Prime Mining Corp.

2022 ESG Report

Published on April 17, 2023

Prime Mining Corp., is managed by an ideal mix of successful mining executives, strong capital markets personnel and experienced local operators, focused on unlocking the full potential of the high-grade Los Reyes Gold-Silver project in Sinaloa, Mexico.

Prime Mining Corp. works to advance the Los Reyes Gold and Silver Project (“Los Reyes”), the Company’s focus is on three areas:

i) use of resources to create maximum value of Los Reyes;

ii) health and safety of team and the communities where we work;

iii) corporate responsibility and governance.

Disclaimer and Forward Looking Statements

Company Profile

Organizational Profile

Name

Prime Mining Corp.

Describe nature of activities, brands, products and services

Prime Mining Corp. works to advance the Los
Reyes Gold and Silver Project (“Los Reyes”), the
Company’s focus is on three areas:

i) use of resources to create maximum value at
Los Reyes;

ii) health and safety of our team and the
communities we work in;

iii) corporate responsibility and governance.

Link to Corporate Website

https://primeminingcorp.ca/

Industry Classification

NAICS:
212220 Gold and silver ore mining

ISIC:
B0729 Mining of other non-ferrous metal ores

Market Capitalization

$100 Million up to $1 Billion USD

Type of Operations

Exclusively non-producing operations

Company Headquarters

Vancouver, Canada

ESG Accountability

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

Daniel Kunz, CEO

ESG Reporting Period

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

From

2022-01-01

2022-12-31

Audit Status

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

Self-Declared

Financial Reporting Period

Specify the frequency of sustainability reporting

Annually

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

Yes

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

info@primeminingcorp.ca

Geographic Scope of Report

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

Mexico

This report covers our operation in Sinaloa,
Mexico.

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.)

This report does not exclude any assets held by
Prime Mining.

Fragile and Conflict-Affected Situations

Identify all of the entity's countries of operations that align with the World Bank's list of "Fragile and Conflict-Affected Situations"

None

Business Operations Scope of Report

This report does not exclude any business
operations in which Prime Mining participates.

Mineral Resource Types in Scope

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

• Inferred
• Indicated
• Measured

Resource Description

Mineral Reserve Types in Scope

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

None

Currency

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

CAD

Organizational Profile

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

Prime Mining Corp is aligned with the
principles of the International Council on
Metals and Mining Principles (including
UNSDGs) and United Nations Guiding
Principles on Business and Human Rights.

Strategy

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

Prime is an early stage exploration company
with limited community and environmental
impacts and risks. Prime is committed to
working with its local communities, including
the state-sanctioned Ejido group in the Area of
Influence, with whom it has a positive and long-
standing relationship. In terms of opportunity,
the company provides training and
employment in mineral exploration, sampling,
mapping, core logging, spectral scanning,
drilling, accounting and community relations
fields. ESG risks are described in greater detail
in the body of this report.

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)

Refer to attachment. Message from the CEO on
Sustainability.

Message from the CEO on Sustainability

Policy commitments

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

At Prime, we hold ourselves to a high standard
of integrity and professional conduct. This
means not only ensuring compliance with the
laws and regulations, but also upholding our
values, Code of Conduct and voluntary
commitments under the United Nations
Guiding Principles on Business and Human
Rights and the International Council for Mining
and Metals Principles.

Please refer to Prime's:
- Audit Committee Charter
- Code of Conduct and Ethics
- Health, Safety, Environment and Social
Responsibility Committee Charter
- Nominating and Corporate Governance
Committee Charter
- Compensation and Human Resources Charter
- Anti-Bribery and Anti-Corruption Policy
Disclosure Policy
- Confidentiality and Securities Trading Policy
- Human Rights and Diversity Policy
- Whistleblower Policy

Corporate Governance Section on Website

Code of Business Conduct and Ethics

What are (if any) the authoritative intergovernmental instruments that the commitments reference

The United Nations Guiding Principles on
Business and Human Rights and the
International Council for Mining and Metals
Principles.

Do the commitments stipulate conducting due diligence

The UNGPs guide companies to conduct
Human Rights Due Diligence. At this early
stage, there are no discernable human rights
impacts from Prime's limited drilling program.
Prime Mining has conducted a baseline study to
understand the social and environmental
characteristics of its concession area. As the
company develops and moves toward
feasibility, it plans to conduct human rights due
diligence and monitor human rights impacts, as
appropriate, in alignment with international
human rights standards and best practices.

Do the commitments stipulate applying the Precautionary Principle or Approach

Yes

Do the commitments stipulate respecting human rights

Yes

Describe the specific policy commitment to respect human rights

All Prime Mining Corp. board members,
officers, employees, contractors or any third
party conducting work or acting on Prime
Mining Corp.’s behalf will behave in a manner
that respects human rights and avoids
infringing upon them. The Corporation will take
appropriate measures to ensure that this policy
is respected. For employees, non-compliance
with this policy may be grounds for disciplinary
action up to and including termination of
employment. For contractors, non-compliance
may be grounds for contract termination. The
Board of Directors is responsible
for overseeing this policy.

What are (if any) the internationally recognized human rights that the commitment covers

Human Rights espoused in the UN Declaration
on Human Rights on which the UNGPs are
based.

What are the categories of stakeholders, including at-risk or vulnerable groups, that the organization gives particular attention to in the commitment

Community members living in the area of
influence include the state-registered
Ejido. There are no at-risk groups per se but
some community members have season-
constrained access to clean water and limited
medical care and educational
opportunity. There are no self-identified
indigenous peoples in the concession Area of
Influence.

Provide links to the policy commitments, if publicly available, or, if the policy commitments are not publicly available, explain the reason for this

The links to the following policy commitments
are listed below

▪ Code of Business Conduct and Ethics
▪ Whistleblower Policy
▪ Anti-Bribery & Anti-Corruption Policy
▪ Human Rights & Diversity Policy
▪ Corporate Governance Policy
▪ Disclosure Policy
▪ Policy on Confidentiality and Securities
Trading

Code of Business Conduct and Ethics

Whistleblower Policy

Anti-Bribery & Anti-Corruption Policy

Human Rights & Diversity Policy

Corporate Governance Policy

Disclosure Policy

Policy on Confidentiality and Securities Trading

Report the level at which each policy commitment was approved within the organization, including whether this is the most senior level

Board of Directors and CEO who sits on the
Board of Directors. This is the company's most
senior level.

To what extent the policy commitments apply to the organization’s activities and to its business relationships

Prime Mining Corp. is committed to taking
actions to maintain a human rights culture and
best governance practices in our
Corporation. We ensure employees and
contractors are made aware of our policies and
understand their responsibility to comply.

Describe how the policy commitments are communicated to workers, business partners, and other relevant parties

These measures include
awareness-raising and training on the policy
and specific aspects within it, such as how to
report concerns related to human rights or
governance via company Whistleblower or
grievance mechanisms. Communication
channels include our website, on-site trainings,
annual policy review and commitment sign-off.

Embedding policy commitments

Describe how the organization embeds each of its policy commitments for responsible business conduct throughout its activities and business relationships

Measures to embed policy commitments
include awareness-raising and training on the
policies and specific aspects within it, such as
how to report concerns related to safety,
human rights or governance via company
Whistleblower or grievance mechanisms, the
latter of which the company is in process of
developing. Communication channels include
our website, on-site trainings, company-wide
emails, messages from managerial leadership
and annual policy review and commitment sign-
off.

How are responsibilities allocated in order to implement the commitments across different levels within the organization

Prime mining is a small company but in 2022, in
addition to the overall responsibilities of our
Country Manager, it established a position
responsible for in-country ESG. This role
reports to executive management who reports
to the Board.

How are the commitments integrated into organizational strategies, operational policies, and operational procedures

Policies are integrated into strategy including
how the company approaches governance and
risk.

How does the organization implement its commitments with and through its business relationships

Prime requires key contractors to understand
and comply with its Code of Business Ethics and
Human Rights Policy.

What implementation training does the organization provide

The Company provided anti-corruption
training, human rights and good governance
trainings in Mexico (for employees and key
contractors) and Insider Trading trainings in
the corporate headquarters in Canada. Live
training is required annually. The Board
received ESG training in 2022.

Supply Chain

Estimated Total number of Business Entities in its downstream

Prime Mining Corp., is an exploration company.
As such, it does not have downstream
customers.

Material Topics

Governance of Material Topics

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

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

Other external sources, please list

The Company hired a third-party
environmental consultant to assess baseline
environmental, biodiversity, socio-economic,
education , health, water access and other
community-related factors to better
understand the area in which the exploration
activity is occurring. We use that data to help
support the community and mitigate any
negative impacts of our operations.

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

The Company conducted a materiality
assessment across management, the Board and
key stakeholders to identify material priorities
and operational impacts in 2022.

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

• Business partners
• Employees and other workers
• Shareholders and other capital providers
• Other, please specify

"Other" includes the Board of Directors and
senior managment.

List the organization's material topics

• Energy
• Water
• Overall environmental
• Occupational Health and Safety
• Local Communities
• Anti-corruption
• Permitting

List the organization's non-material topics

• Biodiversity
• Compliance
• Employment
• Training and Education

Provide reason for considering such topics not material, provide details

Other, please specify

Prime is an early stage exploration company
with limited economic and operational
activities in the community.

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

This is Prime Mining's ESG inaugural report,
and as such, there are no changes to the list of
material topics to report in 2022.

Environment

General Disclosure

Compliance with laws and regulations

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

Number of instances for which fines were incurred

Number of instances for which non-monetary sanctions were incurred

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

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

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

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

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

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

Describe the significant instances of non-compliance

Not applicable. Prime is in compliance with
environmental laws and/or regulations in
Canada and Mexico.

Greenhouse Gas Emissions

Scope 1

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

Carbon dioxide (CO₂) (tonne CO₂-e)

1,040.468

Methane (CH₄) (tonne CO₂-e)

2.000

Nitrous oxide (N₂O) (tonne CO₂-e)

2.980

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

0.000

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

0.000

Sulphur hexafluoride (SF₆) (tonne CO₂-e)

0.000

Nitrogen trifluoride (NF₃) (tonne CO₂-e)

0.000

Perfluoromethane (CF₄) (tonne CO₂-e)

0.000

Perfluoroethane (C₂F₆) (tonne CO₂-e)

0.000

Perfluorobutane (C₄F₁₀) (tonne CO₂-e)

0.000

Perfluorohexane (C₆F₁₄) (tonne CO₂-e)

0.000

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

1,045.448

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%

Mexican regulation on Climate Change matter,
specifies that the sectors that directly or
indirectly emit greenhouse gases or
compounds, incluiding mining, must report
their emissions, as long as they exceed 25,000
tons of CO2e per year. The company generates
a much lower volume than indicated by
Mexican law, for which it is not obligated to
report or surpass emissions estipulated by law.

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

Prime is an exploration company, as such,
emissions are restricted to light vehicles and
portable drill rigs. As a result, emissions are
kept to a minimum and the Company's carbon
footprint is quite small.

Prior to the transition to a development stage
company, Prime will evaluate a long-term
strategy to minimize or neutralize emissions
when the Los Reyes Project enters
development and is operational.

Air Emissions

Report emissions of air pollutants that are released into the atmosphere

Emissions of carbon monoxide, reported as CO (tonne)

0.999

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

0.467

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

0.000

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

0.012

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

0.000

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

0.000

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

0.045

Energy Management

Total energy consumed in aggregate, in gigajoules (GJ) (hydrocarbons and electricity) including the fuel types used (e.g., biomass, hydro-electric power or bioenergy)

146.600

Percentage energy consumed that was supplied by grid electricity

100.0000%

Percentage of energy consumed that is renewable energy

0.0000%

Water

Efficiency

Proportion of water reused and recycled by the site to reduce the overall consumptive water demand

0.0000%

Water Management

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

49.832

The activities carried out by the Company that
withdraw water relate to diamond drilling,
preformed by third-party contractors. The main
source of fresh water in the area are the old
mining works where water gushes out and
feeds the streams, and is extracted with the
authorization of the ejidatarios. During drilling,
this water is injected into the drill holes
together with other biodegradable additives
that do not alter its composition or quality,
returning exactly the same volume extracted to
the natural environment.

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

100.0000%

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

49.832

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

Does Not Apply

Water availability is controlled by natural
seasons with heavy rains followed by
exceptionally dry weeks on opposite ends of
the calendar. In general, water is readily
available with proper managment incluiding
wells and ponds.

As part of the commitment to the community
and the environment, in 2022 water quality
monitoring was carried out in freshwater
sources. A third-party contractor certified by
Mexican environmental authorities, is hired to
perform two samplings in 14 locations
distributed within the perimeter of the project,
before the rainy season (June) and after the
wet season (November). In general, the results
show good water quality, with compliant
results within the official Mexican standards,
minimal differences in the water of the streams
are detected between seasons, due to the
movement and volume of water that is
transported during the wet season.

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

0.000

Operations include the amount of water used
during drilling. During 2022, 47.996 thousands
of cubic meters were used for drilling, the same
volume was reinjected into natural reservoirs
during drilling.

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

0.000

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

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

Waste Management

Disclose the total weight of tailings produced (tonne)

0.000

Not applicable to the Company at this time.

Tailings Storage Facilities Management

Does your company manage Tailings Storage Facilities

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

Not applicable to the Company at this time.

Innovation

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

Describe nature of spending on Research, Development and Technologies for waste management compliance and improvement

Not applicable at this stage of the Company's
operations.

Biodiversity

Management Plan

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

There are no formal environmental and
biodiversity management plans implemented
or required as Prime limits its operational
activities in Mexico to drilling.

The Company will continue to monitor future
activities and will develop formal plans as
required to ensure all standards are
appropriately met.

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

Not applicable

1.2 The topics addressed by the plan(s)

Not applicable

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)

The Company obtains all governmental permits
for exploration activities. The Company has
been compliant with all government
requirements.

Impacts

Does access to the site involve traversing a protected area

Do any of the entities concessions share a watershed with a protected area

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

Does not apply

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

Does Not Apply

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

Does Not Apply

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

0.0000%

Social

Scale of the Organization

Describe how the organisation defines its "Operation"

The Company is undertaking a range of
activities to help determine the amount and
extent of minerals within the project area to
evaluate if there is an economic deposit. Those
activities follow the federal and state guidelines
for exploration within our mineral claims, and
include mapping and sampling the surface
rocks, as well as taking soil samples. Defining
drill targets where we then drill to test the rock
at depth, we sample the core or chips returned
from drilling and send to independent
laboratories to know the amount of the
assaying minerals. One half of all core or chips
are stored at our facilities after sampling.
Modeling of all results will allow us to make the
decision on where we explore next or if we
move to the next stage of exploration and
evaluate if the area has the potential for the
economically profitable extraction of minerals.

Report the total number of operations

Employment

Scale of the Organization

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

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

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

Report the total number of contract employees worldwide

Female employees and contractors as percentage of total employees and contractors

14.8649%

Male employees and contractors as percentage of total employees and contractors

85.1351%

Employee Information

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

Total number of permanent employees

Total number of permanent employees - female

Total number of permanent employees - male

Total number of temporary employees

Total number of temporary employees - female

Total number of temporary employees - male

Report the total number of non-guaranteed hours employees by gender

Total number of non-guaranteed hours employees - female

Total number of non-guaranteed hours employees - male

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

Report the total number of full-time employees

Report the total number of part-time employees

Total number of full-time employees - female

Total number of part-time employees - female

Total number of full-time employees - male

Total number of part-time employees - male

Describe the methodologies and assumptions used to compile the data

Information recovered from managment.

Are the numbers reported in head count, full-time equivalent (FTE), or using another methodology

Head count, with information from managment.

Are the numbers reported at the end of the reporting period, as an average across the reporting period, or using another methodology

Numbers reported reflect year-end head count
according to on-site employees.

Provide contextual information necessary to understand the employment information provided

The information provided was recovered from
a management database as of year-end.

Describe significant fluctuations, if any, in the number of employees during the reporting period and between reporting periods

The Company did not experience significant
fluctuations. Most of the turnover during the
past year was due to employee or contractor
job abandonment, without notice. The increase
in hiring rates (employees and contractors) was
due to growth in the exploration department.

Workers who are not employees

Report the total number of workers who are not employees and whose work is controlled by the organization

Describe the most common types of worker and their contractual relationship with the organization

Not applicable.

The type of work they perform

Not applicable.

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

Total number of permanent contractors

Total number of permanent contractors - female

Total number of permanent contractors - male

Total number of temporary contractors

Total number of temporary contractors - female

Total number of temporary contractors - male

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

Total number of full-time contractors - female

Total number of part-time contractors - female

Total number of full-time contractors - male

Total number of part-time contractors - male

Describe the methodologies and assumptions used to compile the information about workers who are not employees.

Not applicable.

Turnover

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

All Employees

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

Rate of turnover

13.0435%

This percentage includes total number of
contractors and employees.

Female employees

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

Rate of turnover, females

12.5000%

Male employees

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

Rate of turnover, males

13.1148%

Non-binary employees

Turnover & Age Breakdown

Employees aged 30 years old and under

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

As percent of total employees

31.0811%

Rate of turnover

21.6216%

Employees aged between 30 and 50 years old

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

As percent of total employees

44.5946%

Rate of turnover

12.3077%

Employees over 50 years old

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

As percent of total employees

24.3243%

Rate of turnover

5.5556%

Identify types of employees captured in the turnover rate calculations

Not Applicable

Average age of employees

Diversity and Equal Opportunity

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

Board of Directors

Total Board of Directors

Percent Male

75.0000%

Percent Female

25.0000%

Percent under 30 years of age

0.0000%

Percent between 30 and 50 years of age

0.0000%

Percent over 50 years of age

100.0000%

Senior Management

Total Senior Managers

Percent Male

100.0000%

Percent Female

0.0000%

Percent under 30 years of age

0.0000%

Percent between 30 and 50 years of age

40.0000%

Percent over 50 years of age

60.0000%

Salaried (excluding Senior Management)

Total Salaried (excluding Senior Management)

Percent Male

50.0000%

Percent Female

50.0000%

Percent under 30 years of age

50.0000%

Percent between 30 and 50 years of age

0.0000%

Percent over 50 years of age

50.0000%

Technical Employees (skilled hourly)

Total Technical Employees

Percent Male

84.0909%

Percent Female

15.9091%

Percent under 30 years of age

36.3636%

Percent between 30 and 50 years of age

50.0000%

Percent over 50 years of age

13.6364%

Production Employees (unskilled hourly)

Total Production Employees

Percent Male

Does Not Apply

Percent Female

Does Not Apply

Percent under 30 years of age

Does Not Apply

Percent between 30 and 50 years of age

Does Not Apply

Percent over 50 years of age

Does Not Apply

Contractors:

Total Contractors

Percent Male

86.9565%

Percent Female

13.0435%

Percent under 30 years of age

30.4348%

Percent between 30 and 50 years of age

34.7826%

Percent over 50 years of age

34.7826%

Labour Relations

Collective Bargaining Agreements

Percentage of total direct employees covered by collective bargaining agreements

0.0000%

For employees not covered by collective bargaining agreements, report whether the organization determines their working conditions and terms of employment based on collective bargaining agreements that cover its other employees or based on collective bargaining agreements from other organizations

Not applicable.

Notice Periods

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

There is no minimum number of weeks' notice
required for employees. The Company adheres
to all local laws and regulations.

If your organization is subject to collective bargaining agreements, is the notice period and provisions for consultation and negotiation specified in those agreements

Occupational Health and Safety

Work-related Injuries

Injuries - For all employees

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

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

0.000

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

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

0.000

iii. Number of recordable work-related injuries

iii. Rate of recordable work-related injuries

0.000

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

Main type of injury would be those associated
with incidents at a exploration stage resource
company. Potential risks include falls, vehicle
accidents, and drill-rig specific injuries.

v. Number of hours worked

84,014

Lost Time Injuries (LTIs)

Lost Time Injuries Rate (LTIR)

0.000

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

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

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

0.000

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

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

0.000

iii. Number of recordable work-related injuries

iii. Rate of recordable work-related injuries

0.000

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

Main type of injury would be those associated
with incidents at a exploration stage resource
company. Potential risks include falls, vehicle
accidents and drill rig specific injuries.

v. Number of hours worked

42,370

Lost Time Injuries (LTIs)

Lost Time Injuries Rate (LTIR)

0.000

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

Total Hours Worked

126,384

Total number of all work-related injuries

Rate of work-related injuries

0.000

Total Lost Time Injuries (LTIs)

Lost Time Injuries Rate (LTIR)

0.000

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

i. How have these hazards been determined

The Company's EVP of Exploration and on-site
General Manager are responsible for the health
and safety of employees and contractors.
Safety training is provided to individuals at site.
Risks are assessed consistent with common
practice of an exploration stage companies.

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

There have been no incidents at site.

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

Safety training is provided to mitigate risks.
Appropriate protocols are in place with all
equipment. Risks have been mitigated to an
appropriate level that is consistent with
rigorous industry standards.

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

Workers activities (employees and contractors)
are closely supervised in order to identify and
prevent any risk or accident. Training on safety
matters is provided on daily basis.

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

There have been no employee exclusions in this
disclosure.

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

The data had been recovered from
Environment, Health and Safety reports,
completed weekly on site by staff, as well as
information provided by the company´s EVP of
Exploration and on-site General Manager.

Safety Training

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

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

0.41

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

1.18

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

Describe the nature of any social risks, for all operating countries, that could have a material risk to operations

The ability to operate could be adversely
impacted by accidents or events detrimental
(or perceived to be detrimental) to the health,
safety and well-being of employees and
community members. Mining has many
detractors.

Details: Prime could be blamed for environmental changes or perceived social harms to the
community. Increased dust, local water consumption, employment, and operational activities may impact local
perceptions. Changes to the area may impact local ability to access resources or be seen as threatening to the
local community's existing way of life.

Community protest

The Company’s relationships with the communities in which it operates, and other stakeholders are critical to
ensuring the future success of the construction and development of its projects. In contrast to the many benefits
that mining provides to communities including good paying long-term jobs, taxes paid to local and federal
governments, infrastructure and other investments in local communities, improved roads, and access to remote
areas, improved power and water access, and financial support of rural and low income communities nearby, there
is an increasing level of public concern relating to the perceived effect of mining activities on the environment and
on communities impacted by such activities. Publicity adverse to the Company, its operations, or extractive
industries generally, could have an adverse effect on the Company and may impact relationships with the
communities in which the Company operates and other stakeholders.

External opposition

Certain non-governmental organizations (“NGOs”), some of which oppose globalization and resource
development, are often vocal critics of the mining industry and its practices, including the use of cyanide and other
hazardous substances in processing activities. Adverse publicity generated by such NGOs could have an adverse
effect on the Company’s reputation or financial condition and may impact its relationship with the communities in
which it operates.

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

Does Not Apply

The total amount of proved reserves

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

Does Not Apply

The total amount of probable reserves

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

0.0000%

Total amount of inferred, indicated and/or measured resources

812,000

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

Does Not Apply

The total amount of proved reserves

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

Does Not Apply

The total amount of probable reserves

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

0.0000%

Total amount of inferred, indicated and measured resources

812,000

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

The Company does not operate in any
indigenous areas.

Discuss practices and list procedures while operating in areas of conflict

The Company does not operate in areas of
conflict.

Community Relations

Artisanal and Small-Scale Mining

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

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

Does Not Apply

Report the associated risks and the actions taken to manage and mitigate these risks

The Company does not have any sites where
artisanal and small-scale mining (ASM) takes
place on, or adjacent to, the concession area.
Therefore the associated risks and the actions
to manage and mitigate these risks are not
applicable.

Programs

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

In 2021, we conducted a third-party
Environmental and Social Baseline Study in the
mining concession area to better understand
existing basic environmental and community
conditions in the regions where we are
exploring (“Area of Influence”).

Details: We work closely with the local Ejido, supporting it financially and through K-12 education programs. We
continued activities such as roads improvement, donation of heavy machinery hours to Ejido tenants to assist
them in raising cattle and crops. Creation of small dams as a precedent of a future water harvesting program, and
donation of AC equipment to schools to improve the educational conditions.

In 2022 we continued to execute on our long-term ESG strategy by, in addition to the responsibilities of our
Country Manager, hiring a full-time employee with an advanced degree in hydrology to lead our ESG efforts on the
ground; completing a materiality assessment involving employees, the Board and key stakeholders to evaluate
ESG issues most material to Prime’s Mexico operations; strengthening the Company’s ESG-related policies and
Board charters; aligning our policies and practices with the United Nations Guiding Principles on Business and
Human Rights (UNGP) and the International Council on Mining and Metals (ICMM) Principles, demonstrates our
willingness to go beyond Mexican and Canadian law as well as Prime’s commitment to ESG at the highest levels of
the company; and conducting an in-house education survey to evaluate short-term and long-term education needs
in the company’s Area of Influence (aka “Education Needs Assessment”).

We aspire to continually improve our strong relationship with the Ejido and support programs to enhance the
socioeconomic condition of its members.

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

In 2022, the Company completed an Enterprise
Risk Management assessment that included
identification and mitigation of ESG and
community-related risks in the Area of
Influence.

Risks and Opportunities

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

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

Governance

Climate Change

Oversight

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

Yes

Responsibility

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

"Safety, Health, Environment and Quality
committee"

Nature of primary responsibility

Assessing climate-related risks and
opportunities

Reporting

Frequency of reporting to the board on climate-related issues

Quarterly

Incentives

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

No, not currently but we plan to introduce
them in the next two years

Risk and Opportunity Management

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

No-we are planning to introduce a climate-
related risk management process in the next
two years

Risk Assessments

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

No - evaluation in process

Opportunity Assessments

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

Strategy

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

Water Management

Quality and Quantity Dependency

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

Direct use importance rating

Important

Indirect use importance rating

Important

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

Direct use importance rating

Important

Indirect use importance rating

Important

Risk Assessments

Does your organization undertake a water-related risk assessment

Yes, water-related risks are assessed

Select the options that best describe your procedures for identifying and assessing water-related risks

i. Coverage

Full

ii. Risk Assessment Procedure

Water risks are assessed in an environmental
risk assessment

iii. Frequency of Risk Assessment

Not defined

iv. How far into the future are risks considered

Unknown

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

Opportunity Assessments

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

Responsibility

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

Safety, Health, Environment, and Quality
Committee

Policy

Does your organization have a documented water policy

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

Select the options that best describe the scope and content of your organizations' water policy

None

Reporting

Frequency of reporting to the board on water-related issues

Quarterly

Incentives

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

No, not currently but we plan to introduce
them in the next two years

Strategy

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

No, water-related issues not yet reviewed, but
there are plans to do so in the next two years

General Disclosure

Governance structure and composition

Describe its governance structure, including committees of the highest governance body; e.g., the Board of Directors, the Executives, the Board Environment Committee, Board Safety Committee, the Advisory Committee, etc.

Prime has an 8-person Board of Directors.

The Board has 6 independent members and 2
non-independent members.

The Health, Safety, Environment and Social
Responsibility Committee is comprised of all
independent members and reports to the
Board on a quarterly basis.

Prime Mining Board of Directors

Prime Mining Health, Safety, Environment and
Social Responsibility Committee Charter

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

The Company has the following governance
committees that report to the Board quarterly:

1. Health, Safety, Environment and Social
Responsibility Committee

2. Audit Committee

3. Nominating and Corporate Governance
Committee

4. Compensation and Human Resource
Committee.

Please refer to the link below for access to
Prime Mining's Board Committee Charters.

Prime Mining Board Committee Charters

Delegation of responsibility for managing impacts

Describe whether the highest governance body has appointed any senior executives with responsibility for the management of organization’s impacts on the economy, environment, and people e.g., is it part of the Governance structure of the company, the CFO or internal audit reporting to the Board

Yes. The CEO reports to the Board on the
company's impacts.

Daniel Kunz, Prime Mining's CEO is responsible
for economic, environmental, and social topics.

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

The CEO reports to the Board of Directors, and
the Governance Committee on a quarterly
basis or more frequently, as needed.

Consultation Process

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

Senior management and in-country managers
are responsible for most communications with
stakeholders on these topics. Material
communications are reported to the Board in
the CEO's monthly operations report. As an
early-stage exploration company with limited
in-country operations, these communications
and consultations are limited.

Governance structure and composition

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

Number of executive members

Number of non-executive members

Number of independent members

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

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

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

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

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

Refer to attached Annual Information Form
(AIF).

Number of Male governance body members

Number of Female governance body members

Number of members from under-represented social groups

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

The Health, Safety, Environmental and Social
Responsibility Committee is comprised of

Edie Hofmeister (Chair)
Marc Prefontaine
Murray John
Andrew Bowering

Please refer to AIF for individuals background
and competencies.

Prime Mining Annual Information Form April
2022

Description of stakeholder representation

The Board of Directors has a fiduciary duty to
ensure they are acting in the best interests of
the corporation. In that role, the Directors
consider the interests of all affected
stakeholders.

Board Diversity

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

Refer to Human Rights and Diversity Policy in
the link below.

Prime Mining Human Rights and Diversity
Policy

Chair of the highest governance body

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

Conflicts of Interest

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

The Company has a Code of Conduct and Ethics
that all directors and management must adhere
to. It includes an obligation to disclose conflicts
of interest.

The Board annually evaluates its
legal independence and is surveyed about any
potential conflicts of interest and related party
transactions.

Prime Mining Code of Conduct and Ethics

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

Yes

Cross-board membership

Yes

Cross-shareholding with suppliers and other stakeholders

The Company is not aware of any cross-
shareholding relationships. However, its 2023
Independence Questionnaire will specifically
poll the Board to assess those issues.

Existence of controlling shareholder

Yes

Related parties, their relationships, transactions, and outstanding balances

Yes

Collective knowledge of highest governance body

Report measures taken to advance the collective knowledge, skills, and experience of the highest governance body on sustainable development., e.g., board training

Members of the Health, Safety, Environment
and Social Responsibility Committee follow
ESG and legal trends globally and report to the
Committee and Board on relevant
developments. Sources of information include
legal updates from the International Bar
Association Human Rights Committee, the
Harvard Law School Governance Forum and
MSCI's "ESG Now" Guidelines. An ESG training
session was conducted for the Board in
2022. Many board members bring decades of
collective experience and knowledge regarding
sustainable development in a mining context.

Evaluation of Highest Governance Body

Describe actions taken in response to the evaluations, including changes to the composition of the highest governance body and organizational practices

The Board conducts a self-assessment
annually. No actions were taken in response to
these evaluations.

Transparency

Describe the role of the highest governance body and of senior executives in developing, approving, and updating the organization’s purpose, value or mission statements, strategies, policies, and goals related to sustainable development

Senior management, the Health, Safety,
Environment and Social Responsibility
Committee and the Governance and
Nominating Committee are responsible for
developing, approving and updating the
organization's policies, strategies, goals and
value statements. relating to sustainable
development.

Policies are reviewed and adjusted, as
appropriate, by the Board of Directors
annually.

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

Senior management has responsibility for
conducting economic, environmental and social
due diligence to determine company
impacts. These are reported to the Board.

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

Prime does not have the kind of operation that
warrants this level of engagement with
stakeholders. Management is responsible for
stakeholder engagement and reports material
communications to the Board.

Describe how the highest governance body considers the outcomes of these processes

Please see above.

Ethics

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

Refer to the Anti-Bribery and Anti-Corruption
Policy in the link below.

Prime Mining Anti-Bribery and Anti-Corruption
Policy

Anti-Bribery and Anti-Corruption Policy

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

Anti-Corruption

Communication and Training

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

All members of the Board have experience in
Mexico and have received anti-corruption
training.

Total number and percentage of employees that have received training on anti-corruption, broken down by employee category and region

1a. Total number of employees that received training on anti-corruption

Total number of employees

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

98.0392%

2a. Total number of senior employees that received training on anti-corruption

Total number of senior employees

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

100.0000%

3a. Total number of middle management employees have received training on anti-corruption

Total number of middle management employees

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

Does Not Apply

4a. Total number of technical employees that received training on anti-corruption

Total number of technical employees

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

95.6522%

5a. Total number of production employees that received training on anti-corruption

Total number of production employees

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

Does Not Apply

6a. Total number of administrative employees that received training on anti-corruption

Total number of administrative employees

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

Does Not Apply

General Disclosure

Remuneration

Describe how the remuneration policies for members of the highest governance body and senior executives relate to their objectives and performance in relation to the management of the organization’s impacts on the economy, environment, and people

The Compensation and Human Resources
Committee and Board, in partnership with the
CEO, annually identify objectives and impacts
in relation to this category.

Prime Mining Compensation and Human
Resources Committee Charter

How the views of stakeholders (including shareholders) regarding remuneration are sought and taken into consideration

The Compensation Committee of the Board
evaluates compensation practices against Peer
Companies and consults with shareholders,
when appropriate, in the evaluation of Director
and Senior Management compensation.

Report the results of votes of stakeholders (including shareholders) on remuneration policies and proposals, if applicable

Not applicable.

Stakeholder Engagement

Report the purpose of the stakeholder engagement

Not applicable.

Tax

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

i. The approach to engagement with tax authorities

The Company is compliant with tax laws in all
jurisdictions in which the Company operates.

ii. The approach to public policy advocacy on tax

The Company does not advocate for tax policy
changes.

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

The Company regularly engages with a
multitude of stakeholders and an Independent
Auditor regarding its financial position,
including taxes. It also has a Whistleblower
policy which enables stakeholders to express
concerns regarding the Company's approach to
taxes.



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