators are reported by
external audits and verifications on a quarterly
basis.
iii. the effectiveness of the actions, including progress toward the goals and targets; any related adjustments. Not applicable at this stage of development.
iv. lessons learned and how these have been incorporated into the organization’s operational policies and procedures Not applicable at this stage of development.
Please note the material topic was part of an
environmental legacy that Aya Gold and Silver
acquired and is not part of the Corporation's
operational policies and procedures.
Describe how engagement with stakeholders has informed the actions taken and how it has informed whether the actions have been effective. Stakeholder engagement and information were
provided in 2021 through the ESIA stakeholder
consultation process.
Topic #4: Occupational Health and Safety
An explanation of why the topic is material; describe the actual and potential, negative and positive impacts on the economy, environment, and people, including impacts on their human rights. In 2020, Aya Gold & Silver reported Health &
Safety (“H&S”) as a major concern at the
Corporation’s operations. Preliminary findings
from the Corporation’s assessment pointed to a
clear lack of risk awareness, and to the absence
of a H&S culture at all organization levels of the
Zgounder Silver Mine.  This issue remains a top
priority in 2021
Report the boundary for the material topic:
i. Where the impacts occur H&S is a concern for operations within the mine
site and applies to both direct employees and
contractors.

H&S is a material issue and concern at all
operational levels of the Zgounder Silver Mine.
ii. The organization’s involvement with the impacts. e.g., whether the organization has caused or contributed to the impacts, or is directly linked to the impacts through its business relationships H&S is a concern for operations within the mine
site and applies to both direct employees and
contractors.
Any specific limitation regarding the topic boundary No limitations have been identified.
Report whether the organization is involved with the negative impacts through its activities or as a result of its business relationships, and describe the activities or business relationships; Both Activities and business relationships
Describe/provide a link to the corporate policies or commitments regarding the topic Please refer to the document in the link below.
Aya Gold & Silver HSEC Policy
Explain how the organization manages the topic; describe actions taken and related impacts, including:
i. actions to prevent or mitigate potential negative impacts; In 2021, Aya Gold & Silver revamped its H&S
system to incorporate all of the elements of a
working performance management system
based on IFC standards including:
1. A new H&S policy at site;
2. A risk identification and impact system;
3. The development of management plans,
procedures (SOPs), corporate standards;
4. Organizational capacity and competency;
5. Emergency response and preparation system
and;
6. A monitoring and evaluation system for
continuous improvement.

A senior manager was hired to lead H&S efforts
and organize a new H&S department to
strengthen the H&S culture among our
employees and contractors at the Zgounder
Silver Mine.
ii. actions to address actual negative impacts, including actions to provide for or cooperate in their remediation; Please refer to the answers above.
iii. actions to manage actual and potential positive impacts; The results from the newly implemented H&S
system at the Zgounder Silver Mine will be
reported in 2022.
Report the following information about tracking the effectiveness of the actions taken:
i. processes used to track the effectiveness of the actions;
   •  Internal auditing
   •  External auditing or verification
   •  Impact assessments
   •  Measurement systems
   •  Benchmarking
ii. goals, targets, and indicators used to evaluate progress; Aya Gold & Silver utilizes the standard H&S KPI
list and benchmarks against its industry peers
to evaluate its performance.
iii. the effectiveness of the actions, including progress toward the goals and targets; any related adjustments. In 2021, after the implementation of the
system, the Zgounder Silver Mine installed
collective protective equipment in its
operations resulting in a decrease of potential
accidents and near misses. There was also an
increase in risk awareness among employees.
iv. lessons learned and how these have been incorporated into the organization’s operational policies and procedures In 2022, Aya Gold & Silver will report the
results of the implementatation of the new
management system.
Describe how engagement with stakeholders has informed the actions taken and how it has informed whether the actions have been effective. In 2021, a number of H&S committees were
established to represent all levels of the
workforce. These are instrumental in providing
timely feedback to the development and
implementation of the new H&S system.
Topic #5: Local Communities
An explanation of why the topic is material; describe the actual and potential, negative and positive impacts on the economy, environment, and people, including impacts on their human rights. The Zgounder Silver Mine has over 40 years of
history that spans several operators and
administrations, from state companies to
private ownership, and includes intermittent
periods of inactivity.

This has resulted in complicated relations and
historical baggage with the communities.
Report the boundary for the material topic:
i. Where the impacts occur Concerns related to the relationship between
the Zgounder Silver Mine and its host
communities.
ii. The organization’s involvement with the impacts. e.g., whether the organization has caused or contributed to the impacts, or is directly linked to the impacts through its business relationships The impact was caused by an absence of
relationship-building between past mine
operators and the surrounding villages.
Any specific limitation regarding the topic boundary In 2021, local elections were held. Therefore,
Aya Gold & Silver engaged cautiously to avoid
the potential perception of exercising influence
or create expectations over election matters.
Report whether the organization is involved with the negative impacts through its activities or as a result of its business relationships, and describe the activities or business relationships; Both Activities and business relationships
Describe/provide a link to the corporate policies or commitments regarding the topic Please refer to the document in the link below.
Aya Gold & Silver HSEC Policy
Explain how the organization manages the topic; describe actions taken and related impacts, including:
i. actions to prevent or mitigate potential negative impacts; In 2021, Aya Gold & Silver hired a senior
community relations lead t who  established
regular engagement practices with  local
administrations, resulting in the identification
of a fixed set of actions to be implemented by
the Zgounder Silver Mine.
ii. actions to address actual negative impacts, including actions to provide for or cooperate in their remediation; In 2021, Aya Gold & Silver worked with local
authorities to formalize its grievance
mechanism.
iii. actions to manage actual and potential positive impacts; In addition to maintaining a high local content
management strategy, in 2021, Aya Gold &
Silver developed a community investment plan
aligned with  national and regional
development programs, and local authority and
village feedback and participation.
Report the following information about tracking the effectiveness of the actions taken:
i. processes used to track the effectiveness of the actions;
   •  Internal auditing
   •  Impact assessments
   •  Measurement systems
   •  Stakeholder feedback
   •  Grievance mechanisms
   •  Benchmarking
ii. goals, targets, and indicators used to evaluate progress; In 2021, Aya Gold & Silver established and
committed to an annual community investment
budget. All investment targets were met.
iii. the effectiveness of the actions, including progress toward the goals and targets; any related adjustments. Please refer to the answer above. No
adjustments were identified in 2021.
iv. lessons learned and how these have been incorporated into the organization’s operational policies and procedures Aya Gold & Silver defined internal
administrative procedures to streamline
community investments, and learned to work
with local administrations to achieve joint
objectives while safeguarding the company's
commitment to transparency.
Describe how engagement with stakeholders has informed the actions taken and how it has informed whether the actions have been effective. All community investments in 2021 were based
on feedback from local administrations and
villages.
A description of the grievance mechanism, if the management approach includes such mechanism Aya Gold & Silver formalized the Zgounder
Silver Mine grievance mechanism in 2021.
Grievance Mechanism: Ownership of the mechanism The grievance mechanism is managed by Aya
Gold & Silver in conjunction with the local
representative of the Kingdom of Morocco's
Ministry of the Interior.
Grievance Mechanism: The purpose of the mechanism and its relationship to other grievance mechanisms The Zgounder Silver mine grievance
mechanism is exclusively for use by external
stakeholders. Internal stakeholders report
grievances through the Human Resources
system and their representatives.
Grievance Mechanism: The organization’s activities that are covered by the mechanism The community grievance mechanism is utilized
by external stakeholders.
Grievance Mechanism: The intended users of the mechanism Intended users of the mechanism include:

1.  Village residents
2.  Local administration
3.  Local service providers
4.  Civil society organizations
5.  Any other external stakeholders affected by
Zgounder Silver activities
Grievance Mechanism: How the mechanism is managed The mechanism is co-managed by Aya Gold &
Silver and local authorities.
Grievance Mechanism: The process to address and resolve grievances, including how decisions are made Grievances are received by local authorities
and/or community relations employees.
Grievances are jointly investigated and
resolved.  

If required, ad hoc committees can be formed
to resolve complaints.

If warranted the grievance may escalate to be
resolved through the justice system.
Grievance Mechanism: The effectiveness criteria used The effectiveness of the grievance mechanism
is measured by the expedient resolution of
grievances, and by a general lack of
interruptions to the operations as a result of
unresolved community grievances.
The total number of grievances filed through the mechanism during the reporting period 1
The number of grievances that were addressed (or reviewed) during the reporting period 1
The number of grievances that were resolved during the reporting period; 1
The number of grievances filed through the mechanism prior to the reporting period that were resolved during the reporting period; 0
The number of grievances that were resolved by remediation 0
Anti-corruption
Corruption Risks to Operations
i. Total number of operations assessed for corruption risks 1
iii. Percentage of operations assessed for corruption risks 100.0000%
Report any significant corruptions risks identified:
Risk 1 In 2021, Aya Gold & Silver did not identify any
significant corruption risks to its operations at
the Zgounder Silver Mine.
Confirmed Incidents and Response
Total number of confirmed incidents in which employees were dismissed or disciplined for corruption 0
Total number of contracts terminated or not renewed with business partners due to corruption related violations 0
Public legal cases brought against the organization or its employees during the reporting period related to corrupton and the outcomes of such cases 0
Anti-competitive behaviour
Legal Actions
Total number of legal actions pending or completed during the reporting period regarding anti-competitive behaviour and violations of anti-trust and monopoly legislation in which the organization has been identified as a participant: 0
Number of legal actions pending during the reporting period regarding anti-competitive behaviour 0
Number of legal actions completed during the reporting period regarding anti-trust behaviour 0
Tax
Provide a description of the approach to tax, including:
i. Does the organization have a tax strategy No
ii. The frequency of formal review and approval of the tax strategy by the governance body or executive-level position within the organization; Not Applicable
iii. The approach to regulatory compliance In addition to its publicly-mandated corporate
audits, Aya Gold & Silver employs local legal
counsel and tax advisor services to ensure the
Corporation meets its commitment to full
compliance and transparency with regard to
tax obligations.
iv. How the approach to tax is linked to the business and sustainable development strategies of the organization Aya Gold & Silver is committed to full
compliance and transparency with regard to
the Corporation's tax obligations in every
jurisdiction  in which it operates.
Tax governance, control, and risk management
Provide a description of the tax governance and control framework, including:
i. The governance body or executive-level position within the organization accountable for compliance with the tax strategy Since there is no tax strategy in place, there is
no single individual responsible for tax
planning.  Tax planning is done in concordance
with the corporation's external auditors -
KPMG.  

Tax implications are reviewed by the
Corporation's CFO and Corporate Controller
as situations arise.
ii. How the approach to tax is embedded within the organization N/A
iii. The approach to tax risks, including how risks are identified, managed, and monitored As part of its risk management strategy, Aya
Gold & Silver has developed a series of "red
fIags" to identify potential business
misconduct. Among these red flags is the
identification of any payment requested to a
bank in a “tax haven” jurisdiction (e.g. the
Cayman Islands) or in a country identified by
the FATF (Financial Action Task Force on
Money Laundering) as a “Non- Cooperative
Country or Territory” for no apparent reason.
Aya Gold and Silver International Business
Conduct Policy
iv. How compliance with the tax governance and control framework is evaluated Compliance  with tax governance is partially
attained through the Corporation's external
auditors.  

In addition, the Moroccan entities have strict
procedures in place in terms of the accuracy
and timeliness of tax filings for sales tax,
withholding tax, and corporate tax.
Provide a description of the mechanisms for reporting concerns about unethical or unlawful behaviour and the organization’s integrity in relation to tax The Audit Committee Chairman is responsible
for the receipt, retention and investigation of
complaints or concerns received regarding, but
not limited to, fraud, misconduct, management
override, accounting, internal controls, auditing
matters and corporate governance issues
whether received through the whistle-blower
mechanism or other means.
Aya Gold & Silver Whistleblower Policy and
Procedure


Aya Gold & Silver International Business
Conduct Policy
Describe the approach to stakeholder engagement and management of stakeholder concerns related to tax, including:
i. The approach to engagement with tax authorities Aya Gold & Silver does not directly or
(indirectly) engage with tax authorities in any of
the jurisdictions in which it operates.

"Indirect engagement" includes not adhering to
public policy recommendations on tax from
industry groups.
ii. The approach to public policy advocacy on tax Aya Gold & Silver does not advocate on tax
issues in any of the jurisdictions in which the
Corporation operates.
iii. the processes for collecting and considering the views and concerns of stakeholders, including external stakeholders Aya Gold & Silver receives timely information
on tax-related issues from external counsel to
meet its tax obligations.
Country-by-Country Reporting
Report all tax jurisdictions where the entities included are resident for tax purposes, in the organization’s audited consolidated financial statements, or in the financial information filed on public record Kingdom of Morocco
Mauritania
Canada
Barbados
For each tax jurisdiction reported in Disclosure (GRI 207-4-a), report the:
i. Names of the resident entities Aya Gold & Silver operates in the following
jurisdictions and has the following resident
entities:
Aya Gold & Silver operates in the Kingdom of
Morocco under the following entities:
•     Zgounder Millenium Silver Mining S.A.
(ZMSM)
•     Compagnie Miniere Maya-Maroc S.A.
(CMMM)
•     Atlas Gold & Silver S.A.R.L (AGS)
•     Boumadine Gold Mining S.A.  (BGM)

Aya Gold & Silver operates in Mauritania under
the following entities:
•     Algold Mauritania SARL
•     Tijirit recherche et exploration (Tirex) S.A.

Aya Gold & Silver operates in Canada under the
following entities:
•     Aya Gold & Silver Inc.
•     Algold Resources Ltd.

Aya Gold & Silver operates in Barbados under
the following entities:
•     Kanosask (Barbados) Limited

Aya Gold & Silver 2020 ESTMA Report
ii. Primary activities of the organization The entities referenced above primarily focus
on mining exploration and operation.
iii. Number of employees, and the basis of calculation of this number 275
This is the number of Aya Gold & Silver's
employees in Morocco.
iv. Revenues from third-party sales 34301914
v. Revenues from intra-group transactions with other tax jurisdictions 0
vi. Profit/loss before tax 5117383
vii. Tangible assets other than cash and cash equivalents 50060335
viii. Corporate income tax paid on a cash basis 644681
ix. Corporate income tax accrued on profit/loss 3845241
x. Reasons for the difference between corporate income tax accrued on profit/loss and the tax due if the statutory tax rate is applied to profit/loss before tax Corporate tax paid represents the taxes paid in
Morocco for operations that generate
revenue.  However, permanent and temporary
differences arise from the recognition of
deferred tax assets and liabilities.
Report the time period covered by the information reported in Disclosure (GRI 207-4-a):
From 2021-01-01
To 2021-12-31
Public Policy
Political Contributions
Total monetary value of financial and in-kind political contributions made directly and indirectly by the organization by country and recipient/beneficiary 0
Country 1:
Total direct financial contribution 0
In 2021, Aya Gold & Silver did not make any
direct or indirect financial or in-kind political
contributions.
Total indirect financial contribution 0
Total direct in-kind contribution 0
Total indirect in-kind contribution 0
This document was prepared using
, Planet Earth's complete ESG reporting solution.