Last updated 09 October 2023

Health and Safety Policy
Amaroq Minerals Ltd.
(the “Corporation”)

Health and Safety Policy

APPROVED BY THE TSSC COMMITTEE ON 23 AUGUST 2023
APPROVED BY THE BOARD OF DIRECTORS ON 28 AUGUST 2023

Safety is a core company value and safe working is an integral part of how we plan, organise and undertake our business activities and operations, being our first consideration in every action we take.

At Amaroq Minerals we will take all reasonable steps to secure and maintain the health, safety and welfare of all employees, subcontractors, clients and members of the community who may be affected by our activities.  We recognise that everyone has a right to operate in a safe and healthy environment.

As a management team our objective is to maximise the well being of each employee and subcontractor and their potential to contribute to the development of the projects and ensure compliance with the legislation applicable to our operations. It is our policy and overall aim to educate each employee and subcontractor in safe working practices and through this education it is envisaged that they will work together in a safe manner.

We are committed to the goal of Zero Harm and aim to eliminate all accidents and potential hazards and reach our objective of zero injuries. Achieving this requires the full understanding of everyone in the organisation of their safety responsibilities and their commitment to fostering a proactive safety culture, based on a duty of care for oneself, ones co-workers and members of the community.

The responsibility for safety in Amaroq Minerals proceeds from the Board of Directors through to each manager and on to each member of staff or subcontractor.

It is the responsibility of all line management to ensure that all employees or subcontractors are educated and motivated to comply with the safety policies and procedures and that they are made aware of applicable policies and legislation. Line management must be kept fully informed of the impact that activities under its control have on safety policy and take corrective action as appropriate.

Equally all employees and subcontractors have a legal responsibility to co-operate in implementing the safety policies and standards as required by the safety management system. 

Collectively, we all have a responsibility for safety.

Amaroq Minerals is committed to providing:

  • A safe place of work and healthy working environment for all our employees and subcontractors promoting best work practices and safe and healthy lifestyle choices
  • A system to manage health & safety in the workplace where performance is continuously monitored, measured, reviewed and improvements implemented as required
  • Relevant consultation, information, instruction, training and supervision for all employees and subcontractors in order that they can carry out their tasks in a safe manner with no danger to themselves or others who may be affected by their work
  • Training so that employees and subcontractors can recognise and control hazards in the work place, assess risks arising and implement suitable controls
  • An effective Emergency Response Plan
  • Thorough investigation and recording of all incidents with the aim of preventing reoccurrence

A report on the Corporation’s health and safety performance will be submitted to the Health and Safety Committee annually and this policy will be reviewed at that time.

Last updated 09 October 2023

ENVIRONMENTAL POLICY
Amaroq Minerals INC.
(the “Corporation”)

Environmental Policy

APPROVED BY THE BOARD OF DIRECTORS ON 28 AUGUST 2023

This policy constitutes the Corporation’s commitment to social responsibilities, the health and safety of its employees and respect for the environment where it works and outlines its guiding principles in this regard. The Corporation is committed to promoting respect for these responsibilities by continually improving its knowledge, its understanding of challenges and its actions.

Social Responsibilities and Community Involvement

Our business model is designed to ensure that we are close to our communities. As members, we embrace our social responsibilities and contribute to the continuous development of the communities in which we live and work. The Corporation continues to strengthen a culture of sustainable and profitable growth by formalizing a collective commitment to acting responsibly across our operations.

We work together to ensure that our commitment to responsible business practices in terms of quality management, environmental responsibility, community giving and care of our professionals is achieved both within the Corporation and throughout our chain of partners and consultants.

The Environment

Furthermore, the Corporation recognizes that appropriate environmental management is essential to the proper conduct of its mining operations and activities. Accordingly, our goal is to minimize the environmental impacts of our projects and activities. The Corporation makes every effort to protect the environment against risks that may arise from its activities and encourages any action that contributes towards the responsible management of natural resources.

The Corporation is committed to working with stakeholders to promote actions that contribute to increased energy efficiencies, including monitoring and adopting management processes to reduce greenhouse gas emissions. This policy helps uphold our values and benefits all of the Corporation’s employees, suppliers, shareholders and the communities in which it operates. We recognize and encourage each employee to actively support this policy and take part in the implementation of the following guidelines:

  • Make the environment an integral part of the management and  decision-making process and incorporate environmental criteria into the design of projects, whether they be exploration activities, camp construction or access logistics or use of equipment by the Corporation or its contractors;
  • Implement an effective environmental management system by establishing measurable targets for environmental practices, in particular a) limiting pollution, greenhouse gases and other emissions, b) encouraging the prudent use of water, power and other natural resources, c) limiting waste and disposing of waste in a responsible manner, d) reducing, reusing and recycling resources;
  • Rehabilitate environments affected by our exploration operations, returning them, to the extent possible, to their natural or original state and ensure the long-term safety and stability of the land once our activities have ceased;
  • Provide all employees with the tools, expertise and training needed to apply this policy and to motivate them to take responsibility for and comply with the environmental management system when performing their duties;
  • Comply with applicable environmental regulations;
  • Sensitize employees, contractors and suppliers to comply with our  environmental management system and to respect the spirit of this policy;
  • Implement risk analysis programs as well as emergency measures plans;
  • Develop mechanisms to monitor regulations and consult with stakeholders in order to remain apprised of environmental regulations that may affect operations;
  • Submit an  annual report on the Corporation’s  environmental performance to the Corporate Governance Committee.

Last updated 16 January 2024

HUMAN RIGHTS, CHILD AND FORCED LABOUR POLICY
(AMAROQ MINERALS LTD.)

Human Rights Policy

APPROVED BY CORPORATE GOVERNANCE AND NOMINATION COMMITTEE ON DECEMBER 15, 2023
APPROVED BY THE BOARD OF DIRECTORS ON DECEMBER 22, 2023

This Policy articulates our commitment to conduct business in a manner that respects the dignity and rights of all individuals impacted by our operations in Greenland. We are determined to prevent any form of exploitation, ensuring that our operations are free from unethical practices. This Policy is a clear declaration of our dedication to maintaining the highest standards of human and labour rights in every aspect of our business.

COMMITMENT TO HUMAN RIGHTS AND SUSTAINABLE DEVELOPMENT

Aligning with Human Rights Standards: Amaroq Adheres to the International Bill of Human Rights and International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work, initially adopted in 1998 with amendments in 2022. Our commitment extends beyond compliance, as we actively incorporate respect for human dignity and individual freedom into our operational strategies and corporate decision-making. This proactive approach ensures that our principles guide every action and decision we make.

Recognising the significant impact of our activities on local communities and the environment, we are dedicated to conducting business in a manner that not only prevents exploitation but also delivers tangible benefits to local communities. This includes safeguarding vulnerable groups from labour abuses. Our aim is to serve as a positive force for change, contributing to sustainable development in Greenland.

SCOPE AND POLICY PRINCIPLES

This Policy is applicable to all individuals associated with Amaroq, encompassing its personnel, subsidiaries, affiliates, joint ventures, and any other entities under the Corporation’s control. This includes directors, officers, employees, consultants, and contractors, collectively referred to as ‘Personnel’ under the following principles:

Labor Rights

  • Ensuring fair wages and benefits that meet or exceed local standards.
  • Supporting employees’ rights to organize and collectively bargain in a non-coercive environment.
  • Prohibiting any form of forced or child labour in all operations and supply chains.

Compliance with Laws and Standards:

  • Adhering strictly to all national and international laws relevant to our operations, including those specifically targeting human rights, child and forced labour.
  • Aligning our practices with global standards such as the United Nations Guiding Principles on Business and Human Rights.

Commitment to Meaningful Consultation and Dialogue:

  • Establishing ongoing, open channels of communication with local communities and stakeholders.
  • Facilitating community forums and workshops to understand local perspectives and concerns.
  • Engaging in collaborative decision-making processes with communities, aiming for mutually beneficial outcomes.

Indigenous Rights and Cultural Heritage:

  • Acknowledging indigenous sovereignty and rights in all areas of operation.
  • Involving indigenous representatives in planning and decision-making processes that affect their communities.
  • Ensuring that our operations do not infringe upon the rights and welfare of indigenous children and communities.

Respect for Culture and Community Engagement

  • Actively recognizing and valuing the cultural diversity of the communities in which we operate, including the protection of vulnerable groups from exploitation.
  • Ensuring our business practices are sensitive and adaptable to local cultural norms and practices.

Transparency and Accountability

  • Providing clear, accessible information to all stakeholders, including the public.
  • Establishing accessible, confidential channels for reporting human rights abuses or concerns, including those related to child and forced labour.
  • Ensuring that all grievances are investigated promptly and resolved fairly.

Last updated 12 March 2024

SUPPLIER CODE OF CONDUCT POLICY
(AMAROQ MINERALS LTD.)

Code of Conduct Policy

APPROVED BY THE TSSC COMMITTEE ON 15 DECEMBER 2023
APPROVED BY THE BOARD OF DIRECTORS ON 22 DECEMBER 2023

SUPPLIER CODE OF CONDUCT POLICY AMAROQ MINERALS LTD. (THE “CORPORATION”)

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This Supplier Code of Conduct Policy expresses our commitment to conducting business in a manner that upholds the dignity and rights of all individuals affected by our operations. We are resolute in our endeavour to prevent any form of exploitation, guaranteeing that our operations remain devoid of unethical practices. We always align our operations with the principles outlined in the International Bill of Human Rights and the International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work.

Amaroq is committed to creating a path of ethical and sustainable business practices in Greenland’s mining sector. Recognising the pivotal role our suppliers play in helping us achieve our objectives is paramount. Our suppliers are not just vendors or service providers; they are our partners in advancing towards a more sustainable and responsible mining industry. As such, our commitment extends beyond the land we operate to the communities our business impacts.

This Supplier Code of Conduct outlines our expectations and requirements for all suppliers. It is designed not just to ensure compliance with legal standards, but to promote excellence in all aspects of our operations. By adhering to the Code, our suppliers join us in a commitment to uphold the highest standards of integrity, respect for human rights, and preservation of the environment.

POLICY PRINCIPLES

  • Environmental Stewardship:  Our operations are intricately connected with Greenland’s unique and sensitive environment. We expect our suppliers to engage in proactive environmental conservation efforts, including sustainable resource management, waste reduction, and pollution minimization. Compliance with all environmental regulations is a baseline, not an endpoint.
  • Labor and Human Rights: Upholding the dignity and rights of workers across our supply chain is paramount. This entails ensuring fair wages, safe working conditions, and fostering workplaces free from discrimination and harassment. Suppliers must strictly prohibit forced labor, child labor, and any form of human rights violations. Respect for diversity and the promotion of an inclusive work environment are obligatory principles.
  • Health and Safety: Our suppliers must adhere to the highest safety standards, acknowledging the inherent risks associated with mining. This encompasses providing secure work environments, continuous safety training, and ensuring that safety equipment and protocols meet industry best practices.
  • Ethical Business Practices: Integrity forms the bedrock of all our business dealings. Suppliers are required to conduct their operations with transparency, devoid of corruption, bribery, or unethical practices. We expect complete transparency and a commitment to both legal and ethical business practices in all interactions.
  • Community Engagement and Development:  Our presence in Greenland necessitates a mutually beneficial relationship with local communities. Suppliers are encouraged to engage respectfully and sensitively with these communities, including hiring local workers where feasible, participating in community development initiatives, and respecting indigenous rights and traditions.

Public consultation for the draft Environmental Impact Assessment and Social Impact Assessment report on the Nalunaq Gold Mine project has started. You can find the materials by clicking this link.

Closure of the public consultation is scheduled for March 1, 2024.

Background reports for Environmental Impact Assessment (EIA)

17/3/2023 Appendix III Water Management Plan Technical Background Report [17 March 2023] Golder 2023a. 20/1/2021 Appendix IV Seepage Assessment Technical Background Report [20 Jan 2021] Golder 2021c. 20/11/2020 Appendix V DTSF_Design Criteria_20Nov2020 27/1/2021 Appendix VI Hydrological and Hydrogeological Study Technical Background Report [27 Jan 2021] Golder 2021e. 1/2/2021 Appendix VII Nalunaq Gold Mine, Greenland Preliminary Geotechnical Report – Mine Surface Infrastructure [1 Feb 2021] Golder 2021f. 5/7/2021 Appendix VIII Tailings Waste Characterisation Review. [5 July 2021] Golder 2021g. 7/3/2022 Appendix IX Tailings Storage Facility Options Analysis [7 March 2022] Golder 2022a. 15/3/2022 Appendix X Failure Mode and Effects Analysis for Nalunaq Mine [15 March 2022] Golder 2022b. 25/3/2022 Appendix XI Nalunaq Gold Mine, Greenland – Uranium Concentrations – Technical Memo [25th March 2022] Golder 2022c. 15/6/2022 Appendix XII Nalunaq Gold Mine, Greenland. Preliminary Static and Kinetic Testing Results From 2022 Tailings Analysis Programme [15 June 2022] Golder 2022d. 15/6/2022 Appendix XIII Nalunaq Gold Mine Flood Risk Assessment (Updated) [8 April 2022] Golder 2022e. 8/4/2022 Appendix XIV Nalunaq Gold Mine Surface Water Infrastructure Design [8 April 2022] Golder 2022f. 30/3/2022 Appendix XV Nalunaq Gold Mine, Greenland, Preliminary Closure Plan. 21467213.C04.3.A.0 [30 March 2022] Golder 2022g. 12/1/2021 Appendix XVI Mine Inflow Assessment – Groundwater and Surface Water [12 Jan 2021] Golder 2021a 9/10/2020 Appendix XVII Tailings Disposal Options. Technical Background Report Nalunaq [9 October 2020] Golder 2020 3/10/2022 Appendix XVIII Geochemical Testing Results from 2022 Tailings Analysis [03 October 2022] 30/3/2021 Appendix XIX An Investigation into the Environmental Characterization of Tailings from the Nalunaq Mine. [30 March 2021] SGS 2021. 1/11/2019 Appendix XX Water Resources in Nalunaq Valley Desktop study [November 2019] Asiaq 2019. 17/3/2023 Appendix XXI DTSF Potential Failure Modes [17 March 2023], WSP 2023a 17/3/2023 Appendix XXI DTSF Flood Assessment [17 March 2023], WSP 2023b