Permitting and Compliance

To date, the Company has arranged access to the Property for the purpose of exploration through agreements with both private and Crown entities. Much of the Property, including all the BR, EG historical workings, is underlain by Crown Land. Similarly, access to private lands, and securing agreements with landowners has been generally manageable. At the effective date of this Technical Report, the Company held access agreements that specifically apply to surface core drilling. The Company has the necessary Crown Land permits for additional drilling and trenching or expects to receive them through normal exploration permitting process.

The Project will require the acquisition of some privately owned property. The Company has engaged a third-party to complete the relevant property assessments, negotiate property acquisitions, and manage and document the process. Should some individuals refuse to sell through this process, the Company would then pursue the expropriation process to acquire the property which could cause delays, however, would unlikely cause any delays in the overall permitting process.

The Company continues to successfully manage the Industrial Approval (IA) related to the underground Bulk Sample collected in 2018.

The presence of past mining operation infrastructure, including several historical tailings sites associated with the past operation of the historical Boston Richardson Mine within the Gold Brook Lake-Seal Harbour Lake watershed, are recognized as important environmental site factors. Provincial regulators indemnified Orex in 1995 from any environmental liabilities resulting from historical mining activities, assuming that old tailings storage areas are not impacted during exploration or mining activities. A historic tailings management plan will be developed in consultation with Nova Scotia Environment and Climate Change (NSECC) to manage the areas that will be directly disturbed by the Project.

The Company plans to submit an Environmental Assessment Registration Document (EARD) to Nova Scotia Environment (NSE) for a Class 1 Environmental Assessment in Q2 2022. As such, baseline studies and related modelling efforts are ongoing. Critical provincial authorizations are required to proceed with mine development, operation, and reclamation, including an IA. Applications to federal authorities are also required, including a Fisheries Act Authorization through Fisheries and Oceans Canada (DFO) for alteration and destruction of fish habitat and a Schedule 2 addition for tailings placement. Applications for these approvals or permits have not been made at the effective date of this Technical Report, but will be submitted at various points throughout 2022/23.


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