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Sustainability

Reporting

2021 Sustainability Report2022 Sustainability Reporting Data Sheet

NOVAGOLD is a precious metals company and focused on the advancement of its Donlin Gold project in Alaska, owned in equal partnership with Barrick Gold Corporation. The project is federally permitted and is at the development stage.

Donlin Gold LLC is a committed partner with the Alaska Native Corporations who own the mineral and surface rights on which the project is located, as well as the Native communities surrounding the project site and throughout the state. An important factor that distinguishes the Donlin Gold project from most other mining assets in Alaska is that the project is located on Alaska Native-owned, private land that was designated for mining activities over fifty years ago. The commitments that we have made to our Alaska Native Corporation partners to protect the lands and peoples of the Y-K region are at the heart of all our sustainability planning, implementation, performance assessment, and reporting efforts. In 2022, we continued our long-standing record of mitigating impacts to the environment, ensuring the health and safety of our employees, and investing in the communities and people of the places we work.

2022 Sustainability Reporting Data Sheet

2021 Sustainability Report2021 Sustainability Reporting Data Sheet

NOVAGOLD is focused on precious metals and the development of its Donlin Gold project in Alaska, owned in equal partnership with the second-largest global gold producer: Barrick Gold Corporation. The project is at the development level and permitting stage. No construction decision has been made. Donlin Gold LLC is a committed partner with the Alaska Native communities both surrounding the project and within the state as a whole. An important factor that distinguishes the Donlin Gold project from most other mining assets in Alaska is that the project is located on private land that was designated for mining activities five decades ago.

2020 Sustainability Reporting Data Sheet

2020 Sustainability Report2020 Sustainability Reporting Data Sheet

NOVAGOLD believes it is appropriate to increase transparency, accountability, and enhance the suite of ESG metrics the company discloses to stakeholders. We’re committed to providing stage-appropriate and relevant information, to all stakeholders, about ESG performance in alignment with the Donlin Gold project partner Barrick Gold Corporation. NOVAGOLD is working with Barrick to implement international best practice and industry standards at the Donlin Gold project and plans to expand disclosure as the project eventually moves toward construction and into operation. We are strong proponents of ongoing engagement and consultation with stakeholders through the entire development process.

2020 Sustainability Reporting Data Sheet

 

NOVAGOLD's Taskforce on Climate Related Disclosures (TCFD) Report

CDP Reports

Climate Change Response
Water Security Response
Climate Change Response
Water Security Response

 

All reporting data listed below is based on NOVAGOLD’s 2022 fiscal year.

2022 ENVIRONMENTAL PERFORMANCE

The results below are reported separately for Donlin Gold LLC and NOVAGOLD. Additional details on environmental practices can be found on the Donlin Gold LLC website: www.donlingold.com.

Production Statistics
  Donlin Gold LLC NOVAGOLD
Item Value Comments Value Comments
Ounces of Gold Produced (Poured Ounces) 0 Not applicable - All of these are not applicable because the Donlin Gold project is not yet in operation. 0 Not applicable - NOVAGOLD has no operating projects.
Ore mined - Open Pit 0 Not Applicable 0 Not Applicable
Waste Rock Mined - Open Pit 0 Not Applicable 0 Not Applicable
Total Ore Processed 0 Not Applicable 0 Not Applicable
Cyanide Used 0 Not Applicable 0 Not Applicable
Waste Rock Backfilled - Surface 0 Not Applicable 0 Not Applicable
Tailings Produced 0 Not Applicable 0 Not Applicable
Waste That is Geochemically Reactive 0 Not Applicable 0 Not Applicable
Environmental Incidents
  Donlin Gold LLC NOVAGOLD
Item Value Comments Value Comments
Class I - High 0 Immediately reportable to government agencies or impacts beyond site boundary or to surface or ground water, or wildlife mortality of a protected species. 0 Immediately reportable to government agencies or impacts beyond site boundary or to surface or ground water, or wildlife mortality of a protected species.
Class II  - Medium 0 Reportable within 48 hours to government agencies, within site boundary, no impacts to surface or ground water; or multiple wildlife mortalities of non-protected species. 0 Reportable within 48 hours to government agencies, within site boundary, no impacts to surface or ground water; or multiple wildlife mortalities of non-protected species.
Class III - Low 4 Reportable monthly, but not immediately, to government agencies, minimal impact within site boundary, and no more than one wildlife mortality. 0 Reportable monthly, but not immediately, to government agencies, minimal impact within site boundary, and no more than one wildlife mortality.
How Many Environmental Incidents were Reported to the Authority? 4   0  
Non-Compliances
  Donlin Gold LLC NOVAGOLD
Item Value Comments Value Comments
Air 0   0  
Water 0   0  
Waste 0   0  
Land 0   0  
Wildlife 0   0  
Other 0   0  
Environmental Related Fines
  Donlin Gold LLC NOVAGOLD
Item Value Comments Value Comments
Number of Fines Levied 0   0  
Value of Environmental- Related Fines 0   0  
Spills
  Donlin Gold LLC NOVAGOLD
Item Value Comments Value Comments
Number of Spills 4 None immediately reportable to agencies, none to water, all less than 10 gallons to land. 0  
Volume of Oil Spills - Liters 5.7 None immediately reportable to agencies, none to water, all less than 10 gallons to land. 0  
Volume of Fuel Spills - Liters 11.4 None immediately reportable to agencies, none to water, all less than 10 gallons to land. 0  
Volume of Waste Spills - Liters 0   0  
Volume of Chemical Spills - Liters 9.5 None to water, all less than 10 gallons to land. 0  
Volume of Other Spills - Liters 0   0  
Closure and Rehabilitation
  Donlin Gold LLC NOVAGOLD
Item Value Comments Value Comments
Total Land Disturbed and Not Yet Rehabilitated at Start of Reporting Period - Hectares 8.7 All land disturbance is associated with limited exploration level activities, no on-site mine waste or water management facilities. 0  
Total Amount of Land Newly Disturbed within Reporting Period - Hectares 15.7 All land disturbance is associated with limited exploration level activities, no on-site mine waste or water management facilities. 0  
Total Amount of Land Newly Rehabilitated within Reporting Period - Hectares 8.2 All land disturbance is associated with limited exploration level activities, no on-site mine waste or water management facilities. 0  
Total Rehab Planned for the Year (Hectares) 8.2 All land disturbance is associated with limited exploration level activities, no on-site mine waste or water management facilities. 0  
Waste
  Donlin Gold LLC NOVAGOLD
Item Value Comments Value Comments
Hazardous Waste Produced - Tonnes 0.23   0  
Non-Hazardous Waste Produced - Tonnes 576   0  
Hazardous Waste Recycled - Tonnes 0   0  
Non-Hazardous Waste Recycled - Tonnes 0.74   0  
Total Reused - Tonnes 0.74   0  
Total Waste to Landfill - Tonnes 559   0  
Total Waste Incinerated - Tonnes 64   0  
Mercury Produced as a By-Product / Co-Product - Tonnes 0 No production or processing at Donlin Gold 0  
Emissions
  Donlin Gold LLC NOVAGOLD
Item Value Comments Value Comments
NOx - Stationary Sources - Tonnes 0 De minimis, small camp with no production at the Donlin Gold project 0  
Number of Regulatory Exceedances 0 De minimis, small camp with no production at the Donlin Gold project 0  
SOx - Stationary Sources - Tonnes 0 De minimis, small camp with no production at the Donlin Gold project 0  
Number of Regulatory Exceedances 0 De minimis, small camp with no production at the Donlin Gold project 0  
Particulate Matter - PM 10 - μg/m3 0 De minimis, small camp with no production at the Donlin Gold project 0  
Mercury Air Emissions - Tonnes 0 No production or processing at Donlin Gold 0  
Number of Regulatory Exceedances 0   0  
Other Air Emissions as Regulated (Tonnes) 0   0  
Water Use
  Donlin Gold LLC NOVAGOLD
Item Value Comments Value Comments
Surface Water - Cubic Meters 0   379 Includes Salt Lake City and Vancouver offices
Groundwater - Cubic Meters 2,080 All returned to ground after treatment 0  
Total Withdrawals - Cubic Meters 2,080 All returned to ground after treatment 379  
Biodiversity
Biodiversity policy Biodiversity policy pdf
Climate Change
Climate Change Policy Climate Change policy pdf
Energy Inputs / GHG Emissions
  Donlin Gold LLC NOVAGOLD
Item Value Comments Value Comments
Electricity - from Outside Sources - KwH 0 All on-site power generation 54,270 All NOVAGOLD power from outside sources
Electricity - Self-Generated - KwH 1,198,433   0  
Diesel Used for Power Generation - Liters 227,161   0  
HFO Used for Power Generation - Liters 0   0  
Electricity Produced by Renewable Sources - KwH 0   0  
Natural Gas - MMBTU 0   0  
Diesel Used (Less Consumption for Power Generation) - Liters 719,159   0  
Propane Used - Liters 3,305   0  
Petrol / Gasoline Used - Liters 24,594   0  
Aviation Fuel Used 170,990   0  
Total Scope 1 GHG Emissions - Tonnes of CO2 2,633   0  
Scope 1 GHG Emissions from Diesel - Stationary 610   0  
Scope 1 GHG Emissions from Diesel - Mobile 1928   0  
Total Scope 2 GHG Emissions 0   34  

2022 SOCIAL PERFORMANCE

The results below are reported separately for Donlin Gold LLC and NOVAGOLD, where applicable. Donlin Gold LLC information is reported on a 100 percent basis. For additional details on NOVAGOLD’s community and social development practices, please refer to NOVAGOLD’s most recent Form 10-K, Form 10-Q, and management information circular dated March 24, 2023, available at www.sec.gov,www.SEDAR.com or on NOVAGOLD’s website here. Additional details on social practices can also be found on the Donlin Gold LLC website: www.donlingold.com.

Employment
Item Donlin Gold NOVAGOLD Comments
Total OR
Low (if applicable) High (if applicable)
Male Employees 31 90 7 High ranges of Donlin Gold LLC employees in all rows reflect the seasonal nature of work at the project site.
Female Employees 13 24 6 In 2021, women comprised 46 percent (six of 13) of NOVAGOLD’s employees.
Male Contractors 2 2 0  
Female Contractors 0 0 0  
Local Employees 34 94 Not applicable “Local” is defined as Alaska
Regional Employees 17 53 Not applicable “Regional” is defined as Yukon-Kuskokwim region
Shareholder Employees 16 72 Not applicable “Shareholder” refers to having a relationship with Calista or TKC*
National Employees 45 112 13 “National” for Donlin Gold LLC refers to the USA; For NOVAGOLD, to USA and Canada
Foreign National Employees 0 0 0  
Local Senior Managers 5 6 Not applicable  
Regional Senior Managers 0 0 Not applicable  
National Senior Managers 7 8 Not applicable  
Foreign National Senior Managers 0 0 Not applicable All employees / contractors are U.S. or Canadian citizens
Number of Non-Management Employees who are Female 10 22 5 “Non-Management” for NOVAGOLD means non-executive
Number of Management-Level Employees who are Female 2 3 1 “Management” for NOVAGOLD means executive
Local Contractors 2 2    
Regional Contractors 0 0 Not tracked  
National Contractors 0 0 Not tracked  
Foreign National Contractors 0 0 Not applicable All employees / contractors are U.S. or Canadian citizens
Number of Suppliers with Clauses in Contracts Related to Local Employment 0 0 Not applicable  
* Calista Corporation (Calista), which owns the mineral resources at the Donlin Gold project, and the The Kuskokwim Corporation (TKC), which owns much of the surface land, are the Alaska Native Corporations that are our partners on the Donlin Gold project.
Turn Over
Item Donlin Gold NOVAGOLD Comments
Total OR
Low (if applicable) High (if applicable)
Total Number of Employees Who Left the Organization Voluntarily 22   2 Donlin Gold field season ended, Camp closure
Total Number of Employees Who Left the Organization Due to Dismissal 6   0  
Total Number of New Employee Hires 71   1  
Percentage of Open Positions Filled by Internal Candidates 0   0  
Labor Unions
Item Donlin Gold NOVAGOLD Comments
Total OR
Low (if applicable) High (if applicable)
Number of Employees Covered by Collective Bargaining Agreements 0   0 There are no unionized employees at either NOVAGOLD or Donlin Gold LLC.
Days Lost to Strike Action 0   0  
Training
Item Donlin Gold NOVAGOLD Comments
Total OR
Low (if applicable) High (if applicable)
Total Hours of Training for Employees 1,082        
Hours of Environmental Training for Employees and Contractors 314        
Hours of Health, Safety, and Emergency Response Training for Employees 95        
Hours of Health, Safety, and Emergency Response Training for Contractors 88        
Local Employment Plan
Item Donlin Gold NOVAGOLD Comments
Total OR
Low (if applicable) High (if applicable)
Is a Local Employment Plan In Place? Yes   Not applicable For Donlin Gold LLC, this relates to local Land Agreement/Shareholder hire agreements with Calista and TKC
Health and Safety
Item Donlin Gold NOVAGOLD Comments
Total OR
Low (if applicable) High (if applicable)
Near Misses 7   0  
First Aid / Minor Injury 5   0  
Medical - Days of Restriction 10   0  
Hours Worked - Employees and Contractors 274,968   0  
LTIFR 0   0 Lost Time Incident Frequency Rate is defined using the calculation of number of lost-time injuries per one million employee hours worked.
TRIFR 1.42   0 Total Recordable Incident Frequency Rate is defined as an incidence rate of lost-time injuries, fatalities, and medical incidents and is computed using the formula: (number of injuries and illnesses X 200,000) / employee hours worked = medical incidence rate. Note: ‘200,000’ represents the number of hours 100 employees work based on 40 hours per week, 50 weeks per year, and provides the standard base for calculating the incidence rate for an entire year.
Human Rights
Item Donlin Gold NOVAGOLD  
Total OR
Low (if applicable) High (if applicable)
Number of Employees Trained on Human Rights 75   13    
Number of Human Rights Grievances Escalated to Legal 0   0    
Business Ethics
Item Donlin Gold NOVAGOLD Comments
Total OR
Low (if applicable) High (if applicable)
Number of Reportable Code of Conduct Breaches Reported in the Fiscal Year 0   0  
Number of How Many Hours of Training on Anti-Corruption Received in the Fiscal Year 75   Not tracked  
Purchases
Item Donlin Gold NOVAGOLD Comments
Total OR
Low (if applicable) High (if applicable)
Purchases from Regional Suppliers - $USD $       2,099,139   Not tracked Goods / Services from Y-K region
Purchases from Local Suppliers - $USD $    13,058,945   Not tracked Regional and Local (Alaska)
Purchases from National Suppliers - $USD $  9,538,019   Not tracked Regional, Local, and National (US)
Purchases from  International Suppliers - $USD $    17,526,163   Not tracked International only
Suppliers
Item Donlin Gold NOVAGOLD Comments
Total OR
Low (if applicable) High (if applicable)
Number of Regional Suppliers 540   Not tracked “Regional” is defined as Yukon-Kuskokwim region
Number of Local Suppliers 838   Not tracked “Local” is defined as Alaska
Number of National Suppliers 488   Not tracked Regional, Local, and National (US)
Number of International Suppliers 187   Not tracked International only
Local Procurement Plan in Place 0   Not applicable  
Grievances Received
Item Donlin Gold NOVAGOLD Comments
Total OR
Low (if applicable) High (if applicable)
Human Rights (Automatically Escalated) 0   0  
Unmet Obligation 0   0  
Resettlement / Relocation 0   0  
Land Compensation 0   0  
Land Encroachment 0   0  
Land Access 0   0  
Property Damage 0   0  
Road Quality 0   0  
Driving / Speeding 0   0  
Security Behavior 0   0  
Employee Behavior 0   0  
Contractor Behavior 0   0  
Contractor Payment Problems 0   0  
Local Procurement / Contracting 0   0  
Local Employment 0   0  
Spills 0   0  
Water 0   0  
Dust 0   0  
Emissions 0   0  
Noise / Light 0   0  
Vibrations 0   0  
Other 0   0  
Grievances Resolutions
Item Donlin Gold NOVAGOLD Comments
Total OR
Low (if applicable) High (if applicable)
Total Number of Grievances Remaining From the Previous Period 0   0  
Total Number of Grievances Received 0   0  
Community Engagement
Item Donlin Gold NOVAGOLD Comments
Total OR
Low (if applicable) High (if applicable)
Number of Engagements with Local Community Members 6,370   Not applicable For Donlin Gold LLC, this is tracked across more than 56 communities in the Yukon-Kuskokwim region.
Community Investment - Donlin Gold project only
Item Donlin Gold NOVAGOLD Comments
Total OR
Low (if applicable) High (if applicable)
Health - $USD $  464,150   Not applicable All NOVAGOLD investments are made through Donlin Gold LLC under the 50/50 partnership with Barrick. Therefore, NOVAGOLD provides 50 percent of the funds for the Donlin Gold LLC investments.
Education - $USD $  299,650   Not applicable  
Arts, Culture & Sports - $USD $  710,000   Not applicable  
Environment - $USD $  51,799   Not applicable  
Economic Development - $USD $    33,176   Not applicable  
Infrastructure - $USD $    30,000   Not applicable  
Water Infrastructure - $USD $              0   Not applicable  
Community Engagement - $USD $    0   Not applicable  
Other - $USD $      0   Not applicable  
Scholarships Provided - Quantity $  75,000   $5,000  
Compensation Payments - $USD $              0   Not applicable  

2022 CORPORATE GOVERNANCE PERFORMANCE

For additional details on NOVAGOLD’s corporate governance practices, please see the most recent management information circular dated March 24, 2023 and posted to www.sec.gov, www.SEDAR.com or the NOVAGOLD website here.

General
Governance Item Value Additional Comments
Location of Corporate Office Vancouver, B.C., Canada; Salt Lake City, UT, USA  
Description of Services / Products Gold mine developer  
Location of Projects Alaska  
Status of Operations Development stage  
Ownership Publicly traded corporation under the laws of British Columbia, Canada, and trading on the NYSE American and TSX stock exchanges under the symbol NG.  
Does the Company have an Enterprise Level Environmental Policy? Yes. Applicable policy: https://www.novagold.com/_resources/governance/Environmental_Policy.pdf  
Global Compact Signatory No  
Memberships in Associations Alaska Miners Association, Council of Alaska Producers, National Mining Association, Resource Development Council (Alaska), and American Exploration and Mining Association (national)  
Statement from Senior Decision Maker Annual messages from Chairman and CEO are contained in the company’s annual report available on the website at https://www.novagold.com/investors/financials/  
Values, Principles, Standards, and Norms of Behavior See https://www.novagold.com/_resources/governance/Code-of-Business-Conduct-and-Ethics-2014-01-10.pdf and Code of Business Conduct  
Does the Company have a Publicly Disclosed Code of Conduct? Yes. Applicable policy: Code-of-Business-Conduct-and-Ethics-2014-01-10.pdf (novagold.com)  
Mechanisms for Advice and Concerns about Ethics Yes. Applicable policy: Code-of-Business-Conduct-and-Ethics-2014-01-10.pdf (novagold.com)  
Whistleblower Policy or Programs, Including Confidential Hotline and Stated Protection of Whistleblowers Yes. Applicable policy: Code-of-Business-Conduct-and-Ethics-2014-01-10.pdf (novagold.com)  
Process for Delegating Authority for Economic, Environmental, and Social Topics from the Highest Governance Body to Senior Executives and Other Employees Yes. Applicable policy: See pages 95-111 of Management Proxy Circular dated March 24, 2023  
Board Member or Board Committee Responsible for ESG Issues Applicable resources: https://www.novagold.com/_resources/governance/Corporate-Governance-and-Nominations-Charter-updated-Jan-27-2021.pdf and https://www.novagold.com/_resources/governance/EHSS-Technical-Committee-Charter-2016-11-18.pdf and Sustainability Committee Charter https://www.novagold.com/_resources/governance/Sustainability-Committee-Charter-20221205.pdf  
Composition of the Highest Governance Body and its Committees The Board of Directors is the highest governing body, consisting of 11 Directors, eight of whom are independent. There are five standing committees: Audit; Compensation; Engineering and Technical; Corporate Governance and Nominations; and Sustainability. Read more here.  
How many Women / What Proportion of Women are on the Board 3 of 10, or 30%  
How many Directors Serve on the Board 11 seats, 10 current directors and one vacancy  
Board Diversity and Board Independence Yes. See page 95-98 of Management Information Circular dated March 24, 2023 regarding Board independence and pages 102-104 regarding Board diversity  
Diversity Programs See pages 102-106 of Management Information Circular dated March 24, 2023  
Chair of the Highest Governance Body Thomas Kaplan, Chairman of the Board  
The Classification of the Board Chair Non-independent  
Does the Board have an Independent Lead Director? Yes. Anthony Walsh serves as the Board’s independent Lead Director  
Conflicts of Interest See pages 95-101 of Management Information Circular dated March 24, 2023 and the Code of Business Conduct and Ethics: https://www.novagold.com/_resources/governance/Code-of-Business-Conduct-and-Ethics-2014-01-10.pdf  
Role of the Highest Governance Body in Setting Purpose, Values, and Strategy See pages 95-111 of the Management Information Circular dated March 24, 2023  
Collective Knowledge of Highest Governance Body Board of Directors is highest governance body; see biographies of Directors at https://www.novagold.com/company/directors/ and additional Director background in the Management Information Circular dated March 24, 2023  
Evaluation of the Highest Governance Body’s Performance See pages 110 of the Management Information Circular dated March 24, 2023  
Remuneration Policies See Management Information Circular dated March 24, 2023  
Responsibility for Board and Executive Compensation See pages 45-92 of Management Information Circular dated March 24, 2023 and the Compensation Committee Charter and the Board Charter. https://www.novagold.com/company/governance/    
Process for Determining Remuneration See See Compensation Discussion and Analysis and Non-Executive Director Compensation on pages 45-92 in the Management Information Circular dated March 24, 2023  
Has the Company Adopted an Advisory Executive Compensation “Say on Pay” vote? Yes, vote held annually In 2022 shareholders cast 95.3% votes in favor of “Say on Pay”
Approach to Shareholder Engagement Maintaining an active shareholder engagement program is a high priority for the Company and is an integral part of our corporate governance practices. The Board Chair, CEO, and Vice President of Corporate Communications meet regularly with large shareholders, and the Company’s Corporate Communications team is very responsive to shareholder inquiries regardless of ownership level. In 2022, NOVAGOLD placed calls to or met in person with all of its shareholders owning 40,000 shares or more; in other words, NOVAGOLD contracted or attempted to contact its owners holding approximately 86% of the Company’s issued and outstanding Common Shares entitled to vote at NOVAGOLD’s 2022 annual meeting of shareholders. We plan to continue to regularly engage with our shareholders.  
Date of Most Recent Annual Financial Report Annual Report on Form 10-K filed January 25, 2023  
Financial Reporting Cycle 2022 annual financial results reported January 25, 2023. Q1 2023 financial report on Form 10-Q filed April 4, 2023; additional Form 10-Q filings planned in June 2023 and October 2023.  
Sustainability Reporting Cycle Sustainability Report issued annually  
Contact Point for Questions Regarding ESG Disclosure Vice President, Corporate Communications or Manager, Investor Relations: info@novagold.com or Telephone: 604-669-6227; Toll-free: 1-866-669-6227  
Human Rights
Governance Item Value Additional Comments
Human Rights Policy and Scope See https://www.novagold.com/_resources/governance/Human-Rights-Policy.pdf  
Does the Company’s Human Rights or Other Formal Policy Cover Community Consultations and Indigenous Rights? Yes  
Number of Grievances about Human Rights Filed, Addressed, and Resolved through Formal Grievance Mechanisms 0  
Incidents of Discrimination and Corrective Actions Taken 0  
Anti-Discrimination Policy See page 100-106 in the Management Information Circular dated March 24, 2023  
Operations and Suppliers at Significant Risk for Incidents of Child Labor No. All operations and suppliers are located in and operated under U.S. or Canadian regulations and labor standards  
Does the Company’s Code of Vendor Conduct Address Child Labor? No. We do not have a Code of Vendor Conduct; see Human Rights Policy  
Operations and Suppliers at Significant Risk for Incidents of Forced or Compulsory Labor No. All operations and suppliers are located in and operated under U.S. or Canadian regulations and labor standards  
Does the Company’s Code of Vendor Conduct Address Forced Labor? No. We do not have a Code of Vendor Conduct; see Human Rights Policy  
Incidents of Violations Involving Rights of Indigenous Peoples 0  
Operations that have Been Subject to Human Rights Reviews or Impact Assessments 0 At Donlin Gold LLC, 85 employees have been trained in human rights. No grievances at either NOVAGOLD or Donlin Gold LLC were escalated to legal in 2022.
Employee Training on Human Rights Policies and Procedures All NOVAGOLD employees affirm their commitment to the Code of Business Conduct and Ethics annually  
Anti-Bribery & Anti-Corruption
Governance Item Value Additional Comments
Anti-Bribery & Anti-Corruption Policy https://www.novagold.com/_resources/governance/Anti-Corruption-Anti-Bribery-Anti-Fraud-Policy-2020-03-05.pdf  
Highest Level of Executive Oversight for the Company’s Anti-Bribery or Anti-Corruption Program Company Ethics Officer (Vice President & CFO)  
Number of Grievances about Anti-Corruption and Anti-Bribery, Addressed and Resolved Through Formal Grievance Mechanisms 0  
Operations Assessed for Risks Related to Corruption Not Applicable  
Does the Company Provide Anti-Corruption Training to all Employees, Including Management? All NOVAGOLD employees affirm their commitment to the Code of Business Conduct and Ethics annually  
Confirmed Incidents of Corruption and Actions Taken 0  
Payments to Governments https://novagold.com/_resources/financials/NG_ESTMA-Report-FY-2022.pdf (novagold.com)  


“Not Tracked” indicates that the measurement may be deemed Applicable but may be measured and reported in future.
“Not Applicable” indicates that the measurement may only be applied at the project or corporate level.

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