WE PUBLICALLY STATE ON OUR WEBSITE THAT:

A large part of our overall assessment revolves around risk management and a deep understanding of the importance of having a social licence to operate. To that end, Dundee Goodman Merchant Partners integrates all of the social issues (which have been defined by the industry as Environmental, Social and Governance issues), into our overall investment analysis and risk management strategy as part of our due diligence process. The management of ESG issues is critical when seeking the improvement of long-term returns. 
 Immediately following investment, portfolio companies are engaged and consistently monitored throughout the investment process. There is a strict expectation for responsible mining and ESG practices to be implemented into their business systems. 
 The United Nations-supported Principles for Responsible Investment (PRI) Initiative is an international network of investors working together to put the six Principles for Responsible Investment into practice. Its goal is to understand the implications of sustainability for investors and support signatories to incorporate these issues into their investment decision-making and ownership practices. Dundee Goodman Merchant Partners has examined these principles and is now a signatory.

IN ADDITION TO OUR WEBSITE COMMITTMENT WE HAVE DRAFT POLICY PREPARED AS OUTLINE BELOW

KEY ELEMENTS

• Our RI policy is integral with our overall investment policy framework
• Executing on our policy requires qualitative and quantitative input from across our investment team at all stages
• Investment decision making will be responsive to detailed ESG risk assessment
• Our expertise is in actively de-risking and managing as a way of realizing value in undervalued businesses. We will identify all ESG risks and develop remediation strategy to mitigate risk in investee businesses
• Where appropriate we will require investee businesses to be working toward substantial compliance with one or more globally recognized performance standards
• We will require governance level intervention and oversight of critical risk management areas
• We will seek formal reporting on risk management progress

SPECIFICS

• We will invest in business, or actively intervene and direct outcomes, that recognize the importance of sustainable practices

• Areas of specific interest include Multi-stakeholder engagement

• Community engagement and dialogue

• Social responsibility and fairness

• Community and local "return" and sustainability

• Environmental sustainability and stewardship

• Employee and community health and safety

• Cultural awareness and gender and racial equal opportunity

• Human rights

• We expect our investee companies to adopt a full life cycle approach to planning and management (i.e. development to post closure)

• We expect our investee companies to consider product stewardship and supply chain compliance

• We expect our investee businesses to adopt documented governance systems related to oversight of the project management function to ensure that project "stage gates" are passed properly and with full and accurate disclosure

• To ensure a "no surprises" philosophy prevails especially as it relates to schedule, costs, and stakeholder feedback and Social License risk

• To ensure that development proceeds in alignment with ESG requirements and permitting processes

QUANTIFICATION & STANDARDS

• Compliance at operating companies with mandatory and voluntary standards and codes is a key element in mitigating and managing ESG risk
• Minimum requirement is full compliance with local law, regulation, and direction by agencies and competent/legal authorities
• Permit conditions
• Relevant international, Canadian and US law (for example related to transparency and corruption)
• We will require, as appropriate for the jurisdiction and circumstances, substantial compliance (or an agreed compliance timetable) by investee business with one or more internationally recognized standards or conduct codes such as the IFC performance standards
• ICMM codes and standards
• UN Global Compact
• PMI standards for governance of project management
• We will require a best practice approach to the generally accepted definitions of social license, corporate citizenship, social responsibility, human rights, environmental stewardship and sustainability
• We expect best practice governance systems and controls, corporate transparency, and properly organized hierarchical systems allowing controls to cascade into the management of the business or operation

SCREENING OUTCOMES & RISK MANAGEMENT

• We will carry out initial screening assessment for all investment opportunity under consideration with a pass/proceed outcome
• Negative ESG screening outcomes occur when Sovereign risk to a key operating location is high and cannot be mitigated
• Social license has been ignored or lost and ongoing risk cannot be mitigated quickly enough to recover value
• There is no EITI coverage in a key jurisdiction and a transparency risk exists
• Extreme environmental risk, legacy risk, or closure risk will likely negatively affect value over medium and long term
• Poor governance and lack of transparency does not allow for adequate diligence processes
• Positive ESG screening outcomes occur when there are no significant ESG risks discovered during diligence
• And our modelling shows that there is unrecognized value
• Positive ESG screening outcomes but where issues are flagged for risk assessment and mitigation planning is where DGMP can create value
• The DGMP business paradigm/value proposition is that we are a team of professionals with operating and governance experience across the full range of sector risks and disciplines
• We can quantify ESG risk in this sector and develop mitigation strategies and programs
• This allows us to see and realize value that other investors don't see or cannot leverage