Sherritt International Corporation
2024  ESG Scorecard
Published on  August 6, 2025
Sherritt International Corporation
Disclaimer and Forward Looking Statements
Reports By Level
Corporate
Energas
Metals
MOA Nickel Fort Site
Company Profile
Organizational Profile
Name Sherritt International Corporation
Describe nature of activities, brands, products and services Sherritt is a world leader in using hydrometallurgical processes to mine and refine nickel and cobalt – metals deemed critical for the energy transition. Sherritt’s Moa Joint Venture has an estimated mine life of approximately 25 years and is advancing an expansion program focused on increasing annual mixed sulphide precipitate production by 20% of contained nickel and cobalt. The Corporation’s Power division, through its ownership in Energas S.A., is the largest independent energy producer in Cuba with installed electrical generating capacity of 506 MW, representing approximately 10% of the national electrical generating capacity in Cuba. The Energas facilities are comprised of two combined cycle plants that produce low-cost electricity from one of the lowest carbon emitting sources of power in Cuba. Sherritt’s common shares are listed on the Toronto Stock Exchange under the symbol “S”.
Link to Corporate Website https://www.sherritt.com/English/Home/default.aspx
Industry Classification NAICS:
21 Mining, quarrying, and oil and gas extraction
22 Utilities
31-33 Manufacturing
54 Professional, scientific and technical services
Market Capitalization $0-$100Million USD
Type of Operations Primarily production oriented
Company Headquarters Toronto, Canada
ESG Accountability
Role of highest authority within the company for Environment, Social and Governance strategy, programs and performance Chief Executive Officer (CEO)
The name of the highest authority, if applicable Leon Binedell - Executive Chairman, President and CEO
GRI Reporting Requirements
Choose the statement as to how the organization has aligned their reporting utilizing GRI Standards
 The organization has reported with reference to the GRI Standards for the period defined below
ESG Reporting Period
Unless otherwise noted, all data contained in this report covers the following period
From 2024-01-01
To 2024-12-31
External Assurance
Has the report been externally assured No
Geographic Scope of Report
Unless otherwise noted, the data in this report covers sustainability matters related to the following locations of operations
  • Canada
  • Cuba
Reporting Practice
Provide the full contact details (name, title, address, email and/or phone number) for an individual responsible to address questions regarding the report or its contents sustainability@sherritt.com
Currency
Unless otherwise noted, all financial figures referenced in this report are in the following currency CAD
Membership of Associations
List of the industry associations, other membership associations, and national or international advocacy organizations in which the organisation participates in a significant role, as well as any economic, environmental, and social charters, principles, or other programmes that the organisation subscribes to or supports, such as the United Nations Global Compact (UNGC), etc. Refer to Sherritt's 2024 Sustainability Report.
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
Finished Product for Sale
Total amount of finished product for sale - Fossil Fuel
Liquid Petroleum Gas (LPG) (tonnes) 9,213.800
Total amount of finished product for sale - Metals 33,538.000
Cobalt (Co) (tonnes) 3,206.000
Nickel (Ni) (tonnes) 30,332.000
Total amount of finished product for sale - Other
Hydrocarbon Gas Liquids (HGL) (cubic metres, m³) 9,213.800
In 2024, in addition to the numbers reported above, the Fort Site produced 250,272 tonnes of fertilizer for sale.
Strategy
Provide a statement from the highest governance body or most senior executive of the organization (i.e., CEO, chair, or equivalent senior position) about the relevance of sustainable development to the organization and its strategy for contributing to sustainable development. (CEO's message for this report) Refer to Sherritt's 2024 Sustainability Report.
Material Topics
Governance of Material Topics
Describe the process followed to determine the organization's material topics For a full disclosure of Sherritt's material topics please see Sherritt's 2024 Sustainability Report.
How did the organization identify the material topics Materiality Assessment
Environment
Climate Change - Stewardship
Strategy
Have climate-related risks and opportunities influenced your organization’s strategy and/or financial planning Yes
Does your organization have a process for identifying, assessing, and responding to climate-related risks and opportunities Yes
Risk Assessments
Have you identified any inherent climate-related risks with the potential to have a substantive financial or strategic impact on your business No - risks exist, but none with potential to have a substantive financial or strategic impact on business
Refer to Sherritt's 2024 Climate Report for more information on the climate-related risks identified to-date.
Opportunity Assessments
Have you identified any climate-related opportunities with the potential to have a substantive financial or strategic impact on your business Yes
Refer to Sherritt's 2024 Climate Report for more information on the climate-related opportunities identified to-date.
Greenhouse Gas Emissions - Sherritt
Scope 1
The total amount of gross global Scope 1 GHG emissions (CO₂-e) (tonnes) 4,465,634.218
Discuss any change in its Scope 1 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 (i.e. any changes the entity made to the measurement approach, inputs and assumptions during the reporting period and the reasons for those changes, if any) 2024 Scope 1 emissions for the Metals business, which is inclusive of the Fort Site and Moa Nickel, remained within the historical range as there were no material changes in activities or operations from previous years.

However, an increase in net power generation for the Energas business resulted in a subsequent increase in 2024 Scope 1 emissions for Sherritt.
The entity may, where relevant, provide a breakdown of its emissions per resource produced or business unit Sherritt discloses Scope 1 emissions on behalf of our JV partners. Accordingly, the total emissions attributed to Sherritt in this report, and other sustainability reports prepared by the Corporation, overrepresent Sherritt's specific Scope 1 emissions. The total of Scope 1 emissions that can be attributed to Sherritt are 50% for Moa Nickel and Fort Site combined, and 33% for the Energas business due to the level of ownership by Sherritt in each joint venture. Furthermore, any analysis conducted to assess the emission intensities of Sherritt’s businesses or product, should consider that the Sherritt’s Metals business is comprised of the Fort Site and Moa Nickel and the Energas business is comprised of various other sites. Production totals for each separate business should be used to calculate emission intensities.
Discuss short-term, medium-term and long-term  strategy or plan to manage its Scope 1 greenhouse gas (GHG) emissions Refer to Sherritt's 2024 Climate Report.
Scope 2
The total amount of gross location based global Scope 2 GHG emissions (tonnes CO₂-e) 135,491.617
Sherritt discloses GHG emissions on behalf of our JV partners. Accordingly, the total emissions attributed to Sherritt in this report, and other sustainability reports prepared by the Corporation, overrepresent Sherritt's true Scope 2 emissions. The total of Scope 2 emissions that can be attributed to Sherritt are 50% for Moa Nickel and Fort Site combined, and 33% for the Energas business due to the level of ownership by Sherritt in each joint venture. Furthermore, any analysis conducted to assess the emission intensities of Sherritt’s businesses or product, should consider that the Sherritt’s Metals business is comprised of the Fort Site and Moa Nickel and the Energas business is comprised of various other sites. Production totals for each separate business should be used to calculate emission intensities.
Discuss any change in its Scope 2 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 (i.e. any changes the entity made to the measurement approach, inputs and assumptions during the reporting period and the reasons for those changes, if any) 2024 Scope 2 emissions for the Metals business, which is inclusive of the Fort Site and Moa Nickel, remained within the historical range as there were no material changes in activities or operations from previous years.

However, a decrease in grid power purchased for the Energas business resulted in a subsequent decrease in 2024 Scope 2 emissions for Sherritt.
Discuss long-term and short-term strategy or plan to manage Scope 2 emissions, emissions reduction targets, and an analysis of performance against those targets Refer to Sherritt's 2024 Climate Report
Carbon Offset and Pricing - Sherritt
Credits
How much CO₂ (metric tonnes) offset credits were purchased? 0.000
Greenhouse Gas Emissions - Sherritt
Reduction of GHG emissions
GHG emissions reduced as a direct result of reduction initiatives (tonnes of CO₂-e) 0.000
Sherritt is currently in the process of developing a detailed emissions reduction roadmap for all of its major operating facilities and assets, which will ensure a comprehensive approach to meeting emission reduction targets. At present, there are no GHG reductions to report that are a direct result of reduction or abatement initiatives.
Air Emissions - Sherritt
Emissions Management
Disclose the management approach regarding Emissions Sherritt is committed to tracking and managing our energy use and GHG emissions at each site. Sites are required, per Sherritt's Climate Change Standard, to implement GHG emission management systems that meet various requirements in line with the Mining Association of Canada’s (MAC) Towards Sustainable Mining (TSM) Climate Change
Protocol.  Sherritt is currently in the process of developing a detailed emission reduction roadmap for all of its major operating facilities and assets that will ensure a comprehensive approach to meeting emissions reduction targets. At present GHG emissions have not reduced as a direct result of reduction initiatives.
TSM Climate Change Protocol
Emissions of air pollutants that are released into the atmosphere - carbon monoxide, reported as CO (tonnes) 221.720
Emissions of air pollutants that are released into the atmosphere - oxides of nitrogen (NOx), reported as NOx (tonnes) 8,405.560
Emissions of air pollutants that are released into the atmosphere - oxides of sulphur (SOx), reported as SOx (tonnes) 50,569.950
Emissions of air pollutants that are released into the atmosphere - Particulate Matter 10 micrometres or less in diameter (PM₁₀), reported as PM₁₀  (tonnes)
 95.300
Emissions of air pollutants that are released into the atmosphere - lead and lead compounds, reported as Pb (tonnes) 0.000
Emissions of air pollutants that are released into the atmosphere - mercury and mercury compounds, reported as Hg (tonnes) 0.000
Emissions of air pollutants that are released into the atmosphere - non-methane Volatile Organic Compounds (VOCs)  (tonnes) 10.280
Total air emissions reported for Energas, Fort Site and Moa Nickel are based on available information and/or on the applicability of the indicator to the operation.
Energy - Sherritt
Energy Consumption
Total energy consumption within the organization (gigajoules, GJ) 11,900,975.890
The 2024 Sherritt total for energy consumption is less than the total of energy owned and controlled by the organization. This is because, in 2024, our Energas operations sold more energy than was consumed by the operations resulting in a negative total energy consumption value.
Report the energy owned and controlled by the organization consumed in gigajoules for the following 20,880,767.940
Electricity purchased/generated for consumption (gigajoules, GJ) 1,706,409.600
Heating purchased/generated for consumption (gigajoules, GJ) 7,892,630.540
Cooling purchased/generated for consumption (gigajoules, GJ) 0.000
Steam purchased/generated for consumption (gigajoules, GJ) 6,736,753.490
Renewable fuel consumed (gigajoules, GJ) 0.000
Report energy owned and controlled by the organization sold in gigajoules and report the totals for each 8,979,792.050
Electricity sold  (gigajoules, GJ) 8,906,266.000
Heating sold (gigajoules, GJ) 0.000
Cooling sold  (gigajoules, GJ) 0.000
Steam sold (gigajoules, GJ) 73,526.050
Energy Management - Sherritt
Total energy consumed in aggregate, in gigajoules (GJ) (hydrocarbons and electricity) including the fuel types used (e.g., biomass, hydro-electric power or bioenergy) 7,439,874.000
Percentage energy consumed that was supplied by grid electricity 22.9360%
Percentage of energy consumed that was renewable energy (does not include purchased grid-mix) 0.0036%
Water - Sherritt
Reuse and recycle
Total volume of water that has been used in an operational task and is recovered and used again in an operational task, either without treatment (reuse) or with treatment (recycle) (megalitres) 8,811.110
Water Management
Disclose the amount of fresh water that was consumed in its operations (in thousands of cubic meters) 17,275.224
Analyse 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 Does not apply for Energas and Moa Nickel operations. Both these operations do not interact with water bodies classified as being in High or Extremely High Water Stress locations as defined by the WRI Water Risk Atlas tool, Aqueduct.

In 2024, due to drought conditions in the region, the North Saskatchewan River was classified with High Water Stress. Raw water is withdrawn from the North Saskatchewan River by the Fort Site for various onsite uses, such as process water, cooling water, fire water, and boiler feed water. Water withdrawal by the Fort Site is permitted and within Licence parameters.

Please note that this is a conservative calculation as the water stress designation for the North Saskatchewan River varies throughout the year and historical data is not provided by the WRI Water Risk Atlas tool.
Disclose water withdrawn in locations with High or Extremely High Baseline Water Stress (in thousands of cubic meters) 2,610.700
Total water consumed in locations with high or extremely high baseline water stress (in thousands of cubic meters) 1,536.140
Was your organization subject to any fines, enforcement orders, and/or other penalties for water-related regulatory violations No
Total number of incidents of non-compliance associated with water quality permits, standards, and regulations, including violations of a technology-based standard and exceedances of quality-based standards (note: only those that resulted in a formal enforcement
action(s))		 0
Total number of violations - continuous discharges, limitations, standards, and prohibitions that are generally expressed as maximum daily, weekly average, and monthly average (regardless of their measurement methodology or frequency) 0
Total number of violations - non-continuous discharges and limitations that are generally expressed in terms of frequency, total mass, maximum rate of discharge, and mass or concentration of specified pollutants (regardless of their measurement methodology or frequency) 0
Total number of violations - other, please specify 0
Water and Effluents - Sherritt
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)
 Sherritt's Water Management Standard requires all sites to implement a water monitoring program that addresses surface water and groundwater, in where both water quality and water quantity monitoring parameters have been informed by identified risks. The Standard dictates that sites are required to maintain records of facility-level water quality and quantity data and to conduct regular trend analyses to inform iterative water management decision making processes.
Describe the approach used to identify water-related impacts, including the scope of assessments, their timeframe, and any tools or methodologies used
 Sherritt’s Water Management Standard requires sites to identify and assess facility-level risks related to surface water and groundwater. Sites are required to establish water performance objectives that include controls, response and contingency plans, and monitoring for the relevant water risks. Where relevant, sites are required to identify and engage with relevant water-related stakeholders to better understand how they use water resources, including water-related local practices, beliefs, customs and traditional knowledge in the case that water-related impacts arise.
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
 Water management at each of our sites is informed by site specific requirements and the application of overarching principles contained within Sherritt's Water Management Standard. At all sites, water management is a cooperative effort between Sherritt and the appropriate regulatory agencies.
Water Withdrawal by Segment
Total water withdrawn by segment, in megalitres (ML) 21,433.750
Surface water (total in ML) 18,199.870
Freshwater (≤1,000 mg/L Total Dissolved Solids or TDS) 18,199.870
Other water (>1,000 mg/L Total Dissolved Solids or TDS) 0.000
Groundwater (total in ML) 78.050
Freshwater (≤1,000 mg/L Total Dissolved Solids or TDS) 3.900
Other water (>1,000 mg/L Total Dissolved Solids or TDS) 74.150
Seawater (total in ML) 2,448.000
Produced water (total in ML)
 0.000
Freshwater (≤1,000 mg/L Total Dissolved Solids or TDS) 0.000
Other water (>1,000 mg/L Total Dissolved Solids or TDS) 0.000
Third-party water (total in ML)
 707.830
Freshwater (≤1,000 mg/L Total Dissolved Solids or TDS) 707.830
Other water (>1,000 mg/L Total Dissolved Solids or TDS) 0.000
Report on the total water withdrawal from all areas with water stress in megalitres (ML), and a breakdown of this total by the following sources 2,514.020
Surface water (total in ML)
 2,499.870
Freshwater (≤1,000 mg/L Total Dissolved Solids or TDS) 2,499.870
Other water (>1,000 mg/L Total Dissolved Solids or TDS) 0.000
Groundwater (total in ML) 14.150
Freshwater (≤1,000 mg/L Total Dissolved Solids or TDS) 0.000
Other water (>1,000 mg/L Total Dissolved Solids or TDS) 14.150
Seawater (total in ML) 0.000
Water Consumption
Report the total water consumption from all areas in megalitres 17,275.224
Report the total water consumption from all areas with water stress in megalitres 1,536.140
Water Discharge
Report the total water discharge to all areas (in megalitres) 3,320.560
Surface water 1,074.560
Freshwater (≤1,000 mg/L Total Dissolved Solids or TDS) 1,074.560
Other water (>1,000 mg/L Total Dissolved Solids or TDS) 0.000
Groundwater
 165.000
Freshwater (≤1,000 mg/L Total Dissolved Solids or TDS) 165.000
Other water (>1,000 mg/L Total Dissolved Solids or TDS) 0.000
Seawater 2,081.000
Waste - Sherritt
Waste Generation and Significant Waste-Related Impacts
Describe the inputs, activities, and outputs that lead or could lead to significant actual and potential waste-related impacts Refer to Sherritt's 2024 Tailings Management Report.

There are no tailings facilities, and therefore no tailings-related waste produced, at any of the Energas sites or at the Fort Site.

Tailings-related waste is only produced at the Moa Nickel Site.
Report the total amounts of waste generated of the following and associated risks (tonnes) 4,775,332.000
Overburden amount (tonnes) 1,305,614.000
Rock amount (tonnes) 340,219.000
Tailings amount (tonnes) 3,129,499.000
Waste Generated
Report the total weight of waste generated (tonnes) 3,979.970
Total waste composition breakdown - Organization's own activities (tonnes) 3,979.970
Type of waste
Hazardous waste (tonnes) 2,036.750
Non-Hazardous waste (tonnes) 1,943.220
Waste Diverted from Disposal
Total weight of waste diverted from disposal (tonnes) 1,097.69
Total weight of hazardous waste diverted from disposal (tonnes), and a breakdown of this total by the following recovery operations 2.65
Preparation for reuse (total, tonnes) 0
Preparation for reuse - Onsite 0
Preparation for reuse - Offsite 0
Recycling (total, tonnes) 0.4
Recycling - Onsite 0
Recycling - Offsite 0.4
Other recovery operations (total, tonnes) 2.25
Other recovery operations - Onsite 0
Other recovery operations - Offsite 2.25
Report the total weight of non-hazardous waste diverted from disposal (tonnes), and a breakdown of this total by the following recovery operations 1,095.04
Preparation for reuse (total, tonnes) 0
Preparation for reuse - Onsite 0
Preparation for reuse - Offsite 0
Recycling (total, tonnes) 1,095.04
Recycling - Onsite 0
Recycling - Offsite 1,095.04
Other recovery operations (total, tonnes) 0
Other recovery operations - Onsite 0
Other recovery operations - Offsite 0
Waste Directed to Disposal
Report the total weight of waste directed to disposal (tonnes) 3,286.55
Total weight of hazardous waste directed to disposal (tonnes), and a breakdown of this total by the following recovery operations 2,036.53
Incineration (with energy recovery), (tonnes) 0
Incineration (with energy recovery) - Onsite 0
Incineration (with energy recovery) - Offsite 0
Incineration (without energy recovery), (tonnes) 1
Incineration (without energy recovery) - Onsite 0
Incineration (without energy recovery) - Offsite 1
Landfilling (total, tonnes) 2,033.28
Landfilling - Onsite 0
Landfilling - Offsite 2,033.28
Other recovery operations (total, tonnes) 2.25
Other recovery operations - Onsite 0
Other recovery operations - Offsite 2.25
Report the total weight of non-hazardous waste directed to disposal (tonnes), and a breakdown of this total by the following recovery operations 1,250.02
Incineration (with energy recovery), (tonnes) 0
Incineration (with energy recovery) - Onsite 0
Incineration (with energy recovery) - Offsite 0
Incineration (without energy recovery), (tonnes) 0
Incineration (without energy recovery) - Onsite 0
Incineration (without energy recovery) - Offsite 0
Landfilling (total, tonnes) 1,250.02
Landfilling - Onsite 0
Landfilling - Offsite 1,250.02
Other disposal operations (total, tonnes) 0
Other disposal operations - Onsite 0
Other disposal operations - Offsite 0
Waste Management - Sherritt
Disclose the total weight of tailings produced (tonnes) 3,129,499.000
Disclose the total amount of waste rock generated (tonnes) 340,219.000
Disclose the total amount of overburden removed (tonnes) 1,305,614.000
There are no tailings facilities, and therefore no tailings-related waste produced, at any of the Energas sites or at the Fort Site.

Tailings-related waste is only produced at the Moa Nickel Site.
Describe the policies and procedures that are set forth by the company's waste and hazardous materials management strategy Sherritt has developed several guidance documents to direct site-based employees on the management of waste including a Waste Management Process, Waste Process Manual, Hazardous Waste Manifest Procedure and an Annual Waste Report Procedure.
Describe how its policies and procedures compare with those required by local jurisdictions that apply to the entity Sherritt policies and procedures meet or exceed all applicable local, provincial or national waste regulations.
Describe how waste and hazardous materials management efforts are coordinated among business partners (e.g., contractors and subcontractors) Sherritt's Waste Management Standard requires sites to provide training to relevant employees and contractors in accordance with their roles and responsibilities.
Tailings Storage Facilities Management
Does your company manage Tailings Storage Facilities Yes
There are no tailings facilities at any of the Energas sites or at the Fort Site.

There are only tailings facilities at the Moa Nickel Site.
Provide an inventory of all tailings storage facilities (TSFs):
TSF #1: (1) Facility name Acid Leach Tailings Facility
TSF #1: (2) Location Cuba
TSF #1: (3) Ownership status Moa Joint Venture
TSF #1: (4) Operational status Care and maintenance
TSF #1: (5) Construction method upstream
TSF #1: (6) Maximum permitted storage capacity (tonnes) 53,700,000.000
TSF #1: (7) Current amount of tailings stored (tonnes) 53,700,000.000
TSF #1: (8) Consequence classification Significant
TSF #1: (9) Date of most recent independent technical review 2024-12-05
TSF #1: (12) Site-specific EPRP Yes
TSF #2: (1) Facility name North Extension
TSF #2: (2) Location Cuba
TSF #2: (3) Ownership status Moa Joint Venture
TSF #2: (4) Operational status Care and maintenance
TSF #2: (5) Construction method upstream
TSF #2: (6) Maximum permitted storage capacity (tonnes) 13,070,137.000
TSF #2: (7) Current amount of tailings stored (tonnes) 13,070,137.000
TSF #2: (8) Consequence classification Significant
TSF #2: (9) Date of most recent independent technical review 2024-12-05
TSF #2: (12) Site-specific EPRP Yes
TSF #3: (1) Facility name Area 22
TSF #3: (2) Location Cuba
TSF #3: (3) Ownership status Moa Joint Venture
TSF #3: (4) Operational status Operating
TSF #3: (5) Construction method centreline
TSF #3: (6) Maximum permitted storage capacity (tonnes) 19,185,127.000
TSF #3: (7) Current amount of tailings stored (tonnes) 12,779,729.000
TSF #3: (8) Consequence classification Significant
TSF #3: (9) Date of most recent independent technical review 2024-12-05
TSF #3: (12) Site-specific EPRP Yes
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 Piezometer readings, settlement monuments, and other technologies are used to monitor tailings dams, abutments, natural slopes and water levels.
Provide summary of tailings management systems and governance structure used to monitor and maintain the stability of tailings storage facilities The tailings management systems and governance structure used to monitor and maintain the stability of tailings storage facilities are summarized in Sherritt's 2024 Tailings Management Report. Each TSF is monitored regularly by the tailings management teams and Engineer of Record for safety and stability. Instrumentation such as piezometers and settlement monuments are reviewed as part of those assessments.
Disclose the approach to the development of Emergency Preparedness and Response Plans (EPRPs) Emergency Preparedness and Response Plans (EPRPs) are developed along with the Operations Maintenance and Surveillance (OMS) manual every two years or when a major facility change occurs. EPRPs are prepared by the Engineer on Record and the Tailings Dam Team. The initial draft is sent for peer revision and the final version is sent to Moa Nickel Directors and Sub-Directors for revision and commentaries. Finally, this document is sent to local authorities for approval.

The EPRP is currently being updating by GEOCUBA and Moa Nickel. The update includes the fourth stage of A22. The surrounding population will be informed and trained on the new actions. In addition, a new alarm system will be installed in the future.
Disclose the company's approach to engagement concerning  Emergency Preparedness and Response Plans (EPRPs) at tailings storage facilities, including the preparedness of local stakeholders EPRPs and the OMS are designed to account for the close proximity between the tailings facilities and the surrounding community of La Veguita. Two major safety campaigns are implemented annually to engage the local population and warn them of the potential risk of living near tailings facilities. Tailings dam personnel are also trained in these areas throughout the year and during their safety inductions and training.
Biodiversity - Sherritt
Management Plan
Disclose the approach to biodiversity management Sherritt is committed to identifying, managing, protecting, and conserving biodiversity. Our Biodiversity Management Standard is designed to meet all the Level A requirements of the TSM Biodiversity Conservation Management Protocol. 

To achieve implementation of our Biodiversity Management Standard, operating sites are required to develop a site level biodiversity action plan that assesses potential impacts or risks to biodiversity and identifies specific objectives or targets for significant biodiversity aspects. These biodiversity action plans include considerations such as local ecological knowledge, identification of any no-go or buffer zones near key areas, and monitoring and evaluation mechanisms.  Action plans are designed to address legal and corporate obligations (including those related to closure and post-closure) and align with existing regional initiatives, where possible.
TSM Biodiversity Conservation Management Protocol
Describe significant impacts of activities, products and services on biodiversity in protected areas and areas of high biodiversity value outside protected areas
 Does not apply. Project footprints do not overlap with protected areas and areas of high biodiversity value outside protected areas.
Describe the environmental and biodiversity management plan(s) implemented at active sites Biodiversity Conservation Management Plan
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) Mining Association of Canada - Towards Sustainable Mining: Biodiversity Conservation Management Protocol
Impacts
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) 1,088.430
Total amount of land newly disturbed within the reporting period (B) 58.750
Total amount of land newly rehabilitated within the reporting period to the agreed end use (C) 40.000
Total land disturbed and not yet rehabilitated (D= A+B-C; closing balance) 1,107.180
Social
Scale of the Organization - Sherritt
Direct Employee Information
Total number of permanent employees (full-time & part-time) 746
Permanent employees - Male 563
Permanent employees - Female 181
Permanent employees -Non-binary 2
Total number of temporary employees (full-time & part-time) 38
Temporary employees - Male 34
Temporary employees - Female 4
Total number of direct employees (includes full-time permanent, part-time permanent, temporary; exclude workers who are not employees) 784
Direct employees - Male 597
Direct employees - Female 185
Direct employees - Non-binary 2
Workers Who are Not Employees
Total number of workers who are not employees - Male (full-time, part-time) 2,355
Total number of workers who are not employees - Female (full-time, part-time) 236
Total number of workers who are not employees - Gender not disclosed (full-time, part-time) 14
Total number of workers who are not employees and whose work is controlled by the organization (e.g., suppliers, customers, or other business partners, such as in joint
ventures)		 2,605
The Cuban workforce is supplied by two state employment contractors. All contractors are under Sherritt and its partners' duty of care, but Cuban nationals are not hired directly by Sherritt.
Total Workforce
Total workforce (includes direct employees and workers who are not employees) 3,389
Total female workforce 421
Female workforce as percentage of total employed workforce 12.4225%
Total male workforce 2,952
Male workforce as percentage of total employed workforce 87.1053%
Total non-binary workforce 2
Non-binary workforce as percentage of total employed workforce 0.2506%
Total workforce with gender not disclosed 14
Workforce with gender not disclosed as percentage of total employed workforce 1.7544%
Workers who are not employees (contractors) as percentage of total employed workforce 76.8663%
Employment - Sherritt
Turnover & Gender Breakdown
Female direct employees:
Total number of turnover (the number of females that left during the period) 50
Male direct employees:
Total number of turnover (the number of males that left during the period) 130
Non-binary direct employees:
Total number of turnover (the number non-binary that left during the period) 0
Report the total number and rate of turnover for all Direct Employees:
Total number of turnover (the number that left during the period) 180
Voluntary Turnover - direct employees:
Total number of turnover (the number that left voluntarily during the period) 102
Involuntary Turnover - direct employees:
Total number of turnover (the number that left involuntarily during the period) 78
Turnover & Age Breakdown
Direct Employees aged 30 years old and under:
Total number of turnover (the number that left during the period) 29
Direct Employees aged between 30 and 50 years old:
Total number of turnover (the number that left during the period) 91
Direct Employees over 50 years old:
Total number of turnover (the number that left during the period) 60
Identify types of employees captured in the turnover rate calculations All employees on the payroll
New Hires and Rate of Hire
Total number and rate of new hires: All direct employees
Total hires during the reporting period 66
Rate of hire 8.4184%
Total number and rate of new hires: Direct Female employees
Total female hires during the reporting period 12
Females as percent of total new hires 18.1818%
Total number and rate of new hires: Direct Male employees
Total males hires during the reporting period 54
Males as percent of total new hires 81.8182%
Total number and rate of new hires: Direct Employees aged 30 years old and under
Total hires during the reporting period (30 yr. and under) 22
30 yr. and under as percent of total new hires 33.3333%
Total number and rate of new hires: Direct Employees aged between 30 and 50 years old
Total hires during the reporting period (30-50 yrs.) 28
30-50 yrs. as percent of total new hires 42.4242%
Total number and rate of new hires: Direct Employees over 50 years old
Total hires during the reporting period (50+ yrs.) 16
 50+ yrs. as percent of total new hires 24.2424%
Labour Relations - Sherritt
Collective Bargaining Agreements
Percentage of total direct employees covered by collective bargaining agreements (%) 41.5816%
This number applies only to employees at the Fort Site as this is the only site that is unionized under Sherritt's direct supervision. All local Cuban nationals, identified as contractors in Sherritt's workforce, at Energas and Moa Nickel may be covered under a collective bargaining agreement or agreements, but these agreements are not facilitated by Sherritt.
Disclose the number 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:
Number of lock-outs exceeding one week 0
Number of strikes exceeding one week 0
Occupational Health and Safety - Sherritt
Work-related Injuries
Injuries - direct employees:
Number of fatalities as a result of work-related injury 0
Rate of fatalities resulting from work-related injury. Note: calculating per 200,000 hours worked 0.000
Number of high-consequence work-related injuries (excluding fatalities) 0
Rate of high-consequence work-related injuries (excluding fatalities) 0.000
Number of recordable work-related injuries 45
Total recordable work-related injuries rate 1.366
Number of hours worked 6,587,573
Lost Time Injuries (LTIs) 40
Lost Time Injury Rate (LTIR) 1.214
Fatality rate for work-related fatalities - direct employees 0.000
Number of fatalities - direct employees 0
Injuries - workers who are not employees, but whose work and/or workplace is controlled by the organization:
Number of fatalities as a result of work-related injury 0
Rate of fatalities resulting from work-related injury. Note: calculating per 200,000 hours worked 0.000
Number of high-consequence work-related injuries (excluding fatalities) 0
Rate of high-consequence work-related injuries (excluding fatalities) 0.000
Number of recordable work-related injuries 9
Total recordable work-related injuries rate 1.024
Number of hours worked 1,757,264
Lost Time Injuries (LTIs) 5
Lost Time Injury Rate (LTIR) 0.569
Fatality rate for work-related fatalities - workers who are not employees 0.000
Number of fatalities - workers who are not employees 0
Combined (Employees and non-employees, but controlled by the organization):
Total Hours Worked 8,344,837
Total number of all recordable work-related injuries 54
Total recordable work-related injuries rate 1.294
Total Lost Time Injuries (LTIs) 45
Lost Time Injury Rate (LTIR) 1.079
Fatality rate for work-related fatalities - Combined (Employees and non-employees, but controlled by the organization) 0.000
Number of fatalities - Combined (Employees and non-employees, but controlled by the organization) 0
Have rates been calculated based on 200,000 or 1,000,000 hours worked 200,000 hours worked
Were any workers excluded from this disclosure No
Child Labour - Sherritt
Operations and Suppliers At Risk
Are there operations or suppliers considered to have significant risk for incidents of child labour No
Forced or Compulsory Labour - Sherritt
Operations and Suppliers At Risk
Operations considered to have significant risk for incidents of forced or compulsory labor either in terms of type of operation, or countries or geographic areas with operations considered at risk Does not apply.
Countries or geographic areas with operations considered at risk None
Suppliers considered to have significant risk for incidents of child labor either in terms of type of supplier, or countries or geographic areas with suppliers considered at risk Does not apply.
Countries or geographic areas with suppliers considered at risk None
Measures taken by the organization in the reporting period intended to contribute to the elimination of all forms of forced or compulsory labour Sherritt has an established a Human Rights Policy alongside a Child and Forced Labour Standard that stipulate a strict prohibition of any use of child and forced labour in its own operations or supply chain. In 2024, a Conflict-Affected and High Risk Area assessment was completed and follow-up due diligence assessment at Moa Nickel. There is no child or forced labour or other high risks in Sherritt's mineral supply chain. More information is available on Sherritt's Sustainability website.
Sherritt Sustainability

Human Rights Policy
Conflict-affected and high-risk areas - Sherritt
Adherence to Laws and Due Diligence
List the locations of operations in conflict-affected or high-risk areas None of our operations are located in conflict-affected or high-risk areas.
Describe the due diligence process applied for operations in, or when sourcing from, conflict-affected and high-risk areas and Refer to Sherritt's 2024 Responsible Production and Supply Report.
Did the due diligence process align with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas Yes
Security, Human Rights and Rights of Indigenous People - Sherritt
Discuss the practices and procedures while operating in areas of conflict, describing the approach according to the Five-Step Framework outlined in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas Sherritt does not operate in areas of conflict as per the World Bank's list of Fragile and Conflict-Affected Situations.
Human Rights Assessment - Sherritt
Operations Subject to Reviews and Assessments
Total number of operations that have been subject to human rights reviews or human rights impact assessments 2
Total percentage of operations that have been subject to human rights reviews or human rights impact assessments 66.6667%
Provide details about any human rights conducted assessments Of the three operations (the Fort Site, Moa Nickel and Energas), both the Fort Site and Moa Nickel have undergone annual Conflict Affected and High-Risk Area evaluations from 2019 up to and including 2024, which are based on the Responsible Minerals Assurance Process and grounded in the OECD Due Diligence Guidance. More information is available on Sherritt's Sustainability website and in Sherritt's 2024 Responsible Production and Supply Report.
Sherritt Sustainability
Local Communities - Sherritt
Operations with Local Community
Significant disputes relating to land use, customary rights of local communities and indigenous peoples Does not apply.
Number of significant disputes relating to land use, customary rights of local communities and indigenous peoples 0
Description of significant disputes relating to land use, customary rights of local communities and indigenous peoples Does not apply.
The extent to which grievance mechanisms were used to resolve disputes relating to land use, customary rights of local communities and indigenous peoples, as well as the outcomes Does not apply.
Community Relations - Sherritt
Artisanal and Small-Scale Mining (ASM)
Describe the approach to engaging with ASM operators, and the actions taken by the organization to support ASM formalization and professionalization efforts Not Applicable. Sherritt does not operate sites where artisanal and small-scale mining takes place on, or adjacent to the site.
List the mine sites where ASM occurs on or in close proximity to the site None.
Report the total number and nature of incidents involving ASM and actions taken to address them 0 incidents.
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 0.0000%
Risks and Opportunities
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
No site shutdowns occurred to non-technical factors during 2024 across the entire organization.
Indirect Economic Impacts - Sherritt
Infrastructure Investments and Services Supported
Was a community assessment conducted to determine the need for infrastructure and services Yes
What is the extent of development of significant infrastructure investments and services supported
 In Cuba, Sherritt donated to externally-run projects that supported road safety initiatives and renewable energy projects in rural areas. Sherritt also supported local hospitals and care facilities through the donation of kidney dialysis equipment to the health care system in the municipality of Moa.

In Canada, Sherritt supported services including several Indigenous organizations, food banks, women's shelters, skills training for women, a children's hospital foundation, addiction outreach programs and many others.

Refer to Sherritt's 2024 Sustainability Report for more information.
What is the current or expected positive impacts on communities and local economies Significant indirect economic impact, particularly through the indirect effects of employment, economic development, skills developments, and community benefits.

In 2024, Sherritt invested >CAD$690,000 in local communities. 100% of community-based donations were intended to align with local community needs.
What are the types of investments and provide descriptions
  • Commercial engagement
  • In-kind engagement
Indirect Economic Impacts
Significant Indirect Economic Impacts
Provide 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)
  • 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)
Provide examples of significant negative indirect economic impacts of the organization Not Applicable
Governance
Delegation of responsibility for managing impacts
Has the highest governance body appointed any senior executives with responsibility for the management of organization’s impacts on the economy, environment and people (e.g., is it part of the Governance structure of the company, CEO's role, CFO's role, Sustainability Executive, etc.) Yes
Has the highest governance body delegated responsibility for the management of impacts to other employees Yes
Describe the process for senior executives or other employees to report back to the highest governance body on the management of the organization’s impacts on the economy, environment and people, including sustainability-related risks and opportunities The Reserves, Operations, Capital and Sustainability (ROCS) Committee, previously the Reserves, Operations and Capital Committee, is the primary Board committee charged with setting and monitoring implementation of ESG priorities and approving policies and actions identified by the ESG Steering Group and ESG Working Group. The ROCS Committee meets at least four times per year, visits our operating sites (physically, or when not so permitted, virtually), and receives information from corporate and divisional management quarterly, and more often when required.
Frequency for senior executives or other employees to report back to the highest governance body on the management of the organization’s impacts Quarterly
Policy commitments
Provide a description of the organization’s policy commitments for responsible business conduct Sherritt is committed to producing and supplying minerals that meet industry best practices for sustainability and human rights, and to advancing that commitment with its joint venture partners, subsidiaries, and their suppliers and customers. Sherritt’s Responsible Production and Supply Policy and Human Rights Policy identify our commitments, and our Mineral Supplier Code of Conduct identifies expectations for suppliers and due diligence processes to be followed to ensure any human rights risks in our mineral supply chain are identified and mitigated. Sherritt's corporate-wide Business Ethics Policy and Anti-Corruption Policy provide clear guidance to our workforce on what it means to act with integrity. These policies cover conflicts of interest, fraud and corruption, fair dealings, protection and proper use of the Corporation's assets, compliance with regulatory requirements, disclosure, confidentiality, and reporting mechanisms available to employees and contractors.
Responsible Production and Supply Policy

Human Rights Policy

Mineral Supplier Code of Conduct

Anti-Corruption Policy
Governance structure and composition
Describe the governance structure, 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.) Refer to Sherritt's 2024 Annual Information Form and 2025 Management Information Circular.
2024 Annual Information Form

2024 Management Information Circular
Identify and list the committees of the highest governance body that are responsible for decision making and overseeing the management of the organization’s impacts on the economy, environment and people including the oversight of sustainability-related risks and opportunities (e.g. Board level Environment Committee, Safety Committee, ESG Committee, Advisory Committee, etc.) The Board of Directors and the Reserves, Operations, Capital and Sustainability Committee, previously the Reserves, Operations and Capital Committee and the Audit Committee of the Board.
Describe the composition of the highest governance body and its committees by:
Number of  executive members (non-independent)
 1
Number of non-executive members (non-independent) 0
Number of independent members 6
The total number of governance body members 7
Percentage of independent board members 85.7143%
Less than 3 years of tenure of members on the governance body 4
3-6 years of tenure of members on the governance body 2
6-9 years of tenure of members on the governance body 0
More than 10 years of tenure of members on the governance body 1
Number of other significant positions and commitments held by each member, and the nature of the commitments Refer to Sherritt's 2024 Management Information Circular.
Number of Male governance body members 4
Number of Female governance body members 3
Description of competencies relating to economic, environmental, and social topics Refer to Sherritt's 2024 Management Information Circular.
Chair of the highest governance body
Is the chair of the highest governance body also a senior executive in the organization (non-independent) No
For the reporting period the chair of the highest governance body was not a senior executive in the organization (independent). At the time of report issuance, the chair of the highest governance body is also a senior executive in the organization (non-independent).
Conflicts of Interest
Describe the processes for the highest governance body to ensure that conflicts of interest are prevented and mitigated Sherritt's Business Ethics Policy and Anti-Corruption Policy provide clear guidance to our workforce on what it means to act with integrity. These policies cover conflicts of interest, fraud and corruption, fair dealings, protection and proper use of the Corporation's assets, compliance with regulatory requirements, disclosure, confidentiality, and reporting mechanisms available to employees and contractors. Our Business Ethics Policy is not available publicly but may be provided upon request.
Anti-Corruption Policy
Are conflicts of interest disclosed to stakeholders Yes
Are there conflicts of interest related to: cross-board membership Yes
Are there conflicts of interest related to: cross-shareholding with suppliers and other stakeholders No
Are there conflicts of interest related to: existence of controlling shareholder No
Are there conflicts of interest related to: related parties, their relationships, transactions, and outstanding balances No
Collective knowledge of highest governance body
Report measures taken to advance the collective knowledge, skills and experience of the highest governance body on sustainable development. (e.g. board training) Refer to Sherritt's 2024 Management Information Circular.
2024 Management Information Circular
Evaluation of Highest Governance Body
Describe the processes for evaluating the performance of the highest governance body in overseeing the management of the organization’s impacts on the economy, environment and people Refer to Sherritt's 2024 Management Information Circular.
Transparency
Describe the role of the highest governance body and of senior executives in developing, approving and updating the organization’s purpose, value or mission statements, strategies, policies and goals related to sustainable development Refer to Sherritt's 2024 Management Information Circular.
Describe the role of the highest governance body in overseeing the organization’s due diligence and other processes to identify and manage the organization’s impacts on the economy, environment and people Refer to Sherritt's 2024 Management Information Circular.
Does the highest governance body engage with stakeholders to support due diligence and other processes No
In 2024, external stakeholder input on material topics was not sought, however this information may be gathered in future reporting years.
Ethics
Ethics and Integrity
Describe how individuals can seek advice on implementing the organization’s policies and practices for responsible business conduct Sherritt has a Whistleblower Policy that indicates that any person submitting a reportable concern may choose to do so anonymously and confidentially through the Whistleblower Hotline maintained by the Corporation's designated external service provider. Reportable concerns may be submitted by any of the Corporation’s stakeholders including employees, contractors, directors, officers, vendors, and others. Mechanisms for individuals to seek advice on implementing the organization's policies and practices for responsible business conduct include accessing Investor Relations at investor@sherritt.com and/or through Sherritt's Whistleblower mechanism.
Describe the mechanisms for individuals to raise concerns about the organization’s business conduct Sherritt has a Whistleblower Policy and grievance mechanism that allow any person, anywhere in the value chain, to submit a reportable concern. The mechanism is confidential, independent, easily accessible to all community members, allows for anonymity and does not create internal conflict of interest or risk of retribution. The system maintained by the Corporation’s designated external service provider:

1. Online: https://www.clearviewconnects.com/home
2. Skype Audio Reporting: clearview-sherritt
3. Telephone:
• Toll-free (North America): +1-866-840-8702
• Long distance: +1-416-386-5397

For concerns related to the Fort Site in Fort Saskatchewan, Alberta, please call +1-780-992-7000.
Reportable Concerns
Ethics - Sherritt
Compliance with laws and regulations
Report the total number of significant instances of non-compliance with laws and regulations that occurred during the reporting period and a breakdown of this total by 0
Number of instances for which fines were incurred 0
Number of instances for which non-monetary sanctions were incurred 0
Report the total number of fines for instances of non-compliance with laws and regulations that were paid during the reporting period 0
Report the monetary value of fines for instances of noncompliance with laws and regulations that were paid during the reporting period (currency, Thousands) 0
Total number of fines paid for instances of non-compliance with laws and regulations that occurred in the current reporting period 0
Total monetary value of fines for instances of non-compliance with laws and regulations that occurred in the current reporting period (currency, Thousands) 0
Total number of fines paid for instances of non-compliance with laws and regulations that occurred in previous reporting periods 0
Total monetary value of fines for instances of non-compliance with laws and regulations that occurred in previous reporting periods (currency, Thousands) 0
Describe the significant instances of non-compliance Does not apply. All operations are in compliance.
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 Anti-Corruption Policy
Business Ethics Policy
Report net production from activities located in the countries with the 20 lowest rankings in Transparency International’s Corruption Perception Index (CPI) (saleable tonnes, bbls, oz, lb, etc.) 0
Highest Review Position
 Is the highest governance body responsible for reviewing and approving the reported information, including the organization’s material topics Yes
Describe the process for reviewing and approving the reported information The Reserves Operations, Capital and Sustainability Committee of the Board of Directors reviews and approves all reported information, including the organization's material topics. The process involves reviewing all draft manuscripts and data, internal assurance measures, and regulated disclosure topics. Once approvals are secured by the Committee, the COO completes a final approval in the information system.
Communication of critical concerns
Are critical concerns communicated to the highest governance body Yes
Describe how critical concerns are communicated to the highest governance body Critical concerns are reported through quarterly reports.
Report the number of critical concerns that were communicated to the highest governance body during the reporting period 0
Report the nature of critical concerns that were communicated to the highest governance body during the reporting period Not applicable. No critical concerns were communicated to the highest governance body.
Remuneration
Report which of the following remuneration policies apply to the highest governance body and senior executives and provide details:
Fixed pay Yes
Variable pay Yes
Performance-based pay Yes
Deferred and vested shares Yes
Describe how the remuneration policies for members of the highest governance body and senior executives relate to their objectives and performance in relation to the management of the organization’s impacts on the economy, environment and people Refer to Sherritt's 2024 Management Information Circular.
2024 Management Information Circular
Do you provide incentives for the management of climate-related issues, including the attainment of targets No, not currently but we plan to introduce them in the next two years
Describe the process for designing remuneration policies Refer to Sherritt's 2024 Management Information Circular.
Describe the process for determining remuneration Refer to Sherritt's 2024 Management Information Circular.
How the views of stakeholders (including shareholders) regarding remuneration are sought and taken into consideration Refer to Sherritt's 2024 Management Information Circular.
Are remuneration consultants involved in determining remuneration
 Yes
Are remuneration consultants independent of the organization, the highest governance body and senior executives Yes
Stakeholder Engagement
Describe the organization’s approach to stakeholder engagement, including frequency of engagement by type Consultation on economic, environmental, and social topics is delegated to the most senior executive responsible for that function or activity. The resulting feedback is provided to the Board of Directors, as applicable and appropriate, in quarterly reports.
Provide a list of stakeholder groups engaged by the organization Other
Government of Canada, Cuban Government, Cuban JV Partners, UNICEF Associations, Investment Community, International Finance Institutions, Insurers, Sustainability Rating Bodies, Local Community Organizations, Industry Associations, Employees, Contractors, Peers, Customers.
Report the basis for identifying and selecting stakeholders with whom to engage The basis for identifying and selecting stakeholders with whom to engage includes dependency/interest and ability to influence.
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
Main outcomes of completed legal actions, including any decisions or judgments Does not apply. No legal actions completed during the reporting period.
Tax
Does the organization have a tax strategy Yes
The governance body or the executive level position within the organization that formally reviews and approves the tax strategy The Corporation's Chief Financial Officer (CFO) has overall responsibility for the oversight of the tax policy and operating principles. The CFO reports to the Audit Committee on the Corporation's tax status on an annual basis or more frequently if necessary, including material tax issues and risks, reviews by tax authorities, and the overall tax strategy.
The frequency of formal review and approval of the tax strategy by the governance body or executive-level position within the organization Annually
The approach to regulatory compliance a) To comply fully with all relevant laws and regulations, giving due consideration to the Corporation's reputation, brand and social responsibilities when considering tax initiatives.

b) Where tax law is unclear or subject to interpretation, obtaining written advice or confirmation is considered to support the position adopted.

c) Obtaining external advice or confirmation is considered where the financial impact is material to the Group.
How the approach to tax is linked to the business and sustainable development strategies of the organization Linkage with regulatory compliance, business ethics and community benefit contributions.
Provide a description of the tax governance and control framework
The governance body or executive-level position within the organization accountable for compliance with the tax strategy The Corporation's CFO has overall responsibility for the oversight of the tax policy and operating principles. The governance body is the Audit Committee of the Board of Directors.
How the approach to tax is embedded within the organization Considerable involvement of Corporation's Tax Group in treasury, finance, legal and operational transactions.
The approach to tax risks, including how risks are identified, managed, and monitored a) Corporation maintains a low threshold for tax risk and aims for certainty on tax positions it adopts.            

b) Ensures that all tax positions are supported by a strong risk assessment.
How compliance with the tax governance and control framework is evaluated The Corporation has an internal audit function that evaluates and formally reports to management and the Audit Committee on the adequacy and effectiveness of internal controls as specified in the approved annual internal audit plan. Accordingly, external auditors are engaged to conduct annual reviews of the tax department’s compliance with the tax governance and control framework to evaluate performance of internal controls in all tax procedures and processes.
Provide a description of the mechanisms for reporting concerns about unethical or unlawful behaviour and the organization’s integrity in relation to tax
 Sherritt has a Whistleblower Policy and grievance mechanism that allows any person anywhere in the value chain to submit a reportable concern anonymously and confidentially through the system maintained by the Corporation's designated external service provider. Contact details for reporting any concerns are available at the link below.
Reportable Concerns
Provide a description of the assurance process for disclosures on tax and, if applicable, a reference to the assurance report, statement, or opinion Management is responsible for establishing and maintaining adequate internal control over disclosure controls and procedures, as defined in National Instrument 52-109 of the Canadian Securities Commission (NI 52-109). Disclosure controls and procedures are designed to provide reasonable assurance that all relevant information is gathered and reported to management, including the CEO and CFO, on a timely basis so that appropriate decisions can be made regarding public disclosure. Management, with the participation of the certifying officers, has evaluated the effectiveness of the design and operation, as of December 31, 2024, of the Corporation’s disclosure controls and procedures. Based on that evaluation, the certifying officers have concluded that such disclosure controls and procedures are effective and designed to ensure that material information known by others relating to the Corporation and its subsidiaries is provided to them.
Describe the approach to stakeholder engagement and management of stakeholder concerns related to tax
The approach to engagement with tax authorities a) Undertake all dealings with tax authorities, government officials, ministers and other third parties in a professional, courteous and timely manner.

b) Further, the tax function will aim to pro- actively manage the relationship with the tax authorities with the aim of minimizing the risk of challenge, dispute or damage to the Group’s reputation.  Should a dispute arise with a tax authority as to how the Tax law should be interpreted and applied, the Corporation's objective is to resolve any issue promptly in a professional manner. The tax function should consider seeking external advice and/or opinions where the financial impact is material to the Group and/or there is the potential for reputational risk to the Corporation.
The approach to public policy advocacy on tax Completed through public disclosures including the 2024 MD&A.
2024 MD&A
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