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Published on November 28, 2022 |
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At Troilus we are committed to creating value for our shareholders while operating in a safe, socially and environmentally responsible manner, contributing to the prosperity of our employees and our local communities while respecting human rights, cultures, customs and values of those impacted by our activities. |
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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 |
Troilus Gold Corporation |
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Describe nature of activities, brands, products and services |
Troilus Gold Corp. is a Canadian-based junior mining company focused on the systematic advancement and de-risking of the former gold and copper Troilus Mine towards production. |
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From 1996 to 2010, the Troilus Mine produced +2 million ounces of gold and nearly 70,000 tonnes of copper.
Troilus is located in the top-rated mining jurisdiction of Quebec, Canada, where it holds a strategic land position of 1,420 km² in the Frotêt-Evans Greenstone Belt. Since acquiring the project in 2017, ongoing exploration success has demonstrated the tremendous scale potential of the gold system on the property with significant mineral resource growth.
The Company is advancing engineering studies following the completion of a robust PEA in 2020, which demonstrated the potential for the Troilus project to become a top-ranked gold and copper producing asset in Canada. Led by an experienced team with a track-record of successful mine development, Troilus is positioned to become a cornerstone project in North America. |
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Link to Corporate Website |
https://www.troilusgold.com/ |
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Industry Classification |
NAICS: 21222 Gold and silver ore mining |
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Market Capitalization |
$0-$100Million USD |
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Type of Operations |
Exclusively non-producing operations |
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Company Headquarters |
Toronto, Canada |
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Link to company's statements of: Purpose, Vision, Mission and Values; Sustainability/ESG strategy; previously published Sustainability/ESG performance or reports. (URL) |
https://www.troilusgold. com/sustainability/overview/ |
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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 |
Catherine Stretch, VP Corporate Affairs |
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Catherine Stretch, VP of Corporate Affairs is tasked with overseeing ESG practices and reports directly to the CEO. Ms. Stretch informs the ESG Committee on ESG issues pertaining to the company on a quarterly basis; in turn, the ESG Committee reports to the Board of Directors. |
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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 |
2021-01-01 |
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To |
2021-12-31 |
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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 locations of operations |
Canada |
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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.) |
None |
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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.) |
There are no exclusions from this 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 |
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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 |
None |
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Currency |
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Unless otherwise noted, all financial figures referenced in this report are in the following currency |
CAD |
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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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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 |
GRI, UN Global Compact, SASB, Ecologo |
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Strategy |
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Provide a statement from the most senior decision-maker of the organization (i.e., CEO, chair, or equivalent senior position) about the relevance of sustainability to the organization and its strategy for addressing sustainability (CEO's message for this report) |
Please see the attached statement from our CEO. |
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Sustainability at Troilus Gold Corp. |
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CEO Statement |
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Sustainable Development Policy |
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Justin Reid, CEO |
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Provide a description of key impacts, risks, and opportunities, |
As a mine site under development, Troilus is engaged in the permitting process for the Environment & Social Impact Study which will commence in 2022 at the provincial and federal level. The future construction and production at the mine is dependent on the successful and timely completion of the regulatory approval process.
As a closed mine site, Troilus is responsible for the management and reclamation of the former tailings facility which includes ongoing monitoring and treatment of water, revegetation and restoration.
The Troilus project is located on lands that are the traditional territory of the Cree Nation. Troilus is committed to working closely with the families and communities that use the land to ensure its long term health and sustainability.
The Troilus project is subject to known and unknown risks of the mining industry, including without limitation, risks and uncertainties discussed in the company’s most recent 43-101 Technical Report, annual information form, financial statements and MD&A, as well as other continuous disclosure documents available under the Company’s profile at www. sedar.com. |
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Ethics and Integrity |
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Provide a description of the organization’s values, principles, standards, and norms of behaviour |
Troilus Gold Corp. is committed to creating sustainable long-term value for its stakeholders, which is achieved by adhering to best practices in corporate governance.
The Company has established a set of policies with respect to ethical business practices, personal conduct, environmental, safety and occupational health practices, competition and fair dealings, and disclosure of information, that describe its commitment to promoting effective functioning of its personnel and improve the company performance. |
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Whistleblower Policy
Anti-Bribery and Anti-Corruption Policy
Code of Business Conduct & Ethics |
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Code of Business Conduct and Ethics |
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Anti- Bribery and Anti-Corruption Policy |
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Material Topics |
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Governance of Material Topics |
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Describe the process followed to determine its 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 |
• Economic impact assessment • Environmental impact assessment • Social impact assessment • Civil society organizations |
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ii. How has the organization prioritized the impacts for reporting based on their significance |
As an exploration & development stage project in Northern Quebec, we have prioritized environment (current footprint, permitting and future planning for mine restart), engagement with First Nations and local communities, GHG emission (planning for a future carbon neutral operation), health & safety, local procurement, infrastructure, diversity and governance. |
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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 • Employees and other workers • Governments • Local communities • Shareholders and other capital providers |
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List the organization's material topics |
• Indirect Economic Impacts • Procurement Practices • Energy • Water • Biodiversity • Emissions • Compliance • Overall environmental • Environmental Assessment • Employment • Occupational Health and Safety • Training and Education • Diversity and Equal Opportunity • Equal Remuneration for Women and Men • Labor Practices • Non-discrimination • Indigenous Rights • Local Communities • Anti-corruption • Emergency Preparedness • Communications • Permitting |
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Sustainable Development Policy |
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Statement on Sustainable Development |
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List the organization's non-material topics |
• Economic Performance • Market Presence • Materials • Effluents and Waste • Products and Services • Transport • Supplier • Environmental Grievances • Labor/Management Relations • Supplier Assessment for Labor Practices • Grievance Mechanisms • Human Rights Investment • Freedom of Association and Collective Bargaining • Child Labor • Forced or Compulsory Labor • Security Practices • 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 • Customer Privacy • Materials Stewardship |
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Provide reason for considering such topics not material, provide details |
Not applicable |
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Troilus is not in production, has no revenues, no customers, no waste generated, no suppliers. Operating in northern Canada, concerns such as artisanal mining, child labour, forced labour, human rights abuses are not an issue and are strictly governed by Canadian law. At Troilus our focus is on the health and safety of our employees at site, engagement with local communities, environmental permitting and planning for a sustainable future mine site. |
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Report changes to the list of material topics compared to the previous reporting period |
None |
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Environment |
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Compliance |
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a. Report fines and non-monetary sanctions for non-compliance with environmental laws and/or regulations in terms of |
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i. Total monetary value of significant fines |
0 |
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ii. Total number of non-monetary sanctions |
0 |
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iii. Cases brought through dispute resolution mechanisms |
0 |
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b. If the organization is in compliance with environmental laws and/or regulations, a brief statement if this fact is sufficient |
In 2021, Troilus 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) |
426.585 |
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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) |
426.585 |
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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 |
100.0000% |
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The entity shall discuss its long-term and short-term strategy or plan to manage its Scope 1 greenhouse gas (GHG) emissions |
The majority of energy used to operate the Troilus site comes from renewable sources (hydroelectricity in Northern Quebec). Troilus currently generates Scope 1 GHG emissions from the use of gasoline used for vehicle transport, diesel used in generators and drilling at site, propane used for heating the camp facilities.
In 2022, Troilus will be undertaking an audit of GHG emissions generated to date and developing a roadmap to minimize GHG emissions for the future with the objective of building a carbon neutral mining operation. |
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Intensity Ratio |
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The total amount of gross global Scope 1 GHG emissions (CO₂-e) (tonne) |
426.585 |
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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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Where were these credits purchased from |
Not Applicable |
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Troilus has not yet purchased credits to offset historical GHG, but is currently exploring options to do so. |
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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) |
0.000 |
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Emissions of oxides of nitrogen (NOx), reported as NOx (tonne) |
0.000 |
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Emissions of oxides of sulphur (SOx), reported as SOx (tonne) |
0.000 |
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Emissions of Particulate Matter 10 micrometres or less in diameter (PM₁₀), reported as PM₁₀ (tonne) |
0.000 |
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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) |
0.000 |
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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) |
18,463.480 |
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Percentage energy consumed that was supplied by grid electricity |
70.6930% |
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Percentage of energy consumed that is renewable energy |
70.6930% |
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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 |
90.0000% |
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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) |
100.000 |
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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 |
0.0000% |
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Disclose water withdrawn in locations with High or Extremely High Baseline Water Stress (in thousands of cubic meters) |
0.000 |
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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 |
0.0000% |
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Disclose the amount of water that was consumed in its operations (in thousands of cubic meters) |
3.000 |
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Total water consumed in locations with high or extremely high baseline water stress (in thousands of cubic meters) |
0.000 |
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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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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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Water and Effluents |
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Water Consumption |
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Report the total water consumption from all areas in megaliters |
3.000 |
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Waste Management |
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Total amount of tailings waste generated from mining activities by the entity during the reporting period (tonne) |
0 |
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Percentage of tailings waste that was recycled during the reporting period |
Does Not Apply |
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Troilus is not yet in production and does not generate any tailings. |
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Tailings impoundments according to the following U.S. Mine Safety and Health Administration (MSHA) hazard potential classification |
1 |
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High hazard potential (number) |
0 |
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Significant hazard potential (number) |
0 |
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Low hazard potential (number) |
1 |
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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 |
Troilus Mine |
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Permitted Tailings Facility |
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TSF #1: (2) location |
Canada |
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TSF #1: (3) ownership status |
Wholly owned |
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TSF #1: (4) operational status |
Closed |
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TSF #1: (5) construction method |
Upstream |
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The existing tailings facility used for the mine during its previous operation was Upstream construction. A future operation envisions a Centerline construction. |
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TSF #1: (6) maximum permitted storage capacity |
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The existing tailings storage facility was permitted to be filled to a level of no more than 2 metres from the top of the spillway. |
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TSF #1: (7) current amount of tailings stored |
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Tailings have not been added to the TSF since 2010. |
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TSF #1: (8) consequence classification |
Low |
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TSF #1: (10) material findings |
No |
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TSF #1: (11) mitigation measures |
None required. The tailings facility has been closed since the previous operation closed in 2010. The area has been revegetated. Water from the tailings is monitored and treated as required before release into the natural environment. |
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TSF #1: (12) site-specific EPRP |
Yes |
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Disclose the approach to the development of Emergency Preparedness and Response Plans (EPRPs) |
Troilus is a closed mine site but also in the exploration and development stage pending a potential restart of the mine. Camp facilities typically house 25-65 occupants who are engaged in exploration and development activities. Troilus maintains an Emergency Preparedness Response Plan to ensure the health and safety of employees and external contractors at site. |
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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 |
The Company meets quarterly with the Impacted Families to review the closure status of the tailings facility. |
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Innovation |
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Spending on Research, Development, and Technologies for waste management compliance and improvement |
519411 |
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Describe nature of spending on Research, Development and Technologies for waste management compliance and improvement |
In 2021, we had expenditures for the design of the future tailings facility that will be used once the mine is restarted. The focus of the expenditures have been to develop a tailings facility that will be safe, long lasting and a minimal environmental footprint. Troilus also had research expenditures for programs to better understand and manage future waste rock. These studies will have an impact on water quality in the future. |
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Biodiversity |
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Management Plan |
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List the environmental and biodiversity management plan(s) implemented at active sites |
Biodiversity Management Plan |
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1.1 Mine lifecycle stages to which the plan(s) apply |
Exploration and appraisal |
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1.2 The topics addressed by the plan(s) |
• Ecological and biodiversity impacts • Noise impacts |
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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) |
The Quebec Fauna Ministry (MFFP - Ministère de la Forêt, de la Faune et des Parcs) issues guidelines and conditions in the permits they emit that are incorporated into the plan.
In addition, we constructed this plan and policy in conjunction with the EcoLogo Certification program.
ECOLOGO® Certified products, services and packaging are certified for reduced environmental impact. ECOLOGO Certifications are voluntary, multiattribute, life cycle-based environmental certifications that indicate a product has undergone rigorous scientific testing, exhaustive auditing or both, to prove its compliance with stringent, third- party, environmental performance standards. |
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Impacts |
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Does access to the site involve traversing a protected area |
No |
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The Troilus site is located in a “Reserve Faunique”, that allows permitting for commercial tree cutting, quarries and mines. |
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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 |
The Troilus site can easily be reached by road from the towns of Chibougamau, Chapais and Mistissini (daily flights from Montreal).
There is direct road access to the site and no protected areas or protected watersheds are traversed. |
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Access to the Troilus Gold Project |
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Percentage of proved reserves in sites with protected conservation status or in areas of endangered species habitat |
Does Not Apply |
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Percentage of probable reserves in sites with protected conservation status or in areas of endangered species habitat |
Does Not Apply |
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Percentage of inferred, indicated and measured reserves in sites with protected conservation status or in areas of endangered species habitat |
0.0000% |
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Social |
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Employment |
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Scale of the Organization |
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Report the total number of operations |
1 |
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i. Report the total number of direct employees worldwide (exclude contractors) |
31 |
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ii. Report the total number of contract employees worldwide |
2 |
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Female employees and contractors as percentage of total employees and contractors |
36.3636% |
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Male employees and contractors as percentage of total employees and contractors |
63.6364% |
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Non-binary employees and contractors as percentage of total employees and contractors |
0.0000% |
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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 |
31 |
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Total number of permanent employees |
31 |
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Total number of permanent employees - female |
11 |
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Total number of permanent employees - male |
20 |
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Total number of permanent employees - Non-binary |
0 |
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Total number of temporary employees |
0 |
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Report the total number of contractors by employment type (permanent and temporary), by gender |
2 |
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Total number of permanent contractors |
2 |
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Total number of permanent contractors - female |
1 |
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Total number of permanent contractors - male |
1 |
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Total number of permanent contractors - Non-binary |
0 |
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Total number of temporary contractors |
0 |
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Report the total number of employees by employment type (full-time and part-time), by gender |
31 |
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Total number of full-time employees - female |
11 |
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Total number of part-time employees - female |
0 |
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Total number of full-time employees - male |
18 |
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Total number of part-time employees - male |
2 |
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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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Report the total number of contractors by employment type (full-time and part-time), by gender |
2 |
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Total number of full-time contractors - female |
0 |
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Total number of part-time contractors - female |
1 |
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Total number of full-time contractors - male |
0 |
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Total number of part-time contractors - male |
1 |
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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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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) |
5 |
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Rate of turnover |
15.8730% |
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Female employees |
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Total number of turnover (the number of females that left during the period) |
1 |
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Rate of turnover, females |
9.5238% |
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Male employees |
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Total number of turnover (the number of males that left during the period) |
4 |
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Rate of turnover, males |
22.8571% |
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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) |
0 |
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As percent of total employees |
30.3030% |
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Rate of turnover |
0.0000% |
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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) |
1 |
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As percent of total employees |
42.4242% |
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Rate of turnover |
8.6957% |
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Employees over 50 years old |
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Total number of turnover (the number that left during the period) |
4 |
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As percent of total employees |
27.2727% |
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Rate of turnover |
40.0000% |
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Identify types of employees captured in the turnover rate calculations |
All employees on the payroll |
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Average age of employees |
44 |
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Diversity and Equal Opportunity |
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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 |
7 |
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Percent Male |
85.7143% |
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Percent Female |
14.2857% |
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Percent Non-Binary |
0.0000% |
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Percent under 30 years of age |
0.0000% |
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Percent between 30 and 50 years of age |
42.8571% |
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Percent over 50 years of age |
57.1429% |
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Senior Management |
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Total Senior Managers |
10 |
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Percent Male |
60.0000% |
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Percent Female |
40.0000% |
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Percent Non-Binary |
0.0000% |
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Percent under 30 years of age |
0.0000% |
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Percent between 30 and 50 years of age |
40.0000% |
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Percent over 50 years of age |
60.0000% |
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Salaried (excluding Senior Management) |
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Total Salaried (excluding Senior Management) |
23 |
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Percent Male |
65.2174% |
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|
|
|
|
|
Percent Female |
34.7826% |
|
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|
|
|
|
|
|
|
|
|
|
|
|
|
|
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|
|
Percent Non-Binary |
0.0000% |
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|
|
|
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|
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|
Percent under 30 years of age |
43.4783% |
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|
|
Percent between 30 and 50 years of age |
39.1304% |
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|
Percent over 50 years of age |
17.3913% |
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|
|
Technical Employees (skilled hourly) |
|
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|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
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|
|
Total Technical Employees |
0 |
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|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
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|
|
Production Employees (unskilled hourly) |
|
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|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Total Production Employees |
0 |
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|
|
|
|
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|
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|
|
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|
Contractors: |
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|
|
|
|
|
|
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|
|
|
|
|
|
|
|
|
|
|
|
Total Contractors |
2 |
|
|
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|
|
|
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|
|
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|
|
Percent Male |
50.0000% |
|
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|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Percent Female |
50.0000% |
|
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|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Percent Non-Binary |
0.0000% |
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|
|
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|
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|
Percent under 30 years of age |
50.0000% |
|
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|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Percent between 30 and 50 years of age |
50.0000% |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Percent over 50 years of age |
0.0000% |
|
|
|
|
|
|
|
|
|
|
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|
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|
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|
|
|
|
|
Labour Relations |
|
|
Collective Bargaining Agreements |
|
|
Percentage of total direct employees covered by collective bargaining agreements |
0.0000% |
|
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|
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|
|
|
|
|
|
|
|
|
|
|
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 |
2 |
|
|
|
|
|
|
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|
|
|
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|
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|
|
|
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|
|
|
|
|
|
|
|
|
|
Occupational Health and Safety |
|
|
Work-related Injuries |
|
|
Injuries - For all employees |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
i. Number of fatalities as a result of work-related injury |
0 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
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) |
0 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
ii. Rate of high-consequence work-related injuries (excluding fatalities) |
0.000 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
iii. Number of recordable work-related injuries |
0 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
iii. Rate of recordable work-related injuries |
0.000 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
iv. Main types of work-related injury, e.g., confined space, trips, falls, etc. |
Minor contusions, cuts, scrapes, sprains due to use of tools and physical activity. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
In 2021, Troilus enacted a comprehensive Drug & Alcohol Policy that applies to all employees and contractors. The objective of the Drug & Alcohol Policy is to provide clarity to employees and contractors and to ensure the health & safety of all, particularly with regards to operations at site. |
|
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|
|
|
|
|
|
|
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|
|
|
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|
|
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|
|
|
|
|
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|
|
|
|
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|
|
v. Number of hours worked |
53,730 |
|
|
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|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Lost Time Injuries (LTIs) |
0 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
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 |
0 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
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) |
0 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
ii. Rate of high-consequence work-related injuries (excluding fatalities) |
0.000 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
iii. Number of recordable work-related injuries |
0 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
iii. Rate of recordable work-related injuries |
0.000 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
iv. Main types of work-related injury, e.g., confined space, trips, falls, etc. |
Minor contusions, cuts, scrapes, sprains due to use of tools and physical activity. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
v. Number of hours worked |
56,952 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Lost Time Injuries (LTIs) |
0 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Lost Time Injuries Rate (LTIR) |
0.000 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Combined (Employees and non-employees, but controlled by the organization): |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Total Hours Worked |
110,682 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Total number of all work-related injuries |
0 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Rate of work-related injuries |
0.000 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Total Lost Time Injuries (LTIs) |
0 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Lost Time Injuries Rate (LTIR) |
0.000 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Report the work-related hazards that pose a risk of high-consequence injury, including |
|
|
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|
|
|
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|
|
i. How have these hazards been determined |
As a past producer, Troilus is a closed mine site and hazards exist related to the past workings including two open mine pits that are filled with water, waste piles, aging infrastructure, a tailings facility.
The mine site is located in northern Quebec which is subject to extreme weather which can include extreme cold, accumulation of snow and ice in winter months, melting ice in spring, lightning strikes in summer which can lead to forest fires.
Troilus is engaged in exploration and development activities which includes field exploration, drilling, core cutting, road maintenance, etc. The physical nature of the work at the Troilus site can create hazards for employees and contractors. |
|
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|
|
ii. Which of these hazards have caused or contributed to high-consequence injuries during the reporting period |
None |
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|
|
iii. Actions taken or underway to eliminate these hazards and minimize risks using the hierarchy of controls |
Troilus maintains strict safety protocols and procedures to ensure health and safety of all employees and service providers. Troilus maintains a health and safety manual that is updated annually and includes emergency evacuation procedures in the event of a threat to the physical site such as a forest fire.
All staff, contractors and visitors to site are required to participate in a safety briefing. Visitors to site must report in to the camp manager and basic health information is gathered. Troilus ensures there are always staff on shift who have received emergency response training and in 2021, with an increased level of activity, a fulltime nurse is always on site. |
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|
|
Report on actions taken or underway to eliminate other work-related hazards and minimize risks using the hierarchy of controls |
With the exception of a 6 week period at the beginning of the global pandemic in 2020, Troilus has remained in operation. In 2021, Troilus continued to monitor public health guidance and ensured protocols were in place to minimize the risk of spread of COVID-19 amongst staff and contractors at site. This included physical modifications of common areas to allow for social distancing, health questionnaire and testing in advance of arrival at site, isolation rooms in the event symptoms and increased cleaning and hygiene protocols. |
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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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|
Safety Training |
|
|
Disclose the average number of training hours provided to its workforce for health, safety, and emergency management training |
|
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|
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|
|
|
|
|
|
|
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|
|
Average hours of health, safety, and emergency response training for (a) full-time/direct employees |
2.9 |
|
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|
|
|
|
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|
|
|
|
|
|
|
|
|
Average hours of health, safety, and emergency response training for (b) contract employees |
0 |
|
|
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|
|
|
|
|
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|
|
|
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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 |
We have identified a key social risk is engagement with First Nations (Cree) as the Troilus Project is located on traditional Cree territory.
We have extensive ongoing engagement with the Cree Nation and align ourselves with the James Bay Agreement signed between the Government of Quebec and the Cree Nation.
In 2018, Troilus entered into a Pre- Development Agreement with the Cree Nation which serves as a precursor to a future Impact & Benefits Agreement. The PDA provides a framework for communication and cooperation between Troilus and the Cree Nation. |
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|
|
Percentage of proved reserves that are located in or near areas of active conflict |
Does Not Apply |
|
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|
|
Percentage of probable reserves that are located in or near areas of active conflict |
Does Not Apply |
|
|
|
|
|
|
|
|
|
|
|
|
|
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|
|
Percentage of inferred, indicated and measured reserves that are located in or near areas of active conflict |
Does Not Apply |
|
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|
|
Percentage of proved reserves that are located in or near areas that are considered to be indigenous peoples’ land |
Does Not Apply |
|
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|
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|
|
|
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|
|
Percentage of probable reserves that are located in or near areas that are considered to be indigenous peoples’ land |
Does Not Apply |
|
|
|
|
|
|
|
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|
|
|
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|
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|
|
|
Percentage of inferred, indicated and measured reserves that are located in or near areas that are considered to be indigenous peoples’ land |
100.0000% |
|
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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 company notifies First Nations of drilling activity as part of the permitting process. The Company engages in regular communication and interaction with First Nations families, local leadership and community organizations to discuss priority issues such as environment, employment, skills training, safety and business opportunities.
In 2022, Troilus will commence its environmental permitting process which will include extensive community consultations. |
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|
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) |
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 |
0.0000% |
|
|
|
|
|
|
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|
|
Report the associated risks and the actions taken to manage and mitigate these risks |
Artisanal and small-scale mining do not take place at or near the Troilus site. |
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|
|
Programs |
|
|
Report on community relations programs, objectives and achievements in the past 3 years |
During COVID, much of Troilus' in-person community relations were suspended or limited to virtual engagement. In 2022, Troilus will be refocusing on direct engagement with local leadership to keep them informed of development progress and economic contributions, sponsorship of community events, improving hiring of indigenous people and planning for long term capacity building. |
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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 |
Troilus senior management meets with local community leaders on a regular basis to ensure transparent communication and collaboration. Troilus places a priority on local procurement which accounts for 65% of all procurement. Troilus employs a Community Liaison Officer who is indigenous and maintains a Troilus office in the neighbouring indigenous community. |
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|
|
Risks and Opportunities |
|
|
Disclose the total number of site shutdowns or project delays due to non-technical factors |
0 |
|
|
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|
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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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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 |
Sustainability committee |
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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 |
No, not currently but we plan to introduce them in the next two years |
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As Troilus is not yet in production it is premature to set targets. However, Troilus considers climate-related issues at its current stage of development to design a future mining operation that will seek to minimize climate impacts. This includes considerations on future energy sources, vehicle fleet, etc. |
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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 |
No - important but not an immediate business priority |
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As Troilus is still in the exploration and development stage, climate related risks and opportunities are not significant. The Company's focus with regards to climate related risks and opportunities is to design a future mining operation that takes these into account. The Company believes that decisions it makes now regard the design of the mine site can have a significant impact on the the operation's climate impact. |
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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 |
No - risks exist, but none with potential to have a substantive financial or strategic impact on business |
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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 |
Yes |
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Opportunity 1 |
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Where in the value chain does the opportunity driver occur |
Direct operations |
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Opportunity type |
Products and Services: Development and/or expansion of low emission goods and services |
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Opportunity time horizon |
Long-term |
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Opportunity likelihood |
Very likely |
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Magnitude of impact |
Medium |
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Potential impact financial figure and explanation |
Although the main source of revenue from a future mine at Troilus will be gold, copper will also be produced. Estimated revenue will depend on copper pricing at the time of production. During its previous operation from 1996 to 2010, the Troilus mine produced 70,000 tonnes of copper. |
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Primary potential financial impact driver |
Increased revenues resulting from increased demand for products and services |
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Cost and strategy to realize opportunity and explanation of cost calculation |
The mineral resource at the Troilus site is gold and copper. Copper is considered a key mineral in the drive to develop renewable energy technologies. As the energy transition continues to unfold, new sources of copper supply are expected to become increasingly valued. |
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Opportunity 2 |
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Where in the value chain does the opportunity driver occur |
Direct operations |
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Opportunity type |
Resource efficiency : Use of more efficient modes of transport |
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Opportunity time horizon |
Long-term |
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Opportunity likelihood |
Very likely |
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Magnitude of impact |
Medium-low |
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Potential impact financial figure and explanation |
Cost savings by replacing fossil fuel (gas, diesel) powered vehicles with electric vehicle fleet |
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Primary potential financial impact driver |
Returns on investment in low-emission technology |
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Cost and strategy to realize opportunity and explanation of cost calculation |
Troilus is connected to the provincial electricity grid and the source of power is hydroelectricity. Troilus is currently working with the provincial utility to maximize use of hydroelectricity at site, including the infrastructure to support an electric vehicle fleet. |
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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 |
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Since Troilus is still at the development stage, we view planning for climate-risk as an opportunity. Troilus has access to low cost, sustainable hydroelectric power and we are incorporating increased utilization of this energy source into our mine design and planning to minimize the carbon footprint of the future mining operation as much as possible. |
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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 |
Not very important |
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Indirect use importance rating |
Not very 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 |
Not very important |
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Indirect use importance rating |
Not very important |
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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 in an environmental risk assessment |
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iii. Frequency of Risk Assessment |
More than once a year |
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iv. How far into the future are risks considered |
More than 6 years |
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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 |
No |
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Opportunity Assessments |
|
|
Have you identified any water-related opportunities with the potential to have a substantive financial or strategic impact on your business |
No |
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Water scarcity or supply is not an issue for Troilus. However, ensuring the highest standards of water management is a top priority. Troilus is located in a remote area of northern Quebec. The location of the mine site is on traditional indigenous lands that are used by indigenous families for hunting and fishing. The area also hosts flora and fauna. Troilus works closely in consultation with indigenous families to ensure that any future mining operations will not adversely impact water quality in the region. |
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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 |
Sustainability Committee |
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Policy |
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Does your organization have a documented water policy |
No, but we plan to develop one within the next 2 years |
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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 |
No, not currently but we plan to introduce them in the next two years |
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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 |
The two formerly mined pits at site are full of water from years of rain accumulation and snow melt. Troilus has been granted a permit to commence dewatering of the pits as part of its exploration activities. To date, water has only been moved from the smaller pit (which was threatening to overflow) to the larger pit. In the future, the pits will need to be entirely dewatered as the mineral resources are found beneath and around the existing pits. Troilus tests the water in the pits regularly and has done extensive planning and consultations regarding the flow and dispersal of the water once it is removed from the pits.
As part of its long term strategic planning, water management issues are being considered and incorporated into the design of the future mine to minimize environmental impacts including diversion of water, run off from waste pails, treatment of water from the tailings facility, and recycling of water. Water management is a major issue of focus for the indigenous peoples impacted by the mine site so their guidance and input will be incorporated into the design. |
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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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General Disclosure |
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Structure |
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a. Report the governance structure of the organization, 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. |
Troilus has a Board of Directors comprised of 7 people, 6 of whom are independent and one is not independent (CEO). The Board committees include: Audit, Compensation, Governance & ESG, Technical. |
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Committees |
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b. Report the committees responsible for decision-making on economic, environmental, and social topics, e.g., the Board of Directors, the Executives, the Board Environment Committee, Board Safety Committee, the Advisory Committee, etc. |
The Governance & ESG Committee is responsible for decision-making on economic, environmental and social topics. |
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Charter of the Environment, Social, Governance Committee |
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Responsibility |
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a. Has the organization appointed an executive-level position or positions with responsibility for economic, environmental, and social topics , e.g., is it part of the Governance structure of the company, the CFO or internal audit reporting to the Board |
Yes |
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The VP of Corporate Affairs has the responsibility for overseeing economic, environmental and social topics and reports directly to the CEO. The VP Corporate Affairs provides the Governance & ESG Committee with an in-person quarterly report on ESG matters. |
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Reporting Structure |
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b. Report whether position holders report directly to the highest governance body or CEO |
The VP of Corporate Affairs reports directly to the CEO on a daily basis and reports to the Governance & ESG Committee on a quarterly basis. |
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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 |
Stakeholders have multiple direct channels of communication to executives at Troilus. The CEO engages directly with the governing bodies of the First Nations. The VP of Corporate Affairs and VP of Environment engage with stakeholders directly on community consultations, environmental permitting, local procurement.
In late 2021, Troilus commenced its environmental permitting process at the federal and provincial levels of government. The process began with pre- consultation sessions to identify stakeholder's priority issues they would like to see addressed during the extensive consultation period to come. The consultation process is designed and monitored by the government to ensure all stakeholders have a voice. |
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Composition |
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Report 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 |
6 |
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Number of independent members |
6 |
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Less than 3 years |
2 |
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3-6 years |
5 |
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6-9 years |
0 |
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More than 10 years |
0 |
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Lists of each individual’s other significant positions and commitments, and the nature of the commitments, e.g., other boards and executive positions |
Diane Lai is Chair of Troilus. She is Director of Agile Enablement at Rogers Communications Inc. and teaches at the University of Toronto's Entrepreneurship program.
Justin Reid is CEO and Director of Troilus. |
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Board of Directors |
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Number of Male governance body members |
6 |
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Number of Female governance body members |
1 |
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Number of members from under-represented social groups |
1 |
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Description of competencies relating to economic, environmental, and social topics |
Please refer to the link below for a description of the Board's competencies relating to economic, environmental and social topics. |
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Board of Directors |
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Board Diversity |
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Do you have a diversity policy and if so, provide details, link to the policy or attach the file |
Troilus' policies on diversity are currently captured in the Code of Business Conduct and Ethics. |
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Code of Business Conduct and Ethics |
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Non-Executive Director |
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Is the chair of the highest governance body also an executive officer in the organization |
No |
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Conflicts of Interest |
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Report the processes for the highest governance body to ensure conflicts of interest are avoided and managed, e.g., list procedures |
Employees, officers, and directors of the Company are required to act with honesty and integrity and to avoid any relationship or activity that might create, or appear to create, a conflict between their personal interests and the interests of the Company. Employees must disclose promptly in writing possible conflicts of interest to their supervisor, or if the supervisor is involved in the conflict of interest, to the Chairman of the Audit Committee.
Directors or officers of the Company shall disclose in writing conflicts of interest to the Board of Directors or request to have entered in the minutes of meetings of the Board the nature and extent of such interest. |
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Code of Business Conduct and Ethics |
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Report whether conflicts of interest are disclosed to stakeholders, including, as a minimum |
Yes |
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i. Cross-board membership |
Yes |
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ii. Cross-shareholding with suppliers and other stakeholders |
Yes |
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iii. Existence of controlling shareholder |
Yes |
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iv. Related third party disclosures |
Yes |
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Transparency |
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Report the highest governance body’s and senior executives’ roles in the development, approval, and updating of the organization’s purpose, value or mission statements, strategies, policies, and goals related to economic, environmental, and social topics |
The Environment, Social and Governance Committee of the Board of Directors is responsible for encouraging, assisting, supporting and counseling management in developing short and long term policies and standards to ensure that the principles set out in any health and safety, environment, and social responsibility policies are being adhered to and achieved. |
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Report on the measures taken to develop and enhance the highest governance body’s collective knowledge of economic, environmental, and social topics, e.g., board training |
The Environment, Social and Governance Committee of the Board of Directors makes periodic visits to corporate locations to familiarize itself with the nature of the operations, and to review relevant objectives, procedures and performance with respect to health and safety, environment and social responsibility. The Committee members receive a quarterly report from management on ESG issues and concerns within the Company and participate in training to enhance their knowledge of the issues. |
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Report the actions taken in response to evaluation of the highest governance body’s performance with respect to governance of economic, environmental, and social topics, including, as a minimum, changes in membership and organizational practice, (response to external evaluations) |
In 2021, the Governance Committee was renamed the Environment, Social & Governance Committee and expanded its Charter to include oversight of ESG topics. The ESG committee now meets quarterly to receive a report from the VP Corporate Affairs and provide oversight of ESG concerns within the Company. |
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Report the highest governance body’s role in identifying and managing economic, environmental, and social topics and their impacts, risks, and opportunities – including its role in the implementation of due diligence processes, (committee roles) |
The Environmental, Social and Governance Committee is responsible for reviewing the effectiveness of Managements’ health and safety, environment and social responsibility programs and make recommendations for improvement to adequately manage potential health and safety, environmental and social responsibility liabilities.
The Committee reviews any extraordinary incidents and where appropriate report to the Board of Directors. |
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Is stakeholder consultation used to support the highest governance body’s identification and management of economic, environmental, and social topics and their impacts, risks, and opportunities, and if delegated, explain how |
Yes |
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Troilus' CEO engages directly with the governing bodies of the First Nations. The VP of Corporate Affairs and VP of Environment engage with stakeholders directly on community consultations, environmental permitting, and local procurement.
The results of these consultation are reported by the VP Corporate Affairs to the Governance & ESG Committee on a quarterly basis. |
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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 |
Troilus' Anti-Bribery Policy is applicable to all directors, officers, employees and outside parties acting directly or indirectly on behalf of the company and are prohibited from engaging in bribery or any corrupt activity in relation to government officials or private parties, or enabling or facilitating such activity.
Responsibility for implementing and overseeing the Anti-Bribery and Anti-Corruption Policy and related standards and procedures has been given to the Chief Financial Officer and the Company’s Site Manager in Quebec. The Chief Financial Officer communicates with the Site Manager for payments in Quebec and then the Chief Financial Officer has direct reporting obligations to the audit committee of the board of directors. The Chief Financial Officer has an adequate level of autonomy as well as sufficient resources and authority to maintain this autonomy. |
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Anti-Bribery and Anti-Corruption 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 have received training on anti-corruption, broken down by region |
7 |
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ii.) Total percentage of governance body members that have received training on anti-corruption, broken down by region |
100.0000% |
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Total number and percentage of employees that have received training on anti-corruption, broken down by employee category and region |
31 |
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1a. Total number of employees that received training on anti-corruption |
31 |
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Total number of employees |
31 |
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1b. Total percentage of employees that received training on anti-corruption |
100.0000% |
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2a. Total number of senior employees that received training on anti-corruption |
9 |
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Total number of senior employees |
9 |
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2b. Percentage of senior employees that received training on anti-corruption |
100.0000% |
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3a. Total number of middle management employees have received training on anti-corruption |
3 |
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Total number of middle management employees |
3 |
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3b. Percentage of middle management employees have received training on anti-corruption |
100.0000% |
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4a. Total number of technical employees that received training on anti-corruption |
14 |
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Total number of technical employees |
14 |
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4b. Percentage of technical employees that received training on anti-corruption |
100.0000% |
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5a. Total number of production employees that received training on anti-corruption |
0 |
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Total number of production employees |
0 |
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5b. Percentage of production employees that received training on anti-corruption |
Does Not Apply |
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6a. Total number of administrative employees that received training on anti-corruption |
5 |
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Total number of administrative employees |
5 |
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6b. Percentage of administrative employees that received training on anti-corruption |
100.0000% |
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Tax |
|
|
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 |
Troilus retains third-party experts to advise on tax-related issues and ensure full compliance with tax obligations. |
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ii. The approach to public policy advocacy on tax |
Troilus does not directly engage in public policy advocacy on taxes. As members of mining industry groups we may support industry positions on public tax policies. |
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iii. The processes for collecting and considering the views and concerns of stakeholders, including external stakeholders |
Troilus engages with stakeholders on a regular basis, and addresses stakeholder concerns when raised, which may include concerns related to royalty payments, and government fiscal frameworks. |
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This document was prepared using |
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, Planet Earth's complete ESG reporting solution. |
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