Wallbridge Mining Company Limited
2024  ESG Report
Published on  October 14, 2025
Wallbridge Mining Company Limited (the "Company") is focused on creating value through the exploration and sustainable development of gold projects in Quebec's Northern Abitibi region while respecting the environment and communities where it operates.  The Company holds a contiguous mineral property position that extends along the Detour-Fenelon gold trend.  The project is host to the Company's flagship PEA stage Fenelon Gold Project ("Fenelon"), and its earlier exploration stage Martiniere Gold Project ("Martiniere").

DISCLAIMER

This Environmental, Social, and Governance (“ESG”) Report (the "ESG Report") has been prepared by Wallbridge Mining Company Limited (“Wallbridge” or the “Company”) for informational purposes only. The information contained herein is based on data and assumptions believed to be accurate and reliable as of the date of publication. However, the Company makes no representation or warranty, express or implied, as to the completeness, accuracy, or timeliness of the information contained in this ESG Report.

Wallbridge’s disclosure, including that contained in this ESG Report, may contain forward-looking statements or information (collectively, "FLI") within the meaning of applicable Canadian securities legislation. FLI is based on expectations, estimates, projections and interpretations as of the date of this document.

FLI in this ESG Report may include, but is not limited to, statements regarding the Company’s ESG processes, performance, goals, commitments, strategies, expectations, and projections. For further information on
FLI contained in this and other Wallbridge disclosure, please refer to the disclaimers in the Company’s public documents and on its website.

This ESG Report does not constitute investment advice or a recommendation to buy or sell any securities of the Company and should not be relied upon as a basis for making investment decisions.

While the Company is committed to sustainable and responsible operating practices, the ESG metrics and frameworks referenced in this ESG Report are evolving and may not be directly comparable to those of other organizations. The ESG data and performance indicators contained herein are subject to continuous improvement and may be revised in future reports to reflect updated methodologies, more robust data collection, or changes in applicable standards and regulations.

Any third-party data or frameworks referenced in this ESG Report are the property of their respective owners and are used for informational purposes only. The Company disclaims any responsibility for the accuracy or completeness of such third-party information.

Information provided in this ESG Report is based on internal processes and assumptions, is not audited, may not conform to Generally Accepted Accounting Principles (“GAAP“) and has not been approved by any regulatory or government authority.  Neither the Company nor any party involved in the creation of this ESG Report shall be liable for any inaccuracies or omissions or direct, indirect or consequential damages arising from the use of this information. The user assumes all risks associated with using the information contained herein.
 
Company Profile
Organizational Profile
Name Wallbridge Mining Company Limited
Describe nature of activities, brands, products and services Wallbridge is engaged in mineral exploration activities such as drilling, mapping, geophysical surveys, geochemical sampling and various studies  (including environmental baseline studies and permitting).
Link to Corporate Website https://wallbridgemining.com/
Industry Classification NAICS:
21222 Gold and silver ore mining
212220 Gold and silver ore mining

ISIC:
B0729 Mining of other non-ferrous metal ores
Type of Operations Mining Exploration
Company Headquarters Ontario, 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 Brian Penny, CPA, CMA
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
Describe your company's policy and practice for seeking external assurance, including whether and how the highest governance body and senior executives are involved Wallbridge engages independent third parties to review specific data sets where external expertise is required to ensure accuracy and reliability. At this time, Wallbridge has  not yet implemented a formal process for external assurance in line with the GRI Standards. However, the Company recognizes the importance of independent assurance in strengthening the credibility of our disclosures and are evaluating options to align with best practices. Oversight of ESG reporting rests with senior management and the Board of Directors, which will be directly involved in determining the scope and approach of future assurance activities.
Are the highest governance body and senior executives involved No
Not applicable
Has the report been externally assured No
Financial Reporting Period
Does the financial reporting period align with the sustainability reporting period (e.g. calendar vs fiscal) Yes
Geographic Scope of Report
Unless otherwise noted, the data in this report covers sustainability matters related to the following locations of operations Canada
Site map with GPS coordinates Map 2 - Location within Quebec
Identify notable exclusions of the geographical and/or business scope of the report, and reference of 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.) There are no notable exclusions.
Reporting Practice
Provide a list of all legal entities included in its sustainability reporting Wallbridge Mining Company Limited
Does the organization have audited consolidated financial statements or financial information filed on public record Yes
If the organization has audited consolidated financial statements or financial information filed on public record, specify the differences between the list of entities included in its financial reporting and the list included in its sustainability reporting None
Does the organization consist of multiple entities No
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 Kyle Levac
Environmental Superintendent
klevac@wallbridgemining.com
Market capitalization $0-$100Million CAD
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. The Company subscribes to the UL 2724 ECOLOGO® Certification for Suppliers of Mineral Exploration Industry Programme.
Scale of the Organization
Nature of corporate ownership Publicly owned
Legal form of corporate ownership Incorporated entity
Describe how the organization defines its "Operation" and the sector(s) in which it is active Wallbridge is engaged in mineral exploration activities in the Northern Abitibi Region such as drilling, mapping, geophysical surveys, geochemical sampling, project development activities,  environmental baseline studies and permitting at Fenelon and Martiniere.
Report the total number of operations 1
The organization's definition used for ‘mine site’ Site of exploration activities, including drilling and core review.
Mine site #1: Name of the site Detour-Fenelon Gold Trend Project
Mine site #1: Geographic location (country and coordinates) The coordinates for the Fenelon Gold Project are generally around 50°01′ N latitude, 78°37′ W longitude. This location in Quebec's Northern Abitibi region in Canada.
Mine site #1: Size (hectares) 83,100.000
Report the quantity of products or services provided during the reporting period and provide description (e.g. number of units produced, amount of primary commodity produced, number of services provided, etc.) None, we are still in the exploration stage.
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
Mineral Resource Types in Scope
Which of the following mineral resource types are covered by this report
  • Inferred
  • Indicated
Mineral Reserve Types in Scope
Which of the following mineral reserve types are covered by this report None
Strategy
Corporate Purpose, Vision, Mission and Values; statements of sustainability/ESG strategy COMPANY VISION

Vision: To be the leader in advancing quality gold projects in the Northern Abitibi that will generate future value for all stakeholders.



Our core values:
Caring
We care for our employees and the Communities in which we operate, fostering respect, collaboration, and sustainable practices.

Focus
We are dedicated to creating value through responsible mineral exploration and development that emphasizes safe, socially and environmentally sustainable practices in everything we do.

Inclusivity
We embrace diversity and foster growth, creating an inclusive environment where everyone can thrive and contribute to shared success.

Accountability
We take ownership of our actions, commit to excellence, and deliver meaningful results in line with our values.

Integrity
We act with honesty, transparency, and a steadfast commitment to doing what’s right.
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) See attached statement.
CEO Letter
Brian Penny, CEO
Material Topics
Governance of Material Topics
Describe the process followed to determine the organization's material topics We are aligned with the provisons of the Sustainability Accounting Standards Board (SASB) on the material topics for the Metal Mining Industry and have reported our performance based on these topics.  We have not conducted a formal materiality assessment and do not intend to complete one at this stage in the development of the Company's assets. We will continue to rely on the guidance provided by the relevant sustainability standards.
How did the organization prioritize the impacts based on their significance Compliance with regulatory requirements,  compliance with requirements of UL 2724 ECOLOGO® Certification for Suppliers of Mineral Exploration Industry, industry best practices
Describe the approach to identify and address grievances, including the grievance mechanisms that the organization has established or participates in The Company has a publicly available Whistleblower Policy that provides a formal mechanism for reporting and addressing grievances in a confidential and secure manner. All grievances received through this channel are reviewed and managed in accordance with established procedures to ensure fairness, transparency, and timely resolution. In addition, we maintain policies that clearly outline expectations for the conduct of employees and contractors, as well as the processes to be followed in the event of a complaint. Together, these mechanisms support an environment of accountability and integrity while ensuring that concerns are appropriately addressed.
Whistleblower Policy
The total number of grievances filed through the mechanism during the reporting period 0
The number of grievances that were addressed (or reviewed) during the reporting period 0
The number of grievances that were resolved during the reporting period 0
The number of grievances filed through the mechanism prior to the reporting period that were resolved during the reporting period 0
Describe other processes by which the organization provides for or cooperates in the remediation of negative impacts that it identifies it has caused or contributed to There were no grievances raised in the reporting period.
How are stakeholders who are the intended users of the grievance mechanisms involved in the design, review, operation, and improvement of these mechanisms The senior management team maintain active engagement with both internal and external stakeholders to ensure that grievance mechanisms remain effective and responsive. We encourage open dialogue and regularly invite feedback from stakeholders, which is considered in the review and continuous improvement of our processes. Oversight of stakeholder feedback and grievance management rests with senior management and is reported to the highest governance body, ensuring accountability and alignment with best practices. This governance structure helps ensure that our grievance mechanisms remain accessible, transparent, and reflective of stakeholder needs and expectations.
Describe how the organization tracks the effectiveness of the grievance mechanisms and other remediation processes Grievances may be submitted anonymously or directly and are referred to the appropriate department for review, corrective action, and remediation. Each department is responsible for monitoring the progress of resolution activities and reporting on outcomes on a regular basis. Effectiveness is tracked by evaluating the timeliness of responses, the resolution of issues raised, and any recurring themes that may indicate systemic concerns. This information is reviewed by senior management to ensure accountability, continuous improvement, and the ongoing effectiveness of our grievance and remediation processes.
Examples of the effectiveness of the grievance mechanisms and other remediation processes, including stakeholder feedback The effectiveness of our grievance mechanisms is demonstrated through several established practices. Health and safety concerns are addressed proactively through monthly safety meetings, procedure reviews, task observations, and regular supervision, which ensures that issues are identified and resolved in a timely manner. Workplace grievances are managed by the Human Resources department and addressed through a range of approaches, including coaching, counselling, and targeted training, to support resolution and prevent recurrence. Grievances raised by Indigenous and First Nations stakeholders are managed by our Community Relations department through quarterly community information sessions, as well as more frequent engagement when required.

An example of effectiveness includes improvements to our field safety procedures, which were implemented in response to concerns raised during safety meetings. In addition, feedback received from community engagement sessions has directly shaped the design of our consultation process, ensuring it is more inclusive and accessible to local stakeholders. These examples illustrate how feedback is actively incorporated into our operations, helping to ensure that grievance mechanisms remain responsive, effective, and trusted.
Environment
Climate Change - Stewardship
Strategy
Is a system in place to calculate the financial implications or costs, or to make revenue projections No
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 - not yet evaluated
Opportunity Assessments
Have you identified any climate-related opportunities with the potential to have a substantive financial or strategic impact on your business No
Greenhouse Gas Emissions
Scope 1
Provide the total company calculated gross Scope 1 GHG emission amount (tonnes CO₂-e) and a description of methodology in the details 669.000
Carbon dioxide (CO₂) (tonnes) 667.000
Methane (CH₄) (tonnes CO₂-e) 0.300
Nitrous oxide (N₂O) (tonnes CO₂-e) 1.700
Hydrofluorocarbon (CHFs) (tonnes CO₂-e) 0.000
Perfluorocarbons (PFCs) (tonnes CO₂-e) 0.000
Sulphur hexafluoride (SF₆) (tonnes CO₂-e) 0.000
The total amount of gross global Scope 1 GHG emissions (CO₂-e) (tonnes) 669.000
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) Reduced scope of drilling in 2024.
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, describe the differences and provide those reported emissions. We do not currently report to CDP or any other entity.
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 Engineering calculations using established emission conversion factors and consumption data.
The entity may, where relevant, provide a breakdown of its emissions per resource produced or business unit 0.03 tCO2e  (tonne of carbon dioxide equivalent) per meter drilled in 2024.
Discuss short-term, medium-term and long-term  strategy or plan to manage its Scope 1 greenhouse gas (GHG) emissions Operational controls and procedures are in place to reduce consumption and emissions such as but not limited to anti-idling policies  and limiting generator use to applicable office hours in summer months.
Please discuss reduction emissions target(s) (if any) for Scope 1 in your company, how they are set and analyse the performance against the target(s) While the company is engaged in exploration activities and plans to calculate their emissions based on a tCO2e per meter drilled, the Company does not expect to reduce its emissions but strives to maintain its low emission factor at the average of the annual tCO2e per meter drilled per year from 2022 to 2024.  The average of the annual tCO2e emissions from 2022 through 2024 is 0.033 tCO2e per meter drilled.
If relevant, what is the scope of the emission reduction target (e.g., the percentage of total emissions the target is applicable to) tCO2e per meter drilled
What type of target is it: Absolute
Denominator used, if intensity based Unit of Production
The timelines for the emissions reduction activity:
Start year 2024-01-01
Target year 2029-01-01
Base year 2024-01-01
Rationale for choosing the base year for the calculation 2024 is expected to represent the average scope of exploration for the company over the next 3-5 years.
Scope 1 GHG emissions in the base year (tonnes CO₂-e) 669.000
The percentage change against the base year, with the base year representing the first year against which emissions are evaluated toward the achievement of the target -0.0000%
Total base year GHG emissions 669.000
Present year GHG emissions 669.000
What is the mechanism(s) for achieving the target Operational controls
What consolidation approach is used for emissions Operational control
Standards, methodologies, assumptions, and/or calculation tools used and what was the reason they have been chosen Consultant provided GHG inventory  and emission conversion factor spreadsheet.
Energy
Energy Consumption
Total energy consumption within the organization (gigajoules, GJ) 6,783,328.630
Report the energy owned and controlled by the organization consumed in gigajoules for the following 6,783,328.630
Electricity purchased/generated for consumption (gigajoules, GJ) 224.470
Heating purchased/generated for consumption (gigajoules, GJ) 0.000
Cooling purchased/generated for consumption (gigajoules, GJ) 0.000
Steam purchased/generated for consumption (gigajoules, GJ) 0.000
Non-renewable fuel consumed (gigajoules, GJ) 6,783,104.160
Renewable fuel consumed (gigajoules, GJ) 0.000
Fuel types used from non-renewable sources Propane
Heating Oil
Gasoline
Diesel
Jet A
Report energy owned and controlled by the organization sold in gigajoules and report the totals for each 0.000
Report the standards, methodologies, assumptions and/or calculation tools used Consultant provided GHG inventory  and emission conversion factor spreadsheet.
Source of the conversion factors used See link below
Conversion Tables
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) 6,783,329.000
Percentage energy consumed that was supplied by grid electricity 0.0033%
Water
Water Management
Disclose the amount of water that was withdrawn from all sources (in thousands of cubic meters) 83.000
Surface water - including water from wetlands, rivers, lakes, and oceans - (in thousands of cubic meters) 76.200
Ground water (in thousands of cubic meters) 6.800
Rain water collected directly and stored by the company (in thousands of cubic meters) 0.000
Waste water obtained from other entities (in thousands of cubic meters) 0.000
Municipal water supplies (in thousands of cubic meters) 0.000
Other water utilities (in thousands of cubic meters) 0.000
Other, please specify (in thousands of cubic meters) 0.000
Disclose the amount of water that was withdrawn from non-freshwater sources (in thousands of cubic meters) 0.000
Disclose the amount of water that was withdrawn from fresh water sources (in thousands of cubic meters) 83.000
Disclose the amount of fresh water that was consumed in its operations (in thousands of cubic meters) 0.000
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 We do not operate in locations with High or Extremely High Baseline Water stress as classified by the World Resources Institute’s (WRI) Water Risk Atlas tool.
Was your organization subject to any fines, enforcement orders, and/or other penalties for water-related regulatory violations Yes, fines, enforcement orders or other penalties but none that are considered as significant
Biodiversity
Management Plan
Describe the environmental and biodiversity management plan(s) implemented at active sites Our biodiversity management plan involves the protection of the caribou habitat. Activities include care for species at risk and other invasive species, responsible waste disposal, habitat assessments and the suspension of work during sensitive seasons.
1.1 Lifecycle stages to which the plan(s) apply
  • Exploration and appraisal
  • Site development
  • Production
  • During closure
  • Decommissioning
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) Our plans are guided by the Quebec Loi sur les mines, Directive 19 and "Reglement sur l'amenagement durable des forets du domaine de l'etat".
Impacts
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
Social
Scale of the Organization
Direct Employee Information
Total number of permanent full-time employees 25
Full-time - Male 13
Full-time - Female 12
Total number of permanent part-time employees 2
Part-time - Male 2
Part-time - Female 0
Total number of permanent employees (full-time & part-time) 27
Permanent employees - Male 15
Permanent employees - Female 12
Total number of temporary employees (full-time & part-time) 3
Temporary employees - Male 2
Temporary employees - Female 1
Total number of direct employees (includes full-time permanent, part-time permanent, temporary; exclude workers who are not employees) 30
Direct employees - Male 17
Direct employees - Female 13
Percentage of direct employees -  Male 56.6667%
Percentage of direct employees - Female 43.3333%
Out of the total direct employees, what is the number of non-guaranteed hours direct employees 0
Non-guaranteed hours - Male 0
Non-guaranteed hours - Female 0
Describe the methodologies and assumptions used to compile the data This data was aggregated from our HR reporting system.
Are the numbers reported in head count, full-time equivalent (FTE), or using another methodology Head count
Are the numbers reported at the end of the reporting period, as an average across the reporting period, or using another methodology At the end of the reporting period
Provide contextual information necessary to understand the direct employment information provided  2 employees are on a leave of absence and 1 employee is undergoing a temporary layoff.
Describe significant fluctuations, if any, in the number of direct employees during the reporting period and between reporting periods  Our drilling is paused for periods of the year.  During those times, only the necessary operations team members attend to site, so some employees are laid off for those periods.   We also reduced the size of our drilling operations, which resulted in some employees being permanently laid off.
Number of direct employees hired locally 4
Number of direct employees hired locally as a percentage of total number of direct employees 13.3333%
Describe how the entity defines "local" Local is defined as employees located in the Northern Abitibi region.
Workers Who are Not Employees
Total number of workers who are not employees - Male (full-time, part-time) 46
Full-time - Male 46
Part-time - Male 0
Total number of workers who are not employees - Female (full-time, part-time) 6
Full-time - Female 6
Part-time - Female 0
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)
52
Percentage of workers who are not employees -  Male 88.4615%
Percentage of workers who are not employees - Female 11.5385%
Describe the most common types of workers who are not employees and their contractual relationship with the organization The most common type of non-employees are Contractors - 3rd party companies.  Their employees work at the Wallbridge site.
The type of work they perform Most of the contractors perform work such as: mechanics, technicians, core cutters, food services, housekeeping/custodial, diamond  drillers, equipment operators, pad cutters, field technicians, water treatment operators,  helicopter pilots, medical staff.
Describe the methodologies and assumptions used to compile the information about workers who are not employees. We reviewed reports of on site personnel for 2024.
Is the number of workers who are not employees reported in head count, full-time equivalent (FTE), or using another methodology Head count
Is the number of workers who are not employees reported at the end of the reporting period, as an average across the reporting period, or using another methodology At the end of the reporting period
Describe significant fluctuations, if any, in the number of workers who are not employees during the reporting period and between reporting periods The number of contractors is significantly reduced during any pause in drilling (site is shutdown).
Number of workers who are not employees hired locally 41
Number of workers who are not employees hired locally as a percent of total number of workers who are not employees 78.8462%
Total Workforce
Total workforce (includes direct employees and workers who are not employees) 82
Total female workforce 19
Female workforce as percentage of total employed workforce 23.1707%
Total male workforce 63
Male workforce as percentage of total employed workforce 76.8293%
Workers who are not employees (contractors) as percentage of total employed workforce 63.4146%
Total workforce who are hired locally 45
Total workforce hired locally as a percent of total workforce 54.8780%
Diversity and Equal Opportunity
Diversity of Governance Bodies
The highest governance body (Board of Directors)
Total Board of Directors 7
Percent of the highest governance body - Male 71.4286%
Percent of the highest governance body -  Female 28.5714%
Percent of the highest governance body - under 30 years of age 0.0000%
Percent of the highest governance body - between 30 and 50 years of age 0.0000%
Percent of the highest governance body - over 50 years of age 100.0000%
Percent minority or vulnerable group individuals in the "highest governance body" category 0.0000%
Diversity of Direct Employees
Senior Management:
Total Senior Managers: 6
Percent Male 50.0000%
Percent Female 50.0000%
Percent under 30 years of age 0.0000%
Percent between 30 and 50 years of age 16.6667%
Percent over 50 years of age 83.3333%
Percent of minority or vulnerable group individuals in the "Senior Management Employee" category 0.0000%
Salaried (excluding Senior Management):
Total Salaried (excluding Senior Management) 22
Percent Male 59.0909%
Percent Female 40.9091%
Percent under 30 years of age 13.6364%
Percent between 30 and 50 years of age 59.0909%
Percent over 50 years of age 31.8182%
Percent of minority or vulnerable group individuals in the "Salaried Employee" category 0.0000%
Technical Employees (skilled hourly):
Total Technical Employees 2
Percent Male 50.0000%
Percent Female 50.0000%
Percent under 30 years of age 0.0000%
Percent between 30 and 50 years of age 100.0000%
Percent over 50 years of age 0.0000%
Diversity of Workers Who Are Not Employees
Workers who are not employees
52
Number of Males 46
Number of Females 6
Occupational Health and Safety
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 0
Total recordable work-related injuries rate 0.000
Main types of work-related injury, e.g., confined space, trips, falls, etc. There were no work-related injury in the reporting period.
Number of hours worked 51,264
Total recordable incidents for work-related injuries and illnesses 0
Lost Time Injuries (LTIs) 0
Lost Time Injury Rate (LTIR) 0.000
Total recordable incident rate (TRIR) for work-related injuries and illnesses - direct employees 0.000
Number of recordable work-related injuries and illnesses - direct employees 0
Number of hours worked by all direct employees in the reporting period 51,264.000
Fatality rate for work-related fatalities - direct employees 0.000
Number of fatalities - direct employees 0
Near miss frequency rate (NMFR) for work-related near misses - direct employees 11.704
Number of near misses - direct employees 3
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 1
Total recordable work-related injuries rate 2.360
Main types of work-related injury, e.g., confined space, trips, falls, etc. Back strain
Number of hours worked 84,735
Total number of work-related injuries for workers who are not employees (total recordable incidents for work-related injuries and illnesses) 1
Lost Time Injuries (LTIs) 0
Lost Time Injury Rate (LTIR) 0.000
Total recordable incident rate (TRIR) for work-related injuries and illnesses - workers who are not employees 2.360
Number of recordable work-related injuries and illnesses - workers who are not employees 1
Number of hours worked by all workers who are not-employees in the reporting period 84,735.000
Fatality rate for work-related fatalities - workers who are not employees 0.000
Number of fatalities - workers who are not employees 0
Near miss frequency rate (NMFR) for work-related near misses - workers who are not employees 9.441
Number of near misses - workers who are not employees 4
Combined (Employees and non-employees, but controlled by the organization):
Total Hours Worked 135,999
Total number of all recordable work-related injuries 1
Total recordable work-related injuries rate 1.471
Total Lost Time Injuries (LTIs) 0
Lost Time Injury Rate (LTIR) 0.000
Total recordable incident rate (TRIR) for work-related injuries and illnesses - Combined (Employees and non-employees, but controlled by the organization) 1.471
Total number of recordable incidents for work-related injuries and illnesses - Combined (Employees and non-employees, but controlled by the organization) 1
Total Hours Worked - Combined (Employees and non-employees, but controlled by the organization) 135,999.000
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
Near miss frequency rate (NMFR) for work-related near misses  - Combined (Employees and non-employees, but controlled by the organization) 0.000
Number of near misses  - Combined (Employees and non-employees, but controlled by the organization) 7
What is the process for classifying, identifying and reporting near misses Sofvie.  This is a computer program that we use to manage and escalate injuries within the organization. It is updated regularly by the Health & Safety Advisor.
Safety Training
Describe any occupational health and safety training provided to workers, including generic training, as well as training on specific work-related hazards, hazardous activities, or hazardous situations Emergency measures, heavy equipment, fire extinguisher, first aid, WHMIS, supervisor training, hot work permit, lockout, etc.
Average number of training hours per person on health, safety, and emergency response provided to: full-time/direct employees 13.8
Average training hours per person on health, safety, and emergency response for workers who are not employees (contractors) 0.58
Conflict-affected and high-risk areas
Adherence to Laws and Due Diligence
Describe the approach to ensuring adherence to international humanitarian law when operating in conflict-affected and high-risk areas Wallbridge conducts exploration activities in Canada. The Company does not operate in conflict-affected and high-risk areas.
Website
TSM PRIMER
Security, Human Rights and Rights of Indigenous People
Describe the nature of any social risks, for all operating countries, that could have a material impact on the operations There were no social risks identified for this reporting period.
Which indigenous rights of communities in which the entity operates or intends to operate are respected, provide a description of the entity's due diligence practices and procedures in the details.
  • The establishment of formal community agreements
  • Other, please specify
Regular PDA meetings with Cree Nation and Abitibiwinni
Community Relations
Programs
Report on community relations programs, objectives and achievements in the past 3 years Wallbridge continually works to maintain a successful working relationship with all of our First Nations partners.  Examples include Company-funded construction of a cultural center on site, with the grand opening in June 2024 attended by the First Nations groups, members of the Board of Directors, Senior Management and other Wallbridge employees and contractors.  We are also working on a pre-development agreement ("PDA") with Abitibiwinni First Nation to complement the one that was signed in 2022 with the Cree communities.  We hired a full-time community relations coordinator in 2024.  Our operations management team monitors the fair distribution of work between partners and uses suppliers with agreements with communities where possible.  We also require all employees and contractors to complete the Cultural Awareness Program.
Risks
Discuss processes, procedures, and practices to manage risks and opportunities associated with the rights and interests of communities in areas where it conducts business We maintain regular communication with all our First Nations partners and have signed a PDA agreement with two of the three impacted First Nations.  If a concern is raised, senior management will meet with the affected group and work with them to agree on a resolution.  
Economic rights and interests, including, but not limited to, employment, fair wages, payment transparency, national resource governance, and respect of infrastructure and agricultural land We post open positions with our community partners and hire from these communities where possible.  We also provide transparency on how we allocate hours to each community.
Environmental rights and interests, including, but not limited to clean local air and water, as well as safe discharge and disposal of waste We follow Directive 19 for the protection of surface water.  We have dust management plans to ensure air quality. All sampling programs follow provincial and federal regulations.
Lifecycle stages to which the entity's practices apply, if relevant Exploration and appraisal
The underlying references for the entity's 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 We adhere to the PDA, which outlines contract process, hiring practices, dispute resolution, etc.
Opportunities
Lifecycle stages to which its practices apply, if relevant Exploration and appraisal
Opportunities associated with community relations include:
  • Increased social support
  • Improved skills of local labour
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
The CEO is responsible for the management of the organization's progress and performance on sustainability issues.
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 Technical and HSE committee serves as the ESG subcommittee on the board. It receives quarterly reports on the actions, plans and goals for sustainability-related matters. They also receive immediate reports when applicable.
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 Wallbridge has a Code of Business Conduct and Ethics, Insider Trading, and Anti-bribery policies that are binding on every member of staff, director and business partners.
What are (if any) the authoritative intergovernmental instruments that the commitments reference The commitments do not reference any authoritative intergovernmental instruments.
Do the commitments stipulate conducting due diligence Yes
Do the commitments stipulate applying the Precautionary Principle or Approach (see instructions). No
Do the commitments stipulate respecting human rights Yes
Describe the specific policy commitment to respect human rights The Code of Business Conduct and Ethics addresses the company's position on Human Rights.

The Company is committed to providing a
workplace free of harassment, violence and discrimination. Directors, officers and
employees are expected to foster a respectful work environment that adheres to the requirements of applicable human rights law and related workplace legislation. The Company will not tolerate acts of discrimination based on age, ancestry, colour, race, citizenship, ethnic origin, creed, disability, family status, marital status, gender, sex, sexual orientation or any other ground of discrimination prohibited by law.
What are (if any) the internationally recognized human rights that the commitment covers The Company's Code of Business Conduct and Ethics includes the following internationally recognized human rights:

- The Right to Freedom and Equality
- Freedom from Discrimination
- The Right to Equal Treatment Everywhere
- The Right to Equal Protection from
- Discrimination
What are the categories of stakeholders, including at-risk or vulnerable groups, that the organization gives particular attention to in the commitment The Company's Code of Business Conduct and Ethics includes at-risk or vulnerable groups that may suffer discrimination due to age, ancestry, colour, race, citizenship, ethnic origin, creed, disability, family status, marital status, gender, sex, and/or sexual orientation.  
Are the policy commitments publicly available Yes
Provide links to the policy commitments, if publicly available, or, if the policy commitments are not publicly available, explain the reason for this Please see the links below for access to the
Company's policy commitments:
Safety, Health, Environment and Community (SHEC) Policy

Board Diversity Policy

Majority Voting Policy

Code of Business Conduct and Ethics
Report the level at which each policy commitment was approved within the organization, including whether this is the most senior level All policies noted above are approved by the Board of Directors.
Were the policy commitments approved at the most senior level within the organization Yes
To what extent the policy commitments apply to the organization’s activities and to its business relationships The policies noted above are binding on all stakeholders where applicable, including employees, contractors, suppliers, partners, shareholders, and any other parties engaging with the organization in any capacity.
Describe how the policy commitments are communicated to employees, business partners, and other relevant parties The policies noted above are publicly available on the company website.
We require employees to read and sign off on the policies, as  appropriate, whenever the policies are updated or amended.
Embedding policy commitments
Describe how the organization embeds each of its policy commitments for responsible business conduct throughout its activities and business relationships The Company ensures that each director,
officer and employee are provided with a copy of the Code of Business Conduct and Ethics that each of them sign as an acknowledgment of receipt and review.

The Board of Directors of the Company has adopted the policy commitments in order to:
(a) promote integrity and honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest;
(b) promote full, fair, accurate, timely and
understandable disclosure in reports and documents that the Company files with, or submits to securities regulators and in other public communications made by the Company;
(c) promote compliance with applicable
governmental laws, rules and regulations;
(d) promote the protection of Company assets, including corporate opportunities and confidential information;
(e) promote fair dealing practices;
(f) deter wrongdoing; and
(g) ensure accountability for
adherence to the Code of Conduct.
What implementation training does the organization provide During employee orientation, we cover the Code of Business Conduct and Ethics, and we inform employees and contractors of our expectations on ethical conduct.
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.) As of June 26, 2024 (the AGM) The Board of Directors was composed of 7 members and and had the following standing
committees:

1. Audit Committee
2. Compensation and Human Resources Committee
3. Technical and Health, Safety, Environment (HSE) Committee
4. Corporate Governance and Nominating Committee  (CG&N)
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 Technical and HSE Committee is responsible for decision-making and oversight of the organization's impacts on the economy, environment, and people, including the oversight of sustainability-related risks and opportunities.
Technical and HSE Committee Charter
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 17
3-6 years of tenure of members on the governance body 50
6-9 years of tenure of members on the governance body 33
More than 10 years of tenure of members on the governance body 0
Number of other significant positions and commitments held by each member, and the nature of the commitments Please find additional details on our current board members at the link below.  For information on previous board members please contact the Company.
Board of Directors
Number of Male governance body members 5
Number of Female governance body members 2
Description of competencies relating to economic, environmental, and social topics Please find additional details on our board members at the link above.
Description of stakeholder representation, including employees and other workers Other stakeholders are actively engaged in topics they have expertise in.  Members of management attend quarterly board meetings and committee meetings as needed.
Highest Governance Body
Describe the nomination and selection processes for the highest governance body and its committees
The Company's Board of Directors are nominated by the CG&N Committee which must recommend to the Board the necessary and desirable competencies and skills that individual directors and the Board, as a whole, should possess.  

For further information, please refer to the link below:
Corporate Governance and Nominating Committee Charter
Does the organization have a diversity policy, gender equality or gender equity plan and if so, provide details, link to the policy or attach the file Please see link below:
Board Diversity Policy
Report the criteria used for nominating and selecting highest governance body members
Please refer to the link above for the CG&N committee charter.
Are views of stakeholders (including shareholders) taken into consideration for nominating and selecting highest governance body members Yes
Discuss how views of the stakeholders (including shareholders) are  taken into consideration for nominating and selecting highest governance body members The Board and its committees consider diversity and a broad range of views, including those of stakeholders, when selecting potential Director candidates.
Is diversity taken into consideration for nominating and selecting highest governance body members Yes
Discuss how diversity is considered for nominating and selecting highest governance body members The Board and its committees consider diversity and a broad range of views, including those of stakeholders, when selecting potential Director candidates.  Please refer to the Board Diversity Policy at:
Board Diversity Policy
Is independence taken into consideration for nominating and selecting highest governance body members Yes
Discuss how independence is considered for nominating and selecting highest governance body members The Company is committed to putting in place a Board diverse in knowledge, experience, skills, gender, and backgrounds that is constituted with a majority of individuals who meet the independence requirements of applicable legislation, regulatory requirements and policies of the Canadian Securities Administrators and the Toronto Stock Exchange. The Corporate Governance and Nominating Committee regularly reviews Board size and composition to ensure that the Board has diversity and depth of experience to facilitate effective and efficient decision-making.
Discuss whether and how competencies relevant to the impacts of the organization are considered As part of its mandate, the CG&N Committee is responsible for oversight of Board renewal and the nomination of Directors.  See link for the CG&N Committee Charter for further details.
Chair of the highest governance body
Is the chair of the highest governance body also a senior executive in the organization (non-independent) No
Conflicts of Interest
Describe the processes for the highest governance body to ensure that conflicts of interest are prevented and mitigated The CG&N Committee oversees the Code of Business Conduct and Ethics which governs the Company and the behaviour of its Directors, officers and employees, including conflicts of interest.

Please refer to the CG&N Committee Charter above for further details.  
Are conflicts of interest disclosed to stakeholders Yes
Are there conflicts of interest related to: cross-board membership No
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) The Company is committed to the principles of sustainable development. The Company diligently applies technically proven and economically feasible measures to protect the environment in all of its exploration activities.
The purpose of the Technical & HSE Committee is to assist the Board in fulfilling its oversight responsibilities with respect to specific technical matters which are beyond the scope or expertise of non-technical Board members, advising the Board and the Company’s management team in relation to the advancement of the Company’s mineral assets and assisting the Board in fulfilling its oversight responsibilities with respect to the HSE and CSR activities and performance of the Company.

For further details, please refer to the Technical and HSE Committee Charter below.
Technical and HSE Committee Charter
Evaluation of Highest Governance Body
Describe actions taken in response to the evaluations, including changes to the composition of the highest governance body and organizational practices The CG&N Committee is responsible for regularly assessing the Board, its committees and each individual Director regarding his, her or its effectiveness and contribution and reviewing and assessing (i) the size, composition and operation of the Board to ensure effective decision making; and (ii) the size, composition and chairs of the Committees of the Board.
In conducting its evaluation, the CG&N Committee gathers feedback regarding the overall assessment of the Board, of committees of the Board and of individual Directors through verbal discussions with individual Directors and during meetings of the Board, and through the use of a comprehensive confidential written questionnaire.
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 The Board for the Company is responsible for supervising the management of the business and affairs of the Company
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 The Board discharges its foregoing responsibilities by assuming specifically but not exclusively the following duties and responsibilities:
Business Plan and Budgets
•     Ensuring a strategic planning process is in place and approving, on at least an annual basis, a business plan which takes into account, among other things, the opportunities and risks of the Company;
•     Approving the Company’s annual operating and capital budgets;
•     Reviewing operating and financial performance results in relation to the Company’s business plan, budgets and adopted performance metrics;
Governance
•     Overseeing the Company’s overall approach to corporate governance practices, including the formation of Committees, their mandates, and their composition in accordance with applicable regulatory requirements;
•     Appointing the Board Chair, Lead Director (if required) and the Chair of each Committee of the Board and developing written position descriptions for each;
•     Identifying individuals qualified to become new board members, approving the nomination of Directors to the Board, and determining whether individual Directors meet the requirements for independence under applicable regulatory requirements;
•     Providing an orientation program for new Directors to the Board and continuing education opportunities for all Directors, communicating expectations and responsibilities including basic duties relating to attendance at board meetings and advance review of meeting materials;
•     Regularly assessing the effectiveness and contribution of the Board, its Committees and individual Directors, and approving the Company's compensation policy for Directors.
Succession Planning, Appointment and Supervision of Management
•     With the advice of the Compensation and Human Resources Committee, appointing and monitoring the performance of, formulating succession plans for, and approving the compensation of the Chief Executive Officer and other Officers.
•     Together with the Chief Executive Officer, developing a written position description for the role of the Chief Executive Officer and developing or approving the corporate goals and objectives that the Chief Executive Officer is responsible for meeting.
•     Delegating to the Chief Executive Officer and other Officers authority over day-to-day management of the business.  This authority may be subject to specified limits and any transactions or arrangements in excess of general authority guidelines will be subject to prior Board review and approval.
Ethics, Integrity and Culture
•     To the extent feasible, satisfying itself as to the integrity of the Chief Executive Officer and other Officers and that the Chief Executive Officer and other Officers create a culture of integrity throughout the organization.
•     Adopting a Code of Business Conduct and Ethics and monitoring compliance with the Code.
Does the highest governance body engage with stakeholders to support due diligence and other processes No
Describe how the highest governance body considers the outcomes of these processes In general, the Board entrusts management to engage with stakeholders to support due diligence and other processes and as part of the day-to-day management of the business. Management reports directly to the Board on an ongoing and as-needed basis.
Ethics
Ethics and Integrity
Describe how individuals can seek advice on implementing the organization’s policies and practices for responsible business conduct Overseeing the Company’s processes designed to ensure compliance by the Company with applicable legal and regulatory requirements and adopting and monitoring corporate policies and practices as may be appropriate to achieve this
Describe the mechanisms for individuals to raise concerns about the organization’s business conduct The Company has implemented various Board and management policies to address communication of critical concerns raised  by contractors, employees, officers and Directors. Such critical concerns can be communicated to the Board either anonymously directly to the Reporting Contacts (Chair of the Audit Committee or external legal counsel) as outlined in various Board policies or through the corporate chain of command from the manager level through to the Chair of the Board.
No critical concerns were communicated to the Board during the period 2022-2024.
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
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
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 The Company and its Board are committed to honest and ethical conduct in all business dealings and compliance with all relevant laws, rules and regulations governing its operations. The Board has adopted its  Anti-Bribery and Anti-Corruption Policy to supplement and complement the provisions in the Company’s Code of Business Conduct and Ethics and Whistleblower policies and to more explicitly set out the responsibilities of the Company and those working for it as they relate to bribery and corruption in the jurisdictions in which the Company operates.
The Anti-Bribery and Anti-Corruption Policy provides mechanisms to report and manage corruption and bribery risks on an anonymous basis.
Anti-Corruption
Corruption Risks to Operations
Describe how potential impacts of corruption or risks of corruption are managed in the organization’s procurement practices and throughout the supply chain The Company and its Board are committed to honest and ethical conduct in all business dealings and compliance with all relevant laws, rules and regulations governing its operations as outlined above in the Ethics section.
Confirmed Incidents and Response
Total number and nature of confirmed incidents of corruption 0
Total number of Bribery cases 0
Total number of Lobbying cases 0
Total number of Extortion cases 0
Total number of Cronyism cases 0
Total number of Nepotism cases 0
Total number of Parochialism cases 0
Total number of Patronage cases 0
Total number of Influence peddling cases 0
Total number of Graft cases 0
Total number of Embezzlement cases 0
Communication and Training
Total number of governance body members that the organization's anti-corruption policies and procedures have been communicated to 7
Total percentage of governance body members that have been communicated to on anti-corruption 100.0000%
Anti-corruption policies and procedures communication to direct employees by type:
Total number of the direct employees that have been communicated to on anti-corruption 30
Total percentage of the direct employees that have been communicated to on anti-corruption 100.0000%
Total number of senior management employees that have been communicated to on anti-corruption 6
Percentage of senior management employees that have been communicated to on anti-corruption 100.0000%
Total number of technical employees that have been communicated to on anti-corruption 2
Percentage of technical employees that have been communicated to on anti-corruption 100.0000%
Total number of salaried employees that have been communicated to on anti-corruption 22
Percentage of salaried employees that have been communicated to on anti-corruption 100.0000%
Total number and percentage of direct employees that has received training on anti-corruption, broken down by employee category and region
Total number of direct employees that received training on anti-corruption 30
Total number of direct employees 30
Total percentage of direct employees that received training on anti-corruption 100.0000%
Total number of senior management employees who received training on anti-corruption 6
Percentage of senior management employees who received training on anti-corruption 100.0000%
Total number of middle management employees who received training on anti-corruption 4
Percentage of middle management employees who received training on anti-corruption 100.0000%
Total number of technical employees who received training on anti-corruption 2
Percentage of technical employees who received training on anti-corruption 100.0000%
Percentage of production employees who received training on anti-corruption Does Not Apply
Total number of administrative employees who received training on anti-corruption 4
Percentage of administrative employees that received training on anti-corruption 100.0000%
Total number of all other employees who received training on anti-corruption 0
Communication of critical concerns
Describe how critical concerns are communicated to the highest governance body The Company has implemented various Board and management policies to address communication of critical concerns raised  by contractors, employees, officers and Directors. Such critical concerns can be communicated to the Board either anonymously directly to the Reporting Contacts (Chair of the Audit Committee or external legal counsel) as outlined in various Board policies or through the corporate chain of command from the manager level through to the Chair of the Board.
Report the number of critical concerns that were communicated to the highest governance body during the reporting period 0
Remuneration
Report which of the following remuneration policies apply to the highest governance body and senior executives and provide details:
Please refer to Wallbridge's Management Information Circular, section 8, page 14 at the link below:
Management Information Circular (as of April 30, 2025)
Fixed pay Yes
Variable pay No
Performance-based pay No
Equity-based pay Yes
Bonuses Yes
Deferred and vested shares Yes
Sign-on bonuses No
Recruitment incentive payments No
Termination payments Yes
Clawbacks No
Retirement benefits, including the difference between benefit schemes and contribution rates for the highest governance body, senior executives and all other employees No
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 Senior executives are tasked with determining corporate KPIs annually, and the short-term bonus payment is determined by the percentage of successful completion of each KPI.
Describe the process for designing remuneration policies Director compensation is reviewed annually by the Compensation & HR Committee and any recommended changes to the compensation of Directors are presented to the Board for review and approval. Historically the Compensation & HR Committee has engaged third-party consultants on an as-needed basis to review, assess, and modify, where appropriate, the competitiveness and design of the Company’s compensation program.
Describe the process for determining remuneration See above
Are independent members of the highest governance body or an independent remuneration committee overseeing the remuneration process Yes
How the views of stakeholders (including shareholders) regarding remuneration are sought and taken into consideration  The Shareholders vote on the Long-Term Incentive Plan every three years at the AGM.
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 The Board and management understand that establishing good working relationships with all the stakeholder groups the Company interacts with is key to long-term success.
For investment industry professionals and shareholders, the Company employs an investor relations professional to implement and manage ongoing strategies and outreach to the investment community.
The Company recognizes that working with stakeholders in areas where it operates benefits all stakeholders of the Company. Proactive programs enable the Company to connect and engage with local communities to raise awareness, share concerns and opportunities, minimize any perceived negative impacts of its operations and facilitate permitting of its operations. To this end the Company regularly and consistently meets and consults with local stakeholder groups.
Provide a list of stakeholder groups engaged by the organization
  • Permanent or Full-time Employees
  • Investors
  • Local communities
  • Regulatory authorities
Report the basis for identifying and selecting stakeholders with whom to engage The Company will engage with stakeholders that are relevant to the current and/or future business of the company.  We engage with regulatory authorities to ensure compliance as needed.
Report the purpose of the stakeholder engagement To ensure that we are compliant with all regulations and standards, and to ensure a continued good relationship with our local community partners, employees and shareholders.
Describe how the organization seeks to ensure meaningful engagement with stakeholders We have regular communication with local stakeholders to ensure good working relationships and that any concerns are addressed.
Tax
Provide a description of the approach to tax
The Company is committed to following all applicable laws, rules and regulations in the jurisdictions in which it operates
Does the organization have a tax strategy No
The approach to regulatory compliance The Company is committed to following all applicable laws, rules, and regulations in the jurisdictions in which the Company operates. Although not all employees, officers and directors are expected to know the details of all applicable laws, rules and regulations, it is important to know enough to determine when to seek advice from appropriate personnel.  Third-party expertise is obtained for complex tax-related issues or significant transactions.
How the approach to tax is linked to the business and sustainable development strategies of the organization The Company’s policy is to promote high standards or integrity by conducting its affairs honestly and ethically  which includes the Company’s approach to tax. The Company contributes indirectly by engaging suppliers  in the communities in which the Company operates.
Provide a description of the tax governance and control framework
See below
The governance body or executive-level position within the organization accountable for compliance with the tax strategy The CFO is responsible for compliance with the legal and regulatory requirements.  The CEO and CFO are responsible for the control framework.
How the approach to tax is embedded within the organization There is involvement of the CEO, CFO and other senior management, including third-party advisors (tax, legal) if required in transactions.
The approach to tax risks, including how risks are identified, managed, and monitored The company maintains a low threshold for tax risk.
Provide a description of the mechanisms for reporting concerns about unethical or unlawful behaviour and the organization’s integrity in relation to tax
The Company has a Whistleblower Policy in place for stakeholders to report concerns about accounting, internal controls, auditing matters or questionable financial practices and about alleged breaches of the Code of Business Conduct and Ethics. The policy includes an internal reporting mechanism and external reporting contacts. Reports can be filed on an anonymous basis. The policy is posted publicly on the Company’s website and internally.
Provide a description of the assurance process for disclosures on tax and, if applicable, a reference to the assurance report, statement, or opinion  Tax disclosures are included in the annual financial statements which are audited by an independent public accounting firm.
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