Apollo Silver Corp.

2022 ESG Report and Scorecard

Published on February 28, 2023

This ESG Report and Scorecard for the year ended November 30, 2022 is Apollo Silver Corp.'s ("Apollo Silver" or the "Company") maiden ESG report.

At Apollo Silver, we make the safety of our team and the minimization of our environmental impact a priority. We operate with integrity and within policy guidelines that highlight our commitment to responsible exploration and resource development. Our focus is on maintaining a strong environmental, social and governance performance throughout all of our operations.

Company Profile

Organizational Profile

Name

Apollo Silver Corp.

Describe nature of activities, brands, products and services

Apollo Silver, headquartered in Vancouver, BC,
Canada, operates its mineral exploration and
resource development projects in the United
States, through its wholly-owned US subsidiary,
Stronghold Silver USA Corp.

The primary focus of the Company is the
exploration and development of silver projects
with the goal of becoming a premier mid-tier
silver development company.

Apollo Silver’s assets are the Calico Silver
Project (the "Calico Project" or "Calico"),
located in the historical Calico Mining District,
in San Bernardino County, California, and the
Silver District Project, in La Paz County,
Arizona. The Calico Project is Apollo’s
cornerstone asset, which hosts an inferred
mineral resource of 166 Moz silver. Apollo's
2022 focus was on executing its program at
Calico, which was designed to expand and
upgrade the resource at Calico.

Link to Corporate Website

https://apollosilver.com/

Industry Classification

NAICS:
212220 Gold and silver ore mining

ISIC:
B0729 Mining of other non-ferrous metal ores

Market Capitalization

$0-$100Million USD

Type of Operations

Exclusively non-producing operations

Company Headquarters

Vancouver, Canada

ESG Accountability

Role and Name of highest authority within company for Environment, Social and Governance strategy, programs and performance

Thomas Peregoodoff, President, CEO and
Director

ESG Reporting Period

Unless otherwise noted, all data contained in this report covers the following period

From

2021-12-01

This ESG report is aligned with Apollo
Silver's financial reporting period.

2022-11-30

Audit Status

Identify the degree to which any inputs of the report are third-party checked

Self-Declared

Forward-Looking Statements

Financial Reporting Period

Specify the frequency of sustainability reporting

Annually

Whether Financial reporting period aligns with the period for its sustainability reporting

Yes

Specify the contact point for questions about the report or reported information

Rona Sellers, VP Commercial and Compliance
and Corporate Secretary

Geographic Scope of Report

Unless otherwise noted, the data in this report covers ESG matters related to the following countries of operations

• Canada
• USA

The primary focus of this report is the Calico
Project, the Company's flagship asset and is
located in San Bernardino County, California,
USA.

Identify notable exclusions, and reference any existing or planned reports that do or will address these (e.g, assets recently divested or acquired, non-managed joint ventures, specific exploration activities, recently closed sites, etc.)

During the ESG reporting period, Apollo Silver's
operations focused predominantly on the
exploration of the Company's Calico Project.

The Silver District Project is not included in
this 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

Business Operations Scope of Report

The Silver District Project is not included in this
report.

Mineral Resource Types in Scope

Which of the following mineral resource types are covered by this report

Inferred

Mineral Reserve Types in Scope

Which of the following mineral reserve types are covered by this report

None

Currency

Unless otherwise noted, all financial figures referenced in this report are in the following currency

CAD

Organizational Profile

Provide a list of externally-developed economic, environmental and social charters, principles, or other initiatives to which the organization subscribes, or which it endorses, e.g., GRI, UN Global Compact

In 2022, Apollo Silver adhered to the following
guidelines, as they related to our operations:

* CDP - Carbon Disclosure Project
* GRI - Global Reporting Initiative
* GRI Core - Global Reporting Initiative Lite
* GRI Comprehensive
* GRI MM Supplement
* ICMM - The International Council on Mining
and Metals
* SASB - Sustainability Accounting Standards
Board
* UN Global Compact.

Strategy

Provide a description of key impacts, risks, and opportunities,

While our environmental impacts are minimal
at the exploration stage, we evaluate impacts,
risks, and opportunities as they develop.

The Calico Project is located in an arid region
with limited water supplies and this may impact
the Company's ability to obtain sufficient
makeup water to support future operations,
including an on-site processing plant.

The Company will explore for groundwater at
the Calico Project, but it is likely that the
hardrock formations in the Calico District will
produce little groundwater. Purchase of water
rights for milling and mining dust control will
need to be pursued, which is not uncommon for
operations within desert regions.

The San Bernardino County Regional
Conservation Investment Strategy land
designation highlights that the northwestern
portion of the Calico Project (Langtry) is
located within the Superior- Cronese Area of
Critical Environmental Concern for the Mojave
Desert Tortoise (as designated by the
California Desert Renewable Energy Plan). No
formal vegetation or wildlife survey has been
completed on the Calico Project by Apollo
Silver.

Apollo Silver's Calico Project is subject to
known and unknown risks of the mining
industry, including without limitation, risks and
uncertainties discussed in the Company's most
recent 43-101 Technical Report, financial
statements and MD&A, as well as other
continuous disclosure documents available
under the Company's SEDAR profile at www.
sedar.com.

Mojave Desert Tortoise

Biologist visit

Burcham Water well testing

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 for contributing to sustainable development. (CEO's message for this report)

Please see attached statement from our
President & CEO.

CEO Statement

CEO Tom Peregoodoff

Policy commitments

Provide a description of the organization’s policy commitments for responsible business conduct

At Apollo Silver, our focus is on maintaining
strong environmental, social and governance
performance wherever we operate. We
prioritize minimizing our environmental impact
all while maintaining the safety of our
employees. We strive to operate with integrity
and within established and developing policy
guidelines that highlight our commitment to
responsible exploration and resource
development.

The Company has established a set of policies
with respect to its commitment to high
standards in the conduct of its business and of
its employees.

Apollo Silver's Policy Documents

Material Topics

Governance of Material Topics

Describe the process followed to determine the organization's material topics, including:

i. How has the organization identified actual and potential, negative and positive impacts on the economy, environment, and people, including impacts on their human rights, across its activities and business relationships; provide details

Other external sources, please list

As an exploration stage Company, Apollo Silver
has not conducted a formal materiality analysis
for this maiden ESG report.

In 2022, Apollo conducted a Biological
Resources Constraints Analysis, in accordance
with the guidelines set by the California
Environmental Quality Act.

The Company retains a team of professionals
that liaise with key stakeholders, including
communities, authorities, shareholders,
company employees and third-party
contractors. Through these engagements, the
Company is informed of issues that are material
to our stakeholders.

ii. How has the organization prioritized the impacts for reporting based on their significance

Apollo Silver intends on undertaking a formal
materiality analysis as part of its required
Environmental Site Assessments, as it enters
the project development stage.

Specify the stakeholders and experts whose views have informed the process of determining its material topics and provide details

• Civil society organizations
• Employees and other workers
• Governments
• Local communities
• Non-governmental organizations
• Shareholders and other capital providers

List the organization's material topics

• Indirect Economic Impacts
• Energy
• Water
• Biodiversity
• Emissions
• Effluents and Waste
• Compliance
• Environmental Assessment
• Environmental Grievances
• Occupational Health and Safety
• Diversity and Equal Opportunity
• Equal Remuneration for Women and Men
• Local Communities
• Permitting

List the organization's non-material topics

• Economic Performance
• Market Presence
• Procurement Practices
• Materials
• Products and Services
• Transport
• Overall environmental
• Supplier
• Employment
• Labor/Management Relations
• Training and Education
• Equal Remuneration for Women and Men
• Supplier Assessment for Labor Practices
• Labor Practices
• Grievance Mechanisms
• Human Rights Investment
• Non-discrimination
• Freedom of Association and Collective
Bargaining
• Child Labor
• Forced or Compulsory Labor
• Security Practices
• Indigenous Rights
• Supplier Human Rights Assessment
• Human Rights Grievance Mechanisms
• Anti-corruption
• Public Policy
• Anti-competitive Behavior
• Supplier Assessment for Impacts on Society
• Artisanal and Small-scale mining
• Resettlement
• Customer Health and Safety
• Product and Service Labeling
• Marketing
• Communications
• Customer Privacy
• Materials Stewardship

Provide reason for considering such topics not material, provide details

Other, please specify

Due to the scale and location of Apollo Silver's
activities in 2022, pre-revenue generation
stage, many of these topics are not deemed
significant to our Company. Apollo Silver is an
exploration stage Company operating in
California, where there are stringent laws and
regulations governing our practices.

Report changes to the list of material topics compared to the previous reporting period

This is Apollo Silver's maiden ESG report,
therefore, any changes in material topics will be
reported in subsequent years.

Environment

General Disclosure

Compliance with laws and regulations

Report the total number of significant instances of non-compliance with laws and regulations during the reporting period, and a breakdown of this total by:

Number of instances for which fines were incurred

Number of instances for which non-monetary sanctions were incurred

Report the total number of fines for instances of non-compliance with laws and regulations that were paid during the reporting period

Report the monetary value of fines for instances of noncompliance with laws and regulations that were paid during the reporting period ($Million)

Total number of fines for instances of non-compliance with laws and regulations that occurred in the current reporting period

Total monetary value of fines for instances of non-compliance with laws and regulations that occurred in the current reporting period ($Million)

Total number of fines for instances of non-compliance with laws and regulations that occurred in previous reporting periods

Total monetary value of fines for instances of non-compliance with laws and regulations that occurred in previous reporting periods

Describe the significant instances of non-compliance

Not applicable. Apollo Silver did not incur any
significant instances of non-compliance. During
this reporting period, Apollo Silver was in
compliance with all applicable environmental
laws and/or regulations in the jurisdictions in
which it operates.

Greenhouse Gas Emissions

Scope 1

For your operations, disclose the gross global Scope1 greenhouse gas (GHG) emissions to the atmosphere of the seven GHGs covered under the Kyoto Protocol (tonne CO₂-e)

Carbon dioxide (CO₂) (tonne CO₂-e)

336.362

Methane (CH₄) (tonne CO₂-e)

8.550

Nitrous oxide (N₂O) (tonne CO₂-e)

243.168

Hydrofluorocarbon-23 (CHF₃) (tonne CO₂-e)

0.000

Hydrofluorocarbon-32 (CH₂F₂) (tonne CO₂-e)

0.000

Sulphur hexafluoride (SF₆) (tonne CO₂-e)

0.000

Nitrogen trifluoride (NF₃) (tonne CO₂-e)

0.000

Perfluoromethane (CF₄) (tonne CO₂-e)

0.000

Perfluoroethane (C₂F₆) (tonne CO₂-e)

0.000

Perfluorobutane (C₄F₁₀) (tonne CO₂-e)

0.000

Perfluorohexane (C₆F₁₄) (tonne CO₂-e)

0.000

The total amount of gross global Scope 1 GHG emissions (CO₂-e) (tonne)

588.080

GHG emissions calculations were based on fuel
consumption for drilling equipment and light
vehicle transportation during the reporting
period. The GHG conversion factors used for
this calculation are based on the environmental
protection agency ("EPA") guidelines.

The percentage of its gross global Scope 1 GHG emissions that are covered under an emissions-limiting regulation or program that is intended to directly limit or reduce emissions, such as cap-and-trade schemes, carbon tax/fee systems, and other emissions control (e.g., command-and-control approach) and permit-based mechanisms

0.0000%

California's Cap-and-Trade Program,
introduced by the California Air Resources
Board in 2012, applies to entities that emit
25,000 or more metric tons of carbon dioxide
equivalent per year. Apollo Silver did not meet
the Cap-and-Trade Program threshold in 2022.

The entity shall discuss its long-term and short-term strategy or plan to manage its Scope 1 greenhouse gas (GHG) emissions

Apollo Silver does not have a long/short-term
strategy for limiting GHG emissions as this is
currently not a material issue while in the
exploration phase.

A long term strategy will be part of the overall
mine development plan.

Carbon Offset

Credits

How much CO₂ (metric tonnes) offset credits were purchased?

0.000

Air Emissions

Report emissions of air pollutants that are released into the atmosphere

Emissions of carbon monoxide, reported as CO (tonne)

1.970

Emissions of oxides of nitrogen (NOx), reported as NOx (tonne)

8.680

Emissions of oxides of sulphur (SOx), reported as SOx (tonne)

0.000

Emissions of Particulate Matter 10 micrometres or less in diameter (PM₁₀), reported as PM₁₀ (tonne)

0.610

Emissions of lead and lead compounds, reported as Pb (tonne)

0.000

Emissions of mercury and mercury compounds, reported as Hg (tonne)

0.000

Emissions of non-methane Volatile Organic Compounds (VOCs) (tonne)

1.180

Assets held by Apollo Silver are currently in the
exploration stage. The Company is not
monitoring air emissions as these are not
material at this stage of development. Apollo
Silver will establish an air emission baseline and
design the required monitoring systems based
on project needs during the environmental
impact assessment and feasibility studies, as
required by national and state authorities and
international best practice.

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)

4,917.000

Calculations for total energy consumed were
based on total fuel consumption and electricity
usage during the reporting period.

Percentage energy consumed that was supplied by grid electricity

1.4846%

Percentage of energy consumed that is renewable energy

0.0000%

Apollo Silver's primary activity in 2022 was
reverse circulation drilling, which is powered
by diesel. This energy intensive activity has
impacted total percentage of energy consumed
from renewable energy.

Water

Water Management

Disclose the amount of water that was withdrawn from freshwater sources (in thousands of cubic meters)

0.225

Disclose the freshwater withdrawn in locations with High or Extremely High Baseline Water Stress as a percentage of the total water withdrawn

0.0000%

Disclose water withdrawn in locations with High or Extremely High Baseline Water Stress (in thousands of cubic meters)

0.000

In 2022, Apollo Silver sourced its water from
the Daggett Community Services District
(98.5% ) and Barstow Golden State Water
Company (1.5%). According to the Aqueduct
Water Risk Atlas, both suppliers are located in
low baseline water stress locations as at
November 30, 2022.

Disclose freshwater consumed in locations with High or Extremely High Baseline Water Stress as a percentage of the total water consumed

0.0000%

Disclose the amount of water that was consumed in its operations (in thousands of cubic meters)

0.225

Total water consumed in locations with high or extremely high baseline water stress (in thousands of cubic meters)

0.000

Was your organization subject to any fines, enforcement orders, and/or other penalties for water-related regulatory violations

Total number of instances of non-compliance, including violations of a technology-based standard and exceedances of quality-based standards

Waste Management

Disclose the total weight of tailings produced (tonne)

0.000

The Calico Project is not an operating mine and
thus it does not generate any tailings.

Tailings Storage Facilities Management

Does your company manage Tailings Storage Facilities

Disclose the approach to the development of Emergency Preparedness and Response Plans (EPRPs)

Apollo Silver does not manage Tailings Storage
Facilities and therefore does not require EPRPs
for tailings storage.

Innovation

Spending on Research, Development, and Technologies for waste management compliance and improvement

The Calico Project is still in the exploration
stage. At the appropriate stage of project
development (e.g. feasibility stage), and if
required, Apollo Silver will review the need for
investment in research, development and
technologies for waste management.

Biodiversity

Management Plan

List the environmental and biodiversity management plan(s) implemented at active sites

Apollo Silver adheres to national, state and
county regulations and environmental best
practices to promote responsible stewardship
and sustainable exploration and resource
development.

The northwestern portion of the Calico Project
(Langtry property) is located within the
Superior- Cronese Area of Critical
Environmental Concern for the Mojave Desert
Tortoise (as designated by the California
Desert Renewable Energy Plan). As a result,
Apollo Silver has implemented a training and
mitigation plan in consultation with an
independent third-party consisting of
protection protocols for the Desert Tortoise.

These protection protocols are applicable to all
Apollo Silver employees, contractors, third-
party vendors and visitors to the Calico Project.

Apollo Silver Environmental Policy

Calico Project 43-101

Langtry desert tortoise in steam heated altered rocks

Desert Tortoise roaming the Langtry Property

1.1 Mine lifecycle stages to which the plan(s) apply

Exploration and appraisal

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)

Apollo Silver's desert tortoise mitigation plan is
derived from the Desert Tortoise Workshop
administered by the Desert Tortoise Council
and reviewed by ELMT Consulting, located
Santa Ana, California.

Impacts

Does access to the site involve traversing a protected area

Please refer to the map attached.

Map of Access to the Calico Project

Percentage of proved reserves in sites with protected conservation status or in areas of endangered species habitat

Does Not Apply

Percentage of probable reserves in sites with protected conservation status or in areas of endangered species habitat

Does Not Apply

Percentage of inferred, indicated and/or measured resources in sites with protected conservation status or in areas of endangered species habitat

0.0000%

Social

Scale of the Organization

Report the total number of operations

Employment

Scale of the Organization

Report the total number of direct employees worldwide (exclude contractors)

An employee is defined in accordance with
the Employment Standards Act (the "Act") and
includes:
(a) a person, including a deceased person,
receiving or entitled to wages for work
performed for another,
(b) a person an employer allows, directly or
indirectly, to perform work normally performed
by an employee,
(c) a person being trained by an employer for
the employer's business,
(d) a person on leave from an employer, and
(e) a person who has a right of recall.

Report the total number of male direct employees worldwide (exclude contractors)

Report the total number of female direct employees worldwide (exclude contractors)

Report the total number of contract employees worldwide

Total number of female employees and contractors worldwide

Female employees and contractors as percentage of total employees and contractors

32.0000%

Total number of male employees and contractors worldwide

Male employees and contractors as percentage of total employees and contractors

68.0000%

Total number of non-binary employees and contractors worldwide

In Accordance with the Canadian Human
Rights Act, Apollo Silver does not require
employees or contractors to disclose their sex
or gender, sexual orientation, gender identity,
and expression. As such, only those employees
and contractors that have self identified as non-
binary would have been included in this total.

All Company employees and contractors are
required to complete a 1 hour Sexual
Harassments and Abusive Conduct Prevention
Training mandated by the California
Department of Fair Employment and Housing.
Management is required to complete the 2
hour supervisory training course. Completion
of this training is evidenced by a certificate and
is valid for a period of 2 years.

Non-binary employees and contractors as percentage of total employees and contractors

0.0000%

Total number of employees and contractors with gender not disclosed

Employees and contractors with gender not disclosed as percentage of total employees and contractors

0.0000%

Employee Information

Report the total number of direct employees by employment type (permanent and temporary), by gender

Total number of permanent employees

Total number of permanent employees - female

Total number of permanent employees - male

Total number of permanent employees - Gender not disclosed

Total number of temporary employees

Total number of temporary employees - female

Total number of temporary employees - male

Total number of temporary employees - Gender not disclosed

Report the total number of employees by employment type (full-time and part-time), by gender

Report the total number of full-time employees

Report the total number of part-time employees

Total number of full-time employees - female

Total number of part-time employees - female

Total number of full-time employees - male

Total number of part-time employees - male

Total number of full-time employees - Gender not disclosed

Total number of part-time employees - Gender not disclosed

Workers who are not employees

Report the total number of contractors by employment type (permanent and temporary), by gender

Total number of permanent contractors

Total number of permanent contractors - female

Total number of permanent contractors - male

Total number of permanent contractors - Gender not disclosed

Total number of temporary contractors

Total number of temporary contractors - female

Total number of temporary contractors - male

Total number of temporary contractors - Gender not disclosed

Report the total number of contractors by employment type (full-time and part-time), by gender

For this report, full-time contractors are
defined as those that worked exclusively for
the Company during the reporting period.

Total number of full-time contractors - female

Total number of part-time contractors - female

Total number of full-time contractors - male

Total number of part-time contractors - male

Total number of full-time contractors - Gender not disclosed

Total number of part-time contractors - Gender not disclosed

Turnover

Report the total number and rate of employee turnover during the reporting period, by age group, and gender

All Employees

Total number of turnover (the number that left during the period)

Rate of turnover

0.0000%

Female employees

Total number of turnover (the number of females that left during the period)

Rate of turnover, females

0.0000%

Male employees

Total number of turnover (the number of males that left during the period)

Rate of turnover, males

0.0000%

Non-binary employees

Rate of turnover, non-binary

Does Not Apply

Turnover & Age Breakdown

Employees aged 30 years old and under

Total number of turnover (the number that left during the period)

As percent of total employees

56.0000%

Rate of turnover

0.0000%

Employees aged between 30 and 50 years old

Total number of turnover (the number that left during the period)

As percent of total employees

36.0000%

Rate of turnover

0.0000%

Employees over 50 years old

Total number of turnover (the number that left during the period)

As percent of total employees

12.0000%

Rate of turnover

0.0000%

Identify types of employees captured in the turnover rate calculations

All employees on the payroll

Diversity and Equal Opportunity

Report the percentage of employees per employee category in each of the following diversity categories

Board of Directors

Total Board of Directors

Percent Male

71.4286%

Percent Female

28.5714%

Percent Non-Binary

0.0000%

Percent under 30 years of age

0.0000%

Percent between 30 and 50 years of age

28.5714%

Percent over 50 years of age

71.4286%

Senior Management

Total Senior Managers

Percent Male

50.0000%

Percent Female

50.0000%

Percent Non-Binary

0.0000%

Percent under 30 years of age

0.0000%

Percent between 30 and 50 years of age

50.0000%

Percent over 50 years of age

33.3333%

Salaried (excluding Senior Management)

Total Salaried (excluding Senior Management)

Percent Male

50.0000%

Percent Female

50.0000%

Percent Non-Binary

0.0000%

Percent under 30 years of age

50.0000%

Percent between 30 and 50 years of age

50.0000%

Percent over 50 years of age

0.0000%

Technical Employees (skilled hourly)

Total Technical Employees

Production Employees (unskilled hourly)

Total Production Employees

Contractors:

Total Contractors

Percent Male

76.4706%

Percent Female

23.5294%

Percent Non-Binary

0.0000%

Percent under 30 years of age

17.6471%

Percent between 30 and 50 years of age

76.4706%

Percent over 50 years of age

5.8824%

Labour Relations

Notice Periods

Minimum number of weeks’ notice typically provided to employees and their representatives prior to the implementation of significant operational changes that could substantially affect them

Apollo Silver employees have contractually
stipulated notice periods in their employment
agreements that not only meet, but in most
cases exceed, the standards set out in the Act.

Occupational Health and Safety

Work-related Injuries

Injuries - For all employees

i. Number of fatalities as a result of work-related injury

i. Rate of fatalities resulting from work-related injury. Note: calculating per 200,000 hours worked

0.000

ii. Number of high-consequence work-related injuries (excluding fatalities)

ii. Rate of high-consequence work-related injuries (excluding fatalities)

0.000

iii. Number of recordable work-related injuries

iii. Rate of recordable work-related injuries

0.000

iv. Main types of work-related injury, e.g., confined space, trips, falls, etc.

There were no work-related injuries in the
reporting period.

v. Number of hours worked

14,916

Lost Time Injuries (LTIs)

Lost Time Injuries Rate (LTIR)

0.000

Injuries - workers who are not employees but whose work and/or workplace is controlled by the organization

i. Number of fatalities as a result of work-related injury

i. Rate of fatalities resulting from work-related injury. Note: calculating per 200,000 hours

0.000

ii. Number of high-consequence work-related injuries (excluding fatalities)

ii. Rate of high-consequence work-related injuries (excluding fatalities)

0.000

iii. Number of recordable work-related injuries

iii. Rate of recordable work-related injuries

0.000

iv. Main types of work-related injury, e.g., confined space, trips, falls, etc.

There were no work-related injuries in the
2021-2022 reporting period.

v. Number of hours worked

11,014

Lost Time Injuries (LTIs)

Lost Time Injuries Rate (LTIR)

0.000

Combined (Employees and non-employees, but controlled by the organization):

Total Hours Worked

25,930

Total number of all work-related injuries

Rate of work-related injuries

0.000

Total Lost Time Injuries (LTIs)

Lost Time Injuries Rate (LTIR)

0.000

Report the work-related hazards that pose a risk of high-consequence injury, including

i. How have these hazards been determined

Apollo Silver's activities at the Calico Project,
located in the Mojave Desert, are
predominantly exploration related activities,
which by their nature can be hazardous. We
take both a proactive approach, through risk
analysis management, and reactive approach to
determine hazards ahead of and during the
field season. Risk analysis is completed by the
Project General Manager, signed off by the
President and CEO and communicated to the
Board of Directors.

Identified hazards include, but are not limited
to wildlife, working in historical mine conditions
(such as, open unsecured shafts, adits and drill
holes), extreme temperatures, falls, respirable
dust, vehicles, and entering unauthorized areas.

ii. Which of these hazards have caused or contributed to high-consequence injuries during the reporting period

Apollo Silver did not sustain any high-
consequence injuries during this reporting
period.

iii. Actions taken or underway to eliminate these hazards and minimize risks using the hierarchy of controls

Site Specific Hazard Awareness Training is
mandatory for all employees, contractors and
visitors.

The Company employs hazard communication
procedures, emergency procedures and
policies in order to mitigate hazards and
respond to incidents in an expedited and
controlled manner. Some examples of how
identified hazards are minimized or eliminated
include, adequate signage, dust suppression
measures, heat prevention and rules and
procedures around drilling activities.

Waterloo Property warning sign

Report on actions taken or underway to eliminate other work-related hazards and minimize risks using the hierarchy of controls

Apollo Silver has a comprehensive Health,
Safety and Environment (“HSE”) orientation for
all employees, contractors and visitors to its
worksite, as part of its overall Safety
Management Program (the “Program”). The
Program is designed with all pre-identified
operational risks in mind.

The goal of the Program is to prevent job
related injuries and illnesses.

The HSE orientation includes, but is not limited
to:
• Apollo’s Expectations
• Apollo’s Cardinal Rules
• Code of Safe Practices
• Contractor Requirements
• Emergency Response, Evacuation and Fire
Prevention Program
• Working in Heat
• Flora and Fauna
• Desert Tortoises
• Cultural Artifacts and Fossils
• COVID-19 Prevention Plan
• The Community
• Property Map, Location and Evacuation

All Apollo employees, independent contractors,
and visitors are required to complete the HSE
orientation and to familiarize themselves with
site conditions and workplace hazards and are
required to sign an acknowledgment to that
effect.

The site team commences each day with a
toolbox meeting that covers a daily HSE topic.
At this meeting, incidents from the previous
day, if any, are reported and recommendations
are made to mitigate or eliminate the risks
going forward. Further, a daily flash report is
prepared by the Project General Manager and
circulated to the management team.

Whether and, if so, why any workers have been excluded from this disclosure, including the types of worker excluded, e.g., short-term contractors

No workers were excluded from this disclosure.

Disclose any contextual information necessary to understand how the data have been compiled, i.e., any standards, methodologies, and assumptions used

Apollo Silver has developed a Safety
Management Program in alignment with the
Division of Occupational Safety and
Health ("Cal/OSHA") and the rules, regulations
and laws governing the State of California.

Following a daily toolbox meeting, the shift
supervisor documents and reports any work-
related incidents to the Project General
Manager. The Project General Manager
records and reports a summary of any incidents
to senior management as part of the daily flash
report.

Work-related injuries are defined according to
Cal/OSHA's guidelines, as further set out in the
California Department of Industrial Relations
Code of Regulations, and rates are calculated
on 200,000 hours worked.

Safety Training

Disclose the average number of training hours provided to its workforce for health, safety, and emergency management training

Average hours of health, safety, and emergency response training for (a) full-time/direct employees

1.75

Average hours of health, safety, and emergency response training for (b) contract employees

Security, Human Rights and Rights of Indigenous People

Identify the countries of operations within the World Bank's list of “Fragile and Conflict-Affected Situations”

None

Percentage of proved reserves that are located in or near areas of active conflict

Does Not Apply

The total amount of proved reserves

Percentage of probable reserves that are located in or near areas of active conflict

Does Not Apply

The total amount of probable reserves

Percentage of inferred, indicated and measured resources that are located in or near areas of active conflict

0.0000%

Total amount of inferred, indicated and/or measured resources

166,000,000

The Calico Project has an inferred mineral
resource of 166,000,000 ounces of silver.

Percentage of proved reserves that are located in or near areas that are considered to be indigenous peoples’ land

Does Not Apply

The total amount of proved reserves

Percentage of probable reserves that are located in or near areas that are considered to be indigenous peoples’ land

Does Not Apply

The total amount of probable reserves

Percentage of inferred, indicated and measured resources that are located in or near areas that are considered to be indigenous peoples’ land

0.0000%

Total amount of inferred, indicated and measured resources

166,000,000

Describe due diligence practices and procedures with respect to indigenous rights of communities in which it operates or intends to operate

The Company's due diligence practices and
procedures with respect to indigenous rights of
communities in which we operate are threefold:

1) Key stakeholder analysis by an independent
consultant;
2) Pre-activity consultation; and
3) Regular updates to all stakeholders.

The Company engaged with the San Manuel
Mission Indians and the Morongo Mission
Indians tribal organizations soon after
acquiring the Calico Project. A senior executive
of the Company met with the San Manuel tribal
archaeologist to discuss the tribe's knowledge
of the land, and any possible concerns with our
work and procedures in the event artifacts are
encountered.

Additionally, Apollo Silver communicates its
work plans to both tribal organizations as part
of its commitment to transparency and
stakeholder engagement.

The tribes do not hold active land claims or
private lands on or in the vicinity of the Calico
Project. Their communities are located
approximately 85 kilometers from the Calico
Project area.

Discuss practices and list procedures while operating in areas of conflict

Apollo Silver does not operate in areas of
conflict as defined by the SASB standard.

Community Relations

Artisanal and Small-Scale Mining

Number of company operating sites where artisanal and small-scale mining (ASM) takes place on, or adjacent to, the site (not controlled by company/unauthorized)

Percentage of company operating sites where artisanal and small-scale mining (ASM) takes place on, or adjacent to, the site

Does Not Apply

Programs

Report on community relations programs, objectives and achievements in the past 3 years

Apollo Silver strongly believes that
relationships within the communities in which
we operate is crucial to our success and
advancement of the Calico Project.

Our community relations programs and
achievements in 2022 consist of the following:

1) Member of the Daggett Historical Society.
2) Member of the Barstow Chamber of
Commerce.
3) Primary sponsor of the 2022 California Days
at Calico Ghost Town Regional Park.
4) Sponsor of the 2022 Calico Trail Run.
5) Sponsor of the Bunny Hop Community Event
organized by the Barstow Chamber of
Commerce.
6) Sponsor of the Kid's Water Day hosted by
the Daggett Community Service District.
7) Collaborating with the Regional Parks
Department in San Bernardino on a permanent
mining display for the Calico Ghost Town Park.

Sponsorship of the Bunny Hop community event

2022 California Days at Calico

Daggett Historical Society presentation

Sponsorship of the Calico Trail Run -

Discuss the processes, procedures, and practices to manage risks and opportunities associated with the rights and interests of communities in areas where it conducts business

Apollo Silver manages risks and opportunities
related to the rights and interests of the local
communities by regularly engaging with
community leaders and members through
open, honest and transparent dialogue. This
includes apprising them of what is ahead,
partnering when possible, and procuring local
labour, supplies and services, when possible.

While undertaking drilling activities, the
Company used the Hurricane vacuum system
to control drill dust. Noise and light levels from
drilling activities were also monitored to ensure
minimal disturbance to the surrounding
communities.

Apollo Silver also has a community relations
designee in the Barstow area with established
relationships in the community.

Risks and Opportunities

Disclose the total number of site shutdowns or project delays due to non-technical factors

Disclose the total aggregate duration (in days) of site shutdowns or project delays due to non-technical factors

Governance

Climate Change

Oversight

Is there board-level oversight of climate-related issues within your organization

Yes

Responsibility

Provide the highest management-level position(s) or committee(s) with responsibility for climate-related issues

Chief Executive Officer (CEO)

Nature of primary responsibility

Both assessing and managing climate-related
risks and opportunities

Reporting

Frequency of reporting to the board on climate-related issues

As important matters arise

The President and CEO reports on health,
safety and environmental matters at every
meeting of the Board of Directors.

Incentives

Do you provide incentives for the management of climate-related issues, including the attainment of targets

No, and we do not plan to introduce them in the
next two years

Risk and Opportunity Management

Does your organization have a process for identifying, assessing, and responding to climate-related risks and opportunities

Yes

Apollo Silver completed a risk analysis prior to
commencing work on the Calico Project. The
Company's three step process to risk
management framework includes: identifying
and understanding our risks and opportunities;
managing and reducing the identified risks;
and measuring and reporting on our risks and
opportunities.

When unforeseen risks arise, the Company
retains legal, environmental, regulatory experts
and advisors to provide guidance on potential
risks and opportunities.

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 - evaluation in process

Opportunity Assessments

Have you identified any climate-related opportunities with the potential to have a substantive financial or strategic impact on your business

Other, please specify

With silver as a key material in solar energy
applications and silver paste as a key ingredient
in photovoltaic cells used in solar panels, there
are tremendous financial climate related
opportunities for Apollo Silver. The cost and
strategy to realize this opportunity is
something Apollo Silver expects to explore at a
later stage of development.

Strategy

Have climate-related risks and opportunities influenced your organization’s strategy and/or financial planning

Water Management

Quality and Quantity Dependency

Rate the importance (current and future) of freshwater quality and quantity to the success of your business

Direct use importance rating

Important

Indirect use importance rating

Important

Rate the importance (current and future) of sufficient quantity of recycled, brackish and/or produced water for the success of your business

Direct use importance rating

Important

Indirect use importance rating

Important

Risk Assessments

Does your organization undertake a water-related risk assessment

Yes, water-related risks are assessed

Apollo Silver has identified and disclosed
water-related risks and uncertainties for its
Calico Project. The Company will undertake the
required water-related risk assessments as part
of its feasibility study.

Have you identified any inherent water-related risks with the potential to have a substantive financial or strategic impact on operations

Other, please specify

The Calico Project is located in an arid region
with limited water supplies that may impact the
ability to obtain sufficient makeup water to
support an onsite processing plant. At this
stage, the Company recognizes water-related
risks within its direct operations, and will
develop strategies to mitigate the financial and
strategic impacts.

Apollo Silver intends to undertake a detailed
water supply and quality impact assessment in
the future. This will be followed by a water
management plan, in accordance with the
requirements of the California State Water
Resources Control Board and to be approved
by San Bernardino County.

Opportunity Assessments

Have you identified any water-related opportunities with the potential to have a substantive financial or strategic impact on your business

Other, please specify

See above

Responsibility

Provide the highest management-level position(s) or committee(s) with responsibility for water-related issues

Chief Executive Officer (CEO)

Policy

Does your organization have a documented water policy

No, but we plan to develop one within the next
2 years

Reporting

Frequency of reporting to the board on water-related issues

Quarterly

Incentives

Do you provide incentives to C-suite employees or board members for the management of water-related issues

No, and we do not plan to introduce them in the
next two years

Strategy

Are water-related issues integrated into any aspects of your long-term strategic business plan

Other, please specify

No, but the Company will continually monitor
water-related issues and integrate it into the
long-term strategic business plan when deemed
appropriate.

General Disclosure

Governance structure and composition

Describe its 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.

Apollo Silver's Board of Directors is comprised
of seven (7) members, and two (2) standing
committees: Audit Committee and
Compensation Committee.

The Company has four (4) Executives: the
President and CEO, the Chief Financial Officer,
the Vice President of Exploration & Resource
Development, and the Vice President of
Commercial & Compliance and Corporate
Secretary.

The President and CEO reports to the Board of
Directors, and the remaining Executives report
directly to the President and CEO.

All four Executives are members of the
Disclosure Committee. The Disclosure
Committee is responsible for assessing
controls, procedures and policies with respect
to all electronic, written and oral disclosure of
corporate information, among other things.

Please refer to the Company's Organizational
Chart for a full view of the Company's
structure.

Apollo Silver Board of Directors

Disclosure Policy

Apollo Silver's Board of Directors and Management at the Calico Project

Apollo Silver Board of Directors and Management Team

List the committees of the highest governance body that are responsible for decisionmaking on and overseeing the management of the organization’s impacts on the economy, environment, and people; e.g., the Board of Directors, the Executives, the Board Environment Committee, Board Safety Committee, the Advisory Committee, etc

The Board of Directors as a whole is
responsible for decision-making on economic,
environmental and social topics.

Delegation of responsibility for managing impacts

Describe whether the highest governance body has 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, the CFO or internal audit reporting to the Board

Yes

Describe whether the highest governance body has delegated responsibility for the management of impacts to other employees;

Thomas Peregoodoff, the President and CEO,
is responsible for reporting ESG related issues
directly to the Board of Directors.

Consultation Process

Report the processes for consultations between stakeholders and the highest governance body on economic, environmental and social topics, e.g., for most mining companies it would be the executives and operations and not the Board, and if delegated, explain how

The CEO reports on ESG issues to the Board of
Directors on a quarterly basis through regularly
scheduled Board meetings.

Governance structure and composition

Describe the composition of the highest governance body and its committees by

Number of executive members

Number of non-executive members

Number of independent members

Less than 3 years of tenure of members on the governance body

3-6 years of tenure of members on the governance body

6-9 years of tenure of members on the governance body

More than 10 years of tenure of members on the governance body

Number of other significant positions and commitments held by each member, and the nature of the commitments

For a description of our Board of Director's
other significant positions please refer to the
link below.

Apollo Silver Board of Directors

Number of Male governance body members

Number of Female governance body members

Number of members from under-represented social groups

Description of competencies relating to economic, environmental, and social topics

Please refer to the attached document for a
description of our Board of Directors'
competencies on environmental, social and
governance issues.

Apollo Silver Board of Directors

Description of stakeholder representation

Apollo Silver is a Canadian exploration and
development company. Its stakeholder
representation consists of employees and
workers who are not employees, service
suppliers, local communities, its shareholders
and providers of capital.

Board Diversity

Do you have a diversity policy and if so, provide details, link to the policy or attach the file

Yes

Apollo Silver's diversity policy is entrenched in
its Mandate for the Board of Directors.

Chair of the highest governance body

Is the chair of the highest governance body is also a senior executive in the organization

Conflicts of Interest

Describe the processes for the highest governance body to ensure that conflicts of interest are prevented and mitigated

The Company has a Code of Business Conduct
and Ethics (the "Code") that governs its
responsibilities regarding conflicts of
interest.

The Code requires members of the Board of
Directors to disclose their conflict to the Board
of Directors and to refrain from voting on the
matter giving rise to the conflict. Where a
conflict involves a senior officer, approval of
the Board of Directors will be required. Where
a conflict involves an employee or a consultant,
approval of a member of senior management
will be required.

Apollo Silver's Code of Business Conduct and
Ethics

Report whether conflicts of interest are disclosed to stakeholders, including, as a minimum, conflicts of interest relating to

Yes

Cross-board membership

Yes

Cross-shareholding with suppliers and other stakeholders

Yes

Existence of controlling shareholder

Yes

Related parties, their relationships, transactions, and outstanding balances

Yes

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

In 2022, an in-person meeting of the Board of
Directors was held in Barstow, California and
included a site and community tour. The
primary purpose of the visit was to familiarize
the Board of Directors with environmental,
social and governance factors relevant to the
Calico Project and surrounding communities.

The Board of Directors is periodically offered
third party training and update on ESG issues.

Board of Directors site visit

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

Apollo Silver's Board of Directors identified key
environmental, social and
governance expertise required for the
advancement of the Company's projects and
actively recruited members to the Board of
Directors to compliment their expertise.

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 Company's Board of Directors is
responsible for the development and changes
to the organization's purpose, value, and
mission statement, as well as all environmental,
social and governance strategies, policies and
goals.

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

Apollo Silver's Board of Directors is ultimately
accountable for, and oversees economic,
environmental and social topics and their
impacts, risks and opportunities. The Board as a
whole sets performance policies and
procedures and receives feedback for continual
improvement.

Describe whether and how the highest governance body engages with stakeholders to support these processes

The CEO reports on ESG issues derived from
stakeholder consultations to the Board on a
quarterly basis through regularly scheduled
board meetings.

Ethics

Describe the management system and due diligence procedures for assessing and managing corruption and bribery risks internally and associated with business partners in its value chain

The Board of Directors has adopted a Code of
Business Conduct and Ethics delineating the
highest standards of professional and ethical
conduct with which all employees, officers,
directors, consultants and contractors are
expected to comply.

The Code prohibits bribery of public officials
and third parties and requires compliance with
all anti-corruption and other applicable laws in
the countries where the Company does
business.

All employees, officers, directors, consultants
and contractors are required to annually
review and sign-off on Code to confirm their
compliance. Any violations to the Code may
result in disciplinary actions up to and including
discharge from the Company.

In this reporting period, no reports of ethical
violations and no whistleblower complaints
were received by Apollo Silver.

Apollo Silver's Code of Business Conduct &
Ethics

Report net production from activities located in the countries with the 20 lowest rankings in Transparency International’s Corruption Perception Index (CPI) (Saleable tonne)

Anti-Corruption

Communication and Training

i) Total number of governance body members that have received training on anti-corruption, broken down by region

Apollo Silver's anti-corruption and anti-bribery
obligations are embedded in the Company's
Code of Business Conduct and Ethics policy
(the "Code"). All employees, officers and
members of the Board of Directors must
adhere to the Code's principles and policies and
must sign a Certification evidencing their
acknowledgement of the Code.

Code of Business Conduct and Ethics
Certification

ii.) Total percentage of governance body members that have received training on anti-corruption, broken down by region

100.0000%

Total number of employees

1b. Total percentage of employees that received training on anti-corruption

100.0000%

Total number of senior employees

2b. Percentage of senior employees that received training on anti-corruption

Does Not Apply

Total number of middle management employees

3b. Percentage of middle management employees have received training on anti-corruption

Does Not Apply

Total number of technical employees

4b. Percentage of technical employees that received training on anti-corruption

Does Not Apply

Total number of production employees

5b. Percentage of production employees that received training on anti-corruption

Does Not Apply

Total number of administrative employees

6b. Percentage of administrative employees that received training on anti-corruption

Does Not Apply

General Disclosure

Remuneration

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

The Company's senior executives
have measurable KPIs that are linked
to environmental, social and governance
objectives.

Tax

Describe the approach to stakeholder engagement and management of stakeholder concerns related to tax, including:

i. The approach to engagement with tax authorities

Apollo Silver complies with the local tax laws
and regulations, including timely filing of
relevant tax returns and related reports within
the regions in which it operates.

ii. The approach to public policy advocacy on tax

Apollo Silver does not directly engage in public
policy advocacy on tax and it does not make any
political donations or contributions in any of
the regions it operates in.

Apollo Silver complies with the Canadian
Extractive Sector Transparency Measures Act
(ESTMA), which requires public reporting of
payments over CAD$100,000 made to
governments organizations in Canada and
abroad.

iii. The processes for collecting and considering the views and concerns of stakeholders, including external stakeholders

Apollo Silver engages with both internal and
external stakeholders regularly and addresses
any stakeholder concerns that may arise from
time to time.



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