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Published on July 31, 2023 |
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Aya Gold & Silver Inc. (the “Corporation or “Aya”) is a Canadian based precious metals mining corporation which focuses on the exploration, development, production and acquisition of precious metals mining projects.
Its mission is to build a sustainable, ethical and profitable mining business that positively impacts lives.
The Corporation is concentrated on producing silver and exploration activities at its flagship project, the Zgounder property through its 100% ownership of Zgounder Millenium Silver Mine S.A (“ZMSM”). The Corporation also owns 85% of the Boumadine polymetallic project and is the sole owner of the permits related to the Amizmiz, Azegour, Zgounder Regional and Imiter bis properties. All of these properties are located in the Kingdom of Morocco. The Corporation also owns through Algold Resources Ltd. (“Algold”), 75% of the Tijirit project located in Mauritania. Aya’s registered office is located at 1320 boulevard Graham, suite 132, Mont-Royal, Quebec, Canada, H3P 3C8.
Aya is incorporated under the Canada Business Corporations Act; its financial year-end is December 31 and trades on the Toronto Stock Exchange under the symbol “AYA” and on the OTCQX under the symbol “AYASF”. All projects other than the Zgounder project are at the exploration and evaluation stage. |
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Disclaimer and Forward Looking Statements |
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Company Profile |
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Organizational Profile |
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Name |
Aya Gold & Silver |
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Describe nature of activities, brands, products and services |
Aya Gold & Silver's goal is to create shareholder value by generating revenue and growth through its operations and exploration programs. Our seasoned team of directors and officers have extensive experience launching and operating precious metals mines around the world. |
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Together with ongoing Zgounder operational improvements, Aya Gold & Silver is focused on extending Zgounder high-grade mineralization through drill programs with the aim of expanding plant capacity from 700 tpd to 2,700 tpd. |
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Link to Corporate Website |
https://ayagoldsilver.com/ |
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Industry Classification |
NAICS: 2122 Metal ore mining 21222 Gold and silver ore mining |
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Market Capitalization |
$100 Million up to $1 Billion USD |
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Type of Operations |
Primarily production oriented |
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Company Headquarters |
Mont-Royal, Canada |
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ESG Accountability |
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Role and Name of highest authority within company for Environment, Social and Governance strategy, programs and performance |
Benoit La Salle, President & CEO |
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ESG Reporting Period |
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Unless otherwise noted, all data contained in this report covers the following period |
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From |
2022-01-01 |
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To |
2022-12-31 |
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External Assurance |
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Describe its policy and practice for seeking external assurance, including whether and how the highest governance body and senior executives are involved |
This ESG report was first reviewed internally and by analysts from the Onyen Corporation.
The report has been submitted to the ESG Committee of the Board of Directors for final approval before publication. |
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Has the report been externally assured |
No |
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Audit Status |
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Identify the degree to which any inputs of the report are third-party checked |
Self-Declared |
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Financial Reporting Period |
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Specify the frequency of sustainability reporting |
Annually |
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Whether Financial reporting period aligns with the period for its sustainability reporting |
Yes |
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Specify the contact point for questions about the report or reported information |
David Vilder |
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Questions about the report or reported information should be addressed to David Vilder, Sustainability Manager : david.vilder@ayagoldsilver.com |
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Geographic Scope of Report |
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Unless otherwise noted, the data in this report covers ESG matters related to the following countries of operations |
• Canada • Mauritania • Morocco |
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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.) |
In 2022, Aya Gold & Silver holds six exploration assets located in Morocco and Mauritania, and its headquarters are located in the Town of Mount Royal, Quebec, Canada.
This report generally focuses on our single operational site, the Zgounder Silver Mine, while including our exploration activities on the Boumâadine property and Zgounder regional in 2022. As such, all disaggregated information regarding human resources, health and safety, environment, community relations, and climate change relate to all Moroccan employees and activities.
Financial information, however, is disclosed for all of Aya's assets (administrative offices and exploration sites) in Morocco, Mauritania and Canada.
Finally, the governance section of this report relates to Aya's Corporate team in its head office in Canada and to the Corporation's Board of Directors. |
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Zgounder Silver Mine
Boumadine Exploration Project Description
Amizmiz Exploration Project Description
Imiter Bis Exploration Project Description
Azegour Exploration Project Description
Tijirit Exploration Project Description |
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Fragile and Conflict-Affected Situations |
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Identify all of the entity's countries of operations that align with the World Bank's list of "Fragile and Conflict-Affected Situations" |
None |
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Business Operations Scope of Report |
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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.) |
See answer above for Geographic Scope of Report. |
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Mineral Resource Types in Scope |
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Which of the following mineral resource types are covered by this report |
• Inferred • Indicated • Measured |
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Mineral Reserves – Zgounder Mine, Morocco |
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Mineral Reserve Types in Scope |
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Which of the following mineral reserve types are covered by this report |
• Proven • Probable |
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Currency |
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Unless otherwise noted, all financial figures referenced in this report are in the following currency |
USD |
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Markets |
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Report the sector(s) in which it is active |
Primary metal |
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Aya Gold and Silver is a producer in the mining and metals industry. |
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Reporting Practice |
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Report significant changes from previous reporting periods in the list of material topics and topic Boundaries |
The 2022 ESG report does not contain any significant changes in the list of material topics and topic boundaries. |
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If applicable, report the date of the most recent previous report |
2022-07-25 |
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Choose the statement as to whether the organization has chosen the CORE or COMPREHENSIVE options in preparing the GRI aligned report |
This report has been prepared in accordance with the GRI Standards: Comprehensive option |
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Provide a list of all legal entities included in its sustainability reporting |
Aya Gold & Silver Inc. (the “Corporation or “Aya”) is a Canadian-based precious metals mining corporation focusing on the exploration, development, production and acquisition of precious metals mining projects.
The Corporation is concentrated on producing silver and exploration activities at its flagship project, the Zgounder property. Aya owns 100% of Zgounder Millenium Silver Mine S.A (“ZMSM”), which owns the Zgounder property.
The Corporation also owns 85% of the Boumadine polymetallic project and owns the permits related to the Amizmiz, Azegour, Zgounder Regional and Imiter bis properties.
All of these properties are located in the Kingdom of Morocco.
Following the acquisition of Algold Resources Ltd. (“Algold”) completed on June 10, 2021, Aya owns 75% of the Tijirit project located in Mauritania.
Our subsidiaries include: • Aya Gold & Silver Maroc S.A. (“AGSM”) • Zgounder Millenium Silver Mining S.A. (“ZMSM”) • Boumadine Global Mining S.A. (“BGM”) • Atlas Gold & Silver S.A.R.L.(“AGS”) • Kanosak (Barbados) Limited (“KANOSAK”) • Algold Resources Ltd. (“Algold”) • Algold Mauritania SARL (“ALGOLD SARL”) • Société Tijirit Recherche et Exploration SARL (“TIREX”) • Precious Metal Finance and Services Inc. (“PMFS”) |
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Aya Gold & Silver Financial Reports |
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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 |
There are no exclusions related to this report. |
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If the organization consists of multiple entities, explain the approach used for consolidating the information |
The consolidated financial statements of the Corporation have been prepared in accordance with International Financial Reporting Standards ("IFRS"). |
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Does the approach involve adjustments to information for minority interests |
Where the Corporation’s interest in a subsidiary is less than 100%, the Corporation recognizes noncontrolling interests in its Consolidated Financial Statements. |
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How does the approach take into account mergers, acquisitions, and disposal of entities or parts of entities |
In 2022, the Corporation purchased the 15% non controlling interests (NCI) owned by OHNYM in ZMSM. Following the acquisition, the Corporation reversed the equity portion of NCI. Aya was not involved in any merger or disposal activities in 2022.
Refer to the 2022 audited financial statements for further information. |
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Explain whether and how the approach differs across the disclosures in this Standard and across material topics |
N/A |
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Report the reasons for restatements, if any, from previous reporting periods |
In 2023, Aya restated the CO2 factors used for Scope 1 and 2 in its 2021 ESG report.
In May 2023, Aya Gold & Silver contracted a Moroccan consulting firm to calculate its Scope 3 emissions. Through this new partnership, Aya was able to access a new set of factors that are official for Morocco. This resulted in changing our Scope 2 emissions from 21930.617 to 9607.359 CO₂-e tonnes.
Until then, our calculations were based on the factors from the GHG Protocol Tool and the International Energy Agency, which had factors for the Moroccan grid for up to 2020 only.
From 2023 on (which includes the disclosures in the present 2022 ESG report), Aya will exclusively use the factors from the Outil Bilan Carbone Maroc for its Scope 1 and 2 emissions. |
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L’Outil Bilan Carbone Maroc |
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Provide the contact point for questions regarding the report or its contents |
For questions regarding this report, please contact the following: |
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David Vilder, HSEC Manager, david.vilder@ayagoldsilver.com |
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Membership of Associations |
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List of the industry associations, other membership associations, and national or international advocacy organizations in which the organisation participates in a significant role |
In 2022, Aya Gold & Silver did not belong to industry or other associations, including national and international advocacy organizations. |
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Raw Material Produced |
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Metals |
58.497 |
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Aya Gold & Silver has only one project in operations, the Zgounder Silver Mine, which produces silver. In 2022, The Zgounder Silver Mine produced 1880707 ounces of silver. |
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Finished Product for Sale |
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Metals |
58.497 |
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Silver (Ag) (tonne) |
58.497 |
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Net Sales |
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Report the following information ($Millions) |
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Report the net sales (for private sector organizations) ($Millions) |
38 |
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Aya Gold & Silver's 2022 financial statements |
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Organizational Profile |
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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, the Corporation was not a member of any associations and did not participate in any external initiatives.
However, Aya Gold & Silver follows the following initiatives and standards in its approach to Sustainability and HSEC Governance :
• The Global Reporting Initiative (GRI); • The Task Force on Climate-related Financial Disclosures (TCFD); • ISO 14001 and 45001 standards; • The European Bank for Reconstruction and Development (EBRD)'s Environmental and Social Policy; • The International Finance Corporation (IFC)'s Performance Standards; • ICMM guidance. |
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For the purpose of this report, Aya Gold & Silver is disclosing information aligned with the following standards:
• CDP - Carbon Disclosure Project • GRI - Global Reporting Initiative • GRI MM Supplement - Global Reporting Initiative - Mining and Metals Supplement • ICMM - International Council on Mining & Metals • IFC - International Finance Corporation - Equator Principles • ONYEN - Institutional and Investor Questions • OSHA - Occupational Safety and Health Administration • SASB - Sustainability Accounting Standards Board • TCFD - The Task Force on Climate-related Financial Disclosures
Aya's HSEC Governance
Aya's approach to Sustainability |
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Strategy |
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Provide a description of key impacts, risks, and opportunities, |
The impacts, risks and opportunities of the Zgounder Silver Mine are outlined in the Zgounder Silver Mine ESIA.
Please refer to the link below for further information. |
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Zgounder Expansion Project ESIA |
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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) |
As Aya Gold & Silver (“Aya” or “the Corporation”) celebrates its third year of existence, I am proud to share our third ESG Report with you. |
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Benoit La Salle, CEO for Aya Gold & Silver |
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Supply Chain |
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a. Report on significant changes to the organization’s size, structure, ownership, or supply chain, including |
In 2022, Aya Gold & Silver commenced earthworks for the Zgounder Silver Mine Project Expansion.
This induced the introduction of new contractors in the supply chain.
In 2022, Aya also announced that it had closed a deal with the National Office of Hydrocarbons and Mines ("ONHYM") to acquire the ONHYM's 15% interest in the Zgounder project and five adjacent permits to the Zgounder Silver Mine for a total consideration of 67 million dirhams (approximately US$6.5 million).
There were no further significant changes to the organization’s size, structure, ownership. |
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Aya Gold & Silver Closes Deal to Consolidate 100% Interest in Zgounder |
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Changes in Locations and Operations |
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i. Changes in the location of, or changes in, operations, including facility openings, closings, and expansions |
In 2022, Aya Gold & Silver commenced earthworks for the Zgounder Silver Mine Project Expansion.
There were no changes in the location of, or changes in, operations, including facility openings, closings, and expansions in 2022. |
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Changes in Capital Structure |
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ii. Changes in the share capital structure and other capital formation, maintenance, and alteration operations (for private sector organizations) |
There were no changes in the share capital structure and other capital formation, maintenance, and alteration operations in 2022. |
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Changes in Supply Chain |
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iii. Changes in the location of suppliers, the structure of the supply chain, or relationships with suppliers, including selection and termination |
In 2022, Aya Gold & Silver commenced earthworks for the Zgounder Silver Mine Project Expansion, which caused the introduction of new contractors.
There were no changes in the location of suppliers, the structure of the supply chain, or relationships with suppliers, including selection and termination in 2022. |
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Policy commitments |
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Provide a description of the organization’s policy commitments for responsible business conduct |
The Board of Directors of Aya Gold & Silver is committed to ethical practices and high standards of corporate governance.
Our mission is to build a sustainable, ethical, and profitable mining business that positively impacts lives.
We aim to leverage our extensive expertise to play a leadership role in building and operating viable precious metals mines that create value for our shareholders and community stakeholders. |
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Aya Gold & Silver Code of Business Conduct and Ethics
Aya Gold & Silver HSEC Policy
Aya Gold & Silver Strategy
Aya Gold & Silver - Our Approach to Sustainability
Framework for Sustainability Reports |
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What are (if any) the authoritative intergovernmental instruments that the commitments reference |
Aya Gold & Silver follows the following initiatives and standards in its approach to Sustainability and HSEC Governance :
• The Global Reporting Initiative (GRI); • The Task Force on Climate-related Financial Disclosures (TCFD); • ISO 14001 and 45001 standards; • The European Bank for Reconstruction and Development (EBRD)'s Environmental and Social Policy; • The International Finance Corporation (IFC)'s Performance Standards; • ICMM guidance.
For the purpose of this report, Aya Gold & Silver is disclosing information aligned with the following standards:
• CDP - Carbon Disclosure Project • GRI - Global Reporting Initiative • GRI MM Supplement - Global Reporting Initiative - Mining and Metals Supplement • ICMM - International Council on Mining & Metals • IFC - International Finance Corporation - Equator Principles • ONYEN - Institutional and Investor Questions • OSHA - Occupational Safety and Health Administration • SASB - Value Reporting Foundation • TCFD - The Task Force on Climate-related Financial Disclosures |
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Do the commitments stipulate conducting due diligence |
Aya Gold & Silver's International Business Conduct Policy provides stipulations for conducting due diligence. |
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International Business Conduct Policy |
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Do the commitments stipulate applying the Precautionary Principle or Approach |
Yes |
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Aya Gold & Silver's statement regarding the Precautionary Principle or Approach is not referred to in the Corporation Code of Ethics, however it is stipulated in the Sustainability Framework.
Aya Gold & Silver - Our Approach to Sustainability |
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Do the commitments stipulate respecting human rights |
No |
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Describe the specific policy commitment to respect human rights |
Aya Gold & Silver's Code of Business Conduct and Ethics does not specify policy commitments to respect human rights generally. However, the policy specifies the following commitments:
• Compliance with Laws, Rules and Regulations • Compliance with Environmental Laws • Discrimination and Harassment • Health and Safety; and • Diversity & Equal Opportunity |
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What are the categories of stakeholders, including at-risk or vulnerable groups, that the organization gives particular attention to in the commitment |
In 2022, Aya Gold & Silver did not reference any specific categories of stakeholders in its commitments. |
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Provide links to the policy commitments, if publicly available, or, if the policy commitments are not publicly available, explain the reason for this |
Aya's policy commitments are available on the Corporation's website, under the section "Governance". |
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Code of Ethics and Business Conduct |
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Report the level at which each policy commitment was approved within the organization, including whether this is the most senior level |
All of Aya's policies need approval from the Board of Directors, the highest level of authority in the Company. |
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To what extent the policy commitments apply to the organization’s activities and to its business relationships |
The Code of Business Conduct and Ethics (the “Code”) applies to everyone at Aya Gold & Silver Inc. (the “Company”), including its employees, Officers and Directors, regardless of their position in our organization, at all times and everywhere we do business. References in this Code to the “Company” mean the Company and any of its subsidiaries. |
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Describe how the policy commitments are communicated to workers, business partners, and other relevant parties |
Our Company's Code of Business Conduct and Ethics is accessible to the public through our website, where it can be viewed and downloaded at any time. Moreover, our standard terms and conditions and agreements with various partners specifically require that such parties read and agree to abide by the terms and conditions of our core policies, namely the Code of Business Conduct and Ethics and International Business Conduct Policy.
As for our internal communication, our management team has taken a proactive approach to ensure that all employees are fully informed and engaged with the policy. To this end, we have provided every employee with an email containing a comprehensive presentation of all our policies, including the Code of Business Conduct and Ethics. In addition, each employee was asked to sign and return an "Acknowledgment of new effective policies" document, which confirms their understanding and agreement to comply with the policy's provisions. This formal process ensures that our employees have thoroughly reviewed and acknowledged the Code of Business Conduct and Ethics, and are committed to upholding its principles. A formal onboarding process requires that every new employee reads and acknowledges having read and agrees to comply with the corporate policies, including the Code of Business Conduct and Ethics. |
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Embedding policy commitments |
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Describe how the organization embeds each of its policy commitments for responsible business conduct throughout its activities and business relationships |
See answers below. |
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How are responsibilities allocated in order to implement the commitments across different levels within the organization |
The Company embeds each of its policy commitments for responsible business conduct throughout its activities and business relationships by establishing specific persons responsible for its implementation. These include the Board of Directors, its committees, management, and the Legal Officer. Regarding our Aya International Business Conduct Policy, the Board of Directors has reviewed and approved the Policy, and its committees are responsible for reviewing its adequacy and appropriateness. The Legal Officer is responsible for promulgating the Policy, obtaining annual certifications, and providing consultation and advice. The CEO is responsible for ensuring the organization conducts business in accordance with the Policy and fosters a culture of compliance. The CFO is the primary person responsible for financial controls and accounting. |
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How are the commitments integrated into organizational strategies, operational policies, and operational procedures |
We have implemented a range of policies to ensure that our commitments to responsible business conduct are integrated into our organizational strategies, operational policies, and operational procedures. |
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These policies include:
1. Code of Business Conduct and Ethics - this policy outlines the principles and values that guide our business conduct, including our commitment to complying with legal and regulatory requirements.
2. International Business Conduct Policy - this policy sets out the specific standards and guidelines that we follow in our international business activities, including our commitment to ethical business practices, fair competition, and transparency.
3. Whistle-Blowing Policy – Handling of Complaints - this policy provides a mechanism to report any concerns or violations of our Code of Business Conduct and Ethics or other policies, without fear of retaliation.
4. Insider Trading Policy - this policy establishes procedures to prevent the use of confidential information to buy or sell securities for personal gain.
5. Cybersecurity Policy - this policy outlines the measures we take to protect our information and systems.
6. Social Media & Internet Usage Policy - this policy sets out the guidelines for using social media and the internet in a responsible and professional manner, in accordance with our Code of Business Conduct and Ethics.
Overall, these policies are essential to ensuring that our commitment to responsible business conduct is integrated into our everyday operations, decision-making, and strategic planning. By following these policies, we aim to create value for all stakeholders involved and contribute to sustainable development.
Moreover, “Ethics and Integrity” are two of the company’s core values associated to its mission statement. Management strives to integrate these values as part of the company’s DNA through its formal discourse, internal meetings, annual KPIs as well as annual and quarterly certifications by senior management and the board of directors as regards conflicts of interest, suspicion or awareness of fraud or financial reporting integrity, amongst others. On a strategic level, the values and mission statement of the company are an integral part of the Company's risk assessment matrix which is adopted and reviewed at the audit committee level and guides management in their daily risk assessment decisions. |
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How does the organization implement its commitments with and through its business relationships |
In terms of business relationships, we implement our commitments through a range of approaches. Our International Business Conduct Policy applies to all persons, whether or not employees, and all entities who are authorized to interface with Foreign Officials for the Company as agents, representatives or independent contractors. We are developing due diligence procedures as part of our selection of contractors to ensure compliance with our commitments related to environmental stewardship, labor practices, human rights, health and safety, and other areas. Our focus on responsible business conduct is a fundamental part of our organizational culture, and we are committed to upholding these principles in all of our activities and business relationships. |
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What implementation training does the organization provide |
The Company provides periodic training for employees and third parties to inform them of the policies and assist in understanding how they apply to relevant situations and fact- patterns, as well as how to deal with situations in which conduct prohibited by the policies may be encountered. The Legal Officer identifies those employees who will receive training and determines the frequency of repetition, which shall be at least once every three years. The Legal Officer's annual report to the CEO also addresses the efficacy of the training required by the International Business Conduct Policy. |
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Ethics and Integrity |
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Describe the mechanisms for individuals to: seek advice on implementing the organization’s policies and practices for responsible business conduct |
Individuals seeking advice on implementing the organization's policies and practices for responsible business conduct can seek counsel from their supervisor and/or the Legal Officer. The Legal Officer is available to provide advice on compliance with the principles and procedures outlined in the policies. The organization emphasizes the importance of consultation when in doubt and discourages individuals from making difficult judgement calls alone. |
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Aya Gold & Silver Code of Business Conduct and Ethics |
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Describe the mechanisms for individuals to: raise concerns about the organization’s business conduct |
Aya Gold & Silver is committed to the highest standards of openness, honesty and accountability as outlined in the Corporation’s Code of Business Conduct and Ethics (the “Code”). The latter also provides guidance on alternative methods of reporting employee concerns and directs that employees inform designated members of management regarding known or suspected instances of irregularities, fraud or misconduct.
The Corporation has a strong commitment to conduct its business in a lawful and ethical manner. Employees are encouraged to report violations of laws, rules, regulations and the Code of Conduct and Ethics either to their supervisor, member of senior management or through the confidential whistleblower mechanism detailed in the Corporation’s Handling of Complaints - Whistle Blowing Policy. The Corporation prohibits retaliatory action against any employee who, in good faith, reports a possible violation. It is unacceptable to file a report knowing it to be false. |
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Aya Gold & Silver Code of Business Conduct and Ethics
Aya Gold & Silver Handling of Complaints – Whistle-Blowing Policy and Procedure |
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Supply Chain |
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Provide a description of the organization’s supply chain, including the types of suppliers (e.g., brokers, contractors, wholesalers, etc.) |
The Zgounder Silver Mine's supply chain's primary elements include:
- chemical products for metal processing; - transport and logistics; - machinery and parts; - consulting services for engineering, health and safety, environment, and human resources management; - insurance providers; - mining contractors and various contracting works linked with operations. |
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Total estimated number of suppliers throughout its supply chain and in each tier (e.g., first tier, second tier); |
713 |
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Estimated number of first tier suppliers |
713 |
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Estimated number of second tier suppliers |
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Estimated number of third tier suppliers |
0 |
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The types of activities related to the organization’s products and services carried out by its suppliers (e.g., manufacturing, providing consulting services) |
• Manufacturing • Mobile Equipment • Spare Parts • Construction Materials • Chemicals • Transportation Services • Consultancy Services • IT Services • Food and hospitality |
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Describe the nature of its business relationships with its suppliers (e.g., long-term or short-term, contractual or non-contractual, project-based, event-based, etc.) |
The list of suppliers for the Corporation's operations in Morocco include all type of procurement items, from office furniture to parts for the processing plants and to chemical reagents such as cyanide.
Business relationship include long-term mining contractors and short-term contractors such as consulting firms for project-based services. |
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The sector-specific characteristics of its supply chain (e.g., labor-intensive, energy intensive, geograficaly disperced, etc.) |
There is no sector-specific characteristics of the Corporation's supply chain. |
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The estimated monetary value of payments made to its suppliers ($Millions) |
39.200 |
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The geographic location of its suppliers |
• Australia • Belgium • Burkina Faso • Canada • China • Congo, Democratic Republic of the • France • Germany • Italy • Korea, Republic of • Morocco • Netherlands • Spain • Switzerland • United Kingdom of Great Britain and Northern Ireland • United States Minor Outlying Islands |
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Estimated Total number of Business Entities in its downstream |
2 |
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Material Topics |
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Governance of Material Topics |
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Describe the process followed to determine the organization's material topics, including: |
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i. How has the organization identified actual and potential, negative and positive impacts on the economy, environment, and people, including impacts on their human rights, across its activities and business relationships; provide details |
• Environmental impact assessment • Social impact assessment • Human rights impact assessment • Grievance mechanisms • Civil society organizations • Other external sources, please list |
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Aya Gold & Silver's materiality assessment and the topics identified were determined on the basis of approved GRI methodology. While the Corporation's identified material topics are key, our wider efforts continue to address topics beyond those in our material section. Specifically, in 2022 Aya started to include formal Climate Change risk assessment to its routine materiality assessment, in order to address Climate Change related-risks and as per TCFD guidelines.
Further, Aya Gold & Silver conducted a project level risk assessment for the Zgounder Silver Mine Expansion Project prior to finalizing its 2022 Feasibility Study. This risk assessment adds content to the Corporation's materiality assessment. |
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ii. How has the organization prioritized the impacts for reporting based on their significance |
In 2022, the Corporation used the output of the ESIA risk assessment and the output of its internal risk analysis to determine the material topics for the Zgounder Silver Mine.
In addition, we included stakeholder concerns communicated through our continual engagement and grievance mechanism.
Finally, in 2022 Aya Gold & Silver secured a US$100 million debt financing package to support expansion of the Zgounder Silver Project. The European Bank for Reconstruction and Development (“EBRD”). The agreement includes an Environmental and Social Action Plan (ESAP) that is a result of a ESG due diligence from EBRD, and the ESAP further steers' Aya's identification of material topics. |
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Zgounder Environmental and Social Audit and Assessment, Non-Technical Summary |
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Specify the stakeholders and experts whose views have informed the process of determining its material topics and provide details |
• Civil society organizations • Customers • Employees and other workers • Governments • Local communities • Non-governmental organizations • Shareholders and other capital providers • Suppliers |
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List the organization's material topics |
• Energy • Water • Emissions • Effluents and Waste • Overall environmental • Occupational Health and Safety • Supplier Assessment for Labor Practices • Grievance Mechanisms • Local Communities • Anti-corruption • Emergency Preparedness |
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List the organization's non-material topics |
• Economic Performance • Market Presence • Indirect Economic Impacts • Procurement Practices • Materials • Biodiversity • Products and Services • Compliance • Transport • Supplier • Environmental Assessment • Environmental Grievances • Employment • Labor/Management Relations • Diversity and Equal Opportunity • Equal Remuneration for Women and Men • Supplier Assessment for Labor Practices • Labor Practices • Grievance Mechanisms • Human Rights Investment • Non-discrimination • Freedom of Association and Collective Bargaining • Child Labor • Forced or Compulsory Labor • Security Practices • Indigenous Rights • Supplier Human Rights Assessment • Human Rights Grievance Mechanisms • Public Policy • Anti-competitive Behavior • Supplier Assessment for Impacts on Society • Grievance Mechanisms for Impacts on Society • Artisanal and Small-scale mining • Resettlement • Closure Planning • Customer Health and Safety • Product and Service Labeling • Marketing • Communications • Customer Privacy • Materials Stewardship |
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Provide reason for considering such topics not material, provide details |
Not applicable |
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Report changes to the list of material topics compared to the previous reporting period |
The ERBD's due diligence result and subsequent ESAP provided a list of new material topics compared to 2021 incuding: • Procurement Practices (implementation of a supplier management system); • Grievance mecanism |
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For the top 5 material topics, the reporting organization shall report the following information: |
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Topic #1 |
Water |
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An explanation of why the topic is material; describe the actual and potential, negative and positive impacts on the economy, environment, and people, including impacts on their human rights |
Use of water resources, or water stress, is both an operational and a societal risk. Water quality is also material as local communities use water for agriculture and livestock, as well as drinking water from underground sources. |
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Where the impacts occur |
During its due diligence process for the acquisition of the Zgounder Silver Mine, Aya Gold & Silver determined the asset had a history of weak water management.
Water is also a national point of contention, and the variability of precipitations due to climate changes heightens the perceived risk.
The impact occurs in the immediate vicinity of the Zgounder Silver Mine, and at the mine itself. |
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Expansion of the Zgounder Silver Mine is dependent on finding new water sources, which communities require for drinking and agriculture. |
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The organization’s involvement with the impacts. e.g., whether the organization has caused or contributed to the impacts, or is directly linked to the impacts through its business relationships |
Aya Gold & Silver's analysis concluded that water pollution stemmed from a pulp overflow from the cyanide processing plant, prior to 2021.
The expansion of the Zgounder Silver Mine is dependent on finding new water sources. |
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Report whether the organization is involved with the negative impacts through its activities or as a result of its business relationships, and describe the activities or business relationships |
Activities |
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Describe/provide a link to the corporate policies or commitments regarding the topic |
Please refer to the Aya Gold & Silver HSEC Policy in the link below. |
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Aya Gold & Silver's HSEC Policy |
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Explain how the organization manages the topic; describe actions taken and related impacts, including |
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Actions to prevent or mitigate potential negative impacts |
Water risks are assessed through the Corporation's risk management system, where mitigation measures are identified and mitigation plans are developed and incorporated in the annual CAPEX and OPEX budgets.
In 2022, Aya Gold & Silver reinforced physical control measures that were implemented in 2021 as part of the continuous improvement of its environmental and social management system. |
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Actions to address actual negative impacts, including actions to provide for or cooperate in their remediation |
In 2022, no negative impacts related to water were identified in local communities.
The 2022 CAPEX investment aimed to mitigate potential future impacts related to the expansion project. |
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Actions to manage actual and potential positive impacts |
Aya Gold & Silver, together with national authorities, is evaluating the feasibility of building a retention dam or similar infrastructure to take advantage of excess water during the rainy season. |
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Report the following information about tracking the effectiveness of the actions taken |
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Processes used to track the effectiveness of the actions; |
• Internal auditing • External auditing or verification • Impact assessments • Measurement systems • Stakeholder feedback • Grievance mechanisms |
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Goals, targets, and indicators used to evaluate progress; |
The Zgounder Silver Mine Expansion Project is currently implementing hardware and developing capacity to closely monitor water consumption and recycling rates, and thus assess progress on its Water Strategy.
Aya Gold & Silver's water monitoring program tests water quality against national and WHO drinking and irrigation water standards, and sampling is carried out monthly to ensure compliance. |
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The effectiveness of the actions, including progress toward the goals and targets; any related adjustments |
In 2022, the effectiveness of the measures described above was assessed. The overall monitoring results are very positive with a clear improvement in results. |
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Lessons learned and how these have been incorporated into the organization’s operational policies and procedures |
In 2022, the Corporation improved its internal communication of environmental issues and monitoring results to improve corporate and strategic decision making. |
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Describe how engagement with stakeholders has informed the actions taken and how it has informed whether the actions have been effective |
In 2022, the actions taken were informed chiefly from hard data and environmental monitoring. |
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Topic #2 |
Supplier |
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An explanation of why the topic is material; describe the actual and potential, negative and positive impacts on the economy, environment, and people, including impacts on their human rights |
In 2022, Aya identified a gap in its supply chain management performance during a routine Health and Safety (H&S) incident investigation. The findings were consistent with the ESG due diligence conducted by EBRD for the financing of the Zgounder Silver Mine Expansion Project.
This could potentially impact the effectiveness of our H&S management system, including the mine's implementation of its Emergency Preparedness and Response Plan. |
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Where the impacts occur |
H&S is a concern for operations within the mine site and applies to both direct employees and contractors. |
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The Corporation's quarterly water quality sampling reports show that river water in the immediate vicinity of the mine has regularly shown traces of pollution since 2015. Although it remains contained (sample points 3 km downstream are always negative), the Corporation’s management team considers this an extremely urgent matter. |
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The organization’s involvement with the impacts. e.g., whether the organization has caused or contributed to the impacts, or is directly linked to the impacts through its business relationships |
Aya is direcly linked to the impacts as potential H&S impacts affect the Corporation's overall performance. |
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Please refer to Aya Gold & Silver's 2020 Sustainability Report for further information.
Aya Gold & Silver 2020 Sustainability Report |
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Report whether the organization is involved with the negative impacts through its activities or as a result of its business relationships, and describe the activities or business relationships |
Activities |
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Describe/provide a link to the corporate policies or commitments regarding the topic |
Aya's Code of Ethics and Business Conduct covers its relationship with the supply chain. |
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Code of Ethics and Business Conduct |
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Explain how the organization manages the topic; describe actions taken and related impacts, including |
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Actions to prevent or mitigate potential negative impacts |
In 2022, Aya began implementing a supply chain management system. This included reinforced due diligence, risk assessment and monitoring of supplier performance. |
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Actions to address actual negative impacts, including actions to provide for or cooperate in their remediation |
Please refer to the answers above. |
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Actions to manage actual and potential positive impacts |
The results from the newly implemented supply chain management system at the Zgounder Silver Mine will be reported in 2022. |
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Report the following information about tracking the effectiveness of the actions taken |
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Processes used to track the effectiveness of the actions |
• Internal auditing • External auditing or verification • Impact assessments • Measurement systems • Stakeholder feedback • Grievance mechanisms • External performance ratings |
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Goals, targets, and indicators used to evaluate progress |
Indicators to evaluate progress include: • Number of suppliers screened • Number of audits conducted |
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The effectiveness of the actions, including progress toward the goals and targets; any related adjustments |
The effectiveness of the actions will be assessed in 2022. |
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Lessons learned and how these have been incorporated into the organization’s operational policies and procedures |
Aya's supply chain management system is still in its implementation phase. |
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Describe how engagement with stakeholders has informed the actions taken and how it has informed whether the actions have been effective |
Aya's supply chain management system is still in its implementation phase. |
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Topic #3 |
Effluents and Waste |
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An explanation of why the topic is material; describe the actual and potential, negative and positive impacts on the economy, environment, and people, including impacts on their human rights |
Tailing Storage Facilities (TSF) dam leakages or dam failures can impact host populations and the environment.
For further information on the assessment of potential impact, please refer to the Corporation's 2020 Sustainability Report. |
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Aya Gold & Silver 2020 Sustainability Report |
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Where the impacts occur |
This material topic is linked to the Company's TSF obligations.
Two of the four TSFs are decommissioned and stable since 2021. Potential impacts could be incurred by the remaining two TSFs in operation , which are subject to regular monitoring. |
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The organization’s involvement with the impacts. e.g., whether the organization has caused or contributed to the impacts, or is directly linked to the impacts through its business relationships |
Impacts are directly linked to the Zgounder Mine site operations. |
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Report whether the organization is involved with the negative impacts through its activities or as a result of its business relationships, and describe the activities or business relationships |
Activities |
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Describe/provide a link to the corporate policies or commitments regarding the topic |
Please refer to Aya Gold and Silver's HSEC Policy below. |
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Aya Gold & Silver HSEC Policy |
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Explain how the organization manages the topic; describe actions taken and related impacts, including |
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Actions to prevent or mitigate potential negative impacts |
In 2021, the Corporation’s management team mandated quarterly external audits for its TSFs. Action Plans were immediately developed, and the effectiveness of control measures assessed through monitoring.
In 2022, quarterly audits continued and the Corporation continued to monitor all of its TSFs, operating and decommissioned. Action Plans implemented in 2021 were assessed in 2022 and deemed successful in mitigating potential impacts. |
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After extensive repairs in 2020, in 2021, internal quarterly audits were conducted with the objective of implementing GIST standards. |
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Actions to address actual negative impacts, including actions to provide for or cooperate in their remediation |
In 2022, no actual negative impacts were identified on the topic of Effluent and Waste. |
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2020 Sustainability Report |
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Actions to manage actual and potential positive impacts |
In 2022, no positive impacts were identified for this material issue. |
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Report the following information about tracking the effectiveness of the actions taken |
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Processes used to track the effectiveness of the actions |
• Internal auditing • External auditing or verification • Measurement systems • Stakeholder feedback |
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Goals, targets, and indicators used to evaluate progress |
Goals, target and indicators are presented in external audits and verified on a quarterly basis. |
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The effectiveness of the actions, including progress toward the goals and targets; any related adjustments |
In 2022, more than a year since the first control measures were implemented, the Corporation assessed that the latter's effectiveness was highly satisfactory and no further adjustments were needed. The Corporation continues its monitoring and third party audits. |
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Lessons learned and how these have been incorporated into the organization’s operational policies and procedures |
Not applicable at this stage of development. |
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Please note the material topic was part of an environmental legacy that Aya Gold and Silver acquired and is not part of the Corporation's operational policies and procedures. |
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Describe how engagement with stakeholders has informed the actions taken and how it has informed whether the actions have been effective |
In 2022, The Corporation did not seek information from stakeholder engagement with regards to the effectiveness of its control measures as decisions are based on data and environmental monitoring. |
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Topic #4 |
Occupational Health and Safety |
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An explanation of why the topic is material; describe the actual and potential, negative and positive impacts on the economy, environment, and people, including impacts on their human rights |
In 2020, Aya Gold & Silver reported Health & Safety (“H&S”) as a major concern at the Corporation’s operations. Preliminary findings from the Corporation’s assessment pointed to a clear lack of risk awareness, and to the absence of a H&S culture at all organization levels of the Zgounder Silver Mine. This issue remained a top priority in 2021 and remains so in 2022 as cultural, behavioral and organizational change takes time to be effective. |
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Where the impacts occur |
H&S is a concern for mine site operations, for both direct employees and contractors.
H&S is a material issue and a concern at all operational levels of the Zgounder Silver Mine. |
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The organization’s involvement with the impacts. e.g., whether the organization has caused or contributed to the impacts, or is directly linked to the impacts through its business relationships |
H&S is a concern for mine site operations, for both direct employees and contractors. |
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Report whether the organization is involved with the negative impacts through its activities or as a result of its business relationships, and describe the activities or business relationships |
Both Activities and business relationships |
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Describe/provide a link to the corporate policies or commitments regarding the topic |
Please refer to the document in the link below. |
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Aya Gold & Silver HSEC Policy |
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Explain how the organization manages the topic; describe actions taken and related impacts, including |
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Actions to prevent or mitigate potential negative impacts |
In 2022, Aya Gold & Silver continued its efforts to improve organizational competency and capacity to operate, and to implement its Environmental and Social Management System.
Six (6) new members were recruited to reinforce the HSEC department, including senior candidates with over 40 years of experience internationally. |
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Actions to address actual negative impacts, including actions to provide for or cooperate in their remediation |
Please refer to the answers above. |
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Actions to manage actual and potential positive impacts |
The results from the newly implemented H&S system at the Zgounder Silver Mine will be reported in 2022. |
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Report the following information about tracking the effectiveness of the actions taken |
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Processes used to track the effectiveness of the actions |
• Internal auditing • External auditing or verification • Impact assessments • Measurement systems • Benchmarking |
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Goals, targets, and indicators used to evaluate progress |
Aya Gold & Silver utilizes the standard H&S KPI list and benchmarks against its industry peers to evaluate its performance. |
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The effectiveness of the actions, including progress toward the goals and targets; any related adjustments |
In 2022 the H&S department went from 1 to 6 persons, and this enabled us to work more closely with all operations to improve incident detection and reporting. As a result, our LTI & TRI numbers skyrocketed for the 2022 year, however this must be seen as positive as it means we are now able to capture and locate the risks and measure consequence much more accurately as incident reporting and awareness dramatically improved.
The main positive point remains the fact that in 2022 no fatalities were recorded, and this translates in our severity rates curve that is dropping steadily since 2021 as we transition from few recorded accidents to more accidents that are less severe. Our target is that our incident reporting statistics reflects the traditional safety pyramid, whereas there 90% or more of reported incidents are minor incidents. |
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Lessons learned and how these have been incorporated into the organization’s operational policies and procedures |
Looking forward, Aya will continue to work relentlessly to become on par with the best of the industry. While Aya’s ambition is zero incident in the medium-term, H&S targets in the short-term are meaningless. In the near term our focus is on incident analysis, corrective actions, and reporting to management and cross departments meetings to improve awareness and Environmental and Social Management System (ESMS) adoption and consolidation. |
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Describe how engagement with stakeholders has informed the actions taken and how it has informed whether the actions have been effective |
In 2022, the increase in H&S capacity allowed an increase in engagement with stakeholders, committee follow up and internal audits. These are instrumental in providing timely feedback to the development and implementation of the new H&S system.
In 2022 Aya also signed a ESG-linked finance agreement with the European Bank for Reconstruction and Development (ERBD). As a result, the EBRD-issued ESAP has several H&S related action items that has informed the Corporation. |
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Topic #5 |
Local Communities |
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An explanation of why the topic is material; describe the actual and potential, negative and positive impacts on the economy, environment, and people, including impacts on their human rights |
The Zgounder Silver Mine has over 40 years of history that spans several operators and administrations, from state companies to private ownership, and includes intermittent periods of inactivity.
This has resulted in complicated relations and historical baggage with the communities. |
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Where the impacts occur |
Concerns related to the relationship between the Zgounder Silver Mine and its host communities. |
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The organization’s involvement with the impacts. e.g., whether the organization has caused or contributed to the impacts, or is directly linked to the impacts through its business relationships |
The impact was caused by an absence of relationship-building between past mine operators and the surrounding villages. |
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Report whether the organization is involved with the negative impacts through its activities or as a result of its business relationships, and describe the activities or business relationships |
Both Activities and business relationships |
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Describe/provide a link to the corporate policies or commitments regarding the topic |
Please refer to the document in the link below. |
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Aya Gold & Silver HSEC Policy |
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Explain how the organization manages the topic; describe actions taken and related impacts, including |
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Actions to prevent or mitigate potential negative impacts |
In 2022, Aya Gold & Silver hired a senior community relations consultant to help lead the implementation of the Project's Stakeholder Engagement Plan (SEP). |
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Actions to address actual negative impacts, including actions to provide for or cooperate in their remediation |
In 2022, Aya Gold & Silver worked with local authorities to formalize its grievance mechanism. |
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Actions to manage actual and potential positive impacts |
In addition to maintaining a high local content management strategy, in 2022, Aya Gold & Silver continued to develop its community investment plan aligned with national and regional development programs, and local authority and local communities' feedback and participation. |
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Report the following information about tracking the effectiveness of the actions taken |
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Processes used to track the effectiveness of the actions |
• Internal auditing • Impact assessments • Measurement systems • Stakeholder feedback • Grievance mechanisms • Benchmarking |
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Goals, targets, and indicators used to evaluate progress |
In 2021, Aya Gold & Silver established and committed to an annual community investment budget. All investment targets were met.
This budget was increased in 2022, and will continue to increase annually until full commissioning of the Zgounder Silver Mine Project Expansion. |
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The effectiveness of the actions, including progress toward the goals and targets; any related adjustments |
In 2022, Aya adjusted its strategy for the implementation of the Project's SEP. The process was delayed in order to hold several community meetings to reframe Aya's strategy and manage expectations. |
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Lessons learned and how these have been incorporated into the organization’s operational policies and procedures |
Aya Gold & Silver defined internal administrative procedures to streamline community investments, and learned to work with local administrations to achieve joint objectives while safeguarding the company's commitment to transparency. |
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Describe how engagement with stakeholders has informed the actions taken and how it has informed whether the actions have been effective |
In 2022, feedback from local administrations and communities as well as the counselling of a senior social consultant helped Aya reframe its Community Investment Program to increase its participatory process and prepare the implementation of the Project's SEP. |
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A description of the grievance mechanism: if the management approach includes such mechanism, describe how the stakeholders who are the intended users of the grievance mechanisms are involved in the design, review, operation, and improvement of these mechanism(s) |
Aya Gold & Silver formalized the Zgounder Silver Mine grievance mechanism in 2021. |
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Grievance Mechanism: Ownership of the mechanism |
The grievance mechanism is managed by Aya Gold & Silver in conjunction with the local representative of the Kingdom of Morocco's Ministry of the Interior. |
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Grievance Mechanism: The purpose of the mechanism and its relationship to other grievance mechanisms |
The Zgounder Silver Mine grievance mechanism is exclusively for use by external stakeholders. Internal stakeholders report grievances through the Human Resources system and their representatives. |
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Grievance Mechanism: The organization’s activities that are covered by the mechanism |
The community grievance mechanism is utilized by external stakeholders. |
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Grievance Mechanism: The intended users of the mechanism |
Intended users of the mechanism include:
1. Village residents 2. Local administrations 3. Local service providers 4. Civil society organizations 5. Any other external stakeholders affected by Zgounder Silver Mine activities |
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Grievance Mechanism: How the mechanism is managed |
The mechanism is co-managed by Aya Gold & Silver and local authorities. |
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Grievance Mechanism: The process to address and resolve grievances, including how decisions are made |
Grievances are received by local authorities and/or community relations employees. Grievances are jointly investigated and resolved.
If required, ad hoc committees can be formed to resolve complaints.
If warranted, the grievance may escalate to be resolved through the justice system. |
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Grievance Mechanism: The effectiveness criteria used |
The effectiveness of the grievance mechanism is measured by the expedient resolution of grievances, and by a general lack of interruption to operations as a result of unresolved community grievances. |
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The total number of grievances filed through the mechanism during the reporting period |
1 |
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The number of grievances that were addressed (or reviewed) during the reporting period |
1 |
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The number of grievances that were resolved during the reporting period |
1 |
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The number of grievances filed through the mechanism prior to the reporting period that were resolved during the reporting period |
0 |
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The number of grievances that were resolved by remediation |
0 |
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Environment |
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General Disclosure |
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Compliance with laws and regulations |
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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: |
0 |
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Number of instances for which fines were incurred |
0 |
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Number of instances for which non-monetary sanctions were incurred |
0 |
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Report the total number of fines for instances of non-compliance with laws and regulations that were paid during the reporting period |
0 |
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Report the monetary value of fines for instances of noncompliance with laws and regulations that were paid during the reporting period ($Million) |
0 |
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Total number of fines for instances of non-compliance with laws and regulations that occurred in the current reporting period |
0 |
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Total monetary value of fines for instances of non-compliance with laws and regulations that occurred in the current reporting period ($Million) |
0 |
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Total number of fines for instances of non-compliance with laws and regulations that occurred in previous reporting periods |
0 |
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Total monetary value of fines for instances of non-compliance with laws and regulations that occurred in previous reporting periods |
0 |
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Describe the significant instances of non-compliance |
In 2022, Aya Gold & Silver was in compliance with all environmental laws and/or regulations. |
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Greenhouse Gas Emissions |
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Scope 1 |
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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) |
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Carbon dioxide (CO₂) (tonne CO₂-e) |
4,880.695 |
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Methane (CH₄) (tonne CO₂-e) |
0.000 |
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Nitrous oxide (N₂O) (tonne CO₂-e) |
0.000 |
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Hydrofluorocarbon-23 (CHF₃) (tonne CO₂-e) |
0.000 |
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Hydrofluorocarbon-32 (CH₂F₂) (tonne CO₂-e) |
0.000 |
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Sulphur hexafluoride (SF₆) (tonne CO₂-e) |
0.000 |
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Nitrogen trifluoride (NF₃) (tonne CO₂-e) |
0.000 |
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Perfluoromethane (CF₄) (tonne CO₂-e) |
0.000 |
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Perfluoroethane (C₂F₆) (tonne CO₂-e) |
0.000 |
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Perfluorobutane (C₄F₁₀) (tonne CO₂-e) |
0.000 |
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Perfluorohexane (C₆F₁₄) (tonne CO₂-e) |
0.000 |
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The total amount of gross global Scope 1 GHG emissions (CO₂-e) (tonne) |
4,880.695 |
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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% |
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Discuss any change in its emissions from the previous reporting period, including whether the change was due to emissions reductions, divestment, acquisition, mergers, changes in output, and/or changes in calculation methodology |
In 2022, there were no significant changes. |
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In the case that current reporting of GHG emissions to the CDP or other entity (e.g., a national regulatory disclosure program) differs in terms of the scope and consolidation approach used, the entity may disclose those emissions. |
Aya Gold & Silver reports its emissions based on CDP disclosure guidelines. |
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The entity may discuss the calculation methodology for its emissions disclosure, such as if data are from continuous emissions monitoring systems (CEMS), engineering calculations, or mass balance calculations |
In the 2022 report, Aya Gold & Silver reports GHG Scope 1 emissions based on a calculation from the total diesel consumption of mining mobile equipment fleet and light vehicles at the Zgounder Silver Mine. This includes the diesel consumed by long-term mining contractors. |
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The entity may, where relevant, provide a breakdown of its emissions by mineral or business unit |
Scope 1 emissions represent operations at the Zgounder Silver Mine only.
Diesel consumption at Aya's exploration sites at Boumâadine, Imiter Bis, and at Tijirit in Mauritania are mostly caused by drilling machines that are operated by contractors. These emissions will be covered by the Scope 3 calculations that the Corporation will disclose later in 2023. |
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Discuss long-term and short-term strategy or plan to manage its Scope 1 greenhouse gas (GHG) emissions |
Scope 1 emissions are generated mostly by operating machinery to mine ore. The type of machinery that we currently operate does not exist in electric form. As a result, it is currently impossible for us to significantly reduce our Scope 1 emissions.
We plan to monitor new emerging technologies and evaluate other opportunities when our mining equipment needs to be replaced. |
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Please discuss reduction emissions target(s) (if any) for Scope 1 in your company, and analyse the performance against the target(s) as follows |
In 2022, Aya did not set any Scope 1 emissions reduction target, as the solutions and technology required to effectively reduce Scope 1 emissions do not exist at the moment. |
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The percentage reduction against the base year, with the base year representing the first year against which emissions are evaluated toward the achievement of the target |
Does Not Apply |
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In 2022, Aya Gold & Silver did not have any target emissions reduction. |
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Total base year GHG emissions |
0.000 |
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Present year GHG emissions |
4,880.695 |
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The timelines for the emissions reduction activity: |
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Discuss whether its strategies, plans, and/or reduction targets are related to, or associated with, emissions limiting and/or emissions reporting-based programs or regulations (e.g., the EU Emissions Trading Scheme, Quebec Cap-and-Trade System, California Cap-and-Trade Program), including regional, national, international, or sectoral programs |
The Corporation's strategies, plans, and/or reduction targets for are not related to, or associated with, emissions limiting and/or emissions reporting-based programs or regulations. |
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Source of the emission factors and the global warming potential (GWP) rates used, or a reference to the GWP source |
The source of emission factors is the Onyen reporting platform, which uses US EPA conversion factors recommended by the GHG Protocol. |
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Consolidation approach for emissions - whether equity share, financial control, or operational control |
Operational control |
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Standards, methodologies, assumptions, and/or calculation tools used |
For the purpose of this report, we used Carbon Disclosure Project guidelines as a calculation tool. |
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Scope 2 |
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Disclose the gross location-based energy indirect (Scope 2) global greenhouse gas (GHG) emissions to the atmosphere (tonne CO₂-e): |
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Does the company purchase externally supplied energy (grid electricity) |
Yes |
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Report the total energy purchased from external suppliers for the reporting year in gigajoules (GJ) |
51,736.273 |
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In what jurisdiction is the source of energy (utility) located |
Other, please specify |
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In 2022, the source of energy purchased was located in Morocco.
For its Scope 2 emissions, Aya only discloses its emissions linked to operations in Morocco at the Zgounder Silver Mine. |
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Conversion factor (see Guidance): |
0.721 |
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For the purpose of this report, we utilized the factors from Outil Bilan Carbone Maroc, the official list of factors in Morocco, where the operations are based.
The Mohammed VI Foundation for the Environment, with the support of the Association pour la Transition Bas Carbone (ABC), and its Moroccan institutional partners, has adapted the Bilan Carbone® method to the Moroccan context, with in particular the update of 350 emission factors of which 60% are adapted to the national context. |
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Total amount of Scope 2 GHG emissions from purchased energy (CO₂-e) (tonne) |
10,361.634 |
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Does the company purchase externally supplied heat |
No |
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Does the company purchase externally supplied steam |
No |
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Does the company purchase externally supplied cooling |
No |
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The total amount of gross global Scope 2 GHG emissions (CO₂-e) (tonne) |
10,361.634 |
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Percentage of its gross global Scope 2 GHG emissions that are covered under an emissions-limiting regulation or program that is intended to directly limit or reduce emissions, i.e., cap-and-trade schemes, carbon tax/fee systems, and other emissions control (e.g., command-and-control approach) and permit-based mechanisms |
0.0000% |
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Discuss long-term and short-term strategy or plan to manage Scope 2 emissions, emissions reduction targets, and an analysis of performance against those targets |
In line with our HSEC Policy and engagement to reduce our carbon footprint, in February 2023, Aya Gold & Silver signed a Power Purchasing Agreement (PPA) with an independent power producer connected to the Moroccan national grid.
The PPA will come into effect in 2024 on commissioning of the new processing plant.
Please see the press release in the link below. |
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Press Release PPA Agreement |
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Aya Climate Strategy |
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Please discuss reduction emissions target(s) for Scope 2 (if any) in your company, and analyse the performance against the target(s) as follows |
By 2025, the Corporation will reduce the Scope 2 emissions at its Zgounder Silver Mine in Morocco by approximatively 88% compared to 2021, the base year for calculation.
In 2025, Aya expects its Zgounder Silver Mine operations to emit approx. 1148 tCO2e. This represents a 98% reduction compared to Scope 2 emissions of 56,000 tCO2e if operations had continued to be powered with a regular grid connection (Business as usual). |
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If relevant, what is the scope of the emission reduction target (e.g., the percentage of total emissions the target is applicable to) |
This emission reduction target is applicable to 100% of Aya's Scope 2 emissions. |
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What type of target is it: |
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Absolute |
Yes |
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Intensity Based |
No |
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The percentage reduction against the base year, with the base year representing the first year against which emissions are evaluated toward the achievement of the target |
0.0000% |
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Total base year GHG emissions |
9,607.359 |
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Present year GHG emissions |
10,361.634 |
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The timelines for the emissions reduction activity: |
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Start year |
2023-02-16 |
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Target year |
2025-01-01 |
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Base year |
2021-01-01 |
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Rationale for choosing the base year for the calculation |
The Corporation chose 2021 as the base year for the calculation given that it is the first year that Scope 2 emissions were calculated and disclosed. |
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Scope 2 GHG emissions in the base year (CO₂-e) |
9,607.359 |
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The context for any significant changes in emissions that triggered recalculations of the base year emissions |
In May 2023, Aya Gold & Silver contracted a Moroccan consulting firm to calculate its Scope 3 emissions. Through this new partnership, Aya was able to access a new set of factors that are official for Morocco.
Until then, our calculations used the factors from the GHG Protocol Tool and the International Energy Agency, which had factors for the Moroccan grid for up to 2020 only.
From 2023 on (which includes the disclosures in the present 2022 ESG report), Aya will exclusively use the factors from the Outil Bilan Carbone Maroc for its Scope 2 emissions. |
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What is the mechanism(s) for achieving the target |
In 2024, Aya Gold & Silver will sign a Power Purchasing Agreement (PPA) with an independent power producer connected to the Moroccan National Grid, EEM-Nareva.
This PPA will become effective when the new processing plant is commissioned in mid-year 2024.
By 2025, the Zgounder Silver Mine will be powered exclusively with wind power through this PPA. |
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Are there any circumstances in which the target or base year emissions have been, or may be, recalculated retrospectively or the target or base year has been reset |
In 2023, Aya restated the CO2 factors used for Scope 2 emissions in its 2021 ESG report, which are the base-year emissions.
In May 2023, Aya Gold & Silver contracted a Moroccan consulting firm to calculate its Scope 3 emissions. Through this new partnership, Aya was able to access a new set of factors that are official for Morocco.
Until then, our calculations used the factors from the GHG Protocol Tool and the International Energy Agency, which had factors for the Moroccan grid for up to 2020 only.
From 2023 on (which includes the disclosures in the present 2022 ESG report), Aya will exclusively use the factors from the Outil Bilan Carbone Maroc for its Scope 2 emissions. The Corporation does not foresee any further change, recalculation, or restatement to its base-year emissions. |
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Discuss the activities and investments required to achieve the plans and/or targets, and any risks or limiting factors that might affect achievement of the plans and/or targets |
There are no risks or limiting factors that could affect achievement of the plans and/or targets. |
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Discuss the scope of strategies, plans, and/or reduction targets, such as whether they pertain differently to different business units, geographies, or emissions sources |
The strategy covers the Zgounder Silver Mine. |
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Discuss whether its strategies, plans, and/or reduction targets are related to, or associated with, emissions limiting and/or emissions reporting-based programs or regulations (e.g., the EU Emissions Trading Scheme, Quebec Cap-and-Trade System, California Cap-and-Trade Program), including regional, national, international, or sectoral programs |
Aya's emissions reduction strategy is not related to or associated with emissions-limiting and/or emissions reporting-based programs or regulations. |
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Source of the emission factors and the global warming potential (GWP) rates used, or a reference to the GWP source |
For the purpose of this report, we utilized the factors from Outil Bilan Carbone Maroc, the official list of factors in Morocco, where the operations are based.
The Mohammed VI Foundation for the Environment, with the support of the Association pour la Transition Bas Carbone (ABC), and its Moroccan institutional partners, has adapted the Bilan Carbone® method to the Moroccan context, with in particular the update of 350 emission factors of which 60% are adapted to the national context. |
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L’Outil Bilan Carbone Maroc |
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Standards, methodologies, assumptions, and/or calculation tools used |
In this report, Aya Gold & Silver's calculations were made in line with the GHG Protocol methodology, while using TCFD guidelines. |
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GHG Calculation Tool
Implementing the Recommendations of the Task Force on Climate-related Financial Disclosures |
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Intensity Ratio |
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The total amount of gross global Scope 1 GHG emissions (CO₂-e) (tonne) |
4,880.695 |
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The total amount of gross global Scope 2 GHG emissions (CO₂-e) (tonne) |
10,361.634 |
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GHG emissions intensity ratio for the organization |
59.779 |
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The total amount of organization's specific metric chosen to calculate the intensity ratio |
254.976 |
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The above number ( 254.976) is in thousands of tonnes of ore produced. |
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The organizations specific metric unit of measure. Note: when choosing a company specific metric, it must be used throughout all calculations |
Production volume |
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The intensity ratio is thousands of tonnes of ore processed by tonnes of CO2. |
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Types of GHG emissions included in the intensity ratio; whether Scope 1, Scope 2 and/or Scope 3 |
• Scope 1 • Scope 2 |
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Reduction of GHG emissions |
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GHG emissions reduced as a direct result of reduction initiatives (in metric tonnes of CO2 equivalent) |
0.000 |
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In 2022, Aya did not have any initiatives to reduce GHG emissions. The Corporation will start disclosing reduction in 2024, when its Power Purchasing Agreement comes into effect, as per Aya's plan to reduce Scope 2 emissions. |
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Base year or baseline, including the rationale for choosing it |
Base year |
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This is the first reporting period that Aya Gold & Silver has quantified and reported its GHG emissions. |
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Standards, methodologies, assumptions, and/or calculation tools used |
In this report Aya Gold & Silver utilized the Carbon Disclosure Project Calculation guidelines. |
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Carbon Offset |
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Credits |
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How much CO₂ (metric tonnes) offset credits were purchased? |
0.000 |
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Emissions |
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Emissions Management |
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Disclose the management approach regarding Emissions |
As per its HSEC Policy, Aya Gold & Silver strives to promote the efficient use of natural resources in order to reduce consumption and waste, reduce its carbon footprint, and protect the environment.
In 2022, Aya Gold & Silver assessed its climate change-related risks and opportunities against the TCFD guidelines. |
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Details: In evaluating the principal sources of its Scope 1 and Scope 2 GHG emissions, the Corporation determined that it is unable to significantly reduce Scope 1 emissions at this time as it is currently impossible to electrify its mining fleet due the unavailability of appropriate technology. Aya commits to review emerging new technology and assess the feasibility of transitioning to electric mining fleet upon the renewal of its existing fleet, in approximately 5 years (2027-2028).
Scope 2 emissions, however, form the bulk of the Zgounder Silver Mine's carbon footprint. In 2022, the Corporation's first target for Scope 2 emissions was to find a partner and sign a PPA for renewable energy. That year, Aya signed an Interconnection Agreement with the Office National de L’Électricité et de l’Eau Potable (“ONEE”) in order to secure access to a clean energy supply for Zgounder. In February 2023, Aya Gold & Silver signed a renewable Power Purchase Agreement (PPA) with Energie Éolienne du Maroc (EEM).
This PPA will allow the Zgounder Silver Mine to operate predominantly with renewable electricity supplied through the grid and supports the Corporation’s objective of implementing responsible mining and climate change initiatives in the Kingdom of Morocco. Specifically, the wind PPA allows Aya to achieve up to near zero Scope 2 emissions.
By 2025, the Corporation will reduce the Scope 2 emissions at its Zgounder Silver Mine in Morocco by approximatively 88% compared to 2021, the base year for calculation.
In 2025, Aya expects its Zgounder Silver Mine operations to emit approx. 1148 tCO2e. This represents a 98% reduction compared to Scope 2 emissions of 56000 tCO2e if operations had continued to be powered with a regular grid connection. |
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Aya Climate Strategy |
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Air Emissions |
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Report emissions of air pollutants that are released into the atmosphere |
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Emissions of carbon monoxide, reported as CO (tonne) |
25.155 |
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The calculations for CO, NOx, SOx and VOCs correspond to the Zgounder mine's mining fleet and light vehicles. The results are derived from the total annual diesel consumed at the Zgounder Silver Mine, and it includes its Contractors (underground mining, exploration, and general civil engineering surface works).
Emissions of carbon monoxide (CO) are calculated following the US EPA Webfire emissions factors, for Internal Combustion Engines ; Industrial ; Large Bore Engine ; Diesel. Emission Factor : 1.16E+02 Lb per 1000 Gallons Diesel Burned. |
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Emissions of oxides of nitrogen (NOx), reported as NOx (tonne) |
94.982 |
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Emissions of oxides of nitrogen (NOx) are calculated following the US EPA Webfire emissions factors, for Internal Combustion Engines ; Industrial ; Large Bore Engine ; Diesel. Where : Emission Factor : 4.38E+02 Lb per 1000 Gallons Diesel Burned; |
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Emissions of oxides of sulphur (SOx), reported as SOx (tonne) |
56.382 |
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Emissions of oxides of sulfur (SOx) are calculated following the US EPA Webfire emissions factors, for Internal Combustion Engines ; Industrial ; Large Bore Engine ; Diesel. Where : Emission Factor : 2.60E+02 Lb per 1000 Gallons Diesel Burned; |
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Emissions of Particulate Matter 10 micrometres or less in diameter (PM₁₀), reported as PM₁₀ (tonne) |
0.392 |
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The calculations for PM10 correspond to dust emitted from the crushing at the Zgounder Silver Mine's two operating processing plant. This number is the total emissions for particulate matter less than or equal to 10 micrometers (µm) (PM10) ) that are calculated by summing all individual emissions calculated for each substance from each process.
It follows the methodology from the Tools for calculating and reporting emissions for crushed stone processing from the Government of Canada website.
The general equation for estimation using an emissions factor is:
E = A x EF
where:
• E = emissions • A = activity rate • EF = emission factor |
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Emissions of lead and lead compounds, reported as Pb (tonne) |
0.000 |
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Emissions of mercury and mercury compounds, reported as Hg (tonne) |
0.000 |
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Emissions of non-methane Volatile Organic Compounds (VOCs) (tonne) |
2.494 |
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Emissions of non-methane Volatile Organic Compounds (VOCs) are calculated following the US EPA Webfire emissions factors, for Internal Combustion Engines ; Industrial ; Large Bore Engine ; Diesel. Where : Emission Factor : 1.15E+01 Lb per 1000 Gallons Diesel Burned; |
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Discuss the calculation methodology for emissions disclosure |
Engineering calculations |
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In 2022, the Zgounder Silver Mine did not have continuous monitoring devices for air pollutants. However, as per the Corporation's HSEC Policy, Aya strives to develop procedures and strategies to mitigate or avoid its negative impacts on the environment, which include non-GHG emissions.
The Zgounder Silver Mine has a strict strategy for dust suppression in order to reduce its total PM emissions, and it implements strict maintenance schedule with its mobile equipment in order to reduce CO, NOx, SOx, and VOCs emissions
Government of Canada : Tools for calculating and reporting emissions
WebFIRE is EPA’s online emissions factor repository, retrieval, and development tool. |
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Ozone-Depleting Substances (ODS) |
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The reporting organization shall report the following information |
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Production, imports, and exports of Ozone Depleting Substances (ODS) in metric tonnes of CFC-11 (trichlorofluoromethane) equivalent: |
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Production of of ODS in metric tonnes of CFC-11 (trichlorofluoromethane) equivalent |
0 |
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Source of the emission factors used |
Aya Gold & Silver does not utilize equipment in its operations that can produce ozone- depleting substances. |
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Significant Air Emissions |
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The reporting organization shall report the following information |
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Significant air emissions, in kilograms or multiples, for each of the following |
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Volatile organic compounds (VOCs) |
2.494 |
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Emissions of non-methane Volatile Organic Compounds (VOCs) are calculated following the US EPA Webfire emissions factors, for Internal Combustion Engines ; Industrial ; Large Bore Engine ; Diesel. Where : Emission Factor : 1.15E+01 Lb per 1000 Gallons Diesel Burned; |
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Mining Sector |
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Acetone (also known as propanone) |
0.000 |
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Acetaldehyde |
0.000 |
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Antimony (Sb) |
0.000 |
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Arsenic (As) |
0.000 |
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Asbestos |
0.000 |
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Benzene (including benzene from gasoline) |
0.000 |
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1,3-Butadiene |
0.000 |
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Cadmium (Cd) |
0.000 |
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Carbon Dioxide (CO2) |
0.000 |
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Carbon Monoxide (CO) |
25.155 |
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Chloroform |
0.000 |
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Chromium (Cr) |
0.000 |
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Copper (Cu) |
0.000 |
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Cyanide (CN) |
0.000 |
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2,3-dimethylbutane |
0.000 |
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Ethylbenzene |
0.000 |
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Hexachlorobenzene |
0.000 |
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Hydrogen Cyanide (HCN) |
0.000 |
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Hydrogen Sulphide (H2S) |
0.000 |
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Iron (Fe) |
0.000 |
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p-isopropyltoluene |
0.000 |
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Lead (Pb) |
0.000 |
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Manganese (Mn) |
0.000 |
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Mercury (Hg) |
0.000 |
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Aya Gold & Silver considers mercury emissions a material topic at its Zgounder Silver Mine, but we were not able to monitor these emissions in 2022. Any mercury emissions would potentially occur in the vicinity of the silver refinery that is housed within the cyanidation circuit processing plant, which was originally built in the 1980s.
The Zgounder Silver Mine's Expansion Project will include a new processing plant that will be operational in 2024. From that date forward, the mine’s silver ingots will solely be poured at the new processing plant that will have state- of-the-art equipment for mercury capture system. |
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Methane (CH4) |
0.000 |
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Methylene chloride (Dichloromethane) |
0.000 |
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Methyl tert butyl ether (MTBE) |
0.000 |
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Nickel (Ni) |
0.000 |
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Nitrous Oxides (NOx) |
94.982 |
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Particulate Matter (PM2.5) |
0.050 |
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Particulate Matter (PM10) |
0.392 |
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i-pentane |
0.000 |
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Polychlorinated Biphenyls (PCBs) |
0.000 |
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Polyhalogenated Aromatic Hydrocarbons (PAHs) |
0.000 |
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Propene (also known as propylene or methyl ethylene) |
0.000 |
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Sulphur Dioxide (SO2) |
0.000 |
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Sulphur Oxides (SOx) |
56.382 |
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Thallium (Tl) |
0.000 |
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Toluene |
0.000 |
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Tetrachloroethylene (also known as perchloroethylene or PCE) |
0.000 |
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o-Xylenes |
0.000 |
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m-Xylenes |
0.000 |
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p-Xylenes |
0.000 |
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Zinc (Zn) |
0.000 |
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vi. Total Particulate Matter (TPM): |
1.052 |
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This number is the total emissions for each of total particulate matter (TPM), particulate matter less than or equal to 10 micrometers (µm) (PM10) and particulate matter less than or equal to 2.5 µm (PM2.5) that are calculated by summing all individual emissions calculated for each substance from each process.
It follows the methodology from the Tools for calculating and reporting emissions for crushed stone processing from the Government of Canada website. The general equation for estimation using an emissions factor is:
E = A x EF where: • E = emissions • A = activity rate • EF = emission factor |
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PM2.5 |
0.050 |
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PM10 |
0.392 |
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Standards, methodologies, assumptions, and/or calculation tools used |
Aya Gold & Silver does not currently monitor air emissions. In 2023, it will monitor and disclose as per the Environmental and Social Management Plan included in the 2022 Zgounder Silver Mine ESIA.
2022 air emissions numbers were calculated with emissions factors from the US EPA Webfire tool as well as from the tools for calculating and reporting emissions for crushed stone processing from the Government of Canada website. |
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Government of Canada : Tools for calculating and reporting emissions
WebFIRE is EPA’s online emissions factor repository, retrieval, and development tool. |
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Energy Management |
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Total energy consumed in aggregate, in gigajoules (GJ) (hydrocarbons and electricity) including the fuel types used (e.g., biomass, hydro-electric power or bioenergy) |
51,732.673 |
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Percentage energy consumed that was supplied by grid electricity |
100.0000% |
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Percentage of energy consumed that is renewable energy |
19.0000% |
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Energy |
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Energy Consumption |
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c. Report the energy consumed in gigajoules for the following : |
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Electricity consumption (gigajoules, GJ) |
51,732.673 |
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The figure provided here is for the global electricity consumption at the Zgounder Silver Mine in 2022, and does not include the administrative offices in Casablanca. |
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Heating consumption (gigajoules, GJ) |
0.000 |
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Cooling consumption (gigajoules, GJ) |
0.000 |
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Steam consumption (gigajoules, GJ) |
0.000 |
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d. Report energy sold in gigajoules and report the totals for each |
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Electricity sold (gigajoules, GJ) |
0.000 |
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Heating sold (gigajoules, GJ) |
0.000 |
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Cooling sold (gigajoules, GJ) |
0.000 |
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Steam sold (gigajoules, GJ) |
0.000 |
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Report the standards, methodologies, assumptions, conversion factors and/or calculation tools used |
To calculate this data, the Corporation converted the KWh purchased from the national grid to gigajoules, GJ. |
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Energy Intensity Ratio |
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Report the energy intensity ratio for inside the organization. This intensity ratio is the total ratio for all countries in which the company operates |
0.203 |
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Energy Intensity |
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The total energy consumption within the organization, in gigajoules |
51,732.673 |
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The organizations specific metric chosen to calculate the intensity. Note: when choosing a company specific metric, it must be used throughout all calculations |
254,976.000 |
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In tonnes of ore mined. |
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Organization-specific metric to identify the denominator |
Production volume |
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Reduction in Energy Consumption |
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Report the amount of reductions (from the previous reporting period) in energy consumption achieved as a direct result of conservation and efficiency initiatives, in gigajoules (GJ). Note - if you did not report in the previous reporting period, please indicate with a statement in the details section, "This is our foundational (for clarity, our first) ESG report for the organization". |
0.000 |
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In 2022, Aya Gold & Silver did not have any energy consumption reductions planned as the company continues to increase production. A new processing plant will be operational in 2024 as part of the Zgounder Silver Mine expansion project. This new plant is designed with efficiency in mind. |
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Report the basis for calculating reductions in energy consumption, i.e. base year or baseline, including the rationale for choosing it |
N/A |
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Reduction in Energy Requirements |
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Report the reductions in energy requirements of sold products and services in this reporting period (from the previous reporting period), in gigajoules (GJ). Note - if you did not report in the previous reporting period, please indicate with a statement in the details section, "This is our foundational (for clarity, our first) ESG report for the organization", (e.g., if you used electric vehicles this year as opposed to last year, please indicate). |
0.000 |
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Report the basis for calculating reductions in energy requirements, i.e., base year or baseline, including the rationale for choosing it |
N/A |
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Water |
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Efficiency |
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Proportion of water reused and recycled by the site to reduce the overall consumptive water demand |
61.0681% |
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In 2022, the Corporation did not have any hardware installed at the Zgounder Silver Mine to monitor water use and reuse. The equipment was ordered in 2022, but due to supply chain issues it will be installed only in 2023. Aya will publish the data in its 2023 ESG report.
The methodology for establishing these numbers is based on assumption and engineering calculation from the processed tones of ore at the Zgounder Silver Mine (411453m³), as well as an estimate of the consumption of fresh water from the mining camp (40m³ per day for 365 days). |
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Intensity |
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Total volume of water consumed per tonne of ore processed |
0.593 |
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Water intensity is in m³ of freshwater withdrawn per tonne of ore processed. |
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Water Management |
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Disclose the amount of water that was withdrawn from freshwater sources (in thousands of cubic meters) |
238.900 |
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Analyze and list all operations for water risks and identify activities that withdraw and consume water in locations with High (40–80%) or Extremely High (>80%) Baseline Water Stress as classified by the World Resources Institute’s (WRI) Water Risk Atlas tool, Aqueduct |
Aya Gold & Silver's Zgounder Silver Mine and production facility borders an area with low Baseline Water Stress and an area with extremely high Baseline Water Stress as classified by the World Resources Institute's (WRI) Water Risk Atlas tool. |
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World Resources Institute’s (WRI) Water Risk Atlas tool, Aqueduct |
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Disclose the freshwater withdrawn in locations with High or Extremely High Baseline Water Stress as a percentage of the total water withdrawn |
100.0000% |
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Disclose water withdrawn in locations with High or Extremely High Baseline Water Stress (in thousands of cubic meters) |
238.900 |
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Disclose freshwater consumed in locations with High or Extremely High Baseline Water Stress as a percentage of the total water consumed |
100.0000% |
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Disclose the amount of water that was consumed in its operations (in thousands of cubic meters) |
238.900 |
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Total water consumed in locations with high or extremely high baseline water stress (in thousands of cubic meters) |
238.900 |
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Was your organization subject to any fines, enforcement orders, and/or other penalties for water-related regulatory violations |
No |
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The Zgounder Silver Mine does not discharge effluent into the environment. Aya Gold & Silver did not have unplanned water discharge during this reporting period. |
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Total number of instances of non-compliance, including violations of a technology-based standard and exceedances of quality-based standards |
0 |
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Disclosure of incidents governed by national, state, and local statutory permits and regulations, including, but not limited to, the discharge of a hazardous substances, violation of pretreatment requirements, or total maximum daily load (TMDL) exceedances |
Aya Gold & Silver was not subject to any national, state or local authority regulation violation relating to the environment. |
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Water and Effluents |
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Interactions with Water As A Shared Resource |
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Describe how the organization interacts with water, including how and where water is withdrawn, consumed, and discharged, and the water-related impacts caused or contributed to, or directly linked to the organization’s activities, products or services by a business relationship (e.g., impacts caused by runoff) |
Aya Gold & Silver's Zgounder operations draw freshwater from the Macoste spring, which is located 5km upstream from our operations. Water storage facilities were constructed in 2022. Additional water storage and retention walls are being constructed to support Zgounder Silver Mine operations. These enable the Corporation to capitalize on the region's excess hydric conditions in the winter months and store water for dry summer months, in order to reduce the mine's dependency on the Macoste spring and thereby lessen its impact on the shared resources.
Water is consumed by the processing plant and the base camp. There is no discharge into the environment.
For the purpose of this report, potential water- related impacts include the use of a shared water resource, and pollution from operations due to accidental runoff or infiltration. |
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Describe the approach used to identify water-related impacts, including the scope of assessments, their timeframe, and any tools or methodologies used |
Water risks are assessed through the Corporation's risk management system, which include climate change, where mitigation measures are identified, and mitigation plans are developed and incorporated into the annual CAPEX and OPEX budgets. |
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The Environmental and Social Impact Assessment for the Zgounder Silver Mine (approved by Moroccan authorities in Q1 2022) also provided Aya Gold and Silver's management with updated baseline information and impact identification. |
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Describe how water-related impacts are addressed, including how the organization works with stakeholders to steward water as a shared resource, and how it engages with suppliers or customers with significant water-related impacts |
Aya's strategy is to eliminate water-related impact and mitigate when otherwise impossible.
Local stakeholders are engaged through the Zgounder Silver Mine's Stakeholder Engagement Plan and its grievance mechanism. Consultations with stakeholders informed the Corporation's decision to gradually reduce its dependency on the Macoste freshwater spring, and instead rely on storing excess rainwater.
In 2021, Aya Gold & Silver began construction of a 60,000 m³ water storage basin, which became operational in 2022.
Through the Zgounder Silver Mine Expansion Project, two more storage basins will be constructed for an additional storage capacity of 450,000 m³, which corresponds to over a year of production from the new processing plant. |
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Explain the process for setting any water-related goals and targets that are part of the organization’s management approach, and how they relate to public policy and the local context of each area with water stress |
Water-related impacts are identified, assessed, and addressed through the Executive Committee of the Corporation. The targets and actions plans are communicated to the ESG Committee of the Board of Directors.
The Corporation's water-related goals, targets and performance are established by this Executive Committee. |
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Water Withdrawal |
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Total freshwater withdrawn by segment, in megaliters (ML) |
238.900 |
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i. Surface water (total in ML) |
238.900 |
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|
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|
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Freshwater (≤1,000 mg/L Total Dissolved Solids or TDS) |
238.900 |
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|
|
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|
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|
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|
|
Other water (>1,000 mg/L Total Dissolved Solids or TDS) |
0.000 |
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ii. Groundwater (total in ML) |
0.000 |
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|
|
|
|
|
|
|
|
Freshwater (≤1,000 mg/L Total Dissolved Solids or TDS) |
0.000 |
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|
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|
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|
|
Other water (>1,000 mg/L Total Dissolved Solids or TDS) |
0.000 |
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iii. Seawater (total in ML) |
0.000 |
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|
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|
|
|
|
|
|
Freshwater (≤1,000 mg/L Total Dissolved Solids or TDS) |
0.000 |
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|
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|
|
Other water (>1,000 mg/L Total Dissolved Solids or TDS) |
0.000 |
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iv. Produced water (total in ML): |
0.000 |
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|
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|
|
|
|
|
|
|
|
Freshwater (≤1,000 mg/L Total Dissolved Solids or TDS) |
0.000 |
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|
|
|
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|
|
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|
|
|
|
|
|
|
|
Other water (>1,000 mg/L Total Dissolved Solids or TDS) |
0.000 |
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v. Third-party water (total in ML): |
0.000 |
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|
|
|
|
|
|
|
Freshwater (≤1,000 mg/L Total Dissolved Solids or TDS) |
0.000 |
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|
|
|
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|
|
|
|
|
|
|
|
|
|
|
|
|
Other water (>1,000 mg/L Total Dissolved Solids or TDS) |
0.000 |
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|
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Report on the total water withdrawal from all areas with water stress in megaliters (ML), and a breakdown of this total by the following sources |
238.900 |
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i. Surface water (total in ML): |
238.900 |
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|
|
|
|
|
Freshwater (≤1,000 mg/L Total Dissolved Solids or TDS) |
238.900 |
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|
|
|
|
|
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|
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|
|
|
|
|
|
Other water (>1,000 mg/L Total Dissolved Solids or TDS) |
0.000 |
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ii. Groundwater (total in ML) |
0 |
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|
Freshwater (≤1,000 mg/L Total Dissolved Solids or TDS) |
0.000 |
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|
|
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|
|
|
|
|
|
|
|
|
|
|
|
|
Other water (>1,000 mg/L Total Dissolved Solids or TDS) |
0.000 |
|
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|
|
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iii. Seawater (total in ML) |
0.000 |
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|
|
|
|
|
|
|
|
Freshwater (≤1,000 mg/L Total Dissolved Solids or TDS) |
0.000 |
|
|
|
|
|
|
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|
|
|
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|
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|
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|
|
|
|
Other water (>1,000 mg/L Total Dissolved Solids or TDS) |
0.000 |
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iv. Produced water (total in ML): |
0.000 |
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|
|
|
|
|
|
Freshwater (≤1,000 mg/L Total Dissolved Solids or TDS) |
0.000 |
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|
|
|
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|
|
|
Other water (>1,000 mg/L Total Dissolved Solids or TDS) |
0.000 |
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v. Third-party water, in megaliters (ML), and a breakdown of this total by the withdrawal sources |
0.000 |
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Surface water source |
Not applicable |
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Surface water |
0.000 |
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Groundwater source |
Not applicable |
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Groundwater |
0.000 |
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Seawater source |
Not applicable |
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Seawater |
0.000 |
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Produced water source |
Not applicable |
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Produced water |
0.000 |
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|
Report any contextual information necessary to understand how the data have been compiled, i.e., any standards, methodologies, and assumptions used |
Data is estimated from the annual tonnage of processed ore and a recirculation rate of 59% from TSF reclaim water for the flotation circuit, and 78% for the cyanide circuit. |
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Water Consumption |
|
|
Report the total water consumption from all areas in megaliters |
426.000 |
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Report the total water consumption from all areas with water stress in megaliters |
238.900 |
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Report the change in water storage in megaliters, if water storage has been identified as having a significant water related impact, |
60,000,000.000 |
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In 2020, Aya Gold & Silver identified that increased water storage could have a significant water-related positive impact as storage enables operations to capture excess water in the rainy season and reduces withdrawals during the dry season.
In 2021, the Corporation begun construction of a 60,000 m³ water storage basin, and it became operational in late 2022. |
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Report any contextual information necessary to understand how the data was compiled, including standards, methodologies, and assumptions used, including whether the information is calculated, estimated, modeled, or sourced from direct measurements, and the approach taken for this, i.e., the use of any sector-specific factors |
Data is estimated from the annual tonnage of processed ore and a recirculation rate of 59% from TSF reclaim water for the flotation circuit, and 78% for the cyanide circuit. |
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Water Discharge-Related Impacts |
|
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Provide a description of any minimum standards set for the quality of effluent discharge, and how these minimum standards were determined, including: |
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i. How standards for facilities operating in locations with no local discharge requirements were determined |
The Zgounder Silver Mine does not discharge effluent into the environment. |
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The Zgounder Silver Mine is designed to be a zero-discharge facility. The company does not have operational water discharges and/or runoff into the Zgounder river derived from its operations. |
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ii. Water quality standards or guidelines developed internally |
Aya Gold & Silver's water monitoring program tests water quality against national and World Health Organization (WHO) drinking water standards. Water quality is evaluated monthly to ensure compliance. |
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iii. Sector-specific standards considered |
As per above, at the Zgounder Silver Mine, the Corporation tests water quality against national and WHO drinking water standards. |
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iv. Profile of the receiving waterbody considered |
The Zgounder Silver Mine does not discharge effluent into the environment. |
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Water Discharge |
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|
Report the total water discharge to all areas in megaliters |
0.000 |
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The Zgounder Silver Mine is designed to be a zero-discharge facility. The facility does not have operational water discharges and/or runoff into the Zgounder river derived from its operations. |
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i. Surface water (total) |
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ii. Groundwater (total) |
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iii. Seawater (total) |
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v. Produced water (total) |
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v. Third-party water (total) |
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Report the substances of concern, in priority, where discharges are treated in megalitres (ML) |
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i. How priority substances of concern were defined, and any international standard, authoritative list, or criteria used |
Not Applicable. |
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ii. The approach for setting discharge limits for priority substances of concern |
The Zgounder Silver Mine does not discharge effluent into the environment. |
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iii. Number of incidents of non-compliance with discharge limits |
0 |
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Waste |
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Waste Generation and Significant Waste-Related Impacts |
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The reporting organization shall report the following information |
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i. Describe the inputs, activities, and outputs that lead or could lead to these impacts; |
Waste streams that may be generated during the operational phase of mining activities include: |
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• Residues from mining/processing operations (overburden and tailings); • Hazardous waste (waste oil, chemicals, solvents, batteries, laboratory waste and medical waste); • Industrial waste (scrap metal, wood packaging, plastics); • Household waste (inert waste such as plastics, glass and building materials); • Organic waste (food and plant material). |
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ii. Describe whether these impacts relate to waste generated in the organization’s own activities or to waste generated upstream or downstream in its value chain |
These impacts relate to waste generated by the Corporation's own activities at the Zgounder Silver Mine. |
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Report the total amounts generated of the following and associated risks (tonnes) |
566,342.000 |
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Overburden amount (tonnes) |
0.000 |
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Overburden is not applicable to the Zgounder Silver Mine as this is an underground operation as of 2021. |
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Overburden risks |
Not Applicable |
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Rock amount (tonnes) |
317,131.000 |
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This amount has increased significantly compared to 2021. This is due to the development of new mining access that is meant to facilitate production ramp up for 2024, when the new processing plant will become operational as part of the Zgounder Silver Mine Expansion Project. |
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Rock risks |
Not Applicable |
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In 2021, the Zgounder Silver Mine was an underground mining operation, and as such the volumes of waste rock generated are very low. Waste rock is used for mine back-fill and as material for civil engineering.
Aya Gold & Silver commissioned a third-party audit of its waste rock in 2021, and the results showed no significant potential for acid generation. |
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Tailings amount (tonnes) |
249,211.000 |
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Tailing risks |
• Disposal location • Type of waste material disposed • Other, please specify |
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Tailings contain cyanide. |
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Sludges amount (tonnes) |
0.000 |
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Sludges risks |
Not Applicable |
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Report actions, including circularity measures, taken to prevent waste generation in the organization’s own activities and upstream and downstream in its value chain, and to manage significant impacts from waste generated |
Aya Gold & Silver implemented a Waste Management Plan (WMP) in 2021 for its Zgounder Silver Mine.
The WMP seeks to identify sources of waste generation, promote its sorting, pickup and disposal, in addition to its recycling through partnership with contractors. |
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If the waste generated by the organization in its own activities is managed by a third party, a description of the processes used to determine whether the third party manages the waste in line with contractual or legislative obligations |
In 2022, Aya Gold & Silver contracted a third party to remove large quantities of scrap metal that could not be reused internally. The provider was selected through a tender process that qualified bidders through a rigorous compliance process that verified permits, government issued operation permits, ISO 9001 certification, and previous experience. The third party purchased the scrap metal by weight to recycle and repurpose. |
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In 2022, Aya Gold & Silver will establish a partnership with an accredited third-party to dispose of all solid waste present on site that cannot be processed internally: hazardous waste, industrial waste, and domestic waste. |
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Describe the processes used to collect and monitor waste-related data |
Waste quantity is roughly estimated using the number of pick-up trucks that collect waste twice a week from the Zgounder Silver Mine. |
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Waste Generated |
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Report the total weight of waste generated (tonne) |
566,870.000 |
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Report the composition breakdown of the total waste (tonne) |
The total waste (in tonnes) generated by the Zgounder Silver Mine in 2022 is as follows: |
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Explain the relevance to the companies sector or activities, e.g., tailings for an organization in the mining sector, electronic waste for an organization in the consumer electronics sector, or food waste for an organization in the agriculture or in the hospitality sector |
In 2022, relevant waste for the Zgounder Silver Mine was:
• Sterile rock • Tailings • Scrap metal • Toxic waste (oils and batteries) • Tires • Other industrial waste • Domestic waste |
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Materials that are present in the waste |
• Biomass • Metals • Plastics • Textiles |
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Report contextual information necessary to understand the data and how the data has been compiled |
Waste rock and tailings were calculated based on production numbers for 2022.
Domestic waste was estimated based on the number of trucks per week and typical load per truck.
Toxic waste, tires, and other industrial waste was estimated by the site maintenance department. |
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Waste Diverted from Disposal |
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Total weight of waste diverted from disposal (tonne) |
211,821 |
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Total weight of hazardous waste diverted from disposal (tonne), and a breakdown of this total by the following recovery operations |
0 |
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i. Preparation for reuse (total, tonne) |
0 |
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Preparation for reuse - Onsite |
0 |
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Preparation for reuse - Offsite |
0 |
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ii. Recycling (total, tonne) |
0 |
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Recycling - Onsite |
0 |
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Recycling - Offsite |
0 |
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iii. Other recovery operations (total, tonne) |
0 |
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Other recovery operations - Onsite |
0 |
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Other recovery operations - Offsite |
0 |
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Report the total weight of non-hazardous waste diverted from disposal (tonnes), and a breakdown of this total by the following recovery operations |
211,821 |
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i. Preparation for reuse (total, tonne) |
100 |
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Preparation for reuse - Onsite |
100 |
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Preparation for reuse - Offsite |
0 |
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ii. Recycling (total, tonne) |
211,721 |
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Recycling - Onsite |
211,421 |
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Recycling - Offsite |
300 |
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iii. Other recovery operations (total, tonne) |
0 |
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Other recovery operations - Onsite |
0 |
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Other recovery operations - Offsite |
0 |
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Disclose contextual information necessary to understand the data and how the data has been compiled |
In 2022, Aya Gold & Silver contracted a third party to purchase scrap metal by the ton to be recycled and reused. The data was obtained by weighing the trucks when leaving the Zgounder Silver Mine.
Aya also reuse most of the waste rock that is generated at the Zgounder Silver Mine for backfill and civil infrastructure filling. |
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Scrap metal is also reused internally by the maintenance department. The number for reuse - onsite was estimated. |
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Waste Directed to Disposal |
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Report the total weight of waste directed to disposal (tonne) |
51 |
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Total weight of hazardous waste directed to disposal (tonne), and a breakdown of this total by the following recovery operations |
0 |
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i. Incineration (with energy recovery), (tonne) |
0 |
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Incineration (with energy recovery) - Onsite |
0 |
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Incineration (with energy recovery) - Offsite |
0 |
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ii. Incineration (without energy recovery), (tonne) |
0 |
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Incineration (without energy recovery) - Onsite |
0 |
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Incineration (without energy recovery) - Offsite |
0 |
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iii. Landfilling (total, tonne) |
0 |
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Landfilling - Onsite |
0 |
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Landfilling - Offsite |
0 |
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iv. Other recovery operations (total, tonne) |
0 |
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Other recovery operations - Onsite |
0 |
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Other recovery operations - Offsite |
0 |
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Report the total weight of non-hazardous waste diverted from disposal (tonnes), and a breakdown of this total by the following recovery operations |
51 |
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i. Incineration (with energy recovery), (tonne) |
0 |
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Incineration (with energy recovery) - Onsite |
0 |
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Incineration (with energy recovery) - Offsite |
0 |
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ii. Incineration (without energy recovery), (tonnes) |
51 |
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Incineration (without energy recovery) - Onsite |
51 |
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Incineration (without energy recovery) - Offsite |
0 |
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iii. Landfilling (total, tonne) |
0 |
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Landfilling - Onsite |
0 |
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Landfilling - Offsite |
0 |
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iv. Other recovery operations (total, tonne) |
0 |
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Other recovery operations - Onsite |
0 |
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Other recovery operations - Offsite |
0 |
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Disclose contextual information necessary to understand the data and how the data has been compiled |
Data on on-site incineration waste is estimated based on domestic generated in 2022. |
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Effluents and Waste |
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Significant Spills |
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The reporting organization shall report the following information |
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a. Total number of recorded significant spills |
0 |
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Oil spills |
0 |
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Fuel spills |
0 |
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Spills of wastes |
0 |
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Spills of chemicals |
0 |
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Other, as specified by the organization |
0 |
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iii. Material and impacted surface of spill: |
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Oil spills |
Not Applicable |
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Fuel spills |
Not Applicable |
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Spills of wastes |
Not Applicable |
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Spills of chemicals |
Not Applicable |
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Other, as specified by the organization |
Not Applicable |
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c. Impacts of significant spills |
Aya Gold & Silver did not have any significant spills as a result of its operations in 2022. |
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Transport of Hazardous Waste |
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The reporting organization shall report the following information |
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Total weight for each of the following |
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i. Hazardous waste transported (tonne) |
0.000 |
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ii. Hazardous waste imported (tonne) |
0.000 |
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iii. Hazardous waste exported (tonne) |
0.000 |
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iv. Hazardous waste treated (tonne) |
0.000 |
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Percentage of hazardous waste shipped internationally |
Does Not Apply |
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Standards, methodologies, and assumptions used |
In 2022, Aya Gold & Silver stored its hazardous waste onsite while evaluating its options for contracting a third party to transport and remove waste safely. |
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Waste Management |
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Disclose the total amount of non-mineral waste generated (tonne) |
384.000 |
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Disclose the total weight of tailings produced (tonne) |
249,221.000 |
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Disclose the total amount of waste rock generated (tonne) |
317,131.000 |
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Disclose the total amount of overburden removed (tonne) |
0.000 |
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Disclose the total weight of waste generated that was hazardous (tonne) |
5.000 |
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Disclose the total weight of hazardous waste generated that was recycled (tonne) |
0.000 |
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Disclose the total number of significant incidents associated with handling, storage, transportation, or disposal of hazardous materials used in mineral processing activities and hazardous waste generated |
0 |
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Describe the policies and procedures that are set forth by the company's waste and hazardous materials management strategy |
In 2021, Aya Gold & Silver implemented a Waste Management Plan at its Zgounder Silver Mine. As per that plan, hazardous waste was stored onsite in 2022 while the Corporation evaluated third parties to safely dispose of hazardous waste. |
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Describe how its policies and procedures compare with those required by local jurisdictions that apply to the entity |
The Corporation is in compliance with all policies and procedures required by the Ministry of Energy, Mines and Sustainable Development (MEM) of the Kingdom of Morocco. In addition, it generally strives to apply international best practices. |
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Describe its approach to waste management during the entire project life cycle |
Please refer to the attached document for a description of Aya Gold & Silver's approach to waste management. |
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Aya Gold & Silver's Approach to Waste Management |
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Describe the approach to the management of hazardous materials used in processing |
At the Zgounder Silver Mine, hazardous material used in processing consists primarily of processing solution. |
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In 2021, Aya Gold & Silver implemented a hazardous material management plan to assess risks, provide safe storage, handling and disposal of hazardous material. |
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Describe how waste and hazardous materials management efforts are coordinated among business partners (e.g., contractors and subcontractors) |
Please refer to the answer above on the Corporation's approach to waste management during the entire project life cycle. |
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Describe how the company ensures compliance and conformance with waste and hazardous material management policies and procedures |
In 2021, a third-party provider was selected through a tender process that qualified bidders through a rigorous compliance process involving verification of permits, government- issued operation permits, ISO 9001 certification, and previous experience.
That process continued throughout 2022. |
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Tailings Storage Facilities Management |
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Does your company manage Tailings Storage Facilities |
Yes |
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Provide an inventory of all talings storage facilities (TSFs) |
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TSF #1: (1) facility name |
"Historical Tailings" |
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The "Historical Tailings" were operated between 1980 and 1990 by the Société minière de Sidi Lahcen (SOMIL). In 2021, Aya Gold & Silver developed a NI 43-101 Feasibility Study ("FS") for the Zgounder Silver Mine Expansion Project, in which the reprocessing of the historical tailings was added to the project for an estimated 817,000 ounces of indicated silver.
As per the mining plan described in the FS, the Historical Tailings will be reprocessed towards the end of life of the Zgounder Silver Mine, and the Corporation will then proceed to TSF closure and environmental rehabilitation. |
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TSF #1: (2) location |
Morocco |
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TSF #1: (3) ownership status |
Company owned |
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TSF #1: (4) operational status |
Not in operation |
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TSF #1: (5) construction method |
Upstream |
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TSF #1: (6) maximum permitted storage capacity |
0.000 |
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Maximum permitted storage is unknown for this facility. |
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TSF #1: (7) current amount of tailings stored |
318,000.000 |
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Total tailings stored are calculated in tons. |
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TSF #1: (8) consequence classification |
Low |
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TSF #1: (9) date of most recent independent technical review |
2021-05-07 |
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The date of the most recent independent technical review is unknown for this TSF, as it was decommissioned in 1990. |
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TSF #1: (10) material findings |
No |
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TSF #1: (11) mitigation measures |
Not applicable to the results of the most recent independent technical review. |
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TSF #1: (12) site-specific EPRP |
No |
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The TSF was decommissioned in 1990 and does not present any stability risks at present. |
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TSF #2: (1) facility name |
"Ancient Tailings" |
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The Ancient Tailings facility is currently under rehabilitation, and revegetation has begun to close the facility. |
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TSF #2: (2) location |
Morocco |
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TSF #2: (3) ownership status |
Company owned |
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TSF #2: (4) operational status |
Not in operation |
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TSF #2: (5) construction method |
Upstream |
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TSF #2: (6) maximum permitted storage capacity |
0.000 |
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Maximum permitted storage is unknown for this facility. |
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TSF #2: (7) current amount of tailings stored |
272,000.000 |
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The current amount of tailings stored is unknown. |
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TSF #2: (8) consequence classification |
Low |
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TSF #2: (9) date of most recent independent technical review |
2021-05-07 |
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TSF #2: (10) material findings |
No |
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TSF #2: (11) mitigation measures |
Not applicable to the results of the most recent independent technical review. |
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TSF #2: (12) site-specific EPRP |
No |
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The "ancient tailings" facility were operated by the previous management for about one year, in 2019. Decommissioning was already underway when new management started at the Zgounder Silver Mine in mid-2020.
In 2021, Aya Gold & Silver organized a third- party audit to get an independent assessment of the stability of the structure. Recommendations were immediately implemented and the Corporation is now evaluating the process of environmental rehabilitation for this TSF. |
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TSF #3: (1) facility name |
"Flotation Tailings" |
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TSF #3: (2) location |
Morocco |
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TSF #3: (3) ownership status |
Company owned |
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TSF #3: (4) operational status |
In operation |
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TSF #3: (5) construction method |
Upstream |
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TSF #3: (6) maximum permitted storage capacity |
0.000 |
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Aya Gold & Silver's permitting from the Ministry of Energy, Mine and Sustainable Development does not have a maximum permitted storage capacity. Maximum permitted storage is unknown for this facility. |
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TSF #3: (7) current amount of tailings stored |
340,311.000 |
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This amount is an estimation as Aya Gold & Silver does not have data from prior operators of the Zgounder Silver Mine.
In 2022, Aya Gold and Silver added 183779 tonnes of tailings to the facility. |
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TSF #3: (8) consequence classification |
Low |
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TSF #3: (9) date of most recent independent technical review |
2022-09-01 |
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TSF #3: (10) material findings |
No |
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TSF #3: (11) mitigation measures |
Transitioning to GISTM code Piezometer installation Production transfer to new installation in 2024. |
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TSF #3: (12) site-specific EPRP |
Yes |
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Aya Gold & Silver is developing its Emergency Preparedness and Response Plans for conclusion in 2022. |
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TSF #4: (1) facility name |
"Cyanidation Tailings" |
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TSF #4: (2) location |
Morocco |
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TSF #4: (3) ownership status |
Company owned |
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TSF #4: (4) operational status |
Operational |
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TSF #4: (5) construction method |
Upstream |
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TSF #4: (6) maximum permitted storage capacity |
0.000 |
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Aya Gold & Silver's permit from the Ministry of Energy, Mines and Sustainable Development does not state a maximum permitted storage capacity. Maximum permitted storage is unknown for this facility. |
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TSF #4: (7) current amount of tailings stored |
195,459.000 |
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This amount is an estimation as Aya Gold & Silver does not have data from prior operators of the Zgounder Silver Mine.
In 2022, Aya Gold and Silver added 65,459 tonnes of tailings to the facility. |
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TSF #4: (8) consequence classification |
Significant |
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TSF #4: (9) date of most recent independent technical review |
2022-09-01 |
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TSF #4: (10) material findings |
No |
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TSF #4: (11) mitigation measures |
Transitioning to GISTM code Piezometer installation Production transfer to new installation in 2024. |
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TSF #4: (12) site-specific EPRP |
Yes |
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Aya Gold & Silver is in the process of developing its Emergency Preparedness and Response Plans. These will be concluded in 2022. |
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Provide a summary of the tailings management systems used to monitor and maintain the structural integrity of tailings facilities and to minimize the risk of a catastrophic failure |
In 2021, Aya Gold & Silver implemented quarterly audits by external third parties to review the structural integrity and overall status of the two operating tailings facilities, with the objective of applying the Global Industry Standard on Tailings Management (GISTM) retroactively to operating TSFs.
This process is still ongoing in 2022. |
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As per the Feasibility Study for the Zgounder Silver Mine Expansion Project, a new TSF will be constructed ("Site C") in 2023. The GISTM will be applied from the beginning of the planning process. |
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Provide summary of tailings management systems and governance structure used to monitor and maintain the stability of tailings storage facilities |
In addition to quarterly audits, Aya Gold & Silver implements monthly internal audits to monitor the implementation of the recommendations issued by the external third- party audits. |
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The results of these audits are reported to the VP of Operations and the Board of Directors. |
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Disclose the approach to the development of Emergency Preparedness and Response Plans (EPRPs) |
The Corporation is in the process of developing its Emergency Preparedness and Response Plans. Described in OMS. |
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Disclose the company's approach to engagement concerning Emergency Preparedness and Response Plans (EPRPs) at tailings storage facilities, including the preparedness of local stakeholders |
Aya Gold & Silver's approach to the development of the Emergency Preparedness and Response Plans includes engagement and coordination with local authorities. Described in OMS. |
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Innovation |
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Describe nature of spending on Research, Development and Technologies for waste management compliance and improvement |
In 2022, Aya Gold & Silver spend USD 439,988.00 on improvement to the two TSF in operations at the Zgounder Silver Mine. These improvements included reinforcing the walls, improving the storm-water derivation channels around the TSF, as well as spending on third party audits and subsequent corrective measured. |
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Materials |
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Materials Stewardship |
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Identify programs related to materials stewardship and report on their progress |
In 2022, Aya Gold & Silver did not have any programs related to materials stewardship. |
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Supplier Environmental Assessment |
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New Suppliers Screened |
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a. Report the percentage of new suppliers that were screened using environmental criteria |
7.5472% |
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In 2022, the total number of new suppliers for the Zgounder Silver Mine was 106. This number includes all suppliers, from office furniture to engineering firms to mining contractors.
ESG criteria are used to screen new suppliers when the works presents a risk and involved manpower at the Zgounder Silver Mine itself, as per the Corporation's HSEC Management Plan. |
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Negative Impacts in the Supply Chain and Results |
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a. Report the number of suppliers assessed for environmental impacts |
22 |
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In the past, Aya Gold & Silver did not evaluate suppliers based on their environmental impact. During their selection, suppliers are systematically evaluated on criteria such as competitiveness, responsiveness, and reputation in the Moroccan market, which takes into account environmental acceptability factors.
In 2022, the Corporation implemented a new approach for the Expansion Project which includes the pre-selection of suppliers. Each work package/tender includes a questionnaire that screens for H&S, Environment and Community (HSEC) factors. This questionnaire allows the Corporation to rank suppliers and eliminate those with a potential history of negative environmental impacts. |
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b. Report the number of suppliers identified as having significant actual and potential negative environmental impacts |
11 |
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In 2022, the Corporation did not identify any suppliers as currently exerting or likely to exert adverse environmental impact. Raw materials that could potentially impact the environment are imported from global suppliers that respect HSEC international standards and supply leading mining groups in Morocco.
That year, however, our HSEC team at the Zgounder Silver Mine conducted several audits with all contractors present on site. Our of 22 contractors present on site, 11 were identified as having potential or actual negative HSEC impacts, and corrective actions were implemented. |
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c. Report significant actual and potential negative environmental impacts identified in the supply chain |
0 |
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In 2022, 11 contractors were identified as having potential environmental impact, however through engagement and implementation of action plans no significant actual impact was recorded that year in the supply chain. |
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d. Report the percentage of suppliers identified as having significant actual and potential negative environmental impacts with which improvements were agreed upon as a result of assessment |
100.0000% |
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e. Report the percentage of suppliers identified as having significant actual and potential negative environmental impacts with which relationships were terminated as a result of assessment, and why |
0.0000% |
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Biodiversity |
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Management Plan |
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Disclose the approach to biodiversity management |
Please refer to the attached document for a description of Aya Gold & Silver's approach to Biodiversity Management. |
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Aya Gold & Silver's Biodiversity Management Plan |
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Describe significant impacts of activities, products and services on biodiversity in protected areas and areas of high biodiversity value outside protected areas |
The Zgounder Silver Mine is not located in a protected areas or in areas of high biodiversity value outside of protected areas. |
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List the environmental and biodiversity management plan(s) implemented at active sites |
The following plans are implemented at the Zgounder Silver Mine: • HSEC Management Plan • Waste Management • Biodiversity Management Plan • Environmental and Social Management Plan |
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Zgounder Silver Mine ESIA + ESMP |
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1.1 Mine lifecycle stages to which the plan(s) apply |
• Decommissioning • During closure • Exploration and appraisal • Production • Restoration • Site development |
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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 |
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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) |
Environmental management plans were developed internally and are prepared based on the typical ISO 14001 structure as they are part of our Environmental and Social Management System. |
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The Environmental and Social Management Plan was developed by the consulting firm that developed the 2022 Environmental and Social Impact Assessment for the Zgounder Silver Mine Expansion Project.
Aya's Approach to Sustainability |
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Impacts of Policies and Procedures |
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Where relevant, describe specific policies and practices that apply to areas with protected conservation status and/or areas of critical habitat, which are defined by the International Finance Corporation (IFC) Performance Standard 6 |
Aya Gold & Silver does not have any specific policies that apply to areas with protected conservation status and/or areas of critical habitat as the Corporation does not have operations in such areas. |
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If the management policies and practices do not apply to all of the entity’s sites or operations, indicate the percentage of sites to which they were applied |
0 |
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Where environmental management policies and practices differ significantly by mineral resource (e.g., bauxite mining as compared to silver mining) then describe differences for each resource |
Currently, Aya Gold & Silver only produces silver. |
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Disclose the degree to which its policies and practices are aligned with the International Finance Corporation’s (IFC) Performance Standards on Environmental and Social Sustainability, January 1, 2012, including specifically |
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IFC Performance Standard 1 — Assessment and Management of Environmental and Social Risks and Impacts |
Partial alignment |
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IFC Performance Standard 3 — Resource Efficiency and Pollution Prevention |
Partial alignment |
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IFC Performance Standard 4 — Community Health, Safety, and Security |
Partial alignment |
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IFC Performance Standard 6 — Biodiversity Conservation and Sustainable Management of Living Natural Resources |
Partial alignment |
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Impacts |
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Percentage of its mine sites (by annual production output from mines in tonnes) where acid-generating seepage into surrounding surface water and/or groundwater is: predicted to occur |
0.0000% |
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Percentage of mine sites (by annual production output from mines in tonnes) where acid-generating seepage into surrounding surface water and/or groundwater is: actively mitigated |
0.0000% |
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Percentage of mine sites (by annual production output from mines in metric tonnes) where acid-generating seepage into surrounding surface water and/or groundwater is: under treatment or remediation |
0.0000% |
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Provide a breakdown by business unit where acid rock drainage occur, is activelly mitigated and/or under treatment or remediation |
Acid rock drainage does not occur at the Zgounder Silver Mine. |
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Does access to the site involve traversing a protected area |
No |
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Do any of the entities concessions share a watershed with a protected area |
No |
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Provide context and description of site access involving traversing protected areas, and/or watersheds shared with a protected area. Include reference to measures in place to assure access, any proactive programs to support the biodiversity of the protected area, and any formal complaints or compliance issues and related steps to resolve |
Not applicable to the Corporation's Zgounder Silver Mine.
The Zgounder Mine is accessible from the City of Agadir on the well-maintained paved highways of N10 and P1706 that run east for 205 km to Taliouine in the Taroudant Province. Most of the remaining 61 km to the mine is traveled on a paved road to the village of Askaoun. The final five (5) km drive to the mine is via a dirt road. The Zgounder Silver Mine is also accessible with a 278 km drive on paved highways from the City of Marrakesh. |
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Percentage of proved reserves in sites with protected conservation status or in areas of endangered species habitat |
0.0000% |
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Grade (in percentage %) of proved reserves located in areas either with protected conservation status or in areas of endangered species habitat |
0 |
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Silver (Ag) |
0.000 |
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Percentage of probable reserves in sites with protected conservation status or in areas of endangered species habitat |
0.0000% |
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Grade (in percentage %) of probable reserves located in areas either with protected conservation status or in areas of endangered species habitat |
0.000 |
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Silver (Ag) |
0.000 |
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Not Applicable |
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Percentage of inferred, indicated and/or measured resources in sites with protected conservation status or in areas of endangered species habitat |
0.0000% |
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Amount of land (owned or leased, and managed for production activities or extractive use) disturbed or rehabilitated (hectares) |
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Total land disturbed and not yet rehabilitated (A: opening balance) |
100 |
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This is an estimation. |
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Total amount of land newly disturbed within the reporting period (B) |
74 |
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Total amount of land newly rehabilitated within the reporting period to the agreed end use (C) |
0 |
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Total land disturbed and not yet rehabilitated (D= A+B-C; closing balance) |
174 |
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Total cumulative land rehabilitated since the beginning of the operation (hectares) |
0 |
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The number and percentage of total sites identified as requiring biodiversity management plans (BMP) according to stated criteria, and the number (percentage) of those sites with plans in place |
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Identify the total number of sites |
1 |
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Report criteria for deciding that a BMP is required |
Other, please specify |
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As per the Project's ESAP (Environmental and Social Action Plan), delivered by the EBRD (European Bank for Reconstruction and Development), Aya is required to draft and implement a Biodiversity Management Plan. |
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Report the number of total sites that have been assessed under the criteria as in need of a BMP |
1 |
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Report the percentage of total sites that have been assessed under the criteria as in need of a BMP |
100.0000% |
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Of the number of sites in need of a BMP, report the number that have a BMP in place and operational |
1 |
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Of the number of sites in need of a BMP, report the percentage that have a BMP in place and operational |
100.0000% |
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Protected Areas |
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For each operational site owned, leased, managed in, or adjacent to, protected areas and areas of high biodiversity value outside protected areas, report the following information: |
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i. Geographic location |
Aya Gold & Silver does not have any operational sites owned, leased, managed or adjacent to protected areas and areas of high biodiversity value outside of protected areas. |
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ii. Subsurface and underground land that may be owned, leased, or managed by the organization |
Aya Gold & Silver does not have any operational sites owned, leased, managed or adjacent to protected areas and areas of high biodiversity value outside of protected areas. |
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iii. Position in relation to the protected area (in the area, adjacent to, or containing portions of the protected area) or the high biodiversity value area outside protected areas |
Aya Gold & Silver does not have any operational sites owned, leased, managed or adjacent to protected areas and areas of high biodiversity value outside of protected areas. |
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Significant Impacts of Activities, Products and Services |
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Report the nature of significant direct and indirect impacts on biodiversity with reference to one or more of the following: |
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i. Construction or use of manufacturing plants, mines, and transport infrastructure |
• Construction (Startup or Expansion) • Extraction • Processing/Production |
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ii. Pollution (introduction of substances that do not naturally occur in the habitat from point and non-point sources) |
Yes |
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iii. Introduction of invasive species, pests, and pathogens |
Not Applicable |
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iv. Reduction of species |
No |
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v. Habitat conversion |
No |
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vi. Changes in ecological processes outside the natural range of variation (i.e., salinity or changes in groundwater level) |
Not Applicable |
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Significant direct and indirect positive and negative impacts with reference to the following: |
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i. Species affected |
Not Applicable |
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ii. Extent of areas impacted |
Not Applicable |
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iii. Duration of impacts |
Not Applicable |
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Habitats Protected or Destroyed |
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The reporting organization shall report the following information: |
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Size and location of all habitat areas protected or restored, and whether the success of the restoration measure was or is approved by independent external professionals |
There are no significant habitat areas protected or restored surrounding the Zgounder Silver Mine or impacted by its operation. |
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Whether partnerships exist with third parties to protect or restore habitat areas distinct from where the organization has overseen and implemented restoration or protection measures |
No partnerships exist with third parties to protect or restore habitat areas as this is not applicable at the Zgounder Silver Mine. |
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IUCN Red List Species and National Conservation List Species |
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Report the total number of IUCN Red List species with habitats in areas affected by the operations of the organization, by level of extinction risk. Note to reader, as there are 37,400 species on the IUCN Red List that are classified in nine categories, you may choose from the nine categories |
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i. Not Evaluated |
Not applicable to the Zgounder SIlver Mine. |
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ii. Data Deficient |
Not applicable to the Zgounder SIlver Mine. |
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iii. Least Concern |
Not applicable to the Zgounder SIlver Mine. |
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iv. Near threatened |
Not applicable to the Zgounder SIlver Mine. |
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v. Vulnerable |
Not applicable to the Zgounder SIlver Mine. |
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vi. Endangered |
Not applicable to the Zgounder SIlver Mine. |
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vii. Critically Endangered |
Not applicable to the Zgounder SIlver Mine. |
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Social |
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Scale of the Organization |
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Describe how the organisation defines its "Operation" |
Aya Gold & Silver defines its "operations" as its operating sites, as opposed to exploration sites. For the 2022 reporting period, this disclosure is focused on all Company activity in Morocco. |
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Report the total number of operations |
1 |
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Scale of the Organization |
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Report the total number of direct employees worldwide (exclude contractors) |
336 |
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In 2022, the Corporation retained a total of 355 employees: • 19 direct employees at its corporate office in Montreal, Quebec. • 336 direct employees in Morocco. • 15 direct employees in Mauritania.
This report focuses on Aya's operations in Morocco. The human resources statistics in this reports reflect this scope. |
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Report the total number of male direct employees worldwide (exclude contractors) |
310 |
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In 2022, the Corporation retained : • 13 male direct employees at its corporate office in Montreal, Quebec. • 310 male direct employees in Morocco |
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Report the total number of female direct employees worldwide (exclude contractors) |
26 |
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In 2022, the Corporation retained : • 6 female direct employees at its corporate office in Montreal, Quebec. • 26 female direct employees in Morocco |
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Report the total number of contract employees worldwide |
388 |
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For this reporting period, the Corporation has identified contractors as those with contracts exceeding 6 months.
In 2022, the Corporation retained : • 4 contract employees at its corporate office in Montreal, Quebec. • 392 contract employees in Morocco |
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Female employees and contractors as percentage of total employees and contractors |
4.1436% |
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Male employees and contractors as percentage of total employees and contractors |
95.8564% |
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Total number of non-binary employees and contractors worldwide |
0 |
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Non-binary employees and contractors as percentage of total employees and contractors |
0.0000% |
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Total number of employees and contractors with gender not disclosed |
0 |
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Employees and contractors with gender not disclosed as percentage of total employees and contractors |
0.0000% |
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Contractors as percentage of total employed workforce worldwide |
53.5912% |
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Employee Information |
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Report the total number of direct employees by employment type (permanent and temporary), by gender |
336 |
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Aya Gold & Silver's 2022 ESG report focuses on its operation in Morocco. As such, the Corporation presents only its disaggregated employee information for its Morocco subsidiary. |
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Total number of permanent employees |
328 |
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Total number of permanent employees - female |
26 |
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Total number of permanent employees - male |
302 |
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Total number of permanent employees - Non-binary |
0 |
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Total number of permanent employees - Gender not disclosed |
0 |
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Total number of temporary employees |
8 |
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Total number of temporary employees - female |
0 |
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Total number of temporary employees - male |
8 |
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Total number of temporary employees - Non-binary |
0 |
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Total number of temporary employees - Gender not disclosed |
0 |
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Report the total number of non-guaranteed hours employees by gender |
0 |
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Total number of non-guaranteed hours employees - female |
0 |
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Total number of non-guaranteed hours employees - male |
0 |
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Total number of non-guaranteed hours employees - Non-binary |
0 |
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Report the total number of employees by employment type (full-time and part-time), by gender |
336 |
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Report the total number of full-time employees |
336 |
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Report the total number of part-time employees |
0 |
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Total number of full-time employees - female |
26 |
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Total number of part-time employees - female |
0 |
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Total number of full-time employees - male |
310 |
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Total number of part-time employees - male |
0 |
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Total number of full-time employees - Non-binary |
0 |
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Total number of part-time employees - Non-binary |
0 |
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Total number of full-time employees - Gender not disclosed |
0 |
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Total number of part-time employees - Gender not disclosed |
0 |
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Describe the methodologies and assumptions used to compile the data |
Please see below : |
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Are the numbers reported in head count, full-time equivalent (FTE), or using another methodology |
Head count. |
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Are the numbers reported at the end of the reporting period, as an average across the reporting period, or using another methodology |
HR statistics for Aya's direct employees are the Corporation's numbers on December 31, 2022. The year-end number is higher than at the beginning of the 2022 year, which represents the direction of the scale of the Corporation. |
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Provide contextual information necessary to understand the employment information provided |
No contextual information is needed. |
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Describe significant fluctuations, if any, in the number of employees during the reporting period and between reporting periods |
In 2022, the Corporation saw an increase in its number of employees compared to 2021. The trend is expected to continue before plateauing in 2024. Numbers are expected to decrease slightly in 2025 when the Zgounder Silver Mine Expansion Project is completed and operations return to normal. |
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Workers who are not employees |
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Report the total number of workers who are not employees and whose work is controlled by the organization |
388 |
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Describe the most common types of worker and their contractual relationship with the organization |
Mine operations workers who work with subcontracting companies and self-employed contractors.
The employment relationship is managed by service or subcontracting contracts. |
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The type of work they perform |
We call on specialists with the appropriate skills and equipment to perform specific services. |
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Report the total number of contractors by employment type (permanent and temporary), by gender |
388 |
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Report the total number of contractors by employment type (full-time and part-time), by gender |
388 |
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Total number of full-time contractors - female |
4 |
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Total number of part-time contractors - female |
0 |
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Total number of full-time contractors - male |
384 |
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Total number of part-time contractors - male |
0 |
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Total number of full-time contractors - Non-binary |
0 |
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Total number of part-time contractors - Non-binary |
0 |
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Total number of full-time contractors - Gender not disclosed |
0 |
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Total number of part-time contractors - Gender not disclosed |
0 |
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Describe the methodologies and assumptions used to compile the information about workers who are not employees. |
Please see below : |
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Is the number of workers who are not employees reported in head count, full-time equivalent (FTE), or using another methodology |
Head Count |
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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 |
Data on contractors is the monthly average. This better represents the coming and going of Contractor's various works and tasks during a given year of operation at the Zgounder Silver Mine. |
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Describe significant fluctuations, if any, in the number of workers who are not employees during the reporting period and between reporting periods |
In 2022, the Corporation saw an increase in employee numbers compared to 2021. The trend is expected to continue before plateauing in 2024. Employee numbers are expected to decrease slightly in 2025 when the Zgounder Silver Mine Expansion Project is completed and operations return to normal. |
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Turnover |
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Report the total number and rate of employee turnover during the reporting period, by age group, and gender |
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All Employees |
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Total number of turnover (the number that left during the period) |
39 |
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Rate of turnover |
6.2751% |
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Voluntary Turnover |
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Total number of turnover (the number that left voluntarily during the period) |
22 |
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Rate of turnover |
3.5398% |
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Involuntary Turnover |
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Total number of turnover (the number that left involuntarily during the period) |
17 |
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Rate of turnover |
2.7353% |
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Female employees |
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Total number of turnover (the number of females that left during the period) |
3 |
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Rate of turnover, females |
12.5000% |
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Male employees |
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Total number of turnover (the number of males that left during the period) |
36 |
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Rate of turnover, males |
6.0251% |
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Non-binary employees |
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Total number of turnover (the number non-binary that left during the period) |
0 |
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Rate of turnover, non-binary |
Does Not Apply |
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Turnover & Age Breakdown |
|
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Employees aged 30 years old and under |
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Total number of turnover (the number that left during the period) |
18 |
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As percent of total employees |
27.3481% |
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Rate of turnover |
10.5882% |
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Employees aged between 30 and 50 years old |
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Total number of turnover (the number that left during the period) |
16 |
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As percent of total employees |
59.8066% |
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Rate of turnover |
4.3069% |
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Employees over 50 years old |
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Total number of turnover (the number that left during the period) |
5 |
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As percent of total employees |
12.8453% |
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Rate of turnover |
6.2500% |
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Identify types of employees captured in the turnover rate calculations |
Other, please specify |
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The types of employees captured in the turnover rate calculations include direct employees and contractor employees. |
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Average age of employees |
37 |
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New Hires and Rate of Hire |
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|
i. Report the total number and rate of new employee hires during the reporting period, by age group, gender and region |
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All employees |
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Total hires during the reporting period |
252 |
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In this section, the numbers presented are for Aya Gold & Silver Morocco only. |
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Rate of hire |
34.8066% |
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Female employees |
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Total female hires during the reporting period |
16 |
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Females as percent of total new hires |
6.3492% |
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Male employees |
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Total males hires during the reporting period |
236 |
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Males as percent of total new hires |
93.6508% |
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Non-binary employees |
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Total non-binary hires during the reporting period |
0 |
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Non-binary as percent of total new hires |
0.0000% |
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Employees aged 30 years old and under |
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Total hires during the reporting period (30 yr and under) |
111 |
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30 yr and under as percent of total new hires |
44.0476% |
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Employees aged between 30 and 50 years old |
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Total hires during the reporting period (30-50 yrs) |
132 |
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30-50 yrs as percent of total new hires |
52.3810% |
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Employees over 50 years old |
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Total hires during the reporting period (50+ yrs) |
9 |
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50+ yrs as percent of total new hires |
3.5714% |
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Identify types of employees captured in the hire rate calculations |
• All employees on the payroll • Other, please specify |
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The types of employees captured in the hire rate calculations include direct employees and contractor employees. |
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Full-time Employee Benefits |
|
|
Report the benefits which are standard for full-time employees of the organization but are not provided to temporary or part-time employees, by significant locations of operation |
Not Applicable |
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Aya Gold & Silver Morocco's part-time employees receive the same benefits as full- time employees. |
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Provide the definition used for ‘significant locations of operation’ |
In this reporting period, Aya Gold and Silver is disclosing information exclusively from its subsidiary in Morocco. |
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Parental leave |
|
|
Report the total number of employees that were entitled to parental leave, by gender: |
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Male |
17 |
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Female |
0 |
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Non-binary |
0 |
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Report the total number of employees that took parental leave, by gender |
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Male |
17 |
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Female |
0 |
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Non-binary |
0 |
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Report the total number of employees that returned to work in the reporting period after parental leave ended, by gender: |
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Male |
17 |
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Female |
0 |
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Non-binary |
0 |
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|
Report the total number of employees that returned to work after parental leave ended that were still employed 12 months after their return to work, by gender: |
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Male |
17 |
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Female |
0 |
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Non-binary |
0 |
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Report the return to work rates of employees that took parental leave, by gender |
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Male |
100.0000% |
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Female |
Does Not Apply |
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Non-binary |
Does Not Apply |
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|
Report the retention rates of employees that took parental leave, by gender |
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Male |
100.0000% |
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Female |
Does Not Apply |
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Non-binary |
Does Not Apply |
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Diversity and Equal Opportunity |
|
|
Report the percentage of employees per employee category in each of the following diversity categories |
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Board of Directors |
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Total Board of Directors |
8 |
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Percent Male |
75.0000% |
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Percent Female |
25.0000% |
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Percent Non-Binary |
0.0000% |
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|
|
No employees at the Zgounder Silver Mine have self-identified as non-binary. Aya Gold & Silver, as part of its Code of Business Ethics and Conduct, values the diversity of its employees and is committed to providing equal opportunity in all aspects of employment. |
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|
Percent under 30 years of age |
0.0000% |
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Percent between 30 and 50 years of age |
25.0000% |
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Percent over 50 years of age |
75.0000% |
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Senior Management |
|
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Total Senior Managers |
55 |
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Percent Male |
81.8182% |
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Percent Female |
18.1818% |
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|
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|
|
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|
|
Percent Non-Binary |
0.0000% |
|
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|
|
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|
|
|
|
|
|
|
|
|
|
No employees at the Zgounder Silver Mine have self-identified as non-binary. Aya Gold & Silver, as part of its Code of Business Ethics and Conduct, values the diversity of its employees and is committed to providing equal opportunity in all aspects of employment. |
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|
|
Percent under 30 years of age |
18.1818% |
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|
|
Percent between 30 and 50 years of age |
69.0909% |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Percent over 50 years of age |
12.7273% |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
iii. Number of minority or vulnerable groups |
0 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Salaried (excluding Senior Management) |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Total Salaried (excluding Senior Management) |
38 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Percent Male |
78.9474% |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Percent Female |
21.0526% |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Percent Non-Binary |
0.0000% |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
No employees at the Zgounder Silver Mine have self-identified as non-binary. Aya Gold & Silver, as part of its Code of Business Ethics and Conduct, values the diversity of its employees and is committed to providing equal opportunity in all aspects of employment. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Percent under 30 years of age |
42.1053% |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Percent between 30 and 50 years of age |
47.3684% |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Percent over 50 years of age |
10.5263% |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
iii. Number of minority or vulnerable groups |
0 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Technical Employees (skilled hourly) |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Total Technical Employees |
72 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Percent Male |
88.8889% |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Percent Female |
11.1111% |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Percent Non-Binary |
0.0000% |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
No employees at the Zgounder Silver Mine have self-identified as non-binary. Aya Gold & Silver, as part of its Code of Business Ethics and Conduct, values the diversity of its employees and is committed to providing equal opportunity in all aspects of employment. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Percent under 30 years of age |
40.2778% |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Percent between 30 and 50 years of age |
51.3889% |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Percent over 50 years of age |
8.3333% |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
iii. Number of minority or vulnerable groups |
0 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Production Employees (unskilled hourly) |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Total Production Employees |
171 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Percent Male |
100.0000% |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Percent Female |
0.0000% |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Percent Non-Binary |
0.0000% |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
No employees at the Zgounder Silver Mine have self-identified as non-binary. Aya Gold & Silver, as part of its Code of Business Ethics and Conduct, values the diversity of its employees and is committed to providing equal opportunity in all aspects of employment. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Percent under 30 years of age |
21.6374% |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Percent between 30 and 50 years of age |
61.9883% |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Percent over 50 years of age |
16.3743% |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
iii. Number of minority or vulnerable groups |
0 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Contractors: |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Total Contractors |
388 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Percent Male |
98.9691% |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Percent Female |
1.0309% |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Percent Non-Binary |
0.0000% |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
No employees at the Zgounder Silver Mine have self-identified as non-binary. Aya Gold & Silver, as part of its Code of Business Ethics and Conduct, values the diversity of its employees and is committed to providing equal opportunity in all aspects of employment. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Percent under 30 years of age |
27.3196% |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Percent between 30 and 50 years of age |
59.7938% |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Percent over 50 years of age |
12.8866% |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
iii. Number of minority or vulnerable groups |
0 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Salary Ratio Between Genders |
|
|
Report the ratio of the basic salary and remuneration of women to men for each employee category, by significant locations of operation |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Senior Management |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Ratio Salary Male to Female |
1.109 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Ratio Salary Female to Male |
0.901 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Ratio Salary Non-Binary to Male |
1.000 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
No employees at the Zgounder Silver Mine have self-identified as non-binary. Aya Gold & Silver, as part of its Code of Business Ethics and Conduct, values the diversity of its employees and is committed to providing equal opportunity in all aspects of employment. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Ratio Salary Non-Binary to Female |
1.109 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
No employees at the Zgounder Silver Mine have self-identified as non-binary. Aya Gold & Silver, as part of its Code of Business Ethics and Conduct, values the diversity of its employees and is committed to providing equal opportunity in all aspects of employment. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Ratio Salary Female to Male under 30 years of age |
1.081 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Ratio Salary Female to Male between 30 and 50 years of age |
1.122 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Ratio Salary Female to Male over 50 years of age |
1.000 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Salaried (excluding Senior Management) |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Ratio Salary Male to Female |
1.215 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Ratio Salary Female to Male |
0.823 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Ratio Salary Non-Binary to Male |
1.000 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
No employees at the Zgounder Silver Mine have self-identified as non-binary. Aya Gold & Silver, as part of its Code of Business Ethics and Conduct, values the diversity of its employees and is committed to providing equal opportunity in all aspects of employment. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Ratio Salary Non-Binary to Female |
1.215 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
No employees at the Zgounder Silver Mine have self-identified as non-binary. Aya Gold & Silver, as part of its Code of Business Ethics and Conduct, values the diversity of its employees and is committed to providing equal opportunity in all aspects of employment. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Ratio Salary Female to Male under 30 years of age |
1.027 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Ratio Salary Female to Male between 30 and 50 years of age |
1.017 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Ratio Salary Female to Male over 50 years of age |
1.000 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Technical Employees (skilled hourly) |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Ratio Salary Male to Female |
1.219 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Ratio Salary Female to Male |
0.820 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Ratio Salary Non-Binary to Male |
1.000 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
No employees at the Zgounder Silver Mine have self-identified as non-binary. Aya Gold & Silver, as part of its Code of Business Ethics and Conduct, values the diversity of its employees and is committed to providing equal opportunity in all aspects of employment. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Ratio Salary Non-Binary to Female |
1.219 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
No employees at the Zgounder Silver Mine have self-identified as non-binary. Aya Gold & Silver, as part of its Code of Business Ethics and Conduct, values the diversity of its employees and is committed to providing equal opportunity in all aspects of employment. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Ratio Salary Female to Male under 30 years of age |
1.012 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Ratio Salary Female to Male between 30 and 50 years of age |
0.674 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Ratio Salary Female to Male over 50 years of age |
1.000 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Production Employees (unskilled hourly) |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Ratio Salary Male to Female |
1.000 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Ratio Salary Female to Male |
1.000 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Ratio Salary Non-Binary to Male |
1.000 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
No employees at the Zgounder Silver Mine have self-identified as non-binary. Aya Gold & Silver, as part of its Code of Business Ethics and Conduct, values the diversity of its employees and is committed to providing equal opportunity in all aspects of employment. |
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Ratio Salary Non-Binary to Female |
1.000 |
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No employees at the Zgounder Silver Mine have self-identified as non-binary. Aya Gold & Silver, as part of its Code of Business Ethics and Conduct, values the diversity of its employees and is committed to providing equal opportunity in all aspects of employment. |
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Ratio Salary Female to Male under 30 years of age |
1.000 |
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Ratio Salary Female to Male between 30 and 50 years of age |
1.000 |
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Ratio Salary Female to Male over 50 years of age |
1.000 |
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Contractors: |
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Ratio Salary Male to Female |
1.000 |
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Ratio Salary Female to Male |
1.000 |
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Ratio Salary Non-Binary to Male |
1.000 |
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No employees at the Zgounder Silver Mine have self-identified as non-binary. Aya Gold & Silver, as part of its Code of Business Ethics and Conduct, values the diversity of its employees and is committed to providing equal opportunity in all aspects of employment. |
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Ratio Salary Non-Binary to Female |
1.000 |
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No employees at the Zgounder Silver Mine have self-identified as non-binary. Aya Gold & Silver, as part of its Code of Business Ethics and Conduct, values the diversity of its employees and is committed to providing equal opportunity in all aspects of employment. |
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Ratio Salary Female to Male under 30 years of age |
1.000 |
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Ratio Salary Female to Male between 30 and 50 years of age |
1.000 |
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Ratio Salary Female to Male over 50 years of age |
1.000 |
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Non-Discrimination |
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Incidents and Corrective Action |
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Total number of incidents of discrimination during the reporting period |
1 |
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Race |
0 |
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Colour |
0 |
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Gender |
1 |
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Religion |
0 |
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Political Opinion |
0 |
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National Extraction (place of birth) |
0 |
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Social Origin (social class /social caste) |
0 |
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Age |
0 |
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Disability |
0 |
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Migrant Status (foreign birth, foreign citizenship, moving temporarily into a new country) |
0 |
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HIV/AIDS |
0 |
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Sexual Orientation (LGBTQQIP2SAA stands for lesbian, gay, bisexual, transgender, questioning, queer, intersex, pansexual, two-spirit (2S), androgynous and asexual. Two-spirit is term used by some indigenous North Americans to describe those who fulfil a traditional third-gender ceremonial role). |
0 |
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Genetic Predisposition (an increased likelihood of developing a particular disease based on a person's genetic makeup) |
0 |
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Lifestyle (healthy diet, not smoking, minimizing alcohol use) |
0 |
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Report the status of the incidents and actions taken with reference to the following |
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i. Incident reviewed by the organization |
In 2022, the Corporation reviewed an incident where inappropriate language was used on a social media platform towards some female colleagues and constituted an incident of gender discrimination. |
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Labour Relations |
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Collective Bargaining Agreements |
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Percentage of total direct employees covered by collective bargaining agreements |
0.0000% |
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Notice Periods |
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Minimum number of weeks’ notice typically provided to employees and their representatives prior to the implementation of significant operational changes that could substantially affect them |
4 weeks |
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Collective Bargaining Agreements - US & Foreign Workforce |
|
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Report the percentage of U.S. employees in the active workforce that are covered under collective bargaining agreements |
Does Not Apply |
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Report the percentage of foreign employees in the active workforce that are covered under collective bargaining agreements |
0.0000% |
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Disclose the number of work stoppages of work stoppages involving 1,000 or more workers lasting one full shift or longer |
0 |
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Disclose the total duration, in worker days idle, of work stoppages involving 1,000 or more workers lasting one full shift or longer |
0 |
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Report total number of strikes and lock-outs exceeding one week's duration |
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Number of lock-outs exceeding one week's duration |
0 |
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Number of strikes exceeding one week's duration |
0 |
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Number of operations with closure plans |
1 |
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Percent of operations with closure plans |
100.0000% |
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Report on the overall financial provision for closure, or include a reference to the relevant financial statements |
Aya Gold & Silver has designed a closure plan and expansion project for the Zgounder operation. Please see attached NI 43-101 Technical Report Feasibility Study, page 379. |
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NI 43-101 Zgounder Feasibility Study |
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Freedom of Association and Collective Bargaining |
|
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Operations and Suppliers At Risk |
|
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Report the operations and suppliers in which workers’ rights to exercise freedom of association or collective bargaining may be violated or at significant risk either in terms of: |
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i. Type of operation (i.e., manufacturing plant) and supplier |
Aya Gold & Silver's operations at the Zgounder Silver Mine consist of underground mining and metal processing activities. Suppliers consist mostly of contractors working on site. |
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ii. Countries or geographic areas with operations and suppliers considered at risk |
Morocco |
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The Corporation's Zgounder Silver Mine is located in the jurisdiction of Morocco considered by international organizations to have lax statutes on organizing labor. |
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Report measures taken by the organization in the reporting period intended to support rights to exercise freedom of association and collective bargaining |
As per the Kingdom of Morocco's Labor code, the Zgounder Silver Mine has elected worker representatives. |
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Occupational Health and Safety |
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Health & Safety Management System |
|
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For employees and for workers who are not employees, but whose work and/or workplace is controlled by the organization, report the following: |
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A statement of whether an occupational health and safety management system has been implemented |
Yes |
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i. The system has been implemented because of legal requirements and, if so, a list of the requirements |
Yes, the OHS System for the Zgounder Silver Mine has been implemented to meet the following legal requirements: - Moroccan labor code (Loi n°65-99) - Occupational environment (Arrêté N° 93-08 du 6 joumada I 1489 (BO n° 5680 du 06/11/08) - Moroccan mining code |
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ii. The system has been implemented based on recognized risk management and/or management system standards/guidelines and, if so, a list of the standards/guidelines |
The system implemented is based on risk management and ISO 45001:2018. |
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A description of the scope of workers, activities, and workplaces covered by the occupational health and safety management system, and an explanation of why any workers, activities, or workplaces are not covered |
The safety management system applies to all activities and business processes, namely: geology, mining, process, maintenance, laboratory, logistics, purchasing, projects, etc. |
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Hazard Identification, Risk Assessment, and Incident Investigation |
|
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For employees and for workers who are not employees, but whose work and/or workplace is controlled by the organization, report the following: |
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A description of the processes used to identify work-related hazards and assess risks on a routine and non-routine basis, and to apply the hierarchy of controls in order to eliminate hazards and minimize risks, including |
For routine tasks and operations, the Corporation uses its occupational risk analysis standard for workstations to identify hazards and assess risks according to the FMECA (Failure mode, effects and criticality analysis) hazard method. Risk assessments are conducted as follows: 1- Division of activities. 2- Identification of workstations and associated tasks. 3-Identification of hazards and associated risks. 4-Assessment and prioritization of risks according to an evaluation grid 5- Interpretation of the Risk Score 6- Action plan & Operating mode. For non-routine activities, the company uses work permits, standards, assesses risks and applies control measures. |
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i. How the organization ensures the quality of these processes, including the competency of persons who carry them out |
The Corporation ensures the quality of the risk assessment process through its risk assessment standard, training participants tasked with this process, incident analysis and periodic updating of the risk analysis.
The risk assessment is led by a qualified HSE team. |
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ii. How the results of these processes are used to evaluate and continually improve the occupational health and safety management system |
The final product of the risk assessment is in the form of an action plan in which the actions, persons responsible and deadlines for completion are defined. There are also operating modes relating to the identified workstations.
The implementation of the action plan is monitored by the HSE manager in consultation with department managers. |
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A description of the processes for workers to report work-related hazards and hazardous situations, and an explanation of how workers are protected against reprisals |
The Corporation has set up charters for monthly departmental safety meetings in which departmental employees participate and which provide an opportunity to report risky situations. Additionally, HSE inspections and interviews are carried out by the HSE team with employees.
Reporting is also conducted through worker representatives. Hygiene, health and safety committee meetings are held quarterly in the presence of staff representatives to discuss aspects relating to the health and safety of staff and working conditions. |
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A description of the policies and processes for workers to remove themselves from work situations that they believe could cause injury or ill health, and an explanation of how workers are protected against reprisals |
In 2022, Aya Gold & Silver did not have a formal process whereby workers could remove themselves from work situations that they believed could cause injury or ill health.
The Zgounder Silver Mine Occupational Health & Safety (OHS) Charter, however, states that Aya's Gold & Silver managerial team is responsible for the health & safety of all employees and must assume exemplary behavior and leadership. |
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A description of the processes used to investigate work-related incidents, including the processes to identify hazards and assess risks relating to the incidents, to determine corrective actions using the hierarchy of controls, and to determine improvements needed in the occupational health and safety management system |
The OHS charter signed by the CEO requires that all accidents, first aid injuries and incidents in relation to the Corporation's activities be analyzed and communicated, in order to learn lessons and take steps necessary to avoid their recurrence.
Aya Gold & Silver has a site-specific standard for incident Investigation that defines the requirements and rules relating to the classification, investigation, analysis and reporting of accidents. |
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Health Services |
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The reporting organization shall report the following information for employees and for workers who are not employees, but whose work and/or workplace is controlled by the organization: |
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A description of the occupational health services’ functions that contribute to the identification and elimination of hazards and minimization of risks, and an explanation of how the organization ensures the quality of these services and facilitates workers’ access to them |
The Zgounder Silver Mine's on-site clinic is equipped for first-aid treatment with health services provided by an occupational doctor and 3 nurses. The clinic is accessible to all on- site employees who are under the Corporation's operational control. |
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Worker Participation and Communication on Health & Safety |
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The reporting organization shall report the following information for employees and for workers who are not employees, but whose work and/or workplace is controlled by the organization |
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A description of the processes for worker participation and consultation in the development, implementation, and evaluation of the occupational health and safety management system, and for providing access to and communicating relevant information on occupational health and safety to workers |
Worker consultation and participation in the health and safety management system is ensured through monthly safety meetings (SCS, CGS, CHS) as well as through worker representatives. |
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Where formal joint management–worker health and safety committees exist, a description of their responsibilities, meeting frequency, decision-making authority, and whether and, if so, why any workers are not represented by these committees |
The Zgounder Silver Mine has the following worker-management committees: 1- Safety Governance Committee composed of heads and representatives of each different department and workers. 2- Service Safety Sub-Committee composed of management and workers from each department.
Both of these committees have the following objectives.
a. Lead and manage safety within departments; b. Encourage participation and consult employees on aspects relating to working conditions in order to build a preventative culture at site level; c. Supervise meetings in order to achieve OHS&E objectives; d. Ensure effective communication based on respect and active listening; e. Ensure the involvement and participation of non-managerial employees in the OHS&E approach; f. Establish an effective action plan to improve working conditions, eliminate risky situations and examine the safety behavior of staff.
3-The Health and safety committee is a legally required committee that meets quarterly. |
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Health & Safety Training |
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A description of 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 |
The Zgounder Silver Mine has an annual health and safety training program. The program is developed and implemented by the human resources department in consultation with HSE and other departments. Training focuses primarily on risk assessment, analysis and investigation of incidents. |
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Promotion of Worker Health |
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The reporting organization shall report the following information for employees and for workers who are not employees but whose work and/or workplace is controlled by the organization |
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An explanation of how the organization facilitates workers’ access to non-occupational medical and healthcare services, and the scope of access provided |
Aya Gold & Silver's primary operation, the Zgounder Silver Mine, is located in the foreign jurisdiction of Morocco. Zgounder workers are covered under Morocco's public health services. |
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A description of any voluntary health promotion services and programs offered to workers to address major non-work-related health risks, including the specific health risks addressed, and how the organization facilitates workers’ access to these services and programs |
In 2022, the Corporation did not provide any voluntary health promotion services or programs to workers to address major non- work-related health risks. |
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Prevention and Mitigation of Health & Safety Impacts |
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The reporting organization shall report the following information: |
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A description of the organization’s approach to preventing or mitigating significant negative occupational health and safety impacts that are directly linked to its operations, products or services by its business relationships, and the related hazards and risks |
Aya Gold & Silver requires new Zgounder Mine hires to undergo medical exams to ensure their fitness for work. Workers performing high-risk activities are required to complete medical tests on a quarterly basis. |
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Workers Covered by H&S Management System |
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The reporting organization shall report the following information |
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If the organization has implemented an occupational health and safety management system based on legal requirements and/or recognized standards/guidelines: |
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i. The number all workers who are not employees, but whose work and/or workplace is controlled by the organization, who are covered by such H&S system |
395 |
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This is an average calculation as the number of contractors varies from month to month at the Zgounder Silver Mine. |
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i. Percentage of all employees and workers who are not employees, but whose work and/or workplace is controlled by the organization, who are covered by such H&S system; |
100.0000% |
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ii. The number of all employees, who are covered by such H&S system that has been internally audited |
336 |
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ii. Percentage of all employees and workers who are not employees, but whose work and/or workplace is controlled by the organization, who are covered by such H&S system that has been internally audited; |
100.0000% |
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iii. The number of all employees, who are covered by such H&S system that has been externally audited |
336 |
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iii. Percentage of all employees and workers who are not employees, but whose work and/or workplace is controlled by the organization, who are covered by such H&S system that has been externally audited; |
100.0000% |
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Whether and, if so, why any workers have been excluded from this disclosure, including the types of worker excluded |
No operational workers have been excluded from this disclosure. Nineteen workers from Aya Gold & Silver's Montreal corporate office are also covered by the Zgounder Silver Mine's ESMS in case they visit the work site. |
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Any contextual information necessary to understand how the data have been compiled, i.e., any standards, methodologies, and assumptions used |
The number of all workers who are not employees, but whose work and/or workplace is controlled by the organization, is an average calculation. The number of contractors varies from month to month at the Zgounder Silver Mine. |
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Work-related Injuries |
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Injuries - For all employees |
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i. Number of fatalities as a result of work-related injury |
0 |
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i. Rate of fatalities resulting from work-related injury. Note: calculating per 200,000 hours worked |
0.000 |
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ii. Number of high-consequence work-related injuries (excluding fatalities) |
10 |
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ii. Rate of high-consequence work-related injuries (excluding fatalities) |
3.261 |
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iii. Number of recordable work-related injuries |
27 |
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iii. Rate of recordable work-related injuries |
8.804 |
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iv. Main types of work-related injury, e.g., confined space, trips, falls, etc. |
The high-consequence, work-related injuries reported in 2022 relate to activities requiring tool and machine handling, tripping hazards, fall of ground, and internal circulation. |
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v. Number of hours worked |
613,358 |
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Lost Time Injuries (LTIs) |
10 |
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Lost Time Injuries Rate (LTIR) |
3.261 |
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Injuries - workers who are not employees but whose work and/or workplace is controlled by the organization |
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i. Number of fatalities as a result of work-related injury |
0 |
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i. Rate of fatalities resulting from work-related injury. Note: calculating per 200,000 hours |
0.000 |
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ii. Number of high-consequence work-related injuries (excluding fatalities) |
15 |
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ii. Rate of high-consequence work-related injuries (excluding fatalities) |
2.936 |
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iii. Number of recordable work-related injuries |
38 |
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iii. Rate of recordable work-related injuries |
7.438 |
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iv. Main types of work-related injury, e.g., confined space, trips, falls, etc. |
The high-consequence, work-related injuries reported in 2022 relate to activities requiring tool and machine handling, tripping hazards, fall of ground, and internal circulation. |
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v. Number of hours worked |
1,021,835 |
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Lost Time Injuries (LTIs) |
15 |
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Lost Time Injuries Rate (LTIR) |
2.936 |
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Combined (Employees and non-employees, but controlled by the organization): |
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Total Hours Worked |
1,635,193 |
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Total number of all work-related injuries |
90 |
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Rate of work-related injuries |
11.008 |
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Total Lost Time Injuries (LTIs) |
25 |
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Lost Time Injuries Rate (LTIR) |
3.058 |
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Report the work-related hazards that pose a risk of high-consequence injury, including |
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i. How have these hazards been determined |
Workplace hazards are determined by workplace safety inspections, risk analyses, and incident investigations. |
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ii. Which of these hazards have caused or contributed to high-consequence injuries during the reporting period |
In this reporting period, the following hazards contributed to high-consequence injuries: 1) Tools and machines handling; 2) Tripping hazard; 3) Falling objects; 4) Fall of ground; 5) Internal circulation. |
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iii. Actions taken or underway to eliminate these hazards and minimize risks using the hierarchy of controls |
The following actions were taken to eliminate these hazards: 1) Reinforcement of the HSE department by HSE coordinators; 2) Improvement of collective protective equipment and infrastructure; 3) Introduction of new technologies meeting safety requirements for work at the underground mine; 4) Development and deployment of operational standards and procedures; and 5) Training and increasing staff awareness. |
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Report on actions taken or underway to eliminate other work-related hazards and minimize risks using the hierarchy of controls |
Other hazards and their mitigation programs are determined and developed through workplace safety inspections, risk analysis and incident investigation. |
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Whether and, if so, why any workers have been excluded from this disclosure, including the types of worker excluded, e.g., short-term contractors |
No workers have been excluded from this disclosure. |
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Disclose any contextual information necessary to understand how the data have been compiled, i.e., any standards, methodologies, and assumptions used |
Aya Gold & Silver used standards and methodologies based on ISO 45001 to compile the data presented in this report. |
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Work-related Ill-health |
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The reporting organization shall report the following information |
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For all employees: |
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i. The number of fatalities as a result of work-related ill health |
0 |
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ii. The number of cases of recordable work-related ill health |
0 |
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iii. The main types of work-related ill health |
Not Applicable |
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For all workers who are not employees, but whose work and/or workplace is controlled by the organization: |
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i. The number of fatalities as a result of work-related ill health |
0 |
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ii. The number of cases of recordable work-related ill health |
0 |
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iii. The main types of work-related ill health |
Musculoskeletal disorders |
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The work-related hazards that pose a risk of ill health, including: |
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i. How these hazards have been determined |
Ill health hazards are determined through H&S risk assessments. |
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ii. Which of these hazards have caused or contributed to cases of ill health during the reporting period |
No cases of ill health hazards were recorded in this reporting period. |
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iv. Whether and, if so, why any workers have been excluded from this disclosure, including the types of worker excluded |
No workers under the operational control of Aya Gold & Silver at the Zgounder Silver Mine were excluded from this report. |
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Workforce Health and Safety |
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For U.S.-based workforce (full-time employees and contract employees), the entity shall disclose |
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For non-U.S.-based workforce (full-time employees and contract employees), the entity shall disclose |
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All-Incidence Rate (AIR) for full-time employees based on U.S. Mine Safety and Health Administration (MSHA) Form 7000-1, where incidents include |
140 |
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1. Fatalities, or work-related injuries resulting in death to employees on active mine property - full-time employees |
0 |
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2. Nonfatal, Days Lost (NFDL) cases, or occupational injuries that result in loss of one or more days from the entity’s scheduled work or days of limited or restricted activity while at work - full-time employees |
394 |
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3. No Days Lost (NDL) cases, or occurrences requiring only medical treatment (beyond first aid); that is, non-fatal injury occurrences resulting only in loss of consciousness or medical treatment other than first aid - full-time employees |
37 |
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Fatality rate for full-time employees |
0 |
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All-Incidence Rate (AIR) for contract employees based on U.S. Mine Safety and Health Administration (MSHA) Form 7000-1, where incidents include |
89 |
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1. Fatalities, or work-related injuries resulting in death to employees on active mine property - contract employees |
0 |
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2. Nonfatal, Days Lost (NFDL) cases, or occupational injuries that result in loss of one or more days from the entity’s scheduled work or days of limited or restricted activity while at work - contract employees |
520 |
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3. No Days Lost (NDL) cases, or occurrences requiring only medical treatment (beyond first aid); that is, non-fatal injury occurrences resulting only in loss of consciousness or medical treatment other than first aid - contract employees |
31 |
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Fatality rate for contract employees |
0 |
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Disclose the near miss frequency rate (NMFR) for work-related near misses - full-time employees: |
3.261 |
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Full-time employees - number of unplanned incidents in which no property or environmental damage or personal injury occurred, but where damage or personal injury easily could have occurred but for a slight circumstantial shift |
20 |
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Contract employees - number of unplanned incidents in which no property or environmental damage or personal injury occurred, but where damage or personal injury easily could have occurred but for a slight circumstantial shift |
5 |
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Occupational Health and Safety |
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Safety Training |
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Disclose the average number of training hours provided to its workforce for health, safety, and emergency management training |
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Average hours of health, safety, and emergency response training for (a) full-time/direct employees |
3.64 |
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Average hours of health, safety, and emergency response training for (b) contract employees |
5.01 |
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Training and Education |
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Annual Training |
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Report the average hours of training that the organization’s employees have undertaken during the reporting period |
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i. By gender |
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Average training hours per employee |
4.374 |
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Total number of training hours provided to all employees |
3,167 |
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Total number of employees |
724 |
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Average training hours per male employee |
4.540 |
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Total number of training hours provided to male employees |
3,151 |
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Total number of male employees |
694 |
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Average training hours per female employee |
0.533 |
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Total number of training hours provided to female employees |
16 |
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Total number of female employees |
30 |
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Average training hours per non-binary employee |
0.000 |
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Total number of training hours provided to non-binary employees |
0 |
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Total number of non-binary employees |
0 |
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ii. Report the average training hours of employees by employee category |
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Senior Management |
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Average hours Male |
0.822 |
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Average hours Female |
0.400 |
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Average hours Non-binary |
0.000 |
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Average hours under 30 years of age |
1.600 |
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Average hours between 30 and 50 years of age |
0.719 |
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Average hours over 50 years of age |
0.667 |
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Salaried (excluding Senior Management) |
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Average hours Male |
1.100 |
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Average hours Female |
0.250 |
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Average hours Non-binary |
0.000 |
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Average hours under 30 years of age |
0.250 |
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Average hours between 30 and 50 years of age |
1.278 |
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Average hours over 50 years of age |
2.000 |
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Technical Employees (skilled hourly) |
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Average hours Male |
2.984 |
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Average hours Female |
1.000 |
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Average hours Non-binary |
0.000 |
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Average hours under 30 years of age |
1.759 |
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Average hours between 30 and 50 years of age |
3.432 |
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Average hours over 50 years of age |
3.500 |
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Production Employees (unskilled hourly) |
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Average hours Male |
5.345 |
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Average hours Female |
0.000 |
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Average hours Non-Binary |
0.000 |
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Average hours under 30 years of age |
4.947 |
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Average hours between 30 and 50 years of age |
5.604 |
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Average hours over 50 years of age |
4.750 |
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Contractors: |
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Average hours Male |
5.141 |
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Average hours Female |
0.000 |
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Average hours Non-Binary |
0.000 |
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Average hours under 30 years of age |
3.830 |
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Average hours between 30 and 50 years of age |
5.522 |
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Average hours over 50 years of age |
5.740 |
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Skills Upgrading Programs |
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Report the type and scope of programs implemented and assistance provided to upgrade employee skills |
We have identified training needs to develop employee skills during 2022. The program began to be implemented at the end of 2022 and the company intends to accelerate the implementation in 2023. A budget has also been reserved for this purpose in 2023. |
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Report on transition assistance programs provided to facilitate continued employability and the management of career endings resulting from retirement or termination of employment |
The programs identified include the transition continued employability and the management of career endings. |
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Performance Reviews |
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Report the percentage of total employees by gender and by employee category who received a regular performance and career development review during the reporting period |
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i. By gender |
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Percentage of all employees who received a regular performance and career development review during the reporting period |
7.5967% |
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Total number of all employees who received a regular performance and career development review during the reporting period |
55 |
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Total number of all employees |
724 |
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Percentage of all male employees who received a regular performance and career development review during the reporting period |
6.4841% |
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Total number of all male employees who received a regular performance and career development review during the reporting period |
45 |
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Total number of all male employees |
694 |
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Percentage of all female employees who received a regular performance and career development review during the reporting period |
33.3333% |
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Total number of all female employees who received a regular performance and career development review during the reporting period |
10 |
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Total number of all female employees |
30 |
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Percentage of all non-binary employees who received a regular performance and career development review during the reporting period |
Does Not Apply |
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|
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Total number of all non-binary employees who received a regular performance and career development review during the reporting period |
0 |
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Total number of all non-binary employees |
0 |
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Child Labour |
|
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Operations and Suppliers At Risk |
|
|
The reporting organization shall report the following information |
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Disclose operations and suppliers considered to have significant risk for incidents of: |
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i.Child labour |
In 2022, child labour was not considered a risk at the Zgounder Silver Mine. |
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ii. Young workers exposed to hazardous work |
In 2022, young workers were not exposed to hazardous work as child labour is not considered a risk at the Zgounder Silver Mine. |
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Disclose operations and suppliers considered to have significant risk for incidents of child labour either in terms of: |
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i. Type of operation (i.e., manufacturing plant) and supplier |
In 2022, neither Zgounder Silver Mine operations nor its suppliers were considered to be significant risks for incidents of child labour. |
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Forced or Compulsory Labour |
|
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Operations and Suppliers At Risk |
|
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The reporting organization shall report the following information |
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Disclose operations and suppliers considered to have significant risk for incidents of forced or compulsory labor either in terms of |
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i. Type of operation (i.e., manufacturing plant) and supplier |
In 2022, forced or compulsory labour was not considered a risk at the Zgounder Silver Mine. |
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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 |
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Describe the nature of any social risks, for all operating countries, that could have a material risk to operations |
In 2022, human rights risks were not considered significant at the Zgounder Silver Mine. |
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Percentage of proved reserves that are located in or near areas of active conflict |
0.0000% |
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The total amount of proved reserves |
28.700 |
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Proven reserves in millions ounces. |
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Grade of proved reserves located in or near areas of active conflict |
As per the Uppsala Conflict Data Program, the Zgounder Silver Mine does not operate in or near an area of active conflict. |
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Percentage of probable reserves that are located in or near areas of active conflict |
0.0000% |
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|
|
The total amount of probable reserves |
42.100 |
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Probable reserves provided in millions ounces. |
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|
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Grade of probable reserves locate in or near areas of active conflict |
As per the Uppsala Conflict Data Program, the Zgounder Silver Mine does not operate in or near areas of active conflict. |
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Percentage of inferred, indicated and measured resources that are located in or near areas of active conflict |
0.0000% |
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|
|
Total amount of inferred, indicated and/or measured resources |
102.447 |
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Total amount of inferred, indicated and/or measured resources is in millions ounces. |
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Percentage of proved reserves that are located in or near areas that are considered to be indigenous peoples’ land |
0.0000% |
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|
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|
|
The total amount of proved reserves |
28.700 |
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The total amount of proved reserves is in millions ounces. |
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Grade of proved reserves locate in or near areas that are considered to be indigenous peoples’ land |
The Zgounder Silver Mine does not operate in or near areas that are considered to be indigenous peoples' land. |
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Percentage of probable reserves that are located in or near areas that are considered to be indigenous peoples’ land |
0.0000% |
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|
|
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|
|
The total amount of probable reserves |
42.100 |
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|
|
The total amount of probable reserves is in millions ounces. |
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|
|
Grade of probable reserves locate in or near areas that are considered to be indigenous peoples’ land |
The Zgounder Silver Mine does not operate in or near areas that are considered to be indigenous peoples' land. |
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Percentage of inferred, indicated and measured resources that are located in or near areas that are considered to be indigenous peoples’ land |
0.0000% |
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|
|
Total amount of inferred, indicated and measured resources |
102.447 |
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Total amount of inferred, indicated and/or measured resources is in millions ounces. |
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Describe due diligence practices and procedures with respect to indigenous rights of communities in which it operates or intends to operate |
The Zgounder Silver Mine does not operate in or near areas that are considered to be indigenous peoples' land. |
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Describe its due diligence practices and procedures with respect to human rights |
Aya Gold & Silver has not conducted a complete human rights due diligence exercise for the Zgounder Silver Mine. However, the Corporation has identified and remediated its risks. For example, Aya Gold & Silver requested clarification of land tenure from authorities in the Kingdom of Morocco to ensure this right was respected. The Corporation will evaluate the need for further due diligence in human rights in the future. |
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Human Rights |
|
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Indigenous Rights |
|
|
The reporting entity shall disclose |
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Report the number of sites on or adjacent to indigenous territories |
0 |
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Rights of Indigenous Peoples |
|
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Incidents of Violations |
|
|
Report the total number of identified incidents of violations involving the rights of indigenous peoples during the reporting period |
0 |
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Human Rights Assessment |
|
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Operations Reviews and Assessments |
|
|
Report the total number and percentage of operations that have been subject to human rights reviews or human rights impact assessments, by country |
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Report the total number of operations that have been subject to human rights reviews or human rights impact assessments |
0 |
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Report the total percentage of operations that have been subject to human rights reviews or human rights impact assessments, by country |
0.0000% |
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Employee Training on Human Rights Policies |
|
|
Report the total number of hours and percentage in the reporting period devoted to training on human rights policies or procedures concerning aspects of human rights that are relevant to operations |
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Report the total number of hours in the reporting period devoted to training on human rights policies or procedures concerning aspects of human rights that are relevant to operations |
0 |
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Report the percentage of employees trained during the reporting period in human rights policies or procedures concerning aspects of human rights that are relevant to operations |
0.0000% |
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Contracts and Agreements |
|
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Report the total number and percentage of significant investment agreements and contracts that include human rights clauses or that underwent human rights screening: |
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Number of agreements that include human rights clauses or underwent human rights screening |
0 |
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Local Communities |
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Operations with Local Community |
|
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Report the percentage of operations with implemented local community engagement, impact assessments, and/or development programs |
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Percentage of operations with social impact assessments, including gender impact assessments, based on participatory processes |
100.0000% |
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Has (Have) the operation(s) included the use of the following |
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i. Social impact assessments, including gender impact assessments, based on participatory processes |
Yes |
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ii. Environmental impact assessments and ongoing monitoring |
Yes |
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iii. Public disclosure of results of environmental and social impact assessments |
Yes |
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iv. Local community development programs based on local communities’ needs |
Yes |
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v. Stakeholder engagement plans based on stakeholder mapping |
Yes |
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vi. Broad based local community consultation committees and processes that include vulnerable groups |
Yes |
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vii. Works councils, occupational health and safety committees and other worker representation bodies to deal with impacts |
Yes |
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viii. Formal local community grievance processes |
Yes |
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Significant disputes relating to land use, customary rights of local communities and indigenous peoples |
The status of the land where the Zgounder Silver Mine is located was not clearly defined in the past. However, recently the Moroccan state declared this land as land collectively owned by local villages. More than 40% of Morocco’s land is held collectively by villages. The State via the Ministry of Interior is the trustee of collectively owned land. |
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To avoid confusion, Aya Gold & Silver approached the Ministry of Interior to clarify the land tenure status of the mine. After a due process that included consultation with village representatives conducted by the government, without the Corporation's participation or influence, on March 2, 2022, the Ministry of Interior invited Aya Gold & Silver to sign a lease agreement with the government for the required land use. The agreement, which is for 9 years, allows for indefinite renewals provided the Corporation gives the government a 6- month prior notice of intent to renew. |
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|
Number of significant disputes relating to land use, customary rights of local communities and indigenous peoples |
1 |
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Description of significant disputes relating to land use, customary rights of local communities and indigenous peoples |
The status of the land where the Zgounder Silver Mine is located was not clearly defined in the past. However, recently the Moroccan state declared this land as collective land owned by local villages. More than 40% of Morocco’s land is held collectively. The State via the Ministry of Interior is the trustee of collectively owned land. |
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The extent to which grievance mechanisms were used to resolve disputes relating to land use, customary rights of local communities and indigenous peoples, and the outcomes |
In observance of customary decision-making processes, Aya Gold & Silver's grievance mechanism has been established in collaboration with local authorities. |
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As per this process, local authorities receive grievances and forward them to the Corporation. The community relations team at the Zgounder Silver Mine, in conjunction with local authorities, investigate the grievance and resolve as required. In addition, local authorities can set up independent, ad hoc dispute-resolution committees to investigate the grievance and provide a response and resolution. |
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Operations With Negative Impacts |
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Report operations with significant actual and potential negative impacts on local communities, including: |
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i. Identify the location of the operations |
Morocco |
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ii. List the factors that could cause significant actual and potential negative impacts to local communities and provide details about vulnerabilities and risks to the communities from these factors, including intensity, likely duration, reversibility and scale of impact |
• Physical or economic isolation of the local community • Use of hazardous substances that impact the environment and human health in general, and specifically impact reproductive health • Natural resource consumption |
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The Zgounder Silver Mine utilizes hazardous substances in its processing plant, requires water consumption, and is the major employer in the region. All of the impacts described are reversible and have a low to medium impact.
Aya Gold & Silver has implemented controls and safeguards for hazardous material transportation and management. The company is monitoring its water usage and consumption, and has made efforts to employ as many workers from local communities. In 2021, 45% of the Zgounder Silver Mine workforce resided in local villages. Only 1% of the mine's workforce are expats. |
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Physical or economic isolation of the local community |
Applicable |
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Intensity or severity of the impact |
Low |
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Likely duration of the impact |
Medium term |
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Reversibility of the impact |
Completely reversible |
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Scale of the impact |
Small |
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Level of socioeconomic development, including the degree of gender equality within the community |
Not Applicable |
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State of socioeconomic infrastructure, including health and education infrastructure |
Not Applicable |
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Proximity to operations |
Applicable |
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The Zgounder Silver Mine's nearest community is situated at approx. 1.5km. The future tailing storage facility, under construction as part of the Expansion Project, is directly upstream of one of the communities. As a result of the financing for the development of the Zgounder Silver Mine expansion project, Aya has committed to the implementation of an Environmental Social Action Plan (ESAP) that includes a commitment to build the tailings facility in accordance with the GISTM code. |
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Intensity or severity of the impact |
High |
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Likely duration of the impact |
Short term |
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Reversibility of the impact |
Irreversible |
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Scale of the impact |
Small |
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Level of social organization |
Not Applicable |
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Strength and quality of the governance of local and national institutions around local communities |
Not Applicable |
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Other, please specify |
Not Applicable |
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The use of hazardous substances that impact the environment and human health in general, and specifically impact reproductive health |
Applicable |
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Intensity or severity of the impact |
Low |
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Likely duration of the impact |
Short term |
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Reversibility of the impact |
Partially reversible |
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Scale of the impact |
Small |
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The volume and type of pollution released |
Not Applicable |
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The status as major employer in the local community |
Applicable |
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Intensity or severity of the impact |
Medium |
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Likely duration of the impact |
Medium term |
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Reversibility of the impact |
Completely reversible |
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Scale of the impact |
Small |
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Land conversion and resettlement |
Not Applicable |
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Natural resource consumption |
Applicable |
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Intensity or severity of the impact |
Low |
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Likely duration of the impact |
Short term |
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Reversibility of the impact |
Completely reversible |
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Scale of the impact |
Small |
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Other, please specify |
Not Applicable |
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Community Relations |
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Artisanal and Small-Scale Mining |
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Number of company operating sites where artisanal and small-scale mining (ASM) takes place on, or adjacent to, the site (not controlled by company/unauthorized) |
0 |
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Percentage of company operating sites where artisanal and small-scale mining (ASM) takes place on, or adjacent to, the site |
Does Not Apply |
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Programs |
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Report on community relations programs, objectives and achievements in the past 3 years |
Aya Gold & Silver aims to share the benefits of responsible mining and ensure that we leave positive socio-economic and environmental legacies in the areas in which we operate. |
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In addition to local procurement and local employment, the Corporation's CSR plan is expected to help build mutually beneficial relationships between the Aya Gold & Silver and its local stakeholders by contributing to long-term improvements in the quality of life of local communities, and helping to create an environment conducive to private investment. At the Zgounder Silver Mine, the Corporation is concentrating its efforts and its development strategy on income-generating activities (IGAs), education, health, and access to water.
Since Aya's new management takeover in 2020, the community relation's team has focuses on establishing partnerships and dialogue with local authorities, administration, and local communities. The scope and reach of the Corporation's CSR initiatives has increased exponentially between 2020 and the present day.
In 2022, Aya began to implement a Stakeholder Engagement Plan and Community Grievance Mechanism based on IFC and EBRD's performance standards in order to cement the Corporation's improvements with local communities and establish and maintain its Social License to Operate. |
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Discuss the processes, procedures, and practices to manage risks and opportunities associated with the rights and interests of communities in areas where it conducts business |
National legislation in Morocco does not require a CSR strategy or community development.
However, Aya Gold & Silver strives to comply with international best practices, such as International Finance Corporation (IFC) guidelines. In the spirit of best practices, the Corporation has developed a framework of collaboration with local authorities. |
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This framework includes the following methodology: i. Choice of projects CSR projects will be chosen according to the following criteria: Aligned with the strategic axes defined by the Corporation; Aligned with the strategic axes of Morocco defined by the INDH; Aligned with the recommendations of the Environmental and Social Impact Assessment of the Zgounder Silver Mine expansion project.
ii. Consultation The Corporation will undertake consultations with the relevant delegations and institutions for each project developed.
iii. Communication and reporting The Corporation will communicate its CSR strategy, program development and execution performance monitoring with local authorities on a quarterly basis.
An annual report will be produced summarizing the actions carried out by Aya Gold & Silver.
Aya's approach to sustainability
Aya's HSEC Governance |
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Risks |
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The entity shall discuss its processes, procedures, and practices to manage risks and opportunities associated with the rights and interests of communities in areas where it conducts business, where community rights and interests include |
Aya Gold & Silver's CSR strategy aims to be a vehicle for sharing the benefits of responsible mining and ensuring a legacy of positive socio- economic and environmental impact in the areas in which we operate. In addition to local procurement and local employment, the plan is expected to help build mutually beneficial relationships between the Corporation and its local stakeholders, bringing about long-term improvement in the quality of life of local communities. and helping create an environment conducive to private investment. |
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Aya Gold & Silver wishes to concentrate its efforts and its development strategy on the areas of income-generating activities (IGAs), education, health, and access to water. |
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Economic rights and interests, including, but not limited to, employment, fair wages, payment transparency, national resource governance, and respect of infrastructure and agricultural land |
Aya Gold & Silver respects and abides by the Kingdom of Morocco's national legislation on labour as follows: |
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1) Code du Travail (loi n°65-99) 2) Dahir n° 1-60-007 du 5 rejeb 1380 (24 décembre1960) portant statut du personnel des entreprises minières. |
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Environmental rights and interests, including, but not limited to clean local air and water, as well as safe discharge and disposal of waste |
The 2022 Environmental and Social Impact Assessment (ESIA) updated the environmental and social baselines and assess potential impacts. The result is an Environmental and Social Management Plan (ESMP) that provides mitigation and control measures to protect the environment and social rights and interests.
This ESIA was enriched in 2022/2023 with a new social baseline study that included socioeconomic household level surveys. |
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During the ESIA process, water, air emissions (dust) and hazardous materials were identified as potential risks to the environment. Aya Gold & Silver has developed mitigation controls and management plans for these potential impacts. |
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Social rights and interests, including, but not limited to adequate health care, education, and housing |
See above answer. |
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Cultural rights and interests, including, but not limited to protection of places of cultural significance (e.g., sacred sites or burial sites) |
No sacred sites have been identified in the project footprint of the Zgounder Silver Mine. |
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The entity shall disclose the following, where relevant |
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Lifecycle stages to which its practices apply |
• Decommissioning and restoration • During closure • Exploration and appraisal • Mineral production |
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The community rights and interests (enumerated above) specifically addressed by the practices |
Aya Gold & Silver is concentrating its efforts on managing two primary rights and interests: 1) Community health and safety and; 2) Local employment and economic opportunities. |
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The underlying references for its procedures, including whether they are codes, guidelines, standards, or regulations and whether they were developed by the entity, an industry organization, a third-party organization (e.g., a non-governmental organization), a governmental agency, or some combination of these groups |
Aya Gold & Silver develops and implements its procedures internally based on the experience of its HSEC managers and IFC Performance Standards. |
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These procedures reference IFC and ICMM guidelines and documentation. |
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Risks associated with community relations include: |
Other, please specify |
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Aya Gold & Silver monitors and closely manages its water withdrawal and usage at the Zgounder Silver Mine to avoid potential impacts derived from the use of this shared resource. In 2022, as a result of the ESIA, the Corporation improved the water efficiency plans for its expanded mine and processing plant project to avoid consuming additional shared resources. |
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Opportunities |
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The entity shall discuss its processes, procedures, and practices to manage risks and opportunities associated with the rights and interests of communities in areas where it conducts business, where community rights and interests include |
National legislation in Morocco does not require a CSR strategy or community development. However, in addition to local procurement and local employment, the Corporation's CSR plan is expected to help build mutually beneficial relationships between the Aya Gold & Silver and its local stakeholders by contributing to long-term improvements in the quality of life of local communities, and helping to create an environment conducive to private investment.
Please refer to the attached document. |
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Community Relations: Processes, Procedures and Practices |
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Economic rights and interests, including, but not limited to, employment, fair wages, payment transparency, national resource governance, and respect of infrastructure and agricultural land |
Aya Gold & Silver respects and abides by the Kingdom of Morocco's national legislation on labour as follows: |
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1) Code du Travail (loi n°65-99) 2) Dahir n° 1-60-007 du 5 rejeb 1380 (24 décembre1960) portant statut du personnel des entreprises minières
Aya Gold & Silver has a local employment process that has been communicated to contractors for the expansion project. |
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Environmental rights and interests, including, but not limited to clean local air and water, as well as safe discharge and disposal of waste |
An Environmental and Social Impact Assessment was conducted in 2021 in order to update Aya Gold & Silver's knowledge of the environmental and social baseline and to assess potential impacts. The ESIA was validated by authorities in February 2022. |
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The result is an Environmental and Social Management Plan that is designed to provide mitigation and control measures to protect environment and social rights and interests. |
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Social rights and interests, including, but not limited to adequate health care, education, and housing |
An Environmental and Social Impact Assessment (ESIA) was conducted in 2021/2022 in order to update the environmental and social baselines and assess potential impacts. The result is an Environmental and Social Management Plan (ESMP) that provides mitigation and control measures to protect the environment and social rights and interests.
This ESIA was enriched in 2022/2023 with a new social baseline study that included socioeconomic household level surveys. |
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Cultural rights and interests, including, but not limited to protection of places of cultural significance (e.g., sacred sites or burial sites) |
No sacred sites have been identified in the project footprint of the Zgounder Silver Mine. |
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The entity shall disclose the following, where relevant |
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Lifecycle stages to which its practices apply |
• Decommissioning and restoration • During closure • Exploration and appraisal • Mineral production • Pre-bid (when the entity is considering acquisition of a site) • Site development |
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The community rights and interests (enumerated above) specifically addressed by the practices |
The Environmental and Social Management Plans that resulted from the 2022 ESIA for the Zgounder Silver Mine expansion project include the following rights and interests: |
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1) Economic rights and interests, including, but not limited to employment, fair wages, payment transparency, national resource governance, and respect of infrastructure and agricultural land. 2) Environmental rights and interests, including, but not limited to clean local air and water, as well as safe discharge and disposal of waste. 3) Social rights and interests, including, but not limited to adequate job creation, health care, education, and housing. |
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The underlying references for its procedures, including whether they are codes, guidelines, standards, or regulations and whether they were developed by the entity, an industry organization, a third-party organization (e.g., a non-governmental organization), a governmental agency, or some combination of these groups |
Aya Gold & Silver develops and implements its procedures internally based on the experience with its HSEC management and IFC Performance Standards. |
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The underlying references for its procedures are aligned with IFC and ICMM available guidelines and documentation.
Aya's HSEC Governance
Aya's approach to sustainability |
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Opportunities associated with community relations include: |
Other, please specify |
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At the Zgounder Silver Mine, Aya Gold & Silver has implemented local recruitment programs that have resulted in a 46% local workforce. The Corporation has also signed a collaboration agreement with local authorities to foster programs that will increase economic opportunities for villages and promote programs that allow villages to prepare for emergencies within their communities. |
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Risks and Opportunities |
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Disclose the degree to which its policies and practices are aligned with the International Finance Corporation’s (IFC) Performance Standards on Environmental and Social Sustainability, January 1, 2012, including specifically: |
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Performance Standard 4 — Community Health, Safety, and Security |
• All unlawful acts by security personnel is held to strict accountability standards and treated according to the offense • Community engagement is a central aspect of the organization's appropriate security strategy, as good relations with workers and communities can be the most important guarantee of security • Entity has an obligation and interest in safeguarding company personnel and property. If the organization must use security personnel to do so, security is provided in a manner that does not jeopardize the community’s safety and security, or the relationship with the community. It is also be consistent with national requirements, including national laws implementing host country obligations under international law, and with the requirements of Performance Standard 4, which are consistent with good international practice • Security arrangements to protect the organization's personnel and property made on the basis of security risks in the operating environment, company policy or protection of intellectual property or hygiene in production operations • The breadth, depth, and type of analysis is proportionate to the nature and scale of the proposed project’s risks to and potential impacts on the health and safety of the local community • The community engagement process is underway, including the informed consultation and participation process of Affected Communities • The evaluation of climate-related risks includes a discussion of potential changes in hydrologic scenarios, and the resulting potential impacts and mitigation measures considered in the design and operation of the project • The organization employs qualified and experienced professionals with proven experience designing and constructing projects of a similar complexity • The organization has a sound understanding of the social and cultural processes through which communities experience, perceive, and respond to risks and impacts and includes the implementationa of the Infrastructure and Equipment Design and Safety guidelines • The organization has adequate surveillance programs to screen the health of its workers, which may include documenting and reporting on existing diseases as required • The organization has assessed impacts and significant changes in the natural hydrologic regime of an area, such as dams and irrigation schemes or projects located in areas without proper sanitary wastewater discharge and treatment infrastructure, for example, water storage facilities may have significant consequences for the distribution and transmission of vector-borne diseases such as malaria, schistosomiasis, and dengue fever • The organization has considered engineering safety competencies including geotechnical, structural, electrical, mechanical, and fire specialties which are in addition to or beyond local regulatory requirements, on the potential risk of adverse consequences posed by the nature and use of these structural elements and the natural conditions of the area • The organization has evaluated the risks and impacts posed by the management of hazardous materials that may extend beyond the project’s property boundary and into areas inhabited or used by the community • The organization has undertaken an assessement of high risk structural elements could threaten human life in the event of failure, such as dams located upstream of communities by qualified professionals • The organization makes reasonable efforts to avoid the use of hazardous materials, unless there are no feasible alternatives or the organization can ensure their safe management • The organization takes all regulations regarding traffic laws and driving license policies seriously and abides by all national laws governing road safety • The organization uses commercially reasonable means to investigate the contractor/vendor capacity to address safety issues, communicate expectations of safety performance, and otherwise influence the safety behavior of contractors, especially those involved in the transportation of hazardous materials to and from the project site • The organziation reviews significant changes to the physical environment, such as natural vegetation cover, existing topography, and hydrologic regimes including projects such as mining, industrial parks, roads, airports, pipelines, and new agricultural development and special precautions are followed to prevent geological instability, safely manage storm water flow, prevent a reduction in the availability of surface water and groundwater for human and agricultural use (depending on the sources of water that the community has traditionally relied on), and prevent degradation in the quality of these resources • The quality of soil and water as well as other natural resources such as fauna and flora, woodlands, forest products and marine resources, are protected so as not to pose an unacceptable risk to human health, safety, and the environment due to the presence of pollutants |
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Performance Standard 5 — Land Acquisition and Involuntary Resettlement |
100% aligned |
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Performance Standard 8 — Cultural Heritage |
Not applicable |
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In 2022/2023, Aya commissioned a socioeconomic survey and baseline study, which stated that there is no cultural potential at the Zgounder Silver Mine.
Social Impact Assessment, 2023 |
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The discussion shall include how practices apply to business partners, i.e., contractors, sub-contractors, suppliers, and joint venture partners |
Aya Gold & Silver's HSEC policy and corporate standards are shared with suppliers, as well as the Zgounder Silver Mine's Environmental and Social Management Plan that is included in the 2022 ESIA.
As per the Zgounder Silver Mine Expansion Project, Aya has developed a Health & Safety, Environment and Community (HSEC) Management Plan to be shared with all contractors and suppliers involved in the construction of the Project. The HSEC Management Plan summarizes and cites all of Aya's existing applicable practices and is shared during the tendering process. |
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Cyanide providers are all signatories with the International Cyanide Management Code. The ESMP and ESIA will be shared with suppliers for the Zgounder Silver Mine expansion project as well.
Aya's Reports and Disclosures
HSEC Policy |
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Describe efforts to eliminate or mitigate community risks and/or address community concerns: |
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The use of Social Impact Assessment (SIA) that evaluates, manages, and mitigates risks |
Yes |
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Social Impact Assessment, 2023
ESIA, 2022 |
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Efforts to engage with stakeholders, build consensus, and collaborate with communities |
Yes |
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Our Approach to Sustainability |
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“Shared” or “blended” value projects that provide quantifiable benefits to the community and the entity |
Yes |
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Our Approach to Sustainability |
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7.2.1 Discuss how the site risks differ and manifest themselves from country (national), regional (state), community (local) levels, and project levels |
Water is the Zgounder Silver Mine's primary risk. In terms of ESG, this risk is shared with local villages and the Kingdom of Morocco. |
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7.2.2 Sites that are affected by Sovereign Risk (defined as the potential for a central bank or government-backed entity to willingly or unwillingly default on debt obligations, or significantly alter key economic variables, i.e., currency exchange rates, import ratios, and money supply) |
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Site 1 |
No |
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7.3 The organization should identify and describe country risks specific to its projects and unique operating context |
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7.2 and 7.3.1 The organization will include the identification of country, regional, community and site risks and/or the discussion of specific projects: |
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Risks |
General license to operate |
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7.3.2 Discuss how the entity has mitigated these risks (e.g., through community engagement partnerships, and blended value projects); the entity shall quantify this reduction in risk according to the methods described above (reduction in Value at Risk) |
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Risk Mitigation |
In addition to its ESIA management for risk identification and mitigation, Aya Gold & Silver has developed social management processes and procedures aligned with international best practices and local customs. These have generated efficient procedures for dispute resolutions and alliances for social investment that can potentially outlast the life of mine.
Such plans and procedures are : • Stakeholder Engagement Plan • Community Investment Program • Community Health and Safety Management Plan |
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7.3.3 The organization will disclose the country risk classification applied |
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Risk Classification |
Aya Gold & Silver does not apply country risk classification models. |
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Disclose the total number of site shutdowns or project delays due to non-technical factors |
0 |
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Disclose the total aggregate duration (in days) of site shutdowns or project delays due to non-technical factors |
0 |
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Resettlement |
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Have there been community resettlements in order to accommodate business activities and if so, please provide details about the specific sites |
No |
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The Zgounder Silver Mine did not require any village resettlement. Economic displacement was compensated after a thorough due diligence conducted by Aya Gold & Silver through the ESIA and the Moroccan Ministry of Interior. The Corporation signed an economic compensation agreement with the Ministry of the Interior and has also signed an agreement of collaboration with local authorities to promote economic development in villages affected by the economic displacement. |
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Economic Performance |
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Economic Value |
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The reporting organization shall report the following information |
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Direct economic value generated and distributed (EVG&D) on an accruals basis, including the basic components for the organization’s global operations as listed below. If data are presented on a cash basis, report the justification for this decision in addition to reporting the following basic components |
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i. Direct Economic Value Generated (EVG): Revenues ($ Millions) |
38.2 |
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ii. Economic Value Distributed (EVD or D): operating costs, employee wages and benefits payments to providers of capital, payments to government by country, and community investments (expenses) ($ Millions) |
38.18 |
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Operating Costs ($ Millions) |
15.5 |
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Employee wages ($ Millions) |
12.5 |
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Benefits payments to providers of capital ($ Millions) |
0 |
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Payments to government by country ($ Millions) |
9.9 |
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Payments made to Moroccan government in USD 9,8 ($ M) Payments made to Mauritania government in USD ,77 |
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Community investments (expenses) ($ Millions) |
0.28 |
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Community investments for Morocco amounted to USD .260 ($ Millions) Community investment for Mauritania amounted to USD .020 ($ Millions) |
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iii. Economic value retained ($ Millions): |
0.02 |
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Direct economic value generated ($ Millions) |
38.2 |
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Economic distributed ($ Millions) |
38.18 |
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Economic Value Generated and Distributed |
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Report countries of operation that are either candidate to or compliant with the Extractive Industries Transparency Initiative (EITI) |
Mauritania |
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Benefit and Retirement Plans |
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The reporting organization shall report the following information |
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If the plan’s liabilities are met by the organization’s general resources, the estimated value of those liabilities |
0 |
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Aya Gold & Silver is subscribed to a retirement plan in which the employee and the Corporation contribute on a monthly basis in order towards the employee's retirement. |
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If a separate fund exists to pay the plan’s pension liabilities: |
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i. The extent to which the scheme’s liabilities are estimated to be covered by the assets that have been set aside to meet them |
Pensions are managed by a pension fund belonging to an external organization. In Morocco, there is an obligatory government retirement plan and a non obligatory private retirement plan. |
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ii. The basis on which that estimate has been arrived at |
Contributions are a percentage of salary. |
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iii. When that estimate was made |
2022-01-01 |
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Percentage of salary contributed by the organization (employer) |
3.4828% |
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Level of participation, as a percentage, in retirement plans |
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Voluntary schemes (%) |
93 |
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Mandatory schemes (%) |
100 |
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Regional, country-based schemes, or other - please specify |
0.000 |
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Government Financial Assistance |
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The reporting organization shall report the following information by country: |
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Total monetary value of financial assistance received by the organization from any government during the reporting period, including ($ Millions) |
0 |
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i. Tax relief and tax credits |
0 |
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ii. Subsidies |
0 |
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iii. Investment grants, research and development grants, and other relevant types of grant |
0 |
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iv. Awards; |
0 |
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v. Royalty holidays |
0 |
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vi. Financial assistance from Export Credit Agencies (ECAs) |
0 |
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vii. Financial incentives |
0 |
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1) Corporate tax rate is capped at 20% applicable to exporting (and mining) companies, instead of 31% according to the normal scale. 2) Suspensive regime for exporting companies according to which the company can make certain local purchases previously authorized, without VAT. |
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viii. Other financial benefits received or receivable from any government for any operation |
0 |
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Whether, and the extent to which, any government is present in the shareholding structure |
Through ONHYM (Office National des Hydrocarbures et des Mines), the Moroccan government held 15% of the capital of ZMSM and BGM through most of the 2022year. The entity (AGSM) acquired the 15% ONHYM share in ZMSM in November 2022. |
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Market Presence |
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Wage Ratios in the Market |
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The reporting organization shall report the following information |
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When most employees are compensated subject to minimum wage rules, report the ratio of the entry level wage by gender at significant locations of operation to the minimum wage |
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Site 1- Male |
1.000 |
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Site 1 - Female |
1.000 |
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Site 1 - Non-binary |
0.000 |
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In 2022, no employees at the Zgounder Silver Mine have self-identified as non-binary. Aya Gold & Silver as part of its Code of Business Ethics and Conduct values the diversity of our employees and is committed to providing equal opportunity in all aspects of employment. |
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If a local minimum wage is absent or variable, reference which minimum wage is being used (by gender): |
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Male |
Not Applicable |
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Female |
Not Applicable |
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Non-binary |
Not Applicable |
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The definition used for ‘significant locations of operation’ |
In this report, Aya Gold & Silver is only disclosing information relative to its Zgounder Silver Mine. |
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Management Representation |
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The reporting organization shall report the following information |
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Percentage of senior management at significant locations of operation that are hired from the local community |
0.0000% |
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The definition used for ‘senior management’ |
People who have decision-making powers and who are experts in their field of activity. |
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The organization’s geographical definition of ‘local’ |
Local refers to the immediate villages around the mine, within an approximate 50km radius. |
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The definition used for ‘significant locations of operation’ |
Morocco |
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In significant locations of operation, report proportion (percentage) of the facility’s total workforce from the local community |
46.1310% |
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Indirect Economic Impacts |
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Infrastructure Investments and Services Supported |
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The reporting organization shall report the following information: |
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Extent of development of significant infrastructure investments and services supported |
In 2022, as per Aya's Corporate Social Responsibility (CSR) Strategy of contributing to local infrastructure and services in health, education, and general infrastructure, Aya refurbished local roads and schools in the Caïdat of Askaoun. |
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Current or expected positive impacts on communities and local economies |
The aid provided in 2022 improved transit and movement between villages. Aya will keep upgrading local roads to improve traffic safety and resilience to the winter conditions on a yearly basis, as the Corporation's local employees depend on good local road conditions to commute to the Zgounder Silver Mine.
The Corporation also started a school renovations program, whereby every year 2-3 schools will be renovated and improved in order to safeguard the health and safety of children attending schools. A football field was also renovated. |
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Current or expected negative impacts on communities and local economies |
The Corporation monitors potential negative impacts on local communities and economies from project-induced in-migration. Its CSR Strategy is continuously reviewed and improved if needed. |
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Types of investments |
In-Kind |
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Significant Indirect Economic Impacts |
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The reporting organization shall report the following information: |
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Examples of significant positive indirect economic impacts of the organization |
• Economic development in areas of high poverty (such as changes in the total number of dependents supported through the income of a single job) • Economic impacts of improving or deteriorating social or environmental conditions (such as changing job market in an area converted from small farms to large plantations, or the economic impacts of pollution) • Availability of products and services for those on low incomes (such as preferential pricing of pharmaceuticals, which contributes to a healthier population that can participate more fully in the economy, or pricing structures that exceed the economic capacity of those on low incomes) • Enhanced skills and knowledge in a professional community or in a geographic location (such as when shifts in an organization's needs attract additional skilled workers to an area, who, in turn, drive a local need for new learning institutions) • Number of jobs supported in the supply or distribution chain (such as the employment impacts on suppliers as a result of an organization's growth or contraction) • Economic impacts from the use of products and services (such as economic growth resulting from the use of a particular product or service) |
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Examples of significant negative indirect economic impacts of the organization |
Economic impacts from the use of products and services (such as economic growth resulting from the use of a particular product or service) |
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Significance of the indirect economic impacts in the context of external benchmarks and stakeholder priorities, i.e., national and international standards, protocols, and policy agendas |
The positive indirect economic impacts of the presence of the Zgounder Silver Mine align with local and national interests for economic stimulation. |
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Aya Gold & Silver is monitoring the potential increase in indirect local economic demands to determine the potential level of impact on increased costs of goods and services as a result of market demand. |
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Procurement Practices |
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Local Spending |
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a. Report the percentage of the procurement budget used for significant locations of operation that is spent on suppliers local to that operation (i.e., percentage of products and services purchased locally) |
99.6058% |
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In this report, Aya uses the term "local" to signify products and services based in Morocco. |
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Supplier Assessment |
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Suppliers Screened Using Social Criteria |
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Report the percentage of new suppliers that were screened using social criteria |
7.5472% |
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In 2022, the total number of new suppliers for the Zgounder Silver Mine was 106. This number includes all suppliers, from office furniture to engineering firms to mining contractors.
ESG criteria are used to screen new suppliers when the works presents a risk and involved manpower at the Zgounder Silver Mine itself, as per the Corporation's HSEC Management Plan. |
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Negative Social Impacts in the Supply Chain |
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Number of suppliers assessed for social impacts |
22 |
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In the past, Aya Gold & Silver did not evaluate suppliers based on their environmental impact. During their selection, suppliers are systematically evaluated on criteria such as competitiveness, responsiveness, and reputation in the Moroccan market, which takes into account environmental acceptability factors.
In 2022, the Corporation implemented a new approach for the Expansion Project which includes the pre-selection of suppliers. Each work package/tender includes a questionnaire that screens for H&S, Environment and Community (HSEC) factors. This questionnaire allows the Corporation to rank suppliers and eliminate those with a potential history of negative environmental impacts. |
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Number of suppliers identified as having significant actual and potential negative social impacts |
11 |
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In 2022, the Corporation did not identify any suppliers as currently exerting or likely to exert adverse environmental impact. Raw materials that could potentially impact the environment are imported from global suppliers that respect HSEC international standards and supply leading mining groups in Morocco.
That year, however, our HSEC team at the Zgounder Silver Mine conducted several audits with all contractors present on site. Our of 22 contractors present on site, 11 were identified as having potential or actual negative HSEC impacts, and corrective actions were implemented. |
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List of significant actual and potential negative social impacts identified in the supply chain |
• Commitment to compliance and continual improvement • Emissions and discharges of pollutants and generation of waste are to be minimized or eliminated at the source • Exposure to the hazards of physically demanding tasks • Highest standards of integrity are to be upheld in all business interactions • Implement a systematic approach to identify, manage, reduce, and responsibly dispose of or recycle solid waste (non- hazardous) • Potential emergency situations and events are to be identified and assessed • Potential for exposure to safety hazards are to be identified and assessed • Procedures and systems are to be in place to prevent, manage, track and report occupational injury and illness • Process for timely correction of deficiencies identified by internal or external assessments • Production and other machinery shall be evaluated for safety hazards • Provide workers with appropriate workplace health and safety information and training in the language of the worker or in a language the worker can understand for all identified workplace hazards that workers are exposed to |
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Locations of suppliers |
Morocco, Canada |
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In 2022, Aya Gold & Silver's contractors with potential negative social impacts identified for the Zgounder Silver mine were located in the Kingdom of Morocco, with the addition of a new mining contractor from Canada. |
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Customer Health and Safety |
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Assessment of Products and Services |
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Percentage of significant product and service categories for which health and safety impacts are assessed for improvement |
100.0000% |
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Service Category 1 |
Mining contractors |
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Percentage of significant product and service categories for which health and safety impacts are assessed for improvement |
100.0000% |
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Service Category 2 |
Civil works, construction |
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Percentage of significant product and service categories for which health and safety impacts are assessed for improvement |
100.0000% |
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Service Category 3 |
Exploration contractors |
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Percentage of significant product and service categories for which health and safety impacts are assessed for improvement |
100.0000% |
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Service Category 4 |
Maintenance contractors |
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Percentage of significant product and service categories for which health and safety impacts are assessed for improvement |
14.2857% |
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Transport and logistics suppliers were assessed as providing sufficient level of health and safety risk management. |
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Service Category 5 |
Transport and logistics |
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Governance |
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Climate Change |
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Oversight |
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Is there board-level oversight of climate-related issues within your organization |
Yes |
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Responsibility |
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Provide the highest management-level position(s) or committee(s) with responsibility for climate-related issues |
Other committee, please specify |
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Aya Gold & Silver's ESG Committee is responsible for overseeing climate-related issues. |
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Nature of primary responsibility |
Assessing climate-related risks and opportunities |
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Reporting |
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Frequency of reporting to the board on climate-related issues |
Quarterly |
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Incentives |
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Do you provide incentives for the management of climate-related issues, including the attainment of targets |
Yes |
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Key management is awarded incentives for ESG issues, including climate change. The Corporation's approach is described on its website on "Approach to Sustainability". |
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Risk and Opportunity Management |
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Does your organization have a process for identifying, assessing, and responding to climate-related risks and opportunities |
Other, please specify |
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Aya Gold & Silvers' Executive Committee established a Climate Risk Radar for the Corporation through a TFCD-inspired process to identify and assess climate-related risks. This risk register and Climate Risk Radar will be updated annually.
Risks were identified through a benchmark study of the industry and recurring risks, through interviews by the Corporation's HSEC Manager with senior management and relevant stakeholders, and through discussions with EY analysts during the TCFD gap analysis exercise. Risk assessment was conducted by the Executive Committee and the HSEC Manager acting as a facilitator, and within the same workshop responses were identified and developed for each risk.
This is a preliminary climate change risk assessment. It will be updated before end of year 2023 in a standalone TCFD-compliant climate report that will disclose climate scenario analysis across multiple dimensions (strategic, operational, reputational, and financial). Climate scenario analysis will inform Aya management in a structured, systematic, and analytical way that will contribute to resilience and to our mission: To build a sustainable, ethical, and profitable mining business that positively impacts lives. |
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Risk Assessments |
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Have you identified any inherent climate-related risks with the potential to have a substantive financial or strategic impact on your business |
Yes |
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Provide details of identified risks in your direct operations with the potential to have a substantive financial or strategic impact on your business, and your response to those risks |
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Risk 1 |
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Where in the value chain does the risk driver occur |
Direct operations |
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Risk type and primary driver |
Chronic Physical - Changes in precipitation patterns and extreme variability in weather patterns |
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Time horizon of risk |
Other, please specify |
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From short-term to long-term. |
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Likelihood of impact |
Very likely |
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Magnitude of impact |
High |
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Potential impact financial figure and explanation |
Stoppage of operations due to changes in the weather pattern and less precipitation. |
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Primary potential financial impact |
Increased indirect (operating) costs |
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The primary potential financial impact of a reduced water supply would be lower production output and higher operating costs. |
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Cost of response to risk and description |
In 2021, Aya Gold and Silver's primary response to water scarcity was to invest more capital in water retention infrastructure in order to capitalize on the excess water in rainy seasons.
In 2022, Aya invested USD 376,107.00 in response to the risk of change in precipitation (2021 expense was USD 601,500.00). |
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Risk 2 |
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Where in the value chain does the risk driver occur |
Direct operations |
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Risk type and primary driver |
Acute Physical - Increased severity and frequency of extreme weather events such as cyclones and floods |
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Time horizon of risk |
Short-term |
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Likelihood of impact |
Very likely |
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Magnitude of impact |
High |
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Potential impact financial figure and explanation |
Stoppage or slowing of operations due to acute physical events (extreme rain or extreme drought), and physical damage to infrastructure. |
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Primary potential financial impact |
Increased indirect (operating) costs |
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Cost of response to risk and description |
The first response to acute physical events is to build infrastructure (roads, retaining walls, TSF, water basins, stormwater pounds, etc...) with precautionary principles in mind and to apply available best practice (such as GISTM for tailings) and technology. |
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Risk 3 |
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Where in the value chain does the risk driver occur |
Direct operations |
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Risk type and primary driver |
Emerging regulation - Carbon pricing mechanisms |
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Time horizon of risk |
Medium-term |
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Likelihood of impact |
Likely |
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Magnitude of impact |
Medium-low |
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Potential impact financial figure and explanation |
In 2022, the carbon pricing applicable in Canada would be as such : CAD$50/tonne CO2e 22,193 tonnes CO2e
Total : CAD $1,109,650.00, or 853,098.00 $ USD. |
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Primary potential financial impact |
Increased indirect (operating) costs |
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Cost of response to risk and description |
In 2022, Aya's response to the risk of carbon pricing was to sign a Power Purchase Agreement (PPA) with a renewable energy producer in Morocco, to effectively reduce to zero our Scope 2 emissions. There is no cost associated with this measure as this provides costs saving in the long term. |
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Risk 4 |
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Where in the value chain does the risk driver occur |
Direct operations |
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Risk type and primary driver |
Emerging regulation - Other, please specify |
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The state of Morocco could issue a special Climate Change related "solidarity tax" to corporations operating in the country, especially if droughts continue to be recurrent and severe. |
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Time horizon of risk |
Medium-term |
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Likelihood of impact |
More likely than not |
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Magnitude of impact |
Medium-low |
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Potential impact financial figure and explanation |
During the COVID-19 pandemic, the state of Morocco issued a similar "solidarity tax", which cost was low to the Corporation (between USD$100,000 and USD$1M. |
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Primary potential financial impact |
Increased indirect (operating) costs |
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Cost of response to risk and description |
There is no response to risk identified, except government awareness and possible lobbying through the Chamber of Mines in Morocco. |
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Risk 5 |
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Where in the value chain does the risk driver occur |
Direct operations |
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Risk type and primary driver |
Legal Other, please specify |
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Change in reporting obligations are virtually certain to happen, as they have already evolved in the recent years. |
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Time horizon of risk |
Short-term |
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Likelihood of impact |
Virtually certain |
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Magnitude of impact |
Low |
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Potential impact financial figure and explanation |
The potential impact ranges from very insignificant to no financial impact as Aya is already allocating resources to comply with current reporting obligations and apply best practices. |
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Primary potential financial impact |
Increased indirect (operating) costs |
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Cost of response to risk and description |
The Corporation already endeavors to follow best international practice with regard to reporting obligations, so it expects to be ahead of any further requirements. |
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Risk 6 |
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Where in the value chain does the risk driver occur |
Direct operations |
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Risk type and primary driver |
Legal - Exposure to litigation |
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Time horizon of risk |
Medium-term |
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Likelihood of impact |
More likely than not |
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Magnitude of impact |
Medium |
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Potential impact financial figure and explanation |
The Corporation could be exposed to litigation if it fails to comply with reporting obligations. Potential financial impact financial could range from USD$1M to USD$3M. |
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Primary potential financial impact |
Increased indirect (operating) costs |
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Cost of response to risk and description |
The Corporation strives to follow best international practice when it comes to reporting obligations, so it expects to be ahead of any further requirements. |
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Risk 7 |
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Where in the value chain does the risk driver occur |
Direct operations |
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Risk type and primary driver |
Reputation - Stigmatization of sector |
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Time horizon of risk |
Medium-term |
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Likelihood of impact |
About as likely as not |
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Magnitude of impact |
Medium-high |
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Potential impact financial figure and explanation |
The Corporation could be exposed to litigation if it fails to comply with reporting obligations. Potential financial impact could range from USD$3M to USD$10M, as the stigmatization of the mining section could affect the Corporation's ability to raise money. |
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Primary potential financial impact |
Other, please specify |
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Difficulty to fundraise money. |
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Cost of response to risk and description |
There is little direct response that can be identified, however Aya is developing its environmental and social governance to acquire a competitive advantage compared to peers within the sector. |
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Risk 8 |
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Where in the value chain does the risk driver occur |
Direct operations |
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Risk type and primary driver |
Reputation - Increased stakeholder concern or negative stakeholder feedback |
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Time horizon of risk |
Short-term |
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Likelihood of impact |
Very unlikely |
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Magnitude of impact |
High |
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Potential impact financial figure and explanation |
Increased periods of drought induced by climate change could cause instability in Morocco and force the government to take drastic action to appease social tensions such as revoking of mining licenses. The potential impact financial figure has not been calculated, but would be catastrophic. |
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Primary potential financial impact |
Other, please specify |
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The financial impact would be the reduction or total cancellation of revenues for the Corporation. |
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Cost of response to risk and description |
There is little direct response that can be identified as this course of event would beyond the reach of the Corporation's management. Such an impact is, however, extremely unlikely. |
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Risk 9 |
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Where in the value chain does the risk driver occur |
Direct operations |
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Risk type and primary driver |
Reputation - Increased stakeholder concern or negative stakeholder feedback |
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Time horizon of risk |
Short-term |
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Likelihood of impact |
Likely |
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Magnitude of impact |
Low |
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Potential impact financial figure and explanation |
Increased periods of drought induced by climate change could cause instability in Morocco and create tension within local communities as mining production is dependent on freshwater sources. Rising tensions could eventually lead to local uprisings, strikes or short term road blockages. |
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Primary potential financial impact |
Increased indirect (operating) costs |
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Cost of response to risk and description |
In 2020, Aya developed a Corporate Social Responsibility strategy (CSR) to establish and maintain its social license to operate.
The Corporation has been expanding the scope and bandwidth of its CSR programs every year. In 2022, it began implementing a Stakeholder Engagement Plan and Grievance Resolution Mechanism in line with IFC guidance. |
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Risk 10 |
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Where in the value chain does the risk driver occur |
Direct operations |
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Risk type and primary driver |
Technology - Substitution of existing products and services with lower emissions options |
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Time horizon of risk |
Medium-term |
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Likelihood of impact |
Likely |
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Magnitude of impact |
Medium |
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Potential impact financial figure and explanation |
Local regulations could require the Zgounder Silver Mine to source its energy from renewable sources or to invest in a new infrastructure to produce renewable energy. |
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Primary potential financial impact |
Increased indirect (operating) costs |
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Cost of response to risk and description |
In February 2023, Aya announced that its subsidiary, ZMSM, had entered into a 20-year Power Purchase Agreement (the “PPA”) with Energie Éolienne du Maroc (“EEM”), a subsidiary of Nareva, for the procurement of renewable energy starting upon completion of the Zgounder Project expansion. |
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Risk 11 |
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Where in the value chain does the risk driver occur |
Direct operations |
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Risk type and primary driver |
Technology - Unsuccessful investment in new technologies |
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Time horizon of risk |
Long-term |
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Likelihood of impact |
Exceptionally unlikely |
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Magnitude of impact |
Medium-low |
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Potential impact financial figure and explanation |
According to Aya's carbon footprint reduction plan, it has committed to evaluating the feasibility of electrifying its mining fleet when the technology becomes available.
The potential financial impact of failing technology could range from USD$100,000 to USD$1M. |
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Primary potential financial impact |
Increased capital expenditures |
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Cost of response to risk and description |
Aya's management will conduct careful due diligence when evaluating new technologies for the electrification of its mining fleet. |
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Opportunity Assessments |
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Have you identified any climate-related opportunities with the potential to have a substantive financial or strategic impact on your business |
No |
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Strategy |
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Have climate-related risks and opportunities influenced your organization’s strategy and/or financial planning |
Yes, and we have developed a low-carbon transition plan |
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Aya's Climate change strategy |
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Water Management |
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Quality and Quantity Dependency |
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Rate the importance (current and future) of freshwater quality and quantity to the success of your business |
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Direct use importance rating |
Vital |
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Indirect use importance rating |
Important |
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Rate the importance (current and future) of sufficient quantity of recycled, brackish and/or produced water for the success of your business |
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Direct use importance rating |
Neutral |
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Indirect use importance rating |
Neutral |
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Risk Assessments |
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Does your organization undertake a water-related risk assessment |
Yes, water-related risks are assessed |
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Select the options that best describe your procedures for identifying and assessing water-related risks |
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i. Coverage |
Full |
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ii. Risk Assessment Procedure |
Water risks are assessed as part of an enterprise risk management framework |
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iii. Frequency of Risk Assessment |
Other, please specify |
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Aya Gold & Silver assessed water-related risks during the development of the NI 43-101 Feasibility Study for the Zgounder Silver Mine Expansion Project. The assessment covers the life of mine. It is being revaluated and improved on a continuous basis through the Executive Committee. |
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iv. How far into the future are risks considered |
More than 6 years |
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Aya Gold & Silver assessed water-related risks during the development of the NI-43101 Feasibility Study for the Zgounder Silver Mine Expansion Project. The assessment covers the remaining life of mine. |
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Have you identified any inherent water-related risks with the potential to have a substantive financial or strategic impact on operations |
Yes, only within our direct operations |
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Provide details of identified risks in your direct operations with the potential to have a substantive financial or strategic impact on your business, and your response to those risks |
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Risk 1 |
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Type of risk |
Physical |
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Primary risk driver |
Physical - Seasonal supply variability/inter annual variability |
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Primary potential impact |
Reduction or disruption in production capacity |
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Risk timeframe |
1-3 years |
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Applicable to Life of Mine |
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Magnitude of potential impact |
High |
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Likelihood of potential impact |
Very likely |
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Potential impact financial figure and explanation |
Potential reduction in production capacity due to water shortage, estimated at a maximum reduction of 30% or USD 10.5M of revenue per annum. |
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Primary response |
Increase capital expenditure |
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Cost of response and description of response |
In 2021, Aya Gold & Silver's primary response to water scarcity was to increase CAPEX on water retention infrastructure in order to capitalize on the excess water in rainy seasons. The infrastructure was completed in 2022.
Cost of USD 1,001,477.20 to construct 60,000 m³ water retention basin upon completion in 2022. |
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Risk 2 |
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Type of risk |
Physical |
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Primary risk driver |
Physical - Acid rock drainage and metal leaching (metals & mining sector only) |
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Primary potential impact |
Loss of license to operate |
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Risk timeframe |
1-3 years |
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Applicable to Life of Mine |
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Magnitude of potential impact |
High |
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Likelihood of potential impact |
More likely than not |
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Potential impact financial figure and explanation |
Quantification of the potential impact was not completed in 2022. |
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Primary response |
Improve monitoring |
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Cost of response and description of response |
The Corporation's primary response was to implement third-party monitoring of water quality for 15 control points and management committee to discuss and review monitoring results and actions to be taken.
Cost of monitoring: USD 45,688 /year. |
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Risk 3 |
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Type of risk |
Physical |
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Primary risk driver |
Physical - Rupture of tailings dams and toxic spills (metals & mining sector only) |
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Primary potential impact |
Fines, penalties or enforcement orders |
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Risk timeframe |
1-3 years |
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Applicable to Life of Mine |
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Magnitude of potential impact |
High |
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Likelihood of potential impact |
Unlikely |
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Potential impact financial figure and explanation |
Quantification of the potential impact was not completed in 2022. |
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Primary response |
Increase capital expenditure |
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Cost of response and description of response |
In 2020 and 2021, the Corporation's primary response was to spend capital reinforcing tailing dams. Tailings dams were raised and reinforced, and storm water control infrastructure was built.
Tailing basin improvements totaled USD 439,988.00 in 2022 . |
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In 2021, a secondary response was to implement third-party quarterly audits on the two TSFs in operation at the Zgounder Silver Mine. |
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Opportunity Assessments |
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Have you identified any water-related opportunities with the potential to have a substantive financial or strategic impact on your business |
Yes, we have identified opportunities, and some or all are being realized |
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Opportunity 1 |
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Type of opportunity |
Efficiency: Improved water efficiency in operations |
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Opportunity timeframe |
1-3 years |
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Applicable to life of mine. |
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Magnitude of potential impact |
Low |
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Potential impact financial figure and explanation |
In 2022, the Corporation did not assess the potential impact financial figure.
Opportunities exist in improving water reuse and recycling throughout the water balance of the Zgounder Silver Mine, however the gains are negligible. |
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Responsibility |
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Provide the highest management-level position(s) or committee(s) with responsibility for water-related issues |
Chief Executive Officer (CEO) |
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Aya Gold & Silver's VP of Operations is responsible for assessing and managing water- related issues at the Zgounder Silver Mine. |
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Policy |
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Does your organization have a documented water policy |
Other, please specify |
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Aya Gold & Silver has an HSEC Policy that includes all environmental aspects and performance management.
Aya Gold & Silver HSEC Policy |
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Select the options that best describe the scope and content of your organizations' water policy |
• Description of water-related performance standards for direct operations • Reference to international standards and widely-recognized water initiatives • Commitment to align with public policy initiatives, such as the Sustainable Development Goals (SDGs) • Commitments beyond regulatory compliance |
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Reporting |
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Frequency of reporting to the board on water-related issues |
Quarterly |
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Incentives |
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Do you provide incentives to C-suite employees or board members for the management of water-related issues |
Yes |
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Aya Gold & Silver's VP of Operations has incentives for water-related performance at the Zgounder Silver Mine. |
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Strategy |
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Are water-related issues integrated into any aspects of your long-term strategic business plan |
Yes, water-related issues are integrated |
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If water-related issues are integrated into any aspects of your long-term strategic business plan, please describe further |
Aya Gold & Silver integrated water-related issues into the feasibility study for the Zgounder Silver Mine Expansion Project and its accompanying business plan that drives the operations for the life of mine. |
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The Zgounder Silver Mine Expansion Project has been designed to increase production capacity to 2,700 tonnes per day, which will mean freshwater requirements of about 400,000m³ per year. In line with Aya’s water efficiency strategy, the engineering team focused on finding opportunities and new sources of water for the mine expansion without impacting local resource levels. This will be achieved by harvesting excess runoff water in the rainy season and by improving water reuse and recyling. As described in Aya’s inaugural 2020 Sustainability Report, a first 60,000m³ basin was built in the 2021-2022 years. Since then, the basin has been used as a pilot project to assess how much water can be withdrawn from the catchment area, the impact on downstream users, and to refine the mine’s water model based on weather and climate change data.
Two additional water basins will be constructed in 2023 to support the Zgounder Mine expansion, which will boost water storage capacity to approximately 400,000 m³. Water storage, which is a mitigation measure identified through the Corporation’s climate risk assessment, aims to address the risk of both chronic weather change and acute extreme weather events. It will provide the expanded mine with up to a year of water autonomy, thus meeting even the most extreme scenario. In the fall of 2022, Aya launched a series of socio-economic household surveys to fully understand its interactions with host communities with water as a shared resource. Its objective was to better understand the potential impact of the Corporation’s strategy of harvesting excess runoff water and to mitigate any potential harm to downstream communities.
The expanded socio-economic baseline data offers an opportunity to significantly improve Zgounder communities’ quality of life. As a result, Aya will invest in several water infrastructure projects over the coming years that will be identified in partnership with local authorities and governments in Morocco. The improvement in water quality and availability is expected to boost community economic growth given that local livelihoods rely heavily on access to water. Water also represents a new platform on which to expand Aya’s collaboration with local stakeholders while building a strong relationship for integrative and participatory planning.
In 2022, Aya also invested in new technology to harvest drinkable water from ambient air humidity at the Zgounder base camp. 10 “hydropanels” were installed to provide approximately 30 litres per day of pure, drinking water. These panels are “a sustainable water technology that uses the power of the sun to extract an endless volume of clean, reliable drinking water from the air”. |
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If water-related issues are integrated into any aspects of your long-term strategic business plan, identify the associated long-term time horizon |
5-10 years |
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Governance structure and composition |
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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. |
Aya Gold & Silver's governance structure is described on the Corporation's website, on the page HSEC Governance as well as on the page Governance.
See the bellow answer for the details on the Board-level committees. |
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Aya Gold & Silver Board of Directors Committees
Aya's HSEC Governance |
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List the committees of the highest governance body that are responsible for decision making 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 |
Aya Gold & Silver's highest governance body, its Board of Directors, has four committees as follows: |
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Details: • Audit and Risk Management Committee of the Board - Oversees financial reporting, accounting systems, and risk management processes to ensure compliance with laws and regulations. Recommends independent auditors, reviews financial statements, and monitors Whistleblowing Policy. Reports to the Board on performance evaluation and compliance.
• Corporate Governance, Nomination and Compensation Committee of the Board - Oversees the corporation's governance policies and practices, proposes new Board nominees, assesses the effectiveness of the Board, and is responsible for senior management executives hiring, assessment, compensation, and succession planning. The committee also evaluates and recommends compensation programs and employment agreements for senior management and assesses the Corporation's compliance with its Code of Business Conduct and Ethics.
• ESG Committee of the Board - Oversees the Corporation's approach to safety, health, and environmental matters. Reviews policies and procedures, recommends improvements, and receives reports on compliance with legislation and monitoring systems. Mitigates material risks related to safety, health, and environmental matters and reports to the Board on such matters.
• Executive Committee - Centralizes the management and leadership of the company, providing strategic direction, overseeing operational performance and risk assessment, and assisting the Board of Directors in decision-making and guidance on strategic matters. One of its key responsibilities is to consider ESG risks, including but not limited to climate change, health and safety, and other relevant factors, to ensure the company operates sustainably and responsibly.
Corporate Governance |
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Delegation of responsibility for managing impacts |
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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 |
Aya Gold & Silver's CEO is responsible for all ESG and Climate Change issues and reports directly to the Board of Directors. |
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Describe whether the highest governance body has delegated responsibility for the management of impacts to other employees; |
The HSE and CR departments are overseen by the Corporation's HSEC Manager who reports to the VP of Operations and the CEO. |
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Consultation Process |
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Report the processes for consultations between stakeholders and the highest governance body on economic, environmental and social topics, e.g., for most mining companies it would be the executives and operations and not the Board, and if delegated, explain how |
The Board of Directors receives regular feedback from investors, financial institutions and rating agencies.
In addition, C-Suite executives provide quarterly reports and presentations on ESG topics communicated by stakeholders at the Zgounder Silver Mine. |
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Governance structure and composition |
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Describe the composition of the highest governance body and its committees by |
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Number of executive members |
1 |
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Number of non-executive members |
7 |
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Number of independent members |
5 |
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Less than 3 years of tenure of members on the governance body |
5 |
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3-6 years of tenure of members on the governance body |
1 |
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6-9 years of tenure of members on the governance body |
2 |
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More than 10 years of tenure of members on the governance body |
0 |
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Number of other significant positions and commitments held by each member, and the nature of the commitments |
Please refer to the link below for a biographical description of Aya Gold and Silver's Board of Directors and the significant positions and commitments they currently hold. |
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Below please find the list of significant positions and commitments of Aya Gold & Silver's individual Board members. 1) Benoit La Salle 2) Robert Taub 3) Marc Nolet de Brauwere 4) Yves Grou 5) Nikolaos Sofronis 6) Dr. Elena Clarici 7) Dr. Jürgen Hambrecht
Board of Directors Biographical Information
Aya Gold & Silver's AIF |
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Number of Male governance body members |
6 |
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Number of Female governance body members |
2 |
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Number of members from under-represented social groups |
0 |
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Description of competencies relating to economic, environmental, and social topics |
Aya Gold & Silver's Board members' competencies relating to economic, environmental, and social topics are described on the company website. |
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Please refer to the link below.
Aya Gold & Silver's Board of Directors |
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Description of stakeholder representation |
Aya Gold & Silver takes a proactive approach to stakeholder engagement and feedback to incorporate into its management practices.
Feedback is received from investors, shareholders, financial institutions as well as employees, Canadian and Moroccan authorities, and village representatives. |
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Chair of the highest governance body |
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Is the chair of the highest governance body is also a senior executive in the organization |
Yes |
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If the chair is also a senior executive, explain their function within the organization’s management, the reasons for this arrangement, and how conflicts of interest are prevented and mitigated |
Benoit La Salle is President & Chief Executive Officer of Aya Gold & Silver. |
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Conflicts of Interest |
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Describe the processes for the highest governance body to ensure that conflicts of interest are prevented and mitigated |
Conflicts, if any, are subject to the procedures and remedies under the Canada Business Corporations Act. No conflicts of interest currently exist between the Corporation or its subsidiaries and a director or officer of the Corporation or its subsidiaries.
Unresolved potential conflicts involving employees, senior management or Directors are referred to the Board of Director's Nominating and Corporate Governance Committees. |
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Aya Gold & Silver Code of Ethics and Business Conduct |
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Report whether conflicts of interest are disclosed to stakeholders, including, as a minimum, conflicts of interest relating to |
Yes |
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To incentivize disclosure, a quarterly questionnaire is sent out to all members of the Board, as well as senior management, and collected by the corporate secretary regarding any conflicts in the course of the quarter. |
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Cross-board membership |
Yes |
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Cross-shareholding with suppliers and other stakeholders |
Yes |
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Existence of controlling shareholder |
Yes |
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Related parties, their relationships, transactions, and outstanding balances |
Yes |
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Collective knowledge of highest governance body |
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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, Aya Gold & Silver did not provide training on ESG topics for the Board of Directors. |
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Evaluation of Highest Governance Body |
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Describe actions taken in response to the evaluations, including changes to the composition of the highest governance body and organizational practices |
In 2022, Aya Gold & Silver conducted an internal evaluation of ESG issues and developed key ESG performance indicators that are tracked by the organization. |
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Transparency |
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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 |
Aya Gold & Silver's corporate governance policies and values are approved by the Board of Directors. |
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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 ESG Committee of the Aya Board provides oversight of health, safety, environment, community, tailings, human rights, climate change, GHG emissions and water-related issues and risks, all of which align with our broader sustainability strategy. On behalf of the Board, this committee reviews quarterly updates on all ESG and climate-related issues, risks, targets and strategy; approves annual targets, reviews global sustainability strategy progress and outcomes, reduction pathways and scenarios as well as investor inquiries related to climate and SASB/TCFD climate approaches. |
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Safety, Health and Environment Committee |
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Describe whether and how the highest governance body engages with stakeholders to support these processes |
Aya Gold & Silver board-level ESG committee receives updates from the CEO and the HSEC Manager on a quarterly basis, include reports from stakeholder engagement. |
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The Board of Directors continuously receive feedback from investors, financial institutions and rating agencies. In addition, C-Suite executives provide quarterly reports and presentations on ESG issues communicated by stakeholders, and reported by site department heads at the Zgounder Silver Mine. |
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Describe how the highest governance body considers the outcomes of these processes |
The CEO present the Corporation's Action Plans and response to mitigate risks to the Board-level ESG Committee. |
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Ethics |
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Describe the management system and due diligence procedures for assessing and managing corruption and bribery risks internally and associated with business partners in its value chain |
Issues such as corruption and bribery are addressed in Aya Gold & Silver's International Business Conduct Policy. Please refer to the link below. |
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Aya Gold & Silver International Business Conduct Policy |
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Aya Gold and Silver’Aya Gold & Silver's International Business Conduct Policy |
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Report net production from activities located in the countries with the 20 lowest rankings in Transparency International’s Corruption Perception Index (CPI) (Saleable tonne) |
0 |
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Anti-Corruption |
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Communication and Training |
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i. Total number of governance body members that the organization´s anti-corruption policies and procedures have been communicated to |
7 |
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ii. Total percentage of governance body members that have been communicated to on anti-corruption |
100.0000% |
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Total number and percentage of employees that have been communicated to on anti-corruption |
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1a. Total number of employees that have been communicated to on anti-corruption |
55 |
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Our anti-corruption policy has been disseminated among our employees, alongside our other established policies. We have received attestations from our employees, indicating their acknowledgement and commitment to adhere to these policies. Furthermore, we diligently notify all employees during blackout periods, during which trading of securities is strictly prohibited. |
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1b. Total percentage of employees that have been communicated to on anti-corruption |
7.5967% |
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2a. Total number of senior employees that have been communicated to on anti-corruption |
55 |
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2b. Percentage of senior employees that have been communicated to on anti-corruption |
122.2222% |
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3a. Total number of middle management employees that have been communicated to on anti-corruption |
0 |
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3b. Percentage of middle management employees that have been communicated to on anti-corruption |
0.0000% |
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4a. Total number of technical employees that have been communicated to on anti-corruption |
0 |
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4b. Percentage of technical employees that have been communicated to on anti-corruption |
0.0000% |
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5a. Total number of production employees that have been communicated to on anti-corruption |
0 |
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5b. Percentage of production employees that have been communicated to on anti-corruption |
0.0000% |
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6a. Total number of administrative employees that have been communicated to on anti-corruption |
33 |
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6b. Percentage of administrative employees that have been communicated to on anti-corruption |
49.2537% |
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i. Total number and percentage of business partners that the organization's anti-corruption policies and procedures have been communicated to |
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ii. Total percentage of suppliers that the organization´s anti-corruption policies and procedures have been communicated to |
2.0619% |
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Total number of suppliers that that the organization´s anti-corruption policies and procedures have been communicated to |
8 |
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ii. Total percentage of agents that the organization´s anti-corruption policies and procedures have been communicated to |
Does Not Apply |
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Total number of agents that that the organization´s anti-corruption policies and procedures have been communicated to |
0 |
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ii. Total percentage of lobbyists and other intermediaries that the organization´s anti-corruption policies and procedures have been communicated to |
Does Not Apply |
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Total number of lobbyists and other intermediaries that that the organization´s anti-corruption policies and procedures have been communicated to |
0 |
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ii. Total percentage of joint-venture and consortia partners that the organization´s anti-corruption policies and procedures have been communicated to |
Does Not Apply |
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Total number of joint-venture and consortia partners that that the organization´s anti-corruption policies and procedures have been communicated to |
0 |
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ii. Total percentage of government partners that the organization´s anti-corruption policies and procedures have been communicated to |
Does Not Apply |
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Total number of government partners that that the organization´s anti-corruption policies and procedures have been communicated to |
0 |
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ii. Total percentage of customer/client partners that the organization´s anti-corruption policies and procedures have been communicated to |
Does Not Apply |
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Total number of customer/client partners that that the organization´s anti-corruption policies and procedures have been communicated to |
0 |
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Have the anti-corruption policies and procedures been communicated to any other persons or organizations |
No |
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i) Total number of governance body members that have received training on anti-corruption, broken down by region |
7 |
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Security Practices |
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Policy and Procedure Training |
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Report the percentage of security personnel who have received formal training in the organization’s human rights policies or specific procedures and their application to security |
0.0000% |
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Aya Gold & Silver's security personnel at the Zgounder Silver mine do not carry person- restraining equipment. Their functions are limited to conducting vehicle checks, metal checks at entrances and exits, and registering visitors. In case of situations requiring further action, security personnel are instructed to follow the company's chain of command structure and immediately advise the site Director of Operations and, if required, local authorities. |
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Delegation of responsibility for managing impacts |
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Describe the process and frequency 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. |
At the Zgounder Silver Mine, ESG topics are identified and managed on site by the HSE and CR departments. |
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Information on potential ESG risks, and opportunities are reported quarterly to the ESG Committee at the board-level.
All Aya Gold & Silver employees are assigned HSE key performance indicators as part of their performance evaluations. |
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Highest Governance Body |
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Describe the nomination and selection processes for the highest governance body and its committees |
The CEO and Chairman of Aya Gold & Silver seek qualified candidates who wish to be considered for nomination as directors. Proposed nominations are subject to review and approval by the Board. |
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Any new appointees or nominees to the Board must have a favourable track record in general business management, special expertise in areas of strategic interest to the Corporation, and the ability to devote the time required. |
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Discuss whether and how: Views of the stakeholders (including shareholders) are involved |
Aya Gold & Silver's shareholders participate in the election of Board of Directors. |
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Discuss whether and how: Diversity is considered |
While Aya Gold & Silver adheres to its equal opportunity statement, no formal mechanisms have been put into place for diversity considerations at the Board level. |
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Please see the Code of Ethics and Business Conduct Policy below.
Code of Ethics and Business Conduct Policy |
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Discuss whether and how: Independence is considered |
In accordance with the Canadian regulatory National Instruments (NI) and the TSX corporate manual, the majority of Aya Gold & Silver's Board of Directors are independent. |
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TSX Issuer Resources : Corporate Governance |
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Discuss whether and how: Competencies relevant to the impacts of the organization are considered |
Nominations for Board membership are made by the Board's Nominating and Corporate Governance Committee which screens potential candidates based on their expertise and experience in economic, environmental and social topics. |
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Evaluation of Highest Governance Body |
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Describe the processes for evaluating the performance of the highest governance body in overseeing the management of the organization’s impacts on the economy, environment, and people |
In 2022, Aya Gold & Silver did not evaluate the performance of the highest governance body in overseeing the management of the organization's impacts on the economy, environment, and people. |
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Report whether such evaluation is independent or not, and its frequency |
Not Applicable |
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Risk Management |
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Describe the role of the highest governance body in reviewing the effectiveness of the organization’s processes to manage and identify impacts on economy, environment, and people, and report the frequency of this review |
The ESG Committee of the Aya Board provides oversight of health, safety, environment, community, tailings, human rights, climate change, GHG emissions and water-related issues and risks, all of which align with our broader sustainability strategy. On behalf of the Board, this committee reviews quarterly updates on all ESG and climate-related issues, risks, targets and strategy; approves annual targets, reviews global sustainability strategy progress and outcomes, reduction pathways and scenarios as well as investor inquiries related to climate and SASB/TCFD climate approaches. |
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Highest Review Position |
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Report whether the highest governance body is responsible for reviewing and approving the reported information, including the organization’s material topics, and if so, describe the process for reviewing and approving the information |
The highest governance body is responsible for reviewing and approving the reported information, including the organization’s material topics. |
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Aya Gold & Silver's CEO, with the assistance of the Corporation's HSEC Manager, presents the yearly ESG report, including the Corporation's material topics, for approval before publication. |
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Communication of critical concerns |
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Describe whether and how critical concerns are communicated to the highest governance body |
ESG issues are reported to the ESG Committee on a quarterly basis and advice is sought from the Board on improving the organization's effectiveness in managing ESG issues. |
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Report the number of critical concerns that were communicated to the highest governance body during the reporting period |
0 |
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Report the nature of critical concerns that were communicated to the highest governance body during the reporting period |
N/A |
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Remuneration |
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Report which of the following remuneration policies apply to the highest governance body and senior executives: |
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Fixed pay |
Yes |
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Variable pay |
Yes |
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Performance-based pay |
Yes |
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Equity-based pay |
Yes |
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Bonuses |
Yes |
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Deferred and vested shares |
Yes |
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Sign-on bonuses |
Yes |
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Recruitment incentive payments |
Yes |
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Termination payments |
Yes |
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Clawbacks |
Yes |
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Retirement benefits, including the difference between benefit schemes and contribution rates for the highest governance body, senior executives, and all other employees |
Yes |
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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 |
In 2022, Aya Gold & Silver included Environmental, Social and Governance topics, including Climate Change, to the objectives and performance in relation to the management of the organization’s impacts on the economy, environment, and people. ESG-C KPIs represent 20% of the total bonus. |
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Describe the process for designing its remuneration policies and for determining remuneration |
In 2022, Aya Gold & Silver implemented a compensation program for directors and executive management incorporating fixed pay and variable pay compensation policies. |
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The new management team has subsequently worked tirelessly to attract top-tier talent and has hired over a dozen executives from the mining industry. In this transition year, given the significant number of hires, the company engaged an external compensation consultant to help establish a normalized competitive benchmark for compensation across the Corporation, namely for top executives and management. |
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Are independent members of the highest governance body or an independent remuneration committee overseeing the remuneration process |
Yes |
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How the views of stakeholders (including shareholders) regarding remuneration are sought and taken into consideration |
Remuneration packages for directors, C-Suite and Senior Managers at Aya Gold & Silver are approved by shareholders at Annual General Meetings. |
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Describe whether remuneration consultants are involved in determining remuneration and, if so, whether they are independent of the organization, its highest governance body and senior executives |
Independent Consultants |
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Remuneration consultants utilized by Aya Silver & Gold have no other business relationships with the Corporation. |
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Compensation |
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Report the ratio of the annual total compensation for the organization’s highest-paid individual to the median annual total compensation for all employees(excluding the highest-paid individual) |
37.188 |
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For the purpose of this report, the ratio calculated includes the Zgounder Silver Mine in the Kingdom of Morocco. |
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Annual total compensation of the highest-paid individual |
364,817 |
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Median annual total compensation for all of the organization's employees excluding the highest-paid individual |
9,810 |
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Report contextual information necessary to understand the data and how the data has been compiled |
This data has been compiled for Aya Gold & Silver Maroc S.A.
Median annual total compensation for all the organization's employees was based on full- time equivalent pay rates, as in 2022 there were no part-time employees for Aya's operations in Morocco.
The highest-paid individual is the PDG of ZMSM.
This total Compensation include salary and bonus |
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List types of compensation included in the calculation |
Other, please specify |
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Specify whether full-time and part-time employees are included in the calculation |
Yes |
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Specify whether full-time equivalent pay rates are used for each part-time employee in this calculation |
No |
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Title of the highest-paid individual |
General Manager-President of Aya Gold & Silver Morocco S.A. |
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Report the ratio of the percentage increase in annual total compensation for the organization’s highest-paid individual to the median percentage increase in annual total compensation for all employees (excluding the highest-paid individual) |
2.639 |
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Percentage increase in annual total compensation for the organization’s highest-paid individual |
30.3858% |
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Compensation of the above identified individual’s in the current reporting period ($ Millions) |
0.365 |
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Annual salary in USD |
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Percentage increase of the median annual total compensation from the last to current reporting period (excluding the highest-paid individual) |
11.5153% |
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Median annual total compensation in the current reporting period except the above identified highest-paid individual ($ Millions) |
0.981 |
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Stakeholder Engagement |
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Provide a list of stakeholder groups engaged by the organization |
Aya Gold & Silver continuously engages with the following stakeholders: |
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1. Canadian and host country authorities at the national and local levels; 2. Canadian and host country administrative and regulating bodies (Ministry of health, education, etcetera); 3. International and local civil society organizations (NGO's, associations and co-ops); 4. Investors and shareholders, TSX authorities and financial institutions; 5. Employees; and, 6. Supply chain buyers and service providers |
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Report the basis for identifying and selecting stakeholders with whom to engage |
Aya Gold & Silver undertakes stakeholder mapping exercises to determine the level of interest and influence of national and local stakeholders in its operating asset in the Kingdom of Morocco.
The Corporation implemented a Stakeholder Engagement Plan in 2022 based on best practice and guidance from the International Finance Corporation (IFC). |
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Report the purpose of the stakeholder engagement |
Stakeholder engagement is essential for Aya Gold & Silver to ensure that its activities are carried out in a socially and environmentally responsible manner, to maintain a social license to operate, and to attract responsible investment and talent. |
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Report the organization’s approach to stakeholder engagement, including frequency of engagement by type |
Aya Gold & Silver's stakeholder engagement is based on the interest and influence of stakeholders resulting in the following:
1. Continuous engagement is maintained with host country authorities, and regulating bodies; 2. Stakeholder Engagement Plan and Project- specific engagement with administrative bodies and civil society to implement CSR initiatives; 3. Civil society organizations are also engaged to obtain feedback on needs, interests and expectations of stakeholders on their relationship to the Zgounder Mine; and 4. Environmental and Social Impact Assessment (ESIA) for the Zgounder Silver Mine Expansion Project engagement process and its public consultation. |
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Anti-Corruption |
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Corruption Risks to Operations |
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i. Total number of operations assessed for corruption risks |
1 |
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iii. Percentage of operations assessed for corruption risks |
100.0000% |
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Report any significant corruption risks identified |
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Risk 1 |
In 2022, Aya Gold & Silver did not identify any significant corruption risks to its operations at the Zgounder Silver Mine. |
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Confirmed Incidents and Response |
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Total number and nature of confirmed incidents of corruption |
0 |
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i) Total number of Bribery cases |
0 |
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ii) Total number of Lobbying cases |
0 |
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iii) Total number of Extortion cases |
0 |
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iv) Total number of Cronyism cases |
0 |
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v) Total number of Nepotism cases |
0 |
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vi) Total number of Parochialism cases |
0 |
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vii) Total number of Patronage cases |
0 |
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viii) Total number of Influence peddling cases |
0 |
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ix) Total number of Graft cases |
0 |
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x) Total number of Embezzlement cases |
0 |
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Total number of confirmed incidents in which employees were dismissed or disciplined for corruption |
0 |
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Total number of contracts terminated or not renewed with business partners due to corruption related violations |
0 |
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Public legal cases brought against the organization or its employees during the reporting period related to corrupton and the outcomes of such cases |
0 |
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Anti-Competitive Behaviour |
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Legal Actions |
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Total number of legal actions pending or completed during the reporting period regarding anti-competitive behaviour and violations of anti-trust and monopoly legislation in which the organization has been identified as a participant: |
0 |
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Number of legal actions pending during the reporting period regarding anti-competitive behaviour |
0 |
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Number of legal actions completed during the reporting period regarding anti-trust behaviour |
0 |
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Tax |
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Provide a description of the approach to tax, including: |
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i. Does the organization have a tax strategy |
No |
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ii. The frequency of formal review and approval of the tax strategy by the governance body or executive-level position within the organization |
Not Applicable |
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iii. The approach to regulatory compliance |
In addition to its publicly-mandated corporate audits, Aya Gold & Silver employs local legal counsel and tax advisor services to ensure the Corporation meets its commitment to full compliance and transparency with regard to tax obligations. |
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iv. How the approach to tax is linked to the business and sustainable development strategies of the organization |
Aya Gold & Silver is committed to full compliance and transparency with regard to the Corporation's tax obligations in every jurisdiction in which it operates. |
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Provide a description of the tax governance and control framework, including: |
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i. The governance body or executive-level position within the organization accountable for compliance with the tax strategy |
Since there is no tax strategy in place, there is no single individual responsible for tax planning. Tax planning is done in concordance with the corporation's external auditors - KPMG.
Tax implications are reviewed by the Corporation's CFO and Corporate Controller as situations arise. |
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ii. How the approach to tax is embedded within the organization |
N/A |
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iii. The approach to tax risks, including how risks are identified, managed, and monitored |
As part of its risk management strategy, Aya Gold & Silver has developed a series of "red fIags" to identify potential business misconduct. Among these red flags is the identification of any payment requested to a bank in a “tax haven” jurisdiction (e.g. the Cayman Islands) or in a country identified by the FATF (Financial Action Task Force on Money Laundering) as a “Non- Cooperative Country or Territory” for no apparent reason. In addition to the above, the entity is listed on Toronto stock exchange as such it is subject to national Instrument 52-109, certification of (ICFR and DCFR), internal controls for financial reporting and disclosures of controls for financial reporting. The entity maintains a risk matrix for the tax process, The key mitigating controls for financial risks have been identified, the design of such controls have been evaluated and operating effectiveness of those controls are tested regularly. |
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Aya Gold and Silver International Business Conduct Policy |
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iv. How compliance with the tax governance and control framework is evaluated |
Compliance with tax governance is partially attained through the Corporation's external auditors and the CEO CFO certification process. In addition, the Moroccan entities have strict procedures in place in terms of the accuracy and timeliness of tax filings for sales tax, withholding tax, and corporate tax. |
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Provide a description of the mechanisms for reporting concerns about unethical or unlawful behaviour and the organization’s integrity in relation to tax |
The Audit Committee Chairman is responsible for the receipt, retention and investigation of complaints or concerns received regarding, but not limited to, fraud, misconduct, management override, accounting, internal controls, auditing matters and corporate governance issues whether received through the whistle-blower mechanism or other means. |
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Aya Gold & Silver Whistleblower Policy and Procedure
Aya Gold & Silver International Business Conduct Policy |
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Describe the approach to stakeholder engagement and management of stakeholder concerns related to tax, including: |
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i. The approach to engagement with tax authorities |
Aya Gold & Silver does not directly or (indirectly) engage with tax authorities in any of the jurisdictions in which it operates.
"Indirect engagement" includes not adhering to public policy recommendations on tax from industry groups. |
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ii. The approach to public policy advocacy on tax |
Aya Gold & Silver does not advocate on tax issues in any of the jurisdictions in which the Corporation operates. |
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iii. The processes for collecting and considering the views and concerns of stakeholders, including external stakeholders |
Aya Gold & Silver receives timely information on tax-related issues from external counsel to meet its tax obligations. |
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Country-by-Country Reporting |
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Report all tax jurisdictions where the entities included are resident for tax purposes, in the organization’s audited consolidated financial statements, or in the financial information filed on public record |
Kingdom of Morocco Mauritania Canada Barbados Cayman Islands |
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For each tax jurisdiction reported in Disclosure (GRI 207-4-a), report the: |
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i. Names of the resident entities |
Aya Gold & Silver operates in the following jurisdictions and has the following resident entities: |
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Aya Gold & Silver operates in the Kingdom of Morocco under the following entities: • Aya Gold & Silver Morocco S.A. (“AGSM”) • Zgounder Millenium Silver Mining S.A. (ZMSM) • Atlas Gold & Silver S.A.R.L (AGS) • Boumadine Gold Mining S.A. (BGM)
Aya Gold & Silver operates in Mauritania under the following entities: • Algold Mauritania SARL • Société Tijirit Recherche et Exploration SARL (“TIREX”)
Aya Gold & Silver operates in Canada under the following entities: • Aya Gold & Silver Inc. • Algold Resources Ltd. (“Algold”)
Aya Gold & Silver operates in Barbados under the following entities: • Kanosask (Barbados) Limited (“KANOSAK”)
Aya Gold & Silver operates in Cayman Islands under the following entities: • Precious Metal Finance and Services Inc. (“PMFS”) |
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ii. Primary activities of the organization |
The entities referenced above primarily focus on mining exploration and operation. |
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iii. Number of employees, and the basis of calculation of this number |
370 |
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This is the number of Aya Gold & Silver's employees in Morocco, Canada and Mauritania. |
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iv. Revenues from third-party sales |
38,244,921 |
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v. Revenues from intra-group transactions with other tax jurisdictions |
0 |
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vi. Profit/loss before tax |
4,580,280 |
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vii. Tangible assets other than cash and cash equivalents |
63,691,894 |
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viii. Corporate income tax paid on a cash basis |
2,773,663 |
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ix. Corporate income tax accrued on profit/loss |
3,182,692 |
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x. Reasons for the difference between corporate income tax accrued on profit/loss and the tax due if the statutory tax rate is applied to profit/loss before tax |
Corporate tax paid represents the taxes paid in Morocco for operations that generate revenue. However, permanent and temporary differences arise from the recognition of deferred tax assets and liabilities. |
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Report the time period covered by the information reported in Disclosure (GRI 207-4-a) |
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From |
2022-01-01 |
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To |
2022-12-31 |
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Public Policy |
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Political Contributions |
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Total monetary value of financial and in-kind political contributions made directly and indirectly by the organization by country and recipient/beneficiary |
0 |
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Country 1 |
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Total direct financial contribution |
0 |
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In 2022, Aya Gold & Silver did not make any direct or indirect financial or in-kind political contributions. |
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Total indirect financial contribution |
0 |
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Total direct in-kind contribution |
0 |
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Total indirect in-kind contribution |
0 |
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This document was prepared using |
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, Planet Earth's complete ESG reporting solution. |
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