Important Context and Background

PMAC’s members are fiduciaries entrusted to manage their clients’ assets in the clients’ best interests. As asset managers, our members are supportive of processes that increase transparency and that provide readily comparable information to assist them in meeting their clients’ investment objectives.

We welcome modernizing NI 43-101 with measures that introduce more responsive, comparable, and consistent mineral project disclosure, as well as the work started by the Consultation to incorporate environmental, social, governance disclosure and disclosure around due diligence taken to respect Indigenous Peoples’ Rights.

Key Recommendations

1. Prioritize enhanced environmental, social and Indigenous Peoples’ Rights (ESG-I) due diligence disclosure by striking an ESG-I working group that is centered on Indigenous perspectives.
2. Any ESG-I disclosure should be a stand-alone document from Form 43-101F1 (Technical Report) and should be designed with a view to adapting this disclosure for other reporting issuers in the future.
3. Update the ESG-I disclosure document as needed to reflect current standards and best practices.
4. Leverage existing disclosure frameworks in the EU and the CSA’s work to date on Proposed National Instrument 51-107 – Disclosure of Climate-Related Matters (Proposed NI 51-107).
5. Improve the approach to disclosure in NI 43-101 and the Technical Report.

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